A question frequently asked is: "Because I am a specific licensee, do I have to treat radioactive materials distributed to me by an exempt distribution licensee, which I have been handling as an exempt person, as if they are subject to my specific license?"
Exemptions from licensing requirements are based primarily on the Nuclear Regulatory Commission's determination that the quantity or use of certain radioactive materials will not constitute an unreasonable risk to public health and safety. 10 CFR 30.18 was enacted, at least in part, based on staff's determination that the risk to the public from radiation exposure is minimized when restrictions are placed on the amount of radioactive material that can be initially distributed at any one time, as specified in 10 CFR 30.71, Schedule B. Section 32.19 allows an exempt quantity distribution licensee to transfer up to 10 exempt quantities per transaction to persons exempt from licensing.
Once a product, such as a check source, which incorporates the materials in the specified exempt quantities, has been distributed pursuant to 10 CFR 32.18, persons receiving and using the source are not subject to licensing controls or restrictions. In addition, although exempt quantities, such as found in tissue samples, may be transferred from one lab (exempt person) to another lab (exempt person), the exemption in 10 CFR 30.18 does not authorize, for purposes of commercial distribution, the production, packaging, repackaging, or transfer of byproduct material, nor the incorporation of byproduct material into products intended for commercial distribution, except as authorized by a specific license.
The answer is a conditional "no" because the specific licensee can continue to receive and treat the material distributed by an exempt distribution licensee, as a person exempt from licensing, provided the material is received and maintained as exempt material at all times, and the person's specific license does not contain a condition to the contrary. However, regardless of any license condition or lack thereof, a licensee must take dose from this material into account, even though it is unlicensed, in determining total dose (per 10 CFR Part 20) to workers and members of the public.
Although the provisions of 10 CFR 30.18 exempt any person from the requirements for a license and from the regulations in 10 CFR Parts 30-34 and 39 for exempt quantities, other parts of the Commission's regulations may be applicable to the activities of specific licensees involving the use of exempt quantities (e.g., certain requirements found in Part 20). For example, because 10 CFR 30.18 is silent regarding specific licensee activities governed by Part 20 regulations, Part 20 is applicable. And, because Part 20 is applicable in determining both public and occupational doses from unlicensed material as well as licensed materials, exempt materials must be considered when a licensee calculates such doses.
In summary, a non-licensee possessing radioactive material exempt under 10 CFR 30.18 has no regulatory obligations. However, a licensee must take exempt sources into account under its radiation safety program based on the licensee's determination of total dose to workers and members of the public pursuant to Part 20.
(Contacts: Anthony S. Kirkwood, NMSS, 301-415-6140, e-mail: email@example.com; Maria E. Schwartz, OGC, 301- 415-1888, e-mail: firstname.lastname@example.org)
The U.S. Nuclear Regulatory Commission (NRC) has used the criteria on public dose limits and as low as is reasonably achievable requirements in 10 CFR Part 20 to establish limits in Appendix B of Part 20 on the amount of radioactivity, in gaseous and liquid releases, that may be released from a licensed facility to the environment. However, unlike the regulations applicable to gaseous and liquid releases, there are currently no specific criteria in Part 20 governing releases of solid materials by licensees. The Commission recently amended its regulations in Part 20 (Subpart E) to establish criteria for unrestricted use of facility structures and lands at a decommissioned site. However Subpart E is focused on protection of persons entering and using decommissioned structures and lands at a site after a nuclear facility terminates its NRC license, and does not address release of solid materials.
Solid materials include metals, building concrete, onsite soils, equipment, and furniture, etc., that are present at, and/or used in, licensed nuclear facilities during routine operations. Most of this material will have no radioactive contamination, although some materials can have radioactive contamination either on their surfaces or distributed within their volumes. The amount of contamination that a material has, if any, depends largely on the type of licensee involved and its location in a facility.
Even though NRC does not currently have specific criteria in Part 20 covering release of solid materials, licensees have made, and will likely continue to make, requests for release of solid material when it becomes obsolete or defective or when their facilities are decommissioned. NRC currently evaluates these requests on a case-by- case basis using either Regulatory Guide 1.86, "Termination of Operating Licenses for Nuclear Reactors," or other case-specific criteria, including license conditions, NRC Branch Technical Positions, etc.
Case-by-case technical reviews, although protective of public health and safety, can cause inconsistencies and confusion. With the potential for increased licensee requests for release of solid materials as more facilities near decommissioning, the Commission, on June 30, 1998, directed the staff to consider rulemaking to establish a dose-based standard for clearance so that licensee considerations of, and NRC review of, disposition of slightly contaminated solid materials are conducted in a consistent manner that protects public health and safety. (Note that the more broad term "release of solid materials" is being used in this newsletter and in other current staff documents related to this rulemaking rather than "clearance"; this is because the international reference to clearance is generally "release for unrestricted use," whereas the staff's current approach is to also consider restricted use of solid materials.) The Commission also directed the staff to include an opportunity for enhanced public participation, including use of NRC's Internet home page to solicit comments. The Commission further indicated that the staff should: (1) not develop a detectability standard but rather focus on codified levels above background, for unrestricted use, that are adequately protective of public health and safety; (2) base standards on realistic scenarios of health effects from low doses; and (3) develop a comprehensive standard applicable to all metals, equipment, and materials--however if problems that would delay completing the effort arise in certain categories of materials, then a decision could be made to narrow the scope.
In responding to the Commission's direction, NRC staff is currently involved in three principal efforts. These are preparation of an issues paper, the holding of facilitated public meetings, and development of additional technical bases.
Issues paper--An issues paper has been prepared that describes issues and alternatives related to release of solid materials. It is planned that the issues paper will be published, for public comment, in the Federal Register in June 1999. The intent of this paper is to foster discussion about these issues and alternatives before any rulemaking to set standards would begin. The issues paper will also be made available for electronic submittal of comments on NRC's external website when the Federal Register notice (FRN) is published. It is planned that the comment period on the issues paper will last through the end of the facilitated public meetings in November 1999. The issues covered in the paper include alternative courses of action that should be considered and what factors should be considered in making decisions on the alternatives; whether restricted use is a reasonable alternative; and what materials should be covered by a rulemaking.
Facilitated Public Meetings--As directed by the Commission, NRC staff plans to enhance public participation by conducting workshops for interested parties before any rulemaking would begin. Although not seeking consensus on the issues, the workshops are intended to identify relevant issues, exchange information on these issues, identify underlying concerns and areas of disagreement, and, where possible, identify approaches for resolution. Facilitated public meetings will be convened in four locations (Chicago, Atlanta, San Francisco, and Washington, DC) from August through November 1999. Facilitation of the workshops is intended to ensure that there will be broad participation in the meetings to include a range of groups and a variety of viewpoints, and to aid in conducting the meetings so that those viewpoints are heard. The dates and locations of the workshops will be announced in the FRN published for the issues paper, as well as on NRC's website.
Technical Basis Development--In support of any rulemaking conducted on release of solid materials, NRC would evaluate the environmental impacts and cost benefit of rulemaking alternatives. Specifically, NRC would evaluate the implications of a rule with regard to the National Environmental Policy Act. Such an evaluation would consider both radiological and non- radiological impacts associated with alternative dose criteria for release of materials for unrestricted and restricted use. In addition, NRC would prepare a Regulatory Analysis to evaluate costs versus benefits of a rule consistent with Executive Order 12291 and the Commission's regulatory analysis guidelines in NUREG/BR-0058. NRC would also publish regulatory guidance to provide licensees with information on how to demonstrate compliance with the regulation. Guidance would be provided on, for example, measurement methods for low concentrations of volumetrically contaminated material that may exist in various equipment and material types, shapes, and sizes that are anticipated to be available for release. As a first step in developing the technical basis, NRC has issued a draft report for comment (NUREG-1640) that provides a method for determining potential doses to individuals from a wide range of potential scenarios by which members of the public could come in contact with material that had been released for unrestricted use (64 FR 14952, March 29, 1999).
(Contact: Frank Cardile, 301-415-6185, e-mail: email@example.com)
On March 2-3, 1999, the Nuclear Energy Institute (NEI) sponsored a meeting between representatives of the dry storage industry and staff from the U.S. Nuclear Regulatory Commission's (NRC's) Spent Fuel Project Office (SFPO) to provide an open forum for discussions of technical issues that are common to the storage and transport of spent fuel, including lessons learned. Approximately 150 individuals attended representing utilities, vendors, contractors, and fabricators.
To encourage open and candid discussions, the meeting was conducted in a workshop format. Opening remarks were made by Lynnette Hendricks, Director, Plant Support, Nuclear Generation Division, NEI, and E. William Brach, Director, SFPO, NRC. The major topics discussed were application and use of standard review plans (SRPs), dry cask storage lessons learned, use and application of interim staff guidance (ISG), technical specifications, 10 CFR Part 72 rulemaking, American Society of Mechanical Engineers (ASME) Code issues, and inspection observations.
During the meeting, SFPO management discussed industry's and staff's progress and expectations in facilitating a smooth licensing process. Issues discussed included:
• Staff will continue to apply lessons learned from completed casework to facilitate both technical and process improvements.
• Quality of applications has improved significantly. However, several areas require continued improvement, including ASME Code use, identification of SRP deviations, and specification of appropriate features on 10 CFR Part 71 drawings.
• There should be implementation of improved standardized technical specifications.
• The staff requested that any changes in application schedules be communicated promptly, so that resources can be efficiently used.
• Applicants should bring unique designs and design features to the staff's attention early in the application process so that appropriate resources can be made available for a timely review.
In addition, SFPO management stated that SRPs serve as guidance to our reviewers and are not the only way to meet regulatory requirements, and that the ISGs are used as interim guidance until SRPs are updated. The industry stated that issuance of ISGs has been a significant benefit to the vendors, and the industry is anxious to work with the staff to further clarify additional issues. For example, the industry stated that it has additional questions on ISG-3, "Post Accident Recovery & Compliance with 10 CFR 72.122 (Il)"; ISG-4, "Cask Closure Weld Inspections"; and ISG-5, "Normal, Off-Normal, and Hypothetical Accident Dose Estimate Calculations for the Whole Body, Thyroid, and Skin." The industry expects to resolve these issues with the staff in a timely manner.
The meeting included a round-table discussion period wherein NRC staff responded to questions relating to certain specific topics deemed important by the industry. The topics included: ASME Code initiatives, design margin, uniformity of review, fission gas release fraction, and burnup credit. The industry presented an initiative it is pursuing to provide a standard licensing approach regarding ASME Code requirements. The industry reported that ASME Code Section III, Division 3, "Subgroup on Containment Systems for Spent Fuel and High Level Waste Transport Packagings (SG NUPACK)," has modified its scope to include storage canister construction rules. The rules will cover "confinement boundary" items only and will be placed in a new Subsection of Division 3. The confinement boundary will be stamped "SP." Also, the industry reported that on February 23, 1999, the SG NUPACK voted to expedite the new Welding Committee rules on a fast-track schedule, with an expected first reading of the new rules in May 1999. The SG NUPACK anticipates publishing the new rules within 18 months and making them effective 6 months after publication.
The Workshop was continued on March 3, 1999, with SFPO staff and industry discussing development of a plan to resolve open issues. The industry and NRC have agreed to schedule future meetings to continue the dialogue on a number of issues. The following is a list of ISGs that are currently being developed and that will be provided to industry for comment soon: (1) fuel assemblies with burnup greater than 45,000 GWD/MTU; (2) rod buckling; (3) burnup credit; and (4) ASME Code deviations.
To expedite the cask certification process, the industry agreed to pursue the following initiatives and provide clarification and technical rationale:
1. Develop conservative source terms for fission products release;
2. Develop rationale for the demarcation between credible and non-credible accident scenarios;
3. Develop approaches for application of probabilistic risk approach (PRA) in licensing submittals--the staff stated at the workshop that it encourages the use of PRA to provide for a risk-informed approach in the licensing process.
Because a number of issues were raised that require additional time for resolution, future meetings will be scheduled to discuss and reach consensus on these topics:
• Standardized Technical Specification-- meeting tentatively scheduled for April 20, 1999, in the NRC Auditorium;
• ASME Code activities;
• Classification of damaged fuel--NEI to provide additional information;
• Lift heights (10 CFR Part 50 vs. Part 72 requirements)--industry to provide more information.
Other issues that were considered important were discussed at the meeting. However, these issues were regarded as issues that could be addressed further, at some time in the future. One issue relates to the integration of Parts 71 and 72 requirements: specifically, the discrepancy between the licensing periods of transportation (5 years) and storage casks (20 years) and potential impacts they may have on the licensing process. Another issue relates to how the SFPO can logistically integrate the industry's request to be allowed to make comments on future ISGs before they are applied. In this regard, NEI accepted the responsibility to compile industry comments on the proposed ISGs and submit them to the staff by March 12, 1999. No regulatory decisions were requested or made. No proprietary information was disseminated.
(Contact: Dennis Reid, 301-415-8556; e-mail: firstname.lastname@example.org)
NOTE: U.S. Nuclear Regulatory Commission (NRC) contacts may be reached by mail at the U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.
"Conformance to National Policies For Access to and Protection of Classified Information," 64 FR 15636, April 1, 1999. Contact: James J. Dunleavy, 301-415-7404, e-mail: email@example.com.
"Radiological Criteria for License Termination of Uranium Recovery Facilities," 64 FR17506, April 12, 1999. Contact: Frank Cardile, 301-415-6185; e-mail: firstname.lastname@example.org; Elaine Brummett, 301-415-6606, e-mail: email@example.com.
"Elimination of Reporting Requirement and 30-Day Hold in Loading Spent Fuel After Preoperational Testing of Independent Spent Fuel Storage or Monitored Retrievable Storage Installations, 64 FR 17510, April 12, 1999. Contact: Gordon Gundersen, 301-415-6195, e-mail: firstname.lastname@example.org.
"Revision of Fee Schedules; 100% Fee Recovery, FY 1999," 64 FR 15876, April 1, 1999. Contact: Glenda Jackson, 301-415-6057, e-mail: email@example.com.
"Energy Compensation Sources for Well Logging and Other Regulatory Clarifications," 64 FR 19089, April 19, 1999. Contact: Mark Haisfield, 301-415-6196, e-mail: firstname.lastname@example.org .
"Notice of Availability, Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Self-Shielded Irradiator Licenses," NUREG-1556, Vol. 5, 64 FR 11073, March 8, 1999. Contact: Sally L. Merchant, 301-415-7874, e-mail: email@example.com.
"Policy and Procedure for NRC Enforcement Actions; Interim Enforcement Policy for Generally Licensed Devices Containing Byproduct Material (10 CFR 31.5)," 64 FR 11508, March 9, 1999. Contact: James Lieberman, 301-415-2741, e-mail: firstname.lastname@example.org.
"Notice of Availability, Consolidated Guidance About Materials Licenses: Program-Specific Guidance About Commercial Radiopharmacy Licenses," NUREG-1556, Vol. 13, 64 FR 11509, March 9, 1999. Contact: Sally L. Merchant, 301-415-7874, e-mail: email@example.com.
"State of Ohio: NRC Staff Assessment of a Proposed Agreement Between the Nuclear Regulatory Commission and the State of Ohio," 64 FR 12187, March 11, 1999. Contact: Richard L. Blanton, 301-415-2322, e-mail: firstname.lastname@example.org.
"Notice of Availability, Standard Review Plan for the Review of a License Application for the Tank Waste Remediation System Privatization Project," NUREG-1702, 64 FR 13613, March 19, 1999. Contact: Michael Tokar, 301-415-7251, e-mail: email@example.com.
"Notice of Availability, Radiological Assessments for Clearance of Equipment and Materials From Nuclear Facilities," NUREG-1640, 64 FR 14952, March 29, 1999. Contact: Robert A. Meck, 301-415-6205, e-mail: firstname.lastname@example.org.
(General Contact: Paul F. Goldberg, NMSS, 301-415-7842, e-mail: email@example.com)
Detailed information about these enforcement actions can be accessed via the Nuclear Regulatory Commission (NRC) homepage [http://www.nrc.gov/]. Click on "Nuclear Materials," then "Enforcement," then "Enforcement Actions Issued." Cases are listed alphabetically. To access the complete enforcement action, click on the highlighted text following the name of the case.
University of Medicine and Dentistry of New Jersey, Newark, New Jersey, EA 98-536. A Notice of Violation at Severity Level III was issued based on three examples of failure to secure licensed materials in an unrestricted area.
United States Enrichment Corporation, Bethesda, Maryland, EA 98-156. A Confirmatory Order Modifying Certificate was issued for the Paducah Gaseous Diffusion Plant to confirm commitments to install seismic modifications required to bring the facility back into compliance with the Safety Analysis Report.
State of Hawaii Department of Transportation, Honolulu, Hawaii, EA 98-237. A Notice of Violation at Severity Level III was issued based on two instances of failures to adequately secure gauges containing licensed material from unauthorized removal or access.
Materials Testing Lab., Inc., New Hyde Park, New York, EA 98-437. A Notice of Violation was issued at Severity Level III based on failures to: secure licensed material, which resulted in loss of a gauge; review the radiation safety program annually; perform surveys; mark and label packages containing hazardous material transported on public highways; train hazmat employees; observe license possession limits; and maintain required records.
Southern Processing Enterprises, Beaver, West Virginia, EA 98-495. A Notice of Violation was issued for a Severity Level III violation involving: (1) unauthorized removal of fixed gauges, and (2) failure to properly transfer the gauges. The gauges were inadvertently transferred to facilities that were not licensed to possess them.
Special Testing Laboratories, Inc., EA 98-521. A Confirmatory Order was issued based on the licensee's deliberately directing untrained individuals to use moisture density gauges, not providing dosimetry, and making false statements to NRC.
Jose M. Colon-Vaquer, Manati, Puerto Rico, EA 98-184. A $4400 civil penalty was assessed for a Severity Level II problem that involved two misadministrations. A Notice of Violation was also issued for use of licensed material when the license was expired, and a number of other violations that collectively demonstrated lack of oversight.
Nuclear Pharmacy of Idaho, Inc., Boise, Idaho, EA 98-363. A Notice of Violation was issued at Severity Level III based on a contamination event at the licensee's facility. The violations included failures to: (1) perform an evaluation to determine dose to the skin; (2) limit the dose to the skin of the individual involved; and (3) submit a written report within 30 days.
Sinai Hospital, Detroit, Michigan, EA 98-523. A Notice of Violation was issued for a Severity Level III violation involving the licensee's quality management program. The violations involved failures to: (1) check dose calculations within 3 working days; (2) compare the written directive with the calculations each day of treatment; and (3) perform weekly chart checks to verify that treatment parameters were in accordance with the written directive.
Randall Almon, EA 98-061. A Confirmatory Order Prohibiting Involvement in NRC-Licensed Activities was issued based on deliberate inaccurate statements made to NRC and the prime contractor concerning internal welding of a spent fuel cask. The Order prohibits the individual from engaging in NRC-licensed activities for a period of 5 years.
March Metalfab, Inc., Hayward, California, EA 98-529. A Confirmatory Order Prohibiting Involvement in NRC-Licensed Activities was issued based on deliberate inaccurate statements made to NRC and the prime contractor concerning internal welding of a spent fuel cask. The Order prohibits the company from engaging in NRC-licensed activities for a period of 5 years.
Brian K. Rogers, IA 98-062. A Confirmatory Order Prohibiting Involvement in NRC-Licensed Activities was issued based on deliberate inaccurate statements made to NRC and the prime contractor concerning internal welding of a spent fuel cask. The Order prohibits the individual from engaging in NRC-licensed activities for a period of 5 years.
NDT Services, Inc., Caugas, Puerto Rico. An Order Modifying License was issued based on the licensee's failure to provide adequate security and control of radiography devices. The Order required the licensee to take immediate security measures, and then remove the devices to a temporary storage location and transfer the licensed material to an authorized recipient within 30 days.
Marshall Miller & Associates, Bluefield, West Virginia, EAs 97-444 and 98-313. An $8800 civil penalty was assessed based on: (1) failure of the Radiation Safety Officer to perform the minimum required duties; (2) conduct of logging activities by eight individuals who had not received training in the amount or manner as required; (3) failure to conduct surveys; (4) failure to keep a calibrated and operable radiation survey instrument at a temporary job site; (5) failure of a well logger to visually check for defects before each use of the equipment; and (6) failure to lock, and physically secure a source.
(Contact: Joseph DelMedico, OE, 301-415-2739, e-mail: firstname.lastname@example.org)
Note that these are only summaries of U.S. Nuclear Regulatory Commission (NRC) generic communications. If one of these documents appears relevant to your needs and you have not received it, please call one of the technical contacts listed below. The Internet address for the NRC library of generic communications is www.nrc.gov/NRC/GENACT/GC/index.html. Please note that this address is case-sensitive and must be entered exactly as shown.
IN 99-01, "Deterioration of High-Efficiency Particulate Air (HEPA) Filters In A Pressurized Water Reactor Containment Fan Cooler Unit," was issued on January 20, 1999. This notice was issued to all reactor and fuel cycle facilities to alert them to previously unknown limitations on service life and service conditions for HEPA filters used in ventilation systems. Contacts: Richard S. Barkley, RI, 610-337-5065, e-mail: rsb1@ nrc.gov; John J. Hayes, NRR, 301-415-3167, e-mail: email@example.com; John P. Segala, NRR, 301-415-1858, e-mail: firstname.lastname@example.org; Jerry Carter, NRR, 301-415-1153, e-mail: email@example.com; Bill Troskowski, NMSS, 301-415-8076, e-mail: firstname.lastname@example.org.
IN 99-02, "Guidance To Users on the Implementation of a New Single-Source, Dose-Calculation Formalism and Revised Air-Kerma Strength Standard For I-125 Sealed Sources," was issued on January 21, 1999. This notice was issued to all medical licensees authorized to conduct brachytherapy treatments to alert them to changes affecting I-125 sealed source dosimetry. These changes must be properly implemented to avoid unintended differences in doses delivered to patients. Contact: Robert L. Ayres, NMSS, 301-415-5746, e-mail: email@example.com.
IN 99-03, "Exothermic Reactions Involving Dried Uranium Oxide Powder (Yellowcake)," was issued on January 29, 1999. This notice was issed to all uranium recovery licensees to alert them to recent incidents involving strong exothermic reactions that occurred while packaging uranium oxide powder precipitated with hydrogen peroxide. Contacts: Douglas S. Simpkins, RIV, 817-860-8220, e-mail: firstname.lastname@example.org; D. Blair Spitzberg, RIV, 817-860-8191, e-mail: email@example.com; John H. Lusher, NMSS, 301-415-7694, e-mail: firstname.lastname@example.org.
IN 99-04, "Unplanned Radiation Exposures To Radiographers Resulting From Failures To Follow Proper Radiation Safety Procedures," was issued on March 1, 1999. This notice was issued to all industrial radiography licensees to inform them of several recent incidents and remind them of the risk of high exposures from radiography equipment. Contact: J. Bruce Carrico, NMSS, 301-415-7826, e-mail: email@example.com.
IN 99-05, "Inadvertent Discharge Of Carbon Dioxide Fire Protection System and Gas Migration," was issued on March 8, 1999. The notice was issued to all nuclear reactors and all fuel cycle facilities to alert them to recent incidents and inform them of personnel safety hazards and operational complications associated with the discharge of a carbon dioxide fire protection system. Contacts: Beth Korona, RI, 860-447-3170, e-mail: firstname.lastname@example.org; Frank Arner, RI, 610-337-5194, e-mail: email@example.com; Chuck Petrone, NRR, 301-415-1027, e-mail: firstname.lastname@example.org; Peter S. Lee, NMSS, 301-415-8111, e-mail: email@example.com.
IN 99-06, "1998 Enforcement Sanctions As a Result of Deliberate Violations of NRC Employee Protection Requirements," was issued on March 19, 1999. This notice was issued to all licensees to remind them and their employees of the sanctions that could result from deliberately violating NRC requirements in the area of employee protection. Contact: Michael Stein, OE, 301-415-1688, e-mail: firstname.lastname@example.org.
IN 99-07, "Failed Fire Protection Deluge Valves and Potential Testing Deficiencies In Preaction Sprinkler Systems," was issued on March 22, 1999. This notice was issued to all nuclear reactors and all fuel cycle facilities to alert them to test methodologies for fire protection deluge valves that may not adequately demonstrate valve operability. Contacts: Mark H. Salley, NRR, 301-415-2840, e-mail: email@example.com; William F. Burton, NRR, 301-415-2853, e-mail: firstname.lastname@example.org; Robert Caldwell, RII, 334-899-3386, e-mail: email@example.com.
IN 99-08, "Urine Specimen Adulteration," was issued on March 26, 1999. This notice was issued to all power reactors and all licensees authorized to have formula quantities of strategic special nuclear material to inform them of a recent attempt by an employee to circumvent fitness-for-duty testing. Contacts: Ronald J. Albert, NRR, 301-415-3216, e-mail: firstname.lastname@example.org; Dennis Gordon, NRR, 301-415-1162, e-mail: email@example.com.
IN 99-09, "Problems Encountered When Manually Editing Treatment Data On the Nucletron Microselectron-HDR (New) Model 105.999," was issued on March 24, 1999. This notice was issued to all medical brachytherapy licensees to alert them to the potential for patient misadministrations from inadvertent changes to source step size when editing dwell time data. Contact: Robert L. Ayres, NMSS, 301-415-5746, e-mail: firstname.lastname@example.org.
(General Contact: Kevin Ramsey, NMSS, 301-415-7887, e-mail: email@example.com)
NMSS Licensee Newsletter Editor
Office of Nuclear Material Safety
Two White Flint North, Mail Stop 8-A-23
U.S. Nuclear Regulatory Commission
Washington, D.C. 20555-0001
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