ML20236N889
| ML20236N889 | |
| Person / Time | |
|---|---|
| Site: | Saxton File:GPU Nuclear icon.png |
| Issue date: | 06/24/1998 |
| From: | Kuehn G GENERAL PUBLIC UTILITIES CORP. |
| To: | TRANSPORTATION, DEPT. OF |
| Shared Package | |
| ML20236N893 | List: |
| References | |
| 1920-98-20296, NUDOCS 9807160044 | |
| Download: ML20236N889 (58) | |
Text
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1 l 55 June 24, 1998. d GPU Nuclear,Inc g g a Route 441 South
~ NUCLEAg 1920-98-20296 Post Office Box 480 Middletown, PA 17057-0480 Tel 717 944-7621 )
Associate Administrator for Hazardous Mnerials Safety Research and Special Programs Adcninistation U. S. Department of Transportation [C) /Mh 400 7* Street, SW f Washington, D.C. 20590-0001 Attention: Exemptions, DHM-31 Gentlemen:
Subject:
Exemption Requests for the Shipment of the Saxton Steam Generator, Pressurizer and Reactor Vessel
- Ihc purpose of this letter is to submit two complete copies of GPU Nuclear's requests for exemptions, pursuant to 49 CFR 107.105, from the requirements of 49 CFR 173 to support shipping the Saxton Nuclear Experimental Corporation (SNEC) facility's large components. The first exemption it being
~ requested to obtain relief from 49 CFR 173.427 for packaging oflow specific activity (LSA) materials and 49 CFR 173.403 surface enntammated object level limitations for the transportation of a nuclear steam generator and pressurizer to the Barnwell, S. C. burial site. The second exemption is being requested to obtain relief from 49 CFR 173.427 p=ek=ging requirements, the radiation dose limitation at three meters and the 49 CFR 173.403 LSA material definition for a nuclear reactor vessel. It will also be shipped to the Barnwell, S. C burial site. The detailed exemption requests and supporting documentation are prosided in the enclosed =*achments.
Two attachments contain preliminary documents: Attachment 3, the Transportation Plan and Attachment 4, the Emergency Response Plan (Health & Safety Plan). An overview of the transportation plan is included since the railroad arrangements have not been finalized (the ground transportation plan for the components between the SNEC facility site and the rail siding are complete). The Emergency Response Plan, while complete has not been approved. Final versions of the documents will be submitted upon completion /
approval of contract agreements betweet; GPU Nuc! ear, its contractors and the railroad (s) involved. .
GPU Nuclear presented its Large Component Removal Project plans to personnel of the Department of Transportation and NRC Transportation and Storage Safety Section at a meeting on November 5,1997. A second presentation was made to personnel of the NRC's NMSS Disision, Waste Management Section on December 4,1997. GPU Nuclear is currently in the process of responding to a request for additional l information regarding questions that resulted from the second presentation.
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1920-98-20296 Page 2 of 2 Due to the limited window of oppcstunity available to successfully complete the SNEC large component shipment in 1998 (due to schedule, site weather conditions and disposal site availability), it is requested that you process these exemption nquests on an expedi'.ed basis. If additional information is required, please contact Mr. William Heysek of the Nuclear Safety and Licensing Depanment at 717-948-8191.
Sincerely,
/s/ Perry G. Carmel for G. A. Kuehn Vice President SNEC WGH Attachments- see listing cc: DOT Office of Hazardous Materials Safety Technology - Richard W. Boyle NRC Project Manager, NRR- Alexander Adams File 980%
Reactor Vessel Package Attachment List Attachment 1 - Exemption Request Attachment 2 - Transportation System Description Attachment 3 - Transportation Plan Attachment 4 - Emergency Response Plan (Health & Safety Plan)
, A**hment 5 - Characterization Report Attachment 6 - Calculation Package Steam Generator and Pressurizer Package Attachment List Attachment ! - Exemption Requer,t Attachment 2 - Transportation System Description Attachment 3 - Transportation Pian i Attachment 4 - Emergency Response Plan (Health & Safety Plan)
Attachment 5 - Characterization Report Attachment 6 - Calculation Pac.kage i _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Attachment 1 j Saxton Nuclear Experimental Corporation Facility Steam Generator & Pressurizer Shipment Exemption Request
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1 ATTACHNTENT 1 EXEhfPTION REQUEST FROM THE PACKAGING REQUIREMENTS OF 49 CFR FOR THE SHIPMENT OF THE SAXTON STEAM GENERATOR AND PRESSURIZER l
49 CFR 107. l05 Applicationfor exemption.
49 CFR 107.105(a) General.
49 CFR 107.105(a)(1): The requested need date for this exemption is September 9,1998.
Two copies of this exemption have been delivered to:
Associate Administrator for Hazardous Materials Safety Research and Special Programs Administration U.S. Department of Transportation 400 7th Street, SW Washington, D C. 20590-0001 Attention: Exemptions, DHM-31 49 CFR 107.105(a)(2): The applicant name, address and responsible agent for this exemption is:
Applicant Saxton Nuclear Experimental Corporation (SNEC) and GPU Nuclear Inc.
Mr. G. A. Kuehn Jr.
Program Director SNEC Facility GPU Nuclear Inc.
2574 Interstate Drive Harrisburg.PA 17110 49 CFR 107.105(a)(3): Saxton Nuclear Experimental Corporation and GPU Nuclear Inc. are United States corporations.
49 CFR 107.105(a)(4): This is not a request for a Manufacturing Exemption.
49 CFR l07.105(b); Con)idential treatment Confidential treatment of this exemption is not requested.
49 CFR l07. l05(c? Descnption ofexemptionproposal 49 CFR 107105(c)(1): With regard to the transportation of one steam l generator and one pressurizer from the Saxton Nuclear Experimental Corporation Facihty site m Saxton, PA to the burial site in Barnwell, SGPAtich doc 10:10 AM 6/24/98 Page1 J
ATTACHhENT I EXEMPTION REQUEST FROM THE PACKAGING REQUIREMENTS OF 49 CFR FOR TIE SHIPNENT OF THE SAXTON STEAM GENERATOR AND PRESSURIZER
! S.C.. the Applicant seeks relief from the requirements of 49 CFR 173 as follows:
PACKAGING The requirement of 49 CFR 173.427(a) that low specific activity (LSA) material must be packaged in accordance with 49 CFR 173.427(b) or (c).
49CFR 173.427(b)(1) requires that SCO material be packaged "in an L
industrial package", specifically delineated in Table 8 as an IP-2 package for SCO Il contents transported by exclusive use shipment.
SCO Il CONTAMINATION LEVELS 49CFR173.403 which defmes Surface Contaminated Objects (SCO) and 2
provides a limit for SCO-Il of 20 uCi/cm (p-y/LTA) and 2 uCi/cm2 (a) for the non-fixed and fixed contamination on inaccessible areas averaged over 300 cm2.
49 CFR 107.105(c)(2): The specific modes of transportation for this exemption request are
- 1) Motor Vehicle Transponation
. 2) Rail Transportation l
The steam generator and pressurizer will be transported from the SNTC facility site property by land transporter to a local railroad siding for transport by railcar to their final destination.
49CFR107,105(c)(3): A detailed description of the proposed exemptions follows as well the 49CFR107.105(c)(5): basis for the exemption requests.
PACKAGING 49 CFR 173 was not written to specifically accommodate large nuclear components with internal surface contamination such as the Saxton steam generator and pressurizer. However, NRC Generic Letter 96-07 L
promulgated the DOT determination that "the entire steam generator is considered to be the radioactive material contents and there is no
" package" as defined in 49CFR 173.403" SGPAuch. doc 10:10 AM 6/24/98 Page 2
0 ATTACHMENT 1 EXEMPTION REQUEST FROM THE PACKAGING REQUIREMENTS OF 49 CFR FOR THE SHIPMENT OF THE SAXTON STEAM GENERATOR ANT) PRESSURIZER 49 CFR 173.427(a) requires SCO material to be packaged in accordance with paragraph (b) or (c) of this section. For SCO Il material transported as an exclusive use shipment. 49 CFR 173 427(b) and Table 8 would require that the vessel be packaged in an Industrial Package type 2 (IP-2). IP-2 package design and certification requirements are stipulated in 49 CFR 173.411. Under the requirements of 49 CFR 173.411(b)(2) each IP-2 must meet the general design requirements of 49 CFR 173.410 and prevent the loss or dispersion of radioactive material and significant increases in the radiation levels under the testing requirements of 49 CFR 173.465(c) and (d) or evaluated in accordance with 49 CFR 173.461(a).
The applicant proposes to transport the steam generator and pressurizer as transportation systems (non-specification packagings) which provide equivalent safety to IP-2 packages when transponed in accordance with the transportation plan and emergency response plan. A description of the Saxton steam generator and pressurizer transportation systems is enclosed as Attachment 2, the transportation plan is included as Attachment 3 and the emergency response plan is included as Attachment 4.
All Saxton steam generator and pressurizer activities will be controlled by the Transportation Plan and the Emergency Response Plan which will in part require that the Saxton components remain in a horizontal position during all transportation evolutions. In addition, all external lifting devices will be removed or disabled. Therefore, the steam generator and pressurizer were analyzed for a free drop from any orientation up to 30*
from horizontal as opposed to the orientation which would cause
" maximum damage to the safety features being tested" Analyzing horizontal drop scenarios up to 30 is conservative for the conditions of transport as regulated by the Transportation Plan.
It should be noted that the transportation requirements for SCO Il material presented in 49 CFR 173.427(a) will be met with the exception that the sealed steam generator and pressurizer will be shipped unpackaged.
The pressurizer and the primary cooling water side of the steam generator are designed for over 2400 pounds per square inch (psi), and the secondary side of the steam generator is designed for over 1000 psi The overall height of the steam generator is 20 feet with a diameter of 5 SGPAttch. doc 10:10 AM 6/24/98 Page 3
i ATTACHMENTS I
EXEMPTION REQUEST FROM THE PACKAGING REQUIREMENTS OF 49 CFR FOR THE SHIPMENT OF THE SAXTON STEAM GENERATOR AND PRESSURIZER feet 9 inches, a r.ominal shell thickness of 2 7/8 inches and a dnj weight of 52,000 pounds. The overall height of the pressurizer is 200 inches, with an outer diameter of 43 inches, a nominal shell thickness of 3 3 inches and a dry weight of 25,000 pounds.
All nozzles on both vessels will be sealed with welded steel closure plates Bolted inspection plates and manway covers that are currently a part of the steam generator or pressurizer will be left in-place as closure plates for transponation or will be replaced with a welded steel closure plate. The steam generator and pressurizer and all welded or bolted closure plates will be evaluated to assure that they meet the free drop requirements of49CFR173.465(c).
The Applicant concludes that the sealed Saxton steam generator and pressurizer as described herein will be extremely rugged, leak tight packages that meet or exceed the IP-2 packaging requirements of 49CFR 173 410 and 173.411, and that the exemption identified in Generic Letter 96-07 for steam generators allows the above described alternative.
SCO 11 CONTAMINATION LEVELS The applicant has performed a detailed radiological characterization of the steam generator and pressurizer and the results are presented in Attachment 5. This characterization work addressed the non-uniformity of the internal surface contaminants and evaluated the contamination levels separately for each major section of both the steam generator and pressurizer. The characterization results showed the worst case estimated contamination levels within both the steam generator (51 2
microcuries/cm beta / gamma and 0.2 microcuries/cm 2 alpha) and 2
pressurizer (4.2 microcuries/cm beta gamma and 0.6 microcuries/cm 2 alpha) are well below the SCO Il limits of 20 microcuries/cm2 for 2
beta / gamma and 2 microcuries/cm for alpha contamination. However, due to the large inaccessible surface areas of these components, it is not possible to unequivocally show that there is no 300 cm2 area which exceeds the SCO Il limits. Therefore, the applicant seeks relief to the provisions of 49CFR173.403.
The applicant has demonstrated through the radiological characterization results that there is a reasonable assurance that the SCO II contamination level limitations will be met. The applicant has obtained a significant SGPAttch doc 10:10 AM 6/24/98 Page 4 i
ATTACHMENT 1 EXEMPTION REQUEST FROM THE PACKAGING REQUIREMENTS OF 49 CFR FOR (
THE SHIPMENT OF THE SAXTON STEAM GENERATOR AND PRESSURIZER amount of representative sample and survey data to support the characterization effort. However, due to the physical configuration of the steam generator and pressurizer it is not practicable to assess every 300 cm2 area of the internal surfaces.
49 CFR 107105(c)(4): The current project schedule requires shipment of the steam generator and pressurizer from the Saxton site on September 21,1998. Land transpon to the railroad siding and rail transport to the ultimate disposal facility should be accomplished within 120 to 180 day m order to accommodate unforeseen delays in our schedule, we ask that the exemption for the steam generator and pressurizer be applicable for 1 year from the date of approval 49 CFR 107.105(c)(6): The Applicant is not requesting emergency processing under Sec. 107.117.
49 CFR 107.105(c)(7): The Saxton plant is a single loop Pressurized Water Reactor with one reactor vessel, one steam generator and one pressurizer. The steam generator transfers heat from the primary part of the reactor cooling water system, via a bundle of tubes, to the secondary / steam ponion of the power plant. The pressurizer provides a surge volume to accommodate changes in primary water temperature.
The primary water side of the steam generator tubes, the tube sheet which holds the tubes, and the bottom sections or bowl of the steam generator are in contact with water that passes through the reactor core.
The pressurizer is essentially a tank which holds primary water. Over time the primary surfaces of the steam generator and pressurizer receive a uniform adherent coating of radioactive contamination. The secondary side of the steam generator surfaces are not in contact with reactor cooling water, hence there are no radioactive contaminants on these surfaces.
The applicant has performed a detailed radiological characterization of the Saxton Steam Generator and Pressurizer which is enclosed as i Attachment 5 to this exemption request. This report contains a detailed l identification and description of the hazardous material.
The steam generator and pressurizer are to be transported as Surface Contaminated Objects (SCO) with SCO-Il levels of Class 7 (radioactive)
SGPAttch. doc 10:10 AM 6/24/98 Page 5 l
4 ATTACHMENT I EXEMPTION REQUEST FROM THE PACKAGING REQUIREMENTS OF 49 CFR FOR THE SHIPNENT OF THE SAXTON STEAM GENEPATOR AND PRESSURIZER 1
material. The chemical description for the contained Class 7 material is solid metal oxides deposited uniformly on surfaces composed of carbon 4 steel and stainless steel. The total contained quantities of Class 7 (radioactive) material are; Steam Generator 1,060 millicuries Pressurizer 755 millicuries These activities correspond to 8.2 times the A2 fraction for the steam generator and 2.5 times the A2 fraction for the pressurizer.
49 CFR 107.105(c)(8): An exemption is requested for the following shipments; l) The Saxton steam generator approved as SCO II which is a non-specification package transported in accordance with a transponation plan 'and emergency response plan. A detailed description of the transponation system is provided in Attachment 2.
- 2) The Saxton pressurizer approved as SCO 11 which is a non-specification package transponed in accordance with a transponation plan and emergency response plan. A detailed description of the transponation system is provided in Attachment 2, l
49 CFR 107.105(c)(9): Documentation of quality assurance and design controls for the alternative package follows; The Saxton Nuclear Experimental Corpwation Facility is licensed under the provisions Title 10, Code of Federal Regulations. As such the Applicant follows the provisions of 10 CFR Pan 50 Appendix B Quality l Assurance Criteria for radioactive material shipments.
i All welding, rigging, hauling, and movement of the steam generator and l pressurizer will be performed in accordance with approved project procedures and plans. Engineering analyses and calculations that have been developed to demonstrate that the IP-2 packaging of the steam generator and pressurizer are equivalent to or better than the requirements ofIP-2 packaging under 49CFR 173.410 and 173.411. will be independently checked by qualified personnel. These activities will be carried out under the GPUN Appendix B Quality Assurance Program.
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SGPAttch. doc 10:10 AM 6/24/98 Page 6
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, i ATTACHMENT 1 EXEMPTION REQUEST FROM THE PACKAGING REQUIREMENTS OF 49 CFR FOR THE SHIPMENT OF THE SAXTON STEAM GENERATOR AND PRESSURIZER Shipment of radioactive materials, from the Applicant's location will be conducted under site procedures developed in accordance with the GPUN Quality Program. In addition Quality Assurance personnel will conduct independent overviews of the radioactive shipment process including examination of packaging, seals, marking, placarding.
manifests, vehicles, etc. 3 49 CFR 107 l05(d) .histification ofexemption proposal 49 CFR 107.105(d)(1). A description of relevant shipping and incident experience follows-The Salem Unit i Steam Generators were the first large components successfully shipped under the recently revised DOT /NRC transponation regulations. Steam generators have also been successfully transported by land and water in the past per NRC regulations (10 CFR 71). Ponland General Electric Co. transponed steam generators from the Trojan nuclear power plant to the Hanford Washington disposal site in 1994 without incident. Northeast Utilities transported steam generators from the Millstone site to Barnwell South Carolina in 1992 without incident.
The Ponland and Millstone steam generators are larger in size and weight than the Applicant's steam generator.
Transponation of new steam generators from current manufacturers to utilities that are replacing old steam generators is now a fairly common practice and has been conducted without inc; dent. The land transportation methods for these new steam generators is very similar to that which will be used to ship the Saxton steam generators and pressurizer offsite for disposal.
49 CFR 107.105(d)(2): The Applicant is not aware of any increase in risk to safety or propeny that would result from issuing the requested exemptions.
49 CFR 107.105(d)(3): Either- (Note: 49 CFR 107.105(d) allowsjustification by complying with section 105(d)(3)(i) or 105(d)(3)(ii). GPU Nuclear will use l
105(d)(3)(i) to demonstrate compliance.
49 CFR107.105(d)(3)(i): Substantiation that the proposed alternative provides an equivalent level of safety follows:
PACKAGING l
l SGPAttch. doc 10:10 AM 6/24/98 Page 7
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ATTACHhfENT 1
' EXEhfPTION REQUEST FROh! THE PACKAGING REQUIREMENTS OF 49 CFR FOR
. THE SHIPMENT OF THE SAXTON STEAM GENERATOR AND PRESSURIZER The requested exemption is in accordance with the guidance provided in NRC Generic Letter 96-07. The applicant has demonstrated that the Saxton steam generator and pressurizer provide safety equivalent to that of an IP-2 package within the constraints of the transponation' plan.
, SCO Il CONTAMINATION LEVELS
(
l Throuch the extensive radiological characterization effort, the applicant has provided reasonable assunince that the SCO Il contamination levels will be met. Therefore, there is no increased risk to the public health and safety if this proposed exemption is granted.
49 CFR 107105(d)(3)(ii): This section is not applicable to this exemption request.
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Attachment 2 l
l Saxton Nuclear Experimental Corporation l Facility Steam Generator & Pressurizer l Shipment Transportation System Description j
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PRESSURIZER
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ATTACID/IENT 2 STEAM GENERATOR & PRESSURIZER TRANSPORTATION SYSTEM The Saxton Steam Generator & Pressurizer shipment will be transported from the Saxton Nuclear Facility in accordance with the following transportation system:
STEAM GENEPATOR PACK AGING The Saxton Steam Generator will meet the packaging requirements as outlined in the NRC's Generic Letter 96-07. The Steam Generator will have al nozzles and openings closed with welded cover plates, or permanent hatch covers. Tb.: sealed Steam Generator will be filled with grout and the external surfaces will be epoxy coated. The Steam Generator Package will meet the equivalent safety as IP-2 packaging requirements. The Steam Generator package is shown in figure 1.
The Steam Generator Package will be analyzed to meet the general design requirements in 49 CFR 173.410, and specific requirements in 49 CFR 173.465 including design to sustain a one foot free drop in the horizontal position with all closures installed. The Steam Generator Package is 20 feet in length, and 4 feet in diameter, and will have a grouted weight of approximately 57,000 pounds not including the shipping skid. The external lifting devices will be removed or disabled before transport.
PRESSURIZER PACKAGING The Saxton Pressurizer will meet the packaging requirements as outlined in the NRC's Generic Letter 96-07. The Pressurizer will have all nozzles and openings welded closed using closure plates. The sealed Pressurizer will be filled with grout and the external surfaces will be epoxy coated. The pressurizer will meet the equivalent safety as IP-2 packaging requirements. The Pressurizer package is shown in figure 2.
The Pressurizer will be analyzed to meet the general design requirements in 49 CFR 173.410, and specific requirements in 49 CFR 173.465 including design to sustain a one foot free drop in the horizontal position with all closures installed. The Pressurizer is 17 feet in length and 3 feet in diameter and will have a grouted weight of approximately 28,000 pounds not including the shipping skid. The external lifting devices will be removed or disabled before transport.
SHIPPING CRADLE The Steam Generator and Pressurizer will be removed from the containment building at l the Saxton site and down ended on to their shipping cradles. The cradles will consist of l two saddles 10 inches in width, and will be connected by two wide flange beams. Two wire ropes on each saddle of one-inch diameter will attach the vessels to the shipping cradles. End blocking beams will be attached to the shipping skid to restrain the vessels. J The shipping cradles are a single use design and will not be used for other shipments. The 1
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ATTACHMENT 2 STEAM GENERATOR & PRESSURIZER TRANSPORTATION SYSTEM Steam Generator and Pressurizer shipping cradles are shown on figures 3, 4, 5, 6, 7, and 8.
TIE DOWN The Steam Generator and Pressurizer packages will be attached to the trailer transporter by means of turnbuckles, and anchor brackets that will be attached to the designated trailer transporter load points. The tie down system will be designed to meet the requirements of ANSI-N-14.2 (draft). The trailer tiedown system is shown on figures 1 and 2.
The railcar tie down system will consist of hold down clips that will be welded to the railcar deck, and that will attach the container and cradle to the railcar. End blocking clips will be welded to the railcar deck at each end of the cradle to restrain the container, and cradle assembly. The railcar tie down system will be designed to meet the requirements of AAR-Section 1 Open Top Rules. The rail car tie down system is shown on figures 3,4, 5, 6,7,and8.
The tie down system for the 1/2 mile transport from the off loading facility to the Barnwell disposal facility will be the same configuration that will be used for the tie down systems shown in figures 1 and 2. The design of this tie down system will be based on the 49 CFR 393.102(b) requirement of 1/2 times the weight of the components using the aggregate working load limit of the tiedown assemblies..
OVER THE ROAD TRANSPORT The Steam Generator and Pressurizer skid assemblies will be trarisported from the Saxton site to the Rail-siding at Huntingdon, PA. by a heavy-duty trailer with 8 axles. The Steam i Generator skid assembly will weigh approximately 70,000 pounds, and the Pressurizer skid assembly will weigh about 40,000 pounds. The over the road transporter is shown on figures 1 and 2.
The route from Saxton to the Huntingdon, PA Rail-siding is approximately 28 miles. The prime mover will be a three-axle heavy-duty tractor. An additional heavy-duty tractor will accompany the transporter as a back-up prime mover.
TRANSFER TO RAILC ARS The Rail-siding will be prepared to receive the railcars and transporters. The railcars will be cribbed to provide stability for load transfer. The transfer of the Steam Generator and l Pressurizer will be accomplished by one of the following methods.
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ATTACHMENT 2 .
l STEAM GENERATOR & PRESSURIZER TRANSPORTATION SYSTEM The first method will require that timber cribbing be placed between the transponer and the railcar. Rolling-plates will be placed on the railcar deck and timber cribbing. The skid and vessels will bejacked and rolled onto the railcar deck.
l The second method for transfer of the Steam Generator and Pressurizer packages to the railcars will reduce the transfer time and assist in keeping exposures ALARA In this method, the rail car will be positioned next to a suitable (~275 ton) mobile crane rnd the Steam Generator and Pressurizer transporter will be positioned on the opposite side from I
l the railcar. The crane will then pick the Steam Generator and Pressurizer packages from the transporter using slings and a lifting beam and place each package on its respective railcar. The lifts will be made so as to comply with drop analysis criteria.
RAIL TRANSPORT I i
The Steam Generator, and Pressurizer skid assemblies will be transported from the Huntingdon, PA Rail-siding to the Disposal Facility at Barnwell, SC by Conrail and CSX.
The proposed rail route will be from Huntingdon, PA to Hagerstown, MD; Washington, l DC.; Richmond, VA; Rockey Mount, NC; Florence, SC; Charleston, SC , Yemassee, SC.; Robbins, SC.; Dunbarton, SC. ( Barnwell, SC. )
The vessels will be transported on a heavy-duty flat railcar. The total railcar and package height for the Steam Generator on the rail car will be 12 feet 5 inches, and will have a total width of 9 feet 6 inches. The Pressurizer on the rail car will have a height of 11 feet 10 inches, and a width of 9 feet 6 inches. The rail car and Steam Generator and Pressurizer packages are shown on figures 3, 5, 6, and 8.
A dedicated train with escorts / riders will be provided for the transport of the vessel packages. Travel times and speed will be established by the governing railroad, and DOT regulations, and provided in the transportation plan. Scheduled stopovers, and shift l change locations will be identified in the transportation plan and supporting procedures.
RADIATION PROTECTION The radiation pro;ection program for the transpon of the vessel packages will meet the requirements of 49 CFR 174. The radiation protection program will be controlled and l implemented by the owner, and licensee of the shipment and will meet all Railroad and DOT regulations. Two radiation protection personnel will accompany the shipment from the Saxton Site along the over the road and rail transpon routes to the final destination at the Disposal Site in Barnwell, SC.
The radiation protection personnel will conduct all required surveys and inspections along the route, and provide direction on all radiological issues.
3 l
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ATTACHMENT 2 STEAM GENERATOR & PRESSURIZER TRANSPORTATION SYSTEM SECURITY The security program for the transport of the large component packages will be covered under the owner's security program. This includes the transport of the Steam Generator and Pressurizer packages from the Saxton project site to/and including the work at the Rail-siding.
Security will be provided by the responsible Railroad Company as needed along the rail route, and will be in accordance with the railroad security program Security at the Disposal Facility will be in accordance with the Disposal Site Procedures, and security coverage will be provided by the Disposal Site contractor.
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Attachment 3 Saxton Nuclear Experimental Corporation Facility Steam Generator & Pressurizer Shipment Transportation Plan l
The Transportation Plan (TP) for the SNEC facility Large Component Removal Project (SNEC LCRP) is stillin the development stage. An overview of the Plan is provided at this time with the full Plan to follow as soon as it is available.
.. The following parties will approve the SNEC LCRP TP:
. GPU Nuclear-the SNEC Facility co-licensee
. Raytheon Nuclear-the SNEC LCRP prime contractor
. F. W. Hake, Inc. - the SNEC LCRP heavy lift and road transport contractor
. Conrail and CSX - the rail shipment companies
. Chem-Nuclear Systems Inc. - the disposal contractor The table of contents and a brief discussion of each section follows.
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SAXTON LARGE COMPONENT REMOVAL PROJECT TRANSPORTATION PLAN Prepared By: Signature: Date:
Reviewed By: Signature: Date:
Approved By: Signature: Date:
GPUN Approval: Signature: Date:
Document No: Rev. Date:
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TABLE OF CONTENTS 1.0 SCOPE., ....... ... . . . . . .. . . . . ... . .. . .. . . ..
2.0 REFERENCES
3.0 ORGANIZATION & RESPONSIBILITIES ... .. . .. . . . . . . . . . . . . . . . .. . . . .
4.0 . SPECIALINSTRUCTIONS/ REQUIREMENTS. . . . . . . . . . . . . . . . . . . . . .
5.0 PACKAGE DESCRIPTION .. . . . . .. . . . .. .. . . . . .. ... . .
6.0 ROUTE DESCRIPTION.. .. . . . . . . . . . . . . . . . . . . . . . .... . . . . . . . . . .
7.0 PREPARATION FOR TRANSPORT. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
8.0 EQUIPMENT DESCRIPTION... ... .. . . . . . . . . . . . . . . . . . . . . ... . . . . . . . . . . . . . . .
9.0 IN-TRANSIT PROCEDURES.... .. . . . . .. . . . . . . . . . . . . . . . . . . . .. . . . . . . . . .
10.0 SAFETY .... . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. .
11.0 RADIATION PROTECTION .. . . . . . . . . . . . . . . . . . .. . . ... .. .. .. .
12.0 SHIPMENT HAZARDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..
13.0 MARKING / PLACARDING. ... .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . .
14.0 - TRAINING . . .. . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
15.0- ATTAC HMENTS .. .... ... .. ..... ....... . .. .. . . . . . . . . . . . . . . . . . . . . . . . . ..
Attachment 1 - Prerequisites Checklist ... . . .. . . . . . . . . . . . . . . . . ... .
- Attachment 2 - Pre-transport Checklist Road Transpod . . ... ... . . . . . . . . . . . . . . . .
Attachment 3 - Pre-transport Checklist Rail Transport....... . . . . . . . . .. . .. .
Attachment 4 - Procedure For Transfer To Rail Car... . . . . .. . . . .. .. .
Attachment 5- Route Maps l
l
4 The scope of each section is as follows:
1.0 SCOPE 4
The " SCOPE" section will dictate the applicability of the TP and bound its coverage. It will ensure coverage of all applicable phases of the SNEC LCRP including package preparation, loading and tiedown, transportation requirements, precautions and limitations, radiation protection requirements, safety, training, routing and provide checklists.
2.0 REFERENCES
Will provide a list of applicable references for the SNEC LCRP.
3.0 ORGANIZATION & RESPONSIBILITIES Will provide an organization chart and will dictate the lines of authority and responsibility for all major phases of the SNEC LCRP.
4.0 SPECIAL INSTRUCTIONS / REQUIREMENTS This section will spell out the particular operating and performance criteria for specialized equipment and practices for the SNEC LCRP. Examples include the operating restrictions on the heavy haul truck trailers, surveillance requirements on the package tiedowns, etc.
5.0 PACKAGE DESCRIPTION This section will contain a description of the pressurizer, steam generator and re actor vessel shipping container packages similar to that in the
" Transportation System" descriptions. This section will clearly delineate what it e packages consist of.
I l _ ___ _ - - . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
6.0 ROUTE DESCRIPTION This section will describe in detail the route, including highway and rail. It will not describe the route features but serve as a verbal " road map" 7.0 PREPARATION FOR TRANSPORT This section will describe the preparation of the three large components such as the applied coatings, the covering of openings, radiological surveys, removal of lifting attachments, etc. The orientation of the components and the tiedown requirements will also be covered.
8.0 EQUIPMENT DESCRITION This section will provide a detailed description of the tiedown, rigging, transfer and hauling equipment including highway and rail.
9.0 IN-TRANSIT PROCEDURES In this section, the procedures required for safe transport of the packages will be covered. This willinclude routine checks of the tiedown system, orientation of the packages to verify no shifting has occurred, radiation surveys, etc.
10.0 SAFETY Industrial safety precautions unique to this shipment will be covered. The radiological protection requirements are covered by the SNEC Radiation Protection Plan and the LCRP Health and Safety Plan. !
l 11.0 RADIATION PROTECTION l This section will specify the radiological surveys, exposure monitoring of f
the environment and personnel, radiological escort requirements and data i reporting.
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-12.0 SHIPMENT HAZARDS in this section, the specific " hazards" of the shipment will be described including direct radiation exposure, radiological releases in the event of a package breach, and those associated with any heavy load.
13.0 ' MARKING / PLACARDING The specific marking and placarding requirements of all applicable regulations will be listed for the packages and transport vehicles.
14.0 TRAINING Task or position specific training requirements will be specified. Examples include transport drivers, welders, radiological protection personnel, escorts, and quality assurance / verification personnel.
15.0 ATTACHMENTS Attachments will be provided such as route maps, pre-transport checklists, conveyance transfer procedure, etc.
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Attachment 4
- Saxton Nuclear Experimental Corporation Facility Steam Generator & Pressurizer l
Shipment Emergency Response Plan 1
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i Hea1a anc. Safety Plan for tne Transoort l of Saxton Nuclear Experimental-Corporation's Reactor Vessel, Steam i Generator & Pressurizer i l
l Prepared by: Date:
l Reviewed by: Date:
Prepared by: Date:
'. 4%
O Table ofContents 1.'
OBJECTIVE. INTRODUCTION AND BACKGROUND. .. .. . .I Description of Packages.. .. .. . .. 1 Route Deschption . . .
. .2 Work Tasks . . . . . . .7 Pre-Transit Preparation . . .. .
. . .7 Tie Down Inspection and Approval.. . . .. , .7 Shipment Prerequisites.. . . . . .7 Interchange of Load. .. . .. . .7 Scheduled Stops . . . . . .8 I
- 2. SHIPMENT HAZARDS. . . .. . . .. . . . . .9
- 3. STAFF. ORGANIZATION AND RESPONSIBILITIES.. . . . . .12
- 4. REGULATORY REQUIREMENTS.. .
.15
- 5. GENERAL HEALTH AND SAFETY WORK PRECAUTIONS . .. .16 Pre-Shipment Briefmg. . . .
.16 Health and Safety Briefing.. .16 Personal Protective Clothing. .. . . .16
. Respiratory Protection . . .
.17 External Radiation Protection . . .. . .17
- 6. TASK SPECIFIC HEALTH AND SAFETY PROCEDURES. . . . .18
- 7. EMERGENCY RESPONSE. . . . . .20 Responsibilities .
. .20 Radiation Survey / Wipe Test inconsistency . . .20 Unscheduled Stop in an Urban or Sensitise Area . . . .21 Transporter or Train Accident.. . . . . . . .21 Medical Emergency .. , .. . . . 21 !
' LIST OF TABLES .. . . . ii
! LIST OF FIGURES. , , ijj APPENDIX A (to follow once nackare dose rates are known).. . A-1 LIST OFTABLES ;
l Iable a Iitig Pace 5-1 Measured Dose Rates from the Packages 17 7-1 Route Segment. Rail Company and Emergency Response Contacts 22 ,
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LIST OF FIGURES Ficure Title Pace 1-1 Reactor Pressure Vessel and Shipping Cask 4 1-2 Pressurizer 5
l-3 Steam Generator 6
2-1 Dose Rates at Various Distances from the Reactor Package 10 2-2 Dose Rates at Various Distances from the Reactor Package 11 3-1 Transport Lines of Communication 14 l
l 5b
1 Objective, Introduction and Background The Saxton Nuclear Expe-imental Corporation (SNEC) Facility, located in Liberty Township.
near the Borough of Saxton. Pennsylvania. is currently being decommissioned. GPU Nuclear.
Inc.. (GPUN) a SNEC Facility co-licensee. is conducting the decommissioning on behalf of SNEC. Part of this process includes the packaging. transport. and disposal of radioactively
! contaminated items. equipment. soil. debris. etc. Central to the successful decommissioning of the SNEC Facility is the removal. preparation shipment and disposal of the three large components from the nuclear steam supply system. At the SNEC Facility. these components are the pressurizer. steam generator and reactor pressure vessel. This project is referred to as the SNEC Large Component Removal Project (SNEC LCRP). The large components will be packaged and shipped via truck and rail to the low-level radioactive waste disposal site in Barnwell. South Carolina. The shipment process is the focus of this health and safety plan (HASP).
This HASP provides information necessary to assure the safety ofemployees and the public during activities associated with transportation of the large component packages. The objective of this plan is to asrure that all personnel and the public are exposed to minimal radiological risk in accordance with the principle of maintaining radiation exposures As Low As Reasonably Achievable ( ALARA) and in conformance with Federal Regulations and guidelines. Wntten and appros ed procedures address activities dunng normal transport. as well as notifications and activities that need to occur during accident situations. The accident situations addressed in these procedures will represent credible accident scenarios.
Transport activities covered by this HASP include the shipment by truck from the SNEC Facility site to the rail siding in Huntingdon. PA. and transport by rail to the Chem-Nuclear Consolidation Facility near Barnwell. South Carolina. Contracts between GPUN. Raytheon. Inc. the LCRP prime contractor and the carriers Conrail (CR) and CSX Transportation (CSX) describe responsibilities of GPUN. Raytheon and the carriers for activities that must take place prior to and dunng movement of the large component packages. However. most details of these contracts are not appropriate for discussion in this HASP except where they relate to issues of health and safety. Therefore, contractual obligations that address health and safety issues has e been incorporated into this HASP.
All cognizant . railroad. truck transport and other personnel involved in the shipping operation will receis e a copy of this document. supplemented by training in its contents. All such personnel are required to return a signed copy of the HASP review signature sheet to the SNEC LCRP Project Manager before transport occurs. ,
Description ofPackages f
{
Figure 1-1 presents a diagram of the reactor pressure sessel in its shipping cannister. The reactor pressure vessel is a 5-inch thick cylinder with a 5 T outside diameter and is composed of multilay ered sheets of carbon steel. It has a bottom hemispherical head. and an upper section l Pagei Heahh A Safety Plan for The Rail Tramport Of sNECi Reactor ven,et. Piewurner. A steam benerator 4
b __-__________a I
consisting of a thickened flange ring. nozzle ring. and 2 lifting lugs. The reactor pressure s essel is filled with low density cellular concrete (grout) The grout also sen es to fix any radioactive contamination on the internal surfaces. to ensure that there is no free standing water in its interior.
and to stabilize internal components Grout was also placed in the annulus between the exterior of the reactor pressure vessel and the shipping cannister. Without grout. the un-packaged reactor pressure vessel weighs approximately 67 tons.
The reactor pressure vessel single-use shipping cannister is a two-inch thick steel cylinder with an integral flat circular bottom and flat cover. The maximum dimensions of the shipping package are 21.5 feet lorg by 9 feet 4 inches wide. The entire cannister, except for the top cos er and miscellaneous penetration covers. is a single. welded unit. The top cover and miscellaneous penetration covers were welded on after the reactor pressure s essel was placed inside. The package will be shipped as IP-2 Package under USDOT 49 CFR 173. The reactor vessel shipping cannister gross weight is approximately 213.000 pounds or 106.5 tons. The total weight of the reactor vessel shipping cannister and cradle is approximately 120 tons.
Figure 1-2 presents a diagram of the pressurizer. The pressurizer is an elongated cylinder measuring 3 feet in diameter by 17 feet long. It is composed of 3-inch thick carbon steel and u eighs approximately 12.5 tons. The nozzles on the pressurizer will be removed and the inside will be filled with grout. The penetrations will be welded. and the external surfaces will be painted to fix any external contamination that may be present. The pressurizer will sen e as its own package and will be shipped under USDOT 49 CFR 173. per NRC Generic Letter 96-07.
The final weight of the pressurizer with grout is 28.000 pounds.
Figure 1-3 presents a diagram of the steam generator. The steam generator is composed of a carbon steel shell approximately 3-inches thick and is 20 feet in length and 4 feet m diameter.
The empty steam generator weighs approximately 27 tons. and will be prepared for shipment in the same manner i.e.. grouting and welding of penetrations. The steam generator is approximately 57.000 pounds when grouted and will also serve as its own shipping package. The steam generator will also be shipped under USDOT 49 CFR 173. per Generic Letter 96-07.
Infonnation regarding the reactor pressure sessel shippmg cask and the contents u ere obtained from the Reactor Vessel Contamer Design Details Dwg No 7758l-021-E-lMol. Feb 26. I998 Route Description The movement of the packages on the roadway will be performed using a dedicated heavy hauler.
The heavy-duty transporter for the reactor pressure vessel will possess 16 axles and will has e a total length of 130 feet. The heavy-duty tractor-trailer for the pressurizer and steam generator ,
will has e 8 axles and has e a total length of approximately 60 feet. I The movement of the reactor vessel package will proceed at a speed ofless than or equal to 5 miles per hour, and will be escorted by public safety ofDcials. The transporters will proceed from l the SNEC Facility site along Pa. State Route 913 east through the Borough of Saxton. The transponders will ther, travel on Pa. State Route 26 north to Huntingdon. PA to Ridge Road where the rail sidmg is located. The total length of the road transport is approximately 28 miles. There i is only one long-span bridge along the route. there are no steep grades. and no sharp corners.
Theie will be one stop overnight along the route at a location yet to be determined.
Rail mos ement of the packages will be performed using a special dedicated train along a predetermined route. Maximum speed will be limited to that determined by each of the rail companies. The route will be as follows: from Huntingdon. PA to Hagerstown. MD; Page 2 Heahh & safety Pi n For The Rail Transpon Of SNEci Resetor vewct Prewunzer. k Steam Uenerator f
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Washington. DC: Richmond. VA: Rockey Mount. NC: Florence. SC: Charleston. SC: Yemassee.
SC. Robbins. SC; Dunbarton. SC (Barnu ell. SC).
The rail camers will be Conrail from the Huntingdon. PA to Hagerstown. MD. and CSX frorn Hagerstown. MD to Dunbarton. SC. The route the packages will follow needs to be known for emergency response purposes as discussed in Chapter 7.
Page 3 Heahh & Safety Plan For The Rail Transport Of SNEC's Reactor Yessel. Pressunier. & 5 team Uenerator l
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SNEC 4 P- JC l Pressurizer l Page 5 0l_Q SCALE
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I SNEC U
JC Steam Generator l
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Work Tasks Pre-transit Preparation An evaluation of the route between the SNEC Facility and the rail siding in Huntingdon. PA was conducted and included structures such as culverts and bridges, and also reviewed slope stability
. along the public roadway. Any repairs or upgrades on the road or roadway structures will be performed prior to package transpon. All evaluations pertaining to the roadway haul route will be reviewed by the appropriate regulatory agencies prior to transpon.
Tie Down inspection andApproval The tie down systems used for roadway transport of the packages conforms to ANSI N14.2 (draft). Tie down systems used for rail transport of the packages conforms to the requirements of AAR - Section 1 Open Top Rules. Tie down of the packages will be inspected by qualified GPUN personnel prior to transport.
Shipment Prerequisites Besides other contractual obligations prior to shipment. GPUN will ensure that copies of the following documents are delivered to the Corporate Attorney of the rail carriers prior to the commencement of the operation.
A copy of t he USDOT Exemption Approval for the LCRP.
A copy of the Bill of Lading and Shipping Manifest.
A copy of this " Health and Safety Plan"
. . A copy of the SNEC LCRP offsite transportation procedure.
A copy of all Necessary insurance cenificates.
Notifications will be made prior to shipment of the package. A notification package will be sent to the Governor's Office for each state the package will pass through. Additional notifications will be.made to the appropriate state emergency response agencies. Refer to the Public Information Plan for further details regarding notifications.
Stopover along RoadRoute Due to the length of the transport over road from the SNEC facility to the rail siding and the speed of travel, the reactor vessel package transponer will be required to stop for the night. It will stop at a location yet to be determined. When the location is known. a 24-hour watchman will be posted. and the area cordoned off with caution tape such that unauthorized individuals l cannot come within thiny feet of the transporters. A GPUN radiological control specialist will l also be posted at the location until the transport resumes.
- l. ' interchange ofLoads ' '
l l The packages will arrive at the Huatingdon rail siding on hydraulic platform trailers, At this
' location. the packages will be transferred to the rail cars in accordance with an appros ed
. procedure.
Page7 Heahh & sareiy Plan for The Rad Transport Or SNEC's Reactor Yeucl. Prmuruer. & steam Generator
l The GPUN radiological controls specialsts escorting the load will perform radiation ~
measureinents prior to. and after transfer of the packages from the trucks to the rail cars to ensure )
that dose levels are in compliance with 49 CFR 173.399. These dose limits are:
the dose rate at any accessible surface of the container is less than 200 miem/hr.
the dose rate at two meters from the accessible outer edges of the package is less than 10 mrem /hr and removable surface contamination is less than 1.000 dpm/100 sq cm. for beta / gamma emitters.
and less than 20 dpm/100 sq.cm. for alpha emitters (GPUN limit).
The SNEC LCRP Project Manager and Conrail Project Manager will meet to agree that:
loading occurred as specified in the procedure.
all required health and safety training and paperwork has been completed.
! notifications have been made.
the tie-down system has been inspected and approved. and the clearance dimensions have been inspected and approved. if required.
After both agree that these issues have been successfully completed. the shipment may proceed.
3 During the railjourney from Huntingdon. PA to Dunbarton. SC the train crew (s) shall have full j responsibility for operating the train in accordance with the established rail company procedures.
1 Communication consistent with safe operation of the train shall be maintained with the respective Dispatch Control. The radiological content of the packages will not impose any changes in the normal routine procedures for operating the train: however, the weight and size of the load may require the use of special procedures.
During the railjourney the load will be accompanied by tu o GPUN radiological controls specialists. In the event of any incident involving delay or damage to the train. or of failure'or suspect failure of the containment of the packages, then the directions of the GPUN radiological controls specialists shall be followed in all actions. In circumstances following an incident when the guidance of GPUN radiological controls specialist is not available. any uninjured rail employee at the scene should follow the emergency response procedure that applies to the es ent as described in Chapter 7.0. Ifpossible in emergency conditions, rail staff should shut down the train and evacuate the cab to an upwind location.
Scheduled Stops The first scheduled stop will be in Hagerstown. MD. At this point. the GPUN radiological controls specialist will conduct the radiological measurements specified in the procedure. Results of the survey will be recorded, and if they are consistent with the measurements conducted at the -
' start of the shipment. a completed survey form will be made available to the Conrail Project Manager, if measurements indicate a significantly greater exposure rate than observed at the start of the shipment. or the presence of radioactive contamination. then the procedure in Chapter 7 of this HASP must be followed.
( Other stops will occur along the way. Whenever stops are made. the GPUN radiological controls j~ specialist may perform radiation sun eys and wipe tests to confinn the radiological status of the
! load as deemed necessary. and the results of any suneys shall be documented. All such sun e3 activities shall conform to the requirements of the SNEC Facility Radiation protection Plan. {
l PageM Heahh a sareiy Plan for The Rail Trampon of SNECi Reactor venel Pressurizer. A Steam Generator i
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1 2
ShipmentHazards There are a variety of hazards involved with the shipment of the packages this health and safety plan. only radiological hazards are discussed. Durin conditions. the radiation levels in the vicinity of the packages are the primary ha along the road and rail route, and to rail company employees and the train pa the level of radiation is within regulatory limits. and will not pose a hazard to the h encountered. or rail company employees greater than other day- to-day hazards ty residents The dose rate from each package is designed to be less than 200 mrem per ho .
less than 10 mrem per hour at a distance of two meters from anyi side. Since th reduces as one moves further from the package. all personnel should maintain a rea distance. i.e.. at least 20 feet when not performing work related activities P closer than 20 feet in order to perform tasks should follow the As Low As Reas (ALARA) principle. The ALARA principle is used throughout the nuclear industry a organizations that use radioactive materials. and simply means that one should minim her exposure to radiation as much as practical. This can be accomplished by:
minimizing the time spent close to the packages.
maximizing the distance between the individual and the packages. and taking shielding.advantage of physical barriers between the individual and the packages tha All project and rail personnel involved with the actual shipment will receis e training issued appropriate dosimetry as required by the SNEC Facility Radiation Safety record any radiation dose received. Training. and issuance and collection of dosime performed by the GPUN radiological controls specialists aboard the train.
In the event oflengthy (>24 hrs) unscheduled stops. the GPUN radiological contro and rail employees must ensure that all unauthorized individuals maintain a distance of feet from the rail cars carning the packages. It may be necessary to obtain security railroad or local police department depending upon location and length of the delay.
Diagrams of the calculated dose rates at various distances from the reactor vess presented in Figures 2-1 and 2-2. The purpose of the diagrams is to enable the GPUN radiological controls specialists to make decisions regardmg potential doses to indiudua normal transport conditions. The steam generator and pressurizer package dose rates are lower than the reactor vessel package and are not presented in this plan.
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3 Staff, Orgartizatiori aridResportsibilities Figure 3 1 lists SNEC LCRP organizational structure for shipment of the packages. and the lines of authonty and responsibilities between GPUN and the rail companies. Health and safety support for the shipment of the packages will be coordinated and administered by GPUN. GPUN will provide administrative and technical suppon activities and services such as obtaining the proper permits and certificates making the necessary notifications of the shipment, performing health and safety briefmgs. conducting radiological measurements, providing emergency response resources, providing radiation dosimetry and providing GPUN radiological controls specialists to r: company the packages on theirjoumey to Dunbarton. SC.
Overall responsibility for health and safety activities ultimately lies with each individual.
However. it will be the responsibility of the SNEC LCRP and Rail Company Project Managers to ensure that all activities are conducted in accordance with this Health and Safety Plan. The GPUN radiological controls specialists accompanying the shipment will be responsible for implementation of this health and safety plan, and act as the GPUN representative solely responsible for all radiological activities. The Rail Company Project Managers will be responsible for ensuring that their respective personnel involved with the shipment are aware of the contents of this Health and Safety Plan. and that they follow its contents.
A copy of this HASP will be made available to all cognizant personnel involved in the shipment.
They will also be informed ofits contents before work is mitiated through a pre-shipment briefmg. The roles and responsibilities of key individuals include the following:
SNEC LCRP Project Manager / Representative ensure required paperwork is completed and given to the Rail Company ensure appropriate notifications of state and local government agencies were made oversee truck loading operations at the SNEC Facility oversee transfer operations in Huntingdon. PA conduct a pre-shipment briefing !
be available during the shipment to address emergencies or events attend the train in Dunbarton. South Carolina to oversee off-loading operations GPUN Radiological Control Specialists /RSO h proside health and safety briefings to train crews issue and collect TLDs from the train crew i
perform radiation sun eys/ wipe tests of shipment and sign sun ey forms accompany the shipment to fmal destination provide emergency response guidance to train crew and response teams Page 12 Heanh & safety Plan For The R:il Tran pon Of sNEC's Reactor v enel. Preuurder. A Steam Generator t - _ _ . _ - _ - _ _ _ _ - _ - ----------a
SNEC Emergency Response Team -
be available to respond to any emergency during transport Raytheon LCRP Team coordinates the LCRP subcontractors and executes the LCRP Plan Rail Company Chief Engineer
! review design calculations and drawings to ensure that the rail cars with the packages meet the requirements of the Rail Companies for safe transport.
Rail Company Project Representative-
. obsen e loading at Huntingdon. PA observe SNEC health physics specialist conducting radiation measurements
. obtain copies of all radiation measurements ensure rail company personnel wear dosimetry i . inspect placarding l .
test radio communication with dispatch control l ensure that the known conditions of the track and signal / control equipment between i destinations have no known faults that could compromise the safe completion of the joumey.
check on current and anticipated weather conditions with dispatch control to determine
! whether deferring or delaying departure is warranted.
ensure that rail company personnel understand their responsibilities in routine operation or in the event of an emergency.
l meet the train at tmnsfer points. and obtain copies of radiation measurements conducted while being pulled by their train and crew.
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Page 13 Heahh & Safety Plan ror The Rail Transport Of SNEc's Reactor Vencl. Preuurizer. & Steam Generator I
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4 REGULATORYREQUIREMENTS Chapter 5 and 6 of this Health and Safety Plan address the requirements of 10 CFR 20 with respect to protecting the health and saferv of the public and the workers involved in the shipment.
Chapter 7 addresses the appropriate notifications to the various states through which the shi will pass. and what steps personnel should take in the event of a transponation incident. All placarding and manifesting of the shipment will be performed accordmg to Depanment of Transportation regulations.
An information package has been prepared and was submitted to the Office of the Governor of states through which the package will pass. The shipment will pass through the following states:
. Maryland Virginia Nonh Carolina South Carolina in addition. NRC Regions I and 11 will be notified of the shipment. In the es ent of an incident.
the NRC. other Federal agencies. and appropriate State agencies would be notified. For funher information on the requirements to respond to a transponation accident involving radioactive materials. refer to Chapter 7. Emergency Response.
Page 15 Health & Safety Plan For The Rm! Tramt. ort Of sNECi Reactor venel Prev unzer. A steam Generator
5
^ GENERAL HEALTHAND SAFETY WORK PRECAUTIONS Under normal transport conditions. the only hazard presented by the packages are from external radiation as described in Chapter 2. General health and safety work precautions are suggested to ensure that workers involved in the road transport, and to rail employees' exposure to radiation is maintained As Low As Reasonably Achievable (ALARA). It is the Rail Company Project Representative's responsibility to ensure that all of their employees are aware of and follow the suggested work precautions. The work precautions are described below.
Pre-Shipment Briefing Prior to initiating the loading and transport of the packages to Huntingdon. PA. a pre-shipment briefmg will be held by the SNEC LCRP Project Manager to all in olved personnel. The briefing will include a description of the operation that will take place. and the communication and cooperation that will be necessary among all individuals invohed. At this time, the SNEC LCRP Project Manager will ensure that all individuals are aware of and understand their roles and responsibilities. and the radiological conditions associated with the shipment.
Health andSafety Briefings The GPUN radiological controls specialists will provide health and safety briefings to the tn ck transporter and train crew prior to each shipment. Appendix A will incorporate the outline of the briefing that will be provided. At each switch over point when the package is transferred from one rail carrier to another. the GPUN radiological controls specialists will provide the same briefing to the new rail carrier personnel.
Personal Protective Clothing No personal protectise clothing will be necessary for personnel invoh ed with this shipment. The purpose of protective clothing is to pres ent radioactive contamination from coming into contact with an indisidual's skin. The packages are designed such that no removable radioactis e contamination is present. In addition. the GPUN radiological controls specialists will periodically monitor the external surfaces of the package to ensure the absence of radioactis e contamination.
Page 16 Health & Safety Plan For The Rsil Transport Of SNEci Reactor venei. Pseuurizer. A Steam Generator i
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Respiratory Protection
^
Respiratory protection will not be necessary. Respiratory protection is used when there is a potential for individuals to inhale radioactive paniculates. Under normal transport conditions.
there is no potential to inhale radioactive paniculates.
ExternalRadiation Protection Under normal transpon conditions. the packages will emit measurable radiation les els. The highest measured dose rates from the sides of the packages are presented in Table 5-1.
Table 5-1: Measured Dose Rates from the RPV Package Measured Surface Dose Measured Dose Rate at 2 Rate Meters (mR/hr) (mR/hr)
Right Side of RPV Package
- Left Side of RPV Package
- a Top of RPV Package
- Bottom of RPV Package *
- Note: these dose rates will not be known until the reactor vessel package is prepared, this information will be completed following radiological surveys after package preparation.
Similar tables for the steam generator and pressurizer will be added.
The maximum allowable dose rate on contact with the surface of the package is 200 mrem /hr and 10 mrem /hr at two meters. Actual dose rates will be measured prior to initiating transponation and at switch oser points along the transponation route.
All personnel involved with loading and transponation will be issued appropriate dosimetry as directed by the SNEC Facility RSO. Dosimetry will be processed after the transponation event is i complete. and will give an account of the individual's radiation exposure. if any. Dosimetry results will be forwarded to the respective comfanies for disclosure to their employees.
When the stopos er along the road route occurs. a watchman will be posted. and the area cordoned
. off with caution tape such that unauthorized individuals cannot come within thirty feet of the transporters. A GPUN radiological controls specialist will also be posted at the location until the transport resumes.
i Page 17 Heahh k saret3 Plan For The Rail Transfert Of sN EC's Reactor vencl. Prepunzer, & Steam Generator f
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- 6 TASK SPECIFICHEALTH AND SAFETY PROCEDURES SNEC Facility procedures has been developed for the conduct of radiological activities which.
among other activities. includes the following:
Radiation Suney Equipment Use
. Wipe Testing Radiation Surveys These procedures apply to all radioactive material shipping activities and will be in place for the following: loading of the packages at SNEC facility onto the transporters; transferring of the packages to the rail cars at the rail siding in Huntingdon. PA: switch over between rail carriers; and unloading at Dunbarton SC.
After loading the packages onto the transporters at the SNEC Facility site. GPUN radiological controls specialists will conduct external radiation surveys in the transporter cabs and of the packages. perform wipe testing of the packages. and ensure the necessary radiological controls papenvork is completed. The will be made available to the transporter personnel and other interested parties The use of the survey equipment. radiation surveys. and wipe testing will be conducted in accordance with approved procedures.
The GPUN radiological control specialists will provide the transporter drivers and the Conrail Representative with a briefing and appropriate dosimetry for those individuals ins olved with inspecting and transporting the packages. The GPUN radiological controls specialists will also perform a health and safety briefing for the rail carrier individuals.
Upon reaching Hagerstown. MD the train crew will switch over to CSX. and the GPUN radiological controls specialists will collect the dosimetry. The GPUN radiological controls specialists will also conduct radiation surveys and wipe testing at this point to ensure that the integrity of the package has not changed during transport. A copy of the results of the sun ey and wipe testing will be made available to the Conrail representative for their records.
The CSX train crew will be provided appropriate dosimetry by the GPUN radiological controls specialists The GPUN radiological controls specialists will conduct the health and safety briefing. A copy of the survey and wipe test information will be provided to the CSX f representatis e to identify the status of the package at the time that they take responsibility.s .
(
Constant communication betw een the GPUN escorts / riders accompanying the packages in the passenger car and the engineers in the locomotive must be mamtained at all times sia portable radio or other means. In the esent of an emergency. the passengers must be capable of l communicating with the engineers to stop. and have access to local emergency response '
l Page 18 f Health & safety Plan For The Rail Transport Of sNEC's Reactor vessel. Preuurizer. & 5 team Generator i
providers, such as medical EMTs. In addition. the passengers on the train will have satellite phone to contact emergency responders and others as necessary.
As the train progresses along the route, the GPUN escorts / riders must maintain cogn their approximate location for emergency response contact purposes. In addition if th .
stop for any extended period of time, the SNEC LCRP Project Manager or representative
' identify their location. and make all passengers aware of their location in the contact must be made. The GPUN escorts / riders will utilize Global Positioning Systems or similar means to locate their position.
Upon completion of thejourney in Dunbarton. SC the GPUN radiological controls spe will:
~
perform a fmal radiation survey and wipe test of the packages.
collect the dosimetry issued to the CSX employees. and make the data available to disposal site personnel and to the CSX representative.
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Page 19 n Heart & Safety Plan For The Rail Transport Of SNEC's Reactor Venet Pressurizer, & Steam Genera
7 EMERGENCYRESPONSE The response to an incident will depend upon the nature of the incident. Notifica incident has occurred will depend upon the geographical location of the transp time the incident took place.
The types ofincidents that could occur include:
radiation surveys and/or wipe tests that significantly deviate from initial sun ey unscheduled stop in an urban or othenvise sensitive area. and transporter or train accident.
In any event. all actions shall be made with the following priorities:
Pubhc and Environmental Safety Personnel Safety Transport Protection follow during an incident. This section was developed u N14.27-1986. " Carrier and Shipper Responsibilities and Emergency Response Proc Highway Transportation Accidents?
Responsibilities During any event. the GPUN radiological controls specialists or their designee will act SNEC LCRP emergency coordinator and will be responsible for all assignmen actions until the local emergency response organization takes over authority for the SNEC LCRP emergency coordinator will be responsible for making the necessary n detailed in Table 7-1. and will work with the local emergency responders as appropri If the SNEC LCRP emergency coordinator is not capable of performing their duti incident. the next available GPUN escort / rider will make the necessary notification Table 7-1. and assist the local emergency responders. The GPUN/SNEC public comm representative will issue any public notices.
Radiation Survey /IVipe Test Inconsistency if the radiation sun ey or wipe testing identifies radiation levels that significantly excee measurements taken at the last transfer point. then the GPUN radiological controls specialists must:
("significantly"is defined as exceeding an appheable GPUN or l regulator 3 imit) 1.
Ensure the immediate health and safety of train crew by requiring all personnel to ma Page 20 Heath 4 sarety Plan For The Rail Transport OrSNEc"s Reador Vewel Prewurizer. A Stea L_____ . - - -
distance of at least 30 feet from the packages.
2 Contact the SNEC LCRP Project Manager for guidance.
3.
Contact Project the Manager. appropriate State and NRC emergency response center as dire Note:
cases. The SNEC V.P/ Director may act in place of the SNEC LCRP Project Manage Unscheduled Stop in an Urban or Sensitive Area If an unscheduled stop occurs in an urban or sensitive area, the responsibility of the radiological The specialist must:controls specialists is to ensure that the health and safety of the pub 1.
- 2. Decide whether surveys are necessary based on the length of the delay (great
- 3. Conduct radiation surveys and ensure the integrity of the package.
4.
Notify the SNEC LCRP Project Manager of the delay, Ensure that members of the public maintain a distance of at least 30 feet from the t stopped >24 hrs (Local law enforcement officials will be contacted to provide s around the train. See Table 7-1 for a listing of Law Enforcement Agencies that prosi radiological emergency response in the various states the train will be passing Note:
cases. The SNEC V.P/ Director may act in place of the SNEC LCRP Project Mana Transporter or Train Accident In the unlikely event of a transporter or train accident. the immediate action as the NRC. DOE and professional radiation protection associations is to:
1 Rescue victims.
- 2. Provide medical attention.
- 3. Extmguish fires.
4.
Notify the organization located in the area where the incident occurred. Table 7-the hst of orgamzations requiring notification of a transportation incident involving radioactive materials.
5.
Notify the SNLC LCRP Project Manage GPUN's emergency response resources.r. The SNEC LCRP Project Manager will activat Note:
cases. The SNEC V.P/ Director may act in place of the SNEC LCRP Project Manager i MedicalEmergency At least one member of the GPUN escon/ rider crew must be CPR/First A
, first-aid kit available. To facilitate communications with local emergency medical res the SNEC LCRP Project Manager must:
l 1.
- 2. Ensure that two-way communication with the locomotive engineers is maintained at all along thethe Know raillocation route. of the train and the nearest town. municipality. etc. as the train mos es 3; if *he train is stationary for any length of time (i e.. more than three hours) ensure that th police are aware of the train's location. Also, ensure that two-way communication with outside responders is in uorking order at all times. (Note: Cellular and satdlite phon be in a blacked-out location so they should be tested when the train is not in motion for the period of time indicated.)
Page 21 Health & saret> Plan For The Rad Tranywt of$NEci Feactor Venet. Preuvraer. & hicam Ge
e Note: The SNEC V.P./ Director may act in place of the SNEC LCRP Project Manager in all cases. -
Table 7-1: Route Segment, Rail Company, and Emergency Response Contacts Contact Order for Emergencies:
- 1. SNEC LCRP Project Manager - On Board the Train
- 2. SNEC V.P/ Director
- 3. State Emergency Contact - See Table Below
- 4. NRC Headquarters Operations Center - (301) 816-5100 EMERGENCY RAIL SEGMENT RAIL CONTRACTOR RESPONSE CONTACTS -
FIRST RESPONDERS Huntingdon.PA Pennsylvania to Conrail John Bahnweg Hagerstown. MD (717) 651-200124-hour Hagerstown. MD CSX Manland To Carl Trump Washington. DC (410) 631-3300 (8-5 PM)
To (410) 243-8700 after hours Richmond. VA To Virginia Rockey Mount. NC Leslie Foldesi To (804) 674-2400 24-hour Florence. SC To North Carolina Charleston. SC Johnny James
, To (919) 733-386124-hour Yemassee. SC To South Carolina Robbins. SC Sandra Threart To (803) 896-4095 Dunbarton. SC (803) 253-6488 after hours SCEPD Waming Point (803) 734-8020 j Georgia l l James Hardeman l (404)362-2675 (800) 241-4i13 after hours Page 22 Heahh & Safety Plan For The Rail Transport of SNEC'n Reactor Venet. Prewuruer. A hteam Generator
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