ML20027C612
| ML20027C612 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/02/1982 |
| From: | Kanga B GENERAL PUBLIC UTILITIES CORP. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20027C611 | List: |
| References | |
| 4400-82-L-0150, 4400-82-L-150, NUDOCS 8210260236 | |
| Download: ML20027C612 (4) | |
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GPU Nuclear h.
g g{
P.O. Box 480 Middletown, Pennsylvan,a 17057 i
717-944-7621 Writer's Direct Dial Number:
September 2,1982 4400-82-L-0150 Office of Inspection and Enforement Attn: Mr. Ronald C. Haynes, Director Region I US Nuclear Regulatory Punission 631 Park Avenue King of Prussia, PA 19406
Dear Sir:
Three Mile Island Nuclear Station, Unit 2 (M-2)
Operating License No. DPR-73 Docket No. 50-320 Inspection Report J-320/82-06
'Ihis is in response to Inspection Report 50-320/82-06 issued July 30, 1982. The response time specified in the Notice of Violation was extended by three (3) working days to September 2, 1982, as discussed on August 27, 1982, by Mr. S. D. Chaplin of GPU's M-2 Licensing staff and Mr. R. J. Conte, Senior Resident Inspector, M -1, USNRC (acting in behalf of the M -2 Senior Resident Inspector).
As discussed below, GPU takes exception to the Stat ment of Violation, nevertheless, substantial corrective actions have been initiated.
STATEMENT OF APPARDTP VIDIATION "As a result of the inspection conducted on May 12-28, 1982, and in accordance with the NRC Enforcement Policy (10CFR Part 2, Appendix C),
47FR9987 (March 9, 1982), the following violation was identified."
"10CFR71.5 prohibits delivery of licensed material to a carrier for transport unless the licensee complies with applicable regulations of the Department of Transportation in 49CFR Parts 170-189. 49CFR173.392(c)(1) states in part, ' Materials must be packaged in strong, tight packages... '."
" Contrary to the above, on May 5, 1982, the licensee delivered to a carrier for transport to the US Ecology burial site in Richland, WA, licensed material (LSA radioactive waste) in a container that was not a strong, tight package. It is noted that upon examination at the burial site, a 55 gallon drum used as a shipping container for licensed material (105.7 millicuries) was found open, and the contents of the drum were exposed."
"This is a Severity 1cvel III Violation (Supplement V.C.1)."
0210260236 820928 PDR ADOCK 05000320 r is a part of the General Pubhc Utikties System O
Mr., Ronald C. Haynes 4400-82-L-0150
RESPONSE
1his report identifies an apparent violation in that GPU allegedly delivered radinactive material to a carrier for transport in a container that was not a strong, tight padraga. This a: parent violation is based upon a May 5,1982, incident in Richland, Waslington, where one dre of a 1MI-2 ISA shipment was found to have a broken lid holddown ring. h lid of the drum had been lifted by the cr = acted contents. However, the contents were still contained by the polyethelene dr e liner and a radiation survey of the drum and trailer indicated no loose radinactive contamination.
thdesirable as this occurrence is, GPU disagrees with being cited for a violation. W violation appears to be that GPU did not deliver material to its carrier for transport in a strong, tight package. In the following discussion, GPU will dee nstrate that to the best of its ability, with the information available to it at the time, it did deliver material in a strong, tight package. h NRC citation seems-to be based on the fact that the container was fotmd open at the burial site, not as delivered for transport. Because we have deenstrated in the following discussion that the cxmtainer failed during transit due to no fault of GPU, we find the NRC argment coupling the container condition at the burial site with the container condition when delivered to the carrier to be without merit. In spite of our argument against the citation, as can be seen fr m the corrective actions taken, GPU has taken a very responsive attitude toward correcting a patentially imacceptable situation.
GPU believes that when the shipment left 1MI, the dre was in full ccupliance with all D0r rules and regulations including the above cited 49CFR173.392(c)(1).
However, during its transit to Richland, Washington, an equipnmt failure i
occurred in that the ring bolt lug broke which allowed the contents to force l
the lid off, thereby exposing the contents. GPU believes that this equipment failure was not avoidable by reasonable licensee quality assurance measures or management controls. It is, therefore, GPU's position that this situation i
is not a citable event based on 10CFR2 Appendix C.IV.A which states in part,
" Licensees are not ordinarily cited for violations resulting from matters not within their control, such as equipment failures that were not avoidable by reasonable licensee quality assurance measures or management controls".
All 1MI-2 shipnmts of radioactive material are processc.lin accordance with 1MI-2 Operating Procedures which have been approved by the Nuclear Regulatory Caumission. h main purpose of these Operating Procedures is to ensure empliance with all required Dor /NRC rules and regulations. In most cases, 1MI-2 Operating Procedures go beyond what is required by regulation.
D0r regulation (49CFR173.392) requires that an " exclusive use ISA shipnmt" be padcaged in strong, tight containers. Our procedures require the use of a D0r spec.17H dre which meets the more stringent requirements of a Type A container. This 1MI-2 procedural requirement far meaads that which is required by D0r. Each drum received a visual QC receipt inspection upon its arrival on site. In addition, the receipt acceptance criteria also includes the manufacturer's certification that the druns meet the DDI specification for 17H druns dtich is contained in 49CFR178.118-12. When the druns are picked up fra the Warehouse, the drum is again inspected and a Radinactive Material Package Routing Slip is developed for each drum. '1his form is a docunented history of each drun on site from the time it is picked up for use tmtil it leaves the island for burial.
Mr. Ronald C. Haynes 4400-82-L-0150 For the drtan in question, the ring bolt and the drtun closure were visually inspected three separate times by Waste Shipping and Disposal personnel; once when the drum was picked up frcxn the Warehouse, again when the drtrn was picked up after loading in the Protected Area, and finally just prior to loading on the vehicle for shipment. h ring bolt and drtxn closure were found adequate after each inspection. Prior to release of this sh!pment it was examined by onsite NRC I&E personnel and the shipment was found to be acceptable.
When the shipment left the site, based upon doctanent;ed inspection and supported by NRC review, the drian ring was secure on the drtun. GPU believes it was in full ccxrpliance with 10CFR71.5(a) in that licensed material which fully couplied with DDT requirements was delivered to a carrier for transport to a waste disposal facility.
Upon arrival at the consignee (the waste disposal facility), an inspector for the state of Washington noted a problem with drtun ntunber 82-D-II-77.
After notification of the problem, GPU Nuclear began a cmplete and thorough investigation of the incident. This investigation uncovered the following information:
The verbal notification GPU received, that the lid ring had a faulty lug to ring weld, was inaccurate. h failed couponent was the lug and not the lug to ring weld.
The failed lug was made of low carbon sintered iron powder and not dropped forged as required in 49CFR178.118-12.
h use of sintered steel lugs in lieu of dropped forged lugs was authorized by the Association of American Railroads, who is DOI's agent and the approval authority for DOT spec.17H drians.
A failure evaluation of the broken drtan ring conducted by the GPUN Laboratory in Reading, PA, concluded that the reason for failure was the use of lugs made from sintered steel.
Prior to this occurrence, GPU had no knowledge of or reason to suspect a l
problem with sintered steel lugs since GPU has shipped 2,900 55 gallon drtans since January 1981 without a similar incident, GPU has received no NRC notification in the form of I&E Notices, Circulars, or Bulletins that such a material problem may exist, and GPU was not aware of anyone else having problems with this material.
Since the failure was due to the lug material and the lug material was approved for use by D0r's agent, the incident should be considered as an equipment failure which is beyond, as exenplified above, reasonable licensee quality assurance measures or management controls, h refore, GPn believes this event is not a citable offense as,provided for in the " General Policy and Procedure for NRC Enforement Actions' (10CFR2 Appendix C).
Even though GPU believes this is not a citable occurrence, this is an undesirable condition and steps have been taken to avoid similar occurrences with shipments of TMI-2 ISA radwaste, h se include:
All 55 gallon 17H drtan rings are on QC hold until they can be e
replaced as described in the following item.
r Mr., Ronald C. Haynes 4400-82-L-0150 All dr m rings will be replaced with rings which have drop forged lugs welded to the closure ring on all four sides as opposed to the nomal three sided weld.
All new dr m P.O.'s will specify the above closure rings.
If you have any additional questions, please contact Mr. J. E. Iarson of my staff.
- ely,
[
B. K.
ector, 'IMI-2 BKK/SDC/jep CC:
L. H. Barrett, Deputy Program Director
'IMI Program Office Dr. B. J. Snyder, Program Director
'IMI Program Office Sworn and subscribed to before me this 2nd day of September,1982.
h sh sa s C e es u s A tta spa Notary Pub Mc DARLA JEAN BERRY. NOIARY PUBLIC MIDDLEIOWN BORO. DAUPHIN COMn MY COMMIS$10N EXPIRES JUNE 17,1985 M em t.e, Pennsvivania Assoaation of Notanes l
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