[ RadSafe ] Lost Check Source

BLHamrick at aol.com BLHamrick at aol.com
Tue Dec 11 19:19:33 CST 2007

What Glenn says is generally true, because NRC and most other Agreement  
States exempt "persons" from licensing, not the specific "items."  So, if  you are 
a "person" already specifically licensed, you cannot be a "person  exempt."  
California's regulations, however, exempt the items, not the  persons, so if 
the item was manufactured and distributed under an NRC  E-distribution license 
(or an Agreement State E-license for certain NARM), then,  in California, the 
item is exempt from the regulations to the extent authorized  by the exemption 
(some exemptions have limitations), including disposal, because  California 
regulations define "possession" to include receipt, possession, use,  transfer 
or disposal of radioactive material (see 17 CCR 30100(n).
Barbara L. Hamrick

In a message dated 12/11/2007 1:52:35 PM Pacific Standard Time,  
GRMarshall at philotechnics.com writes:

If the  client has a license, then all radioactive material in his
possession is  licensed material.  He can't just say "Oh, it's exempt -
never  mind."  Refer to 10 CFR 20.2001.  It's not reportable under 10  CFR


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