Broad Scope Licenses and Exempt/Generally Licensed Devices

[<L666783@LMSC5.IS.LMSC.LOCKHEED.COM>]

Hello all.

I recently received a request for more information from our regulatory
agency regarding our type A broad scope license renewal/amendment. They
make a statement, "Individuals in a broad scope license may not operate
under individual exempt or general license status unless the company
submits comprehensive procedures to be used to segregate uses of
radioactive materials procured under exempt/general status from those
obtained under the broad scope program."

Why is this? Exempt/generally licensed devices are designed
for/distributed to individuals who have no formal training in radiation
safety, and no radiation safety program. Why, as a broad scope licensee,
should we bear the additional administrative burden for something that
is a non-hazard? Do we need to control our H-3 exit signs the same way
we control our 2300 Ci Co-60 irradiator? Are the exempt products,
concentrations, and quantities no longer exempt, and their use has to be
approved by our Radiation Safety Committee?

What are your thoughts on this? How are you handling this? My license
renewal application will have to be drastically changed to account for
exempt/general license devices.

Donald P. Mercado, O/47-20, B/101      PROFS Nickname: DMERCADO
Radiation Safety Officer            Email: Don.Mercado@lmco.com
Lockheed Martin Missiles & Space            Tel. (408) 742-0759
Sunnyvale, Ca 94089                         Fax. (408) 742-0611