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10CFR40.22 - Small Quantities of Source Material



I have run into an interesting situation and am trying to solicit some
opinions from the denizens of radsafe.

I provide consulting services for a source materials licensee. It turns out
that many years ago they also used to get Zr refractory powders (Th present
and accounted for) to repair cracks in their kilns. The kilns were never
part of the process in which the source material on the license was used.
They no longer have the bags of powder or the kilns but I am finding
residual levels around the facility. In reading 40.22 (b) it is my
interpretation that the exemption granted for use, possession and transfer
does not apply to specific licensees. I have spoken with some members of the
commission and some agree and some do not. I was told to submit a request
for a policy interpretation. Prior to doing that I would be interested in
hearing the views of others.

The licensed material they use has not contaminated much of the facility but
the powder is at levels in excess of the unrestricted release levels. So it
seems strange that there are facilities through-out the US that are probably
contaminated but not obligated to clean-up unless they also possess a source
license. I am interested in knowing if I am "over interpreting"
10CFR40.22(b).

Thanks in advance - if you want to save bandwidth send me e-mail privately
and I'll summarize the responses.

Thanks,

Pete C.

pcollopy@mjwcorp.com
MJW Corporation
338 Harris Hill Road
Suite 208
Williamsville, NY 14221
716-631-8291 x3120
716-631-5631 (FAX)
One pill makes you smaller, one pill makes you bigger - does anyone know if
there is a pill to make your sixteen year old non-hormonal ?

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