ML20133H702

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Forwards NRC GL 96-07, Interim Guidance on Transportation of Sgs
ML20133H702
Person / Time
Issue date: 12/05/1996
From: Rathbun D
NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA)
To: Gingrich N, Gore A, Murphey R
GENERAL ACCOUNTING OFFICE, HOUSE OF REP., SPEAKER OF THE HOUSE, SENATE, PRESIDENT OF THE SENATE
References
CCS, GL-96-07, GL-96-7, NUDOCS 9701170265
Download: ML20133H702 (3)


Text

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,a ***ug g *4 UNITED STATES g j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. enmas anni "s,*****/ December 5, 1996 i

The Honorable Albert Gore President of the United

, States Senate Washington, DC 20510

Dear Mr. President:

Pursuant to Subtitle E cf the Small Business Regulatory Enforcement Fairnes Act of 1996. 5 U.S.C. 801, the U.S. Nuclear Regulatory Commission is submitting a generic letter (i.e. , a final rule) that will inform NRC licensees that the U.S. Department of Transportation (DOT) and NRC have agreed

, on how DOT and NRC transportation regulations apply to shiament of discarded steam generators from nuclear power plants. Revisions to 20T and NRC regulations gonerally became effective April 1.1996, and have changed the regulatory framework under which steam generators are shipped.

l Because of fouling or cracking of heat transfer surfaces, several nuclear utilities have replaced, or plan to replace, their steam generators. The discarded steam generators are very large components that have radioactive contamination on their interior surfaces and consequently must be shipped for disposal or processing pursuant to the hazardous material transportation regulations. The guidance in the generic letter will help ensure that such shipinents are safe. consistent, and practical.

We have &sermined that this rule is not a " major rule" as defined in 5 U.S.C.

804(2). We have confirmed this determination with the Office of Management and Budget.

Enclosed is a copy of the generic letter that is being issued to applicable NRC nuclear power reactor licensees.

Sincerely, K

  • Dennis K. Rathbun. Director l Office of Congressional Affairs l

Enclosure:

Generic Letter 9701170265 961205 PDR ORG NRCCO PDR

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NUCLEAR REGULATORY COMMISSION WASHINGTON D.C. sose64001

's...../ December 5, 1996 The Honorable Robert P. Murphey General Counsel General Accounting Office Room 7175 441 G. St., NW Washington, DC 20548

Dear Mr. Murphey:

Pursuant to Subtitle E of the Small Business Regulatory Enforcement Fairness Act of 1996. 5 U.S.C. 801, the U.S. Nuclear Regulatory Commission is submitting a generic letter (i.e., a final rule) that will inform N'dC licensees that the U.S. bepartment of Transportation (DOT) and NRC have agreed on how DOT and NRC transportation regulations apply to shiament of discarded steam generators from nuclear power plants. Revisions to MT and NRC regulations generally became effective April 1.1996, and have changed the regulatory framework under which steam generators are shipped.

Because of fouling or cracking of heat transfer surfaces, several nuclear utilities have replaced, or plan to replace, their steam generators. The discarded steam generators are very large components that have radioactive contamination on their interior surfaces and consequently must be shipped for  !

disposal or processing pursuant to the hazardous material transportation regulations. The guidance in the generic letter will help ensure that such shipments are safe, consistent, and practical.

We have determined that this rule is not a " major rule" as defir,ed in 5 U.S.C.

804(2). We have confirmed this determination with the Office of Management and Budget.

Enclosed is a copy of the generic letter that is being issued to r -licable NRC nuclear power reactor licensees.

Sincerely, v

4 Dennis K. Rathbun. Director Office of Congressional Affairs

Enclosure:

Generic Letter Y

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ps# 4 p t UNITED STATES y

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NUCLEAR REGULATORY COMMISSION WASHINGTON. D.C. eanas anni

\*****/ December 5, 1996 The Honorable Newt Gingrich Speaker of the United States House of Representatives Washington. DC 20515

Dear Mr. Speaker:

Pursuant to Subtitle E of the Small Business Regulatory Enforcen, ant Fairness Act of 1996. 5 U.S.C. 801, the U.S. Nuclear Regulatory Commission is submitting a generic letter (i.e. a final rule) that will inform NRC licensees that the U.S. Department of Transportation (DOT) and NRC have agreed on how DOT and NRC transportation regulations apply to shi) ment of discarded steam generators from nuclear power plants. Revisions to X)T and NRC regulations generally became effective April 1.1996, and have changed the regulatory framework under which steam generators are shipped.

Because of fouling or e, racking of heat transfer surfaces, several nuclear utilities have replaced, or plan to replace, their steam generators. The discarded steam generators are very large components that have radioactive contamination on their interior surfaces and consequently must be shipped for disposal or processing pursuant to the hazardous material transportation regulations. The guidance in the generic letter will help ensure that such shipments are safe, consistent, and practical.

We have determined that this rule is not a " major rule" as defined in 5 U.S.C.

804(2). We have confirmed this determination with the Office of Management .

ano Budget. j Enclosed is a copy of the generic letter that is being issued to applicable NRC nuclear power reactor licensees.

Sincerely.

An ~ n l N

Dennis K. Rathbun. Director Office of Congressional Affairs l l

Enclosure:

Generic Letter l

I

O UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS >

WASHINGTON, D.C. 20555 December 5,1996 NRC GENERIC LETTER 96-07: INTERIM GUIDANCE ON TRANSPORTATION OF STEAM GENERATORS Addressees All holders of operating licenses and decommissioning fa::ilities with possession-only '

licenses for pressurized-water nuclear power reactors.

Purpose The U.S. Nuclear Regulatory Commission (NRC) is issuing this letter to notify addressees that the U.S. Department of Transportation (DOT) and the NRC have agreed on how DOT and NRC transportation requirements apply to the shipping of  ;

discarded steam generators. The guidance below will help ensure that methods of shipping steam generators are both safe and practical. It is expected that recipients will review the information for applicability to their facilities and consider actions, as appropnate. However, suggestions contained in this generic letter are not NRC requirements; therefore, no specific action nor written response is required.

1 Descriotion of Circumstances DOT and NRC transportation regulations for shipment of radioactive materials were recently revised to be compatible with those of International Atomic Energy Agency (IAEA) Safety Series No. 6,1985 edition. The revisions generally became effective April 1,1996, and have changed the regulatory framework under which steam generators are shipped.

Neither the previous nor the revised IAEA, DOT, nor NRC trcasportation regulations specifically address the shipment of large components, including steam generators.

Several power reactors, or reactors undergoing decommissioning, plan to ship discarded steam ganerators shortly. The following information provides interim guidance on the shipment of steam generators under the revised regulations. In addition to this action, NRC and DOT are jointly studying large component transportation issues. The shipment of steam generators and other large components may be specifically addressed in future guidance and revisions of international and domestic transportation regulations.

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l GL 96-07 Dsccmbsr 5,1996 Page 2 of 3 Discussion DOT and NRC have agreed that steam generators may generally be shipped under DOT procedures and requirements as outlined below:

(1) DOT has determined that steam generators are best categorized as surface contaminated objects (SCOs). Although the average surface contamination '

level over the internals of a steam generator may be shown (through calculation, reasoned argument, and/or measurement) to meet the limits for inaccessible surfaces in the applicable SCO definition, the requirement is that 2

the contamination be averaged over each 300 cm (46.5 in2 ). It is impractical to measure the contamination level on each 300 cm2 (46.5 in 2) of the steam generator internals; therefore, reasoned arguments and calculations should be used. At a minimum, the following uncertainties should be accounted for in the analyses: (a) dose to curie conversions; (b) material differences and uneven crud composition / deposition in the channel head bowl, divider plate, tube sheet, and tunes; and (c) the source term identification (e.g., scaling ratios, transurcnic contribution to A2 total). If significant uncertainty remains concerning the distribution of deposited activity on steam generator surfaces, the licensee should obtain approval from DOT that the steam generator can be properly classMied for shipment as SCO.

(2) The maximum radiation level at 3 meters (9.84 feet) from the unshielded contents [see 49 CFR 173.427(a)(1) and 10 CFR 71.10(b)(2)] is defined as the largest measured or calculated dose rate 3 meters (9.84 feet) from any point i on the outside housing of an unshielded steam generator. Materials securely fastened (e.g., welded) onto the steam generator, to seal penetrations, are considered part of the steam generator, for these purposes.

(3) DOT has determined that the outside housing of a steam generator is ,

considered as part of the " unshielded contents" (i.e., the dose rate is measured I from the outside shell). Therefore, the entire steam generator is considered to be the radioactive material contents, and there is no " package" as defined in 49 CFR 173.403. Shippers wishing to ship an unpackaged steam generator as an SCO would, therefore, need to request that DOT grant them relief from the regulatory requirement to package SCO, given the special nature and practical considerations for steam generator shipments. The request should be made in accordance with 49 CFR Part 107, and should demonstrate that the unpackaged, sealed steam generator provides the safety equivalent to an Industrial Packaging (IP). If such relief (from the requirement that a steam generator be packaged)is not granted, then a steam generator shipped as an SCO must be shipped in an IP or Type A package, pursuant to 49 CFR 173.427.

(4) If shipped as an SCO, a steam generator is subject to the SCO conveyance activity limit of 100 A 2given in 49 CFR 173.427, Table 9.

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GL 96-07 i -

December 5,1996 Page 3 of 3

) (5) If the necessary DOT approvals are obtained, and if the requirements of 10 1

CFR 71.10 are otherwise met, no exemptions from NRC requirements are needed for the provisions of 10 CFR 71.10 to take effect.

) NRC licensee shipments of steam generators are subject to NRC inspection for i compliance with the DOT regulations, pursuant to 10 CFR 71.5. It is particularly l important that each licensee maintain complete documentation of any tests or evaluations required by DOT, for complying with the conditions specified in item (3),

above, for shipping steam generators as unpackaged SCO. These may include engineering evaluations of the unpackaged steam generator's ability to meet the IP or Type A package design standards and criteria,if required by DOT as a compensatory measure for permitting the unpackaged shipment. The requirements for documenting the design of IP and Type A packaging are given in 49 CFR 173.411(c) and 49 CFR 173.415, respectively.

This generic letter requires no specific action nor written response. If you have questions about this matter, please contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor Regulation project manager.

s 1 i Charles J. Hau ney, Actin irecto Spent Fuel Project Offic l Office of Nuclear Material Safety and Safeguards Technical contacts: Richard Boyle, DOT (202) 366-4545 E-mail: rick.boyle@rspa. dot. gov Earl P. Easton, NMSS (301) 415-8520 E-mail: exe@nrc. gov

Attachment:

List of Recently Issued NRC Generic Letters

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  • Attachmsnt GL 96-07 December 5,1996 Page 1 of 1 LIST OF RECENTLY !SSUED GENERIC LETTERS Generic Date of Letter Subiect issuance issued To 96-06 ASSURANCE OF EQUIPMENT 11/13/96 ALL HOLDERS OF OLs OPERABILITY AND CONTAIN- FC R NPRs, EXCEPT FOR MENT INTEGRITY DURING THOSE LICENSES THAT DESIGN-BASIS ACCIDENT HAVE BEEN AMENDED TO CONDITIONS POSSESSION-ONLY STATUS 96-05 PERIODIC VERIFICATION OF 09/18/96 ALL HOLDERS OF OLs DESIGN-BASIS CAPABILITY (EXCEPT THOSE LICENSES OF SAFETY-RELATED MOTOR- THAT HAVE BEEN AMENDED OPERATED VALVES TO POSSESSION-ONLY STATUS) OR cps FOR NPRs 96-04 BORAFLEX DEGRADATION IN 06/26/96 ALL HOLDERS OF OLs SPENT FUEL POOL STORAGE FOR NPRs RACKS 95-09, MONITORING AND TRAINING OF 04/05/96 ALL U.S. NUCLEAR SUPP.1 SHIPPERS AND CARRIERS OF REGULATORY COMMISSION RADIOACTIVE MATERIALS LICENSEES 96-03 RELOCATION OF THE PRES- 01/31/96 ALL HOLDERS OF OLs SURE TEMPERATURE LIMIT OR cps FOR NPRs CURVES AND LOW TEMPERA-TURE OVERPRESSURE PRO-TECTION SYSTEM LIMITS 96-02 RECONSIDERATION OF 01/31/96 ALL HOLDERS OF OLs NUCLEAR POWER PLANT OR cps FOR NPRs SECURITY REQUIREMENTS ASSOCIATED WITH AN INTERNAL THREAT OL = OPERATING LICENSE CP = CONSTRUCTION PERMIT NPR = NUCLEAR POWER REACTORS

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CONGRESSIONAL CORRESPONDENCE SYSTEM 1 DOCUMENT PREPARATION CHECRLIST This check list is to be submitted with each document (or group of Qs/As) sentfor processing y into the CCS.
1. BRIEF DESCRIPTION OF DOCUMENT (S) ~ IA .06W, 1

l 2. TYPE OFDOCUMENT X CORRESPONDENCE HE4 RINGS (Qs/As)

3. DOCUMENT CONTROL SENSITIVE (NRC ONLY) X _ NON-SENSITIVE

. 4. CONGkESSIONAL COMMITTEE AND SUBCOMMITTEE (if applicable)

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Congressional Committee i Subcommittee S. SURIECT CODES (A)

(B) 1 (C)
6. SOURCE OFDOCUMENTS l (A) 5520 (DOCUMENT NAME )

(B) SCAN (C) ATTACHMENTS (D) OTHER

7. SYS7EM LOG DATES (A) }lHrIO1 DATA OCA SENTDOCUMENT TO CCS (B) DATE CCS RECEIVED DOCUMENT i (C) DATE RETURNED TO OCA FOR ADDITIONAL INFORMATION (D) DATE RESUBMITTED BY OCA TO CCS (E) DATE ENTERED INTO CCS BY (F) DATE OCA NOTIFIED THATDOCUMENT IS IN CCS 1700'20 COMMENTS:

RELEASE TO PDR