DOCKET NO: A-98-49

Item: II-B3-123 

Internal 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 arrived 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 unable 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. Laboratory analyses eventually supported the hypothesis that the decay of radon 

progeny was being observed, and confirmed that no loss of containment of radioactive or 

hazardous materials had taken place. The assembly met surface contamination release 

limits set by radiation control (RadCon), and the site developed a specific work order to 

download and emplace the affected payload. 

EPA requested documentation to complete its investigation, specifically: 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 electronically by DOE on January 4, 

2012.

The incident was fully reviewed during the annual inspection opening meeting on July 

17, 2012, and addressed during the July 19 visit to WIPP Laboratories. The inspection 

team reviewed both analytical results generated during 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 Details: 

On November 8, 2011, Shipment OR11009, which included payload TW112 shipped in

TP132, was received at the WIPP site. Payload TW112 contained heterogeneous debris 

from multiple sources at Oak Ridge. On November 9, in accordance with routine

unloading procedure, a vacuum was taken on the closed TRUPACT through a 

radiological air filter (RAF). When the RAF was screened for gross alpha and beta 

radiation, a high alpha count (3100 dpm) was observed. This can be the result of the 
buildup of radon gas from the vented drums inside the sealed TRUPACT. Per procedure

WP-12 HP1100, waste handling personnel waited for counts to decay below RadCon 

limits. On November 10, elevated counts were not observed on RAFs. The TRUPACT

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 

determined, 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 the 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 swipes for 241Pu, 241Am, and the fission products

60Ni and 99Tc. No detections were made.1 By November 16, the remaining swipes did not 

exhibit any elevated beta activity, which is consistent with the decay of short-lived radon 

progeny to 210Pb. Additional swipes taken by RadCon exhibited no alpha activity, and no 

beta activity above 88dpm/100cm2. 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-210, a beta particle emitter. Pb-210 is a decay product of Ra226 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. Ra226 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 210Pb was 

contained by the wrapping, the decision was made not to incur any potential exposure or 

create additional waste by remediating. A Work Instruction was written, approved, and 

rehearsed. The entire assembly, including two seven-packs of drums, an internal 

TRUPact pallet, and transport tubes, was wrapped in brattice cloth over the plastic wrap. 

The 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 241Am 

detection in sample C5806. A conversation with Mansour Akbarzadeh confirmed that a measurement was 

made which was barely above the minimum detection limit of the instrument, but was too low to 

distinguish from background. 241Am 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 elevated 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 222Rn to decay to 210 Pb, and both 226Ra and 238U are present in the 

payload, providing a potential source of 222Rn 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 

postings were 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 

surface 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. Specifically, 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 release 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 obligation 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 DOE 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