ML19308C773
| ML19308C773 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 11/27/1979 |
| From: | Dipiazza R WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 14933, NUDOCS 8002010319 | |
| Download: ML19308C773 (2) | |
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Westinghouse Water Reactor km Electric Corporation Divisions
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4 November 27, 1979 i
U.
S. Iluclear Regulatory Commission I
, Gffice of Nuclear Material Safety & Safeguards i
Division of Puol Cyclo & Material Safety l
Washington, D.C.
20535 Attention: L. C. Rouse, Chief Fuel Processing & Fabrication Branch Sub cct:
Exemption from 10CFR70.54 3
SNM-1107, Docket 70-1151 l
1 Gentlemon:
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The Westinghouse Electric Corporation hereby requests an exemption from the "same day" requirements of 10CFR70.54 regarding the preparation and distribution of the Muclear Material Transaction Report (DOE /NRC-741).
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The printed instructions for completing this form state that "Each shipper of reportablo quantitics of special nuclear acterial, source material, or tritium must dispatch Form D(4:/NCC-741 on the same day the material is shipped....."
Although our current practice, which is based on our under-standing of discussions with NRC percrnnel, interprets "the same day" phrase to mean "within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> afher the material is shipped", the production schedule at the Columbia Facility rakes it very difficult and impractical for Westinghouse to l
comply with this requirement in its entirety.
l The Westinghouse Columbia Pacility typically schedules production personnel for work assignments on Saturday, Sunday and Corporate Holid ys, although administrative personnel are generally not scheduled for work assignments on these days.
In order to avoid maintaining an extraordinary amount of employe work clothing and respirntory protection devices, contaminated laundry and respiratory egnptcert are shipoed for cicaning on a daily besi..
As it is i::c,>raetical to schedule the necessary administrcLive i
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employees for work assignment on these days solely for the purpose of preparing and distributing the DOE /NRC-741 form, Woutinghouse requests an exemption from the "same day" require-monts as stated in the instructions.
The exemption shall be limited to shipments of intentional discards including contam-inated laundry, reapiratory protection devices, baled waste and calcium floride which are shipped on Saturday, Sunday or Corporate Holidays.
The DOE /NRC-741 form for these transactions would be prepared and distributed on the 1st scheduled work day for administrative employees following the discard.
The granting of this exemption will not endanger the life or property of the general public or the common defense and security of the United States of America.
A check in the amount of $150.00 for processing this amendment will be transmitted by separate correspondence.
If you have any questions regarding this matter, please write to at the above address or telephone me on 412-373-4652.
Very truly yours, yl t
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