ML20003C457

QA Program for Packaging Radioactive Matl for Transport & Transportation of Radioactive Matl Under Certain Conditions Under License 31-17677-01

ML20003C457
Person / Time
Site:	07100421
Issue date:	01/07/1981
From:	NAVY, DEPT. OF, FORCES AFLOAT
To:
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ML20003C453	List: ML20003C452 ML20003C455 ML20003C457
References
18501, NUDOCS 8103060115
Download: ML20003C457 (21)

Text

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HUNLEYINST 9900.3 AS31:4S:rth QU ALITY ASSURANCE PROGR A11

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FOR THE PACK AGING OF 1

R ADIOACTIVE M ATERIAL FOR TR AN5 PORT AND TR ANSPORTATION OF RADIOACTIVE MATERIAL UNDER CERTAIN CONDITIONS (10CFR71)

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U.S. NUCLEAR REGULATORY COMMISSION M ATERIALS LICENSE NO. 31-17677-01 LICENSEE:

DEPARTMENT OF THE NAVY USS HUNLEY (AS-31)

FPO MIAMI, FL. 34032 810 808 0 \\ Y5

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. HUNLEYINST 9900.3 AS31:43srih I

i RECORD OF REVISIONS l

REVISION DATE OF DATE ENTERED BY NUM BER '

REVISION ENTERED (SIGNATURE) i P

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HUNLEYINST 9900.3 AS31:43:rth TABLE OF CONTENTS PAGE

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Implementing Instruction Title Page i

P Record of Revisions il Table of Contents lii Definitions iv Organization I-l Organizational Chart I-A-1 Appendix A Responsibility Matrix I-B-1 Appendix B Quality Assurance II-l Appendix A II-A- 1 Document Control 111-1 f

Handling, Storage, and Shipping IV-1 Inspection, Test and Operating Status V-1 Quality Assurance Records VI-l Audits VII-I Audit Plan Appendix A VII-A-1 i

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HUNLEYINST 9900.3 AS31:'23:rlh DEFINITIONS The following terms are defined as they are intended to be used in this instruction.

Auditor - An individual assigned to conduct audits of the RMPQA program and its intended results.

CFR -

Code of Federal Regulations Licensed activity; licensee - USS HUNLEY (AS-31)

Licensed materials - Those materials for which USS HUNLEY holds an NRC approved license NRC - U.S. Nuclear Regulatory Commission i

NDT-Non-destructive Test Laboratory NSF - Nuclear Support Facility Package - A shipping container for licensed radioactive materials RCF-Radiac Calibration Facility RCO-Radiological Controls Of ficer l

RMPQA Officer - The quality Assurance Officer for the RMPQA program charged with implementing and ensuring compliince with the provisions of this program l

RMPQA Program - Quality Assura.2e Program for the Packaging of Radioactive Material i

for Transport and Transportation of Radioactive Material Under Certain Conditions I

(ICCFR71) l e RSO - Radiographic Safety Officer i

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AS31:48:rth i

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. SECTION ONE - ORGANIZATION

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- 1.1 Purcose.

This section sets forth the organizational-responsibilities in the 4

R11PQA Program.

l 1.2 Descr iotion.

The R11PQA Program is composed of five levels of responsibility.

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Commanding Officer.

By definition. the senior official of the licensed I

activity, he'is responstble for the establishment and execution of the R11PQA Program.

l Revisions "o the program.may be authorized only by him. The Commanding Officer j

assigns and certifies the R11PQA Officer.

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Repair Officer.

In his role as Head of Department which actually tses f

licensed materials the Repair Officer has a vested interest in the RA1PQA Program. H is j

responsible for ensuring that the RAIPQA Officer has sufficient organizational freedcm to t

f fulfill his function and for ensuring that corrective actionM is/are accomplished in an effective,' timely manner and is/are not being dela.yed by production schedules or other conflicts.

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Radiolocical Controls Officer (RCO).

Responsible for the safe receipt, handling. operation and shipment of licensed materials in/by the Nuclear Support Facility i

- (N SF). All licensed material received by and shipped from HUNLEY will be processed by the NSF. Tne Radiological Controls Officer is responsible for the following attributes of i

the RN1PQA Program:

(1) Ensuring that shipment of licensed materials by the NSF are conducted in

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accordance with references (a), (b), and (c).

i (2) Ensuring that required inspections and testing incidental to receipt and I

shipment of licensed materials are properly conducted and documented.

l (3) Alan aining records of shipments of licensed material to/by the NSF.

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3 (4) Ensuring that corrective action. when required, is accomplished by the j

NSF in an ef fective, and timely manner.

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(5) Ensuring that personnel under his cognizance assigned to handle licensed i

material are trained in the requirements of this intruction and references (a), (b), and (c).

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Radio 2rachic Safety Officer (RSO). In addition to his responsibilities fer ensuring'~ the safe receipt, handling, operation and shipment of licensed materials he is i

responsible for:

4 (1) Ensuring that shipments of licensed materials are conducted in I

accordance with references (a), (b) and (c).

1 (2) Ensuring that required inspectic 1 and testing incidental to shipment of j

j licensed materials are properly conducted and doccmented.

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(3) Verifying records of shipments as required in later sections of this instruction.

(4) Ensuring that corrective action, when required, is accomplished in an effective, timely manner by the SDT personnel.

(5) Ensuring that personnel under his cognizance assigned to handle licensed material are trained ir, the requirements of this instruction and references (a), (b). and (c).

e.

RMPOA Officer.

The RMPQA Officer shall be certified as to his qualification and appointed by the Commanding Officer. The RSO may be assigned as the RMPQA Officer however the auditors must not have any direct responsibility to the area audited.

His primary function in the RMPQA Prograrii is the verification of the credibility of the program. In this regard he is responsible for:

(1) Development of an audit schedule for approval by the Commanding Officer.

(2) Conducting or directly supervising the conduct of periodic audits of the RMPQA Program.

(3) Conducting or directly surrvising the conduct of unannounced spot checks of the RMPQA Program.

(h) Reporting his findings directly to the Commanding Officer with copies to the Repair Officer, Radiological Controls Officer, RSO, and RMPQA Officer.

(5) Conducting follow-up audits to ensure corrective action is accomplished.

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RMPOA Auditor - The RMPQA Audito-shall be certified as to his qualification anc designatec by the Commanding Officer to audit ite RMPQA Program and records as well as the actual receipt / transfer / shipment process.

He shall be knowledgeable in the areas of inspection and completely independent from all as:ects of the licensed material except as required to conduct his audits. In this regard he is responsible for:

(1) Conducting RMPQA audits as directed by the Commanding officer.

(2) Reporting his findings directly to the Cor.. Tanding Officer with copies to the Repair Officer, Radiological Controls Officers, RSO, and RMPQA Officer.

(3) Conducting follow-up audits to ensure corrective action is accomplished when directed by the Commanding Officer.

1.3 Accendices. Appendices (A) and (B) to this section contain an organizational chart and matrix wnica graphically display the division of responsibility of the above functions into four levels of responsibility.

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HUNLEYINST 9900.3 i

AS31:'48:rth t

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SECTION ONE APPENDIX "A" I

t ORGANIZATIONAL CHART t

i RAIPQA Coil.\\ LANDING t

AUDITOR (S)

OFFICER l

l 1 REPAIR

! OFFICER _

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l RADIOLOGICAL RADIOGRAPHIC CONTROLS SAFETY f

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1 R.\\lPQ A OFFICER 1

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8 HUNLEYINST 9900.3 A531:4S:rth SECTION ONE APPENDIX "B" t

RESPONSIBILITY MATRIX i

R ADIOLOGIC AL R ADIOGR APHIC COMMANDING REPAIRCONTROLS SAFETY RMPQ3 RMPQA FUNCTION OFFICER OFFICER OFFICER OFFICER OFFICtR AUDITC PROGRAM A

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TRAINING A

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i C ERTIFI-B E

E CATION TESTING B

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DOCUMENT A C

D D

CHANGES SHIPPING A

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E AUDITS B

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i AUDIT A

A,C D

D SCHEDULE LEGEND A-Approve B-Accept C-Concur D-Initiate E-Perform l

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HUNLEYINST 9900.3 AS31:4S:rth i

SECTION TWO - OUALITY ASSURANCE PROGR All 2.1 Purpose.

This section specifies the necessary action which must be undertaken to successfully establish and execute a viable quality assurance program for packaging licensed material.

2.2 Discussion.USS HUNLEY is licensed to use certain radioactive materials as specified in reference (a). As an end-user HUNLEY receives these materials from NRC licensed suppliers in NRC approved containers. The thrust of the QA Program aboard HUNLEY shall be directed toward establishing proof of and maintaining the quality of provided containers. 51anufacture or repair of shipping containers for licensed materials shall not be cenducted aboard HUNLEY without prior approval by the NRC.

2.3 Procedure.

a.The promulgation and enforcement of this instruction by the appropriate levels of the chain of command establishes and implements the RN1PQA Program.

b. Training and experience for all RAIPQA Program functions shall be in accc rdanc a with t.stablished procedures:

(1) The Commanding Officer, Repair Officer, and Radiological Controls Officer are specifically assigned by the Bureau of Naval Pc'sonnel in accordance with established directives.

(2) The Radiographic Safety Officer shall be assigned by the Commanding Officer in accordance with reference (a).

(3) The RN1PQA Officer sha!! be assigned and certified by the Commanding Officer following completion of Appendix (A) to this section.

(4) The RNIPQA Auditor (s) shall be assigned and certified by the Commanding Officer following completion of Appendix (A) to this section.

(5) Radiographers shall be qualified in accordance with referer.ce (a).

(6) NSF Technicians shall be qualified in accordance with NAVSHIP5 3S9-0153. Art.103.

(7) RCF Technicians shall be quall'ied in accordance with NAVSHIPS 3S9-0153, Art.107 and REPDEPTINST 5100.9.

(S) The RCO and RSO (unless serving as RN1PQA Officer) are exempt from Commanding Officer certification as RN1PQA auditors due to previous experience and training.

c. Revisions to the QA Program may be made only by formal change to this instruction signed by the Ccmmanding Officer. Revisions which would significantly alter the program must be forwarded to the NRC (fer information pruposes only). Each revision 11-1

s HUNLEY!PST 9900.3 AS31:'4S:r!h shall be entered in the manner directed by the revision and es cumented on the Record of Revisions page.

d. Prior to use all defined quality control procedures, engineering procedures, and specific provisions of the package design approval snall be satisfied for any shipping packages used in conjuction with licensed material.

1 (1) Documentation of this shall be maintained onboard HUNLEY fer any contractor-supplied shipping containers for use with licensed materials.

(2) Specific approval by the NRC shall be obta'Ed, documenting the above attributes prior to locally fabricating, repairing, or altering a shipping container for use with licensed materials.

e.While in the custody of HUNLEY, shipping containers for use with licensed i

materials shall be controlled such that those characteristics of the package which are critical to safety are maintained.

(1) Damage to shipping containers shall be reported immediately to competent authority.

(2) Shipping containers for use with licensed radiographic and radiac calibration sources shall be maintained and used in accordance with reference (b). They shall be stored in the Nuclear Support Facility when not in use.

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HUN :.EYINST 9900.3 AS31:4S:rlh SECTION TWO APPENDIX A I

From:

RMPQA Of ficer Designate /RMPQA Aucitor (circle one)

To:

Commanding Officer, USS HUNLEY (AS-31)

Subj:

Training and experience as RMPQA Officer i

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

ICCFR71 w

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HUNLEY RMPQA Program HUNLEY RMPQA Records and Audits By-product License No. 31-17677-01 HUNLEY Instruction 9900.3 I am prepared to assume the responsibilities of the HUNLEY RMPQA Officer / Auditor.

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Commanding Officer /Date i

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HUNLEYINST 9900.3 AS31:f+S:rlh SECTION THREE - DOCUMENT CONTROL e

3.1 Puroese.

This section describes requirements for the control of documents related to snipping packages.

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3.2 Procedure. Each document related to a specific shipping container shall, where necessary, ce processed in accordance with Naval Supply Systems Command directives in the course of rocciving or shipping licensed materials. When not required to be in the custody of the USS HUNLEY Supply Officer, or others, for review, documents shall be maintained in the custody of the Radiographic Safety Officer. It is anticipated that no document changes should be required.

However, if the need arises changes will be accomplished only with the permission of the Commanding Officer and in accordance with appropri. te procedures.

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SECTION FOUR - HANDLING. STOR AGE. RECEIPT. AND SHIPPING 4.1 Purcose. This section describes those aspects of handling, storage and shipping of packages which are important to safety and includes assignment of responsibilities for the critical aspects of handling, storage, and shipping.

4.2 Discussion.

a. Established safety restrictions concerning the handling, storage, receipt and shipping of packages of special form radioactive material will be followed. Shipments will not be made unless all tests. certifications, acceptance, and final inspections have been completed. Work instructions have been provided for handling, storage, and shipping operations for those shipping containers in use. Work instructions will be provided for handling, storage, receipt and shipping operations for those shipping containers contemplated for future use.

b.The responsibilities of certain personnel involved in the RMPQA Progam 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 Radiological Cont >1s Officer is responsible for the critical handling, storage, receipt and shipping operations for each shipment of licensed material. He shall ensure, for each shipping container, that:

(1) Established safety instructions concerning the handling, storage, and shipping of packages of licensed materials are being followed.

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

(3) Work instructions have been provided for handling, stcrage, and shipping operations.

b.The Radiographic Safety Officer is responsible for the critical handling, receipt, storage and shipping operations for each shipment of licensed material. He shall verif y, for each shipping container that:

(1) Established safety restrictions concerning the handling, storage, and shipping packages of licensed material are being followed.

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

(3) Work instructions have been provided for handling, storage, and shipping operations.

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AS31:48:rth SECTION FIVE - INSPECTION, TEST. AND OPER ATING STATUS 3.1 Puroose.

This section describes those aspects of inspection, test, and operating l

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

5.2 Discussion.

a. Inspection, test, and operating status of packages for certain special form radioactive material will be indicated and controlled by established procedures. The status will be indicated by the tag, label, marking, or log entry.

The status of nonconforming parts or packages will be positively maintained by established procedures.

b.The respor.sibilities 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 inspection, test, and operating status which are conside ed critical.

5.3 Procedure.

a.The Radiological Controls Officer is responsible for the critical inspection.

test, and operating activities associated with each shipping container which may be used for shipment of licensed materials by the NSF.

He shall ensure, for each shipping container, that:

(1) Inspection, test and operating status of packages for certain special form radioactive material is indicated and controlled by established procedure.

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

(3) Status of nonconforming parts or packages are positively maintained by established procedures.

b.The Radiographic Safety Officer is responsible for the critical inspection, test and operating activities associated with each shipping container which may be used for shipment of licensed materials. He shall ensure, for each shipping container, that:

(1) Inspection, test and operating status of packages for certain special form radioactive material is indicated and controlled by established procedures.

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

(3) Status of nonconforming parts or packages are positively maintained by established procedures.

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t HUNLEYINST 9900.3 AS31:43:rth SECTION SIX - OU ALITY ASSURANCE RECORDS t

6.1 Purpose.

This section provides the necessary requirements and guidance for satisfactorily documenting the operation of the R.\\1POA Program aboard HUNLEY.

6.2 Discussion. Adequate documentation will be maintained to demonstrate to interested parties that HUNLEY possesses an effective functional R.\\1PQA Program. To this end the following actions shall be taken:

a. Records to be maintained include:

(!) Operating or source logs.

(2) Inspection results.

(3) Test results.

(4) Audit results.

(5) Qualification records of personnel.

(6) A file of R.\\1PQA procedures and equipment.

(7) A file of audit schedules and completed audits.

b. Records will be maintained according to the procedure delineated in paragraph I

6.3.

c. All records will be identifiable and retrievable.

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

Retention of all records shall be for a period of three (3) years.

6.3 Procedure.

a.The R.\\1PQA 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 ensure that all other records pertinent to the RMPQA Program are maintained in an auditable fashion. They shall be identifiable and retrievable. These shall include, but are not limited to:

(1) Opera *ing or source logs records - Maintained by RSO/RCO as applicable.

(2) Inspections and test records - Maintained by RCO.

i (3) Qualification or RMPQA personnel - Maintained by RSO.

l (4) Qualification of NDT/NSF personnel - Maintained by RSO/RCO as i

applicable.

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(5) Descriptions of procedures and equipment - Maintained by RCO.

(6) Records of receipt shipments - Maintained by ISO /RCO as applicable.

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r HUNLEYlNST 9900.3 AS 31:4S:rth SECTION SEVEN - AUDITS 7.1 Purpose.

This section specifies the requirements which must be met to establish an ef fective audit program.

o 7.2 Discussion.

a. Appendix (A) to this section contains the audit plan for use in audits of the R.\\iPQA Pro:; ram. This format specifies the minimum requirements of each audit. The aucitor should audit to de intent rather than the letter of the audit plan. Each area described in the audit plan should reveal questions 'vhich mus: b2 answered to satisfactorily complete the audit,

b. Audits of th<; RAIPQA program will be performed as scheduled. Results of all audits will be reporte ! :o the Commanding Officer, with copies to the Repair Officer, Radiological Controls Officer, Radiographic Safety Officer, and Radioactive staterial Packaging Quality Assurance Officer. Audit reports will be evaluated and deficient areas corrected. The audits being performed will be dependent on the safety significance of the activity being audited. Audit reports shall be maintained as part of the quality control records.

7.3 Procedure,

a. Audits shall be conducted only by certified auditors or the R11PQA Officer.

b. An audit of each receipt or shipment shall be conducted within two weeks of receipt or shipment of licensed material. This audit shall be conducted bj an auditor with no direct responsibilities in receipt / shipment of licensed material.

c. Semi-annually, a complete audit of the R11PQA Program will be conducted.

This audit shall be conducted by an auditor with no direct responsibilities in receipt / shipment of licensed material.

The specific dates shall be approved by the Commanding Of ficer.

d. The RAIPQA Officer (if also the RSO) shall conduct independent audits to ensure compliance with R11PQA Program requirements. These audits shall be detailed in nature and fully documented. The schedule for these audits shall be approved by the Repair Of ficer.

e.The RSO and RCO shall conduct periodic unscheduled audits to ensure compliance with P""

Program requirements. These audits shall be semi-annual as a s

minimum.

f. All signed audit reports shall be forwarded to the Commanding Officer on the completion of each audit. Copies will be provided to the Repair Officer, Radiological Controls Officer, Radiographic Safety Officer, and Radioactive Niaterial Packaging Quality Assurance Officer.

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i-i HUNLEYINST 9900.3 AS31:43: rih g.The Repair Officer will review proposed corrective actions and assign completion dates.

h.The original audit reports and original records of corrective action shall be maintained in an auditable fashion by the R\\lPQA Officer, i

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HUNLEYINST 9900.3 AS31:4S:rth SECTION SEVEN APPENDIX A R.\\1POA AUDIT Audits of the Radioactive Ntaterial Packing Quality Assurance Program must be conducted to meet the requirements of HUFLEY RAIPQA Program and Appendix E to IC C F R71.

The audit must be conducted by a knowledgable officer certified 5y the Commanding Officer to conduct R.\\1PQA audits. Followup action, including reaudit of deficient areas st all be taken.vhen considered necessary.

(1) For each of the established R.\\lPQA procedures, check the following:

RECOX1.\\1 ENDED CORRECTIVE CHECK CO.\\1NIE.\\lTS ACTION INITIALS

a. The procedures (s) utilized are current with the latest NRC requirements.

" The mest current procedure copy (s) is/

are on file with the RSO.

c. All recuired ap-proval signatures are present.

d. The most current procedure in being uti-lized by NDT/NSF per-sonnel.

(2) The cur rent R.\\1PQA Cfficer and RitPQA au-ditors have completed enclosure (1) to HUNLEY-INST 9900.3 and have been certified be the Commanding officer.

(3) All radiographers have completed reference VII-A- 1

HUNLEYINST 9900.3 AS31:as:rth RECOMMENDED CORRECTIVE CHECK COMMENTS ACTION INITIALS (a) requirementsTor quali-fication and have been approved by the recuired officers. NSF and RCF per-sonnel are qualified in ac-l card..ce vith NAV5 HIPS l

3 3 ?-;153 paragr,.pn 107.2.D.

(4) All RMPQ A revisions have been authorized by the Commanding Officer and each revision is documented on the record of revisions page for all copie<, of HUNLEYINST 9900.3 on file with the RMPCA Officer or in use in NDT/NSF.

(5) For eacn racioactive material shipping package to be used onboard verify that:

a. The NRC approval for that package is onboard.

b. The specific provisions made with the package ap-proval are being adhered to.

(6) A complete list of NRC approved packages in en file.

(7) Registration witn the i

NRC for use of a package occured prior to use of the package and a copy of this registration is on file.

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HUNLEYINST 9900.3 AS31:aS:rth

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RECOMMENDED CORRECTIVE CHECK COMMENTS ACTION INITIALS Fall requirements of the RMFQA Program and the by-preduct material license are being satisfied during shioping/ receipt of licens-ed material.

(9) All required insections/

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tests are being conducted and dccumented upon receipt /

prier to shipment of licens-ed material.

(1G1 Three (3) years of snip-ping / receipt records are re-tained.

11. General Comments / Discrepancies:

(Signature)

(Date) eL.o c-,

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