RIS 2005-10, Appendix F - Regulatory Issue Summary 2005-10, Performance-Based Approach for Associated Equipment in 10 CFR 34.20.

Performance-Based Approach for Associated Equipment in 10 CFR 34.20

ML051590049
Person / Time
Issue date:	06/10/2005
From:	Holahan P K NRC/NMSS/IMNS
To:
References
RIS-05-010
Preceding documents:	ML051590049 (10 June 2005)
Download: ML051590049 (11)

See also: RIS 2005-10

Text

June 10, 2005

NRC REGULATORY ISSUE SUMMARY 2005-10PERFORMANCE-BASED APPROACH FOR ASSOCIATED EQUIPMENT IN 10 CFR 34.20ADDRESSEESAll industrial radiography licensees and manufacturers and distributors of industrial radiographyequipment.INTENT The U.S. Nuclear Regulatory Commission (NRC) is issuing this regulatory issue summary (RIS)to explain the performance-based approach NRC has decided to take regarding therequirements in 10 CFR 34.20, "Performance requirements for industrial radiography equipment," which addresses the regulation of associated equipment used in an industrial radiography syste This RIS supersedes and replaces Information Notice 96-20,"Demonstration of Associated Equipment Compliance with 10 CFR 34.20." No specific action or written response is required.BACKGROUND In the Federal Register notice (68 FR 41757, July 15, 2003), NRC announced its denial of thepetitioner's request for rulemaking to remove from 10 CFR 34.20 the term "associated equipment." The notice also explained that NRC's practice of registering associated equipmentunder 10 CFR 32.210, "Registration of product information," which was previously described in Information Notice 96-20, had been discontinue This RIS supersedes and replaces Information Notice 96-2 SUMMARY OF ISSUE To maintain safety, each licensee must take special care to ensure that all associatedequipment (including modified or customized associated equipment) meets the minimum performance criteria required in 10 CFR 34.2 A licensee that modifies associated equipment is required to demonstrate by actual testing or an alternative analysis that the performance of the radiographic system and individual items of associated equipment meet the criteria in10 CFR 34.2 The results of actual testing or analysis must demonstrate that the replacementcomponent will not compromise the design safety features of the industrial radiography system. Compliance with the performance criteria prevents a licensee from using substandard associated equipment. ML051590049 RIS 2005-10Page 2 of 3PERFORMANCE REQUIREMENTS FOR ASSOCIATED EQUIPMENT The performance requirements for associated equipment are set forth in the paragraphs of10 CFR 34.20, described below:*paragraph (a)(1), incorporates by reference the American National Standards Institute(ANSI) N432-1980, "Radiological Safety for the Design and Construction of Apparatus for Gamma Radiography," (ANSI N432) which specifies the design and method of qualifying (testing) industrial radiography equipment, including equipment that NRC hasdefined as "associated equipment;" *paragraph (a)(2), provides for an engineering analysis as an alternative to actual testing,to demonstrate the performance of individual radiography equipment components;*paragraph (b)(3), allows associated equipment to be modified unless the replacementcomponent would compromise the design safety features of the industrial radiography system;*paragraph (c)(5) and (8), respectively address crushing and kinking tests for a guidetube and the standard test for tensile strength of an exposure head;*paragraph (e), allows a licensee or vendor to apply a realistic torque to the drivemechanism during the life cycle test.The regulations require a licensee to use industrial radiography equipment that has beenmanufactured and tested to meet radiation safety performance criteria under 10 CFR 34.2 The life cycle test in ANSI N432 is an evaluation of the endurance of a source or devic Totest the life cycle of an industrial radiography source or exposure device, all components of theindustrial radiography system (including the associated equipment) must be assembled andoperated for the duration of the tes This requirement, NRC determined, is sufficient tomaintain safety and a separate regulatory approval for associated equipment is not needed as long as the associated equipment meets the minimum criteria in 10 CFR 34.20. Attachment 1 to this RIS contains additional information about definitions and applicablerequirements, certificates of registration for a sealed source or device, custom-built items of associated equipment, acceptable methods to demonstrate compliance, inspection and licensing guidance, and inspection and maintenance procedure Attachment 2 indicates the availability of reference documents that are cited in this RIS and Attachment 1.ENFORCEMENT POLICY The NRC Enforcement Policy, Supplement VI, provides examples of violations in each of thefour severity levels as guidance in determining the appropriate severity level for violations in the area of fuel cycle and materials operations, including industrial radiographic operation Anexample of an activity that would normally result in the NRC issuing a Severity Level III Noticeof Violation is possession or use of unauthorized equipment or materials in the conduct of licensee activities that degrades safet Based on this example, enforcement action would be considered for a licensee that used associated equipment that had not been tested or analyzed RIS 2005-10Page 3 of 3 to meet the performance requirements or that used modified associated equipment thatcompromised the design safety features of an industrial radiography system and threatened ordid not protect the health and safety of workers or members of the public.AGREEMENT STATE COMPATIBILITY NRC has determined that the information provided in this RIS does not change the level of compatibility of the Agreement State regulations to the existing NRC requirement Use of theinformation in this RIS continues to provide Agreement States with the flexibility to revise theirpolicy and guidance to meet unique situations and local conditions and to ensure an orderly, uniform implementation of the performance-based approach for associated equipment.FEDERAL REGISTER NOTIFICATIONA notice of opportunity for public comment on this RIS was not published in the FederalRegister because it is informational, and does not represent a departure from current regulatoryrequirements.SMALL BUSINESS REGULATORY ENFORCEMENT FAIRNESS ACT NRC has determined that this action is not subject to the Small Business RegulatoryEnforcement Fairness Act of 1996.PAPERWORK REDUCTION ACT STATEMENT This RIS requires no specific action or written respons If you have any questions about thissummary, please contact one of the individuals listed below or the appropriate regional office./RA/ Thomas Essig forPatricia K. Holahan, Acting DirectorDivision of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and SafeguardsTechnical Contacts:J. Bruce Carrico, NMSSThomas Young, NMSS301-415-7826301-415-5795 E-mail: jbc@nrc.govE-mail: tfy@nrc.govNote: NRC generic communications may be found on the NRC public Web site,http://www.nrc.gov, under Electronic Reading Room/Document Collections.

Attachments:

1.Additional Information and Applicable Requirements Regarding Associated Equipment Availability of Reference Documents List of Recently Issued NMSS Generic Communciations RIS 2005-10Page 3 of 3 to meet the performance requirements or that used modified associated equipment thatcompromised the design safety features of an industrial radiography system and threatened ordid not protect the health and safety of workers or members of the public.AGREEMENT STATE COMPATIBILITY NRC has determined that the information provided in this RIS does not change the level of compatibility of the Agreement State regulations to the existing NRC requirement Use of theinformation in this RIS continues to provide Agreement States with the flexibility to revise theirpolicy and guidance to meet unique situations and local conditions and to ensure an orderly, uniform implementation of the performance-based approach for associated equipment.FEDERAL REGISTER NOTIFICATIONA notice of opportunity for public comment on this RIS was not published in the FederalRegister because it is informational, and does not represent a departure from current regulatoryrequirements.SMALL BUSINESS REGULATORY ENFORCEMENT FAIRNESS ACT NRC has determined that this action is not subject to the Small Business RegulatoryEnforcement Fairness Act of 1996.PAPERWORK REDUCTION ACT STATEMENT This RIS requires no specific action or written respons If you have any questions about thissummary, please contact one of the individuals listed below or the appropriate regional office.Note: NRC generic communications may be found on the NRC public Web site,http://www.nrc.gov, under Electronic Reading Room/Document Collections.

Attachments:

1.Additional Information and Applicable Requirements RegardingAssociated Equipment2.Availability of Reference Documents List of Recently Issued NMSS Generic CommunciationsDISTRIBUTION: RIS FileML051590049OFFICERGB-ASL:RGB-ATech EditorC:MSIB/IMNSC:RGB/IMNSD:OENAMETYoungCAbramsEKrausTEssig byJJankovichSMoore byMDelligatti FCongel byMSchwartzDATE03/15/2005 05/12/200503/17/200505/13 /2005 05/13/2005 05/24/2005OFFICEDD:STPOGCD:IMNSNAMEPLohaus byAJonesSTrebyPHolahanT. Essig forDATE 05/19/2005 05/24/2005 06/07/2005 / / / / / /OFFICIAL RECORD COPY Attachment 1 RIS 2005-10 Page 1 of 5 ADDITIONAL INFORMATION AND APPLICABLE REQUIREMENTS REGARDINGASSOCIATED EQUIPMENTDefinitions 10 CFR 34.3, "Definitions," defines associated equipment as equipment that is used inconjunction with a radiographic exposure device to make radiographic exposures that drives, guides, or comes in contact with the source [e.g., guide tube, control tube, control (drive) cable,removable source stop, "J" tube, and collimator when it is used as an exposure head]. 10 CFR34.3 defines the following items of associated equipment: collimator, control (drive) cable,control (drive) mechanism, control tube, exposure head (source stop), and guide tub CFR 34.3 defines the following radiographic equipment and related terms: radiographic exposure device, s-tube, sealed source, source assembly, source changer, and storage container.Licensees should be aware of the specific meaning of the terms indicated abov Therequirements applicable to items of equipment depend on how the equipment is defined in 10 CFR 3 It is important to distinguish between items of equipment that are considered tobe associated equipment and items of equipment that are no In some cases, there may be no regulatory requirements that apply to an item of equipment; in other cases, an item of equipment may be a component of a source or device that is required to be specifically authorized for us Following are two examples that illustrate important distinctions which determine regulatory requirements for an item of equipmen The first example distinguishes certain types of collimators that are not associated equipmentand are not required to meet the performance criteria in ANSI N43 Various types of collimators are used as radiation safety devices for industrial radiographic operation In manycases, the exposure head at the end of the guide tube is inserted into a collimato This type of collimator is not an item of associated equipment because the source does not come in contactwith the collimato This type of collimator is not subject to the performance requirements in10 CFR 34.20 or the evaluation process in 10 CFR 32.21 However, if a collimator does comein contact with the source because it also acts as a source stop (exposure head), then it falls within the scope of the definition of associated equipment that is subject to the performancerequirements in 10 CFR 34.20.The second example distinguishes the connector that is located between the sealed source andthe control (drive) cabl CFR 34.3 defines the source assembly to include the connector, stating, "Source assembly means an assembly that consists of the sealed source and a connector that attaches the source to the control cable." The connector is a component of thesource assembly and is, therefore, not an item of associated equipmen The source assembly is subject to the requirements in 10 CFR 30.32, "Application for a specific license." 10 CFR 30.32(g) indicates that an application for a specific license to use byproduct material in the form of a sealed source or in a device that contains a sealed source must either identify the sealedsource or the device as registered under 10 CFR 32.210 or with an Agreement State or must include the information identified in 10 CFR 32.210(c). The manufacturing processes used to attach the connector to the source cable and to the control (drive) cable are also subject to evaluation by NRC or an Agreement State under these requirement Attachment 1 RIS 2005-10 Page 2 of 5 Portable industrial radiographic systems typically include a two-piece connector (swivel couplingdesign) to attach the source assembly to the control (drive) cable in order to operate the syste The performance-based requirement in 10 CFR 34.20(c)(1) indicates that the couplingmust be designed such that it cannot be unintentionally disconnected under normal andreasonably foreseeable abnormal condition The Statements of Consideration at 55 FR 843 (January 10, 1990) include a response to comments received for 10 CFR 34.20(c)(1). The response indicates, "NRC's source and device registration process will ensure compliance withthis performance requirement by requiring NRC approval before the newly designed connectorscould be used." The sealed source or device evaluation process ensures compliance with the performance criteria in the rul Both pieces of the two-piece connector are subject to evaluation under 10 CFR 30.32(g) or 32.210(c). Sealed Source and Device (SS&D) Certificate of Registration NRC determined that the previous practice of registering associated equipment under 10 CFR32.210 was not only not required, but was a regulatory practice that imposed an unnecessaryburden on licensees and for NRC and the Agreement States which are authorized to evaluateSS&D Therefore, this practice has been discontinue NRC does not intend to independentlyrevise current SS&D certificates of registration only to remove references to associated equipmen If it becomes necessary to amend a current SS&D certificate of registration, the applicant may remove or update the information about associated equipment in the applicatio As a matter of convenience, an SS&D applicant under 10 CFR 32.210 may describe theassociated equipment that was used in the life cycle test for the radiographic source or devicethat is being registered; however, there is no requirement to do s If an applicant wants theassociated equipment to be included on the certificate of registration, the application whichdescribes associated equipment must include sufficient information to demonstrate that the performance criteria were met for associated equipment under 10 CFR 34.2 If a certificate of registration does not identify the associated equipment that was used in the system along withthe source or device, then each end-user (licensee) must demonstrate that the items ofassociated equipment which the licensee uses in the system meet the performance criteriaunder 10 CFR 34.20 and do not compromise the design safety features of the syste NUREG-1556, Volume 3, Revision 1, "Consolidated Guidance About MaterialsLicenses-Applications for Sealed Source and Device Evaluation and Registration," (Final Report, April 2004), Section 4.6, "Radiography Equipment," indicates that there is no requirement to identify associated equipment for an SS&D certificate of registratio Note-InSection 15, "Glossary," the definition of "associated equipment" was intended to be removed and should be disregarded because it has been superceded by Section 4.6.Custom-Built or Unique Items of Associated Equipment Associated equipment specifically designed and constructed to the order of a single licenseemust comply with the performance criteria in 10 CFR 34.2 There is no requirement to register custom-built or unique items of associated equipmen However, when modified or custom-built associated equipment introduces components or fabrication methods that differ from those that Attachment 1 RIS 2005-10 Page 3 of 5 were used in the endurance test for a source assembly or exposure device that was previouslyregistered, the licensee must demonstrate compliance with the requirements in 10 CFR 34.20 before the equipment can be used for industrial radiographic operation For example, licensees must obtain information demonstrating that modified guide tubes and exposure heads will withstand tests that demonstrate the equipment will maintain its integrity in normal use andlikely accident conditions. Acceptable Methods to Demonstrate that Associated Equipment Complies with 10 CFR 34.20The performance-based approach that NRC has decided to take for associated equipmentrecognizes that a licensee has latitude to use modified components, unless the design of any replacement component would compromise the design safety features of the syste Furtherguidance about testing or an alternative analysis to testing is described in NUREG-1556,Volume 3, Revision 1, Section 10.5, "Prototype Testing." The NUREG addresses appropriatemethods a licensee may use to demonstrate the ability of a modified industrial radiographysystem to maintain its integrity when subjected to conditions of normal use and likely accidentcondition For example, information about an equivalent system that was previously registered may beused to demonstrate safety and integrity of the modified system, if the design of the modifiedsystem and its intended normal and likely accident conditions of use are identical or similar tothe previously registered syste In some cases, an engineering analysis or operational historywith supporting documentation may be sufficient for a licensee to justify the use of a modified system without repeating, e.g., an endurance tes However, when an appropriate comparisonto the previously registered system is not possible because a licensee is unable to obtainappropriate information about previous prototype testing, engineering analysis, or operational history for the previously registered system or item of associated equipment, then the licenseemust complete actual testing of the modified system and the individual items of associatedequipment to demonstrate compliance with 10 CFR 34.2 NRC contracted a testing laboratory to complete actual testing of three industrial radiographysystems from three manufacturer The contractor developed procedures to test the systemsand individual items of associated equipment to meet the performance criteria in 10 CFR 34.20. In a similar manner, a licensee could contract a testing laboratory or manufacturer of industrial radiography equipment to test or analyze a modified system or component that will be used in asystem that was previously licensed or registered. If a licensee needs to modify associated equipment, the licensee should adopt and implement asuitable engineering procedure or plan to ensure that a modified component will notcompromise the design safety features of the industrial radiographic syste Implementation ofsuch a procedure or plan should demonstrate that modifications to the equipment: (1) will notcreate material incompatibility that may degrade a sealed source or device over the expecteduseful life time; (2) will not diminish the performance of the system in expected use environments and in likely accident conditions over the expected life time of the various systemcomponents; (3) will not allow a source to inadvertently exit the system; and (4) will not initiate Attachment 1 RIS 2005-10 Page 4 of 5 or propagate equipment failures resulting in a "source disconnect." An endurance test for amodified system should indicate that the modified component does not interfere with theperformance of the components of the system that were previously registered.Examples of the performance-based approach that NRC has decided to use for 10 CFR 34.20are included in the following paragraphs to illustrate situations when a licensee must completetesting or analysis of associated equipment to demonstrate that the associated equipmentmeets the performance criteria in 10 CFR 34.20 and does not compromise the design safety features of the system. It is acceptable for a licensee to assume that no further testing is needed for associatedequipment which is listed along with the source or device as an entire system on the certificateof registration because the associated equipment has already been verified to meet the performance criteria in 10 CFR 34.20 when the associated equipment is used with the source or devic However, a licensee that substitutes associated equipment into an industrial radiography system that was registered as an entire system which specified the associatedequipment must demonstrate that the reconfigured system meets the performance criteriaunder 10 CFR 34.2 It is acceptable for a licensee to assume that associated equipment that is used as themanufacturer intended as described in the SS&D certificate of registration meets the performance criteria under 10 CFR 34.2 The SS&D certificate of registration indicates the principal use, normal conditions of use, and the limitations on use for the source or devic However, a licensee that uses associated equipment in a manner that was not intended by themanufacturer as described in the SS&D certificate of registration for the source or device must describe the conditions of use for the equipment and obtain information about performance of the equipment under these conditions of use to demonstrate compliance with 10 CFR 34.20. Conditions of use include, for example, extremely hot or cold operating temperature, excessive vibration or shock, high concentrations of corrosive materials, and underwater usag Inspection and Licensing Guidance NRC is revising inspection and licensing guidance to incorporate the explanation provided bythis RI Inspection Procedure 87121, "Industrial Radiography Programs," directs an inspector to follow a performance-based approach to examine available associated equipment, observe work in progress that involves use of associated equipment, and interview workers about the inspection and maintenance procedures and the worker's awareness that associated equipment must comply with the performance criteria in 10 CFR 34.2 If the associated equipment appears to be modified or defective, the inspector should verifywhether or not the licensee had developed and implemented a testing program to demonstrate that modified components meet the performance criteria in 10 CFR 34.2 The inspectorshould alert the inspection supervisor who may extend the inspection and request an SS&D reviewer to evaluate the licensee's modification of the equipmen The expectation is that the design safety features of the industrial radiography system were not compromised by a Attachment 1 RIS 2005-10 Page 5 of 5 replacement component of associated equipment that was modified by the license Beforeusing the modified system, the licensee is required to demonstrate that the replacementcomponent meets the performance criteria in 10 CFR 34.20.NUREG-1556, Volume 2, "Consolidated Guidance about Materials Licensees-Program-Specific Guidance about Industrial Radiography Licenses" (Final Report, August 1998) is being amended to remove statements that indicate associated equipment must be specifically approved or registered by NRC or an Agreement Stat Instead, the guidance will state thatvendors or distributors of industrial radiography equipment may voluntarily include the items of associated equipment that were used in the system with their SS&Ds that are registered under10 CFR 32.21 To include associated equipment in the certificate of registration, the vendor'sapplication must include information that demonstrates the associated equipment meets theminimum criteria in 10 CFR 34.2 Also, copies of this RIS will be inserted into Appendix F toreplace Information Notice 96-20.Inspection and Maintenance Procedures NRC completed a generic assessment and special team inspection which was published inNUREG-1631, "Source Disconnects Resulting from Radiography Drive Cable Failures" (June1998). The inspection team observed that, in general, radiography exposure devices appeared to be in good working order, showing no evidence of damage, abuse, or lack of maintenanc By contrast, the associated equipment (i.e., control mechanisms, including drive cables) often appeared to be damaged, in disrepair, and lacking maintenanc NUREG-1631 emphasized the importance of a licensee's understanding and commitment tothe operating and use conditions specified by a vendor (manufacturer or distributor) of an industrial radiography system which, if exceeded, could compromise the safety and reliability ofthe syste This is particularly true of items of associated equipment, including drive cable Alicensee should be vigilant to inspect and maintain associated equipment in order to avoid component failures that could result in unnecessary radiation exposures to workers and members of the public. A licensee's equipment inspection and maintenance program should prevent particularequipment problems that may develop from excessive uses where harsh or abusive conditions exist that may cause a component to fai CFR 34.31, "Inspection and maintenance of radiographic exposure devices, transport and storage containers, associated equipment, source changers, and survey instruments," requires a licensee to perform visual and operability checkson associated equipment before use on each day the equipment is to be used to ensure that the equipment is in good working conditio If equipment problems are found, the equipmentmust be removed from service until repaire In addition, the licensee is required to have written procedures for inspection and routine maintenance of associated equipment at intervalsnot to exceed three months or before the first use thereafter to ensure the proper functioning of components important to safet Replacement components shall meet design specification Ifproblems are found, the equipment must be removed from service until repaire Records are required for equipment problems and any maintenance performe Attachment 2 RIS 2005-10 Page 1 of 1 AVAILABILITY OF REFERENCE DOCUMENTS Below are the titles of the reference documents along with the URLs and the ADAMS accessionnumbers (e.g., MLxxxxxxxxx)., if availabl The URLs link directly to the documents that are posted on the NRC's public web sit For documents without an URL, NRC maintains anAgencywide Document Access and Management System (ADAMS), which provides text and image files of NRC's public documents. These documents may be accessed through the NRC'sPublic Electronic Reading Room on the Internet at http://www.nrc.gov/reading-rm/adams.html. If you do not have access to ADAMS or if there are problems in accessing the documents located in ADAMS, contact the NRC Public Document Room (PDR) Reference staff at 1-800-397-4209, 301-415- 4737, or by e-mail to pdr@nrc.go If no URL or ADAMS accessionnumber is indicated for the document then send a written request for a single, paper copy of the document to the Office of Administration, Distribution and Mail Services Section, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; or contact the PDR noted above.1.Federal Register notice (68 FR 41757, July 15, 2003), Denial of a petition for rulemaking[Docket No. PRM-34-5, Amersham Corporation]ML0506205682.10 CFR Part 32, Specific domestic licenses to manufacture or transfer certain itemscontaining byproduct material http://www.nrc.gov/reading-rm/doc-collections/cfr/part032/3.10 CFR Part 34, Licenses for Industrial Radiography and Radiation SafetyRequirements for Industrial Radiographic Operations http://www.nrc.gov/reading-rm/doc-collections/cfr/part034/ 4.American National Standards Institute (ANSI) N432-1980, Radiological Safety for theDesign and Construction of Apparatus for Gamma Radiography, (ANSI N432)

ML0508401395.NRC Enforcement Policyhttp://www.nrc.gov/what-we-do/regulatory/enforcement/enforc-pol.pdf6.NUREG-1556, Volume 3, Revision 1, Consolidated Guidance About MaterialsLicenses-Applications for Sealed Source and Device Evaluation and Registration, (Final Report, April 2004)ML041340618 http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v3/r1/ 7.Inspection Procedure 87121, Industrial Radiography Programs,http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/ip87121.pdf 8.NUREG-1556, Volume 2, Consolidated Guidance about Materials Licensees-Program-Specific Guidance about Industrial Radiography Licenses (Final Report, August 1998)

http://www.nrc.gov/reading-rm/doc-collections/nuregs/staff/sr1556/v2/ 9.NUREG-1631, Source Disconnects Resulting from Radiography Drive Cable Failures(June 1998)

Attachment 3RIS 2005-10Page 1 of 1Recently Issued NMSS Generic CommunicationsDateGC No.SubjectAddressees05/17/05IN-05-013Potential Non-conservativeError in Modeling Geometric Regions in the Keno-v.a Criticality CodeAll licensees using the Keno-V.acriticality code module in Standardized Computer Analyses for Licensing Evaluation (SCALE)

software developed by Oak Ridge National Laboratory (ORNL)05/17/05IN-05-012Excessively Large CriticalitySafety Limits Fail to Provide Double Contingency at Fuel Cycle FacilityAll licensees authorized topossess a critical mass of special nuclear material.04/18/05RIS-05-06Reporting Requirements forGauges Damaged at Temporary Job SitesAll material licensees possessingportable gauges, regulated under 10 CFR Part 30.04/14/05RIS-05-04Guidance on the Protectionof Unattended Openings that Intersect a Security Boundary or AreaAll holders of operating licensesor construction permits for nuclear power reactors, research and test reactors, decommissioning reactors with fuel on site, Category 1 fuel cycle facilities,critical mass facilities, uranium conversion facility, independentspent fuel storage installations, gaseous diffusion plants, and certain other material licensees.04/07/05IN-05-010Changes to 10 CFR Part 71PackagesAll 10 CFR Part 71 licensees andcertificate holders.04/01/05IN-05-007Results of HEMYCElectrical Raceway Fire Barrier System Full Scale Fire TestingAll holders of operating licensesfor nuclear power reactors, except those who have permanently ceased operations and have certified that fuel has been permanently removed from the reactor vessel, and fuel facilitieslicensees.Note: NRC generic communications may be found on the NRC public website,http://www.nrc.gov, under Electronic Reading Room/Document Collections.