ML25259A098
| ML25259A098 | |
| Person / Time | |
|---|---|
| Site: | 07103106, 07103070 |
| Issue date: | 09/04/2025 |
| From: | Fulford G Nordion (Canada), Sotera Health |
| To: | Lemoine E Govt of Canada, Nuclear Security Commission, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML25259A092 | List: |
| References | |
| Download: ML25259A098 (1) | |
Text
47 March Road Ottawa, ON Canada K2K 1X8 613-592-3400 l nordion.com 11/14/24 l 1 November 14, 2024 Mr. Eric Lemoine Director - Packaging and Transport Division Directorate of Nuclear Substances Division Canadian Nuclear Safety Commission 280 Slater Street, P.O. Box 1046, Station B Ottawa, ON K1P 5S9 RE: Request to Update CDN/2081/B(U)-96 to 2018 version of SSR-6
Dear Mr. Lemoine,
Nordion is requesting an amendment to the F-168 transport certificate, CDN/2081/B(U)-96 which will align it with the current requirements of the IAEA document SSR-6, Regulations for the Safe Transport of Radioactive Material 2018 Edition.
We have assessed the requirements in the 2018 version of SSR-6 and have determined that the only impact to Nordion packages relates to aging mechanisms as detailed in paragraphs 503 (e), 613A and 809 (f), (k). Specifically, 503 (e) For packages intended to be used for shipment after storage, it shall be ensured that all packaging components and radioactive contents have been maintained during storage in a manner such that all the requirements specified in the relevant provisions of these Regulations and in the applicable certificates of approval have been fulfilled.
613A. The design of the package shall take into account ageing mechanisms 809. An application for approval shall include:
(f) If the package is to be used for shipment after storage, a justification of considerations to ageing mechanisms in the safety analysis and within the proposed operating and maintenance instructions.
(k) For packages which are to be used for shipment after storage, a gap analysis programme describing a systematic procedure for a periodic evaluation of changes of regulations, changes in technical knowledge and changes of the state of the package design during storage.
11/14/24 l 2 Nordions methodology in establishing an aging management program for the F-168 transport package was based on the DRAFT IAEA document, Ageing Management and Maintenance of Packages for the Transport of Radioactive Material (Draft, 2023) as well as discussion with the CNSC.
In support of this request, Nordion is providing the following documents:
IN/TR 2707 F168, Ageing Assessment of Nordion Transport Package F-168 and F-168-X (1996) B(U) Revision (1)
IN/DS 1811 F168, Design, Manufacturing and Operating Specification for F-168 and F-168-X Transport Packages Revision (3)
These documents have been approved in our document management system however have not been made effective at this time. Once we receive CNSC approval on the final content, we will coordinate the effective date with the issuance of the revised certificate and provide an effective copy for your records.
Please arrange for the CNSC Finance department to contact Nordion to arrange for payment.
Should you have any questions, please do not hesitate to contact me at (613) 592-3400 extension 2658, or e-mail at greg.fulford@nordion.com.
Yours truly, Greg Fulford Manager Radiation Protection and Nuclear Transportation Nordion Encl.
IN/TR 2707 F168, Ageing Assessment of Nordion Transport Package F-168 and F-168-X (1996) B(U) Revision (1)
IN/DS 1811 F168, Design, Manufacturing and Operating Specification for F-168 and F-168-X Transport Packages Revision (3)
Digitally signed by Greg Fulford DN: cn=Greg Fulford, o, ou, email=greg.fulford@nordi on.com, c=CA Date: 2024.11.14 14:33:49
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