NRRPT Petition -Reply and Comments

[Kenneth Price <75301.361@compuserve.com>]

I'd like to make some comments concerning the discussion regarding the petition
for rulemaking submitted by the NRRPT.

re. C. Raddatz-  If the NRC is intending to establish absolute minimums for RSO
qualifications, then my concern is that employers will do just that in selection
of RSO's.  I have e-mailed Mr. Lesar at the NRC for an interpretation of the 200
hours classroom and lab experience requirement of the current 10 cfr 35.900(b).
In times when NRC is getting more demanding operationally and technically with
licensees  an apparent relaxation in RSO requirements seems contradictory.

If the intent is to permit certified Nuclear Med Techs to be RSOs at smaller
clinics and hospitals then the rule should say that.  

At the risk of making a few people upset, I plan to comment on the proposed rule
as follows

              At a minimum, keep the 1 year experience requirement no matter
what!

              Recognize NRRPT registration provided the individual has attained
at
              least a college degree in a science.

              Recognize nuclear medicine tech certification in conjuction with
NRRPT
              registration, with a minimum associates degree in a science.

I am the RSO at the University of Connecticut Health Center, in Farmington, Ct.,
a broad scope human use licensee.  I recognize that NRRPTs are highly skilled,
knowlegeable and dedicated individuals.  However, being RSO at a medical
faciltiy necessitates a more extensive background than that proposed by the
NRRPT.


                                                                   Kenneth
Price, CHP
                                                                   75301.361@comp
userve.com