ML20008F091
| ML20008F091 | |
| Person / Time | |
|---|---|
| Site: | 07100406 |
| Issue date: | 12/19/1980 |
| From: | Yeaton D J.G. SYLVESTER ASSOCIATES, INC. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 18141, NUDOCS 8103120242 | |
| Download: ML20008F091 (4) | |
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J. G. SYLVESTER ASSOCIATES, INC.
M..ALLURGIC AL A N D W.LDING CON SULTANTS p
M ATERI ALS T ESTING - M ET A LLU R GIC A L
INDUSTRI AL R ADIOGR AP FIELD I N S P E CTIO N b
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December 19, 1980
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R Mr. Charles E. MacDonald, Chief
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Division of Fuel Cycl e and Materi al Safety, NMSS
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Dear Sir:
In response to your request of 26 November 1980 enclosed p' ease find a copy of our Procedure " Shipping Container Quality Assurance Requirements".
This Procedure is also being submitted to the Division of Licensing for inclusion in our Radiological Protection Procedures Manual.
If you have any questions regarding this matter do not hesitate to contact us.
l Very truly yours, J.
G. SYLVESTER ASSOCIATES, INC.
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Dennis Yeaton DCY:emm y*?:;=
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Dat e 12-18-80 Section XV Pag e 1 of 3 Attachment K - SHIPPING CONTAINER QUALITY ASSURAflCE REQUIREMENTS K.1 Scope A.
This QA program is limited to fulfilling the requirements of 10CFR71 for shipping containers used by The Company to transport sealed radioactive sources.
Design and f abrication of shipping containers shall not be conducted under this Quality Assurance Program.
K.2 Organization A.
The final responsibility for this Quality Assurance Program rests with The Company whose organizational structure is included in our Radiation Safety Manual.
B.
The Radiation Safety Officer is responsible for overall administration of the program, training and certification document control and auditing.
The Assistant Radiation Safety Of ficer is responsible for handling, storing, shipping, inspection, test, operating status and record keeping and is directly accountable to the Radiation Safety Officer on all radiation safety matters.
Responsibilities are further defined in the Radiation Safety Manual.
K.3 Quality Assurance Program A.
This QA program, although limited in scope, is conducted in accordance with The Company's normal QA policies.
Fo r this-program this requires that all procedures necessary for the safe use and control of' shipping containers be written and defined by the Radiation Safety Manual and that -only properly trained, competent personnel shall conduct the-defined operations, inspections or tests.
Al so the RSO shall assure that all shipping containers are designed and manufactures in accordance with 10CFR71 by certification from the manufacturer, a (.
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Dat e 12-18-80 Section XV Page 2 of 3 Attachment K k.4 Document Control A.
All documents pertaining to radiation safety program are controlled by the RSO and are included in our Radiation Safety Manual.
This manual is distributed to all company employees involved in working with radioactive materials.
Di stribution of the manual and revisions are controlled in a positive manner by return of a transmittal form.
K.5 Handling, Storage and Shioping A.
All operations involving the handling, storage and shipping of packages for certain special form radioactive material will be done in accordance with our Radiation Safety Manual.
tio shipments will be made unless all test, certifications, acceptances, and final inspections have been compl eted.
K.6 Inspection, Test and Ooerating Status A.
The RSO shall assure radiographic personnel conduct inspections and tests as follows:
a.
Receipt Inspection:
The following inspections shall be receipt:
1.
Survey 2.
Visual inspection for correct marking and damage.
3.
Manuf acturers doc umentation.
The survey results will be recorded on the shipping papers.
b.
In-process Inspection and Te sts:. The foll owing inspections. and' tests shall be conducted as required.
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Da t e 12-18-80 Section XV Pag e 3 of 3 1
1.
Leak Tests 2.
Vi sual inspection and survey when damage is suspected.
3.
Daily and Quarterly inspections and maintenance.
c.
Final inspection:
The following inspections shall be conducted immediately prior to shipping equipment off site.
1.
Survey 2.
Proper labeling 3.
Proper preparation for shipping, bolts tightened, seals in place, source identification tag attached etc.
4.
Shipping papers are complete and in order (shippers certificate, bill of lading, etc.)
K.7 flo n co n f orma nc es A.
On' discovery of a nonconformance the container will immediately be surveyed.
If the radiation level exceeds 200 mr/hr at the surf ace or 10 mr/hr at 3 feet,.the restricted area shall be established and.the RSO notified.
He shall.
direct resolution of the nonconformance.
Surveillance of the restricted area shall be maintained until the nonconformance
.is resolved.
If the survey meets the above levels, the equi pment shall.be moved to.a locked secure area.
The RSO shall 'be notified of the nonconformance and he shall provide resolution.
K.8 Quality Assurance Records A.
All shipping container records'will be maintained along with, the other required radiation safety documents.
All record are reviewed quarterly as part of the internal audit program K.9. Audits A.
Audit of this Quality Assurance Program will be conducted on a quarterly schedule along with the radiation safety program audits defined in the Radiation Safety Manual.
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