Department of Transportation Non-Compliances by Vendor Shippers

Contents

• Introduction
• Notice Summary
• Applicability
• Events Summary
• Significance of Events
• Number of Incidents
• Lessons Learned
• Packaging and Transportation Safety Program
• New DOE Orders
• References

Introduction

This notice is one in a series of publications issued by the Office of Nuclear and Facility Safety to share nuclear safety information throughout the Department of Energy complex. For more information, contact Dick Trevillian, Office of Operating Experience Analysis and Feedback, Office of Nuclear and Facility Safety, U.S. Department of Energy, Washington, DC 20585, telephone (301) 903-3074. No specific action or responses are required solely as a result of this notice.

Safety Notices are distributed to U.S. Department of Energy Program Offices, Field Offices, and contractors who have responsibility for the operation and maintenance of nuclear and related facilities, and to other organizations involved in nuclear safety. Written requests to be added to or deleted from the distribution of Safety Notices should be sent to: BR Richard L. Trevillian, EH-33, Room E-460 GTN, U.S. Department of Energy, Washington, DC 20585.

The ESH Office of Information Management maintains a file of Safety Notices and supporting information. Copies can be obtained by contacting the Office of Information Management at (301) 903-0449 or by writing to the Office of Information Management, U.S. Department of Energy, EH-72/Suite 100, CXXI/3, Washington, DC 20585.

Notice Summary

This Notice discusses lessons learned at Department of Energy facilities from receiving hazardous material from non-DOE shippers (vendors) that were not in compliance with Department of Transportation (DOT) regulations. DOE facilities are required to report all such non-compliances to the Occurrence Reporting and Processing System (ORPS) as specified in DOE 232.1.¹

Applicability

This Notice applies to DOE facilities that receive hazardous materials from shippers not under the authority of DOE. No specific action or response is required by this Notice, but the Office of Nuclear and Facility Safety encourages examination of transportation procedures in the light of this information. Many of the lessons can also be applied to incoming shipments of hazardous material from other DOE facilities.

Events Summary

The following events illustrate how non-DOE shippers fail to comply with DOT regulations and, in addition, illustrates the risks involved.

On November 30, 1995, radiological control technicians discovered exterior surface radiation dose rates on seven of 140 radioactive material packages during receipt surveys at Fernald Environmental Management Project. The dose rates exceeded the DOT shipping limit of 0.5 mrem/hr. One of the packages measured 13 mrem/hr and the other six ranged between 0.5 and 1 mrem/hr. Subcontract laboratories shipped the packages to Fernald. Technicians stored the packages in a controlled area of the facility and notified the laboratories of the non-compliance.²

On May 11, 1995, a worker at Hanford was contaminated when he opened a slightly pressurized shipping cask from a non-DOE shipper. Because the shipper's procedures required venting the cask before shipment, the worker assumed the cask was not pressurized. All personnel evacuated the area, the radioactive material was contained within a diameter of 35 feet, and no one else was affected.³

On April 24, 1995, the Mound Plant received a shipping container of explosives from a non-DOE shipper. The container was marked "empty," so receiving personnel did not handle the container as if it held explosive materials. When they discovered the explosives, they contacted the Explosive Facility Group and had the container properly labeled and stored.⁴

On November 2, 1994, Los Alamos National Laboratory received an emergency shipment of special nuclear materials from a non-DOE shipper. DOT regulations required an "Exclusive Use" label for the radiation level of the material and the drums should have been marked, "Reportable Quantity." Because the shipping class and shipping papers were incorrect, the shipment was improperly handled and controlled in transit. The shipment should have been on one carrier, but two carriers were used posing an exposure hazard when the shipment was transferred between carriers. Radiation technicians recognized the discrepancy and surveyed, labeled, and correctly stored the shipment.⁵

On November 15, 1994, Brookhaven National Laboratory received twelve packages of radioactive material containing approximately 27 millicuries each from a non-DOE shipper. The transport vehicle had no placards, the load was not tied down, and shipping papers were incorrect. In addition, the radiation dose rate in the driver's compartment was 0.5 mrem/hr above the limit of 2.0 mrem/hr. Receivers surveyed the packages, sent them to their destination, and placed them in secure storage.⁶

On April 3, 1995, Fernald Environmental Management Project received a package from a non-DOE shipper. It had an external surface dose rate of 1.5 mrem/hr, which exceeded the DOT limit. Fernald investigators determined that samples in the package shifted toward an outer surface of the container during transport or unloading. This shift caused the external surface dose rate to rise above the limit. Receivers surveyed the package and moved it to a storage building.⁷

On May 19, 1994, a radiological control technician at Los Alamos National Laboratory detected tritium in excess of the administrative limit of 10,000 dpm/100cm2 on items contained in a package received from a non-English-speaking country. He measured tritium contamination ranging from 500,000 to 3,000,000 dpm/100cm2. The shipper had placed copper pressure-vessel plugs in fingers of a rubber glove inside two ziploc bags inside a toolbox. There were no placards or labels. Health Physics personnel transferred the material to a controlled radiological area for storage until it could be sent to the Tritium Systems Test Assembly Facility.⁸

Significance of Events

These events are significant because of the potential dangers from unknown hazards when shippers do not comply with DOT regulations. Therefore, DOE receivers should be especially careful when receiving and processing deliveries from non-DOE shippers. Improperly packaged shipments may leak or shift during transit causing chemical or radiological incidents. Mislabeled radioactive sources can lead to unnecessary exposures. Avoidable exposures are inconsistent with the DOE principle of keeping radiation exposure As Low As Reasonably Achievable (ALARA).

Number of Incidents

Based on ORNL/PATS-95-002, Packaging- and Transportation- Related Occurrence Reports, Fiscal Year 1994 Annual Report, from October 1993 through September 1994 there were 186 transportation incidents reported in ORPS. Of these, 97 (52 percent) were categorized as off-site non-compliance with DOT transportation regulations. Non-DOE occurrences for the period totaled 48 (25.8 percent). During fiscal years 1991, 1992, and 1993, non-DOE shipper occurrences averaged 21 percent a year. The non-DOE occurrences are significant because DOE has no authority over non-DOE shippers, yet must receive hazardous material from them.

Lessons Learned

The best means of protection when packages are received from an infrequent shipper is a thorough inspection. Conservative handling and extra precautions can prevent incidents. Receivers and handlers must be prepared for the unexpected.

Non-DOE shippers should be given the following instructions.

• Use a DOE site-approved checklist for packaging, labeling, marking, and transporting.
• Send a copy of the shipping papers to the DOE receiving site for review before shipment.

The following actions and good practices need to be applied at DOE sites.

• Give shippers the name of a specific site transportation specialist to call when questions arise.
• Ensure that personnel receiving shipments have requisite knowledge and training on DOT requirements (49 CFR 100-177⁹).
• Check shipping papers, markings, and labels upon receipt, making sure the items received match the items listed on the papers.
• Inspect shipments for damage or leakage upon receipt (DOE 460.2¹⁰).
• Inspect radioactive material shipments for external surface contamination. (DOE 460.2¹⁰).
• Detain contaminated transport vehicles and immediately notify the delivering carrier (DOE 460.2¹⁰).
• Develop procedures to inspect hazardous material containers labeled empty.
• Treat empty hazardous material containers as if they still contain hazardous material.
• Assume containers are pressurized and take precautions.
• Properly package, mark, label, and store incoming shipments not in compliance.
• Notify the designated shipper contact of non-compliances (DOE 232.1¹).
• Share transportation and packaging safety successes and problems throughout the site and with other DOE contractors (Attachment 1 to DOE 460.1¹¹).

Packaging and Transportation Safety Program

The Oak Ridge National Laboratory has a Packaging and Transportation Safety (PATS) Program, supported by EH-32, that concerns the packaging and transportation of hazardous materials. The Program staff analyzes ORPS reports for trends, impact on operations, safety concerns, and lessons learned in packaging and transportation safety. The Program staff produced the following documents this past year, including five lessons learned in 1994 and three in 1995. PATS Lessons Learned 3720-94-05 is the main source for this Safety Notice.

• ORNL/PATS-95-002, Packaging- and Transportation- Related Occurrence Reports, Fiscal Year 1994 Annual Report, March 1995.
• ORNL/M-3077, Packaging and Transportation Resource Guide, December 1994.
• PATS LL:3720-94-01, Verifying Shipping Documentation, August 1994.
• PATS LL:3720-94-02, Review of Operations, August 1994.
• PATS LL:3720-94-03, Use of Most Current Versions of Safety Analysis Reports for Packaging (SARPS), August 1994.
• PATS LL:3720-94-04, Maintaining Records for Packaging, November 1994.
• PATS LL:3720-94-05, Assisting Non-DOE Contractor Shippers, December 1994.
• PATS LL:3720-95-01, Sharing Site to Site, April 1995.
• PATS LL:3720-95-02, Empty?? Make Sure!, June 1995.
• PATS LL:3720-95-03, Maintaining Protocol for Offsite Response, July 1995.

For additional information on the PATS Program, contact M.J. Welch, ORNL, (423) 574-5068, or Ted Needels, EH-32, (301) 903-4684, or see the PATS home page, Internet address http://www.ornl.gov/~webworks/cpr/rpt/90835.pdf.

New DOE Orders

New DOE orders that cover packaging and transportation for DOE-owned or -operated facilities went into effect on September 27, 1995.

• DOE 460.1¹² establishes safety requirements for packaging and transportation of off-site shipments from DOE and on-site transfers of hazardous materials and for modal safety.
• DOE 460.2¹⁰establishes DOE policies and requirements to supplement applicable laws, rules, regulations, and other DOE orders for materials transportation and packaging operations.

References

1. DOE 232.1, Occurrence Reporting and Processing of Operations Information.
2. DOE Occurrence Report OH-FN-FERM-FEMP-1995-0131, "DOT Shipping Violation by a Non-DOE Shipper," 30 November 1995.
3. DOE Occurrence Report RL--WHC- SOLIDWASTE-1995-0010, "Personnel Contamination at 218W4C Trench 29," 25 May 1995.
4. DOE Occurrence Report OH-MB-EGGM-EGGMAT03-1995-0002, "Improper Labeling of Shipping Container of Hazardous Material for Transportation," 15 May 1995.
5. DOE Occurrence Report ALO-LA-LANL-MATWAREHS-1994-0010, "SNM Shipment Received at LANL that was Improperly Labeled and Shipped from Originator Authorized by the Nuclear Regulatory Commission (NRC)," 21 December 1994.
6. DOE Occurrence Report CH-BH-BNL-BNL-1994-0031, "Non-Compliance with DOT Regulations by an Off-Site Non-DOE Shipper," 25 January 1995.
7. DOE Occurrence Report OH-FN-FERM-FEMP-1995-0036, "DOT Shipping Violation by a non-DOE shipper," 21 April 1995.
8. DOE Occurrence Report ALO-LA-LANL-PHYSCOMPLX-1994-0004, "Tritium Contaminated Copper 'Finger' Plugs Identified in an Uncontrolled Area," 25 May 1994.
9. 49 CFR 100-177, Transportation.
10. DOE 460.2, Departmental Materials Transportation and Packaging Management.
11. Attachment 1, "Contractor Requirements Document," to DOE 460.1.
12. DOE 460.1, Packaging and Transportation Safety.