ML092720221
| ML092720221 | |
| Person / Time | |
|---|---|
| Site: | 05000134 |
| Issue date: | 09/21/2009 |
| From: | Curley M Worcester Polytechnic Institute |
| To: | Ted Carter NRC/FSME/DWMEP |
| References | |
| Download: ML092720221 (10) | |
Text
100 lnstirurc Road Worcester, MA 01609-2280, USA 50R-831-')7')4, Fax 508-831-5064 www.wpi.cdu Financial Services September 21, 2009 Mr. Ted H. Carter U.S. Nuclear Regulatory Commission Mail Stop T-8-F-S Washington, D.C. 20555
Dear Ted,
Enclosed please find WPl's nuclear materials transportation plan. The document has been prepared and reviewed in support of the removal of the fuel during WPl's decommissioning of its nuclear reactor.
Please review at NRC's earliest convenience and provide comments or questions to me. Thank you, Ted.
We certify under penalty of perjury that the enclosure is true and correct to the best of our knowledge.
- '4/2%
Mic~ael J. Curley, Reacf trector/University Compliance and Risk David S. Adams, Ph.D., Radiation Safety Officer Reviewed and approved by an officer of WPI, as indicated by the signature below.
.~.
Jeffrey S. Solomon, Executive Vice president and CFO
Special Nuclear Material Transportation Plan Worcester Polytechnic Institute July 23, 2009 Docket No. 50-134
Background:
This plan specifically addresses compliance with the requirements of 10CFR73 "Physical Protection of Plants and Materials" for the one-time shipment ofWPI's nuclear reactor fuel, for its return to the Department of Energy (DOE),with its destination either a DOE facility or a third party NRC licensee. WPI will deliver the fuel to a DOE contracted carrier (staged at the WPI reactor facility). The scope ofWPI's activities covered by this plan is the providing and receiving of notifications and providing (or overseeing DOE's contractor provide) the arrangements for physical protection during transit and completing paperwork for the SNM shipment.
The shipment will consist of 27 fuel elements (22 used and 5 fresh). Each fuel element contains approximately 167 grams of Uranium-235, giving a total SNM content of approximately 4.5 Kg, with a U-235 enrichment of 19.75%.
This plan specifically addresses the requirements paragraph (g)of 10CFR73.67 "Licensee Fixed site and In-transit Requirements for the Physical Protection of Special Nuclear Material of Moderate and Low Strategic Importance". This plan has been prepared using the format and applicable parts of Regulatory Guide 5.59 "Standard Content and Format for a Licensee Physical Security Plan for the Protection of Special Nuclear Material of Moderate or Low Strategic Significance, Part II". This plan does not modify any plans or requirements ofWPI's existing SNM protection plans for its reactor facility that are currently in place. As indicated below, due to this plan covering a one-time shipment ofthe SNM, not all items covered by Regulatory Guide 5.59 are applicable to this plan.
1.0 Use and Storage Area at a Fixed Site Not applicable.
2.0 Detection Devices and Procedures at a Fixed Site Not applicable.
3.0 Security Response at a Fixed Site Not applicable.
4.0 Response Procedures for a Fixed Site Not applicable.
5.0 SNMTransportation Requirements WPI's Reactor Director is responsible for providing and receiving the notifications described in this section, arranging for (or overseeing DOE and its transportation contractor Nuclear Assurance Corporation (NAC)arrange for) the physical protection during transit. Furthermore, the Department of Energy (DOE) and its transportation contractor (NAC)are responsible arranging for transportation, loading the shipment, inspecting the shipment and completing shipment's paperwork. The transportation requirements performed by the DOE and NAC will be overseen and approved by the WPI's Reactor Director.
5.1 Advance Notification Prior to the shipment of SNM, the receiver is notified of the following:
Mode of transport; Estimated time of arrival; Planned location for transfer of material to the receiver, if other than receiver's facility; Name of carrier; and Transport identification (e.g., number of trucks, train identification, flight number or ship's name).
Shipping procedures provide for obtaining confirmation that the intended receiver has been provided the above information.
5.2 Receiver Confirmation Prior to the shipment of SNM, confirmation is obtained from the intended receiver that the receiver will be ready to accept the shipment at the planned time and location. Shipping procedures provide for obtaining confirmation that the receiver has acknowledged the mode of transport, confirmed the acceptability of the shipment, and has the proper authorization for receipt.
5.3 Containers All SNM shipping containers are sealed using tamper-indicating seals.
These seals are applied to the outer containment system in a manner such that removal of the container cover or lid cannot be accomplished without breaking the seal.
5.4 Inspection Procedures and checklists require and document that the integrity of the package and associated safeguard seals have been verified by visual inspection just prior to shipment.
5.5 In-Transit Protection WPI is responsible for the in-transit physical protection of the shipment of SNM unless the planned receiver is a licensee and has agreed, in writing, to accept responsibility for arranging for the in-transit protection of the material to be shipped. Actions necessary to maintain current information relative to the shipment status are performed in coordination with its carrier.
6.0 Receiver Practices Not applicable 7.0 In-Transit Physical Protection Requirements 7.1 Response Procedures For this transportation of SNM of low strategic significance, events which require responsive actions are given in Table 7.1. The type of response, objectives and associated responsibilities related to those events are given in Table 7.2.
7.2 Notification Arrangements will be made with the receiver or carrier to notify WPI of any shipment which is not received within four hours of the latest estimated time of arrival.
7.3 Lost Material Notification WPI will have the responsibility for scheduling departure and arrival times for SNM shipments. Through communication with DOE and the carrier, WPI will maintain knowledge of the shipment routing, timing, etc. WPI will work with the DOE and carrier to trace a missing or lost shipment or otherwise determine the shipment status.
The WPI will notify the NRC Operations Center within one hour after the discovery of the loss of the shipment and within one hour after recovery of or accounting for such lost shipment in accordance with the provisions of 10 CFR 73.71.
Table 7-1 In-Transit Protection Events Requiring Contingency Response ID CODE EVENT A threat to steal SNM in-transit is received via message or third-party UTI report.
An accumulation of anomalies suggests someone might be planning to UT2 steal in-transit SNM.
Management perceives that Events UTI or UT2 represent a serious UT3 threat to steal SNM A duly constituted authority alerts management that an expressed or UT4 implied threat constitutes a serious threat to steal in-transit SNM.
Information is received suggesting that an attempted theft of in-UT5 transit SNM has occurred or is imminent.
UT6 A shipment is not received as scheduled Container and/or seal inspections indicated damage, lost or missing UT7 containers, or tampering with the shipment.
Table 7-2 In-Transit Contingency Responses Event Action Reactor Director UT A threat to steal in-transit Obtain and report information on Determine if threat is serious.
SNM is received by message or third-shipments to the Reactor Director party report.
without delay.
Assemble appropriate plant management personnel to assess the Objective threat.
Determine if threat is serious.
Assemble available information on the threat and the adversary.
Report the threat within one hour of receipt to the NRC Operations Center (301) 816-5100 or as backup, (301) 951-0550, and to law enforcement agencies, as applicable, and request any pertinent information that might be available.
Analyze available information to assess the threat.
If threat is perceived as serious, go to Event UT3.
UT2 - An accumulation ofanomalies Obtain and report information on Determine if threat is serious.
suggests someone might be planning shipments to the Reactor Director to steal in-transit SNM.
without delay.
Assemble appropriate plant management to assess the available Objective information.
Determine if threat is serious.
Analyze the available information to assess the inferred threat.
Decide if the inferred threat should be considered serious.
If threat is perceived serious, go to Event UT3.
Table 7-2 (continued)
In-Transit Contingency Responses Event Action Reactor Director UT3-Management perceives that Obtain and report information Prevent the theft of SNM.
Events UTI or UT2 represent a relative to any shipment location, serious threat to steal SNM.
status and planned routings.
Report within one hour of perceiving Coordinate WPI activities with the a credible threat to NRC Operations Objective carrier and DOE.
Center (301) 816-5100 or as backup, (301) 951-0550). Inform DOE and Prevent the theft of SNM.
carrier, as appropriate.
In coordination with DOE and the carrier, as appropriate, inform applicable law enforcement authorities of the threat and request assistance, as applicable.
Be prepared to provide support services as necessary.
UT A duly constituted authority Obtain and report information Prevent the theft of SNM.
alerts management that an relative to any shipment location, expressed or implied threat status and planned routings.
Report threat within one hour of constitutes a serious threat to steal Coordinate WPI activities with the receipt to the NRC Operations in-transit SNM.
carrier and DOE.
Center (30C 816-5100 or as backup, (301) 951-0550).
Objective In coordination with DOE and the carrier (as appropriate), inform Prevent the theft of SNM.
applicable law enforcement authorities of the threat and request assistance as applicable.
Be prepared to provide support services as necessary.
Table 7-2 (continued)
In-Transit Contingency Responses Event Action Reactor Director UT5 - Information is received Obtain and report information on the Direct the assessment of the event.
suggesting that an attempted theft of shipment and related problems in-transit SNM has occurred or is without delay. Coordinate activities Assure that the NRC Operations imminent.
with the carrier and DOE.
Center (301) 816-5100 or as backup, (301) 951-0050) is notified within For example:
one hour of receipt of information and law enforcement authorities are Carrier informs WPI of notified. Inform DOE and the problem with the shipment.
carrier as appropriate.
Receiver informs WPI of missing or damaged Be prepared to provide support containers or seals.
services as necessary.
Objective Direct the assessment of the event.
UT6 - A shipment is not received as Obtain and report information on the Direct the assessment of the event.
scheduled.
shipment without delay. Provide liaison between WPI, DOE and the Assure that the NRC Operations For example:
carrier.
Center (301) 816-5100 or as backup, (301) 951-0550) is notified within An expected shipment is not one hour after discovery of loss of the received within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the shipment, and within one hour after latest estimated time of recovery of or accounting for the arrival.
shipment.
Assure that appropriate law enforcement authorities are Receiver informs WPI that a notified.
scheduled shipment was not received within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the Be prepared to provide support latest estimated time of services as necessary.
arrival.
Objective Direct the assessment of the event.
Table 7-2 (continued)
In-Transit Contingency Responses Event Action Reactor Director UT7 - Container and/or seal Report all information relative to Determine the possibility of theft and inspection indicates damaged, lost or shipment to the Reactor Director initiate or coordinate an investigation missing containers or tampering with without delay.
of the circumstances surrounding the the shipment.
incident.
Objective If there has been a loss of SNM or a credible possibility of loss, notify the Determine the possibility oftheft.
NRC Operations Center (301) 816-5100 or as backup, (301) 951-0550) within one hour of discovery or within one hour of recovery. If appropriate, notify applicable law enforcement authorities.
Be prepared to provide support services as requested.
8.0 Export Requirements Not applicable.
9.0 Import Requirements Not applicable.
10.0 Recordkeeping Requirements 10.1 Security Plan WPI shall retain a copy of the current physical protection plan for three (3)years after the close of period for which WPI possesses the SNM under the site license for which the plan was established.
Copies of superseded material shall be retained for three (3)years after each change.
10.2 Response Procedures WPI shall retain a copy of the current response procedures, as a record for three (3)years after the close of period for which the procedures where established.
Copies of superseded material shall be retained for three (3)years after each change.
10.3 Export Shipment Records Not applicable.
lOA Import Shipment Records Not applicable.