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NRC - security of RAM -April 24th Memorandum
After reading the Guidance Memo, I guess I have a few questions:
I am not absolutely clear to what an "aggregate quantity" refers - I assume
this is any one container in a given lab. What if there is more than one
unsecured container in that one lab? [a liquid and a solid waste container
for example] Each is a separate "aggregate quantity", right? [Or if a waste
container measures more than 2mrem/hr at 30 cm. is it only then an
"aggregate quantity"?- see minor violation section.]
"Minor violations" - I assume these would be less than Severity Level IV,
and there would be no NOV?
The next to the last paragraph says no enforcement should be taken...for
quantities less than Appendix C.
So these are not violations, no NOV. I was not clear that [according to
NUREG/CR 6204] "at the present time" 20.1801 and 1802 "do not apply
to amounts less " than Appendix C. "When the guidance is withdrawn,
this EGM will be modified to include security issues involving quantities
less than Appendix C as minor violations." I'm confused. Maybe I just need
to read this a few more times.
Any thoughts or clarification would be helpful, using Radsafe or privately.
THANKS
Aggie
Agnes.Barlow@Yale.edu
203 737-2142
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