ML19219A658
| ML19219A658 | |
| Person / Time | |
|---|---|
| Issue date: | 01/23/1981 |
| From: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | CTI, INC. (FORMERLY ALASKA WELDING CENTER) |
| References | |
| NUDOCS 8102260336 | |
| Download: ML19219A658 (1) | |
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NRC Lic. f50-19202-01 c_,i.
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The enclcrea interration notice ho. 61-0 is Ter=rce: Ter your inTorration and culcar.ce in Ine recuirements Tor sate transccrtation anc carrlace ci ratihcracnic cevices.
ir tncre are any cuestacns relatea to tnl: notice, please contact Inis oTT1ce.
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820226033 0
SSINS No.
6870
/ ccession No.
808220287 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D.C.
20555 January 23, 1981 IE Infomatio2 Notice No. 81-02:
TRANSPORTATION OF RADIOGRAPHY DEVICES
Background:
Recent in.mpections by NRC have identified frequent noncompliance with trans.
portation regulstions by radiography licensees. As of December 3, 1979, the NRC inspection program has included inspection / enforcement of DOT regulations in 49 CFR 170-178 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. Eistorically, this has caused some confusion on the part of radiography users, particularly with respect to sorting out the transport regulatory requirements of 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 wit.hin 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 reminded 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 2 - N4MbidfQg4pQ qqgggactually perform the tests, only that
.y wf the tests. As a practical matter, DUPLICATE DCCUMENT is records a file of such data for each I
e be necessary, therefore, for the Entire dccument previously formation from his source supplier.
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