RE: Exemptions - further clarifications -Reply -Reply

[Keith Brown <KDB1@nrc.gov>]

>>>>>>>>>>>>>>>
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.


<<<<<<<<<<<<<<<

Note that this regulation applies to (per 10 CFR 32.1) holders of licenses to
persons who manufacturer or initially transfer items containing byproduct
material to persons exempt or generally (slightly paraphrased, so you may
want to look at the original), and not to the recipients of these devices.  I
do not believe that was made clear.

My opinion only; not necessarily that of my employer.

Keith Brown
kdb1@nrc.gov