[ RadSafe ] Seeking exempt quantity sources donation.
GEOelectronics at netscape.com
Wed Sep 2 14:51:11 CDT 2009
"----- Original Message -----
From: "Glenn R. Marshall" Now I believe the original question had to do with
a specific licensee wanting a bunch of exempt sources to distribute them to
unlicensed entities such as schools. That requires an exempt distribution
license under Part 32.
Concerning schedule B, exempt quantity sources.
Quite correct Glenn. To receive the sources, they must come from a licensed
To transfer the sources, they must be transferred by a licensed distributor.
No sort of license is needed to own or use them, but an unlicensed user
cannot combine exempt quantity
sources for the purpose of increasing the radioactivity.
It is true that the NRC rules plainly state that there is no restriction on
ownerships.etc and transferring the material.
It says that in plain language, but the NRC also gives guidance that an
unlicensed person may not "enter the sources into the marketplace", and
further states that is is laughable that anyone would thing the rules
mentioned above would
allow someone to purchase the sources from a licensed place, then give them
That certainly seems contradictory, and no one at the NRC office will defend
either application of the rule. It is not their job to do that.
That is the job of the NRC legal department, and they will not do that for
you for free. It is not their job to do that.
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