Distribution of Products Irradiated in Research Reactors (Generic Letter No. 86-11)

                               UNITED STATES 
                       NUCLEAR REGULATORY COMMISSION 
                          WASHINGTON, D. C. 20555 

                                June 25, 1986

TO ALL NON-POWER REACTOR LICENSEES 

Gentlemen: 

SUBJECT:  DISTRIBUTION OF PRODUCTS IRRADIATED IN RESEARCH REACTORS (GENERIC 
          LETTER 86-11) 

We have recently received several inquiries regarding products which are 
irradiated in research reactors and subsequently distributed to unlicensed 
persons. The inquiries were related to irradiations of gems and silicon 
chips, but other products may also be involved. 

We are concerned that research reactor licensees may be irradiating and 
redistributing products containing induced radioactivity to unlicensed 
receivers who utilize or redistribute these irradiated products. Information
provided to NRC in specific cases indicates that gems, silicon chips, and 
many other materials usually acquire relatively long-lived induced 
radioactivity when irradiated in a reactor. Although irradiation of products
in a reactor is not of itself prohibited, 10 CFR Section 30.14 prohibits 
introduction of byproduct material into a product for distribution to an 
unlicensed person, unless the distributor has a specific license issued 
pursuant to 10 CFR Section 32.11 which permits such distribution. 

The purpose of this Generic Letter is to correct any misunderstanding 
concerning the distribution of irradiated products to unlicensed persons. In
accordance with 10 CFR 30.14, the distribution of irradiated materials, even
with low levels of induced radioactivity, to unlicensed persons is 
prohibited unless the distributor of such materials is licensed by the NRC 
to do so. Furthermore, to measure these low levels of induced radioactivity 
very sensitive low background instruments are required, such as shielded 
sodium iodide or germanium-lithium detection systems. 

In addition, we call your attention to subsection 3 of the enclosed NRC 
Policy Statement in the Federal Register notice of March 16, 1965 (30 FR 
3462) regarding products-which are toys, novelties or adornments. The staff 
considers gems to be adornments and has not granted licenses for 
distribution of irradiated gems or similar materials. 

You are responsible for assuring that the distributors of any products you 
have irradiated in your reactor, and which have acquired induced 
radioactivity, are licensed to distribute these products in accordance with 
10 CFR 30.14(c) and 30.31. If you directly distribute the irradiated 
products to unlicensed persons, you must obtain a new license to reflect 
this activity. 


8607020017 

                                    - 2 -

Applications should be addressed as follows:  

     U.S. Nuclear Regulatory Commission 
     Director, Office of Nuclear Material 
          Safety and Safeguards 
     Division of Fuel Cycle and Material Safety 
     Washington, D. C. 20555 

Please note that the NRC has exclusive jurisdiction over reactors and 
distribution of radioactive consumer products. Agreement States do not issue
this type of license. 

This letter is for information only and does not require any response. 
Should you have any questions concerning this matter, please contact Harold 
Bernard at (301) 492-8529. 

                              Sincerely, 


                              Frank J. Miraglia, Director 
                              Division of PWR Licensing-B 
                              Office of Nuclear Reactor Regulation 

Enclosure: 
As stated