United States Nuclear Regulatory Commission - Protecting People and the Environment


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



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