Re: On-Site Transport of Radwaste, exemptions

[slaback@micf.nist.gov]

The NRC Chairman (?Chairperson) has emphasized
a distaste for exemptions, waivers, etc.  This
was emphasized by NRC staff at the last TRTR
meeting.  Their message is
 --make certain proposed rules have any needed
conditions as written.
 --propose revisions to the rules if you feel that
an exception is needed.

my words, not NRCs.....
This might be referred to as the 'Millstone Effect'.
One can also expect a more prescriptive and literal
interpretation of the rules and your license conditions.
'Reasonable' is not likely to be a basis for rule
interpretation in the near term.
'Paranoid' might be a good frame of mind for licensees
for a while.  A regulator would more probably put it as
'walking the straight and narrow'.
Study your federal register carefully.


A little risk adds spice to life.
Lester.Slaback@NIST.gov