Part 21 Report - 1997-452
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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