U.S. Nuclear Regulatory Commission

Technical Assistance Request for Guidance on Exemption / Modification Per 10 CFR 34.20 to Industrial Radiography Equipment (Source Guide Tube)

HPPOS-293 PDR-9306220028

Title: Technical Assistance Request for Guidance on

Exemption / Modification Per 10 CFR 34.20 to Industrial

Radiography Equipment (Source Guide Tube)

See the memorandum from J.E. Glenn to D.M. Collins dated

August 19, 1992. This memo responds to a technical

assistance request by Region II concerning an application

by Fluor Daniel, Inc., for one-time-only modification of

the source guide tubes for Amersham (TechOps) cobalt-60

devices.

Guidance was requested by Region II on whether the licensee

requested exemption was acceptable. If it was acceptable,

guidance was needed on how the request should be granted

since Fluor Daniel is a South Carolina licensee operating

in NRC jurisdiction under reciprocity (10 CFR 150.20). It

was always the intention of NRC to grant exemptions to 10

CFR 34.20 for persons who have special requirements (see

enclosed Part 34 statement of consideration). After

reviewing the information submitted by the licensee in

their application, it was concluded that the proposed

administrative and radiation safety controls were

sufficient to meet the intent of the regulations and were

acceptable.

Regarding the request by Region II for guidance on how to

grant the exemption to Fluor Daniel, a general licensee, it

is normally recommended that exemptions of this type be

granted directly by license amendment. However, since

Fluor Daniel is a South Carolina licensee working under

reciprocity authorized by 10 CFR 150.20 and the requested

exemption is a one-time-only request for a limited period,

it was determined that the administrative procedure of

granting a temporary waiver of compliance to 10 CFR 34.20

(b) is appropriate.

Regulatory references: 10 CFR 34.20, 10 CFR 150.20

Subject codes: 11.1, 12.2, 12.9

Applicability: All