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Home       > Electronic Reading       Room       > Document       Collections       > Generic       Communications >       Generic       Letters >       1996       > Gl96007 
				 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 STEAM                            GENERATORS Addressees  All holders of operating licenses and decommissioning facilities withpossession-only licenses for pressurized-water nuclear power reactors.Purpose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 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.Description of CircumstancesDOT and NRC transportation regulations for shipment of 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. 9611060238.                                                      GL 96-07                                                      December 5, 1996                                                      Page 2 of 3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 the contamination be averaged      over each 300 cm2 (46.5 in2).  It is impractical to measure the      contamination level on each 300 cm2 (46.5 in2) of the steam      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                                                      Page 3 of 3      (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.                                          signed 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