ML19259A899

Forwards QA Requirements for Transport Packages in Compliance w/10CFR71.51

ML19259A899
Person / Time
Site:	07100236
Issue date:	12/21/1978
From:	Anderson C AMERICAN AIRLINES, INC.
To:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 7901110150
Download: ML19259A899 (4)

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. U;T1 December 21, 1978 Director Office Of Nuclear Material Safety and Safeguards U.S.

Nuclear Regulatory Commission Washington, D.C. 20555 I

Dear Sir:

1 Attached is American Airlines proposed program, " Quality Assurance Requirements for Transport Packages," (10CFR71 QA Program).

It is submitted for approval in compliance with 10CFR, Para 6 rah 71 51.

Very truly yours, AERICAN AIRLI:ES, INC s

l C. R. Anderson

{

yanager Nonduestructive Quality Assurance

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M AINTEN ANCE & ENGINEERING CENTER. TULSA. OKLAMOY A 7a'51. 918 8%5511. CASLE AOCRESS AMalR f

ISorcPE RARIT,RAPHY NCN DESTRUCTIVE Page 86 TESTING MANUAL loCFR71 QA PROGRAM (UALITY ASSURANCE REQUIREiTS FCR TRANSPORT PACKAGES A.

SCCPE The gaality assurance requirements of loCFR Part 71, " Packaging of Radioact'_ve Material for Transport and Transportation of Radicactive Faterial Under Certain Conditions" apply to A=erican Airlines (the licencee) when such =aterials are delivered to a carrier for transport or tranrports such caterial outside the confiner of the station concerned.

B.

APPLICABILITY The quality assurance program applies to the design, fabrication, asse=bly, testing, use (preparation of packages for ship =ent) and =sintenance of trans-portation packages. The QA pregram description =ust show how all licensed packaging and transport activities are covered.

The responsibility of the Radiographer concerned extends to all aspects of the transportation package.

Certification from others =ay be used for areas not under the direct control of A=erican Airlines such as design, fabrication, assembly, initial testing, repair and =odification. The authority for A=erican Airlines to use an NRC approved package is contained in the general license in loCFR Parc 71 paragraph 71.12 following registration, by A=erican-Airlines, with NRC and submission of certain other infor=ation. Co=pliance with the provisions of the general licensee is =andatory. However it is.the concerned Radiographer's responsibility to deter =ine that all quality assurance provisions for the package have been followed and to describe to the 1;RC how that determination was =ade.

The actual use =ust be in accordance with American Airlines NRC-approved quality assurance program.

Transport psekages used by A=erican Airlines are Type B, NRC approved, packages.

Model Contents Certificate of Package Compliance No.

Identification No.

650 IR-192 9032 USA /9032/B 660 IR-192 9033 USA /9033/B 500-5U IR-192 9006 USA /90c6/B C.

CRGANIZATICN QUALITY ASSURANCE DIVISION The organization that administers the develop =ent of all condestructive testing programs for the A=erican Airlines system, and the organi:ntion that perfor=s condestructive test at the American Airlines Maintenance and Engineering Center at Tulsa, Cklaho=a.

NON DESTRUcrIVE IScr0PE RADIOGRAPHY TESTING MANUAL Page 87 C. ORGANIZATION (CONTINUED)

SENICR DIRECTOR CUALITY 1.SSURANCE W. W. Schaefer DIREcrOR PCWER PLANT AND COGONEITIS L. J. Pool

..... " MANAGER' 'ND'P/

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C. R. Anderson The overan responsibility for the development of an nondestructive testing programs, which includes the Isotope Radio 6raphy Program.

RADIATION SAFETY OFFICIR B. W. Nethercutt The Radiation Safety Cfficer is responsible for overan administration of the QA program, training and certification, document control, and auditing.

RADIQ',RAPHERS The Radiographers are responsible for handling, storing, shipping, inspection, test, operating status, and recordkeeping.

D.'.QUALITf ASSURANCE PROGRAM The Management of American Airlines establishes and imple=ents this Quality Assurance Program. Training for a n QA functions, prior to engagement in these functions, is required as specified in the NDT Manual pages 29 thru

38. QA Program revisions will be made in accordance with procedures as outlined on page 15 of the General section of the NIrr Manual. The QA Program win ensure that an defined QA procedures, engineering procedures, and specific provisions of the package design approval are satisfied. The QA Program win emphasize control of the characteristics of the packa5e which are critical to safety.

E. DOCUMENT CONTROL All documents related to a specific shipping package will be controlled through the use of established procedures as stated in the General Secticn page 15 of the NDP Manual.

The Radiation Safety Officer will be responsible for manual revisions and insure they comply with the NRC and company regulations.

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ISOICPE RAdICERAPHY NON DISTRUCTIVE Pa;e 83.

TESTE;G MANUAL F.

HANDLEIG STORAGE AND SHIPPHIG Written safety procedures ccacerning the handling, storage an.1 shipping of packsges for certain special form radioactive =aterial win be followed.

These safety procedures are as specified in 10 CFR Part 71 51.

Ship =ents vill not be =ade unless a n tests, certifications, acceptances, mi final inspections have been ecmpleted. All ship =ents win be in fun co=pliance with the Air Transport Restricted Articles Circular No. 6-D.

Handling, Storage, and Shipping instructions are included.in the NDP Manual, pages 65, 66, 66A, and 67 Qualified Radiographers shan perform the critical handling, storage and shipping operations.

G.

EISPECTION, TEST, AND OPERATE!G STATUS Inspection, test, and operating status of packages for certain special form radioactive caterial win be controlled by written procedure in the NDI Manual, page 61 and 62.

Status v111 be indicated by tag, label, marking, or log entry. Status of nonconforming parts or packages win be positively maintained by written procedures.

Qualified Rsdiographers shan perform the regulatory required inspections and tests in accordance wit] vritten procedures as stated in the NUr Manual.

H.

CUALITY ASSURANCE RECORDS Records of package approvals (including references and drawings), inspections, test, operating logs, audit results, personnel training and qualifications, and records of shipments win be maintained. Descriptions of equip =ent and vritten precedures win also be maintained.

The Radiation Safety Officer will =aintain the records or legs as required by the NDP Panual or have access to such records.

I.

AUDITS Established schedules of audits of the Quality Assurance Program vill be perfor=ed using written checklists. Results of audits win be maintained and reported to =anagement. Audit reports will be evaluated and deficient areas corrected. The audits win be dependent on the safety significance of the activity being audited, but each activity vill be audited at least once per year. Audit reports will be maintained as part of the quality assurance records.

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