ML19350E654
| ML19350E654 | |
| Person / Time | |
|---|---|
| Site: | 07100331 |
| Issue date: | 06/15/1981 |
| From: | North Carolina State University, RALEIGH, NC |
| To: | |
| Shared Package | |
| ML19350E652 | List: |
| References | |
| NUDOCS 8106230404 | |
| Download: ML19350E654 (9) | |
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NORTH CAROLINA STATE UNIVERSITY Nuclear Engineering Department g
Quality Assurance Program for Shipping Radioactive Material Intscduction This document establishes the' quality assurance program (QAP) of the Nuclear Engineering Department (NED), North Carolina State University (NCSU) at Raleigh, for the procurement, use, handling and returning of shipping con-tainers for radioactive material (RAM) in accordance with Title 10, Code of Federal Regulations, Pa. : 71, Appendix E, effective August 1,1980. Each paragraph of Appendix E is addressed, if only to specifically exclude these topics. The NED does not anticipate any activity relating thereto.
As defined in Appendix E," ' Quality assurance' comprises all those planne(
and systematic actions necessary to provide adequate confidence that a system or component will perform satisfactorily in savice. Quality assurance in-clud's quality control which comprises those quality assurance actions related e
to the control of the physical characteristics and quality of the material or component to predetermined requirement." The Univ < sity personnel; the Nuclear Reactor Program (NRP) staff, the QA/QC staff and the personnel assisting in each shipment of RAM, are determined to see that all shipments from NCSU Nuclear Engineering Department facilities are made in a safe manner and comply
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fully with existing regulations.
The shipment of radioactive materials are categorized as; exempt, Type A, Type B and large quantities. This QA program is specifically concerned with the Type B, large quantity shipments and shipment of spent fuel assemblies.
Safety control will be comensurate with the radioactivity and the fonn of the material being shipped, The likely materials to be shipped by the NED in increasing order of QA requirements are:
a.
Fresh fuel (unirradiated) b.
Type B quantities c.
Large quantities of activity, and spent fuel assemblies.
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_2 This QAP is applicable to containers owned by another party and for which NCSU is registered as an authorized user. The graded approach to safety control will be applied to each container and shipment through special procedure check-lists, other necessary documents and training to the degree required to be certain the shipment will be accomplished safely.
Organization The North Carolina Stace University (NCSU), through its Nuclear Engineering 4
Department (NED), shall retain and exercise responsibility for the quality as-surance program (QAP) applicable to tha containers in which RAM will be shipped.
The QA~ Program Manager shall be knowledgeable of the NRC and 00T packaging and shipping regulations, and have experience in the planning, preparation, and shipment of radioactive materials. The Reactor Health Physicist (RHP) is designated as the NCSU QA Program Manager (QAPM). The QAPM is authorized to prepare the QAP, prepare changes, additions or modifications as necessary and to submit the QAP and/or changes, etc, to the NCSU Radiation Protection Council for review and approval. The QAPM is authorized to prepare supporting documeny to the QAP, such as procedures, checklists, etc. These supporting documents shall be reviewed by the NED staff, and when coordinat::::, shall be approved by the QAPM.
The QAPM shall supervise the operations perforted under this plan. The QAPM shall report to the Head, Nuclear Engineering Department.
The personnel perfonning the QA/QC functions under this QAP shall not partici-pate in either the actual physical receipt and inspection of the cask, or loading and preparation for shipment.
The Director, NRP, a member of the NED faculty, has overall responsibility for the Nuclear Reactor Program. Qualifications for this position include reactor
' operations and reactor management experience.
In this capacity, the Director will exercise overall supervision of the work perfonned in accordance with this QAP.
The NCSU Radiation Protection Council (RPC) shall review and approve this QAP as well as any subsequent changes or modifications there to and shall appoint an audit committee to review the application of this QAP to shipments of RAM from NCSU.
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. The position of the above mentioned individuals and organization within the University structure is shown in Figure 1.
The QAP and implementing procedures will be reviewed by the QAPM prior to each shipment. Changes to procedures, checklists, etc., consistent with the degree of safety control applicable to the imminent shipment will be made as necessary, reviewed internally, and submitted to the QAPM for approval prior to actual use. The QAPM, during actual container loading operations, will resolve any QA and/or safety questions raised by any member of the loading crew.
The QAPM has the authority to cease operational functions whenever there is justificable cause. Once an operation under this QAP has been interrupted for cause, only the QAPM or his representative may direct continuance of the opera-tion and then only after resolving the cause for the cessation of activities.
The NRP personnel may question any point of the QAP and refer this topic to the QAPM for resolution. The NRP personnel actually performing quality assurance functions whenever they perceive an act or omission they believe to be, or is improper, or unsafe, have the authority to halt the immediate operation and refer the matter to the QAPM for resolution. The NRP personnel, as well as the QAPM, may suggest possible solution (s) to problems. Only the QAPM or his designated representative may approve a procedural change.
2.
Quality Assurance Program This program includes the procurement (of another owner's cask),
handling and use, operational testing prior to use, housekeeping, and return to owner. The NED does not, now, anticipate the undertaking of container design, fabrication, assembly, and proof of design testing.
If in the future it becomes prudent for the NED to undertake any or all of these QA functions now excluded, it will be necessary to amend this QAP accordingly.
As a part of the procurement action, the container owner will be requested to advise the NRP staff on such matters as special tooi s (specific sizes), equipment, spare parts, special instructions and whether or not the owner's checklists would be made available. Further, the cask
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Chancellor NCSU Radiatien g---
Protect. ion Dean of Engineering l
Councf.i I
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Head Protection Nuclear Engineering Dept.
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Other Reactor 8
Director Dept.
Health
--.------- NRP Funct?ons Physics w
OAP Manager NRP Personnel Radiation Safety Protection RAM Shipment SNM Acenuntabili*v Line of Authority
_ _ _ _ _ _ _ _ _ Channel of Cor.
and Advice i
NCSU Quality Assurance Personnel Organization Figure 1.
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. owner would be required to furnish the docunentation required by 10CFR71 relative to the container.
Based upon the information received from the cask owner, implementing pro-cedures, checklists, pre-load testing, loading procedures, pre-shipping checklist, instructions for truck driver, and housekeeping actions will be prepared.These documents will reflect the safety sensitivity of these topics commensurate with the activity and fann of the RAM to be contained in the shipment.
The RPC will be requested to appoint an audit committee to oversee and review the QAP. The records to be made of the shipment will be identified. These records and other documents pertaining to the shipment shall be filed for retention and retrieval as required by ICCFR71.
Shipment of RAM as a regular routine event is not anticipated. Therefore, each shipment will be treated as a "new or not previously accomplished" task by the NRP staff. Hence, the personnel to perform cask receipt, inspection, handling and loading functions will be selected for each shipment, trained to accomplish the specific shipment in accordance with this QAP and its supporting documents.
This training program will include instructions on the purpose of the QAP, its scope, its implementing docunents, a dry run of the loading procedures and a dis-cussion of the graded approach to safety.
3.
Design Control This QA function is not included in the NCSU QAP at this time.
If, in the future, this activity is to be undertaken, an amendment to this QAP will be prepared and approved through the channels described elsewhere.
4.
Procurament Document Control
" Procurement" as used in this QAP means the arranging / rental to use the container owned by another party.
In this sense, the container-owner will be required to furnish evidence of compliance with 10CFR71, Appendix E, that he provide the necessary documents required by Part 71 and/or the Certification of Compliance for the container, and to provide infonnation on tools, equip-ment, checklists, etc., that would facilitate the safe handling and use of 1
. the. cask. The requests snd receipts will be documented.
5.
Instruction. Procedures and Drawings Instructions, procedures and drawings will be prepared and documented for actions affecting quality. These procedures will be in sufficient detail in describing the sequence of events essential to achieving the desired quality objective. These instructions, procedures, etc., will be reviewed prior to the time.of intended usage to insure their applicability. Requisite changes shall be made so that these procedures shall conform to and be consistent with j
the degree of safety control commensurate with the RAM to be shipped.
6.
Document Control i
This QAP and the documents, instructions, procedures, etc., relating there-to shall be controlled to prevent unwarranted changes being made. Changes to the QAP shall be approved by the NCSU Radiation Protection Council. The QAPM is authorized to review and change the instructions, procedures, checklists, etc. implementing the QAP.
The QAPM shall maintain a current master list of applicable documents.
Upon completion of the review of procedures for a specific shipment, the QAPM shall identify the applicable documents to be used; thereby preventing an un-authorized docunent being inadvertently used.
7.
Control of Purchased Material. Equipment and Services This paragraph is not applicable to the QAP.
8.
Identification and Control Materials Parts, and Components This paragraph is not applicable to ths QAP.
9.
Control of Special Processes This paragraph is not applicable to the QAP.
10.
Inspection Inspections as applied to the design, fabrication, assembly, and proof testing is not a part of this QAP.
j Procedures for the conduct of inspections to verify compliance with this QAP and its supporting documents shall be prepared. Personnal conducting
-7 these inspections will-not be the same personnel performing the. quality assurance actions.
- 11. Test Control This paragraph is not-included in this QAp.
- 12. Control of Measuring and Test Eauipment, Meauring and testing under this program shall be limited to that neces-sary to verify the container is ready and safe for use; e.g. the' drain line is open (not plugged), the pressure relief valve is functional, etc. Those items of equipment necessary in the pre-operational testing of a container will be identified and the calibration maintained to the required accuracy, purpose, stability and other conditions affecting the measurement.
.13.
Handling. Sterage, and Shipping Information on special handling, storage and cleaning will be requested of the container owner. Upor: receipt of this information, procedures will be prepared on these topics, on the loading of the cask and on shipping require-ments. Particular attention will be given to advance agreement on the receipt of the RAM, and on advance notification of the' actual shipment. These pro-cedures will include steps of coordination with local and State officials as necessary. These procedures will. identify the shipping papers and special notices, if any, to be placed thereon, and a reference to pertinent NRC and DOT shipping regulations.
14.
Inspection. Test and Operational Status Markings, tags, labels, etc. affixed to the container by its owner to show evidence of satisfactory testing and operational status will not be re-moved or obliterated.
Markings, tags, labels, etc. required by tests accomplished by the NRP staff shall be attached in accordance with NED procedures. The QAPM has the authority to omit tests of components that are not r? quired by the RAM being shipped. For example, shipment of subcritical amount of unused (fresh) fuel assamblies would not require a viable pressure gage, but would require a check on the neutron absorber between elements. Therefore, the pressure gage
=need not be tested, whereas the presence of the neutron absorbers must be
- veri fied.
15.
Non-Conforming Materials. Parts or Components Procedures will be prepared, as necessary, for the identification, docu-mentation, tagging and segregation, and notification of the container owner of the non-conforming materials, parts and/or components.
Whether or not the NRP staff will participate in the review, acceptance, rejection, reworking, repair, and disposal of the non-conforming items will be subject to negotiations with the cask owner.
- 16. Corrective Action The QAPM has the authority to cease operations and/or institute corrective actions whenever he deems the working conditio'ns are adverse or inimical to the achievement of the requisite safety controls applicable to the current shi pment.
Necessary corrective action shall be accomplished prior to the use of any container and/or prior to the continuance of procedure during which a deficiency, deviation, etc., is recognized. The deficiency, eta., and the requisite
. corrective action shall be documented.
- 17. Quality Assurance Records All QA records shall be retained and readily retrievable to provide docu-mentary evidence of compliance with NRC and DOT regulations relative to the shipment of RAM. These records shall include this QAP, implementing procedures, checklists, results of tests, copies of shipping papers, results of inspections and audits with deficiencies noted and corrective actions taken, procurement actions, and non-conformance reports.
- 18. ' Audits It is now contemplated that shipment of RAM from this facility will be very infrequent and spaced in time. Accordingly, the audit function for this situation will be somewhat different from one in which shipments are more routine.
Audits of the NCSU QAP will occur prior to and shortly after the shipment.
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- 5eforehand, the audit will be concerned with the preparation and planning for the shipment to be certair, tha appropriate degree of safety control has been identified and adequately considered; that the necessary documents, procedures, checklists have been properly completed on a timely basis. After
. the shipment, the audit objective will be to make certain the records have been properly completed, assembled and prepared for storage.
Personnel to accomplish these audits will not be selected from the indi.
viduals who performed the safety-related functions.
Written procedures and/or checklists will be prepared to assure a thorough checking and verification of the actions being audited. The results of the audits will be given to the Head, Nuclear Engineering Department, and the Director, NRP, and the QAPM.
Deficiencies will be corrected before proceeding with the loading operation or the storage of records.
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