ML19207B248
| ML19207B248 | |
| Person / Time | |
|---|---|
| Site: | 07100261 |
| Issue date: | 07/10/1979 |
| From: | Beard P NAVY, DEPT. OF |
| To: | |
| Shared Package | |
| ML19207B247 | List: |
| References | |
| 9893.1, NUDOCS 7908230675 | |
| Download: ML19207B248 (5) | |
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OEPARTMENT OF THE NAVY
/ by' UA \\
USS SIMON LAKE AS 33 P
FPO NEW YORK 09501 sun;UE.D:ST 9893.1 NC/,
AS33/04:cle SD10N IAKE INSDUCTION 9893.1
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M Subj: Quality assurance program for radioactive material shipping packages
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associated with radiography r:v W
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(a) Title 10, Code of Federal Regulations, Palt 71.51 7
'b) Internal Inspection Systm (NUT I.udit Plan)
Encl:
(1) 10 CFR Part 71 QA Program for Industrial Padiooraphv licensees 1_
(2) QA Program Implenentation Instructions 1.
Purpose. To establi_h and maint.in an auditable OA program for shipping packages Tor radioactive mterial asrociated with radicgraphy.
2.
Background. Peterence (a), establishes the requirment for SI'Gi IAKE to execute the subject QA program and states the recuired attributes of the prcgram 3.
Scope. This instruction applies only to shipping packages intended for use with radioactive material associated with radiography.
It specifically does not apply to shipping of radioactive materials associated wie naval nuclear propulsion plants.
4.
Procedures. Pnclosure (1) is hereby established as the basic OA program for SUDJ UsKE for designing, purchasing, fabricating, handling, shipping, storing, cleaning, assenbling, inspecting, testing, operating, mintaining, repairing, and rnodifying packages for use in shippirg radioactive mterials associated with radiography. Enclosure (2) contains mre detailed instruc-tions and responsibilities for executing this OA program.
5.
Action. The Padiographic Safety Officer (RSO), under the sumrvision of the Repair Officer, shall implanent, execute and maintain this QA prccram as out-lined in enclosures (1) and (2).
r P. M. BEARD, JR.
o Ccrmanding Officer q
t Distribution:
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n 10 CFR PART 71 OA PRrG'If t I
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FOR INDUSTRIAL RADIOGPI.PHY IlCD'SFS 1.
Organization
'Ihe final responsibility for the Quality Assu ance (OA) Procram for Part 71 Recuirments rests with SImi I1EE. Desian ar.d Fabrication shall not be con-ducted under this OA Program.
The QA Program is inplme-ted using the follow-ing organization:
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CCtPANDING OFFICER
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l PEPAIR GTICER 3
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RADIOGPAPHIC SAITn' CFFICER RADIOIOGICAL C07fROLS C71CE2 (FOR SHIPPING)
SENIOR PADIOGRI@HER
_RADI ADHFRS The Radiographic Safety Officer (RSO), is resnonsible for over 1 administra-tion of the procran, training and certification, document control, and auditing.
The Radiographers are responsible for handling, storina, shipping, insprtion, test and operating status and record keepina.
2.
Cuality Assurance Program The rmnagcment of SIf10N I1EE establishes and implenents this OA Progran.
TrM g, prior to engagcnent, for all OA functions is recaired according to ten procedures. OA Program revisions vill be made according to written pr edures with managcment approval. The nA Procran vill ensure that all defined QA procedures, engineer.ing procedures, and specific provisions of the package design approval are satisfied. The nA program will cripbasize control of the characteristics of the pac.kage which are critical to sarety.
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'Ihe Radiographic Safety Officer shall assure tMt a]1 radioactive material sbip-ping packages are designed and nanufactured under a OA Program arproved by Nuclear Pegulatory Commission for all packages designed or fabricated after i
the effective date of the OA Program. This rwuircnent can be satisficd by receiving a certification to this effect fran the nanufacturer.
3.
Document Control All documents related to a specific shipping oackage will be controlled through the use of written procedures. All doc r:ent changes vill be oerfomed according to written procedures approved bv -anagcnent.
g The Radiographic Safety C"Ficer shall insure 9at all GA functions are conducted Enclosure (1)
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k da in accordance with the latest applicable changes to these documents.
4.
Handling Storage and Shipping Written safety procedures concerning the handling, storage and shipping of packages for certain special fom radioactive material vill be folloved.
Shiprients will not be nade unless all tests, certifications, acceptances,
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and finai inspections have been ecmpleted. Nork instructions will be pro-vided for handling, storage, and shipping operations.
l Padiogrephy personnel shall perfoun the critical handling, storage and ship-h ping operations.
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Inspection, Test and Operating Status
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Inspection, test and operating status of packages for certain special fom radioactive mterial will be indicated and controlled by written procedures.
Status will be indicated by tag, label, mrking er log entry. Status of non-conforming parts or packages will be positively naintained by vritten pro-cedures.
Padiography personnel shall perfom the regulatory recuired insoections and tests in accordance with written procedures.
'Ihe Padioaraphic Safety Of ficer shall ensure that these functions are performed.
6.
Quality Assurance Records Pecords of package approvals (including references and drawings), prcr ure-nent, inspections, tests, operating logs, audit results, personnel training and aualifications and records of shiprients eill be maintained. Descriptions of equirnent and written procedures will also be maintained.
These records will ce maintained in accordance with written procedures. The records will be identifiable and retrievable. A list of these records, with their storage locations, will be maintained by the Radiographic Safety Officer.
7.
Audits Established schedules of audits of the GA Program will be performed usiig written check lists.
Pesults of audits will be mintained and reported to managment. Audit reports will be evaluated and deficient areas corrected.
The audits will be dependent on the safety significance of the activity being audited, but each activity will be audited at least cnce per year. Audit reports will be naintained as part of the cuality atsurance records. Manbers of the audit team shall have no responsibility in the activity beirq audited.
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Enclosure (1) l l
OA Procram Implmenting Instructions l.
Scope. Design, fabrication, repair or redification of shipping packages for radioactive material associated with radiocraphy shall not Fe conducted by SIrm IAKE.
2.
Responsibilities.
In addition to the restonsibilities identified in enclosure (1), the Padiological Controls Officer is resnonsible for the ship-E ping of all radioactive materials.
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3.
Training.
i e
rs a.
Radiographic Safety Officer: Shall te trained in accordance with
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course of instructions given at the 1 2 Schocl, San Dieco, California or at 3
the Naval Nuclear Power Unit at Port Huenme, California and this instruction.
t b.
Padiographers: Shall be trained in accordance with course of instruc-tion given at the Im School, San Diego, California and this instruction.
c.
Padiological Controls Shipping Perscnnel: Shall be trained in accor dance with Article 108 of MAVSHIP 389-0153 (RadiolcxTical Controls), Title 10 CFR, Parts 49 and 71, CCESUPH0;TINST 9900.8A and this instruction.
4.
Document Control. All documents related to a specific shipping package will be controlled in accordance with CCTEU31;cmST 9900.8A.
5.
Handling, Storage and Shipping. Safety procedure.c concerning the handling, storace and shipping of packagee 'nd rssociated verk instructing will be as in strict empliance with CCMSCBLE'II ST 9900.2A, and SImHNTINST 9900.2F.
6.
Inspection, Tes_t and Ooerating Status. SI'Di II.KE Instruction %3.2P, and Title 10 Part 71 specify the inspection and test requircrents and the required operating status of radioactive mate"ial shipping packaces.
Per-sonnel ciualified as radiographers onboard SI'm IRC shall perfom the re-cuired inspections and tests in accordance with these directives.
7.
Quality Assurance Records. The list and locations of recuired records are to be in accordance with Appendix A to this enclosure.
8.
Audits. Audits of the OA program will te parformed using prepared audit plan provided bv the QA Officer.
Audit reports will te evaluated and deficient areas corrected. All areas will be audited at least annually using itms A. 3.a (1) through (6) and (8) and B.2.a,b,d,g,i,j,k,1 and m of reference (b).
Use of other applicable docunents and specifications are encouraged and will be provided by the Radiographic Safety Officer for use during audits. The Audit Team shall consist of two Repair Depam2nt Officers appointed bv the Repair Officer. Audit members will have no direct responsibilities in the areas being audited. Audit rmbers will forwtrd a written renort of discre-l pancien noted during the audit to the Ccrrmding Officer via the %diographic Safety Officer (RSO), and the Repair Officer. A file of audit results and corrective action taken sball be maintained by the PSP.
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i Enclosure (2) l p(
LIST OF RECOPDS ASSOCIATED WITH USS S2m I1EE DA PPDGRV1 FOR MATERIAL ASSOCIATED WITH PIDIOrPAPHY 12;D LIST OF PECORDS ASSOCIATED IfITH USS SI'm Ilde OA PTUFAM FOR SHIPPING PACKAGES FOR RADIOACTIVE IGTERIAL ISSOCIICED NI'IH RADIOrpJrpHy r
h PECORD OR DOCLM2;T LOC 7CICt{
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a.
Training of radiographers
! E Office Files j
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Training of PNXXN Shipping Personnel PADCCt; Division Files and f
individual Service Records t
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Shipping Container Certification NUT Office Files (As Paceived) d.
Written Safety Procedures
? M Office Files (SLI 9900.2F) e.
Peco.a of Tests and Inspections I;IT' O'fice Files and of Containers Prior to Shipping PXX17 Division Files f.
Written Procedure for Handling I m Office Files and Stowage (SLI 9900.2F) g.
Written Procedure f.;r Shipping PADCON Division Files (N/S 389-0153 and Title 10 CFR, Part 49) h.
Pecords of Operational Status im Office Files
- i. I;on-confo.miance Ezcords
? K Office Files i
- j. Audit Scheaule and Results
- E Office Files k.
Shipping Documents FADIt; Division Files l.
Audit Check List BE Office Files m.
Mritten Procedures for Changes Ship's office to the QA Progran
?;avy Correscondence :'anual
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I Appendix A Enclosure (2)
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