ML19309H392

QA Program for Packaging & Transport of Radioactive Matl

ML19309H392
Person / Time
Site:	07100385
Issue date:	03/11/1980
From:	Jardine E NAVY, DEPT. OF, FORCES AFLOAT
To:
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ML19309H384	List: ML19309H383 ML19309H390 ML19309H392
References
HECTORINST-9090, NUDOCS 8005130133
Download: ML19309H392 (17)

Text

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}1.WU TJ USS HECTOR (AR-7) INSTRUCTION 9090.1 Subj: Quality Assurance Program for the Packaging of Radioactive Material for transport and transpo'rtation of Radioacti.ve Material under certain conditions (10CFR71)

Ref:

(a)

U.S. Nuclear Regulatory Commission Material License #04-18130-01

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(b) Code of Federal Regulatic.ats Title 10, Part 71 (10CFR71)

(c) Code of Federal Regulations Title 49 Encl:

(1) RMPQA Program 1.

Dackground.

USS IIECT'JR is authorized by reference (a) to use certain

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radioactive materials abc ard HECTOR and on ships and in areas where USS liCCTOR is operating.

In the course of exercising this authori=atidn, some of these caterials are raipped to and from civilian suppliers who are likewise licensed by the NRC to provide these materials. A recent revision to reference (b) requires the development of a program as follows:

"The licensee shall establish, maintain and execute a quality assurance program satisfying each of the applicable criteria specified in appendix E,

' Quality Assurance criteria for shipping packages for radioactive material',

and satisfying an/ specific provisions which are applicable to the licensee's activities, including procurement packaging."

2.

Scope.

This instruction applies to all radioactive materials ccvered b/ reference (a).

As an end-user it in not intended that lu:CTOR engage in the manufactor or altnration of shipping packages.

Rather, this program is designed to ensure that the quality of the shipping packages received is initially certified by the supplier and maintained uhile such packages are in the custody of USS HECTOR.

This instruction is not to be construed in any case, as a relaxation of the requirements in reference (a) or other directives of higher authority.

T 3.

Action.

This instruction provides for procedures necessary for the

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catiefactory establishment at:d execution of tl'c quality assurance program y

for use in packaging shipnent, and transportation of licensed materials q

l b'/ USS HECTOR ( AR-7 ).

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1;ECTORINST 3120.lA LISTS I,

II and III

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HF MINST 9090.1 11 MAR 1930 l'

l QUALITY ASSUPRICE PRCCRA'! FOR T;iE PACKAGING OF s

RADIOACTIVE MATERIAL FOR TRANSPGPT AND TRANSPORTATION OF RADIOACTIVE MATERIAL UNDER CERTAIN cot 3DITIONS (10CFR71) e U.

S. NUCLEAR REGULATORY COMMISSION MATERIALS LICENSE NO. 04-18130-01 LICENSEE:

DEPARTMENT OF T!!E NAVY USS liECTOR (AR-7)

FPO SAN FRANCISCO, CA 96601 v.~

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liECTOR!!!ST 9090.1 11 MAR 190?

REcoac cP CHMIGES 75 E

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a CHAIJGE DATE OF DATE Et4TERED BY f3UNER CIANGE E'iTERED (SIGIJATURE) l t

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TABLE OF CC::T2?r!'S s

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If1PLE!4ENTING INSTRUCTIONS i

s RECORD OF CHANGES 11 1.

L TABLE OF CONTEtiTS

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iii DEFI!!ITIONS iv i

ORGAllIZATION I-l QUALITY ASSURANCE II-l DOCi!!!ENT CONTROL III-l IIAriDLI::G, STORAGE, AND SHIPPING IV-1

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INSPECTIOri, TEST APID OPERATING STATUS V-1 QUALITY ASSUMt;CE RECORDS VI-l AUDITS VII-1 M*

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IIECTORINST 9090.1 11 MAR 1%3 l

PT DEFINITIONS

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THE FOLLOWING TERMS ARE DEFINED AS THEY ARE INTENDED TO BE USED IN THIS i

INETRUCTION.

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CFR - CODE OF FEDEPAL REGULATIONS r

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LICENSED ACTIVITY; LICENSEE - USS HECTOR (AR-7)

SIe LICENSED MATERIALS - THOSE MATERIALS FOR WHICH USS HECTOR HOLDS AN NRC APPROVED LICENSE

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NRC - U.

G. NUCLEAR REGULA'IVRY COMMISSION.

f_. l NDT LABORATORY - NON-DESTRUCTIVE TEST LABORATORY

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PACKAGE - A SHIPPING CONTAINER FOR LICENSED RADIOACTIVE MATERIALS RMPQA OFFICER - THE QUALITY ASSURANCE OFFICER FOR THE RMPQA PROGRAM - CIIARGED WITH INSPECTING AND AUDITING TO VERIFY THE PROGRAM R'4PQA PROGRAM - QUALITY ASSUPANCE PROGRAM FOR THE PACKAGING OF RADIOACTIVE MATERIAL I'OR TRANSPORT AND TRANSPORTATION OF RADIOACTIVE MATERIAL CNDER CERTAIN CONDITIONS (ICCFR71)

RSO - RADIOGRAPHIC SAFETY OFFICER I

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6 HECTORCNST 9090.1 11 Mk.

I GECTION 0"E - ORGANIZATTON DT ibilities This section sets forth the organizational respons 1.1 Purpose.

in the RMPQA Program.

The RMPQA Program is composed of four levels of l.2 Description.

responsibility.

By de$inition the senior official of thetion A.

Commanding Officer.

licensed activity, he is responsible for the establishment and execu.

l by of the RMPQA Program.

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of The Commanding Officer assigns and certifies the qualif cat on him.

the RMPQA Officer.

In his role as Head of, Department which actually t in the B.

Repair Officer.

uses licensed materials, the Repair Officer has a vested interesThe i

Of ficer has sufficient organizational freedom to fulfill his funct on RMPQA. Program.

is/are accomplished in an and for ensuring that corrective action (s) timely manner and is/are not being de i

effective, schedules or other conflicts.

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Either the Quality Assurance Radiograp_ hic Safety Officer (RSO). Laboratory supervisor is normally C.

(NDT)

Officer or the Non-Destructive TestIn addition to his responsibilities for ensuring the handling, operation and shipment of licensed materials used assigned as the RSO.

safe receipt, in radiography, he is responsible for:

Ensuring that shipments of licensed materials used by the NDT (a), (b) and (c).

(1)

Laboratory are conducted in accordance with references Ensuring that required inspection and testing incidental to ly shipment of licensed materials used by the NDT Laboratory are proper (2) conducted and documented.

Maintaining records of shipments as reqaired in later sections (3) of this instrcction.

b Ensuring that corrective action, when required, is accomplished in an effective, timely manner by NDT Laboratory personnel.

(4) e Ensuring that personnel under his cognicance to process license d{1 d

i d references (a)

(5) material are trained in the requirements of this instruct on an O

A and (b).

d The RMPQA Officer shall be certified as to his LM His primary function D.

RMPQA Officer.

qualification and appointed by the Commanding Officer.in the R ram.

In this regard he is responsible for:

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L HECTORINST 9090.1 11 MAR 1980 l

wF SECTION ONE f )

APPENDIX "A" i

ORGANIZATIONAL CIIART 6

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lA.1 COMMANDING

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RADIOGRAPHIC SAFETY OFFICER tk l

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11 MAR 1980 E

SECTION c?rs b

APPENDIX "B"

RESPONSIBILITY MATRIX RADIPRAPHIC COMMANDING REPAIR SAFETY RMPQA FUNCTION CF.CER OFFICER OFF'I'CER OFFICER i

PROGRAM A

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TRAINING A

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CERTIFICATION B

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TESTING B

E DOCUME!iT CHANGES A

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SHIPPING A

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AUDITS B

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AL3IT SCHEDULE A

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l LEGEND A - APPROVE B - ACCEPT C - CONCUR D - INITIATE y

C - PERFORM EL:.

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HECTORINST 9090.1 11 'AAR 1980 sec m. ~:, - g:n:.tT < Am a m onocPr L

2.1 EurpcGa.

This section specifies the necessary action which must be undertuNen to successfully establish and extcute a viable quality assurance program for packaging lic:.nced materials.

Er USS HCCTOR is '.icensed to use certain radioactive materials l

e 2.2 Discussion.

as specified in reference (a).

As an end-user HECTOR receives these material i

Therefore, the thrust 4

from NRC licensed suppliers in NRC approved containers.

of the QA Program on board USS HECTOR sha'll be directed toward establishing

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Manufacture proof cf and maintaining the quality of provided containers.

or repair of shipping containers for licensed material shall not be conducted aboard US3 HECTCR without prior approval by the NRC.

L 2.3 ELocedure The promulgation and enforcement of this instruction by appropriate A.

g 7 levels, of the chain of command establishes and implements the RMPQA Program.

Training and experience for all RMPQA Programs functions shall be f 'f -

D.

in accordance with the established procedures:

e (1) The Commanding Officer and Repair Officer are specifically

- I assigned by the Bureau of Naval Personnel in accordance with established directives.

I (2) The RSO shall be assigned by the Commanding Of ficer in accordance w'th reference (a).

(3) The RMPQA Officer shall be assigned and certified be 'cne Commanding Officer following completion of Appendix A to thi; section.

(4) Radiographers shall be qualified in accordance with reference (a).

Changes to the QA Program may be made only by a formal change to this C.

instruction signed by the Commanding Officer. Changes which would signifi-i cantly alter the program must be approved by the NRC.

Each change shall be entered in the manner directed by the change and documented on the Record of Changes page.

D.

Prior to uce all defined quality control procedures, engineering procedures, and specific provisions of the package design approval shall be y'

satisfied for any shipping package used in conjunction with licensed material.

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(1) Documenlation of this shall be maintained on board the HECTOR y

for any contractor-supplied shipping containers for use with licensed materials.

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(2) Specific approval by the NPC shall be obtained, documenting the g

above attribute prior to locally fabricating, repairing, or altering a

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shipping container for use with licensed materials.

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I HECTORINST 9090.1 11.V5h 106U D'.

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f APPE!! DIX "A" 9

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t' (PMPQA Officer Designate) 7-To:

Commanding Of ficer, USS IIECTOR ( AR-7)

> :a Subj: Training and Experience as EMPQA Officer

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I have reviewed and am familiar with the most recent revisions to the following instructions and regulations:

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10CFR71 F

USS HECTOR RMPQA Program t

USS HECTOR IUIPQA Records and Audits USS HF.CTOR License Ilo. 04-18130-01 USS HECTOR Instruction 9090.1 2.

I am prepared to assume the responsibilities as USS HECTOR RMPQA officer.

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APPROVED:

(Commanding Officer /Cate) l A-II-l

I f:ECTORINST 9090.1 11 ".S.h 1980 SECTION E!P22 - D.X"IMENT CONTROI,

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L 3.1 Purpose. This section describes requirements for the control of l

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documents related to the shipping packages.

3.2 Procedure. Each document related to a specific. shipping container shall, h

where necessary, be processed in accordance with Naval Supply Systems Command

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directives in the course of receiving of shipping licensed materials. When IE not required to be in custody of USS HECTOR's Supply Officer, or others, for TE review, documents shall be maintained in the custody of the RSO.

It is anticipated that no document changes should be required.

However, if the jj need arises, changes will be accomplished only with the permission of the

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Co:.manding Officer and in accordance with appropriate procedures.

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4 HECTORINST 9090.1 5

11 m 1980 m

SECTION 4 - HANDLI::G. STOPAGE, AND SHIPP NG P'

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4.1 Purpose.

This section describes those aspects of handling, storage j

and shipping of packages which are important to safety and includes assignment of responsibilities for rhe critical aspects of handling, I,

storage, and shipping.

4.2 Discussion A.

Established safety restriction 3as delineated in reference (a)

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concerning the handling, storage, and shipping of packages for special form 2,

of radioactive material will be followed.

Shipments will not be made unless F g, all tests, certifications, acceptances, and final inspections have been completed. Work instructions have been provided for handling, storage, and l j shippin,g operations for those containers in use.

Work instructions will be

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provided. for handling, storage, and shipping operatiens for those shipping Y

containers contemplated for future use.

B.

The responsibilities of certain personnel involved in the RMPQA Program are described in Section One.

This section provides amplification of those responsibilities by specifying requirements for the aspects of handling, storage, and shipment of packages which are considered critical.

4.3 Procedure A.

The Padiographic Safety officer is responsible for the critical handling, storage, and shipping operations for each shipment of licensed material by the NDT Laboratory. He shall ensure, for each shipping container, that:

(1) Established safety restrictions concerning the handling, storage, and shipping of packages for certain special form of radioactive material are being followed.

(2) Shipments are not made unless all tests, certifications, acceptances, and final inspections have been completed.

r (3) Work instructions have been provided for handling, storage, I

and shipping operations.

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l HECTORINST 9090.1 l

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ET SECTICN FIVE - IMSPECTION, TEST, AND OPC2ATING STATUS l

l 5.1 Purpose. This section describes those aspects of inspection, test and b

operating status of packages which are important to safety and includes assignment of responsibilities for the critical aspects of inspection, test, and operating activities.

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5.2 Discussion X$5 A.

Inspection, test, and operating status of packages for certain

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special form radioactive material will be indicated and controlled by j.js established procedures. The status will be indicated by the tag, label, q',;

marking, or log entry. The status of non-conforming parts or packages will

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be positively maintained by established procedures.

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B." The responsibilities of certain personnel involved in the BMPQA l fy Program are described in Section One.

This section.trovides amplification of those responsibilities by specifying requirementt for the aspects of

l inspect.on, test, and operating status which are considerud critical.

'.l z-5.3 Procedure I

A.

The RadioJraphic Sc 'ety Officer is responsible for the critical L

inspection, test and opct k;Ang activities associatel with each shipping container which riay be used for shipment of licensed materials by the NDT Laboratory.

He nhall ensure, for each shipping container, that:

(1) Inspection, test and operating status of packages for certain special form radioactive material

.s indicated and controlled by established procedures.

(2) Status is indicated by tag, label, marking or log entry.

(3) Status of non-conforming parts or packages are positively maintained by established procedures.

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6 HECTORINST 9090.1 11 MAR i.A')

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SECTION SIX - QUALITY ASSURAtiCC RECORDS tw{u Y

ei C.1 Purpose. This section provides the necessary requirements and guidance d

for satisfactorily documenting the operation of the RMPQA Program aboard D

USS HECTOR.

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j 6.2 Discussion. Adequate documentation will be maintained to demonstrate l

to interested parties that USS HECTOR possesses an effective functional I E RMPQA Program. To this end the following actions shall be taken:

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fi-A.

Records will be maintained and include operating logs, inspections, y

tests, and audit results.

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B.

Other records to be maintained will include qualifications of

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personnel and descriptions of procedures and equipment.

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C.. Records will be maintained according to established proceddres.

D.

Records will be identifiable and retrievable.

E.

A list of the required records and their storage locations will be naintained.

6.3 Procedure A.

The RMPQA Officer shall maintain the original audit reports for all audits and shall maintain a master listing (Index) of all required records which shows their location.

B.

The Radiographic Safety Officer shall maintain all other records.

He shall maintain them in an auditable fashicn, i.e.

they shall be identifiable and retrievable.

These shall include, but are not limited to:

(1) Operating logs, inspectionu, and tests.

(2) Qualification of personnel.

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(3) Descriptions of procedures and equipment.

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N (4) Records of shipments.

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o' HECTORIMST 9090.1 11 MAR L"O l

SECTION SEVEN - AUDITS s

7.1 Purpose.

This section specifies the requirements which must be met g

to establish an effective audit program.

7.2 Discussion 2

1 A.

Appendix "A" to this section contains the audit plan for use in L

audits of the RMPQA Program. This format specifies the minimum requirements I!]k of each audit. The auditor should audit to the intent rather than the F3[

letter of the audit plan.

That is to say each area described in the audit

3g plan should reveal several questions which must be answered to satisfactorily JiR complete the audit.

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B.

Established schedules of audits of the EMPQA Program will be performed.

~.A Results of all audits will be reported to the Commanding Officer, with copies,

WE to the. Repair Officer, and Fbdiographic Safety Officer. Audit rep' orts will

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be evaluated and deficient areas corrected. The audits being performed will be dependent on the safety significance of the activity being audited. Audit 1

reports will be maintained as part of the quality control records.

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7.3 Procedure

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1 A.

Audits shall be conducted by or under the direct supervision of the i

RMPQA Officer.

B.

An audit of each receipt or shipment shall be conducted two weeks following that receipt or shipmen,t.

C.

Semi-annually - A complete audit of the RMPQA Program will be conducted. The specific dates shall be approved by the Commanding Officer.

t D.

The signed audit report shall be forwarded to the Commanding Officer on the completion of each audit. Cc,ies will be provided to the Repair Officer and Radiographic Safety Off! er.

E.

The Repair Officer will review proposed corrective actions and assign completion dates.

F.

The original audit reports and original records of corrective i

action shall be maintained in an auditable fashion by the RMPQA Officer.

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HECTORINST 9090.1 11 MAR 1980 SECTION SEVEN y

APPENDIX "A" ic g

RMPQA AUDIT AUDITS OF THE RADIOACTIVE MATERIAL PACKING QUALITY ASSURANCE PROGRAM MUST BE CONDUCTED TO MEET THE REQUIREMENTS OF USS HEC'IOR RMPQA PROGRAM l is_

AND APPENDIX "E" TO 10 CFR 71.

THE AUDIT MUST BE CONDUCTED BY A tTS IG;CWLEDGEABLE OFFICER NOT HAVING DIRECT RESPONSIBILITY IN THE AREA

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AUDITED (10 CPR 71, APPENDIX "E",

PARAGRAPH 18).

FOLLOW-UP ACTION, f

INCLUDING RE-AUDIT OF. DEFICIENT AREAS SHALL BE TAKEN WHEN CCNSIDERED NECESSARY.

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UX 1.

For each of the established RMPQA procedures, check the following:

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.-E INITIAL

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All procedures used were verified by the RMPQA Officer and RSO (as applicable).

~l B.

The most current verified copy is on file.

C.

Two years of files maintained.

D.

All recuired signatures are present.

2.

The current RMPQA Officer has completed enclosure (1) to HECTORINST 9090.1 and has been approved by the Commanding Officer.

3.

All radiographers have completed reference (a) require-ments for qualification and have been approved by the designated officers.

4.

All RMPQA revisions have been authorized by the Co m.andins Officer and each, revision is documented on the Record of Changes page ii HECTORINST 9090. ' on file with RMPQA records (and any others in use).

p 5.

For each radioactive material shipping package to be used on board HECTOR, ver,fy that:

A.

The NRC approval for that package is on board The spedific provisions made with the package B.

approval are being adhered to.

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SECTIOf3 SEVEti - APPE!! DIX "A" CC!.'T' D

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A cocplete list of IIRC approved packages is on file 7.

Registration with the !!RC for use of a package occurred prior to use of the package,and a copy of this regis-tration is on file.

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General comments / discrepancies:

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