ML20066L510
| ML20066L510 | |
| Person / Time | |
|---|---|
| Site: | 07109036 |
| Issue date: | 03/06/2020 |
| From: | Schehr K Isoflex Radioactive |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML20066L510 (4) | |
Text
ISO-RAD TM ISOFLEX RADIOACTIVE LLC 108 Teal Street St. Rose LA 70087 March 06, 2020 Tel: +1-504-305-4320 Cell: +1-504-717-7811 Attn: Document Control Desk Fax: +1-504-324-0237 Director, Division of Fuel Management, Email: kjs@iso-rad.com Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001
Subject:
Docket 71-9036 : Application for Letter of Authorization Reference 1: Photo Nordion Nameplate Reference 2: ISO-RAD Nameplate Drawing Reference 3: Previously submitted 10 CFR 71.95 Notification Investigation Report Dated February 23, 2020 (Not Attached)
Reference 4: Redacted 10 CFR 71.95 Notification Investigation Report Dated February 23, 2020. (Attached)
Document Control Desk:
ISOFLEX Radioactive LLC (ISO-RAD) is a Louisiana Department for Environmental Quality (LDEQ) licensee. As discussed with Mr. Bernard White, Senior Project Manager, Division of Fuel Management, ISO-RAD is submitting the following application for a Letter of Authorization for a variance to the nameplate for the USA/9036/B(U)-96 Type B(U) package Docket Number 71-9036.
Summary:
An initial 10 CFR Part 71.95 Notification was submitted (ID# 29788) to the USNRC on February 14, 2020. Subsequently, a detailed investigation was submitted (ID# 29883) to the USNRC on February 24, 2020 explaining the circumstances surrounding an export shipment that is halted at JFK airport. The investigation revealed a variance in the nameplate attached to the 71-9036 transport packages being used. ISO-RADs fleet of transport containers were voluntarily removed from service pending the investigation and resolution of this matter. ISO-RAD is suffering economic hardship as a result of not being able to transport sources using the 71-9036 transport containers.
Conditions:
The ISO-RAD application is requesting the following conditions for a nameplate variance:
- 1) Allow the transportation of the two 71-9036 containers S/N 146 and S/N 153 with Nordion nameplates (see attached photo) from JFK to ISO-RADs facility in St. Rose, LA. The above containers are in a secure dangerous goods cage at JFK airport and the airline would like to have these out of their warehouse as soon as practicable. The transportation of the RADIOGRAPHIC EQUIPMENT & REPLACEMENT SOURCES
Docket 71-9036 Request for Letter of Authorization March 6, 2020 Page 2 of 3 containers is to be accomplished immediately after issuance of the Letter of Authorization and no later than four (4) weeks of issuance of the Letter of Authorization.
- 2) Allow the continued use of the Nordion nameplate on the drum for a maximum period of four (4) months (see attached photo) from the issuance of the Letter of Authorization. This will enable ISO-RAD to have the proposed new nameplates manufactured and installed.
ISO-RAD will notify the USNRC once this task is completed.
- 3) Allow the use of an ISOFLEX Radioactive LLC nameplate until the current expiration date of the USA/9036/B(U)-96 certificate on October 31, 2021. The proposed ISOFLEX Radioactive LLC nameplate drawing is attached.
Conclusion:
The subject 71-9036 packages in ISO-RADs possession fully comply with current USA/9036/B(U)-96 certificate of compliance in all aspects of safety, integrity, and security. The current affixed nameplate has the required regulatory information as referenced in 10 CFR 71.85.
The 71-9036 transport containers in ISO-RADs possession are inspected according to the conditions stated in the Certificate of Compliance items 7 and 8 with reference to the 71-9036 SAR Sections 7 and 8. The structural elements of the package are identical, with the exception of the nameplates. The request for a nameplate variance does not affect or degrade the safety, security, or integrity of the Type B package.
Thank you and ISO-RAD is ready to respond to any additional requests for information concerning this matter.
ISOFLEX Radioactive LLC Kevin J. Schehr, DBA President & RSO RADIOGRAPHIC EQUIPMENT & REPLACEMENT SOURCES
Docket 71-9036 Request for Letter of Authorization March 6, 2020 Page 3 of 3 Current Nameplate on the drums in ISO-RADs possession RADIOGRAPHIC EQUIPMENT & REPLACEMENT SOURCES
8 7 6 5 4 3 2 1 REVISIONS 1.50 REV. DESCRIPTION DATE APPROVED 203.20mm+1.50
- 0 INITIAL RELEASE 03/06/2020
+.059 8.000in - .059 D D 1.50 5 127mm+1.50 88.90mm+5
+.059 +.197 5.000in - .059 3.500in - .197 C C 4x 3.30mm .130in 5 THRU 175.85mm+5 B +.197 B 6.923in - .197 1.50 1mm 203.20mm+1.50
.039in +.059 8.000in - .059 DRAWN KJS 03/06/2020 DESCRIPTION:
NOTE 1: Large lettering is 12.01mm (0.476") highand etched, engraved or laser engraved 0.25 mm (0.0098") deep. ISOFLEX Radioactive LLC 108 Teal Street UNLESS OTHERWISE SPECIFIED Model C-1 Nameplate A NOTE 2: Medium lettering is 7.14 mm (0.281") high and etched, engraved or laser engraved St. Rose LA 70087 USA DIMENSIONS ARE IN MILLIMETERS A 0.25 mm (0.0098") deep. T +1 504-305-4320 ANGLES .XX .XXX .XXXX ISOFLEX Radiatactive LLC NOTE 3: Small lettering is 6.15 mm (0.242") high and etched, engraved, or laser engraved F +1 504-324-0237 .5 .10 .100 .0500 0.25 mm (0.0098") deep. LICENSE INFORMATION SIZE DWG. NO. REV MATERIAL: AISI 316 NOTE 4: All lettering is filled with black paint, black powder coat, or similar permanant black marking. THE INFORMATION CONTAINED IN THIS DRAWING IS THE SOLE PROPERTY OF ISO-RAD. ANY REPRODUCTION IN PART OR AS A WHOLE WITHOUT THE WRITTEN Stainless Steel NOTE 5: Background is either polished stainless steel, yellow paint, or yellow powder coat. PERMISSION OF ISO-RAD IS PROHIBITED. B 200306-100 0 NOTE 6: Rivet hole pattern may vary THIRD ANGLE PROJECTION SCALE: 1:1 WEIGHT: g SHEET 1 OF 2 8 7 6 5 4 3 2 1