ML20202C739
| ML20202C739 | |
| Person / Time | |
|---|---|
| Issue date: | 10/30/1998 |
| From: | Hodges M NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Kane W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20202C722 | List: |
| References | |
| IEB-97-002, IEB-97-2, NUDOCS 9902010167 | |
| Download: ML20202C739 (6) | |
Text
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p aeg\ UNITED STATES g NUCLEAR REGULATORY COMMISSION wasumeTom, o.c. sessnesei
\y October 30, 1998 MEMORANDUM TO: William F. Kane, Director, SFPO FROM: M. Wayne Hodges, Deputy Director .
Technical Review Directorate, SFFD
SUBJECT:
CLOSURE OF BULLETIN 97-02,
- PUNCTURE TESTING OF SHIPPING PACKAGES UNDER 10 CFR PART 71"
Background
in 1997, the NRC became aware that two holders of NRC Certificates of Compliance for transportation packages had performed the puncture test using a bar that was not properly mounted as specified in 10 CFR 71.73(c)(3). Based on these findings, Bulletin 97-02 was issued on September 23,1997, to notify holders of Certificates of Compliance about issues related to conducting the puncture test specified in 10 CFR 71.73 (c)(3).
i The Bulletin also requested holders of NRC Certificates of Compliance to review the puncture test assessment for each of their certified package designs. If the puncture test assessment was based upon physical testing, the certificate holder was requested to 3 determine whether the puncture test had been performed in accordance with 10 CFR
{ 71.73(c)(3).
1
{ Discussion f
i The responses to the bulletin identified some packages that had not been puncture tested
{ exactly as specified in the regulations. In some instances, the puncture pin had not been secured against lateral movement. In another instance, the pin had been made of concrete i ,
instead of steel. For some older package designs, tl e was insufficient documentation to j allow the certificate holder to determine the exact details of how the test was performed.
I in their replies to the Bulletin, the certificate holders submitted justifications for continued use of packages that had not been puncture tested exactly as specified in the regulations.
Because of the problems identified in the Bulletin, some certificate holders retested their packages to demonstrate adequacy. Some certificate holders determined that the pin did not move during the test, and that securing the pin against lateral movement would not have affected the test results. Some certificate holders determined that even though the tests had been conducted with a concrete pin, the results would not have been *-
significantly different with a steel pin. This is because the packages involved were substantially less rigid than the concrete pin, and thus the test package absorbed essentially all the kinetic energy. Finally, some packages had not been subjected to the puncture test because the outer packaging of the designs is sacrificialin nature. Puncture test damage to the sacrificial outer packaging would not significantly affect the ability of the package to meet the performance requirements of 10 CFR Part 71.
9902010167 990127 PDR ORG NOMA PDR
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2-Based on the justifications for continued use provided by the certificate holders, as well as the excellent transportation safety record developed over several years, the staff believes that no further action is needed with respect to previously approved (grand-fathered) packages. Grand fathered packages are those that have not been shown to meet the l current version of 10 CFR Part 71, and are therefore not designated "-85." Under the provisions of 10 CFR 71.13, grand-fathered packages are authorized for use indefinitely.
l However,10 CFR 71.13 includes certain restrictions for grand-fathered packages, namely, l new packagings may not be fabricated after April 1,1999, and only limited types of
! amendments may be made to the Certificates of Compliance. To receive a "-85" designation, a Certificate holder must submit an application that demonstrates that the l package design meets requirements of 10 CFR Part 71.
The staff will review how puncture testing was performed as part its review of applicistions for a "-85" designation. Only packages which have been properly tested or evaluated for the puncture test condition will be designated as "-85".
Attached is a draft letter we propese to send to certificate holders to close Bulletin 97-02.
The letter reminds certificate holders of the provisions of 10 CFR 71.13, and that an application for a "-85" designation should be accompanied by a test or evaluation of the package design under the conditions specified in 10 CFR 71.73.
Prior to sending this letter to certificate holders, we will provide for CRGR review of this l
issue.
We believe this plan to close Bulletin 97-02 is consistent with guidance received during earlier briefings to the Deputy Executive Director for Regulatory Programs.
Closure of Bulletin 97-02 is being tracked as issue SF 3 in the Generic Issues Management and Control System.
Distribution: -
NMSS r/f SFPO r/f BWhite NLOsgood LYang CBrown AGaunt ABarto KRamsey, IMNS
- C' = Copu without ettschment/ enclosure 'E' = Copy with attachment /enclosuro "N" = No copy
- l OFC NMSS/SFPO E NMSS/SFPO NMSS/SFPO i
NAME DTiktinsky CRChappell MWHodges i
DATE 10/29/98 10/29 /98 10/30/98 j OFFICIAL RECORD COPY 1
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- DRAFT LETTER TO CERTIFICATE HOLDERS i
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SUBJECT:
" PUNCTURE TESTING OF SHIPPING PACKAGES UNDER 10 CFR PART 71"
Dear Mr. :
in 1997, the NRC became aware that two holders of NRC Certificates of Compliance for transportation packages had perfor;ned the puncture test using a bar that was not properly
! mounted as specified in 10 CFR 71.73(c)(3). Based on these findings, Bulletin 97-02 was issued on September 23,1997, to notify holders of Certificates of Compliance about issues
- related to conducting the puncture test specified in 10 CFR 71.73 (c)(3).
The Bulletin requested holders of NRC Certificates of Compliance to review the puncture
- test assessment for each of their certified package designs. If the puncture test assessment was based upon physical testing, the certificate holder was requested to l determine whether the puncture test had been performed in accordance with 10 CFR i 71.73(c)(3).
i l The responses to the bulletin identified some packages that had not been puncture tested
] exactly as specified in the regulations. In some instances, the puncture pin had not been secured against lateral movement. In another instance, the pin had been made of concrete
- instead of steel. For some older package designs, there was insufficient documentation to
! allow the certificate holder to determine the exact details of how the test was performed, i
, in their replies to the Bulletin, the certificate holders submitted justifications for continued 3 use of packages that had not been puncture tested exactly as specified in the ragulations. -
j Because of the problems identified in the Bulletin, some certificate holders retested their 4-packages to demonstrate adequacy. Some certificate holders determined that the pin did not move during the test, and that securing the pin against lateral movement would not have effected the test teruits. Some certificate holders determined that even though the tests had been conducted with a concrete pin, the results would not have been significantly different with a steel pin. This is because the packages involved were substantially lass rigid than the concrete pin, and thus the test package absorbed essentially all the kinetic energy. Finally, some packages had not been subjected to the puncture test because the outer packaging of the designs is sacrificialin nature. Puncture test damage to the sacrificial outer packaging would not significantly affect the ability of the package to meet the performance requirements of 10 CFR Part 71.
Based on the justifications for continued use provided by the certificate holders, as well as the 3xcellent transportation safety record developed over several years, the staff believes that no further action is needed with respect to previously approved packages.
ATTACHMENT
- l. .
r i Certificate holders are reminded that previously approved packages that have not been shown to meet the current version of 10 CFR Part 71, and are therefore not designated as
" 85", are authorized for continued use indefinitely. However,10 CFR 71.13 includes certain restrictions on packages which have not been designated as "-85", namely, new packages may not be fabricated after April 1,1999, and only certain types of amendments may be made to the Certificate of Compliance.
i To receive a *-85" designation, a Certificate holdst should submit an application that demonstrates that the package design meets t% iequirements of 10 CFR Part 71. The staff's review of applications for a "-85" designation willinclude en evaluation of how the punct'Jre testing was performed. Only packages which have been properly tested or l evaluated for the puncture test condition will be designated as "-85".
If you have any questions, please contact Mr. David Tiktinsky at (301)-415 8523.
l Sincerely, l
William F. Kane, Director Spent Fuel Project Office l
Office of Nuclear Material Safety and Safeguards l
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' Addressees - Memorandum Dated 10/xx/98.
Addressess of letter from William Kane entified " Puncture Testing of Shipping Packages under 10 CFR Part 71" i-
[
SUBJECT:
MULTIPLE ADDRESSEE LIST !
- ABB Combustion Engineering i@., Inc., A N
- Mr. Ian C. Rickard i
Advanced Medical Systems, Inc., ATTN: Ms. Sherry J. Stein
- Alpha-Omega Services, Inc., ATTN
- Bruce Hedger
- Amersham Corporation, ATTN: Ms. Cathleen Roughan
- . ANEFCO, Inc., ATTN: Mr. John D. Murphy n
Babcock & Wilcox, Co., ATTN: Mr. M.C. Suwala j i Bumley Technology, Inc., ATTN: Mr. John J. Munro, til '
- Carolina Power and Light Company, ATTN
- Mr.R.E.Rogan
- Chem Nuclear Systems, Inc., ATTN
- Mr. David L. Langan i
Croft Associates Limitej, ATTN: Mr. Trevor N. Walker Department of the Navy, Chief of Naval Opers l Department of Energy, ATTN: Mr. W. P. Engel l Department of Energy, EM 76, ATTN: Mr. Michael E. Wangler l l
i Departroent of Energy, DCRWM, ATTN: Mr. Ronald A. Milner '
(
Department of Air Force, ATTN: AFTAC Radiation Safety Ofc.
Department of Agriculture, ATTN: Mr. John T. Jensen l i Environmental Technologies. Inc., ATTN: Mr. Roger L. Shingleton '
i FBF, Inc., ATTN: Mr. H. Stringfield
!' Frematome Cogema Fuels, ATTN: Ms. Gayle F. Elliott j
l-General Atomics, ATTN: Mr. Keith E. Aaraussen General Electric Company, ATTN: Mr. Chuck W. Bassett '
' General Electric Co., Nuclear Energy, ATTN: Mr. Charles M. Vaughan j
! Holtec international, ATTN: Mr. Mark Soler !
Industrial Nuclear Company, ATTN: E. W. Huddleston
- J. L. Shepherd & Associates, ATTN: Mr. J. L. Shepherd .
Mescalero Environmental, Inc., ATTN: Mr. Fred Peso Molten Metal Technology, Inc., ATTN: Mr. Robert Hogg l NAC international , Inc., ATTN: Mr. Tom C. Thompson Neutron Products, Inc., ATTN: Mr. Frank Schwoerer l Nordion international, Inc., ATTN: Mr. P. A. Gray Northern States Power Co., ATTN: Mr. Marvin Engen Nuclear Fuel Services, Inc., ATTN: Dr. T. S. Beer
- Nuclear Containers, Inc., ATTN: Mr. William M. Arnold Packaging Technology, Inc., ATTN: Mr. Richard T. Heelsig Portland GE Co., Trojan Plant, ATTN: Mr. Stephen M. Quennoz '
Public Service Company of Colorado, ATTN: Mr. Frederick J. Borst Scientific Ecology Group, Inc., ATTN:~ Mr. J. F.' McCarter Siemens Power Corporation, ATTN: Mr. James B. Edgar Sierra Nuclear Corporation, ATTN: Mr. George N. Dixon, Jr.
. Source Production & Equipment Co., Inc., ATTN: Mr. R. Dicharry Tennessee Valley Authority, ATTN: Mr. Raul R. Baron
t n
s Transnuclear,Inc., ATTN: Mr. Michael Mason U.S. Department of Commerce, ATTN: Dr. T. S. Baer U.S. Department of Transportation, ATTN: Mr. James K. O'Steen United States Enrichment Corporation, ATTN: Ms. Beth Darrough Vectra Technologies, Inc., ATTN: Mr. Anthony L. Patko Vectra Fuel Services, ATTN: Mr. Jack F?ollins Westinghouse Electric Corp., ATTN: Mr. A. J. Nardi Yankee Atorr;ic Electric Company, ATTN: Mr. Jay K. Thayer l
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@t p k " UNITED STATES
'
- NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. Essewooi j
p January 21, 1999 1
- ABB Combustion Engineering Co., Inc.
j ATTN: Dr. Ian C. Rickard
- 2000 Day Hill Road )
l l Windsor, CT 06095-0500
- i
SUBJECT:
" PUNCTURE TESTING OF SHIPPING PACKAGES UNDER 10 CFR PART 71*
i j
Dear Dr. Rickard:
in 1997, the NRC became aware that two holders of NRC Certificates of Compliance for transportation packages had performed the puncture test using a bar that was not properly mounted as specified in 10 CFR 71.73(c)(3). Based on these findings, Bulletin 97-02 was 4 i issued on September 23,1997, to notify holders of Certificates of Complianca about issues i related to conducting the puncture test specified in 10 CFR 71.73 (c)(3).
j- :
' l The Bulletin requested holders of NRC Certificates of Compliance to review the puncture test assessment for each of their certified package designs. If the puncture test assessment was based upon physical testing, the certificate holder was requested to determine whether the puncture test had been performed in accordance with 10 CFR 71.73(c)(3).
The responses to the Bulletin identified some packages that had not been puncture tested exactly as specified in the regulations. In some instances, the puncture pin had not been secured against lateral movement, in another instance, the pin had been made of concrete instead of steel. For some older package designs, there was insufficient documentation to allow the certificate holder to determine the exact details of how the test was performed.
In their replies to the Bulletin, the certificate holders submitted justifications for continued use of packages that had not Deen puncture tested exactly as specified in the regulations. Because of the problems identified in the Bulletin, some certificate holders ratested their packages to demonstrate adequacy. Some certificate holders determined that the pin did not move during the test, and that securing the pin against lateral movement would not have affected the test results. Somo certificate holders determined that even though the tests had been conducted with a concrete pin, the results would not have been significantly different with a steel pin. This is because the packages involved were substantially less rigid than the concrete pin, and thus the test package absorbed essentially all the kinetic ensrgy. Finally, some packages had not been subjected to the puncture test because the outer packaging of the designs is sacrificial in nature. Puncture test damage to the sacrificial outer packaging would not significantly affect the ability of the package to meet the performance requirements of 10 CFR Part 71.
Based on the justifications for continued use provided by the certificate holders, as well as the excellent transportation safety record developed over several years, the staff believes that no further action is needed with respect to previously approved packages.
Attachment 2
Multiple Addressees 2 Codificate holders are reminded that previously approved packages that have not been shown to meet the current version of 10 CFR Part 71, and are therefore not designated as "-85", are authorized for continued use indefinitely. However,10 CFR 71.13 includes certain restrictions on packages which have not been designated as "-85', namely, new packages may not be fabricated after April 1,1999, and ortly cer1ain types of amendments may be made to the Certificate of Compliance.
To receive a *-85* designation, a Certificate holder should submit an application that demonstrates that the package design meets the requirements of 10 CFR Part 71. The staff's review of applications for a "-85" designation will include an evaluation of how the puncture testing was performed. Only packages which have been properly tested or evaluated for the puncture test condition will be designated as "-85".
If you have any questions, please contact Mr. David Tiktinsky at (301)-415-8523.
Sincerely, Odgiani signed by /s/
William F. Kane, Director Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Distribution:
Identical Letters sent to those on attached list.
NMSS r/f SFPO r/f EWBrach EJLeeds BWhite NLOsgood CJPaperiello FCSturz LYang CBrown SShankman EEaston AGaunt ABarto PDR/PUBLIC PEng Document Control G:\TIKTINSK\ BULL-CON.WPD; \ BULL DAT.WPD; \ BULL-FRM.WPD; BULL-MRG.WPD
- C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure 'N' = No copy OFC NMSS f SFPO N SFPO E SFPO. k SFPQr,f /
DTikhsky dZiegler NAME CR poll MW ofs hhe DATE 01/El/99 01/2.1/99 01/2.//99 01/,2/ /99 01/ tl/99 OFFICIAL RECORD COPY 1/21/99:dd t
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Addressees - Letter Dated u_, ,i 1999 i
SUBJECT:
" PUNCTURE TESTING UF SHIPPING PACKAGES UNDER 10 CFR PART 71" ABB Combustion Engineering Co., Inc.
i ATTN: Dr. Ian C. Rickard Advanced Medical Systems, Inc.
ATTN: Ms. Sherry J. Stein Alpha-Omega Services, Inc.
ATTN: Bruce Hedger AEA Technology /QSA, Inc.
ATTN: Ms. Cathleen Roughan ANEFCO, Inc.
ATTN: Mr. John D. Murphy BWX Technologies, Inc.
ATTN: Mr. M.C. Suwala Bumley Technology, Inc.
ATTN: Mr. John J. Munro, lil Chem-Nuclear Systems, Inc.
ATTN: Mr. David L. Langan Department of the Navy.
Chief of Naval Opers Department of Energy ATTN: Mr. W. P. Engel Department of Energy EM-70, ATTN: Mr. Michael E. Wangler Department of Energy, OCRWM ATTN: Mr. Ronald A. Milner Department of Air Force ATTN: AFTAC Radiation Safety Ofc.
Framatome Cogema Fuels *
. ATTN: Ms. Gayle F. Elliott General Atomics ATTN: Mr. Keith E. Asmussen
,s a
o a General Electric Company '
ATTN: Mr. Chuck W. Bassett l General Electric Co., Nuclear Energy l ATTN: Mr. Charles M. Vaughan Holtec Intemational L ATTN: Mr. Vikram Gupta industrial Nuclear Company .
ATTN: E. W. Huddieston 1
J. L. Shepherd & Associates ATTN: Mr. J. L Shepherd
?
l' ll Molten Metel Technology, Inc.
( ATTN: Mr. Anihony Patko NAC Intemational, Inc.
l ATTN: Mr. Tom C. Thompson
- Neutron Products, Inc.
ATTN: Mr. Mamn M. Turkanis
' Nordion Intemational, Inc.
ATTN: Mr. R. W. McGregor l- Nuclear Fuel Services, Inc.
L ATTN: Dr. T. S. Beer Nuclear Containers, Inc.
ATTN: Mr. William M. Amold -
Packaging Technology, Inc.
ATTN: Mr. Richard T. Haelsig Portland GE Co., Trojan Plant
- ATTN: Mr. Stephen M. Quennoz
[ Siemens Power Corporation I. ATTN: Mr. James B. Edgar e
' Source Production & Equipment Co., Inc.
ATTN: Mr. R. Dicharry l~ Tennessee Valley Authority
{ ATTN: Mr. Raul R. Baron V
~ . - . - . __. . _- . - - .. . . - . . . - - . . . - - . . .
l 0 Transnuclear, Inc.
l ATTN: Mr. Michael Mason
, U.S. Department of Commerce ATTN: Mr. J. Michael Rowe U.S. Department of Transportation i ATTN: Mr. James K. O'Steen United States Enrichment Corporation ATTN: Ms. Beth Darrough Westinghouse Electric Corp.
ATTN: Mr. A. J. Nardi Yankee Atomic Electric Company :
ATTN: Mr. Jay K. Thayer i
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