ML19323E745
| ML19323E745 | |
| Person / Time | |
|---|---|
| Site: | 07109215 |
| Issue date: | 11/11/2019 |
| From: | Ransohoff B Neutron Products |
| To: | Allen C, Andrea Kock Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| EPID L-2017-LLA-0133 | |
| Download: ML19323E745 (12) | |
Text
Document Control Desk Ms. Andrea Kock, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards US Nuclear Regulatory Commission Washington, D.C. 20555-0001 Mr. Chris Allen Project Manager Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Re:
Revised Procedure R-2014G Docket No. 71-9215 EPID No. L-2017-LLA-0133
Dear Mr. Allen,
neuTROn PRODUCTS inc 22301 Mt. Ephraim Road, P. 0. Box 68 Dickerson, Maryland 20842 USA 301-349-5001 FAX: 301-349-2433 e-mail* neutronprod@erols.com 11 November 2019 As we have discussed, I am writing to supplement our replies to your Requests for Additional Information with our updated revision of our Procedure R-2014G.
If you require additional information, or have any questions, please let me know.
Neutron Products, Inc.
President
R-2014-G Unloading and !.cadirig Procedure for U~/921$/S{l!J Packag~ -
Revlsion: 3 Radioactive Materials Tran~port~Uon Page 1 of l.l UNLOAOiNG ANO LOADING PROCEDURE fOR USA/8215/il(U} PACKAGE -
AAfJtOACTI'v'E W!.ATER!ALS TRANSPORTATION PROCEDURE R-2014-G Effective Date: I \\ /Jovi,,...St I' I q Prepared by Designated Ov.rner and/or App-roved Author
- i'\\j\\?-_~) --*-
William L Ransohoff. Executh I rin.agement Date Reviewed to Ensure Compiiarn:e, Safety, and,11,deq.uaq, for intended Purpose
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Date
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iJate
)): {"cf};~ RSO-Fl~d Op~-;J-or-,s-"---
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OAMRT *&=..
- I\\ fiJfJlflu""-&r J)ot q Dare This is. a controlled derumem and as such shall only be modified ln ao:ordam:e V11ith 1 the latest revision :trf Procedure R0S512., Preparatlo.n of Q..ua.lity Syst.em Programs l a,:id Proc,edures-'RMT and Pi:oc-edure R-5513, Documentwntror-RMT, 1
--.C.....:"'------------ --:...----'----'--~~--'----'1 Not valid fur use without a control copy number.
- Control Copy tllB. -~---
Document No.
R-2014-G
- 1.
Purpose Unloading and loading Procedure for USA/9215/B{U) Package -
Radioactive Materials Transportation Revision: 3 Page 2 of 11 This procedure establishes instructions for the routine handling, loading and unloading of USA/9215/B(U) packages in accordance with the Certificate of Compliance, Neutron's Quality Assurance Program for the Transportation of Radioactive Materials, and applicable provisions of 10 CFR 71, subpart H.
- 2.
Scope 2.1.
This is a genera! procedure applicable to any authorized user and/or facility. Authorized users/facilities should develop and implement specific procedures, work lnstructlons, and/or other documents covering aspects of implementation which are specific to their operations.
2.2.
This procedure app!ies only to USA/9215/B(U) packages at hot ce!is and field operation sites.
2.3.
Transferring radioactive sources between a transfer cask (TC) and a therapy or irradiation unit is within the scope ofthe licensee's radioactive materials license and is not covered under this procedure.
- 3.
Definitions and Abbreviations ALARA:
COC:
C of CA:
OP:
QAMRT:
QAP:
RPP:
RSO:
Shipper of Record:
TC:
Control Copy No. ____ _
As !ow as reasonably achievable per 10 CFR 20.1003.
Certificate of Compliance, USN RC - the certificate issued by the Commission under subpart D of this part which approves the design of a package for the transportation of radioactive material. (10 CFR Part 71).
Certificate of Competent Authority, USDOT - a certificate from a national agency responsible under its national law for the control or regulation of a particular aspect of the transportation of hazardous material (dangerous goods}. (49 CFR Part 171.8}.
Overpack-The protective jacket packaging component, constructed of steel and wood.
Quailty Assurance Manager Radioactive Transportation Quality Assurance Program for the Transportation of Radioactive.
Materials, Neutro~ Products, lnc:.
Radiation Protection Program Radiation Safety Officer, or qualified designee, of the shipper of record if the RSO is used alone. Other RSO positions are specifically designated in the procedure.
Licensee who offers licensed material to a carrier for transport.
Transfer Cask, lead-steel inner portion of the packaging.
Document No.
R-2014-G USDOT:
USNRC:
Unioading and Loading Procedure for USA/9215/B{U) Package -
Radioactive Materials Transportation United States Department of Transportation United States Nuclear Regulatory Commission Revision: 3 Page 3 of11
- 4.
References Federal Regulations USDOT:
49 CFR 172 49 CFR 173 Certificate of Competent Authority-Certificate USA/9215/B(U)
USNRC:
10 CFR 20 10 CFR 37 10 CFR 71 Certificate of Compliance - Certificate USA/9215/B(U)
Neutron Requirements Drawings:
Neutron Drawing {for OP} 240116 Neutron Drawing (for TC) 240122 Procedures:
Procedure R-2019-G S.
Qualificatkn'i and Responsibilities 5.1.
Genera! -Al! Personnel Personnel snail be qua!ified and trained in accordance wlth the app!icab!e QAP and RPP to perform their assigned responsibilities for operations conducted in accordance with this procedure.
5.2.
The QAMRT is responsible for evaluating reports of damage to packaging and consulting with executive management on plans of action to address the problem.
- 53.
The RSO, or qualified designee, shall be responsible for administering the app!icab!e RPP, as it applies to the use of the USA/9215/B(Ul package.
5.4.
Operations
- 6.
Safety Qualified personnel are responsible for receiving, unloading and loading shipping packages in accordance with the COC and applicable regulations.
Qualified personnel of authorized users are responslble for shipping packages in accordance with the COC and applicable regulations.
6.1.
All procedures, regulations, security measures and precautions associated with the handling of radioactive materials shall be followed.
Control Copy No. ___
Document No.
Unloading and Loading Procedure for USA/9215/S(U) Package -
Revision: 3 i
R-2014-G Radioactive Materials Transnortation Page 4 of11 L------'----*--------------'-"---------"-----=-----
6.2.
AH Neutron employees working under this procedure have stop work authority to the extent they believe a proposed operation to be unsafe. Neutron management wm address concerns raised before work is resumed.
6.3.
Replacement parts for, and services performed on, packaging - including those that are critical to safety - are subject to all applicable provisions of applicable regulations, the QAP, and the COC.
- 7.
Equipment Requirements 7.1.
As appropriate, tools, gauges1 measuring and testing devices shall be controlled/
calibrated and adjusted in accordance with the requirements of 10 CFR 71.125 and the applicable QAP.
7.2.
Maintenance and calibration of a!! radiation and contamination monitoring equipment shall be performed in accordance with the RPP and QAP.
7.3.
Tools and equipment for hot cell and/or field operations are specified in documents not covered under this procedure and are therefore approved under the applicable RPP or QAP.
- 8.
Procedure 8.1.
Job Preparation 8.1.1.
Prior to shipping the package, a quaiified person shaH complete a Transfer Cask (TC) Layout Form or equivalent.
8.1.2.
The Transfer Cask (TC) Layout Form or equivalent shall be reviewed by another qualified person to confirm compliance wlth the COC, C of CA, 10 CFR Part 71, and/or DOT regulations. The review shall include, but not be limited to, the following:
8.1.2.1. Source dimensions and position; 8.1.22. Shield plug/sleeve dimensions, position and materials of construction;
- and, 8.1.2.3. Shielding evaluation.
8.1.3.
The shielding evaluation will be based on a review of the following:
8.1.3.1. The isotope, activity and dimensions of the source.
8.1.3.2. The proposed shielding configuration.
8.1.3.3. A comparison of the proposed shipment with prior shipments.
NOTE: If the current shipment is within the bounds of previous shipments then an additional more detailed shielding evaluation is not required. To the extent a proposed shipment is not bounded Control Copy No. ____ _
Document No.
R-2014-G Unloading and loading Procedure for !JSA/9215f B(U} Package -
Radioactive Materials Transportation Revision; 3 Page 5 ofll by prior shipments (in terms of source activity and dimensions), the anticipated dose rates shall be determined by calculation.
8.1.4.
DetaHed Shielding Evaluation. The following describes an acceptable approach to a detailed shielding evaluation. It is not the only approach, but any alternative used shall be demonstrated to provide comparabry accurate results.
8.1.4.1. For sources which are dlmensiona!ly small, !ike a teletherapy type source, the entire activity can be considered a point source. For dimensionaHy !anger sources with uniform activity distribution, such as a penci! source or group of sources, the total activity can be divided into eight equal fractions which, for the purposes of these calculations, will be considered point sources. Dose rate calculations can be performed for each of these eight "sources", with the first such "source" being placed at the very end of the source closest to the side of the cask on which the analysis will be performed, and each subsequent "source" placed at intervals of 1/8th of the overall source 1ength. As seen in the sketch beiow, this "source" placement slightly shifts the activity toward the side of the cask on which the calculations are performed, which may result in the calculated dose rates being slightly elevated:
8.1.4.2. Dose rates for each of the "point sources" can be summed for a total predicted dose rate at a particular point At a mln!mum, the evaluation shall be used to predict the highest dose rate at contact with the surface of the package and at a distance one (1) meter from the package, in order to demonstrate anticipated compliance with 10 CFR 71.47(a). To the extent those dose rates indicate thatthe 71.47{a) ilmits may be exceeded, then the evaluation shall be extended to demonstrate anticipated compliance with 10 CFR 71.47{b}.
8.1.4.3. Any demonstrably effective method may be used for dose rate calculation. Such methods include direct calculation using the inverse square law, as appropriate, and the standard linear attenuation shielding formula:
Control Copy No. ____ _
I= {l0 ) x {e*µx) x B, where:
I ls the shielded dose rate; lo is the unattenuated dose rate;
µ is the linear attenuation coefficient for the shielding material; x ls the thickness ofthe shielding material; and,
Document No.
R-2014-G Unloading and Loadlng Procedure for USA/9215/B(U} Package -
Radioactive Materials Transportation Revision: 3 Page5 of11 B is the buHd-up factor for the thickness of the shielding material.
8.1.4.4. Alternatively, readily available programs such as those offered by Microshie!d and radprocakulator can also be used.
8.2.
Receipt of Packages 8.2.1.
Receipt of packages shall be scheduled by the RSO, or quallfied designee, in accordance with 10 CFR 37.75, and packages shall be received in accordance with 10 CFR 20.1906.
8.2.2.
Survey the package.
8.2.2.1.
If the radiation levels are not within the limits specified in 10 CFR 71.47, the following process shall be foBowed:
Notify the RSO and the RSO of the receiving licensee of the situation; The RSO shall immediately notify the carrier and the NRC Operations office as required by 10 CFR 20.1906; The parties sha!f work to resolve the situation; and, No packages shall be ieft unsecured and unattended during the receiving process.
8.2.2.2.
!f the radiation levels are within the limits as specified in 10 CFR 71.471 remove the package from the transport vehicle if necessary or deslrabie for unloading the TC from the OP.
8.2.2.3.
lf the package contains radioactive material, verify that the sea! is unbroken. If the sea! is broken or if there is no seal, notify the RSO' and proceed according to his or her instructions.
8.2.3.
Visually inspect the package for damage in accordance with R-2019-G.
8.2.3.1.
If the package appears damaged, notify the QAMRT and proceed I
according to their instructions. Instructions shaH include a p!an of action to survey and wipe test the package, as necessary, and notify the RSO of the receiving iicensee.
8.2.4.
As appropriate for the mechanism by which the lid is to be removed, remove the plate, cover, and/or bolts that render inoperable the lid lifting eye, lifting bale or lid cover bolt plates.
8.2.5.
Remove the meta! tid nuts and bolts and save the fasteners for shipping the package later. Remove the metal Hd from the OP.
Control Copy No. ___
Document No.
R-2014-G Unloading and loading Procedure for USA/9215/S{U) Package -
Radioactive Materials Transportation Rev1sion: 3 Page 7 of11 8.2.6.
Remove the nuts from the wooden lid and save for shipping the package later.
Remove the wooden lid from the OP.
8.2.7.
Ensure that the cask lifting bale ls securely attached by the two (2) nuts and bo!ts supplied with the package.
8.2.8.
Remove the TC from the OP and inspect both for damage ln accordance with R-2019-G.
8.2.8.1.
Notify the QAMRT of any damage found.
8.2.8.2.
To the extent damage is identified, use the package for further shipments oniy with the approval of the QAMRT.
8.2.8.3.
Replace both OP tids, as necessary, when the empty package ls left outside during use of the TC.
8.2.9.
Move the TC to the location specified by the receiving facility in accordance with its 10 CFR 37 Securlty Program.
8.3.
- Unloadrng/Loading of Sources From/Into the Transfer Cask {TC) 8.3.1.
Operations involving the transfer(s) of radioactive material utilizing the TC shall be performed in accordance with the NRC or an agreement state operating license{s) specific to the proposed plan of work.
8.3.2.
In addition to authorized users of the package, hot cell operations may a!so be performed, tn conjunction with Neutron Products, lnc., by a licensee approved by Neutron's RSO, field Service Operations, but who is not itself an authorized user of the package.
8.3.3.
Handling, leak test, and wipe tests shall be performed ln accordance with procedures and regulatory requirements.
8.3.4.
Source(s), sleeves, plugs and/or shields shall be unloaded and/or loaded into the TC in accordance with al! requirements of the COC and the speclfic task to be performed.
8.3.5.
Verify that the surface of the gasket{s) has not been damaged during source handling or unloading operations. lf any gasket is damaged, notlfy Neutron's QAMRT in accordance with the latest revision of R-2019-G.
8.3.6.
The TC end covers shall be secured with the bolts and tightened to 100-125 inch-pounds.
8.3.7.
Decontaminate external surfaces of the TC to ensure contamination levels comply with 49 CFR 173.443 and are as low as practical in accordance with ALARA and !icensee procedures.
Control Copy No. ____ _
Document No.
R-2014-G Unloading and loading Procedure for USA/9215/B(U) Package -
Radioactive Materials Transportation Revision: 3 Page 8 of11 8.3.8.
The TC shall be inspected for damage in accordance with the latest revision of R-2019-G and prepared for shipment in accordance with Section 8.4 of this SOP.
8.4.
loading the Transfer Cask {TC) into the OP 8.4.1.
Survey the TC.
8.4.2.
Place a tag on the end covers to serve as an indicator of the radioactive hazard that is present during periods of time when the TC is not contained within the OP.
8.4.3.
Visually inspect the TC and OP assembly and lids before loading the TC ln the OP in accordance with the Visual inspection Checklist for USA/9215/B(U) Packages and maintain the completed form with the shipping records.
8.4.4.
if any damage is found, notify Neutron's QAMRT in accordance with the latest revision of R-2019-G and do not use the package for shipments of radioactive materia! without approval of Neutron's QAMRT.
NOTE: No package shall be left unattended durjng the,oading process, and shipment shall be made as soon as practical in accordance with the security measures in place at the shipping site/facility.
8.4.5.
Load the TC into the OP and install the wooden lid.
8.4.6.
Turn the nuts down on the threaded rods until contact ls made with the washers, then tighten~+/- ;4 turn. Do not overtighten.
8.4.7.
lnstaH the stee! lid.
8.4.8.
!nstail all thirty-six (36) bolts and nuts that were removed during unloading and hand tighten.
8.4.8.1. Drawing 240116 specifies a torque of 40 ft-lbs +/-15%, so the fasteners should be tightened to between 34 and 46 ft-lbs.
NOTE: If any fasteners are lost, missing, or damaged, replace with parts approved for use in accordance with the QAP.
8.4.9.
Visually inspect the assembled package in accordance with the Visual Inspection Checkllst for USA/9215/B(U) Packages to ensure that the package satisfies an requirements of the COC.
8.4.10. Render the lid lifting eye lnoperable for lifting the package.
8.4.11. If a lid lifting bale is used instead of the lifting eyer remove the lid lifting bale before shipplng the package and install the four (4) nuts and bolts ln the holes to render the holes inoperable for lifting.
Control Copy No. ___
Document No.
R-2014-G Unloading and loading Procedure for USA/9215/B{Ui Package -
Radioactive Materials Transportation Revision: 3 Page 9 of 11 8.4.12. Conduct radiation and contamination surveys of the package. if necessary, decontaminate the outside of the package to levels which are in compliance with 49 CFR 173.443 and which are as low as practical in accordance with ALARA.
8.4.13. Prepare and affix the appropriate labels for the shipment in accordance with 49 CFR 172.403.
8.4.14. !nstali a tamper indicating seal and record the results on the Visua! Inspection Checklist for USA/9215/B{U) Packages.
8.4.15. The package shall be loaded onto the transport vehicle and a radiation survey performed in accordance with the applicable requirements of 10 CFR 71.47 and 49 CFR 173.441. if the dose rates exceed the regulatory requirements,, the RSO shall be notified and the situation corrected.
8.4.16. Visually inspect the assembled package on the transport vehide to confirm that it was not damaged during the loading process and that it has been secured in or on the transport vehicle. Notify the QAMRT of any damage and do not shtp unless authorized by the QAMRT.
- 9.
Records 9.1.
Records shall be captured and retained by the RSO in accordance wlth 10 CFR 71.91.
- 10.
Change Record 1----=D=a=t=e,__-+-=R=e=v=*is=io=n~--==A=u=th=o=r"'---l'-=c=h=a=n"'"g~e=D=e=t=a=i!=s------------------1 10/27 /19 3
B. Ransohoff Periodic Review of Procedure - Desktop Audit Control Copy No. ____ _
- !* Aligned Procedure with Forms Performed Process Flow
- !* Aligned SOP w/ Process Flow
.. :. Revised to incorporate request from NRC Section 5 - Consolidated fixed location and field operations into "Operations" and removed references to hot cells throughout the procedure.
Section 8.1-Added "Job Preparation" section, as a result of discussions with NRC.
Section 8.2.9 - Changed to reflect general practice of operating in accordance with site 1.s Security Plan whi!e at field locations.
Document No.
R-2014-G 05/17/18 Unloading and Loading Procedure for USA/9215/B(Uj Package -
Radioactive Materials Transportation Revision: 3 Page 10 of11 I
Section 8.4.2 - Discontinued use of Yellow li I
and Yellow m labels on TC, in favor of a tag communicating comparable dose rate information.
Sections 8.4.6 - 8.4.8 - Added operating details regarding bolt/nut tightening to conform to specifications in revised drawing 240116, Rev J.
8.4.16 -Added additional final package inspection step after it has been secured on transport vehide.
2 J. Fog!e I Cover Page - Added RSO, Field Servlce Operation as
- reviewer.
/ Section 3 -Added QAMRT and QA.P and clarified RSO I posltions.
I l
I Section 4-Removed reference to USA/9102/B(U) COC /
I which has expired.
/
I Section 4 - Removed reference to ANS! specification I for leak testing sources i Section 5 -Added QAMRT and responsibilities.
/ Sectron 5 - Added hot eel! and field operations I personnel and responsibi!ities.
l Section 6 - Added security measures ln listed actions.
I Section 7 - Added tools and equipment for hot eel! and i field operations to clarify app!icabi!ity to appropriate I programs and/or procedures.
I Section 8 - Rewritten to indude receiving packages I on!y.
Section 9 -
New - for unloading and loading of the TC at hot cell and field operation sites.
I Section 10 - New - for loading and shipping the I
kage only.
Section 11-New - for records.
Section 12 - New - for change record.
I Appendix A - Added for parts specified on package components.
Attachment A - Visual inspection checklist, or equivalent - sample.
I I Control Copy No. ____ _
Document No.
R-2014-G Unloading and Loading Procedure for USA/9215/S(U) Package -
Radioactive Materials Transportation APPENOtXA Maintenance Parts The following parts shaH be used for the maintenance of the TC:
Bolt:
Grade 8 stee! hex head cap screw W' -13; 1 ~" long Gasket:
Identification Tag:
item 71, Drawing 240122 Silicone Rubber - ASTM D-2000-80
'/16u thick Item 47, Drawing 240122 item 49, Drawing 240122 The foilowing parts shall be used for the maintenance of the WPJ and MOS:
Threaded Rod:
UNC Steel Threaded Rod 5/{ lnch; 41 W' long (nominal)
View D, Drawing 240116 Nuts for WPJ:
UNC Steel Hex Nut 5/{' inch View D, Drawing 240116 Washer for WPJ:
Steel Fiat Washer 5/s" inch View D, Drawing 240115 Hex Nut for WPJ:
UNC Steel Hex Nut 5/s" inch View D, Drawlng 240116 Plywood Sheet for WPJ:
P!ywood Sheet
%" thick (nominal)
Section F-F, Drawing 240116 Screw for MOS:
Grade 5 Hex Head Cap Screw W' -13; 1JJ !ong Section A-A1 Drawing 240116 Nut for MOS:
Grade 5 Steel Hex Nut Yi" -13 Section A-A, Drawing 240116 Control Copy No. ____ _
Revision: 3 Page 11 of11