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Byproduct vs. Accelerator Produced Materials -Reply
Ted, based on my experience, we do not license non-byproduct materials. We also do
not inspect non-byproduct materials. In most cases the state licenses radioactive
materials and does not differentiate between byproduct and nonbyproduct. However,
the state may not have jurisdiction at your facility. Consequently, you are outside
NRC regulation. Hopefully, someday the Atomic Energy Act will be changed to
address all radioactive materials and x-ray producing machines and fully cover
radiation safety. Until then, good luck!
Again these are my thoughts and musings. KMP @NRC.GOV