ML20246D314

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QA Program 99-QAP-002, Use,Maint & Repair of Shipping Packages for Radioactive Matl
ML20246D314
Person / Time
Site: 07100216
Issue date: 08/14/1989
From:
CONAM INSPECTION
To:
Shared Package
ML20246D310 List:
References
99-QAP-002, 99-QAP-2, NUDOCS 8908250329
Download: ML20246D314 (10)


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CONAM INSPECTION, INC.

DIVISION RADIATION SAFETY OFFICE 6106 ROOKIN STREET HOUSTON, TEXAS 77074-3792 (713) 774-9657 QUALITY ASSURANCE PROGRAM 99-QAP-002 USE, MAINTENANCE AND REPAIR OF SHIPPING PACK.TGES FOR RADIOACTIVE MATERIAL i

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1}-1-78 EWSIN: 2 issuto:

8-14-89 QA PROGRAM 99-QAP-002 CONAM INSPECTION, INC.

QUALITY ASSURANCE PROGRAM 99-QAP-002 REY. NO.

DESCRIPTION DATE APPROVED BY

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T. Powers ( For Appendix Signature see original 1

Sections (6.0)(7.0)

"A" 4-20-79 document).

2 Complete Revision to remove all

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Radiation Safety Officer Date:

11-1-78 Prepared By:

{ Title Approved By:

President Date: 8-14-89 Title l

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-89 QA PROGRAM 99-0AP-002 TABLE OF CONTENTS 1.

INTRODUCTION PAGE.i 1.0 ORGANIZATION.................................

PAGE 1

2.0 QUALITY ASSURANCE PROGRAM....................

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3.0 DOCUMENT CONTROL.............................

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4.0 HANDLING STORAGE AND SHIPPING................

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5.0 INSPECTION, TEST AND OPERATING STATUS........

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6.0 OUALITY ASSURANCE RECORDS....................

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7.0 AUDITS.......................................

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APPENDIX A.........................................

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11-1-78 OA PROGRAM 99-QAP-002 REVISION:

2 ISSUED:

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INTRODUCTION

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This Quality Assurance (QA) Manual specifies the program to be implemented by CONAM INSPECTION, INC. (CONAM) to comply with the requirements of 10 CFR, Part 71, " Packaging of Radioactive Material for Transport and Transportation of Radioactive Material Under Certain Conditions".

Radioactive materials referenced in this OA Manual are those special form materials licensed by the Nuclear Regulatory Commission under 10 CFR, Part 34 and by agreement states.

This OA program is mandatory for all elements of CONAM, whose activities effect the proper implementation of this program.

This QA Manual supplements the requirements of the CONAM Radiation Safety Program, as defined in the companies:

By-product Materials License's Operating and Emergency Procedures Manual Administrative Manual and Radiation Safety Office Directives i

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11-1-78 tssuto:

8-14 - QA PROGRAM' 99-QAP-002-l:

1.0 Organization 1.1 General-

!The final responsibility */ for the Quality Assurance (QA)

Program for 10 CFR, Part 71' requirements rest with CONAM-INSPECTION,' INC. (CONAM).

Design _and Fabrication-shall not.be conducted under this QA-Program.

The QA_.

Program is implemented using the organization ~ described in Appendix "A".

1.2 Responsibilities 1.2.1-Radiation. Safety Officer (RSO).

The RSO hasLthe primary responsibility for implementing'this program.

He will assure that the procedures required by this manual are prepared and distributed.- He will monitor implementation of this-program as part of.

the radiation safety audits.

1.2.2 - Radiation Saf ety Program Members The Radiation Safety Monitors, Managers,. Assistant Managers and Supervisors are responsible for implementing this program within their respective operations.

1.2.3 Authorized Shipper The detailed implementation of this program shall be accomplished by-individuals authorized to ship-sealed sources.

As a minimum, authorized shippers shall be qualified radiographer in accordance with CONAM's Radiatior. Safety Program who have had specific instructions regarding this program and its implementing procedures.

2.0 Quality Assurance Program 2.1 CONAM Radiation Safety Personnel shall be responsible for-implementing this program.

2.2 Training 2.2.1 Authorized shippers shall receive indoctrination in this manual and its procedures.

The indoctrination shall be provided by members of the Radiation Safety Program and shall be documented.

A copy of the documentation shall be placed in the individuals Radiation Safety Qualification file.

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a_14_gg QA PROGRAM 99-QAP-002 2.2.2 Members of the Radiation Safety Program shall be instructed in this program by the RSO or Radiation Safety Managers.

This instruction shall be i

documented and filed in the individual's Radiation Safety file.

2.3 Revisions Revisions to this program require the approval of the Radiation Safety Officer.

2.4 The key elements of CONAM'S QA Prcgram for shipping sealed sources are:

2.4.1 The assurance by the Radiation Safety Officer that all radioactive material shipping packages are designed and manufactured under a QA Program approved by the Nuclear Regulatory Commission for all packages designed or fabricated after July 1, 1978.

(This requirement can be satisfied by receiving a certification to this effect from the manufacturer).

2.4.2 All defined Quality Control (QC) procedures, engineer-ing procedures and specific provisions of the package design approval are satisfied.

2.4.3 The characteristics of the package critical to safety are controlled.

2.4.4 The characteristics of the package critical to safety are controlled.

a.

Adequate labeling of shipments.

b.

Proper preparation of shipping documents.

c.

Inspection and testing of shipments for authorized radiation levels.

3.0 Document Control All documents involved in shipping radioactive sources shall be controlled and retained as QA records.

3.1 Preparation and distribution of shipping documents shall be in accordance with CONAM's procedure for shipping radio-active materials as contained in the CONAM Operating and Emergency Procedure Manual (O&E).

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-QALPROGRAM'.99-QAP-002 3.2

'Any' change in a shipping document shall be accomplished by' lining through the erroneous entry, listing the. proper entry, initialing and dating the correction.

3.3 Shipping documents shall be maintained in the regional and division offices as required by the CONAM Administrative Manual.

4.0 Handling, Storing and Shipping 4.1

.The O&E procedure for shipping of radioactive. sources shall-be observed for all shipments by common carrirr.

4.2 The O&E procedure for transporting radioactive sources in company vehicles shall be followed when transporting sources on public highways.

4.3 Only authorized shipping containers and exposure devices as listed in the By-product Material License shall be used'for shipping sources.

4.4 Radioactive sources shall be stored as required by the O&E.

4.5 Only qualified radiography personnel shall perform the critical handling, storage and sh.oping operations.

5.0 Inspection, Test and operating Status 5.1 The operable status of shipping containers shall be verified by the actual survey of the container when loaded with radioactive materials.

5.2 Pri.r to storage, sources containers shall be tested by mea:uring the radiation levels at defined distances from the surface as stated in the O&E.

These surveys are recorded in the Daily Radiation Report as required by the O&E.

5.3 Prior to release for shipping, the shipping container shall be surveyed es required'by the shipping procedures in the O&E.

The survey results are to be entered on shipping labels, documents and reports as required by the O&E.

The attachment.

of a completed shipping label on a shipping container shall represent a tag verifying the satisfactory functioning of this container.

5.4 Non-conforming Shipping Containers 5.4.1 Non-conforming shipping containers are defined as those which fail the inspection and tests specified above. Non-conforming containers shall not be used.

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'OA:PROGRAMf99-QAP-002 8-14-89'

'5.4.'2 Shipping containers belong to.CONAM suppliers may be used as authorized in CONAM's By-product Material Licenses.

Said suppliers shall be.

notified if their container fails to' meet the tests required above.

Another shipping container shall be obtained-for the shipment and the non-conforming container shall be returned empty to the supplier.

6.0 Records Records as required by t his program. shall be retained' as -

required by CONAM's Administrative Manun1.

6.1 QA records shall include; operating logs, results of inspections, test and audits; qualification of personne3, 3'

procedures, and equipment; and records-of receipt and shipment.

7.0 Audits Audits of the implantation of this Quality Program shall be included in and performed as part of the Radiation Safety Audits as~ required in CONAM's licenses and referenced documents.

7.1 Audits will be conducted at least once each year using a written checklist.

Results of audits will be maintained and reported to management.

7.2 Audit reports will be evaluated and deficient areas corrected.

7.3 Auditors shall have no responsibility in the activity 1

being audited.

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