ML19248C461

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Provides Nrc Response to Tower Memo of 780905 Requesting Assistance in Removing Append E 10CFR71 from NRC Regs. Advises That Original Walzel Ltr Being Considered in Conjunction W/A Petition for rulemaking,PRM-71
ML19248C461
Person / Time
Issue date: 09/20/1978
From: Dircks W
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Tower J
SENATE
References
NUDOCS 7809250150
Download: ML19248C461 (1)


Text

M RBMinogue WDircks, EDO

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SECY 78-1279 1 4F GAAr' o

CEMacDonald, NMS5 he Honorable John Tower PJ4Bernero DANussbaumer, NMSS

  • United States Senate SEP 2 01978 R

Cent 1 File Washington, D. C.

20510 ED0 SD ALPHA Files

Dear Senator Tower:

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os ck-RJDoda I am pleased to respond to your request, which was received by the Commission S'eptember 5,1978, concerning a letter from Mr. D. J.

Walzel, President of Ultrasonic Specialists, Inc., Houston, Texas, requesting assistance in removing Appendix E. to 10 CFR Part 71 from the Commission's regulations.

The requirements for QA (Quality Assurance) programs apply to persons who are subject to 10 CFR Part 71; thus, they apply to shippers of fissile material and Type B quantities of other reiioactive material.

Radiography shipments usually fall into the Type B w

'ory and, therefore, the QA requiremrats for shippers apply to radiography licensees (as well as to all other licensees who ship fissile material or Type B quant' ties of other radioactive material).

The Commission encourages the use of a graded approach in establishing QA programs; therefore, the QA programs required for radiography are correspondingly less complex than those required for~ other packaging and transportation activities involving more significant quantities of radioactive material.

Mr. Walzel's original letter to the Secretary of the Commission is being considered in conjunction with a petition for rulemaking, PRM 71-7, by Non Destructive Testing Management Association, et al. A number of other radiographer-licensees have expressed concern over the effort required to implement QA programs f or their packaging and shipping activities.

All of these conments are being considered, at the present time, in the Commission's determination of this petition.

If I can be of any further assistance, please let me know.

Sincerely, (Si;:ned)

Wi!!iani J. Dircks Dept!y Executiw 1)irMar for operations

Enclosures:

1.

Federal Register Notice, 42 FR39364 2.

Incoming letter dated 8/2/78 990%es' 7FO92 Sol 50 (SEE PREVIOUS YELLOW FOR CONCURRENCES)

TASK NO. :

PRM 71-7 3

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