ML20108E944
| ML20108E944 | |
| Person / Time | |
|---|---|
| Issue date: | 04/17/2020 |
| From: | Office of Nuclear Material Safety and Safeguards |
| To: | |
| David Alley | |
| Shared Package | |
| ML20108E940 | List: |
| References | |
| Download: ML20108E944 (4) | |
Text
Industrial Radiography Licensee Generic Exemptions During the Emergency Caused by the COVID-19 Pandemic 4/13/2020 Reg. Description of Safety Basis (Operating) Safety Basis (Closed) Exemption Language Exemption Subpart C - Equipment 34.25(b)(1) The regulation from which This exemption is relatively The extension of calibration From the date of the issuance of the licensee is requesting short compared to the 6-month time does not constitute a this letter, the licensee is exempt an exemption is the interval. The licensee must significant increase in risk to from the calibration time interval requirement in 10 CFR continue to comply with the public health and safety, required by 10 CFR 34.25(b) for a 34.25(b)(1) that the requirement in 34.25(b)(1) to because the licensee period of 90 days. The licensee licensee shall have each calibrate the instrument after suspended operations and shall perform the instrumentation radiation survey instrument servicing. Therefore, the is not using these calibrations within 7 days of the required in 10 CFR exemption does not constitue instruments. expiration of this exemption.
34.25(a) calibrated at a significant increase in risk to intervals not to exceed 6 public health and safety.
months. The licensee requested to extend the required time interval for calibration by [the requested extension]
during the emergency caused by the COVID-19 PHE.
34.27(c)(1) The regulation from which The extension provided by this The extension provided by From the date of the issuance of the licensee is requesting exemption is relatively short this exemption is relatively this letter, the licensee is exempt an exemption is the compared to the 6-month short compared to the 6- from the requirements to test requirement in 10 CFR interval. Therefore, this month interval. In addition, sealed sources for leakage per 10 34.27(c)(1) that the exemption does not constitute licensees must still perform CFR 34.27(c)(1) for a period of 90 licensee test sealed a significant increase in risk to leak tests if the sources days. The licensee shall perform sources for leakage at public health and safety. exhibit signs that the source the leak testing of sealed sources intervals not to exceed 6 might be leaking. within 30 days of the expiration of months. The licensee Additionally, the licensee this exemption.
requested to extend the has suspended operations, leak test interval required which reduces the by paragraph (c)(1) of this movement of and exposure 1
Industrial Radiography Licensee Generic Exemptions During the Emergency Caused by the COVID-19 Pandemic Reg. Description of Safety Basis (Operating) Safety Basis (Closed) Exemption Language Exemption section by [the requested to sources. Therefore, this extension] during the exemption does not emergency caused by the constitute a significant COVID-19 PHE. increase in risk to public health and safety.
34.27(e) The regulation from which The extension provided by this The extension provided by From the date of the issuance of the licensee is requesting exemption is relatively short this exemption is relatively this letter, the licensee is exempt an exemption is the compared to the 12-month short compared to the 12- for a period of 90 days, from the requirement in 10 CFR interval. Therefore, this month interval. Additionally, requirement in 10 CFR 34.27(e) to 34.27(e) that the licensee exemption does not constitute the licensee has suspended test each exposure device using test each exposure device a significant increase in risk to operations and is not using depleted uranium (DU) shielding using depleted uranium public health and safety. these devices, which are in and an S tube configuration for (DU) shielding and an S locked storage. Therefore, DU contamination, at intervals not tube configuration for DU this exemption does not to exceed 12 months. The licensee contamination at intervals constitute a significant shall perform the DU contamination not to exceed 12 months. increase in risk to public testing within 7 days of the The licensee requested to health and safety. expiration of this exemption.
extend the DU contamination test interval required by paragraph (e) of this section by [the requested extension]
during the emergency caused by the COVID-19 PHE.
34.29(a) The regulation from which The extension provided by this The licensee has From the date of the issuance of the licensee is requesting exemption is relatively short suspended operations and this letter, the licensee is exempt an exemption is the compared to the quarterly is not using the sources or from the requirements of 10 CFR requirement in 10 CFR interval. Therefore, this devices containing depleted 34.29(a), for a period of 30 days, 34.29(a) that the licensee exemption does not constitute uranium, which are in for conducting a quarterly inventory conduct a quarterly a significant increase in risk to locked storage. Therefore, of all sealed sources and devices inventory to account for all public health and safety. this exemption does not containing depleted uranium (DU).
sealed sources and for constitute a significant The licensee shall perform an devices containing inventory of sealed sources and 2
Industrial Radiography Licensee Generic Exemptions During the Emergency Caused by the COVID-19 Pandemic Reg. Description of Safety Basis (Operating) Safety Basis (Closed) Exemption Language Exemption depleted uranium. The increase in risk to public devices containing DU within 7 licensee requested to health and safety. days of the expiration of this extend the quarterly exemption.
inventory required by paragraph (a) of this section by [the requested extension] during the emergency caused by the COVID-19 PHE.
Subpart D - Radiation Safety Requirements 34.43(d) The regulation from which The extension provided by this The extension provided by From the date of issuance of this the licensee is requesting exemption is relatively short this exemption is relatively letter, the licensee is exempt for 90 an exemption is the portion compared to the 12-month short compared to the 12- days, from the requirement in 10 of 10 CFR 34.43(d) that interval. The licensee must month interval. The CFR 34.43(d) to provide annual requires licensees to continue to provide initial licensee must continue to refresher safety training for each provide annual refresher radiation safety training to provide initial radiation radiographer and radiographer safety training for each each radiographer and safety training to each assistant at intervals not to exceed radiographer and radiographer assistant. radiographer and 12 months. The licensee shall radiographer assistant at Therefore, the exemption does radiographer assistant. provide refresher safety training intervals not to exceed 12 not constitue a significant Additionally, the licensee within 30 days of the expiration of months. The purpose of increase in risk to public health has suspended operations. this exemption.
this exemption would be to and safety. Therefore, the exemption allow the licensee to delay does not constitue a this annual training for [the significant increase in risk to requested extension] public health and safety.
during the emergency caused by the COVID-19 PHE.
34.43(e) The regulation from which The extension provided by this The exemption does not From the date of issuance of this the licensee is requesting exemption is relatively short constitute a significant risk letter, the licensee is exempt for 90 an exemption is the portion compared to the 6-month to public health and safety, days, from the requirement in 10 of 10 CFR 34.43(e)(1) that interval. Therefore, the because the licensee CFR 34.43(e)(1) that the licensees requires the licensees exemption does not constitute suspended operations. radiation safety officer (RSO) or radiation safety officer or designee must observe the 3
Industrial Radiography Licensee Generic Exemptions During the Emergency Caused by the COVID-19 Pandemic Reg. Description of Safety Basis (Operating) Safety Basis (Closed) Exemption Language Exemption designee to observe the a significant increase in risk to performance of each radiographer performance of each public health and safety. and radiographer assistant during radiographer and actual industrial radiographic radiographer assistant operation, at intervals not to during actual industrial exceed 6 months. The licensee radiographic operation, at shall have the RSO or a designee intervals not to exceed 6 perform these observations within months. The purpose of 30 days of the expiration of this this exemption would be to exemption.
allow the licensee to delay observation of each radiographer and radiographer assistant for
[the requested extension] during the emergency caused by the COVID-19 PHE.
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