accelerator RAM - federal facilities

[Lester.Slaback@nist.gov]

A few notes:

1.  I believe the below cited order only relates to environmental
emissions and does not authorize on-site control/inspections.  Hence the
state authority would only relate to releases of that material.
>The next monkey wrench is an
>executive order or the federal facilities
>compliance act which states all federal facilities
>must comply with state and local regulation.

2.  Even though such material is not regulated by NRC unless use of that
material is completely isolated from NRC licensed activities you can
expect that an NRC  inspector will consider exposure control and RAM
control to be within her province for inspection and citation.  So while
certain reg's may not explicitly apply most organizations simply apply the
NRC rules and procedures.  On the other hand if the usage is completely
isolated from NRC controlled activities then only the rules imposed by
your agency apply.  In the case of DoD aqnd DoE they have lots.  Most
other federal agencies leave it to the individual organizations. [note
that there is an executive order on radiation exposure control that
applies that presumably the agency should implement.]

 **** beware of political philosophy - ignore as desired **** 3.  What is
the need to include this material within NRC's umbrella? consistency? (the
hobgoblin of ?? minds.)
If there are no problems with the current scheme (however confusing and
inconsistent it is) why advocate more laws?  If one desired consistency in
the arena of nuclear regulation I suspect this would be well down the list
of items one would target for corrective action!
To avoid Melissa's wrath send to me privately your favorite
inconsistencies and I will summarize a list for RADSAFE (assuming this is
a burning topic among our readers). -- 
the above are the personal musing of the author,
and do not represent any past, current, or future
position of NIST, the U.S. Government, or anyone else
who might think that they are in a position of authority.
NBSR Health Physics
NIST
Gaithersburg, MD 20899
301 975-5810
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Lester.Slaback@nist.gov
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