Re: draft reg guide for broad license applications

[baumbaug@nosc.mil (Joel T. Baumbaugh)]

     Paul,

     I would be very interested in a copy of your comments.

     Thank you,

     Joel Baumbaugh
     NRaD
     Safety Office, Code 0382
     San Diego, CA 92152-7042

     (619) 553-5030  Fax (619) 553-6756

Date: Fri, 6 Jan 95 10:08:38 -0600
Sender: radsafe@romulus.ehs.uiuc.edu
From:      "PAUL     SKIERKOWSKI,     UNIV.     OF      OKLAHOMA"
<RADSAFE@aardvark.ucs.uoknor.edu>
To: Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
Subject: draft reg guide for broad license applications



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outdated and should not be used by nrc as a ref.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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