ML20073E917
| ML20073E917 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/07/1993 |
| From: | Hill J LONG ISLAND LIGHTING CO. |
| To: | |
| Shared Package | |
| ML20062L485 | List: |
| References | |
| PROC-930707, NUDOCS 9409290313 | |
| Download: ML20073E917 (75) | |
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PROPRIEURY LONG ISLAND POWER AUTHORITY OPERATIONS PLAN FOR MARINE TRANSPORTATION OF FUEL SHIPMENT P
FROM SHOREHAM, NY TO EDDYSTONE, PA 1
A Approved By:
Resident Manager, Shoreham Project July 7,1993 Rev.0 j
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Long Isla:d P wer Authority Rev.0 Operations Plan For Marine Transportation TABLE OF CONTENTS Section 1.0 - Introduction Page 1 1
Section 2.0 - Marine Transportation Operation Plan i
2.1 Identity and Responsibility of All Parties Involved Page 2 2.2 Description of the Berth at Shoreham, NT Page 3 2.3 Description of the Berth at Eddystone, PA Page 4 2.4 Marine Transportation Route to Eddystone, PA Page 4 2.5 Weather Considerations Page 5 2.6 Description of Barge and Barge Gear Page 5 2.7 Description of Towing Vessel and Towing Gear Page 9 2.8 Regulatory Certificates and Licenses Page 10 2.9 Manne Operations Checklists Page 11 2.10 Communications Plan Page 12 2.11 Insurance Page 13 Section 3.0 - Marine Transportation Emergency Response (Contingency) Plan 3.1 Barge Drawing and Intact and Damaged Stability Studies Page 14 3.2 U.S. Coast Guard Page 14 3.3 Salvage Operations Page 15 3.4 Water Depths and Safe Harbors Page 16 3.5 Responses to Emergency Situations Page 17 3.6 Radio Failure and Emergency Communications Page 20 3.7 Emergency Response Training Page 21 Section 4.0 - Radiological Operations 4.1 Pre - Operational Activities Page 22 4.2 Normal Operations Page 22 4.3 Incident Operations Page 23 L
o Long Island Power Authority Rev.O Operations Plan For Marine Transportation TABLE OF CONTENTS (Con't)
Section 5.0 - Enclosures 5.1 Shoreham Intake Canal Soundings 5.2 Elevation and Grading of Shomham Intake Canal 5.3 Test Borings at Shoreham 5.4 Shoreham Barge Dock Drawings 5.5 Description of S.C. Loveland Barges, Load Line Documents and USCG Certificates of Inspection 5.6 Map of Route 5.7 Salvage, USCG, and Salvage Towers Contacts 5.8 Operations Checklists - Tug and Barge 5.9 2DM Associates Report No. 9315-401 " Specification for Manne Transportation of Irradiated Fuel 5.10 2DM Associates Report No. 9315-402 " Design Calculation Report - Design of Sea-Fastemngs for Marine Transportation of Fuel Casks - Shoreham, Long Island, NY to Eddystone, PA" 5.11 2DM Associates Drawing No. 9315-401 " Barge Leading Arrangement" 5.12 2DM Associates Drawing No. 9315-402 " Sea Fastening Details" 5.13 Certificate of Compliance for IF-300 Cask 5.14 Incident Notification Form 5.15 Supplemental Information Documents 4
Lang Islard P:wer Authority Rev.0 Operations Plan For Marine Transportation Page I of 24 SECTION 1.0 -INTRODUCTION This document details 6 olan for the marine transportation of 33 shipments of fuel from I.ong Island Power Authorst? 'LIPA) Shoreham Nuclear Power Station at Wading River, NY. De destmation of these fuea Aipments, is the Eddystone Power Suttion located on the Delaware River in Eddystone, Pennsylvania.
The fuel is identified as a highway route controlled quantity of radioactive material. It will be moved in Pacific Nuclear IF-300 fuel casks, numbers 301 and 302.
The primary hauling contractor for this project is Williams Crane & Rigging, Inc., Richmond, Virgmia. The water carrier is S.C. I.oveland Co., Inc., Pennsville, New Jersey. The engineer for the work is 2DM Associates, Inc., Houston, Texas. This plan and the associated engineering have been developed in accordance with ANSI N14.24-1985 American National Standardfor Highway Route Controlled Quantities of Radioactive Materials - Domestic Barge Transport (hereafter referred to as N14.24-1985). Where appropriate, definitions and information from that Standard have been incorporated into this plan.
This plan is organized in several major sections. Section 2.0 - Marine Transportation Operations presents a description of the equipment to be used and operations to be executed based on the anticipated conditions and desired end results. Included in this section is a description of the I
required communications activities to be performed throughout the transportation opention.
Section 3.0 - Marine Transportation Emergency Response (Contingency) Plan outlines appropriate activities to be performed in response to a number of potential emergency situations.
Section 4.0 Radiological Operations Plan outlines the normal and emergency response activities that will ensure that fuel shipment radiation levels are below applicable limits and any dose received is as low as reasonably achievable.
Under Enclosure 15, the Security Plan for Fuel Shipment is being provided. The Security Plan has been developed in accordance with 10CFR73.67 and has been submitted to the U.S. Nuclear Regulatory Commission for review and approval. The Security Plan details the in-transit physical protection and specific notification links that will mobilize response resources in the event of an incident affecting the shipments.
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Lars Isla:d Power Auth:rity
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Rev. 0 Operations Plan For Marine Transportation Pa'ge 2 of 24 SECTION 2.0 -
MARINE TRANSPORTATION OPERATION PLAN 2.1 Identity and Responsibility of All Parties Involved American Bureau of Shipping (ABS) The ABS is a non-profit, nongovernmental, international shipclassification society that establishes standards for the design, constmetion, and periodic survey of merchant vessels and other marine structures, ne regulations promulgated by the USCG appoint the ABS as the prime authority for assigning and issuing load line certificates.
Caprain of the Pon (COTP) The COTP is the officer of the U.S. Coast Guard (USCG) under the command of a district commander, so designated by the commandant for the purpose of giving immediate direction to USCG law enforcement activities within an assigned area. This USCG officer also has regulatory authority to supervise and control the transportation, handling, loading, discharging, stowage, and storage of hazardous materials. Additionally the COTP designates facilities for hazardous material operations.
Dese barge shipments will pass through the zones of the COTP long Island Sound, New York, and Philadelphia.
local law enforcement agency A local law enforcement agency (i.e., Port Authority police, state highway patrol, city police, or similar agencies) may assist or support NRC P
licensees in the physical protection of spent fuel.
Marine insurer ne marine insurer or underwriter provides financial protection to the shipper or carrier for non-nuclear events that involve the vessel and cargo. Coverage is available for propeny damage and loss as well as liability.
Naval architect A naval architect is an individual or firm with the technical expertise to design or analyze a vessel for the intended service, or to design and analyze the vessel.
The naval architect transforms codes, standards, regulations, and the requirements of the shipper or carrier into hardware.
2DM Associates, Inc. is providing naval architectural services to the project.
Nuclear insurer The private nuclear insurer or underwriter (or pools thereof) provides financial pivistion to the shipper, carrier, and any other directly or indirectly related g
party from liability or p+Ty damage or loss claims arising from the hazardous pivties of the radioactive materials.
Rigging company (rigger) The loading and unloading of the transport vessel, including the securing and unsecuting of the cargo, is generally carried out by a rigging company.
The tiedown arrangement, design, fabrication, and installation will be perforrned by the rigger, and the remaining unloading or loading operations will follow established procedures. The rigger for this project is also a specialimd heavy hauler and will provide transport vehicles to move heavy packages for short distances, in addition to the loading and unloading functions.
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Iang Isla:d P wer Authority R:.v. 0 Operations Plan For Marine Transportation Page 3 of 24 Williams Crane & Rigging, Inc. is the rigging company for this project.
Shipper ne shipper is the party that has the responsibility under Federal regulations for the radioactive materials being transported. In the commercial sector, the shipper is the Nuclear Regulatory Commission (NRC) licensee that has been granted permission to possess, utilize, and transfer the radioactive material. The shipper bears the additional i
responsibility for integrating the transport activities, although portions of this responsibility may be delegated to others. De shipper certifies to the carrier that the radioactive material being shipped is correctly identified; properly packaged, marked, labeled, and documented; and in proper condition for transportation in accordance with applicable regulations of the Department of Transportation (DOT). The shipper plays the principal role in the transfer of matenals.
Iang Island Power Authority (LIPA) is the shipper for this project.
U.S. Coast Guard (USCG) This military service within the DOT has been delegated the authority for waterborne safety. It promulgates and enforces rules and regulations that pertain to vessel design and operations, vessel manning, casualty investigation, navigational aids, and waterfront facilities. It also provides certam lifesaving and piwy piwwdon services. The COTP and the officer-in-charge, Marine Inspection are the local USCG offices with which a shipper and carrier of radioactive materials will I
deal. Dese offices are often combined under the commanding officer, Marine Safety Office (MSO).
The USCG office at New Haven is the Captain of the Port for Long Island l
Sound, and will coordinate the review and approval of this Operations Plan.
Water carrier The water carrier is the organization that supplies the barge, towing vessel, and crew. In this case, the water carrier will consist of a barge operator and a subcontracted towing vessel operator. De water carrier provides transportation services only. Imading and securing of the cargo is the responsibility of the shipper, although the function may be delegated to a rigging company by the shipper.
S.C. Imveland Co., Inc. is the water carrier for this project.
2.2 Description of the Berth at Shoreham, NY l
Enclosures 5.1 through 5.4 are drawings that detad the layout and construction of the intake canal and barge slip. De intake canal was formed by constructing two jetties (approximately 800') into Ieng Island Sound and digging a canal (approximately another 900') from long Island Sound up to the 'screenwell." The original " channel" of the canal was designed to be 78' wide and 12' deep at mean low water. According to.1, the channel is now 7' to 13' deep at mean low water. De mean range of the tide (from low water to high water) is 5.9 feet for the year and 6.8 feet for the spring. De mean tide level is 3.1 feet.
(These values are based on the U.S.
Department of Commerce 1992 tide tables for Herod Point, which is the closest reference point.)
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IAng Island Power Authority Rev.0 Operations Plan For Marine Transportation Page 4 of 24 ne jetties are constructed of concrete structures and 2-ton to 8-ton armor stone over core stone. The sloping sides of the channel portion of the canal have been stabilized by a covering of medium sized stones. Enclosure 5.2 (Excavation and Grading ofIntake Canal) indicates that there are no stones in the barge loading area next to the dock.
Dere is no evidence in Enclosure 5.2 that there is any stone on the fiat bottom portion of the channel. The borings which were taken in 1966 (Enclosu e 5.3) indicate the area 6
of the intake canal is naturally sandy. Dere is apparently no natural rock in the canal area so the barge operator would only have to be concerned about that rock which was placed in the canal to stabilize the sloping sides.
The Shoreham facility was constructed with a barge dock in the intake canal, ne dock is constructed of 24 concrete blocks which are 14'0" long x 10'0" wide x 2'-6" deep each. ney are laid to form a dock area approximately 48' wide (along the bank) and 28' deep in from the bank. Enclosure 5.4 is a plan of the barge unloading dock and surrounding area.
His dock area was modified several years ago to accommodate the " roll-off" of an overstzed piece of cargo (a transformer). De modification consisted of the construction of a " prepared bed". A prepared bed is a mound of small diameter stone which is dumped at the end of the slip and graded to conform with the shape of the rake plate of the barge. The barge may then be pushed up onto the prepared bed at high tide and P
ballasted with water to keep it in place. The bed is engineered so that the deck of the barge will be nearly equal in height to the surface of the dock. The cargo can then be transferred between the barge and the dock by simply rolling it on or off the barge using -
an appropriate vehicle. Enclosure 5.2 details the construction of the existing prepared bed, ne prepared bed has been used successfully for roll-off operations numerous times over the past several years, ne current condition has been reviewed and no modifications are required.
2.3 Description of the Berth at Eddystone, PA ne barge dock at Eddystone is a part of Philadelphia Electric Company's (PECO)
Eddystone Station. De dock is located to the west of the waste-water treatment plant discharge, ne top of bulkhead elevation is 12.0 feet above mean low water. Water depth at low tide is approximately 9 feet at the bulkhead. De mean range of the tide (from low water to high water) is 5.7 feet for the year and 6.0 feet for the spring. The g
mean tide level is 3.0 feet. (nese values are based on the U.S. Department of Commerce 1992 tide tables for Chester, PA, which is the closest reference point.)
Structural and soil analysis of the dock area will determine whether the barge will be unloaded by a heavy lift rigging crane or a roll-off method.
Any structural improvements necessary will be completed prior to the commencement of shipping operations.
2.4 Marine Transportation Route to Eddystone, PA g
De tug and barge shall exit the Shorehau fae ity and proceed east in Long Island Sound r
antil reaching Block Island Sound. An escort tug will accompany the shipment during
Long Island Power Authority Rev.0 Operations PlIn For Marine Transpsrtatlan Page 5 of 24 the Long Island Sound portion of the shipment. The tug and barge will then pass Montauk Point (the eastern tip of Long Island) and then turn south into the Atlantic Ocean. The tug and barge would proceed south-southwest in the ocean on an essentially straight-line course to the Cape May-Delaware Bay buoy, around Cape May, through the Delaware Bay, ar.d up the Delaware River. The tug and barge will travel north in the Delaware River to Eddystone, PA. There are no scheduled intermediate por:s of call on this tow.
A list of safe harbors is provided in Section 3.4.2. The water depths over which the tow will travel are also listed in Sectiori 3.4.1..6 is a map of the Eastern Seaboard showing the tow route from Shoreham, NY, to Eddystone, PA.
2.5 Weather Conditions h
Williams Crane & Rigging, Inc. will have the primary input regarding weather conditions that affect the loading and unloading of the barge. Particular consideration shall be given to the presence of heavy rain, ice, or snow which will affect the safety of any attempt to perform a roll-on or roll-off operation and extremely high winds and/or high currents j
that would impair the ability to maintain the barge in a stable condition. If conditions at i
Eddystone do not allow immediate unloading, the barge and tug will tie up dockside at Eddystone.
Weather conditions and forecasts will be monitored by Williams Crane & Rigging and Loveland on a regular basis during the performance of this project to assure advance knowledge of changing weather that could adversely affect the work.
Strong winds and high seas are the two principal concerns of the mariner. The water carrier, the towing company, and all parties concerned will verify that the marine forecast calls for winds below 40 mph, Beaufort Scale #8 during the expected term of the voyage (estimated to be 50-60 hours). The USCG will be contacted regarding weather parameters for the trip. Once the tow is underway, the towing vessel Master will closely monitor the local and long range forecast. The vessel Master always has the sole authority to bring the tow to a " safe harbor" for adverse weather or any other reason.
2.6 Description of Barge and Barge Gear i
The barge will be provided by S.C. Loveland Co., Inc., located in Pennsville, New Jersey. The nominated barge is the Loveland 1721 series deck barge (numbers 1721 through 1726). These barges are of steel construction with 18 watertight compartments.
The overall length is 172'-6", the beam is 43'-6", and the molded depth is 10'-9". The bow rake is flat with a slope of about 3.4 : 1. The stern rake is similarly sloped and has two skegs. The deck is flat with neither sheer nor camber. The bottom between rakes is flat. A drawing of the barge construction is shown on Enclosure 5.5.
The ANSI N14.24-1985 addresses vessel and equipment requirements. They are as
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follows for the barge:
Long Island Power Authority Rev.O Operations Plan For Marine Transportation Page 6 of 24 2.6.1 Ioad Line Document This voyage will transit areas that are more than 20 miles offshore, therefore the barge will have a load line cenificate for ocean senice.
The load line document for the Loveland barge showing its ABS cla.ss as A-1 Ocean Service is attached in Enclosure 5.5.
2.6.2 USCG Cern]!cate ofImpection His is a certificate issued by the USCG when they complete their periodic inspection of the vessel, indicating that the vessel is still suitable for coastwise (within 20 miles of the coast) or oceangoing (beyond 20 miles) service. He Certificate of Inspection for the I.oveland barge is attached in Enclosure 5.5.
2.6.3 Barge Iength Barges used for the transport of RAM packages shall be no less than 125 feet in length. He nominated barges are 172'-6" in length, thus meeting this requirement.
2.6.4 Intact Stability Intact stability refers to the behavior of the barge under various loading conditions in the absence of any hull damage. Intact stability shall be m*uad in accordance with 46 CFR 170 (Subpart E of 46 CFR 172 [6] for a Type II hull under 46 CFR, Subchapter O). Intact stability calculations are contained in 2DM Associates Repon Number 9315-402 and demonstrate that the barge meets the requirements. His report is attached in Enclosure 5.10.
2.6.5 Damage Stability Damage stability refers to the behavior of the barge under various loading conditions with defined hull damage. Damage stability shall be assessed in accordance with the rules for a Type II barge hull under Subpan E of 46 CFR 172. These rules specify a one compartment standard, which requires that, following damage to any one companment in the barge, the vessel will still meet specified margins of safety and not sink or capsize. Damage stability calculations are contained in 2DM Associates Repon Number 9315-402 and demonstrate that the barge meets the requirements. This report is attached in.10.
2.6.6 Stowage All casks (excluding the vehicle used to transport the cask by truck if same is transported with the cask on the barge) must be located a minimum of B/5 inboard from the side of the barge, where B is equal to the beam of the barge. On the Loveland 1721, this equates to the cargo being stowed at least 8'-
8" from each side. 2DM Associates Drawing Number 9315-401 *Earge Loading Arrangement" Enclosure 5.11, shows the set-back of the cask, including its support frame, to be in excess of 15 feet from the side.
ne casks, excluding vehicle, shall also be stowed abaft the forward perpendicular
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and foreword of the stern a minimum of 0.495 L" where L is the length of the barge. For the Loveland 1721, the cargo must be stowed at least 15'-4" aft of the forward perpendicular and 15'-4" forward of the stern. 2DM Associates Drawing Number 9315-401 " Barge Loading Arrangement" shows the position of the cask, including its support frame, to be in excess of 67 feet abaft the forward g
perpendicular and 45 feet forward of the stern.
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Long Island Pow:r Authtrity Rev.0 Operati:ns Pirn Fcr Marine Transp:rtati:n Page 7 cf 24 He cask shall be loaded on board in accordance with the positioning shown on 2DM Associates Drawing Number 9315-401 " Barge Loading Anangement".12.
De deck strength, stability, and static analyses in 2DM Associates Repon Number 9315-402 are all based on this position. De sea-fastening requirements noted in N14.24-1985 are addressed by the design 1
calculations in 2DM Associates Repon Number 9315-402. The barge shall be exclusively used for the shipment of the cask and associated equipment.
6 2.6.7 Manning Barges which transpon oversized cargo are unmanned. Radiological health personnel shall accompany the cargo on the primary towing vessel.
2.6.8 ANSI N14.24-1985 also details " required" and " suggested" equipment for the barge. Required equipment shall be provided without exception. The suggested equipment is not considered applicable and will not be provided for this shipment for the reasons stated in section 2.6.8.2.
2.6.8.1 Required Equipment Emergency Position indicating Radio Beacon (EMRB)
The EPERB is a vessel-mounted, radio-signal-transmitting device that is water actuated and aids in the location of a barge that has sunk. The Class A EPIRB floats free from the sunken vessel (i.e., it is untethered), thus its ability to precisely locate the barge D
strongly depends on ocean conditions and emergency response time. For this standard, an EPIRB shall be a Class A unit having a minimum operating time of 10 days. Design, location, stowage, operation, maintenance, and approval of this device shall be in accordance with 46 CFR 161.011 and 46 CFR 94.60.
i Radar Reflector This barge mounted passive device amplifies the return signal to impinging radar. Such a reflector will make the barge more " visible" to other traffic during normal operations and will aid in the location of the barge should it come adrift. De radar reflector shall be mounted on the barge or package no less than 20 feet above the waterline. Mounting shall be designed to withstand the collision and wave action accelerations of N14.24-1985.
Emergency Towing Wire A suitably sized emergency towing wire fastened to i
towing bitts or pads, shall be carried aboard a barge that is towed offshore. This wire runs aft, being affixed to the breakable tiedown points on the pon or L
i starboard deck edge.
A small buoy or length of floatable line (such as polypropylene), attached to the end of the wire trails behind the barge. If the main towing wire breaks, the towing vessel can fall behind the barge and retrieve the end of the emergency towing wire breaking the tiedowns holding it to the deck. This emergency towing wire can then be used to bring the tow to a safe harbor. The emergency towing wire should be approximately 300 feet long.
Sonic Signaling Device A sonic signaling device, or " pinger," is an underwater locating transmitter that remains with the sunken barge. The signals emitted by i
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I. mag Island PowGr Authority Rev. 0 Operations Plan For Marine Transportation Page 8 of 24 this equipment permit accurate. location but are limited in range (i.e.,
approximately 1 mile). Special receiving equipment is required on the search vessel.
For this project, the sonic signaling device shall have a minimum operating time of 30 days.
2.6.8.2 Suggested Equipment
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Row Mounred Ereakwater The breakwater is a structure that is used for oceangoing tows to deflect waves coming over the bow, thus offering some degree of cargo protection. A breakwater is not==7 for these tows and, as the roll-on and roll-off operations will be done over the bow, a breakwater is not desirable (a removable breakwater would be necessary). The stated requirement that the tow seek a safe harbor in the event of heavy weather will effectively avoid the possibility of wave damage to the cargo.
Redundant Tow his technique uses two towing cables instead of one so that the barge will not come adrift in the event of the failure of a single tow line. A double tow cable (hawser) is not common practice on the East Coast and is not necessary or desirable for a tow of this relatively short distance. De barge will be fitted with an emergency towing wire (paragraph 2.6.8.1, above).
I Renore Controlled Anchor his device allows the towing vessel operator to release an anchor and line mounted on the barge in the event of the failure of the tow line. ne remote contrelled anchor is only effective in waters less deep than this tow will be traversing. Dus, this is not an effective tool for this movement.
Air Idenn]fcation A distinct marking on the deck of sufficient size that it can be identified from low flying aircraft. His is redundant in view of the requirement for a radar reflector.
Real Time Motion Monitoring His involves WW equipment that is installed on the barge to measure the forces, motions, or accelerstions to which the barge is subjected. De data is recorded and analyzed in the wheel-house of the towing vessel. As there will be no fragile equipment on the barge during the tow, and because the tow will seek a safe harbor in the event of heavy weather, motion monitoring is not==7 I
Radar 7ht=Wr nese electronic devices emit an encoded identification signal that is visible on marine radar sets. If mounted on the barge, this equipment would facilitate recc,vsry of the barge in the event the tow line fails under poor visibility condidons. The transponder can also be used to monitor both the alignment and proximity of the barge relative to the towing vessel. nisis redundant in view of the requirement for a radar reflector.
2.6.9 Williams Crane & Rigging shall remove all sea fastening and restore the barge upon completion of shipment operations.
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IAng Island Pow:r Auth:rity Rev.0 Operations Plan For Marine Transportation Page 9 of 24 t
2.7 Description of Towing Vessel and Towing Gear
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Towing Vessel - The towing vessels shall be supplied by S.C. Loveland Co., Inc. There will be an additional tug of at least 200 horsepower used for shiftirg at Shoreham and/or i
escort in I.ong Island Sound. ANSI N14.24-1985, Section 6.4, details several requirements for the towing vessels. These requirements will apply to the " principal towing tug".
I 2.7.1 Morbe Power Towing vessels will be of suitable size and horsepower to maneuver the barge under the most adverse weather, tidal, and current conditions.
I The principal towing vessel shall be twin screw and have at least two propulsion engines, each capable of powering the towing vessel. Vessels with a minimum
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of 1,300 horsepower will be used in order to assure suitable power in the event j
of heavy weather.
1 2.7.2 Cernfcarions and kpections The principal tug shall have a current ABS load line certification.
2.7.3 Towing Gear The towing gear and cable shall be inspected by the vessel Master prior to departure of the loaded barge and shall be free of defects that might impair their functioning. There are several methods of connectmg the tug to the barge. The method used will be at the discretion of the tugboat vessel Master i
based on whether the tow will proceed inland, in calm seas, where the tug can make up directly to the barge, or offshore, where seas are high and a hawser must be used.
2.7.3.1 G reen The tug will run a metal cable, or a nylon hawser, from the tug to a "fishplate". The fishplate is a steel plate which connects the main tow hawser to a pair of " bridles". The two bridles are made of chain or wire and run from the fishplate to a bitt at each corner of the barge. A 9" nylon hawser (1,200 feet in length) or 2* diameter steel cable (1,500 feet in length) will be used for the main towing hawser. The shackle size is 35-ton to 50-ton capacity and the fishplate will be 2" thick steel plate.
Bridles will be 1 1/4" to 1 1/2" chain or wire strength equivalent.
The tug will carry a spare hawser equal in size to the original.
I 2.7.3.2 Inland On the inland portion of a tow, the tug will make up to the barge by either:
laying alongside the barge and tightly tying ropes between the tug and barge so that they act as one unit when underway; or, butting the nose of the tug against the stern of the barge and tying lines or cables from the port and starboard after barge bitts to the after quarter bitts on the tug. The lines or cables will be secured g
so tightly that the tug and barge will maneuver as one unit.
I.4ng Island Pooer Authority Rev.0 Operations Plan For Marine Transportation Page 10 of 24 2.7.4 Navigational Aid The principal towing vessel shall be equipped with radar, LORAN C or SATNAV, magnetic compass with deviation table, gyrocompass, charts and publications specified in 33 CFR 164.33 (corrected charts of areas to be transitted, U.S. Coast Pilot, USCG Light List, tide tables, and current tables).
2.7.5 Communications De principal towing vessel and its dirhing office shall have 6
appropriate communications equipment with the proper frequencies. For the tug, this shall include, but not be limited to, at least two permanently mounted VHF radios, a cellular telephone, and an HF radio, all of which are capable ofinland and coastal communications. Such communications redundancy will be provided to compensate for equipment failure.
2.7.6 Manning The crew of the towing vessel shall be in accordance with the regulations contained in 46 CFR 156 and 157 and applicable USCG and vessel inspection circulars. As a minimum, the tug shall be manned by a master and mate (licensed for near coastal route and the tonnage of the tug in accordance with USCG regulations), an engineer, and two deckhands.
2.7.7 Health Physics Technician An individual trained in the principles of health i
physics and equipped with appropnate radiation detection instruments shall be present during barge loading and unloading. A health physics technician shall y
accompany the shipment and shall ride aboard the primary towing tug.
2.7.8 Marine Personnel Training The crew of the principal towing tug, and a
representative from the tower's operations staff will be trained in Security Plan and Operations Plan details. Such training should take approximately four hours and is described in Section 3.7.
2.8 Regulatory Certificates and Licenses 2.8.1 Barge All barges used have a current ABS load line certificate for ocean service (paragraph 2.6.1) and a current USCG inspection certificate for ocean service (paragraph 2.6.2).
2.8.2 Thg De primary towing vessels have a current ABS load line certificate (paragraph 2.7.2). Tugs are not required to be USCG inspected unless they g
exceed 300 gross tons.
2.8.3 Ucenses Marine licenses are issued by the USCG after the mariner has served a lengthy period of apprenticeship and passed a series of tests and a physical examination. De master and mate of all towing vessels used in this project will be licensed by the USCG in accordance with the gross tonnage of the tug and for the route which the tug will follow. (For instance, if the tug is 125 gross tons ar.d the track of the voyage will take it up to 100 miles offshore, then the licenses of the master and mate must be for towing vessels in excess of that tonnage and distance offshore.) De deckhands are unlicensed personnel. The engineer is not required to be licensed unless the tug is over 200 gross tons.
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Imag Island Power Auth:rity Rev.0 Operations Plan For Marine Transportation Page 11 of 24 2.8.4 ICC Operating Authority and Tanf Part 3 oi the Interstate Commerce Act vests the ICC with the authority to regulate water carriers with respect to operating jurisdiction and rates. Water carriers who move cargo between states must possess a valid ICC Certificate granting operating authority for the cargo and the route intended. S.C. Ioveland Co., Inc. holds such an ICC Certificate.
p Prior to a gaiMi=4 move such as those covered by this plan, the carrier (Loveland) shall file a tariff with the ICC or execute an agreement of affreightment in advance of the shipment. Upon approval, the tariff or agreement binds the carrier to the rates and conditions contained therein.
2.8.5 Norryfcarions Pre-shipment notification by Loveland will be sent to the cir*=in of the Port, Iong Island Sound. As this shipment will be defined as " highway route controlled," this notification shall include the date of the proposed loading so that the COTP may have the option of having his representative present during the loading process.
Ioveland will also notify the COTP Long Island Sound 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in advance of j
departure in accordance with 33 CFR 160.213.
Pre-arrival notification will be made to the CCTTP, PhihMphia.
Prior to p
departure, Loveland will also notify the USCG Port Safety Officers in the USCG Districts enroute. (see Enclosure 5.7 to this report for a listing). They will be provided with the name of the principal towing tug and dates during which the tow is anticipated to be in the waters of their District.
There are various notifications which will be made by LIPA. Federal regulations i
prescribe specific notification requirements in advance of shipment of certain radioactive materials. In accordance with 10 CFR 71.97, the NRC and the governor (or governor's designee) of the states entered or passed through in the course of transport of certain quantities of RAM by NRC licensees shall be notified in advance of the shipment. The shipment's consignee shall also receive advance notification in accordance with DOT regulations.
2.8.6 1%el Cask 'Ihe IF-300 fuel shipment cask has a Certificate of Compliance issued by the U.S. Nuclear Regulatory Commission. (See Enclosure 5.13)
I 2.8.7 State Regulations 'Ihe barge will be passing through the waters of New York, New Jersey, Delaware and Pennsylvania. A Certificate of Handling will be obtained as w='y for the State of New Jersey in accordance with Title 7 chayer 28 of the New Jersey Administrative Code. The other states do not have an equivalent requirement.
2.9 Marine Operations Checklists Prior to each voyage and prior to leaving port during the voyage, the towing vessel Master shall inspect the barge and the towing vessel.
The inspection shall be I
documented using a checklist that requires reviewing the condition of all marine safety
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Ieng Island Power Authcrity Rev.0 Operations Plan For Marine Transportation Page 12 of 24 related items and indicating whether the conditions are deficient or satisfactory.
Deficient conditions shall be resolved before leaving port. Separate checklists shall be used for the barge and towing vessel. Each checklist shall identify the barge or the towing vessel, the crew, the location and date of the inspection, and it shall be signed by the operator. Copies of the completed checklists shall be provided to the COTP (in the port that the tug is departing), as required. A copy of each completed checklist shall p ~
be maintained on the towing vessel for the entire voyage. LIPA shall retain a copy of each inspection report in the shipment record file. Operations Checklists for the tug and the barge are attached in Enclosure 5.8.
2.10 Communications Plan In accordance with ANSI N14.24-1985, communications shall be made between the towing vessel and predetermined shore installations at frequent intervals established by LIPA and Loveland, but not exceeding 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
Dere are two types of marine radios generally used by towmg vessels. He VHF set is used for short distance communication (often referred to as "line of sight").
Communications between the bridges of two vessels which are passing one another are made on a VHF radio. The effective distance for a VHF set varies according to the height of the antenna (of both the sending and receiving sets), the weather conditions, y
and the presence of obstructions (skyscrapers, hills etc.) bets. the sender and the receiver. Even between two vessels on the open ocean, in good weather, the signal will not go over the horizon, limiting the effective range to about 20 miles.
Many VHF channels are assigned by the FCC. There are " working channels" reserved for use by tug operators, commercial fisherman, and other workboat and passenger boat operators. There are also VHF channels reserved for the USCG (channel 22), marine telephone operators, traffic service, search and rescue, and continuous weather broadcasts (among others). Channel 13, for example, is the channel used for initiating " bridge to bridge" communications with another vessel and channel 16 is used for " calling and distress" (cmergencies). Most tug companies use a local " house channel" with which they continually communicate with their tugs. The actual VHF frequencies used between the tug and its office will be determined by the towing company which is selected to tow the barge.
I De VHF signal can be " extended" by use of the marme operator. When near the coast or on an inland waterway, the tug can call a marine operator who will patch the call through telephone lines to the desired party. Marine operators are located at intervals along the coast and near large tributaries such as the Delaware Bay. The tug must still be within about 20 miles of the coast to reach a marine operator.
The HF radio is for long distance communications. He HF signal bounces off the upper atmosphere, returns to earth and bounces back to the atmosphere in a continuing cycle
("/VW). HF signals can be picked up for hundreds (or even thousands) of miles.
Reception of HF signals is not absolutely reliable, however. Atmospheries such as sunset, solar flares, and lightning can make an HF signal unreadable, ne strength of I
ne signal is also relative to the proximity of the receiving station to the location where
Long Island Power Authority Rev.0 Operations Plan For Marine Transportation Pass 13 cf 24 the signal returns to earth. HF transmissions are usually made at a predetermined time, and on a predetermined frequency, so that the receiving station will be listening for the sender.
Experience with long range HF transmissions indicates that the signal is successfully sent and received about 75% to 80% of the time.
The primary towing tug will have a cellular phone. 'Ihis system is very reliable when in range of a cellular station. The available cellular systems cover a great deal of the metropolitan area, but have very little coverage over the water (particularly in the ocean).
i It therefore suffers from the same problem as VHF: the tug must be in close proximity (about 24 miles) to the coastline or transmission will not be received.
There will be three types of communications taking place during these voyages:
1.
Communications with the tug's office (dispatcher) on 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> intervals (or less) giving the tow's position, speed, and estimated time of arrival (ETA). The tug's office has the equipment and experience to maintain contact with the tug. The tug's office shall then telephone the LIPA Notification Point at set times with a progress report.
2.
When in VHF range, the tug shall advise each USCG COTP when he enters or leaves, or at such other times prescribed by the USCG COTP. The VHF channels used by each Group are listed in Enclosure 5.7. When the tug is out of
)
range, the tug's office will make the USCG notifications by phone based on HF radio contact with the tug or the best ETA of the tug's arrival into or departure from the COTP zone.
3.
Bridge to bridge communications when in close proximity to other vessels as required by law.
The tug will contact his office and the local COTP immediately if any emergency situation arises which could affect the safety of the vessels or the cargo. These communications are covered in more detail in the Security Plan for Fuel Shipment.
2.11 Insurance ANSI N14.24-1985, Section 6.7, provides a discussion of the insurance coverage required of a prudent shipper and water carrier. The Loveland Company or the tower I
will provide the following insurance coverage (as described in N14.24-1985) with limits satisfactory to the Loveland Company and the LIPA: hull insurance on the barge and tug, including primary collision liability; primary Protection and Indemnity; tower's liability; cargo legal liability; and wreck and removal (salvage insurance).
4
4 14ng Island Power Authority
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Operations Plan For Marine Transportation Rev.O Page 14 of 24 SECTION 3.0 -
MARINE TRANSPORTATION EMERGENCY RESPONSE (CONTINGENCY) PLAN 1
3 3.1 Barge Documentation and Intact and Damages Stability Studies ANSI N14.24-1985 requires that stability analyses for both intact and damaged condit be performed and that the barge meet certain acceptance criteria. These requirem are more fully discussed in paragraphs 2.6.4 (intact stability) and 2.6.5 (damage stability), above.
The required calculations, which show satisfactory results, are contained in 2DM Associates Report Number 9315-402, Enclosure 5.10.
The shipping papers shall be kept aboard the towing vessel, including the bill dangerous cargo manifest, and emergency response guidance. In the event the needs to be moored or tied up, the tugboat will remain near-by. In addition, all ship papers and package documents including those of the sea-fastenings, shall be available at the LIPA Notification Point.
In the event of an emergency involving structural damage to the barge, information ab i
the vessel's construction will be immediately required. A drawing of the Loveland 1721 I
series barges is included in this plan in Enclosure 5.5.
3.2 U.S. Coast Guard During early planning for this project, contact was made with the Captain of the Port f Long Island Sound, who has authority over the loading site at Shoreham and the trans through long Island Sound. 'Ihe COTP Long Island Sound shall coordinate the review of this Operations Plan. Subsequent contacts have been made with the COTPs listed below:
Office Contact Phone 24 Hr Phone VHF Station Station LI Sound Ledr. Skewss 203-468-4464 203-468-4464 16 g
(LA. Schroder)'
(Group Moriches CH 23)
New York Capt.12rabie 212-668-7932 212-668-7936 13 and 16 (Lt. Shatinsky)
Philadelphia Capt. Guldenschuh 215-271 4940 215-271-4940 13 and 16 (Lt. Kuhaneck) 4
)
The USCG shall rlws.. have the final input in matters of weather, navigation and emergency response.
IAng Island P wer Authority Rev.0 Operations Plan For Marine Transportation Page 15 of 24 3.3 Salvage Operations 1
Two separate types of manne salvage may be required in the event of a casualty.
3.3.1 Salvage Towing j
i If the tug had a dual engine failure, or the barge broke away from the tug and could not be located, additional towing power will be needed.
i Depending on the position of the casualty, the owner of the principal towing tug may have one or more tugs ready to respond to the emergency, l
particularly in the case of engine failure of the tug. If the barge has broken away and cannot be located, or if the owner of the principal l
towing tug is not in a position to respond, a tower experienced in towing salvage will be called.
Moran Towing is a well located and equipped salvage tower that is situated to handle a towing emergency. Moran was a partner in Ocean Salvors, a salvage company with operations in many areas of the U.S.
Although that venture was closed several years ago, their personnel.are familiar with ocean and inland recovery and salvage techniques. They have recovered many tugs and barges adrift in the North Atlantic and j
brought them safely to port. They have large tugs stationed in New York and Philadelphia. A list of their equipment and the 24-hour phone i
numbers of each office is attached as Enclosure 5.7.
3.3.2 Traditional Salvage Operations Any casualty which affects the watertight integrity of the hull of either the tug or the barge will require the assistance of a full service salvage company. A traditional salvage company has large pumps, floating cranes, air compressors, gear for removing beached vessels, large winches, and many other types of salvage gear. His gear is kept on hand so that the salvage company is ready to immediately respond to many types of emergencies. More importantly, they have personnel on staff who are experienced with salvage operations including divers, crane operators, engineers, and salvage masters.
I Donlon Marine, based in New York, has held the U.S. Navy Salvage contract for the Great Iakes, Atlantic Ocean, Gulf of Mexico, and other areas since 1979. ney have two heavy lift cranes (220-ton and 1,000-ton capacity) and three tugs (1,200,1,800 and 7,000 HP) in New York. Dey also have heavy winches, various oceangoing barges, beach gear, and other related salvage equipment ready to be moved to the site of a casualty upon notice. This firm has experience in virtually every type of salvage (raising sunken vessels, removal from a beach, bridge collisions, pumping sinking vessels, etc.) neir New York base is not a serious disadvantage if a casualty should occur further south. Much of their equipraent is I
portable (by tr.ickt and they have working relationships with owners of 4
Long Island Pzw:r Authority Rsv. 0 Operations Plan For Marine Transportation Page 16 of 24 barges, cranes, and other equipment which cannot be trucked. Rey also own a hazardous materials pollution control fir:n (Cycle Chem) with offices in Cartaret and Minheth, NJ, and in Swed=o which is in southern New Jersey.
Salvage companies have various ways of charging for their services but in the case of this movement, Donjon would consult with the underwriters and barge company representatives and the local office of the USCG, and then respond to the casualty with all the equipment that they, the USCG, and the surveyor felt was needed to resolve the emergency. After the emergency was concluded Dortion would negotiate a rate for the services performed. De rate would be loosely based on manhours and equipment utilirM, but Donjon (or any other salvage company) would be entitled to a premium over and above the rates charged for manpower and equipment in a normal operating environment. His premium is camed as a result of the risks they take in the performance of their job and the cost of equipment and manpower which must be kept on idle standby waiting for the next emergency. Here is no fee unless a casualty occurs (salvage companies are not put on " retainer") but the fees charged if they do have to respond will vary according to the location of the job and the manpower and equipment needed to conclude the emergency.
In the event of an emergency where the hullintegrity of the barge and the i
tug are not threatened, such as barge breakaway or mechanical failure on i
the prmeipal towing tug, Moran may be called for towing assistance. For I
any other type of marine casualty, Donjon may be called to manage the salvage effort, j
(
Telephone numbers of secondary towers, salvage companies, and USCG l
i Group contacts are also listed in Enclosure 5.7.
3.4 Water Depths and Safe Harbors I
3.4.1 Water Depths Along the Route he IF-300 cask has been calculated to maintain its integrity to a depth of 1
400 feet. He water depths (at mean low water) along the tow route are I
as follows:
Approach to Shoreham Jetties 6' - 15' Iang Island Sound, East of ShRam 75' - 150' Plum Gut 190' Block Island Sound 80' - 100' i
Montauk Point 30' - 60' Montauk Point to Delaware Bay Entrance 60' - 200' Delaware Bay 40'-125' t
Delaware River (channel) 39'- 43' e
i i
r
-.--c-
Long Islaed Power Authority Rev. 0 Operations Plan For Marine Transportation Page 17 of 24 3.4.2 Safe Harbors New York is the safe harbor along the intended route. De vessel Master will contact the COTP New York to identify an anchorage should the need arise to use this safe harbor.
P 3.5 Responses to Emergency Situations The responses outlined below are those which are recommended for consideration after consultation with towers and others. It is noted that this list of responses i
is principally for the benefit and education of non-marine personnel. He actual 1
action taken at the time of the casualty will depend on many factors such as weather, USCG input, salvage equipment available, location of the tow, etc. De i
variables are too numerous to analyze individually and this plan lists only the single response that is assumed to be most appropriate in a majority of the potential situations. Bis list is not intended to limit the parties involved in the event of an actualincident.
In the event of an emergency during barge movement, the carrier shall notify the nearest salvage (or towing) company, the nearest COTP, the COTP Philadelphia and the Coast Guard National Response Center and the LIPA Notification Point P
using the Incident Notification Form Enclosure 5.14. Personnel at the LIPA Notification Point will verify that the Coast Guard has been notified and will notify other government agencies. Based on the details of the incident, LIPA will mobilize response personnel in coordination with the Carrier.
3.5.1 Broken Hawser If the weather is good (calm seas), the tug will retrieve the broken hawser, back up under the bridles and reattach the spare hawser which will be carried aboard the tug. In this event, the tow would continue directly to the destination. If the weather is bad, the tug would fall behind the barge and retrieve the floating line which trails behind the barge and is anached to the end of the emergency towing wire. De emergency pickup wire is attached to breakable points on the side of the barge. As the tug pulls the end of the wire, from aft to foreword, it releases from the attachment points and the end is left attached to the towmg bitts on the bow of the barge. His wire or rope I
g is much shorter than a normal hawser and the tug should proceed to.the nearest port of refuge unless he is able to reattach his spare full-sized hawser while underway.
If the tug is unable to immMintdy reconnect the hawser to the barge, the master shall keep a constant log of the barge's position and notify the USCG and LIPA. It is possible that contact will be lost with the barge in heavy weather or darkness. The salvage tower will be ordered to the scene immediately.
3.5.2 Listing of the Earge ne barge will be ewed with a slight amount of g
" aft drag" (e.g., the cargo should brstowed as shown on 2DM
_ = - - -
Ieng Island Pow:r Authrrity i
Rev. 0
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Operations Plan For Marine Transportation Page 13 of 24 Associates Drawing No. 9315-401 " Barge Leading Arrangement" so as to produce a trim to the stem). This drag allows the stem of the barge to act as a fixed rudder, making the barge more controllable while bemg l
towed on a hawser.
l Other than " aft drag," the barge should not have any type oflist to port l
or starboard or any change in draft. The Barge checklist (h4==e 5.8) requires the tug master to check the drafts prior to departure and upon entering port to seek safe refuge. When pushing the barge, the tug will j
be next to the barge and a change in draft will be easily observable.
When the barge is being towed on a hawser, however, it will be hundreds of feet behind the tug and constantly moving up and down with the wave action. (Part of the tow will also be at night.) Changes in draft will be extremely difficult to detect until the change in draft is extreme enough to be visible from the tug or the Master begins to notice changes in the way the barge is handling on the hawser.
If a change in draft is suspected, the tug will pull in enough hawser to examine the barge at close range. If the Master believes a change in draft has occurred, he should head for the nearest port of refuge and notify the salvage company immediately. Pumps and asstst tugs should p
be made immediately available if there is any sign of a change in dnft.
If the barge appears to be in imminent danger of sinking, the tug will disconnect the hawser, and the Coast Guard and/or the salvage contractor can fly pumps to the site of the incident. Two 2" pumps will be carried by the principal towing tug in the event of an emergency.
3.5.3 Failure ofOne or Borh 7hg Enginer If one tug engine fails, the tug will proceed to the nearest port of refuge. If failure of both engines occurs, the tug will standby the barge. If the owner of the primary towing tug has a nearby replacement tug of suitable power and classification available, he should be allowed to provide same. If these replacement tugs are too far away or are otherwise unsuitable, the salvage company must be called to bring the principal towing tug and the barge to the nearest port of refuge.
g 3.5.4 Heavy Weather If winds and seas are permissible upon departure but increase during the voyage, it would normally be up to the Master of the tug to determine when the tow should be brought to a safe harbor. In j
the case of this cargo, the tower will set the maximum wind and sea conditicas under which the tow can proceed at sea. It should be understood that the Master of the tug always has the sole authority to i
bring the tow to a safe harbor for adverse weather or any other reason.
3.5.5 Shifting Cargo or Damage to the Package
'Ihe barge checklist (Enclosure 5.8) requires the Master of the tug to inspect the cargo and g
the lashings prior to departure form Shoreham av at each post of refuge. When pushing the barge, the tug will br. nc-e the barge and l
Long Island Pow:r Auth:rity Operati:ns Plan For Marine Transp:stati:n Rev.O Page 19 ef 24 a change in the cargo will be easily observable. When the barge being towed on a hawser, however, it will be hundreds of feet behind the tug and changes in the sea-fastenings or radiological condition of cargo will be extremely difficult to detect. (Past cf the tow will also be at night.) If a change in the cargo package or the lashings is susp the tug should pull in enough hawser to examine the barge and the c at close range.
9 3.5.6 Secur*y Threat Security response details are contained in the Plan 3.5.7 Damage to the Hull of the Barge Refer to paragraph 3.5.2 above j
(Listing of the Barge) for the appropriate response actions.
3.5.8 Fire or Damage to the Hull of the Tug orBarge The Master of th\\
shall notify the USCG immediately. A replacement tug, either from the owner of the principal towing tug or the salvage contractor, shall be ordered.
The services of the salvage contractor may be required depending on the extent of damage to the tug. Note: All tugs have fire fighting equipment and the crews are trained in fighting fires.
y Fire aboard the barge is extremely unlikely as there will be no combustible material aboard.
3.5.9 Sinking ofthe Tug If the tug sinks, the crew may try to board the tow.
The USCG will be called to respond to rescue the crew. A replaceme tug shall be ordered from the owner of the principal towing tug or the salvage company. A salvage company chosen by the owner of the principal towing tug will be employed to raise the sunken tug.
3.5.10 Sinking ofthe Barge When the barge is in imminent danger of the tug will release the hawser and remove any men aboard the bar After the barge sinks the tug will record the location where the barg went down and standby at that location until relieved by the salvage contractor. The salvage contractor shall handle underwater location of the barge (using the signals emanated by the " sonic signaling device" I
the EPIRB) and the efforts to raise the vessel.The sea fastening requirements in ANSI N14.24-1985 and as applied to the sea-faste design for this project state that the cargo will be secured in such a manner that the cargo will not separate from the barge in the event of sinking. The cargo will, therefore, be salvaged with the barge.
3.5.11 Grounding or Beaching of the Barge If the barge is put aground or breaks away from the tug and runs up on a shoreline, the salvage contractor and the nearest USCG Group shall be notified by the master of the tug. The salvage contractor shall be contacted by the principa l
towing contractor and shall coordinate all efforts to free the barge.
Img Island Power Authtrity Operations Plan For Marine Transportation Rev. 0 Page 20 of 24 3.5.12 Death, injury or Sickness of Personnel on the 7kg If any pe aboard the tug becomes injured or sick (or dies), the tug shall head the nearest port of refuge. Unless off course, the tow will alway within 60 miles of the coastline, which is within helicopter range. I injury or r.ickness is of a serious nature and the tow cannot of refuge in time, a boat or helicopter evacuation shall be requeste i
the USCG.
3.5.13 RadiologicalEnergency See Radiological Operations Plan, Sectio 3.6 Radio Failure and Emergency Communications Section 2.10 of the Operations Plan (Communications Plan) discusses th methods of communication in detail.
The three primary methods of communication are the VHF radio (effective range about 20 miles), cellular telephone (effective range about 24 miles from the coast), and HF radio wh can transmit over very long distances.
3.6.1 Emergency Communications The cellular phone should be used as the primary means of eme communication with the tug's dispatch office in the event of an emergency in inland waters or near the coastline. Cellular will provide a private means of communication which is unlikely to be interrupte If cellular communication cannot be established in an inla near-coastal emergency, the VHF radio is the second choice. Should the tug be out of cellular and VHF range, the only means of normal communication is the HF radio.
3.6.2 Procedures in the Event of Radio Failure The tug shall carry at least two permanently mounted VHF radios, a cellular telephone, and an HF radio which are all capable of inland and coastal communications (see paragraph 2.7.5). It is unhkely that all of these systems would fail, but if they should and contact is not made within the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> period required, the tug shall seek the nearest harbor I
of refuge and make contact by normal telephone lines. A reptreemen radio shall then be brought to the tug before it continues the voyage.
Once the tug is more than 25 miles from the coastline, VHF and cellular will no longer be effective and HF radio will be the primary means of communication. HF communications can be disrupted by stmospheric conditions or the tug's location.
If the tug loses HF communications due to radio failure or atmospher it shall try to establish communications with a ship or any passing ve I
on VHF channel 13 or 16. That vessel shall be asked to cont
IAng Island Power Authority Rev.0 Operations Plan For Marine Transportation Page 21 of 24 principal towing tug's dispatch office with the tug's position and estimated time of arrival.
Due to the long distances to a port of refuge, the tow should not seek refuge for HF radio failure unless some other emergency exists.
Alternatively, the tow should turn toward shore (weather permitting) and continue the voyage within 20 miles of the coast so that VHF or cellular communications can be established.
The tower's office shall contact the LIPA Notification Point any time the shipment is unaccounted-for. The tower's office shall contact the USCG if contact with the tug, either directly or through another vessel, has not been possible for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or more. At that point, the USCG could decide whether to initiate an air search for the tow based on the last I
reported position.
t 3.7 Emergency Response Trainmg Emergency response traming is discussed in detail in Section 2.7.9 (Marin'e Personnel Training). Subjects to be covered and estimated time of instruction are as follows:
Radiological nature of the cargo and associated risks Construction of the cask and sea-fastening system Role of the water carrier, the health physics technician, the rigger, and the USCG.
List of USCG Groups, salvage companies, and towers enroute Checklists and paperwork Discuss suggested responses for various types of emergencies as noted in Section 3.5 l
Safe harbors Communications plan, emergency communications, and importance of maintaining contact at 6-hour intervals Proposed schedule of operations Question and answers Total training time 3.5 to 4.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> i
Long Island Pewer Autherity Rev. 0 Operations Plan For Marine Transportation Page 22 of 24 I
SECTION 4.0 - RADIOLOGICAL CONTROLS 1
The Long Island Power Authority will conduct operations to ensure that fuel shipment radiation levels are below applicable limits. In addition, all activities will be accomplished with the goal of keeping radiation exposures As Iow As Reasontbly Achievable (ALARA). The LIPA Health Physics Engineer is the designated radiation protection officer for the shipping operations.
i There will be a Health Physics Technician (HP Tech) on the primary towing tugboat.
l 4.1 Pre-Operational Activities Prior to the shipment of the fuel, the LIPA Health Physics Engineer shall have the barge loading plan reviewed and estimates made of the radiation dose that will be received by carrier and rigging personnel during barge loading, transport and unloading operations. This review will ensure that the training and radiation exposure limit requirements of 10 CFR 19 and 20, respectively, are adhered to.
The results of this evaluation shall be documented and retained during the entire shipment period and for a two year period thereafter.
4.2 Normal Operations The following activities will be accomplished routinely during the fuel shipment.
Records will be maintained during the entire shipment period and for a two year period thereafter.
4.2.1 While in transit the fuel cask will be enclosed in a tarp over a retractable metal grate enclosure. Prior to the fuel shipment leaving the Shoreham Reactor Building a radiological survey will be made outside of the retractable enclosure to ensure that there are no radiation levels greater than mesj-ble levels. These readings shall be recorded on the shipping Papers.
DOT /NRC Radiation limits for the fuel shipment are:
200 mR/hr on surface of the enclosure 10 mR/hr at 2 meters from vertical plane of enclosure 1
4.2.2 A HP Technician will be present during loading operations. This HP Tech will perform surveys around the fuel shipment enclosure upon completion of barge loading operations to ensure that radiation levels are consistent with those previously taken.
4.2.3 The barge carrying the fuel shipment will be unmanned during the transit. 'Ihere will not be any routine radiological surveys made during the barge transit.
I 4.2.4 Upon arrival of the barge at the unloading site an HP Tech will board
+,-
Long Island Power Authority i
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Rev.O Operations Plan For Marine Transportation Page 23 of 24 the barge and ensure that radiation levels outside of the enclosure are consistent with the readings on the shipping papers.
4.2.5
'Ihe HP Technician will be present during unloading operations and will take another survey of the cask enclosure when unloading operations are complete.
4.2.6 h HP Technician will survey the barge after each shipment to assure that radioactive contaminatica levels are below 49 CFR 173.443 and 176.715 limits. These readings will be provided to the carrier.
4.2.7 In the event any of the routine surveys done by the Health Physics Technician show dose rates or contammation levels above regulatory limits, the HP Tech will contact the LIPA Notification Point and inform them of the situation.
4.3 Incident Operztions Upon notification of an emergency, the tugboat office will contact the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> LIPA Notification Point and the Coast Guard National Response Center in accordance with 49 CFR 171.15. h LIPA Notification Point will contact the I
appropriate State Agency and the Nuclear Regulatory Commission.
The LIPA On-Call Manager will mobilize support in coordination with the Carrier. The personnel mobilized will be based upon the nature of the incident.
If a significant radiological hazard is present, the Federal Radiological Monitoring Assessment Plan (FRMAP) Team may be mobilized. This team is located at U.S. Department of Energy Brookhaven Area Office in Upton, New York.
4.3.1 Collision or Grounding Given the structural design of the cask and skid it is implausible that any grounding or collision involving the barge will affect the radiological l
integrity of the cask. Therefore the tugboat crew may board the barge to perform r===y response actions without being accompanied by a Health Physics Technician.
6 If the vessel Master determines there is a potential for a breech in cask integrity, the HP Technician will perform a survey once conditions are safe enough to allow access to the barge.
4.3.2 Sinking Upon notification that the fuel shipment is in danger of sinking or has runk, LIPA personnel will work with the tugboat and salvage company to provide radiological support for salvage operations.
i
Ieng Islard Power Authority Rev. 0 Operations Plan For Marine Transportation Pa~ge 24 of 24 4.3.3 Safe Harbor If due to weather or equipment problems the tug and barge seek safe harbor, the vessel Master will contact the U.S. Coast Guard Captain of the Port and the tugboat office. The Coast Guard will specify an anchorage location. 'Ihe tugboat office will notify the LIPA Notification p
Point. The HP Technician will support U.S. Coast Guard and Local I.aw Enforcement requests for information concerning the radiological status of the cask.
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l 38-12-1GG2 ;E:55 509 G87 6290 CEPE uc!ATION
.t rM.0
- ii.f:23. FA t R:D IrORCHAli 3,3 i
Shoreham Nuclear P6wer Station Long P.O. Box 628 Islano North Country Road Power Wacing River. N.Y 11792 Autnority D
August 9, 1993 LRM-93-079 State of New Jersey Department of Environmental Protection and Energy CN 415 Trenton, New Jersey 08625-0415 1
ATTN:
Mr. John Teeney Bureau of Environmental Radiation Division of Environanntal Saf ety, Health and Analytical Programs
')
Application for Cartificate of IIandling Shoreham-Linarick Fuel Shiement
Dear Mr. Feeney:
Enclosed is Long Island Power Authority's (LIPA's) application f
for a Cartificata of Handling (CCH) for the first shipment consisting of saventeen slightly irradiated fusi assemblies from the Shoraham Nuclear Power Station to the Linarick Ganarating In station owned and operated by Philadelphia Electric Company.
accordance with the Nuclear Regulatory Commission (NRC) requittions (10 CFR Section 73.2), the shipment is classified as "Special Nuclear Material of Low Strategic Significance."
five hundred and sixty Shoreham fuel There are a total et assemblies including natural uranium and enriched uranium fuel shipments will be required to assemblies.
Accordingly, 33 complete the fuel tranafer campaign.
't
. -il?.'i t 1
08-12-1593 15:55 509 se? 6390 CEPE GO! ATION o.t_.
s 9 R 93 1!:19 LIFA '.,F.C p:etMct
,o,3 contain any enriched fuel assentlies, The first shipment will not and will consist entirely of natural uranium assemblies.
consequently, the radionuclide content will be below the threshold values for highway route controlled quantities of radioactiva material.
Most of the following 32 shipments are expected to contain highway route controlled quantities.
The shoreham-Limerick fuel shipments will oceply with all NRC and Federal DOT requirements, thereby assuring the radiological We note in that regard that LIPA has safety of the shipment.
due to the applicable federal regulations, New been advised that, Jersey regulation of spent fuel shipments may be preempted by either the Atomic Energy Act or the Hazardous Materials Transportation Act and LIPA reserves its rights in that respect.
however, of our desire to provide all Please be assured, information that you might does appropriate and to cooperate in 3
every other way as well with How Jersey officials to ensure that We are submitting the shipmente proceed safely and promptly.
this latter and the attached application in that spirit and look forward to conferring with you as appropriate.
k Should you have any questions or require any additional information, please do not hesitate to contact siva Kumar of my staff.
He can be reached at 516-929-4177.
Very truly yours, M. Hill
[nr t
- d Resident Manager i
SK/ab Enclosure
+
Sg.
08-1e-1993 15:56 609 987 syso CEPE RAO!AT'ON p. p-t mg WA ;0 '93 1$2 30 L;PA LFe:D ihCAEn'#1 I
.4ew.!arsay Ref erence tio.
h JEQ-036 3 g gl, a
g.
STATE CT NEW JERSEY V90 DEPARTMENT or ENVIRONMENTAL PROTECTIOt:
BURZAU OF ENVIP.ONMENTAL RADIATION
-(y CN 415, TRENTCN, HEW JERSEY 08625 T'
b i
609-9 47-2132 cr rax 6G9-967 A396 APPLICAT:CN TOR CERT!rTCATE Cr MANDL!t:0 5
Transoortation of Radioact2ve Materzal W
Long Island power Anthecity Y
,t p p l ic an s _,,,_
I.
Materials Informaticn A,
Is this Law Specific Activit*/ ( ?.S A) as per d9 CTR y.
1 173.4037 Yos He X 3.
Is this shipment a Highway Reute Centrolla d Cuantity as r
per 49 CTR 173.4037 Yes*
No 1 l3l,Q I'
3' C.
Is this a shipment ef Irradiated Itnactor Tuml?
Ga Yes* 1 No "k
3.
Is thia a shipment of Nuc14ar (fa ste ?
Yes No g If Yes, dees -his shipment require advance notification of the devernor 1
as per 10 Crn 71.97 Yas' No _
List characteristics of Radioactive Materials.
E.
Fo re.
Isotopesf Cuantity Physicai Form (Curies)
(11euid, solid.
Special/Nermal l lgl slightly encapsulated, etc.1 Al or A2 j
Normal 1.
Irradiated 4070 (Max)
Solid (Uranium 5 C Dioxide Ceramic ruel -
"Q pellets with r
2.
Sinnel mi Eircaloy cladding)
Nuclear 3.
gae.c4 1 Of LOW 4.
iteese.nia
~
Significanca Ia.m u aif*=t**
4 for Details) 6.
F.
Does vehicle require 9 Acarding as per 49 CTR 172.50d?
l 1
Yes L No _
c.
Packaging Typets):
A B
x other Explain endinaceive Material PacKace M^d i No. _IF-3OO* NRC ue s /s al /m. f i r. e = rievt 17 h e r ruem assesalies lI:
ene,4f4rmen ne eman14 ance No. anni ; p ar+ an g L,dentitication Nc*
i j:
Inform Covernor's contact person
- y For spent fuel shir.nents, enter " Spent ruel"
- To%e forwarded with advanca notification Page 1 ci E j
~
to Governor's designee.
a
'f-15-1.GG2 15:57 sos se7 6290 CEPE AAct m cN p.14
)
NG.J '?! 15:00 LIM LAcp sucro.M
'k 7:ansportation !.- f orma tien t Comp 1ste sectien A 1 aily Certificate Information CAnnual Certificate Information - CcMPlate Section 5 A.
Daily Cartificate p
1.
Shipperi Long Island Power Authority a.
Name charaham Muc1==e Pow.e f*atinn b.
Address %rewcenerv ma d. w=d4nn e4 var. wtm2
~_
c.
Telepnenea m i ow -san 2.
Carriert a.
Name s.c. f.ovaiana co., rne.
c.
Address p.a. ma-saa, s,.a.una aa_
pann.u411.,
nan 7o a-c.
Telephonea me e ois atan 3.
Driver (al:
a.
Name ce men e n i adi ca (m =_ =c c=ne a 4 m t
- J.
Transport "enicle: Loveland 1721 (or sistership)"
a.
Year 1971 b.
"ake Tidewater tautoment Co.
c.
Colcr Grev d.
State of Regtstration PenneVlvatiis i
- **==aummwommera No.
4Satts e.
5.
Shipments twoyt @3g9g 3
,e 9
a.
cate and time entering ti.J.
b.
Cate and time leaving N.J.
WM93.,mut,94 3
c.
Origins t1) facility Name Sluraham Nuclear Power femelon (2)
Street Marth e% =strv maad (3)
City u=A na River (4)
Ccunty sufrain (5)
State Maw York d.
Oestinations c
.,4nn (1)
C n s ignee r 4,n.rt ene c'.=.=enr 4 na (01 5t; eat m:=c_...n a manat. nan sinna (3)
City 2
(41 County
-r_ =, - --v (51 State 3.ao t o.n 4.
it Schedule Route in New Jersey (lise all roads / highways e.
order travelled).
nalmunes nav naimumen River h1a._2--innd Peaval in Maw Jareevi (u u-Z e s
's
'l page 2 of 5 -
W.E. Landers, D.E. Riddick, W. A. Jones, D.W. Delph
- alternates:
- ABS Class Ocean Deck marge
a i
09-15-1553 1E:57 609 se7 s3se EPE MADIATION p.15 l
D l.
.4 13 '13.!:31 w!PA unct SWACM 24 i,
S.
Annual Certificate 1.
Shipper:
a.
t!ame n.
Address c.
Telepnone (
_i_
D
- 2. Carriert 4.
Name b.
Address c.
Telepnene t i
3.
orivertal (include attachment [IIM31 Listing the name of all driveral a..
Name 4.
Transport Vehicle (include an attachment (IIBal Listing of the following information for all vehiclest a.
Year b.
Make c.
Color d.
State et Raetstration c.
- t. i c e n s e Plate *: umber
- 5. Shipments a.
Days an times (include an attachment II:3!1 !isting the days of the week and times shipment should be traveling in New Jersey) b.
Origins a.
Facility Name b.
Street c.
City _
l d.
Count /
e.
State e.
Destination 4.
Consignee 5.
Street c.
City _
d.
County e.
State d.
Scheduled route in !!aw Jersey (list all rnads/ highways in order travelled).
'n Page J of 5
0 CS-IS-1GG3 15:E' 500 987 6350 CEPE nott. TION 3,,6 9
- m., -
-A 10 '93 if f 31 w :A Lacs shopces 1,
III. Storage Information Is this shipment of radioactivo gatorial coing to be secred s
in transte as defined in NJAC 7:28-L2.2.
v No, proceed to Item IV.
Yes, complete the following section.
g A.
Location of Storage Sita Addresst Ci ty :
3.
Owner of storage site Name Telepnene Nummers (
l and Maximum Quantity of Each Radioactive Material c.
Type t s) stormd:
- sotepes Quantity Physical term form (Cursesi (liquid, snLid S pec i a l / No r-.a t e.g. encapsulated Al or A2 9tc.)
i 0.
Maximum Time of Storage E.
Descr:ption of Storage Location. tanner and Secur* ty:
)
1 l
Fage 4 of 5
/A 05-18-1093 15:58 609 907 6290 CEPE EtAO!ATION p,17 D
- ~
Ni 10 *H 15:?2 LIPA LRCD SHOPCHsdi
_ 8.9
'h T,
' lames, addressas and Telephone Numbers c f Authorities in the
- 4unicipalities having.Iurisdiction over stcrage Sita Property:
(1) Police Chief:
Name
~
Address 1
D Telephone ilumber i 1
(2) rire Chief:
Name Address i
]
Telephone Nurnber (
)
=
IV.
contact Person (s):
Routine (business houral Name Nicholas S. Litto 5300 Ext. 3430__
To Lepnene Numcar t 516
)
929
.margency (24 Hours / day; 7 days / week fCr radioicgical assessment):
Name shoreham W alear Pc":: Station control Roan oiva j
Telepnone ta u m o e r t 516 l 234 g
V.
Insurance Information:
for The f ollowing information relates to insurance to ccmpensate loss and damage due to radiological emergencies involving in$ury,ipment, this sh Mame of Insurance Company Amscican Nuclear Insurars ( AND Policy Nos. NF 269, MF-115 Account Jumte r 200,000,000.00 coll.a r s.
- imits of Liability:
eretofore known as the CCM Holder, hereby swear that the infctmaticn atten is correct to the best of my knowladge, And that this shipment
.:cmplies with all applicable rules and regulations.
k 7 9,
' f * ~r
<ev.= u<---
Date Name sprint or typet briL s, A:
~ signature l
l a
Page ! of 5 i
PR:138
e f
509 GS'1 E290 CEPE iADIAT1.,N
,3 29-23-1993 12:C4
- s
/siss:Nto M f l' W 71 9001 Pactf1e Nuclear Mr. Robert D. Quinn ATTNt 4803 San Ignacie Avenue, suite 100 San Jose, CA 98199 Dear Mr. Quinnt As requested by your application dated July it.1993, as sueelementede August 10,1993,l No. !F 300 package. This certificate supersedes, in its
- 28. for the Meda entirety, certificate of Case 11ance No. 9001, Revision No. 27 dated May 11, 1993.
f Changes made to the enclosed certificate are indicated by vertical Itnes in the margin.
These en the attached 11st have been resistered as users of the package under the general license previsiens of 19 CFA $71.13 er 49 CFR 3173.471.
The approval constitutes authority to use the peakees for sh previstens of 49 CFR 6173.471.
sincerely, Ortsind Signed by Cass R. Chappoil
.g q
.JT, ass R. Chappell. Section Leader Cask Certificaties Section Sterage and freesport Systema tranch Oivisies of Industrial and t
Medical Neslaar Safety NMBt s
Enclosures 1.
Certificate of Caspliance No. 9001, Rev. No.18 t.
Approval Record ccw/ enc 1:
Mr. Jaana K. O'Steen Department af Transportation Reststered Users l
t 4
E
t
- -25-1553 12:05 60S SS7 5250 CEFE RADIAT CN p,03 pon naatFICATE OF 00terLIAf4C5
' 5..'"" "
esR? oeams samnias maniaeus 6 ammen m.m.m curr**m== wisi ise.es maena
. t.r
..a
,..mm.is.r.
m.a 9001 26 USA /9001/af 77-.
I i
3 a*Aa",.,,,
- i......
v.
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,. y,g,s,e,,m,a,,s,,e,,m m sea w a w m,ggwy,.,,,m,a, egg,egmyg,,,,
e L ** s Pacific Nuclear Systems. Inc.
General Elsetric uranium Management Corporatten 1010 South 334th street applicatten dated September 14. 1984, as Federal Way. WA 98003 supplemented.
' M.,
nm,,, v.,
m se ora sen ri. as asunum, sas ou.manem unes name,
'(a) Packaging (1) Medal No.:
1F-300 f
(t) Description i
A stainless steel encased.. depleted urania shielded cask. The cask is cylindrical in shapee64 inahes in diameter and a muzimum of 210 inches long with.saximumt.cavityhdimensises ei 37-1/t inches in diameter b_
by 180-1/4 inches long. Shie)d ag is provided by 4 inches of depleted i
urant e Z-1 a inensa of stainless steel and74 minism,of 4-1/2 inches j
(lle ga lens of a veter.rethylene. glycol.ststure.
i Two closure heads are provided fee the ship' ment of glNL and PWR fuel assentlies.
The heads are 304 stainless steel forpinus and and plates which encase the 36 inch thick depleted urante eMeldung. Either closure head may be used for packaging solid treadiated hardware.
/ :.
The closure heads are s' bused tarthEiast'bedy by means of St.1-3/4 inch studa and nuts. The cask ta sealed with a estallic ring gasket.
The cavity is penetrated by a vent line at the top and a drain line at the bottom. These lines are sealed by bellows stainless steel globe valves and valved quick-disconnect couplings. Stainless steel pipe caps may be used in lieu of the quick-distannect couplings. 'The 7
vent line is aise 44uipped with a 350-400 pais rated rustura disk.
All valves tre housed in protected boxes on the cask exterior.
l I-
l 0e. ;:5-553,,;,: 05 509 SS7 5:50 CEFE QADIATION C.04 l'
maman naamrene oommes
. ens ca n e,,,,
t em Page 2 Certificate Ne. 9001 - Revisten No.18 - Decket No. 11-9001 4
l 5.(4) Packaging (continued)
(1) Cescription(contir.usd)
D Neutron shielding is provided by a lievid-filled. thin-walled, corrugated This cyltadrical structure is s arated containment en the cast extartor.each equipped with two tapansion tan s. fill !
two longitudinsi coasartments, free each cespartment is teretnated by a stat l The fill line re)ief valves.
1ess steel globe valve in a protected box (s parate fres cavity bases) en t ii cask exterior. The stainless steel lobe v vos may be replaced by stainle steel blind flanges.
The vent line rea each compartment gens te an expans tank which is provided with a pressure relief valve set at 100 psig.
The cask has fevr types of fuel baskets which can be interchanged to accom-medate various fuels. The pWR basket holds seven assessites, the unchannel the channellet td tastet holds sever BWR basket holds eighteen assenh11esl basket helda seventeen Shorehaa SWR assenklies, and the Sharsham BM fue assemblies. The channelled and unchannelled 95 fuel. baskets any be provic with supplementary shielding (depleted uranium) near the cask closure.
The cask is shipped horisontally with the lIbtea supported in a tipping c between two pedestals and the upper end resties in a saat=ctreular saddle:
upper and is pinned to the saddle. The cast; supports serwelded to the fr; s
of a 37-1/t-feet long by 4-feet wide structural steel skid. The skid a have installed en it sa austilary cooling' system coastating of two die 1 engines driving tua blowers which discharge coe1Ing air to the corrugate W
surface of the cask via caseen destieg., neither installation ner operatie all or part of this aus111ary coelieg' system is a requirement of this pack approval.
The entire cast and costing system is' covered by 4. retractable aluminus enclosure. Access to the enclosure.it via lockadepanels in the side and a 1
Although the Medal No.: IF-300 cask can be transpc locked door in one end.
for short distances.an the highway, its principal mode of transportatten i railroad.
2 The gross weight af the cask is approatmately 140.000 pounds. The aktd ar other external components weigh approximately 45,000 pounds.
(3) Drawinga The Medal No. IF-300 shipping cask is described by the following General Electric Company Drawing Nes.:
189C5838 - Sheet 1. Rev. 9 Sheet 2, Rev.
Rev. 5: 5 hest 6, Aav e; sheet Sheet 3. Aav. 91 theet 4, Rev. il sheet l,$heet 10. Rev. 58 and Sheet 11 Rev. 4: Sheet 4. Rev. At Sheet 9. Rev. 81 410-11-3000,5heetsI Inc. Drawi Nes.:
2, and pacific Nuclear 5 stems. Sheet 1, 01 440-11-3002, sheets 1 an throu h 9. Rev. 0 4t0-1 -3001, 480-11-2004 Sheets 1 and 2 Rev.
t 410-11 30
. Sheet 1 and I, Rev. 41 410-11-200e, sheet 1. Rev 0; 204I Os 410-11-8005 Sheets 1 and t. Rev. Os Rev.1; and 1045.3003. Sheet 1. key.eeta 1 and 1.
sheets 1 to 4 Rev.1; 1045.3001 Sh O.
13-as-isas.s:ce eca sev esso eps =eoIMICN
- .05 u.a.Num.am mananer somme
.ams seus eie' esemone temmwe, Page 3 - Certifloate No. 9001 - Revisita No. 2e Decket No. 71-9001 5.(a)(4)
Essic components The baste components of the Medal No. IF-300 shipping cask that' tre toportant te nuclear safety are listed in Section IX Table IX 1.
(b)
Contants l
(1) Type and form of matarial Irradiated PWR and SWR uranius oxide fuel assemblies. PWR (1) assentlies any be shipped with er without centrol reds. Partial fuel assemblies. that is, assemblies. free which fuel pins are missing sust nat be.'ahipped unless deny fuel pins are used to displace an assunk of water equal to that displaced by the artginal pins. The specific power of etely feel assembly eust not escoed.40 kW/ key and the burnup of asth' fuel assembly must i
not szceo6 38,000 fee /MTV. The mintsus ceslint. time of each assembly must be ne less than 120 days. Peter to irradiation.
the gun and PWR fuel assentiiss must have the fairesing dimentions and specifications:
//
troup I fuel asses 41.les n
s IE-SE l
l Fuel form C1ed WO ' pallets-Clad 00 pellets.
Cladding mateHa1 e er St.
Zr er SS Maximus.initia1 U contentfassembly,kg 448 198 Maximus initte U-238 "2
enrichment 'w/o,,
4.0 4.0 l
Maximum bundle cross' 5.75 section,in 8.75 Fuel pin array 14x14/18:15 717 Fuel diameter, in 0.380-0.460 0.500 0.400 y
l l
Fuel pfn pitch range, in 0.501-0.581 0.447-0.609 Maximum active fuel 146 length, in 14g i
I
ze-a -tsas a c7 ses sev s so cese youncu
,,es MN l
gas FWImis men eGmem00W teemmuseJ Page 4 - Certificate No. 9001 - Revision No. 28 Decket No. 71-g001 5.
(b) Centants (continued)
Group !! fuel assembites M
M D
Fuel form Clad 00 pellets clad 00 pellets Cladding material 1r er 15 Zr or 55 Nanteum initial U centant/asseabir,h5' 475 133 Mutaum initial U-235 enrichment w/o 4.0 4.0 Maximum bundle cross section, in 8.75 l.75 Fuel pin array 16M15/1Tx3/
Sa8 1
'N
.$. 0.4754.508 0
Fuel pin pitch range, in 0.4g6-SM7 O.630-0.845 Masinua active fuel I
150
'6*"
158-length, in-
~
fuel (ii) Irradiatedttherehen SWE fuel assemblies composed of UO a maxisus redt in an 8 x 8 square array. Esth fual' assembly has aversgenearichment of f.19 w/o U-238..The fuel rods have the following, seminal diesnatans: 0.410.iech fuel pellet disaster, 0.031-incirthick aircalley cladd. tag, 0.54. inch red tch, and lle-inch activatfuel length.t..Thynaminum assembly enup is 87.0 MS/NTU. and the stainecool time is three years. Fuel assemblies any be shipped with protestive oeskaging as described in leetion 1.t.3.1 of application, dated February is 1993. Fue) nasentlies aust be essitioned within stainless steel ch l
l whteh have a nominal thickness of 0.0595 inch and a nasinal length of 167 inches. For natural uranius fuel asseabites.
atrealley channels, having a nominal thickness of 0.1 inch and a i
3 1enoth of reximatal 167 inches, may be used in lieu of l
sta<nless eel channe s.
i I
.a-26-1993 12:07 600 967 6290 CEPE 3AD!ATIQN P,07 i
ua. m unaan sm usa m e m mi mgus enseien comemouste w
Page 6 - Certificate No. 9001 - Revision No. 20. Decket No. 71-9001 5.(b) Centents (continued) 4 (iii) Solid irradiated hardware which may include fissile material.
providea the quantity of fissils saterial does not exceed a Type A quantity and sees not exceed the assa limits of 10 CFR 171.11. As needed appropriate composant spacers suet be used whoe leading irradInted hardware inte the cask cavity te limit e
movement of the centents during. accident tendittens of tranpsort. Use of a steel liner is authorized provided cavity inside dimensions, (1)preminately th its outside dimensions are ap cesstructed of single thickness of )
steel plate with full penetration welds (3) thickness of steal plats does not exceed one inch. and (4) the liner is provided 4
with a drain and went to insure, water removal.
(t) Maximum quantity hf satorial per packinghs, Maxieus decay heat perdackage not to tinteed 40 00 (1)
Maximum 5,728 Stu/hr/P assembly.
assembly.
(ii) Seven PWR feel assemblies, seventeen thennellkd SWR assembliss, etehteen unchannelled IMR fuel assenh11es, as, seventeen shorenas Old fuel assentlies.
i.,.
^
-);,
~-
(iii) Above fuel asseshlies to be coststead in theitreespective fuel i hashets as shoun. in et Ormies.IIsr159C5t38 - Sheet 4 Rev. 8,f rNSI Orewins' No. 4tS 131-300F Sheet L.througE 9,Rere0,erPNSIDrautag.He.[ 2048.3608, sheet 1. Rev.1.
4 (c) Unloaded packager:- contente and statsm:hantity 'of material
.of rehbal radia'hetive material treater than a Tfed-fiNanti A
interier cavity and fuel basket surfaces. products adhering to consisting of si ion and activatten 11 (d) Fissile Class 6.
The end of life total calculated residual gas that could becess available free the fuel plas must not exceed 0.50 lb males for content 5.(b).
7.
The maximum gross weight of the cavity contents must not exceed 21,000 pounds.
1 7
8.
For the shipment of treadiated fuel assemblies,.the cask cavity (containmentvessel must be promptly inerted following removal of the water from the cavi)ty. The cask cavity mat be purged.at least three times with arten, nitrogenkan the cask cavity ve uns.Each purp v er helius.
equivalent to or greater t After the final the cavity must be promptly filled with argen, nitrogen, or heliw purge atL.6stapressure.
and fuel with cladding Known er suspected failed fuel assemblies (reds)ks are not authorized.
9.
defects greater than pin holes and hairline crac i
^
l
03-35-1&&3 12:08 509 SS7 6350 CEFE RADIATION p,c3
?
ua saneampneuwenesamme gem 8 ***
, commeses renamwe, Page 4 - Certificate No. 9001 - Revision:No.18 00cket No. 71 9001 l
10.
Prior te each shipment, the licensee must confirm that the cask contains ne more than 1 cubic feet of water in the cavity ane the licensee sust prepare the cask for shipment, in accordance with Subssetion 10.1 of the application.
11.
The cask centents shall be se limited that under normal conditions prior to transport, et ttees the neutron dose rats plus 4.3 tiens the gaena dose i rate will not exceed 540 aree/hr at a distance of six feet free the side of the cask (ten feet free the cask center-line).
it. The neutron shielding tanks must be filled with appreminately a 50/50 l
volume percent sitture of ethylene glycol and water during the senths of October through May.
13.
Reelaceasnt globe valves other than the valve specified en Drawing No.
litC5234 lheet 4. Rev. e. sust be tested as stated in subsection 4.8.3.2 of the appitcation.
,j 14.
The packaging must be maintained in accordance with the requirements of Subsection 10.1 af the applicatten. During inactive periods, the maintenance and testing frequency may be disregarded provided that the sackage is brought ints full compliance witt these requirariants prior to the nest use of the packages 1
..s 15.
The cask cavity most be' equipped with a rupture disk deviite with a burst sressure within the range.of 450-400 pstt (443*F) including all tolerancas.-
4 The uranium shieldthe-notorialtaust'he taparata[fram ali steel surfacea 16.
with a minimum copper thickness of 4-etts..estopt thakthe stud belts attaching the shield'aseeablies to toe.ofEthe mechannelled But basket mus' be coated witira.aisieue of 1/2-mil.ef copper.
A shutoff valve must not be installed between eech.)neu s
17.
its respective thermal expansion tank.
4 4
la.
The cask any be wrapped with reinforces > plastic during shipment, provided that the decay heat of the contents does not saceed 1.8 Ew. The reinforced plastic used te wrap the cask must not be greater than 0.015 inches thick er have a thermal conductivity less than 0.0848 Stu/hr-ft *F The reisferced plastic wrapeing cannet be used as the cask surface for purposes of complying with 10 CFR 171.87.
19.
For transport of shorehan put fuel asambites, the package may be coverse I
~~
with a tarpaulin. The tarpaulin men not be used as the package surface for purposes of complying with 10 CPR 671.87.
The package autherised by the certificate is hereby approved for use unde i 10.
the general license previsions of 10 CFR 171.12.
{
21.
Expiration date: May 31, 19g8.
I l
Y R
4 08-25-15&3 12:09 609 se7 6350 CEFE,RA01ATION 3.Og
?
u msnm1mmavent soumme sesseinemen e sseg m e ns tennen w e; em Page 7 - Cartificate No. 9001 - Revision' No it - Decket No. 71-9001 BIEEEELI Genera) Electric urantum Management Corporation consolidated application dated September 14, 1984.
p General Electric supplements dated: February 4, April 4, and May 10, 1988, and-March it. 1990.
Pacific Nuclear Systems Inc. supplansats dated: July 28,1990: March it.
Aprt) it, July it, and August 30, 1991: January 3,1991 and February 15, April 9, July 19. and August 10, 1993.
FOR THE U.b NUCLEAR REGULATORY
.t. M l
I5 k
.W_
Cass R. Chappe%T,;teettes' Leader Cask Certif.1 cation section Storage end' Transport Systans tranch Dittisten of4tadustrial ane' Medical Nuclear'849043, M55 e
NR19IM
. 7,r...
- 6.. -
)
2
' ~ '
Date:
'.1.:-
.'.e T.. ;
y., " '
)
- 4 1;i-T
04-15-1953 12:09 509 587 6390 CEPE RACIATION
- .10 p.--
UNffl0 erAree
/'
NUCLEAR REGULATORY COMMISSION i.
4 m enineton,o.c. sums APPROVAL RECORD Medal No. IF.300 package Certificate of Ceaplisace No. 9001 Revision No. 28 i
Ry appiteatten dated July 29, 1993, as nueslemented at 10, 1993, pacifte 3
Nuclear rpm requested an amendment to Centficate ofPN requested Itance No. 9001 the Model No. IF 300 package.
uranius sharehas IWR fuel assenh11es with their strealley flew channels, in lieu of the stainless steel oversited channels which will be used for other sharehan SWR fuel assemblies.
In addition, PN requested autherisation for the package ta be covered with a tarpaulin for shipments of all Shorehan IMR fuel assentlies. The tarpaulin may be used to protect the package from salt spray for targe shipments.
SN!!LDINI previeusly approved thershas SWR fuel assemblies were to be trancperted in protective paskastne which included eversized stainless steel channels. The natural urastus fuel,. assemblies may be shipped with aircalley chcnnels, uhtch have beau slightly irradiated and which have a ersater thickness than ths stainless steel thennels'. The turnup of the natural vrasis fuel assemblies 3
is seestderetly lauer than the naminua assembly burnup used previously, which effsets the increase in source term due to the irradiated channsla.
The applicant showed that shineing 17 natural urastus fuel assemblies with zircalley channels instead of'the stat 1ess steel channels would not result in higher esternal dose rates. The applicant used a unit source of one pheten/second and perfereed dose rata caleulations for the basket with both stainless steel and aircalley channels. The dose rate with the aircalley channels was louer than with the stainless steel channels.
The NAC staff agrees with the asolicant's senclusion that the natural uranius assentlies and airsalley channel's util not affect the ability of the package to meet the asternal radiatten standards of 10 CFR part fl.
CRITICALITY -
To demonstrate that the natural uranium assed)ies with the tirtalley channels are less reactive than the casfiguratten previously analyzed. the appiteant KIND V.a ter code. The applicant performed a crititality analysis using/e U t35, ley chann used fuel assemblies enriched to 1.3 4 ins of natural urentum, with full density moderation and with the straal d
k., was 0.74134, cespared to 0.81709 which was previously calculated for 2.19 The w7e, U tal enriched fuel assemblies with stainless steel chanasis.
applicant concluded that shipment of r.atural uranius em fuel assemblies with aircalley channels will not affect the criticality safety of the IF 300 package.
- 21-26-1993 12
- 10 609 587 6390 CEPE 3AOIATION p,g i
.g.
The NAC staff agrees with the applicant's conclusion that the shipment of natural uranius fue) assemelies with aircalley channels will not affect the ability of the package to meet the criticality safety requirements of g
10 CFR part 11.
TIME pft requested authorizaties to cover the packege with a tarpaulin for transport ef shoreham BWR fuel assenh11es. To show that the tarpaulla would not adversely affect the temperatures in the package, the applicant perfereed a er less thermal analysis based as a desay heat lead of 31.9 watts per sackagedlian This heat lead was based en 17 fuel masse than a watts per assembly.
with the highest burnup being leaded in the p
. The analysia was performed using the HEATIN87.1 code. A full 1 section of the cask and i
tarpaulin was esplicitly endeled. The applicant eteed a thermal analysis for normal conditions of transport since the pac is assumed to separate from the skid under accident conditions.
The results indicate that covering the package with a taryautin vields louer cask centerline ratures, due to reduced solar inselation. The NAC staff agrees with the icast's ceasinsten that the covered by a tarpaulin is bounded ky t previous calculattens for the fuel.
The certificate of Compliance has been amended to specify that natural uranius Shoreham OWR fuel assemblies any be shi pad with aircalley channels in Ifou pf stainless steel channels, and te spect the dimensions (thickness and length) l of the two types of channels. The Cert ficate has been amended to include a condition that the package may be covered with a tarpaulin for shigesets of I
Shorehan IWR fuel asseshlies. These changes de not affect the ability of the i
package to meet the requirements of 10 CFR Part 71.
i
,,IJ H..0
[-
Cass R. Chappell. Section Leader Cask Cartificatica lection Storace and Transport Systems tranch Divisses of Industrial and j
Medical lhealear safety,18188 j
g 9, g l
Date l
l
f a
9 State of New Jersey Departrnent of Environmental Protecdon and Energy i
Office of tne Commasioner CN 402
. Trenton. NJ C36254402
~
Jeanne M. Fox.
Acting Commissioner J
0 VTA FAX AND REGULAR MAIL Frank Maloney, Acting Director U.S.
Department of Commerce National Oceanic and Atmospheric Administration Office of Ocean and Coastal Resource t
Management l
1305 East-West Highway, lith Floor l
New Jersey Consistency Review of
- Long Island Power Authority's U.S.
t Coast Guard Approval to Transport Irradiated Nuclear Fuel From Shoreham Nuclear Power Station Through New Jersey Territorial Waters to Eddvstone. Pennsv1vania
Dear Mr. Maloney:
This letter shall serve. to notify you that the New i
Jersey Department bf Environ = ental Protection and Energy
("NJDEPE"). deana'nds consistency review of the above-referenced j
activity.
pursuant to the provisions of the Coastal Zone Management Act, 16 U.S.C.
51451 31 Agg.
("CZMA"),
and New
. Jersey's approved coastal zone management plan.
NJDEPE is entitled " to review this. activity, which,will take place directly within New Jersey's coastal zone, pursuant to the
- new jeney a e raua ocoomarv r.mpsoyw i
Arcycea face l
o explicit requirements of the.CZMA regarding applications for federal approvals which affect a state's coastal zone.
15 U. S. Q. 514 5E (c) (3 ) ( A)
The applicant in this case has sought a
federai agency approval which is listed in New Jersey's guidelines fot federal consistency in New Jersey's coastal
- zone, which guidelines have oeen submitted to' the ' Office of' Ocegn and Coastal Resource Management ( "OCRM") for approval pursuant to 15 C.F,R.
S930.53.
Thus, pursuant to 15 C.F.R.
5930.53(e), no final federal agency approval of the proposed activity may be issued until NJDEPE completes its consistency review of this activity.
Even if the subject approval wdre not listed pursuant to 15 C.F.R.
- S930s53, OCRM must approve-RJDEPE's.
request for a consistency review in this caso phrsuant to 15 C.F.R.
5930.54(c) because the proposed activity will take place directly within New Jersey's coastal zone, thereby affecting New Jersey's coastal zone and implicating the enforceable policies of New Jersey's approved coastal zone management plan.
This matter involves the.
Long Island Power Authority's ("LIPA's")
plans to transfer radioactive nucl* ear fuel from the abandoned Shoreham Nuclear Power Station in Suffolk County, New York, through New Jersey's territoria1 waters, to Philadelphia Electric Company's ('PECo's") L'imerick j
Generating Station in L!merick, Pennsylvania.
LIPA has applied t$
the U.S.,
Coast Guard for approval to transport the radioactive nucle'ar fue,1 'by barge from the Shoreham facility on i
-2
- - - ^
e n
Long Island through the Atlantic Ocean around Cape May, New Jersey, through New Jersey's territorial waters in the Delaware Bay and up the Delaware River to Eddystone, Pennsylvania.
From Eddysto'ne, the radioactive nuclear fuel will be transported over land to the L'imerick Generating Station for use at that D
facility.
LIPA proposes 33 barge shipments of radioactivo nuclear fuel to take place over a period of at least' seven months.
LIPA plans to commence the first shipment on or about September 23, 1993.
ihe radioactive nuclear fuel constitutes
" dangerous cargo" under applicable U.S.
Coast Guard regulations.
LlLg 33 C.F.R.
$126.07.
- Thus, U.S.
Coast Guard approval is required for' the handling of this material in
~ waterfront facilities and on the waters of the United States.
Sag, eenera1lv, 33 C.F.R. Part 6 and Part 126.*
3 Accordingly, on or about July 7, 1993, LIP'A submitted its "O erations Plan for Marine Transportation of Fue.1, Shipment from Shoreham, NY to Eddystone, Pa" ("Transportatio'n Plan")
to the U.S.
Coast Guard for approval.
(Copy attached as Exh,ibit A).
This Transportation Plan identifies the proposed rou e of the shipments.
Although the exact length of the route which traverses New Jersey's territorial waters is not specified in
- Various federal uclear Regulatory Commission ("NRC")
approvals are also required to transport this radioactiive nuclear fuel.
Sene NRC approvals have already been obtained.
Specifically, the radicactive nuclear fuel will be packaged for transport at the Shoreham facility in a special-cask, the design of which has been approved by the NRC for the proposed shipments.
The NRC has also 4 mended PEco's operating license to allow it to receive. the proposed shipments at its Limerick facility.
-3
I o
i the Transportation Plan, it appears from that document that the proposed nuclear-laden shipments may traverse as much as 50 milss of Nett Jersey's coastale zone.
New Jersey was t
notified 'when LIPA submitted its Transportation Plan to the U.S.
Coast Guard.
On July 27, 1993,.
the U.S.
Coas,t Guard, Captain of i
the Port Long Island Sound, issued its approval of LIPA's t
Transportation Plan, contingent on the satisfactory internal structural inspection of the barges to be used for the radioactive nuclear fuel shipments.
("U.S.
Coast Guard's
. contingent approval",
.py attached as Exhibit B).
Again, New
~
Jersey was not notified when the'U.S. Coast Guard issued this approval.
In fact, it was not until on or about August 9,
- 1993, I
when LIPA submitted an application for a
Certificate of Handling
("COH")
to the NJDEPE Radiation Protection Progran pursuant to New Jersey's Radiation Protection Act, N.J.S.A.
I I
26:2D-1 31 3.3,g., that the NJDEPE actually received notice that the proposed route of the nuclear-laden shipments does, in fact, traverse New, Jersey territorial waters in' the Delaware Bay and Delaware
- River, and will therefore affect New Jersey's 1
coastal' zone.
Moreover, it was not until on or about August l
26, 1993, as the CCH application was being reviewed, that New 1
Jersey learned of the U.S.
Coast Guard's contingent approval of
{
the proposed Transportation Plan.
New Jersey finally received a copy of the Transportation Plan on September'3, 1993.
i
-4 T
m -
-m
- m. --
O s
On September 8,
199.3, the NJDEPE provided written notice to the U.S.
Coast Guard,. Captain of the Port Long Island
- Sound, and to LIPA, pursuant to 15 C.F.R.
$930.54(a), that NJDEPE would require a consistency review of this approval pursuant to the CZMA.
(Copy abtac ed as Exhibit C).
On that 6
same day, a copy of that notice was also provided to the Assistant Administrator, National Oceanic and Atmospheric Administration, U.S.
Department of Commerce, pursuant to 15 C.F.R.
5930. 54 (b).
Finally,- on September 9,
1993, a copy of the notice letter that had previously been sent to the U.,S.
Coast, Guard, Captain of the Port Long Island Sound was also t
sent to U.S.
Coast Guard Headquartdrs, Package Cargo Section, in Washington, D.C., as well as the U.S.
Coast Guard, Captain of the Port New York, and Marine Safety Office Philadelphia, as soon as New Jersey was advised by the Captain of the Port Long Island Sound, that these other agency offices are also involved in this matter.
LIPA has sought federal approval of an activity which is proposed to ta)Se place directly within New Jers,ey's coastal zone,,
Indeed,' the pro' posed. nuclear-laden shipments will traverse a s' much as 50 mil'es of,.New Jersey's territorial waters, and, therefore, may expose a significant area of New k
Jersey's coastal zone to the inherent risks associated with the shipment of such dangerous mdterial.
Thus, NJDEPE is entitled to conduct. 'a consistenpy review of the proposed activity because it affects New Jersey's coastal zone..
.s
- Indeed, pursuant to applicable
- law, because the proposed activity will take place within New Jersey's coastal zone, thereby af fecting New Jersey's coastal zone, LIPA should I
have submitted its Transportation Plan to the NJDEPE fcr consistency review in the first instance when it was applying
)
D to the U.S.
Coast Guard for approval.
NJDEPE should not,be in a position now of having to request.OCRM's approval to review
[
this matter.
The CZMA explicitly requires that:
[a]fter final approval by the [U.S.) Secretary (of Commerce) of a
state's management
- program, gny geelicant for a recuired Federal license or cermit to conduct an activity, in or cutside of the coastal
- zone, affecting-any, land or water use or natural resource of the coastal zone of that state shall provide in the application to the. licensiMg or 3
permitting agency a certification that the proposed activity complies with the enforceable policies of the state's approved program and that such activity will be conducted in a manner consistent with the 3
program.
[16 U.S.C.
51456 (c) (3 ) ( A) ; emphasis added.)
In fact, Congress amended this particular provision in 1990 to give states broader ability to participate in federal permitting decisions which impact the coastal zone.
Federal
. regulations define " federal license or permit".to mean "any authorizati*on, ' certification,. aceroval, or 'other form of permission which any Federal agency is empowered"to issue to an applicant."
15 C.F.R.
5930.51 (emphasis added).
New Jersey received federal approval for its coast'al zone manageme,nt program,in September 1980.
New Jersey's coastal,zo'ne management plan contains enforceable policies f
designed to protect various water and land uses in New Jersey's 6-
- ~ _
~
l 4
coastal Zone, including vari ius water and land use goals for the Delaware Bay.
13.g,
cenerally, N.J.A.C.
7:7E-1 31 giq.
{
Therefore, ' pursuant ' to the explicit mandate'.of.the C2MA, LIPA should have sub.nitted its consisitency certification 'tc the U.S.
i
-' Coast Guard and the NJDEPE when it originally. sucmitted its l
s
~
' Transportation Plan to the U.S. Coast Guard for approval.
- Egg, Southern Pacific Transeortation Co.
v.
C'alifornia Coastal I
Com'n, 520 F.Suco. 800, 803 (N.D. Cal. 1981) ("it was Congress '
intention to make compliance,.with the consistency review procedure mandatory as to any applicant for a required federal license or permit").
In addition, federal' r'egulationsL require states to l
dev lop and submit,*as pa'rt of.their coastal zone. management t
programs, a list of those federal approvals which are likely to affect the coastal zone and which the state wishes to review for i:onsistency with its coastal zone management program.
15 l
C.F.R.
5930.53(b).
Federal regulations further provide that i
"(q)o Federal license or permit described on an approved list shall'be issued by a Federal agency" until state agency review of the application is completed.
15 C.F.R.
593 0. 53 (;e).
J In or about January, 1991, the NJDEPE submitted its guidelines for federal consistency determinations in New Jersey's coastal
- zone
(" Federal Consistency Guideli'nes") to the l
OCRM.
(Copy attached as Exhibit' D).
The Fede'ral Consistency Guidelines include a list which identifies federal licenses and permits for which applicants should consult the MJDEPE for n
n
.-,I
l P
)
+
consistency review pursuant to the CZMA.
This list specifically includes U. S '.
Coast Guard,":p]ermits and authorization for the handling of dangerous cargo'. :y vessels in U.S. ports" (Federal Consistency Guidelines, p.35), the type of approval apparently being sought by LIPA in connection with'the j
transportation of the radioactive nuclear fuel in the present case.
- Thus, the U.S.
Coast Guard's approval of LIPA's Transportation Plan is a " listed" approval in ac Ordance with the Federal Consistency Guidelines that NJDEPE sub=itted to the OCRM in 1991.
Pursuant to 15 C.F.R.
59 3 0. 53 (a), the U.S.
Coast
[
Guard m6st not issue final approval of LIPA's Transportation Plan until the NJDEPE's coinsistency review of th:.s matt;er is completed.,
Even if the U.S. Coast Guard approval being sought by
)
LIPA in this case were not determined
- to be a
" li s t'ed "
I approval, OCRM must approve NJDEPE's retguest to review LIPA's Transportation Plan pursuant to 1$
C.F.R.
$930.54 (c) because
- he proposed activity will take place within and, therefore, will affect New Jersey's coastal zone.
The - propcised ' nuclear-laden shipments will travel through the Atlantic Ocean, outside of but near to New Jersey's territbr[al waters, for the entire length of New Jersey's Atlantic coast and, more'significantly, will directly traverse s.
i New Jersey's territorial waters for a significant length of the 9
proposed route through the. Delaware Bay and the Delaware River, thus directly affecting New Jersey's ' coastal
- ene.
New
-8
l Jersey's coastal zone management plan includes enforceable policies tol protect special areas within New Jersey's coastal zone.
N.J.A.C.
7:7E-3.1 el sec.
Special areas
- include, without limitation, shellfish beds (N.J.A.C.
7:7E-3.2), prime fishing areas (p.J.A.C. 7:7E-3.4), finfish migratory pathways l
(N.J.A.C.
7:7E-3.5), wetlands (N.J.A.C.
7:7E-3.27), endangered j
or threatened wildlife habitats (N.J.A.C.
7:7E-3.38), critical' l
wildlife habitats (N.J.A.C.
7:7E-3.39), and public open space (N.J.A.C. 7 : 7 E-3. 4 0).
All of these special use areas are found in the Delaware Bay region.
In addition, New Jersey's coastal zone management plan specifically protects recreational beaches
\\
(N.J.A.C.
7:7E-3.22) and specifically makes resort and i
recreational uses and commercial fisheries uses the highest priority uses in Cape May County (N.J.A.C. 7:7E-7.3).
9 Thus, specific i= pacts that the proposed activity cay have on New Jersey's coastal zone include:
(1) potential adverse effects on all recreational, tourist, and commercial fishing activities on the Atlantic shore and in the Delaware Bay and Delauare River; (2) potential adverse ef'fects o n, important species in prime coinmercial and recreational fishing 8
areas (including
- shad, herring, striped
- bass, weakfish, drumfish," bluefish, and flounder, as well as shellfish); (3) potential adverse effects on endangered species habitat D
(including the shortnose sturgeon which is an endangered species on both the federal and the, State list);- (4), potential' '
l adverse effects on marine life thaf. supports avian endangered l,
D 1
.. ~. _ -,~
I species (such as the bald eagle and the peregrine falcon, wnich are also both listed on the federal and State lists of l
?
endangered species);
and (5) potential adverse effects on critical wildlife habitat.
Nevertheless, LIPA has not ma,sle
'an'y attempt to" quantify the potential risk of an accidental. relesse of radioactive material in, connection with the proposed nuclear i
fuel shipments in relation to these unique characteristics of
~
New Jersey's coastal zone'.
LIPA has also failed to present any j
analysis of alternative routes for the proposed shipments.
l Such an analysis is critical in this case,since the proposed s
activitky may abversely impact the h'ighest priority uses of New
{
Jersey's coastal zone.
333 N.J.A.C. 7:7E-7.3(b)2.
NJDEPE is i
requiring consistency review of the proposed activity to enable it to evaluate this risk.
Even if the probability of an l
accidental release of radioactive material occurring in i
i connection with the proposed shipments is low, any release at all will have a devastat'ing impact on the protected uses of New Jersey's cerastal zone and the, econcmy. of the regica, and the 9 tate.
Indeed, any mishap in the shipments even short of a release could adversely affect these priority uses.
i
)
~
The Delaware Bay area, in particular:, is one of the j
single most impor. tant ecological, commercial and recreational 1
j marine resources within New Jersey's coastal zone.
Two recent examples illustrate the type of devastating effect.that the proposed shipments can have on New Jersey's, coastal zone and i
r a
2 -
w w
w
i i
l 1
" coastal :ene economy.
Specifically, in the late 1980's, ':ew Jersey.'s coastal community suffered a
significant loss of
~
income when many of New Jersey's beaches nad to be closed as I
medical waste washed ashore.
Cc== unities that survive on income from tourism and recreational activities were cevastated and have just begun to recover.
In another incident, the New Jersey fishing industry was significantly impacted when drums of arsenic were accidently released in New Jersey's coastal waters.
Despite the fact that the arsenic never escaped from the drums, there was an adverse effect on the State's econocy for several months.
Regardless of whatever actual danger the i
waste on the beaches or the " arsenic spill" posed to those who
- would use the beaches or consume New Jersey's ocean products, the public perception of the danger sufficed to have an enormous adverse impact on tourism and the market for products i
from New Jersey's fisheries.
For the foregoing reasons, NJQEPE demands consistency review of the propose'd, activity pursuant to the requirements of the CZMA and New. Jersey"s. approved coastal zone manageme,nt plan.
Pursuant to the CZMA,. NJDEPE is entitled to conduct a c
consistency review of this activity, which will take place directly within New Jersey's ' coastal zone.
, The federal l
approval being sought.in connection with the proposed activity is listed in New Jersey's ' Federal Consistency Guidelines and,
'I therefore, LIPA should have submitted a
consistency certificatign to the NJDEPE in the first instance when it 11 -
e e
submitted its Transportation Plan to the U.S.
Coast Guard for approval.
- Finally, even if the U.S.
Coast Guard approval involved in this case were not a " listed" approval pursuant to 15 L F.R.
5930.53, ths OCRM must approve NJDEPE's review ef this natter pursuant to.15 C.F.R. 5930.54, as NJDEPE is' seeking to ensure that the established policies and uses set forth in New Jersey's coastal zone management plan are adequately considered before LIPA is permitted to commence *sh,ipping radioac,tive nuclear fuel through New Jersey's coastal zone, an activity affecting land and water uses and the natural resources of that coastal zone.
Because LIPA has n o,t yet provided the NJDEPE with sufficient informaticn to enable i
NJDEPE to thoroughly evaluate the potential, risks associated with the proposed shipments, NJDEPE reserves the right to stipplement its case as NJDEPE learns more about the proposed activity.
Very truly yours,
'N h
A L.
. i Jealine M.
Fox, Acting Commissioner N}NIRONMENTAL W
JERSEY DEPARTMENT OF EN PROTECTION AND ENERGY DATE:
oI;ktn\\14 / E l'~l C 5
4 4
O e
e**
- 12
t
!p j
c:
L.S. Coast Guard Captain Thad Allen, Captain of the Port Long Island Sound i
2 (by regular mail)
U.S. Coast Guard Chief E. Pfersich, Package cargo Section, U.S.
Coast Guard (by regular mail)'
U.S. Coast Guard Chief 9f Port Operations, Marine Safety Office Philade.1phia (by regular mail)
U.S.
Coast Guard, l
Captain of the Port New York (by regular mail)
Mr. Arthur Bortz, Resident Manager, Shoreham Nuclear Power Station 1
(by regular mail)
Richard P.
Bonnifield, Esq.,
General Counsel, Long Island Power Authority (by fax and regular mail)
Mr. George A.
- Hunger, Jr.,
Philadelphia Electric Compahy
~
(with Exhibits B, C.,
and D only)
(by f ax' a'nd regular mail)
(Exhibits by regular mail only) r o
+
~.
i t
I t
j
=
1 4
f i -
+
u)
UNITED STATES DISTRICT COURT I
DISTRICT OF NEW JERSEY l
STATE OF NEW JERSEY, et al.,
)
)
Plaintiffs,
)
)
v.
)
Civil Action No.
)
LONG ISLAND POWER AUTHORITY, et al.
)
)
Defendants.
)
OPPOSITION OF DEFENDANT PHILADELPHIA ELECTRIC CONPANY TO PLAINTIFF 8' NOTION FOR A TEMPORARY RESTRAINING ORDER BACKGROUND on the afternoon of September 21, 1993, the day before this hearing, counsel for plaintiffs notified the undersigned counsel for defendant Philadelphia Electric Company ("PECo") that this action was being filed and a temporary restraining order would be sought.
The papers supporting this application were furnished by facsimile at 6:30 p.m.
that evening.
Plaintiffs' belated request for temporary relief is completely without merit.
It provides no proof of any imminent public health or safety hazard, and is based purely on speculation as to some unspecified, hypothetical environmental impacts associated with the transport of nuclear fuel which has been known to plaintiffs since at least late June, 1993.
Moreover, this Court lacks jurisdiction to grant this request. As demonstrated below, the Court of Appeals has exclusive jurisdiction to grant stays of actions authorized by a Nuclear Regulatory Commission ("NRC") license._ Indeed, plaintiffs have
a 4 completely ignored administrative remedies before the NNC which, if unsuccessfully pursued, would have led to an appeal to a court of appeals.
Because plaintiffs have not satisfied the criteria for obtaining interim relief, and have not even provided a basis for jurisdiction, the temporary restraining order should be denied.
ARGUMENT I.
The Court of Appeals Has Exclusive Jurisdiction Over An Acceal From the Issuance of an NRC License.
It is important to understand the relief plaintiffs are actually seeking.
On June 23,
- 1993, the NRC issued PECo an amendment to Facility Operating License Nos. NPF-39 and NPF-85 for the Limerick Generating Station, a two-unit nuclear power reactor located near Pottstown, Pennsylvania. These amendments permit PEco to receive, possess, and use nuclear fuel originally intended for use at the Shoreham Nuclear Power Station, but irradiated at low-power levels to the equivalent of several full-power days of operation.
In issuing the license amendment, the NRC performed, as plaintiffs acknowledge, an evaluation of the environmental impacts associated with the transportation of this fuel from the shoreham to the Limerick facility.F This evaluation was documented in a F
By virtue of holding a facility license for a nuclear power reactor, the Shoreham licensee was already authorized, under a general license approved by the NRC, "to deliver [the fuc.1) to a carrier for transport" in a licensed cask, the mode of transport here.
Egg 10 C.F.R. S 71.12(a).
Therefore, PECo's license amendment did not have to._ include authority for the fuel to be transported, only to receive it.
l
b r
-3 formal Environmental Assessment, dated May 11, 1993, which included a Finding of No Significant Impact.
f2gg 10 C.F.R. S 51. 21.I' In the meantime, the NRC had published a Notice of
- opportunity for Hearing in conjunction with the proposed license amendment.
3.13 58 Fed. Reg. 16867 (March 31, 1993).
No requests for hearing were filed and, following the issuance of the Environmental Assessment as well as a related Safety Evaluation (June 23, 1993), the NRC issued the requested license amendment on that date.
Plaintiffs knew by late June 1993 that Long Island Power Authority (LIPA) was seriously considering shipping the Shoreham fuel by barge rather than rail.
Yet, at no point in the next three j
months did plaintiffs take any action before the NRC to protect i
their asserted interests in the event the barge option were j
adopted.
In effect, plaintiffs seek to enjoin PEco from receiving Shoreham fuel as authorized by its amended license for the Limerick facility. It complains that the environmental evaluation performed by the NRC'in conjunction with the issuance of the amendment is deficient.
Accordingly, plaintiffs
- are, for all practical purposes, challenging the issuance of the license amendment to PECo.
The Third Circuit has emphatically ruled, however, that the i
l' By contrast, the NRC has categorically defined those proposed actions "significantly affecting the quality of the human environment" which require a
full environmental impact statement ("EIS").
133 10 C. F.R. L51. 2 0.
License amendments do not fall into any of those categories.
e-1 4/
it
!b-l UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY
)
HONORABLE GARRETT E.
BROWN, JR.
STATE OF NEW JERSEY,
)
)
Civil Action No. 93-4269 (GEB)
)
Plaintiffs,
)
Return Date: September 22, 1993
)
v.
)
l
)
l LONG ISLAND POWER AUTHORITY,
)
)
I
)
Defendants.
)
BRIEF IN SUPPORT OF DEFENDANT LONG ISLAND POWER AUTNORITY'8 NOTION TO DISNISS AND IN OPPOSITION TO PLAINTIFF'8 APPLICATION FOR TEMPORARY RESTRAINTS AND A PRNLIMINARY INJUNCTION COMEN, SHAPIRO, POLISHER, SHIEKMAN and COHEN Paul G.
Shapiro, #PS 1089 Princeton Pike Corporate 1009 Lenox Drive, Building Four Lawrenceville, New Jersey 08648 (609) 895-1600 KIRKPATRICK & LOCKHART I
Lawrence C.
Lanpher, Esq.
Barry M. Hartman, Esq.
Linda Raclin, Esq.
South Lobby, 9th Floor 1800 M Street, N.W.
Washington, D.C.
20036-5891 (202) 778-9000 COUNSEL FOR DEFENDANTS LONG ISLAND POWER AUTHORITY and THOMAS DEJESU
d 8
Second, NOAA has not approved the Guidelines for use in identifying listed activities.
Such NOAA approval is required before the purported listing by the DEPE may be effect1ve.
15 C.F.R.
S 930.53 (b).
Third, the DEPE reliance on its purported listing set forth Pl.
at page 35 of the Guidelines is not applicable in any event.
Br. at 24.
Under the heading of " Permit Description," the provision is as follows:
Permits and authorization 46 U.S.C.
5 170 for the handling of dangerous cargo by vessels in U.S. ports The cited provision, 46 U.S.C. 5 170, was repealed on August 26, 1983.
P.L. 98-89, S 4 (b), 97 Stat. 599.
Further, the only ports which will be entered by the barge are those in New York and Pennsylvania.
The State of New Jersey has no authority to attempt to exercise jurisdiction over activities that take place in another state.
San Federal Consistency Bulletin, Office of Coastal Zone Management (August 1993).
The DEPE also suggests that certain alleged NRC requirements are " listed" activities requiring' consistency certifications dnd
)
review before such activities are permitted.
Pl. Br. at 25.
Again, the DEPE misses the mark.
The only NRC requirement that the DEPE can point to is the amendment to the Limerick Operating License that PECO obtained to accept delivery of the Fuel.
LIPA
]
was not the " applicant" for this license, and so the CZMA cannot apply to LIPA based on this conduct.
16 U.S.C. 5 1456 (a) (3) ( A).
More importantly, the DEPE states that the CEMA applies only if 20 -
4 w
the PECO license amendment authorized the transport of Shoreham fuel through New Jersey's coastal zone.
Pl. Br. at 25.
It did not; it only authorized receipt of the Fuel.
Finally, the bare assertion by the DEPE that CZMA review is triggered because LIPA was required to amend its license and decommissioning plan in order to transport the fuel is wrong.
P1 Br. at 25.
The DEPE has failed to point to any legal authority requiring that LIPA obtain such approval, because no such authority exists.
Moreover, LIPA did not file such an application, and is therefore not an " applicant" within the meaning of the CZMA.
16 U.S.C. S 1456 (a) (3) (A).U/
C.
The DEPE has Failed to Dammnstrate that Irrecarable Harm Will, or is even Likelv to. Occur in the Absence of Preliminarv Relief.
The DEPE has failed to demonstrate that irreparable harm will, or is even likely to occur in the absence of preliminary relief.
Again, the burden is on the DEPE to demonstrate the immediacy of irreparable harm.
The mere allegation of statutory violations is not enough to meet that burden.
Natural Resources Defense Council. Int v.
Texaco Refinina & Marketina. Inc., 906 F.2d 934 (3d Cir. 1990).
u/
Previously, the DEPE had argued to NOAA that even if the Operations Plan was not a " listed activity" within the meaning of the CZMA, the DEPE was entitled to review it as an " unlisted" activity pursuant to 15 CFR 5 930.54 (a)
ERR Complaint, Ex. H, at 2.
Under the regulations, such a right to review is waived if not raised within 30 days of notice of the federal permitting activity.
In apparent recognition that the DEPE has known full well that the Coast Guard was considering the Operations Plan, the DEPE has not pursued that argument before the Court.
- 21
r s
4
~
0RIGINAL MLED SEP21 Es3 )f a
FRED DeVESA
-- " "'AM T WALSK CLERM
- Acting Attorney General of New Jersey Attorney for Plaintiffs R.J.
Hughes Justice Complex CN 093 Trenton, New Jersey 08625 By:
Thomas A.
Kowalczyk Deputy Attorney General (609) 633-1985 (TK-1736)
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY STATE OF NEW JERSEY,
)
DEPARTMENT OF ENVIRONMENTAL PROTECTION AND ENERGY, and
)
JEANNE M.
FOX, in her official capacity as
)
Acting Commissioner of the Department of Environmental
)
Protection and Energy, 4
b-ib b
401 East State Street,
)
Civil Action No.
Trenton, New Jersey,
)
Plaintiffs, v.
)
VERIFIED COMPLAINT LONG ISLAND POWER AUTHORITY,
)
and THOMAS DeJESU, in his official capacity as Executive)
Director of the Long Island Power Authority, North Country)
Road, Wading River, New York,
)
UNITED STATES NUCLEAR REGULATORY COMMISSION,
)
Washington, D.C.,
- 20555,
)
UNITED STATES COAST GUARD, within the United States
)
Department of Transportation, 2100 Second Street,
)
Washington, D.C.,
20555, and
n a
that it will take at least seven months to complete the shipments.
12.
On several occasions during July of
- 1993, NJDEPE representatives clearly expressed, to both PECo and LIPA
_ representatives, NJDEPE's objections to and serious concerns with the proposed shipment of nuclear fuel from Long Island to Pennsylvania.
These concerns were first raised when then Commissioner Scott A.
Weiner requested Richard V.
- Sinding, Assistant Commissioner for Policy and Planning, to contact a representative of PECo to express the State's concerns.
On July 8th, 1993, and at least on two other occasions, Assistant Commissioner Sinding participated in telephone conversations i
with PECo's Director of Public Policy, Mr. Jan Freeman.
During
)
i these conversations, NJDEPE advised PEco that the State was j
having an excellent tourist season at the New Jersey shore due in part to improved water quality and enhanced public confidence regarding the safety of the shore.
NJDEPE then expressed its serious concerns that 33 shipments of nuclear fuel could potentially have a devastating economic and environmental impact on the State's coastal zone should any one of the shipments be involved in an accident.
Mr. Freeman advised NJDEPE that the shipments would be equipped with various safety features which would protect the State's coastal zone.
Mr. Freeman asked whether NJDEPE would require compliance with any environmental requirements.
Assistant Commissioner Sinding advised him that there were,,
r l
various requirements regarding water quality and coastal zone protection which NJDEPE could impose.
In one conversation, Assistant Commissioner Sinding expressed NJDEPE's concern that although the barge would be equipped with various safety
_ measures, the State's coastal community including mayors and citizen groups had expressed similar concerns to NJDEPE and as of that time PECo and LIPA had failed to conduct sufficient public discussion with the coastal community in response to I
their fears and concerns in order to explain the need for the proposed shipment, the reasons why a coastal route was chosen over an inland
- route, and the various safety measures.
Assistant Commissioner Sinding advised Mr. Freeman that if PECo and LIPA could not address NJDEPE's concerns, it would be very difficult for the State to concur with the proposed shipment at that time.
Mr. Freeman advised NJDEPE that PECo and LIPA would consider NJDEPE's objection and concerns.
During the July 8th conversation, Dr. Gerald P.
- Nicholls, t
the Director of NJDEPE's Division of Environmental Safety, Health and Analytical
- Programs, which includes NJDEPE's radiation protection program, was with Assistant Commissioner Sinding as part of a conference call.
Director Nicholls' staff had previously met with LIPA and PECo represencatives, including Mr. Freeman, to discuss the technical details of the possible use of a barge and the staff had been briefed on the safety features. I
r Upon Mr. Freeman's advice, Assistant Commissioner Sinding also contacted a LIPA representative to similarly
- express j
NJDEPE's objection and concerns.
When a response from neither PECo nor LIPA was forthcoming, Assistant Commissioner Sinding assumed that the rcute through the State's coastal zone was abandoned or at least delayed until NJDEPE's concerns were addressed.
However, upon return from vacation in the middle of r
- August, 1993, Assistant Commissioner Sinding read in a newspaper article that PECo and LIPA planned to proceed irrespective of NJDEPE's objections.
PECo and LIPA's plan was confirmed when he was advised by his staff that LIPA had submitted an application for NJDEPE's Certificate of Handling.
Assistant Commissioner Sinding was very surprised to learn of PECo and LIPA's plan to proceed absent NJDEPE's concurrence.
(See Certification of Richard V.
Sinding and allegation number 20).
13.
The proposed barge route for the 33 shipments is a route from Long Island, south through the Atlantic Ocean 15 miles off-shore of the State's coast, around Cape May, through the State's waters in the Delaware Bay and up the Delaware River, finally docking in Eddystone, Pennsylvania.
i 14.
In February 1993, LIPA filed with NRC an " Updated l
Decommissioning Plan" for Shoreham. (Ex.
"A" attached to the Verified Complaint).
That plan contained only a brief and tentative discussion of " fuel disposal alternatives," and LIPA I
acknowledged that as those alternatives emerged it would have i i
F l
Le FRED DeVESA ACTING ATTORNEY GENERAL OF NEW JERSEY i
Attorney for Plaintiffs R.J.
Hughes Justice Complex CN 093 Trenton NJ 08625 l
UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY STATE OF NEW JERSEY, et al.,
Civil Action No.
Plaintiffs, v.
{
LONG ISLAND POWER AUTHORITY, et al.,
Defendants.
i I
RICHARD V.
- SINDING, of full age, being duly sworn according to law, upon his oath deposes and says:
1.
I am an Assistant Commissioner employed by the i
New Jersey Department of Environmental Protection and Energy
("NJDEPE");
2.
As Assistant Commissioner for Policy and Planning I have participated in various discussions regarding the Long Island Power Authority's proposed shipment of nuclear fuel to Pennsylvania along the New Jersey coast, through the Delaware Bay, and up the Delaware River; 3.
I have read allegation number twelve (12) in the Verified Complaint on behalf of the New Jersey Department of Environmental Protection and Energy and Jeanne M.
Fox attached hereto.
As to allegation number twelve (12), I have knowledge of the mattets 'Tiscussed therein.
As to allegation number
)
a twelve (12),
the factual allegations contained therein are true.
l s
Richarp V./ Sinding Assistang Commissioner Sworn to and Subscribed before me this 2_.I day of September, 1993
_ 1 __
p J AQ-p-N PW9
{
I 2
-