United States Nuclear Regulatory Commission - Protecting People and the Environment


ACCESSION #:  9706120107



SENTINEL



FAX # (617)229-2279                          PHONE # 1(617)273-9021

                                                  or 1(900)815-1383

                                                      Extension 200

FAX TO:   Dr.  Susan Shankman                      FAX MSG WM060997

FAX #:    1(301)415-8555                             TOTAL PAGES: 3

LOCATION: USNRC Transportation Safety and        DATE: June 9, 1997

          Inspection Branch

FROM:     W. M.  McDaniel

          Burlington, Ma.  USA



                                                  URGENT

COPY TO:



Dear Dr.  Shankman,



We appreciate the concerns brought to out attention by NRC during the

June 4th through 6th, 1997 inspection.



Described below you will find (I.) a summary of our understanding of the

concerns expressed by NRC; and (II.) an outline of out proposed action

plan.



We do not at this time have any reason to believe that there are any

immediate health mid safety concerns in regards to our Type B containers.



In regards to the concerns raised by NRC, we feel that 10 CFR Part 21

provides the appropriate framework for assessment.  As you will note from

the proposed action plan described below, we are utilizing our Part 21

procedure for this activity,



We look forward to your telephone call to discuss this matter, and assure

that we are focusing on the game issues.



I.   Summary of NRC Concerns



o         Documentation

          o    Routing/Approval of responses to NRC questions on

               submissions.

          o    Justification of 20% as acceptable for "Significant

               Increase" for normal conditions



               of testing.

          o    Justification of assessment of the most vulnerable area(s)

               and documentation of areas evaluated that were determined

               to not be the most vulnerable and why.  (Tie in our Safety

               Class Assessment process.)

          o    Documentation of the damage incurred during the testing

               and assessment of implications of damage incurred as a

               result of the various testing and the implications on the

               previous "most vulnerable area," assessments.  Potentially

               resulting in re-assessment of most vulnerable area.

          o    Detailed data sheets with step by step sign off and QA

               approvals.

          o    As built documentation of test unit, Normal production

               documentation as a minimum.

          o    Modifications to the test unit.

          o    Center of gravity position assessment.

          o    Assessment of condition of dummy source.

          o    Curie strength of source used in preliminary and post test

               profiling.

          o    All testing equipment controlled in QA/calibration

               program.  Including: billet (Mounted), Drop Pad,

               Temperature Measurement Equipment, other measurement

               equipment.

          o    Engineering assessment of optimum length of billet.



o         Test Condition Integrity

          o    Mounted billet

          o    Optimum length of billet

          o    Drop Pad "Essentially Unyielding Surface",

          o    Drop Pad flat so that billet is vertical.

          o    Loss of one steel plate from 676 unit reducing original

               weight.  Implication on Puncture testing.

          o    Temperature of component impacted.

          o    Center of Gravity relation to drop orientation.

          o    Impacted on most vulnerable area.

          o    Crack found in shell of 676 during the inspection.

          o    Accuracy of information reported in test results and

               submissions.

o

          QA Program Concerns

          o    Testing not performed in accordance with 10 CFR Part 71.

          o    Test plan approvals.

               o    Technical qualifications of individual providing the

                    approval

               o    Approval of additional testing performed after the

                    original approval.

          o    Witnessing of test.



          o    Long Term:

               o    QA involvement

               o    Attention to detail

               o    Strength of QA involvement in Engineering



II.  Amersham's Proposed Action Plan

o    Part 21 Assessment of our current Type B Containers

o    Pad Assessment - Independent.

o    Assess secured vs unsecured billet - Independent.

     o    The result will possibly be device dependent.

o    Secure billet and confirm optimal length

o    Write Type B Container Test Procedure including fundamental test

     parameters.

     o    Send to NRC

o    Retest representative units of the following models for Type B

     Testing Requirement:

     o    660 Series

     o    650/L

     o    702

     o    676

     o    680

     o    715

     o    920

     o    Others as appropriate.

o    Establish test schedule

o    Advise NRC of date(s) for retesting.

o    Periodic updates to NRC



If you should have any questions we can discuss them during our agreed

upon telephone call.



Regards,



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