Decommissioning Facilities under NRC Bro

[Herrold@uwyo.edu (Jim F. Herrold)]

To all NRC broad-scope licensees (and anyone else interested):

Since my last post I have successfully filed an extension in the 
notification required under the "timeliness rule" on decommissioning our old 
burial site. Step two is to wait for the NRC to develop their "methodology" 
before I file more paperwork. In the meantime, I have some other concerns. 
Last Monday I called Region IV to make sure I had met the 9/15/96 deadline. 
While I had someone from the Licensing Branch on the line I asked these 
questions:

Does the timeliness rule apply to ANY facility in which licensed materials 
had at one time been used, but have not been used for more than two years? 
Does this even apply to facilities approved under a broad-scope license (by 
the Radiation Safety Committee) which are still owned by the licensee? Even 
if the overall purpose of the building or room has not changed (it still is 
a laboratory, it just doesn't have radioactive materials in it right now)?

The answer to every question was yes.

What they are saying is, if you have a lone radioisotope user in a building 
(say, Chemistry) and  that person leaves, and no one else uses licensed 
material in the building for at least two years, you will have to notify the 
NRC and begin decommissioning. My problem with this (my MAIN problem... I 
can think of several others) is: what does this do to the powers delegated 
to the Radiation Safety Committee? They can approve facilities, but the NRC 
has to be involved when labs are closed out for more than two years.  What's 
the purpose of having the Committee, then?

In practice this could become a red-tape nightmare for both licensees and 
the NRC. It scares me. In my opinion, this potential can of worms was not 
what the Timeliness Rule originally set out to address. There are a couple 
options here. Each broad-scope licensee could individually file for an 
amendment allowing their RSC to make decommissioning decisions. OR we could 
all get together and request an exception for cases in which the facility 
remains the property of the licensee and is likely to be used for licensed 
material in the future.

Does anyone else agree? Any other observations? Erick, you out there? In any 
event, I intend to write a letter to Region IV asking for clarification on 
this point.

Jim Herrold, RSO
University of Wyoming
herrold@uwyo.edu