ML20039G904

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QA Program for Packaging of Radioactive Matl for Transport & Transportation
ML20039G904
Person / Time
Site: 07100458
Issue date: 12/14/1981
From:
NAVY, DEPT. OF
To:
Shared Package
ML20039G899 List:
References
NUDOCS 8201190277
Download: ML20039G904 (20)
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Text

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FULTONINST 9090.2 e.

QUALITY ASSURANCE PROGRAM FOR THE PACKAGING OF RADIOACTIVE MATERIAL FOR TRANSPORT AND TRANSPORTATION OF RADIOACTIVE MATERIAL UNDER CERTAIN CONDITIONS (10CFR71)

U.S. NUCLEAR REGULATORY COMMISSION MATERIALS LICENSE NO. 31-18014-01 LICENSEE:

DEPARTMENT OF THE NAVY USS FULTON (AS-11)

FPO NEW YORK, NEW YORK 09534

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4 FULTONINST 9090.2 TABLE OF CONTENTS i

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t PAGE Implementing Instruction Title Page i

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i Record of Revisions li Table of Contents iii Definitions Organization

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1-1 Quality Assurance 11-1 Document Control 111-1 4

Handling, Stora;;e, and Shipping IV-1 Inspection, Test, and Operating Status V-1 Quality Assurance Records VI-1 Audits VII-1

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FULTONINST 9090.2 SECTION ONE - ORGANIZATION 1.1 Purpose. This section sets forth the organizational responsibilities in the RMPQA Program.

1.2 Description. The RMPQA Program is composed of five levels of responsi-bility:

a.

Commanding Of ficer - By definition the senior of ficial of the licensed activity is responsible for the establishment and execution of the RMPQA Program.

Revisions to the program may be authorized only by him. The Commanding Of ficer assigns and certifies the qualification of the RMPQA Officer.

b.

Repair Officer - In his role as IIcad of Department which actually uses licensed materials the Repair Of ficer has a vested interest in the RMPQA

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Program. Tharefore, he is responsible for ensuring that the RMPQA Officer has i

sufficient organizational freedom to fulfill his function and for ensuring that the correctivt action (s) is/are accomplished in an effective, timely manner and is/are not beleg delayed by production schedules or other conflicts.

Rad iological Controla Of ficer (RCO)- Respons ible for the safe receipt,

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handling, operation, and shipment of licensed materials in/by the Radiac Calibration Facility (RCF), the Radiological Controls Officer is responsible for the following attributes of the RMPQA Program:

(1) Ensuring that shipments of licensed materials used by the RCF are conducted in accordance with references (a), (b), and (c).

(2) Ensuring that the required inspect ion ~ and tes ting incidental to l

shipment of licensed materials used by the RCF are properly conducted and documented.

(3) Completing records of shipments to/by the RCE-prior to releasing them to the appropriate record keeping of ficer.

- (4) Ensuring that corrective action, when required, is accomplished by --'

the RCF in an effective, timely manner.

(5) Ensuring that personnel under his cognizance assigned to use licensed material are trained in the requirements of this instruction and references (a) and (b).

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SECTION I

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COMMANDING OFFICER s

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QQ ;,s 7 EXECUTIVE OFFICER

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'FOR MATTERS SONCERNING FOR RADCON

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)(AD10 LOGICAL SOURCES' MATTERS L

REPAIR OFFICER s

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PRODUCTION ASSISTANT

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1 RADIOGRAPHIC SAFETY OFFICER R-8 NDT DIVISION OFFICER RADCON OFFICER h

FOR MATTERS CONCERNING SOURCES FOR MATTERS CONCERNING

R-5 D IV IS ION RADIOGRAPHY ASSIST RADIOCRAPHIC 5AFETY OFFICER -

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SENIOR RADIOGRAPHER a

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FUUIONINST 9090.2 SECTION TWO - QUALITY ASSURANCE PROCRAM 2.1 Purpose. This section specifies the necessary action which nust be unde r-taken to succcessfully establish and execute a viable quality assurance program 1

for packaging licensed materials.

2.2 Discussion. USS FULTON is licensed to use certain radioactive materials as specified in reference (a). As an end user USS FULTON receives these materials l

from NRC licensed suppliers in NRC approved containers. Therefore, the thrust of the QA Program aboard USS FULTON shall be directed toward establishing proof of and maintaining the quality of provided containers. Manufacture or repair of shipping containers for licensed materials shall not be conducted aboard USS FULTON without prior approval by the NRC.

2.3 Precedure a.

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

b.

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

(1) The Commanding Officer, Repair Of ficer, and Radiological Controls Of cicer are specifically assigned by the Naval Military Personnel Command in accordance with established directives.

(2) The Radiographic Safety Officer shall be assigned by the Commanding Of ficer in accordance with reference (a).

(3) The RMPQA Officer shall be assigned and certified by the Commanding Officer following completion of Appendix (A) to this section.

(4) Radiographers shall be qualified in accordanc.e with reference (a).

(5) RCF Technicians shall be qualified in accordance with requirements for NEC 9597.

c.

Rev is ions to the QA Program may be made only by a formal change to this instruction signed by the Commanding Officer. Revisions which would signifi-cantly alter the program must be approved by the NRC.

Each revision shall be entered in the manner directed by the revision and documented on the Record of Revisions page, d.

Prior to use of all defined quality control procedures, engineering procedures, and specific provisions of the package design, approval shall be satisfied for any shipping packages used in conjunction with licensed material.

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r 5'ULTONINST 9090.2 (1) Doc.nentation of this shall be maintained on board USS FULTON for any contractor-supplied shipping containers for use with licensed materials.

(2) Specific approval by the NRC shall be obtained, documenting the above attributes prior to locally fabricating, repairing, or altering a shipping container for use with licensed materials, e.

While in the custody of FULTON, shipping containers for use with licensed materipls shall be controlled such that those characteristics of the package which are critical to safety are maintained.

(1) Damage to shipping containers shall be reported immediately to competent authority.

(2) Shipping containers for use with licensed radiographic sources shall be maintained and used in accordance with reference (a).

They shall be stored in the Radiography Vault when not in use.

(3) Shipping containers for licensed radiac calibration soucces shall be maintained and used in accordance with reference (a).

They shall 1e stored in the locked section of the RCF when not in use.

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T FULTONINST 9090.2 DEFINITIONS The following terms are defined as they are intended to be used in this instruction.

CFR - Code of Federal Regulations Licensed Activity; Licensee - USS FULTON (AS-11)

Licensed Materials - Those materials for which USS FULTON holds an NRC approved license NP.O - U.S. Nuclear Regulatory Commission NDT Laboratory - Non-destructive Test Laboratory Package - A Shipping Container for Licensed Radioactive Materials RCF - Radiac Calibration Facility RCO - Radiological Controls Officer s

RMPQA Of ficer - The Quality Assurance Officer for the RMPQA Program - charged with Inspecting and Auditing to Verify the Program RMPQA Program - Quality Assurance Program for the Packaging of Radioactive Material for Transport and Transportation of Radioactive Material Under Certain Conditions (10CFR71)

RSO - Radiographic Safety Of ficer 6*

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Radiographic Safety Officer (RS0) - Either the Quality Assurance Officer or the Non-destructive Test (NDT) Laboratory Supervisor is normally assigned as the RSO.

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

(1) Ensuring that shipments of licensed materials used by the NDT Laboratory are conducted in accordance with references (a), (b), and (c).

(2) Ensuring that required ir.spection and testing incidental to ship-ment of licensed materials used by NET laboratory are properly conducted and documented.

(3) Maintaining records of shipment as required in later sections of this instruction.

(4) Ensuring that corrective action, when required, is accomplished in an effective, timely manner by the NDT laboratory.

(5) Ensuring that personnel under his cognizance to process liceaned material are trained in the requirements of this instruction and references (a) and (b).

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RMPQA Officer. The RMPQA Officer shall be certified as to his quali-fication and appointed by the Commanding Officer. His primary function in the RMPQA Program is the verification of the credibililty of the program.

In this l

regard he is responsible for:

(L) Development of an audit schedule for approval by the Commanding Of ficer.

(2) Conducting or directly supervising the conduct of all audits of the RMPQA Program.

(3) Conducting of directly supervising the conduct of unannounced spot checks of the RMPQA Program.

(4) Reporting his findings directly to the Commanding Of ficer with copies to the Repair Of ficer, Radiological Controls Officer, and RSO.

(5) Conducting follow up audits to ensure corrective action is accomplished.

1.3 Appendices. Appendices ( A) and (B) to this section contain organizational chart and matrix which graphically display the division of responsibility of the above functions into four levels of responsibility.

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r-FULTONINST 9090.2 SECTION ONE APP!:NDIX "B" RESPONSIBILITY MATRIX 2

I RADIOLOGICAL RADIOGRAPHIC COMMANDING REPAIR CONTI:0LS SAFETY RMPQA FUNCTION OFFICER OFFICER OFFICER OFFICER OFFICER l

PROGRAM A

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TRAINING A

C D,E D,E CERTIFICATION B

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j TESTING B

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I DOCUMENT CHANCES A

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SHIPPING A

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E AUDITS B

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SCHEDULE A

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B - Accept C - Concur

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FULTON1NST 9090.2 SEC'? ION TWO APPF.NDIX A From:

(RMPQA Of ficer Designate)

To:

Commanding Of ficer, USS FULTON ( AS-11)

Subj: Training and F.xperience as RMPQA Officer 1.

I have reviewed and am familiar with the most recent revisions to the following instructions and regulaticas:

10CFR71 RMPQA Program j

RMPQA Records and Audits 1

License No 31-18014-01 i

Instruction 9090.1 2.

I am prepared to assume the responsibilities of the USS FULTON RMPQA Of f icer.

J Signature Approved:

Commanding Officer /Date

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T FULTONINST 9090.2 SECTION THREE - DOCUMENT CONTROL 3.1 Purpose. This section describes requirements for the control of documents related to shipping packages.

3.2 Procedure. Each document related to a specific shipping container shall, where necessary, be processed in accordance with Naval Supply Systems Command directives in the course of receiving or shipping licensed materials.

When not required to ba in the custody of the FULTON Supply Of ficer, or others, for review, documents shall be maintained in the custody of the Radiographic Safety Of ficer.

It is anticipated that no document changes should be required, However, if the need arises changes will be accomplished only with the permission of the Commanding Officer and in accordance with appropriate procedures.

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SECTION FOUR - HANDLING, STORAGE, AND SHIPPING 4.1 Purpose. This section describes those aspects of handling, storage and shipping of packages which are important to safety and includes assignment of responsibilities for the critical aspects of handling, storage, and shipping.

4.2 Discussion Established safety restrictions concerning the handling storage, and a.

shipping o,f packages for special fona radioactive material will be followed.

t Shipments will not be made unless all tests, cetificatione, acceptances, and final inspections have been completed. Work instructions have been provided for handling, storage, and handling operations for those shipping containers in t

Work instructions will be provided for handling, storage, and shipping use.

operations for those shipping containers contemplated for future use.

b.

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

This section provides ampification of those responsibilities by specifying requirements for the aspects of handling, storage, and shipment of packages which are considered critical.

4.3 Procedure The Radiological Controls Of ficer is responsible for the critical a.

handling, storage, and shipping operations for each shipment of licensed materials by the RCF.

He shall ensure, for each shipping container, that:

(1) Established safety restrictions concerning the handling, storage and shipping of packages for certain special form radioactive material are being followed.

(2) Shipments are not made unless all test, certification, acceptance, a:.d final inspections have been completed.

(3) Work instructions have been provided for hand'1ing, storage, and shipping operations.

i b.

The Radiographic safety Officer is responsible for the critical

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handling, storage, and shipping operations for each shipment of licensed material by the NDT Laboratory.

He shall ensure, for each shipping container, l

that:

l (1) Established safety restrictions concerning the handling, s to rage and shipping of packages for certain special form radioactive material are being followed.

(2) Shipments are not made unless all test, certifications, acceptances and final inspections have been completed.

(3) Work instructions have been provided for handling, storage and shipping operations.

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1 FULTONINST 9090.2 SECTION FIVE - INSPECTION, TEST, AND OPERATING STATUS h.

5.1 Purpose. This section describes those aspects of inspection, test, and operating status of packages which are important to safety and includes assignment of responsibilities for the critical aspects of inspection,

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and operating activities.

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I 5.2 Discussion a.

Inspection, test, and operating status of packages for certain special form radioactive material will be indicated, and controlled by established procedures. The status will be indicated by the tag, label, marking, or log i

entry. The status of nonconforming parts or, packages will be positively maintained by established procedures.

j b.

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

This section provides ampification of those responsibilities by specifying requirements for the aspects of inspection, j

test, and operating status which are considered critical.

i 5.3 Procedure I

The Radiological Controls Of ficer-is responsible for the critical a.

inspection, test, and operating activities associated with each shipping container which may be used for shipment of licensed materials by the RCF.

He j

shall ensure, for each shipping container. that:

1 (1) Inspection, test and operating status of packages ~ for certain special form radioactive material is indicated and controlled by established i

procedure.

(2) Status is indicated by tag, label, marking or log entry.

(3) Status of nonconforming parts or packages are positively maintained by established procedures.

b.

The Radiographic Safety Officer is responsible for the critical inspection,-

~~" - ^ test and operating activities associated with each shipping container which may be used for shipment of licensed materials by the NDT Laboratory.

He shall ensure, for each shipping container, that:

i (1) Inspection, test and operating status of packages for certain special form radioactive material is indicated and controlled by established procedures.

(2) Status is indicated by tag, label, marking or log entry.

(3) Status of nonconforming parts or packages are positively maintained 1

by established procedures.

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1 SECTION SIX - Q]ALITY ASSURANCE RECORDS l

6.1 Purpose. This section provides the necessary requirements and guidance for satisfactory documenting the operation of the RMPQA Program aboard.

6.2 Discussion. Adequate documentation will be maintained to demonstrate to interested parties that FULTON posses ses an ef fective functional RMPQA Program.

To this end the following actions shall be taken:

1 a.

Records will be maintained and include operating logs, inspections, tests, and audit results, b.

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

c.

Records will be maintained according to established procedures.

d.

Records will be identifiable and retrieveable, A list of the required records and their storage locations will be e.

maintained.

6.3 Procedure l

a.

The RMPQA Officer shall maintain the original audit reports for all audits and shall maintain a master listing (index) of all required records which shows their location.

b.

The Radiographic Safety Officer shall maintain all other records. He shall maintain them in an auditable fashion, i.e.

they shall be ident ifiable and retrievable. These shall include, but are not limited to:

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(1) Operating logs, inspections, and tests.

(2) Qualification of personnel, i

(3) Descriptions of procedures and equipment.

(4) Records of shipments.

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SECTION SEVEN - AUDITS 7.1 Purpose. This section specifies the requirements which must be met to establish an ef fective audit program.

7.2 Discussion Appendix (A) to this section contains the audit plan for use in audits a.

of the RMPQA Program. Thsi format specifies the minimum requirements of each j

audit. The auditor should audit to the intent rather than the letter of the audit plan. That is to say each area described in the audit plan should reveal j

several questions which must be answered to satisfactorily complete the audit.

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b.

Established schedules of audits of th'e RMPQA Program wi!1 be performed.

Recults of all audits will be reported to the Commanding Of ficer, with copies to the Repair Of ficer, Radiological Controls Officer, and Radiographic Safety Officer. Audit reports will be evaluated and deficient ares corrected. The j

audits being performed will be dependent on the safety significance of the activity being audited. Audit reports will be maintained as part of the quality control records.

7.3 Procedure l

a.

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

b.

An audit of each receipt or shipment shall be conducted two weeks following that receipt or shipment.

c.

Semi-annually, a complete audit of the RMPQA Program will be conducted, i

The specific dates shall be approved by the Commanding Officer.

d.

The signed audit report shall be forwarded to the Commanding Officer on the completion of each audit. Copies will be provided tg. the Repair Of ficer, Radiological Controls Officer, Radiographic Safety Officer.

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The Repair _Of ficer will review proposed corrective actions and assign e.

3 completion dates.

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The original audit reports and original records of corrective action 4

shall be maintained in an auditable fashion by the RMPQA Officer.

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FULTONINST 9090.2 SECTION SEVEN APPENDIX "A" RMPQA AUDIT 1.

Audits of the radioactive Material Packing Quality Assurance Program must be conducted to meet the requirements of USS FULTON RMPQA Program and Appendix E to 10CFR71. The audit must be conducted by a knowledgeable officer not having direct responsibility in the area audited (10CFR71), Appendix E, paragraph 18). Follow-up ac t ion, including reaudit of deficient areas shall be taken when considered necessary.

2.

For each of the established RMPQA procedures, check the following:

INITIAL All procedures used were verified by the RMPQA a.

Of ficer and RCO/RSO (as applicable).

b.

The nuut current verified copy is on file.

c.

Two years of files maintained, d.

All required signatures are present.

3.

The current RMPQA Officer has completed unclosures (1) to FULTON INSTRUCTION 9090.2 and has been approved by the-Cummanding Of fict:r.

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FULTONINST 9090.2 4

All radiographers have completed reference (a) requirements for qualifications and have been aproved by the required officers.

RCF personnel are qualified in accordance with requirements for NEC 9597.

5.

All RMPQA revisions have been aut.horized by the Commanding Officer and each revision is documented on the record of revisions page of FULTON INSfRUCTION 9090.2 on file with RMPQA records (and any others in use).

6.

For each radioactive material shipping package to be used on board the USS FULTON verify that:

a.

The NRC approval for that package is on board.

b.

The specific provisions made with package approval are being adhered to.

7.

A complete list of NRC approved packages is on board.

8.

Registration with the NRC for use of a package occurred prior to use of the package and a copy of this registration is on file.

9.

General Comments / Discrepancy:

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(Signature)

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FULTON1h3T 9090.2 SECTION II APPENDIX A RADIOACTIVE MATERIAL CllECKOFF LIST GENERAL INFORMATION:

ITEM NAME:

S!!IPMENT NUMBER DOCUMENT NUMBER CONSIGNEE:

RADIOACTIVE MATERIAL LOG NUMBER:

1 NAME OF PEkSON ASSIGNING APPLICABILITY:

NAME OF PERSON PERFORMING SHIPMENT:

CLASSIFICATION APPLICABILITY COMPLETION SIGNATU RE/DATE SIGNATURE /DATE

1. Radionuclide of major concern being shipped:
2. Transport group of this shipment:

(49CFR173.390) 4

3. Radiation / contamination survey perform: SAT /UNSAT l.
4. Activity with computations:

(NAVSilIPS 389-0153) 1

5. This shipment qualifies as " Low Specific Activity Material" under the provisions of 49CFR173. 389(c) and meets the requirements of 49CFR173.

392 4

6. This shipment qualifies as " radio-t active Material limited Quantities" under the provisions cf 49CFR173.391 and is exempt from specification pack-aging, marking, and labeling and from the provisions of 49CFR173.393.

Normal Form Radioactive Device Figure V-4-1 A-2 FOR OFFICIAL USE ONLY

FULTONINST 9090.2 FOR OFFICIAL USE ONLY

7. If shipment does not qualify as " Low Specific Activity" or " Limited Quantity" radioactive materials, it is classi-fled in one of the following catagories:

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a. Normal Form (49CFR173.389d)
1) Type A Quant. (49CFR173.389L)
2) Type B Quant. (49CFR173.389L)
3) Large Quant. (49CFR173.389b)
b. Special Fona (49CFR173.389g)

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1) Type A Quant. (49CFR173.389L) i
2) Type B Quant. (49CFR173.389L) j
3) Large Quant. (49CFR173.389b) e LABELING AND PACKAGING' i

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1. Shipments that qualify as " Low

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Specific Activity Materials" have been packaged 7 labeled in accord-l ance with 49CFR173.395.

2. Shipments that qualify as

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normal form type A&B and large a

quantities have been packaged in j

accordance with 49CFR173.395.

3. Shipments 'that qualify as

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special form type A&B and large

i quantities have been packaged in accordance with 49CFR173.394.
4. Package contact levels do not j

exceed 100mr/hr.

MARKING AND LABELING E

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1. Package has been marked and labeled IAW 49CFR172 Subparts D&E
a. Type label required:

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b. Transport index:

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SHIPPING PAPERS i.

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1. The consignee is authorized to receive radioactive' material by:

j NAVSEANOTE 9210.08R NRC Licensef Figure V-4-2 A-3 POR OFFICIAL USE ONLY i

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5 FULTONINST 9090.2

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FQR OFFICIAL USE ONLY

2. Shipping document complies with all the requirements of 49CFR172 Subpart C and NAVSHIPS 389-0153 INDEPENDENT OFFICER VERIFICATION:

(prior to shipment)

TO BE COMPLETED ON RELCASE TO CARRIER

1. Section "D" of the radioactive Material Logsheet has beea completed and a copy of the shipping document attached IAW NAVSHIPS 389-0153 l
2. Ensure carrier has been briefed and supplied with.an emergency response plan.
3. Ensure that if sole use vehicle is required, the carrier in fact has supplied a vehicle for sole use i

by consignor and carrier has been j

supplied with specific instructions on how to maintain sole use conditions.

4. Vehicle is placarded if required.
5. receive one copy of signed ship- '

ping papers.

6. Lading is accomplished so as to meet the applicable requirements.

INDEPENDENT OFFICER VERIFICATION:

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1. Clear radioactive material. log 4 source custody card.
2. Mail applicable. documents and return reciept form to consignee.

CHECK LIST PREPARED BY:

RADCON OFFICER REVIEW:

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(prior to shipment) (completion of shipment)

Figure V-4-3 FOR OFFICIAL USE ONLY A'+

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