ML20046D360
| ML20046D360 | |
| Person / Time | |
|---|---|
| Site: | 07100503 |
| Issue date: | 08/13/1993 |
| From: | Hixon E PENN INSPECTION CO. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9308180241 | |
| Download: ML20046D360 (11) | |
Text
{{#Wiki_filter:t 2 PENN INSPECTION COMPANY P.O. BOX 520 CHICKASHA, OK 73023 G-OS$b August 13, 1993 U.S. Nuclear Reg. Commission Transportation Branch Div. of Safeguards and Trans., NMSS Washington, D.C. 20555 Attn: Charles E. MacDonald, Chief
Dear Sir:
Please find enclosed the following information for approval to renew our Quality Assurance Program for Radioactive Material. It expires October 31, 1993. If any questions, please contact me. Sincerely, 6 Exl 7 Norsl Earl Hixon Radiation Safety Officer EH/1k Jg@ Y it)f@ 1791CG ,y i i fd$ f~ A309180241 930813 PDR ADOCK 07100503 I C-PDR {ja 7 /
.. ~. - - 1 L ORGANIZATIONAL Cil ART ij QA'"/ QC PROGRAM i I l R.S.D. s Equip. Procuronent p harchasirg J %/ /\\ tg 1 /\\ .T R.S.O. v d: Quality Assurance 1 . Maintenaire j Equip & Repair N/ /\\ .s k, 4 g Radicerapher Radig:racher Radig rapher j Equirnent Inspectiot Equip wnt Inspection Equignent Inspection 3ej M A k -a ix' a [j
4 ,,, w ;a.ad.w.. r . w.,x.s uw un...i . w.:p ) @ u. u.s ' .f. r ua _. l l1 QUALITY ASSURANCE PROGRAM FOR SHIPPING CONTAINERS ' l 1.0 ORGANIZATION 1.1 Radiation Safety Director - It shall be the responsibility of the Radiation Safety Director to ensure that the Q/A i program for shipping containers is effectively executed. Any changes in the program, or additional procedure i implementation due to regulatory requirements, shall be the responsibility of the Radiation Safety Director. 1.2 Radiation Safety Officer - It shall be the responsibility of the Radiation Safety Officer to ensure the inspection of shipping containers is performed and that deficiencies are corrected. He shall be personally responsible for inspecting shipping. containers on a quarterly basis and shall make a record of such inspections. He shall notify the Radiation Safety Director of deficiencies that require the acquisition of additional equipment or labels and shall see that these deficiencies are corrected. 1.3 Radiographer - It shall be the responsibility of the rad-iographer to inspect shipping containers on a daily basis. Any deficiencies shall be reported to the Radiation Safety Officer to be corrected. Radiographers shall be' appointed by the Radiation Safety Officer and shall be trained in the method of inspection for shipping containers. 2.0 QUALITY ASSURANCE PROGRAM l 2.1 Operating Procedures - The follcwing procedures shall be adhered to when operating or using transport containers. 2.1.1 Only authorized personnel shall be allowed to use the transport containers. i 2.1.2 Inspection of the devices shall be performed in accordance with 2.2 below. 2.1.3 The nut and bolt running through the bolt ring shall be secured to ensure the top is secure. 2.1.4 The container shall then be secured on the vehicle by running a piece of chain through the handle and attaching it to an intergral part of the vehicle. i This chain shall then be locked with a pad-lock. 2.2 Inspection Procedures - The following procedures shall be adhered to when inspecting transport containers. I 2.2.1 Only authorized personnel shall be allowed te I inspect transport containers. f
1 1 i, ".;4:..a h*w J h t % '- .h. *1 44, ' %&LJ.J AM * * '. j. .e.!a.' %J .J ( h bta ' * %J .j -.1 s* e,8 l t i 2.2.2 The overall condition of the transport container ) shall be inspected to ensure that it is not visibly damaged. ] ) 2.2.3 All components shall be inspected for proper and secure fit. 2.2.4 Locks shall be inspected to ensure that they J operate properly and hold securely. + 2.2.5 Bolt ririgs and nut and bolt locks shall be checked to ensure that they work properly. 2.2.6 Inner packing (overpack) shall be checked to ensure it is in place and not damaged. 2.2.7 Labels shall be inspected to ensure that they are not worn off and that they are legible. l 2.2.8 Handles shall be inspected to ensure that they are attached securely and are not in need of repair. I 2.2.9 Container's shall be check'ed to ensure that source plugs and dust covers are in good condition and are in place on the device before it is used. 2.2.10 Radiation levels shall be checked when a new source is placed into the container, as well as on a daily basis by the radiographer. 2.3 Maintenance and Repair Procedures - The following procedures shall be adhered to in order to ensure proper maintenance and repair of t ransport containers. 2.3.1 Maintenance and repair shall only be performed by personnel authorized to do so. 2.3.2 Maintenance, and any necessary repair, shall be performed on at least a quarterly basis. i 2.3.3 Any severe package damage (ie., punctures, holes l in the package, etc.) shall be repaired. If the damage is severe enough that repair is not possible { the package shall not be used. 9 2.3.4 If a problem is found with a lock, it shall be corrected, er the lock shall be replaced before the device is used. 2.3.5 Bolt rings, nuts and bolts shall be oiled. Any thread damage shall be repaired, or the part shall be replaced. )
1 unua.ww w.\\ au M &m A ( m -- A a ria. u:u e,, -_ I 1l .1 2.3.6 Inner packing shall be inspected and, if necessary replaced. I 2.3.7 If labels are not legible, they shall be replaced. r 2.3.8 Handles that are not securely attached shall be repaired before the device is used. 2.3.9 If source plugs or dust covers are missing, or if they are in bad condition, they shall be replaced before the device is used. 2.7.10 If radiation levels exceed permissible levels the device shall have additional shielding added, or be re-positioned on the vehicle in order to bring levels into acceptable limits. 2.4 Packaging, Loading and Unloading of Transport Containers - [ The following procedures shall be followed when packaging a container and when loading and unloading containers. 2.4.1 Packaging, loading and unloading of trar. sport containers shall only be performed by personnel authorized to do so. 2.4.2 Containers shall be checked to ensure proper inner packing. 2.4.3 The exposure device shall be loaded into the con-tainer in the proper position, as indicated by the molded inner packing. v 2.4.4 Packing shall be placed on top of the device and the lid shall be fastened using the bolt ring and nut and bolt. 2.4.5 After ensuring that all labels are present and legible, the device shall be loaded into the vehicle. 2.4.6 The device shall be secured to the vehicle by. running a piece of chain through the handle and attaching it to an integral part of the vehicle and locking it with a pad lock. 2.5 Handling Procedures - Specific handling procedures are outlined in 2.1 (Operating Procedures) and 2.4 (Packaging, Loading and Unloading of Transport Containers) above. 3.0 PROCUREMENT AND CONTROL OF DOCUMENTS 3.1 Suppliers shall be required to submit appropriate verification that shipping containers were manuf actured under control of and NRC-Approved Q/A program, i I - - ~,
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A rw w_u. u wwn.u au -. = 1 ._y-a m.<..< l-3.2 Renewals of suppliers documents shall be obtained upon their expiration. 3.3 Q/A documents shall only be issued to personnel involved' in the company's Q/A program. 3.4 It shall be the responsibility of the Radiation Safety Officer to ensure that the above items are adhered to. 4.0 IDENTIFICATION AND CONTROL OF MATERIALS. PARTS AND COMPDNENTS - i I All parts and components used to repair shipping containers shall be ordered from the manufacturer of the container. No part shall be used_that has been changed or altered in any manner. 5.0 HANDLING, STORAGE AND SHIPPING All shipping containers, which contain radioactive materials, shall be kept in a locked storag'e container at all times when not being used. Keys to the locks on storage containers and shipping containers shall be controlled by the Radiation Safety Officer. The only individuals who will have keys issued are the ones who have had, as a minimum, training that is required for radiographers as outlined in the regulations. 6.0 CORRECTIVE ACTION The corrective action for items found to be in non-compliance are those outlined in 2.3 of this document. It shall be the respons-ibility of the Radiation Safety Officer to ensure that these corrective actions are taken for all items of non-compliance. 7.0 AUDITS 7.1 Quarterly audits of all shipping containers and their i components shall be performed by the Radiation Safety Officer to ensure the containers are in compliance with the regulations. The checklist attached to the end of this document shall be followed. 7.2 Annual audits of the Q/A program shall be performed by the Radiation Safety Director to determine the overall effectiveness and compliance with management policies and procedures. These audits may also include evaluations by outside consulting firms employed by the company. 8.0 Q/A RECORDS 8.1 Q/A records which shall be maintained shall include the following: records of quarterly audits and inspection of equipment, procurement documents, nonconformances,
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u%y.s u, ,,..u, m.m { l' ~ t 1 personnel training and certification records, evidence of operational capability and verification of repair, replacement and maintenance. 8.2 Q/A records shall be maintained for a period of two (2) years from the date on the record, for inspection by the Nuclear Regulatory Commission. 9 m h e m b d 8 4 4 I j .)
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'~ I l INSPECTION FORM FOR SHIPPINC CONTAINERS ' j - 1 Container #: l l Action Item to be Checked Satisfactory-Unsatisfactory Taken I Ceneral Condition of Container Condition of Labels 9 Condition of Locks Condition of Source Plugs ! and Dust Covers Condition of Handles Radiation Levels Date of Inspection: By: ,h 4
....,. 2. ].Ap.2.. uwu _.( %,wj., w v.. sw.- r - ... %-e i. _wma. t. .. um., i I i 4 J l l [ Q/A EXAMINATION t FOR TF> DISPORT CONTAINERS 4 i l 9 o NAME s SOCIAL SECURITY // COMPANY i ADDFISS DATE V t h The enclosed examination consists of 10 questions that are worth 10 points each; for a total of 100 points. A grade of 70% of better is required in order to pass.
u < -{ au -- a s 4 e( a 5 5 ^ - m' ' pgg-fg 2 ' ~~f w 7..:i n.: p t m.m. _ _. u - u-, < n. r n -- ou 1. Explain the radiographer's duties in relation to the inspection of transport containers. P 2. What items must he checked when inspecting transport containers under the Quality Assurance program for this company? /) 3. If a particular item was found to be in unsatisfactory condition during the inspection, of transport containers, what must be done? 1 4. How frequently must the Padiation Safety Officer inspect transport containers. 5. How frequently must the radiographer inspect the transport containers?
m.w*lan uk at O ' ' ' x> - Lf 'g gg g sw;4 um - . w s....a-.t u m s 6. What recourse does a radiographer have if he reports non-compliance of transport containers to the Radiation Safety Officer and no action is taken to correct the problems? 7. Who is authorized to use transport containers for this company? J B. Whose responsibility is it to see that maintenance and repairs to transport containers is performed? 1 ~ 9. How are transport containers to be secured on vehicles? 10. What job positions are involved in the Quality Assurance program for transport containers? I
U. S. NUCLEAR REGULATORY COhMISSION 1 APPROYAL NUMIER NIC F07.M 311 e l ntn, g* 4n.u,w ..,, _. QUAUTX ASSUBAP(CE_PRQG?AM APP {0gYAL=C t visroNwue:ER } l! ' FOR RADIOACTIVE MATERIA L PACKAGE I d Pursuant to the Atomic Energy Act of 1954. as arnended.the Energy Reorganizatson Act of 1974. as amended.and Tit e 10, Code of Federat f Regulations. Chapter 1. Pert 71, and in rebance on statements a nd representations heretof ore made in item 5 by the person named in item (I
- 2. the Quahty Assurance Program identified an ftem 5 is hereby approved. This approval es issued to satisfy the requirements of Section j
I 71.101 of 10 CFR Part 71. This approval is subject to att a;,phcable rules. regulations, and orders of the Nuclear Regulatory Comm#ssion l f now or hereafter in effect and to any conditions specified below. l 4 lt N 3 EXPIRATION DATE, k ? NAME l Penn Inspection Company g sTncET Acon (ss October 31, 1993 l l l Route 3 a ooexEi uvueER y-STA1E ZIP CODE l 6 CIT Y ( 'Chickasha OK 73018 71-0503 ( E k
- 5. QUAUM ASSURANCE PROGRAM APP 8.lC ATION DAl[($)
l October 4, 1988 E {
- 6. co~ nmo ~s l
i Activities authorized by this approval: procurement, maintenance, repair, !E q E g and use to be executed with regard to transportation packages in special ( form. All other activities (i.e., design, fabrication, assembly, testing, l ( and modification) shall be satisfied by obtaining certifications from l package suppliers that these activities were conducted in accordance with j an l'P.C-approved QA program. It shall remain the responsibility of the licensee-user that all transportation activities meet the requirements of i 10 CFR 571.101. I ( g-i i ii I E 1 i c l I d l i l I l k i d ( ( 1 di (l i I i y- .l l ( e i 4 I 4 I (! il l .A / FOR THE U.S. NUCLEAR REGULATORY COMMISSION f< Charles E. M w a s >l m4 MacDor.ald 00T r 419e9 l, f CHIEF. TRANSPORTATION BRANCH DATE I N DIVISION OF SAFEGUARDS AND TRAf.SPoRTATION ( OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS N YU MMXTXtJO*'h g0fdMOpXsW h &iOrXfMr askIn wu ' I V/UO(4 ..}}