U.S. Nuclear Regulatory Commission

Licensing of Industrial Radiographers at NRC Licensed Operating Reactors an d Reactor Construction Sites

HPPOS-207 PDR-9111210359

Title: Licensing of Industrial Radiographers at NRC

Licensed Operating Reactors and Reactor Construction Sites

See the letter from D. A. Nussbaumer to All Agreement

States dated August 29, 1983. This letter states that

Agreement States radiography licensees working at NRC

licensed operating reactors and at reactor construction

sites are subject to the Agreement State's jurisdiction,

unless other factors apply. Factors that may apply include

exclusive federal jurisdiction over the land where the

reactor is located or the reactor is being built or

operated by a federal agency. HPPOS-197 contains a related

topic.

The NRC received inquiries concerning the licensing of

industrial radiography operations not only at reactor

construction sites, but also at NRC licensed operating

reactors. In some cases, the radiography was performed by

contracted radiographers and in other cases by the utility.

The specific question asked was whether such radiography

operations were considered to be "directly connected with

operations" and subject to exclusive NRC jurisdiction.

The OELD reviewed the question and advised that such

radiography is subject to Agreement State jurisdiction when

occurring in Agreement States (unless other factors apply

such as exclusive federal jurisdiction over the land where

the reactor is sited or the reactor is being built or

operated by a federal agency).

Regulatory references: 10 CFR 34, 10 CFR 150.20

Subject codes: 11.5, 12.2, 12.9

Applicability: All