WCS - WASTE CONTROL SPECIALISTS

April 6, 1998

Mr. Ralph Johnson
TRCC Region 7
Waste Program
3300 N "A" Street, Building 4
Suite 107
Midland, Tx. 79705-5404

Re: Spill of K061 material onto the asphalt apron adjacent to the rail spur on April 2, 1998.

On April 2, 1998 approximately 0.34 cubic yards of emissions control dust was spilled onto the asphalt to the south of the rail spur. The area in which the spill occurred was a radioactive work area operating under the control of GPI, a licensed radioactive waste handler.

Reports were made to the Texas Department of Health, The National Response Center and the TNRCC. These reports were not required but was thought it was best to take conservative approach and report as a courtesy to the listed regulatory agencies.

Though the spill exceeded the ten pound Reportable Quantity limit, it was confined to a controlled work area and occurred in tbe presence of those personnel who were qualified to perform the clean up. The definition of a Release provide in 40 CFR 302.3 (Reponsible Quantities, Definitions) excludes any spillage that is confined to a work area. Additionally, the WCS permit (#50358) section B.1 states that the railroad container unloading facility shall be operated and managed to prevent the release of any hazardous waste beyond the zone of engineering control this material was confined to the zone of engineering control and was immediately cleaned up.

We have attached a report from GPI that provides details describing the incident and clean up effort. If there are any questions regarding this matter please call me at 505-394-4300.

Respectfully: Waste Control Specialists, LLC

[signed] Pat McCarl Environmental Manager

[signed] Richard Grondin Facility Manager

cc: Ron Hance, WCS

Operating Record, WCS

Walter Cunningham, GPI

Philip Shaver, Texas Dept of Health


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To: Walter Cunningham, GPI Program Manager, VP Waste Managment Services
From: Tony Mason, CHP, Project Manager
Date: April 3, 1998
Subject: Spill of K061 dust at the Waste Control Spectalists, LLC (WCS) Facility during project 98022.

On April 2, 1998, a 20 yd³ roll-off container was filled with K061 dust (contaminated with approximately 40 pCi/g Cs-137) transfered from rail cars located at the south rail spur posted work area at the WCS facility. The container was covered with plastic and the plastic duct taped onto the container. The bows and tarp lid for the container were secureded with belts, screw-bolted brackets, and bungee cords as supplied with this type of container. The container was smeared and dose rated for release from the work area. During transfer onto a WCS roll-off container (at approximately 1315 hours), the load of K061 dust inside the container shifted and approximately ten cubic feet of material spilled from under the back side of the lid onto the asphalt surface.

GPI personel were in the work area and immediately responded. The container was made horizontal by the WCS truck driver to prevent further spillage and the K061 material was covered with plastic sheeting weighted with sand bags to control dispasion. The fact that the spill occured leeward to the wind break containment and GPI's immediate response minimized dispersal of the material outside the approximately 10'x10' area of the spill. No spread of material into the air or further onto the asphalt was visible. GPI personnel contacted a nearby WCS employee who contacted the project manager and the WCS facility Operations Manager.

GPI personnel maintained control of the area while dry wiping the back of the roll-off container, shoveling the material into two 55 gallon drums, and vacuuming all surfaces The back 10 feet of the roll container was covered in plastic sheeting and duct taped in place to prevent further release of material. The K061 was removed from all surfaces and contained within approximately one and one half hours after the occurence. The K061 residue on the asphalt was cleaned by a combination of low pressure spray and vacuuming with a squeegee attachment into a HEPA filtered vacuum.

WCS contacted the National Spill Hotline, Texas Natural Resource Conservation Commission, and the Texas Department of Health (Bureau of Radiation Control) at approximately 1430 hours.

The area and roll-off container were smeared for radioactive material and all results were not significant above background. Results from the air sample in the work area during the time of the spill were not significant above background. Dose rates in the area were 4-5 uR/h which is the normal background for the area. GPI personnel wore tyvek protective clothing and gloves during the cleanup. No external or suspected dose to personnel has occurred as a result of this incident. Neither GPI personnel in the area nor WCS personnel outside the area appeared to risk intake of the K061 dust. GPI personnel will have metals testing and bioassay for radionuclides at the concluston of the project as scheduled prior to start of work.

A heavy metal plate was screwed onto the back of the container through the tarp lid to provide support during transfer in order to prevent further release of material. The container was transferred by WCS to a storage location without further incident.

The incident was unexpected because of previous transportation evolutions with four previous roll-off containers using the same roll-off transfer truck, personnel, supplied lids and plastic sheeting underneath. The response of all GPI and WCS personnel was appropriate and deserves recommendation for quality and speed of response. Further events of this type will be avoided by securing the back of the lid to the container by means in addition to those provided as standard with the container.

cc: William Possidente, GPI Health and Safety Manager, Radiation Safety Chairman (acting)

Gutierrez- Palmenberg, Inc