ML17229A388

Requests Exemption from Packaging Requirements of 49CFR173.427(B)(1) & Surface Contaminated Object Limits of 49CFR173.403 for Shipment of Two SGs from St Lucie Unit 1. W/Plan & Calculation

ML17229A388
Person / Time
Site:	Saint Lucie
Issue date:	06/19/1997
From:	Stall J FLORIDA POWER & LIGHT CO.
To:	TRANSPORTATION, DEPT. OF
Shared Package
ML17229A389	List: ML17229A388 ML17229A390 ML17309A895 ML17309A896
References
GL-96-07, GL-96-7, L-97-166, NUDOCS 9706270114
Download: ML17229A388 (15)

Text

CATEGORY 1

/~ 't (RIDS)

NEGULATO INFORMATION DISTRIBUTION TEM ACCESSION NBR:97062701l4 DOC.DATE: 97/06/19 NOTARIZED: NO DOCKET FACIL:50-335 St. Lucie Plant, Unit 1, Florida Power & Light Co. 05000335 AUTH. NAME AUTHOR AFFILIATION STALL,J.A. Florida Power & Light Co.

RECIP.NAME RECIPIENT AFFILIATION Transportation, Dept. of

SUBJECT:

Requests exemption from packaging requirements of 49CFR173.427(B)(l) & surface contaminated object limits of 49CFR173.403 for shipment of two SGs from St Lucie Unit l.

Plan & calculation encl also.

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June 19.1997 Associate Administrator for Hazardous thfaterials Satety L-97-166 Research and Special Programs Administration U.S. Department of Transportation 400 7 Street. SW Washington, D.C. 20590-0001 Attention: Exemptions, DHM-31

SUBJECT:

EXEMPTION REQUEST FROM THE PACKAGING REQUIREMENTS OF 49 CFR 173.427(B)(1) AND THE SURFACE CONTAiVIINATEDOBJECT LIMITS OF 49 CFR 173.403 FOR THE SHIPMEVhT OF TWO STEAM GENERATORS FROM ST. LUCIE UNIT I.

Florida Power & Light, (FP&L), requests an exemption from the subject regulations for the shipment of two Steam Generators from St. Lucie Unit 1 to the. Chem-Nuclear Systems (CNS)

Low-Level Radioactive Waste Management Facility in Barnwell, South Carolina. These will be one-time shipments, and will be performed in a controlled manner as described in the information provided as an attachment to this letter. The transportation of these steam generators is expected to begin on or after October 20, 1997, and be completed within one year.

Specifically, FPL requests an exemption from the packaging requirements for a surface contaminated object ("SCO") in 49 CFR 173.427, and from the SCO limits in 49 CFR 173.403, in order to facilitate the one-time, controlled shipment of two steam generators from St. Lucie Unit 1 to Chem-Nuclear, Systems Low-Level Radioactive Waste Management Facility in Barnwell, South Carolina. This exemption would allow the steam generators to be classified as SCOs and transported as unpackaged under a transportation plan that provides an equivalent level of safety to the packages and procedures specified in the Department of Transportation's regulations.

The existing SCO packaging requirements were not developed to accommodate very large, nuclear-grade components such as steam generators. Under these circumstances, the rugged, sealed, steel shell of the steam generators provides protection equivalent to the SCO packaging requirements. An exemption from the limits in the SCO definition is sought because, while analysis shows that these limits are met in the straight tube sections of the steam generators, it is possible they could be slightly exceeded in some other interior surfaces.

Representatives from FP&L and CNS met with members of the Department of Transportation (DOT) and Nuclear Regulatory Commission (NRC) staff on April 3, 1997 to discuss this project.

During this meeting DOT and NRC was presented with an overview of the upcoming steam generator transportation effort. DOT and NRC representatives referenced the NRC Generic Letter 96-07, which was jointly issued by DOT and NiRC to provide interim guidance to those 970am'Orred 970aX9 I 7 PDR ADOCK 05000335 P PD~R llIlillllllllllllllllllllllllllllllllll l

an FisL Graup COrnpany

desiring to transport steam generators. They also discussed their experience with the exemptions granted for transport of the steam generators owned by Public Service Electric 2 Gas in 1996.

Accompanying this letter are a series of attachments that provide all supporting information for this exemption request. Attachment 1 is the compliance matrix that addresses the requirements of 49 CFR 107 for an exemption request. Other attachments provide detailed engineering analyses, drawings, and operational plans and procedures supporting the steam generator transportation effort. Two bound copies and one unbound copy (for copying) is being sent for your use.

Ifyou have any questions concerning this request, please contact our project engineer, Mr.

Russell Gouldy (561) 467-7470, or Mr. Ron Gross our Engineering Manager at (561) 467-7682.

Sincerely, J. A. Stall Vice President, St. Lucie Plant VP-PSL-059 cc: John Bender, Chem-Nuclear Systems

~USNRC Document Desk, Dockett 50-335 Regional Adminstrator, USNRC, Region II NRC Resident Inspector, St. Lucie Plant Attachments:

1. Compliance Matrix.

2. CNS Plan PL-CNSI-97-004, "Transportation and Emergency Response Plan for St. Lucie Unit 1 Steam Generator Project, Project No. 46621."

3. Steam Generator Drawings

4. Transport Structural Analyses of St. Lucie Unit 1 Steam Generators.

5. St. Lucie Unit 1 Steam Generator Transportation General Arrangement Drawings.

6. Preliminary Waste Characterization of St. Lucie Unit 1 Steam Generators.

7. Evaluation of Residual Water in St. Lucie Unit 1 Steam Generators.

Overview The following attachments provide the basis for the exemption request to ship the St. Lucie Unit'1 Steam Generators from Hutchinson Island, Florida to the Chem-Nuclear Systems Low-Level Radioactive Waste Management Facility located at Barnwell, South Carolina. The steam generators will be transported in a controlled manner via barge to the Savannah River Site in South Carolina, then over road from the Savannah River Site to Barnwell, South Carolina. The A and B Steam Generators will be transported separately with the first steam generator leaving the St. Lucie site in late 1997 and the second steam generator leaving in early 1998. The transport process should take approximately one month for each steam generator.

Table of Contents ,Compliance Matrix Transportation Plan Steam Generator Drawings Transport Structural Analysis Summary Steam Generator Transportation General Arrangement Drawings Preliminary Waste Characterization Evaluation Residual Water

Attachment 1 Compliance Matrix

ATTACHIIEiNT1 - COi~IPLIANCE MATRIX EXEMPTION REQUEST FROM THE PACKAGIViGREQUIREMENTS OF 49 CFR 173.427(B)(1) AND THE SURFACE CONTAMINATEDOBJECT LIMITS OF 49 CFR 173.403 FOR THE SHIPMENT OF TWO STEAM GENERATORS FROM ST. LUCIE UNIT 1.

This document provides the basis of the exemption request for the transportation of the St. Lucie Unit Steam Generators. In the following text, the regulation concerning the exemption request 1

is cited, and the applicant's response is provided in indented italics following the respective regulation. Supporting information is provided in other documents also provided as an attachment to this exemption submit'tal.

TITLE 49 TRANSPORTATION CHAPTER I-RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION, DEPARTMENT OF TRANSPORTATION Subpart B Exemptions Source: Amdt. 107-38, 61 FR 21095, May 9, 1996, unless otherwise noted.

Sec. 107.101 Purpose and scope.

This subpart prescribes procedures for the issuance, modification and termination of exemptions from requirements of this subchapter, subchapter C of this chapter, or regulations issued under chapter 51 of 49 U.S.C.

Sec. 107.105, Application for exemption.

(a) General. Each application for an exemption or modification of an exemption must-(1) Be submitted in duplicate and, for timely consideration, at least 120 days before the requested effective date to: Associate Administrator for Hazardous Materials Safety, Research and Special Programs Administration, U.S. Department of Transportation, 400 7th Street, SW, Washington, DC 20590-0001. Attention: Exemptions, DHM-31; This applicationis being snbmilted on or befot e Jnne 20, l997, approrimately 120 days prior to the desiredissvtance date of October 20, 1997. Two copies are providedto the address as stated.

Attachment I - Compliance Matrix Page 'of8 (2) State the name, street and mailing addresses, and telephone number of the applicant; it the applicant is not an individual, state the name, street and mailing addresses, and telephone number of an individual designated as an agent of the applicant for all purposes related to the application; Applicant Floricfa Poiver dc Liglit Compaii>

St. Lucie (Init I 6501 S. Ocean Drive Jensen Beach, Florida 34957 Agent Mr. Bruce Somers Florida Poiver ck Light Company St. Lucie Unil I 650I S. Ocean Drive Jensen Beach, Florida 34957 (3) Ifthe applicant is not a resident of the United States, a designation of agent for service in accordance with Sec. l07.7 of this part; and The applicant a United States Corporation and the ageiit is a resident of the United Slates.

(4) For a manufacturing exemption, a statement of the name and street address of each facility where manufacturing under the exemption will occur.

Not applicable. A maniifacturing evemptionis nol requested.

(b) Confidential treatment. To request confidential treatment for information contained in the application, the applicant shall comply with Sec. 107.5(a).

Not applicable. No confidential trealment is requested.

(c) Description of exemption proposal. The application must include the following information that is relevant to the exemption proposal:

(1) A citation of the specific regulation from which the applicant seeks relief; Regulatory Reqiiirements:

4P CFR I 73. 403 Definitions For purposes of this subpart

Attachment I - Compliaiice Matrix Page 3 of 8

... Svrface Contaminated Object (SCO) means a solid obj ect which is not itself radioacli ve but which has Class 7 (radioacti ve) material distributed on any ofi ts surfaces.....

49 CFR I 73.427 - Transport requirements for low specific activity (LSA) Class 7 (radioacti ve) materials and srirface contaminated obj ects (SCO).

... (b) I:vs'.pt as provided in paragrnph (c) of this section, LSA material nird SCO must be packaged as follows:

(I) In nn incfustrial package (IP-I, IP-2 or IP-3; Sec. I 73.4I I), subject lo the linritalions of Table 8; ....

Fvenrption Request:

NRC Generic Letter 96-07, "Interim Guidnnce on Transportation ofSteam Gc>neralors, "pi'ovides NRC nnd DOT guidance. on th>> applicalion of existing radioacli ve mnterial trairsportnti oii requir c;nrents to the transportation of steam generators. This letter indicates ihnt these sl<<am'generators are best characteri ed within the scope of lhe i egrilalions as SCO, as they are solid, non-radioactive objc>cts with radr'oactiue material distributed on its srrrfaces. As such, SCO material is required to be transportedin packaging meeting DOT's iirdustrinl packaging definitionsin 49 CFR /73.4II.

The generic letter goes on to stale that it isimpractical to measure the contanrinntion level over all contaminated siufaces as required to demonstrate coeplinrrce with the SCO definition. Furthermore, the lelter slates that, the if shipper desires'to ship the steam gerrerators wi thorrt first packaging them, an exemption should be requested fiom the pnckaging reqvirements for SCO material.

As a resrill of this gr ridanc:e, we hereby request exemptions from lhe on requirements and fiom lhe packaging reqriiremenls for .S'CO SCO'emonslrnti material. Supporlinginformalioir is prcrvideclin the form of allachmeirls accompanying this request thai demonstrate equi valent safely lo that specified for the transportation of SCO material per existing regrilalions Srrmmary ofApplicants Request:

The applicant requests exemptions fiom the packaging requirements of 49 CFR I73.427(b)(l) and approval ofallernate IP-2 packaging for two sleam generators. The applicanl submits thai the rugged shell desi grr of these nuclear grade components, combined wi lh the welcled nird boiled closure plates, slniclural evahialionsin crccordnnce with Sec: I 73.46I, and transport operation controls arrd restriclions offer equivalent or better safity than that requiredfor IP-2 by sec. 173.4I0 and 4I I.

Attachment I - Compliance blair'age 4 of 't (2) Specification of the proposed mode or modes of transportation',

The steam generators>>ill be transported by two primary modes, barge and heavy-haul motor vehicle transportation. The steam generators ivill be transported via barge from St. Lucie Site to the Savannah River Site. The steam generators>>ill be transported via land from the Savannah River Site to the final destination Details of Ihe transportation are inclridedin the transportation plan in Attachment 2.

(3) A detailed description of the proposed exemption (e.g., alternative packaging, test, procedure or activity) including, as appropriate, written descriptions, drawings, flow charts, plans and other supporting documents; Alternntive Packaging of the SI. I.ucie Unit I Steuni Cienerators:

The steam generatois>>>ill be ti<<nsported a>> unpackaged radioactive material.

Drawings of the steam generatoi s are provided in A nachnrent 3. The steam generators are approriniately 749 inches long, 240 inches in maximum diameter, and iueigh approrimalely l,000,000 pounds. The steam generator shell is constnicted of carbon steel, and is at least 3 ll4 inche>s thick. The steam l

generators are designed for an operating pressure of more than 000 pounds per sqiiare inch.

The steam generators are prepared for traruportation by cutting the penetrations at the piinrary cooling ivater inlet and outlet no:.les, the secondaryfeedivater no::le, Ihe secondary steam crit no le, and several instrumentation lines. These penetrations are sealed with welded closiires that also provide shielding of the radioactive material inside. Inspection ports and mainvays are covered by bolted closures that are a part of Ihe original desigii. The steam generators as prepared or transport are stntcturally evaluated in Attachment 4. Sketches depicting the orientation of the steam generator <<nd supporting equipment are providedin Attachment 5.

The primary side surfaces ((he interior suiface>> of metal tuhesinside Ihe steam generator) of Ihe steam genei alai s ai e coated ivith i adi iracti ve materials deposited from reactor coolant ivatei diiihg; the course of normal operation The characterization of this radioactive content is providedin Attachmeiit 6. Itis assumed Ihat the radi oacti ve content of ivater potentially trappedin plugged titbesis negligible. The assessment of ii atei i e>maining in plugged tubes is providedi n Attacluirent 7. Fui Ihei niore, it is <<ssumed that the secondary side surfaces inside Ihe steam generator shell coritain negligible quantities of radioactive material.

Attachment I - Compliance h/aui'x Page 5 of 8 Based on the engineering evaluations performedfoi the alternatively packaged steam generators, the steam generators as described herein, along wi lh the transportation plans niid procedures pi oiide a level of snfety equivalent to thai of an industrial package.

(4) A specification of the proposed duration or schedule of events for which the exemption is sought; The cm I ent pi oj ect schedule includes an early start dnte for transportation actin>itiesof October 20, l997. Each steam generatoris to be transported separately, with the conclusion of the trnnsport of the second steam gerierator scheduled for early l998. Based on this schedule of events, and lhe uncertainties inherent in such a proj ecl, we request that lhe exemption be issued by October 20, J 997, and for a lerm of oiie year.

(5) A statement outlining the applicant's basis for seeking relief from compliance with the specified regulations and, ifthe exemption is requested for a fixed period, a description of how compliance will be achieved at the end of that period; This exemption request is submitted in <<ccoi dance ivilb the information provided in NRC Generic Letter 96-07, "Interim Guidance on Trnnsportation of Steam Generator@

" 7%is generic letter is ajoin( effort betiveen NRC and DOT. and provides a basis for this retluest. Since lhe u nnspoi'talion of each steam generalor iii II be a one-time-only event, it is <<oi necessary lo demonstrate conrplinnce al the end of the exemption peti od. 1 (6) Ifthe applicant seeks emergency processing specified in Sec. 107.117, a statement of supporting facts and reasons; Emergency pi ocessing of this exemption application is not reqirested.

(7) Identification and description of the hazardous materials planned for transportation under the exemption; The characleri:ali on of lhe radioactive ivnste material containedin the steam genernlors is providedin Attachr tent 6. This characteri:ation is preliminary becnuse lhe steam generators are stillin use. The document is based on information obtained during Ihe May l996 refiieling outage at St. Lucie Unit l.

Hoive>>er, thi> characteri."ation documenl pi ovides evidence that lhe final characleri=ation nf Ihe generatorsis nol likely Io differ sigi~ificantlyfrom the preliiiiinniyevnluntion.

Atiadrmerrt l - Compliance i 1atrix Page 6of8 A final ei>aluation of the radioactive materiels ivithin the steam generators willbe performed prior to transportation to comply ivith all DOTregulalory rc>quiremenls.

(8) Description of each packaging, including specification or exemption number, as applicable, to be used in conjunction with the requested exemption; As previously stated, Ibis erenipti oii request is for the transportation of two steam generators fionr St. I.rrcie Unit l. Each sieanr genera(or iiillbe prepared as descriheclin r'esporrse Io Vcr C;FR l73. /07(c)(3) above.

(9) For alternative packagings, documentation of quality assurance controls, package design, manufacture, performance test criteria, in-service performance and service-life limitations; FPL anclits conti'actors, Chem-Nuclear Sysienis, <<nd SGT Limited, willperform steam generalor Ir ansportation ac:li i>i lies in accordance ivilb Ihe requirements statedin their respecti ve 10 CFR 50 Appendix 8, QA Progranrs. A proj ect specific OA Progr cpm has been dei eloped hy C'.lrem-Nuclear System. This documenl identifies that the desigrr, fabrication, hardivare installation, traruportati on, inspecli on, and disposal willbe conducted to the reqrrirements of Ihe Chem-Nuclear Systems OA Mainral and respective implementing procedrrres.

SGTLimiled willbe performing lhe ii elding operalions andirrspections to seal lhe package. Special processes (ivelding and nondestnrc:ti ve examination) willbe acconrplished lo Ihe requirenrents of the SGT Limited OA Manual and respective implementing proc.'edures.

(d) Justification of exemption proposal. The application must demonstrate that an exemption achieves a level of safety at least equal to that required by regulation, or ifa required safety level does not exist, is consistent with the public interest. At a minimum, the application must provide the following:

(I) Information describing all relevant shipping and incident experience of which the applicant is aware that relates to the application; This erenrption isj ustifierl because existing SCO packaging requirements r vere not rleveloped to ncconrnrorlnte very large, nuclear-grarle components such as steam generators, Furtlrer, evaluation of tire St. Lucie steam generntors, inclurling loarl rlrop analysis, slroivs tlrat tire sealerl, steel shell ofthe steam generators ivillact as evtrenrely ruggerl, leak-tiglrt packages Chat meet or provirle protection erirri valent of tlie IP-2 pnckagi ng requirements of 10 CFR 173.410 anil 173.411 ivhen transporterl unrler tire controls provirlerlin Attnclrment 2, "Transportation and Lmergency Response Plan for St. Lucie Uiiit 1 Steam Genera(or Proj ecl, Pi oj ect No. 4662L

" FP&L 's contractor for this transportation projec;I, Chem-Nuclear Sysierrrs, has beeninvolvedin three pre>>i oirs steam generator'l <<nsportalion proj ects (Millslone, Yarrkee Rowe, and

Attachment I - C oIitpliance >'vfalrix Pai~e'f 8 Salem). Each of these proj ectsinvoli ed the transportation of multiple steam generators by barge, rail, and road transport modes. Chem-Nuclear Systems was involved in operational and engineering acti vi ties for each of the proj ects, and is intimately familiar with theissuesimportant to safety.

Of these shipping campaigtrs, the Salem proj ect divas completed most recently, and

~as the first to be performed under a DOT exemption similar to that being requestedin this applicatiott. The Salem steam generator transportation effort was completed iui thout incide>nt.

For all these reasons, the requested exemption is permissible pursuant to 49 U.S.C.

5117(a) because the steam generators provide a level of safety equivalent to the SCO packaging requirements.

(2) A statement identifying any increased risk to safety or property that may result ifthe exemption is granted, and a description of the measures to be taken to address that risk; and Noincreased tiskisidentified <<s a result of this request.. The structural shell of the steam generators tvas<<naly"ed for postulated normal transportation events such asa onefoot drop. The results of the analysis show that the stresses in the steam generator under 1-foot droop on a rigid unyielding surface [in accordance with Table 12 of 10 CFR 173.465] are within the allowable values, the cap and plug welds maintain their integrity, and the deformation at the point of impacts is such that none of the protrusions make a contact with the rigid surface. This application provides similar structural analyses for the St. Lucie Unit Steaml Generators.

(3) Either-(i) Substantiation, with applicable analyses, data or test results, that the proposed alternative will achieve a level of safety that is at least equal to that required by the regulation from which the exemption is sought; or Structut al analyses are providedin Attachment 4 that demonstrate the ability of the steam generators to be transported as alternative packaging. The transportation plan providedin Attachment 2 details the special steps <<nd operational controls that at e performed that serve to provide additional safety over a typical, uncontrolled shipment of radi oacti ve material.

Attachment I - Comp(iance lvfatrix Page 8 of 8 (ii) Ifthe regulations do not establish a level of safety, an analysis that identifies each hazard, potential failure mode and the probability of its occurrence, and how the risks associated with each hazard and failure mode are controlled for the duration of an activity or life-cycle of a packaging.

Not applicable. This application prnvicles a basis for equivalent safety of the allernati ve packagi t tg.

Attachment 2 Transportation Plan