ML19282D075

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Proposed QA Program Does Not Meet Requirements of App E to 10CFR71.Forwards Sample QA Program for Industrial Radiography Licensees, ,to Assist in Application Revision.Requests Revision by 790520
ML19282D075
Person / Time
Site: 07100116
Issue date: 04/20/1979
From: Macdonald C
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Miller W
NAVY, DEPT. OF
References
NUDOCS 7905110210
Download: ML19282D075 (3)


Text

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  • APR 2 o 1979 FCTR: RHO 71-0116 U.S. Department of the Navy U.S.S. Prairie ( AD-15)

ATTN:

Mr. W. A. Miller FP0 San Francisco, CA 96601 Gentlemen:

This refers to your application dated June 2,1978 requesting approval of your Quality Assurance (QA) program as meeting the QA program requirements of 10 CFR 571.51.

In connection with our review, we have determined that your proposed QA progra:'1 does not meet the requirements of Appendix E to 10 CFR Part 71.

To assist you in revising your application, we have enclosed a sample QA program for industrial radiography licensees dated April 2, 1979.

Please submit sevsn copies of your revised application within 30 days of the date of this letter.

If you have any questions regarding this request, please contact Mr. Jack Spraul at (301) 492-7741.

Sincerely,

$k

?'C Charles E. MacDonald, Chief Transportation Branch Division of Fuel Cycle and flaterial Safety, NMSS

Enclosure:

Sample QA Progran 7905110A[D

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April 2, 1979 (Revision 1) 10 CFR PART 71 OA PROGRAM FOR INDUSTRIAL RADIOGRAPHY LICENSEES 1.

Organization The final responsibility for the Quality Assurance (QA) Program for Part 71 Requirements rests with (Company Name).

Design and Fabrication shall not be conducted under this QA Program.

The QA Program is implemented using the following organization:

Note: The Organizational Chart as used in the license application should be presented.

It may be advisable to designate the Radiation Safety Officer as the responsible individual for the Part 71 QA Requirements.

The Radiation Safety Officer is responsible for overall administration of the 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.

Quality Assurance Program The management of (Company Program) establishes and implements this QA Program. Training, prior to engagement, for all QA functions is required according to written procedures. QA Program revisions will be made according to written procedures with management approval.

The QA Program will ensure that all defined QC procedures, engineering procedures, and specific provisions of the package design approval are satisfied.

The QA program will emphasize control of the characteristics 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 after the effective date of the QA Program.

This requirement can be l

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

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.

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4 2.

4.

'llandling Storage and Shipping h'ritten 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, cert i fi cat ions, acceptances, and final inspections have been completed.

Work i.nstructions will be provided for handling, storage, end shipping operations.

Radiography personnel shall perfom 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 nonconfernir.g parts or packages will be positively maintained by written protedurcs.

Radiography parsonnel shall parform the regulatory required inspections and tests in accordance with written procedures.

The Radiation Safety Officer shall ensure that these functions are performed.

6.

Quality Assurance Records Records of package approvals (including references and drawings), procure-ment, inspections, tests, operating logs, audit results, personnel training and qualifications and records of shipments will be maintained.

D scriptions of equipment and written procedures will also be maintained, nese records will be maintained in accordance with written procedures.

The records will be identifiable and retrievabic.

A list of these records, with their storage locations, will be maintained by the Radiation Safety Of ficer.

7.

Audits Established schedules of audits of the QA Program will be performed using written check lists.

Results of audits will be maintained and reported to managenent.

Audit reports will be evaluated and deficient areas corrected.

H e 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.

Members of the audit team shall have no responsibility in the activity being audited.

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