ML19259A895
| ML19259A895 | |
| Person / Time | |
|---|---|
| Site: | 07100223 |
| Issue date: | 12/18/1978 |
| From: | Mehaffey R BENJAMIN F. SHAW CO. (SUBS. OF BLOUNT, INC.) |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7901110142 | |
| Download: ML19259A895 (15) | |
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. db lCH U. S. Nuclear Regulator Commission Transportation Branch (NRC PUBUC DOC,Ut/ENT ROOM)'
Division of Fuel Cycle and Material Safety Office of Nuclear Material Safety & Safeguards Washington, D. C. 20555 Attn: Charles E. MacDonald, Chief Gentlemen:
In compliance with 10 CRF Part 71 and your notifications dated May 1,1978 and June 28, 1978, we have incorporated into our Isotope Manual of Operating &
Emergency Procedures a Quality Assurance Program.
Please find enclosed three (3) copies of Section "F" of our manual which includes the Quality Assurance Program as required.
Sincerely yours, BErJAMIN F. SHAW COMPANY
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. fjehaffey Asst. Radiation Prote tion Officer RRM:lfc Enclosures cc:
L. P. Smeal E
J. Cresci THIS DOCUMENT C J. McDermott N3 File P0OR QUAUTY PAGES'j1E31 J
79011101Q T HE Bf.NJ APAIN F. SHAW COP.tPANY a EOX 24. Late AI.. !!wTH CAROLIN A 20yA a Ec3 CE2c1 6P[CI ALISTS IN F ASRICAf t0N AND tr.57 ALLAT10, C F t %;.$ TRIAL PtPING $!*.CE tt32
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ISOTOPE RADIOGRAPHY OPERATIftG AND EMERGENCY PROCEDURES t
s SECTIO.'l F QUALITY ASSURANCE PROGRAM Afl0 PROCEDURE FOR THE PACKAGIflG, TRANSPORTING, SHIPPING AND OPENING 0F PACKAGES CONTAINING SEALED SOURCES A.
QUALITY ASSURANCE PROGRAM 1.
The Quality Assurance Manager of Benjamin F. Shaw establishes and implements this Quality Assurance Program. Training for all Quality Assurance functions, prior to engagement in these functions, is required according to written procedures approved by the Q. A. Manager. The Radiation Protection Officer shall assure that all radioactive material shipping packages were approved by the Nuclear Regulator Commission after 1 January 1979.
2.
Organization (a) The final responsibility for the Quality Assurance Program for Part 71 requirements rests with Benjamin F. Shaw.
(b) Design and fabrication of radioactive material shipping packages shall not be conducted under this Quality Assurance Program.
(c) The Radiation Protection Officer is responsible for overall admin-istration of the Q. A. Program, training and certification, document control, and audition.
(d) The Radiographers are responsible for handling, storing, shipping, inspection, testing, operating status and record keeping.
(e) The Quality Assurance Program is implemented using the following organization:
President G. D. PROFITA Vice-President - Production J. J. McDERMOTT Quality Assurance Manager Radiation Protection Officer L. P. SMEAL 11E.31 Chief Radiographer Asst. Radiation Protection Officer R. R. f1EHAFFEY i
Radiographers
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SECTION F
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_Q_UALITY ASSURANCE PROGRA!! A'lD PROCEDURE FOR THE_
s PACKAGING, TRANSPORTlflG, SHIPPING AND OPENillG OF PACKAGES 3
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CONTAINING SEALED SOURCES (Cont. from page F-1) 3.
Document Control (a) All documents related to a specific shipping package, including NRC approval, will be maintained by the Radiation Protection Officer.
(b)
The Radiation Protection Officer shall insure that all Q.A. functions are conducted in accordance with the latest applicable changes to these documents.
4.
Handling, Storage and Shipping (a) Written safety procedures concerning the handling, storage and shipping of packages for certain special form radicactive material will be fol-lowed.
Shipments vill not be made unless all tests, certifications, acceptances, and final inspections have been completed. Work instructions will be provided for handling, storage and shipping operations.
(b)
Radiography personnel shall perform the critical handling, storage and shipping operations.
5.
Inspection, Test and Operating Status (a)
Inspection, test and operating status of packages for special form radioactive material will be indicated and controlled by label and log entry. Status of nonconforming parts or packages will be maintained in accordance with the B. F. Shaw Co. Isotope f4anual.
(b)
Radiography personnel shall perform the required inspections and tests in accordance with the above written procedures. The Radiation Protec-tion Officer shall ensure that these functions are perfomed.
6.
Quality Assurance Records (a)
Records of NRC package approvals will be maintained. Descriptions of equipment will also be maintained.
(b) The records will be identifiable and retrievable. A list of these records, with their storage locations, will be maintained by the Radiation Protection Officer.
7.
Audits (a)
Established schedules of audits of the Quality Assurance Program will be perfomed using writte ' checklists. Results of audits will be maintainei and reported to the Q.A. lanager. Audit reports will be evaluated and deficient areas correctei. 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. f4 embers of' the audit team shall have no responsibility in the activity being audited.
F-2 DECEf4BER,1978
i
_SECTION F QUALITY ASSURANCE PROGRAM AND PROCEDURE FOR THE PACKAGING, TRANSPORTIflG, SHIPPIllG AMD OPEfilflG 0F PACKAGES g-CONTAINING SEALE0 SOURCES (Cont. from page F-2)
B.
The NRC has authorized our use of sealed sources at temporary field sites away from our plant. The use of see. led sources at these locations must be specifically approved by the Radiation Protection Officer.
C.
Transportation from Laurens to field sites and from field sites to Laurcns, or other field sites, must be in accordance with the instructions below:
1.
Sealed Sources shall be transported outside of plant property only when accompanied by a radiographer employed and certified by the Benjamin F.
Shaw Company.
The radiographer shall be responsible for full compliance with the requirements of this section.
2.
(a) The transporting vehicle shall not be used to transport packages bearing a RADI0 ACTIVE YELLOW III label.
(b) The transporting vehicle shall be posted on each side and rear with the following sign:
IN CASE OF ACCIDENT - i;0TIFY BENJAMIN F. SHAW COMPANY (803) 682-3231, LAURENS, SC OR U. S. NUCLEAR REGULATOR COMMISSION (803)824-6331, Ext.
3333, AIKEN, SC (404) 526-4503, ATLANTA, GA The sign shall be white with black lettering at least 1/2 inch in height.
3.
(a) The exposure device must be firmly secured inside the vehicle by the use of ropes or straps so as to avoid any bouncing or other movement.
The package shall be marked and labeled in accordance with Part "C" of this Section.
The outer surfaces of the vehicle and the passenger compartment must be surveyed to assure that radiation levels do not exceed 2 mr/hr and lead or concrete snielding must also be secured to make it immobile.
Care cust be taken so that the driver and/or passengers in the vehicle are not subjected to radiation levels in excess of 2 nr/hr.
(REF: Section B., Para. C.4.a.
of these procedures.) A record of this survey should be made, In
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F-3 DECEMBER, 1978
SECTION F QUALITY ASSURANCE PROGRAM A*'D PROCEDURE FOR THE PACKAGING, TRANSPORTING, SHIPPli4G CD OPENIi!G OF PACKAGES C0ilTAINING SEALE0 SOURCES (Cont. from page F-3)
C.
Transportation from Laarens to field sites and from field sites to Laurens, or other field sites, must be in accordance with the instructions below:
(Cont'd) 3.
(a) Cont'd.
the event an automobile is used as the transporting vehicle, the container will be secured in the vehicle's-trunk.
No passengers will be allowed in the rear seat of the automobile when radioactive materials are in the trunk.
(b) The TECH /0PS model 533 projector shall be -t; ansported by vehicle only when a TECH /0PS model 715 protective overpack for radiographic devices is used, if the contents exceed 20 curies of iridium 192.
4.
The following items must be packed in the transporting vehicle prior to departing to, or from, a field site:
(a) A copy of the Ccmpany's Operating and Emergency Procedures.
(b) Survey Meter with current calibration.
i.
NOTE:
On trips of less than 90 days duration, the survey meter re-calibration due date shall be beyond the expected date of return to the Laurens Plant.
s (c) Sufficient coils of repe or barricade tape.
(d) Sufficient " Caution - High Radiation Area" signs.
)
(e) Sufficient " Caution - Radiation Area" signs.
(f) Sufficient " Caution - Radioactive flaterial" signs.
(g) Sufficient stands to use in stringing rope or tape.
(h) A sufficient quantity of " Report of Radiographic Production" forms.
(i) The exposure device and all related cables.
(j) Road Flares, or red blinker lights (battery operated).
i (k)
Dosimeter charger (1) Daily and Monthly record of dosimeter form.
F-4 DECEMBER,1978 c
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SECT 10fl F QUALITY ASSURANCE PROGRA*1 AtlD PROCEDURE FOR THE PACKAGING, TRANSPORTING, SHIPPING A!!D OPENING 0F PACKAGES CONTAINING SEALED SOURCES (Cont'd. from page F-4)
C.
Transportation from Laurens to field sites and from field sites to Laurens, or other field sites, must be in accordance with the instructions below: (Cont'd) 4.
(Cont'd.)
(m) A copy of South Carolina rules and regulations for radiation control.
(n) A copy of decay curve, and receiving report for the source taken.
5.
Prior to transporting sealed sources from Laurens, SC, to field sites, or from field site to field site, the Radiation Protection Officer shall be advised by the Chief Radiographer or Radiographer at the field site of the following:
(a) Description of work to be performed.
(b) Location and dates work is scheduled.
(c) Devices and sources to be used, including type and activity of source.
(d) Radiographer's name.
(e) Name of a Customer Supervisor at the temporary field site who can be notified in case of an accident at the field site. This person shall be known as the Site Representative.
6.
In case of an accident involving a vehicle transporting by-product material, the emergency procedures outlined in Section "G" of these procedures shall be followed.
D.
Transportation via common carrier shall be in accordance with the following:
1.
Sealed sources shall be shipped via con:on carrier only upon approval of the Radiation Protection Officer.
2.
SeMW ources shall be prepared for shipment by a radi:,grapher in shipping
' o ' inefs or projectors listed on our By-Product Material License and J c <ibed in Section "A" of this manual.
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ThE K CH/0PS MODEL 533 PROJECTOR IS N01 AN APPROVED SHIPPING CONTAINER FOR1RiOHQ192SEALEDSOURCESINEXCESSOF20 CURIES.
3.
Sealed sources shall not be shipped to any location where a qualified Benjamin F.
Shaw Company Radiographer is not in attendance, except when sealed sources are rdurned to tiit source supplier. The delivery of sealed sources shall O coordinated by the Radiation Protection Officer to avoid any delay in accepcing delivery of a sealed source.
4.
A shipper's certification form will be required for shipments. Refer to sample forms at the end of this section.
F-5 DECEMBER,1978
SECTIO:i F QUALITY ASSURANCE PROGPA'1 AND PROCEDURE FOR THE PACKAGIfiG, TRNASPORTIfiG, SHIPPI::G NiD OPEf;IfiG OF PACKAGES CONTAINIf4G SEALED SOURCES (Cont'd. from page F-5)
D.
Transportation via comon carrier shall be in accordance with the following:
(Cont'd) 5.
Shipping packages shall be labeled with two labels on opposite sides as follows:
(REF: Title 49 CFR, Part 173.399.)
(a) Each package not exceeding 0.5 nr/hr at any point en the external surface of the package:
RADI0 ACTIVE WHITE I LABEL j
WHITE
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NO. OF CURIES ;.j N
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V F-5 DECEf5ER, 1978
SECTION F QUALITY ASSURANCE PROGRAM A'!D PROCEDURE FOR THE PACKAGIfiG, TRANSPORTIf!G, SHIPPIris A:!D OPEfilflG OF PACKAGES CONTAINIf!G SEALED SOURCES (Cont'd. from page F-6)
D.
Transportation via cormion carrier shall be in accordance with the following:
(Cont'd) 5.
Shipping packages shall be labeled with two labels on opposite sides as follows:
(Cont'd)
(b) Each package exceeding paragraph (a) but not exceeding 10 mr/hr at any point on the external surface of the package and not exceeding 0.5 mr/hr at 3 feet from the external surface of the package:
RADI0 ACTIVE YELLO'.l II LABEL
- YELLOW a
HANDLE CAREFULLY DIOACTlVE SEPARATIONDISTANCES CBSERVE PRESCRIDED FOR FILM AND PERSONNEL CONTENTS:..vis M
L NO. OF CUR,lEJ: ['.................
TRANSPORT (NDEKi (MAXIMUM OF.C0 PER VLHICLE OR AREAT..
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7 UHITE F-7 DECEM3ER, 1978
SECTION F QUALITY ASSURANCE PROGRAM A*10 PROCEDURE FOR THE PACKAGIflG, TRAflSPORTlflG, SHIPPI.lG A'lD OPENING OF PACKAGES C0flTAINIflG SEALED SOURCES (Cont'd. from page F-7)
D.
Transportation via common carrier shall be in accordance with the following:
(Cont'd) 5.
Shipping packages shall be labeled with two labels on opposite sides as follows:
(Cont'd)
(c) Each package exceeding paragraph (b) but not exceeding 200 mr/hr at any point on the external surface of the package and not exceeding 10 mr/hr at 3 feet from the external surface of the package:
RADI0 ACTIVE YELLOW III LABEL
- YELLOW a
HANDLE CAREFULLY ADIDACI E
SEPARATIONDISTANCES OBSERVE PRESCRIBED FOR FILM AND PERSONNEL CONTENTS:........ g...
No. or cudas4..lS..........
TRANSPORT INdE5, (MAXIMUM OF:$0i i
PER VEHICLE W
OR ARE/.)]
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waiTE F-8 DECEMBER,1978
SECTION F
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QUALITY ASSURANCE PROGRAM AND PROCEDURE FOR THE 1
PACKAGING, TRANSPORTING, SHIPPliiG AND OPENING 0F PACKAGES CONTAINING SEALED SOURCES (Cont'd. from page F-9)
D.
Transportation via conmon carrier shall be in accordance with the following:
(Cont'd.)
6.
The transport index to be assigned to the Yellow II and Yellow III labels shall be determined by measuring the highest radiation dose rate, in millirems per hour at 3 feet from any accessible external surface of the shipping container.
Individual containers may have a transport index of not less than 0.1 and not more than 10, 7.
Insure that old shipping labels have been removed from the package.
8.
If a shipping container is packaged inside a crate or other outer packaging, the outside package shall be marked "INSIDE CONTAINER IN ACCORDANCE WITH Fill in space with appropriate D0T specification number.
9.
For air shipment, the package shall be labeled with a "CARG0 AIRCRAFT ONLY" label.
NOTE: LABELING 0F EMPTY DEPLETED URANIUM SHIELDED CONTAINERS IS NOT REQUIRED, PROVIDED THE SURFACE RADIATION LEVEL IS LESS THAN 0.5 MILLIROENTGENS PER HOUR AND THERE IS NO MEASURABLE RADIATION LEVEL AT 3
THREE FEET FROM THE SURFACE.
THE PACKAGE SHALL BE MARKED:
" RADIOACTIVE - ISA" EXEMPT FROM THE PROVISIONS OF 49 CFR 173.393 PER 49 CFR 173.391 C
, AND THE REQUIREMENTS OF 49 CFR PART 175 PER 49 CFR 175.10 A) 6 E.
OPENING PACKAGES CONTAINING SEALED SOURCES 1.
General Instructions (a) Packages containing sealed sources shall be opened only by radiographers.
(b) Personnel monitoring equipment, as outlined in Section "E" of these procedures, must be worn by all radiography personnel invcived in opening packages containing sealed sources.
2.
Specific Instructions (a)
Inmediately upon receipt of a package containing a sealed source, but in no case later than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> after receipt or 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />, if received after normal working hours, the package shall be checked on all external surfaces with a radiation survey meter.
If radiation levels are found on the external surface of the package in excess of 200 mr/hr or at 3 feet from the external surface of the package in excess of 10 mr/hr, the Radiation Protection Officer shall be notified immediately.
F-9 DECEMBER,1978
SECTION F QUALITY ASSURANCE PROGRAM AND PROCEDURE FOR THE PACKAGirlG, TRANSPORTING, SHIPPING A::D OPENING OF PACKAGES CONTAINING SEALED SOURCES (Cont'd. from page F-9)
E.
OPENING PACKAGES CONTAINING SEALED SOURCES (Cont'd.)
2.
Specific Instructions (Cont'd)
(a)
Cont'd A restricted area will be established around the package in accordance with Section "C" until directions are provided by the Radiation Protection Officer for the safe disposition of the package.
(b)
In the event the shipping container is packaged within a crate or similar package, the packaae shall be monitored as described in paragraph 2 (a) above.
Acceptable packages shall then be opened and the source changer or projector monitored in accordance with the instructions in Section "B" of this manual.
The operating procedures for the applicable device outlined in Section "A" of this manual shall be followed when placing the device in service.
F-10 DECEfBER, 1978
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.the applicable law, st,bject to legal penalties. This Certification shall in no circumstance be signed by an IATA
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9033 L FitE A*.tBLE of the Departrnent of Transportation liarardous lbis certificate is issuM in satisf y Sections t 73.393a.173.394.173.395. ae=1 173.396146 19-10a and 14G-19-100 of the Ocpartm 2.la)
Materiais Her:ufarinns (49 CFD 170 fff9.wl 14 CFR 103) acwt Scetiens Transportation Dangerous Cargoes Hoquiations (46 CFR 14G-149), as amersferf.
ka ung anal contents descret.erf in itern 5 tielow, rnects the sif arv st.vutaeils set for et, in Suhove C of Title 10. Cnsle of FMeeal Requtatiems, Part 71. ** Pack.:gmq of R.idioactive Materiats for leansport and Transaurtation of Rad.oactive f.*.aterial 2 (ii) 1ha tut Cc tain Cormht ons/*
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Title =<=s idane fication of report ne at ofica' ion 3 la)
Psesureel by (thme an<f 4<hfrecs):
Technical Op,erations, Inc. application Technical Operations, Inc.
dated f! 'embey' 8, '1974.
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ITnfag t'if tk s'muirer.9;'s of.Syboart 0;of.10 CFR 71. as appbcable. and the conditions spec 1
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Descri1 tion of Packagmg arul Authorizarf C'ontents. fAoriet Nur er, F,essiie Class. Other Corvsitions and
References:
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Primary A steel encased, uranium shielded'Gama Ray Pro.iector.
components consist of an 00Mr steel shell, polyurethane putting e
The material, uranium shield, Zircalloy "S" tube,~ and end plugs.
contcnts are securely positioned in the Zircalloy "S" tube by a Tamper-proof.
source cable locking device and shipping plug.
Total weight of the seals are provided on the packaging.
packaging is 44 pounds.
s (3)
Drawings 1-The packaging is constructed in accordance wilo the following Technica,1 Operations, Inc. Drawings Nos.:
B66001-16, 17, 20, 21 3,
D666J1 B66001-1 to 3 A66001-22 ll.
A66001-4 to 6 866001-24 3
B66001-7 C660 A66001-ll B66101-1 Bill of Materials D66001 866001-12 C66001 -13, 14 053301-11 D66001-15 0660E01 B66001-23 M-a m
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BE! JAMI!! F. SHAW CC:!PANY Laurens, South Carolina INDUSTRIAL PADIOGRAPIPI REQUEST FOR FIELD RADIOGPMHY Location of work
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Plant Fld. Site Fld. Site Plant Radiographer's Na::e Asst. Radiographer's Name APPROVALS: Radiation Protection Officer CHECK LIST:
TiExposure device locked and secured in vehicle.
' j Items listed in Operating & Ercrgency Procedures, Section F., Para. B4.
G Radiation warning, and notificaticn incase of adcident signs posted on vehicle exterior as required.
(iCopy of Operating & Ibergency Precedures in possession of radiographer.
I Physical radiation survey of vehicle exterior and driver and passenger f~ compartment. Maximum radiation reading nr/nr.
I1 Appropriate personnel at destination notified of arrival time.
Signed :
Title:
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z 4