ML20148G942
| ML20148G942 | |
| Person / Time | |
|---|---|
| Site: | 07109098 |
| Issue date: | 10/11/1978 |
| From: | Voth M UNION CARBIDE CORP. |
| To: | Casey Smith NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7811130306 | |
| Download: ML20148G942 (4) | |
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- UNION CARBIDE CORPORATION
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MEDICAL PRODUCTS DIVISION Pi'EtVED P.O. DOX 124. TUXEDO. NEW YORK 10957 O'E l'/
M i 21 TELEPHONE: 914 351 2131 U.S. F
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october MfST9.781hf10M INRC puutJC DOCUMUM -
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h Np Dr. Clifford V.
Smith, Jr.
J El Director, Office of Nuclear Material h5 ' 4 I C Jl Safety and Safeguards U. S. Nuclear Regulatory Commission k1 O
sf Washington, D. C.
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Dear Mr.. Smith:
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Pursuant to 10 CFR Part 71 we wish to amend our Certificate y'
of~ Compliance-Numberu.909L&: for the_Model. UCC 20WC-2 shipping r
container.
Specifically, we request that the " Maximum quantity of material per package" in line 5 (b) (2) of our Certificate dated September 28, 1977 be increased from 600 Curies to 1000 Curies.
This application is prepared in accordance with Regulatory Guide 7.5 and ANSI Standard N14.
10.2-1973.
We believe that the public interest would be served by the issuance of this revised limit.
The UCC-20WC-2 shipping container is used to deliver medical diagnostic radionuclides, Mo-99/Tc-99.
Generally speaking, transportation and handling costs are added to the cost of the product.
By minimizing l
the transportation and handling costs thru larger shipments i
per container, a substantial savings can be passed on the geneeal public.. Another concern of the general public is to optimize the use of our transportation systems and thereby conserve our nation's resources.
The 435 pound UCC-20WC-2 contains a plastic bottle of medical' product solution weigh-ing less than'one pound.
The increased limit would eliminate a substantial amount of freightage.
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. Curtificate of Complaince #909 8
.Amendent 3.
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Radiation-Induced Embrittlement - The Mo-99/Tc-99 is shipped in a 0.2N solution NaOH.
A 1000 ourie shipment consists of about 180 ml which is placed in a plastic bottle.
The bottle is then sealed in a gasketed, leak-tight metal container which is placed in a steel-clad depleted uranium cask with a bolted cover.
The cask is then placed in a steel barrel-like outer container which has a wood filler between the cask and the outer b.
container.. Even though multiple-barriers exist, con-cern was given to the integrity of the inner sample bottle which is the component most subject to radiation-induced embrittlement.
A prototype test showed that the most sensitive part of the bottle may receive up to four megarads if 1000 Curies of Mo-99 were allowed to decay for an infinite period of time.
Tests were performed in which two bottles were irradiated to three megarads and two others to seven megarads.
The linear polyethylene bottles showed no effects in either The polypropylene caps were yellowed but plyable case.
after three megarads.
After seven megarads the caps were somewhat hardened but leak tests showed no loss of h~
integrityv These tests are consistent with the litera-ture which states that the materials can tolerate up to 100 megarads which is substantially greater than that involved in the proposed application.
l Radiolytic Decomposition - A substantial volume of free hydrogen and oxygen are generated by the radiolytic decomposition of water in the 0.2 norma 3 NaOH solution.
If. a reducing agent were present the oxygen would be scavenged and the hydrogen buildup would pressurize the container.
Without a reducing agent present the free hydrogen and oxygen would rise to the air space in stoichiometric proportions and recombine with no signi-ficant pressure increase.
The latter has been found to l
be the case; no pressure buildup has been observed in 600 Curie shipments.
If pressure were to increase, it would be observed in shipments containing well below 600 Curies, i
We believe all other pertinent aspects of the shipping container
'l are on file and have been evaluated by the Commission.
This
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safety evaluation 'has reconsidered those aspects ef fected by j
a higher Curie content and found that there is no significant effect.on the. health and safety of the general public.
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['U.S.N.R.C.
' Certificate of Compliance #9098 2.
. Amendment-A specific customer's situation prompts this application.
The short half-life Mo-99/Tc-99 material is carried express by sole use chartered aircraft.
Shipments of 1000 rhther than 600 Curies per package would eliminate one refueling stop and1 improve maneuverability of the aircraft.
These factors are especially significant during the winter months when timely delivery of medical products becomes dependent
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on regional flying conditions.
We do not believeJ that granting the-increased limit would Our provide an unfair economic advantage over another group.
interest'is to safely provide the best product to the public at the most reasonable cost.
The safety evaluation shows that the container contents can be increased without signifi-cantly affecting the health and safety of the general public.
t Any competitor who could show the same overall benefit is expected to request and be granted a similar provision.
The safety evaluation concludes that increasing the contents of the package from 600 to 1000 Curies is acceptable.
Since the structure of the container is not changed from that sub-mitted for the current certificate, structural matters are I
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not; addressed _. The.four; safety concerns addressed are as 4
follows:
External Radiation Level - Data submitted with our August 19, 1977 letter showed data which, if extra-polated to 1000 Curies would predict 100 mR/hr on contact and 10 mR/hr at three feet from the package.
Additional information gathered in the past year substantiates these numbers.
The dose received by personnel handling a single package of large Curie content would be no different than the dose received l
handling numerous packages containing the same total activity in smaller quantities per container.
Heat Buildup _ - The thermal output from a 1000 Curie Mo-99/Tc-99 source was calculated to be four watts.
An experiment was performed in which a four heat source was placed in the UCC-20WC-2 shipping container rather than the plastic bottle of solution.
No credit was taken for the-reduction of heat characteristic of the radio-1 activejdecay.
Over a-period of four days the inside l
air temperature increased to 220C above ambient and j
stabilized.
Such an increase is insignificant relative i
to the' design rating of 1200C for the sample bottles.
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O.S.N.R.C.
'C'ertificate of Compliance #9098
.Amendent 4.
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The modified specifications for the contents of a UCC-20WC-2 container are proposed to be as follows:
Decription of Material - Molybdenum-99/ Technetium-99m in 0.2N Sodium Hydroxide Solution Total Curies - Up to 1000 Curies (each isotope)
Volume-- Up to 200 ml Hazard Classification - Group IV Radionuclides The UCC-20WC-2 shipping container has been used by Union Carbide for several years.
Approximately 1200 shipments have been made by truck and air, of which 200 contained in the range of 400 to 600 Curies.
There have been no significant incidents.
Transport will continue to be made by truck or appropriate aircraft.
As all applicable regulations will be followed, no special controls are appropriate.
We are the petitioner and~will be the shipper of the container I
described in.this. letter of application.
s Union Carbide Corporation P.
O. Box'324 Tuxedo, New York 10987
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(914) 351-2131 We trust that all points have been adequately addressed so as to' facilitate your decision.
We wish to underscore the benefits of approval prior to winter; your efforts to meet this schedule l
will.be greatly appreciated.
Should I be able to be of assistance I
in processing this request, please do not hesitate to call me j
at (914) 351-2131 Extension 345.
Very truly yours, h
1dJ\\*J VL.
Marcus H. Voth Manager Nuclear Operations MHV:js l
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