ML20040A439
| ML20040A439 | |
| Person / Time | |
|---|---|
| Site: | 07100394 |
| Issue date: | 12/22/1981 |
| From: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Gallagher R NUCLEAR SOURCES & SERVICES, INC. |
| References | |
| NUDOCS 8201210096 | |
| Download: ML20040A439 (2) | |
Text
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g-7/o3W DEC 2 21981 n~b FCTC:LL6 71-0394 W
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Huclear Sources & Services, Inc C
ATTH: Mr. Robert D. Gallagher 6; eE 'q.p 7f /98
77 P.O. Box 34042 A
J d'd flouston, TX 77034 1
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This is in response to your letter dated October 13, 1981, to !!r. Len Gordon of my staff requesting clarification of (a) requirements for an HRC approved QA program for shipping activities, and (b) the need to be registered with HRC as a user of packages.
Concerning the need for an HRC approved QA program, a prerequisite to the general license in Section 71.12 of 10 CFR Part 71 is that NRC licensees have a quality assurance program whose description has been submitted to and approved by the Cor:vnission as satisfying the provision of 71.51. Also, under paragraph 150.20(b) of 10 CFR Part 150 a person who holds a specific license from an Agreement State would be subject to the provisions of Part 71 for activities conducted in a non-Agreement State. To implement the provisions of a NRC approved QA Program, the person having the approved QA plan must ensure himself that material, equipment, or services received from others are consistent to the extent necessary to meet the pertinent provisions of the approved NRC program.
The person obtaining the material, equipment, or services, and having the NRC approved program would be the person to determine that the i
services received are consistent with his approved QA program.
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Nuclear Sources & Services, Inc. DEC 2 21981 l
In regard to registration, NRC licensees are required to provide to the NRC the information specified in Paragraph 71.12(b) prior to the use of a package for which a license, certificate of compliance, or other approval has been issued by the Comission. Other persons such as Agreement State licensees are required to provide to the NRC the information specified in 49 CFR 173.393a before the first shipment in a package approved by the NRC. Note that registration is not required for use of DOT specification containers and packages for which the DOT has revalidated the foreign material competent authority certificate.
Enclosed are copies of NRC regulations 10 CFR Parts 7Il and 150 referenced above.
We hope that this information will be helpful.
Sincerely, Orirird *
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Charles E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety, NMSS
Enclosures:
As stated Distribution: w/o encls
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