ML19263A771

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Forwards Copies of Radiographic Transportation Package QA Program in Compliance w/10CFR71.51
ML19263A771
Person / Time
Site: 07100217
Issue date: 12/14/1978
From: Joseph Turner
PULLMAN POWER PRODUCTS CORP. (FORMERLY PULLMAN, INC.)
To:
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 7901020300
Download: ML19263A771 (6)


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Director Office of Nuclear Materials Safety and Safegu6rds United States Nuclear Regulatory Commission Washington, D.C.

20555 Re: US NRC License No. 42-16573-01

Dear Sir:

Attached are three (3) copies of the Pullman Kellogg Radiography trans-portation package Q. A. program. This program was developed to comply with the regulations of 10 CFR part 71.51.

Sincerely yours, E/w James E. Turner Assistant Radiation Protection Officer JET /elb Attachments cc:

D. C. Vaughn w/o K. L. Kluge/ Chrono w/o AE-NRC w/att.

1?.E'.S 79010203oO World headquarters iv M W. Kellogg technology and service.

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QUALITY ASSURANCE PROGRAM S

REVISED BY:

DATE ISSUED: 14 cec. 78

'2 10 CFR 71 RADIOGRAPHY TRANSPORTATION g,,7g ggy, I

REV. APP. SY:

PACKAGE Q. A. DROGRAM

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ORGANIZATION The final responsibility for the radiography transportation package 1.1 Quality Assurance Program to meet part 71 requirements rests with Pullman Kellogg Construction Department.

Design and/or fabrication of radioactive material shipping packages sha,11 not ' e conducted c

unde. ';his program.

1.2 The Quality Assurance program is implemented using the following organization:

The " Radiation Protection.0fficer (RPO)", Kenneth L. Kluge, shall have the over-all responsibility and authority for the 10 CFR 71 Q.A. Program, reporting in such capacity to D. C. Vaughn, Vice President.

1.3 The Radiation Protection Officer is responsible for the following:

1.3.1 The safety of all personnel performing or coming in contact with the performance of radiography.

1.3.2 The training of all Radiographer.'s Assistants and Radiographers.

1.3.3 Reviewing radiation dosage records, survey records, inventory records, and personnel records.

1.3.4 The testing of all personnel performing radiography.

1.3.5 Disciplinary action when requi, red.

1.3.6 Periodic inspections of performance and ' equipment.

1.3.7 Refresher training of personnel periodic and cont.inuing.

1.3.8 Reviewing over with personnel any deficiency found and the required correction.

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ORGANIZATION (cont'd) 1.4 The radiographars are responsible to the Radiation Protection Officer for the conduct of the Kellogg Construction Department Radiography program at each field iobsite including source handling, storing, m

shipping, inspection, tests, operating status and record keeping.

2.

QUALITY ASSURANCE PROGRAM 2.1 The management of Pullman Kellogg has established and dictates the implementation of this Quality Assurance Program.

2.2 No person shall be permitted to act as a Kellogg Construction Department Radiographer or Radiographers Assistant until such a person has been tested and certified as outlined in part A of the Kellogg Construction Department Radiography Program Manual.

2.3 Radiocraphy Program revisions are made according to written. procedures with the approval of Radiation Protection Officer and the appropriate regulatory agency.

2.4 The Kellogg Construction Department Radiography program ensures that all manufacturer Q. C. procedures and specific provisions of the package design approval are satisfied. The' transportation package Q. A. Program will emphasize control of the characteristics of the package which are critical to safety.

2.5 The Radiation Protection Officer shall assure that all radioactive material shipping packages used by the Kellogg Construction Department are designed and manufactured under a Quality Assurance Program approved by the Nuclear Regulatory Commission for all packages i

designed or fabricated after 1 July 1978. This raquirement will be

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PACKAGE Q. A. PROGRAM rw Z

8 QUALITY ASSURANCE PROGRAM (cont'd) 2.

satisfied by receiving a certification to this effect from the manufacturer.

3.

DOCUMENT CONTROL All documents and forms related to a specific shipping packag 3.1 d

contairer will be controlled through the use of written proce ur that will be included in the Kellogg Construction Department Radiography Program.

All document changes will be performed according to wri 3.2 cpproved by the Radiation "rotection Officer.

The Radiation Protection Officer shall insure that all transp 3.3 h

tion package Q. A. functions are conducted in accordance latest applicable ci.drges to these documents.

HANDLING, STORAGE AND SHIPPING hipping 4.

Written safety procedures concerning the handling, storage 4.1 llogg of packages for certain special form material used by P d

will be followed as stated in part B, " Operating, Maintenanc Emergency Procedures" of the Kellogg Construction Depa Radiography Program.

Shipments of radioactive materials shall not be made u 4.2 have required test, certifications, acceptances and final inspec been completed as called-out in the Kellogg Constructi I

Radiography Program.

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PACKAGE Q. A. PROGRAM j;i REV. APP. SY: -

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b-HANDLING, STORAGE AND SHIPPING _ (cont'd) 4.

Work instructions are provided for handling, storage and shipping 4.3 operations in Part B of the Kellogg Construction Department Radio graphy Program.

Only radiographers shall perfcrm the critical handling, storage i

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and shipping operations.

I INSPECTION, TESTS AND OPERATING STATUS 5.

Inspection, tests and operating status of transportation packages 5.1 for certain special form radioactive materials will be indicated and controlled as specified in Part B of the Kellogg Construction Department Radiography Program.

Status will be documented by appropriate check list.

5.2 Status of nonconforming items will be positively maintained as 5.3 required by Part B of the Kellogg Construction Department Radio-graphy Program.

6.

QUALITY ASSURANCE RECORDS Records of package approvals, including references and drawings, 6.1 inspections, tests, operating records, audit results, perscnnel training and-qualifications and records of shipments will be maintained in the Houston office.

Description of radiography equipment and wr'itten safety proced 6.2 are maintained in the Kellogg Construction Department Radiograp Program Manual.

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QUALITY ASSURANCE RECORD 5 (cont'd) 6.3 All radiography records are identifiable and retrievable. A list of these records with their storage locations is maintained by the Radiation Protection Officer.

7.

AUDITS 7.1 Established schedules of Audits of jobsite radiography projects will be performed using a written check list.

Results are maintained and reported to management.

7.2 Audit reports are evaluated and deficient areas corrected.

7.3 Each jobsite radiography program is audited once every calendar quarter.

7.4 Audit reports are maintained as part of the Radiography Program records.

7.5 Audits shall be conducted by either the Radiation Protection Officer or the Assistant Radiation Protection Officer.

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