ML19289D902
| ML19289D902 | |
| Person / Time | |
|---|---|
| Site: | 07100274 |
| Issue date: | 01/05/1979 |
| From: | Forsyth J NAVY, DEPT. OF |
| To: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML19289D901 | List: |
| References | |
| 43, NUDOCS 7903190361 | |
| Download: ML19289D902 (14) | |
Text
.
1 j
,,f "..,
CE? MNENT OF THE NAVY t ~ /,,'
/
Nav4L suuurnist support FACILITY SEW LONDON
- d 'g - ({
sox soo
{M,E ai cnorou. coussericur ces4o
(,.
NSSF:775: sin:SP 3
9893 Ser 4 $
i 5 JAN 1979 i
From:
Commanding Officer, Naval Submarine Support Facility New London To:
Director, Office of Nuclear Material Safety and Safeguards
[
Via:
Commander, Submarine Squadron TWO j
i Subj: Quality Assurance Program for the use of shipping containers; i
forwarding of l
Ref:
(a) USNRC Note of 1 May 1978 (b) COMSUBLANT ltr 9893 ser 6477 of 30 Nov 78 (c) NAVNUPWRU ltr 3203 ser 925 of 27 Jul 77 Encl:
(1) Quality Assurance Program for the use of shipping containers for radioactive sources in special form (8).
1.
Reference (a) identified a change to Title 10 CFR Part 71 which modified requirements for shipping container preparation and maintenance as associated with radiography and radiac calibration sources.
j 2.
In accordance with reference (b), enclosure (1), which has been approved locally, is forwarded for your review and approval.
3.
Additionally, based on reference (c), source changer model 650 (manufactured by Tech Ops) will be used for shipments originated at this
)
activity.
'l
{
SP F0RSYTH Copy to:
COMSUBLANT (N45)
NAVNUP!CU, Port Hueneme ~
~--'
~~
c F
1, 3
g
[.,1 f._h--
t-Y 790319036(
1
1 l
4 b-r-.
P Cl QUALITY ASSURANCE PROGRAM FOR THE USE OF SHIPPING 1::
Ir CONTAINERS FOR RADIOACTIVE SOURCES IN SPECIAL FOIOf h
et Naval Submarine Support Facility New London, Groton, Connecticut U.S. Nuclear Regulatory Commision Liceses # 06-12193-01 and 1 06-07150-01 Prepared Radiological dohtrols Officer Approved 1/ f//
C6f(
/l
=mandingOfficer/,NAVSUBSUPPFACNLON tw F
7;
- n.1 h
L. i pr Enclosure (1) l l
1 I
RECORD OF REVISIONS
- h. ;
J-
,jl REVISION ENTERED BY DATE r '
NUMBER f
J i
4--
l 1
L:
b
.b:
n'.a I 2.)
hd
~
2 Enclosure (1)
1 TABLE OF CONTENTS PAGE NO.
~
E INTRODUCTION h
P 1.
Organization
(
2.
Quality Assurance Program 3.
Document Control
(
4.
Handling, Storcge, and Shipping 5.
Inspection, Test, and Operating Status 6.
Quality Assurance Records 7.
Audits Appendices A.
Audit of Quality Assurance Program for Shipping Containers for Special Form Radioactive Material.
,hme me
=-en--
e w-
=
ra im
[. '
f";]
W
=
3 Enclosure (1)
l i
INTRODUCTION
?
The Naval Submarine Support Facility New London (NAVNUBSUPPFACNLON)
Y
is licensed by the U.S. Nuclear Regulatory Co= mission to receive, use, b'j and transfer certain licensed radioactive sources. Examples of these sources are the special form radiographic sources used for non-destructive I
testing by the Quality Assurance Division of the Repair Department.
[
This Quality Assurance Program herein described fulfills the requirements
(
of 10 CFR Part 71, " Packing of Radioactive Material for Transport and OL_
Transportation of Radioactive Material Under Certain Conditions" to insure that all quality assurance provisions that apply to shipping containers used by NAVSUBSUPPFACNLON have been satisfied.
fi G
3 fJl
~
w 4
Enclosure (1)
4 1.
Organization P
b.
h The final responsibility for the Quality Assurance Program for Part 71 Requirements rests with the Cor=nanding Officer. Design and fabrication u
of radioactive material shipping packages shall not be conducted under this Quality Assurance Program. The Quality Assurance Program is implemented
(:
using the following organization:
S c
COMMANDING OFFICER REPAIR OFFICER QUALITY ASSURANCE OFFICER RADIOLOGICAL CONTROLS OFFICER RADIATION SAFETY OFFICER RADIOLOGICAL CONTROLS DIVISION SHIPPING PETTY OFFICER C;
r1
- .y e..
g I.te LM 3-5 Enclosure (1)
i The Reoair Officer manages a department dedicated to the repair and
=
maintenance of nuclear submarines. The Quality Assurance Officer assists 4.
the Repair Officer by applying quality assurance measures to all aspects of repair and production.
{
The Radiation Safety Officer is responsible to the Quality Assurance L
Officer to ensure proper handling and storing of radiographic sources.
i d
The Radiological Controls Officer is responsible to the Repair Officer for the proper handling of radioactive material. The Radiological f
Controls Division Shipping Petty Officer receives radioactive material l
for the Naval Submarine Support Facility, performs inspections and tests on the material, and makes all packaging and administrative preparations for shipment of radioactive material by NAVSUBSUPPFACNLON.
2.
Quality Assurance Program The Commanding Officer of NAVSUBSUPPFACNLON establishes and implemente
{
this Quality Assurance Program. Training for all QA functions, prior to engagement in these functions, is required according to written procedures.
i QA Program revisions will be made according to written procedures with the Commanding Officer's approval. The QA Program will ensure that all defined QA procedures, engineering procedures, and specific provisions of the package design approval are satisified. The QA Program will emphasize control of the characteristics of the package which are critical to safety.
The Radiological Controls Division Shipping Petty Officer shall ensure that all radioactive material shipping packages are designed and manufactured under a Quality Assurance Program approved by the Nuclear Regulatory Commission for all packages designed or fabricated af ter 1 January 1979. This requirement can be satisfied by receiving a certification to this effect from the manufacturer, as an example.
3.
Document Control All documents related to a specific shipping package will be controlled thrcugh the use of written procedures: All documents changes will be fJ
~ ~ ' performed according to written procedures approved by the Commanding Officer.
C I,
The Radiological Controls Officer shall insure that all QA functions g.
are conducted in accordance with the latest applicable changes to these g
documents.
3w 6
Enclosure (1)
J-
~, n -
I f
4 Handlin1, Storage, and Shipoing b
Written safety procedures concerning the handling, storage, and shipping of packages for certain special form radioactive material will
[
I be followed. Shipments will not be made unless all tests, certifications, L
acceptances, and final inspections have been completed. Work instructions I
will be provided for handling, storage, and shipping operations.
s R
Radiography personnel shall perform the critical handling and storage of radiographic sources. Radiological Controls Division personnel shall perform the critical handling and storage of radiac calibration sources.
The Radiological Controls Division Shipping Petty Officer shall perform shipping operations for all radioactive sources.
5.
Inspection, Test, and Operating Status 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 procedures.
Radiography personnel shall perform the regulatory required inspections and tests on radiography sources in accordance with written procedures.
The Radiation Safety Officer shall ensure that these functions are performed.
Radiological Controls Division Personnel shall perform the regulatory required inspections and tests on radiac calibration sources in accordance with written procedures. The Radiological Controls Officer shall ensure that these functions are performed.
6.
Quality Assurance Records Records of package approvals (including references and drawings),
inspect. ion, tests, operattyg. logs,.. audit results _ personnel. training and g"l -
qualification, and records of shipments will be maintained. Descriptions of equipment and written procedures will also be maintained.
[
These records will be maintained.in accordance. with written procedures.
The records will be identifiable and retrievable. A list of these Lj records, with their storage locations, will be maintained by the Radiological I#
Controls Officer.
4 7
Enclosure (1)
I 7.
Audits 5
Established schedules of audits of the Quality Assurance Program
[
will be performed using the written checklist of Appendix A.
Results of audits will be maintained ar.d reported to senior officers.
(
Audit reports will be evaluated and deficient areas corrected.
t-The audits will be dependent on the safety significance of the activity being audited, but both the Radiography section of the Quality Assurance (j
Division and the Radiological Controls Division will be audited at. least L
once per year.
Audit reports will be maintained with this QA Program outline.
Auditors shall have no responsibility in the activity b '.ng
- audited, i
_ w t
.~.
k_ml
.~~~.?
~~-~~~~
l b:
i.--
8 Enclosure (1)
.~_
^
l i
APPENDIX A 2
AUDIT OF OUALITY ASSURANCE PROGRAM y
FOR SHIPPING CONTAINERS FOR SPECIAL p
F ra FORM RADIOACTIVE MATERIAL f
E.
AUDITOR DATE Ref:
(a) NAVSUBSUPPFACNLON Quality Assurance Program for Shipping Containers for Special Form Radioactive Material (b) 10 CFR Part 71 I.
This audit should assess the ef#ectiveness of the Quality Assurance Program for Shipping Containers for special form radioactive material and the compliance of personnel with the applicable directives. The auditor should familiarize himself with reference (a) and the applicable portions of reference (b) for this audit to be meaningful. Deficiencies will be noted and the references for the deficiency cited.
II.
Quality Assurance Program A.
Is training for all QA functions associated with this program being conducted in accordance with written procedures prior to engagement in these functions?
B.
Does the QA Program ensure that defined QA procedures, engineering procedures, and specific provisions of the package design approval are satisfied?
C.
Does the QA Program emphasize centrol of the characteristics of
['
the package which are critical to safety?
J Li D.
Are revisions to the QA Program made according to written procedures?
E' I-s E.
Have all shipping packages which have been used since the last audit been decigned and manufactured under a QA Program anproved by the NRC7 Enclosure (1)
g,..
i
~
l i
k i
F.
Document Control
[e P
(1) Are all documents related to a specific shipping container h
controlled through the use of v:itten procedures?
9x.
(2) Are all document changes made according to written procedures?
(3) Are all QA functions performed in accordance with the latest applicable changes to these documents?
l l
C.
Handling, Storage, and Shipping (1) Are all written safety procedures concerning the handling, storage, and shipping for certain special form radioactive caterial being followed?
(2) Are all tests, certifications, acceptances, and final inspections being comp?.eted prior to shipments?
(3) Are work instructions provided for handling, storage, and shipping operations?
h(,
(4) Are critical handling, storage, and shipping operations i
performed by personnel specified in reference (a)?
4 ha C
H.
Inspection, Test, and Operating Status (1) Are inspections, tests, and the operating status of I
2 Inclosure (1)
. ~..
packages for certain special form radioactive material indicated j
and controlled by written procedures?
I l
(2) Is the status of material indicated by tag, label, marking, 5
or log entry?
(3)
Is the status of nonconforming parts or packages positively maintained by written procedures?
(4) Are the appropriate personnel specified in reference (a) performing the regulatory required inspections and tests in accordance with written procedures?
l l
I.
Quality Assurance Records (1) Are records of packages approvals (including references and drawings), inspections, test, operating logs, audit results, personnel training and qualifications, and records of shipments being maintained?
i (2) Are descriptions of equipment and written procedures being maintained?
(3) Are these records maintained in accordance with written procedures?
~~
~ ~ ~ ~
~ ~.
',,,, I
[:
S
'~
y i.,.D.
(4)
Are these records identifiable and retrievable?. _
l b
_7 N
(5)
Is a list of these records, with their storage locations, being maintained by the R*DCON Officer?
3 Enclosure (1)
~
l
.x Y. -
J.
Audits 9
(1) Are results of audits being maintained and reported to I.
senior officers?
E b
b 1r (2) Have previous audit reports been evaluated and deficient areas corrected?
(3) Are audits being conducted at least once per year?
(4) Are audit reports being maintained with the QA Program outline?
s (5) Are auditors assigned who have no responsibility in the activity being audited?
-K.- Overall Assessment of the Quality Assurance Program for
-~
~ ~ ' -
Shipping Containers:
d
- s..-
.r-___.-
[9 f.,
Auditor Signature
[Q
?
III. Reviews PJC00N Officer Quality Assurance Officer 4
Enclosure (1)
~ -.
~
t l
t Repair Officer B
II~
Connanding Officer g
L Reviewers' Coc::nents F(
s
[
he em.-
ewww w*m e
e,m
. ee -
w r,
- ~.
u.
Q4-I,'.i t.-a h
6 5
Enclosure (1) l