RE: Exemptions - further clarifications -Reply

[Catherine Mattsen <CRM@nrc.gov>]

In response to Bill Spell's questions.
I am in the Office of Research at NRC and involved in reevaluating the regulations
in the area of exemptions (There are no rule changes in the works yet as a result of
this.)  My comments are concerning NRC regs. only.  Some State regs. may be
different.  The provision about 10 separate exempt quantities in one shipment is in
10 CFR 32.19.  In the case of this particular exemption, all commercial distributors
(including those in Agreement States) should have an NRC license issued under 10
CFR 32.18.

In response to a statement of Eric Darois, the condition that recipients be
provided with instructions not to combine exempt quantities is important in
determining whether the activities of the user should be licensed.