ML20216F429
| ML20216F429 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/25/1997 |
| From: | Callan L NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| References | |
| SECY-97-164, SECY-97-164-01, SECY-97-164-1, SECY-97-164-R, NUDOCS 9709110252 | |
| Download: ML20216F429 (5) | |
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..........eees ses.eees POLICY ISSUE (Notation Vote)
July 25.1997 SECY-97-164 FOR:
The Commissioners FROM:
L. Joseph Callan Executive Director for Operations l
SUBJECT:
SHIPMENT OF DECOMMISSIONED REACTOR VESSEL, CONTAINING IRRADIATED INTERNALS, FROM THE TROJAN NUCLEAR PLANT TO HANFORD NUCLEAR RESERVATION, RICHLAND, WASHINGTON PURPOSE:
To request Commission approval of staff's approach for reviewing a request from Portland General Electric Company (PGE) for a one-time shipment of its decommissioned reactor vessel (RV), including irradiated intemals, from the Trojan Nuclear Plant near Portland, Oregon to a disposal site at the Hanford Nuclear Reservation near Richland, Washington, BACKGROUND:
On March 31,1997, PGE requested that the Commission issue a Type B Certificate of Compliance (COC) under 10 CFR 71, which would allow the one-time shipment of a decommissioned RV, together with its irradiated intemals, under the general license provisions of 10 CFR 71.12. Under this proposal, the RV, together with its irradiated intemals intact, would be transported from the Trojan Nuclear Plant near Portland, Oregon, by barge approximately 434 kilometers (km) (270 miles) up the Columbia River to the Port of Benton, Washington, and then by special transporter to a disposal site operated by CONTACTS: Susan Frant Shankman, SFPO/NMSS oh 05/f (301) 415-2287
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John Hickey, DWM/NMSS (301) 415-7234 NOTE:
TO BE MADE PUBLICLY AVAILABLE WHEN THE FINAL SRM IS MADE AVAILABLE
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i 2-U.S. Ecology on the Hanford Nuclear Reservation near Richland, Washington The total trip is expected to take about 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, j
The RV, fitted with impact limiters for transport, would measure approximately 13 meters (m) (43 feet) in length and 8.5 m (28 feet) in diameter, and wou!d weigh 1
approximately 925 metric tons (1,020 tons). The RV, with its irradiated intemais, would contain over 74 petabecquerels (PBq) (2 million curies), primarily in the form of activated metal contained within the reactor intemals, Activity in the form of intemal surface i
contamination is estimated to be approximately 5.7 terabecquere's (TBq) (155 curies). In addition, it is estimated that the irradiated internals would generate approximatuy 20 to 30 kilowatts in decay heat.
DISCUSSION:
PGE's request to ship the RV with its intemals intact, represents a departure from the i
shipping arrangements envisioned by PGE Previously, the licensee had planned to remove the irradiated intemals from the RV prior to its shiprnent, with the intemals being shipped separately in Commission certified shipping packages. Because the proposed shipping package (i.e., the RV with intemals intact) does not meet the packaging performance standards for Type B packages, PGE has requested that the Commission issue a COC under the provisions of 10 CFR 71.41(c). If approval is not granted under 10 CFR 71,41(c) PGE requests an exemption under 10 CFR 71.8. Section 71'41(c) would allow the Commission to issue a COC based on the use of alternative environmeMal and test conditions for Type B packages. In this case, the applicant must demonstrate that the additional controls and the attemate test conditions proposed for a shipment provide ' equivalent safety" of the shipment l
to that provided if 10CFR 71.41(c) were not used.
in this instance, PGE has proposed that certain Type B test conditions for normal conditions of transport (e.g., the one-foot drop test as defined in 10 CFR 71.71), and for hypothetical accident conditions (e.g., the thirty-foot drop and puncture tests as defined in 10 CFR 71.73) l be replaced with less stringent test conditions, based on operational controls exercised during shipment. Altematively, if the Commission is unwilling to accept the applicant's analysis under 10 CFR 71.41(c), PGE has requested an exemption from the same test conditions under 10 CFR 71.8. Assuming that the Commission certifies the RV, with intemals, as a Type B package, PGE is proposing to ship the RV under the general license provisions in 10 CFR 71.12.
Staff will review PGE's request for a COC under 10 CFR 71.41(c). However, if the i
Commission is unable to certify the RV with intemals ur, der 10 CFR Part 71, PGE would still have the option of removing the irradiated intemals from the RV, shipping the intemals that are not classified as C eater Than-Class-C (GTCC) waste separately in Nuclear Regulatory Commission-certifie:i Type B packsges to a qualified disposal site, and storing the GTCC waste on-site.
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4 Under this option, the RV could either be shipped intact as either a Type B package (which requires Commission approval based on similar alternative test conditions as described above), or eher type package (e.g., an IP-2 package if it qualifies under Department of Transporta'i n regulations in 49 CFR), or could be dismantled into individual pieces, which could then ve shipped in Type B or other type packages.
Apart from trar,sportation, the PGE application has raised another important and potentially precedent setting issue. PGE, in proposing this shipment, has assumed that the RV, intact with intemals, can qualify for near-surface disposal. The basis for this assumption is the Branch Technical Position on Concentration Averaging and Encapsulation, issued by the Office of Nuclear Material Safety and Safeguards on January 17,1995, in contrast, if the intemals were removed for shipment separately, it is probable some of the intemals would be classified as GTCC wastes, and would not qualify for disposal at a near-surface disposal site.
PGE estimates that about 340 cubic feet of reactor intemals would exceed Class C limits.
Staff estimates that GTCC components contain about 80 percent of the total activity proposed for disposal. These GTCC components would require storage at the Trojan site until a suitable repository or disposal site is approved. Shipping and dicposal of the RV with intemals intact, would, if approved, eliminate the need to provide on-site storage for GTCC RV components. It should be noted that the State of Washington has made a preliminary waste classification determination that the Trojan RV with its intemals is consistent with NRC's Branch Technical Position on Concentration Averaging and Encapsulation and could be disposed of, with the reactor intemals intact, at the U.S. Ecology, Inc., burial facility in the State of Washington. The State of Washington is awaiting specific activation analysis which the licensee is to provide and any NRC staff review of the licensee analysis prior to making a final determination.
Because of its potential for impacting the environment and public health and safety, and its potential for setting a precedent, staff is requesting approval from the Commission on its approach for reviewing PGE's request, before committing significant staff resources. A preliminary estimate of the minimum resources that would be required to complete a review under 10 CFR Part 71 are 0.5 full time equivalent (FTE) staff years, and 100,000 dollars in contract support. These resources are included in NRC's FY 1998 budget request.
Therefore, staff requests that the Commission approve the following general approach for reviewing PGE's application:
(1)
Staff intends to consult with the State of Washington, an Agreement State, as to whether the RV with its intemals, is suitable for disposal at the U.S. Ecology site.
If the State of WashinrM determines that the RV with its intemals is not suitable for disposal at ine U.S. Ecology site, staff intends to terminate its review ar:d rotum PGE's application. Shipment and disposal of the RV and non-GTCC intemals could proceed as previously proposed by PGE.
(2)
If the waste classification of the RV with intemals is appropriate for the U.S. Ecology burial site, staff will notice receipt of PGE's application in the Federal Reaister.
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(3)
Staff will review PGE's request for shipment using the provisions in 10 CFR 71.41(c) to demonstrate equivalent safety, Staff willinform the Commission of its intent to !ssue any COC under 10 CFR 71.41(c).
(4) Altematively, if staff cannot approve the application under 10 CFR 71.41(c), it will so inform the Commission, and proceed to assess PGE's request for an exemption under 10 CFR 71.8. The staff willinform the Commission of the procass for that review.
COORDINATION:
This paper has been coordinated with the Office of Nuclear Reactor Regulation and the Office of General Counsel (OGC). OGC has no legal objection to this paper.
The Chief Financial Officer has concurred in thia paper.
RECOMMENDATION:
That the Commission:
6pp.rpyg the general approach outlined in this paper to review the shipment of a decominissioned RV from the Trojan Nuclear Power Plant near Portland, Oregon to a disposal site at the Hanford Nuclear Reservation near Richland, Washington.
Note that the staff will continue to inform the Commission of precedent setting issues, involving the transportation and disposal of large reactor components, such as reactor vessels.
Note that the State of Oregon has written to Chairman Jackson urging expeditious consideration of PGE's proposal (letter attached).
L.Jo h Callan Executive Director for Operatiens
Attachment:
Commissioners' comments or consent should be provided State of Oregon letter to directly to the Office of-the Secretary by COB Monday, Chairman Jackson August 11, 1997.
DISTRIBUTION:
Commission Staff Office comments, if any, should be Commissioners OCA submitted to the Commissioners NLT August 4, 1997, OGC CIO with an information copy to the Office of the Secretary.
OCAA CFO If the paper is of such a nature that it requires OIG EDO additional review and comment, the Commissioners and the OPA SECY Secretariat should-be apprised of when comments may be expected.
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b June 12,1997 DEPA RTME NT Of ENERGY The Honorable Shirley Ann Jackson, Ph.D., Chairman U.S. Nuclear Regulatory Commisrion Washington D.C. 20555 0001
Dear Chairman Jackson:
I On March 31,1997, Portland General Electric sent the NRC a request to amend the decommissioning plar for the Trojan Nuclear facility. The nature of the proposed amendment is to allow the reactor vessel to be removed and shipped in one piece, instead of removal of reactor vessel internals and segmentation of the vessel.
i PGE has estimated that this amendment would save nearly 20 person rem over segmentation, as well as avoiding many contamination events. In addition, the public radiation exposure would be an order of magnitude less owing to a single river shipment as opposed to over 50 highwas 41pments. The State of Oregon has worked closely with the Navy as well as local govern - ns along the Columbia RJver to address issues raised by 62 shipments of submarine reactor compartments over the past several years. Shipping the Trojan reactor vessel presents l
issues very similar to these Navy shipments. One piece reactor vessel removal would save an estimated SIS million, in addition to the identified public health benefits. I have attached a copy of an editorial from the Portland Oreconian regarding this matter for your information.
Oregon's Energy Facility Siting Council (EFSC) has been briefed on the issue, and while they have not yet taken action, they have reacted positively to the brief~mg As is our custom on high profile issues, EFSC will not take action until we understand the NRC's analysis of the matter.
I urge you to give PGE's proposal quick consideration. I believe the proposal has merit.
Many of the r,afety issues of one piece reactor vessel removal are similar to PGE't large component removal of two years ago. We found that large component removal went well, and cost and radiation dose were lower than anticipated in planning.
Please contact me if you have any questions. Thank you for your consideration.
Sincerely, i+n A van
(.0% rfh0F David A. Stewart Srnith, Administrator D;,i Energy Resources Oregon NRC Liaison Officer 625 Manon Street NE Salem, OR 97310 (503) 378-4040 FAX (503) 373-7806 Toll-free 1-800 221-8035 i
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