Exempt quantities

["Dale E. Boyce" <dale@radpro.uchicago.edu>]

Having been the one who suggested distributing as exempt quantities
I should follow up on Sharron's post to say I have also had some 
interesting discussions with inspectors over the exempt regs.  I
would highly recommend talking with the NRC offices in both regions
before proceeding.  However, the license to distribute exempt
quantities is explicitely for commercial distribution.  There is
no equivalent license for non-commercial distribution.  In my
talks with the folks at IDNS I was told that the reason behind
the exempt regs was precisely to allow collaboration with small
unlicensed facilities, and that the Commercial license was a way
to prevent large scale use of RAM by buying large numbers of
exempt quantities to avoid getting a license.  Whether or not
an inspector interprets the regs in the letter and intent with
which they are written is a whole 'nuther matter.

The applicable Parts are 10 CFR 30.18 and 32.18

Dale E. Boyce
dale@radpro.uchicago.edu