ML25016A199
| ML25016A199 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 01/16/2025 |
| From: | Casulli E Susquehanna, Talen Energy |
| To: | Mellott T Document Control Desk, Office of Nuclear Reactor Regulation, State of PA, Dept of Environmental Protection |
| References | |
| PLE-0026677 | |
| Download: ML25016A199 (1) | |
Text
Edward Casulli Site Vice President January 16, 2025 Bureau of Waste Management Susquehanna Nuclear, LLC 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3795 Fax 570.542.1504 Edward.Casulli@TalenEnergy.com Pennsylvania Department of Environmental Protection Division of Hazardous Waste Management Attn: Tom Mellott Post Office Box 69170 Harrisburg, PA 17106-9170 SUSQUEHANNA STEAM ELECTRIC STATION SUPPLEMENT TO REPORT FOR MISSED ANNUAL INVENTORY REQUIRED BY 40 CFR 266, SUBPART N AND REQUEST TO RECLAIM CONDITIONAL EXEMPTION PLE-0026677 TALEN~
ENERGY 40 CFR266 Docket No. 50-387 50-388
References:
- 1) Susquehanna letter to PaDEP, "Low-Level Mixed Waste Conditional Exemption (PLE-0024767)," dated July 13, 2009.
- 2) Susquehanna letter to PaDEP, "Missed Annual Inventory Required by 40 CFR 266, Subpart N (PLE-0026645)," dated October 16, 2024.
By letter dated July 13, 2009, Reference 1, Susquehanna Nuclear, LLC (Susquehanna),
submitted notification to the Pennsylvania Department of Environmental Protection (PaDEP) claiming low-level mixed waste (LLMW) conditional exemption per 40 CFR 266, Subpart N (incorporated by reference at 25 Pa. Code 266a.20). The exemption was conditional and based on continued compliance with 40 CFR 266.230. By letter dated October 16, 2024, Reference 2, Susquehanna notified PaDEP of noncompliance with the requirements of 40 CFR 266.230(b)(4) which nullified the conditional exemption granted by PaDEP.
This letter serves two purposes: ( 1) to supplement the Reference 2 report with the information required by 40 CFR 266.240(a)(l)(ii), thereby completing the required reporting and (2) to request reclamation of the condition exemption.
As documented in Reference 2, contrary to the requirements of 40 CFR 266.230(b)(4),
Susquehanna did not conduct annual inventories since June 14, 2021. The absence of inventory records was discovered during an internal compliance review conducted on September 19, 2024.
Reference 2 satisfied the reporting requirements in 40 CFR 266.240(a)(l), subparts (i) and (iii).
The attachment to this letter satisfies the final reporting requirements of 40 CFR 266.240(a)(l)(ii) by providing the description of the LLMW (including the waste name, hazardous waste codes and quantity) and storage location at the Susquehanna Steam Electric Station.
Bureau of Waste Management PLE-0026677 Having restored compliance with 40 CFR 266.230, Susquehanna also requests to reclaim the LLMW conditional exemption in accordance with 40 CFR 266, Subpart N. The following information is provided in accordance with 40 CFR 266.245 to support reclaiming the exemption:
(a)(1):
As noted herein, Susquehanna has restored compliance with 40 CFR 266.230.
40 CFR 266.230(a):
Name:
Susquehanna Nuclear, LLC*
Address:
769 Salem Boulevard Berwick, PA 18603 RCRA ID No.:
PAD000765883 NRC License No.:
NPF-14 (Unit 1), and NPF-22 (Unit 2)
Waste Codes:
D001, D002, D003, D004, D005, D006, D007, D008, D009, D010, D011, D022, D029, D035, D040, F001, F002, F003, F005 Storage Units:
- 1. Hazardous Waste Storage Area - 656 Elevation, Unit 1 Conditioner Room
- 2. Radiological Waste Storage Building - 676 Elevation, Dry Active Waste Collection Area
- 3. Outside Storage Yard Susquehanna qualifies for a LLMW conditional exemption and will continue to maintain compliance with the requirements of 40 CFR 266.230(b).
Susquehanna Steam Electric Station is now operated by Susquehanna Nuclear, LLC. If approved, the conditional exemption should be issued to Susquehanna Nuclear, LLC.
(a)(2)(i):
As documented in Reference 2, Susquehanna failed to conduct annual inventories since June 14, 2021. The absence of inventory records was discovered during an internal compliance review conducted on September 19, 2024. While Susquehanna was completing required quarterly inspections, Susquehanna did not complete the required annual inventories.
(a)(2)(ii):
This letter serves as certification that the failures noted in (a)(2)(i) have been corrected and that Susquehanna again meets all required conditions as of January 05, 2025.
Bureau of Waste Management PLE-0026677 (a)(2)(iii):
As noted previously, for the affected timeframe (i.e., June 14, 2021, until January 05, 2025), Susquehanna completed the required qumierly inspections but failed to complete the annual inventories. Upon review, it was dete1mined that inspections had a recurring work mechanism by which to ensure timely initiation and completion of the activity. No such recurring work mechanism existed for the inventories. Therefore, Susquehanna developed an automated annual recurring work mechanism requiring completion of LLMW inventory in accordance with 40 CFR 266.230(b)(4).
(a)(2)(iv):
In addition to the action documented in response to (a)(2)(iii), Susquehanna has planned corrective actions to revise existing procedures and/or create new procedures to better document the requirements of 40 CFR 266 and establish roles and responsibilities for applicable staff.
Susquehanna respectfully requests approval of the reclamation of the conditional exemption by March 18, 2025.
This letter contains no new or revised regulatory commitments.
Should you have any questions regarding this submittal, please contact Mr. Adrian Nestico, Manager-Radiation Protection, at (570) 542-1643.
I declare under penalty of pe1jury that the foregoing is true, complete, and correct.
Executed on i )!t/ [!3
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E. Casulli
Attachment:
Mixed Waste Inventory as of January 05, 2025 Copy:
NRC Region I Ms. J. England, NRC Senior Resident Inspector Ms. A. Klett, NRC Project Manager Mr. M. Shields, PA DEP/BRP
Attachment to PLE-0026677 Mixed Waste Inventory as of January 05, 2025
PLE-0026677 Attachment Page 1 of 6 Mixed Waste Inventory as of January 05, 2025 Location: Hazardous Waste Storage Area - 656 Elevation, Unit 1 Conditioner Room Waste Code(s)
Drum #
Material Container size (gal) Weight (lbs) % Full D006 D009 D008 D010 D007 20-603 Parts Cleaner Solvent 55 Unknown 100 D006 D009 D008 D010 D007 21-172 Parts Cleaner Solvent 55 Unknown 100 Location: Radiological Waste Storage Building - 676 Elevation, Dry Active Waste Collection Area Waste Code(s)
Drum #
Material Container size (gal) Weight (lbs) % Full D008 16-0296 Lead Blankets 55 Unknown 100 D008 20-0169 Lead Bisco 55 Unknown 100 D008 21-441 Lead Blankets 55 453 100 D008 21-440 Lead Blankets 55 453 100 D008 24-262 Lead Waste 55 400 100 D008 22-340 Lead Blankets 55 453 100 D008 21-154 Lead Blankets 55 460 100 D008 23-570 Lead Blankets 55 455 100 D008 20-115 Lead Bisco 55 480 100 D008 09-0331 Lead Bisco 55 560 100 D008 09-0299 Lead Bisco 55 496 100 D001 16-0032 Acetylene bottles 55 N/A 90 D006 24-481 USED Ni-Cad batteries 55 N/A 50 D001 D003 24-538 USED Li-Ion batteries 55 N/A 25
PLE-0026677 Attachment Page 2 of 6 Mixed Waste Inventory as of January 05, 2025 Location: Radiological Waste Storage Building - 676 Elevation, Dry Active Waste Collection Area (CONTINUED)
Waste Code(s)
Drum #
Material Container size (gal) Weight (lbs) % Full D001 23-582 Aerosol Cans 55 N/A 80 D009 17-0296 Light Bulbs - various 30 N/A 87.5 D009 17-0296a Light Bulbs - various 55 N/A 10 D009 N/A mercury device 1
N/A 5
D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 20 N/A D008 N/A lead acid battery N/A 10 N/A D008 N/A lead acid battery N/A 10 N/A D008 N/A lead acid battery N/A 10 N/A D008 N/A lead acid battery N/A 10 N/A D008 N/A lead acid battery N/A 10 N/A D008 N/A lead acid battery N/A 10 N/A D008 N/A lead acid battery N/A 10 N/A D001 N/A acetylene bottle N/A N/A 0
D001 N/A acetylene bottle N/A N/A 0
PLE-0026677 Attachment Page 3 of 6 Mixed Waste Inventory as of January 05, 2025 Location: Radiological Waste Storage Building - 676 Elevation, Dry Active Waste Collection Area (CONTINUED)
Waste Code(s)
Drum #
Material Container size (gal) Weight (lbs) % Full D001 N/A acetylene bottle N/A N/A 0
D001 N/A acetylene bottle N/A N/A 0
D001 N/A acetylene bottle N/A N/A 0
D001 N/A acetylene bottle N/A N/A 0
D001 N/A acetylene bottle N/A N/A 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
D001 N/A Propane bottle N/A 20 0
PLE-0026677 Attachment Page 4 of 6 Mixed Waste Inventory as of January 05, 2025 Location: Outside Storage Yard Waste Code(s)
Sealand #
Drum #
Material Container size (gal) Weight (lbs) % Full D008 EL-120 11-0122 Hepa Hose from Lead work 55 115 N/A D008 EL-120 12-0240 Lead Bisco 55 322 N/A D008 EL-120 09-0303 Lead Bisco 55 602 N/A D008 EL-120 09-0302 Lead Bisco 55 592 N/A D008 EL-120 11-0299 Lead Bisco 55 197 N/A D008 EL-120 12-0205 Lead Bisco 55 860 N/A D008 EL-120 10-0365 Lead Bisco 55 380 N/A D008 EL-120 10-0358 Lead Bisco 55 177 N/A D008 EL-120 07-0283 Lead Bisco 55 427 N/A D008 EL-120 11-0156 Lead Bisco 55 360 N/A D008 EL-120 11-0088 Lead Bisco 55 413 N/A D008 EL-120 11-0123 Hepa Hose from Lead work 55 74 N/A D008 EL-120 09-0290 Lead Bisco 55 360 N/A D008 EL-120 09-0276 Lead Bisco 55 520 N/A D008 EL-120 11-0915 Lead Bisco 55 632 N/A D008 EL-120 11-0068 Lead Bisco 55 419 N/A D008 EL-120 09-0216 Lead Bisco 55 553 N/A D008 EL-120 00-0901 Lead Bisco 55 514 N/A D008 EL-120 11-0518 Lead Bisco 55 593 N/A D008 EL-120 09-0136 Lead Bisco 55 700 N/A D008 EL-120 12-0249 Lead Bisco 55 384 N/A D008 EL-120 08-0461 Lead Bisco 55 510 N/A D008 EL-120 10-0513 Lead Bisco 55 144 N/A D008 EL-120 12-0413 Lead Bisco 55 630 N/A D008 EL-120 10-0154 Lead Bisco 55 420 N/A D008 EL-120 13-0272 Lead Blankets 55 Unknown N/A D008 EL-120 15-0404 Lead Blankets 55 Unknown N/A
PLE-0026677 Attachment Page 5 of 6 Mixed Waste Inventory as of January 05, 2025 Location: Outside Storage Yard (CONTINUED)
Waste Code(s)
Sealand #
Drum #
Material Container size (gal) Weight (lbs) % Full D008 EL-120 14-0138 Lead Blankets/Bricks 55 Unknown N/A D008 EL-120 14-00113 Lead Blankets/Bricks 55 Unknown N/A D008 EL-120 15-0322 Lead Blankets 55 Unknown N/A D008 EL-120 13-0312 Lead Blankets 55 Unknown N/A D008 EL-120 15-0055 Lead Blankets 55 Unknown N/A D008 EL-120 14-0010 Lead Blankets 55 Unknown N/A D008 EL-120 14-0215 Lead Blankets 55 Unknown N/A D008 EL-120 13-0275 Lead Blankets 55 Unknown N/A D008 EL-171 11-0154 Lead Bisco 55 181 N/A D008 EL-171 09-0378 Lead Bisco 55 138 N/A D008 EL-171 11-0234 Lead Bisco 55 332 N/A D008 EL-171 08-0223 Lead Bisco 55 260 N/A D008 EL-171 09-0049 Lead Bisco 55 294 N/A D008 EL-171 09-0131 Lead Bisco & 4 monitor shields 55 568 N/A D008 EL-171 09-0325 Lead Bisco 55 530 N/A D008 EL-171 09-0293 Lead Bisco 55 496 N/A D008 EL-171 07-0201 Lead Bisco 55 480 N/A D008 EL-171 10-0462 Lead Bisco & Penetration Debris 55 388 N/A D008 EL-171 13-0391 Lead Bisco 55 120 N/A D008 EL-171 13-0036 Lead Bisco 55 274 N/A D008 EL-171 13-0040 Lead Bisco 55 375 N/A D008 EL-171 11-0136 Lead Bisco 55 325 N/A D008 EL-171 13-0231 Lead Bisco 55 540 N/A D008 EL-171 13-0156 Lead Bisco 55 520 N/A D008 EL-171 13-0039 Lead Bisco 55 350 N/A D008 EL-171 09-0242 Lead Bisco 55 333 N/A
PLE-0026677 Attachment Page 6 of 6 Mixed Waste Inventory as of January 05, 2025 Location: Outside Storage Yard (CONTINUED)
Waste Code(s)
Sealand #
Drum #
Material Container size (gal) Weight (lbs) % Full D008 EL-171 11-0521 Lead Bisco & Penetration Debris 55 474 N/A D008 EL-171 10-0543 Lead Bisco 55 212 N/A D008 EL-171 11-0512 Lead Bisco 55 197 N/A D008 EL-171 11-0446 Lead Bisco 55 719 N/A D008 EL-171 11-0449 Lead Bisco 55 682 N/A D008 EL-171 11-0472 Lead Bisco 55 704 N/A D008 EL-171 11-0462 Lead Bisco 55 766 N/A D008 EL-171 11-0471 Lead Bisco 55 144 N/A D008 EL-171 08-0188 Lead Bisco 55 207 N/A D008 EL-171 11-0304 Lead Bisco 55 277 N/A D008 EL-171 11-0527 Lead Bisco & Penetration Debris 55 199 N/A D008 EL-171 11-0051 Lead Bisco 55 541 N/A D008 EL-171 13-0389 Lead Bisco 55 615 N/A D008 EL-171 11-0313 Lead Bisco 55 Unknown N/A