ML20135A297

Responds to NRC Re Violations Noted in Insp Repts 50-277/85-27 & 50-278/85-25.Corrective Actions:Personnel Sent to Burial Site to Investigate Incident & Truck Unloaded,Inspected & Reloaded to Verify Shipment Integrity

ML20135A297
Person / Time
Site:	Peach Bottom
Issue date:	08/28/1985
From:	Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8509100088
Download: ML20135A297 (4)

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,r 1-PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 SHILLOSL.DALTROFF auW!ic","J"Nia August 28, 1985 Docket Nos. 50-277 50-278 Inspection Report Nos. 50-277/85-27 50-278/85-25 Mr. Thomas T. Martin, Director Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Martin:

Appendix A to your letter dated July 29, 1985 addresses activities which were identified by Inspection Report No. 50-277/85-27; 50-278/85-25 as possible violations with respect to Peach Bottom Atomic Power Station. Our response, along with actions taken, are discussed below.

Restatement of Violation:

"10 CFR 71.5 prohibits delivery of licensed material to a carrier for transport unless the licensee complies with applicable regulations of the Department of Transportation in 49 CFR Parts 170-189."

"49 CFR 173.425(b)(1) requires shipments of low-specific activity materials be packaged in strong, tight packages so that there will be no leakage of radioactive material under conditions normally incident to' transportation."

" Contrary to the above, on May 30, 1985, a drum containing low specific activity shipped by the licensee was received at Richland, Washington, and was not packaged in a strong, tight package. Specifically, licensee's drum No. S-146-85 was found to have a hole in it."

This is a Severity Level III violation (Supplement V).

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Mr .eThomas T. Martin August 28,.1985 Page 2

- Admission of Alleged Violations i We agree that a puncture hole was discovered in drum No. S-1 146-85 at the Richland, Washington, site and that the drum originated at the Peach Bottom Atomic Power Station.

Reason-for Alleged Violation:

Following notification, a Peach Bottom representative was i sent to.Richland, Washington, to investigate and review the (

details regarding this event with burial site personnel.

Our representative investigated and was informed that the -

shipment arrived at' Richland, Washington, with all internal 1- bracing intact. The puncture was located just above the j mid-plane of the drum and was facing forward in the trailer.

! A detailed inspection of .tlue subject drum (S-146-85) also j showed some deep dents below the lid-ring.- We noted that

., some of the deep dents (Which -did not puncture the drum) closely resembled the lid-ring bolting ears that stick _out from this type drum in such a way that, if jammed against

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another drum, could have caused . the same type tear or

-puncture.. This damage could have been caused by a severe i jar during transportation or other -mishandling type problem j after the truck . left the Peach Bottom site.

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! Investigation at the Peach Bottom site included inspection j of the lifting and handling devices,- the capping tool, a

review' of our loading and integrity ' inspection' procedures, i and interviews with the crews involved in the loading operation of - this - trailer. This investigation disclosed j that' for this particular shipment, .each shipping container F was clearly.and thoroughly inspected for integrity as well

. as other requirements such as correct placarding, shipping

. papers,. labeling and radiation measurements. hk) puncture holes 'were identified during the inspection and loading operation. ,

- Our exhaustive- investigation of this event has Enot

identified - a scenario Which could cause .tdue puncture. No evidence has .been found Which would indicate that the puncture occurred before the . drums were11oaded 'on the )

trailer.

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-Mr. Thomas T.: Martin August 28, 1985 Page 3 Significance of Violation:

The significance of the puncture hole was minimal because the drumz Wh i ch was punc t ured contained oils with low 4

specific activity . that had been solidified with concrete forming a monolithic free standing block inside the drum.

The drum was used as the casting . form for solidification.

The' intent of'49-CFR 173.425(b)(1), which requires strong,.

tight packages, is to avoid leakage.during transportation.

The type of drum which was used as the shipping container met the criteria for integrity and leakage. This type drum has been the standard -in the industry for many years and in the past has been used almost exclusively for packaging of hazardous and. radioactive waste for transportation. They.

are designed to be' tight and strong and have had extensive-generic ; testing of their design in orderThey to meet strict were purposely.

Department of Transportation criteria.

used by Philadelphia Electric Company because- of their strength and leak tightness during transportation.

The material in the drum. remained monolithic and the contents remained in .the drum even though the container integrity was breached, thereby meeting the intent of the regulations for avoidance of leakage.

Corrective Actions Taken to Avoid Future Noncompliance Immediately after the alleged. violation was reported Philadelphia Electric Company sent Peach Bottom personnel to the burial site in. Washington' ' State to investigate the incident. Also, as a precautionary step,.a loaded truck-i ready for shipment from Peach Bottom was. unloaded, 4

inspected,- and reloaded to verify- integrity .of the shipment.

The ~ site personnel responsible ' for : handling radioactive waste were reminded of'the.importance of thorough l- inspection of all shipments. for integrity along with l

l careful and strict compliance with procedures. To ensure

'  : continued emphasis on the importance of proper handling, t

~ instructions have been issued toithe labor support -

contractor to. provide instructions to personnel assigned to-4 the loading operations.. Further, we'. increased controls in-F this area 'by revising the truck loading procedure and .the.

procedure which controls solidification, packaging, and

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l , inspection of liquid and materials in preparation for shipmen t. . The' revision to the. truck' loading procedure-now j

includes precautionary statements Which will not' allow 'the l fork 'lif t operator to use one container' to = push 'another, or

' allow the ' fork lift tongs to touch another container. ~The

.responsibilitylof . the QC : inspectors has been increased to

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), v Mr.. Thomas T. Martin August 28, 1985 Page 4 ensure that the integrity of the drums is not compromised during the loading of the truck.

Additionally, in order to reduce the likelihood of dents caused by lid-ring bolting ears contacting neighboring drums during the shipment, the truck loading procedures will be revised to orient drums on the truck with the lid-ring bolting ears protruding into the space between adjacent drums. A QC inspection of the loaded truck will check this orientation. This revised procedure will be implemented by September 30, 1985.

Date When Full Compliance Will Be Achieved:

The state of Washington, following informal . negotiations and telephone discussions with the Peach Bottom site involving .tlue incident and our site procedures, reinstated Permit #5625 effective June 17, 1985_ authorizing Philadelphia Electric Company to use the commerciel low-level radioactive waste disposal site at :Richland.

Philadelphia Electric recognizes that continued authorization to transport and. dispose - of - waate depends on strict adherence to procedures used for compliance to DOT /NRC regulations. Philadelphia Electric intends to maintain such compliance by strict adherence to these procedures, regulations, and inspections..

Philadelphia Electric Company believes that1 full compliance to regulations has been provided. .All corrective action associated with this event will be achieved by September 30,'1985. ,

Should you have any questions or require additional information, please do not hesitate to contact us.

Very truly-yours,

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DPH vdw cc: Dr. T. E. Murley, Administrator, . Region I, USNRC T. P. Johnson, Resident' Site Inspector: