Responds to NRC Bulletin 97-002,requiring Holders of Certificates for Shipping Packages Respond within 30 Days by Notifying Commission of Intent to Review Safety Analyses & Provide Rept Documenting Any Corrective ActionML20217J493 |
Person / Time |
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Site: |
07109208, 07109079, 07109159, 07109176, 07109145, 07109177, 07109178, 07109179 |
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Issue date: |
10/10/1997 |
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From: |
Hogg R External (Affiliation Not Assigned) |
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To: |
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
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References |
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IEB-97-002, IEB-97-2, NUDOCS 9710210132 |
Download: ML20217J493 (3) |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20206G5491999-04-28028 April 1999 Advises That Coc 9176 for Model Nupac 14/210L,NUPAC 14/210H, Cnsi 14-215H Series A,Ln 14-195L & Ln 14-195H Packages Expired on 990401.Certificate Cannot Be Renewed as Packages & Use Are Now Regulated by Us DOT ML20205S6761999-04-14014 April 1999 Requests to Withdraw from NRC consideration,Chem-Nuclear Sys Request to Grant Temporary Extension to Expiration Date for Type a Package Coc ML20205T3331999-04-14014 April 1999 Informs That Certificate of Compliance 9179 for Model Nupac 6/100L,NUPAC 6/100H,LN 6/80L & Ln 6/80H Packages Expired on 990401.Use of Packages Under General License Provisions of Subpart C of 10CFR71 Is Terminated ML20205T3131999-04-14014 April 1999 Informs That Certificate of Compliance 9178 for Model Nupac 7/100 & Ln 7-100 Packages Expired on 990401.Use of Packages Under General License Provisions of Subpart C of 10CFR71 or 49CFR173.471,is Terminated ML20206J8371999-04-14014 April 1999 Informs That Coc 9079 for Model Nupac 14D-2.0 Package Expired on 990401.Use of Package Under General License Provisions of Subpart C of 10CFR71 & 49CFR173.471 Is Terminated ML20206F3691999-04-14014 April 1999 Informs That Coc 9159 for Model Nupac 14/190L,NUPAC 14/190M, Nupac 14/190H,LN 14-170L,LN 14-170M & LN-170H Packages Expired on 990401.Use of Packages Under General License Provisions of Subpart C of 10CFR71 Is Terminated ML20205T3071999-04-14014 April 1999 Informs That Certificate of Compliance 9177 for Model Nupac 10/140 & Ln 10/135A Packages Expired on 990401.Use of Packages Under General License Provisions of Subpart C of 10CFR71 or Under Provisions of 49CFR173.471,is Terminated ML20206A4301999-04-14014 April 1999 Informs That Coc 9145 for Model Nupac 50-1.5L,NUPAC 50-2.5L, Nupac 50-3.OL & Nupac 50-4.OL Expired on 990401.Use of Packages Under General License Provisions of 10CFR71 or Under Provisions of 49CFR173.47 Is Terminated ML20204H9881999-03-18018 March 1999 Requests That NRC Grant Temporary eight-month Extension to Expiration Date for Subject Type a Package Cocs (Cask Models Nupac 14-190H & CNS 14-215H Respectively) ML20204C0161999-03-17017 March 1999 Forwards Certificate of Compliance 9179,rev 9 for Model Nupac 6/100L,NUPAC 6/100H,LN 6-80L & Ln 6-80H Packages. Changes Made to Encl Certificate Are Indicated by Vertical Lines in Margin ML20205G1701999-03-11011 March 1999 Forwards Coc 9176,rev 15 for Model 14/210L,NUPAC 14/210H, Cnsi 14-215H Series A,Ln 14-195L & Ln 14-195H Packages. Approval Constitutes Authority to Use Package for Shipment of Radioactive Matl,Iaw 49CFR173.471 ML20207K6531999-03-11011 March 1999 Forwards Coc 9178,rev 9 for Model Nupac 7/100 & LN-7-100 Packages.Approval Constitutes Authority to Use Packages for Shipment of Radioactive Matl & for Packages to Be Shipped IAW Provisions of 49CFR173.471 ML20207K6791999-03-11011 March 1999 Forwards Coc,Rev 9 for Model Nupac 14/190L,NUPAC 14/190M, Nupac 14/190H,LN 14-170L,LN 14-170M & Ln 14-170H Packages. Approval Constitutes Authority to Use Packages for Shipment of Radioactive Matl & Shipped IAW 40CFR173.471 ML20207J8661999-03-11011 March 1999 Forwards Coc 9177,rev 9,for Model Nupac 10/140 & Ln 10-135A Packages.Approval Constitutes Authority to Use Packages for Shipment of Radioactive Matl & for Packages to Be Shipped IAW 49CFR173.471 ML20207J3221999-03-0404 March 1999 Forwards Rev 18 to Coc 9079 for Model Nupac 14D-2.0 Package & Approval Record ML20207J2661999-03-0404 March 1999 Forwards Rev 13 to Coc 9145 for Models Nupac 50-1.5L,NUPAC 50-2.5L,NUPAC 50-3.0L & Nupac 50-4.0L Packages.Revised Coc & Approval Record,Encl ML20202E6121999-01-27027 January 1999 Notification of Registration as User of Certificate of Compliance 9159,in Response to 990112 Request ML20199J7011999-01-21021 January 1999 Notification of Registration as User of Certificates of Compliance 9079 & 9176,in Response to 990105 Request ML20199J6861999-01-21021 January 1999 Notification of Registration as User of Certificate of Compliance 9145,in Response to 990105 Request ML20202B3041999-01-12012 January 1999 Requests Registration as User of Listed Chem-Nuclear Sys Radioactive Matls Package,Cask Identification Number USA/9159/A ML20199F3411999-01-0505 January 1999 Requests Registration as User of Chem-Nuclear Sys CNS 14-170 Radioactive Matls Shipping Cask ML20199F3791999-01-0505 January 1999 Requests Registration as User of Chem-Nuclear Sys CNS 14-215H Series a Radioactive Matls Shipping Cask USA/9176/A ML20199F3661999-01-0505 January 1999 Requests Registration as User of Nupac 50-1.5L, Nupac 50-2.5L,NUPAC 5-3.0L & Nupac 50-4L Radioactive Shipping Cask Packages USA/9145/A ML20197H4671998-12-10010 December 1998 Notification of Registration as User of Certificate of Compliance 9176,in Response to 981120 Request ML20197J3131998-12-0101 December 1998 Informs That Molten Metal Technology,Inc Is Transferring All Cocs & TRs Listed in Encl,To Buyer.Buyer Will Be Holder for Encl Info & Accepts Responsibility for Completeness & Accuracy of Statements & Representations in Respective TRs ML20196A5611998-11-20020 November 1998 Notification of Registration as User of Certificate of Compliance 9176,in Response to 981111 Request ML20196B7931998-11-20020 November 1998 Requests Registration as User of Model Chem-Nuclear Systems, Inc Cnsi 14-215H Series a Radioactive Matl Shipping Cask ML20195F6181998-11-11011 November 1998 Requests Registration as User of Model Nuclear Packaging,Inc Nupac Model 14/210L & 14/210H Radioactive Matls Shipping Package Cask ML20153G2661998-09-25025 September 1998 Notification of Registration as User of Certificates of Compliance 9151,9176 & 9222,in Response to 980915 Request ML20153D2031998-09-15015 September 1998 Requests Registration as User of Molten Metal Technology,Inc Nupac Model 14/210 Series Radioactive Matls Shipping Casks ML20151X5001998-09-11011 September 1998 Informs That NRC Records Indicate That Licensee Was Previously Registered as User of Coc 9176,in Response to .No Further Action Is Necessary ML20238F6801998-08-25025 August 1998 Requests Registration as User of Nupac Model 14/210L Radioactive Matls Shipping Package ML20238F6791998-08-25025 August 1998 Requests Registration as User of Nupac Model 14/210H Radioactive Matls Shipping Package ML20237D6761998-08-21021 August 1998 Notification of Registration as User of Certificate of Compliances 9073 & 9208,in Response to 980721 Request ML20236R9681998-07-17017 July 1998 Notification of Registration as User of Certificate of Compliances 9079 & 9184,in Response to 980618 Request ML20236S0141998-07-17017 July 1998 Notification of Registration as User of Certificate of Compliances 6601,9094,9159,9168 & 9176,in Response to 980618 Request ML20249C8431998-06-18018 June 1998 Requests Registration as User of Model 14-190H Radioactive Shipping Cask Package ML20236E9371998-06-18018 June 1998 Requests Registration as User of Model 14-215 Radioactive Shipping Cask ML20249A9481998-06-17017 June 1998 Notification of Registration as User of Certificate of Compliance 9176,in Response to 980611 Request ML20249A6871998-06-11011 June 1998 Requests Registration as User of Model 14/210L & 14/210H Radioactive Matls Shipping Package ML20248J2101998-06-0505 June 1998 Responds to Requesting Info About Invoices for Which Molten Metal Technology May Be Responsible.Invoice FL0196-98 Ack as pre-petition Debt for Which NRC Will Not Pursue.C of C 9210 Will Not Be Billed Until 980724 ML20248J2281998-05-0404 May 1998 Requests Status of Any Invoices for Licenses C of C 9145 & C of C 9210 for Transfer of Cask from Seg to Molten Metal Technology ML20217Q5161998-04-29029 April 1998 Requests Registration as User of Models CNS 8-120A,NUPAC 14/210L,NUPAC 14/210H,CNSI 14-215H Series A,Ln 14-195L,LN 14-195H,CNS 8-120B & CNS 14-170,Series III ML20199K2551998-02-0202 February 1998 Notification of Registration as User of Certificate of Compliance 9145,in Response to 980120 Request ML20198R0401998-01-20020 January 1998 Requests Registration as User of Models 50-1.5l,50-2.5l, 50-3.0l & 50-4.0l ML20217J4931997-10-10010 October 1997 Responds to NRC Bulletin 97-002,requiring Holders of Certificates for Shipping Packages Respond within 30 Days by Notifying Commission of Intent to Review Safety Analyses & Provide Rept Documenting Any Corrective Action ML20211D4371997-09-18018 September 1997 Forwards Certificate of Compliance 9079,rev 17 for Model Nupac 14D-2.0 Package ML20211D4721997-09-17017 September 1997 Forwards Coc 9159,rev 8 for Model Nupac 14/190L, Nupac 14/190M,NUPAC 14/190H,LN 14-170L,LN 14-170M & LN-14-170H Packages.Approval Constitutes Authority to Use Packages for Shipment Radioactive Matl ML20211D4541997-09-17017 September 1997 Forwards Coc 9145,rev 12 for Models Nupac 50-1.5L, Nupac 50-2.5L,NUPAC 50-3.OL & Nupac 50-4.OL.Approval Constitutes Authority to Use Packages for Shipment of Radioactive Matl & Packages to Be Shipped IAW 49CFR173.471 ML20211D4111997-09-17017 September 1997 Forwards Certificate of Compliance 9176,rev 14 for Models Nupac 14/210L,NUPAC 14/210H,CNSI 14-215H Series A,Ln 14-195L & Ln 195H Packages,As Requested by 1999-04-28
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20205S6761999-04-14014 April 1999 Requests to Withdraw from NRC consideration,Chem-Nuclear Sys Request to Grant Temporary Extension to Expiration Date for Type a Package Coc ML20204H9881999-03-18018 March 1999 Requests That NRC Grant Temporary eight-month Extension to Expiration Date for Subject Type a Package Cocs (Cask Models Nupac 14-190H & CNS 14-215H Respectively) ML20202B3041999-01-12012 January 1999 Requests Registration as User of Listed Chem-Nuclear Sys Radioactive Matls Package,Cask Identification Number USA/9159/A ML20199F3411999-01-0505 January 1999 Requests Registration as User of Chem-Nuclear Sys CNS 14-170 Radioactive Matls Shipping Cask ML20199F3661999-01-0505 January 1999 Requests Registration as User of Nupac 50-1.5L, Nupac 50-2.5L,NUPAC 5-3.0L & Nupac 50-4L Radioactive Shipping Cask Packages USA/9145/A ML20199F3791999-01-0505 January 1999 Requests Registration as User of Chem-Nuclear Sys CNS 14-215H Series a Radioactive Matls Shipping Cask USA/9176/A ML20197J3131998-12-0101 December 1998 Informs That Molten Metal Technology,Inc Is Transferring All Cocs & TRs Listed in Encl,To Buyer.Buyer Will Be Holder for Encl Info & Accepts Responsibility for Completeness & Accuracy of Statements & Representations in Respective TRs ML20196B7931998-11-20020 November 1998 Requests Registration as User of Model Chem-Nuclear Systems, Inc Cnsi 14-215H Series a Radioactive Matl Shipping Cask ML20195F6181998-11-11011 November 1998 Requests Registration as User of Model Nuclear Packaging,Inc Nupac Model 14/210L & 14/210H Radioactive Matls Shipping Package Cask ML20153D2031998-09-15015 September 1998 Requests Registration as User of Molten Metal Technology,Inc Nupac Model 14/210 Series Radioactive Matls Shipping Casks ML20238F6801998-08-25025 August 1998 Requests Registration as User of Nupac Model 14/210L Radioactive Matls Shipping Package ML20238F6791998-08-25025 August 1998 Requests Registration as User of Nupac Model 14/210H Radioactive Matls Shipping Package ML20249C8431998-06-18018 June 1998 Requests Registration as User of Model 14-190H Radioactive Shipping Cask Package ML20236E9371998-06-18018 June 1998 Requests Registration as User of Model 14-215 Radioactive Shipping Cask ML20249A6871998-06-11011 June 1998 Requests Registration as User of Model 14/210L & 14/210H Radioactive Matls Shipping Package ML20248J2281998-05-0404 May 1998 Requests Status of Any Invoices for Licenses C of C 9145 & C of C 9210 for Transfer of Cask from Seg to Molten Metal Technology ML20217Q5161998-04-29029 April 1998 Requests Registration as User of Models CNS 8-120A,NUPAC 14/210L,NUPAC 14/210H,CNSI 14-215H Series A,Ln 14-195L,LN 14-195H,CNS 8-120B & CNS 14-170,Series III ML20198R0401998-01-20020 January 1998 Requests Registration as User of Models 50-1.5l,50-2.5l, 50-3.0l & 50-4.0l ML20217J4931997-10-10010 October 1997 Responds to NRC Bulletin 97-002,requiring Holders of Certificates for Shipping Packages Respond within 30 Days by Notifying Commission of Intent to Review Safety Analyses & Provide Rept Documenting Any Corrective Action ML20216J4511997-09-10010 September 1997 Requests Registration as User of Listed Radioactive Matls Shipping Packages ML20151L2861997-07-24024 July 1997 Requests Registration as User of models,14D-2.0,50-1.5L, 2.5L,4.0L,14/190L,M,H,14/210L,H,10-140,7-100,6-100L,H,PAS-1, 10-142,CNS-14-170 Series Iii,Cns 14-170,CNS 14-195H & CNS 21-300 ML20147J4061997-04-22022 April 1997 Requests Registration as User of Vectra Technologies Inc Radioactive Matl Shipping Cask Upac 14-190L,14-190M & 14-190H ML20138F5471997-04-21021 April 1997 Requests Registration as User of Vectra Technologies Inc Radioactive Matl Package Shipping Cask Nupac 14-210 H or L ML20135E9961997-02-27027 February 1997 Informs of Receiving Notification from Vectra That CPC Had Not Been Placed on Registered Users List for Vectra Cask (50-2.5),package Identification USA/9145/A.Copy of Requesting Registration as User of 50-2.5 Cask,Encl ML20135B6671996-11-18018 November 1996 Requests Registration as User of Nuclear Packaging,Inc Nupac Models 50-1.5L,50-2.5L,50-3.0L & 50-4.0L Radioactive Matls Shipping Packages ML20129C0411996-10-16016 October 1996 Requests Registration as User of Packages USA/9176/A & USA/9094/A for Nupac Model 14-210H Type a Shipping Cask & Chem-Nuc Model 14-195H Type a Shipping Cask ML20135F0011996-06-15015 June 1996 Requests Registration as User of Nupac Model 50-2.5 Radioactive Materials Shipping Package ML20059E2161993-12-28028 December 1993 Requests Registration as User of Nuclear Packaging,Inc Nupac Model 14/190H Radioactive Matls Shipping Package (Cask) ML20059E8191993-12-15015 December 1993 Requests Registration as User of Nupac 14210 Cask for 931220 Shipment.Requests to Be Advised If Approval Will Be Delayed ML20059M9901993-11-15015 November 1993 Requests Registration as User of Nupac Models 10-142 & 14-210H Shipping Casks ML20059L6721993-11-0303 November 1993 Requests Registration as User of Nupac Model 14-190 Radioactive Matls Shipping Package (Cask) L-93-279, Informs Staff of Intent to Exercise General License Provisions of 10CFR71.12 for Units 1 & 2 for Use of Listed Chem-Nuclear Sys,Inc Radioactive Matl Shipping Casks1993-10-28028 October 1993 Informs Staff of Intent to Exercise General License Provisions of 10CFR71.12 for Units 1 & 2 for Use of Listed Chem-Nuclear Sys,Inc Radioactive Matl Shipping Casks ML20057F4711993-10-0101 October 1993 Provides 10CFR71.12(c) Notification for SCE Using Nupac Model 14-190H Type a Radioactive Matls Shipping Package Starting 931018 ML20056F7091993-08-23023 August 1993 Requests Registration as User of Model 14/190H Cask ML20044C8161993-04-30030 April 1993 Notifies of Intent to Maintain Designs for Listed Packages for Certificates of Compliance 9159,9176,9177,9178 & 9179 ML20035H6071993-04-30030 April 1993 Requests Registration as User of Model Nupac 14/210 Shipping Package ML20035H6111993-04-29029 April 1993 Notifies That Licensee Wishes to Continue Using Certificate of Compliance 9176,Model CNS 14-215H Series a Transport Packaging Currently Under Timely Renewal by Certificate Holder ML20035H3461993-04-27027 April 1993 Requests Registration as User of Models 14/210H,NUPAC 14/210L,CNSI 14-215H,Series A,Ln 14-195L & Ln 14-195H ML20036A4781993-04-26026 April 1993 Requests Future Correspondence Pertaining to Radioactive Matls Packages Be Addressed to Jd Sieber ML20138D2051993-02-10010 February 1993 Advises That Cnsi Drawing C-119-B-0017,transmitted in 930118 Application for Amend to Certificate of Compliance 9176 for Model Cnsi 14-215H May Be Submitted to PDR for Copying & Distribution ML20128L6421993-02-0202 February 1993 Lists Packages That No Longer Need Trojan Listed as User,Per 930201 Conversation & Closure of Plant.Licensed Packages Util Will Continue to Use Also Listed ML20126F2341992-12-21021 December 1992 Forwards Addl Sketches Illustrating an Optional One Inch Thick Lid for Shield Insert for Certificate of Compliance 9176 ML20125B6591992-12-0202 December 1992 Requests That Company Name Be Changed from Nuclear Packaging Inc to Pacific Nuclear Sys,Inc.Address Unchanged ML20058H8381990-11-19019 November 1990 Requests Registration as User of Models CNS 21-300, CNS 14-190H & CNS 14-215H Shipping Packages ML20058D8141990-11-0202 November 1990 Requests Registration as User of Chem-Nuclear Sys Inc Model Nupac 14/190H Radioactive Matls Shipping Cask NRC-90-0174, Requests Registration as User of Model Nupac 14/190H Under Certificate of Compliance 91591990-11-0202 November 1990 Requests Registration as User of Model Nupac 14/190H Under Certificate of Compliance 9159 ML20058C2611990-10-26026 October 1990 Requests Registration as User of Model 14/210L & 14/210H Radioactive Matls Shipping Cask ML20062C6691990-10-23023 October 1990 Requests Registration as User of Model HN-142 Shipping Cask Under Certificate of Compliance 9208 ML20058P7441990-08-16016 August 1990 Requests Registration as User of Models LN-142 & Nupac 10-142 ML20055J2351990-07-26026 July 1990 Requests Registration as User of Model Nupac 14D-2.0 for Radioactive Matl Shipping Cask Under Certificate of Compliance USA/9079/A 1999-04-14
[Table view] |
Text
.
Molten MetalTecitnology,Inc.
- 1009 Commerce Park Dnve, Suite 400
- http: //www mmtm October 10,1997 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:
This letter is in response to NRC Bulletin 97-02. The subject Bulletin requires that holders of Certificates for shipping packages respond within 30 days by notifying the Commission of their intent to reviev the safety analyses associated with the certificates and provide a report documenting any necessary corrective action within the time frames specified in the Bulletin (or provide an alternate plan of action and schedule), fir. ally the Bulletin requires the certificate holder notify the Commission upon completion of review and corrective actions.
MMT-TN is the certificate holder for eight transportation packages. The following certificates are the subject of this response:
9079,9145,9159,9176,9177,9178,9179,9208 The response to items 1,2 and 3 of the requested actions identified in the Bulletin are provided in this letter and the attached report. Item I is addressed for each cask in the attached report. Items 2 and 3 do not apply to any MMT-TN packages as described in the summary of the attached report.
This response provides the required notification to the NRC that MMT-TN has completed its review and activities associated with the response to Bulletin 97-02.
If you have any questions regarding this response please call me at (423) 220-5012.
Sincerely, b
l!
I Robert C. Hogg, Man Regulatory Affairs Molten Metal Technology,Inc c:
Mr. Charles J. Haugney, Acting Director Spent Fuel Project Office Office ofNuclear Material Safety
(({l{l$h)Ih and Sareguards
?ph**$0h)h $$09079 C: '*'C"' *****"'T-'N "!*" '* *""* -02 doc P I C
PDR
c MMT-TN Response to NRC Bulletin 97-02 Intfoduction:
On June 27,1997, NRC issued Information Notice 97-47 to notify licensees ofissues related to
- the performance ofpuncture tests as required in 10 CFR 71.73 (c)(3). The notice identiiled two instances of NRC approved package certificate holders,who performed the hypothetical accident condition puncture test using a bar that was not " mounted" as required (see NRC Ollice of Public Affairs, Annmncement Numbers97-091 and 97-098). NRC issued Bulletin 97-02 on September 23,1997, requiring written response from certificate holders for shipping packages.
In response to the bulletin, MMT-TN reviewed the information for applicability to MMT-TN packages. The MMT-TN evaluation and findings of the evaluation are provided in this report.
This report addresses items 1,2, and 3 of the NRC Bulletin, as required for the MMT-TN held certificates.
Discussion:
MMT-TN acquired assets including the intellectual property related to two Type B transportation
. packages when it purchased assets from VECTRA in early 1997. One of these packages is a Type B package, certified by the NRC under Certificate of Compliance number 9208. MMT-TN reviewed the safety analysis report for the subject cask and reviewed guidance provided by NRC on demonstrating compliance (in accordance with 10 CFR 71.41) with the testing requirements stated at 10 CFR 71.73.
- Regulation at 10 CFR 71,41(a) states "...the test specified in 71.73......must be evaluated by subjecting a specimen or a scale model to a specific test, or by another method of demonstration
- acceptable to the Commission." Guidance in NRC Regulatory Guide 7.9 " Standard Format and Content of Part 71 Applications for Approval of Packaging of Type B, Large Quantny, and Fissile Radioactive Material," identifies the acceptable standard format and content of the safety analysis reports to demonstrate cen.pliance in accordance with 71.41.
Section 2.7 of the standard format of an application should describe the hypothetical accident conditions evaluated for the subject package. Section 2.7.2. of the Guide describes the expect.:d content af the application discussing the puncture test. Section 2.7.2 says that "the general comments in paragraph 2.7.1" of the Guide apply to the puncture test. Section 2.7.1 of the Guide states that "the assessment of the package may be made by analysis, prototype testing, model testing, or comparison to a similar package.
' l0:1pjy1 C:\\msoficetwinwordfilesulAIT.TN Respo$e to Bulletm 97-01 doc p. 2
Each MMT-TN Cenificate is addressed below.
Certificate Numbers - 9079,9145,9159,9176,9177,9178,9179 These packages are not required to withstand the hypothetical accident conditions defined in 10 CFR 71.73, because they are limited to transporting LSA or SCO material in accordance with section 71.52.
Certificate Number-9208 The original Safety Analysis Report (SAR) for this package was tendered by Pacific Nuclear Systems in April 1991. The analysis perfonned, to demonstrate compliance with the hypothetical accident conditions as required, is generally described in section 2.7, on page 2-40 of the SAR. Pacific Nuclear, and other approved package vendors, asserted and MMT-TN continues to believe that demonstration by analysis is adequate to demonstrate the capability of this package to withstand the accident conditions. The analysis that was performed to demonstrate this package could withstand the puncture test is described in section 2.7.2, on page 2-70 of the SAR.
The original license application, submitted by a previous owner of the cask, provided an analytical assessment of the hypothetical accident conditions, as deemed acceptable by NkC statfin Regulatory Guide 7.9. No analytical reference was made to actual testing of this cask, nor was any reliance placed on or comparison made to actual testing of another cask. Therefore, the question of the adequacy of the " mounted" puncture bar for puncture testing is not applicable to the MMT-TN safety evaluations.
Summary:
Based on MMT-TN's review of the licensing records, MMT-TN has determined that the safety evaluations and NRC review and approval of the safety evaluations demonstrate MMT-TN's Type B package is in compliance with the regulations at 10 CFR 71.41 and 71.73. Operating experience with the Type B package now owned by MMT-TN provides additional assurance that the operation of the MMT-TN Type B cask is safe and operated in accordance with the Certificate of Compliance and the appropriate regulations.
In addition, MMT-TN transportation packages which are certified to carry LSA and SCO material in accordance with 10 CFR 71.52 are not required to demonstrate compliance with the hypothetical accident condition requirements.
Since no MMT-TN package was assessed using a physical puncture test, items 2 and 3 of the Bulletin does not apply to the MMT-TN packages.
lot 10!41 C:\\msoficebunnordjilesalMT TN Response to Bulletm 9'-0ZJoc. p 3