Re: Broad Scope Licenses and Exempt/Generally Licensed Devi

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

I'd probably question what "comprehensive" means in this statement, 
but the key would be how the licensee keeps the GL material separate 
from the SL material.  The problem with exempt sources is maintaining 
evidence that they really are exempt (e.g., distributed under an NRC 
"E" license).  So make sure you have a comprehensive inventory 
program for ALL SL material.  If you keep a centralized GL inventory 
(I'd advise it), keep it clearly separate from the SL inventory.

The RSO needs to be able to definitively state "This is under the 
Broad License; This is GLed; This is Exempt".  Note that GL and 
exempt sources are required to be labeled as such, so life should be 
reasonably easy.

Another nice tack is to say "please explain to me what the difference 
is between GL, SL and exempt sources and how they are licensed?"  

This is a personal opinion and should not be confused with NRC or 
California policies and/or interpretations.  You should be holding 
any necessary conversations with Calif, since they are the ones you 
have to make happy.  

Wes

> Date sent:      Wed, 29 Jan 97 10:58:49 -0600
> Send reply to:  radsafe@romulus.ehs.uiuc.edu
> From:           <L666783@LMSC5.IS.LMSC.LOCKHEED.COM>
> To:             Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:        Broad Scope Licenses and Exempt/Generally Licensed Devices

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