ML103370448
| ML103370448 | |
| Person / Time | |
|---|---|
| Site: | 05000113 |
| Issue date: | 11/22/2010 |
| From: | Williams J Univ of Arizona |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML103370448 (9) | |
Text
Nuclear Reactor Laboratory THE UNIVERSITY OF John G. Williams, Director Engineering Building (20) A RD Z O N A E-mail: igw(engr.arizona.edu P.O. Box 210020 I Xo N f. Voice: (520) 621-9729 Tucson, Arizona 85721-0020 TUCSON ARIZONA FAX: (520) 621-8096 November 22, 2010 U.S. Nuclear Regulatory Commission 10 CFR 71 ATTN: Document Control Desk Washington, DC 20555-0001
Subject:
Revised Quality Assurance Program for the University of Arizona Research Reactor, Facility License No. R-52, Docket No. 50-113 This letter updates the University of Arizona's Quality Assurance Program previously submitted on November 1 for U.S. NRC approval.
We continue:
" No reactor operations,
" Storing fuel outside the reactor core so the core contains insufficient fissile material to attain criticality under optimum available conditions of moderation and reflection,
" Maintaining the reactor in a "secured" condition,
" Possessing the nuclear fuel,
" Our surveillance activities, and
" Maintaining the facility-including the storage, control, and maintenance of the spent fuel-in a safe condition until the defueling is completed.
By prior agreement, the DOE through its Reactor Fuel Assistance Program will assist in defueling our nuclear reactor following the end of operations.
I declare under penalty of perjury that the foregoing is true and correct. Executed on November 22, 2010.
John G. Williams, Director University of Arizona Research Reactor Attachment University of Arizona Assurance Quality Program, Revision 1 ).
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Revised Quality Assurance Program for the University of Arizona Research Reactor, Facility License No. R-52, Docket No. 50-113 dated November 22, 2010 Copies to:
John B. Hickman, NRC/FSME/DWMEP/DURLD Robert R. Temps--NMS-S/DSFS-T/LID/R
& Lin N: Tran, NRC/NRR/DPR/PRLB/
Patrick J. Isaac, NRC/NRR/DPR/PROB U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 U:S. NRC Region IV Texas Health Resources Tower 612 East Lamar Blvd.
Arlington, TX 76011-4005 Dr. Leslie Tolbert Vice President for Research University of Arizona P.O. Box 210066 Tucson, AZ 85721-0066 Acting Director Arizona Research Laboratories University of Arizona Gould-Simpson Bldg. 1011 P.O. Box 210077 Tucson, AZ 85721-0077 Daniel Silvain, Director Radiation Control Office University of Arizona P.O. Box 245101 Tucson, AZ 85724-5101
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QAP Quality Assurance Program 1 Page I of 7 11/2212010 University of Arizona QUALITY ASSURANCE PROGRAM 1 INTRODUCTION The Quality Assurance Program submitted here is to assist in the handling of shipments of TRIGA type reactor fuel, and other radioactive material. Specifically the program will cover activities related to the shipping of approved packages containing radioactive material.
The Quality Assurance Program will be the responsibility of the Reactor Supervisor at the University of Arizona. The transport of all radioactive material will be done by a licensed carrier.
The shipping container will be Type B containers with an approved Certificate of Compliance (CoC). The containers will usually be on lease or loan from entities such as the Department of Energy or prime contractor.
The University of Arizona does not design, fabricate, assemble, or test containers, and does not intend to procure any container for ownership or lease to others. The University of Arizona does not intend to rework, repair, maintain or modify the container.
The QA Program is submitted pursuant to 10 CFR Part 71.
2 ORGANIZATION Figure 1 shows the organization chart for the operation of the reactor facility. The Quality Assurance Program will be performed within the Operating Organization. The Reactor Committee will review and approve all written procedures. The Reactor Operation personnel and the Health Physics personnel will have primary responsibility for monitoring all packaging, shipping and receiving activities.
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Figure I 3 QUALITY ASSURANCE PROGRAM The scope of the program includes handling, loading, delivering to a carrier for transport an approved package for the transport of TRIGA fuel or other radioactive material. The shipments are planned to occur as a single transfer to unload the reactor core. Quality assurance will be exercised primarily through the use of written procedures constructed from regulatory requirements, applicable portions of the University of Arizona Research Reactor Procedures, University of Arizona Radiation Control Office procedures, specific procedures develop by the manufacturer of the package, and other procedures or safeguards developed during review of packaging and transportation planning. Quality Assurance will be effected by formatting these procedures as check-lists (or equivalent) to be used by the individuals or their designees who are responsible for quality assurance.
4 PACKAGE DESIGN CONTROL Design activities related to packages will not to be performed by the University.
5 PROCUREMENT DOCUMENT CONTROL Procurement activities related to packages will not be performed by The University of Arizona.
The proper procurement document control shall be the responsibility of the supplier of the designated package. The University QA program will include documentation of the currency of the cask CoC and its owner's QA Plan.
6 INSTRUCTIONS, PROCEDURES, AND DRAWINGS Activities important to safety will be ensured by following all manufacturer's instructions, procedures, and limitations as they relate to the safe use of the packages.
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QAP Quality Assurance Program I Page 3 of 7 11/22/2010 7 DOCUMENT CONTROL Control shall be exercised over the documents that are used in this shipping activity. The documents include a master document check-list, inspection procedures, loading and unloading procedures, package certification documents, radiation survey records, and shipping papers. All procedures and check-lists and changes will be approved either by the Reactor Laboratory Director, Reactor Supervisor, or the Radiation Control Office Director.
8 CONTROL OF PURCHASED MATERIAL, EQUIPMENT, AND SERVICES No materials or equipment are to be purchased for this activity. Control of equipment and materials will be carried out under the cask owner's approved QA Plan, subject to its CoC, using procedures and methods reviewed and approved by a Certified Level Ill Cask Operator. The University QA program will include documentation of the currency of the cask CoC and its owner's QA Plan. Any required services such as container off-loading and carrier transport will be procured via normal University procedures.
9 IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS No materials, part or components are to be identified or controlled for this activity. Replacement parts will be obtained from the manufacturer or certificate holder.
10 CONTROL OF SPECIAL PROCESSES Special process activities will be carried out under the shipping cask owner's approved QA Plan, subject to its Certificate of Compliance (CoC), using procedures and methods reviewed and approved by a Certified Level Ill Cask Operator. The University QA program will include documentation of the currency of the cask CoC and its owner's QA Plan.
11 INTERNAL INSPECTION The following inspection activities will be implemented for each package procured for shipping purposes:
11.1 Receiving Inspections Inspections will be performed to ensure the integrity of containers that are used for transportation purposes. Visual inspection will include surface conditions, structural integrity, gaskets and flanges, tie-downs, 1
labeling and marking, and other features as specified by the certificate holder.
11.2 FinalInspections Checklists will be established to ensure inspections are performed to verify:
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- 1. Proper package assembly
- 2. Moderators and neutron absorbers are present (if applicable)
- 3. Valves are set to specification and to prevent tampering
- 4. Shipping papers are properly completed
- 5. Packages are conspicuously and durably marked in compliance with USDOT regulations
- 6. Measures are established to ensure that appropriate personnel designated by the package user sign shipping tags or indicators prior to the authorization for shipping 11.3 Maintenance Inspections These inspections will not be performed under this activity unless specifically designated by the package standard operating procedures.
11.4 Inspection Documentation Inspection records will be maintained to document performance of inspection activities 12 TEST CONTROL 12.1 Procedures Measures will be established to ensure that applicable tests, surveys, or other measurements be performed according to manufacturer's instructions. Properly calibrated equipment will be used and methods for documenting tests will be established.
12.2 Acceptance Tests Measures will be established to ensure that acceptance tests (as applicable) are performed prior to offering a package for transport. Tests may include structural integrity, leak tightness, component performance, and shielding and thermal integrity.
12.3 Results Measures will be established to ensure that test results are documented, evaluated, and maintained as QA records. The Radiation Control Office Director will determine acceptability of the records.
13 CONTROL OF MEASURING AND TEST EQUIPMENT 13.1 CalibrationControl Gauges, reference standards, etc are not expected to be used for this activity. The exception to this is the use of radiation measuring equipment. This equipment will be properly calibrated with traceable standards according to existing standard operating procedures.
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QAP Quality Assurance Program I Page 5 of 7 11/22/2010 13.2 Out of CalibrationEquipment Radiation measuring equipment that is out of calibration will not be used.
14 HANDLING, STORAGE, AND SHIPPING CONTROL 14.1 Preservation Measures will be established to ensure that cleaning, handling, storage, and shipping are accomplished in accordance with the package design requirements to prevent damage or deterioration by environmental conditions. Provisions for use of special equipment such as cranes or lifting devices will to adequately identify and protect package components. Conditions identified in the CoC will be adhered to when unloading packaging.
14.2 Preparation,Release and Delivery to Purchaser Measures will be established to ensure that the following requirements are completed prior to shipping:
I. Cavities have been adequately dried
- 2. All conditions have been completed prior to offering for transport
- 3. All USNRC and USDOT requirements have been satisfied prior to offering for transport
- 4. All shipping papers have been completed and reviewed by qualified personnel for accuracy and completeness 15 INSPECTION, TEST, AND OPERATING STATUS A master check-list will be established to track the status of inspections, test, and operating conditions.
16 NONCONFORMING MATERIALS, PARTS, OR COMPONENTS This section does not apply to this activity.
17 CORRECTIVE ACTION 17.1 Reporting Causes of conditions that are detrimental to quality will be promptly identified and reported to the Radiation Control Office Director. Measures will be established to identify any corrective action from suppliers are obtained and that corrective actions were implemented and effective.
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QAP Quality Assurance Program I Page 6 of 7 11/22/2010 18 QUALITY ASSURANCE RECORDS 18.1 General QA records will be generated for each activity that is performed during the receipt, unloading, opening and closing, loading, preparation of shipping papers, and adherence to conditions specified by the manufacturer. The records will demonstrate delivery to a carrier and have evidence to show that USNRC and USDOT requirements have been satisfied.
Inspection and test records will identify the test or observation, show that the tests or inspections were complete, record test or survey data, identify any conditions that are non-conforming or are detrimental to quality, names of individuals performing the tests or inspections, and whether the results were acceptable.
18.2 GeneratingRecords Measures will be established to generate and store records. Paper copies of records generated will be stored in secure files. Additionally documents will be scanned in a pdf format for electronic storage.
18.3 Indexing and ClassificationRecords Records generated for these activities will be designated as non-permanent and will be retained for a period of at least 3 years.
18.4 Receipt, Retrieval, and Disposition of Records The records generated by these activities will be maintained by the Radiation Control Office Director. Procedures are in place for storage of records that relate to transportation and health physics activities that relate to the use of licensed material at the University.
18.5 Storage, Preservation,and Safekeeping Measures will be established to maintain records for the required period. Measures to be established include:
- 1. Prevention of damage from fire, flood, or other environmental damage
- 2. Record will be filed in folders in steel storage cabinets
- 3. Electronic records will be stored on a server which is backed up daily in a remote location
- 4. Unauthorized personnel will not have access to records
- 5. Electronic information is accessible to authorized users with password only access
- 6. Data will be electronically stored as read only pdffiles
QAP Quality Assurance Program 1 Page 7 of 7 11/22/2010 19 AUDITS 19.1 Elements of an Audit Program Due to the small number of uses of any package an audit will be conducted after each use of a package. An auditor will be appointed by the Reactor Committee or the Radiation Control Office Director. The conditions of Regulatory Guide 7.10 Section 18.1 will be met in establishing an audit program.
19.2 Scheduling of Audits An audit will be performed after each shipment to ensure that elements of the program are in place and that appropriate documentation was generated and maintained.
19.3 Team Selection Due to the small scope of this activity an independent individual will be chosen that has an understanding of the program and the requirements for compliance.
19.4 Various Audit Actions The auditor will meet prior to the audit to discuss scope and objectives and after the audit to discuss findings, clarify facts, and to ensure all appropriate information has been gathered. A report will be generated to identify deficiencies and a response is required to address deficiencies. The auditor will ensure that a schedule for resolving the items identified is presented and that corrective action is implemented.