ML19249C909
| ML19249C909 | |
| Person / Time | |
|---|---|
| Site: | 07100236 |
| Issue date: | 08/10/1979 |
| From: | AMERICAN AIRLINES, INC. |
| To: | |
| Shared Package | |
| ML19249C908 | List: |
| References | |
| NUDOCS 7909190276 | |
| Download: ML19249C909 (4) | |
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Quality Assurance Requirements for Packaging of Radioactive Material for Trans-pcrt (10 CFR Part 71 QA Program)
A.
Introduction CFR-71 " Packaging of Radioactive Material for Transport and Transportation of Radioactive Material Under Certain Conditions" requires a description of the QA program applicable to shipping packages and a QA program for the design, fabrication, assembly, testing, use, and maintenance of the shipping packages.
B.
Orcaniza tion _
l.
The final responsibility for the Quality Assurance program for 10 CFR Part 71 requirements rests with the American Airlines Maintenance and Engineering Center.
2.
Within the Maintenance and Engineering Center, the Quality Assurance Division develops radiological techniques using the licensed isotopes; administers the training, records keeping, handling, storage, shipping, inspection, test and audit programs; and uses the isotopes to obtain radiographs of aircraf t and engine structure and canponents.
Vice President Maintenance & Engineering R. J. Masiello Senior Director Quality Assurance W. W. Schaefer Manacer Nondestructive Testing QA C. R. Anderson The Manager Nondestructive Testing QA has the overall responsibility for the development of all nondestructive testing programs, which includes the Isotope Radiography Program.
Radiation Safety Officer B. W. Nethercutt The Radiation Safety Officer is responsible for overall administration of the package QA program, training and qualification of personnel, certification of equipment, and document control.
Radiograohers The Radiographers are responsible for assembling, maintaining, clean-ing, handling, storing, shipping, inspection, test, operating status, and record keeping of licensed isotopes and packages.
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Applicability Transport packages used by American Airlines are Type B, Nuclear Regulatory Comission approved, packages.
Certificate of Package Model Contents Compliance No, Identification flo.
650 1R-192 9032 USA /9032/B 660 1R-192 9033 USA /9033/B 500SU 9006 USA /9006/B D.
Quality Assurance Program 1.
This Quality Assurance Program applies to all activities affecting the components of the packaging which are significant to SAFETY. This includes purchasing, handling, shipping, storing, cleaning, assembling, inspecting, testing, operating, maintaining, repairing, and modifying transport packaging.
2.
Certification from vendors may be used for areas not under the direct control of American Airlines such as design, fabrication, assembly, initial testing, repair and modit' cation of packaging components.
The Radiation Safety Officer shall assure that all radioactive material shipping packages are designed and manufactured under a quality assur-ance program approved by the Nuclear Regulatory Commission for all packages designed or fabricated after January 1,1979. This require-ment may be satisfied by receiving a proper certification from the manufacturer.
The Radiation Safety Officer shall assure that packaging sent to vendor for repair or modification after January 1,1979, is repaired or modified under a Quality Assurance Program approved by the NRC.
This requirement may be satisfied by receiving a proper certification from the vendor.
3.
The authority for American Airlines to use an NRC-approved package is contained in the gtaeral license in 10 CFR Part 71 paragraph 71.12 following registration by American Airlir.es with NRC and submission of certain other infonnation. Compliance with the provisions of the general license is mandatory.
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4 The Tadiographer concerned is resoonsible. for all ' aspects of the trans-portation package. He shall determine that all cuality assurance provisions for the package have been followed and to describe to the NRC (through documentation) how that detennination was made.
5 The Radioisotope training program, as outlined in the NDT Manual, will be completed prior to assuming responsibility within the QA program for packaging materials.
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Quality Assurance Program 6.
Revisions to this QA program will be made in accordance with pro-cedures outlined in the General Section of the NDT Manual, page 15, 7.
Radiographers will assure that all applicable QA procedures, engineer-ing procedures and specifications and specific operating procedures of the package manufacturers are satisfied. The QA program will emphasize control of the characteristics of the package which are critical to SAFETY.
E.
Document C introl All documents related to a specific shipping package will be controlled through the use of established procedures as stated in the General Section page 15 of the NDT Manual.
The Radiation Safety Officer will be responsible for manual revisions and insure they comply with the NRC and company regulations.
F.
_ Handling, Storage, and Shipping Written safety procedures concerning the handling, storage, and shipping of packages for certain special form radioactive material will be follcwed.
These safety procedures are as specified in 10 CFD Part 71.51. Shioments will not be made unless all tests, certifications, acceptances, and final inspections have been completed. All shipments will be in full compliance with the Air Transport Restricted Articles Circular No. 6-D.
Handling, Storage, and Shipping instructions are included in the NDT Manual, pages 65, 66, 66A, and 67.
Qualified Radiographers shall perfom the critical handling, storage, and shipping operations.
G.
Inspection, Test, and Operating itatus Inspection, test, and operating status of packages for certain special fom radioactive material will be controlled by written procedure in the Nui Manual, page 61 and 62. Status will be indicated by tag, label, mark-ing, or log entry. Status of nonconfoming parts or packages will be positively maintained by written procedures.
Qualified Radiographers shall perfonn the regulatory required inspections and tests in accordance with written procedures as stated in the NDT. Manual.
The Radiation Safety Officer shall assure that these functions are perfomed.
H.
Quality Assurance Records Records of packace approvals (ine,luding references and drawings), inspections, test, operating logs, audit results, personnel training and qualifications, and records of shipments will be maintained. Descriptions of equipment and written procedures will also be maintained.
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Quality Assurance Records (Continued)
The Radiation Safety Officer will maintain the records or logs as required by the NDT Manual or have access to such records.
I.
Audi ts Established schedules of audits of the Quality Assurance Program will be performed using written check lists. The auditor or auditors will have no responsibility in the activity being audited. Results of audits will be maintained and reported to management. 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 once per year. Audit reports will be maintained as part of the quality assurance records.
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