ML20246B921

Requests Registration as User of Models 660 & 650 Re Exposure Device & Source Changer,Respectively

ML20246B921
Person / Time
Site:	07100447, 07109033, 07109032
Issue date:	06/16/1989
From:	Malinoski J NAVY, DEPT. OF, NAVAL SEA SYSTEMS COMMAND
To:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
11-00721, 11-721, 25652, NUDOCS 8907100173
Download: ML20246B921 (13)

Text

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S. Nuclear Regulatory Commi tan Division of Safeguards and Tran Transportation Branch Washington, DC 20555 Ocntlemen:

Enclosure (1) requests Shore Intermediate Maintenance Activity, Charleston, SC be registered as a user for the Model 660 exposure device, Package ID Vo. USA /9033/B(u) and Model 650 source changer, Package ID No. USA /9032/B(u) and requests amendment of NRC Quality Assurance Program Approval No. 0447.

Sincenly, J.

. MALIN0 SKI

Enclosure:

(1) SIMA Charleston ltr 9000 Ser 03/0750 of 25 Apr 89 w/ endorsement

' Copy to:

CNO (OP-45)

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COMNAVSURFLANT (N421N)

SIMA Charleston i-..ti.

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DEPARTMENT OF THE NAVY cOMMANDLP NAVAL SURFACE FORCE NORFOLK. Vih3fNIA 235116292 9000 Ser N421N/() $ $ Q f 19 MAY 1999

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i FIRST ENDORSEMENT on'SIMA Charleston ltr 9000 Ser 03/0750 f

of 25 Apr 89 From: ' Commander, Naval Surface Force, U.S. Atlantic Fleet To:

Officer in Charge,. Naval Sea Systems Command Detachment RASO, Yorktown q

Subj:

REQUESTING REGISTRATION AS A USER AND AN AMENDMENT TO 1

EXISTING QUALITY ASSURANCE PROGRAM l.

Readdressed and forwarded recommending approval.

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Copy to:

.SIMA Charleston 1.

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' DLPARTMENT OF THE NAVY COMMANDING 097tCER NAVALSURFACE FORCE ATLANTSC RE AOINESS SUPPORT GROUP CM ARLESTON CHARLESTON, SOUTH CAROLINA 29a08-6850 Ser 03/ 0750 25 APR 1989 From:

Commanding Officer, ShoreIntermediate Maintenance Activity, Charleston To:

Commander, Radiological Affairs Support Office, Naval Weapons Station, Yorktown, VA 23691-5098 Via:

Commander, Naval Surface Force, U.S. Atlantic Fleet (N421N)

. Subj:

REQUESTING REGISTRATION AS A USER AND AN AMENDMENT TO EXISTING QUALITY ASSURANCE PROGRAM Ref:

(a) Code of Federal Regulations (b) RASO Yorktown, VA ltr 5104 Ser 455/8U586632 of 9 Nov 88 Encl:

(1) Revised Quality Assurance Program Instruction 9091.2A 1.

In accordance with reference (a), it is requested that ShoreIntet' mediate Maintenance Activity, (SIMA), Charleston be registered as a user of AMERSHAM Model 660 exposure device docket number 71-9033 and AMERSHAM Model 650 source changer docket number 71-9032. Reference (b) provides approval to utilize this exposure device and source changer at this facility.

2.

To reflect this change requested by paragraph (1) in the current Quality Assurance Program, it is requested that SIMA Charleston's Quality Assurance Program be modified as shown in enclosure (1). Request review and reply at your earliest convenience.

3.

For further information regarding this matter, contact IIT1 (SW) Schacht or 11T1 (SW)

Gammell at ext. (803) 743-3991 or Autovon ext. 563-3991. Your assistance is greatly appreciated.

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SIM ACHASNINST 9091.2A 03:jee i

SIMA CHARLESTON INSTRUCTION 9091.2A i

Subj:

QUALITY ASSURANCE PROGRAM REQUIREMENTS FOR SHIPMENT OF l

RADIOACTIVE SOURCES USED IN G AMM A R ADIOGRAPHY

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Ref:

(a) Navy Radioactive Materials Permit Number 39-52903-AINP Amendment # 0 issued to Shore Intermediate Maintenance Activity, Charleston on 8 Dec 88

)

(b) SIM ACH ASNINST 5100.6A l

(c)

U.S. Nuclear Regulatory Commission Rules and Regulations, Code of Federal Regulations, Transportation (Parts 100 to 199)

(d)

U.S. Nuclear Regulatory Commission Rules and Regulations, Title 10 -

Energy, Part 71, Packaging of Radioactive Material for Transport and j

Shipment of Radioactive Material under Certain Conditions (c) COMNAVSURFLANTINST 9091.2 Encl:

(1) Checklist for Packaging and ShiprLent of Radiographic Sources (2) Instructions forInternalInspections and Controls of Radiographic Operations (3) Audit Forms I,11 and III i

1.

Purpose. To promulgate the minimum precautionary measures to be utilized in the shipment of Radioactive Sources used in Gamma Radiography from Shore Intermediate Maintenance Activity (SIM A), Charleston to a vendor licensed by the U.S. Nuclear Regulatory Commission to receive Radioactive Materials, in accordance with references (a) through (c). This instruction is a complete rewrite of the superseded instruction.

Individual changes, additions and deletions have not been indicated.

2.

Cancel,lation. SIM ACHASNINST 9091.2.

3.

Discussion.

a. Radioactive Isotopes are capable of inflicting serious bodily harm if used improperly or without regard to safety.

b. All shipments or transfers of radioactive materials over public areas, including shipments made with private or government vehicles, must comply with the appropriate federal, state and local transportation requirements. This instruction is provided to ensure SIM A Charlesten complies with references (a) through (c), with regards to the shipment of Radioactive Sources.

c. when questions arise concerning this instruction or referenced instructions, clarification may be obtained from the Radiographic Safety Officer.

4.

Organization. The final responsibility for the Quality Assurance (QA) Program for compliance with this instruction and references (a) through (c) rests with SIM A i

I DRAFT

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DRAFT SIM ACHASNINST 9091.2A l

Charleston, Design and fabrication will not be conducted under this program. The QA Program is implemented using the Chain of Command as shown below:

COMM ANDING OFFICER I

QUALITY ASSURANCE OFFICER I

R ADIOGRAPIIIC SAFETY OFFICER -

SENIOR RADIOGRAPHER RADIOGRAPHER The broken lines indleate a provision for direct access up the chain of command in matters involving safety.

5.

Quality Assurance Program.

a. The Commanding Officer shall establish and implement this program upon approval.

b. The Radiographic Safety Officer is responsible through the chain of command for the overall administration of the QA program including training and certification of Radiographer, document control and conducting audits as required by reference (b). The Senior Radiographer is responsible for completion of all required documentation and maintenance of all required records. The Radiographer are responsible for the handling, storage, shipping, inspections, test and operating status, and record keeping of radioactive

sources,

c. Training of all radiographic personnel on radiation safety and the requirements of the U.S. Nuclear Reguistory Commission will be conducted, at a minimum, annually. All radiographic personnel will be required to be tested on the above train!ng. The training and examination are to be administered by the ARSO/RSO.

6.

Document Control. The Certificate of Compliance for the Radiographic Exposure Device, Radiographic Source Changer / Shipping Container and the Special Form Encapsulated Source used by the radiographic personnel at SIMA Charleston will be resintained by the Radiographic Safety Officer.

Modifications or alterations to this equ:pment will not be accomplished by this command.

7.

Handling, Storage and Shipping:

a. The procedures contair.ed in reference (b) concerning the handling, storage and shipping of Radiographic Sources will be strictly adhered to. Shipments will not be made until all tests, certifications, acceptances and final inspections have been completed,

b. Use Checklist for Packaging and Shipment of Radiographic Sources, enclosure (1) of this instruction.

2 DRAFT 1

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N p.,s.

i DRAFT I

SIM ACII ASNINST 9091.2 A

c. Only qualified Radiographer, as defined in reference (b), will accomplish the required handling, storage and shipping operations.

8.

Inspection, Test and Operating Status,

a. Inspection, test and operating status of packages of Radiographic Sources will be indicated and controlled by the written procedures contained in reference (b), and documented on the forms contained therela.

b. Only qualified Radiographer will perform the required inspections and tests, in accordance with references (a) through (e). The Senior Radiographer will supervise the performance of the required inspections and tests. The Radiographic Safety Officer will ensure compliance.

9.

Quality Assurance Records.

a. Records of package approval, procurement, inspection, test, operating logs, audit results, personnel training and qualification, and record of shipment will be maintained in accordance with references (b) and (d). The Radiographer is responsible for maintenance of the records,

b. The records will be maintained in an auditable manner so as to be readily identified and retrieved. The Radiographic Safety Officer will maintain a list of the records and storage locations.

10. Audits.

Established schedules of audits of the QA Program will be performed utilizing enclosure (2) and documented on prepared audit forms of enclosure (3). Results of the audits will be maintained and reported to the Quality Assurance Officer. Audit reports will be conducted yearly unless otherwise required.

Audit reports will be maintained as part of the Quality Assurance records. Members of the audit team will have no responsibility to the Nondestructive Laboratory.

C. E. CARROLL Distribution:

SIM ACH ASNINST 5216.1C ListI 3

DRAFT

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1 DRAFT 1

1 SIM ACHASNINST 9091.2A CHECK LIST FOR PACKAGING AND SHIPMENT OF RADIOGRAPIIIC SOURCES 1.

Ensure source leak test has been conducted in accordance with Comp.

reference (b).

2.

Utilizing the inspection sheet contained in reference (b)

Comp.

(encl 10) complete appropriate sections for source changer.

3.

Compare unit with Certificates of Compliance and supporting Comp.

documentation to ensure correct package is being utilized. Compare packaged ID No. USA /9032/B (U).

4.

Verify that the organization to which materialis being shipped Comp.

is authorized to receive radioactive material.

5.

Place material for transport in package in accordance with Comp.

procedures set forth in reference (b).

6.

Description of shipment in accordance with reference (b)

Comp.

(enel 11).

7.

Take and record radiation levels: 1 meter mr/hr 6" Comp.

mr/hr and contact mr/hr.

8.

Prepare requisition and invoice / shipping document (DD-1149)

a. Fill out parts 1, 2, 3, 5, 6, 8 and 10 as with a normal shipment.

b. Parts (a) through (k) will consist of the following statements in this sequence:

(1) Shipping Name (2) Shipping Class (3) Total quantity of material in curies, millicuries or microcuries as appropiate l

(4) Type of packaging (5) Name of radionuclides (6) Description of physical and chemical form and serial number if applicable (7) Transport index (8) Category of label applied (9) The statement " Package requires radiological controls for unpacking. Return receipt requireci."

DRAFT

,e DRAFT SIM ACHASNINST 9091.2 A (10) The statement "This is to certify that the above named materials are properly classified, described, packaged, marked and labeled, and are in proper condition l

for transportation according to applicable regulations of the. Department of Transportation."

(11) A statement of receipt.

c. DD-1149 form filled out as speelfied above.

Comp.

9.

Utilize emergency procedures when government owned vehicle is Comp.

to be used.

10. Place copy of DD-1149 and source decay chart in container.

Comp.

11. If shipment is transferred via Navy supply-for future receipt by authorized organization, enter shipment on tickler sheet in front of Action Pending File held by Senior Radiographer. Send copy of shipping papars together with letter to receiving organization to inform them of shipmt nt. Serial Number and date of letter Comp.

12. !f shipment is being carried by a SIMA Charleston driver and vehicle for future receipt:

Note:

Hazardous materials are not allowed on public bridges and tunnels unless approval is granted by higher authority; therefore, routes chosen for transport should not include the use of bridges or tunnels if possible.

a.

Driver must be designated by the Commanding Officer.

b.

Provide driver with copy of the emergency procedures designating the actions he shall take in case of an accident and whom must be notified.

e.

Provide driver with three copies of DD-1149 to be signed as receipts by receiving organization.

d.

Ensure placards are placed on vehicle as described in Comp.

reference (b).

13. Assemble all documents produced during the completion of the Comp.

enclosure and file in Action Pending File of Senior Radiographer.

14. Upon receipt of confirmation of receipt of shipment by licensed Comp.

addressee, remove pending documents and file in Completed Source Shipment File, along with this completed enclosure.

15. Enclosure complete.

Senior Radiographer l

l Radiographic Safety Officer Encl (1) 2 DRAFT

,s.,

DRAFT SIM ACII ASNINST 9091.2 A INSTRUCTIONS FOR INTERNAL INSPECTIONS l

AND CONTROLS OF RADIOGRAPHIC OPERATIONS 1.

The Radiographic Safety Officer is responsible for ensuring that NRC regulations, license provisions, operating and emergency procedures are complied with by the Radiographer. The duties of the Radiographic Safety Officer are as follows:

a. Serve as the licensee's liaison offleer with the NRC on license matters.

b. Review and inspect operating and emergency procedures.

c. Maintain control of procurement and licensed by-product material and disposal of licensed by-product material.

d. Supervise the personnel monitoring program for NDT.

c. Assume control and institute corrective action in emergency situations.

f. Supervise guarterly inventories.

g. Investigate causes of incidents and determine necessary preventative action.

h. Supervise radioactive source replacement and tagging operations,

i. Conduct a quarterly audit of radiographic operations and facilities on announced or unannounced basis, utilizing Forms I, II, and III at enclosure (3).

(1) Results of quarterly audit will be forwarded to Commanding Officer, SIMA Charleston on Form II at enclosure (3).

(2) Correction of audit findings will be noted on Form 111 at enclosure (3) and forwarded to Commanding Officer, SIMA Charleston.

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NOTE Items of noncompliance involving safety of personnel or Radiographic source security will be corrected immediately.

(3) Forms I,11 and III when filled out, will be maintained on file by the Radiographic Safety Officer for three years.

DRAFT Enci (2)

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i DRAFT 2

SIMACHASNINST 9091.2 A

- AUDIT FORM I i

QUARTERLY AUDIT REPORT OF ISOTOPE RADIOGRAPHIC FACILITIES SAT UNSAT 1.

UTILIZATION LOG

'2.

ISOTOPE RECEIPT AND TRANSFER LOG l

3..

POCKET DOSIMETER LOG 4.

RADIOGRAPIIIC EQUIPMENT MAINTENANCE RECORDS

. 5.

QUARTERLY SOURCE INVENTORY LOG 6.

RADIOGRAPHIC SOURCE MOVEMENT SHEETS 7.

RADIATION SURVEY RECORDS 8.

RADIAC CALIBRATION RECORDS 9.

SOURCE LEAK TEST RECORDS

' 10. PROPER POSTING OF RADIATION AREAS AND FORM NRC-3

11. TRAINING RECORDS OF RADIOGRAPHER

12. GENERAL MATERIAL CONDITION OF EQUIPMENT AND FACILITIES

13. REMARKS:

l l

l RADIOGRAPHIC SAFETY OFFICER Copy to:

QA Officer Senior Radiographer DRAFT EncI (3) i

r-y DRAFT SIM ACHASNINST 9091.2A I

i AUDIT FORM II i

DATE

)

From: Radiographic Safety Officer j

To:

Commanding Officer, Shore Intermediate Maintenance Activity, Charleston Subj:

QUARTERLY AUDIT FOR ISOTOPE RADIOGRAPHIC FACILITIES Ref:

(a) SIM ACH ASNINST 9091.2 A i

1.

A quarterly audit, as required by reference (a), was conducted on NDT Isotope Radiographic Facilities and the following conditions were noted:

I RADIOGRAPHIC SAFETY OFFICER Copyto:

CO QA Officer Senior Radiographer Encl (3) 2 DRAFT

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DRAFT SIM ACH ASNINST 9091.2 A l

AUDIT FORM HI DATE From: Radiographic Safety Officer To:

Commanding Officer, ShoreIntermediate Maintenance Activity, Charleston Subj:

CORRECTION OF DISCREPANCIES NOTED WHILE CONDUCTING QUARTERLY AUDIT OF ISOTOPE RADIOGRAPHIC FACILITIES ON Ref:

(a) SIM ACHASNINST 9091.2A 1.

In accordance with reference (a), the following discrepancies were noted while conducting subject audit and have been corrected as discussed below:

i RADIOGRAPHIC SAFETY OFFICER Copy to:

QA Officer i

a l

3 Enc 1 (3)

DRAFT I

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