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)).