ML20212E354

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Submits Response to QA Program Submittal.Separate QA Program Approval No Longer Needed as Result of Changes to Program
ML20212E354
Person / Time
Issue date: 09/17/1999
From: Eng P
NRC (Affiliation Not Assigned)
To: Schaan C
MARYLAND, STATE OF
References
NUDOCS 9909240211
Download: ML20212E354 (1)


Text

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September 17, 1999 Mr. Chuck Schaan

- Radiation Safety Officer C&J's NDT, Inc.

' P.O. Box 7025 Bismarck, ND 58507-7025

SUBJECT:

RESPONSE TO QA PROGRAM SUBMITTAL

Dear Mr. Schaan:

The Nuclear Regulatory Commission (NRC) published a final rule, effective June 27,1997, revising the requirements of 10 CFR Part 34, " Licenses for Industrial Radiography and Radiation Safety Requirements for Industrial Radiographic Operations." The revision, which contained numerous changes in the requirements, CM nodified the Quality Assurance (QA) requirements for transportation. ' As a result of these changes, a separate NRC QA program

.approvalis no longer needed.

Specifically, regarding transportation activities, a new paragraph,10 CFR 71.101(g), was added to the regulations which provides that inspection and maintenance programs limited to radiographic exposure devices, source changers, or packages transporting these devices and meeting the provisions for 10 CFR 34.31(b), or equivalent Agreement State regulations, satisfy the general license requirements specified in 10 CFR 71.12(b) for Type B transport packages.

On July 29,1999, you transmitted by fax a document titled, "10 CFR Part 71 Transportation QA Program for Industrial Radiography and Sealed Sources." In that transmittal, you did not indicate that you were seeking NRC approval of your QA Program. Through phone conversations with Mr. Temps, on September 2,1999, we understand that you submitted the

document at the request of the North Dakota Department of Health in relation to a radiography-related license application you filed with them. Provided your radiography program meets the provisions of 10 CFR 71.101(g), you are not required to obtain approval from the NRC for your QA program. Therefore, we plan no further action regarding the QA document you sent us.

-There is no need for you to respond to this letter, if you have further questions, please contact Robert Temps of my staff (telephone: 301415-2552, e-mail: RRTONRC. GOV).

Sincerely, Patricia L. Eng, Section Chief Transportation and Storage inspection Section Spent Fuel Project Office, Office of Nuclear lO Material Safety and Safeguards DISTRIBUTION:

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