Interpretation Response #06-0014
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Feb 13, 2006
Mr. Edward F. Janzow
Reference No. 06-0014
Frontier Technology Corporation
1641 Burnett Drive
Xenia, OH 45385
Dear Mr. Janzow:
This responds to your letter dated January 1, 2006, requesting an interpretation of the phrase "satisfy the requirements of Subpart H of 10 CFR 71" in paragraph 4 of "Special Form Radioactive Materials Certificate," USA/0367/S, Revision 7.
Your understanding is correct. Although you are required to have and to implement a "Quality Assurance Program" as detailed in Subpart H of 10 CFR 71, you are not required to obtain a Nuclear Regulatory Commission (NRC) approval of your program nor obtain an NRC Certificate of Compliance (CoC) for special form radioactive materials, which are limited to those materials which, if released from a package, would present a hazard due to direct external radiation only.
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
173.476
Regulation Sections
| Section | Subject |
|---|---|
| § 173.476 | Approval of special form Class 7 (radioactive) materials |