"License-Free" Gauges -Reply

[Tom Hill <Tom_Hill@mail.dnr.state.ga.us>]

Some Agreement States have objections to
the distribution of gauges that use sources
which are exempt from licensing.  I
understand that at least one, if not more
Agreement States have already initiated
Rule revisions to limit the number of exempt
sources that may be possessed without a
specific license.  Also, I am not aware of
these gauges having a regulatory agency
evaluation for purposes of radiaton safety.

I understand that BSI distributes the gauges
without the radioactive sources being
installed.  They instruct their customer to
purchase the exempt Cs-137 sources and
install them in the source holder and install
the source holder in the gauge.  

I understand, although I have not verified
USDOT requirements, that not more than
10 exempt quatity sources can be shipped
in one shipment.  If that is indeed the case
three or more shipments are required to
receive the number of sources needed to
make the gauge operational.

THill

>>> "Joe Greco" <jgreco@kodak.com>
03/16/98 04:58pm >>>
For all those who may use industrial density
or level gauges:  be aware
that BSI, Aliquippa, PA is currently
distributing gauges containing Cs-137
to recipients "free of licensing
requirements".  No specific license
required. 
Not distributed under a general license. 
How?  By using "exempt
quantities" of Cs-137.  Those familiar with
exempt quantities may remember	
that the value for Cs-137 is 10 microcuries,
which doesn't do a whole lot
by itself
in gauging applications.  So BSI uses
multiple exempt quantities, up to
30 individual ten uCi sources, in one gauge,
along with a NaI detector.
They note that the NRC and all agreement
states are aware of this, and
have no objections.

Questions:
1.  Is anyone aware of similar situations that
take full advantage of the
so-called
exempt quantity table?  Wasn't the intent of
this table to allow persons to
possess small quantities of materials
without the hassle of licensing?

2.  Are you as surprised as I that, with all
the recent incidents of 
RAM-contaminated metals in scrapyards,
this received federal/state approval
(rather, that it follows 10CFR 30.18 and
32.19)?

Note that BSI states that they will confirm
user possession annually, take
disposal 
responsibility, and provide reports to
customers/states if/as required.

Joe Greco
jgreco@kodak.com