ML20206E309

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Forwards,For Approval,Shipping Container QA Program Requirements,Per 49CFR173.471.Supporting Documentation Also Encl.Fee Paid
ML20206E309
Person / Time
Site: 07100601
Issue date: 05/22/1986
From: Tillberg R
CARRIER CORP.
To:
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
27046, NUDOCS 8606230282
Download: ML20206E309 (27)


Text

{{#Wiki_filter:7/- 06 of a UNITED carrier Corporation g\\ if n TECHNOLOGIES CARNER C rrer Parkway RETURN TO 396-SS LTO.vmmi May 22, 1986 M -2 N0 5b U.S.N.R.C. Transportation Certification Branch Division of Fuel Cycle and Material Safety Washington, DC 20555 Gentlemen: l Re: (a) 49 CFR, 173.471 In accordance with the requirements of reference (a) please find enclosed our procedure " Shipping Container Quality Assurance Program" submitted for your approval. Enclosed please find application fee in the amount of one hundred fifty dollars, and also a copy of our New York Material License. i Very truly yours, ( r i et,4 f. IM% Ronald E. Tillberg, Manager CML-A Codes and Standards COMMERCIAL APPLIED DIVISION RET /kpm Enclosures (1) N.Y. Radioactive Materials License No. 2253-0183 (2) Application Fee tWTrij33DI I ______ h' gc1 t c =,, ~~~ g~~~'- / ,s t Remittcr I gg g p-tg 99. $ [ $ t$ - h M E E T F;c Cat:ccry jgi/ ~ ~ ~ ~- Typa cfg,;3 _ gjs - - - ...i N3W_ cue c.,,m. ag(g - [vic c,c e.7. ;..,,;Q Cy: C606230282 860522 PDR ADOCK 07100601 C PDR O-5008 O-84) 907-232

m UNITED carri:r corpor:ti:n E,&, TECHNOLOGIC CARRIER PO Box 4808 Carre Parxaay Syracuse. New York 13221 315/432-6000 SHIPPING CONTAINER QUALITY ASSURANCE REQUIREMENTS 1. SCOPE 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 fabrication of shipping containers shall not be conducted under this Quality Assurance Program. 2. ORGANIZATION The final responsibility for this Quality Assurance Program rests with the Company whose organizational structure is included as a part of this procedure. The Radiation Safety Officer is responsible for overall administration of the program, training and certification, document control and auditing. The Lead Radiographer is responsible for handling, storing, shipping, inspection, test, operating status and record keeping and are directly accountable to the Radiation Safety Officer on all radiation safety matters. 3. QUALITY ASSURANCE PROGRAM This QA program, although limited in scope, is conducted in accordance with the Company's normal QA policies. For 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 definea operations, inspections or tests. Also, the RSO shall assure that all shipping containers are designed and manufactured in accordance with 10CFR71 by certification from the manufacturer. 4. DOCUMENT CONTROL 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. Distribution of the manual and revisions are controlled in a positive manner by return of a transmittal form. i i G-78 (1-84)

l 5. HANDLING, STORAGE AND SHIPPING All operations involving the: handlica, storage and sh.ippios of.oackages for_certain special form radioactive material will be done in accordance with our Radiation Safety Manual. No shipments will be made unless all test, certifications, acceptance i and final inspections have been completed. I 6. INSPECTION, TEST AND OPERATING STATUS The RSO shall assure radiographic personnel conduct inspections and test as follows: i a. Receipt Inspection: The following inspections shall be conducted at receipt. 1. Survey 2. Visual inspection for correct marking and damage 3. Manufacturer's documentation The survey results will be recorded, b. In-process Inspection and Tests: The following inspections and tests shall be l conducted as required. ] 1. Leak tests 2. Visual inspection and survey when damage is suspected 3. Daily and monthly 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.) i 7. NONCONFORMANCES On discovery of a nonconformance the container will immediately be surveyed. If the radiation level exceeds 200 mr/hr at the surface or 10me/hr at 1 meter the restricted area shall be established and the RS0 notified. He shall direct resolution of the nonconformance. Surveillance of the restricted area shall be. maintained until the nonconformance 1: resolved. If the survey meets the above levels, the equipment shall be moved to a locked secure area. The RSO shall be notified of the nonconformance 4 and he shall provide resolution. 8. QUALITY ASSURANCE RECORDS All shipping container records will be maintained along with the other required radiation safety documents. All records are reviewed quarterly as part of the internal audit program. 4 ,___4 .y _w-n---. p 2

9. AUDITS Audit of this Quality Assurance program will be conducted on an annual schedule. Organizational Structure The program will be under the direct supervision of the Safety and Industrial Hygiene Manager and the Radiation Safety Officer (RS0). Radiographers and assistant radiographers report directly to the lead radiographer (s) and indirectly to the RSO. The RSO reports to the Manager of Safety and Industrial Hygiene. FLOW 0F ORGANIZATION MANAGER OF SAFETY AND INDUSTRIAL HYGIENE A RADIATION RADIATION SAFETY OFFICER CONSULTANT LEAD RADIOGRAPHER RADIOGRAPHER AND ASST. RADIOGRAPHER

SHIPPING CONTAINER QUALITY ASSURANCE AUDIT CHECK LIST SAT. UNSAT. 1. Receipt Inspections Are radiation surveys conducted on receipt? a. b. Are surveys conducted within allowable time limits? Are visual inspections conducted on receipt? c. d. Are current " Certificates of Compliance" on file? e. Have received sources been leak tested within six months? f. Were leak te'sts within allowable limits? 2. In-Process Inspections of Tests a. Leak tests conducted within last 6 months. b. Daily and quarterly maintenance inspections conducted. Inspections conducted when damage is suspected c. 3. Inspections Prior to Shipment a. Radiation surveys conducted. b. Surveys within allowable limits. c. Proper radioactive labels affixed. d. Properly prepared for shipment (bolts tightened, seals in place, source I.D. tag attached, etc.) Shipper's certificates properl.y prepared. e. f. Bills of lading properly prepared. 4. Notices of Receipt received from consignee. Date: Auditor Approval Radiation Safety Officer

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.g,. - 4.;;W re w.... Q J- .w. w:-r.4 STATE OF Mpir YORK.3 '~'? a8 Dages O (n.%Paga .f.cg.pf,. JMMR. 4 BEINOACTNE MATEMAL5 ..q w. .. ~ 'I n. ~ dg&:+g.Jds$$2%i /. ' "' ~ -* . u -~ ~ D l- .M Ptunuant to the Labor Law and Industrial Code Rule No. 38. and in r=H=u = on statements and representations M (. +-- hohe~toforU.,nia'de br Uidlicensee designitsd below, a IIcense is hereby issued authorizing such licensee to receiv.e,' possess ' e.. radb,..b matenal(s) designated below and to use such radioactive materials for the purpose.... m'(s) designated below. This license is subject to all applicable rules. regulations, and (s)and orders now o'r hem'eseht of all oye. eszte regulatory agencies and to any conditions speczfied below. my q3:is;& . g,_ , y.' Ti,

3. License Number Carrier Corporation 2253-0183
2. Address Carr.d_er Parkway
  • February 28, 1982 Syracuse, New York 13221 Sa ReferenceNo.
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8. Maimum quantitylicensee (element and mass number) may possess at any one time

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Iridium 192 A. Sealed source A. No single source to (Techical Operations, exceed 100 Curi~es Inc. Model A 424-9) CONDITIONS

9. Authorized use. (Unless otherwise specified, the authorized place of use is the licensee's address stated in Rem 2 above.)

Condition 6.A. In Technical Operations, Inc. Model No.660 Radiography Exposure Device for the performance of industrial radiography. Inc. Model Nos.M or 650 Radiography Source Changers for sourceIn Technical Operations, replacement and storage. I a.

10. The licenseETshall comply with the provisions of the State of New York j

Industrial Code Rule No.38, " Ionizing Radiation Protection" (12 NYCRR 38), effective July 10, 1978. l

11. The radioactive materials shall be.used by, or under the supervision of, qualified liceng.e~.'p'eysonnel designated by 4?;rcid 11idlw (Radiation Safety Officer).

The licensee shalf maintain complete and accurate records of all qualified licensee personnel. >N, a

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ggys; ~ ^ .%y_.SyQ3~gy. .? .~ 12. The licensee $isuauthorized to receive, possess, use and transfer sealed sources of;' Iridium.192 where the radioactivity exceeds the maximum amount of radioactivity specified in Condition 8 of this license provided that:. A. Such possessionidoes not exceed the quantity per source specified in Condition 8 by more than 20% for Iridium 192. B. Records of the licensee, show that no more than the maximum amount of radioactivity per source specified in Condition 8 was ordered from the supplier or transferor of the radioactive materials. C. The levels of radiation for radiographic exposure devices (device) and storage containers do not exceed those specified in Appendix A.3 'of Industrial Code Rule No.38. i 13. The licensee radiation protection program manual specified in Condition 15.A., including a copy of the Code Rule shall be made available to each person working with or having responsibility for sources of radia-tion pursuant to Section 38.34(b) of 12 NYCRR 38. The operating and emergency procedures, including the inspection and maintenance of devices and storage containers shall be followed. Any change in the manual affecting the radiation protection of persons shall be submitted to this Department for license amendment prior to issuance to personnel. 14. Pursuant to Appendix A, Section A. 3 (e)- of 12. NYCRR 38.,- the licensee is authorized to perform tests for leakage or contamination of sealed sources authorized by this license in accordance with procedures contained in Carrier Corporarion's " Radiographic Examination Manual" dated September 4 1979. 15. Notwithstanding the periodic leak test required by Appendix A, Section A. 3 (e) of 12 NYCRR 38, such requirement does not apply to radiography sources that are stored and not being used. The sources excepted from this test shall be tested for leakage prior to any use or transfer to another person unless they have been leak tested within six months prior to the datejof use or transfer. r e-j*:; = e

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. - - = 4 .:..;.a dc. g.,; 4'-- ?:. ' ',' -. FOR THE NEW YORK STATE PAR M NT OF LABOR by W( Cfb February 29, 1980-L.gKasyk, Senior Ridlophysicist s. n Ge GLK:bd for: Carl J. Mattei, Director

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September 17, 1979 Depart =ent of Labor Division of Safety and Health Two World Trade Center i New York, NY 10047 W.

Dear Sirs:

! (dOLUF. i' Enclosed, please find, nicessary documents required in obtwing l an Isotope Radiougraphy License. Submitted, as listed, are: l l 1. Operating and E=ergency Procedure - 2 copies 2. Application for license in front of 0 and E =anual - 2 copies t 3. Letter pertaining to Bond Waiver - 1 copy 4 Fiscal Reports as per Bond Waiver Requirement - 2 copies If these are not sufficient or any other questions surface, please direct them to either the writer or Carrier's Radiation Censultant: 1 Carrier Corporation Radiation Consultant Paul Tsujisoto Frank Clifford i Nuclear Quality Assurance Engineering P.O. Box 452 Building TR-1, 3-Eay Penthouse Niantic, CT 06357 Carrier Parkway Syracuse, NY 13206 Phone: (203) 442-2909 Phone: (315) 432-6192 1 Thank you for your time, g:-- ~. 5 l 0 y.*,. / ' 0 Paul Tsujimoto PT/cjb Enclosure Mr. Richard Chapcan - Carrier Syracuse cc: Mr.. ira J5hnson - Carrier Syracuse Mr. Edward Giroux - Carrier Syracuse Mr. Harold Ridler - Carrier Syracuso C 1..,on o, Carr er C.orocration 1 P C. Box 4808. Carrier Parxway. Syracuse. New York 13221. Phone (315) 432-6000 G.5043 907 206s

e. 4* STATE C F NEW YORK 4 ) DEPARTMENT OF LABOR l g-Division of Safety and Health l } TWO WoRLD TR AoE CENTER Wg NEW YORK, N.Y.10047 February 10.1986 Address Reply To: Radiologica] Health Unit Carrier Corporation Refer To: Post Office Box 4808 Radioactive Materials License Syracuse. New York 13221 No. 2253-0183 Reference No. 1 Attention: Mr. Ronald E. T111 berg Amendment No. 1 Manager. Commercial Applied Division DOSH Application No. DL89-370 Installation No. LR 0183

Dear Mr. Tillberg:

Enclosed herewith is an Amendment to State of New York Radioactive Materials License authorizing your firm to possess and use Radioactive Materials licensed therein pursuant to the State of New York Industrial Code Rule 38 " Ionizing Radiation Protection" (12 NYCRR 38), as amended effective June 25, 1985. IMPORTANTr This letter shall be retained with this License. Your attention is directed to Section 38.7 of 12 NYCRR 38 entitled " Security". Radioactive Materials authorized by this License are exempted from the Security requirements pursuant to Subdivision (d), Paragraph (4). Your firm will have to comply with either Subdivision (a) or (c) should it contemplate changes which will no longer meet any of the exemptions of Subdivision (d). Eutsuant to Section 38.11 entitled " Duration of Licenses" voor firm is recuired 1o file a let-1er (acolication) _ gore than 30 days orter to the exairation date o f_ your License for a renemal of the_Licenitu Do not hesitate to contact the Department should you have any questions concerning this matter. Very truly yours, Stuart Schrank. Director m?c C2h Enclosure ech e L. Kasyk GLK wo Associate Radiophysicist

~~ ENDtTO%DEPARDAINTOnO ' omistcWWsAriMrJGEttit[p@ORCLCE'd-%Wm J .=~- Q,,f l.MB*7# oEs@{Femfh S W -f N;;- ( - ~'IM.. s. -...,t 2 %: RADIOACTIVE MATERIALS LICairwe 7.:r- .J ' # " *' x AMENDMENT .c. ..yp -' G. M W.-s ' n-~ . :"M. '.' .Qw - paoE g'piggg-1 .q op .< y. z PURSUANT TCL En law ~ AND INCUSTRIAL CODE MULE 38, AND IN REUANCE oN STATEMENTS @-- REPRESENTATIONsiMERYTCFORE' MACE 3Y THE UCENSEE DESIGNATED BELON, A LICENSE is HERESY 438ueC AUTHOR 1Z1NG SUCH f.!CENSEE TO RECEIVE. POSSESS, USE AND TRANSFER RADICACTIVE MATERIAL 5tS) DISIGNATED. BELOW: AND TO USE SUCH RADIOACTIVE MATERIALS FOR THE PURPOSE (31 AND AT THE PLACE (s) DESIGNATED sELOW.' TNis UCENSE IS SusMCT TO ALL APPUCABLE RULES, REGULATIONS, AND ORDERS NOW OR HEREAPTER IN EFFECT OF ALL APPROPRIATE REGULATORY AGENCIES AND TO ANY cONDITICNS SPECFIED sELOW.

1. NAME OF UCENSEE
3. UCENSE NUMOER Carrier Corporation 2253-0183.-

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4. EXPT RATION CA35, c :.
2. AooxEss or ucENsEE FehFuer)e;eZR,. ~ 1989 ;

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~ p :*7 "ha: Condition 9.6.A. Changed to read ~ 'C 4.. ' -4 In Technical Operations, I n c. Ptodel 660: Radiography;. Exposure Device for the perf orman ce of irtdustrial '-radio-graphy. In Technical Operations, Inc. Moder:6501 Radfo-graphy Source Changer for for source replacement.and sto-rage. Condition 9. Expiration Date changed. Condition 10. Changed to read: The licensee shall comply with the provisions of The State of New York Industrial Code Rule 38, " Ionizing Radiation, Protection" (12 NYCRR 38), as amended effective June 25, 1985. Condition 11. Changed to read: Licensed materials shall be used by personnel designated by Frank L. Clifford (Radiation Safety Officer). The licensee shall maintain complete and accurate records of all qualified licensee personnel. Condition 13. Changed to read: The licensett shall, pursuant to 12 NYCRR 38, Section 3 8. 3't c " Instructing personnel-Posting Notices", instruct and provide each person working with, or having responsibility for radioac-tive materials, with operating procedures, referenced in Condition 16.A. herein, and with a copy of 12 NYCRR 38. The procedures and 12 NYCRR 38 shall-be followed and any chanses in the procedures affecting the safety and health.of persons'shall be submitted to the Department for approval priarcto issuance to personnel. .? -.g ,c. e.... ..';g

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14.- - ~ 5s. Ref. No. Ik Amend. Na 2.g, - -r Condition 14. Changed to read: The licensee shall have Sealed Sources tested for leakage or ' contamination pursuant to Section 38.26(f) of 12 NYCRR 38. The testa shril only be performed by persons specifically licensed by...the Department. The State of New York Department of Health. The City of New York Department of Health. The U.S, Nuclear Regulatory Commission or by another Agreement State;.to' perform such services. 4, \\ 2' ' c., Condition 15. Changed to read: e 1-?;@ The licensee is authorized to ' collect leak ' testt samples. i'Wac -. cordance with the procedures described--irr thedfcans'ee 's 2.. 6.t: Radia. tion Safety Manual for analys'is.by Telhafca129ip,erati'se y Inc. Alternatively, leak t es t samples. may be' ciitElected 'andi[esEk analyzed by other persons specifically au thor-i;radt bur s uame?5F# ) Condition 19. herein. ' eh,i;; @l'tf* zz '!.f Wrec.?; w* Condition 16. Changed to read: _. l'M.I.WY* m.mh' J," M. A. Licensee's " Radiation Safety Manual For RadiosEmid d; dated; January 29, 1986. C Condition 16. Documents added: C. Her letters dated M'a[ch 19, 1985 and March 26, 1985, signed by Jane B. Monahan, with enclosure. I D. His letters dated October 29,1985 and January 30s 1986, signed by Ronald E. T111 berg, with enclosure. Condition 17. News D. Burley.. T;. Vandverven and I. Johnson are authorized to per-form source exchange in accordance with procedures contained in licensee's manual referenced in Condition 16.A. herein. Condition 18. News Sealed Sources containing licensed material shall not be opened. Stuart Schrank. Director for: THE COMMISSIONER OF LABOR-DATE: February 10, 1986

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l A UNITED a 4 TECHNOLOGIES C:rrier corporation CARRIER car'* Par =~ar POBc 4808 [ _. Syracuse. New York 13221 January 30, 1986 Department of Labcr Roce 6989 State cf New York Twc Weric Trade Center New Ycrk, NY 10047 Att: Mr. Gecrge Kasyk

Dear Mr. Kasyk:

Subject:

License Number 2253 0183 Thank ycu for ycur assistance in the review of the final draft of cur Radiation Safety Manual. Your recommendations of January 29, 1986 have been incorporated into the manual submitted

herewith, i

Ycur recommendations for Mr. Clifford's survey report will be given ta him. This survey will be conducted in conjunction with cur start-up training and will be submitted to you under separate ccver. If I can be cf further assistance, please contact me at (315) 432-6700. Sincerely ycurs, N/ et,d C I enald E. Tillberg, Manager CML-A Ccdes and Standards COMMERCIAL AFFLIED DIVISION RET /kpm Attachment Mr. FrankIC1'ifford, Clifford Associates cc: Mr. Thomas Munro, Carrier, TR-7 Mr. Gerald Bailey, Carrier, TR-19 Mr. Rex A. Niles, Carrier, TR-1 l? O d-5098 (1-84)

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  • if T, TECHNOLOGIES carrier Corporation CARRIER Camer Parkway PO Box 4808 October 29, 1985 w a h m m 2i Department of Labor Roon 6949 State of New York Two World Trade Center New York, NY 10047 Atti Mr. George Kasyk

Dear Mr. Kasyk:

Subject:

License Number 2253-0183 Enclosed for your review and approval please find the October 16, 1985 revision to Carrier's Radiation Safety Manual for Radiography. Your comments'of October'1, have been incorporated. 1985 including those applicable to Appendix 'B' to help sake your review a bit easier. Revisions on each page are designated by a (*) { Enclosed, also, is a copy of a letter from Mr. Frank Clifford sussarizing the initial (1980) training of our Radiographers in source changing. to this they have received annual refresher training as well as experience in In addition actual source changing. Sincerely yours, 1 ssf/ C (E Ronald E. Tillberg Code Consultant CML-A Quality Assurance COMMERCIAL APPLIED DIVISION RET /kpa Enclosure cc: Mr. Thomas Munro, MCHC Mr. Gerald Bailey, TR-18 \\ OCT 2 fi E' G40ee (144)

_. L. CLIFFORD ASSOCIATES I W-i Safety and Training Consuftants P.O. Box 452 Niantic, Connecocut 06357-0452 (203) 739-8305 16 October 1985 Carrier Mr. Carl Johns - TR 18 P.O. Box 4804 Syracuse, N.Y. 13221 Daar Mr. Johns; In response to our telecon this date this is to verify that the following CARRIER personnel completed the on-the-job phase of a Radiography Training Period conducted by myself, and completed on 19 March 1980. During this training period cpproximately three (3) hours were devoted to source exchanging utilizing Tech-Ops models 660,650 and 414 devices. BURL 5.7., D VANDVERVEN, T. JOHNSON, I very truly your / 'F.L. ifford Radiation Control Specialist Ge s O

UNITED [=,TECHNULOGif carrtr c:rpor:ti:n CARRIER Po sousca Camer PJ&way Syracuse. New York 13221 315/432 6000 i March 26, 1985 New York State Depart =ent o'f Labor Division of Health and Safety Radiolegical Health Unit Two World Trade Center (Roos 6989)

?ew York, NY 10047 Attn: George Kasyk

Dear Mr. Kasyk:

This is in regard to UTC/ Carrier's radioactive caterials license I nu=ber 2253-0183. Our license has expired due to a considerable change-over in personnel in both the canage=ent of the Quality Assurance Department as well as the Safety and Industrial Hygiene Dapartment at Carrier. i In the future all applications for license renewals, licenses and amendments will be handled through this office to avoid reoccurrence cf this proble=. Should it becoce necessary to replace the RSO the candidate's name and qualifications will be submitted to the NYSDOL-RHU for approval prior to his appointment. As requested Mr. F. L. Clifford has enclosed a-letter to you outlining the following four points: 1. Upon receipt of the A=end ant renewing the License, Mr. Clifford i shall conduct a full day (at least'7 hrs.) of refresher j for Mr. Johns and the radiographic department, including review of the =anual, pertinent regulations and practical training in the use of the isotopes. j 2. Mr. Clifford shall for the next six months at approximately monthly intervals visit Carrier for a full day during which, together with Mr. Johns, he will perform a review of radiographic operations an~d audit all the records. Remaining time to be spent with'Mr. Johns reviewing past assiantents, testing his retentivity of material presented and assign future study and duties to be performed during his absence. -( 6 78i!-84) v-...

~, RE: RADIOACTIVE MATERIALS LICENSE MARCH 19, 1985 i. 3. Mr. Clifford shall make detailed entries into the firm's log, making account of ti=e spent on individual actions. 4. Mr. Clifford shall countersign this agreement in order to I acknowledge his understanding of these requirements and obligations. I would like to take this opportunity to formally request renewal of Carrier's radioactive material license number 2253-0183. The radioactive material is Iridium 192 in a sealed source (Technical Operations, Inc. Model A424-9) with no single source to exceed 100 curies. Let ee know if there are any additional requirements. Yours truly, / .. l.'l/ W m .q ). Jane B. Monahan Director Industrial Relations, NA0 JBM/cwr 't i i E } O I J 1. 1

UNITED r TECHN31&GIE: carricr carporatian CARRIER i ' 0:8" '"8 Carrer Parkway Syracuse. New York 13221 '.115/432 6000 (- March 19. 1985 h.. 4 New York State Department of Labor Division of Health and Safety Radiological Health Unit Two World Trade. Center (Room 6989) Naie York, NY 10047 t Attn: George Kasyk

Dear Mr. Kasyk:

This is id regard to Carrier Corporation's radioactive materials licens,e nu=ber 225.3-0183. i I would like to designate Mr. Frank L. Clifford of'-F.L. Clifford Associates as the Radiation Safety Officer (RS0) for the Carrier i Corporation's Syracuse, New York facility. Mr. Clifford's resu=e outlining his training and experienceEnclosed please" find p ( in the field of Radiation Protection. Let =e'know if there are any other additional qualifications required for approval by your department. Very truly youra, w ^ u \\, ., 'p /?&fi, Jane B. Monahan ' Director Industrial Relations, NAO JBM/ cur Enclosure O 90?Asa

-1; Trank L. Clifford USS Nautilus And USS Skipjack Fleet Post Office New York, New York ) 1. Ti tle January 1957 to March 1958 Nautilus, Health Physics Dept. March 1958 to September 1959 Skipjack, Health Physics Dept 2. Nature and Extent of Responsibilities A. Qualified in the following tests and procedures (1) Reactor primary coolant radiochemistry (2) Boiler water gross activity (3) Reactor fresh water gross activity (4) Potnble water samples for gicss activity (5) Enviromental Monitoring (6) Personnel Monitoring (7) Instrument Calibration \\ (8) Decontanination t (9) Photodosimetry 1 B. From March 1958 to September 195.0, I performed the following duties: (1) Directed the training and work of a staff of 3 Hospital corpsmen in their duties in connection with the tests and procedure: listed nbove. (2) verified the results of all radiochemical analyses necessary for the operation of the reactor. (3) Established and administered a training program in Radiological Health Theory and Techniques for monitors and radiation casualty teams. (4) Conducted inspections and supervised monitoring of all areas concerned with nuclear repair and maintenance. (5) Supervised the photodosimetry program. (6) Calibrated radiac equipment, dosimeters and film badges. (7) Supervised Health Physics of handling, processing, packaging and disposal of radioactive waste. (8) Established radiological controls during reactor naintenance operations. .-a 4 98 *

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I. ( Frank L. Clifford U.S.N. Nuclest Power School U.S.N. Submarine Base, New London, Connecticut 1. Ti tle Nucleonics Laboratory Instruccor September 1959 to August 1961 2. Nature and Extent of Responsibilities A. As a principal user on A.E.C. byproduct license, I was responsible for overall control, movement, storage and disposition of all radioactive material in the laboratory. I made up suitable samples for training of Medical Officers and other Medical Personnel in techniques of Radiochemistry, Nealth Physics and Photodosimetry. B. Taught Basic Radiological Control course to Nedical Officers and USN L'ine Officers. C. The following is a list of experiments supervised by me as part of of the training program: (1) G-N counter scaler check, 60 cycle test, high voltage test, and G-N tube operation. (2) Councing statistics. Demonstrating the statistical variation in counting. (3) Geometry factors of Beta and window counters. (4) Backscatter. .faect of "z" number and thickness of backscatter and sourc.s energy on sample count rate. (S) Efficiency vs endpoint energy. (6) Photodosimetric film calibration (7) Beta absorption, P-32. Plot a Beta absorption curve and determine the true zero count rate. (8) Radioactive Air sampling techniques, portable equipment. (9) Sample preparation and decay study of Iodine -131. (10) Radioassay of I-131. (11) Teacher analysis. Determination of beta particle range and energy by the use of a net beta absorption and the feather analyser. (12) Potable water activity. Determination of potable water activity, technique and calculations. (13) Portable alpha water survey instruments. Operation, cuintenance and calibration procedures. (14) Portable Beta-gamma survey instruments. Operation maintenance a,nd[ca'11bration procedure. (1S) Radioisotope sample preparation. Decay curve plot and half-life determination of mixed isotopes. Separation of the two independent decay curves and determination of the half-lives. (16) Photodosimeteric film pratice. Developing techniques. (17) Photodosimeteric film practice. Reading and interpreting.

+ I. { Trank L. C11iford Educational Background 1. U.S.N. V-12 Program Harvard University 1943 and 1944 Najor-Physics 2. U.S.N Submarine Medicine School New I.cndon, Connecticut 1951 Subjects: A. Medical Administration B. Medical Diagnostics C. Anatomy G Physiology D. Materia Medica E. Ninor Surgery T. Diving Physiology 3. U.S.N. Medical School Bethesda, Nd. \\ 1955 to 1956 Subjects: A. Radioisotope Therapy B. Chemistry C. Nath D. Physics E. Radiochemistry F. Radiobiology G. Radiation Therapy 4. U.S.N. Nuclear Engineering School New LLadon, Connecticut 1956 to 1957 \\ Subjects: A. Radiological Controls B. Nuclear Plant Systems C. Nuclear Physics D. Na thma tics E. Reactor Principles F. Nealth Physics C. Radiochemistry N. Radiobiology I. Radiochemical Laboratory Technique 5. Various extension and correspondence courses.

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j## *'%,I*. umrao states p. NUCLE AR REGULATORY COMMis3 ION 7 g wAsmucrow. o. c. rossa December 15, 1982 FCMLB:JCW i 1 F. L. Clifford Associates ATTN: Mr. F. L. Clifford P.O. Box 452 i Niantic, Connecticut 06357 Gentlemen: This refers to your letter dated October 25 which you submitted description of your prop,osed industrial 1982, with radiography training program. We consider the course acceptable to the extent th ons who training in the radiation and radiation safety portions of A A,10 CFR Part 34. t and in use of equipment in determining of competency to ppendix radiographer's assistant is the responsibility of the license i personnel you may be training. e whose i i Sincerely, I (. v 2 dosephC. Wang I Material Licensing Branch " Division of Fuel Cycle and Material Safety j 4

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Entlosure (2) to Quotation Mc 851214 F. L. CLIFFORD ASSOCIATES Racation Safety Consultants g - Box 452 Niantic, Connecticut 06357 (203) QUCTIATICH TO: Carrier Corporation PAGE10FlPAGES Mr. John Knowles, Mgr. Safety P.O. Box 4808 NUMBER: 834i 1 985 Syracuse, N.Y. 13221 We sutuait the following quotation, prices and terms being in accordance with conditions stated bersin. i Serve as Client's Consultant Radiation Safety Officer, performing the following services commencing 1 April 198 5 for a period of 12 months: 1. Liason with Federal & State Regulatory Agencies for License matters. 2. Maintain the radiation safety program. 3. Maintain an internal radiation safety audit program. 4. Act in advisory capacity to management and radiography personnel. 5. Investigate radiation incidents and recommend corrective actions. 6. Develop current operating & emergency procedures. 7. Calibrate and maintain radiation detection equipment and devices. [ 8. Audit and assure maintainence of required records. 9. Assist in radiation emergency situations. 10. Prepare required reports to regulatory agencies. 11. Assure control of procurement & disposal of licensed materials. 12. Conduct the source leak testing program. 13. Conduct quarterly inventory radiography sources. 14. Evaluate and certify Radiograph Personnel. 15. Conduct a radiation refresher training session once each calendar year 16. Conduct radiation surveys of facilities and equipment at least once each calendar year or more often if necessary. 17. Any other services mutually agreed to in writing. This quotation supersedes all previous quotations and is autcasatically withdrawn unless a purchase order or contract is issued and accepted ' l. _ within 30 days freut its date. , // SUBMITTED bis g, 6 DATE : 8 November 1984

8 e ( _ Trank L. Clifford F.L. Clifford Associates Niantic, Connecticut 1.

Title:

President: Part time 1966 to 1972 : Full Time: 1972 to date 2. Nature and extent of responsibilities A. Radiation Training and Safety Consultant. (1) Provide radiation safety consultant services to numerous clients. (2) Conduct NRC approved training courses and certify personnel in safety requirements for users of byproduct material and radiation producing equipment. (3) Previously possessed USAEC Byproduct Material License ( 06-12117-01. (4) Presently possesses USNRC Byproduct Material License 06-12117-02. B. Radiation Detection Instrument Repair and Calibration. (1) Repairs, adjustments and calibration of most radiation detection instrumentation for numerous clients. I C. Radiogrphic equipment inspection and maintainence. Ganca Industries, Inc. January 1970 to October 1972 Baton Rouge, LA 1. Title Regional Manager 2. Nature and extent of responsibilities A. Supervision of sales, service and engineering in a fourteen state area. (1) Duties included equipment repair, source exchanges, source '( recovery and equipment maintainence. l

i I. Frank L. Clifford \\ ,~ t General Dynnnics/ Electric Boat Croton, Connecticut Ti tle Chief Radiation Protection Officer September 1961 to February 1970 N2ture and Extent of Responsibilities A. Supervise the radiation protection program for 220 Certified Radiographers and responsible for the following: (1) Serve as.the Licensee's liaison officer with the Atonde Energy Coundssion - on license matters. (2) Supervise control of procurment and disposal of licensed byproduct material. (3) Develop and maintain up-to-date operating and emergency procedures. Ensure compliance with thease procedures. (4) Establish and supervise personnel monitoring program. (S) Procure and maintain adequate radiation survey instruments. (6) Supervise the AEC training progrna for radiographers and radiographers' assistants. (7) Establish and Maintain adequate storage facilities. (8) Supervise maintanence of exposure devices, radiography facilities nnd associated equipment. (9) Coordinate the leak testing program. (10) Supervise the internal inspection program both at GD/EB, Groton and at all field sites. (11) Ensure proper source tagging operations. (12) Conduct quarterly inventories and maint.ain utilization logs. (13) Supervise survey instrument calibration program. (14) Assume control and institute corrective action in emergency situations. (15) Investigate cause of incidents and deter:dne necessary preventive action. (16) Act in advisory capacity to licensee's management and radiography personnel. B. Conduct courses of instruction for reactor test Engineers in the following subjects: (1) Radiological control for naval nuclear propulsion plants. (2) Radiochemical controls for naval nuclear propulsion plants. C. Member of the Radiological Guidance Committee. This committee in an advisory capacity to management in establishing policy for handling radiation and contaminati problems. M

I. (~ ~ Frank L. Cli!!ord USS Nautilus And USS Skipjack Fleet Post Office New York, New York 1. Title January 1957 to March 1958 Nautilus, Health Physics Dept. March 1958 to September 1959 Skipjack, Health Physics Dept 2. Nature and Extent of Responsibilities A. Qualified in the following tests and procedures (1) Reactor pricury coolant radiochemistry (2) Boiler water gross activity (3) Reactor fresh water gross activity (4) Potable water samples for g; toss activity (S) Enviromental Monitoring (6) Personnel Monitoring (7) Instrument Calibration (8) Deconta=ination (9) Photodosimetty B. Fron March 1958 to September 1959, I performed the following duties: (1) Directed the training and work of a staff of 3 Hospital Corpsmen in their duties in connection with the tests and procedure: listed above. (2) Verified the results of all radiochemical analyses necessary for the operation of the reactor. (3) Established and administered a training program in Radiological Health Theory and Techniques for monitors and radiation casualty tea =s. (4) Conducted inspections and supervised monitoring of all areas concerned with nuclear repair and maintenance. (5) Supervi ad the photodosimetry program. (6) Calibrated radiac equipment, dosimeters and film badges. \\ (7) Supervised Health Physics of handling, processing, packaging and disposal of radioactive waste. (8) Established radiological controls during reactor maintenance operations. o - ( \\

~ Frank L. Clifford i U.S.N. Nuclear Power School U.S.N. Submarine Base, New London, Connecticut 1. Ti tle Nucleonics Laboratory Instructor September 1959 to August 1961 2. Nature and Extent of Responsibilities A. As a principal user on' A.E.C. byproduct license, I was responsible for overall control, moveDent, storage and disposition of all radioactive material in the laboratory. I made up suitable samples for training of Medical O!!icers and other Medical Personnel in techniques of Radiochemistry, Nealth Physics and Photodosimetry. B. Taugh,t Basic Radiological Control course to Medical Officers and USN Line O!!icers. C. The following is a list of experiments supervised by me as part of of the training program: (1) G-M counter scaler check, 60 cy le test, high voltage test, and { C-M tube operation. (2) Counting statistics. Demonstrating the statistical variation in counting. (3) Geometry facto,rs of Beta and window counters. (4) Backscatter. E!!ect of "z" number and thickness of backscatter and source energy on sample count race. (5) E!!iciency vs endpoint energy. (6) Photadosimetric film calibration (7) Beta absorption, P-32. Plot a Beta absorption curve and deterndne the true zero count rate. (8) Radioactive Air sampling techniques, portable equipment. (9) Sample preparation and decay study of Iodine ~131. (10) Radioassay of I-131. (11) Teacher analysis. Determination of beta particle range and energy by the use of a net beta absorption and the feather analyser. (12) Potable water activitu. Determination of potable water activity, technique and calculations. (13) Portable alpha water survey instru=ents. Operation, maintenance and calibration procedures. (14) Portable Beta-gamma survey instruments. Operation' maintenance and ' calibration procedure. (15) Radioisotope sample preparation. Decay curve plot and half-life determination of mixed isotopes. Separation of the two independent decay curves and determination of the half-lives. (16) Photodosimeteric film pratice. Developing techniques. ( (17) Photodosimeteric flim practice. Reading and interpreting. e a we.=- m ~

a (~' - '.. ^ Frank L. Cli!!ard Educational Background 1. U.S.N. V-12 Program Narvard University 1943 And 1944 Major-Physics 2. U.S.N Submarine Medicine Schoci New London, Connecticut 1951 Subjects: A. Medical Administration B. Medical Diagnostics C. Anatomy & Physiology D. Materia Medica E. . Minor Surgery F. Diving Physiology 3. U.S.N. Medical School Bethesda, Md. ( 19SS to 1956 Subjects: A. Radioisotope Therapy B. Chemistry C. Math D. Physics E. Radiochemistry F. Radiobiology G. Radiation Therapy 4. U.S.N. Nuclear Engineering School New London, Connecticut 1956 to 1957 Subjects: A. Radiological Controls B. Nuclear Plant Systems C. Nuclear Physics D. Ma thmati u~s E. Reactor Principles F. Realth Physics C. Radiochemistry H. Radiobiology ~ I. Radicche=ical Laboratory Technique S. Various extension and correspondence courses. ( 1

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