ML20205M764
| ML20205M764 | |
| Person / Time | |
|---|---|
| Issue date: | 04/12/1999 |
| From: | Doug Broaddus NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Galen Smith APGEE CORP. |
| References | |
| SSD, NUDOCS 9904160038 | |
| Download: ML20205M764 (3) | |
Text
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April 12, 1999 G. M. (Bud) Smith, Jr., President Apgee Corporation Hopewell Business and Indurtrial Park 103 Corporation Drive Aliquippa, PA 15001-4863
Dear Mr. Smith:
This is in response to your application, dated June 4,1997, requesting amendment to registration certificate NR-0112-D-111-S.to add a 80 mm (3.1") diameter version of the device to the registration certificate and to increase the authorized source length from 1000 mm to 1250 mm (39.4" to 49.2"), and my telephone conversation with Mrs. Mary Keller on September 28,1998, in that conversation, Mrs. Keller indicated that Apgee Corporation wished to make the Model LB 300 MUMLT device " inactive," and that the request to authorize source lengths up to 1250 mm was being withdrawn. In addition, Mrs. Keller indicated that all model devices " active" on that date, except for the Model LB 7400 Series devices, were being requested to be made " inactive." This would inc!ude registration certificate NR-0112-D-105-S I
for the Mo'iel LB 6600 Series. In previous correspondence, this model series had not been requested to be made " inactive," and to date, no hardcopy request to make the registration certificates for Model LD 300 MUMLT and LB 6600 Series devices has been received. In order to proceed with these actions, please confirm that Apgee requests the registration certificates for the Model LB 300 MUMLT and LB 6600 Series devices be made " inactive."
i in addition, our Region I office issued Confirmatory Action Letter (CAL) 1-97-023 and Supplement 1 to this CAL to you on September 19,1997, and October 3,1997, respectively, which discussed severalissues concerning the design and manufacture of the Model LB 300 MUMLT devices. Your responses to the CAL and Supplement 1 will be incorporated into the registration certificate, but as of this date, final resolution of design and construction issues identified in the CAL and Supplement 1 remain open. For this reason, we are voiding all actions for the Model LB 300 MUMLT, pending resolution of all issues identified in the CAL and Supplement 1, and resubmission of a complete application. Following resolution these issues, please submit a copy of all design and construction information concerning the Model LB 300 M82LT, submitted to our Region I office in response to the CAL and Supplement 1.
When providing a copy of design and construction information in response to the CAL and l
Supplement 1, please ensure that drawings and/or a description of all devices that have been distributed in the past are provided, to ensure the background informatica in our files is as Jl complete as possible. We received a copy of your letter to Mr. A. Randolph Blough, dated November 21,1997, concerning differing designs of devices distributed in the past. Certain discrepancies in this submission were identified and are attached. It is our understanding that our Region 1 office had previously provided this information to you, but we are providing it for consistency. Drawings and descriptions provided in response to these issues should include the materials of construction of the devices, dimensional ranges, isotopes and maximum activities, and any options that were included with the devices that could affect the operation of the shutter, shielding, or the containment integrity of the sealed source or device.
9904160039 990412 PDR RC SSD PDR u
G. Smith In addition, the folicwing specific issues concerning your application, submitted under a June 4,1997, cover letter, for the 80 mm shield must also be addressed in order for us to continue our review of the application:
I 1.
Your application dated May 12,1997, (submitted under a June 4,1997, cover letter) indicated that a 80 mm diameter shield would be constructed and subjected to performance testing, and that the results of the testing would be provided approximately September 1997. To date, the results of this testing have not been provided. Please indicate if this testing was ever performed, and if so, provide the results of this testing.
2.
Your application dated May 12,1997, (submitted under a June 4,1997, cover letter) was inconsistent in the specification of the length of the source capsule installed in the 80 trm diameter device. Section 3.0 and 3.1.1 of your application indicate that the length of the source is 275 mm (10.8"), whereas Section 3.2 indicates that the source length is e
290 mm (11.4"). Please indicate the actual source length.
Please provide a single response for all issues discussed above for the Model LB 300 MUMLT (registration certificate NR-0112-D-111-S). You may provide confirmation that Apgee is requesting the Model LB 6600 (registration certificate NR-0112-D-105-S) be made inactivate, by separate cover. If you have any questions concerning this matter, please contact me at (301) 415-5847 or Mr. Fritz Sturtz at (301) 415-7273.
Sincerely,
/s/
Douglas A. Broaddus, Mechanical Engineer Materials Safety and Inspection Branch Division of Industrial and Medical Nuclear Safety, NMSS
Attachment:
as stated Distribution:
SSD File # NR-0112-D-105-S '
NE01 JMcGrath, RI.
JLubinski
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SSD File # NR-0112-D-111-Se SSD-97-45 /
SSD-97-46 /
FSturz DOCUMENT NAME: C:\\WPDOCS\\BERTHOLD\\NR112111.DF2 Vo recohrt e copy of thin document, Indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachrnent/ enclosure "N" = No copy OFFICE MSib C
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NAME DBroa66ds DATE 4//a'99 OFFICIAL RECORD COPY I
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The following inconsistencies or areas of concern were identified in Apgee's letter dated November 21,1997:
Apgee provided a listing of 17 device drawing numbers indicated as corresponding to bottom plate designs currently in use. However,22 drawings were provided, of which only 15 corresponded to those identified in Apgee's listing and seven additional l
drawings were provided that were not in Apgee's listing. Apgee should clarify this i
inconsistency.
Of the 22 drawings provided,18 indicated a bolted bottom plate design. Of these 18, l
seven did not indicate an o-ring between the bottom plate and the body of the device.
l This is of concern, especially since these devices may be subjected to very dirty environments and may be exposed to (possibly even submerged) hot and dirty water during use. An o-ring would act as a barrier to contaminants migrating into the device, but the lack of an o-ring would tend to allow this to occur, potentially causing I
degradation of the internal workings of the device.
Apgee indicated that they inadvertently failed to request a drawing from EG&G Berthold in Germany and that they could not locate a file or drawing for one of the customers.
l Apgee committed to providing this information in a timely manner. To date, this information has not been provided to IMNS.
Apgee had previously indicated that approximately 40 deyices were in use by customers throughout the U.S. Apgee should indicate if the designs indicated in their November 21,1997, letter include all customers previously identified. In addition, Apgee should indicate the number of devices in use with bolted bottom plates, welded bottom plates, and with automatic actuators.
One of the designs indicated in the November 21,1997, letter (drawing 21314.000-000) was a design which is not contained in any background information for registration certificate NR 0112-D-111-S (an alternate top and bottom plate design and actuation mechanism). As previously indicated for the bolted bottom plate design, Apgee should either submit sufficient justification as to why this device design should be allowed for continued use, or immediately recall these devices.
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