ML19247B348
| ML19247B348 | |
| Person / Time | |
|---|---|
| Site: | 07100092 |
| Issue date: | 07/19/1979 |
| From: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Scherberger R EASTMAN KODAK CO. |
| References | |
| NUDOCS 7908080386 | |
| Download: ML19247B348 (4) | |
Text
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NUCLEAR REGULATORY COMMISSION
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WASmNGTON, O C. 20555
- e. r JUL 10 379
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FCTR: RHO 71-0092 Eas*. man Kcdak Co.rpany ATTN:
Mr. R. F. Scherbergec Building 320 - Kodak Park Rochester, NY 14650 Gen tlem.en:
This refers to your application dated Ano 20,19/8 requesting c;'nroval of your Quality Assurance (QA) program as.ceeting the QA progrum requireamts of 10 CFR 571.51.
In connection with our review, we need.he information identified in the enclosure to this letter. Please setim ; ;even copies of your response tn the enclosed request for adaitionai inforaation within 30 days following receipt of this letter.
Also, based on your interest in our acceptance criteria as discussed by our Mr. Fred L'aderbach with your Mr. E. Scott Harter during a telephone call cn. o 25, 1979, we are pleased to enclose a copy of our acceptance criteria dated April 2,1979 (Rev.1) for your information.
If you have an/ puestions regarding this request, please contact Mr. Fred Liederbach at (201) 392-7741.
Sincerely,
[
Charles E. MacCcnald, Chief Transpcrtaticn Branch Division of Fuel Cycle and Material Safety, NMS:
Enclosures:
1.
Request far Additional Infomation 2.
Acceptance Critaria Sill 2;10 790808033b
s EASD'AN KODAK COMPANY (71-0C82)
Request for Additicnal Infornation Clarify your application to provide a clear ccmaitment that trained, experienced, quali fied radiographers, as opposed to sales and marketing perscnnel, are responsible for handling, storage, sbiocing, inspection, test and operating status, and record keeping; and for overseeir.g the student radiographers in the safe use of radioactive sources.
It is not arketing Education Specialist (who is also your clear whether your v Radiation Safety Supervisor) is a trained.. experier.ced, qualified radiographer.
Individual resumes need not be submitted provided the above commi tment is made.
O 501
April 2, 1979 (Revision 1) 10 CFR PART 7i OA "2030",'i TOR INDUSTRIAL RADIOGRAPHY LICE
- BEES 1.
O rgan i za ticn The final responsibility f or the Quality Assurance (CA) Program for Part 71 Requirements res ts wi th (Ccopany Na,e).
Cesign and Fabrication shall not be conducted under this OA Prcgr3m.
The QA Progr3m is implenr.nted using the follcwing organization:
Note:
The Crganizational Chart as used in the licer.se 3pplicatici should te presentem.
It ay be advisabla to dccignate :he R3diation Safety Officer as the responsible individual for the Part 71 QA Requirements.
The Radiation Safety Of ficer is responsible for overall 3<dninis tration of the program, training and certi fic3 tion, document control, and audi ting.
The Radiographers are responsible for handling, storing, shipping, inspection, tc3t and operating st3tus and record keeping.
2.
Quality Assurance Program The management of (Company Program) establishes and implements this QA P ro g ra.1.
Training, prior to engagement, for all CA functions i > required according to wri t*an procedures.
CA Progr3m revisions will be 93Je procedures wi th -ar.agccen t 3; pro v 31.
The CA Progr3m according to writ.
.i will ensare that all defined QC procefures, engineering procedures, 3rd saecific provisions of the 03ckage desic.n apt :v31 3ra satisfied-The QA program sill erohasize ccntrol of tne c aracteris.ics of tne : 3:eage anich 3re cri *ical to s afety.
The Radia*..;n 23fety Of#.cer ; ball 3: sura indt all r3'li:3r*i.'e ~3'._ri3' 2n er a ;A ' :gr37 3:;rs.ec d
sni; ping pa'_ 3;es are designe: and nan ficiare:
Oy NLClejr Eigula t0ry :ornist i0n #ar all p3c.J;es desi; red or #ibtic3*ed after tne effecti/e date of the ;A Frogr37 Inis re :uirerert cin te satisfied bj r2ceiving a certifi:3 tion to this ef#ect fron.1e ~v Jactar2r.
3.
- ocu ment Coctrol All docurents related
- .o a specific shi;;ing package ill be c ntrclied through the ;se of writtcn proce jures.
All cocurer. changes aill te cerformed according to v,ri tten arcce dures 30; roved by mina;;~ent.
The Radiation Safety Cf ficer sr.ali insure tha t all C' f;ncticns are conducted in accordance aith the 13 test apolicible changes to t"ece g4 q dccurents.
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2.
4
' Handling Storage and Shipping Written safety procedures ccncerning the handling, storage and shipping of packages for certain special form radicactive material will be foll:wed.
Shipments will not be made unless all tests, certifications, acceptances, and final inspections have been completed.
Work instructicns will be provided for handling, storage, and shipping operations.
Radiography perscnnel sha.1 perform the critical handlin;, stortge and shipping operations.
S.
Inspection, Tes t and Operatir.g Status In s p ec t io n, test and operating status of packages for certain special farm radioactive naterial will be indicated and controlled by written procedures.
Status will be indicated t: tag, l a be l, T.a rk i n g o r l a g e n t ry.
Status of nonconforming parts or packages will be posi+ivel" maintained by written p rocedurcs.
Radiography personnel shall perform the regulatorf required inspecticas and tests in accordance with written procedures.
The Radiation Safety Officer shall ersure that these functions are perfol=ed.
6.
Qunlity Assurance Records Records of package approvals (including refer ~nces and drawings), procure-ment, inspections, tests, operatin; logs, audit results, persennel training and qualifications and records of ship cats will be maintained.
Ocscriptions of equipment and written procedures will also be maintained.
1hese records will be maintained in accardance with written procedures.
The records will be identifiable and retriesable.
A list of these records, with their storaga locations, will be maintained by the Fadiati:n Safety Of ficer,
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Established schec;1es of audits cf the QA prc;rar will be perfarr.cd using written che:k lists.
results of aulits will be maint tincl and reported t o man 2 ge r.- ' '
Audit reports will be evaluated and deficient areas co rrected.
The audi ts
.1 be dependent on the safety significance of the actr.ity being audited, but each activity will be audited at least once per year. Audit reports will be maintained 1 part of the quality assurance recor's.
Me-ters of the audit tear shall have no responsibility.-
.a2 activity beir.; audited.
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