ML19241B507
| ML19241B507 | |
| Person / Time | |
|---|---|
| Site: | 07100096 |
| Issue date: | 05/15/1979 |
| From: | Dunn N PAN AMERICAN WORLD AIRWAYS, INC. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 5-15-33-(9-9.1), NUDOCS 7907180732 | |
| Download: ML19241B507 (2) | |
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15 May 1979 x.nn.dy so.c. cont.,.,m,ia.22899 5-15-33 (9-9.1)
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_g Mr. Charles E. MacDonali, C h '.c f Transportation Branch
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Division of Fuel Cycle e..A d 4
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SUBJECT:
PAN AMERICAN WO?LD AIRLAYS, M
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1) 10 CFr 71.5.
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onted 27 April 1979;
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Telec n rt*viea Mr.
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Spraul, NRC,
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Martin, Pan American Health Ihysics, on 14 May 1979 Rela tiv e to the referenced letter and telecon, Pan American i
World Airways, Inc. (PAA), is requesting a 180-day extension commencing 27 May 1979 for submittal of a revised application describing the QA Program to be utilized by the licensee to meet the requirements of 10 CFR 71.51.
The requested extension is necessary, in part, as a result of impending changes to the status of PAA as a licensee.
The following is provided as background information regarding such changes.
As discussed with members of your staff prior to PAA's QA program submittal on 26 June 1978, and as reaffirmed during the referenced telecon with Mr. Spraul, PAA provides health physics services under contract to NASA and the USAF at Kennedy Space l
Center / Cape Canaveral Air Force Station (KSC/CCAFS), Florida.
NASA /KSC and the USAF at CCAFS have permanent, approved radia-tion protection programs currently in force in their locations.
D As part of the contractual health physics services to NASA /USAF, N
PAA is charged with the i=plementation of those programs.
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NASA /KSC has submitted an application to the NRC for a Byproduct p
Material License of Broadscope for NASA operations ot KSC/CCAFS.
hh' Upon issuance of the NASA /KSC license, it is PAA's intent to l7 transfer all radioactive materials currently maintained under the f
PAA license to the NASA /KSC license.
(It should be noted that s
all radioactive materials maintained by PAA are government ftp p
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PAN AMERICAN UORLD AIRWAYS,'
INC. QA PROGRAM 15 May 1979 Page 2 5
property.)
This action will eliminate the necessity for PAA to maintain the subject QA Program as a licensee of the NRC.
It is anticipated that NASA /KSC will tvd issued their broad-scope license within the 180-day extension pe.riod requested.
i At the present time FAA does not possess, nor does it expect I
to possess, Type B, large quantities, and fissile materials.
If any such materials are to be acquired by PAA for the benefit of the government, their acquisition will be contingent upon them being transported in manufactured containers which have been constructed under an NRC approved QA program.
In all cases, PAA will require a written certification from the transferring licensee for each shipping container.
Your consideration of the abc"e request will be appreciated.
(
htmly Nett e M.
- Dunn, M.D.
Medical Director Chairman, PAA Radiation Safety Committee RK:I/ g a t I
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IJNITED STATES
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Dr. Nettie M..Dunn l
Kennedy Space Center, FL 32899
. Gentlemen:
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. This refers to your application dated June 26, 1978 requesting approval of your Qualitty Assurance (QA) program as meeting the QA program requirements of 10 CFR 71.51..,
In connection with our review, we have determined that _your orocosed QA program does r.ot meet the recuirements of Appendi_x.E _to_ lq,CF_R,_._
Part 71.
To_ assist you in revising your application, we have enclosed a sample QA program for industrial radiography licensees dated April 2, 1979.
J Please submit seven copies,of your, revised application within 30 days of the date of this letter.
If you have any questions regardiiig this request, please contict"Mr. Jack _Spraul at (301) 492-7741.
Sincerely, h,.
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Charles E. MacDonald, Chief Transportation Branch
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Division of Fuel Cycle and Material Safety, NMSS R
Enclosure:
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Sample QA Program
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April 2, 1979 (Revision 1) 10 CFR PART 71 OA PROGRAM FOR INDUSTRIAL RADIOGRAPHY LICENSEES
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1, Organization The final. responsibility for.the Quality Assurance (QA) Program fo'r Part i
-hi 71 Requirements rests with (Company Nr.me).
Design and Fabrication shall not be conducted under this QA Program. The QA Program is implemented'
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I using the following organization:
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Note:
The Organizational Chart as used in the license application -
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should be presented.
It may be aditisable.to des.ignate the v-
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Radiation ScFety Officer as the responsible individual for
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the Part.71 QA Requirements.
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The Radiation Safety Officer is responsible for overall adminiskation of '
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the program, training and certification, document controi, and aud3ing.
The Radiographers are responsible for handling, storing, shipping,
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inspection, test and operating status and record keeping.
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Quality Assurance Program it The management of (Company Program) establishes and implements this QA Program.
Training, prior to engagement, for all*QA functions is required
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according to written procedures. QA Program revisions will be made according to written procedures with management approval. The QA~ Program will ensure that all defined QC procedures, engineering procedures, and l'
I specific provisions of-the package design approval are satisfied. The c
QA program will emphasize control of the characteristics of the package
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The Radiation Safety Officer shall assure that all~ radioactive material '
shipping packages are designed and manufactured under a QA Program approved by Nuclear Regulatory Commission for all packages designed or fabricated
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y; after the effective date of the QA Program.
This requirement can be s
satisfied by receiving a certification to this effect from the manufacturer.
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Document Control y
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All documents related to a specific shipping package will be controlled N
through the use of written procedures.
All document changes will be perfomed according to written procedures approved by mana;ement.
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The Radiation Safety Officer shall insure tha
'l A functions are k_j conduced in accordance with the latest appli jd
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.i) j Handling Storage and Shipping t-Written safety procedures concerning the handling, storage and shipping f,]
of packages for certain special form radioactive material will be followed.
Shipment, will not be made unless all tests, certifications, acceptances, mg and fir t1 inspections have been completed.
Work instructions will be gij proviced for handling, storage, and shipping operations.
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Radiography [ personnel 'shall p.erform the critical handling, storage and
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shipping operations.
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Inspection,' Test and Operating Status
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Inspection, test and operating status of packages for certain special form radioactive material will.be indicated and controlled by written
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procedures.
Status wil'1 be indicated by tag,--label, markir.g or log entry.
Status of nonconforming parts or packages will be positively maintained by
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s-written procedurcs.
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Radiography personnel shall perform the regulatory required inspections an'd tests in accordance with written procedures.
'Ihe_ Radiation Safety. Officer shall ensure that these functions are performed.
Quality 'ssurance Records 6.
A Records of package approvals (including references and drawings), procure-ment, inspections, tests, operating logs, audit results, personnel training and qualifications and records of shipments wi1} be maintained.
Descriptions
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of equipment and written procedures will also be maintained.
Rese records will be maintained.in accordance with written procedures.
H e records will be identifiable and retrievable.
A list of these records, with their storage locations,.will bc =aintained by the Radiation Safety Of ficer.
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7.
Audits
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.t Established schedules of audits of the QA Program will be performed using
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Results of audits will be maintained and reported f{
to management.
Audis reports vill be evaluate 21 and deficient areas corrected.
ne audits will be dependent on the safety significance of the activity being C(
audited, but each activity will be audited at least once per year.
Audit reports will be maintained as part of the quality assurance records.
Members f(
of the audit team shall have no responsibility in the activity being auditet!.
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