Re: NRC Release Criteria

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

Bob,

The criteria pertain to anyone holding an NRC (medical) license.  
NRC does not have any jurisdiction over non-NRC licensees.  

So, in a non-Agreement State, by-product material would follow under 
the NRC regulations.  Accelerator produced material would be 
regulated according to the state regulations.  The NRC regulations 
also have no effect in an Agreement State unless and until the 
Agreement State modifies its regulations.   NRC usually allows up to 
3 years for Agreement State programs to adopt "compatible" 
regulations (e.g., NRC determines national standards are necessary).  
This still doesn't help non-agreement state licensees.

So if you like an NRC regulation that your regulatory agency does not 
currently authorize, you either need to get an amendment to your 
license (sometimes doable, sometimes not) or you have to wait until 
your regulations are changed.  Whether you can petition for a rule 
change or otherwise speed up the process depends on your state 
regulations and/or laws.  Talk to your regulator for further 
information.

Wes

> Date sent:      Thu, 17 Apr 97 12:27:31 -0500
> Send reply to:  radsafe@romulus.ehs.uiuc.edu
> From:           CMMI012 RSO <rso.gscancer@worldnet.att.net>
> To:             Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:        NRC Release Criteria

> Hello Everyone,
> Given the fact that the new NRC criteria for the release of patients 
> administered radioactive material (NUREG-1492) will come into effect on 
> 5/29, what will be the resopnisibility of non-agreement state regulators 
> (e.g. New Jersey)? Can/will they have any "jurisdiction" over the 
> release criteria, or do NRC regs take precedence in non-agreement 
> states? This is probably going to be a "hot" topic, and probably 
> deserves some discussion. Will non-agreemnet states have to follow NRC 
> guidelines as a matter of fact, or do the appropriate state agencies 
> have to be petitioned by individual organizations, or need to "give 
> their blessings"? Any help/discussion would be greatly appreciated.
> Bob Dunn
> 
> 
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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
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