ML19247C084
| ML19247C084 | |
| Person / Time | |
|---|---|
| Issue date: | 01/23/1981 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | THIOKOL CORP. |
| References | |
| NUDOCS 8102180007 | |
| Download: ML19247C084 (1) | |
Text
-
. ga ascg
![?
UNITED STATES t-
~,
NUCLEAR REGULATORY COMMISSION 3.[.
. [. 5 REGION 11 gg4 f
101 MAR lETT A ST., N.W. sulT E 3100 f
ATLANTA. G E ORG L A 30303
.. s JAN 23 SBT
.m t re,f g p% /
's ' (( lj Q
'V-R fthXs j'
J4tg'o g,C 3I A r9,N, E
TmIant C*E"! CAL CCdPCWATIC' musT5vILLL DI<IbICs y
AL W U7 h1 Dj7 ors h musiS*ILLE cSE= C ' 6 5 6,0 2_;
g
. J sWC LIC,
- t
, &T:N Gentlemen:
The enclosed Information Notice No. 81-02 is forwarded for your information and guidance in the requirements for safe transportation and carriage of radio-graphic devices. If there are any questions related to this notice, please contact this office.
Sincerely, f
Wm s~ n f
=.
~
James P. O'Reilly Director
Enclosures:
1.
IE Information Notice No. 81-02 w/its enclosures 2.
List of Recently issued IE Information Notices 81G2180cm
SSINS No.
6S70 Accession No.
80S2202S7 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT k'ASHINGTON, D. C.
20555 Janua ry 23, 1981 IE Informatica Netice No. 81-02:
TRANSPORTATION OF RADIOGRAPHY DEVICES
Background:
Recent inspections by NRC hace 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 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 operctional 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 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 ths application of operational licensing requirements versus transport requirements applicable to shippers and carriers, thereby enhancing regulatory compliance with the requirements.
Discussions:
Source Design -- Radiogiaphy 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 reminded that these rec,uirements call for each shipper of a special form source to maintain a file of supporting safety analysis or documentation containing the results of the t.esting performed on the source to demonstrate that it meets the special fcrm requirements. This does net mean that each shipper has to actually perform the tests, only that J the tests. As a practical matter,
'b#4+4Wf
- -iw i+ -
m 1
. I records a file of such data for each DUPLICATE DOCUMENT 3e necessary, therefore, for the reation from his source supplier.
Entire dccument previously I
l entered into syster. under:
ASO bhhbhkhA 7 J
S c.
of pages:
h rey n,ws,n,;%w.a%m,,g. ;.c ww W
e~-