ML20155C095
| ML20155C095 | |
| Person / Time | |
|---|---|
| Issue date: | 10/29/1998 |
| From: | Steven Baggett NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Galen Smith AFFILIATION NOT ASSIGNED |
| References | |
| SSD, NUDOCS 9811020075 | |
| Download: ML20155C095 (5) | |
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i UNITED STATES NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 20666-0001 k
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October 29, 1998 G.M. Smith, Jr., President BSI Instruments j
l Hopewell Business Park l
101 Corporation Drive.
Aliquippa, PA 15001
Dear Mr. Smith:
This letter is in response to your application dcted October 16,1998, requesting registration of the Model NW-501D/L series devices. Typically, the U.S. Nuclear Regulatory Commission (NRC) performs an initial acceptance review of an application upon receipt. In this case, NRC has performed a complete technical evaluation your application. In order to continue our evaluation of your application, we request that you provide the following information:
1.
Some drawings in your application include statements that the drawings must be withheld from public disclosure. In order for NRC to consider this request, you must submit an application, in accordance with 10 CFR 2.790, requesting NRC to withhold the information. The application must be accompanied by an affidavit as-specified in i
Section 2.790(b)(1) of 10 CFR Part 2 requires that each supporting application be accompanied by an affidavit thst contains a full statement of the reasons on the basis of which it is claimed that the information should be withheld from public disclosure.
The section further states that the Commission will consider whether the information is of a type customarily held in confidence by the applicant. Please note that, in general, only that information which can not be obtained through observation or measurement of components or documentation obtainable by a member of the public can be withheld as proprietary material.
In addition,10 CFR 2.790(b)(1)(ii) requires that a non-proprietary version be submitted. In preparing the non-proprietary version place brackets around the l
material considered to be proprietary, and white out or black out the proprietary portions, leaving the non-proprietary portions intact.
With regard to the diagrams and blueprints, information typically considered to be proprietary includes information such as dimensional tolerances and specific manufacturing notes o, details listed on the drawing. Any additionalinformation on the drawings would be releasable. In order to address this, please identify the 1
specific information on each drawing that BSI wishes to be held as proprietary.
p A proprietary version (with the brackets), non-proprietary version (with the marked out information), and the new affidavit must be submitted prior to the staff making its final proprietary detcrmination. In accordance with 10 CFR 2.790(c), the information sought to be witnheld will be placed in the Commission's Public Document Room 9811020075 9@d)39" O 7
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G.M. Smith, Jr.
2 unless you provide the Commission with the requested information, or a request that I
the letter be withdrawn, within 30 (thirty) days of the date of this letter.
2.
There are discrepancies and missing information in your application concerning the design of the device. Please review the application and clarify all discrepancies. In doing so, please address the following:
For both devices:
page 5 of the application indicates that 3/8" diameter pipe is used and the l
drawings indicate that %" diameter pipe is used.
For Model NW-501D:
Please explain the legend, note 1, on the drawing. Specifically, the radiation l
l levels are above 0.5 mr/hr, based on attachments 9-11, and it is unclear which l
dimensions could vary.
Please provide the length of item 1 of the drawing.
l Please provide the specifications for the end caps.
j Please provide the size and materials of construction for item 2 of the drawing.
Please explain the purpose of the knuri on the source holder since it will not be l
visible during use of the device and explain why there is no indicator, on the outside of the device, to indicate the inactive area.
I For the Model NW-501L:
Please verify that the device will only contain either 30 or 60 sources, that each source is installed into the appropriate source holder, and the source holders are installed into the device such that the sources are installed at a uniform distance over the entire length of,the device.
l Please provide specifications for the spacer that will be used in the inactive area of the device.
3.
BSI has indicated that the design and materials of construction for the dip tube, in which the device will be used, will be determined by the user of the device. Please specify how BSI will determine that the dip tube will ensure that the device will not be i
subjected to environments outside those included in BSI's application.
l 4.
Please provide specifications and materials of construction for the shipping containers for each device.
5.
Please explain how the Model NW-501D, which is over 10" long due to the end caps.
j will fit into the NW501D shipping container, which has an inner length of 10" l
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l G.M. Smith, Jr.
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6.
Please explain how the Model NW-501L, which is over 60" long due to the end caps, will fit into the NW501L shipping container, which has an inner length of 58.625".
7.
It does not appear that general licensees' access to the sources is restricted.
Specifically, the end caps only screw onto the device. Please indicate how the design will be modified to restrict access. The use of epoxy or thread " locking" compound would not be considered acceptable for restricting access.
8.
Please explain how the devices will be held stationary within the dip tube.
9.
Please explain how it was verified that the degradation of Teflon, due to radiation exposure, will not adversely effect source integrity.
10.
Pl ease explain why the labeling information is included on a tethered label rather than being directly engraved / etched into the device. If the concern is size of the labeling, please explain why at least some of the information (e.g., radiation symbol, model number, serial number) is not included directly on the device. Please include how the labelis attached to the rope, what pull off force is needed to separate the two, and how it was verified that the stainless steel rope would survive likely conditions of use.
11.
Your application discusses a label that is tethered to the device and includes all labeling information. However, your handling and installation instructions reference a second label that is tethered to the dip tube flange. Please provide specifications for this second label. In addition, please explain why this second labelis tethered rather than more durably attached to the dip tube (e.g., riveted to the dip tube cap).
12.
Please explain how users, not in the area of cap to the dip tube, and persons trying to enter the vessel will know that the device is installed in vessel.
13.
Please provide specifications for labeling the shipping containers.
14.
Please provide rationale for an exemption from tt]e color requirement of 10 CFR 20.1901.
15.
Please provide a demonstration that the design of both the Models NW-501L and NW-501D, when containing Teflon or carbon source holders, will maintain their integrity during the normal conditions of use and likely accident conditions. The demonstration should consider elevated temperatures, vibration, corrosive environments, humidity, bending (for the NW-501L), and impact. The prototype testing information provided in the application did not address vibration, corrosive environments, humidity, and bending. Typically, devices used as insertion gauges are subjected to extreme vibration, corrosive environments, and high humidity. In l
addition, a 5'long device is likely to be subjected bending forces when inserted or l
removed from a dip tube.
l 16.
While the prototype testing information provided in the application did address
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temperature and impact testing, the information was not sufficient to support use of l
G.M. Smith, Jr.
4 the device in the proposed environments. Therefore, please address the following concerns about the prototype testing:
It is unclear what design of the device was tested. Specifically, there are design discrepancies in the application (see item 2 of this letter). Therefore, please verify that the design of the device which BSI plans to distribute was j
tested.
All designs of the source housing were not tested. For example, testing was not performed on prototypes containing both Teflon and carbon source holders.
The drop test indicates that the testing was onto a flat target and the housing was dropped in such a manner to cause maximum damage to the face of the housing. It is unclear how the housing face could have contacted the target since the end caps on the device have a larger diameter than the pipe.
Testing at 1700'F for i hour does not support continued use of the device at 1700'F.
17.
The application is confusing with respect to maximum dose rates around eacn source holder, device, shipping container, and accessible surfa:es of the installation. Most of the confusion is due to unclear definitions of these terms Therefore, please verify or correct the following maximum dose rates which are based on the definitions provided:
The source holder is the Teflon or carbon plugs into which the source are epoxied. No dose rates were provided nor needed.
The device is the pipe, incorporating sources and Teflon or carbon plugs, and end caps. Please verify the following maximum dose rates (in mr/hr) around the device:
Model On Surface at 12" at 30" NW-501 L 8
1 0.4 NW-501D 100 5
2 The shipping containers are described in drawings S-NW501D and S-NW501L.
The maximum dose rate on the surface of each shipping container is 0.5 mr/hr.
The accessible surfaces of the installation is the accessible surfaces of the tank or vessel which contain the device, in a dip tube. The maximum dose rate on the accessible surfaces of each installation is 2.0 mr/hr.
I 18.
Please provide complete details and justifications for the dose estimates provided on pages 7 through 9 of the application. The details and justifications should include dose rates, distances, and times in each location.
G.M. Smith, Jr.
5 19.
Please provide the likely annual doses to persons working in the area around vessels containing the devices.
20.
Please indicate the maximum number of devices that will be installed in one dip tube and in one vessel. If more than one device is installed in a vessel, please demonstrate how persons occupying areas that have multiple devices will not exceed the dose criteria established in 10 CFR 32.51.
21.
The application does not include information sufficient to support having general l
licensees install or provide servicing of the device. Please provide additional information to justify your rationale for having general licensees perform these operations.
A copy of your application has been forwarded to NRC's Office of the Chief Financial Officer (OCFO) to address fee issues. OCFO will contact you directly regarding fees.
Please provide the requested information within thirty (30) days. If we do not receive the requested information within thirty (30) days of the date of this letter, we will consider your application as having been abandoned by you. This is without prejudice to the resubmission of a complete application. Once our evaluation is complete, we will forward a copy of the registration certificate to NRC's region I to support amendment of BSI's general distribution license. If you would like to discuss any of the issues identified in this letter or have any
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questions, please contact me at (301) 415-7231 or Mr. John Lubinski at (301) 415-7868.
NRC is open to having a telephone conference call or meeting with BSI to discuss in detail any of the items identified in this letter.
Sincerely, orsnaisignedey:
StevenLBaggett I
l Steven L. Baggett, Deputy Branch Chief Materials Safety Branch l
Division of Industrial and l
Medical Nuclear Safety l
Office of Nuclear Material Safety and Safeguards l
Distribution:
IMNS r/f SSD-98-95 NE01I GPangburn, RI TCombs, OCA LCamper FCombs DCool MKnapp i
DOCUMENT NAME: C:\\ FILES \\SSDS\\NR112501.DEF To nctive a copy of this docuroent,)h'dicate in the boa: "C" = Copy without attachment / enclosure "E" = Copy with attachment /enctosure
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NAME JLubinski/jl SBaggett DATE p /6 /98 A /ly /98 OFFICIAL RECORD COPY l