ML19247C123
| ML19247C123 | |
| Person / Time | |
|---|---|
| Issue date: | 01/23/1981 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Union Boiler Co. |
| References | |
| NUDOCS 8102180121 | |
| Download: ML19247C123 (1) | |
Text
.
ga pro g~
[
) ! % _.
UNITED STATES NUCLEAR REGULATORY COMMISSlON
{,.[gp __ [5 IQ REGION 11 g
<g
/
AT LANT A, GE CRGI A 00333 9
O JAN 2 3 El 1em z \\ Y,^ N ir s
\\
t y
Y
.N
( y
'y L \\
'JNICN " El I L E k CO"EANY
]
ge U
I' \\
f TI.G70< TESTI M.Iv!$10' I'T S Dc,l u a c }
7
- .- v. s a,0, s7 181a 75u. %
s-
-gNTI GTJN iv 25717 e 7=lt182=01-j@
.50 LIC. st c
'I g ? ) '
~ - _ -
Gen:1emea:
The enclosed Inf ormation Notice No. S1-02 is f orwarded f or your inf ormation and guidance in the requirements f or safe transportation and ca :riage of radio-graphic devices. If there are any q_ - tions related to thir notice, please contact this office.
Sincerely,
~ _ 31 3 ~,,
=
James P. O'Reilly Director
Enclosures:
1.
IE Information Notice No. 31-02 w/its enclosures 2.
List of Recently issued IE Info:=ation Notices 8102180 M
SSINS No.
657v Accession No.
805220287 UNITED STATES NUCLEAR PIGULATORY COMMISSION OFFICE OF INSPECTICN AND ENFORCEMI.NT WASHINGTON, D.C.
20555 Janua ry 23, 1981 lE Information Notice No. 81-02:
TRANSPORTATION OF RADIOGRAPHY DEVICES Eackground:
Recent inspections by NRC have identified frequent noncompliance with trans-portation regulations by radiography licensees.
As of December 3, 1979, the NEC 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 aevices 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 transportation requirements for radiognphy devices when used as transport " packages." The explanations should help to clarify the application cf operational licensiag 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 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 demonst ate that it meets the special form requirements. This does not mean that each shipper has to actually perform the tests, only that
' :' k *++ng ex y % m
-.: the tests. As a practical matter, records a file of such data for each DUPLICATE DOCUMENT
,e necessary, therefore, for the Entire dccument previously entered into system under:
ANO bhhbh2hA5'7 g
N o.
cf pages:
h V w w n w. w.n #.
.