ML20137K552

Application for Coc 9271,requesting Approval to Allow one- Time Shipment of Trojan Rv Package as Type B Exclusively for Radioactive Matl Transportation Package

ML20137K552
Person / Time
Site:	07109271, Trojan  File:Portland General Electric icon.png
Issue date:	03/31/1997
From:	Quennoz S PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML20137K558	List: ML20137K552 ML20137K581
References
VPN-022-97, VPN-22-97, NUDOCS 9704070055
Download: ML20137K552 (20)

Text

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Stephen M. Quennoz March 31,1997 Trojan Site Executive VPN-022-97 Trojan Nuclear Plant Director Office of Nuclear Materials Safety and Safeguards U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

Dear Director:

10 CFR 71 Certificale of Compliance Application for the One-Time Shipment of the Troian Reactor Vessel Package i

Portland General Electric (PGE) requests that the Nuclear Regulatory Commission (NRC) issue a Certificate of Compliance for the one-time shipment of the Trojan Reactor Vessel Package (RVP) as a Type B, exclusive use, radioactive material transportation package. Approval of this i application would allow the one-time, short duration shipment of the RVP under extensive and proven procedural controls and along a well-defined, favorable transportation route to the US Ecology licensed radioactive waste disposal facility on the Hanford Nuclear Reservation near Richland, Washington. PGE-1076," Trojan Reactor Vessel Package Safety Analysis Report" (SAR), is enclosed and provides the bases for PGE's application for package approval pursuant to Subpart D of 10 CFR 71. The proposed method of packaging and transport ensures the safety of the shipment and is consistent with the Commission's policy to maintain radiation exposure to workers and the public as low as reasonably achievable.

The RVP with impact limiters will be approximately 42 feet 6 inches long, and 28 feet in diameter. The reactor vessel walls are ferritic steel 5%" to 10%" thick. Over 99% of the radioactivity contained in the RVP is in the form of activated me'tal which cannot be released to the environment. The RVP will be filled with a low density cellular concrete to reduce external radiation levels and immobilize the internal contamination. Steel shielding will be secured to the RVP to satisfy exposure rate limits specified in the transportation regulations (i.e.10 mrem /hr at 2 meters and 200 mrem /hr contact). Also, it should be noted, the external radiation levels c the unshielded vessel are less than I rem /hr at 3 meters, which is acceptable for shipment of LSA material. As prepared for transport, the RVP will have a design weight of 1020 tons and will be secured by an engineered tie down system. Attachment 1,"RVP Project Description," provides additional project information in the form of an executive summary.

Safety of the shipment will be ensured through package design and stringent transportation f controls. A Transportation Safety Plan (TSP) will be approved by the Oregon Office of Energy, prior to shipment and will identify responsibilities and interfaces of PGE, PGE contractors, and federal, state and local agencies. The TSP will be implemented by detailed procedures that 9704070055 970331 g' g /p PDR ADOCK 07109271- @ ,I N N M E . g" pl t/ 0 S PDR ~

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- March 31,1997 l P= 2 of 4' i address operational controls, radiological controls, and contingency actions. The controls l

' imposed for the single RVP shipment will be similar to those that governed the five successful

-l shipments made during the Trojan Large Component Removal Project (shipment of the four  :

steam generators and the pressurizer). This one-time shipment, with an estimated duration ofless  !

. than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, will travel approximately 300 miles to the Hanford Nuclear Reservation along a l route similar to that traveled during the Large Component Removal Project. The size of the i package and the transportation route are similar to that of the reactor compartment shipments {

. which are currently being successfully completed by the US Department of the Navy. Among the  !

numerous controls described in the SA. R, this one-time shipment will use a specially designed

. barge limited in speed to 10 knots, and a specially designed land transporter limited in speed to  :

'5 miles per hour. The shipment will be continuously accompanied by a transportation coordinator i

4' and a radiation protection escort. l l

l The State of Washington and US Ecology have indicated their acceptance of the RVP for l; disposal. The RVP will contain the residual .adioactivity within a very robust disposal package (i.e., an ASME Code,Section III, Safety Class I reactor vessel). l i

In accordance with 10 CFR 71.41(c), PGE requests the Commission's approval of different i i . environmental and test conditions than those specified in 10 CFR 71.71(cX7), one-foot drop, and i

'71.73(cXI), 30-foot drop. This request is based on Trojan's favorable, relatively short  !

transportation route and the extensive transportation controls that are being placed on this l one-time shipment. Safety studies performed for PGE by independent industry experts  ;

' demonstrate an equivalent, if not improved, level of safety for the proposed land and river

, transport scenarios. Attachment 2," Request for Alternate Conditions Approval,"is provided to {

demonstrate that the RVP single shipment as a Type B package under the controls PGE proposes .

will provide safety for the RVP shipment equivalent to the numerous shipments which would be necessary if segments were shipped in smaller packages which meet the environrrental and test j conditions of Sections 71.71(cX7) and 71.73(cXI).

' If approval is not granted under 10 CFR 71.41(c), PGE requests an exemption in accordance with 10 CFR 71.8 from the drop conditions specified in 10 CFR 71.71(cX7) and 71.73(cXI). The  ;

RVP size and weight, the fact that it will not be lifted during transport, the favorable  ;

transportation route and the extensive controls being placed on the shipment eliminate any drop l scenario as a condition of transport. PGE also requests an alternative approach to evaluating i 4 fracture toughness. Regulatory Guide 7.12 provides acceptance criteria to address brittle fracture ,

concerns for transportation packages. It also provides for the use of alternative methods to assess l material toughness. The SAR uses an ASME Section XI fracture initiation approach which is j typically used in evaluations of operating plants. This calculation is discussed in Attachment 2

, and concludes that with very conservative assumptions, the RVP will not experience brittle l failure. Additionally, to enhance safety margins, the transport of the RVP will only be scheduled  ;

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VPN-022-97 March 31,1997 Page 3 of 4 _

during the most favorable weather conditions (i.e. late July and August). Attachment 2 also providesjustification in accordance with 10 CFR 71.8 that the proposed packaging and shipment will not endanger life or property, nor compromise the common defense and security. However, PGE is providing an additional margin of safety by designing the RVP with impact limiters for a one-foot horizontal drop, one-foot oblique drops with the RVP pinned on either end, an 11 foot horizontal drop, and 11 foot oblique, pinned drops. The 11 foot distance corresponds to a non-mechanistic fall from the height the RVP is above the roadway when secured to the transporter. Although no credible scenario exists that would result in the breach of the RVP containment boundary, PGE has performed two analyses which investigate the consequences of such a breach. One is assumed to occur during road transport and the other during river transpo t. The results of these analyses indicate that the possible radistion dose received from either of the breach scenarios is a fraction of the radiation dose used to establish Type A transportation package limits.

The proposed packaging and shipment method is furtherjustified when examined in comparison to its alternative. The alternative would require the operationally undesirable task of remote, underwater segmentation of the reactor vessel internals. Under this alternative, portions of the segmented internals would be packaged and transported in approximately 44 individual cask shipments to the US Ecology facility. Once segregated, portions of the internals with the highest activation levels would no longer qualify for disposal under 10 CFR 61 regulations and would require indefinite on-site storage. After segmentation of the internals, the reactor vessel would then be segmented or removed and disposed ofintact, increasing the number of shipments to a total of 45 to 54. This alternative would substantially increase occupational radiation exposure at least 100% (i.e.,134 to 154 person-rem versus 67 person-rem), will increase radiation exposure to the transportation workers at least 1000% (i.e.,1.06 to 1.19 person-rem versus 0.09 person-rem), and will increase the very low public exposures to radiation at least 2300%

(i.e.,0.48 to 0.56 person-rem versus 0.02 person-rem). The RVP single shipment approach, l

when weighed against the alternative which could result in up to 54 shipments, will reduce the risk to public health and safety.

PGE is confident that the RVP design, in combination with the specially designed transportation ,

equipment, proven procedural controls, and a well-dermed, relatively short transportation route, I will ensure the safety of the general public and effectively minimize occupational and pubhc j exposure. Additionally, the proposed single shipment will help conserve limited TNP J decommissioning funds. Upon receipt of required regulatory approvals, PGE will begin RVP i preparation activities to support an August 1998 shipment window. In order to meet this schedule, PGE requests that a Certificate of Compliance for a one-time shipment as a Type B, exclusive use, transportation package be issued by the NRC before the end of November 1997.

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VPN-022-97 ~  ;

March 31,1997:

- Paoe 4 of 4 ' < f i

i PGE will work with the NRC's staff to promptly address any issue associated with this application. Please contact Mr. Ray Pate of my staff at (503) 556-7480 if you have any question. -.

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Sincerely,  !

% +1&*-

q Steven M. Quennoz  ;

Trojan Sits Executive Attachments c: D. G. Reid, NRC, NMSS (10)

M. T. Masnik, NRC, NRR )'

R. A. Scarano, NRC, Region IV J. V. Everett, NRC, Region IV i USNRC Document Control Desk- 1 A. Bless, OOE j

. D. Stewart-Smith, OOE M. J. Eisen, WDOH (2) j A. Crase, US Ecology  ;

. T. R; Hayes, US Ecology j J. Peterson, Columbia County Board of Commissioners l t

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STATE OF OREGON ) )

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COUNTY OF COLUMBIA )

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, I, Stephen M. Qusanoz, being duly sworn, subsenh to and say that I ana the Trojan Site Execudw for . I Pardaad General Electric Company, the appucant herein; that I haw full =mharity to execute this oash; that ~

I haw reviewed the foregoing; and that to the best of ary knowledge, infor==sian, and belief the des ==ensa l made in k are true, i

Date 3[3I ,g997 l l

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, ,&y/u a M1J Stephen M. Quennoz W j Trojan Site Executiw l

Pordaad General Electric Company On this day personally appeared before me Stephen M. Quennoz, so me known to be the individual who executed the foregoing instrument, and ackno#@ that he signed the same as his free act.

GIVEN under my hand and seal this 31* day of War 6 . 1997.

1 OfflCIAL SEAL II b [ld- I Ndb p A. M M NotaryPublicin 4 the i'

@si wMMCSON fMMS.ONL 1. W NOTARY PJBUC4)REGON COMMISSON NO.024926 State of Oregon Residingat hD,lt.AdNA OMudt4 uy comm,ission expir.e w i, ie,

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION in the Matter of )

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PORTLAND GENERAL ELECTRIC COMPANY )

TIIE CITY 01 EUGENE, OREGON, AND )

PACIFIC POWER & LIGilT COMPANY )

(TROJAN NUCLPAR PLANT) )

CERTIFICATE OF SERVICE I hereby certify that copies of VPN-022 97,"10 CFR 71 Certificate of Compliance Application for the One-Time Shipment of the Trojan Reactor Vessel Package," which contain the Trojan Reactor Vessel Package Safety Analysis Report, dated March 31,1997, have been served on the following by hand delivery or by deposit in the United States Mail, first class, this 3 ist day of March 1997:

Mr. Jack Peterson, Chairman State of Oregon Columbia County Board of Commissioners Attn: David Stewart-Smith Columbia County Courthouse Oregon Office ofEnergy St. IIelens, OR 97051 625 Marion Street NE Salem, Oregon 97310 State of Wa'shington Attn:MikelJ. Eisen Washington Department ofIlealth P.O. Ikw 47827 Olympia, WA 98504 Date bA 4 \ ,1997 ,

d'. ~A. 3d mennan Acti g Matager, Licensing, Compliance.

and itment Management h/7. bmm t.etnph On this day personally appeare4 before me !! !! M, to me know to t e individual who executed the foregoing instnunent, and acknowledged that he signed the same as his free act.

GIVEN under my hand and seal this 31st day of March,1997.

A b Notary Publicin and for[e e uv C02 gg NOTARYPUBLIC4mEGON 7

State of Oregon Residing at IJ My commission expirci 7tR ~7-69

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c VPN-022-97

" Attachment I  !

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"RVP PROJECT DESCRIPTION" Contingent upon the receipt of required regulatory approvals, the Trojan Reactor Vessel Package i (RVP) will be shipped as a Type B, exclusive use, radioactive material transportation package for j the purpose of disposal at the US Ecology low level radioactive waste facility on the Hanford  !

Nuclear Reservation near Richland, Washington. {

The defueled reactor vessel will be prepared as a Type B shipping package. The reactor vessel is  ;

a large, thick-walled, steel structure measuring approximately 42' 6" long and 17' 1" in outside . i diameter, it was a Safety Class 1 vessel originally designed in accordance with the requirements  !

of the ASME Code,Section III (1%8 edition with Addenda through winter 1%8). After - l

. preparation, the RVP will be shipped approximately 300 miles from the TNP site to the US j

. Ecology disposal site. During the shipment, the RVP is expected to be outside the Trojan site  :

and US Ecology site boundaries less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. j i

The RVP project will include the following activities:  !

1. Interferences will be removed (e.g., enlarge containment opening, remove concrete from f the egress path, sever piping attached to the reactor vessel). l

2. Installation and testing of the heavy lift equipment to be utilized inside and outside of containment.

3. As described in the RVP Safety Analysis Report (SAR), the RVP will be assembled as follows:

a. Reactor vessel external surfaces will be decontaminated, as necessary, to ensure  !

compliance with 10 CFR 71.87(i) and will be coated to fix any residual contamination.

b. Reactor vessel external attachments will be removed, sealing 0-rings installed,  !

and the reactor vessel head installed and tensioned using 54 head studs and nuts. l

c. The reactor vessel void space, with internals installed and intact, will be filled with low density cellular concrete (LDCC) to prevent movement of radioactive  ;

material within the reactor vessel. This will stabilize dose rates during transport, limit any potential accident related releases, and provide radiation shielding. ,

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VPN-022-97 Page 2 of 3 The bulk of the approximately 2 million curies of activity in the RVP is in the form of activated metal, which cannot be released to the environment  ;

in particulate or gaseous form. Internal contamination is approximately 155 curies which is less than the contamination contained in the TNP Steam Gerierators which were successfully licensed and shipped as Greater than Type A, LSA packages.

The fissile material content of the RVP will consist of 3.56 g of Plutonium. 10 CFR 71.53(a) provides that a package containing not more than 15 g of fissile material is exempt from fissile material classification and from the fissile material standards of 10 CFR 71.55 and 10 CFR 71.59.

d. Penetrations will be sealed with welded closures that have been designed to meet regulatory requirements for all conditions of transport.

c. Steel shielding will be installed on the exterior surface of the reactor vessel, as  !

necessary, to comply with the dose limt cequirements of 10 CFR 71.47 and i 10 CFR 71.51. Radiation surveys will !,e conducted to verify the requirements are met.  !

f. The RVP will be removed from containment, lowered to ground level, and j secured onto a specially designed transporter using an engineered tie down i system.

g. Impact limiters will be installed to minimize reactor vessel stresses due to the analyzed RVP drops. ,

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h. As described in Chapter 8 of the SAR, acceptance tests and inspections will be performed on the RVP, before it is transported, to ensure compliance with the )

requirements of Subpart G of 10 CFR 71.

4. The RVP loaded transporter will be moved and secured onto a specially selected barge at l the TNP barge shp.

5. The RVP will be shipped up the Columbia River (approximately 270 miles) to the Port of j Benton in Washington.

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6. After the barge off-load, the RVP loaded transporter will be moved to the US Ecology I low level radioactive waste facility.

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VPN-022-97 Attachment 1 Page 3 of 3 "RVP PROJECT ALTERNATIVE" The alternative to a one-piece, single shipment of the reactor vessel and its internals is the individual removal and disposal of the reactor vessel ar.d internals. The reactor vessel internals would require remote underwater segmentation. The segmented internals would either be packaged in individual casks and transported to the US Ecology facility or stored on-site, as appropriate based on their activity level. This would require approximately 44 separate shipments. In addition, the reactor vessel would either be removed and disposed ofin one piece or segmented which would require one or a minimum of 10 shipments based on the selected method.

l Performing the alternative project would result in the following:

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1. Increase the radiation dose to the general public, plant, and transportation personnel.

Increase occupational radiation exposure at least 100%

(i.e.,134 to 154 person-rem versus 67 person-rem)

Increase radiation exposure to the transportation workers at least 1000%

(i.e.,1.06 to 1.19 person-rem versus 0.09 person-rem)

Increase the very low public exposures to radiation at least 2300%

(i.e.,0.48 to 0.56 person-rem versus 0.02 person-rem)

2. Increase the number of personnel contaminations, plant cleanup concerns, and increase the generation of highly activated radioactive waste as a result of the dross fines that are created during segmentation.

3. Greatly increase the required number of radioactive material shipments and reduce transportation safety (45 or more ship...;ats via public highway transport as compared to one controlled shipment primarily via barge).

4. Increase TNP decommissioning funds expenses (estimated additional cost of $14.6 Million).

VPN-022-97 Page1 of11

" REQUEST FOR ALTERNATE CONDITIONS APPROVAL" Portland General Electric (PGE) requests that the Nuclear Regulatory Commission (NRC) issue a Certificate of Compliance for the one-time shipment of the Trojan Reactor Vessel Package (RVP) as a Type B, exclusive use, radioactive material transportation package to the. US Ecology disposal facility on the IIanford Nuclear Reservation near Richland, Washington.

This PGE request requires NRC approval pursuant to 10 CFR 71.41(c) or alternatively, 10 CFR 71.8. The 10 CFR 71 regulations provide the NRC with authorization to approve packaging and shipments based on alternative transport conditions. These regulations recognize that special controls imposed by the shipper may provide equivalent safety as those specified in  ;

10 CFR 71.

The following provides a description of the alternative and itsjustification. In addition, a section is provided which discusses the consequences of two hypothetical accidents in which the RVP containment boundary is breached. The conclusion reached in this section is that the breach of the containment boundary would not result in a significant radiological consequence to the public.

I. Normal Condition of Transport - RVP Drop The normal conditions of transport specified by 10 CFR 71(c)(7) requires a drop of the specimen through a distance of I ft onto a fiat, essentially unyielding, horizontal surface, striking the surface in a position for which maximum damage is expected. PGE is taking special precautions to ensure the safe shipment of the RVP which are described in Chapter 7 of the Safety Analysis Report (SAR). Based on the SAR, given the specified transportation route, method of shipment, and special controls, the 1 foot drop should not be considered a normal condition of transport. Therefore, PGE requests NRC acceptance of the conditions and controls for this shipment under 10 CFR 71.41(c) or an exemption under 10 CFR 71.8 based on the demonstration of adequate safety of the shipment.

Prior to shipment, the RVP will be prepared s; a shipping package and will be loaded and tied down onto a specially designed transporter. The loaded transporter will be moved onto a specially selected barge and secured tilizing an engineered tie down :.ystem. The barge will be grounded during this evolutic.. he RVP loaded transporter will be barged up the Columbia River to the Port of Benton v'here a prime mover will connect to the transporter and move it off the barge and overland to the disposal facility. The RVP will be off-loaded at the disposal facility.

VPN-022-97 Page 2 of11 The RVP will be rotated to a horizontal position (i.e., the centerline longitudinal axis of the package will be horizontal) during preparation in the TNP industrial area. During transport, the RVP will remain oriented in the horizontal position. Because of the unique size and mass of the package and the method of support of the package, no other orientation is reasonable during RVP transport. Once loaded onto the transporter, the RVP will not be removed from th: transporter at anytime during transport.

Based on above conditions and the special handling and operational controls to be exercised, the one foot drop should not be considered a normal condition of transport.

liowever, PGE has designed and analyzed the RVP with impact limiters to withstand the effects of a 1 foot horizontal drop and I foot oblique pivot drops.  ;

II. Hypothetical Accident Condition - RVP drop The hypothetical accident condition specified by 10 CFR 71.73(c)(1) irquires a drop of the specimen through a distance of 30 feet on a flat, essentially unyielding horizontal surface, striking the surface in a position for which maximum damage is expected. PGE is taking special precautions to ensure the safe shipment of the RVP which are described l in Chapter 7 of the SAR. Based on the SAR specified transportation route, method of shipment, and special controls, the 30 foot drop should not be considered a hypothetical accident condition. Therefore, PGE requests NRC acceptance of the conditions and controls for this shipment under 10 CFR 71.41(c) or an exemption under 10 CFR 71.8 based on the demonstration of adequate safety of the shipment.

10 CFR 71.73 specifies the hypothetical accident conditions to which Type B radioactive material packages are to be designed for unrestricted use. According to a NRC-sponsored modal study, packages designed to 10 CFR 71.73 are capable of withstanding greater than 99% of all credible accidents, rail and highway, without functional failure. As a consequence,10 CFR 71 does not require in-transit precautions such as escorts, routing restrictions, speed controls, inspections, etc.

PGE has conducted a safety evaluation of the specific route, method of transport, and operational controls and shipment specific conditions to be utilized during the transportation of the package.

Transportation Route Evaluation The overland route for the RVP from the Port of Benton to the US Ecology disposal site can be considered as very benign in that: 1) the road is in good condition,2) there are no obstacles such as heavy traflic, bridges or overpasses to cross,3) there are no "hard

VPN-022-97 Pace 3 of 11 targets" or surfaces,4) the area is essentially unpopulated, 5) there are no hazardous terrain features, and 6) it is an area where nuclear activities are well known and understood. A portion of the haul route was used for disposal of the TNP Steam ,

Generator and Pressurizer and is routinely used for the transport of decommissioned defueled naval submarine reactor plants.

The discrete probabilities of the significant accidents evaluated on both the Columbia River and overland are:

Event Discrete Probability ,

Impact of the RVP on the Barge 3.2E-07 Separation of the RVP/ Barge 1.0E-06 Severe Fire / Explosion 6.0E-10 (during barging)

Land Transport Accident 1.3E-07 As noted in the RVP river transit study, because of the unique nature of the RVP shipment, and the importance of safety in all aspects ofits planning, the accident rates determined from historical records (and utilized in the study) will tend to overstate the  ;

accident probabilities for the RVP river shipment. l l

Operation Controls and Shinment Specific Considerations The following operational controls and shipment-specific considerations will be utilized dunng the transport of the RVP.

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A Transportation Safety Plan (TSP) will be prepared that identifies the responsibilities )

and interfaces of PGE, PGE contractors, Federal Agencies, State Agencies, and Local  !

Agencies. The TSP will address the operating controls and procedures, radiological controls, and contingency actions to be taken in the event of a problem during transport.

The requirements of the TSP will be implemented by detailed procedures and coordinated with state and local agencies responsible for emergency response along the route. The TSP will be approved by the Oregon Office of Energy (OOE) prior to shipping the  !

Reactor Vessel Package. The TSP will be made available to the United States Coast  ;

Guard (USCG) Captain of the Port (COPT) for review prior to shipment. Changes to the

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. VPN-022-97

' Attachment 2 :  ;

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1 L plan will be approved by OOE and reviewed by the USCG. Appropriate advance 'f

' notifications, per 10 CFR 71.97(b), will be made prior to the shipment. 'l 2 - . .

1 The shipment will comply with the applicable specifications of ANSI N14.24-1985,-- i "American National Standard for Highway Route Controlled Quantities of Radioactive j

Materials - Domestic Barge Transport," the applicable requirements of 10 CFR 71 - {

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Packaging and Transportation of Radioactive Material,33 CFR.- Navigation and j Navigable Waters,46 CFR - Shipping, and 49 CFR - Transportation.  !

_ The transporter, specially designed for transporting large, heavy loads, will be limited to a  !

- maximum overland transport speed of 5 mph. The transporter and prime mover will be j inspected prior to shipment to ensure the vehicles are working properly and to ensure j conformance with applicable state and federal standards. The structural adequacy of the j

- transporter will be demonstrated by analysis and the transporter will be loaded in j accordance with the manufacturer's specifications. The entire land transportation route, l onsite and offsite, will be evaluated to confirm that it is structurally capable of 'j

{ - withstanding the load. The Omgon Department of Transportation may, at its option,  ;

perform Commercial Vehicle Safety Alliance (CVSA) inspections on the loaded j transporter and prime mover prior to leaving the Industrial Area. In addition, the RVP -;

will be inspected for acceptance by US Ecology prior to leaving the Industrial Area.

1 The tug and barge chosen for this shipment will be required to have high standards of j maintenance. Two well-qualified and well-informed crews with local knowledge of the Columbia River will be provided (one on the primary tug and one on the backup tug).

The barge loading procedure will be specified by a naval architect. The prime mover will i- not be transported on the barge. The barge will have a current classification by the I

American Bureau of Shipping and a Certificate ofInspection by the U.S. Coast Guard (USCG), and assigned for sole use. The barge selected will have a high level of subdivision (i.e., multiple watertight compartments). Intact and damage stability calculations will be performed by a naval architect to verify compliance with 46 CFR 172 and will be reviewed and approved by the USCO. Tie down design and calculations will be reviewed and approved by the National Cargo Bureau (NCB).

Prior to departing the Trojan barge slip, the following requirements will be met: j l

1. A backup tug is present to accompany the primary tug.

2. Communication is established between the tugs and a base station to monitor

= progress of the barge transport.

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3 . He primary and backup tug and the barge are equipped with navigation and ' i emergency equipment appropriate for river navigation (per ANSI N14.24-1985) and approved by the USCG.

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4. Here is no adverse weather forecast between the TNP and the Port of Benton that l may threaten the safety of the barge and package.

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5. There are no mechanical problems with the tug, backup tug, or the barge that may  :

affect the capability to safely transport the package. j

. e i 6. The primary and backup tug captains are licensed per 46 CFR Subchapter B 4

" Merchant Marine Officers and Seamen." i L .

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7. The U.S. Coast Guard will establish a safety zone per 33 CFR 165, if required, to l

ensure appropriate safety and security measures are met. The determination to j establish a safety zone will be made upon the completion of a waterway threat .;

assessment conducted by the U.S. Coast Guard. j i

8. A PGE Radiation Protection (RP) representative and a PGE transportation  !

s coordinator will accompany the shipment. The RP representative will be trained j in the principles of health physics and equipped with appropriate radiation 1 protection instruments to provide radiological support by performing inspections  !

and/or surveys and maintain personnel exposure ALARA. l 7

9. Arrangements have been made with the U.S. Army Corps of Engineers to provide l priority passage and exclusive use through the locks en route to the Port of i J

Benton.

10. The NCB has evaluated the package to transporter and transporter to barge tie down systems and has certified that the two tie down systems comply with the applicable regulations.

I1. A marine surveyor, the NCB, and the USCG have inspected the condition of the barge and the stowage of the package on the barge to ensure integrity of the barge and that the final stowage configuration complies with the approved designs.

12. Notifications of the pending shipment to appropriate authorities have been made.

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13. The tugs will meet the applicable requirements of 46 CFR Subchapter C,  ;

l "Uninspected Vessels." The tugs will be inspected by a marine surveyor prior to l

departure.

During river transport, maximum speed will be 10 knots. Transit of the barge will be halted to avoid hazardous conditions or to await passage through a lock or to await safe navigation conditions. When moored, appropriate measures will be taken to restrict unauthorized access to the barge. During the barge transport phase, the tug will check in with the base station at least every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

I After arrival at the Port of Benton barge slip, the barge will be grounded, the transporter-to-barge tie downs will be removed and the transporter will be moved off the barge onto the landing. Prior to departing the Port of Benton Property, the Washington State Patrol may, at its option, perform a Commercial Vehicle Safety Analysis (CVSA) inspection of the RVP loaded transporter and the prime mover.

The RVP loaded transporter will travel to the US Ecology site, less than 30 miles from the barge slip, with a maximum overland transport speed of 5 mph. An overload permit will be obtained from local authorities for the overland travel. Escorts will control road traffic in the vicinity of the transporter during the entire overland transport. All railroad traffic in the area will be stopped during transit.

Prior to entry at the disposal site, the RVP loaded transporter will be re-inspected for acceptance by US Ecology. Once accepted, the transporter will be moved to a prearranged location at the US Ecology site. The prime mover and transporter will be driven into a prepared trench and the RVP will be off-loaded.

Conclusion The transportation environment (i.e., route and operational controls) are significantly different from that contemplated in 10 CFR 71 for unrestricted packages. There are no man-made or natural terrain features (e.g., bridges, cliffs, overpasses) which could produce impacts which are equivalent to the 10 CFR 71.73(c)(1) described 30 foot drop onto an unyielding surface. The 30 foot drop in the regulations is equivalent to a 44 fps (30 mph) velocity. The overland travel speed of the RVP transporter is limited by pmcedure to 7.3 fps (5 mph), a factor of 6 less. The river travel speed of the barge is limited by procedure to 16.9 fps (10 knots), a factor of 2.6 less. In addition, there are extensive in-transit precautions such as escorts, routing restrictions, moving safety zones, etc. that are not typically required of a standard Type B package.

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VPN-022-97 Attachment 2 Page 7 of11 As previously stated, the RVP w"I be moved to a horizontal position (i.e., the centerline longitudinal axis of the package will be horizontal) during preparation in the TNP industrial area. During transport to the US Ecology disposal facility, the RVP will remain oriented in the horizontal position. Because of the unique size and mass of the package, no other orientation is reasonable during RVP transport.

Once loaded onto the transporter, the RVP will remain tied down to the transporter until the RVP is unloaded at the disposal site. Therefore, based on the Transponation Evaluation and the operational controls and specific considerations, the hypothetical  ;

accident condition of a 30 foot drop should not be considered a condition of transport for the RVP.  ;

Based on the specific transportation route and controls established, a maximum non-mechanistic drop configuration has been determined. The maximum postulated distance that the RVP could drop, based on the design of the impact limiters, transportation system, and route, during a hypothetical transport accident is 11 feet. This ,

drop height and horizontal orientation was used as a design basis for the RVP in the SAR.

111. RVP Brittle Fracture Evaluation Methodology The Trojan reactor vessel was a Safety Class 1 vessel, and was originally designed in  ;

i accordance with the requirements of the ASME Code, Section 111 (1968 edition with Addenda through winter 1968). The design pressure for the vessel and the reactor coolant system was 2485 psig, and the maximum design temperature was 650"F.

Part 71 of Title 10 of the Code of Federal Regulations," Packaging and Transportation of Radioactive Materials," requires that packages used to transport radioactive material be designed with consideration of normal trasport and hypothetical accident events that might occur at temperatures as low as -20 F (-29"C). In order to assess the potential for brittle fracture of the Trojan vessel under transport accident conditions, the hypothetical side drop and puncture conditions were analyzed to determine the appropriate stresses.

The concerns for brittle fracture of the vessel are addressed using an ASME Code Section  !

XI, Appendix A fracture mechanics approach.

Linear elastic fracture mechanics analyses are normally used to evaluate brittle fracture concerns in reactor vessels during normal operation and accident (i.e., emergency and l faulted) conditions. The approach defined in ASME Section XI, Appendix G specifies the assumptions to be used in the brittle fracture analysis for detennining the allowable  !

operating pressure-temperature limits for heatup and cooldown. The Appendix G l procedure establishes safety margins to prevent crack initiation during normal heatup, j i

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VPN-022-97 Page 8_of_11 l

cooldown, and hydrostatic test operation. For severe emergency and faulted conditions, more detailed fracture met hanics analyses are required and alternative acceptance criteria are available in ASME Se: tion XI, Appendix A. These ASME Code requirements assure adequate margins against brittle fracture of the reactor vessel for operating plants.

No specific design criteria are provided in the regulations, however, for protecting a shipping container against brittle fracture initiation and ustable growth. Studies conducted by Lawrence Livermore National Laboratory (LLNL) in the early 1980's 'were published in NUREG/CR-3826, and the recommendations for brittle fracture prevention contained in that document led to the publication of Regulatory Guide 7.12. The .

guidance in Regulatory Guide 7.12 is applicable only to ferritic steels with extremely low nil-ductility transition temperatures; however, NUREG/CR-3826 provides recommendations for an altemative approach based on ASME Section XI brittle fracture evaluation methods. The criteria utilized in the analysis center around the concept of no fracture initiation based on the alloweble flaw sizes specified in IWB-3510-1 of Section XI of the ASME Boiler and Pressure Vessel Code.

Other methods were investigated to benchmark the adequacy of this approach. In particular, the I AEA "Guidelinesfor Safe Design ofShipping Packages Against Brittle Fracture " describes three acceptable methods for preventing brittle fracture of radioactive material transport packages. One method can be referred to as a fracture mechanics approach. This method is used to demonstrate, by analysis or by a combination of analysis and test, that sufficient margin is available (considering applied stress, flaw size, and/or material fracture toughness) to preclude crack initiation and brittle fracture during design basis events. This is equivalent to the method utilized in the SAR. Fmthermore, this method provides three acceptable options for determining material fracture toughness. One of these options defines a lower-bound or near (statistically) lower-bound value for the fracture toughness at the lowest service temperature. This definition of material fracture toughness is inclusive of the dynamic (Kg) reference material fracture toughness curve for ferritic steels assumed in this analysis, and for this reason this option is noted to coincide with the present analysis approach.

With respect to safety factors used in this analysis, no specific safety factors are given in NUREG/CR-3826. However, the IAEA guidelines suggest that, when using the applied method, an overall minimum safety factor (Ku/K i) of approximately 3 is appropriate for normal loading conditions during shipping, with a suggested safety factor of 1.4 for ,

unexpected loadine events such as hypothetical accident conditions.

VPN-022-97 Attachment 2 Page 9 of 11 The results from the fracture mechanics calculations using stresses derived from the finite element analysis show significant margins against brittle crack initiation (i.e., K i/KP 1.0) under all evaluated conditions. In general, stress levels in the vessel are sufficiently low so that no crack initiation is predicted to occur for the analyzed side drop loading condition. This is due to the ability of the impact limiters to reduce the amplitude of the longitudinal beam bending stresses relative to ovalization and localized bending stresses. The membrane stress contribution is small regardless of the assumption for intemal pressure (< 200 psi) near the impact locations and at geometric discontinuities (e.g., at the corner of the outlet nozzle). At an ambient temperature of-20*F, large margins against crack initiation (> 5.65) are calculated for all locations along the shell with the smallest margins (2.0) occurring close to the outlet nozzle. The other points of i high stress concentration are at the contact locations with the impact limiters where the calculated margins are 2.51 and 3.17, respectively.

The axial stresses throughout much of the beltline region are very low (less than 10 ksi tension) or even compressive. Ovalization effects at the mid-core region are present and some tensile hoop stresses develop in these regions. Ilowever, the safety factor against  ;

brittle crack initiation at the most embrittled region of the vessel is greater than 7.0.  !

Because of this, the beltline region of the Trojan vessel is not considered to be a limiting concem for the analyzed drop condition.

A more limiting condition is the hypothetical puncture loading. A safety factor of 1.01 and 1.0 was calcH+d at the upper and lower heads, respectively, at an ambient temperature of-20 F. Although these values are relatively low,it should be noted that the calculations are based on very conservative assumptions. For example, the use of ambient temperature instead of actual metal temperature, use oflarge assumed full-circumference or quarter-circular surface flaws at the worst stress locations, and use oflower bound dynamic reference toughness instead of using the static reference l toughness all add to the conservatism of the analysis results. In addition, the inconel welds at the head penetrations have not been modeled separately, the toughness properties of the adjacent base metal were assumed for the fracture mechanics analyses.

The Inconel nickel-base alloys are known to have excellent toughness at low temperatures because of their strength and ductility. Furthermore,Inconel alloys do not ,

undergo a ductile-to-brittle transition in toughness, even at very low temperatures. A i flaw remaining within the inconel overlay would not experience brittle crack initiation. I Therefore, assuming dynamic toughness consistent with that of the ferritic base metal properties is very conservative.

Based on utilizing worst case assumptions, the transportation route's lack of hard targets, the limited orientations for the analyzed drop conditions, and the overall extremely low

VPN-022-97 Page 10 of 11 probability of an accident, this is considered acceptable. However, using the conservative fracture mechanics analysis techniques described in the SAR, a minimum safety factor of 1.4 has been demonstrated for the evaluated RVP drop and hypothetical puncture loading conditions at an ambient temperature of 45*F. The shipment route's mean low daily temperature for the July / August shipment period is 48*F. Administrative controls will ensure that RVP will be transported only if the forecasted mean daily temperature for the (less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> expected duration) shipment route is above 45 F.

This brittle fracture analysis has been provided to the Electric Power Research Institde (EPRI) Major Component Reliability group for their review. Their review determined that the input assumptions and the fracture mechanics methodology have a well founded technical basis and the results demonstrate adequate safety factors for the loading conditions postulated. They also noted that the overall conclusion of the analysis is conservative.

IV. Consequences of a Non-Credible Reactor Vessel Containment Breach The evaluation of the transport of the package has determined that the drop conditions should not be considered as conditions of transport. In addition, the design and analysis provided within the SAR demonstrate that the package will not be breached for the conditions analyzed. However, PGE evaluated the radiological consequences to the public from two non-credible accidents in which the RVP containment boundary is breached. The following conditions were evaluated:

1. During overland shipment, the reactor vessel package falls ofTthe transporter, and is breached.

2. During river shipment, the reactor vessel package falls off the barge near the intake to a water treatment plant that draws drinking water from the river, and is breached.

The evaluation concluded that calculated doses for individuals due to either non-credible breach accident are well below the doses used to establish the Type A transportation package limits (5000 mrem TEDE,50,000 mrem TODE, and 15,000 mrem eye dose equivalent).

Type A package limits are also used for several other purposes in the regulations, such as specifying Type B activity leakage limits, LSA, and excepted package content limits. In establishing the Type A limits, the regulations assume that a person is unlikely to remain at a distance of 1 meter from the damaged package for more than 30 minutes.

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Attachment 2 Paae 11 of 11

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As required by the SAR, PGE Radiation Protection personnel will accompany the }tVP f shipment, and therefore, will be available to establish boundaries and perform emergency response functions. In addition, traffic escorts will control / restrict' road traffic in the -

vicinity of the transporter during the overland trangort. - As a result, the evaluation for the overland shipment accident assumed exposure conditions for an individual standing j 100 meters from the scene of the accident for 30 minutes. The evaluation determined the i external exposure (DDE) to an individual is approximately 25 mrem and the internal j (CEDE)is approximately 12 mrem. l The evaluation for the river shipment accident determined that the extemal exposure l (DDE) to an individual is 0 mrem and the internal exposure (CEDE) is approximately i 1.25 mrem.  !

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Therefore, it is concluded that the above non-credible accidents will not result in a j significant radiological consequence to the public. l I

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