IR 05000289/1977020
| ML19256D332 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/22/1977 |
| From: | Knapp P, Mcclintock R, Plumlee K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19256D314 | List: |
| References | |
| 50-289-77-20, NUDOCS 7910170838 | |
| Download: ML19256D332 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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0FFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 77-20 Docket No. 50-289 License No. DPR-50 Priority _ --
Category C
Licensee:
Metrooolitan Edison Company P. O. Box 542 Reading, Pennsylvania 19603
Facility Name:
Three Mile Island I
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Inspection at:
Middletown, Pennsylvania i
Inspection conducted: June 13,-15 and 20 & 21,1977
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Inspectors:
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h1 7/2.2-/77
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'Kh rl umlea, Radiati 5 egiali t, F&MS Branch 'date signed (3 b
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Robert O. McClintock, Chief, Materials Radiological (.hte/ signed
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Konald L. Nimitz, adlation bpeClalist (Co-op),
date signed FF&MSJpnch
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W2%)11 Dr.Cqrl pallina,InvestigationSpecialist d$te ' signed
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7/u/7 7 Approved by.
Fet'ifrDnapp, cfiief,ption Support Section fate' signed FF&MS Branch V
Inspection Summary:
Inspection on June 13-15 and 20-21, 1977 (Report No. 50-289/77-20)
Areas Inspected:
Special, announced inspection of radioative liquid waste solidi-fication, packaging and shipping following a telephone notification of waste con-tainer leakage that occurred on June 13 and 14,1977, during transport of TMI waste (intended delivery to Sheffield, Illinois burial site-turned back in the Clinton county, Pa. area).
The inspection involved 43 inspector-hours on-site by four NRC inspectors.
Upon arrival, areas where work was being conducted were examined to review radiation safety control procedures and practices.
Results:
Of the three areas inspected three apparent items of noncompliance were identified (infractions-failure to adhere to 'our areas of procedures, and lack of procedures-Paragraph 8; failure to label con;.ainers of radioactive material-Para-graph 9.b; and failure to post a high radiation area-Paragraph 9.a)
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791017 9 Region I Form 12 (Rev. April 77)
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DETAILS
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1.
Persons Contacted
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a.
Metropolitan Edison Company Personnel
- W. Cotter, Supervisor of Quality Assurance
- R. Dubiel, Supervisor of Radiation Protection and Chemistry l
E. Fuhrer, Operations Engineer R. Klingaman, Manager, Generation and Engineering
- G. Kunder, Supervisor of Operations, Unit I R. McCann, Radiation Protection Foreman
- G. Miller, Site Superintendent J. O'Hanlon, Unit I Superintendent J. Smith, Foreman, Rad-Waste Operation P. Velez, Radiation Protection Foreman b.
State of Pennsylvania Personnel T. Gerusky, Director, Pennsylvania Bureau of Radiological-()
Health (PBRH); and member, Hazardous Substance Transportation Board (HSTB)
J. Shaw, Executive Secretary, HSTB L. West, Investigator, HSTB c.
Other Personnel
i G. Costomiris, Gilbert Associates
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I D. Ferrigno, Gilbert Associates K. Gablin, Vice President, Protective Packaging, Incorporated
- denotes those contacted during the exit interview, conducted by telephone on June 16, 1977.
2.
Licensee Description of Shipment Leakage.
The licensee representative stated that radioactive waste shipment no. 77-60 departed the TMI site at 3:25 P. M. on June 13,1977, and these events followed:
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a.
The vehicle traveled northbound on Pa. Route 441, Interstate Route 83 and 283, Pa. Route 15, and westbound on Interstate Route 80 to a highway rest area in Clinton County, Pa. (site 34 between exits 28 and 29).
The total highway travel was 90 miles to this point.
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b.
The driver made a routine check of the vehicle and tires and j
found a drip of liquid from the trailer ~ transporting the eight waste cor.'ainers, at 7:30 P. M.
The shipment did not proceed further.
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c.
The driver contacted various individuals by telephone inclu-i ding the TRISTATE Motor Transit dispatcher at Joplin, Mo. and the TMI shift supervisor, by 8:06 P. M.
d.
The TMI representatives organized a team to check the shipment and notified the Director of the PBRH by. 8:40 P. M. and the j
NRC R:I duty officer by 9 P. M.
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e.
The Director of PBRH arrived at the Rest Area before 11:15 P.
I M. and the TMI team departed from the Harrisburg area at 9 P.
O M.
and arrived at the Rest Area at 11:15 e. M. on June 13
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1977.
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f.
After taking precautions to preclude any additional leakage, l,
and having decontaminated the point where water had dripped on
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'the paving at the rest area, there was concurrence that the shipment, should be returned to TMI.
The rest area pavement-was wet over less than a one square foot area; and there was no removable contamination; the radiation level at contact was 0.16 mrem /hr as left.
Barricades erected by the Highway Patrol were then removed.
(The inspector noted that the rest area is the responsibility of Pennsylvania authorities and that the condition as left appeared to be within the accep-table limits stated in Table I of Regulatory Guide 1.86 for release of an area to unrestricted use.
g.
The transport vehicle departed the rest area at 15 minutes before 1 A. M. on June 14, 1977, and arrived at the TMI site at 3:50 A. M.
Several checks for any recurrence of leakage were made enroute.
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h.
The licensee represen.tative stated to the inspector that a quart of liquid had leaked from container no. 77-C-58 into the trailer when he checked the shipment at 11:15 P. M. on June 13, and there did not appear to be any other leak.
i.
A subsequent sample and analysis of liquid leaking from con-tainer no. 77-C-58 is described in Paragraph 5.
Based on this information it appears that a quart of liquid contained 105 microcuries of radioactivity and at least that amount had leaked into the transport trailer and a detectible amount
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dripped on the Rest Area pavement.
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3.
Observation of Decontamination Results, Return Shipment, and Offloading of Shipment a.
After the transport vehicale started the return trip, inspec-tors surveyed the point in the rest area where the transport vehicle had stopped.
The inspectors found that the release of this area for unre-stricted use appeared to be acceptable as described in Para-graph 2.f.
b.
An inspector subsequently interviewed the Director of the PBRH
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a.nd the Director stated that a gallon of liquid appeared to have leaked into the trailer when he checked it at the rest
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area, and a small area under the trailer was wet which he
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described as one square foot in area.
Subsequent observation by an inspector on June 15 during offloading indicated that at that time in excess of a gallon of liquid had leaked into the trailer, however four containers appeared to leak on June 15.
(Tape had been applied over the
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leak in container no. 77-C-58 to prevent leakage, before leaving the rest area.)
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c.
Inspectors followed the return of the shipment and observed, when the transport vehicle reached the TMI site at 3:50 A. M.
on June 14, 1977, that there appeared to have been no recur-rence of dripping, that the protective covering on the trailer appeared not to be disturbed, and that the incensee secured the vehicle on arrival at the TMI site.
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d.
Later on June 14, the licensee placed the transport trailer containing shipment no. 77-60 indoors at the fuel handling.
building loading dock and the shipment was offloaded on June 15.
The inspector observed that smears were taken of four leak areas on four different containers during offloading and the reported removable contamination was 30,000 to 93,000 DPM on these smears.
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e.
Smears of the dry underside of the trailer and the spare tire,
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which was cradled under the trailer were reported to be >i3,000 l
DPM on June 14.
The licensee representative stated that the trailer will be decontaminated before it is returned to high-
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way use.
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4.
Observation of Draining of Containers on June 20 and 21,1977
An inspector also witnessed the draining of each of the eight containers of shipment no. 77-60 on June 20 and 21 and the follow-ing amounts of liquid were drained from these containers, which had
been shipped as containers of' solidified waste.
The licensee
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representative stated that each container had been drained at least l
i two times over a period of two or three months prior to June 13, 1977, and that each was drained again before being loaded for
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transport offsite.
There were no records of the amounts drained on
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any previous efforts to drain these particular containers, however, the oral statement was that up to 60 gallons had been. collected
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where a given container was drained several times over a three month period.
Container No. Manufacturer's Volume Liquid Coments Serial No. _
Drained (L)
pH (see below)
77-C-51 1164 DF 48 1/2 1.2 A
77-C-52 3022 DF none NA B
77-C-57 3025 DF 46 1/2 0.95 B,C 77-C-58 306 DF
1.08 B
77-C-63 1153 DF 1/2 Not measured A
77-C-64 305 DF
1.33 A
77-C-65 3010 DF
1.18 A
77-C-66 3012 DF
4.63 B,C 1454 248
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Connents :
A - these containers did not appear to leak at any time during the inspection.
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B - these containers appeared to leak (observed June 13, when this shipment was found to drip, or during offloading on June 15, 1977.
C - these containers appeared to have been patched prior to June 13, 1977 and the licensee repre-sentative stated that these patches were over leaks'known prior to June 13 (Container no. 77-C-57 appeared to leak at a patch).
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Based on the above information at least 691/2 liters (about 18
gallons) of liquid appeared to be present in three containers that leaked and at least 64. liters appeared to be present in the four containers that did not leak.
Container no. 77-C-52 appeared to
leak at a point 2-in. above the bottom but efforts to drain the container did not draw off any liquid.
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5.
Activity of Liquid Leaked from Container No. 77-C-58 On June 14, 1977, a licensee representative obtained a 25 m1 sample (-)
of liquid that leaked from container no. 77-C-58 and obtained the
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following analysis.
Nuclide Activity (uCi/ml)
+or-Sigma
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Mn-54 5.90E-4 9.3E-5 Co-58 1.03E-2 1.3E-3 Co-60 1.06E-3 1.6E-4 Xe-133 4. 91 E-3 6.4E-4
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Cs-134 4. 91 E-2 4.6E-3
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Cs-137 5.38E-2 6.6E-3 Total 1.1E-1 Assuming that a quart (0.95 L) leakea into the trailer (Paragraph
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2.h), this liquid appears to have contained 105 uCi(+ 8% std dev.)
of radioactivity that was released into the trailer.
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6.
Quantities & Radiation Levels of the Shioment and Individual Containers The following information was obtained from shipping records.
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a.
Contents of shipment no. 77-60 (bill of lading dated June
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13, 1977
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Number of Containers - 8 Volume 0 50 cu. ft. ea. - 400 Net weight of 8 containers - 25,000 lbs Total contained activity - 4,698.23 millicuries
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b.
Contents of individual containers (two survey records dated June 8,1977-part of shipping papers
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Physical mrem /hr mrem /hr quantity l
Container No.
State at surface at 3 ft.
(millicuries)
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Solid 150
242.74 77-C-51 77-C-52 Solid 130
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77-C-57 Solid
8 190.8 l
77-C-58 Solid
10 190.8 77-C-63 Solid
60 9.2
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77-C-64 Solid 100
1274.
77-C-65 Solid 100
1274.
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77-C-66 Solid 100
1274.
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The licensee representative stated that these quantities nre i
calculated from concentrated waste sample analyses and a con-servative estimate that 262 gal. (i.e. 75% by vol. or 106 ml)
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of concentrated waste was placed in each container for solidi-fication.
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7.
Quantity of Activity in Liquid Drained from Each Container
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It appears that the followi_ng quantity of radioactivity was present in liquid drained from each container on June 20, and 21,1977.
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Container Liquid Concent-Quantity l
No.
Volume (m1)
ration *(uCi/ml)
(millicuries)
i 77-C-51 48,500 0.24 11.64 77-C-52 0.24
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77-C-57 46,500 0.19 8.84 77-C-58 11,000 0.19 2.09 77-C-63 500 0.009 0.005
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77-C-64 7,000 1.27 8.89 77-C-65 8,000 1.27 10.16
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i 77-C-66 12,000 1.27 15.24 i
- Apparent concentration of concentrated waste storage tank liquid transferred into the shipping container.
The inspector noted that the liquid removed from each of six shipping containers apparently contained in excess of a millicurie of radio-activity and could not be considered to be a limited quantity exempt from the requirements of 49 CFR 173.393 (g)(2) & (3) that absorbent material must be provided to absorb at least twice the (q volume of radioactive liquid contents of containers of liquid
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radioactive material and that a secondary container must be provided, for a shipment of such materials.
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8.
. Review of the Solidification and Packagina of Shipment No. 77-60 l
i The Technical Specifications i.n section 6.8 " Procedures" require that written procedures be established and maintained that r.eet or
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exceed the requirements and recommendations of Sections 5.1 and 5.3 of ANSI N18.7-1972, subsection 5.3.7 of which requires written procedures for the control and management of radioactive waste.
a.
TMI Administrative Procedure 1003 " Radiation Protection Manual" requires in section 6.3.1.3 that all shipments of radioactive materials will comply with DOT Regulations.
1.
The licensee representative stated to the inspector that
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it had not been elected to consign shipment no. 77-60 as Low Specific Activity (LSA) radioactive material and the inspector noted that the containers and the vehicle were not marked LSA and the shipping papers did not state that the consignment was LSA rraterial.
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The inspector noted that, since the shipment was not con-signed as LSA material it would have been necessary to package in compliance with the requirements of 49 CFR 173.393 (g)(1), (2) and (3) for leak-resistant and corrosion-resistant inner containers, enough absorbent material to absorb twice the volume of radioactive liquid contents,
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and a secondary containment vessel adequate to prevent
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loss or dispersal of the radioactive contents under normal conditions of transport.
(A different list of requirements apply to LSA shipments).
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The licensee's failure to take these required precautions.
j apparently resulted in the release of 105 microcuries of
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radioactive liquid into the trailer during transport over i
public highways on June 13, 1977, and a detectible amount l
of radioactive liquid dripped onto the Rest Area pavement.
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2.
The inspector noted that to comply with the requirements
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of 49 CFR 172.100,-172.402,-172.403 (g)(.?), and-173.310 j
(a)(1) and (2) these containers would have been labeled or. marked to show the proper shipping name of the hazardous
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material, the Transport Index, the gross weight of each
container, and the words." TYPE A" in letters at least
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1/2-inch high, and multiple labeling or marking would
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have been provided on each container.
The inspector noted that noria of these containers was marked " Radioactive LSA" or " Radioactive NOS"; that the six containers having transportation indexes greater than 10 were not marked to show this; that the gross weight was not marked on any container; and that although the words " Type A" were handwritten on the Radioactive Yellow-III labels the information was difficult to find because the letters were less than 1/4-inch high and not 1/2-inch high as required.
Two containers did not have multiple Radioactive Yellow-III labels and this appeared to be the result of one of the two labels on each container falling
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to the floor of the trailer during shipment or offloading.
The inspector noted that the licensee's apparent failure to mark and label those containers in strict compliance with the DOT Regulations could have resulted in errors during transport or at the destination of the shipment.
(Other labeling requirements are given in pargraph 9)
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3.
The inspector noted that to comply with the requirements of 49 CFR 173.393(j) specific instructions for maintenance of vehicle exclusive use controls would have been given in the shipping papers for shipment no. 77-60.
The survey record showed that six of the eight waste con-tainers each had a Transportation Index greater than 10 (and the aggregate transport index exceeded 50) but the shipping papers did not specify instructions for maintenance of exclusive use controls by the carrier and this omission i
could have resulted in errors during the transport of these containers.
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b.
Procedure 1104-28 " Solid Radwaste Disposal System-Packaging and Solidification of Solid and Liquid Radwaste" in procedure section 1104-28.2.1.1 requin es that the Shift Formean shall
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enter instructions for the sampling, analysis and packaging of
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batches of waste from either the Spent Resin Storage Tank,
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l Used Precoat Tanks or Concentrated Waste Storage Tanks in the
" Process Instruction and Data Sheet" prior to the initiation
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of any transfers from these tanks and that the operator (s)
performing these function (s) shall enter all subsequent data concerning sampling, analysis and packaging of a batch of solid waste.
Further statements concerning entries and changes to the " Process Instruction and Data Sheet" appear in procedure sections 1104-28.2.1.1,-28.3.1.b,-28.3.2.a and-28.3.4.a and in sections 1104 -29.24.4.2.4,-29.24.4.2.6, and-29.24.4.3.2.
The licensee representative stated that no " Process Instruction and Data Sheets" had been prepared prior to, during, or after the transfer of concentrated waste from the concentrated waste storage tanks or in any connection with the packaging of the eight containers of shipment no. 77-60 or any other container of solidified concentrated waste processed up to that date (June 14,1977).
' The inspector stated that the transfer and packaging of radwaste without the rquired instructions prior to these operations, and the failure to maintain the required records of the sampling, analysis and packaging were apparent instances of noncompliance with the above procedures which could result in errors in the solidification, packaging and shipping of radwaste as well as failures to identify any errors.
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c.
Procedure section 1104-28.3.1.a requires that the Supervisor of Operations, or his designee designates on the applicable data log that a sufficient amount of radwaste has accumulated
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in a specified tank to warrant initiation of the packaging operation.
The licensee representative stated that no such data log was maintained.
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i The inspector stated that the failure to log the required in-
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formation was an item of apparent noncompliance with the above i
procedure which could have resulted in errors in radwaste
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operations.
d.
Adherence to Radiation Work Permit (RWP): The licensee "Radi-ation Protection Manual" in section AP 1003-2.10 " Radiation Work Permit" requires enforcement of all the radiation con-trols and adherence to the instructions listed on the Radi-l ation Work Permit, and states that Radiation Work Permits are required for all work or entry in areas that could cause ()
exposure in excess of 5 mrem /hr or greater than 2200 DPM/100 J
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cm2 Beta-Ganma.
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l During the inspector's observation of the draining of shipping containers on June 21,1977, at 2 P. M., in the area described l
in Paragraph 9 which was at that time posted as a High Radi-ation Area and a Contaminated Area and contained areas accessible
to personnel wher in exposure was possible up to 150 mr/hr and 50,000 DPM/100 cm of removable Beta-Gantna contamination, the i
l inspector observed that an individual entered (who had crossed two ropes bearing the above signs) without the survey instru-
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ment, shoe covers, and gloves required by the applicable RWP (no. Il92-standing RWP for routine entries).
The inspector identified this as an apparent item of noncom-pliance with the above requirements, which could cause un-necessary exposure to tl.m individual involved.
e.
Procedures for Draining and Patching of Solidified Radwaste Containers:
the licensee representative stated that no record was available for inspection that individually identified any of the containers composing shipment no. 77-60 as having been drained; that there were no written approved procedures for draining these containers before June 14, 1977; and that there were no written approved procedures for patching containers that leaked, prior to that date.
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The inspector observed that the Rad-Waste Operations Foreman's logbook contained entries indicating that work had been done but did not identify the individual containers involved or any
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criteria by which the work was accepted.
The inspector identified the lack of written approved procedures for draining and patching of these solidified radwaste containers t
as an apparent item of noncompliance with the requirements of Technical Specifications section 6.8.1, which could result in errors in draining containers and in repairing containers that
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were known to leak.
9.
Posting of a High Radiation Area and Labeling of Solidified Radioactive Waste Containers After observation of the completion of the offloading of shipment no. 77-60 prior to 3:00 P. M. on June 15, 1977, the inspector requested the licensee representative to arrange for a tour of the
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room in the Auxiliary Building where these eight containers had been stored as these were offloaded.
This room was at a lower
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level than the loading dock.
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a.
Posting:
On entering this room, after 4:00 P. M., the inspector requested the licensee representative to show him the "High Radiation Area" posting for the area.
The sign was then found facing a wall, and the licensee representative stated that the stand and rope supporting the sign had been moved out of the way earlier in the day to clear the entrance to the room for passage of the forklift used to store the eight containers of i
waste shipment no. 77-60, and apparently the sign was overlooked
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at the completion of that job. The inspector observed that a
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rope and a " Radioactive Material Area" and " Contaminated Area"
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sign had been placed across an outer area, but no "High Rad-fation Area" sign was visible and the area had apparently been
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i only intermittently attended during offloading (most of the dayshift) and had been unattended between 3:00 P. M. and 4:00 P. M. on June 15, 1977.
The inspector requested the licensee representative to survey the area, and the licensee's measurements indicated 150 mr/hr at 12-inches distance from each of two solidified waste containers that were not part of shipment no.
77-60 and had not been moved either during the day or following a previous survey known to a licensee representative.
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The inspector identified the failure to conspicuously post this high radiation area as an item of noncompliance with the require-ment of 10 CFR 20.203(c)(1) which could cause an unnecessary exposure to personnel.,(77-20-02)
b.
Labeling: The inspector noted that neither of these two containers were labeled as " Radioactive Material" or otherwise individually identified as radioactive by any visible sign or posted record.
The inspector noted that the entrance of the antiroom was posted at a distance of 40 feet from these containers, as described above.
The inspector identified the failure to label each of these two containers with a clearly visible label identifying the radio-active contents as an item of noncompliance with the labeling requirement of 10 CFR 20.203(f) " Containers", which could cause an error in managing these containers.
(77-20-03)
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10.
Exit Interview
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The inspector reviewed the scope and the findings of the inspection with the licensee representatives by telephone on June 16,1977, as indicated in Paragraph 1.
The inspector identified the examples of failure to adhere to procedures and the lack of procedures, described in Paragraph 8, as an item of
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noncompliance with the requirements of Techniul Specifications Section
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6.8 " Procedures" (77-20-01); and the failures to post a high radiation
area and to label containers, described in paragraph 9, as items of noncompliance with 10 CFR 20.203(c) and (f).(77-20-02 and 77-20-03).
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