U.S. Nuclear Regulatory Commission

Question 108: Can the surveys of radiographic exposure

devices performed under 10 CFR 34.43 (b) and (c) be used to

show compliance with 10 CFR 20.1906 (f)? If so, is it

sufficient to document the survey once, to satisfy both

requirements?



Answer: The survey performed to show compliance with 10

CFR 34.43 (c) can be used to show compliance with 10 CFR

20.1906 (f). It is sufficient to document the survey

results one time.



The survey performed to show compliance with 20 CFR 34.43

(b) cannot be used to show compliance with 10 CFR 29.1906

(f). The purpose of the survey performed under 10 CFR

20.1906 (f) is to ensure the radioactive source is still

properly lodged in its shield after transport. (Reference:

10 CFR 20.1906 (f), 34.43 (b), and 34.43 (c)).