05000454/FIN-2011005-04
From kanterella
Jump to navigation
Jump to search
Finding | |
|---|---|
| Title | Failure to Identify Hazardous Materials on Transportation Manifest |
| Description | A self-revealed finding of very low safety significance (Green) and an associated NCV of 10 CFR 71.5, Transportation of Licensed Material, was identified when licensee personnel failed to comply with 49 CFR 172.203(c) and shipped packages of radioactive material with transport manifests that did not document all applicable hazardous substances. On multiple dates, the licensee shipped containers of radioactive material to a waste processor with incomplete information on the transport manifest. Specifically, the transport manifest that accompanied the shipments failed to identify hazardous materials, including asbestos, lead, and other chemicals that were contained in the packages. Upon arrival at the waste processors facility, the waste processor identified the non-conformances in the shipping containers and notified the licensee. Follow-up actions by the licensee included performing a revised characterization of the shipped packages. The revised radiological characterization identified negligible impact relative to the initial radiological assessment and package characterization. This event was documented in the licensees CAP as: IR 1221229; RWS11-006 Contained Un-Manifested Asbestos; IR 1173307; RWS10-013 Contained Unapproved Mixed Waste; IR 928393; Non-Conforming Metal Shipped to Bear Creek Processing; IR 1015646; Non-Conforming Waste Found in Radwaste Shipment; and IR 1067394; Non-Conforming Radioactive Waste in Shipment. Immediate corrective actions included providing a corrected copy of the transport manifest to the waste processor. Additionally, the licensee initiated IR 1285148 to evaluate the human performance issues associated with the shipping non-conformances. Further, the licensee placed locks on the shipping containers to control items placed in the packages and to ensure that the manifest accurately represented the hazards contained in the shipping package. Analysis: The failure to completely identify all required package contents on a transport manifest was a performance deficiency. The finding was determined to be more than minor because it was associated with the Program and Process attribute of the Public Radiation Safety Cornerstone and adversely affected the cornerstone objective of ensuring the adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation, in that, providing incorrect information, as part of hazard communication, could impact the actions of response personnel. The finding involved an occurrence of the licensees radioactive material transportation program that was contrary to NRC regulatory requirements. The inspectors determined that the finding could be evaluated using the SDP in accordance with IMC 0609, Significance Determination Process, Appendix D, Public Radiation Safety Significance Determination Process. Using the Public Radiation Safety SDP, the inspectors determined: (1) radiation limits were not exceeded; (2) there was no breach of a package during transit; (3) it did not involve a certificate of compliance issue; (4) it was not a low level burial ground nonconformance; and (5) it did not involve a failure to make notifications or provide emergency information. As a result, the finding screened as having very low safety significance (Green). This finding has a cross-cutting aspect in the Work Control component of the Human Performance cross-cutting area H.3(b) since the waster shipper failed to coordinate work activities by incorporating actions to address the impact of the work on different job activities, and the need for work groups to maintain interfaces with offsite organizations, and communicate, coordinate, and cooperate with each other during activities in which interdepartmental coordination is necessary to assure adequate human performance. Specifically, these events occurred because the radioactive material shipper did not control the items placed in the waste packages and was not present when the boxes were loaded. Title 10 CFR 71.5, Transportation of Licensed Material, requires licensees to comply with the Department of Transportation (DOT) regulations in 49 CFR Parts 170 through 189 relative to the transportation of licensed material. Title 49 CFR 172.203, Additional Description Requirements, required, in part, that hazardous materials be listed on the transport manifest Contrary to the above, between May 10, 2010 and May 26, 2011, the licensee failed to list relevant hazardous materials on the transport manifest for a shipment also containing DAW. This violation was entered into the licensees CAP as IR 1285148. Because this violation was of very low safety significance and it was entered into the licensees CAP, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. |
| Site: | Byron  |
|---|---|
| Report | IR 05000454/2011005 Section 2RS8 |
| Date counted | Dec 31, 2011 (2011Q4) |
| Type: | NCV: Green |
| cornerstone | Pr Safety |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 71124.08 |
| Inspectors (proximate) | R Jickling R Ng C Thompson B Bartlett J Robbins J Cassidy B Palagi J Benjamin E Duncan J Dalzell J Nance |
| CCA | H.5, Work Management |
| INPO aspect | WP.1 |
| ' | |
Finding - Byron - IR 05000454/2011005 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Finding List (Byron) @ 2011Q4
Self-Identified List (Byron)
| ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||