ML19259A981
| ML19259A981 | |
| Person / Time | |
|---|---|
| Site: | 07100242 |
| Issue date: | 12/21/1978 |
| From: | Erwin R LAW ENGINEERING TESTING CO. |
| To: | Hopkins D NRC OFFICE OF STANDARDS DEVELOPMENT |
| References | |
| NUDOCS 7901150156 | |
| Download: ML19259A981 (6) | |
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LAW ENGINEERING TESTING COMPANY Geotechnicaland Materials Engineers 2600 CEN IURY PAR KWAY, N.E. / SUITE 425 / P. O. BOX 98003 ATLANTA, GEORGIA 30359 / (4CM) 325 3933 December 21, 1978
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6, U. S. Nucicar Regulatory Commission ICE/pEO r.
MS 5650 N/L 1
Ogg2 g 7 Washington, D. C. 20555 g
Attn:
Mr. Donald R. Hopkins Re:
Quality Assurance Program 10CFR71 M
Gentlemen:
Attached is a Quality Assurance Program which will be implementad by Law Engineering Testing Company when involved with packaging radio-active material for transport and transportation of radioactive material.
This Quality Assurance Program meets
'te requirements of Title 10, Part 71, Appendix E.
The program will b-ame effective January 1,1979.
Respectively submitted, LAW ENGINEERING TESTING COMPANY Y
r Robert G. Erwin Corporate Safety Director
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'11531 790115oISG C
Law Engineering Testing Co=pany Quality Assurance Program To Comply with 10CFR 71
" Packaging of Radioactive Material for Transport & Transportation of Radioactive Material Under Certain Conditions" 1.
ORGANIZATION The final responsibility for the Quality Assurance (QA) Program for Part 71 Requirements rest with Law Engineering Testing Company.
Design and e
Fabrication shall not be conducted under this QA Program. The QA Program is implemented using the following organization..(See attachment A)
The individual Radiation Safety Officers are responsible for overall adminis-trations of this program, training and certification, document control and auditing. The radiographers are responsible for handling, storing, shipping, inspection, test and operating status and record keeping.
2.
@ TTY ASSURANCE PROGRAM Tk Raliation Safety Officer will train radiographers in the QA functions mentioned above such functions being enumerated in Law Engineering Testing Company's operating and emergency prc:edures and in tource exchange procedures.
There will be no revisions in the QA program except in writing with management approval. This QA program thru the Radiation Safety Officer will ensure that all defined procedures and specific provisions of the package design are
- satisfied. Special emphasis will be placed on controlling those character-istics of the package which are critical to safety
' The Radiation Safety Officer shall assure that all radioactive material shipping packages are designed and manufactured under a QA program approved by Nuclear Regulatory Commission for all packages designed or fabricated af ter January 1,1979. This requirement can be satisfied by receiving a certification to this effect from the manufacturer.
Page 2 3.
DOCUMENT CONTROL All documents related to a specific shipping package will be controlled through the use of written procedures. All document changes will be performed according to written procedures approved by management.
The Radiation Safety Officer shall insure that all QA functions are conducted in accordance with the latest applicable changes to these documents.
4.
HANDLING STORAGE AND SHIPPING Written safety procedures concerning the handling, storage and shipping of packages for certain 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 will be pro-vided for handling, storage, and shipping operations.
Radiography personnel shall perform the critical handling, storage and shipping operations.
5.
INSPECTION, TEST AND OPERATING STATUS Inspection, test and operating status of packages for certain special form radioactive material will be indicated and controlled by written procedures.
Status will be indicated by tag, label, marking or log entry. Status of non-conforming parts or packages will be positively maintained by written pro-cedures.
Radiography personnel shall perform the regulatory required inspections and tests in accordance with written procedures. The Radiation Safety Officer shall ensure that these functions are performed.
Page 3 6.
QUALITY ASSURANCE RECORDS Records of pa'ckage approvals (including references and drawings, procurement, inspection, tests, 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.
These records will be maintained in accordance with written procedures.
The records will be identifiable and retrievable. A list of these records, with their storage locations, will be maintained by the Radistion Safety Officer.
7.
AUDITS Established schedules of audits of this QA program willbe performed using written check list. 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 The audits shall be performed by appropriately trained personnel not having direct responsibilities in the areas being audited.
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Attachment A LAW ENGINEERING TESTING COMPANY 2600 Century Parkway, N. E.
Suite 423, P. O. Box 98008 Briarcliff Station Atlanta, Georgia 30329 ADMINISTRATIVE CONTROL AND RADIOGICAL PROTECTION PROCEDUR A.
Responsibility for' the Control and Use of isotopes Specific Duties
_ Advisory Duties 1.
Deveiop and maintain 1.
Maintain Technical Liaison up to date operating
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1 With The AEC,and and emergency proce.
President dures.
agreement states, 2.
Investigate cause of in.
2.
Estabiish, maintain and Safety Director cidents and determine aud.it a personnei necessary preventive monitoring program.
action.
3.
Report allincidents to the 3.
Conduct the established Radiation Safety Atomic Energy Conimissio training program for Officers radiographers and radio.
4.
Act in advisory capacity graphers assistants.
to management reporting directly to. the Executive 4.
Examine and determine Vice President or,in his c'9mpetency of radio-temporary absence, the Branch Manager Safety Director.
graphic personnel.
5.
Establish.. maintain and 1.
Maintain control of audit the record keeping Radiographer procurement and disposal system and instrument Radiographer Assistants of licensed by. product calibration program.
material.
'6.
Reports directly to the 2.
. Establish and maintain Executive Vice President adequate storage f ac.ilities.
3.
Maintain exposur,e devices, or, in his temporary absence, the Safety radiography facilities and Director.
associated equipment.
4..
Fiesponsibility for the source repiacement operations.
5.
Procure & maintain adequate radiation survey instruments.
6.
Review and insure safety -
in handling of by product
' material.
7.
Maintain branch level files.
8.
Audit facilities and personnel operations. '-
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POSITION INCUMBENTS OIART OF RESIONSIBILITY FOR THE CDNTROL AND USE OF ISO'IUPES Effective January 1,1979 President A. J. Glenn, III Office Phone 404/325-3933 Home Phone 404/993-3146 Safety Director R. G. Erwin Office Pnone 404/325-3933 Home Phone 404/636-0256 North Carolina, RSO E.'H. Beck Office Phone 704/523-2022 Home Phone 704/365-2446 South Carolina, RSO E. M. Beck Office Phone 704/523-2022 Home Phone 704/365-2446 Virginia, RSO J. A. Unterspan Office Phone 703/790-5700 Home Phone 703/860-2575 Georgia, RSO G. V. Aseff Office Phone 404/873-4761 Home Phone 404/627-5379 Florida, RSO B. B. Wildes Office Phone 904/396-5173 Home Phone 904/743-0367 Alabama, RSO R. D. Phillips Office Phone 205/252-9901 Home Phone 205/681-6393 Charlotte Branch Manager E. L. Page Office Phone 704/523-2022 Home Phone 704/364-3092 Raleigh, Branch Manager R. C. Leach Office Phone 919/874-0416 Home Phone 919/787-5374 Washington Branch Manager J. A. Unterspan Office Phone 703/790-5700 Home Phone 703/860-2575 Jacksonville Branch Manager W. H. Johnson Office Phone 904/396-5173 Home Phone 904/398-4399 Tampa Branch Manager K. J. Seefried Office Phone 813/879-0750 Home Phone 813/846-1128 Atlanta Branch Manager W. T. Kiser Office Phone 404/873-4761 Home Phone 404-451-5084 Birmingham Branch Manager K. E. Roberts Office Phone 205/252-9901 Home Phone 205/870-4691 Columbia Branch Manager C. M. Jenkins Office Phone 803/779-3161 Home Phone 803/781-4292