ML19340B747
| ML19340B747 | |
| Person / Time | |
|---|---|
| Site: | 07106400 |
| Issue date: | 10/17/1980 |
| From: | Austin M BABCOCK & WILCOX CO. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 17671, NUDOCS 8011120053 | |
| Download: ML19340B747 (3) | |
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Mr. C. E. MacDonald, Chief S.
9 Dhcqti.O Transportation Certification Branch MC
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U.S. Nuclear Regulatory Commission g 7,k goo P 1
Washington, D.C. 20555 C
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Dear Mr. MacDonald:
ct Pennsylvania Operations of the Babcock & Wilcox, Nuclear M$terrMs-and ~'
Manufacturing Division respectfully requests:
N C.1. 5 (1) A specific authorization for the limited _ use (as described herein) of our company-owned Model 6400 (" Super Tiger")
shipping package; and concurrently, (2) an exemption from the requirements of 10 CFR 71.32(b) and Condition No. 3 of Appendix A of 10 CFR 71, as they specifically apply to the limited use of this same company-owned package.
We request authorization for limited use of our Model 6400 shipping package under the following conditions and constraints:
1.
The package shall be used for the shipment of waste only from our Parks Township Site Facility to the Rockwell International-Facility in Richland, Washington. The package shall be unloaded at the Rockwell International Facility and returned empty to our Parks Township Site.
2.
Bow (flatness) measurements of the inner cavity walls shall be perfonned prior to each shipment to assure the structural integrity of the package containment is continually monitored and maintained.
If any significant deviations are observed, shipments will cease until corrective actions are taken with the approval of the NRC.
3.
An inspection and non-detructive analysis of the inner and outer cavity welds shall be performed prior to the next use of the package.
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Mr. C. E. MacDonald October 17, 1980 4.
Compliance with the conditions of the latest Revision No. 8 of Certificate of Compliance No. 6400 shall be maintained, with the understanding that our package is constructed in accordance with Babcock & Wilcox Drawing No.11-D-2130
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previously submitted with the August 15, 1980 letter from M. A. Austin to C. E. MacDonald.
5.
With the exception of those requirements requested for exemption in this letter, compliance with all applicable Nuclear Regulatory Commission requirements (Title 10 CFR) and Department of Trans-portation requirements (Title 49 CFR) shall be maintained.
In support of our. requested exemption from 10 CFR 71.32(b) requirements, the following information is provided. The basis for the subject external pressure requirement is not certain, however, it may be related to a postulated submersion in water to a depth that will produce 25 psi.
It should be noted that the Model 6400 package has a positive bouyancy force of over 35,000 pounds, and so the possibility of actually sinking it during an immersion test becomes unrealistic. A Mechanics Research Report No. 62378, dated May 4,1970, entitled " Engineering Evaluation of the Super Tiger Overpack Designed for the Shipment of Large Quantities of Hazardous Materials", states:
"It should be noted that in the event of a hypothetical accident in which a 4
truck trailer rig carrying a Super Tiger was plunged into a river or lake, the Super Tiger's bouyancy is sufficiently great that it would support not only its own 45,000 pounds but also the entire weight of the rig, with 4 ton of capacity to spare."
In support of our requested exemption from Condition No. 3 of Appendix A of 10 CFR 71, the following information is provided. The basis for this subject pressure requirement is not certain, however, it may be related to a postulated air shipment during which a package may be subjected to such changes in atmospheric pressure differential. ~ We emphasize that the Model 6400 package shall only be transported via highway vehicle.
Concern over this requirement as it pertains to the Model 6400 may be related to the_ concern over the circumstances surrounding the reported failure in 1974'of a Super Tiger traveling cross country from Idahr Falls to Pittsburgh.
During this subject incident, the Super Tiger had been loaded and sealed at Idaho Falls where the standard atmospheric pressure is 12.37 psi, and unloaded in Pittsburgh where the standard atmospheric pressure is 14.17 psi. Consequently, during most of the trip the inner cavity was under a.significantly lower pressure than atmospheric, thus contributing to conditions causing partial collapse of the inner cavity wall. We ntend to use our Model 6400 in a very limited manner as described above, using a route in which the standard atmospheric pressure will vary as shown below:
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Mr. C. E. MacDonald October 17, 1980
- Inches, Pressure, Elevation Hg psi (Star')
Parks Township, PA 790 29.10 14.29 Cleveland, Ohio 600 29.30 14.38 South Bend, Indiana 726 29.18 14.33 Lacrosse, Wisconsin 651 29.25 14.36 Sioux Falls, South Dakota 1420 28.40 13.94 Buffalo, Wyoming 4635 25.30 12.42 Billings, Montana 3117 26.75 13.13 Butte, Montana 5767 24.10 11.83 Spokane, Washington 1910 27.90 13.70 (Finish) Richland, Washington 660 29.24 14.36 Thus, when the Model 6400 package is loaded at Parks Township where the standard atmospheric pressure is 14.29 psi in the inner cavity and travels to Richland, Washington, the external pressure is calculated to never exceed the internal pressure by more than 0.09 psi, which occurs at Cleveland, ohio.
Relative to the above mentioned 1974 incident, it should be noted that a documented investigation revealed that the package failure was primarily due to an improperly prepared foam mixture and improper foaming procedures.
- Also, it is of interest that this package failure apparent 1/ occurred only once and was primarily related to the previously mentioned improper foaming practices.
The following additional information is provided for your consideration, as it pertains to our Model 6400 package and supports this present request. Our Model 6400 package has been used exclusively by Babcock & Wilcox and has not been subjected to the abusively heavy loads which have apparently caused problems with other similar Super Tiger packages.
Further, the safety of this requested limited use of our Model 6400 package is demonstrated by the fact that the package has been used for this very purpose over this cross country route for some thirty round trips since 1976.
In conclusion, we feel that our proposed limited use of our Model 6400 package will not endanger life or property of the general public, and we, therefore, respectfully ask your approval of this request.
If you have any questions regarding the information in this submittal, please contact me.
Sincerely, 9
Michael A. Austin Manager, Technical Control MAA/mhb MD
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