ML20010E294
| ML20010E294 | |
| Person / Time | |
|---|---|
| Site: | 07100440, 07109036, 07109056 |
| Issue date: | 08/17/1981 |
| From: | Andresky E PROFESSIONAL SERVICE INDUSTRIES, INC. (FORMERLY PTL-I |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20010E295 | List: |
| References | |
| 19532, NUDOCS 8109030297 | |
| Download: ML20010E294 (1) | |
Text
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Pittsburgh R g t.g y 9 Testun
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,9 August 17, 198 g co g
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0 25198;s Mr. Charles E. MacDonald, Chief Af,qgpss U. S. Nuclear Regulatory Commission g
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/7 44 Transportation Certification Branch Washington, DC 20555 g
Re:
Packaging Registration
Dear Mr. MacDonald:
In response to your letter dated August 7, 1981, we remain somewhat confused.
Your letter of August 7, 1981, indicates that we have been denied certification due to our (QA) program not being approved.
On June 10, 1981, we received a letter from you stating that our program was approved.
Your June 10, 1981 letter, approval number 0440, and our (QA) program are attached.
Please explain our condition at this time.
Thank you very much for your cooperation.
Very truly yours, IT dURGI TESTING LABORATORY L-*'
N E. L. Andresky
.s Radiological Safety o 'ilinatsar s'
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UNITED STATES g
NUCLEAR REGULATORY COMMISSION
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FCTC:LLG 71-0440 Pittsburgh Testing Lab.
ATTN:
Mr. E. L. Andresky Radiological Safety Coordinator 850 Poplar Street Pittsburgh, PA 15220 Gentlemen:
Enclosed is Quality Assurance Program Approval for radioactive material packages No. 0440, Revision ilo. O.
Please note the conditions included in the approval.
Sincerely, Charles E. MacDonald, Chief Transportation Certification Branch Division of Fuel Cycle and Material Safety, NMSS
Enclosure:
As stated d 5b 4Y'3 f
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N5'c FOH513k1 U.S. NUCLEAR REGULATORY COMMISSION 1.AP AL NUMBER "3-N QUALITY ASSURANCE PROGRAM APPROVAL REvisiom muueER FOR RAE ?OACTIVE MATERIAL PACKAGES 0
Pursuant to the Atomic Energy Act of 1954,as amended,the Energy Reorganization Act of 1974, as amended, and Title 10, Code Uf Federal Regulations, Chapter 1, Part 71, and in reliance on statements and representations heretofore made in item 5 by the person named in item 2,the Quality Assurance Program identified in item 5 is hereby approved. This approval is issued to satisfy the requirements of Section 71.51 of 10 CFR Part 71. This approval is subject to all applicable rules, regulations, and orders of the Nuclear Regulatory Commission row or hereafter ir effect and to any conditions specified below.
3.RAME
- 3. E XPIR ATION D ATE Pittsburgh Testing Lab.
July 31, 1986 EVREET ADDRESS 850 Poplar Street
- 4. oocxET NuusER l STATE CITY ZIP CODE 71-0440 Pittsburah DA 19??n S. QU ALIT Y ASSUR ANCE PROGRAM APPLICATION DAT EtS)
April 8,1981
- 6. CO N DIT IO NS A.
The shipping activities authorized by this approval are procurement, maintenance, repair, and use of packages for licensed material in special form. All other shipping activities (i.e., design, fabrication, assembly, testing, and modification) shall be satisfied by obtaining certifications from package suppliers that these activities were conducted in accordance with an NRC-approved QA program.
It shall remain the responsibility of the licensee-user that all transportation activities meet the requirements of 10 CFR 571.61.
B.
Activities conducted under applicable criteria of Appendix E of 10 CFR Part 71
+o be executed with regard to transportation packages by June 30, 1981.
rd n
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j [k,/ /) FORM U.S. NUCLEAR REGUL ATORY COMMISSION SIGN ATWr
.'MacD51aDhibf, Transportation Certification Branch IDATE Division of Fuel Cycle and Material Safety, NMSS JtJN 101981
o PITTSBURGH TESTING LABORATORY 850 POPL AR STREET, PITTSBU RGH, P A.15220 PROCEDURE: INDUSTRIAL RADIOGRAPHY QA PROGRAN PROCEDURE NO. :
iP-QA '
Is ue Date:
4-8-81 Prepared by:
E. L. Andresky, Radiologica Safety Coordinator cs Reviewed & Accepted by:
4 W.H.
Levelius, Vice President &
Liason Officer REVISION HISTORY AND APPR3 VAL T-REV.
DATE DESCRI PT ION PTL QA MGR PTL MGMT.
APPROVAL ACCEPTA)CE c
0 4-6-81 Origir.al Issur N8 m
l l
l STATUS:
ISSUED FOR REVIEW AND COMMEh'T x ISSUED FOR USE X
UNCONTROLLED CONTROLLED CONTROLLED COPY NO.
(
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)
QUALITY CONTROL PROCEDURE REV.
NO.
O I
I TITLE _ INDUSTRIAL RADIOGRA&D3A PRCGRAM (10 CFR PART 71 OA PROGRAM)
REV DOCUMENT NO.
IR-RA-l_
DATE.S-8-61 1.
Organization The final responsibility for the Quality Assurance (QA) Progran for Part 71 Requirements rests with Pittsburgh Testing Laboratory.
De sign and Fabrication shall not be conducted under this QA Program. The QA Progran is implemented using the organizational chart shown in Appendix A.
The Liaison Officer is responsible for overall administration of the program, training and certification, document control, and auditing.
The Radiographers are responsible for handling, storing, shipping, inspection, test and operating status and recordkeeping.
2.
Quality Assurance Progran The management of Pittsburgh Testing Laboratory establishes and inplements this QA Program.
Training, prior to engagement, for all QA functions is required according to written procedures.
QA Program revisions will be made according to written procedures with management approval.
The QA Program will ensure that all defined RC procedures, engineering procedures, and specific provisions of the package design approval are satisfied.
The QA program will emphasize control of the characteristics of the package which are critical to safety.
The Radiological Safety Coordinator shall assure that all radioactive material shipping packages are designed and manufactured under a QA Program approved by the Nuclear Regulatory Commission for all packages designed or fabricated after January 1, 1979.
This requirement will be satisfied by receiving a certification to this effect from the manufacturer.
3.
Document Control All documents related to a specific shipping package will be controlled through the use of written procedures. All document changes will be performed according to written procedures approved by management.
The Radiological Safety Coordinator shall insure that all QA functions are conducted in accordance with the latest applicable changes to these documents.
1 PITTSBURGH TESTING LABOR # STORY p,og 1 og 3 l
QUALITY CONTROL PROCEDURE REv NO O '
I I
TITLE INDUSTRIAL RADIOGRAPHLQA PROGRA*4 (10 CFR PART 71 OA PROGRA'4)
REV DOCUMENT NO.
IR-OA '
DATE 4-C-EI 4.
Handlino, Storage, and Shinninc Written safety procedures concerning the handling, storage, and shipping of packages for certain special forn radioactive naterial will be followed.
Shipments will not be nade unless all tests, certifications, acceptances, and final inspections have been conpleted.
Work instructions will be provided for handling, storage, and shipping operations.
Radiograph 3 personnel shall perforn the critical handling, storatt, and shipping operations.
4 5.
Insnection, Test, and Operating Status Inspection, test, and operating status of packages for certain special forn radioactive naterial will be indicated and controllcd by written procedurcs.
Status will be indicated by tag, label, narking, or log entry.
Status of nonconforning parts of packages will be positivcly naintained by written procedures.
Raciography personnt _ shall perforn the regulatory reluired inspections and tests in accordance with written procedures.
The Radiological Safety Coordinator shall ensure that these functions arc perforned.
6.
Quality Assurancc Fecords Records of packaoe approvals, procurenent, inspections, tests, operatin; logs, audit results, personnel training and qualifications and records of shipnents will be maintained.
Descriptions of equipment and written procedures will also be naintained.
These records will be maintained in accordance with written procedurcs.
The records will be identified and retrievabic.
A list of these records, with their storage locations, v.ill be maintained t the Radiological Safety Coordinator.
7.
Audits Established schedules of audits of the QA Progran will be perforned using wri tten check lists.
Results of audits will be maintained and reported to managenent.
Audit reports will be evaluated and deficie:,t areas corrected.
The audits will be dependent on the safety significance of the activity being audited, but each activity will be audited at least once per year.
Audit reports will be maintained as part of the quality assurance records.
Members I
of the audit team shall have no responsibility in the activity being audited.
PITTSBURGH TESTING LABORATORY 2
3 1
QUALITY CONTROL PROCEDURE REV.
NO __O I
l TITLE MDUSTRIAL_RARICGRAPHLOA_PROGP@l l
(10 CFR PART 71 OA PRCGRAN)
REV DOCUMENT NO.
TR-CA-1_
DATE
- 1-El 8.
Reference Documents Appendix E - Certificate of Compliance (Ganna Industries, Inc.)
Appendix C - NRC Certificate of Compliance Certificate No. 6717 4
Appendix D - IAEA Certificate of Competent Authority Certificate No. 6717-E Appendix E - IAEA Certificate of Competent Authority Certificatt No. USA /OlGo/S Appendix F - Type A Package Certificate Letter - Troxler Electronic Laboratory Dated 3-11-77 J
Appendix G. - NRC Certificate of Cor.pliance Certifictte No. 9050 Appendix H - NRC Certificate of Conpliance Certificate No. 903L I
i e
i PITTSBURGH TESTING LABORATORY y,og 3 og 3 a-..
i OPGANIZATIONAL CH/tRT r
3 Ll.
H. Levtlius Vice Presidcri c
Liason Officer
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E. L. Andre sk:
Radiological Safety l
Coordinator 3
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Radiation Safc t;. Officer Radiation Safety Supervisor District Office District Office N
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Radiographer
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1 Assistant Radiographer 2
L 3
r Trainees I
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GAMMA INDUSTR I
ES A Dwision of Nuclear Systems, Inc.
BA10N ROUGE HOU$f0N P. O BOX 2543 P. O BOX 34526 2255 TED DUNMAv AVENUE HOU5 TON. TEX A5 77034 BATON ROUGE LOUISI AN A 70821 TELEPHONE 713/944 7676 TELEPHONt ',04/342-7791 CERTIFICATE OF COMPLIANCE Ymtermrmtm m.m.mrm.wrmrmr t 1
r_
,t a
TO:
Mr. Joe Nalapa ji Pittsburgh Testing Lab
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_P_
O. Ecx 16!6 f
Pittsburgh, PA 15230
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REFERENCE:
Ga ra Industries Y
Modelc:
Ga=a 35, Ga=a Century, Gara Pipeliner Model 1, Ga=a C g*
Above devices meet the DOT Specification 7A This is to certify that the referenced device has been tested and complies with all requirements of DOT regulations pertaining to this device when used in accordance with DOT regulations. Documentation t
of all tests are on file at Gamma Industries, Baton Rouge, Louisiana.
g I
(i J W$d,'LL k
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\\ Don Riddle
?
!i Quality Assurance Manager I
l Apper. dix P s
......n e
Form NRC418 U S. NUCLE AR REGUL AToRY COMYlSSION
" 2 73' CERTIFICATE OF COMPLlANCE gn g,3 73 For Radeosctive Materials Packages 1.(3) Certificate Nwmeer 1.(b) Revision No.
1.t c) Package identification No.
1.(d) Pages No. 1.(a) Total No. Pages 6717 4
USA /6717/B 1
2
- 2. PRE AMBLE 2.(a)
This certificate is issued to satisf y Sections 173.393a.173.394.173.39s. and 173 396 of the oemanment of Transportation Mazardows Materals Regulations (49 CFR 170189 and 14 CFR 103) and Sections 146-19.10a and 146-19-100 of the oepartment of Transponstion oangerous Cargoes Regulations (46 CF R 146-1491. as amended.
2.tbl The paesaging and contents described in item 5 below, tweti the safety standartis set forth in Subpart C of Title 10. coce of Federaf Repai ons. Part 71. " Packaging of Radioactive Materiais for Transport and Transoonation of Radioactive Mater a' unde-Certain Conditions. '
2.f cl This cenificate does not refieve the consignor from compliance with any recwirement wf the regulations of tne U.S oera tmeat of Transocetation or otner spoticable regulatory agencies, including ine government of any country inrouga or inte annen tne pacn e;e will be transponed.
- 3. This certificate is isswed on the basis of a safety analysis report of the package design or apphcation-3.lal Prepared by (Name and address) 3.tbl Title and identification of report or applicateon.
Gamma Industries Nuclear Packaging, Inc. application dated P.O. Box 2543 June 20, 1975, as supplemented Baton Rouge, LA 70821 3.rci coemet No. 73_ p;7 3 7 4 Cr NoiTIO NS ines certificate is conditenal woon the fw! filling of tne reewirements of Swbcart o of 10 CF R 71. as acobcable, and tne concit.ons soecifie:
in ste' 15 deloa.
- 5. oescreotion or Facias.ng and Awtncraes Contents. Moce. Numoe. Fissile C;ats. otner Conditions, and Ref erences (a) Packaging (1) Model No..
6717-B (2) Description Radiographic device within a protective overpack.
The overpack consists of an outer container which is a 10 gallon open head steel drum having a minimum 20 gauge body and cover, welded seams and a clamp-ring type head closure.
The. void space between the inner and outer container is filled with 1-1/2" thick molded asbestos free liner on sides, top and bottom, plus molded polyurethane filler to position and secure the radiographic device within the drum.
Maximum gross weight of the package not to exceed 75 pounds.
(3) Drawing The packaging is constructed in a,ccordance with Nuclear Packaging Inc.
l Drawing No. SK-D-1, Rev. 2.
Appendix C l
9 Page 2 - Certificate No. 6717 - Revision No. 4 - Docket No. 71-6717 5.
(b)
Contents (1) Type and form of material Iridium-192 as sealed sources which meet the requirements of special form as defined in 10 CFR 571.4(o).
(2) Maxicaum quantity of material per package 200 c.uries.
6.
The contents must be secured in a single snug-fitting innet radiographic device which has a metal outer wall and meets the requirements of 49 CFR 6178.350 (DOT Specification 7A).
7.
The source shall be secured in the shielded position of the radiographic device by the shipping plug, source assembly, and locking device.
The shipping plu"E and sotrce assembly used must be fabricated of materials capable of resisting a 1475 F fire environment for one-half hour and maintaining their positioning function.
The ball stop of the source assembly must enf'ge the locking device.
The flexible cable of the source assembly and shipping plug must be of sufficient length and diameter to -
provide positive positioning of the source in the shielded puition.
'3.
The packaging a'.thorized by this certificate is hereby approved for use under the general license provisions of 10 CFR 571.12(b).
9.
Expiration date:
July 31, 1985.
REFERENCES Nuclear Packaging, Inc. application dated June 20, 1975.
Supplements dated:
August 8, 1975; and FebrLary 26, 1980.
FOR THE U.5. NUCLEAR REGULATORY COMMISSION fw Charles E. MacDonald, Chief Transporation Certification Branch Division of Fuel Cycle and Material Safety M
4 Date:
9 Appendix C
DEPARTM ENT OF TRANSPORTATION RESEARCH AND SPECI AL PROGR AMS ADYlNISTR ATION W Asas sNGTON DC 20$90 IAEA CERTIFICATE OF COMPETENT AUTHORITY Type E Radioactive Material Packace Desdrn Certificate Number USA /6717/E (Revision 3)
This establishes that the packaging design described herein, when loaded with the authorized radioactive contents, has been certified by the National Competent Authority of the United States, as meeting the regula-tory requirements for Type B packaging for radicactive caterials as pre-scribed in IAEA 1/ Regulations and $$ 49 CFR 173.393a and 173.394(b)(3) of the USA 2/ Regulations for the transport of radioactive materials.
I.
Package Identification - Model No. 6717-5.
II. Packaginc Description - Packaging authorized by this certificate consists of an outer 10-gallon steel drum with an inner container which is a metal-walled container meeting the requirements of DOT Specificatien 7A, st rrounded by polyurethane filler and a 1-1/2" asbestos line r. Cross weight is approximately 75 pounds.
III. Authorized Radioactive Contents - The authorized contents consist of radioactive materials, n.o.s. as not mere than 200 curies of iridium-192 as sealed sources which must meet the rcquirements fer special form as set forth in 49 CFR 173.359(g).
IV. General Conditions -
- a. Each user of this certificate must have in his possession a copy of this certificate.
l 1
l
- b. Each user of this certificate, other than Gamma Industries, Baton Rouge, Louisiana, shall register his identity in writing to the Office of Hazardous Materials Regulation, U.S. Department of Transportation, Washington, D.C.
20590.
- c. This certificate does rot relieve any consignor or carrier fron l
compliance with any rr.quirement of the Government of any country through or into which the package is to be transported.
V.
Marking and Labeling - The package must bear the marking USA /6717/B as well as the other marking and labels prescribed by the USA Regulations.
l l
l Appendix D
~
Oertificate Nu=ber USA /67*7/B (Rev. 3)
Page 2 VI.
Expiration Date - This certificate, unless renewed, expires on July 31, 1985.
This certificate is issued in accordance with the requirements of the IAEA and USA Regulations and in response to the March 10, 1975, petition by Nuclear Systems, Inc., Baton Rouge, Louisiana, and revised in response to.
the August 12, 1950, petition by Gac=a Industries, Baton Rouge, Louisiana and in consideration of the associated infor=ation provided in U.S. Nuclear Regulatory Co==ission Certificate No. 6717 (Appendix A).
Certified by:
alud7M D
\\
Richard R.
Rawl
~
(Date)~
Chief, Radioactive Materials Branch Office of Hazardous Materials Regulation Materials Transportation Bureau 1f " Safety Series No. 6, Regulations for the Safe Transpert of Radioactivi Materials," 1967 Edition published by the International Ato:ic Energy Agency (IAEA), Vienna, Austria.
r 2/ Title 49, Code of Federal Regulations, Parts 100-19 9, USA.
Revision 1 issued to incorporate USNRC Certificate No. 6717, Revision 1.
Revision 2 issued to in orporate USNRC Certificate No. 6717, Revision 2 and to extend expiration date.
Revision 3 issued to incorporate USNRC Certificate No. 6717, Revision 3 and to extend expiration date.
l Appendix D
/
(.
>./
.cf Certificate Number USA /0166/S, Revision 1 Page 2 II.
Radioactive Contents (continued)
Model No. (cont'd)
Contents (cont'd)
NB, NBG and NB(HP) 25 curies Americium-241 30 mil 11 curies Ra-226 5C3 mil 11 curies Americium-241 and Cesium-137 mixture Single Encapsulation Universal Source 500 curies Iridium-192 20 curies Cobalt-60 e
Double Encapsulation Universal Source 5000 curies Iridium-192 2000 curies Cobalt-60 Single Encapsulation Side k' eld 500 curies Iridium-192 20 curies Cobalt-60 III.. This certificate, unless renewed, expires September 30, 1982.
This cer tifica e is issued in accordance with paragraph 803 of the IAEA Regulations anc. in response to the September 24, 1979, petition by Camma.lndustries, Baton Rouge.. Louisiana,.cnd in consideration.of the associated information tharein.
' Certified by:
e s
,f
' 'l l
, (
hND l
f (Date)
R. R. Raul Corpetent Authority for the pesignated U.S.
International Transportation of Radioactive Materials I
J Of fice.of Hazardous. Materials Regulation-r Materials ~ Transportation Bureau.
U.S. ' Department-of Transportation.
2"Saf ety Series No. 6. Regulations for the Safe Transport of Radioactive 1973 Revised Edition", published by the International Atomic Materials, Energy Agency (IAEA), Vienna, Austria.
)
~
Title 49, Code of Federal Regulations, Part 170-178, USA.
p 2
Revision O issued in response to the September 7, 1979, petition by Cac=a Industries Baton Rouge, Louisiana.
Revision 1 issued to add Cesium-137 to Models VD and VD(EP).
Appendix E i
l 1
DEP ARTMENT OF TR ANSPORTATION
[
S RESEARCH AND SPECI AL PROGR AMS ADMINIST R ATION W AS HIN GTON. D.C.
2o59o
~
1,
,e I AEA CERTIFICATE OF COMPETENT AUTHORITY REram TOs Special Fore Radioactive Material Encapsulation 4
Certificate Nu ber USA /0166/S (Revision 1)
This certifies that' the encapsulated sources, as described, when loaded with the authorized radioactive contents, have been demonstrated to ceet the regulatory reqyirements f or special fore radioactive caterial as 2
prescribed in I AEA and USA Regulations for the transport of radioactive caterials.
Source Description - The sources described by this certificate are 1.identified as the following Cac:a Industries codels which are constructed acccrding to the listed drawing nu=bers:
Drawing No.
Model No.
602-7001-004 VD and VD(HP) 602-7001-005 NE,
."5.0 and NB (HP) 602-7001-006 Single Encapsulation Universal Source 602-7001-007 Double Encapsulation Universal Source 602-7001-008 Single Encapsulation Side k' eld All models are welded encapsulations constructed of 300 series stainless 8
steel.
Cont ents - The authorized radioactive contents of these II.
Eadicactive sources cor.sist of not more than:
Contents Model No.
300 curies of:
VD and V.n(HP)
Barium-131
. Manganese-54 Cadmium-109 ' 1 Phosphorus-32 Calcium-45
.' Rubidium-86 i
Calcium-47
. Selenium-75 Cesiu=-137 Strontium-85 Chlorine-36
~Thalliu=-204 Chromium-51 Thulium-170 Iridium-192 Tin-113 Cobalt-60 Ytterbium-169 Iron-59 zinc-65 e
9 1
e TYPE A PACKAGE CERTIFICATION Troxler Electrcnic Lateratories, Inc. certifies that their models 1255, 1257, 1351, 1352, 22 A, 2376, 2401, 2402, 2451, 2452, 3401, and 3411 contain Type A quantities of specia: form radioactive materiais and are packed for shipment in Specification 7A Type A (general packaging) containers (L'S Title 49 CFR 178.350;.
These containe: 3 tr.e e t the requirements of CFR 173.24 ar.d are designed and constructed te mect the standards as specified in CFR 173.389(j) and 173.395(b).
The:: are rark; d '.5; DOT 7A TYPE A, RADIOACTIVE MATERIALS in conformance with CFE :73.J.
These regulationz are in cenformance with the requirecents (Marginal C-6) of the Internationa] Atomic Energy Agency's " Regulations for the Safe Transport of Radioactive Materials", Safer. Series No. 6, 1973, revision edition. These regula:icnc dr nct require cenpeten authcrity for international shipment as covered in Settier VIII, paragraph 801.
For re-s'iprtrt, the shipper must reintain a copy of this Certification on file r
fc: a peried of ene year in accorda ce with CFR 173.394 (a) (1).
Note that 173.393 3) requires that "Each package must incorrerate a feature such as a seal, whi:' is m: readily breakable and which, while intact, will be evidence tha: t r..c p a c e c g.: has not been illicitly opened.
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? A/ 0!
- 1
- v R. L. Ber.
I. a. o President Research and Leselepren:
Mar ci 1:, 1977 1
RLL t w 1
Appendix F e