|
||||||
Answer to Question #130 Submitted to "Ask the Experts"Category: Policy, Guidelines, and Regulations The following question was answered by an expert in the appropriate field: Q
Must an NRC licensee report the loss of a 10CFR31.3 Po-210 static
eliminator? Per 10CFR20.2201? Why or why not? This is a graded approach
question because the device is low dose and already accessable to the
general public with basically no controls.
A
My understanding (based on conversations with regulators and regulated
alike) is that loss of generally licensed materials by licensees still
must be reported. In fact, I had one regulator tell me that Region I's
interpretation was that even exempt quantities had to be reported as
lost if they belonged to a licensee. Apparently the philosophy is that
a licensee is responsible for ALL radioactive material received, even
if generally licensed. One rationale for this is that, if contamination
above release limits is found in an uncontrolled area or if radioactive
material is found in a dumpster nobody is going to try to find a
pedigree for the material to see if it was licensed, generally
licensed, or exempt. On the other hand, I have also been told that
exempt material is exempt no matter who holds it.
In the case of the static eliminator that's generally licensed you should also check to see who owns it. We have several here, but they're all leased. We haven't lost any, however, so I don't know what the outcome of that would be. The bottom line is that my understanding is that a licensee is responsible for all radioactive materials received. Hope this helps. Andrew Karam, CHP University of Rochester
The information and material posted on this Web site is intended as general reference information only. Specific facts and circumstances may alter the concepts and applications of materials and information described herein. The information provided is not a substitute for professional advice and should not be relied upon in the absence of such professional advice specific to whatever facts and circumstances are presented in any given situation. Answers are correct at the time they are posted on the Web site. Be advised that over time, some requirements could change, new data could be made available, or Internet links could change. For answers that have been posted for several months or longer, please check the current status of the posted information prior to using the responses for specific applications.
|
||||||
| Ask a Question • Search ATE & ATE Categories • If you have Web-related problems, contact our Webmaster. If you are lost, see our site map. This page last updated 19 May 2009. | ||||||
