ML19247C291
| ML19247C291 | |
| Person / Time | |
|---|---|
| Issue date: | 01/23/1981 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | LAW ENGINEERING TESTING CO. |
| References | |
| NUDOCS 8102180727 | |
| Download: ML19247C291 (1) | |
Text
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.o, UNITED STATES y 'fp ~..
i NUCLEAR REGULATORY COMMISSION 3
A REGION 11
.u m. - ;,i 101 M AR1ETT A ST., N.W., SUIT E 3100 4 K y.g
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AT LANT A, GEORGIA 30303 "3,
JAN 2 d 1381 LA. ENGINEE,IsG TEdTING CD*PasY d6v0 CENTUM v eAHAaAYe NE c25 ATLAwiA GA 30329 wC LIC. si c y 00346=03 Gentlemen:
The enclosed Inf ormation Notice No. 31-02 is f orwarded 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, r
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James P. O'Reilly Director
Enclosures:
1.
IE Information Notice No. 81-02 w/its enclosures rist of Recently issued IE Information Notices h
SSINS No.
6870 Accession No.
80S220267 UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT k'ASHINGTON, D.C.
20555 January 23, 1981 lE 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 progra= bas included inspection / enforcement of DOT regulations in 49 CFR 170-17S 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 confurion 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 =ost 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 "p a c ka g e s. " 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 Desien -- 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 fort cource to maintain a file of supporting safety analysis or documentatiot. containing the results of the testing performed on the source to demonstrate that it mee.s the special form requirements. This
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DUPLICATE DOCUMENT is records a file of such data for each be necessary, therefore, for the lp Entire doc =ent previously formation from his source supplier.
entered into system under:
xNo 8668RGG A87 No. cf pages:
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