ML19291C258
| ML19291C258 | |
| Person / Time | |
|---|---|
| Site: | 07109116 |
| Issue date: | 11/01/1979 |
| From: | Hansen L NUCLEAR PACKAGING, INC. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML19291C256 | List: |
| References | |
| 15113, NUDOCS 8001230233 | |
| Download: ML19291C258 (2) | |
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November 1, 1979 Mr. Charles E.
MacDonald, Chief Transportation Branch Division of Materials & Fuel Cycle Facility Licensing United States Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. MacDonald:
As you know, we are a commercial company operating as a small business.
We derive our income by providing engineering, consulting services and hardware to all levels of the nuclear transportation industry.
A major activity involves interfacing with the regulatory agencies in order to secure Certificates of Compliance for a wide range of users.
These currently include most of the major nuclear utilities, waste transporters and a large number of DOE laboratories.
In order to provide the required services, it is necessary that we fully understand the current regulations, which brings me to the purpose of this letter.
We need clarification on the question of impact during cold tempera-tures.
Numerous Safety Analysis Reports on LSA and Type "B" Packages submitted in the last nine (9) months have been questioned on this point.
In each case we have been asked to evaluate the package for impact conditions at -400F.
In reviewing 10CFR71, we find that the only reference to a " Cold" condition is given in Appendix A.
This section requires that "Each of the follo'..ing Nor:aal Conditions of Transport is to be applied separately to determine its affect on the package".
Therefore, SAR's have been submitted with separate evaluations for " Cold" and " Free Drop".
Our customers have asked that we request the specific reference in the regulations that require packages to be evaluated for combined Cold (-400F) and Drop Conditions.
The implementation of a combined requirement is having an extreme impact on the industry.
Questions related to material suitability for this condition are unanswerable unless some type of acceptance criteria is establisned.
If a naterial acceptance criteria such as that which is provided in the ASME Ccde fcr R2 actor Vessels is imposea, carbon steel vill no longer 'c2 q-acccptable fabrication material.
Replacing carbon steel with stainless s:2el, which does meet the code requirements, increases th cost of faoriention by over a factor of three.
Redesign, rell:ensing and fabrication of renlacement casks for industry will cost T.illion of dolla}-
r,i }hb years ia lost time.
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NRC N o v e.T.b e r 1, 1979 Therefore, on behalf of ourselves, the utilities and the waste transporters, we respectfully request clarification of this matter.
If the requirement exists in the regulations, then some type of acceptance criteria for evaluating interials must he provided.
b'e would like to thank you for the cooperation we have received in the past.
Should you wish to meet and discuss the matter in more detail, please feel free to call.
Thank you again.
Sincerely yours, NUCLE ACF GI 'G, INC.
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