Re: Broad Scope Licenses and Exempt/Generally Licensed Devices

[xat@inel.gov (Alden Tschaeche)]

L666783@LMSC5.IS.LMSC.LOCKHEED.COM wrote:
> 
> 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."

I suggest that you ask the General Council of the NRC for an
interpretation of the NRC regulations that would require "comprehensive
procedures" such as the ones requested.  I cannot believe that the NRC
ever intended to require such a thing.  This sounds like an NRC staff
requirement that goes far beyond the regulatory requirements.  If the
NRC really did intend to have such a requirement, it needs to be
codified in the regulations with opportunity for public comment.  Al
Tschaeche xat@inel.gov