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

HPPOS-293 PDR-9306220028

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

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