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Revised NRC Form 3
Hello Radsafers:
I just received revised copies (1-96) of Form 3 from the NRC. I've a couple
of comments and questions regarding the "required" posting of revisions of
the "Notice to Employees":
I last posted our rad use areas with the 7-95 revision. Thirty days after
we had finished the posting we received the 9-95 revision. I hesitated at
the time to ask our rad tech to tear down the "old" notices in favor of the
revision, although intuition told me it may be another "requirement." I was
considering posting the 9-95 revision this spring in conjunction with lab
audits. Interestingly, the only difference I can find between the 9-95 and
the 1-96 revision is that the word "Also" has been eliminated as the first
word in the last paragraph in the Q&A section (although I may have missed
something).
My questions are:
1) Is a NRC licensee required to re-post all rad use areas with revised notices?
2) If so, is there a time frame following receipt of such in which the
licensee must complete the posting of the revision?
3) Looking at my copy (1-1-94) of Part 19, section 19.11(c) states ". . .a
specific license SHALL prominently post NRC Form 3 (Revision dated June
1993). . ." Given the fact that a revision is mentioned there, do we
conclude that the "Form 3 Revision" that is referred to in the most recent
revision of Part 19 is the one that we are required to post??? (If that's
true, does a revision in Form 3 automatically justify a revision in Part 19?
-- just a thought!)
4) For those of you with the most recent revision of Part 19, what revision
of Form 3 is mentioned there?
I know this may seem trivial, but the man-hours spent reposting every time a
Form 3 revision comes out can be considerable.
Thanks for your patience!
-Erick Lindstrom
Erick Lindstrom
Radiation Safety Officer
309 Montana Hall
Montana State University
Bozeman, MT 59717-0244
Phone: (406) 994-2108
Fax: (406) 994-4792
avrel@gemini.oscs.montana.edu