ML18303A300
| ML18303A300 | |
| Person / Time | |
|---|---|
| Site: | 07109226 |
| Issue date: | 10/25/2018 |
| From: | Asmussen K General Atomics |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| SHP-4948, USA/9226/B(U)F-85 | |
| Download: ML18303A300 (5) | |
Text
+ GENERAL ATOMICS VIA OVERNIGHT DELIVERY SERVICE ATTN: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 October 25, 2018 SHP-4948 RE:
Request for Renewal of Certificate of Compliance No. 9226 for the GA-4 Shipping Package; Package Identification No. USA/9226/B(U)F-85 General Atomics (GA) holds a valid Certificate of Compliance (CoC) for its Model GA-4 shipping package. The certificate number is 9226 and the package identification number is USA/9226/B(U)F-85. The current certificate is due to expire on October 31, 2018. GA hereby requests the renewal of the subject CoC for an additional 5 years.
The attachment to this letter provides a section by section analysis of all changes to 10 CFR Part 71 that have occurred since the previous renewal along with a discussion of any potential impacts on the GA-4 package. As detailed in the attachment, the revisions to 10 CFR Part 71 standards since the last renewal in 2013 do not necessitate any additional supporting analysis or documentation, and the GA-4 design, safety analysis and operating procedures continue to meet the requirements of 1 OCFR71.
If you have any questions regarding this request, or need additional information, please do not hesitate to contact me at (858) 455-2823 or Keith.Asmussen@ga.com, or Paul Pater at (858) 455-2758 or Paul.Pater@ga.com. As I will be retiring from GA in January of 2019, please note that Mr. Pater will be GA's point of contact starting mid-January 2019.
Very truly yours, Keith E. Asmussen, Ph.D.
Director Licensing, Safety & Nuclear Compliance
/Jlv'! :5 5 z_ D 3550 GENERAL ATOMICS COURT, SAN DIEGO, CA 92121-1122 PO BOX 85608, SAN DIEGO, CA 92186-5608 (858) 455-3000
Attachment to General Atomics' Letter No. SHP-4948 dated October 25, 2018 Analysis of Changes to 10 CFR Part 71 with Regard to the Renewal of the GA-4 Shipping Package Coe No. 9226 The following table lists the changes to 10 CFR Part 71 that have occurred after 2013 (when CoC No 926 was last renewed) and the corresponding potential impacts of those changes on the renewal of Coe No. 9226.
Revised Section SUBPART A - GENERAL PROVISIONS 7
1.0 Purpose and Scope
71.1 Communications and records.
71.2 Interpretations 71.3 Requirement for license 71.4 Definitions 71.5 Transportation of licensed material 71.6 Information collection requirements: 0MB approval 71.7 Completeness and accuracy of information 71.8 Deliberate misconduct 71.9 Employee protection 71.10 Public Inspection of application 71.11 Protection of Safeguards Information SUBPART B - EXEMPTIONS 71.12 Specific exemptions 71.13 Exemption for low level materials 71.14 Exemption for low level materials Revisions made in 2017 to ensure compatibility with 2012 edition and draft 2018 edition of the IAEA SSR-6 regulations and Potential Impact on Coe Renewal
- No Change since 2013, therefore No Impact.
None. Changes are administrative in nature, and amended section has same applicability as before.
Revised, but No Impact - denoted below as RNI.
RNI None. Definitions have no impact on CoC renewal.
RNI None. Administrative in nature and section has same applicability as before.
RNI RNI RNI RNI None. Protection of safeguards information as required by Part 73 applies RNI RNI RNI
71.15 Exemption from classification RNI as fissile material SUBPART C - GENERAL LICENSES 71.17 General license: NRC-None. Administrative in nature and section has same applicability as approved package before.
71.19 Previously approved package RNI 71.20 General License: DOT None. 71.20 has been deleted from 10CFR71.
specification container 71.21 General license: use of Foreign RNI approved package 71.22 General license: Fissile material RNI 71.23 General license: Plutonium -
RNI beryllium special from material SUBPART D -APPLICATION FOR PACKAGE APPROVAL 71.31 Contents of application RNI 71.33 Package Description RNI 71.35 Package Evaluation RNI 71.37 Quality Assurance RNI 71.38 Renewal of a CoC or quality RNI assurance program approval 71.38 Requirement for additional RNI information SUBPART E-PACKAGE APPROVAL STANDARDS 71.41 Demonstration of compliance RNI 71.43 General Standards for all RNI packages 71.45 Lifting and tie down standards RNI for all packages 71.47 External radiation standards for RNI all packages 71.51 Additional requirements for RNI Type B packages 71.55 General requirements for RNI Fissile material packages 71.59 Standards for arrays of fissile RNI material packages 71.61 Special requirements for Type RNI B packages containing more than 10 A2 71.63 Special requirement for RNI plutonium shipments
71.64 Special requirements for RNI plutonium air shipments 71.65 Additional requirements RNI SUBPART F - PACKAGE, SPECIAL FORM, AND LSA-111 TESTS 71.70 Incorporation by reference New section, but no impact on Coe renewal 71.71 Normal conditions of transport RNI 71.73 Hypothetical accident RNI conditions 71.74 Accident conditions for air RNI transport of plutonium 71.75 Qualification of special form RNI radioactive material 71.77 Qualification of LSA-111 material RNI SUBPART G - OPERATING CONTROLS AND' PROCEDURES 71.81 Applicability of operating RNI controls and procedures 71.83 Assumptions as to unknown RNI properties 71.85 Preliminary determinations RNI 71.87 Routine determinations RNI 71.88 Air transport of plutonium RNI 71.89 Opening Instructions RNI 71.91 Records RNI 71.93 Inspection and tests RNI 71.95 Reports None; Does not affect the package design or performance requirements.
71.97 Advance notification of None. Section is administrative in nature; RNI shipment of irradiated reactor fuel and nuclear waste 71.99 Violations RNI 71.100 Criminal penalties RNI SUBPART H - QUALITY ASSURANCE 71.101 Quality Assurance None; RNI; Administrative in nature and does not affect the package Requirements design or performance requirements 71.103 QualiW Assurance RNI 71.105 Quality Assurance Program RNI 71.107 Package design control RNI 71.109 Procurement design control RNI
71.111 Instructions, procedures and RNI drawings 71.113 Document control RNI 71.115 Control of purchased RNI material, equipment, and services 71.117 Identification of and control RNI of materials, parts, and components 71.119 Control of special processes RNI 71.121 Internal inspection RNI 71.123 Test Control RNI 71.125 Control of measuring and test RNI equipment 71.127 Handling, storage and RNI shipping control 71.131 Nonconforming materials, RNI parts or components 71.133 Corrective action RNI 71.135 Quality assurance records RNI 71.137 Audits RNI Appendix A to Part 71-None. Provides values for A1and A2. Because GA-4 is a Type B package, Determination of A1 and A2 there is no impact.