ML21323A108

LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G

ML21323A108
Person / Time
Site:	Indian Point
Issue date:	11/19/2021
From:	Fleming J Holtec
To:	David Lew Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, NRC Region 1
References
HDI-IPEC-21-034
Download: ML21323A108 (4)

Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 10 CFR 20, Appendix G November 19, 2021 Mr. David C. Lew Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 2100 Renaissance Blvd, Suite 100 King of Prussia, PA 19406-2713 Indian Point Energy Center Provisional License No. DPR-5 Renewed Facility License No. DPR-26 and DPR-64 NRC Docket Nos.50-003, 50-247, 50-286, and 72-051

Subject:

LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G Pursuant to the provisions 10 Code of Federal Regulations (CFR) 20, Appendix G, Holtec Decommissioning International, LLC (HDI) is submitting this report to identify the results of the investigations performed relative to shipment and transport of low-level radioactive waste (LLRW) from Indian Point Energy Center (IPEC) to the Waste Control Specialists, LLC (WCS) disposal facility in Andrews, Texas. The LLRW shipment exceeded the 20-day time limit for notification of receipt from the disposal facility as specified in 10 CFR Part 20, Appendix G.

Radwaste Shipment(s) No., 21-3002, 21-3003, 21-3004, and 21-3005 were shipped via flatbed truck from IPEC to Newton, Connecticut and transferred to rail and conveyance to the WCS waste disposal facility in Andrews, Texas. IPEC Radwaste shipping personnel were notified of railcar shipment receipt at WCS after the 20-day time for notification had expired. The total transport time for these LLRW shipments was 22 days.

10 CFR 20, Appendix G, Requirements for Transfers of Low-Level Radioactive Waste Intended for Disposal at Licensed Land Disposal Facilities and Manifests,Section III.A(9) states for any shipments or any part of a shipment for which acknowledgment of receipt has not been received within the times set forth in this appendix, to conduct an investigation in accordance with Section III.E of this appendix.

Section III.E states that any shipment or part of shipment for which acknowledgement is not received within the times set forth in this section 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.

HDI-IPEC-21-034 Page 1 of 2

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 IPEC Radwaste Shippers initiated a trace investigation for these shipments. These trace investigations identified that there were no significant or unusual transport delays encountered.

IPEC Incident Report, IR-IP3-00289 was issued to document the issue of not meeting the 20-day investigation and report time limit identified in 10 CFR 20, Appendix G.

This letter contains no new regulatory commitments.

If you have any questions or need further information, please contact Mr. Walter Wittich, IPEC Licensing or myself at (856) 797-0900, ext. 3578.

Sincerely, Digitally signed by Jean A. Fleming Jean A. DN: cn=Jean A. Fleming, c=US, o=Holtec Decommissioning International, LLC, ou=Regulatory and Fleming Environmental Affairs, email=J.Fleming@Holtec.com Date: 2021.11.19 12:24:10 -05'00' Jean A. Fleming HDI Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC Attachment - IPEC Radwaste Shipment Investigation Report for LLRW Shipments 21-3002, 21-3003, 21-3004, and 21-3005 cc: (with Attachment)

NRC NMSS Project Manager, Indian Point Energy Center NRC Senior Regional Inspector, Indian Point Energy Center President and CEO, NYSERDA NYS Public Service Commission NYS Department of Environmental Conservation HDI-IPEC-21-034 Page 2 of 2

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-IPEC-21-034 Attachment 1 IPEC Radwaste Shipment Investigation Report for LLRW Shipments 21-3002, 21-3003, 21-3004, and 21-3005 LLRW Shipment Exceeded 20-Days (2 total pages including cover page)

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 IPEC Radwaste Shipment Investigation Report Report #: 21-3002, 21-3003, 21-3004, 21-3005 Revision #: 0 Investigation Start Date: 11/03/2021 Investigation Report Completion Date: 11/09/2021

==

Conclusion:==

No unusual or significant shipping delays were identified for the referenced shipment. The 20-day time limit identified in 10 CFR 20, Appendix G, for initiating an investigation when shipment receipt notification is not provided from the waste disposal facility is too conservative for road to rail shipments originating from the Indian Point Energy Center (IPEC) and transported to Waste Control Specialists (WCS) facility in Andrews, Texas. An Incident Report (IP3-00289) was written to document the issue of not meeting the 20-day investigation and report time limit.

Shipping Report Details:

Shipment Start Date: 10/14/2021 Investigation Start Date: 11/03/2021 Shipment Manifest Id #s: 21-3002, 21-3003, 21-3004, 21-3005 Shipment Item

Description:

One Sealand of DAW on each truck, four total on rail flatcar SOX 20190 Destination: WCS, Andrews, TX Shipping Companies Involved:

Highway Transporter: S&J Transportation Company Rail Transporter #1: Housatonic Railroad, Inc Rail Transporter #2: CSX Transportation, Inc Rail Transporter #3: Union Pacific Rail Transporter #4: Watco Companies LLC DBA Texas and New Mexico Railway Shipping Problems or Delays: No issues. Typical delays with transload logistics and receiving facility schedule.

Shipment Tracking Start date: 10/14/2021 On 11/3/2021(day 20), flatcar SOX 20190 was in Fort Worth, Texas, on 11/4/2021 flatcar was in Eunice, New Mexico, on 11/5/2021 it arrived at Waste Control Specialists, in Andrews, Texas Shipment Current Status: Received at WCS on 11/5/2021 (22 days)

WCS Shipment Receipt Notification to Shipper (signed manifest received): 11/09/2021 Investigation Preparer: Gene LeClair, CDI / IPEC Radwaste Shipper Investigation Reviewer: Jennifer Bakker, CDI Waste Management Lead HDI-PIL-21-034 Page 2 of 2