draft reg guide for broad license applications

["PAUL SKIERKOWSKI, UNIV. OF OKLAHOMA" <RADSAFE@aardvark.ucs.uoknor.edu>]

we recently completed our submission of our renewal application
for our broad scope license.  as part of the process, we reviewed
draft reg. sugid DG-0005 "applications for licenses of broad scope"
draft reg.guide DG-0005 "Applications for licenses of broad scope"
the draft is "FOR COMMENT" and the deadline if 1-25-95.  We felt
there were items to comment on and wondered if other broad license
holders were interested in a dialogue on the draft.

specifically, if you change chair of the rsc, you'd have to submit
a license amendment.  that could get expensive if you're not
fee exempt.

there is a requirement to indicate the "number" of survey instru-
ments in your application.  if that became a license condition
it could lead to unnecessary citations.

The long lived waste dilema refers to storage of r.a.m. with 
half lives  s greater than 65 days.  s-35 is 87 days and can be
safely and economically disposed of by decay in storage.  

the IAEA standard for lab classification (dated 1973) is badly 
outdated and should not be used by nrc as a ref.  for example,
an RIA lab using I-125 is classified as "High Toxicity" by the
IAEA standard.

I've submitted comments to the NRC and would gladly send you an
email copy of my comments if you're interested.  

paul skierkowski, rso, univ. of oklahoma - norman
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