ML19247C102
| ML19247C102 | |
| Person / Time | |
|---|---|
| Issue date: | 01/23/1981 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | MATERIALS TESTING LABORATORY, INC. |
| References | |
| NUDOCS 8102180046 | |
| Download: ML19247C102 (1) | |
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NUCLEAR REGULATORY COMMISSION s
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Gentlemen:
The enclosed Inf ormation Nctice No. 81-02 is forwarded f or 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,
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en n f James P. O'Reilly Director
Enclosures:
1.
IE Information Notice No. 81-02 w/its enclosures 2.
Elst of Recently issued IE Information Notices 81021806 %
SSINS No.
6870 Accession No.-
80S220287 UNITED STATES NUCI. EAR REGULATORY COMMISSION OITICE OF INSPECTION AND EhTORCE" INT WASHINGTON, D.C.
20555 January 23, 1981 lE Information Notice No. 81-02:
TRANSPORTATION OF RADIOGRAPHY DEVICES
Background:
Recent inspections bv 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 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.
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 transportat ' 3n 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 fom" 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 perfomed on the source to demonstrate that it meets the special fom requirements.
This does not mean that each shipper has to actually perform the tests, only that
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