ML24331A246

QSA Global Model 880 Series Rsi Response Letter

ML24331A246
Person / Time
Site:	07109296
Issue date:	11/07/2024
From:	Podolak L QSA Global
To:	Boyle R Office of Nuclear Material Safety and Safeguards, US Dept of Transportation, Office of Hazardous Materials Technology
References
EPID L-2024-LLA-0112
Download: ML24331A246 (1)

Text

QSA Global, Inc. 40 North Avenue Burlington, MA 01803 800.815.1383 781.272.2000 qsa-global.com 7 November 2024 Mr. Rick Boyle Radioactive Materials Branch Office of Hazardous Materials Technology Pipeline and Hazardous Materials Safety Administration East Building, E21-303, PHH-23 U.S. Department of Transportation 1200 New Jersey Avenue, S.E.

Washington, D.C. 20590-001 RE:

USA/9296/B(U)-96 Response to NRC RAI Enterprise Project ID L-2024-LLA-0112

Dear Mr. Boyle:

QSA Global, Inc. provides the following in response to the NRC RAI letter dated 23 September 2024.

Responses are provided point by point in the attached document.

Should you have any additional questions or wish to discuss this submission after receipt, please feel free to contact me. I would be happy to correspond, or coordinate Teams conference calls to discuss this matter in further detail to resolve any issues or questions that remain.

Sincerely, Lori Podolak Senior RA/QA Specialist Regulatory Affairs/Quality Assurance

Enclosure:

RAI Responses Service Bulletin SG-23 Regulatory Affairs Approval Engineering Approval E-SIGNED by Lori Podolak on 2024-11-07 12:40:13 GMT E-SIGNED by Mary Flanigan on 2024-11-07 13:37:21 GMT E-SIGNED by Paul Benson on 2024-11-07 14:26:27 GMT

Responses to Request for Supplemental Information Certificate of Compliance No. 9296 Docket No. 71-9296 Revision 12 The questions below describe information needed by the staff for it to begin its review of the application and to determine whether the applicant has demonstrated compliance with regulatory requirements.

Structural Review RSI-St-1:

Provide a complete fatigue evaluation for the important-to-safety reusable package components, for the expected service life (i.e. number of years that the applicant expects the package to be in use), that considers the combined effects of all applicable types of accumulated stress cycles during normal service conditions.

The expected working life for the 880 packages is approximately 10 years, although this can vary significantly depending on environment of use. After 10 years, the user should arrange for the device to be inspected and assessed by a qualified authority (e.g., the manufacturer) to determine whether the working life can be extended or if the package should be removed from service.

A description of the periodic maintenance inspections in Section 7.1.1.2 of the SAR include a visual examination of the container weldment for signs of damage as well as the hardware used on the package. These components are important to ensuring continued package integrity.

Additional package inspection and maintenance instructions for the 880 packages are contained in the enclosed service bulletin SB-23. This service bulletin includes additional quarterly and annual inspections as well as inspections to be performed on packages after storage for 1 year or more. Package components subject to degradation mechanisms and aging processes include the following:

Wear: The only components affected by wear that could impact package integrity related to transport, are the source assembly, the screwed fittings securing the endplates to the package weldment and the lock assembly components (e.g. lockslide, lockslide spring).

The screwed fittings and lock assembly components are inspected for damage/deterioration on an annual basis and the fasteners are visually examined prior to transport for any damage. These components are not routinely removed as they are only removed on an annual basis during in depth package maintenance. If damage/wear is observed on any of these components, they are replaced prior to continued package transport.

On the source assembly source capsule and the shield source tube can experience wear over time resulting from source assembly cycling in and out of the package during industrial radiography. The source assemblies have a recommended working life of 2 years, however, typical working lives are usually less than 1 year prior to replacement.

The source assemblies are required to be tested for potential leaking by physical testing every 6 months. The 880 devices also are required to be tested for potential source tube wear through to the depleted uranium on an annual basis. Both of these leak tests

indicate failure if the test results exceed 0.005 µCi of removable contamination. In cases of failure, the applicable source assembly/package would be removed from service.

Fatigue:

Handling Stresses: Stainless steels in the 300 Series (which are predominantly used for components important to structural integrity on the 880 packages) have good fatigue resistance under cyclic loading conditions. The austenitic structure of these steels, combined with their toughness and ductility, allows them to withstand repeated stress over time.

Lifting and Tiedown Point Review:

Lifting and tiedown points for the Model 880 packages can be done by either the jacket or using a cut out feature that can be used for hoisting/tiedown. If either of these features failed, it would not affect the shield container or source wire security.

If hoisted/tied-down by the jacket handle or the welded containment via the cut out feature, failure could allow drop of the package or unintended movement within a transport vehicle. The package has demonstrated its integrity and source security after worst case orientation 30 ft (9 m) drops and 1 m puncture bar drops (see SAR Section 2.7). The drop configurations included versions of the Model 880 packages with and without the optional jacket attached. Results of these testing demonstrated no significant increase in radiation levels from the test units nor any damage that adversely impacted the package integrity.

The potential damage that could be inflicted resulting from a hoisting drop or tie-down failure during transport will result in significantly less damage to the package than was seen after the 30 ft (9m) and 1 m puncture drop testing. As a result, package safety will not be compromised as a result of a jacket/hoisting point failure.

Hardware Review:

Cyclic loading within the 880 packages is confined to major hardware which holds the Rear Plate and Front Plate assemblies to the body weldment (e.g., canister). The stainless-steel canister which holds the primary shielding does not see significant effects due to cyclical loading as it is a welded steel tube with end plates fully welded on each end. There are no external forces which would cause extensive cyclical loading.

880 hardware, particularly the security screws which hold the front and rear plate, experience two types of cyclical loading, removal/installation during service, and vibration during transport.

The Model 880 package designs minimize the effects of cyclical loading (fatigue) by:

Utilizing appropriately sized bolts for the intended load.

Utilizing torque specifications for safety critical hardware.

Utilizing specification grade stainless steel hardware for enhanced performance and to minimize the effects of corrosive environments.

Utilizing an Inspection and maintenance program which identifies and removes components with wear and fretting that could result in component failure.

In a low cyclical environment, a properly designed and sized bolt can last for decades or even the entire lifespan of the structure or equipment, as long as it remains within its load limits and is not exposed to excessive environmental factors (like corrosion).

Here are a few specifics:

Bolt Material and Size: If the bolt is made of high-quality material and appropriately sized for the load, it will increase its fatigue resistance.

Preload and Installation: Correctly tightened bolts (following torque specifications) ensure the joint doesnt experience excess stress that could lead to fatigue.

Service Fatigue:

The endplate screws are torqued to 75-80% of their minimum yield force. The minimum yield is defined by a strain of 0.2%. Per NUREG/CR-6909, austenitic stainless steels tested in air at 0.2% strain amplitude have an expected service life of 105 cycles. The endplate screws on an 880 will see roughly 40 removals/installations over a 10 year period based on the recommended service requirements. Even in an over-loaded condition with cycles to no strain, this is 4 orders of magnitude too low to constitute a realistic failure mode.

Transport Vibration Fatigue:

These endplate screws do not experience much strain variation in transit as they are consistently under tension between service events. Per EPRI Presentation ML16183A0841, vibration fatigue failure resides in the 106 to 1011 cycle count range, and it typically manifests as a sudden brittle failure. Given the extreme variability of this failure mode, it is unlikely that a full set of four screws would fail concurrently Overloading:

Excessive loads beyond the bolt's capacity could only occur during accident conditions. At proper torque, endplate screws have at least 473 lb of tensile capacity before reaching their yield limit. An endplate has four of these screws, so an endplate would have to exert 1,892 lb to overload the screws. The rear plate assembly, which is heavier than the front plate, weighs about 2.5 lb. A deceleration of 756 Gs would be required to exert this amount of force. This is at the high end of the impact range measured under simulated accident conditions. An impact of this magnitude would 1 EPRI Presentation to NRC June 30, 2016 Fatigue Limit of Stainless Steel for Use in Vibration Evaluation.

cause sufficient damage to require increased inspection of the package prior to continued use. Inspection would identify any integrity impaired screws and result in their replacement prior to continued transport of the package.

Improper Installation:

1. Under-tightening could cause wear and fretting. This would not cause the screw to fail completely in a time interval between service events. A completely loose screw would be detectable during the daily, visual inspection. Associated wear would be visible damage and trigger replacement prior to continued package use.

2. Over-tightening would not lead to fatigue failure since it would stretch the screw, causing it to bind at the next removal. Such binding would result in replacement of the screw.

Corrosion:

Especially in harsh environments, corrosion can weaken screws over time. The presence of corrosion is visually identifiable and its detection during daily inspections would result in the screws replacement.

Lock Assembly Component Review:

Consistent visual inspections as identified in SB-23 (see attached) will ensure identification of any signs of cumulative fatigue, wear or drop damaged to the package and its components.

The only moving components which might experience complete fatigue failure are the springs in the endplate assemblies. These components are all replaced during annual service. In the unlikely event of failure, the Model 880 packages can still be manually secured in the package prior to transport. Alternatively, the source can be transferred to a source changer to allow for service and repair of the rear plate assembly on the 880 package.

The lock slide, selector ring, and other components with running/sliding surfaces can show signs of wear which is observable during annual service. Significant wear will produce functional/operational problems (e.g., binding, sticking, etc.) that would indicate the need for component replacement. These components would be replaced due to this type of damage long before a complete fatigue failure of the component could occur.

Thermal Stresses - Package:

Thermal stresses, including thermal expansion, on the package are evaluated in SAR Sections 2.6.1 and 2.7.4. All stresses calculated are well below strengths for the materials of construction. As documented in Table 3.1.A and SAR Sections 3.4.1.1 and 3.4.1.2, the highest package temperature under normal conditions of transport is 149.7°F (65.4°C).

Thermal cycling is generally not a significant concern at temperatures below 150°F (65°C) for stainless steel components. At these lower temperatures, the thermal expansion and contraction of stainless steel are minor, and the stresses remain well within the materials elastic range, meaning they wont cause fatigue or significant structural changes. Heres why thermal cycling impact is minimal at these temperatures:

1. Thermal Expansion: The structural components of the 880 are all austenitic stainless steel. The thermal expansion coefficients vary little within this group of alloys. The range is within 8 to 10 ppm/°F. The components expand at a similar rate, so no significant internal stresses are generated at junctions.

2. Limited Oxidation: Stainless steel's protective chromium oxide layer is effective at these lower temperatures, minimizing any oxidation risk during cycling.

3. Microstructural Stability: The temperature range is too low to cause phase changes or chromium carbide precipitation, meaning the metals microstructure and corrosion resistance remain stable.

4. Fatigue Resistance: At lower temperatures, cycling is unlikely to produce thermal fatigue, as the stress does not reach the level required for crack initiation or propagation.

The package material degradation over the working life of the package when it is properly inspected and maintained, will be minimal. Observable damage/deterioration identified during periodic inspections, which could lead to package degradation, would instead lead to the components removal from use.

Thermal Stresses - Source/Special Form Capsules:

The worst case source capsule heat source results in a maximum 3 Watts over the life of the source (reference SAR Section 1.2.2). The titanium tube and DU act as a heat sink for any minimal heat that is generated. The associated decay heat from the source capsule has negligible impact on the source tube and DU shield.

The source capsule has a significantly shorter life span (6-12 months) versus the overall package recommended working life of 10+ years. The heat generated by decay also drops by approximately 1% per day and after 1 year it is roughly 4% of its original value. Source decay energy does not generate enough heat to significantly increase the package thermal temperature or induce significant thermal stresses in the package (reference SAR Sections 3.4.1.1 & 3.4.1.2).

The Ir-192 and Se-75 source capsules used on the source assemblies transported in the Model 880 packages have been used for decades without any observed failures due to thermal or pressure expansion/contraction. These source capsules are tested every 6 months for any signs of leakage that could result from a breach of the capsule welds or base material. The only known instances of capsule failures over this time have been related to use of the source/package under extreme operational conditions (e.g., units not properly maintained and used in sandy/gritty environments

using unapproved lubricants). Such operation has resulted in accelerated wear of the source capsule base material over time. There have been no failures of the source encapsulations when they, and the 880 packages in which they are used, have been maintained as described in SB-23.

Corrosion: The package weldment and fasteners are stainless steel and naturally corrosion resistant. The majority of structural materials used on the 880 packages are manufactured from stainless steel (primarily 300 Series). 300 Series stainless steels are highly corrosion-resistant due to their high chromium and nickel content. This helps to form a protective layer of chromium oxide on the surface, shielding the metal from further oxidation and corrosion.

The integrity of this weldment is inspected at least annually to confirm its effectiveness.

If degradation/deterioration is noted, on the weldment or any other components important to package integrity, they are replaced or repaired prior to continued package transport.

Radiation Damage: Gamma radiation creates only heat when it is attenuated by metals.

There is no time dependent damage to the containment or shielding system due to radiation damage.

Pressurization: The 880 packages are open to the atmosphere and contain no components which could create a differential pressure relative to atmospheric conditions. The authorized contents are special form capsules that meet a minimum ANSI N43.6-2007 pressure classification of 3. This classification demonstrates the capsule can retain its integrity under increased external pressure conditions from 25 kN/m2 (3.6 psi) to 2 MN/m2 (290 psi). This classification is more than sufficient to comply with the pressure requirements in 10 CFR 71 (increased external pressure of 20 psi), 49 CFR and IAEA (reduced external pressure of 8.7 psi (60 kPa)).

Thermal cycling is not a significant concern unless there is uneven expansion. This can be caused by uneven heating or a junction between two materials which have different thermal expansion characteristics. The source capsules are small and thermally conductive, so they do not support large heat gradients. All encapsulations (primary and secondary) for Ir-192 and Se-75 are welded without the use of filler material. There is no filler metal, so there is no differential expansion between different alloys. Therefore, thermal stresses pose no significant danger of cyclic internal stress to the weld or capsule integrity.

Oxidation: Stainless steel and titanium both develop a limited protective oxide layers in air which prevent further oxidation and related deterioration of the base metal.

Vibration: The only parts that could loosen from vibration during transport are the tamper-proof screws used to secure the endplates to the package weldment. This type of screw has been used on the 880 package and other similar devices over the past 35

years. Field use of these screws has shown they have never loosened as a result of vibration. Further, these screws are torqued to 110 +/- 5 in-lbs to ensure the screws remain installed during transport. This torque is reapplied at least annually during annual inspection and maintenance of the package.

If such a complete fatigue evaluation cannot be performed, or if the fatigue evaluation cannot show adequate protection against fatigue failure considering the combined effects of all applicable types of accumulated stress cycles in components, provide the following information:

1. A description about how periodic maintenance inspections will be used to identify and address fatigue cracks in components of the package.

2. A description of the corrective actions that will be taken for any detected fatigue cracks, such as analytical flaw evaluation with follow-up inspections, repair/replacement of components with cracks, etc.

Per the International Atomic Energy Agency (IAEA) SSG-26, Revision 1, Paragraph 613A.1 guidance, to determine that fatigue is not an aging concern, the applicant needs to provide a complete fatigue evaluation that considers the combined effects of all applicable types of stress cycles during normal service, including consideration of the lifting cycles, pressurization cycles, thermal stress cycles, and vibration cycles (during transport). The fatigue evaluation should also consider stress concentration factors to account for any stress increases at a local discontinuity or change in cross section of a member. If certain types of stress cycles are not applicable or negligible for certain components, explain why these are not applicable or are negligible.

This information is requested to determine compliance with the requirements in Paragraphs 613A of the IAEA SSR-6, 2018 Edition.

Materials Review RSI-Ma-1:

Please describe any national or international codes, standards, and/or other methods, programs, or procedures that are implemented to ensure that package maintenance activities (including visual inspections, screening and evaluation of visual indications, and corrective actions such as component repairs and replacements) are adequate to manage the effects of aging in metallic package components that would see long-term use, such that the package components are capable of performing their requisite safety functions throughout the period of use.

The staff requests that this description address the following criteria:

1. Inspection methods (e.g., bare metal visual exams and/or other types of nondestructive exams such as liquid penetrant exams or ultrasonic exams) for detection, characterization, and sizing of localized aging effects such as cracks, pits, and crevice corrosion. Bare metal visual examinations by Type B package users is sufficient to identify wear/defects that could adversely impact package integrity. Inspections and maintenance for the 880 packages

have been expanded in SB-23 which covers pre-shipment inspections as well as periodic inspections and maintenance performed quarterly, annually and after removal from storage for over a year. SB-23 identifies criteria for determining acceptability or removal from use due to identification of aging effects or damage.

Based on the materials used, the design of these packages, and the history of issues previously identified using visual examinations, there have been no known failures related to aging effects for the 880 packages (e.g. no unidentified failures known in over 20 years+ of transport).

These packages are inspected and transported typically multiple times a week. Current visual examinations by shippers and users of these packages are sufficient to identify any significant package integrity issues and remove packages from use.

2. Inspection equipment and personnel qualification requirements (e.g., lighting and visual acuity requirements for performing visual exams) to ensure reliable inspections that can adequately detect and characterize indications of localized aging effects prior to component failure or loss of safety function. These package designs are highly robust so that damage/deterioration which could impact the package integrity will be identifiable by bare metal visual examinations. No specialized lighting or visual acuity are necessary to reliably identify significant component deterioration which could result in adversely impacting the package integrity. Regardless, the majority of users of this package are employed by radiography companies who use ASNT Certified Level II or III radiographers.

Personnel performing these inspections are predominately employed by industrial radiography companies. Such companies in the USA are required under 10 CFR 71.17(b) and 71.101(g) to have USNRC approved QA programs. International package users are typically covered by programs operating under an ISO 9001 QA programs. Both types of programs include requirements for personnel training and qualification, therefore, staff performing these inspections will be trained and approved to perform such inspections.

These packages have been safely transported for over the past 20 years. Based on the frequent package inspection requirements and typical transport frequency per package, current visual examinations specified in Section 7.1.1.2 and the attached SB-23 are sufficient to identify any significant package integrity issues and remove deficient packages from use.

3. Acceptance criteria for aging effects such as early stage fatigue cracks and localized corrosion of stainless steel components, such as chloride induced stress corrosion cracking (SCC),

pitting, and crevice corrosion. Examples of visual indications that may indicate potential localized corrosion of stainless steel components include the accumulation of atmospheric deposits such as salts, buildup of corrosion products, rust colored stains or deposits, and surface discontinuities or flaws associated with pitting, crevice corrosion, and/or SCC. Any signs of fastener fatigue cracking, weld cracking or weldment corrosion will result in removal of the package/components from continued use until repaired/serviced if possible or replaced (e.g., fasteners). A visual examination of the tamper-proof security screws used to secure the endplates to the package weldment is performed. Prior to shipment the visible external surfaces of these fasteners are examined for any signs of fatigue cracking. As required in Section 7.1.1.2.c. of the SAR and SB-23, these fasteners are also removed at least annually and subjected to an enhanced inspection for identifying any signs of thread deterioration, cracking, etc.

4. Describe any surface cleaning requirements that are implemented to ensure that bare metal visual inspections of component surfaces are capable of detecting surface flaws, and for ensuring adequate removal of atmospheric deposits such as salts or other chemical compounds that may contribute to localized corrosion of stainless steel components. No specialized surface cleaning requirements are necessary to ensure reliability of bare metal visual inspections. If needed, the package can be cleaned using mineral spirits or soap and water for removal of any deposits of salts, etc. that could contribute to localized corrosion of stainless steel components (see SB-23).

5. Describe any flaw evaluation methods (such as flaw sizing and flaw analysis methods) and associated flaw acceptance criteria that may be used to determine whether components containing flaws are acceptable for continued service. No detailed acceptance criteria is provided for components identified with flaws. Criteria used for flaw identification is part of the detailed inspection covered under SB-23. Annual inspection/maintenance and when a Model 880 package involves complete disassembly of the front and rear plates.

During this process all components are visually evaluated for signs of wear and/or damage. During annual maintenance of these packages, springs used on the lock assembly are automatically replaced to ensure continued reliable operation. Fit checks are utilized in other cases for functional items such as the lock slide, selector ring, rotor, etc. to determine acceptability of continued use. Fasteners identified with flaws are considered unacceptable for continued use and must be replaced.

Minor instances of container weldment corrosion would result in rejection from continued use as a transport package until the corrosion is removed. Section 7.1.1.2.b specifies that any heavy rusting, cracked welds, and/or cracks/damage to the steel housing which breaches the container results in no further transport as a Type B container and recommends contacting QSA Global, Inc. for further guidance prior to shipment.

The majority of 880 packages do not see significant disuse as they are routinely transported in order to use in performance of industrial radiography. However, should a package be disused for 1 year or more, it would require annual inspection per SB-23 prior to its next use to transport a Type B quantity or radioactive material which would include inspection for flaws/defects that could adversely affect the package integrity.

Per IAEA SSG-26, Paragraph 613A.3, the package should be evaluated during the design phase in the demonstration of compliance with the Transport Regulations. Based on this evaluation, an inspection and maintenance programme should be developed. The programme should be structure so that the assumptions (e.g. thickness of containment wall, leaktightness, neutron absorber effectiveness) used in the demonstration of compliance of the package are confirmed to be valid through the lifetime of the packaging.

This information is requested in order to verify compliance with requirements of the 2018 Edition of IAEA SSR-6, Paragraphs 503(e), 613A, and 809(f).

RSI-Ma-2:

The staff requests the applicant to provide a discussion on abrasion being evaluated as an aging mechanism.

Per IAEA SSG-26, Paragraph 613A.1, The designer of a package should evaluate the potential degradation phenomena over time, such as corrosion, abrasion, fatigue, crack propagation, changes of material compositions or mechanical properties due to thermal loadings or radiation, generation of decomposition gases and the impact of these phenomena on performance of safety functions.

This information is requested in order to verify compliance with requirements of the 2018 Edition of IAEA SSR-6, Paragraph 613A.

See SB-23 supported by responses to RSI-St-1 and RSI-Ma-1 including assessments/evaluations contained in Sections 2 and 3 of the SAR, specifically Sections 2.2.2, 2.2.3, 2.6 and 2.7. Natural resistance of 300 Series stainless steel to corrosion which are used in components important to package integrity minimizes degradation over time. Routine inspections and maintenance as detailed in SB-23 and SAR Sections 7 & 8 ensure package structural integrity is maintained.

Abrasion on the Model 880 package with the potential of significant impact on the package integrity and source security are limited to 4 areas:

Lockslide and Selector Ring The lock slide is thoroughly visually inspected during routine maintenance, it is also qualified via the functional check.

S-Tube The s-tube is wipe tested for detection of possibly break through related wear to the depleted uranium shield below. The complete assembly is functionally checked with an inactive source assembly to ensure that any s-tube wear is insufficient to impede source movement to the locked position within the 880 package.

Front Plate Rotor All components of the front plate assembly are visually inspected during annual maintenance. The complete assembly is functionally checked with an inactive source assembly to ensure that any s-tube wear is insufficient to prevent source movement into the 880 package during loading/unloading.

RSI-Ma-3:

The staff requests the applicant to provide the aging management program (per the structure and procedure in IAEA SSG-26, Paragraph 613A.3) and gap analysis program.

Per IAEA SSG-26, Paragraph 613A.5, For designs of Type B(U), B(M) and Type C packages these programmes are required to be included in the application for approval of packages for shipment after storage (see paras 809(f) and (k) of the Transport Regulations). The results of the ageing management programme and the gap analysis programme should be taken into account when preparing an inspection plan prior to transport. The staff was not able to locate an aging management program or gap analysis program as required by IAEA SSR-6, Paragraphs 809(f) and (k).

This information is requested in order to verify compliance with requirements of the 2018 Edition of IAEA SSR-6, Paragraphs 809(f) and (k).

Gap Analysis Programme QSA Global has a procedure in place which reviews and evaluates the impact of regulatory changes on pre-existing product and internal programs used to obtain product approvals. The results of these reviews are then used to modify and/or update existing products, including previously distributed products to 3rd parties, and internal programs as necessary to maintain compliance with applicable regulatory requirements.

Aging Management Program QSA Global has internal procedures related to the inspection and service of Type B containers prior to shipment after use. These procedures identify the standard inspection requirements specified in Section 7 and 8 of the Safety Analysis Report for Type B containers, the need to remove containers from use that do not meet these inspection criteria, and the process for review and approval of any service/repair operations performed to return the package to compliance.

Inspection requirements take into consideration package component durability and for non-durable items such as gaskets, frequencies for routine replacement in packages during inspection are implemented in the inspection procedures. The majority of components used on QSA Type B packages are highly durable which typically do not require replacement unless visible signs of damage, rusting, weld degradation, etc. are identified during the package inspection prior to reuse for Type B shipment.

The majority of the packages transported by QSA, and its customers experience limited storage as they are active exposure devices used to support radiographic operations. Typically, these containers are shipped back and forth with QSA Global, or to support customer jobsite use anywhere from 4 times a year (e.g., 702 bulk container shipments) up to over 4 times a month for radiography at temporary jobsites (e.g., 880 Delta).

SERVICE BULLETIN.

SB-23 Page 1 of 8 November 2024 Purpose This document provides information applicable to the inspection and maintenance of the Model 880 Series transport packages to comply with IAEA SSR-6 (2018). In addition to ensuring the package is in accordance with the operating instructions supplied with the transport package, per 10 CFR 71.87 and 71.89, specifically Sections 7 & 8 of the Model 880 Series Safety Analysis Report, compliance with this bulletin is required for all packages shipped under a USDOT certificate, or other foreign Type B certification, endorsed to IAEA SSR-6 (2018).

Package Inspection & Maintenance Requirements The Model 880 Series packages must be maintained regularly by trained and qualified personnel to ensure the package complies with applicable Type B(U) or Type A approval requirements and the package maintains its integrity during transport.

The recommended inspection and maintenance requirements are based on the system's design, application, materials, anticipated work cycles, environmental factors of use under the normal and abnormal conditions of transport. A program of systematic maintenance will prolong the working life of the package in addition to ensuring safety during transport and use. By most national radiographic regulations, routine maintenance of the systems is required at intervals not to exceed 3 months in addition to the daily inspections for obvious defects. The complete annual servicing ensures the integrity of the system.

Maintenance program administrators must recognize the need for maintenance intervals that are less than the required 3-month interval especially in cases where the systems are used in severe environmental conditions. Maintenance program administrators must ensure the systems are completely serviced immediately after certain jobs in severe conditions. Extreme or severe conditions may include, but is not limited to conditions where the equipment was:

Immersed in water or mud.

Subjected to high-concentrations of particulate such as fly ash, sand or foundry green-sand.

Subjected to hot radiography conditions.

Subjected to salt-water conditions, caustic or acidic materials.

Subjected to accidental drops or falling objects.

Whenever subjected to extreme environmental conditions.

The routine maintenance performed every 3 months (see Section 4) requires a more indepth inspection and check of the package. The complete maintenance (performed once a year or after removal from long term storage - see Section 5) involves a complete disassembly, cleaning, inspection, re-lubrication and operational tests of the major assemblies on the package.

Personnel performing the inspections and maintenance in this bulletin must be adequately trained and approved to perform these duties. Personnel approved and qualified under either a USNRC approved QA program or an ISO 9001 QA program to perform Type B container inspection and maintenance would meet the training requirements in this bulletin.

1. General Requirements

a. The Model 880 Series transport packages must be loaded and closed in accordance with procedures that, at a minimum, include the requirements in Sections 7 & 8 of the SAR and this bulletin. Shipment of Type B quantities of radioactive material are authorized for sources specified in Section 2. Maintenance and inspection of these packages is in accordance with the additional requirements specified in Section 3 through 5.

SERVICE BULLETIN.

SB-23 Page 2 of 8 November 2024 NOTE:

Package conformance after storage and prior to use for Type B shipments is ensured by proper inspection and maintenance. The materials used in the Model 880 Series packages are not vulnerable to degradation due to irradiation over time, and there will typically be no chemical/galvanic material interactions between package materials during storage so long that the package is not exposed to hazardous chemicals and is stored under controlled environmental conditions1.

For packages removed from storage and prior to shipment, the package components are inspected for any degradation due to non-use/storage. Any degradation identified will prevent the package use for shipment until correction by replacement, service and/or repair. (

Reference:

IAEA SSR-6 §503(e) & 613A).

b. Results of package inspections and maintenance covered in this bulletin must be recorded and include, at a minimum, The date of inspection and maintenance.

Name and signature of the qualified individual performing the required inspections.

Problems found and maintenance or repairs performed.

Model number and serial number of the exposure device and transport container.

Associated equipment that was inspected and maintained.

Part numbers and associated lot numbers or serial numbers of replacement parts installed If any defective/damaged components are identified on the package or source, they must be removed from transport use and identified with a status indicator (tag, label, or tape) to prevent inadvertent shipment or use. Defective or damaged components must be repaired or replaced before continued use of the Model 880 package (or source assembly as applicable) in transport.

Contact QSA Global, Inc. if additional guidance or assistance is needed to determine actions needed to deal with defective/damaged equipment.

2. Authorized Package Contents The Model 880 Series transport packages are designed for use with a special form source capsules as approved under a U.S. Department of Transportation special form certification2. The approved isotopes and maximum package activity limits are shown in Table A. Details of encapsulation as well as chemical and physical form of the radioactive material will comply with specifications approved under U.S. Department of Transportation or other Competent Authority special form certifications.

1 Storage of the Model 880 Series packages must be in a temperature and humidity controlled area away from chemicals or other hazardous substances to prevent degradation of the package integrity while in storage.

2 Special Form is defined in 10 CFR 71, 49 CFR 173, IAEA TS-R-1 and SSR-6.

SERVICE BULLETIN.

SB-23 Page 3 of 8 November 2024 Table A: Isotopes Permitted in the Model 880 Series Model Nuclide Maximum Capacity3 Maximum DU Weight Maximum Weight Without Jacket Maximum Weight With Jacket (Version 1)

Maximum Weight With Jacket (Version 2 or 3) 880 Delta Ir-192 150 Ci 34.4 lbs (15.6 kg) 46 lbs (21 kg) 52 lbs (24 kg) 55 lbs (25 kg)

Se-75 150 Ci 880 Sigma Ir-192 130 Ci 34.4 lbs (15.6 kg) 46 lbs (21 kg) 52 lbs (24 kg) 55 lbs (25 kg)

Se-75 150 Ci 880 Elite Ir-192 50 Ci 25 lbs (11 kg) 37 lbs (17 kg) 42 lbs (19 kg) 45 lbs (20 kg)

Se-75 150 Ci 880SC Ir-192 150 Ci 34.4 lbs (15.6 kg) 46 lbs (21 kg) 52 lbs (24 kg)

NA3 4 Se-75 150 Ci

3. Packaging Maintenance and Inspection Prior to Shipment

a. If the package has been in storage for 1 year or longer, inspection to the requirements in Section 5 must be completed in addition to the maintenance and inspection listed in this section.

b. Ensure all markings are legible and the labels are securely attached to the package. If a source is loaded in the package, inspect the legibility and attachment of the source identification tag that describes the radioactive source contained in the package.

c. Inspect the container for signs of significant degradation. Ensure all welds are intact, the container is free of heavy rust and cracks/damage to the steel housing which breaches the container. If there is any evidence of bent or cracked welds contact QSA Global, Inc. prior to shipping.

d. Inspect the locking mechanism to ensure the protective covers are installed over the source assembly connector. Inspect the plunger lock to ensure the lock will engage when the plunger is depressed, and the key is removed. Grasp the entire locking mechanism with one hand and try to move the lock to determine that the screws have not loosened due to vibration. Unlock the plunger lock and confirm it releases the protective cover. Return the protective cover to the lock assembly and secure it to the package with the plunger lock.

e. Inspect the outlet port for damage and for smooth operation by operating the outlet port cover.

Verify that the outlet port cover rotates smoothly and that the mechanism is not clogged with dirt, grease or sludge.

f.

Assure all bolts and fasteners (hardware) required for assembly of the package and as specified on the drawings referenced on the Type B transport certificate are fit for use. Without removing the hardware by disassembly from the device, examine the visible external surfaces of the bolts/fasteners for any signs of damage including fatigue cracking.

3 Maximum Capacity Activity for Ir-192 is defined as output Curies as required in ANSI N432 and 10 CFR 34.20 and in line with TS-R-1/SSR-6 and Rulemaking by the USNRC and the USDOT published in the Federal Register on 26 January 2004.

4 The Model 880SC uses only the Version 1 optional jacket.

SERVICE BULLETIN.

SB-23 Page 4 of 8 November 2024 Note:

A visual examination of the bolt/fastener thread condition is performed after removal from the exposure device as part of the Annual maintenance inspections required for radiography devices under 10 CFR 34.31 or equivalent Agreement State regulations and as specified in Section 4 of this bulletin.

The bolts/fasteners must be replaced if they are no longer fit for use (e.g., threads stripped, unable to fully thread, signs of cracking, etc.). Ensure the front port is properly secured. Ensure seal wire(s) are properly installed. Ensure any replacement hardware meets all applicable specifications listed on the drawings referenced on the Type B transport certificate.

g. If the container fails any of the inspections in steps 3.a-f, remove the container from use until it can be brought into compliance with the Type B certificate.

4. Packaging Quarterly Maintenance and Inspection Perform general cleaning of the exterior of the package using water and/or mild detergent only.

Record any defects that might affect safe operation or contribute to unsafe transport of the container.

If deficiencies are found during this maintenance, the package must be removed from service until repairs are accomplished and the results of subsequent operational tests and inspection are satisfactory. Inspect the package for the following using a satisfactory or deficient criterion:

a. Complete the inspections in Section 3.b through 3.g.

b. Check the welded container stainless steel end plates for any weld failures (e.g. cracks, gaps, etc.). When a jacket is used, ensure the handle, the bottom contact surfaces and the sides comprising the plastic jacket of the exposure device are intact. Check the bottom contact surfaces of the jacket to ensure the contact area is not excessively worn allowing contact of the stainless steel body with the work surface. If any deficiencies are found during this inspection, contact QSA Global, Inc. to determine if repairs can be performed. Significant repairs will need to be performed by QSA Global, Inc. Note: The package may require unloading to return for service since it cannot be transported loaded until repairs have been performed to return the package to a compliant condition.

c. Check the outlet port for proper function by attaching and removing a source guide tube. The operation should be smooth and resistance free. If there is any resistance or crunchy feeling noticed during attachment or removal of the source guide tube or during movement of the outlet port cover, this indicates excessive amounts of sand or dirt may be within the mechanism. The outlet port mechanism must be removed, cleaned and lubricated according to the complete service instructions.

d. If the container fails any of the inspections in steps 4.a-c, remove the container from use until it can be brought into compliance with the Type B certificate

e. Maintain records of this inspection and maintenance.

SERVICE BULLETIN.

SB-23 Page 5 of 8 November 2024

5. Packaging Annual Maintenance and Inspection Model 880 Series packages must receive inspection and maintenance at least once a year. The locking mechanism and outlet port mechanism must be removed from the package and disassembled for proper cleaning, inspection and lubrication of components that are critical to safety. These procedures can only be performed on an empty package, which requires transfer of the radioactive source assembly into an approved storage container.

A leak test of a sealed source must be performed every 6 months or prior to its first use after removal from storage. Acceptable results of a radio-assay must indicate removable contamination is less than

<185 Bq (0.005 µCi). If the source requires a leak test, perform the test and obtain the results prior to transferring the source from the package into a source changer.

Prior to this inspection, transfer the source from the package following the instructions in the package and source changer operations manuals. The annual inspection and maintenance must be performed by individuals specifically trained, qualified and authorized for this work.

a. After unloading the package, perform a leak test of the package for removable depleted uranium contamination. This test is typically required annually for projection type radiography devices where the source projects out of the device during use. The purpose of the leak test is to detect the long-term wear through of the device's source tube that may consequently expose the DU shielding. A wipe-test wand that is both flexible and long enough to reach a bend radius or a wear point is required to perform a leak test. The wand enables direct contact with the DU where the devices source tube has worn through.

The analysis performed on the wipe test must be capable of detecting the presence of 0.005 µCi (185 Bq) of radioactive material on the test sample. If the test sample reveals 185 Bq (0.005 µCi )

or more of removable DU contamination, the package must be removed from service until an evaluation of the wear on the S tube has been made. Should the evaluation reveal that the source tube is worn through, the exposure device may not be used again.

DU shielded devices do not have to be tested for DU contamination while in storage and not in use. Before using or transferring a device that has been in storage for more than 12 months, the exposure device must be leak tested for DU contamination prior to use or transfer. Please contact a QSA Global, Inc. for guidance in the disposition of worn through packages.

b. Complete the inspections in Section 3.b through 3.g.

c. Remove the four 5/16-18 x 11/2 in socket button-head screws that retain the locking mechanism plate from the empty Model 880 device using the tamperproof tool bit mounted in a ratchet.

d. Remove the 10-32 socket head screws that retain the selector-ring and plunger lock housings from the mounting plate.

e. Disassemble the locking mechanism assembly. Discard all used locking mechanism springs and replace with new springs5. All compression springs located within the selector ring mechanism must be replaced at 12-month intervals to ensure smooth and consistent operation of the mechanism.

5 Replacement parts compliant for use under the Type B approval can be obtained from QSA Global, Inc. Use of unauthorized replacement parts may invalidate the device and/or Type B approval.

SERVICE BULLETIN.

SB-23 Page 6 of 8 November 2024 Place the remaining disassembled locking mechanism components into a pan filled with fresh, clean mineral spirits. Clean all parts using a brush to dislodge any dirt or grease. Once cleaned, remove the parts from the solvent bath, dry and place on a clean surface. Inspect all parts for wear. Replace worn parts as necessary.

Remove the lock retainer from the mounting plate by unscrewing the two 10-32 x 1/2 in socket head screws. Remove the plunger lock from the lock retainer by removing the cap screw. Clean the lock plunger, lock retainer and springs with mineral spirits. Ensure the lock plunger is thoroughly rinsed to remove all dust from the key tumblers. Take the cleaned parts and dry thoroughly, using compressed air to dry the lock tumbler. Inspect all parts for wear. Replace worn parts as necessary.

Lubricate the plunger lock barrel and tumbler using two drops of light viscosity oil. Apply threadlocker6 to the lock set screw and install. Check the plunger lock for proper function by using the key to engage and unlock. Apply threadlocker to the lock retainer's 10-32 x 1/2 in screws, then mount the lock retainer to the locking mechanism plate. Hand-tighten the screws.

Apply a light coating of lubrication7 to the inside surfaces of the selector body and selector ring.

Do not lubricate the lock slide and sleeve. Note that some other unapproved types of greases may undergo chemical changes and form tars when exposed to radiation.

f.

Perform a visual examination of the bolt/fastener thread condition. The bolts/fasteners must be replaced if they are no longer fit for use (e.g., threads stripped, unable to fully thread, signs of cracking, etc). Ensure any replacement hardware meets all applicable specifications listed on the drawings referenced on approval certifications.

g. Begin assembly of the locking mechanism by lightly coating/lubricating all components. Treat all screw thread ends with threadlocker.

Mount the locking mechanism plate horizontally in a vise or fixture with the plunger lock and retainer at a 12 oclock position. (Note: Carefully mount the mounting plate in a vise or fixture so hands are free for the assembly procedure and no damage to the mounting plate will occur.)

The narrow end of the lock slide slot must be located at the 3 o'clock position. Locate the lock slide and return spring into the mating slot of the selector body.

Place the selector ring with the word CONNECT at the 12 o'clock position, over the selector body.

Push the lock slide inward during placement of the selector ring for clearance. Doing so will allow the selector ring to rest flush on the selector body. Insert the anti-rotation lug springs at the top and bottom of the selector body. Place the anti-rotation lugs over the springs.

Place the tungsten sleeve with the large diameter facing downward, on the center of the lock slide.

Place the compression spring over the sleeve.

Install the selector ring retainer into the selector ring. Verify that the three non-threaded holes line up under the word CONNECT located on the selector ring. Depress the selector ring retainer into the selector ring until it is flush with the top of the selector ring. Hold the selector ring retainer firmly against the mounting plate until the 10-32 x 11/4 in screws are installed.

6 Unless otherwise noted, references to threadlocker apply to Loctite' 242.

7 Unless otherwise noted, references to lubrication (including lightly coated references) in this bulletin apply to the use of MIL-G-23827B (or C), MIL-PRF-23827C, (or equivalent radiation resistant grease authorized in writing by QSA Global, Inc.).

SERVICE BULLETIN.

SB-23 Page 7 of 8 November 2024 While firmly holding the locking mechanism against the mounting plate, turn the plate over to expose the back side of the mounting plate. Install the four 10-32 x 11/4 in socket head screws to secure the mechanism to the mounting plate. Torque the socket head screws to 30 in/lb (3.39 Nm) +/- 5 in/lb (0.57 Nm) using a calibrated torque wrench.

h. Perform functional safety testing of the automatic securing and locking mechanism (see operations and maintenance manual MAN-027 for a more detailed description of performing the functional test.) Verify the securement action of selector mechanism by attempting to both push and pull an inactive source assembly out of the selector mechanism while in the EXPOSE, LOCK and CONNECT positions.

Rotate the selector mechanism back to the OPERATE position and push in the lock slide to ensure smooth operation and positive engagement. Attempt to push the lock slide towards the SECURED position to test for a positive engagement of the sleeve in the lock slide. If a smooth operation is not attained and/or the lock slide can be forced into the secured position by testing for positive engagement, disassemble and thoroughly re-inspect for faulty components.

Thoroughly inspect all components for rough edges, wear points, burrs, etc. which could cause jamming or irregular operation. Replace parts as necessary, re-lubricate and reassemble the selector assembly. Repeat the functional safety testing to verify smooth and safe operation of the selector mechanism. Do not install the serviced back plate (lock mechanism) module to the exposure device at this point.

i.

Remove the front plate containing the outlet port mechanism from the empty Model 880 device by removing the four 5/16-18 x 11/2 in socket button-head screws using the tamperproof tool bit mounted in a ratchet.

After removing the outlet port mechanism, clean the S tube of the exposure device by pushing cloth swabs wetted with solvent through the S tube until they come out clean. Use a dry cloth swab to remove any residual solvent from the S tube after cleaning.

Clean the exterior of the Model 880 using a mild detergent solution to remove all dirt and grime.

Visually inspect the packages stainless steel end plates for weld failures (cracks, etc.) on the locking mechanism and outlet port ends. Ensure the handle, the bottom contact surfaces and sides comprising the plastic jacket are intact. Check the bottom surfaces of the jacket to ensure the contact area is not excessively worn allowing contact of the stainless steel body with a flat work surface. Additionally, if dents to the devices body or flanges due to accidental drops are found during this inspection, contact QSA Global, Inc. to determine if repairs can be made to correct the damage.

If the label needs replacement due to illegibility, remove the old label from the package by using a number 30 drill-bit mounted in a hand drill. Remove the rivet heads used to fasten the label to the stainless steel body by drilling through the rivet head just enough to allow the rivet head to rotate freely. Remove all rivet heads to remove label. Install the replacement label and use a pop-rivet gun to secure the new 1/8 in x 3/16 in stainless steel rivets to secure the label to the package.

Disassemble the front plate (outlet port mechanism) by removing the set screw (or roll pin) from the outlet port cover. Discard the set screw. Unscrew the two socket head cap screws from the pivot disk. Remove and discard the two compression springs from the outlet port mechanism and replace with new springs.

SERVICE BULLETIN.

SB-23 Page 8 of 8 November 2024 Clean all parts in mineral spirits using a brush to dislodge all dust and dirt. Dry all components thoroughly. Do not lubricate, leave all components completely dry. Inspect for wear and burrs on the brass slider and rotor surfaces. Verify the tungsten port shield is not loose within the rotor. If the port shield is loose, remove the set screw, apply threadlocker (e.g., VibratiteTM) and retighten the set screw against the tungsten port shield. If the port shield uses a roll pin, remove the roll pin and replace. Inspect the front plates outlet port for wear and burrs where the source guide tube bayonet fitting engages.

Install new compression springs and assemble the outlet port mechanism. Apply threadlocker to the socket head cap screws before tightening. Apply threadlocker (e.g, Loctite' 222), and install a new set screw to the outlet port cover.

After assembly of the front plate, perform the following safety function tests using a bayonet source guide tube fitting. Pull the outlet port cover and rotate clockwise 90 degrees. Movement should be smooth and limited to a clockwise 90 degree turn. Insert a bayonet fitting into the outlet port and rotate 90 degrees in a counter-clockwise direction. Insertion and rotation of the bayonet fitting should be smooth and without snags. Rotate the outlet port cover from a 3 oclock position to a 5 oclock position. This operation moves the rotor from the port shield position to a pass-through section of the rotor. Reverse the operation to disengage the bayonet fitting.

Repeat the function test multiple times to ensure smooth operation.

j.

Re-assemble the Model 880 package by performing the following steps:

1) Apply anti-seize thread lubricant (e.g., PermatexTM 81343) to the first several end threads of the back plates (locking mechanism) four 5/16-18 x 11/2 in socket button-head screws. Align and attach the locking mechanism assembly to the exposure devices end plate by installing the four 5/16-18 x 11/2 in screws using a tamperproof tool bit mounted in a calibrated torque wrench. Torque the tamperproof screws to 110 in/lbs (12.43 Nm), +/- 5 in/lb (0.57 Nm).

2) Operationally test the function of the entire system using a bayonet-fitting source guide tube, the remote controls and a mock source assembly. Attachment of the bayonet source guide tube to the outlet port must be smooth and without resistance. Rotate the outlet port mechanism to enable exposure of the mock source assembly.

3) Connect the remote controls to the mock source assembly connector and the device locking mechanism. Push the lock slide into the EXPOSE position and crank the control cable into the exposure mode. While cranking the mock source assembly from the package, carefully feel for resistance or snags. During retraction of the mock source assembly back into the package, carefully feel for any resistance or snags during movement. Conclude the test by verifying the lock slide automatically secures the mock source assembly. Action of the lock slide should be smooth with an audible snap during automatic securing. After automatic securing, attempt to expose the mock source assembly from the package to confirm a positive capture. Repeat this testing several times. If resistance, snags or sluggish movement of the lock slide is discovered during this testing, remove the outlet port and locking mechanism plates to determine the cause. Repeat all safety function tests if any additional servicing is required.

4) If the package is operating normally, the mock source assembly can be removed from the package and an active source assembly loaded into the package.

k. Maintain records of this inspection and maintenance.