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Stephen. L. TurnerScience Applications International Corporation
Presented to: IAEA Technical Meeting on Methods and Experiences of Heavy
Component Replacements in Nuclear Power PlantsLynchburg, Virginia
May 27, 2009
Heavy Component Shipments: US Regulations and Experience
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Topics
• Key US Regulations
• History of US Regulations
• US Large Component Special Permits (SP)
• Concept for International Rule and US SP Analysis
• US Proposal for international rule
• US Waste Imports
• Observations
Key US Regulations
• Packaging And Transportation Of Radioactive Material,10 CFR 71, Nuclear Regulatory Commission: The governing regulation of the DOE covering transport of radioactive shipments.
• Hazardous Materials Regulations, Subpart I—Class 7 (Radioactive) Materials, 49 CFR 173, All Sections, US Department of Transportation: The key technical guidance for the transport of radioactive materials including large components. Exceptions for large components are because some part of 49 CFR 173 cannot be met.
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Key US Regulations (cont’d)
• Hazardous Materials Regulations, Part 171—General Information, Regulations, And Definitions, 49 CFR Parts 171.1; US Department of Transportation: The governing regulations of the DOT with many subparts that include general requirements for all hazardous material transportation.
• Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, Emergency Response Information, and Training Requirements, 49 CFR Part 172.101, US Department of Transportation: The table of shipment IDs adopted from international identifiers for shipments. Most large component shipments are UN2912.
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Key US Regulations (cont’d)
• Hazardous Materials Regulations, Part 107, Subpart B, Paragraph 107.105-Application for Exemptions, 49 CFR Part 171 § 107; US Department of Transportation: Establishes the criteria for exemptions and exceptions.
• Regulations for the Safe Transport of Radioactive Material, 2005 Edition – Safety Requirements, TS-R-1, International Atomic Energy Agency: IAEA regulations adopted by the US for international but also served as the basis for the LSA and SCO practices in the DOT and NRC regulations. There is also a guidance document TS-G-1.1.
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Who regulates?
• The NRC has coordinated its part 71 revisions with DOT, because DOT is the U.S. Competent Authority for transportation of hazardous materials. ‘‘Radioactive Materials’’ is a subset of ‘‘Hazardous Materials’’ in 49 CFR under DOT authority. Currently, DOT and NRC co-regulate transport of nuclear material in the United States.
• More NRC involvement with difficult items like reactor Pressure Vessels. Reactor Pressure Vessels are handled as “Special Arrangements” with NRC approval
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History of Regulations
1961: Initial regs.I
A
E
A
D
O
T
N
R
C
Series 6 Revised 1996, Revised 2000 and renamedTS-R-1
Pre 1995 1995-2008 Future
NRC 96-7 for SG shipment
DOT 2001 Rule
TS-R-1
NRC 2002 RuleTS-R-1
NRC 1995 Rule IAEA
NRC 2004a Rule Special Arrangement
2007: USA/07/11 proposal to IAEA1967: HMR;
49 CFR Parts 171– 180
DOT 2004 Rule49 CFR Mod 2009 to include
large component?
12 14244422 111
0898 0706058
0403020199 009796Yr
#
Number of SP Issued
DOT 1995 Rule
SCO, LSA, IAEA
NUREG-1608Guidance for
characterization
1967: IAEA Series 6
Revised Series 6: 1973, 1985
TRANSSC studies USA/07/11
2000 Issues paper
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Large Component Transport Experience
• Data from Special Permits for exclusive shipments of large components– Not all information is same quality:
• Some information is proprietary (structural analysis)
• Information is inconsistent: DOT does not have a strong content and format guide
– DOT provides examples and tells shipper to follow the example
• Steam Generators (SG) 38 Reactor Pressure Vessels (RPV) 8 Pressurizers (PZR) 6 Reactor Coolant Pumps (RCP) 3 Reactor Pressure Vessel Head (RPVH) 12 Other 1
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Content of Special Permit Application • Description: A description of the item to be shipped and
the history of its operation and any unique features.
• A table that shows compliance to the exemption requirements in 49CFR107.105, “Application for a Special Permit”.
• The characterization: Calculations to show that the item is properly understood as an SCO or LSA and the potential doses
•
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Content of Special Permit Application (cont’d)
• The structural analysis: Usually, this analysis must conclude that the item is equivalent to IP-2 Industrial Packaging by complying with 49 CFR 173.411, “Industrial Packaging’’. The General Design requirements of 49 CFR 173.410 must be met, the 1-foot free drop test per 49 CFR 173.465(c) must be met (may be by calculation), and the stacking test of 49 CFR 173.465(d) must be met.
• The transportation and emergency plan: this is the key element for the safety basis because DOT and NRC say that an exclusive shipment that is carefully planned and requires the full-time presence of a Radiation Control Officer was as safe as a Type A shipment (equivalent safety)
•
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Guidance for Characterization
• NUREG-1608 provides methods/guidance for characterization as LSA or SCO on question and answer format: – Flowcharts for classification,
categorization,
– distribution of activity in LSA material or on SCO
– mixing LSA and SCO in a package,
– radiation level measurements including accounting for activation and decay
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Special Permit
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Special Permit (cont’d)
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10CFR173 Exemptions for US Shipments49 CFR Para. Exemption Items173.403 Components may be considered SCO or LSA even though
definitions in 173.403 are not strictly met. Levels are sometimes exceeded. Definitions do not cover mixtures of activated metals and surface contaminated metals.
All types, 22 cases
173.411 RPV package approved as equivalent to IP-2 RPV, 2 cases
173.416 Greater than A2 quantities but package is not certified as Type B, B(U), or B(M) (Trojan only case)
RPV, 2 cases
173.427(a) SCO can be transported in non-specification packaging or quantity limits.
SG, RPV, PZR, Steam Drum, RPVH, 14 cases
173.427(a)(1) The dose rate requirement of less than 10 mSv/hr at 3 meters is not met but internals are fixed in place and the vessel is filled with low density concrete.
RPV, 3 cases
173.427(b) Requirement for transportation in authorized packagings is waived. Transport plan provides the equivalent safety.
RPV, RCP, SG, RPVH, 12 cases
173.427(c) Requirement that LSA must be transported in authorized packagings is waived. Transport plan provides the equivalent safety.
RPVH, 1 case
173.441 (b)(1)(iii)
External package limit should be 2 mSv/h (200 mrem/h) on the external surface of the package if there are loadings and unloadings. (Protection measures to prevent access to high activity areas were used).
RPVH, 2 cases
173.465(c) (d) Modified mechanical testing is authorized and stacking tests are not required.
RPV, RPVH, PZR, 13 cases
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Concepts to Develop an International Rule
• Develop the standards like TS-R-1 in phases
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Analysis of Shipments
• Two figures used to show the US data on the concept– Y-axis: the line for exempt is from TS-R-1 508 is 4 Bq/cm2 and is
too far below the items of interest to show. So only the SCO-I and SCO-II limits are shown.
– X-axis: SAIC charts cannot be exactly made to show the range of activity as on the Japan chart
– the limits for the material groups are based on different parameters
• The exempt and LSA-1 limits depend on the Bq/g values in Table I of TS-R-1 (LSA-1 limit is 30X the exempt limit).
• The LSA-II and LSA-III limits depend on the A2/gram characteristics of the component.
• the isotopes may be different for each large component, the limits for exempt and LSA-1 in Bq/g are not directly related to the A2/g parameters
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Analysis Based on Contamination• For this study most of the activity for the SG, PZR, and RCP is from
contamination and the activity is in the exempt range. A value of 1x10-8 is used as the exempt limit (70 Bq/gram) for the chart
1.E-02
1.E-01
1.E+00
1.E+01
1.E-09 1.E-08 1.E-07 1.E-06 1.E-05 1.E-04 1.E-03 1.E-02 1.E-01 1.E+00
Co
nta
min
ati
on
(Fra
ctio
n o
f SC
O I
I)
Activity (fraction of LSA III= 2 x10-3 A2/g)
Activity and Contamination for US Components(log scales)
SG RPVH PZR RPV RCP
LSA-I LSA-II LSA-IIISCO-II
SCO-1
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Analysis Based on Activity• The x-axis values are only approximations of the fraction of LSA-III ratio
based on the exempt limit of 70 Bq/gram.
• For the SG, PZR, and RCP the x-axis activities are assumed to be in the 10-9
range to display them on the charts. The actual activities are usually so low that they are not used.
1.E-01
1.E+00
1.E+01
1.E+02
1.E+03
1.E+04
1.E-09 1.E-08 1.E-07 1.E-06 1.E-05 1.E-04 1.E-03 1.E-02 1.E-01 1.E+00
Act
ivit
y
(Fra
ctio
n o
f A
2)
Activity (fraction of LSA III= 2 x10-3 A2/g)
LSA Activity and A2 Activity for US Components(log scales)
SG RPVH PZR RPV RCP
LSA-I LSA-II LSA-III
US Proposal to Revise TS-R-1
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• US proposal US/07/11 to revise TS-R-1 for large component package and transport
• Add a single paragraph to TS-R-1 based on US experience to cover large components
• Compensatory measures for equivalent safety are transportation plans, emergency plans, exclusive use shipments, Health Physics escorts (as in the US experience)
US Proposal to Revise TS-R-1 (cont’d)
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Issues on US/07/11
• US opinion: – large component shipments are very unique and should not be
handled like other radioactive materials shipments:• US has not used the usual radioactive material shipment rules for
large components
• Do not want to modify the “current system” for shipments in TS-R-1 to include large components
• US proposes a standalone section for the special case for large components.
• US does not want to use the full Q system
• US proposes to use a flexible way:– approval very simple but uses much judgment
– US knows it may be difficult for other countries to accept this approach
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Issues on US/07/11 (cont’d)
• The US does not have strong basis other than experience and judgment for the two quantitative requirements in US/07/11 that are:– (e) A component that contains greater than a 5A2quantity may
only be transported if approved by the relevant Competent Authority and
– (h) the non-fixed contamination on any unpackaged exterior surface of the component does not exceed ten timesthe Paragraph 508 limits for non-fixed contamination on packages
• DOT says maybe the Q system approach in TS-G-1.1 para. 241.2 and 241.3 can be used as the basis to validate the 5A2 values and other parts of the proposal
• But DOT does not want to use the entire Q system
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US Waste Imports
• No large components (yet?)
Import License No
Max Volume for Import (ft3)
Action Countries
IW002 66 Waste returned after processing Germany
IW004 826,750 Waste returned after processing Canada
IW006 3,885 Disposal after processing Taiwan
IW008 ? Process and dispose of wastesMineral oil will be processed and reused
UK
IW009 66 Disposal after processing Germany
IW010 1,375 Disposal after processing UK
IW012 10,417 Waste returned after processing Canada
IW016 2,080 per shipment
Disposal after treatment and processing Mexico
IW017 300,000 Waste returned after processing Canada
IW018 30 US Origin- Disposal after processing France
IW019 5,000 per shipment
Waste returned after processing Canada
IW021 10,875 US Origin- Disposal after processing Canada
IW022 275,000 Waste returned after processing Canada
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US Waste Imports
• No large components (yet?)
Import License No
Max Volume for Import (ft3)
Action Countries
IW002 66 Waste returned after processing Germany
IW004 826,750 Waste returned after processing Canada
IW006 3,885 Disposal after processing Taiwan
IW008 ? Process and dispose of wastesMineral oil will be processed and reused
UK
IW009 66 Disposal after processing Germany
IW010 1,375 Disposal after processing UK
IW012 10,417 Waste returned after processing Canada
IW016 2,080 per shipment
Disposal after treatment and processing Mexico
IW017 300,000 Waste returned after processing Canada
IW018 30 US Origin- Disposal after processing France
IW019 5,000 per shipment
Waste returned after processing Canada
IW021 10,875 US Origin- Disposal after processing Canada
IW022 275,000 Waste returned after processing Canada
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US Waste Imports (cont’d)
• There is no regulation that prevents the import of wastes for processing and keeping secondary wastes or recycled materials in the US.
– 10 CFR 110.32(f)(5) states that, for proposed imports of radioactive waste, the volume and the ultimate disposition (including forms of management of the waste), should be described.
– 10 CFR 110.32(f)(6) states that the industrial or other process responsible for generation of the waste should be described.
– 10 CFR 110.32(f)(5) states that, for proposed imports of radioactive waste, the volume and the ultimate disposition (including forms of management of the waste), should be described. Similarly, 10 CFR 110.32(f)(6) states that the industrial or other process responsible for generation of the waste should be described.
• The recent case in favor of EnergySolutions to import wastes from Italy is the key example that wastes can be imported
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Observations
• The US has made many successful large component shipments including PZR and SG that exceed the SCO-II limit
• The US/07/11 proposes to make TS-R-1 based on the US experience including cases above SCO-II
• Discussions continue on TS-R-1 as a basis for easier international shipments of large components that can benefit future large component disposal
• Other countries will require more bases and more revisions in TS-R-1 than initially proposed by the US/07/11
