Re: posting requirements

[Karl Von Ahn <kxv@po.cwru.edu>]

Andy,

This is a suttle issue beyond direct regulations, namely there are
direct license requirements and then there is also the  10 CFR
20.1101(a) requirement for a radiation safety program as it applies to
the licensee.

Anything you put into the radiation safety program (i.e. your rad safety
manual)  is enforcable as part of your license.  The 20.1101(a) program
is to be reviewed at least annually (20.1101c).  Minor changes to the
program that do not alter the content need not be sent to the NRC as an
amendment.  For example, the radiation safety committee can revise the
safety manual section on safe work practices without any regulatory
oversight/amendment.

--
Karl Von Ahn - Asst RSO
Case Western Reserve University
Cleveland, OH
mailto:kxv@po.cwru.edu
(216) 368-2906