Project Assessment Report for GB/3746B Certificate of Approval Extension

Transcription

1 Title of document ONR Transport Competent Authority Project Assessment Report for GB/3746B Certificate of Approval Extension Project Assessment Report ONR-TD-PAR Revision 0 30 April 2018 Office for Nuclear Regulation, 2018 If you wish to reuse this information visit for details. Published 04/18 For published documents, the electronic copy on the ONR website remains the most current publicly available version and copying or printing renders this document uncontrolled. Template Ref: ONR-DOC-TEMP-005 Revision 12 Page 1 of 10

2 EXECUTIVE SUMMARY This report summarises the basis of the regulatory decision by the Office for Nuclear Regulation (ONR) as the Great Britain (GB) Competent Authority (CA) for Class 7 (radioactive materials), to issue an extension to the existing Certificate of Approval (CoA) of package design, under regulation 802 of IAEA SSR-6, to QSA Global Inc. (USA), for the radioactive material transport package with CA identification mark GB/3746B/B(U)-96. Permission Requested QSA Global Inc. requested a renewal of the CoA for the transport package GB/3746B/B(U)-96 to transport a combination of special form sources up to a maximum of 7.4 TBq of iridium-192 and 12 TBq of selenium-125 by all modes of transport i.e. road, rail, sea and air. A limit shall be imposed such that the sum of the proportionate amounts of each radionuclide present with respect to the quantities above does not equal one. Background The existing CoA for the GB/3746B/B(U)-96 was issued on 22 January 2013 and expires on the 28 February The renewal application was submitted to ONR on 13 October To prevent an interruption in the use of the package, which transports sources used in industrial radiography equipment, a decision was taken by the CA Delivery Lead (DL) to undertake an extension to the existing CoA. Assessment and inspection work carried out by ONR in consideration of this request ONR carried out a programme of assessment work in accordance with ONR s management system for transport approvals in consideration of an extension to the existing CoA, focussing on the key package safety functional areas of engineering, shielding and safety case requirements. Matters arising from ONR's work The engineering assessment recommended that an extension of six months to the existing CoA should be granted. This is to provide the applicant time to apply engineering changes; should they be necessary as part of ONR s assessment of the renewal application. Conclusions Assessments in the areas of radiological protection, mechanical engineering and safety case requirements have all concluded that no major changes had been applied to the package / material design that would undermine the existing approved application and that the previous ONR assessments did not place any limitation on the continuing adequacy of the package / material design. ONR concludes that the QSA Global Inc. GB/3746B/B(U)-96 meets the regulatory requirements for a Type B(U) radioactive material transport package, as implemented in UK law, to transport a combination of special form sources up to a maximum of 7.4 TBq of iridium- 192 and 12 TBq of selenium-125 by all modes of transport i.e. road, rail, sea and air. With the limit such that the sum of the proportionate amounts of each radionuclide present with respect to the quantities above does not equal one. Recommendation It is recommended that ONR grant a six-month extension to the existing CoA and issues CoA GB/3746B/B(U)-96 Issue 4 with expiry date 31 August Office for Nuclear Regulation Page 2 of 10

3 LIST OF ABBREVIATIONS CA CoA DL GB HOW2 IAEA ONR USA Competent Authority Certificate of Approval Delivery Lead Great Britain (ONR) Business Management System International Atomic Energy Agency Office for Nuclear Regulation United States of America Office for Nuclear Regulation Page 3 of 10

4 TABLE OF CONTENTS 1 PERMISSION REQUESTED BACKGROUND ASSESSMENT AND INSPECTION WORK CARRIED OUT BY ONR IN CONSIDERATION OF THIS REQUEST MATTERS ARISING FROM ONR'S WORK CONCLUSIONS RECOMMENDATIONS REFERENCES... 8 Figures Figure 1: Figure 2: Photo showing GB/3746B transport package Illustration showing x-section of GB/3746B transport package Office for Nuclear Regulation Page 4 of 10

5 1 PERMISSION REQUESTED 1. QSA Global Inc. requested a renewal of the CoA for the transport package GB/3746B/B(U)-96 to transport a combination of special form sources up to a maximum of 7.4 TBq of iridium-192 and 12 TBq of selenium-125 by all modes of transport i.e. road, rail, sea and air. 2. A limit shall be imposed such that the sum of the proportionate amounts of each radionuclide present with respect to the quantities above does not equal one. 3. This approval is requested for contents at activity levels that require the package to be classified as a Type B(U) package. The GB/3746B/B(U)-96 shall be referred to as the GB/3746B in the remainder of this document. 2 BACKGROUND 4. This package design was originally created by Amersham International Plc and known as the 0666W. The design has been in service since the late 1970's, and was licensed under the IAEA 1973 Regulations. The design number changed to GB/3605B for the IAEA 1985 Regulations. In 2003 the packaging and design rights were transferred to AEA Technology plc. who re-designated it the GB/3746B. QSA Global Inc. has subsequently acquired the package rights. 5. Figure 1 shows a photo of the GB/3746B package. The package outer is a carbon steel drum, with a full diameter lid and a stainless-steel clamp-band. Two handles provide for lifting and for tie-down. Impact and thermal protection is provided by the drum and a cork liner whilst a lead pot provides radiation shielding. The pot can have tungsten or depleted uranium inserts for additional radiation shielding. The pot holds the special form capsules of iridium-192 and selenium-75. Figure 2 shows an Illustration showing a x-section of GB/3746B package. 6. The existing CoA [1] for the GB/3746B was issued on 22 January 2013 and expires on the 28 February The renewal application was submitted to ONR on 13 October To prevent an interruption in the use of the package, which transports sources used in industrial radiography equipment, a decision was taken by the CA DL to undertake an extension to the existing CoA [1]. 7. The maximum heat output of the sealed sources is 3.6W. There is no criticality risk due to the non-fissile nature of the contents. The package external dose-rate primarily arises from the gamma radiation emitted during the decay process of iridium-192 and the bremsstrahlung from its beta decay. Selenium-75 only contributes a small fraction to the package external dose-rate compared to iridium-192.the primary hazard associated with the package is the external radiation dose-rate. 3 ASSESSMENT AND INSPECTION WORK CARRIED OUT BY ONR IN CONSIDERATION OF THIS REQUEST 8. ONR carried out a programme of work in assessment work in accordance with ONR s HOW2 [2] management system for transport approvals in consideration of an extension to the existing CoA [1], focussing on the key package safety functional areas of engineering, shielding and safety case requirements. 9. Because an extension to an existing CoA [1] was considered, ONR assessors performed a comparison between the renewal application [3] [4] and the existing approved application [5] [6], to ensure that there were no significant changes or developments since the granting of the existing CoA [1] that could call into question the continuing validity of the existing approved application [5] [6], or the use of the package / material design. The Design Review Report (DRR) [7], which forms part of the Office for Nuclear Regulation Page 5 of 10

6 renewal application and which was submitted separately and after the renewal application, was also considered by the assessors. 10. The engineering assessment conducted by ONR [8] found that no major changes had been applied to the package / material design that would undermine the existing approved application [5] [6] and that the previous ONR assessment did not place any limitation on the continuing adequacy of the package / material design. 11. The engineering assessment recommended that an extension of six months to the existing CoA [1] should be granted. This is to provide the applicant time to apply engineering changes; should they be necessary as part of ONR s assessment of the renewal application [3] [4], which will involve detailed assessment of the package examination, inspection and testing. 12. The shielding and dose-rate assessment conducted by ONR [9] found that no major changes had been applied to the package / material design that would undermine the existing approved application [5] [6] and that the previous ONR assessment did not place any limitation on the continuing adequacy of the package / material design. 13. The shielding and dose-rate assessment found that the change that had been made was beneficial in terms of radiological safety. This change was a reduction in activity of iridium-192 to be transported from 7.4 TBq to 3.4 TBq when using the tungsten shielding insert. This change increases the regulatory safety margin by reducing package external dose-rates. 14. The shielding and dose-rate assessment recommended that an extension to the existing CoA [1] should be granted. 15. The safety case requirements assessment conducted by ONR [10] found that: no significant changes or developments had occurred since the granting of the existing CoA [1] that could undermine, or call into question the continuing validity of the existing approved application [5] [6], or the use of the package / material design; package operational experience (including regulatory intelligence / incidents) relating to the package / material design and duty-holders did not give rise to any concerns or unresolved issues (this included design, manufacture, maintenance, use, carriage, in-transit storage, receipt by consignee); the previous ONR assessment did not place any limitation on the continuing adequacy of the package / material design. 16. The safety case requirements assessment recommended that an extension to the existing CoA [1] should be granted. 17. No criticality assessment was required due to the non-fissile nature of the contents, e.g. specification of allowable contents will be the same as in the existing CoA [1]. 4 MATTERS ARISING FROM ONR'S WORK 18. The engineering assessment recommended that an extension of six months to the existing CoA [1] should be granted. This is to provide the applicant time to apply engineering changes; should they be necessary as part of ONR s assessment of the renewal application. Office for Nuclear Regulation Page 6 of 10

7 5 CONCLUSIONS 19. This report presents the findings of ONR s assessment for an extension to the existing CoA [1] for the transport of QSA Global Inc. radioactive material transport package GB/3764B/B. 20. Assessments in the areas of radiological protection, mechanical engineering and safety case requirements have all concluded that no major changes had been applied to the package / material design that would undermine the existing approved application [5] [6] and that the previous assessments did not place any limitation on the package / material design. 21. To conclude, I am satisfied that the GB/3746B meets the regulatory requirements for a Type B(U) radioactive material transport package, as implemented in UK law [11], [12], [13], to transport a combination of special form sources up to a maximum of 7.4 TBq of iridium-192 and 12 TBq of selenium-125 by all modes of transport i.e. road, rail, sea and air, with the limit such that the sum of the proportionate amounts of each radionuclide present with respect to the quantities above does not equal one. 6 RECOMMENDATIONS 22. It is recommended that ONR grant a six-month extension to the existing CoA and issues CoA GB/3746B/B(U)-96 Issue 4 with expiry date 31 August 2018 [14]. Office for Nuclear Regulation Page 7 of 10

8 7 REFERENCES 1. GB/3746B (SVC ) - Document - High Technology Sources Limited - Design Approval Certificate GB3746B-B(U)-96- Issue 3 - Signed Final 22 January TRIM Ref: 2012/ ONR HOW2 Guide - Purpose and Scope of Permissioning - NS-PER-GD-014 Revision 4. July GB/3746 (SVC ) - GB/3746B renewal - Application part 1 of 2 - QSA Global Incorporated - 17 October 2017 TRIM Ref: 2017/ GB/3746 (SVC ) - GB/3746B renewal - Application part 2 of 2 - QSA Global incorporated - 17 October TRIM Ref: 2017/ GB/3746B (SVC ) - - Commissioning note for Renewal - High Technology Sources Limited Part 1-11 April 2012 [Superseded by 2012/431674]. TRIM Ref: 2012/ / GB/3746B (SVC ) - - Commissioning note for Renewal - High Technology Sources Limited - Part 2-11 April 2012 [Superseded by 2012/431674]. TRIM Ref: 2012/ GB/3746 (SVC ) - GB/3746B renewal - - QSA Global Inc - Design Review Report (DDR). TRIM Ref: 2018/ GB/3746 (SVC ) - GB/3746B Extension - QSA Global Inc - Mechanical Engineering Assessment Note. TRIM Ref: 2018/ GB/3746 (SVC ) - GB/3746B Extension - QSA Global Inc - Shielding and Dose-Rate Assessment Note. TRIM Ref: 2018/ GB/3746 (SVC ) - GB/3746B Extension - QSA Global Inc - Safety Case Requirements (SCR) Assessment Note. TRIM Ref: 2018/ The Carriage of Dangerous Goods and Use of Transportable Pressure Equipment Regulations (CDG) (SI 2009 No. 1348). 12. IAEA Safety Standards for Protecting People and the Environment, Specific Safety Requirements No. SSR-6, Regulations for the Safe Transport of Radioactive Material, 2012 Edition IAEA Safety Standards for Protecting People and the Environment, Specific Safety Guide No. SSG-26 Advisory Material for the IAEA Regulations for the Safe Transport of Radioactive Material 2012 Edition GB/3746 (SVC ) - GB/3746B Extension - QSA Global Inc - CoA. TRIM Ref: 2018/ Office for Nuclear Regulation Page 8 of 10

9 Report ONR-TD-PAR Figure 1 - Photo showing GB/3746B transport package Office for Nuclear Regulation Page 9 of 10

10 Figure 2 - Illustration showing x-section of GB/3746B transport package The diameter of the GB/3746B package is 325 mm. The height of the GB/3605B package is 405 mm. Office for Nuclear Regulation Page 10 of 10