ML20199H152

Responds to Requested Info Contained in NRC Bulletin 97-002, Puncture Testing of Shipping Packages Under 10CFR71, Dtd 970923.Puncture Test Was Not Deemed Necessary by W for MCC Shipping Container Per Listed Statement

ML20199H152
Person / Time
Site:	Westinghouse, 07109239
Issue date:	11/17/1997
From:	Goodwin W WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-97-055, CON-NRC-97-55 IEB-97-002, IEB-97-2, NUDOCS 9711260032
Download: ML20199H152 (3)

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LJ Westinghouse Commercial Nuclear g*ga r.oum caronna 2mo Electric Corporation Fuel Division isor ns 2sio NRC-97-055 November 17,1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Gentlemen:

Ref:

1) NRC Bulletin No,97-02

2) NRC Certiricate of Compliance No. 9239

3) NRC License SNM-1107/70-1151 4

4) Extension of Response Period for NRC Bulletin 97-02, Letter from NRC, October 17, 1997

5) Westinghouse Response to NRC Bulletin No. 97-02, November 6,1997 This letter provides the response requested in NRC Bulletin 97-02, " Puncture Testing of Shipping Packages under 10CFR Part 71," dated September 23,1997.

NRC Bulletin 97-02, Puncture Testing of Shipping Packages Under 10 CFR Part 71, of September 23, 1997 requires that Westinghouse Electric Corporation submit a response pursuant to the information requested in items 1 and 2 contained in the bulletin. This response is being submitted in accordance with Reference 4 which extended the response period for the subject bulletin; specifically, an assessment of each certified package against the requirements of 10CFR71.73(c), and a justification for continued use in regards to public health and safety.

A review of the assessment of the puncture test outlined.n 10CFR71.73(c) for the MCC shipping packages at Westinghouse was performed in accordance with NRC bulletin 97-02.

A puncture test was not deemed neessary by Westinghouse for the MCC Shipping Container per the following license application statement:

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Section 2.7; IIYPOTHETICAL ACCIDENT CONDITIONS, Section 2.7.2. Puncture -

c "Due to the localized nature of the puncture impact, the pin puncture will not change the.

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ability of the container to maintain the criticality spacing of the fuel assemblies.

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' addition, due to the redundancy in the containers' design, any single component that could' c

be destroyed by the puncture even,' such as a clampframe or connection, would not change the efectiveness of the:puckage.

Therefore, the puncture event described in 10CFR l

71. 73(2) is not a controlling conditionfor the MCC containers. "

This license. application statement was approved by the NRC in the Safety Evaluation Report-~

for the Model No. MCC-3 Package Certificate of Compliance No. 9239 with the following statement:

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- Section 4. Hypothetical' Accident Conditions (10 CFR 71.73), Puncture "Because of the localized nature of the puncture impact, a puncturefollowing the 30-foot drop test will not change the ability of the package to mairtain the subcriticality spacing of thefuel assemblies. ' Also, even with the damagefrom the 30-foot drop test, any single component (e.g. clampframe or connection) destroyed by the subsequent puncture test will l

. not change the efectiveness of the package because of the redundancy in the package design. "

Based on the above statements, there are no special precautions or operational controls that are

. needed to assure safe use of the package. The MCC shipping containers are analyzed to worst

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case; Hypothetical Accident Conditions (HAC) as described in Section-2.7 of the MCC Shipping Container license application. The criticality safety analysis of the MCC container assumes the worst case HAC with water ingress and egress such that optimum moderation is present.in the container. Since any damage caused by the puncture test will be localized, the criticality spacing of the fuel assemblies within the container will not change. Therefore, there

--are no heakh and safety concerns related to the continued use of the MCC shipping containers.

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Westinghouse continues to support the safe licensing basis for the MCC shipping containers.

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The HAC criticality analysis model used as the licensing basis for the MCC shipping container remains the bounding accident analysis model including the consequences of the puncture test as described in 10 CFR 71.73(c)(3).- The MCC shipping container (and its predecessers) have been licensed for safe operation of shipping fresh, unirradiated PWR fuel assemblies for over 25 years? Westinghouse continues to support the safe operation of the container with bounding

. accident analysis per 10 CFR 71.73.

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-Page 3 November 17,1997

I hereb affirm that the statcments in this response are true and correct to the best of my.

knowledge and belief.

if you should have any questions regarding this matter, please write me at the above address,

.or telephone me et (803) 776-2610, Intension 3282.

Sincerely, WESTINGIlOUSS ELECTRIC CORPORATION Wilbur L. Goodwin Manager Regulatory Affairs

- Director, Spent Fuel Project Office cc:

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