ML20058J055
| ML20058J055 | |
| Person / Time | |
|---|---|
| Site: | 07003051 |
| Issue date: | 11/19/1990 |
| From: | Mangusi J TRANSNUCLEAR, INC. |
| To: | Datta A NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9011270181 | |
| Download: ML20058J055 (1) | |
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- TRkNSNUCLEAR,INC.
November 19, 1990 Mr Amar Datta Uranium Fuel Section Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety Office of Nuclear Material Safety and Safeguard US Nuclear Regulatory Commission
- Washington, DC. 20555
Dear Mr Datta:
Thank you for your ef forts in clarifying the situations under which a decommissioning funding plan or financial assurance certification may not be required.
This letter is to request an exception f or UF6 heel quantitles (less than 25 pounds of UF6) in model 30B UF6 cylinders to be considered
- as sealed special nuclear material.
While the regulations, as far as we can determine, do not explicity state that a 30B UF6 cylinder containing a residual UF6 heel satisfies the definition of sealed s,ecial nuclear material, we believe that the bare cylinder, whica is considered :. Type A pac'kaging (49CFR173.417), meets the intent from a practical standpoint.
These cylinders are allowed to be shipped bare, without overpack, domestically and internationally.
Certainly the shipping environment has the potential of inflicting greater forces on the cylinder than does storage.
Other packagings listed in 49CFR173.417 authorized for the shipment of fissile material require the inclusion of an internal sealed container to hold the material.
The 30B bare cylinder has no similar requirement for the shipment of heel material.
-We, therefore, believe there is merit in the argument that the 30B UF6 cylinder is n scaled container and that the heel material in the cylinder should be considered scaled special nuclear material.
We remain available to further discuss this subject, if necessary, incerg y,
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ohn M ngusi m
b eneral Mann er-operations 0884D TWO SKYLINE DRIVE
- HAWTHORNE, NEW YORK 10532 2120 y[) 3 TELEPHONE: 914 347 2345
- FAX: 914 347 2346
- TELEX: 6818082 3
I 9011270181 903339
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