QSA GLOBAL QSA Global, Inc.QSA GLOBAL QSA Global, 40 North Avenu Burlington, MA Telephone: (781 Toll...

QSA GLOBAL QSA Global,

40 North Avenu

Burlington, MA

Telephone: (781

Toll Free: (800)

16 January 2013 Facsimile: (781

Mr. Michael Waters, ChiefLicensing BranchDivision of Spent Fuel Storage and TransportationOffice of Nuclear Material Safety and SafeguardsU.S. Nuclear Regulatory Commission11555 Rockville Pike, Mailstop EBB-3D-02MOne White FlintRockville, MD 20852

RE: 10 CFR 71.95 report for CoC number 6613

Dear Mr. Waters:

We are making a 10 CFR 71.95 report concerning the Model 702 Type B package (CoC 6613).We have determined that shipments of this container have been made using aluminium cans tolimit the movement of source capsules within the shield cavity of the package. The descriptivedrawing for this package allows the use of metallic cans/inserts so long as these items are madefrom non-pyrophoric metals with a melting temperature at or above 800'C. The melting point ofaluminium is below 800'C and therefore should not have been used under the Type B(U)approval.

While reviewing options for use of an aluminium can to limit source capsule movement in anupcoming shipment to a new consignee, the question was raised by production staff as to theacceptability of using these cans in the new shipment. Based on a review of the Type B(U)approval it was advised to the production staff that aluminium containers did not meet the criteriafor use under the Type B(U) approval. It was at this point that internal RA/QA staff were advisedthat these cans had been used in past shipments to an affiliated QSA Global, Inc. company (LomaSystems) in the Czech Republic since December 2010.

A review of past shipments identified that these aluminium cans could have been used in a totalof 55 shipments since December 2010 to limit source capsule movement inside the 702 shieldcontainer. These shipments were shipments of Ir-192, Se-75 or a combination of those twoisotopes.

The identification of this issue prompted a detailed review of the internal specifications used byQSA Global, Inc. for preparation of these containers for Type B(U) shipment. Prior to thecertificate renewal in December 2010, this container had allowed the use of metallic cans to limitmovement of source capsules, but there had been no limitation on the pyrophoric nature ormelting temperature of the metallic cans used within the package. With the renewal of thecertificate at revision 14, these requirements were added, however, our internal procedures forthis package were not updated to reflect the additional material restrictions.

Inc.

01803

1)272-2000

815-1383

) 273-2216

w w w . q s a - g I o b a I . c o m

The addition of these material restrictions was prompted due to NRC concerns in a letter dated 4Oct 2010 that "The melting or ignition of the metallic canister used to hold the special formsource could result in damage to the special form source capsule, leading to an unanalyzedcondition or release of radionuclides."

For all affected shipments where aluminium canisters were used to limit movement of sourcecapsules inside the 702, there was no degradation of the aluminium canisters including no meltingor ignition of these canisters during or after the shipment was received and unloaded by Loma inthe Czech Republic. The use of these canisters, although not authorized under the Type B(U)certificate, did not cause any damage or degradation to the special form capsules transportedwithin the 702 in any of these shipments. In all cases, there were no significant safety issues orreduction in source containment integrity as a result of the use of the aluminium cansisters, norwere there any Part 21 implications as a result of their use in Type B(U) transport of thiscontainer.

Since internal identification of this issue on 14 January 2013, Production staff involved with theloading/preparation of the 702 Type B(U) container have been informed of the materialrestrictions for metallic cans/inserts when making a Type B shipment in the Model 702containers. Further, the internal guidance provided for staff in preparation of this container hasbeen revised to clarify the material restriction on metallic cans allowed for use in Type Bshipments of the Model 702.

In addition, a review of the loading procedures in Section 7 of the SAR was made and a revisionto Section 7.1.2.1.c. in included with this letter which clarifies the limitation and use of metalliccans/inserts inside the Model 702 for Type B(U) shipments. This is included as a revision topages 7-3 through 7-8 of SAR Revision 11 (see Enclosures). Since the applicable descriptivedrawing for this package (R70290 Revision W) specifies the limitations of use for thesecans/inserts, the additional revisions to Section 7 of the SAR are being made for consistency andto address circumstances where the transport of Ir-192 does not require the use of a tungsteninsert to ensure package dose rates are compliant with the regulatory limits in 10 CFR 71.47. Assuch, we also request amendment to certificate USA/6613/B(U)-96 to incorporate the changes toSection 7 of the SAR as detailed in the enclosed pages. (There are no other changes to the SARat this time.)

Lastly, we will revise our internal procedures to require a review of all affected internalloading/shipping instructions upon renewal/amendment of a Type B container. Records of suchreviews will be maintained as part of the package approval documentation.

Should you have any additional questions, or wish to discuss our amendment request, pleasecontact me.

Sincerely,

Lori PodolakSenior Regulatory Affairs SpecialistRegulatory/Quality Affairs DepartmentPh: (781) 505-8241Fax: (781) 359-9191Email: [email protected]

RA/QA Approval/5 Z•-'9i' Z1/3

Date

Enclosure: Revision 11 of the SAR, pages 7-3 through 7-8List of Affected Pages

cc: ATTN: Document Control DeskDirector, Division of Spent Fuel Storage and TransportationOffice of Nuclear Material Safety and SafeguardsU.S. Nuclear Regulatory Commission11555 Rockville PikeOne White FlintRockville, MD 20852

Safety Analysis Report for the Model 702 Transport Package

List of Affected Pages

Revision 4, Revision in entirety. This revision supercedes previously submitted19 July, 2001 SAR's for the 702.Revision 5, 12 Revision in entirety. Incorporated changes to the nuclide capacities,March 2002 profile information and minor typographical corrections.Revision 6, 19 Revision to Cover sheets, and page 13 (incorporate reference toJuly 2002 IAEA para. 619, pages 20 and 22 (modifying the minimum capsule

wall/weld thickness) and descriptive assembly drawings.Revision 7, 24 Revision to reformat following guidance in Regulatory Guide 7.9Jun 2005 Revision 2 and to document compliance with IAEA TS-R-1Revision 8, 9 May Revision to incorporate changes requested under NRC RAI dated 282008 Apr 08 and to make administrative changes to the SAR format.

Revised pages include the cover page plus pages ii, iii, iv, 2-18 thru2-20, 5-1, 5-8, 5-10, 7-2 thru 7-8 & 8-3

Revision 9, SAR updated to reflect compliance to NUREG 1886 (Final Report -August 2010 March 2009).Revision 10, Page 1-4 revised to limit inserts materials to non-pyrophoric metalsOctober 2010 with melting temperatures at or above 800'C. Drawings references

in Section 1.3 undated from R70290 Rev U to Rev V.Revision 11, Pages 7-3 through 7-8 revised to clarify loading instructionsJanuary 2013 regarding use of metallic cans/inserts in accordance with restrictions

on drawing R70290 referenced on the Certificate of Compliance.

+

-4-

i

+

+

+

+


QSA Global, Inc. January 2013 - Revision 11Burlington, Massachusetts Page 7-3

NOTE: All removal and installation of radioactive material containedwithin the 702 must be performed in a shielded cell/enclosurecapable of holding the maximum isotope capacity of thiscontainer. This can only be performed by persons specificallyauthorized under an NRC or agreement state license. Allnecessary safety precautions and regulations must be observed toensure safe transfer of the radioactive materiaL

7.1.2.1 Prior to transportation, ensure the package and its contents meet thefollowing requirements:

7.1.2.1 .a The contents are authorized for use in the package.

7.1.2.1 .b The package condition has been inspected in accordancewith Section 7.1.1.2.

7.1.2.1 .c Ensure that the source(s) are secured into place in thestorage positions in accordance with the followingrequirements. Compliance with the following requirementsensures that the sources are secured in position beforeshipment.

I. Install the radioactive material into the 702.

Note 1: The optional use of metallic cans and inserts isallowed in the 702 shield cavity to limit movement ofsource capsules. Such cans/inserts must comply withthe requirements of drawing R70290 referenced on theCertificate of Compliance.

Note 2: The use of tungsten cans/inserts is optionalwhen transporting Ir- 192 where supplemental shieldingis desired to ensure dose rates from the package arewithin the regulatory limits of 10 CFR 71.47.

2. After loading of the source capsules into the shieldcavity, install the gasket. The gasket must be in goodphysical condition with no rips or tears. Place the caskcover onto the top of the 702 cask and seat the coverproperly. To seat properly, the lid must lie flush withthe top of the cask. This will effectively shield thecontainer so that it can be safely handled.



3. The cask can then be removed from the shieldedcell/enclosure. The operator should verify that theradioactive material is properly stored by surveying allsides of the cask.

4. The cask cover can then be properly installed on thecask and secured with the six 3/8-16 x 7/8 inch longhex head bolts. Install lock washers and a flat washerwith the bolt. Torque the bolts to 236 ± 5 inch-pounds.

5. Seal wire two of the hex head bolts on the cask cover.

6. Place the cask onto the metal skid. Insert the four 1/2-13 hex head bolts with lockwashers through the caskbottom plate mounting holes and into the 4 holes on thesteel plate of the metal skid. Torque the bolts to 370 ±5inch-pounds.

7. Place the cask hold down assembly (clamp ring) ontothe top of the cask. Inspect the four 1/2-13 threadedrods to assure that they are not damaged or bent. Insertthe rods through the clamp ring and into the 4 steelweldments on the skid.

8. Secure the bottom of the threaded rod with a 1/2-13square nut. The rod should completely engage the nut.

9. Secure the threaded rods with a 1/2-13 hex nut and steellockwashers at the top of the clamp ring. Torque theseto 370 ±5 inch-pounds.

10. Wipe test the cask and metal skid over an area of 300square centimeters and assure the level of removable

2contamination is less that 0.0001 ýLCi (4 Bq) per cm2.

11. Place the metal protective cage on the skid and secure itin 4 comers with lockwashers, flatwashers, and 1/2-13hex head bolts. Torque the bolts to 370 ±5 inch-pounds.

12. Seal wire one of the drilled bolts to provide a tamperindicator seal. The seal wire should pass through thedrilled head of the bolt and around the steel tubing.


QSA Global, Inc. January 2013 - Revision 11Burlington, Massachusetts -5

7.1.3 Prepatration for Transport

7.1.3 1 Ensure that all conditions of the certificate of compliance are met.

7.1.3,2 Perform a contamination wipe of the outside surface of the package andensure removable contamination does not exceed 0.0001 jiCi whenaveraged over a wipe area of 300 cm 2.

7.1.3 3 Survey all exterior surfaces of the package to assure that the radiation leveldoes not exceed 200 mR/hr at the surface. Measure the radiation level atone meter from all exterior surfaces to assure that the radiation level is lessthan 10 mR/hr.

7.1.3 4 Ship the container according to the procedure for transporting radioactivematerial as established in 10 CFR 71.5 and 49 CFR 171-178.

i

NOTE: Th, US Department of Transportation, in 49 CFR 173.22(c), requires eachshipper of Type B quantities of radioactive material to provide prior notificationto t ie consignee of the dates of shipment and expected arrival.

7.2 Package Unloading

7.2.1 Receipt of Package from Carrier

7.2.1Z1 The consignee of a transport package of radioactive material must makearrangements to receive the transport package when it is delivered. If thetransport package is to be picked up at the carrier's terminal, 10 CFR

20.1906 requires that this be done expeditiously upon notification of itsarrival.

7.2.12 Upon receipt of a transport package of radioactive material:

7.2.1.2.a Survey the transport package with a survey meter as soon aspossible, preferably at the time of pick-up and no more thanthree hours after it was received during normal working hours.Radiation levels should not exceed 200 mR/hr at the surface ofthe transport package, nor 10 mR/hr at a distance of 1 meterfrom the surface.

7.2.1.2.b Record the actual radiation levels on the receiving report.

7.2.1.2.c If the radiation levels exceed these limits, secure the containerin a Restricted Area and notify the appropriate personnel inaccordance with 10 CFR 20 or applicable Agreement Stateregulations.


QSA Global, Inc. January 2013 - Revision 11Burlington, Massachusets Page 7-6

7.2.1.2.d Inspect the outer container for physical damage or leaking. Ifthe package is damaged or leaking or it is suspected that thepackage may have leaked or been damaged, restrict access tothe package. As soon as possible, contact the Radiation SafetyOffice to perform a full assessment of the package conditionand take necessary follow-up actions.

7.2.1.2.e Record the radioisotope, activity, model number, and serialnumber of the source and the transport package model numberand serial number.

7.2.2 Recelpt of Contents

7.2.2 1 Unload the 702 in accordance with the applicable licensing provisions forthe user's facility related to radioactive material handling.

7.2.2,2 Remove the inner shield container from the Model 702 skid andprotective cage assemblies.

7.2.2.3 Place the shield container in a shielded cell/enclosure capable of holdingthe maximum isotope capacity of this container.

7.2.2,4 Remove the six 3/8-16 x 7/8 inch long hex head bolts, lock washers andflat washers and remove the cover lid from the shield cask.

7.2.2.5 Use remote handling techniques to remotely unload each source andtransfer the source to an alternate, shielded storage location.

7.3 Preparation of Empty Package for Transport

In the folloing instructions, an empty transport package refers to a Model 702 transportpackage without an active source contained within the depleted uranium shieldedcontainer.

7.3.1. Perform the following procedure to confirm that there are no unauthorized sourceswithin the container:

7.3.141 Place the shield container in a shielded cell/enclosure capable of holdingthe maximum isotope capacity of this container. Remove the cover.Remove any shield inserts used in that shield container and visuallyinspect the container for any source capsules.

7.3.142 Use remote manipulators, mirrors, and radiation monitors if necessary,inspect the container to verify that it is empty.


QSA Global, Inc. January 2013 - Revision 11Burlington, Massachuse Page 7-7

7.3.1i3 Once the shield cavity is determined to be empty, place all shield insertsback into the container and install the cover.

7.3.2 Assure that the levels of removable radioactive contamination on the outsidesurface of the transport package do not exceed 4 Bq/cm2 (when averaged over 300cm2).

7.3.3 When it is confirmed that the Model 702 transport package is empty, survey thedevice and prepare the transport package for shipment. Survey the assembledpackage to ensure the external surface radiation level does not exceed 5 p.Sv/hr.

7.3.4 Ship the container according to the procedure for transporting radioactive materialas established inl0 CFR 71.5.

1

7.4 Other OperI ations

7.4.1 Package Transportation By Consignor

Persons transporting the Model 702 transport package in their own conveyancesshould comply with the following:

7.4.1.1 F or a conveyance and equipment used regularly for radioactive materialtransport, check to determine the level of contamination that may be presenton these items. This contamination check is suggested if the package showss gns of damage upon receipt or during transport, or if a leak test on thes )ecial form source transported in the package exceeds the allowable limit of195 Bq (0.005 gtCi).

7.4.1.2 IfI contamination above 4 Bq/cm2 (0.0001 g Ci/cm 2) based on wiping an area of3 00 cm 2 is detected on any part of a conveyance or equipment used regularlyfor radioactive material transport, or if a radiation level exceeding 5 ptSv/h(•.5 mR/hr) is detected on any conveyance or equipment surface, then removetlhe affected item from use until decontaminated or decayed to meets theselin its.

7.4.1.3 E=nsure the package is properly blocked and braced prior to transport top event movement within the conveyance during transport.

7.4.2 Eme gency Response

In thq event of a transport emergency or accident involving this package, followthe gýidance contained in "2008 Emergency Response Guidebook: A Guidebook



for First Responders During the Initial Phase of a Dangerous Goods/HazardousMaterials Incident", or equivalent guidance documentation.

Reference: "2008 Emergency Response Guidebook: A Guidebook for FirstResponders During the Initial Phase of a Dangerous Goods/Hazardous MaterialsIncident.

7.5 Appendix

Not Applicable.

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