ML20011B056

QA Program for Packaging of Radioactive Matl for Transport

ML20011B056
Person / Time
Site:	07100385
Issue date:	09/21/1981
From:	Venezia H NAVY, DEPT. OF
To:
Shared Package
ML20011B054	List: ML20011B053 ML20011B055 ML20011B056
References
19831, NUDOCS 8111040093
Download: ML20011B056 (14)

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04 : Wh ln ET SEP 1961 USS liECTOR (AR 7) INSTRUCTION 9090.!A Sub]: Quality Assurance Progran for the Packaging of Radioactive: hterial for transport and transportation of Rad t.oactive hterial under certain conditions (10CFR71) j Ref:

(a)

U.S. Nuclear Regulatory Commission Material License 404-18110-01 (b) Code of Federal Regulations Titic 10. Part 71 (10CFR71)

(c) Code of Federal Regulations Title 49 Enc 1:

(1) RMPQA Progren I

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Background.

US S HECTOR (AR 7) is authorized by reference (a) to use certain radioactive materials aboard HECTOR ytd on ships and in areas where HECTOR is operating.

In the course of exercising this authorization, some of these mterials are shippel to and fro:a civi:ian suppliers who are likewise licensed by the NRC to provide these materials. A recent revision to reference (b) requires the development of a program as follo. s :

"The licenne call establish, maintain and execute s quality assurtac.

prnr.m natisfying each of the applicable criteria specified in appendix E.

'Qu tity Assurance criteria fo r shipping packane s for radioactive materia!',

i a:t! satisf ying any speci f ic provisions which are applicable to the licen we's activitica, taci udi ig ?r c.corescat pa c ka g i u, Sc o pe.

L i r, in s trtic tion app lies to all radimictive citerials covered by referecce (a).

As an end-user it is not Intended that HECTOR ear; age ia i

the manufacture or literation of shipping packages.

kather, this progru is de signed to ensu re tha t the quality of the sh ip,iing pac kat',e 9 received is initially certif ted by the supplier and raintained while such pack iges are in the custo!y of USS HECTOR. This ins truct ion is not to be construed in nay caso, as a relaxatten of the requirerent3 in reference (a) or o the r directives ni b ic,he r au t ho ri ty.

3 Ac t lon.

Bis f as t r ac t ion provides for procedures necessary for the atisfactory estahltsbrent and execution of the cuality assurance prograe f o r us e in p ic ka r,i n g, shipment, and t ranspo rt1t ion of licensed ma terials by USS HECTOR ( AR 71 1

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iPECORINST 3170.1A Lints I, II, ani III

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8111040093 811016 PDR ADOCK 07100385 C

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1 HECTORINST 9090.15 Bi1 SEP 19t' gdALITY ASSURANCE PROGRAM FOR Tile PACKACING OF PJJ)10 ACTIVE MATERIAL 10R TRANSPORT AND TRANSPORTATION OF RADI0 ACTE 7E MATERIAL UNDER CCRTAIN CONDITIONS (10CFR71)

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S., NUCLEAR REGULATORY COMMISSION MATERIALS LICENSE NO. 04-18130-01 LICENSEE:

DEPARTMENT OF TliE NAVY USS HECTOR (AR 7)

FPO SAN FRANCISCO 96643 s'

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I{ECTORINST 9090.IB REC 0RD OF C11ANGES, Q j ${p - 1981 3

CIWICE DATE OF DATE ESTTERED BY 1,

NUl'RER CilA NG.E E'ITERED (SIGNATURE) t W

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IIECTORINST 9090.18 E~f' SEP 1981 TA3LE OF CONTENTS PAGE UtPLDIETTING INSTECCTIO'iS i

Kr. CORD OF CHANCES 11 TABLE OF CONTEKTS ill DEFINITIONS iv 04CANIZATl0N I-l QtJALITY ASSURM;CE II-1 IFX"JMENT CONTHOL III-I

!L\\NDLING, STOR>.CE, AND SHIPPING IV-1 INSPECTION, TEST A O OPERATING STATUS V-1 Qt; ALITY ASS:.RAC F. 40:O RD3 VI-l A!!OITS VII-l a

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7 IIECTORINST 9090. IB

21 SEP 1981 DEFINITIONS THE A* CWING TEFJiS ARE DEFT?!ED AS THEY ARE INTENDED TO EE USED IN THIS INSTRUCTION

CFR - CODE OF FEDEML REGUI.ATIONS i

LICENSED ACTIVITY; LICENSEE - USS HECTOR (AR 7)

LICENSED. MATERIALS - TiiOSE MATERIALS WR WHICil USS HECTOR HOLDS A'i NRC A? PROVED LICENSE d

NRC - U. S. NUCLEAR REGULATORY COMMISSION NDT IA30RATORY - NON-DESTRUCTIVE TEST IABORATORY

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PACKAGE - A SHIPPING CONTAINER FOR 14 CENSED RADI0 ACTIVE MATERIALS i

RMPQA 0FFICER ~ THE QtLiLITY ASSURANCE OFFICER NR THE RMPQA PROGRAM - CHARCED y

WITH INSPECT 1#, AND AUDITING TO VERIFY THE PROGRAM RMPQA PROGRAM - QUALITY ASSURANCE FROGRAM WR TiiE PACKAGING OF RADI0 ACTIVE MATERIAL FOR TRANSPORT AND TRANSPORTATION OF RADIOACTIVE PATERIAL UNDER CERTA.IN CONDITIONS (10CFR71)

RSO - RADIOGRAPHIC SAFETY OFFICER ARSO - ASSISTA!(T RADIOGRAPIIIC SAFETY OFFICER - THE SENIOR RADIOGRAPHER WITHIN THE LICENSED ACTIVITY.

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-e IIECTORINST 9090. lB 21 SEP 1981 SECTION ONE - ORG ANIZATION l.1 Pu rpo s e. This section sets Artti the organizational responsibilitf.es in the RMPQA Program.

1.2 De sc ri p t ion.

The RMPQA Program is composed of five levels of r e << pons inili ty.

_ Commanding Of f icer.

By definition the senior of ficial of the licensed a.

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activity. he is responsible for the establisht.ent and execution of the RMPQA Prograa.

Rev i sions to the program may be authorized only by him.

The Commanding Of ficer assigns and certifies the qualification of 'the RMPQA Officer b.

Repair Of fice r.

Es his role as Head of Departsent which actually uses licensed as terials, the Repair Of ficer has vested interent in the RM?QA Progran. Therefore, he is responsible for eneuring that the RMPQA Of ficer has sufficient organizational freedom to fulfill his function and for ensuring that corrective action (s) is/are acgonplished ir. an ef fective, timely manner and is/are not being delayed by production schedules or other conflicts.

Radiographic _S_afetr Of ficer (RS0).

Either the Qualtty Assurance c.

af ti:cr or the Nondestructive Test (NDT) Laboratory supervisor is normally asnigned as the RSO.

In addition to his responsibilities for ensuring the safe receipt, handling, operation and shipment of licensed materials use 1 in radiography, he in responsible for:

( 1)

Ensuring tha t shipments of licensed materials used by the NDT

!aboratory are conducted in "accordance with references (a), (b), and (c).

(2)

Ensuring that required inspection and testing incidental to shipe.ent of licensed naterials used by the NDT Laboratory are properly conducted and documented.

( 3).1aintaining records of shipments as required in later sections of thii instruction.

(4)

Encu ring tha t correc t ive act ion, when required, is accomplished in an effective, tirly manner by NIrr Laboratory personnel.

(5) casaring that personnel under his cogniunce to process licen ed r.aterial are traine,i in the requirements of this instruction and references (3) and (b),

d.

Assistint hi t oc.rachic Saf e ty Of ficer ( ARSO). Th e Senior Radiographer 4 thin the licen w i activity not fulfilling the position af RSO will be

1. signed as tha Ak h.

In addition to the safe receipt. handling. operation j

n! shipeent of lic. ned material used in radiography, he is responsible for:

i (1) Ens u r i n.; tLat shipments of licensej,aterials used by the NDI hit: oratory are conducted in accordance with ref e rences (a). (b) and (c).

( 2)

Enou t ing t ha t required inspect ion i an1 test!ng incidental to 6 1puents of licen ed materials used by the NDT Laboratory are properly conducted ud docurrnted.

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( 3)

Physical maintenance of records for ! shipments as required by tho.

RSO and in later sections of this instruction.

(4) Corrective action when required is accomplished in an ef fective tinely manner.

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HFC TORINST 9090.13 Zt SEP 19 81

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( 5) Training of personnel under his cognizance W.o process licensed ii m.itert.11, in accordance with the requirements of this instruction and references i!

(a), (b), and (c).

l (6)

Performing the duties of the RSO in his absence in accordance with the instruction, and references (a), (b) and (c).

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.-- a.A Offic.er.

The R.MPQA Officer shall be certifed as to his M PO - - - - - - -

<pulific.ition and appointed by the Co:.anding Of ficer.

His pricary function In the R>i?q r Prog r in is the verification of the credibility of the prog n.

In this regird he is re sponsible for:

( 1)

Sevelopzeat of an audit schedule for approv al by the Co==.ind ing officer.

(2)

Con luct ing or directly supe rvis tru the conduct of all audtts of te R".PQA Program.

(3) Comhe t im; or dir ectl y supe rvising the conduct of unannounctd 4p 2: checks of the PJ1FOA Progran.

(4)

Report ir.g his findings directly to the Com unding Officer with c op ie s to the Rcptir Officer and RS6 (5) Conduc t ing follow-up audits to ensure corrective action is acco plished.

1. 3 Annend ice s.

Appendices A and B to this section contain and orginizttion chart and anrix which graphically di splay the division of re4pensibility of the above f ur t ions into four levels of responsibility.

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11PETORINST 9090.18 ET s'EP 1981 SECTION ONE.

APPENDIX "A" 0:tGANIZATIONAL CHART t

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0FFICER ASSISTANT.

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b HFfTORINST 9090.lB 21 SEP 198 SECTION ONE

. APPENDIX "B" R FS PONSIB I!.ITY MATR IX ASSIS TANT RADIOGRAPHIC RADIOGRAPHIC COMMANDING REPAIR S AFEn' SAFETY FMPQA FUNCTION OFFICER 0FFICER OFFICER O E'F I C ER OFFICER" P R0". T A

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D 1.EC END A - APPROVE B - ACCEPT C - CONCUR D - INITIATE E - PERFO:C4 me#

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i HECTORINST 9090.1B 21 SEP 1981 e

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_SECTION TWO - OUALITY ASSURANCE PROGRAM 2.1 Pu rpo s e. As the final responsibility for the QA Program as specified by reference (b), requirn 1ts.reat with HECTOR, this section specifica the necessary action which must be undertaken to successfully establish and execute viahle quality assurance progran for packaging licensed materials, a

i 2.7 Discussion.

USS HECTOR is licensed to use certain radioactive materials as specified in reference g(a). As an end-user llECTOR receives these materials f rom NaC licensed suppliers NRC approved containers.

Therefore, the thrust ofn the QA Program on board USS HECTOR shall be directed toward establishing proof of and maintaining the quali,ty of provided containers.

Manufacture or repair.

of shipping containers for licensed material shall not be conducted aboard USS l

HECTOR without prior approval by the NRC.

2.3 Procedure g

a.

The promulgation and enforcement of. this instruction by appropriate levels of the chain of command establishes and implements the RMPQA Program, b.

Training and experience for all RMPQA Programs functions shall be in accordance with the established procedures:

(1)

The Conmanding Of ficer and Repair Of ficer are specifically assigned h-the Bureau of Rtv.21 Personnel in accordance with established directiven.

(2) The PS0 shall be assigned by the Corr.eanding Of ficer in accordance with reference (a).

(1) The ?MPQA Of ficer shall te assigned and cert i fied by the Comninding Of ficer.

(4)

Pu !! o p a phe cs shall be qualified in accordance with reference (a),

c.

Changer, to the QA Program may be a:ade only by a formal change to this instruction atyned by the Co::canding Of ficer. Changes which would it4 tificaatly a !ter the program must be approved by the NRC.

F,tch change Will to enteret la the anner directed by the change and documented on the m erd of Chang e n pa ge.

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Prior to use, all defined qattity control procedures, engineerind or ecdures, and specific provisions of the pr ". age design approval shall be uttsfied. Additionally, tbc QA Program rill mf hasize control of critical 3

afety characteristics f or any shipping packag.m used in conjuction with licensel material.

( 1) Docuwntation of thin shall be maintained on board the HECTOR for any contractor-supplied shipping containers for use with licensed materials.

( 2)

Specific approval by the MRC shall be obtained, documenting the a irec attribute prior to locally f abricating repairing, or altering a nippin.; container for use with licensed alterials.

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HFCTORINST 9090.1B 21 SEP 1981 SECTION-THREE -DOCL?.ENT_ C_ONTROL lt

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1,1 Purpose. This section describes requirements for the control-of. documents-

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related to the sh8.pping packages.

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3.2 Procedure. Each document relat A to a specific shipping container shall, I

j where necessary, be processed in accordance with Naval Supply Systems Command directives in the course of' receiving of shipping licensed naterials. ;When not required to be.in custody of USS HECTOR'S Supply. Officer, or others, for review, documents shall be maincained in the custody of the RSO.

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anticipated that no document changes should be required. Ilovever, if 'the need

.T arines, changes vill be accomplished only with the permission of the Cor::manding-Of ficer and in accordance with appropriate procedures.

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HEcr0RINST 9090. lB 21 SEP 1981 SECTION 4 - ILUTDI.ING, STOP. AGE, AND SHIPPING

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i 4.1 Pu rpo se. This section deacribes those aspects nf handling, storage and shipping of packages which are important to safaty and includes assignment of responsibilities for the critical aspects of handling, storage, and shipping.

4.2 Discussion.

Established safety restrictionc as delineated, in reference (a),

a.

1 concerning the handling, storage, and Jhipping of packages for special form of' W

radioactive material will be followed. Shipments vill not be sade unless all'e g

tests, certifications, acceptances, and final inspections have been completed.

Work instructions have been provided for handling, storage, and shipping i

operations for those containers in use.. Work instructions will be provided for handling, storage, and shipping operations for those shipping containers contemalated for future use.

b.

' The responsibilities of certain personnel involved in the RMPQA Program are described in Section One.

This section provides umplification of those responsibilities by specifying requireeents for the aspects of handling, storage, and shiptent of packages which are considered critical.

'.3 P ROC EDUR E.

a.

The Radiographic Safety Of ficer is responsibile for the critical han:lling, storage and shipping operations for each shipment of licensed mt.:rt.nl by the ND. laboratory.

He :. hall ensaro, for each shipping container, that the ARSO performs the following operations:

(1)

Es'.ablishing safety restrict ions concerning the handling, s torage, j

.ind shipping of packages for certain special form and radioactive material are f o l lo west.

(2)

Ensuring that shipment s are not made unless all tests, certifications, t

acceptances, and final inspections have been ccepleted.

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

h.

While in the cue.tody of USS HECTOR, shipping centainers for use with licensed materials shall be controlled such that those characteristics of the

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pickage which are critical to safety are maintained.

(1)

Dssage to shipping containers shall be reported immediately to the Radiographic safety Of ficer.

(2) Shipping contair.ers for use with licensed radiographic Lources shall be maintained and used in accordance with reference (a). They shall be stored in the radiography vault when not in use.

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l HICTORINST 9090.1B E r sEP 19 B' SECTION FIVE - INSPECTION TEST AND OPERATING STNIUS u

5.1 hirpose.

This section describes those aspects r" inspection, l test and operating statas of packages which are important t'

_fety and. includes -

assignement of responsibilities for the critics' ects of inspection, test, 4

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and opera ting activi t ies.

5.2 Discussion A.

Inspection, test, and operat', status of packages for certain'special fans radioactive eaterial will be i

.eted and controlled by established procedures. The status will be indica ted by the ~ tag, label, marking, or leg s

entry.

The status of non-conforming parts or packages will be positively maintained by established procedures.

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B.

The. responsibilities of certain personnel involved in the RMPQA j)

Progrta are described in Sectios One.

This section provides amplification of those responsibilities by specifying requirements for the aspects of

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inspection, test, and operating statys which are considered critical.-

i 5.3 Procedure A.

The Ra<tiogr.2phic Safety Of ficer is responsible for the critical luspection, test and operating activities associated with each shipping container which may be used for shipment of licensed materials by the NDT i

La bo ra t o ry.

Er shall ensur7, for each shipping container, that, the ARSO l

pe rforns the following operations:

f (1)

Inspection, tedt and operating status of packages for certain j

special form radioactivo material is indicated and controlled by established

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procedures.

(2)

Status is indicated by tag, label, marking or log entry. -

'(3)

Status of non-conforming parts or packages are positivelv reitntained by established procedures, i

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8' 7j IIECTORINST 9090.1B Ei! SEP 19 @

SECTION SIX -- QUALITY ASSURANCE RECORDS L

6.1 Purpose. 'this section provides the necessary requireeents and guidance i

for satisf actorily documenting the operation of the EMPQA Program aboard USS s

i!ECTOR.

6.2 Disc us sion_.

Mequate documentation will be maintained to demonstrate to. -

interested partice that USS IIECTok possesses an ef fective functional RMPQA-

I Program. To this end the following actions shall be talen

Records vill be maintained ar.d include operating logs, inspections.

4 a.

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tests, and audit results.

H b.

Other records to be maintained will include qualifications of personnel and descriptions of procedurns and equipment.

c.

Records will be maintained according to established procedures.

d.

F.ecords will be identifiable and retrievable.

e.

A list of the required records and their storage locations vill be u intained.

6.3 rocedare f

N F#FQA Of ficer shall maintain the original audit reports for all audita and shall maintain a master listing (index) of all required records e!ch shows their loca tion.

b.

n., Ra.liographic Safety Of ficer shall raintain all other records.

Fe shall maintain them in an'auditable fashion, i.e.,

they shall be ideatifiable anj retrievable. These shal-l include, but not limited to:

(1) Operating logs, inspections, and tests.

I (2)

Qualification of personnel.

(3)

Devart.ption of procedures and equipment.

(4)

Records of shipments.

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,e llf SECTION_SEVEN - AUDIT _S_

igj 7.1. Pu_ryose.

This section specifies.the requi rements which rust be met to y

establish an effective audit-program, b{.

7.2. Discussior..

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Established ' achedules of audits of the RMPQA Program vill be perform 5d.

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a.

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

Results of all addits will-be reported to the commanding officer, with copies to the repair officer and f

radiographic safety officer. Audit reports vill be evaluated

• nd deficient a

j-areas corrected. The audits being performed vill be dependent on the safety significance of the activity being audited. Audit reports vill be maintaiaed f_

as part of the quality control records.

7.3. Procedure I-s s

Audits shall be conducted by or under the direct supervision of the a.

R:!PQA Of ficer.

b.

An audi t of each receipt or shipeent shall be coaducted two weeks following that receipt of shipment.

c.

Semi-aanually - A completed audit of the RMPQA Program will be conducted.

The specific dates shal1 ~ be approveJ. by the cornandf ug Of ficer, d.

W-signed audit report shall be forwarded to the Conmanding Of ficer r

on the co pletion of each audit. Copics will be provided to thc Rep.tir f

Of ficce and Radiogn chic Safety Of ficer. '

The Repair of ficer will review proposed corrective actions and e.

assly,n completion bites.

f.

The orginal audit reports and original record 4 of corrective action shall be maintained in an auditable fashion by the RMPQA Officer, i

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