ML20151C521
| ML20151C521 | |
| Person / Time | |
|---|---|
| Issue date: | 07/13/1987 |
| From: | Bradburne J NRC OFFICE OF GOVERNMENTAL & PUBLIC AFFAIRS (GPA) |
| To: | Hollings E SENATE, COMMERCE, SCIENCE & TRANSPORTATION |
| Shared Package | |
| ML20151C507 | List: |
| References | |
| NUDOCS 8804130043 | |
| Download: ML20151C521 (30) | |
Text
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4ss *e au,,4" UNITED STATES
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NUCLE AR REGULATORY COMMISSION l
WA$MINGTON. O C. 20Sil j.
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July 13, 1987 i
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The Honorable Ernest F. Hollings, Chaiman Comittee on Comerce, Science, 1
l and Transportation l
United States Senate Washington DC 20510 l
Dear Mr. Chaiman:
Enclosed, for inclusion in the Hazardous Materials Transportation Act 2
hearing record of April 21, 1987, are our responses to post-hearing 3
questions from the Subcomittee on Surface Transportation.
I trust this information is respersive to your needs.
If I can be of i
further help, please do not hesitate to contSct me.
4
$1r.corely,
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/ _ -deh'n C. Bradburne. Dire tor Congrentonal Affairs
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Office of Governe.entai' and Public Affairs
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Enclosure:
As statec l
1 cc: 3enator John C. Danforth I
Senator J. James Exon Senator Robert W. Kasten j
I CORRESPONDENCE PDR 4
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I Some have proposed the use of dedicated trains to carry OUEST!0N 1.
a What are shipments of extreetly radioactive materials.
i 4
your views on this?
i r
f 1
i ANSWER.
The Comission believes that neither safety nor safeguards considerations i
dictate the use of dedicated trains. Hence NRC's regulations do rot require i
the use of dedicated trains. However, the Comission -talizes the desire of states for greater participttion in the transportation regulttien process.
If states desire an additional degree of confidence that spent nuclear fuel j
is being transported safely within state borders, the Commission suggests that states examine the inspection and escort program of the State of Illinois, i
Each spent nuclear fuel.hipeent traveling in 1111rois is inspected by the i
~
State's Department of Nuclear Safety to assure that all applicable Federal I
The Illinois State and State radiation protection requirements are met.
i The Illinois Folice inspect and escort trucks carrying these shiptr.ents.
Comerce Corsnission inspects rail shiptrents.
This inspection and escort program provides Illinois with an added measure of assurance that spent nuclear fuel is being transported safety without, it appears, ireposing burdensome procedures on licensees and carriers.
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6/5/87 HOLLINGS/ EXON Q1
What role do you feel States and localities shculd play in OVESTION 2.
the transportation of radioaccive materials? How do you feel the federal government might improve in its assistance to States and localities, particularly in tems of information and resources?
ANSWER.
The roles of State and local gov unments should be limited to those activities not preempted by the routing and other regulatory requirements of the U.S. Department of Transportation (DOT). States should enforce 00T regulations when those regulations have been incorporated into State law, but this enforcement should be no more burdensome to interstate comerce for radioactive materials than for any other hazardous materials.
The NRC recognizes the primary responsibility of State / local jurisdictions
'tecting members of the public in case of accidents, including those in imolving radioactive materials (see attached NRC Response to Accidents General Occurring During the Transportation of Radioactive Material:
Statement of Policy,49 FR 12335, March 29, 1984).
Much information and training is availab11 to States and localities, both from the Federal government and from the private sector (see Report to the Congress on Hazardous Materials Training, Planning, and Preparedness, U.S. Department of Transportation ard Federal Emergency Management Agency, July 1986).
We understand that the Department of Trarsportation and the Federal Emergency Management Agercy are considering the best means for previding any additiona information ed resources to State and local government agencies.
6/5/87 HOLLINGS/ EXON Q2
6/5/87 HOLLINGS/ EXON Q2 - AttaChrent UNITED STATES NUCLEAR REGULATORY COMMISSION RULES and REGULATIONS Tf7L113. CHAPTgR 1, CDDg DF P1DgmAL RgGULAtloNS-gNgm0Y
=
COMMISSION NOTICES POLICY STATEMENTS Transportation The roles in regulatory reopens.biht)
The emisur3 Memorandum of as P m 12235 of NRC and DOT have been dehnested Undersiending betwnn th DOT and Pw w F2 W in a Memotandwn of Understandmg the NRC { men..or ed abcvej us.gne (MOU) between the two agencies dated NRC the respons.bihty for the ngu]suon Jee 3. te's (+4 F'R 346001 The MOU ud certification of shippmg containers doce not defirie the specific for fisade malenals and for other W
radioacae res!enals (oeer than low Meeloactio Waternet.Generei tvepons;bdines of each agenc)in specif;c activity materials)in quantibes g pggy tespondq to transportanon accider:ts enceedmg Type A hmits es defined in 10 or incidents However. tn s!! accaderits CFR Part 717)e MOU sea.gns DOT Go seasset Nuclear P agulatory incidets and instances of actual or responsibihty for ngsJet.on of most Comtnasiert sapenJed leakage mvolving packagn other sepects of nuclear treasportauon actioac Central Statement of Puhey of radicactive matenalregulated by the e.:nvion DOT operate e % tonal avesuanr:De Nuclear Repletory NRC. ce MOU ass gns to NRC the Respecas Cents' which serses to relay Commission (N7C) has denned in a responsibary to act u leed agency for mformation concernmg trensrortation pnent pobey statement its role in minugen Ge uun of ee Mahage beidents involving he r ardsus matsnals.
nspondmg to acedents snd incidente and preparing a report of the DOT replatons requin a carner. at the related to the transportaben of nuclear inv ntpuen.
earl:est practicable enment. to gne matenals The purpose of ee pohey The Federal Einergency Management nonce to ce NSosal Response Canter sisterent is to state clearly the entent og e
f der an modut mun dums de the NRC's partactpation ene invoNemer.t e FM M@d course of transportshon m whah.
in nepondmg to such a transportsuon Erergency Ruponse Plan (F%TRP) On among o$er th:rtas Pre. breakest.
h
$rch 291964 December 13.1940 FT.MA pubbshed a spdtage. or suspected radioactae to "Master Plan" for commercial nuc! ear contaminauen oceun mielv:ng Poe rumtwen mecaustiou contact; pown plot accidnte (4$ F1649101 shipmest cf rad.cactne restenal Each Dr jusun T.Long Omce of Nuclear Development of the F%T.Jt.P. which is notificatun of a transportahunincadent Metenal Safety and Safspards.U.S scheduled for c.orr pleuen c 1.964. entals CI MI k'Pd 's relayed by the Nabonal Nucle r Repletory Corvn.ssion.
,pg,n,g gg.y,g pg includmg Response Cote to se Reg onalOftca
% a sherton. D C. 30653. telephone (3011 g, o p u pon g mee,porp, pron oon, cf the Etivtromments!Protecnon Agency 33 for responding to alli)Tes of pescentre
! EPA) for inode:.te on la d or to the U1 ra diological eme*sencies includtrg Ceest Guarc Cap'am of ee Port for transportanon accidents. Asadability of 8
'*0
88 54d pound plannmg pidance for developmg the
[', "Q'M8, i
The Nuclest Rep! story Corr. mission F%ERP was nobced in the Federal ra6cactne matenal notificauen is also (NRCL under the Atomic Energy Act of Register on Apnl 23.1643148 FR 19m)
M 4 ee Reg onal Coordmatag 1954. a s amer.ded (42 U S C Chapter 2J)
The FRIAP wdl be based on me Office for Radiolog est Ass stance of the and section act of the Energy plannmg pidence and on the resalts of U $ Dep tr ni of Ene p (DOEl and W Reorgarnauen Act of17?4. as emveded a Fun Field Exercise conducted in ce ee Reped Omu M % wehar (42 U.S C 5441L ls autheftsed to Uf tate vemiry of the St Lucie nuclast power Repletory Conasoon NRC my also and regu!ste the receipt possessiert uso p!pt in March 1964 te:ome ane e of a transpneuen and trattsfer of"byproduct matanal."
The reopense to transportanon m.dnt eragi oen osants aud u "sourca matanal. and "specal nuclest accidents is less serveru.ted than the the emp;er to carr er.or tu pohce or matenal"(as dentled in 42 UJ C. 3014).
Th NRC authortty to beente air radiolog,cet ecce guey response to h g% ptrol accidents at heea. sed sites oecause of DCE hn s'eIed h Dors shipmnt of protontwn is further ee uncans.nues seround.ng (1) the governed by Pub L 94-79 Pemnent locanon where Ge accident occvs (21
'30 " " ' " " ' ' ' h"
NRC resvist;one are contained a to the doenity of authenty of those who C77 Parta 30. 40.10. Pt. and 73 wdl be respond r.g and (3) ce hhel hmited radianon knowledie of the frei.
'[,'
['[y'p jg',','M.j ne U $ Departs:ent of n
Transpenattert (DOT). ur pr the onnene responders (who are usually educe and counsel m areas where Dange*ous Cargo Aci(R % 4472. se local o'hcials) The states have the states eey esed ses. stance Such tesms amended 44 U S C 1?0). 7ttle VI and 902'h1of the Federal Ananon Act of pnt-a y respers bihty for proteches the
,,e h g% profess:ena'. and art estipped 1954 (49 U S C 1421-1430 and 14?2th)).
hes;th and saf ety of the citeere from a pg,,shtical and d; agnostic the Decartment cf Transportanon Act psbhc herards Pecosthon of the sepon M ro to wie mohed ia reepors:bihtas f or red abori hasards is dens; actmen $4 tums on ste (49 U S C 101. et seg I and the refected by the essetence of an veder ce DCE Rad. oles esi Ass;stanca Hans'dous MaterWe Transportation apprepnoe'y desyated stoe espey p.craan or ce Federal Red.olegtca' Act (49 U S C. 4:51313). is required to chartered with the respor.sibihty of kloniton's and Assessment P!an(DUE
'entate esfety in the transportation of respondq to rsdsolog cal emergent;e' coor tnated) atardous raa'eraa!a. taciudeg The Commisoon invites su interested
- adiosctne tr etenals Pernment DOT persons who destre to subtrut utitles regulauer: art contained m 49 CF7 Part 100 to 176
POUCY STATEMENTS comments or suggesticas on this general bltC eso.alance is requested bv the s'aiement of pobey to send dem to the on. scene coordinalet. NRC actmties Sestetary of the Commission. Uruted will be pnmanly hmiled to Ste'es Nvelear Regulatoay Commission-information collecuen.
% a nNngtort. D C. 20555* Attenuco:
-Provide neommendations to Docketing and Service Branch by July
,,,79,n,y r,,,,n,, p,,, ann,i on 27.1964 radiologicalispee if NRC asaietsace Consideration wd! be gnen to such should be requested by the on-scene avbmissions sn connection with possible coordinator or if a need is recogmaed futun review ;. c'the stated pobey.
by NRC personnel Copies of co. inents received may be Np here m M M W 4 esamined.at the Commission's Pubhc to :adiolorcal concerna Respending to Docurnefit Room.1717 H Street N W.,
any attempt to stes; or sabotage a Weahtngfort. D C.
shipment of nuclear ma'enalis a Statement of NRC Polic'y
"'P'08'bihty of the Federal Bureev of Investigstion (FBI) as dehnesied m the la any accident or incident occurnna NRC/ FBI Memorard. n of in connection with the transportation of Undester tr>g daad Apn! 3719?9 end radioactive eaten.alin which a nport sa pubhahed DeceTher 2019*9. at a4 FR req red to be sent to the National 75535 Response Center by DOT resdations in 04 49 CFR 17115 NRC radiatan safety we'ed,se w aihms.on D C, we urd 4.r er as a nt actions wiu consist of the 7,,
I
-Call the agency designated by the s'fected Sinie to respond to
" * * ' C# " " '#"
transportauon accidents mvolvtra i
radioactive matenals se soon as practicable to erisare that agency has been informed of the incident (The Sta'e goverent is nsponsible for sesa.ing control of the accident scene to protect the health and safety of the pubbe)
-Offer NRC tedru;al asa: stance 6n ihe form of eformauon. aduce. and 1
eval.auens te the Siete at the ture the initiel nouficauon is made to the appropr:ste State agency.
-Assare awareness of the recident by the DOE r.nd c2er affwed asencies j
inc!wd.r,g any agencies spectica !y des gnated by the Federal Emergency Mansgement Agency
-Ma4nts.n awareness of the sitwation until nerma! cond.tions are restored at the scene of 2e accident.
-Provide mfortnatien on packagir4 character?stlCs @ respo"se ko any q.ery regard.r,g NRC sp;roted packages
~ Respond to regaesta for informahon on NRC netivities m connection wh the evernt. Requeste for specific information on so occident normauy wiu be refernd to the appropnaie
$ late agency, or to the DOE J the sitaation relates to DOE actwities
-lf the sNpper,a as S7C hee see ensae that the shirrer provides corp lete and sceus'e it.ferma' ion concorrang the ratoscute matenal and detada of the aNpment to emergency resporse personnel
-In accordance wit.h the NRC-DOT Memorande of Understand;ng. act as.'ted agency for investaatta all accidenta incidents and testances of actal or sospected leshage evolvig pachases of radicactne rasterial re Wated by the NRC AM NRC personnel si the scene of a transportatien accident wdi notify the on scene coord nator of h.s or her presence and make ciest that. uniese December 31,1985 (reet)
PS.T R.2
00E has apparently submitted a number of shipping casks, QUESTION 3.
which it self-certifies pursuant to 49 CFR 173.7(d), to NRC for direct certification. NRC apparently has raised a number of questions about these casks and 00E subsequently What withdrew a number of the certification requests.
problems did NRC identify with the DOE casks and why didn't NRC certify them since in theory they already complied with NRC regulations?
ANSWER.
DOE, on its cwn initiative, has submitted 17 shipping cask designs, which 00E For many of them, NRC requested may se,f-certify, to the NRC for certification.
In 17 cases, DOE did not respond to NRC additional information from DOE.
00E later withdrew the packages from service and withdrew their reques ts.
Areas where specific information was requested requests for certification.
It should be for these 17 designs are provided in the accompanying table.
noted that none of these design applications were actually denied or "rejected" by the NRC, as the NRC review for these cases was never completed.
1 1
6/5/87 HOLLINGS/ EXON Q3
)
- QUESTION 3. (Continued)
CASX APPLICATIONS CANCELLED OR WITHCDAWN BY 00E DOE ADDITIONAL INFORMATION CERTIFICATE PACXAGE MODEL REQUESTED TYPE NO.
N0.
(S;e explanations below*)
1,2 HNPF 1.
5469 Spent fuel 1,2,6,7 2.
5608 Spent fuel BR-63-0101 3.
5753 Spent fuel ORNL LOOP 6,7 4.
5907 Spent fuel ORNL In-pile 1,2,3,5,6,10 2,6,9 ANL-390 5.
6104 Spent fuel ANL-402-SPM/403-SPM 1.5,9 6.
6345 Spent fuel 1,6,8,9 6495 Spent fuel Paducah Cask 2,8 8.
4960 PU, Normal form LLD-1 1,2,8,10,11 9.
5645 PU, Special fom AL/5645 2
'O.
5885 PU, Special form FRFE 1,2,3,9
- 11. 6115 PU, Special form R1010-0032 1,6
- 12. 9931 PU, Normal form C47H, C47V 2,8,9
- 13. 5097 Fissile Uranium 44 8,10
- 14. 5170 Fissile Uranium 8
- 15. 5467 fissile Uranium
- 16. 6088 Waste, Type B Garden Carrier No. 2 2,8,9 2
- 17. 6421 Byproduct.
AL/6421 Special Form
- EXPLANATIONS _
The NRC was not able to complete its review under 10 Specific requests for information included:
1.
Detailed design drawings 2.
Thirty foot drop test analysis Puncture analysis Internal gas generation and effects on package containment 3.
4 Buckling and brittle fracture of containment vessel 5.
Establishment of specific containment criteria Analysis of containment vessel for normal and accident ccndi+ ions 6.
7.
Criticality analysis 8.
Operating procedures, acceptance and maintenance programs 9.
- 10. Themal analysis
- 11. Shielding analysis 6/5/87 HOLLINGS/ EXON 03
NRC's current routing and notification regulation are aimed Qt'ESTION 4.
at limiting the consequences of acts of sabotage and terrorism and NRC does not believe that there is any other How safety factor necessitating consideration of routing.
does the NRC reconcile its obligation to keep radiation doses to the public, including transport workers, As-Low-As-Resonably-Achievable, while ignoring routing consequences?
ANSWER:
In 1977, NRC prepared a Final Environmental Statement (FES) on the Transporta-tion of Radioactive Materials by Air and Other Modes (NUREG-0170), which fo that radiological risks in transport are small, and that routine radiation doses to the public and the transport workers are very low and not very sensitive to The Con:nission subsequently concluded that "present regulations are routing.
adequate to protect the public against unreasonable risk from the transport A strict application of As-Low-?,s-Reasonably-Achievable radioactive materials."
(ALARA) would require the direct routes through cities rather than the use of 00T's routing rule does seek to beltways around cities, where available.
minimize radiological transport impacts but, based on the FES, NRC advised 00T on their hiS way routing (00T Docket HM-164) to require routing of shipments h
so as to minimize total _ annual health impacts, including nonradiological We believe, all things properly considered, transport exposures are impacts.
6/5/87 FOLLINGS/ EXON Q4
NRC's testimony argues that as a result of a recent study of QUESTION 5.
historical highway and railroad accident conditions the Please public is really even safer than previously thought.
provide the study cited in your testimony and identify any other studies completed in the last ten years by the NRC relevant to transportation of radioactive shipments.
ANSWER.
A copy of the study mentioned in our testimony, NUREG/CR-4829, "Shipping Container Response to Severe Highway and Railway Accident Conditions,"
February 1987, is attached. The following additional NUREG and NUREG/CR Reports are related to transportation of radioactive shipments:
NUREG/CR-4829 Vols. 1 and 2 Shipping Container Response to Severe Highway and Railway Accident Conditions NUREG-0383 Vols. 1, 2, and 3 Directory of Certificates of Compliance for Radioactive Material Packages Study on Fabrication Criteria for Ductile NUREG/CR-4363 Cast Iron Spent Fuel Shipping Containers Highway Accident Involving NUREG/CR-4035 Radiopharinaceuticals Near Brookhaven, Mississippi on December 3, 1983 Fabrication Criteria for Shipping NUREG/CR-3854 Containers Radioactive Material (RAM) A cident/
NUREG/CR-3611 Incident Data Analysis Progras Recomended Welding Criteria for Use in l
NUREG/CR-3019 the Fabrication of Shipping Containers for Radioactive Materials State Surveillance of Radioactive Material hUREG-1015 Transportation 6/5/87 HOLLINGS/ EXON 05
. QUESTION 5.(Continued)
Simulation of Loading Conditions for a Type NUREG/CR-3536 A Package Containing Americium-241 Involved in an Airplane Crash at Detroit Metro Airport in January,1983 Transportation of Radioactive Material NUREG/CR-2325 (RAM) to and from U.S. Nuclear Power Plants (Draft Environmental Assessment)
Mechanical Analysis of Transportation NUREG/CR-3452 involving Errpty Shipping Casks for Radioactive Materials Near Hilda, South Carolina, in November, 1982 Severe Rail and Truck Accidents: Toward a NUREG/CR-3499 Definition of Bounding Environments for Transportation Packages Cost-Benefit Analysis of Unfired Pu02 NUREG/CR-3445 Pellets as an Alternative Plutonium Shipping Fonn Dynamic Analysis to Establish Normal Shock NUREG/CR-2146 and Vibration of Radioactive Material Shipping Packages Transportation of Radioactive Material in NUREG/CR-2949 Washington State Final Report on Shipping Cask Sabotage NUREG/CR-2472 Source Term Investigation Transportation of Radioactive Material in NUREG/CR-2852 Nevada Transportation of Radioactive Material in NUREG/CF,-2851 Illinois, June 1980 - June 1981 Transportation of Radioactive Material in NUREG/CR-2842 SouthCarolinaOctober1980-September 1981j Transportation of Radioactive Material in f
Michigan Transportation of Radioactive Material in NUREG/CR-2699 Maryland:
Transportation Surveillance Study l Transport of Low Specific Activity NUREG/CR-2440 Radioactive Materials An Unconstrained Oversight of the Critical NUREG/CR-2225 Elements in a Model State System for Emerger <
Re ponse to Radiological Transportation Incidents 6/5/87 HOLLINGS/ EXON QS
- QUESTION 5. (Continued)
Transportation of Radioactive Material in MUREG/CR-2036 Florida Transportation of Radioactive Material in htREG/CR-2195 South Carolina (Surveillance Study October 1979 - September 1980)
Transportation of Radioactive Material in NUREG/CR-2280 Georgia (Transportation Surveillance Study, October 1979 - 1980)
Transportation of Radioactive Material in NUREG/CR-2037 Washington State (Transportation Surveillance Study September 1979 -
September 1980)
Recomendations for Protecting Against NUREG/CR-1815 Failure by Brittle Fracture in Ferritic Steel Shipping Containers up to Four Inches Thick Transportation of Radioactive Material in MUREG/CR-2034 Michigan (Transportation Surveillance Study 1 September 1979 - 31 August 1980)
Transportation of Radioactive Material in MUREG/CR-2033 Geor la (Rept for October 1978 - September 1979 A Review of Removablo Surface Contamination NUREG/CR-1858 on Radioactive Materials Transport Container A Method for Determining Radioactive Materia NUREG/CR-1117 Shipment Patterns in Urban Areas Transportation of Radioactive Material in NUREG/CR-2035 Illinois (6 June 1979 - 6 June 1980)
Potential Crush loading of Radioactive NUREG/CR-1588 Material Packages in Highway, Rail and Marir Accidents Transportation of Radioactive Materials in NUREG/CR-1671 Kentucky (October 1978 - December 1979)
Annotated Bibliography on the Transportatio NUREG/CR-1275 and Handling of Radioactive Materials Survey of Current State Radiological NUREG/CR-1620 Emergency Response Capabilities for Transportation Related Incidents Shock Environtrents for Large Shipping NUREG/CR-1277 Containers during Rail Coupling Operations 6/5/87 HOLLINGS/ EXON 05
- QUESTION 5. (Continued)
Identification and Assessment of the Social hCREG/CR-0744 Impacts of Transportation of 4dioactive Materials in Urban Envirorcents Review and Assessment of Packagt huREG/CR-0535 Requirements (Yellowcake) and Emergency Response Transportation Accidents Review and Integration of Existing NUREG/CR-0742 Literature Concerning Potential Social Impacts of Transportation of Radioactive Materials in Urban Areas Puncture of Shielded Radioactive Material MUREG/CR-0930 Shipping Containers: Analysis and Results Transportation of Radioactive Material in NUREG/CR-1194 Michigan (1 September 1978 - 31 August 1979)
Transportation of Radioactive Material in NUPEG/CR-1193 Illinois (6 June 1978 - 6 June 1979) i Emergency Response Scenarios for NUREG/CR-1149 Transportation Accidents involving J
Radioactive Materials-Compilation of State laws and Regulations NUREG/CR-1263 on Transportation of Radioactive Materials Snipping ccntainers for Nuclear Materials:
NUREG/CR-614 A Descr ive Bibliograpny Transportation of Radioactive Material in NUREG/CR-0931 Georgia (1 August 1977 - 30 September 1978)
Transportation of Radioactive Material in NUREG/CR-756 Illinois (6 June 1977 - 6 June 1978) j Transportation of Radioactive Material in NUREG/CR-0266 South Carolina (31 January 1977 - 1 February 1978) i Transportation of Radioactive Material in NUREG/CR-0286 Pennsylvania (October 1976 - September 1977)
Sumary Report of the State Surveillance NUREG/CR-0393 Program on the Transportation of Radioactive Materials The Transportation of Radioactive Materials NUREG/CR-0170 by Air and Other Modes Executive Sumary of Safeguards Systems NUREG/CR-334 Concepts for Nuclear Material Transportatio 6/5/87 HOLLINGS/ EXON QS
. QUESTION 5_.(Continued)
Safeguards Systems Concepts for Nuclear NUREG/CR-0335 Material Transportation Regulatory and Other Responsibilities NUREG/CR-0179 as Related to Transportation Accidents Calculations of Radiological Consequences NUREG/CR-0194 from Sabotage of Shipping Casks for Spent Fuel and High-level Wastes Exposure of Airport Workers to Radiation NUREG/CR-0154 from Shipments of Radioactive Materials.
A Review of Studies Conducted at Six Major Airports Potential Releases of Cesiun from Irradiated NUREG/CR-0069 Fuel in a Transportation Accident.
Supplement 17 to WASH-1238.
Environmental Survey of Transportation of NUREG-75/038 Radioactive Materials to and From Nuclear Power Plants. Supplement I Recomendations for Protecting Against NUREG/CR-3826 Failure by Brittle Fracture in Ferritic Steel Shipping Containers Greater than Four Inches Thick Qualification Criteria to Certify a Package NUREG-03e0 for Air Transport of Plutonium Study of the Mechanics of a Transportation NUREG/CR-0558 Accident Involving Natural Uranium Concentrate Plutonium Air Transport Package Model NUREG-0361 PAT-1-Safety Analysis Report Mechanics of a Highway Accident at Wichita, NUREG/CR-0992 Kansas, Involving Natural Uranium Concentrate A Study on Ductile and Brittle Failure NUREG/CR-3760 Design Criteria for Ductile Cost Iron Shipping Containers Review of Criteria for Packaging Plutonium NUREG/CR-0428 for Transport by Air Case Histories of West Valley Spent fuel NUREG/CR-4847 Shipments
Enclosure:
NUREG/CR-4829 6/5/87 HOLLINGS/ EXON 05
6/5/87 HOLL!?iGS/ EXON 05 - Attachrent i NUREG/CR-4829 UCID 20733 Vol.1 RT Shipping Container Response to Severe Highway and Railway Accident Conditions Main Report Manuscript Completed: April 1986 Date Published: February 1987 Prepared by L. E. Fischer, C. K. Chou, M. A. Gerhard, C. Y. Kimura, R. W. Martin, R. W. Mensing, M. E. Mount, M. C. Witte Lawrence Livermore National Laboratory 7000 East Avenue Livermore, CA 94550 j
Prepared for Division of Reactor System Safety Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission Washington, DC 20666 NRC FIN A0397
6/5/87 HOLLit'GS/ EXON 05 - Attachment NUREG/CR-4829 UCID 20733 Vol. 2 RT Shipping Container Response to Severe Hic,way and Raiway Accicent Concitions Appendices Manuscript Completed: Apnl 1906 Date Published: February 1987 Prepared by L. E. Fixhor, C. X. Chou, M. A. Gerhard, C. Y. Kimura, R. W. Martin, R. W. Mensing, M. E. Mount, M. C. Witte Lawrence Uvermore National Laboratory 7000 East Avenue Uvermore, CA 94550 Prepared for Division of Reactor System Safety Office of Nuclear Regulatory Research U.S. Nuclear Regulatory Commission Washington, DC 20666 NRC FIN A0397
Please provide an inventory of all NRC approved casks.
QUESTION 6.
ANSWER.
SPENT FUEL SHIPPING CASKS CURRENTLY CERTIFIE0 BY NR MODEL CERTIFICATE MODE OF NO.
NO.
TRANSPORT CONTENTS _
SMI-1 5957 Truck Material Test Reactor &
Research Reactor Fuels, FSV-1A 6346 Truck High Temperature Gas Cooled Reactor Fuel GE-100 5926 Truck Fuel Rods or Fuel Plates GE-600 5980 Truck Reactor Fuel IF-300 9001 Rail Commercial Power Reactor Fuel IPO-200 5971 Truck Fuel Rods or Fuel Plates M-130 6003 Rail Naval Reactor Fuel M-160 9781 Rail Naval Reactor Fuel KAC-1 9183 Truck Natural Uranium Fuel Rods Commercial Power Reactor Fuel NLI-1/2 9010 Truck Commercial Poner Reactor Fuel NLI-10/24 9023 Rail NLI-6502 9103 Truck NRU/NRX Reactor Fuel Rods T-2 5607 Truck Test Reactor Fuel T-3 9132 Truck Mixed Oxide Fuel Assemblies Commercial Power Reactor Fuel TN-8 TN-8L 9015 Truck TN-9 9016 Truck Commercial Power Reactor Fuel 125-B 9200 Rail TMI-2 Reactor Fuel 700 5942 Truck Fuel Rods or Fuel Plates 1600 9044 Truck Fuel Rods or Fuel Plates 6/5/87 HOLLINGS/ EXON 06
., QUESTION 6_.
(Continued)
(a) The historical record shows that several NRC casks ha to be withdrawn from service or their use modified because they were ultimately found to be defective in some manner.
How many NRC casks have been withdrawn from service or required modification or alteration of service after being Please identify them by name, date of approval approved?
and alteration of approval?
ANSWER.
Certificate Modification or Alteration Model No.
No.
This cask was formerly identified as the Model NAC-1 9183 No. NFS-4, Certificate No. 6698. Containment vessel dimensions deviated from design require-ments, probably caused by manufacturing methods used during lead pour. Casks were ordered out of service April 6, 1979. Three of the seven casks were returned to limited service December 12, 1979 with the following restrictions: 1) maximum decay heat load reduced from 11.5 kilowatts to 2.5 kilo-watts, and 2) the casks were required to be shipped Subsequently several amendments were issued dry.
and on July 23, 1983, all casks were returned to service with contents limited to uranium metal fuel rods and decay heat limited to 625 watts.
6/5/87 HOLLINGS/ EXON 06
- QUESTION 6.
(Continued)
Certificate Modification or Alteration Model No._
No.
In June of 1981, General Electric Co. and IF-300 9001 Ca' olina Power and Light Co. notified NRC that the pressure relief valve on the cask did not perform as expected during operational tests. As a result, casks were removed from wet service and only shipped dry. On April 6,1982, Revision No.13 to Certificate of Compliance No. 9001 deleted wet shipments, in September 1982, General Electric Co. and Carolina Power and Light Co. notified NRC that a nonconservative SWR basket weight was used in the analysis of the 30-foot drop test. On September 30, 1982, shipment of BWR fuel assemblies was delated by Revision No. 14 to the certificate of
)
compliance. On March 22, 1983, Revision No. 15 to the Certificate of Comoliance l
was issued which reinstated the shipment of BWR fuel assemblies based on General Electric Co. structural analysis demonstrating adequacy of the BWR fuel basket.
6/5/87 HOLLINGS/ EXON 06
. QUESTION 6.
(Continued)
Certificate Modification cr-Alteration Model No_._
No.
In February 1985, NRC was notified that SMI-1 5957 radioactive contamination was present in the shield cavity. Cask was not to be used until corrective action had been taken. On March 22, 1985, NRC approved the repairs to the cask and the cask was returned to normal service.
In January 1987, NRC was notified of a cracked 1600 9044 weld at the bottom of the cask. The Cask is to remain out of service until repairs are satisfactorily completed.
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6/5/87 HOLLINGS/ EXON Q6
- QUESTION 6.
(Continued) l (b) Have any current NRC-licensed casks successfully passed Have any been physical, thermal, drop and imersion tests.
destructively tested?
t ANSWER.
No destructive tests or full-scale physical tests to the conditions specified in 10 CFR Part 71 have been conducted on spent fuel casks presently licensed The NRC requires applicants to demonstrate that cask designs meet by the NRC.
This demonstration may be by means of full-scale testing, NRC safety standards.
scale model testing, engineering analysis, or a combination of these methods.
Casks that are currently licensed by the NRC have met our safety standards by i
The use of a combination of scale model testing and engineering analysis.
engineering analysis techniques, including computer modeling, and the use of scale model tests are well established and verified engineering practices.
A number of computer programs are available and have been used by engineers to accurately model a variety of different systems and to successfully Likewise, the scientific predict their performance under specific conditions.
basis and reliability of scale model testing is well documented in the technical literature.
6/5/87 HOLLINGS/ EXON Q6
Does NRC have regulatory authority under existing QUESTION 7.
statutes to require licensing of all DOE high-level nuclear waste or spent fuel shipeents and casks to an MRS or a repository since those will be NRC licensed facilities?
M SWER_
No.
It is well established that the transportation of source, special nuclear, or byproduct material by the Department of Energy is not subject, under the That statute Atomic Energy Act of 1954, as amended, to regulation by the NRC.
generally extends NRC jurisdiction to any "person" engaged in specified act vities, but excludes "the [ Atomic Energy] Cccrnission" and its legal successors from the scope of this definition. 00E is a successor to AEC insofar as it (NRC does have exercises functions authorized by the Atomic Energy Act.
licensing jurisdiction, however, "as to" certain 00E storage facilities, under Section 202 of the Energy Reorganization Act of 1974.)
In view of this background, there is no requirement under the Atomic Energy Act, nor the Nuclear Waste Policy Act of 1982, for 00E to comply with NRC This would include transportation of 00E high-level transport regslations.
nuclear waste or spent fuel and casks to an MRS or a repository.
6/5/87 HOLLINGS/ EXON Q7
What considerations and procedures does NRC ta k to assure QUESTION 8.
that state and local emergency response capability is available and adequate along approved transportatien routes and for individual shipments?
ANSWER.
The NRC has no authority over State or local errergency response organizations.
However, the NRC maintains an awareness of the capabilities of States for About ten years ago, responding to radiological transportation emergencies.
the NRC commissioned a study of the subject (Survey of Current State Capabilities for Transportation Related Incidents, NUREG/CR-1620, School of Environmental and Public Affairs, Indiana University, September 1980).
We are Futher infoma-in the process of awarding a contract to update this study.
tion is also available (Profile of State and Local Radiation Control Programs in the United States for FY-1985, Conf. Pub. 87-3, Conference of Radiation Control Program Directors, 1987).
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In the event we are notified of a transportation accident, NRC would notify the affected state that the Agency is prepared to provide technical assistance (see answer to Question 2).
In addition, we are cognizant of the infomation contained in the Congression-ally mandated DOT-FEMA study (see answer to Question 2) and the extensive response information available through CHEMTREC (a service of the Chemica Manuf acturers Association), the U.S. Department of Energy, and other sources.
6/5/87 HOLLINGS/ EXON Q8
Could you describe your agency's responsibilities with QUESTION 9.
regard to the TMI shipments and walk us through the Please processes your agency has been involved in to date?
include a description of your interaction with the other two agencies.
ANSWER:
The NRC does not have regulatory authority for Department of Energy (DOE) TMI shipments, however NRC performed a safety review of the cask being used for The TN1 shipments and determined that its design meets NRC requirements.
DOE, on its own intiative, submitted the application to NRC for review on Additional information was requested from the applicant on June 14, 1985.
August 9 and December 23, 1985. Over 12 meetings were held witn the applica NRC Certificate of Compliance No. 9200 for the Model 125B cask was issued on April 11,1986 and revised on July 17, 1986. The NRC also inspected the manufacture of the shipping cask and the canisters which hold the fuel debris 00E is the shipper of record from the TMI site to the Idaho within the cask.
National Engineering Laboratory.
The Project Office The NRC has a Project Office located at the TMI-2 site.
reviews and approves the design of the canisters, procedures for loading fuel into the canisters and procedures for loading the canisters into the cask.
Before a shipment leaves the site, the Project Office performs a radiological survey of the cask to assure compliance with fiRC and 00T regulations.
6/5/87 HOLLINGS/EXO'1 Q9
QUESTION 9._(Continued)
The actual transport of the casks, including the routing, is regulated-by Thus, NRC is responsible for reviewing the safe design, manufacture 007.
and loading of the TMI cask while 007 is responsible for regulating safety i
in transport.
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6/5/87 HOLLINGS/ EXON Q9
00E justifies moving rail shipments of nuclear materials OUESTION 10.
through densely populated areas by setting criteria that give the greatest weight to choosing the shortest route and the best maintained tracks.
I have two questions Is 00E the appropriate agency for setting such about this:
criteria? How would you react to the suggestion that there should be rail routing guidelines which give more attention to avoiding highly populated areas, similar to those used for highway transportation of hazardous materials?
ANSWER _.
Under existing law, 00T has rail routing regulatory responsibility, while 00E As stated in has responsibility for selecting rail routes for its shipments.
the answer to question 4, NRC believes that radioactive material routing guide-From the technical stand-Ma s9uld minimize total annual health impacts.
ic should be noted that NRC has prepared a Final Environmental Impact po rt, Statement (NUREG-0170) on the transport of radioactive materials that consider rail transport and concluded that radiological transport risks are small.
)
6/5/87 HOLLINGS/ EXON Q10
^
00E tells me that dedicated trains are no' necessary for QUESTION 11.
the safe transportation of highly radioactive materials such as the TMI wastes because it believes in the integrity of the containers that are used. Most railroads tell me they prefer to carry highly radioactive shipments separately.
If one of the DOE's main criteria in selecting a route is avoiding switching, how can the use of mixed trains be justified?
Isn't this contradictory? Should DOE's position be reassessed?
ANSWER.
NRC defers to DOT on specific questions concerning route safety, mixed versus dedicated trains, etc. (see response to question 4). However, based on our assessment of the transport safety standards, the transport safety record, and i
confirmatory research studies, we believe the packages designed to NRC standards and practices provide adequate safety during shipment.
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1 6/5/87 HOLLINGS/ EXON 011 i
How manageable are current regulations? Do you see QUESTION 12.
evidence of confusion at the state and local level, or are the workshops to which 00T refers providing adequate clarification?
ANSWER.
As with any regulatory system that has evolved from several different author-Nevertheless,it izing statutes, there is always the potential for confusion.
is our belief that the regulatory roles among federal agencies are well defined, and that the regulatory system provides for adequate protection of the public The regional workshops on the transportation of radioactive health and safety.
material sponsored by 00T have brought federal, state and Indian representa-tives together to begin a dialogue on regional transport questions and concerns, it is our understanding that the state and Indian representatives have found the workshops helpful.
6/5/87 HOLLINGS/ EXON Q12
Isn't it cumbersome to deal in Mencrandums of Understanding CUESTION 13.
Wouldn't it be to coordinate agency responsibilities?
oreferable for all agencies to be subject to one set of regulations? It seems to me that public anxiety about nuclear shipments is heightened because they aren't confident that safety standards are uniformly high.
ANSWER.
The authorizing statutes for 00E, NRC, and 007 provide overlapping responsi-bilities in the area of radioactive material transportation due to the unique characteristics of these materials. Memorandums of Understandir,g provide an effective means for delineating these responsibilities and eliminating dupli-In fact we believe that effective operation of these agen-cation of effort.
NRC and DOE are at present consi-cies has resulted in high safety standards.
dering a Memorandum of Understanding which would address consistency in t application of safety standards to the package certification process.
6/5/87 HOLLINGS/ EXON Q13
I am alarmed to realize that the 00E sanetimes uses OVEST10N 14.
How casks or containers that the NRC earlier rejected.
can this be justified?
ANSWER.
00E has recently established an independent group to perform the technical review of package designs and has formal training courses for the reviewers.
Many of the reviewers have also spent one or two weeks working at NRC to Our impression of the new 00E certification observe the NRC review process.
process is that it is very good.
The casks in question were submitted to NRC before COE established its new After the new 00E certification centenlized review and certification process.
process was initiated, we understand that all of the casks in question have In all, we understand that 00E has de-certified 18 been removed from service.
package designs which were previously authorized by DOE before the new review group was formed.
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6/5/87 HOLLINGS/ EXON Q14
Inspection and enforcement staffing seems to be the QUESTION 15.
Does your agency last priority, a fact that concerns me.
honestly have the staffing and financial resources to get the job done? What would be a better level?
ANSWER.
At this time, the NRC has no information which suggests that the current level of NRC effort, resources, and funding in performing transportation inspections is inadequate.
The conduct of inspections of transportation activities of NRC licensees is given equivalent priority within the overall NRC program for inspection of other radiological safety aspects.
Region-based radiation specialist inspectors are provided with training in nuclear transportion reguldtions.
These inspectors, whether in the materials license facility, fuel facility, or reactor inspection program areas, routinely inspect transportation For major shippers, such as fuel facilities, reactors, and major activities.
radioisotope suppliers, the frequency of such inspections is at least On a reactive inspection basis, NRC has been inspecting a high annually.
percentage of actual shipments in the spent fuel shipping campaigns over th These shipments have involved the facilities at West Valley, past four years.
NY, Morris, Il and Three Mile Island, in addition to several other reactor facilities.
6/5/87 HOLLINGS/ EXON Q15
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