ML18127B735
| ML18127B735 | |
| Person / Time | |
|---|---|
| Site: | 07109215 |
| Issue date: | 05/07/2018 |
| From: | Ransohoff B Neutron Products |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML18127B734 | List: |
| References | |
| Download: ML18127B735 (4) | |
Text
Document Control Desk Director Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards United States Nuclear Regulatory Commission Washington, DC 20555-000 neUTROn PRODUCTS lnC P.O. Box 68 22301 Mt. Ephraim Road Dickerson, MD 20842 Tel: (301) 349-5001 7 May 2018
Subject:
Consolidated Application for Renewal of CoC - USA/9215/B(U) Packages Please find attached the consolidated application for renewal of the Certificate of Compliance USA/9215/B(U). We request that the Certificate be renewed for the maximum allowable period.
A table summarizing the changes made to the Certificate since the last consolidated application has been attached.
The last consolidated application was Revision 4 of the Safety Analysis Report. In 2012, Section 5 was revised to make some corrections to the shielding calculations, with the substituted pages labeled as Revision 5. This submittal is Revision 6.
We request that the drawings included in this application be withheld from public disclosure due to the proprietary nature of the information contained therein. In accordance with the requirements of 10 CFR 2.390, this request is supported by the attached affidavit.
Furthermore, as discussed in RIS 2005-31, the drawings and the application itself contain, or may contain, security-related sensitive information and, on that basis, should also be withheld from public disclosure under 10 CFR 2.390.
While many editorial and formatting changes have been made to this Revision, very few substantive changes have been made.
The package was initially used primarily to transport teletherapy sources. Although it is still used in that capacity, it is increasingly being used to also transport sources in different configurations. As a result, throughout the SAR, some references to "teletherapy sources" and "teletherapy machines" have been removed, and some references to other sources, such as "pencil sources" have been added;
9215 Renewal Application 7 May 2018 Page 2 In Section 2, the weight of the shield plugs used was increased to provide for the more extensive use of tungsten alloy shield plugs. This change did not increase the maximum weight of the package used in the calculations because that maximum weight of 6,000 pounds is already significantly greater than the weight of the package as it is normally configured, which is approximately 5,200 pounds; In Section 5, some additional shielding calculations and examples were added.
The referenced drawings were updated to remove Drawing A240012, which had previously been incorporated into Drawing 240122, and to reference Rev. J of Drawing 240116, which has been added to the current Certificate (Rev. 14).
In addition to renewing the Certificate, we request that the following additional changes be made to the Certificate:
Item 5(a)(2), Description, be changed to increase the diameter from approximately 49 inches (which reflects the body of the Steel Shell of the overpack) to 55 inches, which would also include the flange which secures the lid to the body, and the tie downs.
Item 7 be changed from "lead, steel, or tungsten full diameter plugs and spacers" to "lead, steel, and/or tungsten alloy full diameter plugs and spacers." The text of the SAR has used both descriptions, "tungsten" and "tungsten alloy" interchangeably, and that is in error. However, the calculations have always been conducted based on tungsten alloy, as can be seen in Table 5.3.1 which is now in SAR section 5.3.2 Material Properties.
"Tungsten alloy" is called out in the Table, and the density is reported as 17 glee, instead of 19 glee which would be the case if pure tungsten had been used as the basis for the calculations.
The Safety Evaluation Report which accompanied Rev. 10 of the CoC in May, 2010 includes a requirement that is not in the CoC. On page 2 of the SER,"... and provided that the applicant uses at least 2 inches of Lead or Tungsten, or 3 inches of steel as axial shielding material in the drum assembly." We have complied with this requirement since its issuance, but it is not actually in the CoC. There are two issues here. First, regarding the merits, we submit that the requirement is not necessary for long, very low activity sources and request that the NRC reconsider the requirement. Second, if the NRC determines that it is a necessary requirement, we request that it be added to the CoC.
Thank you for your consideration of these matters. The referenced Certificate is the company's only Type B package and is essential for our continuing participation in the delivery of radiation therapy sources for medical applications; the reloading and removal of sources in various inc
9215 Renewal Application 7 May 2018 Page 3 irradiators used in research, academia, industry and government facilities; and the OSRP and IAEA efforts to recover sources which are no longer in use.
We believe that there is no technical reason why this request for renewal should not be granted.
If you have any questions, or require additional information, please contact me at (301) 349-5001. Alternatively, I can be contacted by e-mail at neutronprod@rcn.com. Mail can be sent to Neutron Products, Inc./ PO Box 68 / Dickerson, MD 20842.
Neutron Product, Inc.
President This submission includes the following documents:
Filename 001 Renewal 9215 -Letter ofTransmittal.pdf (this document) 002 Renewal 9215 -Affidavit.pdf 003 Renewal 9215 -Table of Contents.pdf 004 Renewal 9215 - Section l.pdf 005 Renewal 9215 - Section 2.pdf 006 Renewal 9215 - Section 3.pdf 007 Renewal 9215 - Section 4.pdf 008 Renewal 9215 - Section 5.pdf 009 Renewal 9215 - Section 6.pdf 010 Renewal 9215 - Section 7. pdf 011 Renewal 9215 - Section 8.pdf 012 Renewal 9215 - Sandia Test Results.pdf 013 Renewal 9215 - Drawing 240122H-l.pdf 014 Renewal 9215 -Drawing 240122H-2.pdf 015 Renewal 9215 - Drawing 2401161. pdf Size Sensitivity 993 kB Public 842kB Public 327kB Public 368 kB Public 3976 kB Public 1968 kB Public 624kB Public 1341 kB Public 39kB Public 1259 kB Public 296kB Public 8573 kB Public 1808 kB Proprietary 937kB Proprietary 409kB Proprietary All documents were submitted electronically, there are no BLOBs, no special instructions, the files do not deviate from approved formatting and do not contain links to other files or websites.
neLJTROn PRODUCTS inc
Table 1: Certificate of Compliance No. USA/9215/B(U) coc Reason for Amendment Amendment 10/29/1992 Consolidated application for renewal of Coe No. 9215. This supplemented our initial application for renewal dated September 14, 1992 11/17/1993 Request for approval to use alternative cask internals, i.e. drum assemblies that were approved for use under other Coe 9102 and CaC 5800 in the 9215 package.
9/8/1997 Request for the Coe USA/9215/B(U) to be renewed for the maximum period.
9/5/2002 Request for the CoC USA/9215/B(U) to be renewed for the maximum period.
5/1/2003 Request for renewal and amendment of Coe USA/9215/B(U). Supplement to application dated September 5, 2002 10/7/2003 Request to have drawing 240116 in Coe USA/9215/B(U) be corrected from Rev. F to Rev. G to correct the cavity depth of the WPJ from 27-1/4 to 29-1/4 inches.
2/16/2007 Request to amend the Coe USA/9215/B(U) by adding a note including rivet and SS screw sizes, also that the vent holes in the package would be covered with waterproof tape.
3/15/2007 Correction to subject line of February 16, 2007 letter 3/12/2008 Request for renewal of CoC USA/9215/B(U). Updated revisions of R-2014-G, Rev.1 &
R-2019-G, Rev.1 were attached.
4/8/2010 Request to add special form Cs-137 sources to the list of authorized contents in our USA/9215/B(U) packages.
4/15/2010 Email regarding shipment of a special form Cs-137 in our 9215 package including plans for package configuration.
2/9/2012 Request with supporting documentation to increase the permissible activity limit for Cs-137 in our USA/9215/B(U) package from 600 Ci. to 20,600 Ci.
7/5/2012 Revised SAR to correct shielding calculations/analysis errors in our October 29, 1992 consolidated application 3/29/2013 Request for renewal of Coe USA/9215/B(U}. Updated revisions of R-2014-G, Rev.2 &
R-2019-G, Rev.2 were attached.
8/24/2018 Submitted modified Drawing 240116 Rev. J for review to be included in Coe 9215.
Coe 9215, Rev 14 was issued on April 17, 2018.
9/22/2018 Submitted modified Drawing 240116 Rev. J for review to be included in CoC 9215.
Coe 9215, Rev 14 was issued on April 17, 2018.
3/1/2018 Submitted modified Drawing 240116 Rev. J for review to be included in CoC 9215.
Coe 9215, Rev 14 was issued on April 17, 2018.