ML18179A210
| ML18179A210 | |
| Person / Time | |
|---|---|
| Site: | 07109196 |
| Issue date: | 06/15/2018 |
| From: | Mccann J Columbiana Hi Tech |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML18179A207 | List: |
| References | |
| CoC No. 9196 | |
| Download: ML18179A210 (4) | |
Text
I Date: June 15, 2018 Attn: Document Control Desk Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 I
Subject:
Application for Renewal of Certificate of Compliance No. 9196 for the Model No.
UX-30 Transportation Packaging, Docket No. 71-9196
References:
(1) NRC Certificate of Compliance for the Model No. UX-30, USA/9196/B(U)F-96, Rev 29 (2) Safety Analysis Report for the Model UX-30 Package, Revision 3, September 2014 (3) U.S. Department of Transportation Competent Authority Certification USA/9196/B(U)F-96, Rev. 32.
( 4) Canadian Nuclear Safety Commission Endorsement CDN/E 150/-96, Rev 23 In accordance with 10 CFR 71.31 and 71.38, Columbiana Hi Tech, LLC (CHT) herewith submits an application to revise and renew the Certificate of Compliance (CoC) for the UX-30 packaging. The current CoC, Revision 29 [1], references the following supplements:
Columbiana Hi Tech supplements dated: January 6, 2015.
A consolidated application for renewal of the existing Certificate of Compliance is submitted that incorporates all changes to the Safety Analysis Report (SAR) [2], as incorporated by reference in the existing certificate, into the Revision 4 of SAR. All data and information from above listed supplement(s) were incorporated into the SAR Revision 3 at the time it was submitted. Page changes for Revision 4 of the SAR are summarized in Enclosure 1.
These page changes include minor editorial changes and the marking of Chapter ?-Operating Procedures and Chapter 8-Acceptance Tests and Maintenance as "proprietary" to indicate this information is to be withheld from public disclosure.
Chapter 7 and Chapter 8 of the SAR provide information for the use and maintenance of the UX-30 that is required to be maintained by authorized users of the UX-30.
The U.S.
Department of Transportation (DOT) endorses the NRC approval of UX-30 package design by issuing a Competent Authority Certification (CAC) [3] that is validated in other countries.
Validations are issued in other countries as required by Safe Transport of Radioactive Material Enclosures transmitted herewith contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.
1621 Old Greensboro Road - Kernersville, NC 27284 336-497-3600
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(SSR-6), Validation of Certificates, para. 840. CHT and others expend significant effort and money to maintain the regulatory approval of the UX-30 that allows for use of package in international commerce. Classifying the drawings, and other information relating to the use and maintenance of the UX-30 as "proprietary" allows CHT to protect the privileged commercial information that is required for use of the UX-30 for shipments within the U.S. and other countries. An affidavit pursuant to 10 CFR 2.390 that seeks proprietary treatment of the drawings, Chapter 7, and Chapter 8 is enclosed for consideration.
Additionally, CHT requests the package review include consideration of NUREG-1886, "Joint Canada - United States Guide for Approval of Type B(U) and Fissile Material Transportation Packages." The current Canadian endorsement for the UX-30 is CDN/E2150/-96, Rev 23 [4].
CHT has a quality assurance program, approved by the Commission, which satisfies the provisions of subpart H (Quality Assurance) of Part 71. Furthermore, CHT complies with the terms and conditions of the applicable requirements of subparts A (General Provisions), G (Operating Controls and Procedures), and H (Quality Assurance) of Part 71.
The application documents are prepared in accordance with the Guidance for Electronic Submissions to the NRG, and the application is submitted via the EIE process.
Columbiana Hi Tech requests that the NRC issue Revision No. 30 of the UX-30 CoC on or before October 31, 2018, to allow sufficient time for approval by validation in other countries prior to expiration of the current CoC, Revsion No. 29. In addition [1], CHT requests that the NRC issue CoC Revision No. 30 with a condition to allow continued use Revision 29 [1] of the CoC until the expiration on December 31, 2019. This allows for continued use of the UX-30 for international shipments under the current Revision No. 32 of the U.S. DOT Competent Authority Certification (CAC) [3] that references NRC CoC, Revision No. 29 [1] while validations of the CAC in other countries are obtained.
Should the NRC staff require additional information to support review of this application, please do not hesitate to contact Mr. Peter Vescovi at 336-420-8325.
Jim cCann President and COO Columbiana Hi Tech, LLC 1621 Old Greensboro Road Kernersville, NC 27284 (336) 497-3601 cc:
Jim Mccann, President and COO, Columbiana Hi Tech, LLC Chris White, Director of Sales, Columbiana Hi Tech, LLC 1621 Old Greensboro Road - Kernersville, NC 27284 336-497-3600
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Robert Glazier, VP EHS and QA, Columbiana Hi Tech, LLC Bernard White, Senior Project Manager, U.S. Nuclear Regulatory Commission Pierre Saverot, Senior Project Manager, U.S. Nuclear Regulatory Commission Glenn Mathues, Licensing Engineer, TN Americas LLC Enclosure( s)
001 NRC UX-30 Renewal Application Transmittal Letter.pdf 002 CHT Affidavit for Request to Withhold lnformation.pdf 003 UX-30 SAR Rev 4.pdf 004 UX-30 SAR-Appendix 1.4.1-Engineering Drawings(Proprietary).pdf 005 UX-30 SAR Chapter? and Chapter 8(Proprietary).pdf 1621 Old Greensboro Road - Kernersville, NC 27284 300 KB 120 KB 28,705 KB 1244 KB 1897 KB 336-497-3600
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ENCLOSURE 1 The following list summarizes the changes to the Safety Analysis Report for Revision 30 to Certificate of Compliance No. 9196 for the Model No. UX-30 Transportation Packaging, Docket No. 71-9196 Affected Section Change Description Reason Justification or Pages Front matter Update Title Page, Table Revision Editorial Title of Contents, and Record Pages i - iv of Revisions Section 1.4 Appendix Corrected engineering Provide index of Editorial Page 1-12 drawing numbers drawings Chapter 7-0peration Marked "proprietary" and Privileged commercial See Affidavit Pursuant to 10 minor revision.
information.
CFR 2.390.
Chapter 8-Marked "proprietary" Privileged commercial See Affidavit Pursuant to 10 Accpetance Tests and information.
CFR 2.390 Maintenance 1621 Old Greensboro Road - Kernersville, NC 27284 336-497-3600