Re: Occupational and Public Dose

["Wesley M. Dunn" <WDUNN@brc1.tdh.state.tx.us>]

This is the "Standard Disclaimer" found in all/most radiation
regulatory programs (in Texas, it is TRCR 11.13).  It allows the NRC
to communicate ground rules that staff and the licenses can work with
without requiring the official "sign-off" from OGC.  Otherwise,
EVERYTHING would have to officially go through the lawyers and you
would never get your amendment, reg guide, etc...  You do NOT want
this to happen (because it takes forever).  Of course, it would also
mean that people like me wouldn't be able to provide info over
=radsafe=.  But me? I'm covered by TRCR 11.13.  So I can tell you
these things without worrying (too much) about someone trying to build
a court case against me.

Of course the NRC reserves the right to change their mind.  But it
also means that they can fix any mistakes they make while still
letting you know how issues and circumstances will be interpretted.



> Date:          Thu, 30 May 96 12:05:06 -0500
> Reply-to:      radsafe@romulus.ehs.uiuc.edu
> From:          Kent Lambert <lambert@hal.hahnemann.edu>
> To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:       Re: Occupational and Public Dose

> In response to my original post, REHA@ccmail.ceco.com wrote:
> >
> >      NUREG/CR-6204 "Questions and Answers Based on Revised 10 CFR Part 20"
> >      may give some insight here.
>
> The Preface to Questions and Answers ... on the New Part 20 states:
>
> "The answers to questions do not constitute offical legal interpretation, which can only
> be provided by the General Counsel, and they do not reflect official NRC policy as
> approved by the Commission."
>
> This is true even though, "Answers to these questions have been prepared by, and
> reviewed by NRC staff members in the NRC Offices of Nuclear Reactor Regulation, Nuclear
> Material Safety and Safeguards, Nuclear Regulatory Research, Office of State Programs,
> and the five NRC Regional Offices.  The questions and answers also have been reviewed by
> attorneys in the NRC Office of the General Counsel"
>
> So what use are these?  I think that the Q & A was a good thing and the NRC is to be
> commended for publishing these; however, after all of these reviews to say that these
> are not necessarily their view makes the documents virtually worthless.
>

*********************************************************************
Wesley M. Dunn, C.H.P.                     512-834-6688
Deputy Director, Licensing                 512-834-6690 (fax)
(Texas) Bureau of Radiation Control        wdunn@brc1.tdh.state.tx.us
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