ML19347F306
| ML19347F306 | |
| Person / Time | |
|---|---|
| Site: | 07100443 |
| Issue date: | 04/14/1981 |
| From: | Hartman J JOHN DEERE CORP. |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 18985, NUDOCS 8105180324 | |
| Download: ML19347F306 (5) | |
Text
Ill-6M fMh JOHN DEERE FOUNDRY Nbf'r8 D
' V' usf wount, twNois suu A
'D. Cr ArY O
- 8
- m.ss
%e p
4 0 5yg
{
f (3%I MR 20 % \\ 53 To
- t s&
%cN U.S. NUCL CAM 2G s
CortmM(OH M
g,-
14 April 1981 tetS5 nant.$ticD04 O
g
/[ % I, f Director, Office of Nuclear Safety & Safeguards United States Nuclear Regulatory Commissions 4IE/ 0 7198 Washington, D.
C.
20555
.Z 1
,; v.s.kgg s
SUBJECT:
APPLICATION FOR APPROVAL OF QUALITY ASSURANCE \\ n U.-
PROGRAM AND REGISTRATION FOR SHIPMENT AND PACKAGE DESIGN O
\\'
N
(
Reference:
NRC License No. 12 09111 - 01)
INTRODUCTION:
John Deere Foundry is licensed for two (2) Cobalt 60 sealed sources:
No. 1 is a 50 curie sealed source (Tech / Ops Model No. 424-8 modified to use a 4550 Ball Connector) and stored in a Tech / Ops Model 446 projector.
This source will be shipped, once in every 5 years (Half-Life) to Technical Operations, Inc. of Burlington, Mass.
The shipping package will be either a Tech / Ops Model 488 source changer, or a Tech / Ops Modal 771.
Model #488:
Tech / Ops has informed us that this Model is a Dot Specification 55 container and that we do not need to maintain any documentation or package approval.
Model 4771:
U.S.N.R.C.
certification No. 9107 has been assigned to this container and we do have a copy of Tech /
Ops documentation.
Model A 424-8 encapsulated source; U.S.N.R.C. certification No. USA /0165/S (Revision O).
We have a copy of Tech / Ops "IAEA Certificate of Competent Authority".
No. 2 Source:
Is a 15 millicurie source contained in a Tech / Ops Model 571 survey meter calibration kit and does not require a registration No. for shipment.
Our radiographic staff consists of:
three (3) Radiographers
)
one on 1st shift and one on 2nd shift and one stand-by Radiographer; and two Radiation Protection Officers - One on 1st shift and one on 2nd shift.
p=
t*UTR* W**
ss;>
18985 8105180 M h
N k
Pcgo 2 f
~
I
~
i JONN DEERE POUNDRV t
Since we participate in the shipping of a sealed source only once every 5 years, we involve our entire Radicgraphic l
Staff in this operation.
This gives us the opportunity to i
review, retrain and update the entire staff in the entire procedure of packaging, testing, labeling and shipping of a sealed source.
i 4
1.
ORGANIZATION:
l The final responsibility for the Quality Assurance Program
{
for Part 71 requirements rests with John Deere Foundry.
Design and fabrication of radioactive material packages
{
shall nct be conducted under this Quality Assurance Progra:1.
-i The only packaging to be used by John Deere Foundry, for l
shipping a rype A sealed source greater than 20 curies, is i
either a Tech / Ops Model No. 488 source changer or a Tech / Ops Model 771 source changer.
The Radiation Protection Officer is responsible for overall l
administration of the program, training and certification, I
document control and auditing.
l The Radiographers are responsible for handling, storing, shipping, inspection, test, operating status and. record keeping.
See c*.tachment #1 for Organizational Chart.
2.
QUALITY ASSURANCE PROGRAM:
The management of John Deere Foundry establishes and imple-ments this Quality Assurance Program.
Training for all Quality Assurance functions, prior to engagement in these i
functions, is required according to written procedures which are part of " John Deere Foundry Radiographic Manual".
This manual (2 copies) has been presented to the Licensing i
Branch.
The Radiation Protection Officer will assure that all Radio-4 active Material packages (provided by Technical Operations Inc. of Burlington, Mass) are designed and manufactured under a Quality Assurcnce Program approved by the N.R.C. possessing a certification from the manufacturer (Tech / Ops).
3.
DOCUMENT CONTROL:
All documents related to a specific package will be controlled through the use of written procedures. All document changes will be according to written procedures approved by management.
i The Radiation Protection officer will insure that all Quality Assurance functions are conducted per the latest documents.
.-r
, -.. ~. -
Paga 3
~
JOHN DEERE POUNDRV 4.
HANDLING, STORAGE AND SHIPPING:
All written safety procedures covering the handling, storage and shipping of our #1 sealed source, will be followed.
This includes:
all receiving activities (including Radiation survey of shipping package and recording of results), storage of package while in our facility, and shipping, which includes; sealing, labeling, leak testing, radiation survey, completing of all shipping documents, and maintaining all results and records.
Radiographers will conduct all of these activities and Radiation Protection Of ficer(s) will ensure that all functions are properly performed.
5.
INSPECTION, TEST & OPERATING STATUS:
Inspection, test and operating status of packaging (Tech / Ops Model 771 source changer) for shipping our sealed Cobalt 60 source will be indicated and controlled by written procedures.
Status will be indicated by tag, label, marking or log entry.
Status of nonconforming parts or packages will be maintained l
by written procedures.
Radiographers will perform the required inspections and tests
}
according to our written procedures.
The Radiation Protection Officer (s) will ensure that these functions are performed.
6.
Records of Package approvals, inspection, tests, operating j
logs, audit results, personnel training and qualifications i
and records of shipments will be maintained.
Description of shipments and written procedures will be maintained.
I Records will be maintained in accordance with written procedures.
Records will be identifiable and retrievable.
A list of records, i
with their storage location, will be maintained by the Radiation Protection Officer.
7.
AUDITS:
l Audit schedules of the Quality Assurance Program will be established (each instance of a shipment - normally once every 5 years) and will be conducted by using a written check list, results will be maintained and reported to management.
Audit results will be evaluated and deficiencies will be corrected.
Audit reports will be maintained as part of the Quality Assurance records.
Audit team member (s) will have no respon-sibility in the activity being audited, i
l
,n.
Pcga 4 JOHN DEERE POUNDRY CONCLUSION:
We are presently anticipating the replacement of our No. 1 source (50 curies) during the month of June.
This is timed to correspond with a maintenance function which requires the storing of source in a source changer which has to be shipped to us from Tech / Ops.
We had planned to have a new source shipped in the container and then return the decayed source (will be approximately 27 curies at time of shipment).
We would like to proceed as planned; however, I tu June that we may not have received our registration by this date.
May we proceed as planned, or would we be in violation to do so?
If necessary, we can delay exchanging our source until August or September.
May I request a decision on this from your office so that we can schedule accordingly?
Thank you.
Y
?Uchn Hartman, Radiation Protection Officer h John Deere Foundry JH:ms l
P l
l
e ORGANIZATIONAL STRUCTURE
- i
~U CENERAL MANAGER O
- n O
Ps m N $,
p r d
r Oz m M S m E a a M
n WORKS MANAGER MANAGER
"^
^
b MANAGER PERSONNEL INDUSTRIAL ASSURANCE f
RELATIONS RADIATION SAFETY OFFICERS Nm RADIO-(j CRAPilERS CTI
. _ _