View source for RIS 2006-25, Requirements For the Distribution and Possession of Tritium Exit Signs and the Requirements in 10 CFR 31.5 Ad 32.51A

{{Adams
| number = ML062770363
| issue date = 12/07/2006
| title = Requirements For the Distribution and Possession of Tritium Exit Signs and the Requirements in 10 CFR 31.5 Ad 32.51A
| author name = Schlueter J R
| author affiliation = NRC/FSME/DMSSA
| addressee name = 
| addressee affiliation = 
| docket = 
| license number = 
| contact person = 
| document report number = RIS-06-025
| document type = NRC Regulatory Issue Summary
| page count = 7
| revision = 0
}}
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[[Issue date::December 07, 2006]]

NRC REGULATORY ISSUE SUMMARY 2006-25REQUIREMENTS FOR THE DISTRIBUTION AND POSSESSION OFTRITIUM EXIT SIGNS AND THE REQUIREMENTS IN 10 CFR 31.5AND 32.51a

==ADDRESSEES==
All U.S. Nuclear Regulatory Commission (NRC) licensees distributing tritium exit signs andthose possessing a tritium exit sign under a general license.

==INTENT==
NRC is issuing this regulatory issue summary (RIS) to reiterate the requirements in10 CFR 32.51a that distributors of tritium exit signs must follow when transferring them to general licensee In addition, this RIS is intended to reiterate the requirements in 10 CFR 31.5 for general licensees regarding transfer and disposal of the tritium exit sign It is NRC's intentthat this will minimize the chances that tritium exit signs will be disposed of incorrectly and be disposed of in the nation's landfills or be sold on eBay or in other venues such as flea market This RIS does not transmit any new requirements or new staff positions.

==BACKGROUND==
The Commonwealth of Pennsylvania and the State of New Jersey have expressed theirconcerns to NRC about the possible improper disposal of tritium exit sign Their concerns are based on a report, issued by the Pennsylvania Department of Environmental Protection, regarding increased levels of tritium found in leachate in Pennsylvania landfill The report concludes that the increased levels of tritium are attributable to the improper disposal of tritium exit sign For this reason, the reporting requirements for the distribution and possession of generally licensed tritium exit signs in 10 CFR 31.5 and 32.51a are being reiterated.

==SUMMARY OF ISSUE==
For the purposes of this RIS, the following terms are defined:"Specific Licensee" is an individual or entity that is authorized to manufacture and/or distributetritium exit sign It also refers to an individual or entity that possesses a license issued by NRC or an Agreement State, that authorizes them to possess byproduct materials; and ML062770363 1 The Office of Nuclear Material Safety and Safeguards was reorganized on October 1, 200 The Office ofFederal and State Materials and Environmental Management Programs is now responsible for the tracking ofgenerally licensed device However, until the affected regulations in the Code of Federal Regulations areamended, please continue to use the address above when corresponding with the NR "General Licensee" is used to describe an individual or entity that possesses a generallylicensed device, such as a tritium exit sig Although the general licensee does not need specific approval from NRC, the general licensee is responsible for understanding and following the applicable NRC regulations (i.e., 10 CFR Part 31). General licensees are also subject to NRC inspection and enforcement activities, including issuance of civil penalties.NRC regulations in 10 CFR 32.51a(a) require that each specific licensee who transfers agenerally licensed device provide the following information to the general licensee receiving the device: (1) a copy of the applicable portions of the general license contained in 10 CFR 31.5; (2) copies of 10 CFR 31.2, 30.51, 20.2201, and 20.2202; (3) a list of services that may only be performed by the specific licensee; (4) information on acceptable disposal options for the deviceand the estimated cost for disposal; and (5) an indication that NRC's policy is to issue high civil enforcement penalties for improper disposal of device Furthermore, 10 CFR 32.51a(a)
requires the specific licensee to provide this information before the device is transferred.The relevant portions of the general license contained in 10 CFR 31.5(c)(8)(i) includerequirements that general licensees must follow regarding the transfer or disposal of generally licensed devices, including tritium exit signs, that contain byproduct material. In order for a general licensee to dispose of a device properly (i.e., when the device is no longeruseful), the general licensee must transfer the generally licensed device to a specific licensee. Examples of specific licensees that would typically receive tritium exit signs when they are no longer useful include the manufacturer, distributor, licensed radioactive waste brokers, and licensed low level waste disposal facilitie These licensees often charge fees to receive suchmaterial, so possessors of tritium exit signs are advised to contact specific licensees and explore disposal option Transfer to a specific licensee is the only authorized disposal methodfor generally licensed tritium exit sign The requirements for transferring a generally licensed device to a specific licensee are found in 10 CFR 31.5(c)(8)(ii) and state that a general licensee:Shall, within 30 days after the transfer of a device to a specific licensee or export,furnish a report to the: Director, Office of Nuclear Material Safety and Safeguards1ATTN: GLTSU.S. Nuclear Regulatory Commission Washington, DC 20555-0001using an appropriate method listed in 10 CFR 30.6(a) of this chapte The report mustcontain -(A)The identification of the device by manufacturer's (or initial transferor's) name, model number, and serial number; (B) The name, address, and license number of the person receiving the device(license number not applicable if exported); and(C) The date of the transfer.In addition, general licensees are also required, by 10 CFR 31.5(c)(12), to appoint an individualresponsible for having knowledge of the appropriate regulations and requirements and the authority for taking required actions to comply with appropriate regulations and requirements.General licensees intending to transfer and dispose of tritium exit signs must comply with theserequirements.If you believe that you have received this RIS in error, please notify NRC in writing at:Director, Office of Nuclear Material Safety and SafeguardsATTN: GLTS U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

===FEDERAL REGISTER NOTIFICATION===
A notice of opportunity for public comment on this RIS was not published in the FederalRegister because this RIS is informational and does not represent a departure from currentregulatory requirements.

===CONGRESSIONAL REVIEW ACT===
NRC has determined that this action is not subject to the Congressional Review Act.

===PAPERWORK REDUCTION ACT STATEMENT===
This RIS does not contain any new or amended information collection requirement Theseinformation collections were approved by the Office of Management and Budget (OMB),
approval numbers 3150-0016 and 3150-0001, which expire August 31, 2008.

===PUBLIC PROTECTION NOTIFICATION===
The NRC may not conduct or sponsor, and a person is not required to respond to, a request forinformation or an information collection requirement unless the requesting document displays a currently valid OMB control numbe 

==CONTACT==
Please direct any questions about this matter to the technical contact or the appropriateregional office./RA/Janet R. Schlueter, Director Division of Materials Safety and State Agreements Office of Federal and State Materials and Environmental Management Programs

===Technical Contact:===
Ujagar Bhachu, FSME 301-415-7894 E-mail: usb@nrc.gov

===Enclosure:===
List of Recently Issued NMSS Generic Communications 

==CONTACT==
Please direct any questions about this matter to the technical contact or the appropriateregional office./RA/Janet R. Schlueter, Director Division of Materials Safety and State Agreements Office of Federal and State Materials and Environmental Management Programs

===Technical Contact:===
Ujagar Bhachu, FSME 301-415-7894 E-mail: usb@nrc.gov

===Enclosure:===
List of Recently Issued NMSS Generic CommunicationsDISTRIBUTION:DMSSA r/fFSME r/fML062770363OFFICESSSBSSSBMSEATECH EDOISOGC-CRAOGCNAMETHerreraTHarrisAMcIntoshEKrausBSt.MaryJAdlerFCameronDATE10/05/06 10/05/06 10/12/06 10/09/0610/25/06 10/26/0611/13/06OFFICEDDMSSADMSSANAMES.MooreJSchlueterDATE11/30/0612/05/06OFFICIAL RECORD COPY Recently Issued NMSS Generic Communications DateGC No.Subject

==Addressees==
09/14/06RIS-06-19Availability of Guidance on RadioactiveSeed LocalizationAll NRC medical licensees.08/31/06RIS-06-18Requesting Exemption from the PublicDose Limits for Certain Caregivers of Hospital PatientsAll NRC medical licensees.07/20/06RIS-06-11Requesting Quality Assurance ProgramApproval Renewals Online by Electronic Information Exchange All 10 CFR Part 71 quality assurance program andcertificate holders.04/23/06RIS-06-10Use of Concentration Control for CriticalitySafetyAll licensees authorized to possess a critical massof special nuclear material.01/26/06RIS-02-15, Rev.1NRC Approval of Commercial DataEncryption Products For the Electronic Transmission Of Safeguards InformationAll authorized recipients and holders of sensitiveunclassified safeguards information (SGI).01/24/06RIS-06-01Expiration Date for NRC-Approved SpentFuel Transportation RoutesThe U.S. Nuclear Regulatory Commission (NRC)licensees who transport, or deliver to a carrier for transport, irradiated reactor fuel (spent nuclear fuel(SNF)).01/13/06RIS-05-27, Rev.1NRC Timeliness Goals, Prioritization ofIncoming License Applications and Voluntary Submittal of Schedule for Future Actions for NRC ReviewAll 10 CFR Parts 71 and 72 licensees andcertificate holders.07/10/06IN-06-13Ground-Water Contamination Due toUndetected Leakage of Radioactive WaterAll holders of operating licenses for nuclearpower and research and test reactors including those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor and those authorized by Title 10 of the Codeof Federal Regulations (10 CFR) Part 72licenses to store spent fuel in water-filledstructures.07/06/06IN-06-12Exercising Due Diligence WhenTransferring Radioactive MaterialsAll materials licensees.06/12/06IN-06-11Applicability of Patient Intervention inDetermining Medical Events for Gamma Stereotactic Radiosurgery and Other Therapy ProceduresAll medical licensees.03/31/06 IN-06-07Inappropriate Use of a Single-parameterLimit as a Nuclear Criticality Safety LimitAll licensees authorized to possess a critical massof special nuclear material.03/21/06IN-02-23, Supl. 1Unauthorized Administration of ByproductMaterial for Medical UseAll medical licensee DateGC No.Subject

==Addressees==
01/19/06IN-06-02Use of Galvanized Supports and CableTrays with Meggitt Si 2400 Stainless- Steel-jacketed Electrical CablesAll holders of operating licenses for nuclearreactors except those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel; and fuel cycle licensees and certificate holders.Note: NRC generic communications may be found on the NRC public website at http://www.nrc.gov, under Electronic ReadingRoom/Document Collections.
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