ML20202B526
| ML20202B526 | |
| Person / Time | |
|---|---|
| Issue date: | 01/25/1999 |
| From: | Camper L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Siegrist W AFFILIATION NOT ASSIGNED |
| References | |
| NUDOCS 9901290104 | |
| Download: ML20202B526 (1) | |
Text
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Fcicon Watch Company ATTN: Wcr::rr Si:: grist January 25, 1999 2510 Brentwood Blvd., Suita 203 St. Louis, MO 63144
Dear Mr. Siegrist:
This responds to your request in a letter dated December 5,1998, for an exemption from 10 CFR 32 licensing requirements for the distribution of watches containing tritium.
We are unable to authorize an exemption (10 CFR 30.11) from the licensing requirements in Part 32 since exclusion from these requirements is not authorized by law. We sympathize with your situation as a small business and appreciate the fact that you do not " manufacture, process, or produce self-luminous products," however, our regu!ations [10 CFR 30.15(b)]
require that any person who desires to initially transfer for sale or distribution timepieces containing tritium should apply for a specific license (10 CFR 32.14).
Since an exemption from Part 32 is not now authorized by law, you might consider a petition to the U.S. Nuclear Regulatory Commission (NRC). This is a means by which any interested person may petition the Commission to issue, amend, or rescind any regulation (10 CFR 2.802). The petition should be addressed to the Secretary, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001, Attention: Rulemakings and Adjudication Staff.
Further information on this process may be found in the enclosed copy of 10 CFR 2.
As suggested to you by Mr. Kirkwood of my staff, you might also investigate the possibility of having a licensed distributor receive the watches first and initially distribute them to you. This would eliminate your NRC license obligations. Another option, exercised by small businesses in similar situations to your own, is to sell self-luminous watches that do not contain any radioactive material.
If you have any questions, please contact Anthony Kirkwood of my staff at (301) 415-6140.
Sincerely, (orig, signed by)
Larry W. Camper, Chief Materials Safety Branch Division of industrial and Medical Nuclear Safety Office of Nuclear Materials Safety
/
9901290104 PDR ORG 990125 O NOMA PDR
Enclosure:
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