Part 21 Report - 1997-453
ACCESSION #: 9708140098
SENTINEL
Amersham Corporation
40 North Avenue
Burlington, MA 01803
tel (617) 272-2000
6 August 1997 tel (800) 815-1383
fax (617) 273-2216
Document Control Desk
U.S. Nuclear Regulatory Commission
Washington, DC 20555 Amersham
Dear Sir or Madam:
Amersham is making an interim report under CFR 21.21(a)(2). This report
concerns the Amersham Type B packages listed in the attachment.
On 6 Jun 97 we learned from NRC Transportation and Safety Branch that the
puncture test required for Type B package testing described in 10 CFR 71
was to be performed with the puncture bar secured to an essentially
unyielding surface. This was followed up by USNRC Information Notice
number 97-47 where the interpretation of the word "mounted" in 10 CFR 71
was given as secured. The puncture tests that had been performed by
Amersham were performed with the puncture bar not secured to the surface.
Initial evaluations have been performed to determine the potential safety
impact on the Type B packages of not securing the puncture bar for the
test.
These initial safety assessments were completed and submitted to NRC
Transportation and Safety Branch on 16 Jun 97 as justification for
continued transport of the Type B packages, (copy enclosed). These
safety assessments were accepted by NRC on 25 Jul 97. We will be
continuing with these assessments as committed to in a Confirmatory
Action Letter dated 10 June 1997, (CAL number 97-7-005). All closeout
activities related to this interim report will be in accordance with the
CAL and submitted to NRC Transportation and Safety Branch, unless there
are any other required Part 21 issues.
Please contact me if you require any additional information.
Sincerely,
Cathleen Roughan
Regulatory Affairs Manager
cc: Dr. Susan Shankman, NRC Transportation and Safety Branch
Mr. Robert Hallisey, Massachusetts Department of Health
Attachment 1
Model number Certificate Number
660 9033
650 9032
650L 9269
676 9029
680 9035
684 9026
702 6613
715 9039
741 9027
770 9148
771 9107
820 9137
850 9147
855 9165
864 9166
865 9187
920 9143
500SU 9006
Gammatron 20, 50 9126
Gammatron 100, 200 9127
C-8 9128
3206 9167
6717 6717
GENERAL NOTES AND JUSTIFICATION FOR ALL PACKAGES
A review and assessment has been made on the Amersham Type B(U) packages
to determine the justification for continued use. These reviews/
assessments were performed from 7 Jun 97 - 12 Jun 97 by representatives
of Engineering, Quality Assurance and Regulatory Affairs. They reviewed
existing test documentation, materials and methods of construction,
operational history and incident assessment. A more detailed assessment
will be performed as a part of the Part 21 evaluations for these
packages.
- Packages have been extensively used in the field under the severe
environmental conditions of industrial radiography, ie dropping off
vehicles and scaffolding and in the transportation cycle on a daily
basis with no release of the source or significant degradation in
transport related safety features for the entire history of the
design of the devices being assessed.
- Packages have been subjected to accident conditions such as drops,
flooding and fires with no release of the source or significant
degradation of transport related safety features. There has not
been a failure of an Amersham Type B container in the operational
history of these packages.
- Packages were subjected to a 30 foot drop test and a 1 meter drop
onto a steel billet. In most cases they have undergone several drop
and puncture tests on the same unit with no change in radiation
levels as a result of the tests. Majority of puncture tests were
performed with center of gravity over impact point.
- Amersham owned source changers have a documented QC inspection
performed on each unit prior to every shipment to assure structural
integrity.
- Radiography devices are subject to the requirements of 10 CFR 34.28
for inspection prior to each use and must be inspected and
maintained every three months. This helps ensure that packages are
in good condition prior to transport by the radiography company.
- Prior to each shipment, packages are surveyed at the surface and at
one meter to assure radiation levels are less than 200 mR/hr and 10
mR/hr respectively.
- Users of the equipment are required by 10 CFR 34 to survey after
each exposure and when placing device into storage, providing early
indication of any potential problems.
- Due to changes in 10 CFR 34, most packages currently in use are new
manufacture or have undergone a detailed inspection prior to being
retrofitted to meet new equipment standards.
- Packages were assessed using the following criteria:
- results of initial package testing
- ability to meet normal conditions of transport
- details of construction
- historical information
- no significant change in radiation levels after accident
conditions
16 Jun 97 Page 1
- frequency of transport
16 Jun 97 Page 2
Package model NRC Justification for Continued Use
-Approximate Number Coc
Manufactured Number
-Number of Years in Use
660 9033 Have received and inspected more than
30 accidentally dropped 660s from
- 8000 Units various heights ranging from 2 feet to
- 23 years 70 feet. In all cases the source
remained secured in shielded position.
Shipped daily with no evidence of
unusual radiation levels.
650 9032 Source securing mechanism is protected
by outer shipping cover which takes
- 400 Units the impact forces during a drop.
- 22 years Flanges on outer containment take
impact energy. Shipped daily with no
evidence of unusual radiation levels.
650L 9269 Source securing mechanism is protected
by outer shipping cover which takes
- 220 Units (modified the impact forces during a drop.
- from existing 650 base) Flanges on outer containment take
- 2 years (modified 650) impact energy. Shipped daily with no
evidence of unusual radiation levels.
702 6613 Cask is constructed of stainless steel
and utilizes stainless steel hardware.
- 31 Units Has several layers of protection, ie
- 20 years metal mesh cage, skid, cask hold down
assembly and cask itself. Has been
accidentally dropped 5 feet with no
damage to inner cask assembly.
676 9029 No immediate health and safety risk.
With additional precautions taken by
- 37 Units customer during transport can be
- 22 years safely transported by radiography
licensees. For shipments by common
carrier the source should be removed
and placed in a source changer and the
676 shipped empty or the 676 must be
placed in an authorized Type B
overpack, i.e., 20 WC, as controls
exercised during shipment by a common
carrier are unknown.
680 9035 No historical problems and has been
routinely transported to radiography
- 400 Units job sites. Shipped daily with no
- 22 years evidence of unusual radiation levels.
16 Jun 97 Page 3
Package model NRC Justification for Continued Use
-Approximate Number Coc
Manufactured Number
-Number of Years in Use
741 9027 No historical problems and has been
routinely transported to radiography
- 200 Units job sites. Shipped frequently with no
- 22 years evidence of unusual radiation levels.
684 9028 No historical problems and has been
routinely transported to radiography
- 170 Units job sites. Shipped frequently with no
- 22 years evidence of unusual radiation levels.
No longer manufactured.
6717 6717 The barrel is inspected prior to each
shipment and replaced if dented,
- 100 Units therefore, the barrels have a limited
- 22 years lifetime. The inner containers have
been approved by a regulatory
authority as devices capable of
securing the source. The lock
mechanisms of the devices are
protected within the barrel. Several
layers of protection are incorporated
in the package, i.e., outer barrel,
chalk insulation, a foam insert and
the locked device. The barrel is
suitable for all authorized contents
listed on CoC except for the Pipeliner
Model 1 device. Due to questionable
test information that requires
additional time and information to
resolve, and as a conservative
approach, we recommend that the
Pipeliner Model 1 not be transported
in the 6717 drum until these issues
can be resolved.
715 9039 The model 715 is constructed from a
Mil-Spec barrel of 18 gauge steel. It
- 85 Units is currently used to transport the
- 22 years model 616 exposure device which meets
the requirements of DOT Type A. In
addition there are several layers of
protection provided through the chalk
liner and rubberized hair insert.
16 Jun 97 Page 4
Package model NRC Justification for Continued Use
-Approximate Number Coc
Manufactured Number
-Number of Years in Use
770 9148 The 770 is a solid carbon steel
weldment. The depleted uranium shield
- 1 Unit is held in place by a rod bracketing
- 18 years structure contained within an inner
welded box construction. Locking
assemblies are recessed and protected
by shipping plates. Amersham owns the
only 770 in existence and it is used
approximately once a year.
771 9107 The 771 is a solid carbon steel
weldment. The depleted uranium shield
- 5 Units is held in place by a rod bracketing
- 19 years structure contained within an inner
welded box construction. Locking
assemblies are recessed and protected
by shipping plate. Amersham owns all
of the model 771 in use and it is used
approximately 17 times a year.
820 9137 Stainless steel construction with all
exterior hardware out of stainless
- 8 Units steel. Source locking mechanism is
- 17 years protected by a flanged cover hat. The
model 820 source changers are owned by
Amersham and currently being shipped
approximately 4 times a year.
850 9147 Stainless steel construction with
stainless steel hardware. Locking
- 15 Units assemblies protected by steel plates
- 16 years secured in place. The model 850
source changers are owned by Amersham
and are shipped approximately 6 times
a year.
855 9165 Locking assemblies are recessed and
protected by top cover. All model 855
- 14 Units source changers are owned by
- 14 years Amersham. Results of a recent drop by
carrier demonstrated that sources
remained in secured position, there
was no loss of shielding integrity and
no damage to source locking mechanism.
864 9166 Locking assemblies are recessed and
protected by top cover. Amersham
- 9 Units possession and approximately one
- 14 years shipment a year.
16 Jun 97 Page 5
Package model NRC Justification for Continued Use
-Approximate Number Coc
Manufactured Number
-Number of Years in Use
865 9187 All stainless steel construction and
hardware for containment. Outer cover
- 70 Units protects locking assembly. Locking
- 13 years assembly fails safe, ie keeps source
rod within stored position in device.
920 9143 Constructed of stainless steel. Due
to step down in source tube, source
- 70 Units can not exit the device even if
- 16 years locking assembly sheared off. Several
devices have been accidentally dropped
approximately 4-5 feet and the source
remained in the secured and shielded
position.
C-8 9128 Only unit in existence is owned by
Amersham and is no longer routinely
- 1 Unit used. Locking assembly is protected
- 18 years by a welded structure with a hinged
cover.
Gammatron 20/50 9126 Infrequent transport as not authorized
for use under 10 CFR 34 requirements.
- 60 Units Locking assembly is protected by pipe
- 18 years welded over locking assembly. There
has been no evidence of unusual
radiation levels during its use.
Gammatron 100/200 9127 Infrequent transport as not authorized
for use under 10 CFR 34 requirements.
- 22 Units Locking assembly is protected by pipe
- 18 years welded around locking assembly.
AI 500SU 9006 Outer housing constructed from
stainless steel. Locking mechanism
- 220 Units and shipping caps are protected by
- 12 years hinged and secured cover of device.
Amersham ownership and infrequent use.
3206 9167 Not currently used as a Type B
package.
- 20 Units
- 14 years
16 Jun 97 Page 6
*** END OF DOCUMENT ***
Page Last Reviewed/Updated Wednesday, March 24, 2021