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Re: basis for source material exemption
Will-
Since I am working on some Part 40 issues right now, I can tell you that all the historical information points to the exemption limit as being based on national security issues at the time. 12 FR 1855 (dated March 20, 1947) states that "the regulations in (10 CFR Part 40) for the control of source material ...were to prevent the use of such material in a manner inconsistent with the national welfare." From 1947 to 1961 (when an overall revision of Part 40 occurred) the 0.05% concentration limit was based primarily on control of strategic material.
If you take a look at the Atomic Energy Act of 1946, you can find more detailed information. Specifically, if you look at Senator McMahon's explanation of his bill (S. 1717 (the bill which became the 1946 Act) he said (see 92 Cong. Rec 6210 -Daily Ed.):
"In section 5 of the bill, provision is made for control of source materials, the uranium
ores from which the fissionable material is made, This material is at the foundation of all
atomic energy production. To keep track of our supplies of this material and to prevent
their export or diversion into unauthorized channels, S. 1717 requires that all transfers of
source materials be licensed by the Commission."
The discussion goes on to discuss the (then proposed) S. 1717 bill, and because source materials were "peculiarly essential" to the product of fissionable materials, and since Congress in 1946 apparently apprended no health or safety hazards from its apparent use, the statement (in sec. 5(b)(2) of the Act, and sec. 62 of the 1954 Act) that "licenses shall not be required for unimportant quantity from a conservation or national security standpoint.
Hope this helps. In addition, you can check out NUREG/CR-5881, "An Examination of Source Material Requirements Contained in 10 CFR Part 40," issued in 1992, which discusses a lot of the historical nature of this Part .
Cynthia G. Jones
Senior Level Advisor for Health Physics
Office of Nuclear Material Safety & Safeguards
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Tel: (301) 415-7853
Fax: (301) 415-5369
>>> William McCabe <WMCCABE@tnrcc.state.tx.us> 04/14 8:50 AM >>>
I hope some of you history buffs can help me with this.
I'm having a DISCUSSION regarding the 0.05 percent by weight exemption
for source material. My opponent argues that the exemption limit is based
on national security issues and therefore is not protective of human
health and safety; that there was no health and safety considerations
given in determining this exemption or regulatory level. I believe this to be
incomplete and potentially misleading.
I say that when this limit was established back in the 40's, the
concentrations of U that were considered unsafe were comparatively
much higher than what may be considered acceptable today, and
knowing this, the regulators based the 0.05 percent by weight exemption
for source material on what was considered to be economically
unfeasable for recovery.
I'd appreciate any insights, comments, and most of all references!
Thanks.
Will McCabe
wmccabe@tnrcc.state.tx.us
Any opinions expressed in this message are solely my own and do not
necessarily reflect the opinion or policy of the TNRCC.
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