ML20031G818

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Requests Clarification of QA Program for Model 9088.Since Vendor Does Not Design or Fabricate Type B Shipping Containers,Exemption from Program Requirements Should Be Granted
ML20031G818
Person / Time
Site: 07100394
Issue date: 10/13/1981
From: Gallagher R
NUCLEAR SOURCES & SERVICES, INC.
To: Gordon L
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
19806, NUDOCS 8110260055
Download: ML20031G818 (2)


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40 Division of Fuel Cycle ano Material Safety, NMSS 7915 Eastern Ave.

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Attention: Ian Cortion

Dear Mr. Gordon:

I u. wb.we In order for Schlumberger Well Services, Inc. (SWS) to properly administer their Q.A. program for Type B container USA /9088/B(), the regulations that any supplier of ocxuponent parts for the package must also have a similar program.

NSSI is a manufacturer of a variety of scaled sources including sane which would be type B quantities under 11m rules. We manufacture for SWS 19.999,

curie Am 241 De neutron sources in ccmpliance with ANSI standards for sealed sources for high pressure /high tanperature use.

SNS has indicated that NSSI must ocanply with the requircments of NRC 10CFR71, Appendix E for the manufacture of radioactive material shipping containers.

NSSI feels that the function it prcvides is no different than that pmvided by a manufacturer of radiography sources which require only a limited 9.A.

pmgram.

NSSI feels that it does not design or fabricate type B radioactive material shipping containers for SWS and should not be required to provide a program inconsistent with the work being performed.

Please review the attached information and indicate if the radiography source Q.A. program is applicable. If so please provide an outline of the acceptance criteria for radiography sources so that we can canplete our Q.A. subnission.

For your reference, previous correspondence referenced FC'IC: RHO 71-0394.

I would also appreciate your cla. lfication of the following situation:

As the shipping containers when received anpty and transported back to SWS loadcd have a Type B Label, should NSSI; who is both the shipper and carrier, be listed v a user of the package?

8110260055 811013

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PDR ADOCK 07100394 I

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I will appreciate your clarification and cx2ments.

If you need additional information frcm NSSI, please contact tre.

Sincerely, er lagt President ILY]:j0t cc: 01arles E. Mcdonald J

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