ML22251A094

From kanterella
Jump to navigation Jump to search

QSA Global, Inc., Renewal Request for CoC No. USN9371/B(U)-96 Revision 3 (Model 360 Series)
ML22251A094
Person / Time
Site: 07109371
Issue date: 08/29/2022
From: Flanigan M
QSA Global
To: Yoira Diaz-Sanabria
Office of Nuclear Material Safety and Safeguards
Shared Package
ML22251A097 List:
References
Download: ML22251A094 (11)
v • d • e


Text

QSAGLOBAL~

29 August 2022 Ms. Yoira K. Diaz-Sanabria, Chief Storage and Transportation Licensing Branch Division of Fuel Management 71-9'3 71 U.S. Nuclear Regulatory Commission Office of Nuclear Material Safety and Safeguards 11555 Rockville Pike One White Flint Rockville, MD 20852 RE:

Renewal Request for Coe number USN9371/B(U)-96 Revision 3 (Model 360 Series)

Dear Ms. Diaz-Sanabria:

QSA Global, Inc. requests renewal of the certificate referenced above for the Model 360 Series Type B(U) container. The current certificate expires on August 31, 2023. This application includes minor changes/updates to the package approvals as described and assessed in the summary change tables included with this letter. The majority of changes to the Safety Analysis Report (SAR) are associated with minor formatting, editorial or clarification revisions with no significant impact on the package performance or continued Type B transport compliance.

Enclosed is Revision 6 of the SAR. Also enclosed are SAR and drawing change tables that identify specific changes and their impact on package compliance. Please see the attached CD for copies of all application enclosures. A hard copy of the full application is being submitted separately to the Document Control Desk.

Should you have any additional questions, or wish to discuss the renewal request, please feel free to contact me.

Sincerely, E-SIG'f\\J:13D by Mary Flanigan l r Yl on 2022~08-29 14:46:43 GMT Mary Flanigan Regulatory Affairs Associate Ph: (781) 505-8266 Email: mary.flanigan@qsa-global.com Enclosures on CD:

, J::.:S\\fNED by Lori Podolak 6Q_:~g_22-08-30 11 :36:01 GMT RA/QA Approval

.',E-~1,GNED by Paul Benson lqo_ 2922-08-29 14:51 :55 GMT Engineering Approval

  • : Proprietary Documents
  • : Non-Proprietary documents August 30, 2022 Date August 29, 2022 Date QSA Global Inc.
  • 40 North Avenue Burlington, MA 01803
  • 800.815.1383
  • 781.272.2000 ext. 241
  • F: 781.229.2279
  • qsa-global.com

cc:

ATTN: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 11555 Rockville Pike One White Flint Rockville, MD 20852 Mr. Bernard White Senior Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 11555 Rockville Pike One White Flint Rockville, MD 20852 QSA Global Inc.

  • 40 North Avenue Burlington, MA 01803 ° 800.815.1383
  • 781.272.2000 ext. 241
  • F: 781.229.2279
  • qsa-global.com

, : Affidavit Pursuant to 1 O CFR §2.390 QSA Global Inc.

  • 40 North Avenue Burlington, MA 01803
  • 800.815.1383
  • 781.272.2000 ext. 241
  • F: 781.229.2279
  • qsa-global.com

AFFIDAVIT Pursuant to 10 CFR §2.390 I, Lori Podolak, Senior RA/QA Specialist of QSA Global, Inc. hereby affirm and state:

1. I have been specifically delegated the function of reviewing the information sought to be withheld and am authorized to apply for its withholding on behalf of QSA Global, Inc.
2. QSA Global, Inc. is providing NRC with a detailed drawing (R36000 Rev H) and technical details, specifications and product related information as parts of the SAR Revision 6 for the Model 360 Series transport packages. These documents contain proprietary commercial information.
3. The information sought to be withheld pursuant to the provisions of 10 CFR §2.390(a)(4) are marked as follows in Attachment 2 of our application letter "Proprietary information submitted under 10 CFR §2.390 to be withheld from public disclosure".
4. These documents should be held in confidence by the NRC per 10 CFR §2.390(a)(4) based on the following justifications:
a. This information is owned and been.held in confidence by QSA Global, Inc.
b. This information is of a type that QSA Global, Inc. has determined should be held in confidence since its release for public disclosure could result in a loss of an existing or potential competitive advantage as follows:
i.

The information reveals the distinguishing aspects of the design and the prevention of its use by QSA Global, Inc. competitors gives QSA Global, Inc. a competitive economic advantage.

ii. The information, if used by a competitor, is likely to reduce the competitor's expenditure of resources or improve their advantage in design, quality, and manufacture of a similar product.

c. This information is being transmitted to the NRC voluntarily and in confidence for use in evaluation and approval of these package designs for Type B(U) transport certification.
d. This information is not available in public sources.
e. Public disclosure of this information is likely to cause substantial harm to the competitive position of QSA Global, Inc. because of the reasons outlined below:
i.

Similar products are manufactured and sold by competitors of QSA Global, Inc.

ii. The development of this information by QSA Global, Inc., including test/evaluation documentation supporting these package designs, is the result of significant expenditure of staff effort and a considerable amount of money. It is our belief that a competitor would have to undertake similar effort and expense to generate equivalent information.

iii. In order to generate such information, a competitor would also require considerable time (e.g., in excess of 1 year).

iv. If a competitor used this information and did not have to undertake the work required to generate this information, they are likely to have lower overall costs and so are likely to have an unfair economic advantage over QSA Global, Inc. in offering a similar product to the market.

5. QSA Global has spent considerable commercial and technical resources to design and build this innovative family of source changers that is unique in its ability to store and transport a wide range of industrial radiography sources that are used worldwide. Access to the technical information for this unique design would give a competitor an unfair advantage in expanding their domestic and international market without having to perform their own research and development of the market needs and the ideal configuration of the transport package to meet a wide variety of customer needs. Accordingly, QSA Global, Inc. requests that the designated information be withheld from public disclosure pursuant to 10 CFR

§2.390.

Subscribed and sworn to (or affirmed) before me on thisol.S" day of /L:j,,*15 f ~.

2022 by Lori Podolak, proved to me on the basis of satisfactory evidence to e the person who appeared before me.

Signature <Jfi.RJ:s n I (J)~

Seal My Commission Expires j_J_ day of Ju/\\.Q.

, 20!}{}_.

6

~'

MELISSAJ. WOLFE ffl -Nota,y Public, _Co_mmonweatth o, Massachusetts My Comm,ssron Expires June 17. 2027

Revision Description for the Model 360 Series SAR from Revision 5 to Revision 6 August 2022 Page 1 of 6 Revision 6 to the 360 Series SAR updates reference revision information based on document changes and makes other minor editorial or clarification revisions with no significant impact on the package performance or continued compliance for Type B transport. These changes are listed under the SAR Section in Revision 6 where the change occurs.

Section Summary Change Change Impact of Change on Units Previously or Currently in Use Action Taken By QSA Location Reported under the Certificate Regarding Affected Pursuant Units to 71.95 Various Revised section headers to reflect new No None. Administrative change only.

None. Not applicable.

QSA Global branding formatting. Due to the volume of formatting changes, these changes are not denoted by color and change bars in the text of SAR.

Various References to units revised to list both No None. Change made to consistently reflect both imperial and SI None. Not applicable.

imperial and SI units.

units throughout the SAR.

Various References to temperatures revised to No None. Change made to consistently reflect both temperature None. Not applicable.

reflect Celsius and Fahrenheit scales throughout the SAR.

equivalent values.

Various References to "mR/hr" units replaced No None. Change made to reflect applicable units from the None. Not applicable.

with "mrem/hr" and "R/hr" with "rem/hr

regulations. Changes made where applicable throughout the when referencing compliance to SAR.

regulation limits.

Various Updated SAR throughout to correct No.

None. Change made for accuracy.

None. Not applicable.

grammatical errors and typos.

Contents, Updated page numbers. Due to volume No None. Accuracy to reflect changes in page numbers throughout None. Not applicable.

List of of changes in page numbers, these the SAR.

Table &

changes are not denoted by color and List of change bars in the text of SAR.

Figures

Contents, Updated titles to reflect revision No Accuracy to reflect referenced document revision levels and None. Not applicable.

2.12.7-changes, or to correct issue date issued dates.

2.12.10, references in supplementary 2.12.13, certificates and reports.

2.12.14, 3.6.1 &

Revision Description for the Model 360 Series SAR from Revision 5 to Revision 6 August2022 Section Summary Change Change Impact of Change on Units Previously or Currently in Use Location Reported under the Certificate Pursuant to 71.95 3.6.2 1.2 Revised phrasing of sentence in the No None. Change made for clarity.

first paragraph, fourth sentence.

1.2 Revised the third paragraph, third No Change made for clarity and to reflect the handling grips are sentence to add the words 'maximum' optional as noted on drawings in Appendix 1.3.

before 'length' and 'optional' before

'protruding handling grips'.

Table 1.2a Added note 5.

No None. Change made to specify how to calculate the source

& Table capacity in equivalent SI units of TBq.

7.1a 1.2.1.1 Added option of carbon steel material No None. Change made to allow for option to use carbon steel on for lifting provision.

future lifting provisions.

Figure 1.2d Added '(optional)' under the call out for No None. Change made for clarity that the grip brackets are two grip brackets.

optional.

Figure 1.21 Added '(optional)' under the call out for No None. Change made for clarity that the cable assembly is the cable assembly.

optional.

Table 2.2a Clarified that the condition for stainless No None. Change made for clarification and accuracy based on steel alloy group 1, 2 or 3 fasteners is values listed in the table.

CW1 under ASTM F593.

2.6.2 Specified 49 CFR as the applicable No None. Change made to clarify where requirements derive from.

regulations.

2.6.3 Further specified regulations and No Change made to clarify where requirements derive from, and to removed incorrect reference to 3.6 psi.

list the current pressure requirement values. No change in Page 2 of 6 Action Taken By QSA Regarding Affected Units None. Not applicable.

None. Not applicable.

None. Not applicable.

None. Changes specified on drawings will not be implemented until accepted under the Coe.

None. Not applicable.

None. Not applicable.

None. Not applicable None. Not applicable.

None. Not applicable.

Revision Description for the Model 360 Series SAR from Revision 5 to Revision 6 August 2022 Section Summary Change Change Impact of Change on Units Previously or Currently in Use Location Reported under the Certificate Pursuant to 71.95 pressure conformance.

2.6.5 Removed 'hex head' screw description No None. Change to allow more flexibility in screw head type.

from the first paragraph, first sentence.

Change does not impact package's performance. The hex head configuration of the screw in not important to its performance on the package, so long as the screw head meets all other requirements on drawing R36000 in Appendix 3.

Figure 2.6i Added '(optional)' under the call out for No None. Change made for clarity that the tungsten shield design the tungsten shield.

is optional per drawing R36000 in Appendix 3.

2.6.10 Added reference to the 2009 edition of No None. Change made to clarify that the 360 Series also IAEA TS-R-1 regulation.

conforms to the 2009 edition of IAEA TS-R-1.

2.7.3.4 Corrected reference from 10 CFR No None. Change made for accuracy. No change in puncture test 71.73(c)(2) to 10 CFR 71.73(c)(3).

conformance.

Table 3.1a Changed 343°F to 168°F in first row No None. Change made to correct error in conversion of 75.3°C of table.

to °F.

3.3.1 Added referral to Section 3.6.

No None. Change made for accuracy.

3.4.1.1 Revised 'Appendix 3.6.2' to 'Appendix No None. Change made for simplicity.

3.6' under the first paragraph, first sentence.

3.4.1.2 Revised 'Appendix 3.6.1' to 'Appendix No None. Change made for simplicity.

3.6' under the first paragraph, first sentence.

3.4.1.3 Replaced the word 'minus' with the No None. Change made for consistency with how temperatures symbol'-' before 40°C.

are specified throughout the SAR.

3.5.1 Replaced the word 'meter' with the No None. Change made for consistency with how length abbreviated unit symbol 'm'.

measurements are specified throughout the SAR.

Page 3 of 6 Action Taken By QSA Regarding Affected Units None. Not applicable.

None. Not applicable.

None. Not applicable.

None. Not applicable.

None. Not applicable.

None. Not applicable.

None. Not applicable.

None. Not applicable.

None. Not applicable.

None. Not applicable.

Revision Description for the Model 360 Series SAR from Revision 5 to Revision 6 August 2022 Section Summary Change Change Impact of Change on Units Previously or Currently in Use Location Reported under the Certificate Pursuant to 71.95 4.4 & 8.1.4 Updated references from the 1992 No Change made to reflect current operations. Requirements in edition of ISO 9978 to the 2020 both the 1992 and the 2020 editions of ISO 9978 related to edition.

performance and analysis of source capsule leak testing are identical. Therefore, there is no adverse impact of referencing the current revision of this standard.

5.1.2 Corrected reference from 'Section No None. Changes made for accuracy.

5.5.1.2' to 'Section 5.5.2' within the second sentence. Corrected reference from 'Section 5.5.1.1' to 'Section 5.5.1'.

Table 5.1e Corrected total package surface No None. Change made for accuracy. No changes in surface

& Table radiation levels for the top, side and radiation level conformance.

5.1f bottom surfaces.

Table 5.1f Corrected the total vehicle surface No None. Change made for accuracy. No changes in surface radiation levels for the top, side and radiation level conformance.

bottom surfaces.

Table 5.1t Corrected conversion value of 0.05 No.

None. Change made for accuracy. No changes in surface mrem/h to 5E-4 mSv/hr (previously radiation level conformance.

5E-5 mSv/hr ) for the top surface radiation level.

5.3.1 Revised the first table under this No None. Change to mrem/hr made for demonstration of section to list values in mrem/hr compliance to regulatory limits. Footnote indicating equivalency instead of mR/hr and added table between mR/hr and mrem/hr as one to one applies footnote for mR/hr to mrem/hr conservative conversion factor for table values.

equivalency.

7.1.3.4 Replaced the word 'procedure' with No None. Change made for accuracy.

'requirements'.

7.2.1.2.c. &

Included reference to international No None. Change in accuracy as these packages may ship Page 4 of 6 Action Taken By QSA Regarding Affected Units None. Not applicable.

None. Not applicable.

None. Not applicable.

None. Not applicable.

None. Not applicable.

None. Not applicable.

None. Not applicable.

None. Not applicable.

Revision Description for the Model 360 Series SAR from Revision 5 to Revision 6 August 2022 Section Summary Change Change Impact of Change on Units Previously or Currently in Use Location Reported under the Certificate Pursuant to 71.95 8.1.1.4 regulatory requirements.

internationally.

7.2.1.2.e.

Updated the word 'source' to No None. Change made for accuracy and clarification as more

'source(s)'.

than one source may ship in these packages.

7.4.2 &

Updated references to the Emergency No Updated for accuracy to current guidebook revision and title.

7.5.1 Response Guidebook from 2014 to 2020 edition.

Page 5 of 6 Action Taken By QSA Regarding Affected Units None. Not applicable.

None. Not applicable.

Retrieved from "https://kanterella.com/w/index.php?title=ML22251A094&oldid=3790975"