ML20129G795
| ML20129G795 | |
| Person / Time | |
|---|---|
| Issue date: | 11/23/1981 |
| From: | Nussbaumer D NRC OFFICE OF INTERNATIONAL PROGRAMS (OIP) |
| To: | Gordon L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20129G101 | List: |
| References | |
| NUDOCS 9610300207 | |
| Download: ML20129G795 (1) | |
Text
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NOV 22 21 HEMORANDUN FOR: Len Gordon FCTC Division of Fuel Cycle &
- taterial Safety, IMSS FRON
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Donald A. Nussbaumer, Assistant Director for State Agreements Program I office of State Programs
SUBJECT:
AGENDA ITEM FOR 10WG MEETING '
/
At the most recent All Agreement States meeting, the States made the following comment:
"The IRC should reevaluate the G.L. device distribution licensing concept and seriously consider rescinding the G,L. concept of licensing gauges."
The States also reported they have seen a number of incidents involving misuse of G.L. devices. I believe it would be 4
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beneficial to include this matter as a discussion item of the next 10WG reeting.
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I Donald A. Plussbaumer Assistant Director for State Agreements Program Office of 9thie Programs Distribution:
J0lubenau SA R/F Dir. R/F NMSS File (fc)
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9610300207 960830 r PDR REVGP NRCRDRG F PDR o
- - s.
STATE OF NEW YORK
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DEPARTMENT OF LABOR DIVISION OF SAFETY AND HEALTH Radiological Health Unit
. Building #12, Room 457 State Office Building Campus Albany, NY 12240 i
November 13,1995 Joel Lubenau U.S. Nuclear Regulatory Commission Mail Stop T-8F5 Washington, DC 20555
Dear Joel:
- I would like to propose a strawman for the next meeting of the working group on control of sealed sources.
Premises: 1) " General Licensing" of scaled sources / devices is a basically flawed concept that tries to establish a middle ground between exemption and specific licensing. It fails because it results in too little control of hazardous sources, and invites over-regulation of sources that do not pose a realistic hazard if lost or stolen.
- 2) As long as we continue to combine sources with such disparate comparative hazards in one regulatory class, we will not solve the
- current problems. Any increase in regulatory oversight will simply shift the imbalance a bit - continuing under-regulation of the hazardous sources and increasing over-regulation of the others.
4 Solution: 1) Divide current " generally licensed" sources / devices into those that should be specifically licensed and those that should be exempted.
- 2) As a starting point I would suggest these guidelines:
a) Specific licerises - gauges continuing millicurie quantities of gamma emitters, gas chromatograph sources.
b) Exemptions - self-luminous lights, static eliminators, liquid scintillation counter sources, small beta sources.
These are not comprehensive lists, but a starting point for discussion.
4L, c 'll% & LL g pp_
y .
- i 2-This would not eliminate all problems. Some exempted sources might still set-off i sensitive alanns, but so does out-patient waste in municipal trash. However, it should prevent the smelting of sources big enough to cause major problems, and it will restore sanity to our regulatory approach.
Sincerely, l
Rita Aldrich RA/fdh Principal Radiophysicist l
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CNTRINTG.SSD ,
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