Source Material - Exempt, Generally or Specifically Licensed

[glenn <ins@the-spa.com>]

I realize that this is an old issue (2+ months).  However, I recently
straightened
out my inability to post to radsafe although I've been receiving
messages for quite
a while. This is posted at this time since I saw no one express the
following limitation.

I previously tried to say:

Careful, With regards to source material (which I think is the material
of
interest)

10 CFR 40.22(b) last sentance:  "...Provided , however, that this
exemption shall
not be deemed to apply to any such person who is also in possession of
source
material under a specific license issued pursuant to this part."

40.22 is the general license provision that most generally licensed
source materials 
falls under; i.e., 15 pound transfer at a time, 150 pounds max per year.

Glenn Roberts


Wes Van Pelt wrote:

> Hi Radsafers,
>
> I believe Erik's licensing theory to be entirely false.
>
> Regardless of any other licenses a person may have, he/she/it may have
> generally licensed material and exempt material without placing these materials
> under the "umbrella" of, say, a specific license.
>
> The ONLY crossover between a specific license and additional exempt or
> generally licensed material is that an individual's dose must include dose from
> all sources, not just the the specifically licensed sources.
>
> regards,
> Wes
> --
> Wesley R. Van Pelt, Ph.D., CIH, CHP            KF2LG
> President, Van Pelt Associates
> Radiation Safety and Environmental Radioactivity
> mailto:vanpeltw@idt.net   http://idt.net/~vanpeltw/
>
> "Erik C. Nielsen" wrote:
>
> > The interpetation that I have been operating under is that a someone that
> > does not have a radioactive material license is allowed to possess this
> > material under a "general license" but when you have a rad material license
> > the material is no longer generally licensed and is part of your
> > radioactive inventory with all associated controls.
> >
> > A very similar situation occurs with Ni-63 sources in ECD's.  The license
> > is held by the manufacturer, you must do wipe tests but the sources are
> > considered generally licensed.  Get a radioactive material license and
> > these items get "captured" by the license.  There are other similar exempt
> > source situations where the controls needed depend on your license status.
> >
> > Erik
> >
> > Erik C. Nielsen
> > mailto: enielsen@stl-inc.com
> > +++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++
>
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