ML20133H975

Forwards GL That Will Inform NRC Licensee That DOT & NRC Have Agreed on How DOT & NRC Transportation Regulations Apply to Shipment of Discarded SG from NPPs

ML20133H975
Person / Time
Issue date:	12/05/1996
From:	Rathbun D NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA)
To:	Faircloth L, Schaefer D HOUSE OF REP., SENATE, ENVIRONMENT & PUBLIC WORKS
References
CCS, NUDOCS 9701170353
Download: ML20133H975 (2)

Text

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i f S umTEo STATES j g P; NUCLEAR REGULATORY COMMISSION i

WASHINGTON, D.C. SeeH001 j

4,***** December 5, 1996 l

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! The Honorable Dan Schaefer, Chaiman i

Subcommittee Energy and Power Committee on Commerce United States House of Representatives i Washington, DC 20515 l

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Dear Mr. Chairman:

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! Pursuant to Subtitle E of the Small Business Regulatory Enforcement Fairness l Act of 1996, 5 U.S.C. 801, the U.S. Nuclear Regulatory Commission is submitting a generic letter (i.e., a final rule) that will inform NRC licensees that the U.S. Department of Transportation (DOT) and NRC have agreed l on how DDT and NRC transportation regulations apply to shipment of discarded steam geherators from nuclear power plants. Revisions to DOT and NRC i regulations generally became effective April 1, 1996, and have changed the j regulatory framework under which steam generators are shipped.

! Because of fouling or cracking of heat transfer surfaces, several nuclear l utilities have replaced, or plan to replace, their steam generators. The discarded steam generators are very large components that have radioactive contamination on their interior surfaces and consequently must be shipped for j disposal or processing pursuant to the hazardous material transportation i regulations. The guidance in the generic letter will help ensure that such j shipments are safe, consistent, and practical.

j We have determined that this rule is not a " major rule" as defined in 5 U.S.C.

4 804(2). We have confimed this determination with the Office of Management and Budget.

Enclosed is a copy of the generic letter that is being issued to applicable NRC nuclear power reactor licensees.

Sincerely.

L W

Denni:, K. Rathbun, Director Office of Congressional Affairs

Enclosure:

As Stated cc: Rep. Frank Pallone

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9701170353 961205 .

PDR I&E PDR MISC -

i p 1* UNITED STATES i g NUCLEAR REGULATORY COMMISSION

} WASHINGTON, D.C. MeeHopi

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• • • • • December 5, 1996 l

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l The Honorable Lauch Faircloth, Chairman

Subcomeittee on Clean Air, Wetlands, Private i Property and Nuclear Safety ,

i Committee on Environment and Public Works i

! United States Senate i Washington, DC 20510 l

Dear Mr. Chaiman:

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! Pursuant to Subtitle E of the Small Business Regulatory Enforcement Fairness

! Act of 1996, 5 U.S.C. 801, the U.S. Nuclear Regulatory Commission is i submitting a generic letter (i.e., a final rule) that will infom NRC licensees that the U.S. Department of Transportation (DOT) and NRC have agreed i on how DOT and NRC transportation regulations apply to shipment of discarded l steam generators from nuclear power plants. Revisions to DOT and NRC

{ regulations generally became effective April 1,1996, and have changed the l regulatory framework under which steam generators are shipped.

t i Because of fouling or cracking of heat transfer surfaces, several nuclear i utilities have replaced, or plan to replace, their steam generators. The j discarded steam generators are very large components that have radioactive 1 contamination on their interior surfaces and consequently must be shipped for j disposal or processing pursuant to the hazardous material transportation

regulations. The guidance in the generic letter will help ensure that such j shipments are safe, consistent, and practical.

i We have determined that this rule is not a " major rule" as defined in 5 U.S.C.

804(2). We have confirmed this detemination with the Office of Management l and Budget.

1 Enclosed is a copy of the generic letter that is being issued to applicable

) NRC nuclear power reactor licensees.

I j Sincerely, ,

I Dennis K. Rathbun, Director l Office of Congressional Affairs i

j

Enclosure:

l As Stated 4

) cc: Senator Bob Graham 4

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! UNITED STATES NUCLEAR REGULATORY COMMISSION i OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

, WASHINGTON, D.C. 20555 i

December 5,1996 i

NRC GENERIC LETTER 96-07: INTERIM GUIDANCE ON TRANSPORTATION OF l

. STEAM GENERATORS

. Addressees j All holders of operating licenses and decommissioning facilities with possession-only licenses for pressurized-water nuclear power reactors.

l k Purnose

! The U.S. Nuclear Regulatory Commission (NRC) is issuing this letter to notify i addressees that the U.S. Department of Transportation (DOT) and the NRC have l agreed on how DOT and NRC transportation requirements apply to the shipping of l discarded steam generators. The guidance below will help ensure that methods of shipping steam generators are both safe and practical. It is 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. i i Description of Circumstances  !

i  !

DOT and NRC transportation regulations for shipment of radioactive materials were i recently revised to be compatible with those of International Atomic Energy Agency j (IAGA) Safety Series No. 6,1985 edition. The revisions generally became effective l April 1,1996, and have changed the regulatory framework under which steam l 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.

4 Several power reactors, or reactors undergoing decommissioning, plan to ship j discirded steam generators shortly. The following information provides interim j guic.ance on the shipment of steam generators under the revised regulations. In j addition to this action, NRC and DOT are jointly studying large component j trarmportation issues. The shipment of steam generators and other large components

{ may be specifically addressed in future guidance and revisions of international and j domestic transportation regulations.

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l GL 96-07 J -

Dicamber 5,1996 Page 2 of 3 l

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Discussion j DOT and NRC have agreed that steam generators may generally be shipped under DOT procedures and requirements as outlined below

l (1) DOT has determined that steam generators are best categorized as surface

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contaminated objects (SCOs). Although the everspe 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 cm (46.5 in2 ). It is impractical to measure the contamination level on each 300 cm8 (46.5 in 8) of the steam

! generator internals; therefore, reasoned arguments and calculations should be i used. At a minimum, the following uncertainties should be accounted for in l 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 tuoes; and (c) the source term identification (e.g., scaling ratios, transurcnic contribution to A2 total). If significant uncertainty remains

! concerning the distribution of deposited activity on steam generator surfaces, l the licensee should obtain approval from DOT that the steam generator can be j properly classified for shipment as SCO.

1 i (2) The maximum radiation level at 3 meters (9.84 feet) from the unshielded I 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 j on the outside housing of an unshielded steam generator. Materials securely i fastened (e.g., welded) onto the steam generator, to seal penetrations, are l; considered part of the steam generator, for these purposes.

! (3) DOT has determined that the outside housing of a steam generator is j 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 j be the radioactive material contents, and there is no " package" as defined in l 49 CFR 173.403. Shippers wishing to ship an unpackaged steam generator as j 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 equivalant 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 j 173.427.

J (4) If shipped as an SCO, a steam generator is subject to the SCO conveyance activity limit of 100 A, given in 49 CFR 173.427, Table 9.

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i j , GL 96-07 ,

December 5,1996 j

! Page 3 of 3 (5) If the necessary DOT approvals are obtained, and if the requirements of 10 l

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.

. f Charles J. Hau nay, Actin irecto 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 l

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h Attachmsnt l

GL 96-07 4

December 5,1996 Page 1 of 1

{ LIST OF RECENTLY ISSUED GENERIC LETTERS l Generic Date of Letter Subiect lasuance lasued To i

j 96-06 ASSURANCE OF EQUIPMENT 11/13/96 ALL HOLDERS OF OLs OPERABILITY AND CONTAIN- FOR NPRs, EXCEPT FOR l MENT INTEGRITY DURING THOSE LICENSES THAT j DESIGN BASIS ACCIDENT HAVE BEEN AMENDED TO CONDITIONS POSSESSION-ONLY STATUS

96-05 PERIODIC VERIFICATION OF 09/18/96 ALL HOLDERS OF OLs l'

DESIGN BASIS CAPABILITY (EXCEPT THOSE LICENSES OF SAFETY-RELATED MOTOR- THAT HAVE BEEN AMENDED l OPERATED VALVES TO POSSESSION-ONLY

STATUS) OR cps FOR NPRs i 96-04 BORAFLEX DEGRADATION IN 06/26/96 ALL HOLDERS OF OLs SPENT FUEL POOL STORAGE FOR NPRs i RACKS i

1 95-09, MONITORING AND TRAINING OF 04/05/96 ALL U.S. NUCLEAR SUPP.1 SHIPPERS AND CARRIERS OF REGULATORY COMMISSION j RADIOACTIVE MATERIALS LICENSEES 96-03 RELOCATION OF THE PRES- 01/31/96 ALL HOLDERS OF OLs i SURE TEMPERATURE LIMIT OR cps FOR NPRs l CURVES AND LOW TEMPERA-1 TURE OVERPRESSURE PRO-i TECTION SYSTEM LIMITS i 96-02 RECONSIDERATION OF 01/31/96 ALL HOLDERS OF OLs i

NUCLEAR POWER PLANT OR cps FOR NPRs i SECURITY REQUIREMENTS

! ASSOCIATED WITH AN INTERNAL l THREAT i OL = OPERATING LICENSE i CP = CONSTRUCTION PERMIT i NPR = NUCLEAR POWER REACTORS

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CONGRESSIONAL CORRESPONDENCE SYSTEM DOCUMENT PREPARATION CHECEl.lST This check list is to be submitted with each document (or group of Qs/As) sentforprocessing into the CCS.

1. BRIEF DESCRIPTION OF DOCUMENT (S) - (YlIUhg

2. TYPE OF DOCUMENT X CORRESPONDENCE HEARINGS (Qs/As)

3. DOCUMENT CONTROL SENSITIVE (NRC ONLY) X NON-SENSITIVE

4. CONGkESSIONAL COMMITTEE AND SUBCOMMITTEE ({f applicable)

Congressional Committee Subcommittee

5. SURIECT CODES (A)

(B)

(C) l

6. SOURCE OFDOCUMENTS (A) 5520 (DOCUMENT NAME )

(B) SCAN (C) ATTACHMENTS (D) OTHER

7. SYSTEM log DATES l (A) llllPlll / DATA OCA SENTDOCUMENT TO CCS \

(B) DATE CCS RECEIVED DOCUMENT (C) DATE RETURNED TO OCA FOR ADDITIONAL INFORMATION (D) DATE RESUBMITTED BY OCA TO CCS (E) DATE ENTERED INTO CCS BY (F) DATE OCA NOTIFIED THATDOCUMENT IS IN CCS COuuENrS: 1700gy RELEASE TO PDR