United States Nuclear Regulatory Commission - Protecting People and the Environment

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

HPPOS-207 PDR-9111210359

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

Page Last Reviewed/Updated Thursday, June 25, 2015