[ RadSafe ] Lost Check Source

[BLHamrick at aol.com]

Wes,
 
I thought your comment was probably tongue-in-cheek, but I'm always timid  
about making assumptions about emails, since I can't see the sly grin on the  
author's face.
 
The NUREG cited below indeed only calls out the obligation to include dose  
considerations, but also states, "because 10 CFR 30.18 is silent regarding  
specific licensee activities governed by Part 20 regulations, Part 20 is  
applicable."  The further discussion only touches on the dose  considerations, but 
I'm curious how they find that, in general, "Part 20 is  applicable," but then 
only address the dose considerations, and not the other  sections of Part 20, 
such as the waste disposal provisions.
 
Perhaps someone from the NRC would like to chime in here.
 
Barbara.
 
In a message dated 12/12/2007 5:55:52 PM Pacific Standard Time,  
WesVanPelt at verizon.net writes:

Barbara, 
I  was being slightly sarcastic. Sorry. However, the real answer is  here: 
> 
_http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/br0117/991.html_ 
(http://www.nrc.gov/reading-rm/doc-collections/nuregs/brochures/br0117/991.html)  
In  fact, a “person” can simultaneously have all of the rights and  
responsibilities of both an “exempt person” and a licensed person. There is  only a 
slight crossover which requires adding the dose from both licensed and  
unlicensed sources. 


 



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