ML20004E406

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Requests Status of Transportation Activities,As NRC Indicates That Subj Activities May Not Be in Accordance w/10CFR71
ML20004E406
Person / Time
Site: 07100456
Issue date: 03/23/1981
From: Macdonald C
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
NAVY, DEPT. OF
Shared Package
ML20004E400 List:
References
810423, NUDOCS 8106120136
Download: ML20004E406 (1)


Text

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NAVY, DEPARTetNT OF THE USS PROTEUS (AS 19)

FPO SAN FRANCISCO CA 96601 0c.18041.o3 Gentlemen:

In our letter of November 25, 1980, we noted that your transportation activities may not be in accordance with 10 CFR Fart 71.

Please indicate in the appropriate boy. below the status of your transportation activities and return to me within thirty (30) cays from the date of this letter.

Sincerely, Ms Charles E. FacDonald, Chief Transportation Certification Branch Divisior. of Fuel Cycle and Material Safety, NMS5 We do not deliver to a carrier for transport licensed material in excess of 20 Ci per package.

We already have an NRC approved QA program, approval number __,_.

I xxj An application for approval of a QA pregram and registration for

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package oesign(s) have been submitted under separate cover.

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, LTJG, USN' Signed:,

Position: Radicgraphic Safety Officer Date:

21 APRIL 1981 P00R ORGINAL 8166120 0 (,

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PROTEUSINST 9900.4 AS19:02:es 24 APR 1981 USS PROTEUS INSTRUCTION 9900.4 Subj: Quality Assurance Program for the Packaging of Radiographic Material for Transport and Transportation of Radiographic Material under Certain Conditions (10CFR71)

Ref:

(a) U. S. Nuclear Regulatory Commission Materials License 04-18041-01 (b) Code of Federal Regulations Title 10, Part 71 (10CFR71)

(c) Code of Federal Regulations Title 49 Enc 1:

(1) Radioactive Material Packaging Quality Assurance Program 1.

Background. PROTEUS;is authorized by reference (a) to use certain radioactive materials aboard PROTEUS and tended vessels and in areas where PROTEUS is operating.

In the course of exercising this authorization some

.of these materials are shipped to and from civilian suppliers who are like-wise licensed by the NRC to provide these materials. A recent revision to 5

reference (b) regt. ires the development of a program to establish, maintain and execute a quality assurance program satisfying each of the applicable criteria specified in reference (b), Appendix E, " Quality Assurance Criteria for Shipping Packages for Radioactive Material", and satisfying any specific provisions which are applicable to the licensee's activities, including pro-curement packaging.

2.

Action. This instruction provides for procedures necessary for the satisfactory establishment and execution of the quality assurance program for use in packaging, shipment, and transportation of licensed materials j

by PROTEUS.

3.

Scope. This instruction applies to all radioactive materials covered by reference (a). As an end user it is not intended that PROTEUS engage in the manufacture of alteration of shipping packages. Rather, this pro-gram is designed to ensure that the quality of shipping packages received l

is as initially certified by the supplier and is maintained while such packages are in the custody of PROTEUS. This instruction is not to be construed, in any case, as a relaxation of the requirements in reference l

(a) or other directives of higher authority.

4 Intent. The intent of this instruction is to place the burden of com-pliance for shipping, transporting, and receipt of licensed material on the individuals utilizing and respor.sible for those sources. Consequently the Radiological Controls Officer (RCO) and Radiographic Safety Officer (RS0) have received the major portion of document responsibles.

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PROTEUSINST 9900.4 24 APR 1981 they have been tasked with audit requirements to ensure they periodically evaluate the functioning of their organization and it's record keeping pro-cedures. This procedure also allows the RSO to serve as Radiographic Material Packaging Quality Assurance (RMPQA) Officer, but places additional document maintenance and audit responsibilities upon him if this be the case. Addition-ally when the RSO serves as RMPQA Officer; auditor (s) with no direct responsi-bilities to licensed materials must be certified to conduct semiannual and receipt / shipping audits. Their independence from by-products material re-sponsibilities is crucial to the success of the RMPQA Program.

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Distribution:

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