Re: Broad Scope Licenses and Exempt/Generally Licensed Devices

[steven t hand <hand@wam.umd.edu>]

In our state regulations under source material, this applies and is
in writing distinguishing the two operations between general and 
specific.  I cannot find one for byproduct, however we do license all
material at our "site."  Does our license say that radioctive material
at your specific "site" must be under your control ?

steve at umcp
shand@wam.umd.edu

On Wed, 29 Jan 1997, Alden Tschaeche wrote:

> 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
>