[ RadSafe ] Exempt Quantity source shipments

garyi at trinityphysics.com garyi at trinityphysics.com
Fri Jul 24 20:01:38 CDT 2009

Hellllooooo!  Someone who makes money SELLING new sources wishes they could sell 
fewer sources?  I'm no shipping expert, but basic economics says you should believe these 
"in the know" people at your own risk.  Cary's NUREG reference seems pretty conclusive. 

-Gary Isenhower

On 24 Jul 2009 at 15:39, Cary Renquist wrote:

Geo:     "I have talked today with those that are in the know and are
in the 
          business of selling exempt quantity sources, they still tell
          me, no>  an unlicensed end user can't TRANSFER and exempt
          source.We wish it were otherwise"

I think that you are taking a rather broad definition of transfer as
it relates to Dan's initial question about shipping the sources....  
Transfer in the NRC regulatory sense relating to exempt sources is
transfer of ownership not transport.

As long as the sources were initially transferred by a licensed
entity, an individual can transfer ownership as well as long as it is
not a commercial transfer e.g. giving them to neighbor, donating to
school, etc. as long as it is not related to a commercial transaction.

The HP position paper that you cite, clearly gives an example of a
commercial transfer of ownership.

>From NUREG 1556-8-rev1:
This exemption allows persons to receive, possess, use, own, or
acquire small quantities of byproduct material and to transfer items
such as tissue samples and counting standards to other unlicensed
persons on an occasional basis, not for commercial benefit, without a
distribution license. When the transfer of byproduct material in
individual quantities not exceeding the limits set in §30.71, Schedule
B, occurs for commercial benefit, then §§30.18(c) and (d) apply and
the manufacture, transfer, or distribution to persons exempt from
licensing requirements must be specifically licensed. Therefore, each
person engaging in the commercial transfer or distribution of exempt
distribution products must have a license authorizing distribution
under §32.18. The commercial transfer of a product refers to the
introduction of a material into the marketplace, whether or not a
charge is assessed for that distribution. Commercial benefit does not
necessarily include a monetary exchange


Cary Renquist
cary.renquist at ezag.com

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