[ RadSafe ] Seeking exempt quantity sources donation.

[Geo>K0FF]

Glenn said:
"----- 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.

Glenn "

Concerning schedule B, exempt quantity sources.
Quite correct Glenn. To receive the sources, they must come from a licensed 
distributor.
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 
away.

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.





George Dowell