CY-05-018, Connecticut Yankee Atomic Power Company, 10 CFR 20 Appendix G Investigation
| ML050380547 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 01/26/2005 |
| From: | Gerard van Noordennen Connecticut Yankee Atomic Power Co |
| To: | NRC Region 1 |
| References | |
| CY-05-018, FOIA/PA-2005-0203 | |
| Download: ML050380547 (5) | |
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CONNECTICUTWANKEE ATOMIC POWER COMPANY HADDAM NECK P e N T 362 INJUN HOLLOW ROAD EAST HAMPTON, CT 06424-3099 1 -41 J.9 :?
05
,Ink -
JAN 2 6 2005 Docket No. 50-213 CY-05-0 1 8 U. S. Nuclear Regulatory Commission Region 1 475 Allendale Rd.
King of Prussia, PA 19406 Haddam Neck Plant 10 CFR 20 Appendix G Investiaation This letter documents the investigation performed regarding twenty four (24) intermodal containers of radioactive waste contained on three (3) rail cars which exceeded the time limit provided in 10 CFR 20 Appendix G. The investigation determined the shipments were being tracked on a daily basis and the location of the shipments were known to the carrier during the period the shipments exceeded the time frame set forth in I O CFR 20 Appendix G.
10 CFR 20 Appendix G - Requirements for Transfers of Low-Level Radioactive Waste Intended for Disposal at Licensed Land Disposal Facilities and Manifests; Section Ill (9) states a licensee shall for any shipments or any part of a shipment for which acknowledgement of receipt has not been received within the times set forth in this appendix, conduct an investigation in accordance with paragraph E of this appendix.
Paragraph E states any shipment or part of a 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 of 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.
USNRC Region I CY-05-018 I Page 2 On October 14,2004, the NRC granted Connecticut Yankee Atomic Power Company (CYAPCO) an exemption from certain requirements of 10 CFR 20, Appendix G, Section III.E, for tracking shipments of low-level radioactive waste that are not acknowledged by the recipient within 20 days after transfer to the shipper. The exemption extends the receipt acknowledgement 20-day time period to 35 days before CYAPCO will have to investigate and report on the status of a low-level radioactive waste shipment.
A total of twenty-four (24) intermodal containers were shipped on October 13, 2004, October 14, 2004, and October 28, 2004 and were originally manifested to be sent to the Envirocare of Utah disposal facility. The intermodal containers were shipped to a rail spur and loaded onto three (3) rail cars. The individual shipment numbers and the respective rail car numbers are listed on Table 1. CYAPCO receives daily tracking reports of all waste shipments shipped by rail for the Haddam Neck Plant site from the transportation vendor utilized for the shipments (MHF Logistical Solutions). The locations of the shipments are verified and the shipments are traced until their receipt. In this case, the rail cars were redirected during transit to the Alaron Corporation facility in Wampum, Pennsylvania in response to issues identified with similar materials shipped during the same period of time. The rail cars were received at the Alaron facility on the dates indicated on Table 1. The containers were inspected and based on the findings, the material was removed from the containers, repackaged, and is being shipped to the Envirocare of Utah disposal site by Alaron Corporation.
Since the shipments were redirected to and received by a licensed radioactive waste processing facility and the original containers have been emptied and their contents repackaged, CYAPCO considers the shipments to be complete. The documentation for the affected shipments has been annotated to indicate the change of shipment destination.
In accordance with site procedures, CYAPCO tracked the progress of the shipments to ensure compliance with the requirements of IO CFR 20 Appendix G as modified by the approved exemption. When CYAPCO determined the shipments had exceeded the 35 day limit, the carrier, MHF Logistical Solutions, was contacted to verify the shipments were being tracked and their location was known during the time period the shipments exceeded the thirty-five day time frame. At no time were the shipments lost or in an unknown location. This issue was documented in Condition Report CR-04-1632 and discussed with NRC Region I on December 9, 2004 during the weekly conference call.
Attached is a summary of the shipments (Table 1) which exceeded the time provided in 10 CFR 20 Appendix G as modified by the approved exemption. The summary includes the shipment identification numbers, shipment dates, and the dates of receipt at the Alaron Corporation facility.
T. B. Smith (NRC) to W. Norton (CYAPCO), Haddam Neck Plant - Exemption from Certain Low-level Waste Shipment Tracking Requirements of 10 CFR Part 20, Appendix GI Section 111.E dated October 14, 2004.
USNRC Region 1 CY-05-018 / Page 3 Should you have any questions regarding this submittal, please contact me at (860) 267-3938.
Sin cere I y,
Gerard P. van Noordennen Date Regulatory Affairs Manager cc: R. R. Bellamy, Chief, Decommissioning and Laboratory Branch, NRC Region I USNRC Document Control Desk
USNRC Region 1 CY-05-01 8 / Attachment / Page 1 Shipment Number Table 1 Total Days Prior to ReceiPt Date Rail Car Date Rec'd @
Shipped Number Alaron 2004-646 2004-647 I011 312004 GCCX 200008 1 I
/23/2004 41 10/13/2004 GCCX 200008 1 1 /23/2004 41
_ _ _ _ ~
1 2004-648 1
10/13/2004 I GCCE00008 1 11/23/2004 1
2004-651 2004-652 2004-653 41 1011 312004 GCCX 200008 1 1 /23/2004 41 10/13/2004 GCCX 200008 1 1 /23/2004 41 1011 312004 GCCX 200008 1 I
/23/2004 41 1
2004-649 1
10/13/2004 1 GCCX 200008 1 11/23/2004 1
Shipment Number 41 Date Shipped I
2004-650 I
10/13/2004 2004-658 2004-659 2004-660 2004-661 GCCX 200008 1 11/23/2004 I 1 O/'l4/2004 10/14/2004 10/14/2004 10/14/2004 41 12/21 /2004 1 2/2 1 /2004 1 2/21 /2004 12/21 /2004 68 68 68 68 I
2004-656 I
10/14/2004 1
2004-657 1
10/14/2004 1
2004-662 1
10/14/2004 1
2004-663 I
10/14/2004 Rail Car Number MHFX 51 6233 MHFX 516233 MHFX 51 6233 MHFX 516233 MHFX 516233 MHFX 51 6233 MHFX 516233 MHFX 51 6233 Total Days Prior to Recei t Date Rec'd @ P Alaron 12/21/2004 I 68 1 2/2 1 /2004 1 212 1 /2004 12/21/2004 I 68
USNRC Region 1 CY-05-018 / Attachment / Page 2 Date Rail Car Shipped Number 10/28/2004 MHFX 516215 10/28/2004 MHFX 516215 Table 1 (Continued)
Total Days Prior to Alaron Receipt Date Recd @
12/21/2004 54 12/21/2004 54 Shipment Number 10/28/2004 10/28/2004 10/28/2004 1
204-773 MHFX 51 621 5 12/21/2004 54 MHFX 516215 12/21/2004 54 MHFX 516215 12/21/2004 54 I
204-774 1
204-775 I
204-776 204-777 204-778 204-779 204-780 10/28/2004 1 MHFX516215 1 12/21/2004 1
54 10/28/2004 1 MHFX516215 I 12/21/2004 I 54
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10/28/2004 1 MHFX516215 1 12/21/2004 1
54