ML20202G463

Rev 0 to PGE-1076, Trojan Reactor Vessel Package SAR, Environ Rept

ML20202G463
Person / Time
Site:	07109271, Trojan  File:Portland General Electric icon.png
Issue date:	02/02/1999
From:	PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20202G436	List: ML20202G429 ML20202G451 ML20202G463
References
PGE-1076, PGE-1076-R, PGE-1076-R00, NUDOCS 9902050189
Download: ML20202G463 (23)

Text

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PGE-1076 I

! PORTLAND GENERAL ELECTRIC COMPANY

!. TROJAN REACTOR VESSEL PACKAGE 2

SAFETY ANALYSIS REPORT ENVIRONMENTAL REPORT l

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Revision 0 Portland General Electric Company 121 SW Salmon Street Portland, Oregon 97204 O

9902050189 990202

{DR ADOCK 05000344E PDR i

Trojan Reactor Vessel Package - Safety Analysis Report - EnvironmentalReport

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TABLE OF CONTENTS 1.0 INTR O D UCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E- 1 2.0 ENVIRONMENTAL EVALUATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-1 2.1 IDENTIFICATION OF THE PROPOSED ACTION . . . . . . . . . . . . . . . . . . . . E-1 2.2 THE NEED FOR THE PROPOSED ACTION . . . . . . . . . . . . . . . . . . . . . . . . . E-3

2.3 DESCRIPTION

OF THE ENVIRONMENT AFFECTED BY THE PROPO S ED ACTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-3 2.4 ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION . . . . . . . . . E-4 2.4.1 EFFECT ON HUMAN ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . E-4 2.4.2 EFFECTS ON TERRAIN, VEGETATION, AND WILDLIFE . . . . . . E-5 2.4.3 EFFECTS ON ADJACENT WATERS AND AQUATIC LIFE . . . . . . E-5 2.4.4 EFFECTS OF RELEASED RADIOACTIVE MATERIALS . . . . . . . . E-5 2.4.5 EFFECTS OF RELEASED CHEMICAL AND SANITARY WA S TES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-6 2.4.6 EFFECTS ON RADIATION EXPOSURE TO THE PUBLIC . . . . . . . E-7 2.4.7 CONSEQUENCES OF A NON-CREDIBLE REACTOR VESSEL

• CONTAINMENT BREACH . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-7 2.5 ALTERNATIVE TO THE PROPOSED ACTION . . . . . . . . . . . . . . . . . . . . . . E-8 N 2.5.1 RADIATION EXPOSURE (ALARA) . . . . . . . . . . . . . . . . . . . . . . . . . E-9 2.5.2 NUMBER OF RADIOACTIVE WASTE SHIPMENTS . . . . . . . . . . E-10 2.5.3 S C H E D UL E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E- 10 2.5.4 TOTAL COST . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E- 1 1 2.6 ALTERNATIVE USE OF RESOURCES . . . . . . . . . . . . . . . . . . . . . . . . . . . E-13 2.7

SUMMARY

AND JUSTIFICATION OF EXEMPTIONS . . . . . . . . . . . . . . . E-13 2.7.1 NRC EXEMPTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-13 2.7.2 DOT RE. LATED EXEMPTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-14 2.8 REGULATORY GUIDE 7.I2 ALTERNATIVE . . . . . . . . . . . . . . . . . . . . . . E-15 2.9 STATUS OF COMPLIANCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-16 3.0 RECOVERY PLAN FOR THE TROJAN RVP OVERBOARD AND LAND TRANSPORT DROP SCENARIOS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-17 3.1 WATER TRANS PORT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E- 18 3.1.1 DEEP WATER RECOVERY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-18 3.1.2 SHALLOW WATER RECOVERY . . . . . . . . . . . . . . . . . . . . . . . . . . E-19 3.1.3 PACKAGE OVERBOARD DAMAGE . . . . . . . . . . . . . . . . . . . . . . . E-19 3.2 L AND TRANS PO RT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-2 0 3.2.1 RE C OVERY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-20 3.2.2 PACKAGE DAMAGE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . E-21 APPENDIX E-1, CONTINGENCY PLAN FOR PACKAGE RECOVERY b

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Trojan Reactor vesselPackage - Sclety Analysis Report - EnvironmentalReport ,

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1.0 INTRODUCTION

i This Environmental Report evaluates the environmental impact of the proposed action of shipping the Trojan Reactor Vessel Package (RVP) to an approved disposal site on the Hanford Reservation near Richland, Washington. The report is submitted by Portland General Electric Company (PGE) in response a a request by the Nuclear Regulatory Commission (NRC) in a letter, dated July 9,1998, which transmitted, " Trojan Reactor Vessel Package Request for Additional Information." The report is prepared in accordance with 10 CFR 51.45, ,

" Environmental Report," to facilitate the NRC's preparation of an Environmental Assessment in i accordance with 10 CFR 51.30," Environmental Assessment," for approving the proposed action under an exemption per 10 CFR 71.8," Specific Exemptions." Additionally, this Environmental Report specifically addresses Questions E-1 through E-4 of the request for additional information.

2.0 ENVIRONMENTAL EVALUATION 1

2.1 IDENTIFICATION OF THE PROPOSED ACTION

' Contingent upon the receipt of required regulatory approvals, the Trojan Reactor Vessel Package (RVP) will be shipped as a Type B (as exempted), exclusive use, radioactive material transportation package for 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 (as exempted) shipping package. The  ;

reactor vessel is a large, thick-walled, steel structure measuring approximately 42' 6" long and 17' 1" in outside diameter. It was a Safety Class 1 vessel originally designed in accordance with <

the requirements of the ASME Code,Section III (1968 edition with Addenda through Winter 1%8). After preparation, the RVP will be shipped approximately 300 miles from the Trojan Nuclear Plant site to the US Ecology disposal facility. During the shipment, the RVP is expected to be outside the Trojan Nuclear Plant site and US Ecology facility boundaries less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

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 extemal attachments will be removed, sealing 0-rings installed, and the reactor vessel head installed and tensioned using 54 head studs and nuts.

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Trolan Reactor Vessel Package - Safety Analysis Report - EnvironmentalReport C. The reactor vessel void space, with intemals 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.

The bulk (99.99%) 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. Intemal contamination is approximately 155 curies, which is less than the contamination contained in the Trojan Steam Generators which were successfully licensed and shipped as greater than Type A, low specific activity (LSA) packages.

The fissile material content of the RVP will consist of 3.56g of Plutonium, and is contained within the intemal contamination. 10 CFR 71.53(a) provides that a package containing not more than 15g 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 transpon.

,O 'E. Steel shielding will be installed on the exterior surface of the reactor vessel, as necessary, to comply with the dose limit requirements of 10 CFR 71.47 and 10 CFR 71.51.

Radiation surveys will be conducted to verify the requirements are met.

F. The RVP will be removed from containment, lowered to ground level, and secured onto a specially designed transporter using an engineered tiedown system.

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

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.

After preparation as a shipping package as discussed in Chapter 2 of the RVP SAR, the RVP will be loaded onto a transporter at the Trojan site and transported as an exclusive use shipment. The RVP will be secured to the transporter by an engineered tiedown system. This tiedown system is designed to meet the requirements of ANSI N14.2, "Froposed American National Standard Tiedowns for Truck Transpon of Radioactive Materials." Once loaded onto the transporter, the RVP will not be removed until it is off-loaded into the disposal trench at the US Ecology disposal facility.

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1>olan Reactor vessel Package - Safety Analysts Report - Enviromnental Report hhe shipment will comply with the specifications of ANSI N14.24-1985, "American National Standard for Highway Route Controlled Quantities of Radioactive Materials -Domestic Barge Transport," and with the applicable requirements of 10 CFR 71 -Packaging and Transportation of l

. Radioactive Material (as exempted),33 CFR - Navigation and Navigable Waters,46 CFR - )

Shipping, and 49 CFR -Transportation (as exempted).

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The RVP-loaded transporter will be moved and secured onto a specially designed barge at the l Trojan barge slip. The RVP will be ' shipped up the Columbia River (approximately 270 miles) to I the Port of Benton in Warddngton. After the barge off-load, the RVP-loaded transporter will be moved to the US Ecology low level radioactive waste facility for disposal.

2.2 THE NEED FOR THE PROPOSED ACTION The Trojan Nuclear Plant was shutdown in November 1992, and on January 27,1993, Portland General Electric Company notified the NRC ofits decision to permanently cease power l operation and subsequently defueled the reactor, storing the spent fuel in the Trojan spent fuel l pool. Currently, PGE has a possession-only license under 10 CFR Part 50 and applied to i terminate its license on January 25,1995, by submitting a decommissioning plan. PGE proposed  ;

to decommission the facility using a dismantlement or DECON approach as defined in the " Final  ;

' Generic Enviro unental Impact Statement on Decommissioning of Nuclear Facilities," 1 NUREG-0586, dated August 1988.

In accordance with the NRC-approved decommissioning plan, PGE's plans for decommissioning the Trojan Nuclear Plant include decontaminatior; and dismantlement of contaminated structures, systems, and components. The removal of the Trojan reactor vessel and the internals is an evolution that is discussed in the decommissioning plan, and is necessary for completion of decommissioning and release of the site for unrestricted use.

2.3 DESCRIPTION

OF THE ENVIRONMENT AFFECTED BY THE PROPOSED ACTION The Trojan Nuclear Plant is located in Columbia County, Oregon, approximately 42 miles north of Portland, Oregon, on the Columbia River at Mile 72.5 from the mouth. The site consists of approximately 634 acres incorporating a recreational area / park, various office buildings, and an industrial area enclosed by a security fence. The Trojan barge slip is located just south of the

' industrial area on the Trojan site. The river at this location is the boundary between the States of Oregon and Washington.

The Port of Benton in Washington is located approximately 270 miles up the Columbia River from the Trojan Nuclear Plant. The licensed US Ecology low level radioactive waste facility is O located on the Hanford Nuclear Reservation near Richland, Washington, less than 30 miles overland from the Port of Benton.

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2.4 ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION l l

l The RVP will be assembled and shipped approximately 300 miles as a one-time shipment from the Trojan Nuclear Plant to the US Ecology disposal facility located on the Haubrd Nuclear Reservation near Richland, Washington. The expected duration of the land transport will be less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This includes the portions at the Trojan site and at Hanford. The duration of the l river transit is expected to be less than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Thus the total expected time the RVP will be j outside of the Trojan site and disposal facility boundaries will be less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

The one-time, short duration shipment of the RVP will be made under extensive and proven procedural controls and along a well-defined, favorable transportation route to the US Ecology licensed radioactive waste disposal facility. Removal of the reactor vessel with its internals intact and transport of the RVP will facilitate completion of decommissioning and release of the I site for unrestricted use, which is a positive impact on the local Trojan site environment. The RVP will be shipped to a facility that is licensed to accept and dispose oflow level radioactive waste.

The shipment of the RVP involves no irreversible or irretrievable commitments of resources and

,w ill have negligible impact on the environment. The proposed method of packaging and transport ensures the safety of the shipment and is consistent with the NRC's policy to maintain radiation exposure to workers and the public as low as reasonably achievable.

2.4.1 EFFECT ON HUMAN ACTIVITIES l

Additional workers will be employed at Trojan during the project. The peak in number of I workers is expected to occur during the time (approximately two months) that the reactor vessel l is first lifted and penetration covers and shielding are welded on. Skilled craft, particularly welders, will be needed. Some of the skilled workers will come from local communities. The largest source of skilled craft is in the Portland, Oregon area.

The Trojan site is in an area that has experienced construction of several large industrial facilities l in addition to the construction, operation, and maintenance of Trojan. The maximum number of  ;

on eite workers during the RVP removal and disposal project is expected to be significantly less than that for a normal refueling outage when the plant was operational. Most of the workers from Portland are expected to commute, due to the short term nature of the project. No significant adverse impacts are expected on temporary housing or schools as a result of the project.

The proposed method of packaging and transport ensures the safety of the shipment and the public. The effect on river traffic will be minor since this activity adds only one barge shipment on a majorriver that routinely carries a large number of commercial barge shipments. Highway O- traffic near the transport route from the Port of Benton to the disposal facility will be controlled E-4

Trojan Reactor Vessel Packase - Safety Analysis Report - Environmental Report while the RVP-loaded transporter transits to the disposal trench at the US Ecology disposal j facility. The traffic control measures will have only a minimal, short duration impact on routine -

'l traffic flow.

l 2.4.2 - EFFECTS ON TERRAIN, VEGETATION, AND WILDLIFE

' The RVP removal and package preparation will take place on previously developed areas of the Trojan site. The reactor vessel will be removed from an existing building and transported on an existing road to the barge slip. The barge slip area is in a rocky area along the Columbia River, and is adjacent to an archaeologically significant area where Indian artifacts have been found. 1 l Any barge slip dredging will be done in accordance with permit requirements. I

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. Since the project will utilize existing developed areas, no impact is expected to occur on the )

(- . undeveloped areas. The proposed activities will not affect endangered or threatened species or

!  ; critical habitat in the vicinity of the site. No changes are needed to the conclusions reached by l PGE on the environmental effects of decommissioning activities in PGE-1063, " Supplement to  :

l Applicant's Environmental Report" (Ref: Section 4.2), or to the conclusions reached by the NRC I l

in the " Environmental Assessment by the U.S. Nuclear Regulatory Commission Related to the Request to Authorize Facility Decommissioning," December 1995 (Ref: Section 2.1.3).

i Land transport of the RVP from the Port of Benton, Washington, to the US Ecology disposal facility will also take place on previously developed areas. No impact on terrain, vegetation, or wildlife is expected from this portion ofland transport.

2.4.3 EFFECTS ON ADJACENT WATERS AND AQUATIC LIFE The RVP will be transported by barge up the Columbia River to the Port of Benton Appropriate

permits from the US Army Corps of Engineers will be obtained for barge slip dredging as necessary. Required permits will also be obtained for any barge slip modification that may be required. Regarding the potential for radioactive contamination of the water, radioactive

. shipment regulations require that the package be free of any loose surface contamination.

Reactor vessel external surfaces will be decontaminated, as necessary, to ensure compliance with i 10 CFR 71.87(i) and will be coated to fix any residual contamination. The RVP will be tied

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down to the transporter, and the transporter tied down to the barge. Tiedown designs will be  !

reviewed by the appropriate authorities. The reactor vessel nozzles and other penetrations will 1 have covers welded over them, thus minimizing the potentiel for contamination of adjacent j waters and aquatic life. Therefore, there will be no impact on adjacent waters or aquatic life.

2.4.4 EFFECTS OF RELEASED RADIOACTIVE MATERIALS c Radioactive gas may be removed from the reactor vessel via venting connection (s) during LDCC l l filling operations. Radioactive paniculate matter will be generated during certain operations of 1

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Trojan Reactor VesselPackage- Safety Analysis Report-EnvironmentalReport the project such as cutting and grinding. These operations will take place inside the Containment Building. High efficiency particulate air (HEPA) filters (local and/or Containment Building purge exhnust) will be utilized as necessary. The opening in the Containment Building will be closed when there is a likelihood of airbome contamination. This will minimize the potential for an unmonitored release of gaseous radioactive material.

Regarding the potential for radioactive liquid effluents, the reactor vessel will be drained prior to filling with LDCC. Any radioactive liquid will be processed as required prior to disposal.

Water is used on the diamond wire saw during concrete cutting operations. Although not expected to be contaminated, the effluent will be monitored prior to release.

The proposed method of packaging and transport ensures the safety of the shipment and precludes the release ofradioactive materials during transport. Therefore, there will be no impact of released radioactive materials during transport.

2.4.5 EFFECTS OF RELEASED CHEMICAL AND SANITARY WASTES A small amount of boron may be in water drained from the reactor vessel. In addition, a O' ' chemical foaming agent may be used in the LDCC. Any chemical discharges resulting from the project will be made in accordance with the limitations and conditions of the NPDES Waste Discharge Permit.

Regarding sanitary wastes, the Trojan sewage waste treatment plant was placed in service in 1989 and was based on operational staffing levels. The maximum number of workers on-site during the RVP removal and disposal project will be less than for a typical refueling-maintenance outage when the plant was operational. Thus, there should be no adverse impact on sanitary waste treatment and effluent discharge.

No uncontained chemical or sanitary wastes are expected to be generated during land and water transport of the RVP.

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2.4.6 EFFECTS ON RADIATION EXPOSURE TO THE PUBLIC By the time the vessel leaves the Containment Building, it will be filled with LDCC and have penetration covers and shielding installed. By the time the vessel leaves the site, it will meet the applicable radiation exposure requirements of 10 CFR 71.47 and 71.51; and 49 CFR Parts 171 and 172 (categorize hazardous materials), Part 173 (prescribe requirements for package preparation), and Parts 176 and 177 (prescribe general requirements for water and land transport, respectively).

The reactor vessel will be transported by barge to the Port of Benton. As such, the number of people in close proximity to the package will be significantly less compared to overland shipments. Detailed information on predicted exposures is provided in Section 2.5 and Table E2-1 of this environmental report. Total dose to the public is predicted to be only approximately 0.019 person-rem. Comparing this total dose to all members of the public to the 10.CFR 20.1301 limit of 0.1 rem per year to an individual member of the public from a facility such as an operating nuclear power plant, shows that the radiation exposure to the public from this project is well within acceptable standards for radiation exposure to the public.

2.4.7 CONSEQUENCES OF A NON-CREDIBLE REACTOR VESSEL CONTAINMENT Oa BREACH PGE evaluated the radiological consequences to the public from two non-credible accidents which result in a non-credible breach of the RVP. The following conditions were evaluated:

A. During overland shipment, the reactor vessel package falls off the transporter, and is breached.

B. 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, described in Section 1.1.1.4 of the SAR, 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 (5,000 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 I meter from the damaged package for more than 30 minutes.

As required by the SAR, PGE Radiation Protection personnel will accompany the RVP bQ shipment, and therefore, will be available to establish boundaries and perform emergency E-7

Trojan Reactor VesselPackage - Safety Analysis Report - Environmental Report O

V response functions. In addition, traffic escorts will control / restrict road traffic in the vicinity of the transporter during the overland transport. As a result, the evaluation for the overland shipment accident assumed exposure conditions for an individual standing 100 meters from the scene of the accident for 30 minutes. The evaluation determined the external exposure (DDE) to an individual is approximately 25 mrem and the intemal (CEDE) is approximately 12 mrem.

The evaluation for the river shipment accident determined that the extemal exposure (DDE) to an individual is O mrem and the intemal exposure (CEDE) is approximately 1.25 mrem.

Therefore, it is concluded that the above non-credible accidents will not result in a significant radiological consequence to the public, and do not significantly affect the public health and safety.

2.5 ALTERNATIVE TO THE PROPOSED APIION The proposed action and three alternatives were considered for the disposal of the reactor vessel and internals from the Trojan Nuclear Plant:

A. Reactor Vessel and Internals Removal (Proposed Action)

O V One piece disnosal of the reactor vessel with its internals intact. The RVP will be transported via barge and land transporter to the US Ecology disposal facility near Richland, Washington. This scenario is the preferred method based on radiation exposures to the general public and workers, and based on schedule and cost.

B. No Action Storage of the reactor vessel on site. On-site storage of the reactor vessel with its intemals intact is not considered to be a viable attemative since federal regulations (10 CFR 50.82(b)(1)(i)) require decommissioning within 60 years. Storing the vessel on-site for 50 years prior to removal is similar to the SAFSTOR decommissioning alternative, which was addressed in NUREG-0586," Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities." On-site storage for 50 years is not consistent with the DECON decommissioning alternative that was selected by PGE and approved by the NRC. The DECON decommissioning attemative has also been accepted and approved by the State of Oregon for the decommissioning of the Trojan Nuclear Plant.

On-site storage of the reactor vessel would result in retaining the 10 CFR 50 license and necessary staff to mcintain radiological controls and other 10 CFR 50 required programs.

Other results include, but are not limited to, performance of required periodic surveys, increased exposure to workers, and increased cost. It should be noted that low level radioactive waste disposal costs tend to increase at a rate greater than that ofinflation.

V Although radioactive decay would reduce shielding requirements, the reactor vessel E-8.

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Trojan Reactor Vessel Package - Safety Analysis Report - Environmental Report Iv) would still have to be disposed using one of the alternatives described below. Since insignificant gain would be realized, this scenario was not further evaluated.

C.

Modified Reactor Vessel and Intemals Removal (Modified RVAIR)

Disoosal of the reactor vessel in one piece with only the non-greater than Class C (non-GTCC) internals left inside. The GTCC intemals will have to be segmented underwater, placed into containers, and stored in the spent fuel pool or the Independent Spent Fuel Storage Installation (ISFSI) at the Trojan site. The vessel and non-GTCC internals will be shipped via barge in a single package, similar to the RVAIR alternative. The GTCC internals will be shipped at an unknown date in the future when a high-level waste repository becomes available to accept the waste.

D. Separate Disposal Separate disposal of the reactor vessel and internals. The reactor vessel internals will be segmented under water. The non-GTCC internals will be placed in shielded casks and shipped to the US Ecology disposal facility via truck. The GTCC internals will be stored in the spent fuel pool or the ISFSI at the Trojan site. The reactor vessel will be disposed h

1. of separately from the internals and either shipped whole via barge, or segmented and shipped via truck to the disposal facility. The GTCC internals will be shipped at an unknown date in the future when a high-level waste repository becomes available to accept the waste.

Radiation exposures, number of radioactive waste shipments, cost, and schedule were analyzed.

These categories are described below and summarized in Table E2-1 in a comparative form.

2.5.1 RADIATION EXPOSURE (ALARA)

Radiation exposure for the proposed action and alternatives was analyzed for the categories listed below. Dose estimates do not include doses resulting from on-site storage and future shipment of GTCC waste to a high-level waste repository (date and site unknown).

a. Occupational - exposure to workers completing the various work activities at the Trojan site.

b. Transportation Occupational - exposure to the drivers, inspectors, barge personnel, etc., related to the transportation of the radioactive waste shipments.

c. General Public - exposure to the general public based on the distance to the site, population dose factors, and the number of shipments. ,

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Trolan Reactor Vessel Package - Safety Analysis Report - Environmental Report ,

l d. On-looker - exposure to members of the general public when the package is not in .

l transpon. For truck shipments, this is when the truck driver stops for food, fuel, l or inspections. For barge shipments, this is when the barge is in the locks. ,

e. Disposal Facility Occupational - exposure to workers who dispose the packages at  ;

the disposal facility.  !

! 2.5.2 NUMBER OF RADIOACTIVE WASTE SHIPMENTS l The number of radioactive waste shipments was based on the amount and configuration of the waste produced, i  :

Radioactive waste shipments include two future shipments for GTCC waste for the Modified  !

RVAIR and the Separate Disposal alternatives. Not included are shipments of Dry Active Waste

! (DAW), or cavity cleanup waste (e.g., filters). For the RVAIR proposal,1 DAW shipment is estimated. For the Modified RVAIR alternative,2 DAW shipments and I filter shipment are estimated. For the Separate Disposal alternative,5 DAW shipments and 2 filter shipments are estimated.

lO 2 .5.3 SCHEDULE I

l The estimated schedules for the proposed action and alternatives are based on a final

determination of the selected project by approximately the fourth quarter of 1998. In addition, l- the schedules are based on a limited period for water transpon due to Columbia River level constraints on barge facilities.

The RVAIR proposal is currently scheduled for completion in the third quarter of 1999.

! The Modified RVAIR alternative would complete in the third quarter of 2000 based on the scope of work necessary to segment portions of the internals, package and remove the reactor vessel and the remaining internals, and ship the package for disposal.

The Separate Disposal alternative would complete in the third quarter of 2001 based on the scope of work necessary to segment all of the internals, package and remove the internals, and ship the reactor vessel.

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2.5.4 TOTAL COST The RVAIR proposal is estimated to cost $23.8 Million in 1996 dollars. This cost includes the packaging, transport, and disposal of the reactor vessel and internals.

The Modified RVAIR alternative is estimated to cost $34.7 million in 1996 dollars. This cost includes removal of the required portion of the internals, on-site storage of the required material and eventual disposal, and the cost related to packaging, transport, and disposal of the reactor vessel and remaining portions of the internals.

The Separate Disposal attemative is estimated to cost $38.4 million in 1996 dollars. This cost includes segmentation of all of the internals, on-site storage of the required material and eventual disposal, the cost related to packaging, transport, and disposal of the remaining portions of the internals, and the separate packaging and disposal costs for the reactor vessel.

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Table E2-1 Summary of Proposal and Alternatives Option RVAIR MODIFIED SEPARATE Description RVAIR m DISPOSAL WU Shipment Method Barge Barge Truck + Barge Occupational 67.1 87.8 133.2  !

Exposure

• Transportation Occ. 0.092 0.092 1.060 Exposure

• General Public 0.005 0.005 0.245 Exposure

• On-looker 0.014 0.014 0.234 Exposure *

, Disposal Facility 0.2 0.2 4.2 to

) Occ. Exposure

• 5.2 Total Exposure

• 67.4 88.1 138.9 to 139.9 No. of Radioactive 1 3m 47m Waste Shipments")

Estimated Total 23.8 Million 34.7 Million 38.4 Million Cost (1996 Dollars)

Schedule Third Quarter 1999 Third Quarter 2000 Third Quarter 2001

• person-rem (1) Dose estimates do not include doses resulting from on-site storage and future shipment of GTCC waste to a high-level waste repository (date and site unknown).

(2) The reactor vessel is shipped whole by barge and the non-GTCC reactor vessel internals are segmented and shipped by truck.

(3) Radioactive waste shipments include two future shipments for GTCC waste.

(4) Not included are shipments of dry active waste (DAW), or cavity cleanup waste (e.g., filters). For the RVAIR proposal,1 DAW shipment is estimated. For the Modified RVAIR alternative,2 DAW shipments and I filter shipment are estimated. For the Separate Disposal alternative,5 DAW shipments and 2 filter shipments are estimated.

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Trojan Reactor Vessel Package- Safety Analysis Report - Environmental Report o 2.6 - ALTERNATIVE USE OF RESOURCES i

i The removal of the Trojan reactor vessel and the internals is necessary for completion of

' decommissioning and release of the site for unrestricted use. If the reactor vessel and the l intemals are not removed, it effectively results in storing radioactive waste at the Trojan site and precludes the release of the site for unrestricted use. {

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2.7

SUMMARY

AND JUSTIFICATION OF EXEMPTIONS

a Full compliance with the regulations of 10 CFR 71 and 49 CFR 173 is impractical for the I proposed shipment of the Trojan RVP. Full compliance with drop-height test requirements I would significantly increase the size and cost ofimpact limiters attached to the reactor vessel.

Larger impact limiters would raise the center of gravity of the RVP in its transport configuration

' resulting in a larger actual drop height that could occur during the shipment. Larger impact limiters could also make the shipment by barge physically impossible since a slightly taller package would not fit under the minimum overhead clearance point for the shipment route.

Furthermore, installation oflarger impact limiters would result in an increase in occupational dose to the workers performing the installation, which is not in keeping with the As Low As f

Reasonably Achievable (ALARA) concept. The RVP design meets the intent of the regulations j

, g 'to ensure that a drop of the package during shipment will not result in unacceptable 4 \ consequences to workers, the public, or the environment. In summary, the RVP design provides an equivalent, if not improved, level of safety by a simpler and more cost-effective and dose-  !

effective means.

j 2.7.1 NRC EXEMPTIONS

, The exemptions requested of the NRC are from two requirements specified in 10 CFR 71:

A. Normal Conditions of Transport (NCT): 10 CFR 71.71(c)(7) requires a drop of the l specimen through a distance of I foot onto a flat, essentially unyielding, horizontal surface, striking the surface in a position for which maximum damage is expected.

B. Hypothetical Accident Conditions (HAC): 10 CFR 71.73(c)(1) requires a drop of the specimen through a distance of 30 feet onto a flat, essentially unyielding, horizontal surface, striking the surface in a position for which maximum damage is expected.

The exemption from 10 CFR 71.71(c)(7) is fully described and justified in Sections 1.1.1.1 and 2.6.7 of the SAR. Based on the conditions and the special handling and operational controls to be exercised, the one foot drop should not be considered a normal condition of transport.

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Trojan Reactor Vessel Package - Safety Analysis Report - Environmental Report However, PGE has designed and analyzed the RVP with impact limiters to withstand the effects of a one foot horizontal drop and one foot oblique pivot drops.

The exemption frem 10 CFR 71.73(cXI) is fully described and justified in Sections 1.1.1.2 and .

2.7.1 of the SAR. Based on the transportation 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 of the RVP. However, 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  ;

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.

Based on the justification provided, it is concluded in accordance with 10 CFR 71.8 that the proposed packaging and shipment will not endanger life or property, nor the common defense  ;

and security. Furthermore, as stated in Section 2.4 of this report, this shipment will have negligible impact on the environment, and the proposed method of packaging and transport ensures the safety of the shipment and is consistent with the NRC's policy to maintain radiation exposure to workers and the public ALARA.

'2.7.2 DOT RELATED EXEMPTIONS The RVP is classified as a highway route controlled quantity of normal form Class 7 radioactive material, n.o.s. (not otherwise specified), to be shipped under exclusive use provisions. The total i quantity of radioactivity in the RVP is approximately 2 million curies, primarily of activated .

metal, which exceeds the A2 value of 49 CFR 173.433 for the mixture ofradionuclides. For the  !

RVP classification and quantity of radioactivity, the following Title 49 regulations lead in series to the conclusion that the appropriate shipping package for the RVP is a Type B package that meets the applicable requirements of 10 CFR 71 and that has been approved by the NRC-i A. 49 CFR 173.24(c)(1) states in part," Authorized packagings. A packaging is authorized for a hazardous material only if--The packaging is prescribed or permitted for the j hazardous material in a packaging section specified for that material in Column 8 of the l 172.101 [ Hazardous Materials] Table . . . " l B.- 49 CFR 172.101 Hazardous Materials Table Column 8 specifies {l73.416 as the applicable section for packaging of" Radioactive material, n.o.s."

C. 49 CFR 173.416(a) states,"Each of the following packages is authorized for shipment of quantities exceeding A, or A2 , as appropriate: Any Type B . . . packaging that meets the E-14

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Troian Reactor Vessel Package - Safety Analysis Report - Environmental Report , l O

applicable requirements of 10 CFR Part 71 and that has been approved by the U.S.

Nuclear Regulatory Commission may be shipped . . . "

In addition to 49 CFR 173.416(a), there are two other applicable Title 49 regulations that rely on the radioactive material transportation package being certified by the NRC as a standard Type B package. 49 CFR 173.403 states," Type B package' means a Type B packaging that, together with its radioactive contents, is designed to retain the integrity of containment and shielding required by this part when subjected to the normal conditions of transport and hypothetical accident test conditions set forth in 10 CFR Part 71." 49 CFR 173.467 states,"Each Type B packaging . . . must meet the test requirements prescribed in 10 CFR Part 71 for ability to ,

withstand accident conditions in transportation."

Since the NRC has indicated that their approval of PGE's request for the one-time shipment of the RVP per 10 CFR 71,will not include issuance of a C of C for the RVP as a Type B radioactive material transportation package, PGE seeks relief specifically from Regulations 49 CFR 173.416(a),173.403, and 173.467. The non-specification package is otherwise being assembled and controlled as a Type B package (as exempted by the NRC), except that it will not be marked " TYPE B," since that is specifically prohibited by 49 CFR 172.310 for a package that does not conform to Type B requirements. l O The information provided in the RVP SAR meets the requirements forjustification of the exemption proposal, as set forth in 49 CFR 107.105. It demonstrates that the exemption achieves l a level of safety at least equal to that required by regulation and is consistent with the public ,

interest.

Information describing relevant shipping and incident experience that relates to this application is l provided in Sections 1.1.1.1 and 1.1.1.2 and Appendices 1-1,1-2, and 1-3 of the RVP SAR.

I Also provided in those references is substantiation by industry experts that the favorable, relatively short transportation route and the extensive transportation controls that are being placed on this one-time shipment demonstrate an equivalent, if not improved, level of safety for the proposed land and river transport scenarios. The transportation controls are discussed in Chapter 7 of the SAR. Fmthennore, it is shown in the exemption requests from 10 CFR 71 discussed above that it is impractical to meet the requirements from which exemption is requested due to considerations of the package, the transportation route, and the transportation controls.

2.8 REGULATORY GUIDE 7.12 ALTERNATIVE The RVP brittle fracture evaluation methodology is fully described and justified in Sections )

1.1.1.3 and 2.1.2.3, and Appendix 2-12 of the RVP SAR. This information provides the basis j E-15

pojan Reactor vessel Package - Safety Analysis Report - Environmental Report froin which the NRC can conclude that the attemative method of evaluating fracture toughness of the RVP is acceptable.

2.9 STATUS OF COMPLIANCE Federal permits and approvals that must be obtained in connection with transporting the RVP for disposal at US Ecology's low level waste disposal facility and their status are as follows:

A. Approval from the NRC in accordance with 10 CFR 71 for the one time shipment of the RVP as a radioactive material transportation package, including approval of an exemption from drop test requirements of 10 CFR 71.71(c)(7) and 71.73(c)(1).

STATUS: Application was made by PGE on March 31,1997. The NRC issued a first Request for Additional Information (RAI) on May 19,1997. A response to the first RAI was made by PGE on June 18,1997. The NRC issued a second RAI on July 9,1998. A response to the second RAI is being made by POE, including this Environmental Report.

Approval from the NRC is currently anticipated to occur in the fall of 1998.

B. Approval from the DOT of an exemption from 49 CFR 173.403,173.416(a) and 173.467, O' with respect to those regulations relying on the RVP being certified by the NRC as a standard Type B package.

STATUS: Application by PGE for the exemption is expected to occur in August 1998, to allow the DOT to complete their review and noticing in parallel with gaining approval by the NRC. Approval from the DOT is anticipated to occur within approximately one week of them being provided evidence of the NRC's approval.

C. Hazardous Material Certificate of Registration from the DOT.

STATUS: Current <

D. Load Line Certificate for the barge from the American Bureau of Shipping, acting as an agent of the U.S. Coast Guard.

STATUS: Will be issued upon request.

E. Certificate ofInspection for the barge from the U.S. Coast Guard.

STATUS: Complete.

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' Trolan Reactor YesselPackage- Safety Analysis Report- EnvironmentalReport y

q F. Certificate of Documentation for the barge from the U.S. Coast Guard.

STATUS

Complete, i G. Approval of stability for the barge from the U.S. Coast Guard.

l STATUS: Complete.  ;

H. Certificate of Loading for the barge from the National Cargo Bureau, Inc. (NCB),

functioning as an agent of the U.S. Coast Guard.

STATUS: NCB completed a review of the Barge Tiedown Structural and Barge Stability I

Analyses, Revision 1, dated June 25,1998. They have identified to PGE the remaining i

- inspections that will be required before the Certificate of Loading is issued. Since some  !

of tnese inspections are to be performed after the RVP is secured to the barge and the barge is afloat, issuance of the Certificate of Loading by the NCB is anticipated to occur

between the first ofJuly and the end of October 1999.

The only identified applicable environmental quality requirements associated with transporting

. 'the RVP for disposal at US Ecology's low level waste disposal facility other than those with

'~ which tug boats and prime movers routinely deal, are land use regulations associated with disposal of the RVP. It is required that the State of Washington Department of Health (WDOH) j- determine that the RVP is suitable for disposal under the State's regulations.- In that regard, US Ecology provided to WDOH a Radiological Dose Pathways Analysis for disposal of the RVP.

WDOH is completing a review of the analysis. - It is expected that WDOH will inform US l 1

Ecology that the RVP is suitable for disposal at US Ecology's facility before the NRC approves )

the one time shipment of the RVP for disposal.

3.0 - RECOVERY PLAN FOR THE TROJAN RVP OVERBOARD AND LAND TRANSPORT DROP SCENARIOS The probability of a significant accident during water and land transport has been evaluated and is included in the RVP SAR as Appendices 1-1 and 1-2. The results of the evaluation determined the probability of an accident that would require some sort of recovery operation is extremely minimal. The discrete probabilities of the significant accidents evaluated on both the Columbia River and overland are:

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Trojan Reactor VesselPackage- Safety Analysis Report- Environmental Report l

l Table E3-1 L Probabilities of Significant Transport Accidents 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 l (during barging)  ;

Land Transport Accident 1.3E-07  !

l As noted in the RVP river transit study (Appendix l-1 of the RVP SAR), 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. 1 Nevertheless, in the unlikely event that such an accident were to occur, a contingency plan has been' developed to recover the RVP and is included as Appendix E-1 to this environmental report. Possible scenarios include foundering (sinking) of the barge, capsize, or failure of sea fastenings (tiedowns) during a collision. The contingency plan identifies technically feasible salvage methods, available equipment, and potential methodologies for recovering the submerged RVP.

The initial activity will be to complete an assessment of the barge and/or package based on the accident. This assessment will include a determination of the amount of damage to the components and determination of the best attematives for recovery and repair. 1

.j 3,1 WATER TRANSPORT 3.1.1 DEEP WATER RECOVERY.

Deep water immersion of the entire RVP, cradle, and barge is not considered to be a credible I accident event. However, if this were to occur, the assembly would almost certainly be capsized, with the barge resting on top of the cradle and RVP, due to air trapped in the barge. In this  ;

l unlikely event, the preferred recovery method would be to separate the components, salvaging l l first the barge, then the cradle, and then the RVP. There are a variety of salvage methods for the 1

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j Trojan Reactor vesselPackage- Safety Analysis Report- EnvironmentalReport o

barge, because even in a damaged condition, air can be bubbled into compartments in the hull for flotation. The RVP and cradle do not contain enclosed permeable spaces and must be lified. The

most likely procedure would be to rig the package for a submerged lift, lift it nearly to the j )

surface, and move it to the nearest suitable shallow water location for further preparation and repair.

l l The recovery of the RVP to shallow water can be accomplished by a variety of strategies. The i

most conventional method would be to mobilize several large derrick barges with sufficient

' , combined lifting capacity. Several suitable west coast derrick barges and two salvage vessels have been identified by PGE's naval architect. If sufficient derrick capacity is not readily

available, portable lifting gear can be rigged to a conventional barge, and the RVP lified directly l under the barge. Since the load is centered, this can be accomplished using a relatively small barge. The RVP can then be moved to the nearest suitable shallow water for recovery operations.

3.1.2 SHALLOW WATER RECOVERY )

Potential shallow water (less than 50 feet depth) immersion cases that are considered are: the l barge capsized and stabilized at a suitable site with the cradle and RVP intact, and the RVP O separated from the barge, with or without the cradle attached. In the case of a capsized barge with intact package, the assembly may be righted by lifting with one or more derricks using lifting wires wrapped around the barge. Parbuckling is another option, where horizontal forces are exerted to right the barge using two sets of wrapped wires. Another alternative is to ground the assembly, detach the barge and cradle, and lift separately. The method chosen will depend on the circumstances encountered, such as the degree of damage and the availability of equipment.

In the case of the RVP separated from the barge, with or without the cradle attached, the barge, cradle, and transporter would be salvaged, shipped to the appropriate shipyard, vendor, or owner for refurbishment or repair, as necessary, and retumed to the incident site. The RVP would be lified in air using cranes and lowered onto the cradle on the repaired barge. The vessel would be inspected, and further repairs would be made, if necessary. The RVP would then be secured to the transporter and barged to the Port of Benton for subsequent disposal at the US Ecology disposal facility.

3.1.3 PACKAGE OVERBOARD DAMAGE Remedial action would be required if closure plates or shielding were dislodged, or if there were a breach in the vessel wall. In the event of dislodged closure plates, the preferred method of repair would be to use mechanical / pneumatic plugs which would be installed by a team of divers.

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l Trojan Reactor Vessel Package - Safety Analysis Report - Environmental Report In areas of partial detachment, a sealing compound (either epoxy or metallic) would be applied to the open area, breach, or crack.

In the event that shielding is dislodged, reattachment could be accomplished by the installation of circumferentially placed slings, which would be tensioned to hold the shielding plates against the vessel or remaining shielding. If this method were not feasible, the shielding plates could be tack .

welded until permanent repairs could be effected on the surface.

In the event of a breach in the vessel wall, steel plates would be welded over the breach and additional steel plates would be added as necessary to reduce radiation levels to within acceptable limits for continued transport. In the extreme case of a breach in the vessel wall under the shielding, an indirect approach to sealing this breach would be used. The perimeter ofthe i shielding covering the area of the breach would be seal welded to the vessel to create a boundary l around the breach. l After submerged repairs are made, the RVP would be lifted in air using cranes and lowered onto the cradle on the repaired barge. The vessel would be inspected and further repairs made, if necessary. The RVP would then be secured to the transporter, and barged to the Port of Benton for subsequent disposal at the US Ecology disposal facility.

O V 3.2 LAND TRANSPORT 3.2.1 RECOVERY A land transport accident that would require a recovery operation is extremely minimal, and based on the design basis drop for the package, subsequent damage is not expected. However, in .

the event it did occur, the initial activity will be to complete an assessment of the transporter and/or package based on the accident. This assessment will include a determination of the

. amount of damage to the components and determination of the best attematives for recovery and repair. A bounding estimate for the potential radiation exposure was completed for the type of potential actions necessary. The extent of damage and methods of repair were assumed to be

similar to the water recovery scenario. Mobile cranes of sufficient capacity will be assembled at the accident site. First, the transporter and cradle will be recovered and repaired. The vessel will then be repaired, lifted onto the cradle on the transporter, and secured to the transporter. Final repairs will be effected, as necessary, and the package will be transported to the US Ecology disposal facility.

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'i Trojan Reactor VesselPackage - Safety Analysis Report- EnvironmentalReport O

V 3.2.2 PACKAGE DAMAGE A similar number of man-hours estimated for . vater repairs are assumed to effect land repairs. In the event of a breach in the vessel wall, steel plates would be welded over the breach and additional steel plates would be added as necessary to reduce radiation levels to within acceptable limits for continued transport. In the extreme case of a breach in the vessel wall under the shielding, an indirect approach to sealing this breach would be used. The perimeter of the O~

shielding covering the area of the breach would be seal welded to the vessel to create a boundary around the breach.

l After repairs are made, the RVP would be lifted in air using cranes and lowered onto the cradle on the repaired transporter. The vessel would be inspected and further repairs made, if necessary.

The RVP would then be secured to the transporter and transported to the US Ecology disposal ,

facility.

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