ML19219A654
| ML19219A654 | |
| Person / Time | |
|---|---|
| Issue date: | 01/23/1981 |
| From: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | EMVSUPER |
| References | |
| NUDOCS 8102260324 | |
| Download: ML19219A654 (1) | |
Text
s
/
l i-
}
pn y
g*
a
% i e'.,.
, nm,
-m s
- m... c, c.,
g y., -
i
~
- i../-
}
,3
-.s5
- U....,l' l
.. o%
.3 3
s n gj
?,,,, --
w
-e-
. 3 i b,,
'?
1 W
P. O. Eox 607 S N(L J Superintendence Corpeny (Canadel LT S
.h-L L
Ik "tEB066M " D Fairbanks, U M 01 in.-g 2,
arx s
u.s g,m q
,x,,.C,u a.c. +-,vo-27a 9-01
~
7 2
9
.s\\
N Chi lhD w e..a., c.
- 1. -
II.2 EnClCEEC inTCr".3t1Cn n0!100 t.O.
51-L 4. if ICP12TCOC T C P VC u r i nT O rN'.1 Cn EnO CJ;cance in Ine reCulrenents Tor 53~9 tr2n5CCT!31Cn anC Carr1ECe OT T2 Ci CCTE""1C CSVI CL'S.
IT IC372 3re P"Y UL'C501CnS relEISO IO Inl5 TOIlCE.
pietre centact tnis cTTice.
...~w,. 4Jg w
, + " ^
'^*q'
_ l 4 W
..'p._..
$ -[
_n; eiken g.
tn0105Ure5*
3, T, r e., s, 2
t u i s a,
..vo..,.;
- v.
-.+
s
.-,-r
,9 L 4 b e I
- }
ne.e,',,,.. v 1 y~.
A....w a
- w y
- 4.,
s%6 :
,w
. c a. )
Gf\\f;'b.[
I W ' ! h, i. j h.f,;;'
- 7 '
Q i- -
3 JJ, ' M 4 l l H
~
yo-p -
u i
, d U
b
.,s (i.s O.ifL w b 'a O 8102260 N Y
SSINS No.
6870 Accession No.
808220287 UNITED STATES NUCLEAR REGULATORY Comf1SSION OFFICE OF INSPECTION AND EhTORCE' INT WASHINGTON, D.C.
20555 January 23, 1981 IE Information Notice No. 81-02: TRANSPORTATION OF RADIOGRAPHY DEVICES
Background:
Recent inspections by NRC have identified frequent noncompliance with trans-portation regulations by radiography licensees.
As of December 3, 1979, the NRC inspection program has included inspection / enforcement of DOT regulations in 49 CFR l'/'-178 as direct NRC requirements (see 10 CFR 71.5).
The nature of radiography operations is somewhat unique in that radiography devices most frequently serve a dual function; that is, they serve as operational radiography cameras / source changers and as transportation packages. Historically, this has caused some confusion on the part of radiography users, particularly with respect to sorting out the transport regulatory requirements ol' 49 CFR/10 CFR 71 from the operational requirements of 10 CFR 34 and the specific license which has been issued to the radiography user. Another source of confusion for the radiography operator is that he most frequently functions, with respect to the transportation regulations, in the dual role of both shipper and carrier.
This notice discusses some of the pertinent transportation requirements for radiography devices when used as transport " packages." The explanations should help to clarify the application of operational licensing requirements versus transport requirements applicable to shippers and carriers, thereby enhancing regulatory compliance with the requirements.
Discussions:
Source Design -- Radiography sources contained within a device are always encapsulated (Co-60 or Ir-192) and, therefore, meet the physical integrity requirements of "special form" as defined in 49 CFR 173.389(g) and 173.398(a).
Radiography transporters are reninded that these requirements call for each shipper of a special form source to maintain a file of supporting safety analysis or documentation containing the results of the testing performed on the source to demonstrate that it meets the special form requirements. This
% ~* ~# 3 O " C,7 T g g g g aetually perform tle tests, only that 4,,
y of the teste.
As a practical matter, DUPLICATE DOCUMENT
's records i filt of such data for each
! be necessary, therefore, for the Entire document previously formatien from his source supplier.
entered into System under:
ANO b h h b M h h h 7 No. of pages:
h J
ng g-
_, n.
in
'hD
,kh f k
h i
7,;
,