Bulletin 79-20: Packaging, Transport and Burial of Low-Level Radioactive Waste

                                                  Accession No: 7908070524 
                                                  SSINS No: 6820    
      
                                UNITED STATES
                        NUCLEAR REGULATORY COMMISSION
                    OFFICE OF INSPECTION AND ENFORCEMENT
                           WASHINGTON, D.C. 20555
                                     
                               August 10, 1979

IE Bulletin No. 79-20 

PACKAGING, TRANSPORT AND BURIAL OF LOW-LEVEL RADIOACTIVE WASTE 

Description of Circumstances: 

Low-level radioactive waste is that waste which can be transferred and 
shipped to one of three waste burial facilities which are located in and 
licensed by the Agreement States of Nevada, South Carolina, and Washington. 
On July 10, 1973, the Governors of the three states notified NRC Chairman 
Hendrie of the serious and repeated disregard for rules governing the 
shipments of low-level  radioactive wastes to these burial facilities. 

Examples of violations of Agreement State, DOT and NRC rules follow: 

Improperly packaged uranium films igniting packaged liquid scintillation 
vials in combustible waste is believed to have caused a fire and destruction
of a truck at the Beatty, Nevada burial facility on May 14, 1979. 

On July 2, 1979, three of twelve steel containers shipped to the Beatty 
burial facility were found to be leaking radioactive material. The material 
was described on the bill of lading as being a solid inorganic salt 
(evaporator concentrates solidified with urea formaldehyde) from a reactor 
facility. The Governor of the State of Nevada ordered the drums to be 
shipped out of the state and the burial facility was temporarily closed. 

On July 30, the first shipment into the reopened Beatty facility contained 
free liquid in "solid" material. The radioactive contents were sand filters 
used a at an insitu leaching process at a uranium mill. 

Forty-three shipments with sixty-three deficiencies were observed during the 
package inspection program between April 10 and July 5, 1979, by the 
Agreement State of South Carolina, at the Barnwell, S.C. burial facility. 
The shipments were from reactor, medical, industrial and military 
facilities. 

On June 28, 1979, the Federal Highway Administration issued a Notice of 
Violation to a reactor facility proposing a $10,000 fine for truck 
contamination resulting from improper closures on 55-gallon drums of LSA 
material and for improper loading of the drums on the vehicle. 
.

IE Bulletin No. 79-20                                       August 10, 1979 
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These are a few examples of shipments of radioactive material to burial 
facilities which did not fully meet NRC, DOT and Agreement State 
requirements which were developed to protect the health and safety of the 
public. The Governors of the three States with licensed burial facilities 
have indicated that if the situation is not rectified, they may have to 
initiate actions which would deny use of the three burial sites by 
violators. 

Sources of Information: 

The DOT regulatory requirements can be found in 49 CFR Parts 170-179. The 
NRC regulatory requirements can be found in 10 CFR Parts 19 to 71. The NRC 
regulatory requirements for Agreement State licensees in non-agreement 
states are in 10 CFR Part 150. Copies of the regulations may be purchased 
from the Superintendent of Documents, U. S. Government Printing Office, 
Washington, D.C. 20402. 

Information about licensing requirements for NRC packages can be obtained 
from the NRC Transportation Branch (301-427-4122). Information about DOT 
packaging and transport requirements can be obtained by calling the DOT 
Office of Hazardous Materials (202-426-2311). 

Action To Be Taken By Licensees: 

To assure the safe transfer, packaging, and transport of low-level 
radioactive waste, each licensee is expected to: 

1.   Maintain a current set of DOT and NRC regulations concerning the 
     transfer, packaging and transport of low-level radioactive waste 
     material. 

2.   Maintain a current set of requirements (license) placed on the waste 
     burial firm by the Agreement State of Nevada, South Carolina, or 
     Washington before packaging low-level radioactive waste material for 
     transfer and shipment to the Agreement State licensee, If a waste 
     collection contractor is used, obtain the appropriate requirements from
     the contractor. 

3.   Designate, in writing, people in your organization who are responsible 
     for the safe transfer, packaging and transport of low-level radioactive
     material. 

4.   Provide management-approved, detailed instructions and operating 
     procedures to all personnel involved in the transfer, packaging and 
     transport of low-level radioactive material. Special attention should 
     be given to controls on the chemical and physical form of the low-level
     radioactive material and on the containment integrity of the packaging.
.

IE Bulletin No. 79-20                                       August 10, 1979 
                                                            Page 3 of 3    

5.   Provide training and periodic retraining in the DOT and NRC regulatory 
     requirements, the waste burial license requirements, and in your 
     instructions and operating procedures for all personnel involved in the
     transfer, packaging and transport of radioactive material. Maintain a 
     record of training dates, attendees, and subject material for future 
     inspections by NRC personnel. 

6.   Provide training and periodic retraining to those employees who operate
     the processes which generate waste to assure that the volume of 
     low-level radioactive waste is minimized and that such waste is 
     processed into acceptable chemical and physical form for transfer and 
     shipment to a low-level radioactive waste burial facility. 

7.   Establish and implement a management-controlled audit function of all 
     transfer, packaging and transport activities to provide assurance that 
     personnel, instructions and procedures, and process and transport 
     equipment are functioning to ensure safety and compliance with 
     regulatory requirements. 

8.   Perform, within 60 days of the date of this bulletin, a management-
     controlled audit of your activities associated with the transfer, 
     packaging and transport of low-level radioactive waste. Maintain a 
     record of all audits for future inspections by NRC or DOT inspectors. 
     (Note: If your have an established audit function and have performed 
     such an audit of all, activities in Items 1-6 within the past six 
     months, this audit requirement is satisfied.) 

No written reply to this Bulletin is required. NRC inspectors will examine 
your continuing response during future inspection of your activities. 
Licensees who do not generate low-level waste for burial do not need to take
actions described above. If you desire additional information regarding this
matter, contact the Director of the appropriate NRC Regional Office.