unconditional release

["Les Slaback, Health Physics" <SLABACK@micf.nist.gov>]

It would be nice if some 'NRC' type could informally respond to these legal
questions, but, sticking my neck out.....
 ..as waste: no way, Jose.  If it is classed as waste it must be disposed of
(ie. released) in compliance with all NRC/EPA waste rules.
 ..under Part 30 as exempt concentration or exempt quantity:  the internal
NRC 'position paper' postulates an extremely restrictive interpretation of
the Part 30 rule, but if you can meet the Part 30 requirements you can
transfer to a non-licensee.  But that is NOT an unconditional release.  That
recipient is still subject to various NRC requirements, including Part 20.
 ... any other form of release, or of unconditional release would almost
assuredly have to be a specific condition of your license.

Of course, Part 35 grants several means of unconditional release, assuming
you can get the material into a person within the scope of those allowed
uases.

SLABACK@MICF.NIST.GOV
   ...a little risk, like a bit of spice, adds flavor to life