ML21266A277

HDI Clarification of Exemption Requested from 10 CFR 20, Appendix G, Section Iii.E

ML21266A277
Person / Time
Site:	Pilgrim
Issue date:	09/23/2021
From:	Sterdis A Holtec Decommissioning International
To:	Amy Snyder Reactor Decommissioning Branch
Snyder A
References
Download: ML21266A277 (3)

Text

From: Andrea Sterdis To: Snyder, Amy Cc: Dave Noyes; Francis McGinnis

Subject:

[External_Sender] HDI Clarification of Exemption Requested from 10 CFR 20, Appendix G, Section III.E Date: Thursday, September 23, 2021 1:09:23 PM September 23, 2021

Reference:

HDI-PIL-21-103 Email: Amy.Snyder@nrc.gov ATTN: NRC NMSS Project Manager - Pilgrim Nuclear Power Station Pilgrim Nuclear Power Station Renewed Facility License No. DPR-35 NRC Docket No. 50-293 and 72-1044

Subject:

Clarification of Exemption Requested from 10 CFR 20, Appendix G, Section III.E, Road Carrier Tracking Additional Information

References:

[1] Letter from Andrea L. Sterdis (Holtec Decommissioning International) to U.S. Nuclear Regulatory Commission, Request for Exemption from 10 CFR 20, Appendix G, Section III.E, August 30, 2021 (ML21242A267)

By letter dated August 30, 2021 (Reference 1), Holtec Decommissioning International (HDI) submitted a proposed exemption from 10 CFR 20, Appendix G, Section III.E, to address an extension of the time period to receive acknowledgement that the shipment has been received by the intended recipient be extended from 20 days to 45 days for low-level radioactive waste shipments.

The NRC requested a clarification to the HDI exemption relative to identification of methods to be used to track the status and location of radwaste shipments transported by truck (i.e., roadway shipments). The proposed clarification is provided below.

This email contains no new regulatory commitments.

If you have any questions or need further information, please contact me at (856) 797-0900, ext.

3813.or a.sterdis@holtec.com.

Respectfully, Andrea L. Sterdis Andrea L. Sterdis Vice President Regulatory and Environmental Affairs Holtec Decommissioning International (HDI)

Krishna P. Singh Campus 1 Holtec Blvd.

Camden, NJ 08104 A.Sterdis@Holtec.com Tel: (856)797-0900, x3813

Mobile: +1 (724)493-1833 Holtec Logo-EmailSignature Attachment to HDI-PIL-21-103 NRC Clarification Request:

The NRC requested a clarification to the HDI exemption request relative to methods to be used to track the status and location of shipments when they are transported by truck.

HDI Response to Clarification:

PNPS proposes the following revision to the Section IV - Justification for Exemption found in Attachment 1 to the HDI request for exemption (Reference 1 to this letter) .

IV. JUSTIFICATION FOR EXEMPTION As stated in 10 CFR 20.2301, "The Commission may, upon application by a licensee or upon its own initiative, grant an exemption from the requirements of the regulations in this part if it determines the exemption is authorized by law and would not result in undue hazard to life or property."

(1) The Requested Exemption is Authorized by Law There are no provisions in the Atomic Energy Act (or in any other federal statute) that impose a requirement to investigate and report to the NRC low-level radioactive waste shipments that have not been acknowledged by the intended recipient within 20 days after transfer. Therefore, there is no statutory prohibition on the issuance of the requested exemption, and the NRC is authorized to grant the exemption under law.

(2) The Requested Exemption Would Not Result in Undue Hazard to Life or Property The intent of 10 CFR 20, Appendix G, Section III.E is to require licensees to investigate, report, and trace radioactive shipments that have not reached their destination within 20 days after transfer. For truck (roadway) and rail shipments, PNPS utilizes an electronic data tracking system that allows monitoring the progress of the shipments by the rail/road carrier on a daily basis. As a result, granting an exemption to PNPS for shipments of low-level radioactive waste to disposal facilities or waste processors results in no undue hazard to life or property.

The purpose of the 10 CFR 20, Appendix G regulation is to investigate a late shipment that may be lost, misdirected, or diverted. For truck (roadway) and rail shipments, PNPS utilizes an electronic data tracking system interchange that allows monitoring the progress of the shipments daily. As a result, it will be unlikely that a shipment could be lost, misdirected, or diverted without the knowledge of the carrier or PNPS.

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