DOCKET NO: A

- 98

- 49 Item: II

- B3

- 123

Interna l Contamination in TRUPACT

- 132, Shipment OR11009

EPA Investigation and Summary

EPA Notification and Agency Actions : On the afternoon of Thursday, December 7, 2011, EPA received notification from NMED that a payload had arriv ed at WIPP with contamination external to the waste containers . No further information was provided at the time . EPA immediately contacted CBFO environmental compliance personnel, who were una bl e to provide details of the situation . An RPD staff member was already planning to be present at Sandia National Laboratories in Carlsbad the following week, so arrangements were made for a meeting with the necessary personnel to investigate the incident.

On December 14, Jonathan Walsh of EPA met with George Basabilvaso, Russ Patterson, and Bob Kehrman in the Skeen

- Whitlock building in Carlsbad to discuss the incident

. Representatives of NMED participated as observers. EPA was informed that low levels of surface contamination had been discovered on the payload delivered in TRUPACT 132

. L aboratory analys e s eventually supported the hypothesis that the decay of radon
progeny was being observed , and confirm ed that no loss of containment of radioactive or hazardous materials had t aken place

. T he assembly met surface contamination release limits set by radiation control (RadCon) , and t he site developed a specific work order to download and emplace the affected payload.

EPA requested documentation to complete its investigation, spe cifically: a timeline of the incident including the procedures enacted, the analytical data generated by RadCon and WIPP Laboratories , and the work order developed for the downloading and emplacement of the assembly. This information was delivered electron ically by DOE on January 4, 2012.

The i ncident was fully reviewed during the annual inspection opening meeting on July 17, 2012 , and addressed during the July 19 visit to WIPP L aboratories

. The inspection team reviewed both analytical results generated du ring the incident (Attachment B to this report) and QA documentation associated with these analyses. This report was finalized in conjunction with the 2012 annual inspection reports.

Full D etails :

On Nov e m ber 8

, 2011, Shipment OR11009 , which includ ed payload TW112 shipped in TP 1 32

, was received at the WIPP site

. Payload TW112 contained heterogeneous debris from multiple sources at Oa k R idge. On November 9, i n accordance with routine unloading procedure, a vacuum was taken on the closed TRUP ACT through a radiological air filter (RAF). When the RAF was screened for gross alpha and beta radiation , a high alpha count (3100 dpm) wa s observed

. T his can be the result of thebuildup of radon gas from the vented drums inside the sealed TRUP ACT

. Per procedure

WP

- 12 HP1100 , waste handling personnel waited for counts to d e c ay below R ad C on limits

. On November 10, elevated counts were not observed on RAFs. The TRUP ACT was opened, and the payload of fourteen 55

- gallon drums was hoisted. RadCon swipes taken on the bottom of the payload pallet showed elevated alpha and beta activity

. Although the alpha counts quickly decayed, low but elevated beta counts at bottom of assembly persisted

. Because the source of the beta radiation could not be immediately determi ned, contaminated areas were covered with plastic wrap and the assembly was moved to the Shielded Storage Room of the Waste Handling Building and the room was posted as a contamination area. TP132 was sealed , and t he RadCon swipes were sent to WIPP labs to identify the source of the contamination.

Over the next week, WTS Operations collaborated with WIPP Laboratories, CCP, and ORNL to conclusively rule out contamination by TRU radionuclides

. WIPP Laboratories specifically tested the highest

- activity swipe s for 241 Pu, 241 Am, and the fission products
60 Ni and 99 Tc. No detections were made

. 1 B y November 16 , the remaining swipes did not exhibit any elevated beta activity , which is consistent with the decay of short

- lived radon progeny to 210 Pb

. Additional swipes taken by RadCon exhibited no alpha activity , and no beta activity above 88dpm/100cm 2

. Having eliminated other possible sources, the beta emissions were most likely the result of the decay products of radon gas. As stated in the WTS work order (Attachment C to this report): “ The contamination found on the payload from TRUPACT 132 is Pb

- 21 0 , a beta particle emitter. Pb

- 210 is a decay product of Ra

226 which is a naturally occurring radionuclide used to manufacture other radionuclide's [sic] and is part of the source term in at least two ORNL waste streams. Ra

226 decays to Rn

- 222 which is a gas and will vent through the waste containers filter and eventually decay to Pb

- 210

. ”

Because a loss of containment was conclusively ruled out, any need for hazardous waste remediation (as required by the facility hazardous waste permit) was eliminated. The assembly met RadCon release limits for surface radioactivity, and since any 210 Pb was contained by the wrapping, the decision was made not to inc ur any potential exposure or create additional waste by remediating. A Work Instruction was written

, approved, and rehearsed. The entire assembly, including two seven

- p a cks of drums, an internal TRUPact pallet, and transport tubes, w as wrapped in brattice cloth over the plastic wrap. T he assembly was placed in the underground on December 7, 2011

. TP132

, sealed at the onset of the incident , was shipped back to the generator site to be decontaminated there.

1 The WIPP Laboratories data package included as Attachment B to this report includes an evident 241 Am detection in sample C5806 . A conversation with Mansour Akbarzadeh confirmed tha t a measurement was made which was barely above the minimum detection limit of the instrument, but was too low to distinguish from background. 241 Am is not a beta emitter.TP132 is placed on a facility pallet for downloading and emplacement

Agency Analysis and Conclusions :
After a review of data generated by RadCon and WIPP laboratories, EPA agrees with conclusions that no loss of containment of radioactive materials took place . It is highly plausible that the el evated counts observed were most likely due to radon progeny: the timeframe during which beta radiation was observed is consistent with the time required for the daughters of 222 Rn to decay to 210 Pb, and both 226 Ra and 238 U are present in the payload, pro viding a potential source of 222 Rn within the TRUPACT (see Attachment D, WDS Shipment Data Report) . Whatever doubt remains about the source of the observed contamination, DOE is able to demonstrate that no release of radioactive material took place.

The site appears to have acted appropriately and according to procedure. Radiological posting s w ere updated and notifications made according to WP 12 HP

- 1500

, Radiological Posting and Access Control

. Because no TRU appeared on RAFs, and specified limits of

sur face contamination were not reached, neither 12

- HP 2001, Abnormal Radiological Conditions , nor 12

- ER 4903

, Radiological Event Response , was invoked.EPA is concerned by the delays in receiving notification and information concerning the

incident. Speci fically, Attachment 1 of procedure 02 EC 3506, Environmental Incident Reporting, Rev. 7, calls for the site to notify DOE or EPA within 24 hours in the event of “Any spill involving, or having the potential to involve, radionuclides.” EPA acknowledges that no r elease took place, and therefore DOE was not bound by the reporting requirements listed at 40 CFR §194.4. However, although radon was suspected to be the source of contamination , it was made clear during the discussion that took place on December 14 that the incident was treated as a potential loss of containment of both radioactive and hazardous waste constituents beginning on November 10

. The analyses which determined that this was not the case were not completed until November 16

. During this time period, when some uncertainty persisted, it would have been appropriate for DOE management to notify EPA of the incident and the site’s response

. Even if the Department has no legal o bligation to report an incident, providing notification and information to EPA helps the Agency to understand the magnitude of the event and respond to any public inquiry. These concerns were raised to DOE during the July discussion of the incident, and DO E was receptive to providing courtesy notifications in the future.

Attachments :

A. Timeline of DOE’s response to TP132 B. WIPP Laboratory Data Package C. CHAMPS Work Order 1112576 D. WDS Shipment Data Report, Shipment OR110009