NRC Generic Letter 1996-08
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, D.C. 20555 December 5, 1996 NRC GENERIC LETTER 96-07: INTERIM GUIDANCE ON TRANSPORTATION OF
Addressees
All holders of operating licenses and decommissioning facilities with possession-only licenses for pressurized-water nuclear power reactors.
PurDose The U.S. Nuclear Regulatory Commission (NRC) is issuing this letter to notify addressees that the U.S. Department of Transportation (DOT) and the NRC have agreed on how DOT and NRC transportation requirements apply to the shipping of discarded steam generators. The guidance below will he p ensure that methods of shipping steam generators are both safe and practical. Ii :s expected that recipients will review the information for applicability to their facilities and consider actions, as appropriate. However, suggestions contained in this generic letter are not NRC
requirements; therefore, no specific action nor written response is required.
DescriDtion of Circumstances DOT and NRC transportation regulations for shipment cf radioactive materials were recently revised to be compatible with those of International Atomic Energy Agency (IAEA) Safety Series No. 6, 1985 edition. The revisions generally became effective April 1, 1996, and have changed the regulatory framework under which steam generators are shipped.
Neither the previous nor the revised IAEA, DOT, nor NRC transportation regulations specifically address the shipment of large components, including steam generators.
Several power reactors, or reactors undergoing decommissioning, plan to ship discarded steam generators shortly. The following information provides interim guidance on the shipment of steam generators under the revised regulations. In addition to this action, NRC and DOT are jointly studying large component transportation issues. The shipment of steam generators and other large components may be specifically addressed in future guidance and revisions of international and domestic transportation regulations.
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GL 96-07 December 5, 1996 Discussion DOT and NRC have agreed that steam generators may generally be shipped under DOT procedures and requirements as outlined below:
(1) DOT has determined that steam generators are best categorized as surface contaminated objects (SCOs). Although the average surface contamination level over the internals of a steam generator may be shown (through calculation, reasoned argument, and/or measurement) to meet the limits for inaccessible surfaces in the applicable SCO definition, the requirement is that
2 the contamination be averaged over each 300 cm2 (46.5 in ). It is impractical to measure the contamination level on each 300 cm (46.5 in2) of the steam
2 generator internals; therefore, reasoned arguments and calculations should be used. At a minimum, the following uncertainties should be accounted for in the analyses: (a) dose to curie conversions; (b) material differences and uneven crud composition/deposition in the channel head bowl, divider plate, tube sheet, and tubes; and (c) the source term identification (e.g., scaling ratios, transuranic contribution to A2 total). If significant uncertainty remains concerning the distribution of deposited activity on steam generator surfaces, the licensee should obtain approval from DOT that the steam generator can be properly classified for shipment as SCO.
(2) The maximum radiation level at 3 meters (9.84 feet) from the unshielded contents [see 49 CFR 173.427(a)(1) and 10 CFR 71.10(b)(2)] is defined as the largest measured or calculated dose rate 3 meters (9.84 feet) from any point on the outside housing of an unshielded steam generator. Materials securely fastened (e.g., welded) onto the steam generator, to seal penetrations, are considered part of the steam generator, for these purposes.
(3) DOT has determined that the outside housing of a steam generator is considered as part of the "unshielded contents" (i.e., the dose rate is measured from the outside shell). Therefore, the entire steam generator is considered to be the radioactive material contents, and there is no "package" as defined in
49 CFR 173.403. Shippers wishing to ship an unpackaged steam generator as an SCO would, therefore, need to request that DOT grant them relief from the regulatory requirement to package SCO, given the special nature and practical considerations for steam generator shipments. The request should be made in accordance with 49 CFR Part 107, and should demonstrate that the unpackaged, sealed steam generator provides the safety equivalent to an Industrial Packaging (IP). If such relief (from the requirement that a steam generator be packaged) is not granted, then a steam generator shipped as an SCO must be shipped in an IP or Type A package, pursuant to 49 CFR
173.427.
(4) If shipped as an SCO, a steam generator is subject to the SCO conveyance activity limit of 100 A2 given in 49 CFR 173.427, Table 9.
GL 96-07 December 5, 1996 (5) If the necessary DOT approvals are obtained, and if the requirements of 10
CFR 71.10 are otherwise met, no exemptions from NRC requirements are needed for the provisions of 10 CFR 71.10 to take effect.
NRC licensee shipments of steam generators are subject to NRC inspection for compliance with the DOT regulations, pursuant to 10 CFR 71.5. It is particularly important that each licensee maintain complete documentation of any tests or evaluations required by DOT, for complying with the conditions specified in item (3),
above, for shipping steam generators as unpackaged SCO. These may include engineering evaluations of the unpackaged steam generator's ability to meet the IP or Type A package design standards and criteria, if required by DOT as a compensatory measure for permitting the unpackaged shipment. The requirements for documenting the design of IP and Type A packaging are given in 49 CFR 173.411 (c) and 49 CFR
173.415, respectively.
This generic letter requires no specific action nor written response. If you have questions about this matter, please contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor Regulation project manager.
Charles J. Hau ey, ActinJirecJ
Spent Fuel Project Offic -
Office of Nuclear Material Safety and Safeguards Technical contacts: Richard Boyle, DOT
(202) 366-4545 E-mail: rick.boyle@rspa.dot.gov Earl P. Easton, NMSS
(301) 415-8520
E-mail: exe@nrc.gov Attachment: List of Recently Issued NRC Generic Letters F~~/4 /
Attachment GL 96-07 December 5, 1996 LIST OF RECENTLY ISSUED GENERIC LETTERS
Generic Date of I attmr A, .hkt-t lcctinnnra lcceiri Tn
96-06 ASSURANCE OF EQUIPMENT 11/13/96 ALL HOLDERS OF OLs OPERABILITY AND CONTAIN- FOR NPRs, EXCEPT FOR
MENT INTEGRITY DURING THOSE LICENSES THAT
DESIGN-BASIS ACCIDENT HAVE BEEN AMENDED TO
CONDITIONS POSSESSION-ONLY STATUS
96-05 PERIODIC VERIFICATION OF 09/18/96 ALL HOLDERS OF OLs DESIGN-BASIS CAPABILITY (EXCEPT THOSE LICENSES
OF SAFETY-RELATED MOTOR- THAT HAVE BEEN AMENDED
OPERATED VALVES TO POSSESSION-ONLY
96-04 BORAFLEX DEGRADATION IN 06/26/96 ALL HOLDERS OF OLs SPENT FUEL POOL STORAGE FOR NPRs RACKS
95-09, MONITORING AND TRAINING OF 04/05/96 ALL U.S. NUCLEAR
SUPP. 1 SHIPPERS AND CARRIERS OF REGULATORY COMMISSION
RADIOACTIVE MATERIALS LICENSEES
96-03 RELOCATION OF THE PRES- 01/31/96 ALL HOLDERS OF OLs SURE TEMPERATURE LIMIT OR CPs FOR NPRs CURVES AND LOW TEMPERA-
TURE OVERPRESSURE PRO-
TECTION SYSTEM LIMITS
96-02 RECONSIDERATION OF 01/31/96 ALL HOLDERS OF OLs NUCLEAR POWER PLANT OR CPs FOR NPRs SECURITY REQUIREMENTS
ASSOCIATED WITH AN INTERNAL
THREAT
OL = OPERATING LICENSE
CP = CONSTRUCTION PERMIT
NPR = NUCLEAR POWER REACTORS
- GL 96-07 December 5, 1996 (5) If the necessary DOT approvals are obtained, and if the requirements of 10
CFR 71.10 are otherwise met, no exemptions from NRC requirements are needed for the provisions of 10 CFR 71.10 to take effect.
NRC licensee shipments of steam generators are subject to NRC inspection for compliance with the DOT regulations, pursuant to 10 CFR 71.5. It is particularly important that each licensee maintain complete documentation of any tests or evaluations required by DOT, for complying with the conditions specified in item (3),
above, for shipping steam generators as unpackaged SCO. These may include engineering evaluations of the unpackaged steam generator's ability to meet the IP or Type A package design standards and criteria, if required by DOT as a compensatory measure for permitting the unpackaged shipment. The requirements for documenting the design of IP and Type A packaging are given in 49 CFR 173.411 (c) and 49 CFR
173.41 5, respectively.
This generic letter requires no specific action nor written response. If you have questions about this matter, please contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor Regulation project manager.
Original 1sf by Charles J. Haughney, Acting Director Spent Fuel Project Office.
Office of Nuclear Material Safety and Safeguards Technical contacts: Richard Boyle, DOT
(202) 366-4545 E-mail: rick.boyle(rspa.dot.gov Earl P. Easton, NMSS
(301) 415-8520
E-mail: exe@nrc.gov Attachment: List of Recently Issued NRC Generic Letters 96-07.GL *See Previous Concurrence.
OFC [ SFPO* E SFPO* I C SFPO* C NRR/DRPM* lC OGC* C TEDITOR I N
NAME RLewis:LMG EEaston SShankman TMartin ENJenson EKraus *
DATE 10/9/96 10/10/96 10/10/96 10/18/96 10/22/96 10/22/96 OF
NAME
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lDAT E 10/24/96 10/24/96 ..
11/15/96 , I' NV
C = COVER E = COVER & ENULOUbUK N = Nu COPtY
GL 96-07 November 13, 1996 (5) If the necessary DOT approvals are obtained, and if the require ents of 10 CFR
71.10 are otherwise met, no exemptions from NRC requiremen are needed for the provisions of 10 CFR 71.10 to take effect.
NRC licensee shipments of steam generators are subject to NRC in pection for compliance with the DOT regulations, pursuant to 10 CFR 71.5. It is particulaly important that each licensee maintain complete documentation of any tests or evalua ions required by DOT, for complying with the conditions specified in item (3), above, for s ipping steam generators as unpackaged SCO. These may include engineering evaluatio s of the unpackaged steam generator's ability to meet the IP or Type A package design st ndards and criteria, if required by DOT as a compensatory measure for permitting the unpackaged shipment. The requirements for documenting the design of IP and Type A p ckaging are given in
49 CFR 173.411 (c) and 49 CFR 173.415, respectively.
This generic letter requires no specific action nor written esponse. If you have questions about this matter, please contact one of the technical c tacts listed below or the appropriate Office of Nuclear Reactor Regulation projec manager.
Charles J. aughney, Acting Director Spent Fue Project Office Office of uclear Material Safety and Sa eguards Technical contacts: Richard Boyle, DOT
(202) 366-4545 E-mail: rick.boyle~rspa. ot.gov Earl P. Easton, NMSS
(301) 415-8520
E-mail: exe@nrc.go Enclosure: List of Recently Issued NR Generic Letters S:IPROJIRXL\SGGENLTR.JRC
- See Previous Concurrence.
OFC SFPO* EI SFPO* I C S/PO* I C NRR/DRPM* I Cl C TEDITOR I N
NAME RLewis:LMG EEaston Shank an TMartin ENJenson EKraus *
DATE 10/9/96 110/10/96 /10/96 10/18/96 10/22/96 10/22/96 OFC 1DWM* IMOB l- S IiiiiP IlI
NAME RJohnson KRamsey CJ g y l DATE
CE C
10/24/96
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GL 96-07 November 13, 1996 (5) If the necessary DOT approvals are obtained, and if the requirements of 10 CFR
71.10 are otherwise met, no exemptions from NRC requirements are needed for the provisions of 10 CFR 71.10 to take effect.
NRC licensee shipments of steam generators are subject to NRC inspection for compliance with the DOT regulations, pursuant to 10 CFR 71.5. It is articularly important that each licensee maintain complete documentation of any tests o evaluations required by DOT, for complying with the conditions specified in item (3), abo e, for shipping steam generators as unpackaged SCO. These may include engineering aluations of the unpackaged steam generator's ability to meet the IP or Type A package esign standards and criteria, if required by DOT as a compensatory measure for pe itting the unpackaged shipment.
The requirements for documenting the design of I and Type A packaging are given in
49 CFR 173.411 (c) and 49 CFR 173.415, respe ively.
This generic letter requires no specific action r written response. If you have questions about this matter, please contact one of the chnical contacts listed below or the appropriate Office of Nuclear Reactor Regul ion project manager.
harles J. Haughney, Acting Director pent Fuel Project Office Office of Nuclear Material Safety and Safeguards Technical contacts: Richard Boyle, D T
(202) 366-454 E-mail: rick.bo le@rspa.dot.gov Earl P. Easto NMSS
,
(301) 415-8 20
E-mail: exe nrc.gov Attachment: List of Recently I ued NRC Generic Letters S:IPROJIRXLISGGENLTR.JRC *See Previous Concurrence. 1 OFC SFPO E SFPO iSFPO* IC ; DRPM OGC* I C TEDITOR IN
NAME RLewis:LMG EEaston/ SShankman TMartin ENJenson EKraus DATE 1 10/9196 10/1019h L1/10/96 10/18/96 10/22/96 10/22/96 OFC DWM *OB SFPlXl NAME RJohnson KRams y CJ Ke DATE P96 toA9o IC) 0.96 _~9
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GL 96-##
October ##, 1996 specified in item (3), above, for shipping steam generators as unpackaged SCO.
These may include engineering evaluations of the unpackaged steam generator's ability to meet the IP or Type A package design standards and criteria, if required by DOT as a compensatory measure for permitting the unpackaged shipment. The requirements for documenting the design of IP and Type A
packaging are given in 49 CFR 173.411(c) and 49 CFR 173.415, respectively.
This generic letter requires no specific action nor written response. If you have questions about this matter, please contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor Regulation project manager.
William D. Travers, Director Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Technical contacts: Richard Boyle, DOT Earl P. Easton, NRC/NMSS
(202) 366-4545 (301) 415-8520
e-mail: rick.boyle@rspa.dot.gov exe@nrc.gov Attachment:
List of Recently Issued NRC Generic Letters S:\PROJRXLXSGGENLTR.JRC *See Previous Concurrence.
OC SFPO* LE SFPO* I C SFPO* l- C NRR/DRPM- C OGC* I C TEDITORl NAME RLewis:LMG EEaston SShankman TMartin ENJenson EKraus*
DATE 10/9/96 10/10/96 10/10/96 10/18/96 10/22/96 10/22/96 =
OFC DWM IMOB SFPO SFP
NAME RJohnson KRarnser CJHhQti4 WD1Welrs /
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1 DATE &96 l __ _j_ 96/ 1__ 6 __ _96
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10-22-1996 12: 24PM FP-' FETZER-KRAUS. INC. 202 537 r 33 P. 3 FROM NRCzSFPO OZ.61.2980 0. 46 GL 96-fl October tt, 1996 lpments of steam generators Utt'so: are subject to NRC inspection for compliance with the DOT regulations, pursuant to 10 CFR Part 71.5. Itis particularly laportant that each licensoe Maintain complete documentation of any tests or evaluations required by DOT, for complying with the conditions specified In item (3), above, for shipping steam generators as unpackaged SCO.
These may include engineering evaluations of the unpackaged steam generator's ability to meet the IP or Type A package design standards and criteria, if required by DOT as a compensatory measure for permitting the unpackaged shipment. The requirements for documenting the design of IP and Type A
packaging are given In49 CFR 173.411(c) and 49 CFR 173,415, respectively.
This generic letter requires no specific actlon r written response. If you have questions about this matter, please contact one of the technical contacts listed below or the appropriate Office of Nuclear Reactor Regulation .fiRt- project manager.
William D. Travers, Director Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Technical contacts: Richard Boyle, DOT Earl P. Easton, NRC/NMSS
(202) 366-4545 (301) 411-85tO
0-mail; rick.boylegrspa.dot.gov exetnre.gov Pr 7r Attachment-
)J4u. L st of Recently Issued NRC Generic Letters SA~PROJUfIXLOGOENLTR4RO *'oo Previous Concurence, OFC E FO C E 11 NRIMA OCTEIT
NAME R~ewis:LMG EH eston $Shankmnun 1TMerJl DATE 1019198 101IDbI9B 10/10196laJ 1 I/96 ' 10 *A 6 s OFC M86F0S1 __
NAME P.Johnson l(Rarnsey V4Houghnev WDT'revera _ _ _ _ __ _ _ _ _
DATE I /Be1 16 /96lo
0
c)
GL 96-##
October ##, 1996 P ge 3 of 3 Shipments of steam generators by NRC licensees are subject'to NRC inspection for compliance with the DOT regulations, pursuant to 10/tFR Part 71.5. It is particularly important that each licensee maintain complete documentation of any tests or evaluations required by DOT, for complying with the conditions specified in item (3), above, for shipping steam generators as unpackaged SCO.
These may include engineering evaluations of the 'unpackaged steam generator's ability to meet the IP or Type A package design standards and criteria, if required by DOT as a compensatory measure for permitting the unpackaged shipment. The requirements for documenting the design of IP and Type A
packaging are given in 49 CFR 173.411(c)/and 49 CFR 173.415, respectively.
This generic letter requires no specific action or written response. If you have questions about this matter, please contact one of the technical contacts listed below or the appropriate OfFice of Nuclear Reactor Regulation (NRR)
project manager. //
William D. Travers, Director Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Technical Richard Boyle, DOT Earl P. Easton, NRC/NMSS
(202) 366-4545 (301) 415-8520
rick.boyle@rspa.dot.gov exe@nrc.gov Att
1. Issued NRC Generic Letters Q.%PRn-1%RYXI r1FNLTR-JRC See Previous Concurrence.
OFC SFPO* I E SFPO* lC SFO ICNRR/DROCGC~ NRDRP l DICEG
FO i TEDITORl S,
NAME RLewis:LMG EEaston SShankman (, ar en EKraus DATE 10/9/96 10/10/96 10/10/96 1s / Ig/96 /1P296 I /96 OFC DWM lIMOB l SFPO l _SFPO l NAME RJohnson3,~L KRamsey CJHaughney WDTravers DATE o' /z5 /96 I /96 I /96 I /96 l V il _0
LPJi F-UnUI 1E h l
C = COVER L = tCUVt:K & tFULPLU:OURE I'm = Rev1 %0vr I
This generic letter requires no specific action or written re onse. If you have questions about this matter, please contact one of the echnical contacts listed below or the appropriate Office of Nuclear Reactor egulation (NRR)
project manager.
am D. Travers, Director Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards Technical contacts: Richar Boyle, DOT Earl P. Easton, NRC/NMSS
(20 366-4545 (301) 415-8520
Attachment:
1. List of Recentl Issued NRC Generic Letters S:IPROJXRXLISGGENLTR.JRC *See Previous Concurrence.
OFC lSF P9 lE SFOSP R/RMOGC l TEDITORll NAME RLev LNG EEastozpe aSn TMartin ENJenson EKraus DATE 1j/9 /196 (o/to/96 1o/10/96 / /96 / /96 j /96 OFC DWM l IMOB I SFPO SFPOll NAME RJohnson KRamsey CJHaughney WDTravers DATE / /96 I /96 I /96 / /96 C = COVER E = COVER & ENCLOSURE N = NO COPY
3