ML20204D452

Forwards Sample QA Program to Assist in Preparing Acceptable QA Program,Per 880907 Ltr & 880920 Telcon.Exempt Quantities of Fissile Matl Must Be Less than 15 G

ML20204D452
Person / Time
Site:	07100661
Issue date:	10/13/1988
From:	Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:	Bolon A MISSOURI, UNIV. OF, ROLLA, MO
References
NUDOCS 8810210148
Download: ML20204D452 (7)

Text

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O SGTB:LLG MI I I 71-0661 Ur,1versity of Missouri - Rolla ATTN: Mr. Albert E. Bolon, Director Nuclear Reactor Facility Rolla, Missouri 65401 Gentlemen:

This is in response to your letter dated Septerber 7, 1988, and subsequent tele-phone conversation on Septerrber 20, 1988, with Dr. M. Straka, Reactor Manager at your facility, concerning registration for use of the GA fechnology Model I shipping package.

You state in your letter that the contained ft.el rods in the shipment are less than 1 kilogram of U-235 and should be considered as an exempt quantity. However, pursuant to paragraph 71.53(a) of 10 CFR Part 71, exempt quantities of fissile material must be less than 15 arams, in order to register under the general license provisions of Section 71.12 of 10 CFR Part 71, you need to have an NRC approved QA program meeting the applicable requirements of Subpart 11 of 10 CFR Part 71.

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To assist you in preparing a QA program description acceptable to NRC, crc.losed is a copy of a QA program typically used by universities for "one-time" shipments of reactor fuel, to off-site locations. If we can be of further assistance please contact Mr. Len Gordon of my staff on 301/492-0482.

Sincerely, S

Charles E. NacDonald, Chief Transportation Branch Division of Safeguards and Transportation NMSS

Enclosure:

As stated DISTRIBUTION:

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QUALITY ASSURANCE PROGRAM FOR USE OF HODEL SHIPPING CDhTAINER REV. 0 (new)

JANUARY 15, 1988 Submitted in Accordance with 10 CFR 71.12 Licensee!

License! 6 Docket No. M I

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\ l Se QUALITY ASSURANCE PROGRAM FOR USE OF_

~ TYPE 6 SHIPPING CASK l

INTR 0_ DUCT 10N, ,

f This Qual!.tv Assurance Program (QA) is for the use of the 61, radioactive materials shipping cask (licensed,tofor Te

.) by the '

The program under which this cask vill be used is base considerations:

(a) S possesses one-hundred and eleven (111) irradiated TRIGA Mark III fuel rods.

(b) h is decommissioning the TRIGA reactor and must return the used fuel to the DOE.

(c) M does not design, fabricate, assemble, or test radioactive This QA Program is limited to leasing ownership cr lease to others.and use of the m . owned cask to accomplish the fuel to DOE.

The QA Program is submitted pursuant to 10 CFR 50, 10 CFR 71.12, 10 CF The Program outline follows Regulatory 71.101 and Title 49 Part 173.471.

Guide 7.10 (January 1983).

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1. Oreanizatiin_

The Reactor Administrator, reports to the Chairman of the Departeent of Nuclear Engineering who for the purpose of reactor administration, reports l

to the Chancellor of theThe Reactor Supervisor is responsible i d to the Reactor Ad I

the safe operation and maintenance of the reactor and its assoc a:e

. l equipment.

The Reactor Health Physicist is a member of the staff of the Campus Office of Environmental Health and Safety and is responsible for theHe reports to the radiation safety program in the Reactor Laboratory.

Campus Fadiation Safety Officer.

The Reactor Hazards Committee reviews, approves and audits matters of radiation health and safety pertaining to reactor operations and to each The Committee is directly responsible to The Vice stage of decommissioning.

Quality Assurance Supervisor h

M is responsible for establishing and implementing the- quality . The W assurance plan for defueling of the *

.' d l will report direct 1' to the Provost of the Professional Schools an-oblems, recomme l Colleges. The will identify qualiev out a verif y implementation of such solutio: . He will establish and carr) i comprehensive system of planned audits and surveillances to verify 9 - _

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compliance e f f ec.tivenes s .

with all aspects of the QA Program and to determine itsHe w hia activities throughout the deco...issioning project.

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2. Quality Assurance Pr'oiram*

_Tne scope of the program includes leasing, handling, loading, and U.S. Nuclear Regulatory Commission delivering (NRC) approved to aB(carrier for transport:)F radioactive shipping cask for return of irr diated The quantity of material to be shipped is fuel to the Pep'artment of Energy. fixed"1XPCfshe's to return this material to the DOE arti've portion of the pr'ogram will s* pan a period of no more than a few months.

Quality Control (QC) will be exercised primarily through the use of (a) federal regulatory requirements; written procedures constructed from:(b) lessor's instructions, procedures portfdns of campus radiation protection procedures.be effected by formatt individuals or their designates who are responsible for quality assurance.

A Qullity Assurance audit will be performed at the conclusion of the defueling.

3. Designing Control The cask lease agreement is to include the lessor's certificate that the design was accomgished IsIIder control of an NT,C-approved QA Program.

4. Lease Agreement Document Control,

~N) x-A checklist of lease documents will include: (a) the lessor's certification of item (3), above; (b) the lessor's instructions for handling ar.1 use of the cask; and (c) tne lessor's provision of other required or pertinent documentation such as the Certificate of Compliance, as-built drawings, sketches and use manuals.

5. Instructions. Procedures and Drawings 5.1 Preparation of Packaging for Use. The routine determinations of10 10 CFR 71.87, where applicable, will be subject to checklist assurance.

CFR 71.87 (h) and 10 CFR 71.45 are to be sa*.isfied by lessor's certifi-cation.

5.2 Repair. Rework and Maintenance. O will not undertake repair, Servicing, such is gasket replacement, shall be in rework or maintenance.

accordarce with lessor's specifications.

5.3 Loading. Loading shall be conducted under a plan of sufficient specificity to identif y and' {ulin(itative}y accountSurveys for all fue. conforming of radiation to ghippirfg' papers and incentory change 'repo4ts.fisTds and surface c 5.4 Transport.of Package. Upon delivery of packages to a carrier for transport, the'cofdition of the package, as evidenced by visus 1 insgection

vill be noted; the seals and labels will be recorded along with package f

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. A checklist identification by model and license registration numbers.

procedure will be used.

6. Document Control l

Control ahn11 be exercised over the following documents:

(1) Document checklist (2) Operating procedures (3) Inspection procedures (4) Loading Documents plans provided by lessor that relate to certifications, QC and (5)

QA (6) Radiation survey results (7) Shipping papers Procedures and checklists, and changes thereto are to be approved tive by either the Reactor Supervisor, the Reactor Health Physicist, or their respec designates.

and Services

7. Control of Purchased Katerial, Equipment, No special purpose matetfals or equipment are to be purchased for thic activity.

Services, such as a qualified reactor defueling contractor, crane and forklift trucks, and licensed carrier transport will be procuredl via of normal university procedures, with the Reactor Administrator's approva initiating documents.

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8. Jdentification and Control of Materials. Parts and Components

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Section 5.2, above, is applicable here.

9. Special Processes No special processes are to be undertaken under this program.

10. Inspection Control 10.1 Receipt Inspection. Inadequately identified packaging, or packaging which deviates significantly used from unless or until certifications, corrected drawings, or by lessor.

specifications, will not ba Maintenance other than prescribed servicing vill 10.2 Maintenance.

not be performed by .

10.3 Final Inspections. Checklists will be established to assures (1) Packages are properly assembled. Moderators and/or neutron (2)

(3) Shipping papers are properly completed.

(4) Packages are conspicuously and durably carked as required by the Department of Transportation (DOT).

(5) Pre- and post-loading radiation surveys have been co=pleted.

(6) Final inspection has been completed.

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' Inspection is to be jointly certified by the Reactor Supervisor and the Reactor Health Physicist or their designated alternates.

l 11. Protection Test Control 11.1 Use of Packages. Tests permitted, recommended, or specified by lessor will be used to establish a QA checklist.

11.2 Radiation survey results are to be compiled and records main-tained by the Reactor He.,1th Physicist Office of Environmental Health and Safety.

12. Contrcl of Measurine and Test Equipment As a lessee, f]h vill perform all required tests or inspections, asDocumentation req defined by the package lessor.

include a statement as to the currentness of the calibrations of pressure Radiation survey equipment shs11 be gauges and pressure relief valves.

raintained and calibrated in accordance with normal procedures of the jbdD Office of Environmental Health and Safety.

13. Handling. Storage. and Shipping 13.1 Handlins and Storage. Special handling and lifting equipment will be used in accordance with equipment specified or provided by the lessor, and accord *ng to conditions identified in the Certificate of See paragraphs Compliance, as well as instructions provided by the lessor.The cask vill be used promptl G 4, 5, and 6, above.it will be in protected storage until used, and shipped to the receiver of the fuel as soon as feasible after loading.

13.2 Preparation for Release and Shipment. Measures will be instituted to ensure that:

(1) Cavities are dry.

(2) Specified operations, inspections, and tests are verified by checklists.

(3) The Rector Supervisor is responsible for the observation 1

of NRC and O'T re,uirements, and for the p eparation of the shipping papers.

Quality Assurance vill be performed with checklists.

14 Inspection. Test._and Operating Status m

Status is to be tracked by a master checklist that acknowledges check-off of individual checklist completion.

15. Control of Nonconformine Materials. Parts, or Components Not applicable. Rework, repair, maintenance, or modification are not to be undertaken by 1 EEL

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16. Correction Actions.

It is the responsibilit) of the @ QC/QA Program to report conditions detrimenta) to quality to the lessor, who will be responsible for any corrective action required.

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Q 'ality Assurance Recer s_

Records showing evidence of delivery to a carrier under NRC and l DOT requirements shall be retained for a minimum of one year, except for Specia NuclearMaterial(ShM)transferandinven@toryrecordt.retainedforthe decocaissioning. Racords are duration of NRC licensing authority over is to be retained by the Office of Fnvironmental recordsHealth relatingand Safety, which to personnel also responsible for maintaining all exposures, radioactive material releases and shipments, and related radiation protectio & matters.

18. Audits The activity covered by the defueling program is a short-term effort.

The M 113 perform a close out audit The toReactor determine theCoenittee Hazards adequacy mayof the recorjs generated under this program.

perfore. its own audit of the overall QA Program.

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