The State of Iowa and the Organization of Agreement States will be made aware of this action and will be provided with a copy of the attached Generic Letter once published. OGC has reviewed this paper and has no legal objection. That the Commission note that, unless directed otherwise, the staff will issue a generic letter to all materials licensees. Staff requests action within 10 days. Action will not be taken until an SRM is received.
All materials licensees.
It is expected that recipients will review this information for applicability to their facilities and consider actions, as appropriate. However, no specific action nor written response is required. However, based upon additional requests of a much more extensive nature, NRC now finds that combining any exempt sources is inconsistent with the regulations, pursuant to 10 CFR 30.18, 32.18, 32.19, and 32.20. Instructing persons exempt from licensing to combine exempt quantities, and providing devices for them to do so, is in direct conflict with NRC's requirements for labeling of exempt sources. Section 32.19 specifically instructs persons not to combine exempt quantities, since the exemption provided in 10 CFR 30.18 is applicable only as long as no individual nor discreet quantity of the byproduct materials exceeds the quantity limits specified in 10 CFR 30.71, Schedule B, and as long as the quantities set out in that schedule are originally received and remain separate and distinct from other quantities of exempt byproduct materials.