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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                  
                                                                               
QUIT