ML20207M281
| ML20207M281 | |
| Person / Time | |
|---|---|
| Site: | 07100503 |
| Issue date: | 10/04/1988 |
| From: | Hixon E PENN INSPECTION CO. |
| To: | NRC |
| References | |
| 24801, NUDOCS 8810180215 | |
| Download: ML20207M281 (12) | |
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RETURN TO y_y,j37 77_.g goza PENN INSPECTION COMPANY RT. 3, BOX 311 CHICKAShts. OK' e
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Nuclear. Regulatory Commi Washington, D.C.
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Dear Sir:
Os Enclosed is a check for $150.00 to renew our Quality Assurance j '
Program Approval for Radioactive Material Package #0503.
If ani questions, please contact me.
l Sincerely, O'
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ldh Earl Hixon Radiation Safety Officer j
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r QUALITY ASSURANCE PROGRAM FOR SHIPPING CONTAINERS r
1.0 ORGANIZATION 1.1 Eadiation Safety Director - It shall be the responsibility of the Radiation Safety Director to ensure that the Q/A program for shipping containers is effectively executed.
Any changes in the program, or additional precedure implementation due to regulatory requirements, shall be the responsibility of the Radiation Safety Director.
i 1.2 Radiation Safety Officer - It shall be the responsibility of ths-Radiation Safety Officer to ensure the inspection of shipping containars 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 cf deficiencies that require the acquisition of additional equipment or labels and shall see that these deficiencies are corrected.
7 1.3 Radiographer - It shall be the responsibility of the rad-iographer to inspect shipping container 3 on a daily basis.
l 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.
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2.0 QUALITY ASSURANCE PROGRAM l
2.1 Operating Procedures - The following procedures shr.11 be a
adhered to when operating or using transport containers.
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i 2.1.1 Only authorized personnel shall be allowed to use the transport containers.
2.1.2 Inspection of the devices shall be performed in accordance wi th 2.2 below.
2.1.3 The nut and bolt running through the bolt ring i
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 l
and attaching it to an intergral part of the vehicle.
This chain shall then be locked with a pad-lock.
2.2 Inspection Procedures - The following procedures shall be adhered to when inspecting transpcrt containers.
i 2.2.1 Only authorized personnel shall be allowed te inspect transport containers.
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- 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 operate properly and hvid securely.
4 2.2.5 Bolt rings and nut and bolt locks shall be checked to ensure that they work properly.
i 2.2.6 It'er packing (overpr:k) shall be checked to ensure it is in place and t't damaged.
2.2.7 Labels shall be inspecttd to ensure that they are i
not worn off,and that t,ey are legible.
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2.2.8 Handles shall be inspected to ensure that they are attached securely and are not in need of repair.
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i 2.2.9 Container's shall be checked to ensure that source plugs and dust covers are in good condition and are in place on the device before it is used.
F 2.2.10 Radiation levels shall be checked when a new source i
is placed into the container, as well as on a daily l
basis by the radiographer.
2.3 Haintenance and Repair Procedures - The following procedures shall be adhered to in order to ensure proper maintenance t
and repair of trans, aort containers.
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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 perforced on at least a quarterly basis.
j 2.3.3 Any severe package damage (ie., punctures, holes in the package, etc.) shall be repaired.
If the i
damage is severe enough that repair is not possible the package shall not ba used.
2.3.4 If a problem is found with a lock, it shall be corrected, or the lock shall be replaced before the device is used.
2.3.5 Bolt rings, nuts and bolts shall be oiled.
Any l
thread damage shall be repaired, or the part shall L
be replaced.
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- 2.3.6 Inner packing shall be la;p.cted and, if necessary replaced.
2.3.7 if labels are not legible, they'shall be replaced.
2.3.8 Har.dles 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 e.h'e device is used.
2.3.10 Il radiatisn 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.
1-2.4 Packagine. Loadine and Unicading of Transpurt 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 transport cor. tainers 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.
2.4.4 Packing shall be placed on top of the device and the lid shall be fastened using the bolt ring ano 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 Unicading of Transport Centainers) above.
3.0 PROCUREMENT AND CONTROL OF DOCUMENTS 3.1 Suppliers shall be required to submit appropriate verification that shipping containers were manuf actured uncer control of and NRC-Approved Q/A program.
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32 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.
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3,4 16 shall be the responsibility of the Radiation Safety Officer to ensure that the above items are adhered to.
4.0 IDENTIFICATION AND CONTROL OF HATERI ALS, PARTS AND COMPONENTS -
I All parts and components used to repair shipping containers shall be ordered from the manufacturer of the container.
No part l
shall be used 3 hat has been changed or altered in any manner.
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I 5.0 RANDLING, STORAGE AND SHIPPING t
All shipping containers, which contain radioactive materials, shall be kept in a locked storagi container at all tiras when not being used.
Keys to the 1ccks on storage containers and shipping l
containers shall be contro11ei by the Radiation Safety Officer.
The only irdividuals who will nave keys issued are the ones who have had, as a minimum, trainicg that is required for radiographers as outlined in the regulations.
6.0 CORRECTIVE ACTION i
The corrective action for items found to be in non-compliance are those outlined in 2.3 of this document.
Ic shall be the respons-F ibility of the Rcdiation Safety Officer to ensure that these l
j corrective actions are taNen for alt items of non-comp 16ance.
7.0 AUDITS
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I 7.1 Quarterly audits of all shipping containers and the.r
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j components shall be performed by the Radiation Safety i
Officer to ensure the containers are in compliance with s
the regulations.
The checklist. attached to the end of this document sh311 be followed.
l 7.2 Annual audits of the Q/A program shall be performed by l
r the R3diation Safety Director to determine the overall effectiveness and compliance with management policies and t
procedures. These audits may also include evalustions by outside consulting firms employed by the compa..y.
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8.0 Q/A RECORDS 8.1 Ql records which shall be maintained shall inclu
.m followings records of quarterly audits and inspect; m of l
l equipment, procurement documents, nonconf ormances, 1
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personnel training and certification records, evidence of operational capability and verification of repair, replacement and maintenance.
8.2 Q/A rc'ords shall be mii,tained for a period of two (2) years from the date on the record, for inspection by the Nuclear Regulatory Comiss ion.
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INSPECTION FORM FOR SHIPPING CONTAINERS Container #:
Action item to be Checked Satisfactory Unsatisfaa.cory Taken General Condition of Container
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- Condition of Labels e
r Condition of Locks l
Condition of Source Plugs /
and Dust Covers Condition of Handles i
Radiattor Levels r
t Date of Inspection:
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Q/A EXAMINATION _
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t FOR TP ANSPORT CONTAINERS i
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4 NAME SOCIAL SECURITY #
COMPMTf ADDRESS DATE i
t The enclosed examination consists of 10 questions that are worth 10 j
points each; for a total of 100 points.
A grade of 70% of better is required in order to pass.
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f Pago 1 of 2
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Explain the radiographer's duties in relation to the inspection.
.of transport intainers.
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2.
What itens mus,t.,be checked when inspecting transport containers under the Quality Assurance program for this company?
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If a particular item was found to be in unsatisfactory condition
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during the inspection of transport containers, what must be done?
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4.
How frequently must the Padiation Safety Officer inspect transport j
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containers.
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5.
How frequently must the radiographer inspect the transport containers?
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6.
What recourse does a radiographer have if he reports non-compliance i
of transport containers to the Radiation Safety Officer and no action is taken to correct the problems?
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Who is authorized"t'o use transport con >ainers for this company?
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8.
Whose responsitility is it to see that maintenance and repairs to transport containers ja performed?
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9.
How are transport containers to be secured on vehicles?
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- 10. What job positions are involved in the Quality Assurance program I
for transport containers?
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UNITED 8TATES 8
NUCLEAR REGULATORY COMMISSIOW g
e WASHING TON, D. C. 20666
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SGTB:LLG 71-0503 Penn Inspection Company ATTH: RSO Route 3 Chickasha, OK 73018 Gentleir.en:
Your Quality Assurance Program Approval for Radioactive Material Peckage No. 0503 expires on October 31, 1988.
If you are an NRC licensee and conduct activities under the General Licenses of Subpart C of 10 CFR Part 71 or an Agreement State licensee subject to the requirements of 10 CFR Part 71, as required by 10 CFR Part 150.20, a quality assurance (QA) program approved by the Commission as satisfying the provisions of Subpart H of 10 CFR Part 71 is required. You should request renewal of your quality assurance program at least 30 days prior to the expiration date.
This will provide for continuation of your QA program to satisfy part of the provisions of Subpart C of 10 CFR Part 71 until a final determination has been taken on your c pp,lica tion.
Unless an exemption is provided by 10 CFR Part 170.11, an application fee of
$150.00, as required by 10 CFR Part 170.31, should be included with your request i.
for renewal. This notice of expiration should not be construed that such notice 3
will be provided in the future.
If you do not desire to renew your QA program, please let me know, j
Sincerely, t
f Charles. MacDonald, Chief Transportation Branch Division of Safeguard * *nd Transportation, NMS) z a,.. ~ i -
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