ML20155F230

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Requests Review of Encl 10CFR71 QA Program Re Shipping & Receiving of Radiographic Exposure Devices.Fee Paid
ML20155F230
Person / Time
Site: 07100662
Issue date: 09/08/1988
From: Barnett R
BARNETT INDUSTRIAL X-RAY
To:
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
24769, NUDOCS 8810130189
Download: ML20155F230 (11)


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Director Office of Nuclear Safety and Safeguard tg3 pod ; y U.S. Nuclear Regulatory Commission

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Dear Sirs:

We are presently being evaluated at Region 3V for licensure to conduct industrial radiography activities.

As industrial radiographers, it will be necessary for us to occasionally act as shippers.

Please review our 10CFR 71 Quality Assurance Program which is enclosed with this correspondence.

A check for $150.00 has been included to cover the cost of this evaluation.

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Rol. ort Barnett, RSO RB/mjs l

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T ITEM 10.7 e

10CFR71 QA PROGRAM 1.

Organization Intent-The final responsibility for the Quality Assurance (QA) l Program for 10CFR71 Requirements rests with the licensee.

Designation and fabrication shall not be conducted under i

this QA Program.

See Attachment Item 7 for Organizational Structuro.

Implementation:

The Radiation Safety Officer will be responsible for the overall administration of the Program.

l 2.

Quality Assurance Program Intent:

Management establishes and implements this QA Program.

Training, prior to engagement, for all QA functions is i

required according to written procedurcs.

QA Program l

revisions will be made according to written procedures with management approval.

The QA Program will insure that all defined QA procedures, engineering procedures, and specific provisions of the package design approval i

are satisfied.

The QA Program will emphasize control of the characteristics of the package which are critical z

to safety.

t Implomontation:

The Radiation Safety Officer shall assure that all radioactive matorial shipping packages are designed and manufactured under a QA Program approved by Nuclear Regulatory Commission for all packages designed or fabricated after the effectivo date of the QA Program.

This requirement can be satisfied by rocciving a cortification to this offect from the manufacturor.

3.

Document Control Intent:

All documents related to a specific shipping package will be controlled through the use of written procedures.

All document changes will be perforened according to written procedures approved by management.

Implementation:

Tho Radiation Safety Officer shall insure that a.ll QA functions are conducted in accordance with the latest applicable changos to these documents.

78

e 4.

Handling, Storage and Shipping Intent:

Written safety procedures concerning the handling, storage and shipping of packages for certain special form radioactive material will be followed.

Shipments will not be made unless all tests, certifications, acceptances, and final inspections have been completed.

Work instructions will be provided for handling, storage, and shipping operations.

Radiography personnel shall perform the critical handling, storago and shipping operations.

Implementation:

The Radiation Safety Officer will establish written procedures for handling, storage and shipping of l

radioactive materials.

He/she will be responsible for implementing the procedures.

5.

Inspection, Test and operating Status Intent:

Inspection, test and operating status of packages for certain f

special form radioactive material will be indicated and controlled by written procedures.

Status will be indicated by tag, label, marking or log entry.

Status of nonconforming parts or packages will be positively maintained by written proceduros.

s Implementation:

The Radiation Safety Officer shall direct initial and periodic inspections of exposure devices.

Radiography personnel shall perform the regulatory required inspections and tests in accordance with written procedures.

The Radiation Safety officer shall ensure thtt these functions are performed.

6.-

Quality Assurance Records Intent:

Records of packago approvals (including references and drawings, procuromont, inspections, tests, operating logs, audit results, personnel training and qualifications and i

records of shipments will be maintained.

Descriptions of 1

equipment and written procedures will also be maintained.

Implomontation:

Those records will be maintained in accordance with written proced'iros.

The records will be identifiablo and retrievable.

A list of these records, with their storage locations, will be maintained by the Radiation Scfety Officer.

79

7.

Audits Intent:

Established schedules of audits of the QA Program will be performed using written check lists.

Results of audits will be maintained and reported to management, Audit reports will be evaluated and deficier.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 of the audit team.

shall have no,( responsibility in the activity being audited.

Implementation:

The Radiation Safety Officer will schedule audits of the QA program.

He/she shall make recommendations to management on individuals to conduct this inspection.

He will act as a resource in providing information and answering questions.

Reports will be ffled directly with management.

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l 80

I ITEM 10.7 VENDOR QUALITY ASSURANCE PROGRAMS i.

Technical Operations, Inc. conducts activities under NRC approved Quality Aosurance Program #0040.

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Technical Operations, Inc. conducts transportation activities l

associated with certain of their exposure devices and shipping containers under IAEA Certificate of Competent Authority E's:

1 l's:

660 = USA /9033/E(U) 683 = USA /9053/B(U) 680 = USA /9035/B(U) 650 = USA /9032/B(U) 1 750 = USA /9121/B(U) 771 = USA /9107/B(U) 773 = Type A i

sealed sources = USA /0154/B(U)

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Co-137 = GB/24/S (X8) e lii.

Gamma Industries, Inc. conducts activities under NRC approved Quality Assurance Program 90010.

iv.

Gamma Industries, Inc. conducts transportation activities associated with certain of their exposure devices and

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shipping containers under IAEA Certificate of Competent Authority #'s:

Century S&SA = USA /9135/B(U)

Gammatron 100 A = USA /9127/B(U)

C-8 = USA /9128/B(U)

C-10 = USA /6717/B(U)T Scaled sources = USA /0166/S

    • NOTE: Copies of appropriate documentation of Vendor Compliance Programs and approvals will be kept on file.

82

ITEM 10.7 SHIPPING AND RECEIVING INSTRUCTIONS FOR RADIOGRAPHIC EXPOSURE DEVICES 1.

Transported from (Vondor):

Amount Ordered mci Amount Received mci 2.

Shipped to Dato shipped Transportation by 3.

Shipping Containor:

Sorial No.

Model:

4.

Radiation Survey at the Package Surface:

mR/hr. of dust on exterior when wiped with clean cloth mR/hr. (not to exceed 200 mR/hr.) at surfaco 2

mR/hr. (not to exceed 10 mR/hr.) at 3' 5.

Radiation Survey of Exposure Device:

Source locked and keys removed mR'hr. at 6"

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mR/hr. at 1 motor (approximately 39")

6.

Survey Motor used:

Model and No.

7.

Sourco No.

8.

Projector Sorial No.

9.

Date of Exposure Device picked up:

Radiographor in charge of operations:

Packago labeled and shipping papers completo 83

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ITEM 10.7 An evaluation and audit of the Quality Assurance Program and the activities conducted under the program has been conducted.

Items checked below are judged to be satisfactory at this time.

Any item judged not to be satisfactory is explained in detail on attached shoot (s).

1.

Organization Satisfactory Not satisfactory i

2.

Quality Assurance Program

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Satisfactory

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,"Not satisf actory

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3.

Document Control ./...

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Satisfactory

  • 4 *Not s'atisfactory 4.

Handling, Storing and Shipping Satisfactory Not satisfactory e

5.

Inspection, Test and operating Status

  • Satisfactory Not s'tisfactory.

6.

Quality Assurance Records satisfactory Not satisfactory 7.

Audits Satisfactory Not satisfactory Name Title i

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