Why does the NRC consider the current requirements inadequate for GLDs that contain quantities of radioactive material above 1/10 of the IAEA’s Category 3 threshold values?
Under the current regulations, a general licensee is not subject to the same regulatory controls (i.e., pre-licensing review, inspection, and safety and security requirements) as specific licensees that possess similar quantities of radioactive material. Placing certain generally licensed devices under the specific licensing process would subject them to aspects of oversight beyond those associated with the general licensing process, including the license application and review process, security requirements, and an increased number of routine inspections.
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