L-21-078, Late LLRW Shipment Investigation Report Pursuant to 10 CFR 20, Appendix G

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

ML21187A200
Person / Time
Site:	Pilgrim
Issue date:	07/06/2021
From:	Sterdis A Holtec Decommissioning International
To:	David Lew Document Control Desk, Office of Nuclear Material Safety and Safeguards, NRC Region 1
References
HDI-PIL-21-078
Download: ML21187A200 (7)

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 July 6, 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 Pilgrim Nuclear Power Station Renewed Facility License No. DPR-35 NRC Docket Nos. 50-293 and 72-1044

Subject:

Late 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 a report to identify the results of the investigations performed relative to shipment and transport of low-level radioactive waste (LLRW) from Pilgrim Nuclear Power Station (PNPS) to the Waste Control Specialists, LLC (WCS) disposal facility in Andrews Texas. The LLRW shipments exceeded the 20-day time limit for notification of receipt from the disposal facility as specified in 10 CFR Part 20, Appendix G.

On May 6 and 7, 2021, Radwaste Shipment No.,21-123 and 124 were shipped via flatbed truck from PNPS to the Greenfield Logistics LLC transfer facility in Binghamton, NY for transload to rail and conveyance to the WCS waste disposal facility in Andrews, Texas. Pilgrim Radwaste shipping personnel were notified of railcar shipment arrival at WCS on June 11, 2021, for the 21-123 shipment and June 15, 2021, for the 21-124 shipment. The total transport time for these LLRW shipments was 36 and 39 days, respectively.

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 shipments 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-PIL-21-078 Page 1 of 2

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 PNPS Site Radwaste Shippers initiated a trace investigation on May 26, 2021, for the 21-123 shipment and on May 27, 2021, for the 21-124 shipment. These trace investigations were completed on June 22, 2021. These investigations revealed that the LLRW shipments took a total of 36 and 39 days to complete transport from Pilgrim Station to the WCS waste disposal facility in Andrews, Texas. The trace investigations identified that there were no significant or unusual transport delays encountered.

Pilgrim Incident Report, IR-PIL-03086 was previously issued to document corrective actions relative to the general concern that site road to rail shipments from PNPS to WCS in Texas are expected to exceed the 20-day time constraint for investigation and report 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 me at (856) 797-0900, ext.

3813.

Sincerely, Digitally signed by Andrea Sterdis Andrea DN: cn=Andrea Sterdis, c=US, o=Holtec Decommissioning International, ou=HDI, Sterdis email=a.sterdis@holtec.com Date: 2021.07.06 12:03:14 -04'00' Andrea L. Sterdis HDI Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC Attachment - Pilgrim Station Radwaste Shipment Investigation Reports for LLRW Shipments21-123 and 21-124 cc: (with Attachment)

NRC NMSS Project Manager (Pilgrim Nuclear Power Station)

HDI-PIL-21-078 Page 2 of 2

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 HDI-PIL-21-078 Attachment 1 Pilgrim Station Radwaste Shipment Investigation Reports for LLRW Shipments21-123 and 21-124 LLRW Shipment Exceeded 20-Days (5 total pages including cover page)

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Pilgrim Station Radwaste Shipment Investigation Report 21-123 Report #: 21-123 Revision #: 0 Investigation Start Date: 5/26/2021 Investigation Report Completion Date: 6/22/2021

==

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 Pilgrim Nuclear Power Station (PNPS) and transported to Waste Control Specialists,(WCS) disposal facility located in Andrews, Texas. An Incident Report (IR-PIL-03086) was written to document the issue of not meeting the 20-day report notification time limit. A corrective action was assigned to draft a proposed exemption from the 10 CFR 20, Appendix G, 20-day investigation and report time constraints.

Shipping Report Details:

Shipment Current Status: Received Shipment Start Date: 5/6/2021 Shipment Id # : 21-123 Shipment Item

Description:

(8) Nine Yard Bags of Non-Compactible Trash Destination : WCS , Andrews TX Shipping Companies Involved:

Highway Transporters:

Carrier: Interstate Ventures Carrier: Greenfield Logistics, LLC Rail Transporter #1: NYSW Rail Yard to Norfolk Southern Railroad Carrier: New York, Susquehanna, & Western Railway Rail Transporter #2: Binghamton, NY to Clearing, IL Carrier: Norfolk Southern Railroad Rail Transporter #3: Clearing, IL to Lubbock, TX Carrier: BNSF Rail Transporter #4:

Carrier: Lubbock & Western Railway (LBWR)

HDI-PIL-21-078 Page 2 of 5

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Shipment Duration: 39 days Shipping Problems or Delays: Typical delays with transload logistics and receiving facility schedule.

Shipment Tracking Start date: 5/6/2021 Shipment Receipt Date: 6/11/2021 WCS Shipment Receipt Notification to Shipper: E-mail notification on 6/11/2021 Investigation Preparer: Joseph Voegtli, PNPS Radwaste Shipper Investigation Reviewer: Jim Buckley, CDI Waste Management Lead PNPS HDI-PIL-21-078 Page 3 of 5

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Pilgrim Station Radwaste Shipment Investigation Report 21-124 Report #: 21-124 Revision #: 0 Investigation Start Date: 5/27/2021 Investigation Report Completion Date: 6/22/2021

==

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 Pilgrim Nuclear Power Station (PNPS) and transported to Waste Control Specialists,(WCS) disposal facility located in Andrews, Texas. An Incident Report (IR-PIL-03086) was written to document the issue of not meeting the 20-day report notification time limit. A corrective action was assigned to draft a proposed exemption from the 10 CFR 20, Appendix G, 20-day investigation and report time constraints.

Shipping Report Details:

Shipment Current Status: Received Shipment Start Date: 5/7/2021 Shipment Id #: 21-124 Shipment Item

Description:

DAW non-compactible trash Destination: WCS, Andrews TX Shipping Companies Involved:

Highway Transporters:

Carrier: Interstate Ventures Logistics: Greenfield Logistics, LLC Rail Transporter #1: NYSW Rail Yard to Norfolk Southern Railroad Carrier: New York, Susquehanna, & Western Railway Rail Transporter #2: Binghamton, NY to Clearing, IL Carrier: Norfolk Southern Railroad Rail Transporter #3: Clearing, IL to Lubbock, TX Carrier: BNSF Rail Transporter #4:

Carrier: Lubbock & Western Railway (LBWR)

HDI-PIL-21-078 Page 4 of 5

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 Shipment Duration: 39 days Shipping Problems or Delays: Typical delays with transload logistics and receiving facility schedule.

Shipment Tracking Start date: 5/7/2021 Shipment Receipt Date: 6/15/2021 WCS Shipment Receipt Notification to Shipper: E-mail notification on 6/15/2021 Investigation Preparer: Joseph Voegtli, PNPS Radwaste Shipper Investigation Reviewer: Jim Buckley, CDI Waste Management Lead PNPS HDI-PIL-21-078 Page 5 of 5