NRC coverage of Xrays, accelerators

[Slaback@micf.nist.gov]

If the accelerator or x-ray work is not fully separated from the NRC controlled work, then NRC 

will issue citations where that work is not in compliance with NRC rules.  Obviously the 

facility's license does not directly address those non-AEC_Act operations, but the results of 

those operations (staff exposure, emissions, access control) are considered as if they are NRC 

licensed facilities.  I have had NRC inspectors audit (inspect) actual accelerator facilities that 

had no licensed activity but were in the same building as licensed operations.

In agreement states this is less ambiguous because the same regulatory agency regulates both.

Also, some of this coverage is under the umbrella of the NRC-OSHA agreement by which NRC enforces 

OSHA rules at licensed sites.  NRC has been particularly concerned with fire safety issues in 

recent years since that directly impacts radioactive material control.

Of course, none of this is a real concern since we all conduct our operations in full compliance 

with all federal and state laws.