ML20129C029
| ML20129C029 | |
| Person / Time | |
|---|---|
| Site: | 07109271, Trojan File:Portland General Electric icon.png |
| Issue date: | 10/17/1996 |
| From: | Quennoz S PORTLAND GENERAL ELECTRIC CO. |
| To: | Travers W NRC |
| References | |
| VPN-065-96, VPN-65-96, NUDOCS 9610230187 | |
| Download: ML20129C029 (16) | |
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Portland General Electric Company Stephen M. Quennoz Trojan Site Executive October 17,1996 VPN-065-96 William D. Travers Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 1
Dear Mr. Travers,
Irgj_an "' clear Plant Reactor Vessel Package The Trojan Decommissioning PA. submitted and approved by the NRC provides for the prompt decommissioning of the plant. This plan currently provides for the removal and segmentation of the internals and the options of segmenting or removing the Reactor Vessel whole. These methods were proposed based on projects completed by other facilities. Since the Decommissioning Plan was submitted, additional evaluation of methods for disposal of the internals and the vessel were performed. This evaluation determined that the intact disposal of the Reactor Vessel and Internals provided significant benefits and advantages .
This evaluation determined that the intact removal of the vessel and internals results in decreased radiation exposure to the plant workers, reduction in the number of radioactive shipments resulting in a decreased exposure to the public during transportation, reduced risk for transportation accidents, elimination of potential risks and problems associated with the segmentation of the internals and disposal of the highly activated components, and a significant cost savings. Based on these advantages, disposal as a single package is the preferred ;pproach.
A major consideration in this project is the ability to design, package, and transport the package safely and in accordance with the design requirements of 10 CFR 71 for a Type B (U) package.
PGE developed a propmed method for packaging and transporting the package and has worked with your staff to reviev. our proposal and resolve their concerns. Based on these meetings, PGE has made a significant revision to the previous approach. This includes the addition ofimpact limiters to the package, analyzing and designing the package to meet a l' drop, analyzing and designing the package to meet an alternative drop for the Hypothetical Accidents, and modifying our shipment schedule to correspond to summer months.
Attachment I provides a synopsis of the design requirements specified by 10 CFR 71 and PGE's position. Attachment II addresses the specific areas as noted on Attachment I and other concern 9610230187 961017 PDR ADOCK 07109271 C
230085 PDR f&( l 71760 Columbia River Highway. Rainiet OR 97048 503/556-3713
VPN-065-96 '
' Page 2 of 2 areas. Based on the design reviews, PGE is confident that the RVP can be designed, packaged, and transported safely and can be licensed as a Type B package. PGE is willing to work with your staff to resolve their concerns.
This issue impacts both the design of the Independent Spent Fuel Storage Installation as well as the Trojan Nuclear Plant deconunissioning schedule. PGE needs to resolve any programmatic or policy issues you or your staffmay have with this issue. PGE will contact your office in approximately one week to discuss this matter and establish a meeting schedule to resolve concerns. Please feel free to contact Paul Yundt of my staff at (503) 556-7492 ifyou have any questions.
Sincerely, Cf 341 for Step en M Quennoz Trojan Site Executive i Attachments l
c: M. T. Masnik, NRC, NRR C. R. Chappell, NRC, NRR ;
N. L. Osgood, NRC, NRR l
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Attachment I Page1 of13 VPN-065-96 October 17.1996 -
10CFR71 Synopsis of Requirement Proposed Method of Compliance Section SUBPART D APPLICATION FOR PACKAGE APPROVAL 71.33 The application must inclu.de a description of the PGE has determined that the Reactor Vessel proposed package in suflicient detail to identify the Package (RVP) will be classified as a Type B(U) package.
package accurately and provide a suflicient basis for A Safety Analysis Report (SAR)will be submitted using the evaluation or the package. guidance of Regulatory Guide 7.9.
71.35(a) The application must include a demonstration that the Each of the requirements for Subparts E and Supart F and package satisfies the standards specified in Subpart E the method of compliance are addressed under Sections (71.4I through 71.65) and Subpart F (i.e.,71.71 71.41 through 71.77.
through 71.77) 71.35(b) The application for a fissile material package must The RVP will constitute a single shipment. The RVP will include the allowable number of packages that may be contain less than 15 gms of fissile material and is therefore transponed in the same vehicle in accordance with exempt from classification as a fissile material 71.59. classification in accordance with 71.53(a).
71.35(c) The application for a fissile material shipment must The RVP SAR will include a discussion of the handling include any special controls and precautions for and transporting of the package.
transport, loading, unloading, and handling and any proposed special controls in case of an accident or delay.
71.37 The application shall describe the Quality Assurance The QA Program for the RVP will be controlled by the (QA) program for design, fabrication, assembly, existing 10CFR50 Appendix B program " Trojan Nuclear testing, maintenance, repair, modification, and use of Plant (TNP) QA Program (PGE-8010). The QA program the proposed package. was revised on November 2,1994 to include the criteria of 10 CFR 71, Subpan H.
Attachment I Page 2 of13 VPN-065-96 ~ October 17.1996 -
10CFR71 Syncpsis of Requirement Proposed Method of Compliarice Section !
SUBPART E PACKAGE APPROVAL STANDARDS l i
71.41 Demonstration of Compliance 71.41(a) The effects on a package of the test specified 71.71 The efTects on the package in accordance with the (Normal Conditions of Transport) and those specified specified tests will be demonstrated analytically.
in 71.73 (Hypothetical accident conditions) must be evaluated by a specimen, scale model, or other method acceptable to the NRC.
71.41(b) Taking into account the type ofvehicle, the method The RVP SAR will contain a description of the of securing or attaching the package, and the controls transporter, the method of securing the package to the to be exercised by the shipper, the NRC may permit transporter, and the shipping controls.
the shipment to be evaluated together with the transporter vehicle.
71.41(c) Environmental and test conditions difTerent from For the hypothetical drop accident (71.73(c)(1)), PGE those approved in 71.71 and 71.73 may be approved proposes to perform an analysis based on specific route by the NRC if the controls proposed to be exercised and method of transport. For the Normal Conditions of by the shipper are demonstrated to be adequate to Transport I foot drop, PGE proposes to define package provide equivalent safety of the shipment. orientation based on method of transport. Attachment II provides additional information.
71.43 General Standards for all packages 71.43(a) The smallest overall dimension of a package may not The smallest overall dimension of the RVP package will be less than 10cm (4in.) not be smaller than 4 in. The smallest overall dimension of the RVP will be approximately 192 in.
Attachment I Page 3 of13 ;
VPN-065-96 October 17.1996 -
10CFR71 Synopsis of Requirement Proposed Method of Compliance l Section !
71.43(b) The package must incorporate a feature such as a seal The RVP will consist of the reactor vessel, welded i that while intact would demonstrate that the package penetration closures, and the bolted reactor vessel head.
has not been opened (i.e. Tamper Proofindication) A tamper proofindicator will be provided on the head l bolts. l t
71.43(c) The package must include a containment system The RVP containment boundary will consist of the reactor !
securely closed by a positive fastening device that vessel with the head installed and bolted. Penetrations will j cannot be opened unintentionally or by a pressure that have welded enclosures. Calculations will demonstrate !
may arise within the package. that maximum credible pressure will not result in failure of :
the containment boundary.
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71.43(d) The package must be made ofmaterial and The RVP will be constructed of compatible materials and i construction that assure there will be no significant an evaluation will be provided to demonstrate this !
chemical, galvanic, or other reaction aniong requirement is met. [
packaging components and/or contents. The effect of water in leakage must be considered.
71.43(e) A package valve or other device whose failure could The RVP will not be provided with a valve or other device l ~
result in allowing the radioactive contents to escape whose failure could result in the release of radioactive must be protected against unauthorized operation. failure.
i 71.43(f) The package must be designed, constructed, and The acceptance criteria specified by 71.43(f) will be [
prepared for shipment so that under the tests specified applied to the test analysis required by 71.71(Normal ;
in s71.71 there would be no loss or dispersal of Conditions of Transport). The test requirements specified radioactive contents, no significant increase in for the Normal Conditions ofTransport are discussed l external radiation levels, and no substantial reduction individually under Section 71.71 of this table. i in package effectiveness.
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Attachment I Page 4 of13 VPN-065-96 October 17.1996 -
10CFR71 Synopsis of Requirement Proposed Method of Compliance Section 71.43(g) A package must be designed, constructed, and An analysis will be performed and presented in the RVP prepared for transport so that in still air at 38'C and SAR using the conditions specified in 71.71(c)(1) to in shade no accessible surface temperature will exceed demonstrate compliance with this acceptance criteria.
85'C (limit is for exclusive use) 71.43(h) A package may not incorporate a feature intended to The design will not include a feature to allow venting allow continuous venting during transport. during transportation.
71.45 Lifting and tie-down standards for all packages 71.45(a) Any lifling attachment that is a structural part of the The design of the RVP does not include a lifling package must be designed with a minimum safety attachment that will be a structural component.
factor of 3 against yielding when used to lift the package.
71.45(b)(1) Tie-down devices that are a structural part of the Attachment II provides a discussion of the method that package, must be capable of withstanding a static will be used to secure the RVP to the transporter including force of 2g vertical,5g transverse, and 10g horizontal design criteria.
without generating stress in any material of the package in excess ofyield strength.
71.45(b)(2) Any other structural part of the package that could be Attachment II provides a discussion of the method that used to tie down the package must be rendered will be used to secure the RVP to the transporter including inoperable or meet the requirements of 71.45(b)(1) design criteria.
Attachment I Page 5 of13 VPN-065-96 October 17.1996 -
10CFR71 Synopsis of Requirement Proposed Method of Compliance Section '
71.45(b)(3) Each tie-down device that is a structural part of a Attachment Il provides a discussion of the method that -
package musts be designed so that failure of the will be used to secure the RVP to the transporter including device under excessive load would not impair the design criteria.
ability of the package to meet other requirements of this part.
71.47 External radiation standards for all packages 71.47(a) Except as provided in 71.47(b) the package must be The RVP will be transported as exclusive use, therefore, designed so that under the normal conditions incident the limits of 71.47(b) are applicable.
to transport the radiation level does not exceed 200 mrem /hr at any point on the external surface of '
the package and the transport index does not exceed 10.
71.47(b) A package that exceeds the radiation limits of The RVP shielding will be designed to limit external t 71.47(a) must be transported by exclusive use package dose rates to less than or equal to 200 mr/hr.
shipment only, and the radiation limits must not exceed 200 mr/hr (a limit of 1000 mr/hr is allowed if additional restrictions are followed) 71.47(c) For shipments made under the provisions of 71.47(b) The RVP will be a one-time exclusive use shipment. A ,
written instructions must be included with the procedure will accompany the shipment providing written shipping paper information. instructions to ensure the requirements / assumptions of the .
RVP SAR are implemented.
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Attachment I Page 6 of13 VPN-065-96 October 17.1996 10CFR71 Synopsis of Requirement Proposed Method of Compliance Section 71.47(d) The written instructions required for exclusive use Written instructions (procedure) will be provided to shipments must be sufficient so that when followed accompany the RVP during transportation.
they will not unnecessarily delay delivery or result in increased radiation levels or exposures to transport workers or members of the public.
71.51 Additionni requirements for Type B packages 71.51(a)(1) A Type B package must be designed, constructed, The RVP will meet the specified accident conditions for and prepared for shipment so that under the Normal the Normal Conditions of Transport (71.71)
Conditions ofTransport (71.71) there would be no loss or dispersal of radioactive contents, as demonstrated to a sensitivity of 104 A2 Per hour, no significant increase in external surface radiation levels, and no substantial reduction in package efTectiveness.
71.51(a)(2) A Type B package must be designed, constructed, The RVP will mm: the specified condition and prepared for shipment so that under Hypothetical Accident Conditions (71.73) there would be no escape of Kr" exceeding 10A2in I week, no escape ofother radioactive material exceeding a total amount A2 in I week, and no external radiation at im from external
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surface of the package.
71.51(b) Where mixtures of different radic nuclides are The RVP will contain mixtures of different radio nuclides.
present, the provisions of Appendix A, paragraph IV The method presented in paragraph IV of Appendix A will i of thispart shall apply except that Kr", an efTective be used to determine the effective value of A2-value of 10A 2may be used. ;
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Attachment I Page 7 of13 VPN-065-96 October 17.1996 -
10CFR71 Synopsis of Requirement Proposed Method of Compliance Section 71.51(c) Compliance with the permitted release limits of The RVP design will not incorporate filters or mechanical 71.51(a) may not rely on filters or mechanical cooling cooling systems.
systems.
71.53 Fissile material exemption 71.53(a) A package containing not more than 15g of fissile The RVP will contain less than 15g of fissile material material is exempt from the fissile material standards (present fissile material content is analyzed to be of 71.55 and 71.59. approximately 3.6 grams) 71.55 General requirements for fissile material packages The RVP will contain less than 15 g of fissile material (present fissile material content is analyzed to be approximately 3.6 grams) and is therefore exempt from the requirements of 71.55 as provided by 71.53.
71.59 Standards for arrays of fissile material packages The RVP will contain less than 15 g of fissile material (present fissile material content is analyzed to be approximately 3.6 grams) and is therefore exempt from the requirements of 71.59 as provided by 71.53.
71.61 Special requirements for irradiated nuclear fuel shipments The RVP will not be used for the shipment ofirradiated nuclear fuel, therefore this requirement is not applicable.
71.63 Special requirements for plutonium shipments This requirement is applicable for shipments which contain in excess of 20 Ci of Plutonium. The RVP is anticipated to contain approximately 12Ci of Plutonium, therefore the requirements of this section are not applicable to the RVP SAR.
Attachment I Page 8 of 13 VPN-065-96 October 17.1996 10CFR71 Synopsis of Requirement Proposed Method of Compliance Section 71.64 Special requirements for plutonium air shipments The RVP will not be shipped by air, therefore the requirements of 71.64 are not applicable.
SUBPART F PACKAGE, SPECIAL FORM, AND LSA-III TFSTS 71.71 Normal Conditions of Transport 71.71(a) Evaluation of the package design under the normal The RVP SAR will analytically demonstrate compliance conditions of transport must include a determination with the acceptance criteria for the tests specified for the of tl e effect on that design of the conditions and test Normal Conditions ofTransport (71.71).
specified in this section. Separate specimens may be used for the free drop test, compression test, and .
penetration test provided et.ch specimen is subjected s to the water spray test prior to performance of other ,
tests.
71.71(b) The initial conditions for the test in this section must The RVP will be analyzed to determine compliance with be based on ambient temperatures preceding and the test conditions specified for the Normal Conditions of ,
following the tests remaining constant between - Transport (71.71). Each of these analyses and the 29"C(-20*F) and +38"C(100*F) which is most assumptions regarding temperature and pressure are unfavorable for the test being conducted. The initial discussed for the nine (9) different tests specified in internal pressure within the containment boundary 71.71(c).
must be considered to be the maximum normal operating pressure, unless a lower internal pressure i consistent with the ambient temperature considered i for the test is more unfavorable.
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Attachment I Page 9 of13 VPN-065-96 October 17.1996 10CFR71 Synopsis of Requirement Proposed Method of Compliance Section 71.71(c)(1) (IIeat) The package will be evaluated at an ambient The RVP will be evaluated using the conservative temperature of 38"C in still air and insolation conditions specified in 71.71(b). The acceptance criteria according surface shape and orientation during of 71.43(f), 71.43(g) and 71.51(a)(1) will be imposed to transport. demonstrate compliance.
71.71(c)(2) (Cold) The package will be evaluated at an ambient The RVP will be evaluated using the conservative temperature of-40 C in still air. conditions specified in 71.71(b). The acceptance criteria of 71.43(f), 71.43(g) and 71.51(a)(1) will be imposed to demonstrate compliance.
71.71(c)(3) (Reduced External Pressure) The package will be The RVP will be evaluated using the conservative evaluated at an extemal pressure of 25 kPa (3.5 psi) conditions specified in 71.71(b). The acceptance criteria absolute. of 71.43(f),71.43(g) and 71.51(a)(1) will be imposed to demonstrate compliance.
71.71(c)(4) (Increased External Pressure) The package will be The RVP will be evaluated using the conservative evaluated at an external pressure of 140 kPa (20 psi) conditions specified in 71.71(b). The acceptance criteria absolute. of 71.43(f), 71.43(g) and 71.51(a)(!) will be imposed to demonstrate compliance.
71.71(c)(5) (Vibration) The package will be evaluated at vibration The RVP will be evaluated usi.g the conservative normally incident to transportation. conditions specified in 71.71(b). The acceptance criteria of 71.43(f), 71.43(g) and 71.51(a)(1) will be imposed to demonstrate compliance.
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Attachment I Page 10 of13 VPN-065-96 October 17.1996 -
10CFR71 Synopsis of Requirement Proposed Method of Compliance j Section !
71.71(c)(6) (Water Spray) The package will be evaluated with a The RVP will consist of the reactor vessel, reactor vessel water spray that simulates exposure to rainfall of head, and welded steel closure plates for vessel and head ;
approximately 5 cm/h for at least I hour. penetrations. A qualitative analysis will be provided in the RVP SAR to demonstrate the ability of the package to withstand exposure to the water spray criteria. ;
71.71(c)(7) (Free Drop) The packagevill be evaluated for a free _ The RVP will be evaluated using the conservative - i drop through a distance of 1 foot (based on weight of conditions specified in 71.71(b). The acceptance criteria package) onto a flat, unyielding surface, striking the of 71.43(f), 71.43(g) and 71.51(a)(1) will be imposed to ,
surface in a position for which maximum damage is demonstrate compliance. PGE proposes to specify the '
expected. The test follow within 1.5 to 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of drop orientation based on the method of transport.
l conclusion ofwater spray test. ;
71.71(c)(8) (Corner Drop) This test npSes only to fiberboard, This test would not be applicable to the RVP since the wood, or fissile material not etceeding 110lbs for minimum estimated weight of the package is 820 tons. .
rectangular packages or 220!bs for cylindrical packages.
71.71(9) (Comprenion) TiJ< test is applicable for packages This test would not be applicable to the RVP since the
- weighing up to 11,000lbs. minimum estimated weight of the package is 820 tons.
71.71(10) (Penetration) The package will be evaluated for an The RVP will be evaluated using the conservative impact of a hemispherical end of a vertical steel conditions specified in 71.71(b) for the test specified in cylinder of 3.2 cm diameter and 6kg mass dropped 71.71(10) The acceptance criteria of 71.43(f), 71.43(g) from a height of 1m onto the exposed surface of the and 71.51(a)(1) will be imposed to demonstrate
- package that is expected to be most vulnerable to compliance. j' puncture. The long axis of the cylinder must be perpendicular to the package surface.
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Attachment I Page1I of13 VPN-065-96 October 17.1996 -
10CFR71 Synopsis of Requirement Proposed Method of Compliance Section 71.73 Ilypothetical accident conditions 71.73(a) Evaluation for hypothetical accident conditions is to The Hypothetical Accident Conditions (71.73) analyzed be based on sequential application of the tests conditions will meet the acceptance criteria specified by specified in thi:: section in the order indicated to 71.51.
determine the cumulative effect on the package. An undameged specimen may be used for the water immersion test specified by 71.71(c)(6) 71.73(b) The initial conditions for the test (except vater The initial conditions specified by 71.73(b) will immersion test of 71.73(c)(6)) in this sectica mest be be used in the analysis for each of the required based on ambient temperatures preceding and Hypothetical Accident Conditions.
following the tests remaining constant between -29*C and +38*C which is most unfavorable for the test being conducted. The initial internal pressure within the containment boundary must be considered to be the maximum normal operating pressure, unless a lower internal pressure consistent with the ambient teraperature considered for the test is more unfavorable.
71.73(c)(1) (Free Drop) The package must be evaluated for a free Attachment II provides the proposed method of drop of 30f1 onto a flat essentially unyielding compliance with this requirement.
horizontal surface in a position for which maximum damage is expected.
Attachment 1 Page 12 of 13 VPN-065-96 October 17.1996 -
10CFR71 Synopsis of Requirement Proposed Method of Compliance Section 71.73(c)(2) (Crush) This test is only required for packages with a This test is not applicable to the RVP since its weight is mass not greates than 1100 bounds, and overall greater than 1100 lbs.
density not greater than 62.4 lbs/ft', and radioactive contents greater than 1000A2 not as special form radioactive material.
71.73(c)(3) (Puncture) The package must be evaluated for a free An analysis of the RVP for the conditions specified by drop of im onto the upper end of a solid, vertical 71.73(c)(3) will be present in the RVP SAR.
cylindrical, mild steel bar mounted on a horizontal, unyielding surface. The position of the package is to be selected to result in maximum anticipated damaged.
71.73(c)(4) (Thermal) The package must be evaluated for timed An analysis of the RVP for the conditions specified by average temperature of 800*C for a period of30 71.73(c)(4) will be present in the RVP SAR.
minutes.
71.73(c)(5) (Immersion-fissile material) For fissile material The RVP contains less than 15g offissile material and is subject to 71.55, in those cases where water in therefore not subject to the requirements of 71.55 as leakage has not been assumed for criticality analysis, provided by 71.53. This test is therefore not applicable to immersion under a heat of at least 3ft for which the RVP design.
maximum leakage is expected.
71.73(c)(6) (Immersion - all packages) A separate undamaged An analysis of the RVP for the conditions specified by package must be analyzed for immersion under at 71.73(c)(6) will be present in the RVP SAR.
least 50ft ofwater. An external pressure of water of 150kPa gauge is considered to meet these conditions
j Attachment I Page 13 of13 VPN-065-96 October 17.1996 10CFR71 Synopsis of Requirement Proposed Method of Compliance Section 71.74 Accident conditions for air transport of plutonium The RVP contains less than 20 Ci of plutonium and will not be transported by air, therefore the requirements of 71.74 are not applicable.
71.75 Qualification of special form radioactive material The RVP does not meet the definition for special nuclear material provided in 71.4, therefore the requirements of -
71.75 are not applicable.
71.77 Qualification of LSA-III Material The RVP does not meet the definition for LSA-III material provided in 71.4, therefore the requirements of 71.75 are not applicable.
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Attachment II Page1 of2 VPN-065-96 October 17,1996 Alternative Conditions and Discussion Items l Normal Conditions ofTransport - 1 foot Drop The Reactor Vessel Package will be loaded and secured onto the transporter and will not be handled until the package is off-loaded at the disposal facility. The transporter, loaded with the package will be driven onto a barge and then secured to the barge. The transporter / package will be barged up the Columbia River to the Port of Benton where it will be driven off the barge and travel overland to the disposal facility. During transport the package will be oriented in the
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horizontal position (i.e. the centerline longitudinal axis of package will be horizontal). Because of the unique size, mass and bulk of the package, no other orientation is considered feasible during the normal conditions of transport.
Based on this, the analysis will consider a 1 foot horizontal drop and a 1 foot drop of either end with the opposite end considered held in place.
Hvoothe_tical Accident Condition - 30' Dron The Reactor Vessel Package is a one-time shipment under a well defined, planned, and controlled evolution. The operational controls established for the transport of the Steam Generators will be used for this effort. This transportation methodology is significantly different than the conditions anticipated to occur during the typical transport of a Type B package. PGE proposes to perform a drop analysis based on the specific route and method of transport as provided by 71.41(c), or by an exemption request as provided by 71.8. PGE will work with the NRC staff to establish the acceptable parameters for this condition.
Shieldine The shielding will be designed and installed to remain attached for the analyzed normal and accident conditions.
Reculatory Guide 7.12 PGE will perform an ASME Section XI fracture initiation criterion based analysis as referenced in R.G. 7.12. This analysis will be based on the actual stresses determined in the analysis for the Normal and Accident Conditions. The design of the RVP will include impact limiters to maintain stress on the vessel well below yield conditions. This analysis will show that the intent of R.G.
7.12 is met and that the vessel will not fail. To provide additional margin the actual package shipment will be conducted during the summer months of the year.
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VPN-065-96 October 17,1996 1 Tie-down System The RVP tie-down system consists of pedestal assemblies positioned on the transporter and located under the upper head flange and vessel barrel near the lower head tangent point. Vertical j upward forces are resisted by cables running over the top of the RVP at the pedestal locations.
Longitudinal loads are resisted by a blocking beam assembly which captures two of the eight outlet nozzles which project from the vessel. 4 The reactor vessel nozzles will be analyzed for the ability to withstand the simultaneous application of 2g vertical, Sg transverse, and 10g longitudinal without generating stress in any material of the package in excess ofits yield strength.
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