ML20207P151

QA Program for Packing of Radioactive Matl for Transport & Transportation of Radioactive Matl Under Certain Conditions (10CFR71)

ML20207P151
Person / Time
Site:	07100385
Issue date:	10/08/1986
From:	Leeke H NAVY, DEPT. OF
To:
Shared Package
ML20207P145	List: ML20207P144 ML20207P147 ML20207P149 ML20207P151
References
HECTORINST-9090, NUDOCS 8701150100
Download: ML20207P151 (16)

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DEPARTMENT OF THE N AVY U.s.s. H ECTO R AR 7

'C/D FLEET POST OFFICE SAN francisco, CALIFORNIA 96643 ECIMINST 9090.IC 04:G:ddy 0 8 007 1986 WS ECKR (AR 7) INS 1HETKN 9090.IC Subj: QmLITY ASSUWG PRO @#d RR 11E PACKIPG CF RADIO 5CTIVE MATERIAL Im 1RANSKRT #D TRANSIGATKN CF RADIOSCTIVE MATERIAL (NJER ORTAIN (DOITKNS - (10CFR71)

Ref:

(a) U.~.S. Nuclear Regulatory Ccmn'ission Wterial License #04-18130-01 (b) Code of Federal Regulations Title 10, Part 71 (10GR71)

(c) Code of Federal Regulations Title 49 Encl:

(1) Radioactive Wterial Packing Quality (RWQ%) Progran 1.

Background. MS ECKR (AR 7) is authorized by reference (a) to use certain radioactive nuterials aboard WS ECKR and on ships and in areas where MS ECKR is operating.

In the course of exercising this authoriz-ation, scme of these nuterials are shipped to and fran civilian suppliers who are likewise licensed by the PSC to provide these nuterials. A recent revision to reference (b) requires the developTent of a progran as follows:

"The licensee shall establish, nuintain and execute a quality assurance program satisfying each of the applicable criteria specified in appendix E,

' Quality Assurance criteria for shipping packages for radioactive nuterial',

and satisfying any specific provisions which are applicable to the licensee's activities, including procurement packaging."

2.

Cancellation. ECKRINST 9090.lB 3.

Scope. This instruction applies to all radioactive rmterials covered by reference (a). As an end-user it is not intended that GS ECKR engage in the nunufacture or alteration of shipping packages. Rather, this progran is designed to ensure that the quality of the shipping packages received is initially certified by the supplier and nulntained while such packages are in the custody of MS HCKR. This instruction is not to be construed in any case, as a relaxation of the requiremnts in reference (a) or other directives of higher authority.

4.

Action. This instruction provides for procedures necessary for the satisfactory establishrent and execution of the quality assurance progran for use in packaging, shipnent, and transportation of licensed rmterials by WS WCKR.

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Distribution:

WCKRINST 3120.lA Lists-I, Case A 8701150100 861008 PDR ADOCK 07100385 C

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FECKRINST.9090. lC 0 8 OCT 1986 eye OfME MTE &

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IECKRINST 9090.lC 08OCT1916 TABLE OF ENTENTS PKE IWIRENTIE INSIBUCTICNS i

REERD & G4ES ii TABLE CF GNTENTS ii1 OEFINITim S iv GGANIZATICN 1-1-5 QALITY ASSLR4G 2-1-2 DOC 1]ENT CDGO.

3-1-1 H40.IK, SIGM NO SHIPPim 4-1-1

-INSPECTICN, TEST NO CFERATim STATUS 5-1-1 QlRI.lTY ASSLRYG REERDS 6-1-1 NDITS 7-1-1 Enci (1) lii

e ifCImlNST 9090.lC 08 OCT 5 QlMLITY ASSUWG PRO @AM RR llE PKKIPC OF RADIQaCTIVE M41FAIAL RR 1RANSKRT MO 1RaNSRRTATIW

& RaDIQaCTIVE MATERIAL LNER RTAIN GPOITimS (100R71 U. S ttK1 EAR REGLAlmY CDMISSIN MATERIALS LI NSE to. 04-18130-01

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03 LIO NSEE EEPAR1MNT & 11E NAVY USS IECKR (AR 7)

FEO SAN FlWCISCD 96643

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ifCKRINST 9090.lC D 8 OCT 1906 TFINITICNS The following terms are defined as they are intended to be used in this instruction:

OR - Code of Federal Regulations Licensed Activity: Licensee - USS ECKR (AR 7)

Licensed Materials - Those nuterials for which USS IfCKR holds an Nuclear Regulatory Cannission(f@C) approved license r@C - U. S. NJclear Regulatory Cannission NX Laboratory - Non-Destructive Test Laboratory TPackage - A shipping container for licensed radioactive materials W Of ficer - The Quality Assurance Of ficer ior the RWQA, 01arged with inspecting and auditing to verify the'progran W Progran - Quality Assurance Progran for the packaging of radioactive material for transport and transportation of radioactive nuterial under certain condtions (100R71)

RSO - Radiographic Safety Officer ARSO - Assistant Radiographic Safety Of ficer - The senior radiographer within the licensed activity J

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leCItRINST 9090.1C

.,A 8 OCT M106 SBCrKN CNi - CBGWIIATIN 1.1 Purpose. This section sets forth the organizational responsibilities in the IW Program.

~ 1.2 Description. De IBRA Program is conposed of five levels of responsibility.

a.

Camanding Of ficer. By definition the senior official of the licensed activity, he is responsible for the establistnent and execution of

. the IW Program. Revisions.to the program may be _autorized only by him.

3e Comanding Officer assigns and certifies the qualification of the IW Officer.

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b.

Repair Officer.

In his role as Head of Department which actually uses licensed naterials, the Repair Officer has vested interest in the 144Q4 Program. Therefore, he is responsible for ensuring that the IBMA Of ficer has sufficient organizational freedom to fulfill his function,and for ensuring that corrective. action (s).is/are acconplished in_ an ef fective, timely nanner and is/are not being delayed by production schedules or other conflicts.

c. -Radiographic Safety Officer (RSO). Either the Quality Assurance Officer or the Non-Destructive -Test UUT) Laboratory supervisor is nomally assigned as.the RSO.

In addition to his responsiblities for ensuring the

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safe receipt, handling, operation and shl ment of licensed materials used in i

radiography, he is responsible for:

(1) Ensuring.that shipments of licensed naterials used by the NX Laboratory are conducted in accordance with references (a), (b) and (c).

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(2) Ensuring that required inspection and testing incidental to L

shipnent of licensed nuterials used by the POT Laboratory are properly conducted and docmented, f4 (3) hintaining records of shipments as required in later. sections of this instruction.

(4) ' Ensuring that corrective action, when required, is acconplished in an ef fective, timely nunner by Per Laboratory personnel.

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- (5) Ensuring that personnel under his cognizance to process licensed L

. materials are trained in the requirments of this instruction and references l.

_a) and (b).

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d. ! Assistant Radiographic Safety Officer (ARSO). 'Ihe 4 8 PCT 1986 Senior Radio-grapher within the licensed activity not fulfilling the position of RSO will be assigned as the ARSO. 'In addition to the safe receipt, handling, operation and shipment of licensed material used in radiography, he is responsible for:

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(1) Ensuring that shipnents of licensed materials used by the ICT 1.aboratory are conducted in accordance with references (a), (b) and (c).

(2) Ensuring that required inspections and testing. incidental to shipments of licensed materials used by the ICT 1.aboratory are properly conducted and docmented.

(3) Physical maintenance of records for shipments as required by the RSO and in later sections of this instruction.

(4) Corrective action' when required is acconplished in an ef fective timely nunner.

(5) Training of personnel under his cognizance, d o process licensed material, in accordance with the requiremnts of this instruction and references (a), (b) and (c).

(6) Perfonning the duties of the RSO in his -absence in accordance with the instruction,' and references (a), (b) and -(c).

e.

16 Of f icer. The I W Officer shall be certified as to his qualification and appointed by the Camanding Officer. His primary function "in the IW Program is the verification of the credibility of the program.

In this regard he is responsible for:

(1) ' Development of an audit schedule for approval by the Camanding 6

(2) Conducting or directly supervising the conduct of all audits of' 3-

, s the IW Program.

(3) Conducting or directly supervising the conduct of unannounced spot checks of the IW Program.

(4) Reporting his findings directly to the Camanding Of ficer with copies to the Repair Officer and RSO.

(5)

Conducting follow-up audits to ensure corrective action is accmplished.

1.3 Appendices. Appendices A and B to this section contain and organization chart and matrix graphically display the division of responsiblity of the above function into four levels of responsiblity.

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4 ECKRINST 9090.lC 08 OCT 1986 SECTICN OE APfB DIX "A" CIGWlZATIOML OMRT GMftOffG

&FI R W

REPAIR GFI R GFI&R RADIGR RilC SAETY GFI R I

ASSISTANT RADIOGRAR-ilC SAETY GFI R l-3-4

IfCKRINST 9090.IC 08 00T 1986 SrcrICN OE APPEfOlX "B" RESICNSIBILITY MA'IRIX

' ASSIST /NT RADIO @ARilC RADIO @NNIC CDMVOIPC REPAIR SAFETY SAFETY W

IUCTKN GFIGR GFIGR GFI&R TFI R GFI R PRO @/M A-E E

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1RAINifG A

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GRTIFICATKN B.

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DOWENT OffCES A

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SHIPPIPG A

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b IECKRINST 9090.lC 08 DCT 126

' SBCTICN 1110 - QLALITY ASSLR#G PROGRM4 2.1.' Purpose. As the ' final responsibility for the Q4 Progran as specific by reference (b), requirements rests with'IECKR, this section specifies the 1 '

necessary action which nust be undertaken to successfully establish and execute a viable quality assurance progran for packaging licensed materials.

2.2 Discussion. USS IECKR-is licensed to use certain radioactive materials as specified in reference (a). As an end-user ifCKR receives these materials i

. fran IPC licensed supp!!ers in MC approved containers. - Therefore, the-thrust of the Q4 Progran on board IECRR shall be directed toward establishing proof of and maintaining the quality of provided containers. 2 nufacture or repair of shipping containers for licensed materials' shall not be conducted aboard IECKR without prior approval by the MC.

~ 2.3 Procedure a.

The promigation and enforcement of this instruction by appropriate

. levels of the chain of comand establishes and inplements the RWQ4 Progran.

E b.

Training and experience for all RWQ4 Progran functions shall'be in accordance with the established procedures:

(1) The Carmanding Of ficer and Repair Officer are specifically assigned by' the Naval Military Personnel Camand in accordance with established directives.

(2) The RSO shall be assigned by the Comanding Of ficer in accord-ance with reference (a).

(3) The RWQ4 Of ficer shall be assigned and certified by the Comanding Of ficer.

(4) Radiographers shall be qualified in accordance with reference c.

Oanges to the Q4 Progran may be trade only by a formal change to this instruction signed by the Camanding Of ficer. Changes which would significantly alter the progran nust be approved by the MC. Each change shall be entered in the nunner directed by the change and doctmented on the Record of O anges page.

d.

Prior to use, all defined quality control procedures, engineering

, procedures, and specific provisions of the package design approval shalI be satisfled. Additionally, the QA Progran will arphasize control of critical safety characteristics for any shipping packages used in cor. junction with i

. llcensed material.

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IfCRRINST 9090.IC (1) Doctnentation of this = shall be maintained on bokrbb for any contractor-supplied shipping containers for use with licensed materials.

(2) Specific approval by the f@C shall be obtained, docunenting the

- above attribute prior to locally fabricating, repairing, or altering a shipping container for use with licensed naterials.

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}ECKRINST 9090.lC 0 8 DCT 1986 SELTKN 1}SEti - DOC 1MNT GNIR1 3.1 Purpose. This section describes requirements for the control of documents related to shipping packages.

3.2 -Procedure. Each doctment related to a specific shipping container shall, dere necessary, be processed in accordance with Naval. Supply Systems Chmand directives in the course of receiving of shipping licensed materials. Men not required to be in custody of IECKR's Supply Officer, or others, for review, doctments shall be maintained in the custody of the RSO.

It is anticipated that no doctment changes should be required. Ibwever, if the need arises, changes will be acconplished only with permission of the Camanding Officer and in accordance.with appropriate procedures.

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c, ECItRINST 9090.lC 08W W SecTlav fu.R - H9{ LIPO, 51GW

, M O SHIPPIrG

.4.1 Purpose. A ls section describes those aspects of handling,. storage and.

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. shipping of packages which are inportant to safety and includes assigment of.

responsibilities for the critical aspects of handling, storage, and shipping.

4.2 Discussion a.

Established safety restrictions as delineated in reference'(a) concerning the handling, storage, and shipping of packages for special~ form of radioactive material will be followed. Shiprents will not be made unless all tests, certifications, acceptances, and final inspections have been conpleted.

% rk instructions have been provided for handling,. storage, and shipping operation for those containers in use. % rk instructions will be provided for

' hand!!ng, storage and shipping operations for those shipping containers conterplated for future use.

b.

The responsibilities of certain personnel involved in the IBRA Progran are described in Section One. H is section provides anplification of those responsibilities by specifying requireTents for the aspects of handling, storage and shipTent of packages which are considered critical.

4.3 Procedure a.

The Radiographic Safety Of ficer is responsible for the critical handling, storage and shipping operations for each shipTent of licensed material by the ITE Laboratory. He shall ensure, for each shipping container, that the ARSO performs the following operations:

(1) Establishing safety restrictions concerning the handling, storage, and shipping or packages for certain special fonn and radioactive material are followd.

(2) Ensuring that shipnents are not made unless all tests, certification acceptances, and final inspections have been carpleted.

2 (3) Ensuring that work instructions have been provided for handling, storage, and shipping operations.

b.

%ile in the custody of USS IfCKR, shipping containers for use with licensed naterials shall be controlled such that those characteristics of the package which are critical to safety are maintained.

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(1) Damage to shipping containers shall be reported irmediately to the Radiographic Safety Officer.

(2) Shipping containers for use with licensed radio shall be naintained and used in accordance with reference (a) graphic sources h

They shall be stored in the radiography vault when not in use.

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IECKRINST 9090.1C

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SBCrim FIVE - INSPECTIN, TEST #O CPf3MTifG STA1US 5.1 Purpose. 'lhis ;section describes those aspects of inspection, test and operating status of packages which are inportant to safety and includes assigment of responsibilities for the critical aspects of inspection, test, and operating activities.

5.2-Discussion a.

Inspection, test, and operating status of packages for certain special form radioactive material will be indicated and controlled by established procedures. The status will be indicated by the tag, label, marking, or log entry. H e status of non-conforming parts or packages will be positively maintained by established procedures.

b.

The responsibilities of certain personnel. invoIved in the W Progran are described in-Section Ole. This section pro'vides arrplification of those responsibilities by specifying require 7ents for the aspects of s

inspection, test, and operating status which are considered' critical.

5.3 Procedure a.

The Radiographic Safety Of ficer is responsible for the critical inspection, test and operating activities _ associated with each shipping container which rray be used for shipment of licensed rnaterials, by the FOT Laboratory. He shall ensure, for each shipping container, that, the ARSO performs the following operations:

s (1) Inspection, test and operating status of ' packages for certain special form radioactive material is indicated and controlled by established procedures.

'(2) Status is_ indicated by tag, label, marking or log entry.

(3) Status of non-conforming-parts or packages are positively naintained by established procedures.

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ifCKRINST 9090.lC 0 8 OCT W SBCrKN SIX - QUA1.lTY ASSUWCE RECGDS 6.1 Purpose. This section provides the necessary _ requirements and guidance -

for satisfactorily docunenting the operation of the I W Program aboard USS lECKR.

6.2 Discussion. Adequate docunentation will be maintained to demnstrate to interested parties.that _USS ifCKR possesses an ef fective functional RW Progran. To this end the following actions shall be taken:

a.

Records will be maintained and include operating logs, inspections tests, and audit results.

b..Other records to be maintained will include qualification of personnel and descriptions of. procedures and equipTent.

c.

Records will be maintained according to established procedures.

d.

Records will be identifiable and retrievable.-

e.

A list of-the required records and their storage location will be maintained..

~6.3 Procedure a.

The IW Of ficer shall maintain the original audit reports for all:

audits and shall risintain a master listing (index) of all required records which show their location.

b.

De Radiographic Safety Of ficer shall maintain all other records. He shall maintain then in an auditable fashion, i.e.,

they shall be identifiable and retrievable. R ese records shall include,-but not limited to:

(1)- Operating logs, inspections, and tests.

(2). Qualification of personnel.

(3) Description of procedures and equipnent.

(4) Records of shipnents.

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T:CHRINST 9090.IC SECTKN SEVEN-- ALDITS 08 OCT 1986

.7.1 Pur>ose. His section specifies the requirerents which rmst be met to establisi an effective audit progran.

7.2 Discussion a.

Established schedules of audits of the 16@ Progran will be.

perfomed. Each activity will be-audited.at least once a year... Auditors-shall have no day-to-day responsibility in the activity being audited.

Results of alI audits wi11 be reported to the Ormanding Officer, with copies

.to the repair of ficer and radiographic safety of ficer. Audit reports will be-evaluated and deficient areas corrected. De audits being perfomed will be-dependent upon the safety significance of the activity being audited. -Audit reports will be maintained as part of the quality control records.

7.3 ' Procedure a.-- Audits shall be conducted by or under the direct supervision of the IB Q Officer.

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b.

An audit of each receipt or shiprent shall be conducted two weeks

-following that receipt of shiprent.

c. - Seni-annually - A caTpleted audit of the W Progran will be conducted. He specific dates shall be approved by the Camanding Of ficer.

d.

The signed audit report shall be forwarded to the Camanding Of ficer

on.the carpletion of each audit. Copies will-be provided to the Repair E Officer and Radiographic Safety Officer..

De Repair Of ficer will receive proposed corrective actions and e.

assign ccrrpletion dates.

L f.: The original audit reports and original records of corrective action

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shall be naintained in an auditable fashion by the RQ Of ficer.

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