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Re: Static eliminator in copy machines


	My reading of 10 CFR 30.71 (Schedule B) indicates that the "exempt"
quantity for Po-210 is 0.1 microcuries.  What this figure means is that if
you as a member of the public wished to possess an amount of Po-210 ABOVE
this amount, you would have to first apply for and receive an NRC license
which would entail your committing yourself to the applicable radiation
safety requirements of 10 CFR 20, etc.  Thus, the 0.1 microcurie figure is
in effect a "licensing activity threshold" value BELOW which you are
"exempt" from the requirement to have a license and above which you must
have one.

	Title 10 CFR 31.3(a) issues a "general license" for Po-210 incorporated
into certain designated devices.  Specifically, static elimination devices
can be sold to the public that contain per each not more than 500
microcuries of Po-210.  What a "general" license means, to a member of the
public, is that the NRC has approved the manufacturer's design/safeguards
associated with the device that incorporates the radioactive material and
has "approved" the "consumer product" (the device containing the
radioactive material) for distribution to the public.  You, as a member of
the public, then do NOT need a specific NRC license to buy/use/dispose of
the item.  The manufacturer of the device, however, must apply for and
receive a "specific" license from the NRC, or the Agreement State, and be
approved by the NRC to possess the radioactive material and commit to
manufacturing the item according to the representations, commitments,
statements made in their NRC license application, etc.

	In the case of static elimination devices, the manufacturers of such
devices are "specifically" (individually) licensed by the NRC/Agreement
State, but the items, once manufactured, are allowed by the NRC to be
distributed for sale to the public by the manufacturer under "general
license."  To summarize, the NRC "general licenses" set forth in Part 31
have the effect, from the standpoint of a member of the public, of
permitting each of us, as consumers, to buy as many of these products as we
want without having to have a specific license to own and use them.

	My understanding of your message is that Staticmaster static eliminators
are NOT "exempt" items, but rather "generally licensed" items.  The only
thing semantically "exempt" about these items is that, from the standpoint
of a consumer/member of the public, such person is exempt from the
requirement to have a license to own/use them.

	I see now that I have provided you a long-winded explanation to the
situation.  Perhaps some of NRC Radsafers can clarify if I have made any

Best regards David

At 10:01 AM 4/30/98 -0500, you wrote:
>I have some questions regarding the static eliminators (Staticmaster) for
>microgram scales.
>If they are 250 uCi ea. Why are they exempt? (exempt quantity is 100uCi or
>less for 210Po) Don't they require leak testing?( sealed sources containing
>alpha emitting material >10 uCi do).
>Mark Dater
>NeXstar Pharmaceuticals, Inc.
>2860 Wilderness Place
>Boulder, CO. 80301
>Work phone: (303) 546-7703
>Fax: (303) 444-0672
>E-mail mdater@Nexstar.com

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