ML20245A975
| ML20245A975 | |
| Person / Time | |
|---|---|
| Issue date: | 06/12/1989 |
| From: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Miller V NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| References | |
| NUDOCS 8906220309 | |
| Download: ML20245A975 (2) | |
Text
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'JUM 3 2, W MEMORANDUM FOR:
Vandy Hiller, Assistant Director for State Agreements State, Local and Indian Tribe Programs FROM:
Charles E. MacDonald, Chief Transportation Branch Division of Safeguards and Transportation Branch, NMSS
SUBJECT:
CALIFORNIA TRANSPORTATION INQUIRIES This responds to your memo, dated May 8,1989, concerning a request for information you received from the California Department of Health Services.
With regard to the quality assurance (QA) program of Industrial Nuclear Company (IEC), we withdrew their QA program on June 27, 1988, as a result of an inspec-tion conducted at their facilities on June 14-15, 1988. On October 17, 1988, INC submitted an application to reinstate their QA program, and on March 21, 1989, a request for additional information in connection with the QA program was sent to INC. Presently, we are awaiting INC response to our request for information, and to the notice of violation and notice of non-conformance which was sent to INC on May 17, 1989.
With regard to the problem of labels being placed over Department of Transpor-tation (DOT) required radiation related labels, D0T regulatior.s (49 CFR 171.12(e))
would be applicable.
In part, these regulations require that radioactive materials being imported into the US be packaged, marked, labeled and otherwise prepared for shipment in accordance with IAEA " Regulations for the Safe Transportation of Radioactive Materials". Further, the 00T revalidation of packaging certificates l
of compliance requires all users, except for the person requesting the revalidation, to register with the DOT.
It is not required for persons to verify that their l
customers are registered users of a package in which radioactive material is received. However, licensees must have procedures for safely opening packages (10 CFR 20.205 and 71.89).
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' Lastly, with regard to maximum ac'tivity limits specified in certificates of compliance, it should be noted that a certificate of compliance does not.autho-rirereceipt,possessionoruseofradioactivematerials,(10CFR71.0),nordoes Lit mean that when fully loaded with its authorized contents the dose rates will be within the regulatory limits for transport on non-exclusive use vehicles.
.The review of applications for a certificate of compliance is to ensure that all packaging standards are met. The certificate of compliance does not relieve the 4
- consignor from compliance with requirements of uther applicable regulatory agencies, including..the need to obtain an appropriate. license to receive, possess and use radioactive materials.
Charles E. MacDonald, Chief Transportation Branch
. Division of Safeguards and Transportation, NMSS Distribution:
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DATE: 6 / 4 /89 :
0FFICIAL RECORD COPY a-_____-.
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