DOE/EH-0210 --- Issue No. 92-01 --- 06/92

Problems in Packaging and Transportation
of Hazardous Materials

BACKGROUND

The Department of Energy (DOE), in support of its weapons production and research and development programs, is a major shipper of radioactive and other hazardous materials. The regulation of offsite shipments of all hazardous materials is a function of the Department of Transportation (DOT). Certain aspects of some offsite shipments of radioactive materials to or from licensees are also a responsibility of the Nuclear Regulatory Commission (NRC). DOE is responsible for administration of facilities, which are responsible for implementing procedures to ensure safe facility operation and compliance with regulatory requirements, DOE Orders, and management directives. From 1989-1991, 36 incidents were reported at DOE facilities that involved the packaging and transportation of hazardous materials. A discussion of these incidents, information on upcoming changes to requirements, and recommendations follow.

INCIDENTS WITHIN DOE

Of the 36 incidents within DOE, 20 incidents involved a release of radioactive material; 7 incidents involved the release of a toxic chemical or gas; 5 incidents resulted in a fire or increased the potential for a fire; and 4 incidents involved criticality safety violations. These incidents were the result of regulatory noncompliance, procedural violations, and inadequate procedures. Although none of the incidents had a serious outcome, all of them jeopardized employees, the public, or the environment unnecessarily.

Regulatory Noncompliance - Potential for Radioactivity Release

A tritium leak was detected in a uranium trap loaded by one DOE facility and transferred to another DOE facility for calorimetric measurement enroute to an international destination. The uranium trap was a customer-provided container that was different from the DOE-owned uranium traps generally used for these shipments. Elevated levels of contamination were measured on internal surfaces when the package was opened at the intermediate DOE facility. The containment pot was immediately placed inside a glove box to prevent any contamination spread. The initial leak rate of tritium to the glove box was measured at 20 curies per hour. Investigation revealed that the leak was through the valve seat. A review of loading records indicated that the required post loading leak tests had not been conducted on the uranium trap because of the configuration of the container. All shipments with this type of uranium trap have been discontinued.

Violation of DOE Order - Radioactive Contamination

Radioactive contamination in excess of limits established by DOE Order 5480.11 was discovered on a classified component shipped between DOE facilities. The DOE facility receiving the shipment determined that the alpha plus beta activity was in excess of 6000 dpm for a 15 cm2 area. This exceeds the 5000 dpm/100 cm2 limit for fixed plus removable contamination established by the Order. A memorandum of understanding will be sought from the originating facility certifying the establishment of procedures to prevent recurrence.

Procedural Violations - Radiation Hazard

At one DOE facility, a Research and Development staff member moved some Co-60 sources through a controlled area without the participation of a radiation protection technologist (RPT). This violated a published facility procedure governing the onsite movement of radioactive materials between radiation areas. The staff member stated that he failed to enlist the aid of an RPT because he was not aware of the procedure. Results of the investigation indicate that the lack of adequate knowledge could be due in part to existing inconsistencies in procedure compliance from one facility to another and to less-than-adequate radiation worker training or retention of training. Management must emphasize to employees that procedures are designed to safeguard employees, the public, and the environment. Each individual is responsible for knowing and following established safety procedures.

Procedural Violations - Fire

While personnel were in the process of combining depleted uranium scrap for disposal, they opened a drum containing 69 kg depleted uranium; and the uranium began to burn. They quickly placed the lid on the drum and smothered the fire. Procedures required that the uranium turnings be shipped in oil to protect them from reaction with oxygen; however, the shipment did not have a protective layer of oil. Procedural violations in this case resulted in a fire and risk of personnel exposure to radioactive airborne particulates.

Procedural Violations - Toxic Fume Exposure

Bagged and sealed waste was placed in a waste dumpster compactor. During compacting, the compactor operator noticed a strong acidic odor and saw a liquid on the compactor platen and loading door. The operator stopped the compacting process and removed the suspect bag from the compactor chamber. He stated, "The pressure of one finger on the side of the bag caused liquid to squirt from the bag." The liquid was tested and identified as fuming nitric acid. The presence of this acid resulted in the exposure of the compactor operator to an acid/acid fume hazard. Three waste packaging criteria limitations were violated in this incident. Further investigation revealed that a poorly designed compactor exhaust system contributed to the acid fume problem. Corrective actions included modifying the procedures for handling waste and redesigning the filtered exhaust system to discharge outside the building instead of within the compactor room. This latter modification helps insure that personnel will not be exposed to harmful fumes, should chemicals be present in the waste. A stack monitoring system was also installed to monitor the discharge for radioactivity downstream of the HEPA filters.

Inadequate Procedures - Radioactive Contamination

A staff member unpacked a radioactive shipment inside a fume hood. The shipment had been packaged in a hot cell. The staff member wore the required protective clothing, and an RPT monitored the operation. Because there was higher-than-expected contamination present on the contents, the operation was stopped for reevaluation. An immediate personnel survey by the RPT did not indicate any detectable contamination outside of the fume hood. While surveying samples in another room, an RPT detected contamination on the staff member's laboratory coat. The contamination had also spread to the staff member's forearm and the sleeve of his personal clothing. Investigation of the incident concluded that personnel did not use sufficient caution to detect unexpected activity promptly or to determine the extent of contamination spread when unexpected activity was found. Lack of a specific procedure for unpacking this type of incoming shipment was a contributing cause. No specific procedure required that incoming shipments be unpackaged in the same class of facility (e.g., hot cell or glove box) in which they had been packaged.

FACILITY AND EMPLOYEE RESPONSIBILITIES

Each employee is responsible for full compliance with regulatory requirements. All DOE Orders are designed to protect the employee, the public, and the environment. All DOE facilities are responsible for implementing procedures that ensure the health and safety of their employees and for ensuring compliance with all requirements.

CHANGES TO REGULATORY REQUIREMENTS AND DOE ORDERS

Changes to Regulations

Regulatory requirements are subject to change, and facilities need to stay up-to-date at all times. An example of a major change to the regulations is the recently enacted Hazardous Materials-181, "Performance-Oriented Packaging Standards; Changes to Classification, Hazard Communication, Packaging and Handling Requirements Based on United Nations Standards and Agency Initiative." This change represents a significant revision to DOT regulations. Among other changes, the new regulations will phase-out many DOT specification packagings currently used to transport hazardous materials.

Compliance with all government regulations is mandatory. The Federal Aviation Agency levied a fine of $40,000 against an individual carrier for not attaching the proper shipping name, hazard class, identification number, and quantity of hazardous materials to a shipment. The pilot transporting the shipment experienced nausea and physical discomfort when this improperly labeled and packaged material leaked during flight.

Changes to DOE Orders

DOE Orders 1540.1-4 on materials packaging and transportation and DOE Order 5480.3 (Safety Requirements for the Packaging and Transportation of Hazardous Materials, Hazardous Substances and Hazardous Wastes) are under revision. Although the date for finalization of these orders is not yet known, DOE facilities should maintain an awareness of changes as they are announced and should modify procedures as rapidly as possible to ensure implementation of the new requirements. Training in the new requirements will also be necessary.

GUIDANCE AND INFORMATION

Two programs are available for guidance and practical information on changing requirements. The Transportation Information and Communication Resource Center at (301) 903-7280 provides information on transportation-related topics, such as emergency response, risk analysis, shipping campaigns, accidents and incidents, environmental issues, training, and transportation modes. The Regulatory Compliance Program also provides transportation-related information that can be accessed by calling the Hotline at (301) 903-7272.

RECOMMENDATIONS

DOE contractors who package and transport hazardous materials should take the following steps:

1. Review procedures to ensure that they are adequate. Try to anticipate special situations that might arise. Have a mechanism in place for identifying and responding to unexpected situations that require formulation of new procedures.

2. Take disciplinary action in cases of willful violation. Noncompliance with regulatory requirements, DOE orders, or facility procedures can jeopardize the employee, the public, and the environment. Noncompliance with regulatory requirements can result in significant fines.

3. Train all personnel involved in packaging or transporting of hazardous materials, and ensure that such training is effective. Training should include the following elements, as appropriate:

   a) recognition of the DOT hazardous materials classification system

   b) use and limits of hazardous materials placarding, labeling, and marking systems

   c) general handling, loading, and unloading techniques; strategies to reduce release or damage of hazardous materials

   d) health, safety, and risk factors

   e) appropriate emergency response and communication procedures

   f) use of DOT's Emergency Response Guidebook

   g) applicable transportation regulations

   h) personal protection techniques

   g) preparation of shipping documents

4. Increase surveillance of hazardous materials containers; survey for contamination prior to shipping and upon receipt of shipment.

5. Stay aware of changes to regulatory requirements, DOE orders, and management directives. Incorporate them into facility procedures in a timely manner.

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