ML19256F191
| ML19256F191 | |
| Person / Time | |
|---|---|
| Site: | 07100087 |
| Issue date: | 10/24/1979 |
| From: | NAVY, DEPT. OF |
| To: | |
| Shared Package | |
| ML19256F190 | List: |
| References | |
| NUDOCS 7911280320 | |
| Download: ML19256F191 (17) | |
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a U.S.S. PIEDMONT AD-17 Fleet Post Office New' York New York 09301 AD17 INST 9090.3
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4 QUALITY ASSURANCE PROGRAM FOR THE PACKAGING OF RADIOACTIVE MATERIAL FOR TRANSPORT AND TRANSPORTATION e
k-0F RADIOACTIVE MATERIAL UNDER CSRTAIN CONDITIONS (10CFR71) l U.S. NUCLEAR REGULATORY CO)SilSSION MATERIALS LICENSE No. 31-17753-01 i
LICENSEE:
DEPARTMENT OF THE NAVY USS PIEDMONT (AD-17) 1705 288 FPO NEW YORK, NEW YORK 09501 7911280 3 d C i
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AD17 INS 59090.3 DEFINITIONS The following terms are defined as they are intended to be used in this instruction.
".5 ik CFR - Code of Federal Regulations y
Licensed activity; license - USS PIEDMONT (AD-17)
Licensed materials - Those materiale for which USS PIEDMONT holds an NRC approved license.
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NRC - U.S. Nuclear Regulatory Commission NDT Laboratory - Non-destructive Test Laboratory l
Package - A shipping container for licensed radioactive materials RMPQA Of ficer - The Quality Assurance Officer for the RMPQA program-charged with in-specting and auditing to verify the program RMPQA Program - Quality Assurance Program for the Packaging of Radioactive Material for Transport and Transportation of Radioactive Material Under Certain Conditions (10CFR71)
RSO - Radiographic Safety Officer
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ADl7 INST 9090.3 TABLE OF CONTENTS SN 9
I PAGE F
Implementing Instruction Title Page i
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Record of Revisions 11 Table of Contents 111 Definition i
Orgnaization I-1 Quality Assurance 11-1 Document Control III-1 Handling, Storage, and Shipping IV-1 Inspection, Test and Operating Status V-1 Quality Assurance Records VI-1 Audits VII-1 1705 290 iii E.
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AD171NST 9'090.3 Section One - ORGANIZATION 1.1 Purpose. This section sets forth the organizational responsibilities in the E u..
RMPQA Program.
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1.2 Description. The RMPQA Program is composed of four levels of responsibility:
Commanding Officer - By definition the senior official of the licen' sed acti-a.
vity, hs is responsible for the establishment and execution of the RMPQA Program. Re-visions to the program may be authorized only by him. The Commanding Officer assigns and certifies the qualification of the RMPQA Officer.
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b.
Repair Officer - In his role as Head of Department which actually uses licensed materials the Repair Officer has a vested interest in the RMPQA Program. Therefore, he is resposible for ensuring that the RMPQA Officer has sufficient organizational freedom to fulfill his function and for ensuring that corrective action (s) is/are ac-r complished in an effective, timely manner and is/are not being delayed by production schedules or other conflicts.
c.
Radiographic Safety Officer (RS0) - Responsible for the safe receipt, handling, operation and shipment of licensed materials in/by the NDT Laboratory, the Radiographic Safety Officer is responsible for the following attributes of the RMPQA Program:
(1) Ensuring that shipments of licensed materials used by the NDT Laboratory are conducted in accordance with references (a), (b), and (c).
(2) Ensuring that required inspection and testing incideptal to shipment of licensed materials used by the NDT Laboratory are properly conducted and documented.
(3) Ensuring that corrective action, when required, is accomplished by the NDT Laboratory in an effective, timely manner.
(4) Ensuring that personnel under his cognizance assigned to use licensed material are trained in the requirements of this instruction and references (a) and (b).
d.
RMPQA Officer.
The RMPQA Officer shall be certified as to his qualification and appointed by the Commanding Officer.
His primary function in the RMPQA Program is I
the verification of the credibility of the program. In this regard he is responsible for:
(1) Development of an audit schedule for approval by the Commanding Officer.
(2) Conducting or directly supervising the conduct of all audits of the RMPQA program.
(3) Conducting or directly supervising the conduct of unannounced spot checks of the RMPQA Program.
C (4) Reporting his findings directly to the Commanding Officer with copies to the Repair Officer, and RSO.
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(5) Conducting follow-up' audits to ensure corrective action is accomplished.
1.3 Appendices. Appendices (A) and (B) to this section contain an organizational chart and matrix which graphically display the division of responsibility of the above func-tions into four levels of responsibility.
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AD171NST 9090.3 SECTION ONE
' APPENDIX "A" a...
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ORGANIZATIONAL CHART COMMANDING 0FFICER Li i
RMPQA REPAIR
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OFFICER OFFICER RADIOGRAPHIC 9AFFTV OFFiCFR o
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AD171NST 9090.1 SECTION ONE
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APPENDIX "B" g~1:
RESPONSIBILITY MATRIX RADIOGRAPHIC t-COMMANDING REPAIR SAFETY RMPQA FUNCTION OFFICER OFFICER OFFICER OFFICER
,7-PROGRAM A
E E
E TRAINING A
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I CERTIFI-B E
CATION TESTING B
E DOCUMENT A
C D
CHANGES SHIPPING A
C E
AUDITS B
E AUDIT A
C D
SCHEDULE LEGEND l
A - Approve t
B - Accept I
C - Concur D - Initiate E - Perform 1705 294 1-B l'
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_ _._ m _ __. _ _..... a _._.. m SECTION TWO - QUALITY ASSURANCE PROGRAM 2.1 Purpose. This section specifies the necessary action which must be undertaken to successfully establish and execute a viable quality assurance program for pack-aging licensed materials.
4f, C-2.2 Discussion. PIEDMONT is licensed to use certain radioactive materials as speci-fied in reference (a). As an end-user PIEDMONT receives these materials from NRC licensed suppliers in :Gus approved containers. Therefore, the thrust of th,e QA Pro-gram aboard shall be directed toward establishing proof of and maintaining the quality of. approved ~codtainers. Manufacture or repair of shipping containers for licensed materials shall not be conducted aboard PIEDMONT without prior approval by the NRC.
2.3 Procedure.
The promulgation and enforcement of this instruction by the appropriate a.
levels of the chain of command establishes and implements the RMPQA Program.
b.
Training and experience for all RMPQA Program functions shall be in accor-dance with established procedures:
(1) The Commanding Officer and Repair Officer, are specifically assigned by the Bureau of Naval Personnel in accordance with established directives.
(2) The Radiographic Safety Officer shall be assigned by the Commanding Officer.
(3) The RMPQA Officer shall be assigned and certified by the Commanding Officer following completion of Appendix (A) to this section.
(4) Radiographers shall be qualified in accordance with reference (A).
c.
Revisions to the QA Program may be made only by a formal change to this instruction signed by the Commanding Officer. Revisions which would significantly alter the program must be approved by the NRC.
Each revision shall be entered in the manner directly by the revision and documented on the Record of Revisions page, d.
Prior to use all defined quality control procedures, engineering procedures, and specific provisions of the package design approval shall be satisfied for any shipping package used in conjunction with licensed material.
r-(1) Documentation of this shall be maintained onboard PIEDMONT for any con-tractor-supplied shipping containers for use with licensed materials.
(2)
Specific approval by the NRC shall be obtained, documenting the above attributes prior to locally fabricating, repairing, or altering a shipping container for use with licensed materials.
e.
While in the custody of PIEDMONT, shipping containers for use with licensed materials shall be controlled such that those characteristics of the package which are critical to safety are maintained.
(1) Damage to shipping containers shall be reported immediately to compe-tent authority.
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(2) Shipping containers for use with licensed radiographic sourc'es shall be main-tained and used in accordance with reference (a). They shall be stored in the Radio-graphy Vault when not in use.
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SECTION TWO APPENDIX A From:
J-(RMPQA Officer Designate)
To: Commanding Officer, USS PIEDMONT (AD-17)
Subj: Training and Experience as RMPQA Officer
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L-1.
I have reviewed and am familiar with the most recent revisions to the following instructions and regulations:
F 10CFR71 PIEDMONT RMPQA Program PIEDMONT RMPQA Records and Audits PIEDMONT License No 31-17753-01 PIEDMONT Instruction 9090.3 2.
I am prepared to assume the responsibilities of the PIEDMONT RMPQA Officer.
Signature Approved:
Commanding Officer /Date t
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-....._w...,.__..1 AD171NST 9090.3 Section Three - DOCUMENT CONTROL
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3.1 Purpose. This section describes requirements for the control of documents re-j' lated to shipping packages.
t, 3.2 Procedure. Each document related to a specific shipping container shall, where necessary, be processed in accordance with Naval Supply Systems Command dire.ctives in the course of receiving or shipping licensed materials. When not required to be in the custody of the PIEDMONT Supply Officer, or others, for review, documents shall be maintained in the custody of the. Radiographic Safety Officer.
It is anticipated that L-no document changes should be requirud.
However, if the need arises changes will be accomplished only with the permission of the Cocmanding Officer and in accordance with appropriate procedures.
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AD17 INST 9090.3 Section 4 - HANDLING, STORAGE, AND SHIPPING 4.1 Purpose. This section describes those aspects of handling, storage and shipping of packages which are important to safety and includes assignment of responsibilities
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for the critical aspects of handling, storage, and shipping.
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4.2 Discussion, a.
Established safety restrictions concerning the handling storage, and ship-ping of packages for special form radioactive material will be followed.
Shipments will not be made unless all tests, certifications, acceptances, and final inspections have been completed. Work instructions have been provided for handling, storage, and L_ I '
shipping operations for those. shipping containers in use.
b.
The responsibilities of certain personnel invclved in the RMPQA Program are described in Section One.
This section provides amplification of those responsibities by specifying requirements for the aspects of handling, storage, and shipment of pack-ages which are considered critical.
4.3 Procedure, a.
The Radiographic Safety Officer is responsible for the critical handling, storage, and shipping operations for each shipment of licensed material by the NDT Laboratory. He shall ensure, for each shipping container, that:
(1) Established safety restrictions concerning the handling, storage and shipping of packages for certain special form radioactive material are being followed.
(2) Shipments are not made unless all test, certifications, acceptances, and final inspections have been completed.
(3) Work ins.tructions have been provided for handling, storage, and shipping operations.
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1 AD17 INST 9090.3
'Section Five - INSPECTION, TEST, AND OPERATING STATUS r (..
5.1 Purpose.
This section describes those aspects of inspection, test, and operating status of packages which are important to safety and includes assignment of respon-sibilities for the critical aspects of inspection, test and operating activ,ities.
5.2 Discussion.
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Inspection, test, and operating status of packages for certain special form L
a.
radioactive material will be indicated and controlled by established procedures.
The status will be indicated by the tag, label, marking, or log entry. The status of nonconforming parts or packages will be positively maintained by established procedures.
b.
The responsibilities of certain personnel involved in the RMPQA Program are described in Se ction One.
This section provides amplification of those responsibilities by specifying requirements for the aspects of inspection, test and operating status whici: are considered critical.
5.3 Procedure.
a.
The Radiographic Safety Officer is responsible for the critical inspection, test and operating activities associated with each shipping container which may be used for shipment of licensed materials by the NDT Laboratory. He shall ensure, for each shipping container, that:
(1)
Inspection, test and operating status of packages for certain special form radioactive material is indicated and controlled by established procedures.
(2)
Status is indicated by tag, label, marking or log entry.
(3)
Status of nonconforming parts or packages are positively maintained by established procedures.
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AD171NST 9090.3 Section Six - QUALITY ASSURANCE RECORDS 6.1 Purpose. This section provides the necessary requirements and guidance for g
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satisfactorily documenting the operation of the RMPQA Program aboard PIEDMONT.
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6.2 Discussion. Adequate documentation will be maintained to demonstrate to inter-ested parties that PIEDMONT possesses an effective functional RMPQA Program. To this end the following actions shall be taken:
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a.
Records will be maintained and include operating logs, inspections, tests, and audit results.
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b.
Other records to be maintianed will include qualifications of personnel and descriptions of procedures and equipment.
c.
Records will be maintained according to established procedures.
d.
Records will be identifiable and retrievab1h.
e.
A list of the required records and their storage locations will be. maintained.
6.3 _ Procedure.
a.
The RMPQA Officer shall maintain the original audit reports for all audits and shall maintain a master listing (index) of all required records which shows their location.
b.
The Radiographic Safety Officer shall maintain all other records.
He shall maintain them in an auditable fashion, i.e. they shall be identifiable and retrievable.
These shall include, but are not limited to:
(1) Operating logs, inspections, and tests.
(2) Qualification of personnel.
(3) Descriptions of procedures and equipment.
(4) Records of shipments.
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AD17 INST 9090.3 I
Section Seven - AUDITS 7.1. Purpose. This section specif'les the requirements which must be met to establish an effective audit program.
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h a.
Appendix (A) to this section contains the audit plan for use in au.dits of the RMPQA Program. This format specifies the minimum requirements of each audit. The auditor should audit to the intent rather than the letter of the audit plan. That is to say each area described in the audit plan should reveal several questions which must be answered to satisfactorily complete the audit.
lm b.
Established schedules of audits of the RMPQA Program will be performed.
Results of all audits will be reported to the Co=manding Officer with copies to the Repair Officer, and Radiographic Safety Officer. Audit reports will be evaluated and deficient areas corrected. The audits being performed will be dependent on the safety significance of the activity being audited. Audit reports will be maintained as part of the quality control records.
- 7. 3 Procedure.
Audits shall be conducted by or under the direct supervision of the RMPQA a.
Officer.
b.
An audit of each receipt or shipment shall be conducted two weeks following that receipt or shipment.
c.
Semi-annually, a complete audit of the RMPQA Program will be conducted. The specific dates shall be approved by the Commanding Officer.
d.
The signed audit report shall be forwarded to the Commanding Officer on the completion of each audit.
Copies will be provided to the Repair Officer and Radio-graphic Safety Officer.
The Repair Officer will review proposed corrective actions and; assign com-e.
pletion dates.
f.
The original audit reports and original records of corrective action shall be maintained in an auditable fashion by the RMPQA Officer.
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~.5 AD17 INST 9090.3 SECTION SEVEN APPENDIX A RMPQA AUDIT "L
1 Audits of the Radioactive Material Packing' Quality Assurance Program must be conducted to meet the requirement of PIEDMONT RMPQA Program and Appendix E to 10CFR71. The audit must be conducted by a knowledgeable officer not having direct responsibility in the area audited (10CFR71, Appendix E, paragraph 18).
Followup action, including reaudit of deficient areas shall be taken when considered necessary.
1.
For each of the established RMPQA procedures, check the following:
INITIAL a.
All procedures used were verified by the RMPQA Officer b.
The most current verified copy is on file I
c.
Two years of files maintained.
d.
All required signatures are present.
2.
The current RMPQA Officer has completed enclosure (1) to PIEDMONT instruction 9090.3 and has been approved by the Commanding Officer pp"*
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ADI,7 INST 9090.3 i
3.
All radiographers have completed reference (a) requirements for qualification and have been approved by the required officer.
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4.
All RMPQA revisions have been authorized by the Commanding Officer and each re-i t,}.
vision is documented on the record of revisions page of PIEDMONT Instruction 9090.3 on file with RMPQA records (and any others in use).
5.
For each radioactive material shipping package to be used onboard PIEDMONT verify 9*
v that:
a.
The NCR approval for that packaa,e is onboard.
b.
The specific pr <isions made with package approval are being adhered to.
6.
A complete list of NRC approved packages is on file 7.
Registration with the NRC for use of a package occurred prior to use of the package and a copy of this registration is o~n file, c
8.
General Comments / Discrepancies:
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