ML19259A885
| ML19259A885 | |
| Person / Time | |
|---|---|
| Site: | 07100245 |
| Issue date: | 12/28/1978 |
| From: | Toupin E NAVY, DEPT. OF |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7901110119 | |
| Download: ML19259A885 (21) | |
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U. S. S. L Y. SPEAR (AS.36)
FLEET POST OFFICE t:CENtilf YORK 09501
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AS36:48:gp fi9 JM4 2 p.9 9 54 1686 b
n, 2 8 DEC 1978 y;
. sea Fran: Cr - anding Offic MUSS.LT-k (AS 36)
US Nuclear Reguhitidry h%g2cn (ATIN: Director of Nuclear Material
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Safety ard Safeguards, Washington, D.C. 20555)
L Subj: Quality Assurance Fswse for the Packaging of Padirwt.ive Material for Transport and Transportation of Padime-tive Material Under Certain L
Conditicns (10GR71); forwardirx] of Paf:
(a) Title 10 Cbde of Federal Regulaticas Part 71 (b) letter.frcm Charles E. P h ald (NFC) dated 1 May 1978 Encl:
(1) USS L. Y. SPEAR (AS 36) Instruction 9090.1; Quality Assurance Fi;ws for the Packaging of Padim_e-tive Material for Transport and Transgt.aticn of Padime-tive Material Under certain Ccrdit-icns (10CFR71) (7 Copies) 1.
In ah with references (a) and (b), Enclosure (1) is forwarded for approval.
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AS36:48:dl g 55 3 3 ^~.0 I3N USS c. Y. SPEAR INSTRUCTION 9090.1 Subj: Quality Assurance Prcgrati for the Packaging of Padioactive Material for Transport and Transportation cf Radioactive Material Under Certain Ccnditions (10CFR71)
Ref:
(a) U. S. Nuclear Regulatcry Cer: mission Materials License 31-17970-01 (b) Code of Federal Regulations Title 10, Part 71 (10CFR71)
(c) Code of Federal Regulations Title 49 Enc!:
(1) P2PQA Prcgram 1.
Backgreur.d. USS L. Y. SPEAR is authorized by reference (a) to use certain racicactive materials aboard L. Y. SPEAR and on ships and in -
areas where USS L. Y. SPEAR is operating. In the ccurse of exercising this authorization scme of these caterials are shipped to and frcm civilian suppliers who are likewise licensed by the NRC to provide these materials.
A recent revisien to reference (b) requires the development of a program as follcws:
"The licensee shall establish, maintain and execute a quality assurance program satisfying each of the applicable criteria specified in Appendix E,
' Quality Assurance Criteria for Shipping Packages for Radioactive Material',
and satisfying any specific provisiens which are applicable to the licensee's activities, including procurement packaging."
2.
Acticn. This instruction provides for procedures necessary for the satisfactory establishment and executien of the quality assurance program for use in packaging, shipment, and transportation of licensed materials by USS L. Y. SPEAR.
3.
Scoce. This instruction applies to all radioactive materials cevered byreference(a). As an end-user it is not intanded that L. Y. SPEAR en-gage in the manufacture or alteration of shipping packages. Rather, this program is designed to ensure that the quality of shipping packages received is initially certified by the supplier and maintained while such packages are in the custody of L. Y. SPEAR. This instructicn is not to be construed in any case, as a relaxation of the requirements in reference (a) or other dire:tives of higher authority.
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U,as. S. L. Y. SPEAR (AS-36) gyg' Q
FLEET POST OFFICE
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NEW YORK 09501 L. Y. SPEARINST 9090.1 s
2 3 CZC INS OUALITY ASSURANCE PROGRAN F0?I THE PACXAGI?!G CF RADI0 ACTIVE MATERIAL FOR TRANSPORT AND TRMiSPCRTATION OF RADI0 ACTIVE MATERIAL Uf; DER CERTAIN CONDITIONS (10CFR71)
U.S. NUCLEAR REGULATORY COMMISSION MATERIALS LICEllSE fl0. 31-17970-01 J
LICD'SEE:
DEPARTMEffT OF THE NAVY USSL.Y. SPEAR (AS-36)
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L. Y. SPEARINST 9090.1 28 DEC E73 RECORD OF REVISIONS REVISION DATE OF DATE ENTERED BY NUMBER REVISION ENTERED (SIGNATURE) 11 1
L. Y. SPEARINST 9090.1 0 8 DF.C 1373 TABLE OF CONTENTS PAGE Implementing Instruction Title Page i
Record of Revisiens 11 Table of Contents iii Definitions Organization I-l Quality Assurance 11-1 Document Centrel HI-1 Handling, Storage, and Shipping IV-1 Inspection, Test and Operating Status V-1 Quality Assurance Records VI-1 Audits VII-l t
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L. Y. SPEARINST 9090.1 28 DEC M3 DEFINITIONS The following terms are defined as they are intanded to be used in this instruction.
CFR - Code of Federal Regulations Licensed activity; licensee - USS L. Y. SPEAR (AS-25)
Licensed materials - Those materials for which USS L. Y. SPEAR holds an NRC approvt.d license NRC - U.S. Nuclear Regulatory Cornission fiDT Laboratory - llon-destructive Test Laboratory Package - A shipping container for licensed radioactive materials RCF - Radiac Calibration FaciTity RCO - Radiological Controls Officar P3PQA Officer - The Quality Assurance Officer for the FliPQA program -
charged with inspecting and auditing to verify the program FSPQA Program - Quality Assurance Prcgram for the Packaging of Radioactive Material for Transport and Transportation of Radioactive Material Under Certain Conditions (10CFR71)
RSO - Radiographic Safety Officer
L. Y. SPEAP,IttST 9090.1 2 8 DEC 1973 Section One - ORGAtlIZATI0tl 1.1 Puroose_. This section sets forth the organizational responsibilities in the RMPQA Program.
1.2 Description. The RMPQA Program is composed of four levels of rescon-sibili ty:
a.
Commanding Officer - Dy definition the senior official of the licensed activity, he is responsibla for the establishment and execution of the RMPQA Program. Revisions to the program may be authorized only by him. The Commanding Officer assigns and certifies the qualification of the RMPQA Officer.
b.
Repair Officer - In his role as Head of Department which actually uses licensed materials the Repair Officer has a vested interest ia the RMPQA Program. Therefore, he is responsible for ensuring that the Pf4PQA Officer has sufficient organizational freedom to fulfill his function and for ensuring that corrective action (s) is/are accomplished in an effective, timely manner and is/are not being delayed by production schedules or other conflicts.
Radiolooical Controls Officer (RCO) - Responsible for the safe c.
receipt, handling, operation and shipment of licensed materials in/by the Radiac Calibration Facility (RCF), the Radiological Controls Officer is responsible for the following attributes of the RMPQA Program:
(1) Ensuring that shipments of licensed materials used by the RCF are conducted in accordance with references (a), (b), and (c).
(2) Ensuring that required inspection and testing incidental to shipment of licensed materials used by the RrF are properly conducted and documented.
(3) Completing records of shipments to/by the RCF prior to releasing them to the appropriate record keeping officer.
(4) Ensuring that corrective action, when required, is accomplished by the RCF in an effective, timely manner.
(5) 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. 'Radicarachic Safety' 0fficer (RS01 - Either the Quality Assurance Officer or the flon-destructrive Test (tiDT) Laboratory Supervisor is normally assigned as the RSO. In adlition to his responsibilities for ensuring the safe receipt, handling, opclation and shipment of licensed materials used in radiography, he is respq:sible for:
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L. Y. SPEARINST 9090.1 2 8 DEC M3 (1) Ensuring that shipments of licensed materials used by the fiDT Laboratory are conducted in accordance with references (a), (b), and '(c).
(2) Ensuring that required inspection and testing incidental to shipment of licensed materials used by the f!DT laboratory are properly conducted and documented.
(3) Maintaining records of shipments as required in later sections of this instruction.
(4) Ensuring i. hat correctiva actica, when required, is acco.aplished in an effective, timely manner by the NDT Labaratory.
(5) Ensuring that personnel under his cognizance to process licensed material are trained in the requirements of this instruction and referc mes (a) and (b).
e.
RMPQA Officer. The RMPQA Officer shall be certified as to his qualification and appointed by the Connanding Officer. His primary function in the RMPQA Program is the verification of the credibility of the program.
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in this regard he is responsibic 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 PJtPQA Program.
(3) Conducting or directly supervising the conduct of unannounced spot checks of the RMPQA Program.
(4) Reporting his findings directly to the Ccmmanding Officer with copies to the Repair Officer, Radiological Controls Officer, and RSO.
(5) Conducting follow-up audits to ensure corrective action is accc.,plished.
1.3 Acoerdices. Appendices (A) and (B) to this section contain an organ-izaticral chart and matrix which grachically display the division of responsibility of the above functions into four levels of responsibility.
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L. Y. SPEARINST 9090.1 SECTION ON3 2 8 DEC 1978 APPENDIX "A" ORGANIZATIONAL CHART COFDIANDING OFFICER REPAIR OFFICER RADIOLOGICAL RADIOGRAPHIC CONTROLS SAFETY OFFICER OFFICER l
RMPQA 0FFICER e
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L. Y. SPEARINST 9090.1
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2 8 DEC1978 APPENDIX "B" RESPONSIBILITY MATRIX RADIOLOGICAL RADIOGRAPHIC COMMANDING REPAIR CONTROLS SAFETY RMPQi FUNCTION OFFICER OFFICER OFFICER OFFICER OFFICER PROGRAM A
E E
E E
TRAINING A
C D,E D,E CERTIFI-B E
E CATION TESTING B
E E
DOCUMENT CHANGES A
C D~
D SHIPPING A
C E
E AUDITS B
E AUDIT SCHEDULE A
C D
LEGEND A - Approve B - Accept C - Concur D - Initiate E - Perform it "h
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L. Y. SPEARINST 9090.1 2 8 DEC 1978 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 packaging licensed materials.
2.2 Discussion.
L. Y. SPEAR is licensed to use certain radioactive materials as specified in reference (a). As an end-user L. Y. SPEAR receives these materials fro,m NRC licensed suppliers in NRC approved con-tainers. Ther' fore, the thrust of the QA Progran aboard L. Y. SPE/d shall be directad toward establishing proof of and maintaining the quality of provided containers. Manufacture or repair of shipping containers for licensed materials shall not be conducted aboard L. Y. SPEAR without prior approval by the NRC.
2.3 Procedure.
The promulgation and enforcement of this instruction by the appro-a.
priate levels of the chain of command establishes and implements the RMPQA Program.
b.
Training and experience for all Pf1PQA Program functions shall be in accordance with established procedur,s:
(1) The Commanding Officer, Repair Officer, and Radiological Controls Officer are specifically assigned by the Bureau of Haval Personnel in accordance with established directives.
(2) The Radiographic Safety Officer shall be assigned by the Commanding Officer in accordance with reference (a).
(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).
(5) RCF Technicians shall be qualified in accordance with REPDEPTINST 1500.2.
Revisions to the QA Program may be made only by a formal change to c.
this instruction signed by the Ccmmanding Officer. Revisions which would significantly alter the program must be coproved 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 specif*.c p;) visions of the package design approval shall be satisfied for any shipping yackage used in conjunction with licensed material.
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L. Y. SPEARINST 9090.1 3 3 g;g 19td (1) Documentation of this shall be maintained on board L. Y. SPEAR for any cont- ~ tor-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 L. Y. SPEAR. shipping containers for use with licensed materials shall be centrolled : uh th;.
t hose character i.,:ics of the package which are critical to safety are maintained.
(1) Damage to shipping containers shall be reported immediately to competent authority.
(2) Shipping containers for use with licensed radiegraphic sources shall be maintained and used in accordance with reference (a).
They shall be stored in the Radiography Vault when not in use.
(3) Shipping containers for licensed radiac calibration sources.
shall be maintained and used in accordance with reference (a}. They cha11 be stored in the locked section of the RCF when not in use.
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.a L. Y. SPEARINST 9090.1 2 3 CEC 5:
S7.CTION TWO APPD3II A Pron:
(EMPQA Officer Designata) r To:
Cc nnding Of ficer, USS L. Y. SPD.R(AS-36)
Subj :Trair.ing and Experiente as RMPQA Officer 1.
I have r; viewed and as fa=ilic.r uith the ucst recent revisions to the following instructions and regulations:
10CFR71 L. Y. SPEAR RMPQA Progra:a L. Y. SPEAR RMPQA Records and Audits L. Y. SPEAR License Nc 31-1790-01 L. T. S? EAR Instruction 9090.1 2.
I am prepared to assune the responsibilities of the L. Y. SPL\\R MC'QA Officer.
Signature Approved:
Co: nand.ing Of ficer/Date
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L. Y. SPEARINST 9090.1 2 8 DEC 1973 Section Three - DOCUMENT CONTROL 3.1 Purpose. This section describes requirements for the control of documents related to shipping packages.
3.2 Procedure.
Each document related to a specific shipping container shall, where necessary, be processed in accordance with Naval Supply Systems Co= mand directives in the course of receiving or shipping licensed t-erials. When not required to be in the custody of the L. Y. SPEAR Supply Otticer, or others, for review, documents shall be maintained in the custody of the Radiographic Safety Officer.
It is anticipated that no document changes should be required. However, if the need arises changes will be accomplished only with the permission of the Commanding Officer and in accordance with appropriate procedures.
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L. Y. SPEARINST 9090.1 2 8 DEC 'mid Section 4 - HANDLING, STORACE, 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 for the critical aspects of handling, stor-age, and shipping.
4.2 Discussion.
Established safety r'estrictions concerning the handling stcrage, a.
and shipping 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 shipping operations for those shipping containers in use.
Work instructions will be provided for handling, storage, and shipping operations for those shipping containers contemplated for future use.
b.
The responsibilities of certain personnel involved in the RMPQA Program are described in Section One.
This section provides amplificat_ ion of those responsibilities by specifying requirements for the aspects of handling, storage, and shipment of packages which are considered critical.
4.3 Procedure.
a.
The Radiological Controls Officer is responsible for the critical handling, storage, and shipping operations for each shipment of licensed materials by the RCF.
He shall ensure, for e.,ah shippitig container, that:
(1) Established safety restrictions concerning the handling, storage and shipping of packages for certain spec.ial form radioactive material are being followed.
(2)
Shipments are not made unless all test, certification, accep-tances, and final inspections have been completed.
(3) Work instructions have been prcvided for handling, storage, and shipping operations.
b.
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 contain-er, that:
(1) Established rafety restrictions concerning the handling, storage and shipping of packager for.certain special form radioactive material are being followed, y
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L. Y. SPEARINST 9090.1 2 8 DEC 1373 (2) Shipments are not made unless all test, certifica t ions, eptances, and final inspections have been ec=pleted.
a (3) k'ork instructions have been provided for handling, storage, and shipping operations.
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4 L. Y. SPEARINST 9090.1 2 8 DEC 1973 Section Five - INSPECTION, TEST, AND OPERATING STATUS 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 responsibilities for the cirtical aspects of inspection, test, and operating activities.
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- 5. 2 Discussion.
a.
Inspection, test, and operating status of packages for certain special form 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 R:!?qA Program are described in Section One.
This section provides amplification of those responsibilities by specifying requirements for the aspects of inspection, test, and operating status which are considered critical.
5.3 Procedure.
The Radiological Controls Of ficer is responsible for the critical a.
inspection, test, and operating activities associated with each shipping container which may be used for shipment of licensed materials by the RCF.
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 procedure.
(2)
Status is indicated by tag, label, narking or log entry.
(3)
Status of nonconforming parts or packages are positively maintained by established procedures.
b.
The Radiographic Safety Officer is responsible fe. 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 cperating status of packages for certain special form radioactive material is indicated and controlled by established procedures.
(2) Status is indi sted by tag, label, marking or log entry.
(3)
Status of noncInforming parts or packages are positively maintained by e stablished p;heedures.
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L. Y. SPEARIrtST 9090.1 DEC B78 Section Seven - AUDITS 7.1 Purcose. This section specifies the requirements which nust be met to establish an effective audit program. 7.2 Discussion. a. Appendix (A) to this section centains the audit plan for use in audits of the RMPQA Program. This format specifies the minimum require-ments of each. audit. The auditor should curit to the intent rather than the letter of the audit plan. That is to say c3ch acca described in the audit plan should reveal several questiens which must be answered to satisfactorily complete the audit. b. Established schedules of audits of the RMPQA Program will be per-formed. Results of all audits will be recorted to the Ccamanding Officer, with ccpies to the Repair Officer, Radiological Controls 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 cf the activity being audited. Audit reports will be maintained as part of the quality control records. ~ 7.3 Procedure. a. Audits shall be conducted by or under the direct supervision of the RMPQA Officer. b. An audit of each receipt or shipment shall be conducted two weeks following that receipt or shipment. Semi-annually, a complete audit of the RMPQA Program will be c. conducted. The specific dates shall be approved by the Ccmmanding Officer. d. The signed audit recort shall be forwarded to the Ccananding Officer on the completion of each audit. Copies will be provided to the Repair Officer, Radiological Controls Officer, and Radiographic Safety Officer. The Repair Officer will review propcsed ccrrective actions ar.d e. assign compiecicn dates. f. The original audit reports and original records of corrective action shall be maintained in an auditable fashion by the RMPQA Officer. VII-l
L. Y. SPEARINST 9090.1 2 8 CEC 1978 Section Six - OUALITY ASSURANCE RECORDS 6.1 Purpose. This section provides the necessary requirements and guidance f or satisf actorily documenting the operation of the RMPQA Program aboard L. Y. SPEAR.
- 6. 2 Discussion. Adequate documentation will be maintained to demonstrate to interested parties that L. Y. SPEAR possesses an ef fective functional RMPQA Program.
To this end the following actions shall be taken: a. Records will be maintained and include operating logs, inspections, tests, and audit results. b. Other records to be maintained will inculde qualifications of personnel and descriptions of procedures and equipment. Records will be maintained according to established procedures. c. d. Records will be identifiable and retrieveable. A list of the required records and their storage locations will e. be maintained.
- 6. 3 Procedure.
The RMPQA Officer shall maintain the original audit reports for a. all audits and shall maintain a master listing (index) of all required records which shows their locatict. b. The Radiographic Safety Officer shall maintain all other records. He shall maintain them in an auditable fashion, i.e. they shall be identi-fiable and retrievable. These shall include, but are not limited to: (1) Operating logs, inspections, and tests. (2) Qualificatien of personnel. (3) Descriptions of procedures and equipment. (4) Records of shipments. VI-l 9 e
d L. Y. SPEARI :ST 9090.1 8 CEC 1970 SECTION SEVEN APPENDIX A RMPOA ACLIT Audits of the Radioactive Ma'terial P&cking Quality Assuranca Progrt: =ust be c nducted to caet the requirements of L. Y. SPEAR RMPQA progran and Appendix E to 10CFR71. The audit must be conducted by a knowledgabla offi a r n:t having direct raspensibility in the area audited (10CER71, Appendix E, paragtnph 18). Follovup action, including reaudit of deficient areas shall be taken when considerad nassary. 1. For cach of the established FJIPQA proce;ures, check the following: INITAL a. All procedures used were verified by the RMPQA Officer and RCO/RSO (as applicable) b. The most current verified copy is on fila. c. Two years of files r.aintained. d. All raquired signatures are present. 2. The current RMIQA Cfficer has completed enclosure (1) to L. Y. SPEAR Instruction 90's0.1 and has been approved by the 1 Co=manding Officer. I
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~ L. Y. SPEARIN"T 9090.1 4 8 DEC 1373 3. All radiographers have completed reference (a) requirements for q..ualification and Tave been approved by the required officers. RCF personnel are qualified in acevrdance with L. Y. SPEAR INST 1500.2 (series). 4. All RMPQA revisions have been authorized by the Commanding Officer and each revision is documented on the record of revisions page of L. Y. SPEARINST 9090.1 on file with RMPQA records (and any others in use). 5. For each radioactive material shipping package to be used on board L.'f. SPEAR, verify that: a. The NRC approval for that package is on board. ~. _. 4 - ; 5-. g.__ b. The specific provisions made with the 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 on file. 8. General Comments / Discrepancies: d .i 'e (Signature) A-2 'N 'i 5 .}}