ML20217J493

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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
ML20217J493
Person / Time
Site: 07109208, 07109079, 07109159, 07109176, 07109145, 07109177, 07109178, 07109179
Issue date: 10/10/1997
From: Hogg R
External (Affiliation Not Assigned)
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
IEB-97-002, IEB-97-2, NUDOCS 9710210132
Download: ML20217J493 (3)


Text

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Molten MetalTecitnology,Inc.

  • 1009 Commerce Park Dnve, Suite 400
  • onk Rdge.TN 37830 U.S.A
  • Tel: 423-4824260
  • Fat 42148242t2
  • 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

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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.

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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.

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