Re: basis for source material exemption

[George Harder <gharder@perma-fix.com>]

I've been doing a little research into the topic of source material and
have found three position papers by the NRC.

First there is HPPOS-135 located at

http://www.nrc.gov/NRC/NMSS/HP/POS/hppos135.txt

This was titles 10 CFR 40.14 is not to be used for issuing exemption
licenses.  In it the NRC addresses the question about how the limit used as
the basis for the "0.25 percent by weight thorium, uranium, or any
combination of these,..." was obtained.  The response stated "the basis for
the exemption was that the quantity of source material present in the
exempted materials was not significance to the common defense and
security."  There is more information in this position paper that may be of
interest.

The next position paper is HPPOS-202 located at

http://www.nrc.gov/NRC/NMSS/HP/POS/hppos202.txt

This addresses titanium bearing ores and waste products from titanium
dioxide manufacturing.  Under this, it appears the 0.25% exemption is for
"unrefined and unprocessed ores."

Finally there is HPPOS-029 located at

http://www.nrc.gov/NRC/NMSS/HP/POS/hppos029.txt

This talks about exemptions listed in 10 CFR 40.13(c)(1)(vi) which applies
to rare earth products containing <0.25% source material by weight.
Looking at these, it appears health must not have been the driving factor
in the 0.05% level.


At 07:50 AM 4/14/1999 -0500, you wrote:
>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.


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