ML19274D802
| ML19274D802 | |
| Person / Time | |
|---|---|
| Site: | 07105916 |
| Issue date: | 11/08/1978 |
| From: | Renee Taylor MONSANTO CO. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7902260166 | |
| Download: ML19274D802 (2) | |
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Nonsan::o CNGiteCD>EO PRODUCTS MON 5ANTO RESEARCH CORPORA ;ON g} g Dayton Laboratorv
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r;<". >g J-Mr. Charles E. MacDonald, Chief
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Dear Mr. MacDonald:
Ref: Docket 71 R Monsanto Research Corporation requests that N.R.C. Certificate of Compliance USA /5908/B( )F for the MRC Model 2501 Shipping Container be amended to permit shipping plutonium in quantities greater than 20 curies, i
i We have reviewed our past submittals for licensing of our 2501 shipping container as they relate to the new paragraph 71.42 of 10 CFR.
Our analysis shows that if a source capsule meets "special form criteria" and is at least double-encapsulated then the combination of this capsule and the container will meet all the requirements of paragraph 71.42.
In fact, the degree of protection provided is far in excess of that required of paragraph 71.42.
As an example, we estimate the capsule will see a temperature of about 100 F if the container is subjected to the accident fire test while our source capsules are analyzed and/or tested to verify survival in a 1475 F environment for 10 minutes (p 27 of Model 2501 submittal, supplement c).
In reviewing all the other equirements of Appendices A and B of Part 71 in relationship to the analys of our 2501 container we find a similar high degree of conserv-atism in our use of the container if we ship plutonium as "special form".
We propose that under the exemption allowed in subparagraph (b)(3) of paragraph 71.42 we be permitted to ship plutonium in our 2501 container as long as the radioisotope is at least doubly encapsulated in a container that has been shown to meet special form criteria per 10 CFR 71.4(o).
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Mr. Charles E. MacDonald 8 flovember 1978 I
We further propose that the leak test performed on the completed as-shipped capsule configuration be able to detect a leak rate of 1 x 10-s standard cc/sec or lower.
In summary, stipulating "special form" automatically requires that the capsules be of a very special construction and made of metals in order to pass the various tests.
It also requires that the capsule singuarly meet rigorous tests that are more severe than the capsule will see if housed in a shipping container.
Additionally, Monsanto Research Corporation presently ships nearly all soruces as special form material. This means that most sources are tested or analyzed to show that they meet special form criteria. Thus, tying the shipping require-ments to "special form" will be cost effective in that additional tests will not be required.
We believe that this exemption is entirely consistent with the intent of Paragraph 71.42 as evidenced by the exemption allowed for reactor fuel elements (subparagraph (b)(1)) which are generally only single-encapsulated.
If you wish any additional information we will be happy to discuss further our request. We would appreciate your handling this matter as quickly as possible due to future scheduled shipments of plutonium sources.
Sincerely,
- GIXERED PRODUCTS DEPARTMENT Robert R. Ta !ar Manager j
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