Reporting Requirements

["Sue M. Dupre" <DUPRE%PUCC.bitnet@vmd.cso.uiuc.edu>]

Thanks for your help in tracking down the NRC's fax number.  At Paul Skier-
kowski's suggestion, I am posting the text of the letter we're sending to the
NRC:

"We have reviewed the proposed rulemaking which would impose reporting require-
ment on licensees when intentional misuse of licensed material has occurred or
when such intentional misuse cannot be ruled out.  We have the following com-
ments to offer:

1) We agree that the intentional misuse of licensed material should be reported
   to the NRC for those incidents for which it is ESTABLISHED that the misuse
   was intentional.

2) We would find it burdensome to report all events in which the intentional
misuse of licensed material cannot be ruled out.  For instance, there are like-
ly to be occasional instances of contamination in locations such as faucet
handles or refrigerator handles which occur when personnel unintentionally
touch those surfaces with contaminated gloves.  Howver, someone who intention-
ally planned to contaminate other personnel might choose to place contamination
on commonly handled surfaces such as faucet handles or refrigerator handles.

We believe that we would find it nearly impossible to rule out the intention-
al application of contamination in certain locations even though we realize
that contamination in such locations is almost always accidental.  It would be
necessary for us to report a number of such instances a year at the least.
This rulemaking in its current form will require the reporting of common inci-
dents of low-level contamination because those incidents occur in places which
could also figure in plausible scenarios of intentional misuse.

3) We believe that the 48 hours allowed to report events in which intentional
contamination cannot be ruled out is unreasonable and out of proportion to the
severity of the contamination events we might have to report (under the rule-
making as currently proposed.  A reporting time of 48 hours is certainly un-
reasonable in a situation in which a few hundred dpm of contamination on a
refrigerator handle have been found.  The process of ruling out an intentional
act is very likely to take longer than 48 hours.  Many people work in our
larger laboratories and tracking all of them down and waiting for responses
from people who are unavailable or out of town could take several days.

4) Unless this rulemaking is revised to clearly eliminate the type of incident
we describe in item 2) above, the radiation safety program at many institutions
will be subject to very time-consuming and unnnecessary reporting requirements
which will most certainly divert resources away from more important radiation
safety issues. "

That's the basic text of our statement.  This letter is signed by my boss, who
is the RSO and by me, the asst. RSO.

Sue Dupre/Health Physicist/Princeton University
dupre@princeton.edu

For once I can actually say that this letter was reviewed by my management
who appear to support our views!