ML20318A087
| ML20318A087 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/03/2020 |
| From: | Bates A Southern California Edison Co |
| To: | Office of Nuclear Reactor Regulation, Division of Nuclear Materials Safety IV |
| References | |
| Download: ML20318A087 (2) | |
Text
An £DISON /".TF.Rtv4TIO,'iAL' Comp,,n)
Al Bates Manager Regulatory Affairs 10 CFR 20 Appendix G USNRC, Region IV 1600 E. Lamar Boulevard Arlington, TX 76011-4511 November 3, 2020
Subject:
Docket Nos. 50-361 and 50-362 Report of Investigation Pursuant to 10 CFR Part 20 Appendix G San Onofre Nuclear Generating Station (SONGS), Units 2 and 3 This letter documents the results of an investigation performed with respect to a recent radioactive waste shipment, consisting of four containers of radioactive asbestos, which exceeded the 20-day criteria for notification of receipt from the disposal facility as specified in 1 O CFR Part 20 Appendix G, Section 111.A.9. The investigation was completed on October 23, 2020. The shipments were being traced on a daily basis and the location of the shipment was known to the carrier, Burlington Northern Santa Fe (BNSF) and to Ene.rgySolutions, LLC Waste Operations personnel. The disposal facility notification verified that the shipments were received as indicated below.
10 CFR Part.20 Appendix G, "Requirements for Transfers of Low-L~vel Radioactive Waste Intended for Disposal at Licensed Land Disposal Facilities and Manifests," Section 111.A.9 states that a licensee shall for any shipments or an'y part of a shipment for which acknowledgment of receipt has not been received within *the times set fc;>rth in Appendix G, conduct an investigation in accordance with paragraph E.
Paragraph E states that any shipment or part of shipment for which acknowledgement has not received within-the times set forth must:
- 1. Be investigated by the shipper if the shipper has not received notification or receipt within 20 days after transfer; and
- 2. Be traced and reported. The investigation shall include tracing the shipment and filing a report with the nearest Commission Regional Office listed in Appendix D to this part.
Each licensee who conducts a trace investigation shall file a written report with the appropriate NRC Regional Office within 2 weeks of completion of the investigation.
Investigation Report On September 29, 2020, four intermodals (container numbers ESUU800257, ESUU800264, ESUU800258, ESUU800263) were manifested to the EnergySolutions' Clive Disposal facility in Clive, UT. The SONGS shipment number for the railcars was MLLW-20-020.
A BNSF crew arrived onsite October 7, 2020 to pick up the waste-shipment which left the SONGS spur early on October 8, 2020. This delay in pick-up was attributed to unanticipated P. 0. Box 128 San Clemente, CA 92674 scheduling changes by BNSF as they had just taken over servicing the site from Pacific Sun railway on October 1, 2020. Even with a 7-day delay, the anticipated receipt date at Clive was expected to be within 20 days of the manifested date.
From the SONGS site, the shipment was transported to the Stuart railyard located]ust south of SONGS, where it remained until pick-up by BNSF on October 14,.2020. The 6-day duration at the yard wa~ also attributed to s~heduling adjustments controlled by BNSF.
Upon leaving the Stuart railyard, the shipment made sever91 train transfers with BNSF and arrived in Colton, CA on October 16, 2020 where an interchange occurred to the Union Pacific (UP) railway.
The shipment left Colton, CA later on October 16, 2020 and continued transport to the Clive facility, arriving on October 23, 2020 for a total transit duration of 24 days from the manifest date.
The location of the shipment was monitored using GPS and EnergySolutions, LLC received daily tracking reports of the waste shipment from BNSF until its receipt to ensure compliance with the requirements of 10 CFR Part 20 Appendix G, Section 111.E. At no time was the shipment lost or at an unknown location.
Industry experience indicates that this transit time was not inordinate or uncommon during rail transportation from locations on the West Coast. In anticipation of such delays, SCE had requested extension of the 20-da1' criteria to 45 days as was submitted in our letter dated September 1, 2020 (ML20255Ab83). SCE understands that this submittal is currently being reviewed by the NRC Staff.
The issue described in this report has been placed in the corrective action program as Condition Report SDS-000907. Should you have any questions regarding this report, please contact me at (949) 368-7024.
There are no commitments in this letter.
Sincerely, C/iJ~\\
cc:
S. Morris, Regiqnal Administrator, NRC Region IV A Snyder, NRC Project Manager, SONGS Units 1, 2 and 3 U.S. NRC Document Control Desk P.0.Box128 San Clemente, CA 92674 t