Re: Licensing of C-14

["Daren Perrero" <dmperrero@email.msn.com>]

Another possibility to consider is that the company preferred to deal with
their local regulatory agency rather than the US NRC.  Since the
Headquarters Office of the US NRC is the only entity that has the authority
to issue licenses for the distribution of radioactive material to persons
exempt from licensing, they only choice left (to both California and the
licensees) was distribution of the product as a generally licensed device.
The drawback to this is the limitation that all generally licensed products
can only be subsequently transferred to persons specifically licensed (with
only a few exceptions).

But to address the point of your question, as it stands now the only
mechanism available to regulatory agencies to "track" products sold to
general licensees is the distribution report each company is required to
file with the various regulatory agencies.  Although I agree that tracking
50 uCi of C-15 is more than a little ridiculous, the mechanism also serves
the purpose of tracking 500 mCi of Cs-137 in gauging devices and other
similar radioactive sealed sources.  Many allowances are made in the
regulations for general licensees so that they do not have to go through the
full rigors of being a specific licensee, one of the trade offs of which is
limited subsequent transfer of the product.  The choices before regulators
these days are raising the quantities of radioactive materials which can be
distributed as exempt or forcing all generally licensees to become specific
licensees, neither of which is really palatable.  I think the middle road
being pursued these days is to hold general licensees more accountable for
the devices/sources that they possess.  Personally, I'm in favor of allowing
general licensees to transfer their products to other persons, however,
there is no control mechanism in place to ensure such materials do not fall
through the cracks when it come to accountability.  I am aware of a recent
study groups involving manufacturers, users, regulators and the scrap
industry which is looking closely at this issue.  I think they have at least
a draft report available for review.  Perhaps one of the NRC/Radsafe
participants can point us to its web location.

Daren Perrero
dmperrero@email.msn.com
Specialist in Radiation Safety
I'm with the government, I'm here to help you.....

>Barbara,
>
>This is anecdotal and heresay, but when I first inquired of the
>manufacturer several years ago why their products with less than exempt
>quantities were distributed under a general license, they replied
>"because the state of California required it". That's what prompted the
>statement in my previous note. However, the focus of that note wasn't in
>regards to the general license, but rather the requirement for a
>SPECIFIC license for 50 microcuries of C-14 for subsequent transfers.
>
>Bruce Pickett
>The Boeing Company, Seattle, WA
>bruce.d.pickett@boeing.com
>