Information Notice 1996-20, Demonstration of Associated Equipment Compliance with 10 CFR 34.20

Demonstration of Associated Equipment Compliance with 10 CFR 34.20

ML031060147
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant
Issue date:	04/04/1996
From:	Cool D NRC/NMSS/IMNS
To:
References
IN-96-020, NUDOCS 9603290269
Download: ML031060147 (11)

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

WASHINGTON, D.C. 20555 April 4, 1996 NRC INFORMATION NOTICE 96-20: DEMONSTRATION OF ASSOCIATED EQUIPMENT

COMPLIANCE WITH 10 CFR 34.20

Addressees

All industrial radiography licensees and radiography equipment manufacturers.

Purpose

The U.S. Nuclear Regulatory Commission is issuing this information notice to

inform radiography licensees of acceptable methods to demonstrate that their

associated equipment used in radiographic operations meets the regulations in

10 CFR 34.20. It is expected that recipients will review the information for

applicability to their facilities and consider appropriate actions. However, this information notice does not contain any new requirements; therefore, no

specific action nor written response is required.

Description of Circumstances

Section 34.20 of 10 CFR Part 34 specifies performance requirements for

radiography equipment. Paragraph (d) of 10 CFR 34.20 provided that all newly

manufactured radiographic exposure devices and associated equipment

(manufactured after January 10, 1992) acquired by NRC licensees must meet

Section 34.20 requirements. Paragraph (e) of 10 CFR 34.20 provides that all

radiographic exposure devices and associated equipment in use by NRC licensees

after January 10, 1996, must comply with the requirements specified in

10 CFR 34.20. NRC amended the regulations in 10 CFR 34.20 to permit licensees

to use an alternate value of torque for performance testing criteria and to

allow licensees to use engineering analysis to demonstrate that a modest

change in an already approved design is acceptable without the need to perform

prototype testing. The changes were published in the Federal Register as a

-final rule on May 31, 1995.

NRC Information Notice (IN)95-58: "10 CFR 34.20; Final Effective Date,"

issued on December 18, 1995, to all radiography licensees, reminded licensees

of the final effective date implementing the regulations in 10 CFR 34.20. IN 95-58 also reminded licensees that associated equipment used with radiography

cameras (i.e., source assemblies, drive cables, guide tubes, control tubes, source stops, etc.) were subject to 10 CFR 34.20 requirements. IN 95-58 went

on to explain that, previously, certain associated equipment had not been

independently registered and/or evaluated by the NRC or the Agreement States

(AS). This includes drive cables, guide tubes, and source stops. Most new

9603290269 PADR Ano

Pt 96-oao %oqoq for

IN 96-20

April 4, 1996 camera models and their basic associated equipment

the gamma radiography system as described in the were registered as part of

N432-1980, "Radiological Safety for the Design and American National Standard

Construction

for Gamma Radiography." Therefore, information concerning of Apparatus

equipment to be used with the devices was included certain associated

system evaluation and registration process. Some as part of the overall

labeling their equipment with an identifier, such manufacturers have also been

as the manufacturer's logo, to indicate that the equipment meets the requirements

IN 95-58 went on to remind licensees that 10 CFR of 10 CFR 34.20.

34.20

responsible for ensuring that equipment meets regulatorymakes the licensee

requirements.

NRC and AS review and evaluate radiography-associated

exposure heads, and collimators) as well as sealed equipment (guide tubes, exposure devices (cameras) and source changers for sources, radiographic

Part 34. On completion of this evaluation, acceptablecompliance with 10 CFR

identified on a registration certificate. Information components are

National Registry System maintained by NRC. Regulatory is also included in a

information in their licensing and inspection activities. authorities use this

Discussion

The regulation on performance requirements for radiography

Section 34.20 -- require that the radiographic exposure equipment --

associated equipment must meet the requirements of device and all

ANSI

specific requirements listed in 10 CFR 34.20. Associated N432-1980, and other

source assemblies, drive cables, guide tubes, control equipment includes

tubes, collimators, exposure heads, and source stops. tubes, cranks, "J"

In particular for guide tubes, 10 CFR 34.20(c)(5)

have passed the crushing tests for the control tubestates, "The guide tube must

and a kinking resistance test that closely approximatesas specified in ANSI N432 likely to be encountered during use." In addition, the kinking forces

10 CFR 3 4.20(c)(8)

requires that the connection between the guide tube

to withstand the tensile test for control units and exposure head be able

specified

Section 8.9 of ANSI N432-1980 specifies that radiography in ANSI N432. Since

withstand the endurance test described in that section, systems must

demonstrate that guide tubes and exposure heads licensees must

test. will withstand the endurance

Recently some questions were raised concerning what

head vs. a guide tube. Exposure heads may be a constitutes an exposure

guide tube. NRC's analysis of associated equipmentseparate or integral part of a

tubes, exposure heads) has shown that there is little (i.e., collimators, guide

source travel for equipment that guides a source risk of obstruction of

assembly a distance less than

. I

-. :%

IN 96-20

April 4, 1996 10 times the length of the source capsule. NRC's analysis included a review

of equipment designs and incidents involving source travel obstructions.

Based on these findings, NRC's policy is that associated equipment that guides

a source assembly a distance greater than 10 times the length of the source

capsule (i.e., exposure heads, "J" tubes, jet engine probes, source stops) is

considered a guide tube and must meet the testing requirements for guide

tubes. In addition, NRC's policy is that only associated equipment that comes

in contact with the source (e.g., collimators that slip over the end stop)

must meet the applicable testing requirements.

The NRC has identified several ways licensees can demonstrate that their

radiography equipment meets 10 CFR 34.20 requirements. First, the most direct

method would be that the equipment has been labeled by the manufacturer

pursuant to a registration certificate. (If the label has worn off, you

should contact the manufacturer or have support information as described

below.) Alternatively, licensees can make this demonstration if they can

provide a document trail to registered associated equipment. The equipment

will be considered to meet the requirements, if the licensee has in its

possession one of the following for each piece of equipment:

(a) A purchase order(s) listing the radiography equipment that can be

tied-back to a registration certificate; or, (b) Documentation from the manufacturer verifying that the equipment

the licensee is using was approved and registered with the NRC or

AS. The documentation must clearly identify which equipment meets

the requirements; or, (c) A signed NRC or AS recognized checklist(s) certifying that the

licensee has evaluated its equipment, and that it meets the

specifications of the checklist. In order for the checklist to be

recognized, it must have been provided by the manufacturer of the

equipment and approved by the NRC or AS. As of this date, only

one checklist has been approved. See Attachment 1 for the

recognized checklist.

If a licensee possesses and intends to use radiography equipment that is not

labeled by the manufacturer, or that the licensee cannot demonstrate that it

meets 10 CFR 34.20 requirements, then the licensee must submit an application

for a custom evaluation. Attachment 2 includes information on how to file an

application for custom evaluation. Equipment cannot be used in radiographic

operations until it has been approved for use by NRC or an AS.

IN 96-20

April 4, 1996 This information notice requires no specific action nor written response. If

you have any questions about the information in this notice, please contact

the technical contact listed below or the appropriate regional office.

Donald A. Cool, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material

Safety and Safeguards

Attachments:

1. Recognized Checklist for Associated Equipment

2. Custom Evaluation of Associated Equipment

3. List of Recently Issued NMSS Information Notices

4. List of Recently Issued NRC Information Notices

Contact: Thomas W. Rich, NMSS

(301) 415-7893 Ar4 Ajar ~

1 II

__-_1i

Attachment 1 IN 96-20

April 4, 1996 Checklist for Amersham's Model 591 Controls

To assure the associated equipment you are using are approved Amersham

manufactured accessories, please perform a side by side comparison against a

known (i.e.,'flying A is legible or'Pos are available) Amersham manufactured

piece. Perform a detailed mechanical and visual inspection of your equipment

against the following checklist... If you have any questions, please call

Amersham for assistance.

Amersham Controls:

1. All controls have a yellow polyvinyl housing with a 9/16 inch outer

diameter.

2._ The fittings are 3 inches long (including the hex nut).

3. The hex nut is 11/16 inch.

4. Check the fittings fo' swage marks,'the fittings will have 3 single

swage marks =1/8'inch wide and = 1/2 inch apart or 4 single swage marks

1/8 inch wide and = 1/2 inch apart.

5. The first swage mark is typically 3/8 inch from the end.

6. The thread pattern for the control connector is 5/8"-18.

7. The 661 connector assembly Will;have an indentation =1/2 inch wide band

behind the jaws, for newer units this will be covered with a red stripe, but this stripe may have worn off on the older models.

To the best of my knowledge the piece of equipment identified below (the

equipment must be uniquely identifiable, either by labeling, marking, or

tagging, or other means to signify which piece of equipment is certified as

meeting the conditions of this checklist)has been manufactured after 1964, meets the conditions of this checklist, and is the same design as a similar

piece of equipment that has been registered and approved by the NRC.

Specify Equipment (i.e., Guide Tube) Signature

Include Identifier/Labeling

Printed or Typed Name

Attachment 1 IN 96-20

April 4, 1996 Amersham Model 402, 489, and 676 Guide Tubes

To assure the associated equipment you are using are approved Amersham

manufactured accessories, please perform a side by side comparison against

a

known (i.e., flying A is legible or POs are available) Amersham manufactured

piece. Perform a detailed mechanical and visual inspection of your equipment

against the following checklist. If you have any questions, please call

Amersham for assistance.

Amersham Guide Tubes:

1. Housing should be yellow polyvinyl with either a 5/8 inch or 3/4 inch

outer diameter.

2. The fittings are yellow iridited steel, the threaded fittings consist of

1 inch 18 thread.

3. The fittings for both the threaded fitting and the source stop fitting

will have 2 single swage marks approx 1/4 inch apart.

4._ The Amersham standard source stops are made from aluminum and are 2 1/2 inches long.

To the best of my knowledge the piece of equipment identified below (the

equipment must be uniquely identifiable, either by labeling, marking, or

tagging, or other means to signify which piece of equipment is certified

meeting the conditions of this checklist) has been manufactured after 1964,as

meets the conditions of this checklist, and is the same design as a similar

piece of equipment that has been registered and approved by the NRC.

Specify Equipment (i.e., Guide Tube) Signature

Include Identifier/Labeling

Printed or Typed Name

Attachment 2 IN 96-20

April 4, 1996 CUSTOM EVALUATION OF ASSOCIATED EQUIPMENT

The information provided below applies to custom registration of associated

equipment.

Product Registration

Either the manufacturer, distributor, or user of the radiographic equipment

can submit the information outlined in 10 CFR 32.210 for evaluation.

If the applicant is located within the jurisdiction of the U.S. Nuclear

Regulatory Commission, the application should be sent to the following

address:

U.S. Nuclear Regulatory Commission

Sealed Source Safety Section

Mail Stop T-8-F-5 Washington, DC 20555 Otherwise, the applicant should submit the information to the appropriate

Agreement State.

Application Contents

General:

Licensees are required to use only radiography equipment, including exposure

heads and source guide tubes, that meets the requirements specified in 10 CFR

34.20. The regulations require that the exposure device and all associated

equipment must meet the requirements in American National Standard N432-1980,

"Radiological Safety for the Design and Construction of Apparatus for Gamma

Radiography," and other specific requirements listed in 10 CFR 34.20. The

standard defines the requirements for the design and method of qualifying

(testing) prototypes of gamma radiography systems.

Refer to Regulatory Guide 10.10, "Guide for the Preparation of Applications

for Radiation Safety Evaluation and Registration of Devices Containing

Byproduct Material" for information on what types of information needs to be

included in your application.

Specific:

Applications for registration for the equipment must, at a minimum, include

the following documentation:

Attachment 2 IN 96-20

April 4, 1996 1. A demonstration, either by testing or by engineering analysis, that

prototypes of the associated equipment meets the appropriate tests

listed below;

2. A list of all radiographic exposure equipment with which the equipment

will be used, and an explanation of how the equipment is compatible with

each piece of equipment;

3. Details of how the associated equipment will be identified, such as by

labeling, marking, or tagging, as meeting the requirements of

Section 34.20;

4. Complete specifications, including materials, details of construction, and complete dimensions of each component of the equipment; and

5. Likely environments (i.e., temperature, pressure, vibration, humidity, impact) and conditions of use of the equipment.

Prototype Tests

Each associated equipment design (e.g., source guide tube, collimator, exposure head) must either pass the appropriate tests listed below, or by

engineering analysis demonstrate that the designs would likely meet the test

requirements.

NRC's policy is that associated equipment that guides a source assembly a

distance greater than 10 times the length of the source capsule (i.e.,

exposure heads, "J"tubes, jet engine probes, source stops) is considered a

guide tube and must meet the testing requirements for guide tubes.

Source Guide Tube Tests

Source guide tubes are required to meet the following:

a. The crushing test specified in Section 8.6 of ANSI N432-1980;

b. a kinking resistance test that closely approximates the kinking

forces likely to be encountered during use;

c. the endurance test specified in Section 8.9 of ANSI N432-1980; and

d. the tensile tests specified in Section 8.7 of ANSI 432-1980 for

control units.

K>

Attachment 2 IN 96-20

April 4, 1996 Exposure Head and Collimator Tests

Exposure heads and collimators that are not considered guide tubes, need only

meet the tests listed in item c, and d above.

Engineering Analysis

Engineering analysis will be considered in lieu of actual testing if the

analysis is based on a similar design that has been tested in accordance with

the standard and has been approved by the NRC or Agreement State. The

engineering analysis, at a minimum, must compare the tested design against the

associated equipment you want evaluated and address the effects of the

materials of construction (i.e., wear resistance, strength, corrosion

properties), the wall thickness, the length (i.e., resistance), any bends, bend angles and the minimum bend radii over which the bends will be produced

(curvature), and any other properties that would have an effect on the outcome

of the endurance test.

Attachment 3 IN 96-20

April 4, 1996 LIST OF RECENTLY ISSUED

NMSS INFORMATION NOTICES

Tn, nnm,+4nn flt - r

I

IL. uI 111i lull UDate OT

Notice No. Subject Issuance Issued to

96-18 Compliance With 10 CFR 03/25/96 All material licensees

Part 20 for Airborne authorized to possess and

Thorium use thorium in unsealed form

96-04 Incident Reporting 01/10/96. All Radiography Licensees

Requirements for and Manufacturers of

Radiography Licensees Radiography Equipment

95-58 10 CFR 34.20; Final 12/18/95 Industrial Radiography

Effective Date Licensees.

95-55 Handling Uncontained 12/6/95 All Uranium Recovery

Yellowcake Outside of a Licensees.

Facility Processing Circuit

95-51 Recent Incidents Involving 10/27/95 All material and fuel cycle

Potential Loss of Control licensees.

of Licensed Material

95-50 Safety Defect in Gammamed 10/30/95 All High Dose Rate

12i Bronchial Catheter Afterloader (HDR) Licensees.

Clamping Adapters

95-44 Ensuring Combatible Use of 09/26/95 All Radiography Licensees.

Drive Cables Incorporating

Industrial Nuclear Company

Ball-type Male Connectors

95-39 Brachytherapy Incidents 09/19/95 All U.S. Nuclear Regulatory

Involving Treatment Commission Medical

Planning Errors Licensees.

95-29 Oversight of Design and 06/07/95 All holders of OLs or CPs

and Fabrication Activities for nuclear power reactors.

for Metal Components Used

in Spent Fuel Dry Storage Independent spent fuel

Systems

storage installation

designers and fabricators.

Attachment 4 IN 96-20

April 4, 1996 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

96-19 Failure of Tone Alert 04/02/96 All holders of OLs or CPs

Radios to Activate When for nuclear power reactors

Receiving a Shortened

Activation Signal

96-18 Compliance with 10 CFR 03/25/96 All material licensees

Part 20 for Airborne authorized to possess and

Thorium use thorium in unsealed

form

95-03 Loss of Reactor Coolant 03/25/96 All holders of OLs or CPs

Supp. 1 Inventory and Potential for PWR power plants

Loss of Emergency Mitiga- tion Functions While in a

Shutdown Condition

96-17 Reactor Operation Incon- 03/18/96 All holders of OLs or CPs

sistent with the Updated for nuclear power reactors

Final Safety Analysis

Report

96-16 BWR Operation with 03/14/96 All holders of OLs or CPs

Indicated Flow Less Than for boiling-water reactors

Natural Circulation

96-15 Unexpected Plant Perform- 03/08/96 All holders of OLs or CPs

ance During Performance for nuclear power reactors

of New Surveillance Tests

96-14 Degradation of Radwaste 03/01/96 All holders of OLs or CPs

Facility Equipment at for nuclear power reactors

Millstone Nuclear Power

Station, Unit 1

96-13 Potential Containment 02/26/96 All holders of OLs or CPs

Leak Paths Through for nuclear power reactors

Hydrogen Analyzers

96-12 Control Rod Insertion 02/15/96 All holders of OLs or CPs

Problems for nuclear power reactors

OL = Operating License

CP = Construction Permit