ML19276F531
| ML19276F531 | |
| Person / Time | |
|---|---|
| Site: | 07106400 |
| Issue date: | 03/12/1979 |
| From: | Austin M BABCOCK & WILCOX CO. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7903300578 | |
| Download: ML19276F531 (3) | |
Text
. A 7/4m
.,. # t.
a r#, v-(NRC PUsuC C,,
,..- ; p,
~
9 Babcock &Wilcox
.s 2 n o e n.te,,m o. cn 1
6o9 N *t9 Warren Avenue, Apcho. Pa.15613 IG-Te'e;here: (412) 842-o111
\\
.n'
\\ ~
March 12,1979 Mr. Charles E. Mcdonald, Chief Transportation Branch Division of Fuel Cycle and Material Safety U.S. Nuclear Regulatory Commission Washington, D.C. 20555
References:
1.
B&W Letter dated 27 Dec 78, Austin to Mcdonald 2.
NRC Letter dated 18 Jan 79, Cabell to Austin 3.
B&W Letter dated 1 Feb 79, Austin to Cabell 4.
NRC Letter dater 26 Feb 79,ficDonald to Austin
Dear Mr. Mcdonald:
In response to your letter (reference 4 above), we have reviewed the Statement of Consideration (39 FR 20960) concerning 10 CFR 71.42 -
special requirements for glutonium shipments after June 17, 1978 -
and have the following comments:
As our plutonium wastes with twenty (20) curies or more ner drum are in the form of solid non-pyrophoric contamination on or mixed with otherwise nonradioactive material, we cannot provide absolute assurance that they are in a non-respirable form and therefore we acknowledge the apolicability of the provision that "the inner container (in this case a 17H 55-gallon drum) will maintain its integrity in the packaging (the Supertiger) after the package is subjected to the normal and accident test conditions,...." The test results reported in the second reference on the Certificate of Compliance (Mechanics Research, Inc. Report C2378) to which you referred us state on page 63 "In contrast, two of the drums were standard 16 gage 17H with removable covers.
These experienced little or no deformation as evidenced in photo 45a.
It is felt that had thicker walled drums been used exclusively, no liquid would have been lost <
Also the presence of a plastic drum liner would have provided added assurance." From this recort, it is clear to us that the failure of the inferior used 22 gage oil drums without liners has no bearing on the integrity of the packaging that we use.
Since we have used and will continue to use the standard 13/16 gage i7H 55-gallon drums with plastic liners, we conclude that our 55-gallon drum inner container will maintain its integrity when the Supertiger is subjected to the accident test conditions (the 30 foot free fall).
?
-'?
.f, f ;. q :. ; j i.
79023005~18
_>.. j_. i.. :
"?
The Dabccck & Wdcox Co r:r, Estabbshed 1867
Babcock & Wilcox Mr. Charles E. Mcdonald March 12,1979 For your information, the liners we use are a minimum of.012 inches thick and are sealed with tape or bungs prior to securing the covers on the 17H drums.
The 55-gallon (17H) drums are purchased to conform to the requirements of the Department of Transportation, Title 49, CFR 178.118 - Specification 17H.
B&W performs quality assurance overchecks to assure compliance with this specification.
The above information is provided as requested in your letter to enable review of our application (reference 1 above) to demonstrate that the drum inner containers which we use will maintain their integrity following the accident test conditions of transport.
In the text of the Statement of Consideration (39 FR 20960) it was stated that "The Commission believes that the increases in the amount of plutonium to be shipped and the changing characteristics of plutonium will not change significantly in the next four years when compared to years beyond 1978." The quantity and characteristics of the plutonium in transit have not in fact changed in the past five years (since 1974).
Additionally, it can be reasonably anticipated that neither the quantities nor the characteristics of plutonium to be shipped in the foreseeable future are likely to change.
Consequently, just as there was no perceived problem with ongoing plutonium shipments in the four year period from 1974 to 1978, there should be no special concern about our present and planned plutonium waste shipments which are no different from those of the 1974 through 1978 time frame.
In conclusion, for the reasons elaborated above, it is requested that either our present Certificate of Compliance No. 6400, Revision 4, issued September 8,1978 be further modified promptly in the manner requested in reference 1 above or our previous Certificate of Compliance No. 6400, Revision 3, dated Acril 13, 1978 be extended through the term of our present SNM-414 license which expires January 31, 1984.
Babcock & kVilcox 1
Mr. Charles E. Mcdonald March 12,1979 If you have any questions we would be pleased to meet with you at your convenience to resolve this matter. Thank you for your con-sideration of this impcrtant request.
Sincerely, O
Michael A. Austin Manager, Technical Control MAA/mhb cc: Mr. R. P. Dipiazza Westinghouse Electric Corporation P.O. Box 355 Pittsburgh, PA 15230
-