ML19246A812

Submits Repair Dept Instruction 9900.5A Incorporating Revisions to QA Program as Requested in NRC

ML19246A812
Person / Time
Site:	07100268
Issue date:	05/18/1979
From:	Skorupski S NAVY, DEPT. OF
To:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 7907090018
Download: ML19246A812 (14)

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Ccmmanding Of ficer, USS ORICN (AS-IS)

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Director, Office Of Nuclear Material Safety and Safeguards Nuclear Regulatory Commission. L'ashington, D.C.

20555 Subj: Quality Assurance Program for Shipping Packages for Radioactive j

Materials Re?-

(a) CCMSUBLANT ltr FF4-12:545, 9893, ser 6477 of 30 November 1978 (b) Code of Federal Reguiations, Title 10, Chapter 1, Part 71 (NRC 10 CFR 71)

(c) United States Nuclear Regulatory Commission ltr FCTR/ RHO 71 N mf 20 April 1979 ORIUN (AS-18) ltr 40:rbs, 9893 Set 74 of 16 January 1979 (d) Lu, vaa Encl:

(1) USS Of ON 3epair Department Instruction 9900.5A 1.

Refsrence (a) directed the submission of a quality assurance plan for shipping and stowage containers meeting the criteria of ref erence (b) to the Nuclear Regulatory Commission (NRC) for approval.

2.

Reference (c) specified that the proposed Quality Assurance pro;; ram submitted by reference id) does t meet the requirements of reference (b) and that a revised prot rau should be submitted.

Reference (c) provided a sample Quality Assurance program for industrial radiography licenses to assist in revising ORION's application.

3.

The revisions required have been incorporated in enclosure (1) which is submitted for approval.

Enclosure (1) provides a description of the Quality Assurance Program exercised by USS ORION for receipt, processing and transfer of radioactive materials handled under NRC license number 31-16096-01.

4.

Enclosure (1) has been written utilizing the essential elements as described in the sample QA program provided by ruterence (cf.

This required that scme of the-verbiage and format be modified so as to comply with the Navy's prescribed method of preparing shipboard instruction or directive.

3.

Enclosure (1) comprises a totai program for the receipt, processing and transfer of radioactive materials handicd under NxC License 231-18036-01, and the Quality Assurance controls associated with that program, and complies with reference (b).

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REPDEPTINST 9900.5A g

A'L5 18 MAY R79 REPAIR DEPARTMENT INSTRUCTION 9900.5A Subj: Quality Assurance Program for Administrative Controls and Protection Procedures Associated with Radiography and Radiac Calibration Sources Ref:

(a) Code af Federal Regulations, Title 10, Chapter 10, Chapter 1, Part 71 (NRC 10 CFR 71)

(b) ORION Repair Department Instruction 5100.10F; Administrative Control and Protection Procedures for Gamma Radiography and Radiac Calibration Source Encl:

(1) Organizational Structure of Quel;ty Assurance Program for Radiographic and Radiac Calibration Source (2) Audit Plan (#1 through 10) for the Evaluation of Administrative Controls and Protection Procedures for Gamma Radiography /Radiac Calibration Sources and Associated Quality Assurance Program 1.

Purpose.

To promulgate instrections to establish and define the quality assurance program for administrative controls and protection procedures for gamma radiography and radiac calibration sources and to establish an auditing program to insure compliance with current directives.

2.

Cancellation. Repair Department Instruction 9900.5 of 15 January 1979.

3.

Discussion. The final responsibility for the Quality Assurance program for reference (a) requirements rests with the USS ORION.

Design and fabri-cation shall not be conducted under this Quality Assurance program.

The instructions set forth herein, and in reference (b), which were approved under Nuclear Regulatory Commission (NRC) License #31-18096-01, define ORI0h's administrative controls and protection procedures for gamma radio-graphy, radiac calibration sources and the associated quality assurance pregram.

These instructions fulfill the requirements of reference (a).

Situatione not clearly defined in this instruction will be handled by recom-mendation from ORION's Radiographic Safety Officer and approved by ORION's Repair Officer. Changes to this instruction will be routed to the NRC for approval.

4 Organization /Resocnsibilities. The Quality Assurance Program is implemented using the following organization:

The Renair Of f ker_(as directed by the Cormanding Of ficer) is directly a.

responsible f or the radioactive sealed sources onboard ORION. He vill be assisted by the Radiological Controls Of ficer and the Radiographic Safety Officer.

Enclosure (1) is attached to delineate the organizational structure.

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REPDEPTINST 9900.5A S 8 MAY 1979 b.

The Radiological Controls Of ficer is responsible:

(1) For ensuring that handling, stewage, preparation for shipping, inspections, leak tests and operational requirements relating to radiac calibration sources, and the preparation for shipping and leak test of radiographic s<

ces comply with references (a) and (b) and paragraph 5 of this instruction.

(2) To the Repair Officer for ensuring that required audits are conducted as promulgated by this instruction.

c.

Radiographic Safetv Officer has overall responsibility 6,7 admin-i istering this pr^ gram and for ensuring that the requirements and provisions of the U.S. Nuclear Regulatory Commission By-products Material License approved for the USS ORION are complied with.

He will:

(1) Maintain adequate security and stowage facilities for radio-graphic sources in compliance with NRC regulations.

(2) Develop, promulgate, and conduct _ training, verify personnel qualifications, and supervise car:alty procedures involving radioactive

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q sources authorized by the NRC By-aroduct License.

1 (3) Assist the Radiological Controls Officer in conducting required audits promulgated by this instruction.

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'4) Fe respensible for auditable record controls, d.

Radiographic, Radiac Calibration and Radiological Controls nersennel are responsible for handling, storing, shipping, inspecting, testing, and l

operating evolutions, and record keeping.

5.

Shipping Materials and Identification. The following shipping packages ar.sociated with by-product, source, and/or special nuclear nsterial are approved by NRC License d31-18096-01 and are the sole shipping packages authorized to be used onboard ORION for radiography and radiac calibration sources:

a.

Automation Industries Model 200-520-008 Sealed Source (I r-192) b.

Oak Ridge National Laboratories Model A-4 Sealed Source (Cs-137) c.

Autenation Industries Model 520 Exposure Device d.

Automation Industries Model 500-SU Source Changer e.

TS-1216 A/UD Radiac Calibrator 6.

Action. USS ORION establishes and implements the Quality Assurance Program described herein and in reference (b).

Training and auditing procedures and specific provisions in package design will be in ccepliance with this instruction and those delineated by reterences (a) and (b).

Emphasis will be placed on con

' of activities affecting the components of the packaging which are significant to safety.

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+4 REPDEPTINST 9900.3A 40 18 MAY 1979 a.

Auditable Record Controls will be maintained to establish and verify compliance to the specifications outlined by references (a) and (b).

b.

Handling, Storace and Shipping shall be performed in accordance l

with established instructions and procedures of references (a) and (b), and only by those personnel authorized by reference (b).

c.

Inspections, Tests and Operations involving all radioactive material and storage containers shall be in compliance with references (a) and (b) and performed only by those personnel authorized by reference (b).

d.

Quality Assurance _R stds of tests, inspections, operating logs, f

audit resulta, personnel training and qualification, and records of ship-ients as well as descriptions of equipment and written procedures will be maintained as specified by reference (b).

c.

Audits shall be conducted as prescribed below:

(1) Enclosure (2) provides audit plans for use in monitoring and evaluating ORION's compliance with references (a) and (b) and this instruction.

Audits shall be conducted using these audit plans at 1 cast semi-annually by an of ficer appointed as Audit Team Leader by the Repair Officer (of ficer appointed will not be directly

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-o. source handling on ORION) anc assisted by the Radiographic Safety Officer Raciological Centrols Officer and any cdditional of ficer as deemed necessary to perform an adequate and complete audit.

(2) A report of audit findings shall be submitted to the Repair Officer, by the Audit Team Leader, no later than five (5) working days af ter ccmpletion of the at dit.

Audit findings should include those recommendations /

corrective acticns that the audit team considers necessary to align ORION's administrativa control and protection procedures for gamma radiography and radiac calibration scurces and the associated Quality Assurance Program with the requirements of references (a) and (b) and this instruction.

(3) The Repair Officer shall teview and forward the audit sort to the Commanding Officer when corrective actions have been completed. Audit reports, af ter the Ccamanding Officer's review, shall be retained on file i

for three (3) years.

Pre ared by:

Submitted by:

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D.\\. HALL G. A. NELSOh CWO2 USS CDR USN Approved by:

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ORGANIZATION STRUCTURE OF OUALITY ASSURANCE PROCRAM FOR RADIOGRAPHIC AND RADIAC CALIBPATION SOURCE 1.

The Chain of Co:n,and as refered to in this instruction is depicted below as it relates to radiographic and Fadiac Calibration. The dotted lines indicate a provision for direct access up the Chain of Corrand in ratters involving safety.

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