ML20012E361
| ML20012E361 | |
| Person / Time | |
|---|---|
| Site: | 07109222 |
| Issue date: | 04/03/1990 |
| From: | Roy B SCIENTIFIC ECOLOGY GROUP, INC. |
| To: | Macdonald C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20012E362 | List: |
| References | |
| IEIN-83-10, NUDOCS 9004040244 | |
| Download: ML20012E361 (3) | |
Text
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L, SCIENTIFIC ECOLOGY GROUP, INC.
o April 3, 1998 L
Mr. Charles E. MacDonald i
Transportation Branch Division of Safeguards and Transportation, NMSS Nuclear Regulatory Commission Washington, DC 20555 Dear Mr. MacDonald As a follow-up to our recent conversation, included herewith is a i
submi ttal of a revised Safety Analysis Report (SAR) for our Certificate of Compliance No. USA /9222/A cask which describes the inserts.that we have used.
The changes made to' the SAR and the
' drawing are summarized in Attachment 1.
As I mentioned on the telephone, I am. unable to explain why.our August-11,1989,. letter did not make it to your desk.
As the letter indicates, it was drafted to inform you of our actions,
.did not require follow-up on your part, and was accordingly mailed-via the U.S.
Postal Service (hand-delivered by us. to them).
As I believe the enclosed submittal will demonstrate,'the use of the subject inserts as part of the cask contents presents no l
conditions that would reduce margins of safety or present
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conditions not already bounded by the conservative analyses in the approved SAR revision.
Having read and reread IE Information Notice 83-10, we were confident until your call that the
, statements in the Notice that are underlined in Attachment 2 to this letter clearly distinguished our insert concept from those requiring explicit authorization in the Certificate of Compliance.
i I
Our voluntary removal of these inserts (2 exist) from our fleet a
poses a hardship for two of our customers.
Because of the j7I circumstances surrounding this item and the limited scope of this submittal, I
am requesting your expedited review of it and, I'
further, your approval of the followings m
1.
SEG be permitted to reinitiate the use of these inserts effective with informal notice from you that you have received and preliminar11y reviewed this submittal.
9004040244 900403 PDR ADOCK 07109222 C
PDC f4 1
P.O. Box 2530 1560 Bear Creek Rd.
Ook Ridge, Tennessee 37831-2530 (615)481 0229
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Charles E. MacDonald l
April 3,
1990 Page 2 2.
SEG be permitted a period of 90 days after a revised Certificate of Conformance is issued to implement the cask name change included in this submittal.
Enclosed herewith is our application fee check for One Hundred Fifty Do11sts.($150.00).
As usual, the documentation submitted themets&46[ 15 ' proprietaryjwi egelesisCeap A ne Ms166ed j 43jpheiNRC;Ci MR!
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My apologies for the unfortunate delay in our letter t
communication and our apparent misinterpretation of IN 83-10.
As
- always, we are committed to a model Part 71 program and open working relationship with your office.
i Very Truly yours, Bryan Roy Manager Engineering & Technical Resources BR/dg ENG-9002 Attachments
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ATTACHMENT 1 All changes made between Revision 1
and Revision 2
of SEG document STD-R-02-016 are highlighted by revision bars in the l
right margin of each page stamped March 20, 1990.
The changes to the SEG drawing STD-02-077 are limited to the cask name change and allowance for the gaskets to be affixed to either sealing surface.
Each change is highlighted by a cloud on the drawing.
Chances BAR Gection Throughout The cask name has been revised from HN-l 215H to 14-215.
1 1.2.14 A description of the inserts is added.
2.3 The insert material is identified.
Pg. 2-33 Word "under" corrected to " binder".
30 The thermal evaluation text was revised to clarify the calculation assumptions and organization within the
- section, however the calculations and conclusions were agi revised.
A discussion of the effect (negligible) of the insert was l
added.
5.1 A discussion of the insert was added.
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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT WASHINGTON, D. C.
20555 March 11, 1983 IE INFORMATION NOTICE NO. 83-10:
CLARlFICATION OF SEVERAL ASPECTS RELATING 10 USE OF NRC CERTIFIED TRANSPORT PACKAGES
. Addressees:
All NRC-licet. sed reactor facilities and registered users of NRC-Certified transport peckages..
Purpose:
i The NRC's Office of Nuclear Materials Safety and Safeguards (NHS$) has identified a need to clarify certain matters relating to the use of NRC.
Certified packages.
These matters are discussed below.
t
'l Discussion:
Temperary Shielding--Pursuant' to 10 CFR 71.22. an applicant for an NRC Certifi-cate of Compliance for a Radioactive Materials Package must include with his application a " description of the proposed package in sufficient detail to identify the package accurately and to provide a sufficient basis for evaluation of the packaging."
For some packages, it may be desirable to add temporary fh In these cases the hte genrna shielding as an auxiliary component of the packaging.
additional inclusion of such shielding to the pac cage must have been specifically addressed in'the package application and thereby authorized in the Certificate of Compliance.
in addressing such temporary shielding, the applicant must i
demonstrate that the shielding remains effective during the applicable normal and/or accident conditions of transport.
In other words, the use of such temporary additional shielding (such as metal shoring or lead sheets),
gg banded or attached to the package so as to conform to applicable regulatory limits for externaI radiation, would not be authorized unless it is specifically provided for in the Certificate of Compliance issued by NMSS.
The_above require.
l ments would not, of course apply to any temporary shielding which is not attached to the package, whose sole ouroote is to reduce external radiation cose rates below reoulatory requirements (e.g., additionni shielding attached to the sides of the trailer or truck cab).
i
_ Preparation and Assembly--Pursuant to 10 CFR 71.54, a shipper / licensee must determine that a package satisfies the applicable package standards, and in
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addition, determine that among other things, for each shipment:
1.
the packaging has not been significantly damaged; 2.
the closure of the package and any sealing gaskets are present and f ree from defects; and 4 212060377 F
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