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20.1002
10CFR20.1002 does not use the term 'licensed material'. It applies to all
by-product, source, and SN Material, except for a few noted exception.
10CFR30.14 and 30.18 provide exemptions from the requirements of parts 30-34,
36, and 39 but in my reading ***do not*** exempt the possessor/user from
Part 20.
Regarding a holder of a license with a line item covering the radionuclide
acquired via an exempt distribution process, I think the reg's are unclear.
While 10CFR exempts you from the Part 30... provisions, your license tends
to apply to all of that nuclide in your possession. I have been told that
the 'exempt' sources are not covered but have not seen it in writing, nor
do I think this is discernable from 10CFR without a NRC lawyer's stamp of
approval. It is between you and your inspector.
If someone has a specific wriiten reference on this it would be appreciated.
SLABACK@MICF.NIST.GOV [NBSR Health Physics Group]
...a little risk, like a bit of spice, adds flavor to life
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