ML20141H639

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Responds to Re Portland General Electric Co Request for Approval of one-time Shipment of Decommissioned Reactor Vessel from Plant to Disposal Site in Hanford Nuclear Reservation
ML20141H639
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 07/23/1997
From: Shirley Ann Jackson, The Chairman
NRC COMMISSION (OCM)
To: Colvin J
NUCLEAR ENERGY INSTITUTE (FORMERLY NUCLEAR MGMT &
References
NUDOCS 9708010051
Download: ML20141H639 (1)


Text

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f*  % UNITED STATES p* NUCLEAR REGULATORY COMMISSION 4 /

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WASHINGTON, D.C. 20555-0001

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h p f July 23, 1997

@W CHAIRMAN i

l l Mr. Joe F. Colvin President, Nuclear Energy Institute j

1776 i Street NW, Suite 400 l Washington, D.C. 20006-3708 i i

Dear Mr. Colvin:

I am responding to your letter dated June 24,1997, conceming Portland General Electric Company's (PGE's) request for approval of a one-time shipment of its decommissioned l reactor vessel from the Trojan Nuclear Power Plant near Portland, Oregon, to a disposal site at the Hanford Nuclear Reservation near Richland, Washington. In this regard, I would like to assure you that the Commission notes the concems raised in your letter, and that the final  !

decision on PGE's request will be reviewed by the Commission.  !

As you know, the final decision on PGE's request must be consistent with the Commission's primary mission to protect public health and safety and the environment. The Commission will consider PGE's request in a timely manner and will address potential issues, including the appropriate weight to be given to possible safety and environmental concems associated with increased exposure to radioactive material before, during, and after shipment; waste l classification; and package integrity. l l trust that this reply responds to your concems. I would like to thank you for your interest in the Commission's activities in assuring the safe transport of radioactive materials.

Sincerely, b

Shirley Ann Jackson pV c10017

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Joe F. Colvin m saw r o e.m o,e m ~ ,, ; n b

June 24,1997 j The Honorable Shirley A. Jackson Chairman l U.S. Nuclear Regulatory Comm i ssion

Washington, DC 20555-0001  ;

Dear Chairman Jackson:

1 j NEI is aware that the Commission is reviewing an application to ship a reactor vessel with internals intact.1 The results of the review could provide needed regulatory flexibility and clarification of the Commission's regulatory program. The proposed l

process would result in significant dose reduction to workers and would permit more appropriate use of decommissioning funds.

The dose savings is achieved by not cutting out the vesselinternals. An estimated 70 rems will be avoided. In addition, estimates of cost savings for shipping the vessel i intact exceed $14 million. Part 71 of the Commission's regulations recognized that l transportation needs would arise that were not envisioned when the regulation was drafted. ~We believe approving shipment of a reactor vessel with internals intact is an appropriate exercise of those provisions of the Commission's regulations.

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Prompt Commission action on this request provides an opportunity for the Commission l to clarify its regulatory program in two related areas, classification of waste and use of j'

i alternate methods for assessing the potential for brittle fracture of transportation

! packages.

Shipping the vessel with internals intact results in safe immediate disposal of waste as j.

opposed to potentially orphaning the same waste. By not cutting up the internals a i licensee can avoid creating Greater than Class C low-level waste. '

1 Current NRC regulatory guidance for evaluating the brittle fracture potential of transportation packages refers to chly one acceptable method. Prompt action on the

1 i i Portland General Electric Company O'GE) has submitted an application for an exemption from Part 71 to ship the Trojan .

I reactor vessel with internals intact to the llanford low level wante disposal site.

2 The NRC branch technical position on concentration averaging. correctly in our view, permits averaging of act;vity over the

] component. The branch technical position uses a very conservative exposure scenario to project dose to intruders hundreds of years into the future. The scenario assumes allinstitutional controls preventing residence on the site are gone. The limiting l condition scenario for activated metals is that an intruder living on the site picks up small pieces of activated material that j

have worked their way to the surface. The intruder places the n. mall pieces of material on their mantle w here they are exposed i

several hours a day. If the component is not cut up the " mantle piece

  • scenario does not apply and the component does not exceed the Class C Part 61 m aste classification criteria.  !

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. .. The IIonorable Shirley A. Jackson l June 24,1997 l l' age 2 l pending request creates an opportunity for the Commission to provide needed clarification ofits position on use of more advanced methods for assessing the brittle fracture potential of transportation packages, if you have any questions about NEI's position please do not hesitate to contact me or Ralph Beedle at (202) 739-8088.

Sincerely, )

!R bk J F. Colvin FC/LH/tnb c: Commissioner Kenneth C. Rogers Commissioner Greta J. Dieus Commissioner Nils J. Diaz Commissioner Edward McGaffigan, Jr. .

Mr. Leonard J. Callan

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