ML20246M391

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Corporate Radiation & Administrative Control
ML20246M391
Person / Time
Site: 07100093
Issue date: 08/18/1988
From:
HUNTINGTON TESTING
To:
Shared Package
ML20246G240 List:
References
25886, PROC-880818, NUDOCS 8909070147
Download: ML20246M391 (24)


Text

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'4 HUNTINGTON TESTING. INC.

Y Section 1 Index 5/18/85 HUNTINGTON TESTING. INC.

CORPORATE RADIATION AND ADMINISTRATIVE CONTROL 1.

ORGANIZATION CHART " RADIATION SAFETY" 2.

SCOIE 3.

DEFINITION OF TERMS 4.

RESPONSIBILITIES 5.

RADIOACTIVE MATERIAL INVENTORY 6.

LEAK TESTING 7.

RADIATION SURVEY INSTRUMENT CALIBRATION 1

8.

PERIODIC EQUIPMENT INSPECTION 9.

AUDIT OF RADIOGRAPHIC OPERATIONS 10.

QUALITY ASSURANCE PROGRAM AS REQUIRED BY 10 CFR-PART 71 t

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HUNTINGTON TESTING, INC. ORGANIZATION CHART RADIATION SAFETY Corporate President W.' YEOMAN Radiation Safety Officer C.MAY Radiographic Personnel L:- ---

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Section 1 Page 1 of 18 l

5/28/88 j

1.0 SCOPE 1.1 The radiation controls and procedures set forth in this document are designed to protect not only the Radiographic Personnel who, by the nature of their work, may be exposed to radiation but to assure that all personnel at various field sites are also protected.

1.2 Radiation in common with toxic chemicals, combustible materials and high voltage electricity as well as other potential hazards are capable cf inflicting bodily harm if used improperly and without due regard to safety.

In some measure, radiation is more of a hazard in that it cannot be seen, felt, heard or smelled.

1.3 The Radiation Administration Control, Operating and Emergency Procedures contained herein are in conformance with the provisions of the following Federal and State Agencies:

1.3.1 U.S. Nuclear Regulatory Commission 1.3.2 States that have entered into an agreement with N.R.C.

transferring regulatory authority over by-product materials to that State.

1.3.3 Rules and regulations of non-agreement States pertaining to radiation protection.

1.3.4 U.S. Department of Transportation.

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Section 1.

Page 2' of 18 5/28/88 DEFINITION OF TERMS USED IN THIS DOCUMENT

'2.0 DEFINITIONS:

- 2.1 "By-Product M ateri al" means any radioactive material (except special nuclear Material) yielded 'in or made radioactive ' by exposure to the radiation incident to the process of producing or utilizing special nuclear material.

2.2 " Radiation" means any or all of the following... Alpha Rays, Beta Rays, Gamma Rays and X-Rays.

2.3 " Radiation Area" means any area where radiation exists at such levels that a major pottion of the body could receive in any one hour, a dose in excess of 2 MR.

2.4 "High Radiation Area" means any area in which there exists radiation at such levels that a major portion of the body could receive in any. one hour a dose in excess of 100 MR.

2.5 " Curie" is a unit of activity kr measuring the quantity of radioactive material.

One (1) curie yields 2.7 x 10th power (3.7 - billion) disintegrations per second.

2.6 " Roentgen" (R) is the unit of measurement of X-rays and Gamma Rays absorbed in air, it is a measure for the absorption of X-rays-and Gamma Radiation in the same sense that feet of inches are a measure of length.

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2.7. " Milliroentgen" (MR) is 1000 of a roentgen (R).

2.8 "Survev" means :neasuring radiation intensities at various locations in an area where radiation exists.

2.9 " Survey Ch art" is an outline or sketch of the location where a radiation L

survey is taken and-the recording of the result of the curvey.

Form 1 RT-2 Section 11 will be used in conjunction with all radiation surveys.

2.10 " Monitoring" is the act of surveying or measuring with instruments, pocket dosimeters or film badges, the amount of radiation present or 1:

accumulated.

2.11 " Radiation Signs" are painted magenta or purple on a yellow background with the conventional three bladed symbol conforming to AEC requirements.

The degree of radiation present is indicated in the wording.

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Section 1 Page 3 of 18 5/28/88 DEFINITION OF TERMS USED IN TIIIS DOCUMENT 2.12 " Scattered Radiatin" results from the deflection of primary rays as they interact with the atoms in materials such as air, steel, concrete or lead shields and may emerge from the exposed material in any direction.

That scattered in a forward direction "the direction of the primary radiation" has higher energies that scattered in the opposite (Backscatter).

2.13 "Eldridine Material" is any material used to absorb or reduce radiation intensity levels.

2.14 " R adio gra phic Exoorure D aice" means any device that is AEC or Agreement State approved and is designed to contain a sealed source which may be moved or otherwise changed from a shielded to unshielded position for making a radiographic exposure.

2.15 " Sealed Source" means any by-product material that is encased in a capsule designed to prevent leakage or escape of the by-product material.

.2.16 "Stora ge Container means a device in which sealed sources are stored.

2.16 "B y-Prod u ct Material Shionine Container" means a device in which by-product materials are transported.

The design ar.d labeling of these must conform to AEC, State and U.S. Department of Transportation Requirements.

2.18 " Rem" as used in this section is a measure of the dose of ionizing radiation to the body tissue in terms of it's estimated biological effect (RBE). One " millirem" - one (R) of X or Gamma Radiation.

2.19 " Pl a nt or Construction Personnel" means all employees not directly concerned with radiation or any other personnel who may be at a plant or construction site.

2.20 " Radiographic Person nel" means all personnel directly connected with radiographic operations.

2.21 "Special Jigs and Fix tures" are devices designed to position sources for radiographic exposures where source tubes provided by the original manufacturer of a radiographic exposure device cannot be used.

Any Huntington Testing manufactured device that alters or replaces any part of the original approved exposure device must have NRC or Agreement State approval prior to use.

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Section 1 Page 4 of 18 5/28/88 RESPONSIBILITIES 3.0 RESPONSIBILITIES 3.1 The " Radiation Safety Officer" will be responsible for the enforcement of Rules, Regulations and Procedurec involving the safe handling and use of toy-product materials and X-ray generating equipment in the possession of Huntington Testing, Inc.

Records, equipment and radiographic personnel will be audited by him at frequent intervals to assure compliance with regulations and procedures pertaining to radiation safety.

In addition he will be directly responsible for carrying out the following duties.

3.1.1 Procedures, equipment cnd records will be monitored and evaluated for compliance with the rules and regulations of Federal, State and local Agencies and Huntington Testing pestaining to the safe handling and use of by-product materials and X-ray generating equipment.

3.1.2 He shall act as the licensee's liaison officer with the Nuclear Regulatory Commission and State Agencies on all license matters.

3.1.3 Establishes and conducts training programs for radiographic personnel.

3.1.4 Examines, determines competency and qualifies personnel to fulfill the functions described in 3.2 and 3.3 of Training Program.

'.. 5 Maintain control of procurement and disposal of licensed by-product material.

3.1.6 Maintains personnel monitoring programs.

3.1.7 Procures and maintains adequate radiation survey instruments.

3.1.8 Maintains adequate storage facilities.

3.1.9 Maintenance of exposure devices and related equipment.

3.1.10 Takes leak test swab to be forwarded to laboratory for rad:o-assay and maintains leak !sst records.

3.1.11 Conducts by product material quarterly inventories.

3.1.12 Monitors utilization logs i

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3.0 RESPONSIBILITIES (Cont'd) 3.1.13 Maintains the survey instruments that will have a range such that two milliroentgen per hour through one roentgen per hour can be measured.

Calibrates radiation survey instruments at intervals not to exceed ninety (90) days in accordance with Procedure 15.

3.1.14 Review radiation records not kept by himself.

3.1.15 Assumes control and institutes corrective action in emergency situations.

3.1.16 Investigates cause of incidents and determines necessary preventative action.

3.1.16 Supervises the shipment of transfer of by-product materials to insure compliance with the rules and regulations of the U.S.

Department of Transportation.

3.2 The " Radiographer" will be responsible for the safe use and handling of by-product materials and X-ray generating equipment while performing a radiographic assignment.

He sha'l ascertain that all regulations, rules and procedures pertaining to rasiation safety are strictly adhered to, prior to, during, and after taking a radiographic exposure.

Any deviation from written procedure is strictly forbidden.

3.3 Physical Examinations:

3.3.1 Pre-Emniovment Physical Examination 3.3.1.1 A complete radiation history will be obtained whenever possible in order to determine if the applicant has I

i previously received any significant exposure to radiation.

3.3.1.2 Each applicant will receive a

complete physica!

examination including a blood count and urinalysis.

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3.3.1.3 Where an applicant has pre-existing blood abnormalities, j

such as a persistent anemia, he shall not be assigned work where it is possible to be exposed to ionizing radiation

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Section 1 L

Page 6 of 18 5/28/88 RESPONSIBILITIES 3.0 RESPONSIBILITIES (Cont'd) 3.3.2 Periodic Physical Examinations 3.3.2.1

" Radiation Personnel" will be given a complete physical examination at least once a year.

Examinations will include a blood count and urinalysis.

3.3.2.2 In the event a film badge report indicates a radiation dosage in excess of 1250 MR has been received by an individual, he will be given a physical examination including a blood count and urinalysis, regardless of the time of his previous examination.

4.0 PERSONNEL RADIATION RECORDS:

4.1 Film badge monitoring records will be retained indefinitely by Huntington Testing, Inc.

4.2 All radiation exposure reports that are required in " Personnel Monitoring" Procedure (Number II of Section II) will be retained in the same manner as film badge monitoring records.

5.0 MANDATORY PERSONNEL MONITORING REPORTS CFR TITLE 10 -- CHAirrER I, PART 10 5.1 Within the first quarter of each calendar year a personnel monitoring report indic.:ing the total number of individuals for whom monitoring was provided during the previous calendar year will be issued in accordance with Part 20, 20.407.

5.2 When an individual terminates employment or is transferred out of the department performing radiographic inspection, a

personnel monitoring report will be issued in accordance with Part 20, 20.408.

5.3 Upon the request of an employee or former employee, a radiation exposure record will be provided in accordance with Part 20, 20.409.

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Section 1 Page 7 of 18 5/28/88 RADIOACTIVE M ATERI AL INVENTORY

3.0 SCOPE

The following procedure describes the method of inventorying, each calendar quarter, all radioactive materials in the possession of Huntington Testing, Inc.

2.0 RESPONSIBILITIES

It shall be the responsibility of the Radiation Safety Officer or his representative to take by-product material quttterly inventories.

3.0 INVENTORYING PROCEDURE:

3.1 A quarterly physical source inventory will be taken of all sources received and in the possession of Huntington Testing, Inc.

3.2 January 1st will be considered the beginning of the first quarter of the year.

3.3 Source storage containers or exposure devices will be removed from their place of storage and place in an area where no radiation is present.

3.4 A calibrated radiation survey instrument will be positioned at the container surface and the radiation level noted.

3.5 Form 1-RT-04 will be used in recording the following quarterly inventory information:

Date of source inventory Source type (i.e. Cobalt 60 or Iridium 192)

Source serial number Source strength at day of inventory Initial of individual taking inventory Radiation-level at source container surface 3.6 Source inventory records will be retained in the files of Huntington

'l esting, Inc.

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Section 1 Page 8 of 18 5/28/88 LEAK TESTING

1.0 SCOPE

This procedure describes the method of taking leak tests of radioactive sources.

2.0 RESPONSIBILITIES

It is the responsibility of the Radiation Safety Officer or his representative to perform this test and to enstne that it is done at least every six months.

3.0 EQUIPMENT

3.1 A radiation survey instrument capable of reading

.1 MR per hour or less.

3.2 Technical Operations Inc. Leak Test Kit Model 518.

4.0 PROCEDURE

4.1 Remove plug from storage container or from source tube part of exposure device.

4.2 Wet the swab with EDTA solution.

Snake off excess solution and insert the swab into the hole of the container.

Wipe the interior of the hole thoroughly by rotating swab holder.

4.3 Withdraw swab and place in plastic envelope.

4.4 The swab is now to be monitored by turning the radiation survey instrument to it's most sensitive range.

Place the survey instrument in a low background area and move the swab in it's plastic envelope to the survey instrument.

NOTE: Move the swab, not the survey instrument.

'.5 If thc.e is no indication on the meter, or if the indication is no more than 0.2 MR per hour above background, put the plastic envelope with the swab in the provided mailing box; mail to Technical Operations, Incorporated, Burlington, M Massachusetts, with the T/O supplied leak test report for m.

4.6 If the swab should show more than 0.2 MR per hour, DO NOT M AIL.

contact Technical Operations, Inc., for specific instructions..

l 4.7 Fill out Form 1-RT-5 and retain in files.

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5/28/88 l

4 RADIATION SURVEY INSTRUMENT CALIBRATION -

1.0 SCOPE

This: procedure describes the methods and equipment required to calibrate radiation 1 survey instruments. in use at Huntington Testing, Inc.

2.0 RESPONSIBILITIES

' It is the responsibility of the Radiation Safety Officer or his representative.to calibrate radiation, survey instruments at least every calendar quarter and after repairs that may have affected an instrument's accuracy.

3.0., CALIBRATION PROCEDURE:

3.1 Radiation survey instruments.will. be calibrated veing Technical Operations Calibration Kit Model T/O 571 or Technical Operations Model.

  1. 773 Calibration? Unit.

3.2' Remove case of survey instrument, exposing the calibration adjustment screws for ~ each scale.

3.3A Victoreen 592-B Turn survey meter range selector lever to "zerc" position.

Allow a few minutes for the survey meter to " warm u p".

(If indicator drifts, additional ' time is required for " warm up").

Adjust knob on outside of survey meter so that the indicator points to "zero".

In the event that the meter. fails - to "zero", set screw knob at a halfway position and adjust "zero" set screw on the 'inside of meter. It is to be noted that the knob on the outside of the meter is for fine "zero" adjustments and the inside set screw is for coarser adjustments.

If the meter cannot be " zeroed", the batteries may be weak and must be replaced.

Then turn knob to the first scale.

3.3B Eberline E130G and #520 Turn instrument knob to battery check position.

Needle should enter the zone so marked on the meter face, if not, change the batteries. Then turn knob to the first scale.

3.3.C NDS ND-2000

' Exact.

Report of.3.3.B 1

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5/28/88 RADIATION SURVEY INSTRUMENT CAI IBRATION 4.0 PREPARATION FOR USE:

4.1 ' Remove from storage area and place the ' source shield in a restricted

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area. so that the directional pcrt is aimed horizontally.

To minimize the effects of scattered radiation, the unit 'should be at least 16 feet from any wall, in : the direction of the primary beam.

4.2 Position a support 10' long horizontally from the T/O-571 or T/O-773 directional. shield,- ar, shown on Drawing 57101.

t 4.3 Restrict access to an' area 10' from the container.

-5.0 SURVEY METER CALIBRATION:

5.1 On the bottom of the identification label is a dose / distance computer.

The source size and date of calibration is stamped. on the -identification label. Follow these steps: (1) Set the ege of the source shown on Scale A opposite the original source size shown on Scale B.

(2)

Tighten the screws holding the bottom scale.

Desired dose rates are shown on Scale C and you may read the correct distance directly below the dose rate desired.

5.2 Turn on your survey instrument, let it warm up for. about 10 minutes and zero the meter.

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5.3 Turn the range switch to the low range, and place the meter at the i

appropriate distance -(see dose / distance computer) for a 2.5 mR/hr reading.

The survey meter should be located so - that the center of the chamber, or detector, is at the correct distance and centered on the center line of the radiation beam.

The longest dimension of the ion chamber could be at right angles to the radiation beam.

Depending on the physical size and configuration of your survey meter, it may be necessary to mount the 571 source shield somewhat higher than the bench surface.

When the proper geometry for -your meter has been established, use the same physical set-up consistently in future i-calibration operations.

l A maximum dose rate of 1000 mR/hr can be obtained with certain survey meters in contact with the radiation port; however, the physical geometry of some survey meters may lead to incorrect readings at such a close distance.

Do not use less distance than the minimum distance which provides the correct maximum dose in accordance with the dose / distance computer.

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Section 1 l

Page 11 of 18 5/28/88 RADIATION SURVEY IN_STRUMENT CALIBRATION CAUTION The meter should be placed so that you can read it from a distance wittoout exposing yourself to the primary beam i

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Section 1 Page 12 of 18 5/28/88 BADI ATION SURVEY INSTRUMENT CALIBRATION 5.0 SURVEY METER CALIBRATION:

5.4 Stand A W A Y from the primary beam and open the source shutter.

This may be done by lifting the source rod manually, or remotely with a string attached to the source rod.

Check the reading on the instrument and then close the source shutter by allowing the source rod to drop to the stored position.

If the reading does not agr e within plus or minus 10% an adjustment is required.

5.5 in turn check two points on each scale using the correct distance indicated by the dose / distance computer.

The points to be check as follows:

Eberline E 130 G Scale Points XXI 2&8 X10 2&8 X100 2&8 Eberline E 520 XD 5 & 15 X.1 5 & 15 XI 5 & 15 X10 5 & 15 X100 5 & 15 Victoreen 592 B XI 2&8 X10 2&8 X100 2&8 NDS ND-2000 XI 2&8 X10 2&8 X100 2&8 5.6 On completion of the calibration, the source rod is to be dropped to the closed position, the locking bar inserted to prevent source movement, j

and the lock is to be locked and secared.

Return the source shield to storage are a.

5.7 Survey meters which cannot be calibrated should be returned to the manufacturer for repair.

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5/28/88 RADIATION SURVEY INSTRUMENT CALIBRATION 5.0 SURVEY METER CALIBRATION: Cont'd) 5.8 Fasten a label to your survey meter indicating the date of calibration.

5.9 The results of the survey instrument calibration will be recorded on Form 1-RT-6 and retained in the files of Huntington Testing, Inc.

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Section 1

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5/28/88 PERIODIC INSPECTION 1.0 SCOPE f

This procedure describes the method and frequency. of ~ making. a periodic inspection of radiographic test equipment.

2.0 RESPONSIBILITY

It is the responsibility of the Radiation Safety Officer to audit periodic inspection results

3.0 FREQUENCY

-~ Periodic inspection and. maintenance will be performed at least quarterly when equipment has been in normal use or after prolonged storage.

3.1 Normal use se, ned as equipment that has been in use forty-five (45) ~

or more days during any calendar quarter.

3.2' Prolonged storage is defined as equipment that has not been used-during any calendar quarter.

4.0 AUDIT

The audit results wili be recorded on Form 1-RT-8 and shall become a part of the permanent - records for each device.

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Section l' Page 15 of 18 5/28/88 AUDIT OF RADIOGRAPHIC OPERATIONS

1.0 SCOPE

The following procedure describes the method of auditing, at least once per calendar ' quarter, -all radiographic operations being performed by Huntington '. Testing personnel.

2.0 RESPONSIBILITIES

It. shall. be the responsibility of the Radiation Safety Officer to conduct these audits.

- 3.0 AUDIT PROCEDURE:

3.1' A physical audit of all radiographic operations will be undertaken at least once per calendar quarter.

- 3.2 -January 1st will be considered the beginning of the first quarter of the year.

i 3.3 Each temporary job-site will be audited for compliance with applicable procedures : and instructions, and will include the following:

a.

Review 'of all charts and reports required to be maintained as outlined in the ' pertinent operating procedures.

b.

Review of personnel operating techniques. with particular regard to-compliance with source handling procedures and the posting of high radiation areas.

c.

Condition of equipment labels and source identification tags.

- 3.4 Form 1 RT-7 will be used to record the necessary quarterly audit information as outlined in 3.3 above.

3.5' If any area of non-compliance is found during an audit, the RSO shall initiate whatever corrective action he deems necessary to insure compliance with Huntington Testing's Operating and Emergency Procedures. and pertinent Federal Regulations.

Such corrective action shall be recorded in the remarks column of Form 1-RT-7.

3.6 These records will be retained in the offices of Huntington Testing, Inc.

for a period of at least two years.

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1-RT-7 5/28/88 Internal Insoection Checklist I

Radiographic Location Date Time Radiographer inspector Radioisotope Curies Serial No.

Projector Serial No.

Projector Model No.

Survey Meter Model No.

Ser. No.

Calib. Due Y_Ci 19A

1. Was the radiographer wearing a film badge and dosimeter?
2. Were other individuals working within the restricted area wearing film badges and dosimeters?
3. Was the restricted area posted with " CAUTION (or DANGER)

RADIATION AREA" signs?

4. Was the restricted area properly controlled to prever:

unauthorized entry?

5. Was the high radiation area posted with " CAUTION (or DANGER) lilGH RADIATION AREA" signs?
6. Did the radiographer have a calibrated and properly operating survey meter?

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7. Was the utilization log properly filled out?
8. Did the radiographer have sufficient knowledge of safety rules?

(Ascertained by oral questions).

9. Was the radiographer working with defective equipment?

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10. Did the radiographer properly survey the source projector and source tube and take a radiation reading I foot (0.3m) in front of the source following the radiographic exposure?

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11. Were radioactive irstopes stored properly and kept locked to prevent unauthonzed removel?
12. Was the storage 'rea posted with " CAUTION (cr DANGER)

RADIOACTIVE MATERIAL" signs?

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5/28/88 Internal Insnection Checklist (Cont'd) i les Em i

13. Did the radiographer possess a copy of the applicant's operating and emergency procedures and, as applicable, State or NRC rules and regulations for protection against radiation 7
14. Were there any items of noncompliance other than those listed on this form?

(if any, explain in remarks).

Remarks l

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YY Section 1 Page 16 of 18 5/28/88 QUALITY ASSURANCE PROGRAM AS REOUIRED BY 10 CFR - PART 71

1.0 ORGANIZATION

1.1 The final responsibility for the Quality Assurance Program for Part 71 Requirements rests with Huntington Testing, Inc.

Design and fabrication or radioactive material shipping packages shall not be conducted under this Quality Assurance Program. The Quality Assurance Program is implemented using the attached organization chart.

1.2 The Radiation Safety Officer is responsible for overall administration of the program, training and certification, document control, auditing, and Part 71 Quality Assurance Requirements.

1.3 The Radiographer are responsible for handling, storing, shipping, inspection, test, operating status and record keeping.

2.0 QUALITY ASSURANCE PROGRAM:

2.1 The management of Huntington

Testing, Inc.

establishes and implements this Quality Assurance Program.

Training for all QA functions, prior to engagement in these functions, is required according to written procedures.

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

The QA Program will ensure that all defined QC procc dures, engineering procedures, and specific provisions of the package design approval are satisfied.

The QA Program will emphasize control of the characteristics of the package which are critical to safety.

2.2 The Radiation Safety Officer shall assure that all radioactive material shipping packager are designed and manufactured under a Quality Assurance Program approved by the Nuclear Regulatory Commission l

for all packages designed or fabricated after 1,

July 1978.

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

3.0 DOCUMENTCONTROL-I 3.1 All documents related to a specific shipping package will be controlled through the use of written procedures.

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

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3.2 The Radiation Safety Officer shall insure that all QA func' ions are conducted in accordance with the latest applicable changes to these documents.

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1 5/28/88 QUALITY ASSURANCE PROGRAM AS REOUIRED BY 10 CFR - PART 71 i

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' 4.0 HANDLING STORAGE AND SIIIPPING:

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I 4.1 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.

i 4.2' Radiography personnel shall perform the critical handling, storage and shipping operations.

5.0 INSPECrlON, TEST AND OPERATING STATUS:

5.1 Inspection, test and operating ' status of packages for certain 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 procedure.

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

The Radiation Safety Officer shall ensure that these functions are performed.

6.0 QUALITY ASSURANCE RECORDS:

6.1. Records of package approvals (including references and drawings),

inspections, tests,. operating logs, audit results, personnel training and qualifications and records of shipment will be maintained.

Descriptions of equipment and written procedures will also be maintained.

6.2 These records will be maintained in accordance with written procedures.

The records will be ' identifiable and retrievable.

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

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Section 1 Page 18 of 18 5/28/88 l

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OUALITY ASSURANCEPROGRAM A3 REOUIRED BY 10 CFR - PART 71 7.0 AUDTTS:-

7.1 Established' schedules of audits of.the. Quality Assurance Program will be performed using written checklists.

Results of audits will be maintained and reported ' to managements Audit reports will be evaluated and deficient' 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.

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