Frontier Technology Corporation — Hazardous Materials Safety Interpretation

Page 1FEB 13 ZUUG Mr. Edward F. Janzow Ref. 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, Chief, Standards Developmer Office of Hazardous Materials Standards 173.476 060014#

Page 21/18/06 Radioactive Materials Branch, PHH-23 James Williams Office of Hazardous Materials Technology, Room 8430 .S. Department of Transportatio ipeline and Hazardous Materials Safety Administratio 100 Seventh Street, S.W Nashington D.C. 2059 202 366 6177 James. Williams@dot.gov Re: Special Form Radioactive Materials Certificate USA/0367/S, Revision 7 Dear Mr. Williams: Please verify the above. Sincerely, Eland 2 Jano#