ML18243A497
| ML18243A497 | |
| Person / Time | |
|---|---|
| Site: | 07106613 |
| Issue date: | 08/31/2018 |
| From: | John Mckirgan Spent Fuel Licensing Branch |
| To: | Podolak L QSA Global |
| White B | |
| Shared Package | |
| ML18243A495 | List: |
| References | |
| EPID L-2018-LLA-0211 | |
| Download: ML18243A497 (5) | |
Text
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION August 31, 2018 Ms. Lori Podolak Senior Regulatory Affairs Specialist Regulatory Affairs Department QSA Global, Inc.
40 North Avenue Burlington, MA 01803
SUBJECT:
REVISION NO. 20 OF CERTIFICATE OF COMPLIANCE NO. 6613 FOR THE MODEL NO. 702 TRANSPORTATION PACKAGE
Dear Ms. Podolak:
As requested in your application dated August 8, 2018, (Agencywide Documents Access and Management System Accession No. ML18226A089), enclosed is Certificate of Compliance No. 6613, Revision No. 20, for the Model No. 702 transportation package. Changes to the enclosed certificate are indicated by vertical lines in the margin. The staffs safety evaluation report is also enclosed.
The approval constitutes authority to use the package for shipment of radioactive material and for the package to be shipped in accordance with the provisions of Title 49 of the Code of Federal Regulations (CFR) 173.471 Requirements for U.S. Nuclear Regulatory Commission Approved Packages, and 10 CFR 71.17, General license: NRC-approved package.
Upon removal of Enclosure 3, this document is uncontrolled.
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION L. Podolak If you have any questions regarding this certificate, please contact me or Bernard White of my staff at (301) 415-6577.
Sincerely,
/RA/
John McKirgan, Chief Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Docket No. 71-6613 EPID No. L-2018-LLA-0211
Enclosures:
- 1. Certificate of Compliance No. 6613 Revision No. 20
- 2. Safety Evaluation Report
- 3. List of Registered Users cc w/encls. 1 & 2: R. Boyle, U.S. Department of Transportation J. Shuler, U.S. Department of Energy, c/o L. F. Gelder Registered Users OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION L. Podolak
SUBJECT:
REVISION NO. 20 OF CERTIFICATE OF COMPLIANCE NO. 6613 FOR THE MODEL NO. 702 TRANSPORTATION PACKAGE, DOCUMENT DATE: August 31, 2018 DISTRIBUTION:
DSFM r/f NMSS r/f DMarcano ARivera-Varona MLayton RPowells, RI EMichel, RII MKunowski, RIII RKeller, RIV G:\SFST\PART 71 CASEWORK\Model 702 Docket 71-6613\6613.R20.docx; G:\SFST\PART 71 CASEWORK\Model 702 Docket 71-6613\6613.R20.Letter&SER.docx Closes EPID No. L-2018-LLA-0211 ADAMS PKG: ML18243A495 Ltr & SER: ML18243A497 Encl. 1: ML18243A496
- via e-mail OFC DSFM *DSFM *DSFM *DSFM DSFM NAME BWhite WWheatley RTorres MRahimi JMcKirgan DATE 8/29/2018 8/29/2018 8/29/2018 8/ 31/2018 8/31/2018 OFFICIAL RECORD COPY OFFICIAL USE ONLY - SECURITY-RELATED INFORMATION
SAFETY EVALUATION REPORT Docket No. 71-6613 Model No. 702 Package Certificate of Compliance No. 6613 Revision No. 20 EVALUATION By application dated August 8, 2018 (ADAMS Accession No. ML18226A089), QSA Global, Inc.,
(QSA) requested an amendment to Certificate of Compliance (CoC) No. 6613 for the Model No.
702 package. QSA proposed drawing changes to remove the American Society of Mechanical Engineers (ASME) B18 standards and three other minor clarifying changes to the drawings.
The staff reviewed the application for the Model 702 Type B package. The application identified a discrepancy in the material certification requirements for hardware detailed in Drawing No.
R70290, Revision X. The requirement stated that all hardware should meet ASME B18 standards. However, the applicant clarified that ASTM certification requirements provide the necessary performance criteria control for the hardware to meet the requirements in Title 10 of the Code of Federal Regulations (10 CFR) CFR Part 71. Therefore, the need for conformance with ASME B18 standards is not needed for safe performance of the package. The applicant also discussed the root cause for the discrepancy and defined corrective actions, including the revision of Drawing No. R70290, Revision X.
The applicant clarified that Drawing No. R70290, Revision X also required not-important-to-safety hardware (washers, eyebolt) to conform to ASME B18 standards. The applicant clarified that this requirement is not necessary as general material requirements are identified, as needed, in the bill of material descriptions.
The staff reviewed the justification provided by the applicant, as summarized above. Further, the staff reviewed the revised Drawing No. R70290, Revision Y to confirm that the removal of the requirement for conformance with ASME B18 standards was consistent with the applicants justification. The staff confirmed that other changes made to Drawing No. R70290, Revision Y, did not result in changes to the package design and were merely for clarification purpose.
The staff finds that (1) the removal of the requirement for conformance with ASME B18 is adequately justified, and that (2) Drawing No. R70290, Revision Y, properly identifies ASTM materials certification requirements for important-to-safety hardware. The staff, therefore, finds that Drawing No. R70290, Revision Y, complies with 10 CFR 71.33(a)(5).
Based on the statements and representations in the application, the staff concludes that the changes do not affect the ability of the package to meet the requirements of 10 CFR Part 71.
Enclosure 2
CONDITIONS The conditions specified in the certificate of compliance have been revised to incorporate several changes as indicated below:
Condition 5(a)(3) updates Drawing No. R70290 to Revision Y.
Condition 8 was added to authorize use of Revision No. 19 of the certificate for a period of 1 year.
Conditions No. 8 and 9 were renumbered.
The References section has been updated to include this amendment request as a supplement.
CONCLUSION Based on the statements and representations in the application, as supplemented, and the conditions listed above, the staff concludes that the changes do not affect the ability of the package to meet the requirements of 10 CFR Part 71.
Issued with Certificate of Compliance No. 6613, Revision No. 20.