ML20213D724
| ML20213D724 | |
| Person / Time | |
|---|---|
| Issue date: | 11/07/1986 |
| From: | Glenn J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Richman M RESEARCH-COTTRELL, INC. |
| References | |
| NUDOCS 8611120207 | |
| Download: ML20213D724 (2) | |
Text
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07 NOV 1986 1
i Docket No. 99990001 Reiearch-Cottrell 4:
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' ATTN: Mark Richman
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Technical Manager Air Pollution Control Division' P.O. Box 1500
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Scinerville, New Jersey 08876 1
i Gentlemen:
Subject:
Inspection No. 99990001/86-06 This is in reference to an inquiry visit by Messrs. Michael Varela and 3
Steven Courtimanche of thi's office or. August 19, 1986; This inquiry was made to determine the nature of the services you have been providing to your f
customers, who may either be general or specific licensees of the Nuclear Regulatory Commission, in regards to the permanent installation of nuclear gauges at their facilities.
i From our inhiry',,it is our understanding that all nuclear gauges are shipped directly to your customers by the manufacturer and are at no time shipped directly to Research-Cottrell.
Furthermore, after initial installation by Research-Cottrell personnel these nuclea'r gauges are then calibrated and ad-justed by the manufacturer or his representative. We understand that the manu-facturers/ distributors you deal with are Ohmart, Texas Nuclear and Kay-Ray, with Kay-Ray being the only manufacturer whose representatives are physically present during the initial installation of the gauging devices and with Texas Nuclear and Ohmart gauges being installed independently by your employees with a later check being made by the manufacturer's representatives.
10 CFR 31.5(c)(3) requires, in part, that each general licensee ensure that the generally licensed device be installed by a person holding an NRC license issued pursuant to 10 CFR Parts 30 and 32, or by an Agreement State pursuant to comparabin regulations. Similarly, a condition in every specific license, requires,. in part, that each specifically licensed device listed on the license be installed by a person holding a specific license fro:n the NRC or from an Agreement State.
If you continue to install generally and specifically lic-ensed devices without such a specific license issued by the NRC or an Agreement State, your customers will be in violation of NRC's rules and regulations con-cerning installations and subject to enforcement _ actions by the NRC.
It is our understanding that unless, or until, you request and receive a
.h' only participate in such insta1Vations in the physical presence, and under the license to perf orm installation services involving licensed material, you will OFFICIAL RECORD COPY IR RESEARCH 86 0001.0.0
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IE GA999 EXIRESCO RE1UCI ORIG 11RL TO i pf{1 f
1/i 99990001 PDR REGI0ll I.
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4 07 NOV 1988 Research-Cottrell 2
supervision of a licensed service representative of the manufacturer of the gauging device. We are enclosing the appropriate forms and guides to prepare an application for such a license.
If our understandings are incorrect, please notify this office in writing within 30 days of the receipt of this letter.
We appreciate your cooperation in this matter.
If you have any questions, please contact me at (215) 337-5239.
Sincerely, Original Signed Dyr John E. Glenn John E. Glenn, PhD., Chief Nuclear Materials Safety Section B Division of Radiation Safety and Safeguards
Enclosures:
1.
10 CFR 2,19,20,30,31,32,71,170 2.
Form NRC-313 3.
GUIDE FOR LICENSE APPLICATION FOR THE USE OF RADI0 ACTIVE MATERIALS IN SERVICING PREREGISTERED GAUGES, MEASURING DEVICES AND SEALED SOURCES USED IN SUCH DEVICES cc:
Research-Cottrell ATTN: Don Balunis Manager of Purchasing P.O. Box 1500 Somerville, New Jersey 08876 i
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([3hhDRSS:RI DRSS:
SS:RI ourtemanche/pj/fi Varela Glenn
/ff 0FFICIAL RECORD COPY IR RESEARCH 86 0002.0.0 10/31/86 l