Re: Licensing of C-14 -Reply

[Tom Hill <Tom_Hill@MAIL.DNR.STATE.GA.US>]

Barbara Hamrick was correct in her response.  Additionally, the General Licensee under which Boeing possesses and uses the devices does not authorized Boeing to transfer the devices to any one exempt form regulations.  When Boeing no longer needs the devices they must be transfered to a specific licensee. 

Tom Hill
Radioactive Materials Program
Georgia Department of Natural Resources

>>> steve hand <hand@wam.umd.edu> 05/06/98 01:28pm >>>


Pickett, Bruce D wrote:

> My company has purchased several light measuring devices (which we refer
> to as photometers) that were manufactured and distributed under a
> general license in California. These photometers contain sealed sources
> with 50 microcuries (1.85 MBq) of carbon-14. One hundred microcuries
> (3.7 MBq) of C-14 is an amount normally exempt from licensing, however,
> California requires that these photometers with half of the exempt
> amount be distributed under a general license.
>
> On the bottom of the photometers are "Caution Radioactive Material"
> labels which provide information pertinent to licensing (see copy at end
> of message). The third sentence of the label states "This device shall
> not be transferred, abandoned, or disposed of except by transfer to a
> person holding a specific radioactive material license to receive this
> device." So even though this material would normally be exempt from
> licensing, and the manufacturer sold it to my company under a general
> license, if I sell it or otherwise transfer it to someone else, THEY
> have to have a SPECIFIC LICENSE!
>
> The requirement for someone to have a specific license for 50 *Ci of
> carbon-14 in a sealed source seems excessive. Has anyone run into
> similar situations? Does anyone have any insight into this requirement?
>
> Bruce Pickett
> The Boeing Company, Seattle, WA
> bruce.d.pickett@boeing.com
>
> -------------------------------------------------------
> CAUTION: RADIOACTIVE MATERIAL
>
> This device has been manufactured for distribution as a generally
> licensed device under California State Department of Public Health
> License 2189-70GL to Photo Research, Division of Kollmorgen Corporation.
> The receipt, possession, use, and transfer of this device are subject to
> a general license or equivalent, and the regulations of the U.S. Nuclear
> Regulatory Commission or Agreement States.
> This device shall not be transferred, abandoned, or disposed of except
> by transfer to a person holding a specific radioactive material license
> to receive this device.
> Service involving sealed sources used in this device shall be performed
> only by persons specifically licensed to provide this service.
> This device and the sealed radioactive light source contained therein
> need not be tested for any purpose.
> -------------------------------------------------------


  This does not seem unreasonable; although both California and Maryland are
Agreement states there may well be differences in how their respective
regulations are written.  In Maryland, " Except as otherwise provide in his
license and subject to the provisions of ... any licensee may transfer
radioactive material:  to any person authorized to receive such material
under the terms of a general license or its equivalent, or a specific
license ...."

  As Barbara Hamrick stated it may be that the company is restricted in its
license to this condition on the products that it distributes.


steve hand
university of maryland