response from U. of OK. to proposed 10CFR20.2205

["Paul Skierkowski" <PAUL@ess-lan.studies.uoknor.edu>]

The following is fyi - submitted by the Univ. of Oklahoma in response to 
NRC proposed 10CFR20.2205

=====================================================================

                             19 March 1996


Secretary, U.S. Nuclear Regulatory Commission
Washington, DC  20555-0001  
ATTN: Docketing and Service Branch

VIA FAX:  301-415-5389

REF: Proposed Reporting Requirements for Unauthorized Use of Licensed
Radioactive Material [10CFR20.2205]

The University of Oklahoma Radiation Safety Committee has reviewed the
Federal Register notice of the proposed additional requirements
referenced above and wishes to make the following comments concerning
this proposal.

Although your Regulatory Analysis concludes that the occurrence of
events that would be affected by this rule is expected to be rare, 
the wording of the proposed rule appears to be much more stringent. 
The removal of a exposure limit threshold literally means that any
contamination, no matter how minor, would need to be reported IF
intentional or unauthorized use canNOT be ruled out.  It would be
virtually impossible to completely rule out such use - that's like
trying to prove the negative.  

In 20.2205(b) you would require notification as soon as practical, but
not later than 48 hours after discovering the event.  In your
Regulatory Analysis you estimate that 20 hours would be required to
determine the cause of the event, prepare the report, complete
management review, and make a telephone call to the NRC Operations
Center.  When you consider the 20 hours estimate to be normal working
hours - when individuals are available to question, review etc., it is
doubtful a call to NRC could be made within a 48 hour limit.  Since
this could make licensees susceptible to possible citation for missing
the deadline,  it could cause reporting without complete analysis and
have the result of increasing the number of calls made.  

We are further concerned that this proposed rule is in response to
isolated incidents which occurred recently and received media
attention.  However,  the actual cause of the incident is yet to be
determined.  It is still not known if the contamination was self
caused or caused by an outside party.  Lacking this determination,  we
feel additional regulatory requirements are impulsive and unwarranted.

Thank you for the opportunity to present these comments concerning the
proposed ruling for your consideration



Sincerely,




Asmare Atalay, Ph.D.
Chair, Radiation Safety Committee 
University of Oklahoma





PAUL SKIERKOWSKI                      OOOOO       EEEEEE
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