IR 05000029/1980005
| ML19309G002 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 03/17/1980 |
| From: | Crocker H, Kinney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19309G001 | List: |
| References | |
| 50-029-80-05, 50-29-80-5, NUDOCS 8005020127 | |
| Download: ML19309G002 (13) | |
Text
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No.
50-29/80-05 Docket No.
50-29 License No.
DPR-3 Priority Category C
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Licensee:
Yankee Atomic Electric Company 25 Research Drive Westborough, Massachusetts 01581 Facility Name:
Yankee Nuclear Power Station (Yankee Rowe)
Inspection At:
Rowe, Massachusetts Inspection Londucted:
February 19-20, 1980 Inspectors:
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W. W. Kinng, Tranyportation Inspector
/ dhte date date Approved by:
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$1-3[/7/td P
H.\\jW Crocker, Chief >, Fuel Facility Projects
/ d6te Section, FF&MS Branch Inspection Summary:
Inspection on February 19-20, 1980 (Report No. 50-29/80-05)
Areas Inspected:
Special unannounced inspection by a region-based inspector of circumstances surrounding a transport trailer carrying Yankee Atomic Electric Company LSA radioactive waste having surface radiation levels greater than 200 mR/hr, when the trailer was received at the Chem-Nuclear Systems, Inc. burial facili:.y near Barnwell, South Carolina.
The inspection involved 9 inspector-hours onsite by one region-based inspector.
Results:
No items of noncompliance or deviations were identified.
l Region I Form 12 (Rev. April 1977)
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l DETAILS i
1.
Persons Contacted j
- N. N. St. Laurent, Assistant Plant Superintendent
- J. L. Staub, Technical Assistant to Plant Superintendent
- J. C. Trejo, Health Physics Supervisor
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G. Babineau, Health Physicist
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denotes those present at the exit interview 2.
Scope of Inspection This inspection was of the circumstances surrounding a McCormack's Highway Transportation, Inc. trailer having high radiation levels at the surface, when it was received at the Chem-Nuclear Systems, Inc. (Chem-Nuclear)
burial facility near Bernwell, South Carolina.
The trailer contained low specific (LSA) material from the Yankee Atomic Electric Company (Yankee
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Rowe) facility near Rowe, Massachusetts.
On January 22, 1980, Chem-Nuclear Systems, Inc. and the State of South Carolina measured radiation levels from a spot on the surface of the trailer ranging from 400 to 700 mR/hr, j
depending upon the survey instrunent used.
The radiation exceeded the limit of 200 mR/hr given in 49 CFR 173.393(j)(2).
3.
Description of Events and Circumstances Yankee Atomic Electric Company has a purchase order dated May 8, 1979, issued to and acknowledged by Chem-Nuclear Systems, Inc. for the transporta-
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tion and disposal of waste from the Yankee Rowe Nuclear Power Station in Rowe, Massachusetts. This purchase order gives agreements between the parties as to responsibilities in the shipment.
The following agreed to responsibilities are pertinent to the situation being inspected.
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Chem-Nuclear will supply the equipment, labor and services necessary to transport and dispose of radioactive waste at an authorized dis-posal facility.
Radioactive waste offered by Yankee will be free of standing liquids
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and will be packaged and labeled in accordance with applicable regulations.
Chem-Nuclear will be responsibla for blocking, bracing, tying,
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chaining, covering and placard #ng loads and transport vehicles prepared for shipment by Yankea Rowe.
Chem-Nuclear will supply, unless otherwise directed, an empty trailer
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to be left on site at Yankee Rowe for loading prior to shipment.
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This contract will be valid only as long as Chem-Nuclear maintains
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currsnt licenses as applicable to possess and transport radioactive materials in the amounts being handled.
Chen-Nuclear will be understood to possess and assume full responsi-
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bility for all radioactive waste offered by Yankee Rowe upon signature as receipt by Chem-Nuclear or its agent on Yankee Atomic Electric Company's Radioactive Material Shipment Record.
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Chem-Nuclear shall be responsible for the transportation of said radioactive material in a manner complying with all applicable state and federal transportation regulations.
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This contract shall remain in effect for a period of one year from
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the date of this purchase order, or a period of 30 days from the receipt of a written cancellation notice from either party.
In actual practice, it would appear that the following observations pertain to each of the agreed respor.sibilities, respectively.
Chem-Nuclear pays the common carrier for transporting the waste from
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the Yankee Rowe Nuclear Power Station to their Barnwell Waste Manage-ment Facility.
Chem-Nuclear receives, unloads and buries the waste at the Barnwell burial site.
Yankee Rowe solidifies liquid evaporator bottoms with cement or
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mortar.
Yankee Rowe packages and labels waste in accordance with requirements of 49 CFR 173.392(c). In the present situation, Yankee Rowe prepared a package in a manner which allowed the radiation level at the surface of the package to increase from 100 mR/hr at the time of packaging to greater than 200 mR/hr while the package
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was being transported to the Barnwell burial site.
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Chem-Nuclear depends on the common carrier driver to assure that loads are properly blocked, braced, tied, chained and that trailers are properly placarded.
According to Yankee Rowe, they secure the loads in the trailers and they close and seal the trailer doors. The doors are generally sealed closed before the common carrier arrives to remove the loaded trailer.
The carrier leaves an empty tra'ler at the Yankee Rowe facility when i
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he picks up the loaded trailer.
Chem-Nuclear has NRC License No. 46-13536-01 which allows Chem-Nuclear
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to receive and possess packaged waste byproduct and source material in any state of the United States except in Agreement States and to dispose of the waste by burial at its Barnwell burial site.
The license is currently under " timely renewal".
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Yankee Rowe and Chem-Nuclear do not agree on when the transfer of
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possession of the radioactive waste and responsibility for the waste from Yankee Rowe to Chem-Nuclear occurs.
Yankee Rowe claims that, when the common carrier driver signs the Yankee Atomic Electric Company Offsite Radioactive Material Shipment Record, Chem-Nuclear has taken possession of the packaged waste and has assumed full responsibility of the waste. Chem-Nuclear claims that they take i
possession of and responsibility for the waste after the waste has been received at their Barnwell burial site and placed into the ground.
The common carrier in the present situation, McCormack's Highway Carrier Transportation, Inc., considers themselves only to be a common carrier and do not consider themselves to be Chem-Nuclear's agent.
Chem-Nuclear depends upon the common carrier to transport the radio-
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active material in a manner complying with applicable state and federal transportation regulations.
Yankee Rowe specifies that " exclusive use" vehicles are to be used to transport the low specific activity (LSA) radioactive waste from their facility to the disposal site because they wish to package the material in the manner required by 49 CFR 173.392(b) and (c) rather than in the manner required by 49 CFR 173.392(a).
In the present situation, Yankee Rowe had loaded a 45 foot long McCormack's Highway Transportation trailer with 53 steel drums and 1 wooden box
containing LSA radioactive waste.
The drums were placed in the front of the trailer. No bracing was used to hold the drums in position.
The box was placed toward the back of the trailer with the long axis of the box at approximately 30 degrees to the long axis of the trailer.
The skids of the box were nailed to the floor of the trailer with 16 penny nails.
The trailer was closed, and Yankee Rowe placed their seal on the trailer.
Meanwhile, Yankee Rowe arranged with Chem-Nuclear for the waste on the trailer to be disposed of in the Barnwell burial site. A Prior Notification Plan (PNP) Form was prepared.
Yankee Rowe then arranged with McCormack's Highway Transportation, Inc. to have the waste picked up on January 18, j
1980, for arrival of the vehicle with the waste at the Barnwell burial
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site on January 23, 1980.
Yankee Rowe made out shipping papers for the shipment of LSA radioactive waste.
Besides the Chem-Nuclear Systems, Inc. Prior Notification Plan Form, these included:
Yankee Atomic Electric Company Offsite Radioactive Material Shipment
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Record;
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Barnwell Waste Management Facility Radioactive Shipment Record Form,
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3 pages;
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" Exclusive Use" Vehicle Instructions to Carrier; and,
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Yankae Atomic Electric Company Radioactive Material Shipment - Truck Survey.
The radiation levels from each package both at the surface and at 3 feet were listed on the Barnwell Waste Management Facility Radioactive Shipment Record Forms.
The radiation at the surface of the 55 gallon drums ranged from 1-15 mR/hr.
The radiation from the surface of the box was listed as 100 mR/hr.
According to the licensee, the box was surveyed just prior to the box being loaded in the trailer.
There was a location in the middle of a side of the box which had the 100 mR/hr radiation.
The box was listed to contain ccmpacted dry waste on the Barnwell Waste Management Facility Radioactive Shipment Record Form.
Actually, the box contained pieces of noncompressible dry waste, according to the licensee.
As arranged by Yankee Rowe with McCormack's Highway Transportation, on the morning of January 18, 1980, McCormack's Highway Transportation i
spotted another empty trailer at the Yankee Rowe facility and picked up
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the loaded trailer. The driver certified that he received the drums and box of LSA N.O.S. radioactive material on the Yankee Atomic Electric Offsite Radioactive Material Shipment Record.
The driver also signed and dated the three pages of the Barnwell Waste Management Facility Radioactive Shipment Record Form.
Finally, the driver signed the " Exclusive Use" Vehicle Instructions to Carrier form under the CARRIER ACKNOWLEDGEMENT section.
This section was as follows, "I have read the listed instructions and have a clear understanding of their content. This shipment will be made in accordance thereof." The following were the instructions:
This shipment of radioactive material is being transported in an
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exclusive use vehicle.
The material is to be loaded by the shipper and unloaded at its
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final distination only.
In the event of an emergency or accident contact Yankee Atomic
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Electric Company at 1-413-625-6140 or 1-413-424-5261.
Routing Instructions (Yankee Rowe gave the route through Vermont and
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Massachusetts that the driver must take).
The tractor-trailer was taken to the McCormack's Highway Transportation, Inc. terminal in Schnectady, New York.
The trailer was weighed.
According to a letter from McCormack's Highway Transportation, Inc. to Yankee i
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Atomic Electric Company, dated January 24, 1980, "On Friday, January 18, 1980, McCormack was forced to move several drums to the rear of trailer
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When McCormack's Highway Transportation shifted the load, they moved the wooden box so that it was next to the side of the trailer.
The axis of the box was made parallel with the long axis of the trailer.
Apparently, the side of the box with the location during radiation of 100 mR/hr was positioned next to the side of the trailer.
McCormack's Highway Transpor-tation did not perform a radiation survey after the load was shifted in the trailer.
The tractor-trailer arrived at the Barnwell Waste Management Facility on January 22, 1980.
Chem"Juclear Systems, Inc. and an inspector from the Bureau of Radiological Health of the South Carolina Department of Health and Environmental Control measured the radiation from the material in the shipment.
They found a location on the trailer which had surface radiation readings ranging from 400 to 700 mR/hr., depending upon the survey instrument used.
The radiation from the surface of the box had evidently increased during transit, since the " hot" spot on the box was reading 100 mR/hr, when the box was surveyed at the Yankee Rowe Nuclear Power Station.
It was postulated by the licensee that a " hot" piece of noncompressible waste moved from the center of the box closer to the side of the box.
Two Health Physicists from Yankee Atomic Electric Company went to the Barnwell site on January 23, 1980, and investigated the situation.
They surveyed the trailer, and found that the location of high radiation read 260 mR/hr using two different instruments.
(These instruments were calibrated the day before). The trailer was opened and the shifting of the load was noted.
The seal placed on the trailer at the Yankee Rowe facility was on the floor of the trailer, according to the Yankee Rowe representative.
The Health Physicists from Yankee Atomic Electric Company then went to Columbia, South Carolina, and met with South Carolina Department of Health and Environmental Control personnel.
They were informed that an order to Yankee Atomic Electric Company was signed by the Commissioner of the South Carolina Department of Health and Environmental Control that morning.
It was ordered that any and all radioactive materials generated by Yankee Atomic Electric Company were prohibited from being transported into or delivered to South Carolina until such time as Yankee Atomic
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Electric Company demonstrates to the satisfaction of the Department of
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Health and Environmental Control that adequate procedural modifications have been implemented to ensure compliance by Yankee Atomic Electric Company with all applicable provisions of law.
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4.
Procedures for Packaging of Waste by Yankee Rowe When the waste shipped on January 18, 1980, was being accumulated for ultimate disposal, Yankee Rowe had 3 operating procedures in effect for packaging and shipment of radioactive material for disposal by burial.
These were:
Procedure he. OP-2381, Revision No. 5, CONCENTRATING AND DRUMMING EVAPORATOR BOTTOM:; Procedure No. OP-2382, Revision No. 3, SOLID RADI0 ACTIVE WASTE DISPOSAL; and Procedure No. OP-8301, Revision No.
2, RADI0 ACTIVE MATERIAL SHIPMENT.
The inspector reviewed these procedures for controls on the amount of radiation from the packaged waste.
Procedure No. OP-2381 gave procedural steps which were designed to keep the radiation level from the surface of the 55 gallon drums of solidified evaporator bottoms at levels less than or equal to 200 mR/hr.
Radiation readings at contact with the drum and 1 meter from the drum were to be taken after the the liquid was mixed with the cement.
Procedure No. OP-2382 for the packaging of solid radioactive waste material gave no steps specifically designed to keep the radiation levels less than to equal to 200 mR/hr at the surface of the package.
The procedures did call for:
(1) "All waste with high radiation levels should be encap-sulated in cement for shielding" and (2)." Solid waste can be placed in
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approved containers without cement if the radiation levels are low."
However, the procedures did not define high or low radiation levels.
Maximum radiation levels from the packages at contact and at 1 meter were i
to be determined after the packaging was complete.
Procedure No. OP-8301 provided instructions for shipment of radioactive material.
This procedure states, "To insure safe radiation and contamination levels, a Health Physics representative will perform a survey of the material to be shipped." This procedure called for completing the "Offsite Radioactive Record." The procedure also stated, " Specific instructions for maintenance of exclusive use shipment controls must be provided by the shipper to the carrier.
Such instructions must be included with the shipping paper information. Issue OPF-8301.4 (" EXCLUSIVE USE" VEHICLE INSTRUCTIONS TO CARRIER) to carrier."
As a result of the order from the South Carolina Department of Health and Environmental Control, Yankee Rowe revised the three procedures as described below.
Procedure No. OP-2381, Revision No. 7, CONCENTRATING AND DRUMMING EVAPORATOR BOTTOMS, now included reference to: 1) South Carolina Radioactive Materials License No. 97 and its latest Amendments; 2) CNSI Barnwell Site Disposal Criteria (latest updates); and 3) CNSIs USNRC Radioactive Materials License No. 46-13536-01 and its latest amendments.
The media for solidifying the evaporator bottoms was changed from portland cement to Miracle Lime 1-1-0 mortar.
This was done because this mortar solidified the boron
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containing evaporator bottoms much more satisfactorily than portland cement did.
A series of insoection steps were added to assure that: 1)
there was not unacceptable amount: of free liquid in the drums; 2) the sealing surfaces of the drum, cover, and gasket were clean and fynctional; and 3) the surface contamination on the drum was < 200 dpm/100cm.
Procedure No. OP-2382, Revision No. 5, SOLID RADI0 ACTIVE WASTE DISPOSAL, now included reference to: 1) 10 CFR 20; 2) South Carolina Radioactive Materials License No. 97 and its latest amendments; 3) CNSI Barnwell Site Dispcsal Criteria (latest updates); and 4) CNSI USNRC Radioactive Materials License No. 46-13536-01 and its latest amendments.
The step mentioned previously which called for waste with high radiation levels to be encap-suiated in cement for shielding was replaced with meaningful precautions based on dose rates as follows:
Waste material reading < 200 mR/hr contact may be processed according
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to the normal procedure outlined herein.
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Waste material reading from 200 to 1000 mR/hr must be packaged such that the radiation levels outside of the package are in compliance with the applicable regulation and such that the radiation levels outside the package will not change due to shifting of the material within the package under conditions normally incident to transportation.
Waste material readings in excess of 1000 mR/hr must be evaluated
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specifically for the need to provide shielding in order to comply with the applicable radiation levels outside the package or vehicles.
Alternatives may include encapsulation in cement, specifically designed containers incorporating distance and/or shielding, and cask shipments.
Refer to the special provisions of 10 CFR 71 for greater than TYPE A quantities.
Further changes in OP-2382 were as follows. If solid dry waste was placed into drums partially filled with solidified evaporator bottoms, the procedure called for insuring that the Radioactive Shipment Records and other applicable documents are updated to reflect the additional material.
The step mentioned previously which stated, " Solid waste can be placed in approved containers without cement if the radiation levels are low," was changed to refer to the precautions based on the dose rates given above.
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Finally, the following steps were added to the procedure.
Boxes or containers shall be packaged such that no shifting of the
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contents may occur during conditions normally incident to transporation which may cause violations of any applicable regulations.
(e.g.,
dose rates at the side of the vehicle)
Filter capsules in cement shielded containers shall be prepared such
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that the container is closed prior to shipment. (e.g., lids must by placed on drums)
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Containers for burial at Barnwell which weigh in excess of 600
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pounds shall be palletized to allow easy off-loading.
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Perform a survey of the package including the maximum contact dose rate, and the maximum dose rate at three feet.
Document the survey.
Procedure No. OP-8301, RADI0 ACTIVE MATERIAL SHIPMENT, was made considerably more extensive.
The REFERENCES were extended to include the federal and state licenses involved in preparing waste and waste packages for burial and transporting of waste packages.
The Plant Health Physicist was made responsible for safe packaging an'd labeling of all radioactive material leaving the plant site.
The following were additions to the procedure which should help assure proper preparation of waste for burial and transporation of the waste to the burial site.
For shipments of radioactive material for disposal, the shipment
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shall also be verified to comply with any burial site criteria and/or specific state or federal license provisions applicable to the material.
Up-to-date copies of burial site criteria shall be
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maintained at Yankee.
Only personnel trained in accordance with the Health Physics training
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program shall be qualified to prepare or authorize radioactive material shipments.
For shipments of radioactive material for disposal, insure that the
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disposal facility has been notified of the shipment and is prepared to accept it.
For shipments to Chem-Nuclear Systems, Inc. (CNSI),
detailed scheduling and allocation procedures must be followed or the shipment may be returned.
For specifics refer to CNSI's Prior Noti-fication Plan and also CNSI's Allocation Plan.
For shipments of radioactive material for burial:
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Complete the appropriate burial facility shipment forms and include them with the shipment papers.
Insure that the inspection and certification required by the State of South Carolina is completed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the shipment time (if applicable).
Insure that the radioactive material, its packaging, and the loading configuration on the vehicle meets all applicable burial site criteria requirements.
Insure that the load is properly blocked, braced, or otherwise
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secured to prevent any shifting or damage due to conditions normally incident to transporation.
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Perform a second independent vehicle survey for any placarded shipment
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within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to shipment time.
Document on OPF-8301.2 and include with all copies of the shipment papers.
'The licensee also revised the " Exclusive Use" Vehicle Instructions to Carrier form.
The following instructions are on the form.
This shipment of radioactive material is being transported in an
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EXCLUSIVE USE vehicle, loaded by Yankee Atomic Electric Company (the consignor) and must only be unloaded by the consignee (49 CFR 173.392(c)(4)).
Any removal, addition to, or movement of, any material in this
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shipment by anyone, except by the consignee, shall constitute a violation of federal law.
A closed van shipment :Sall not be opened, nor shall any shipment be
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changed or modified in any manner, except by the consignee, without the prior authorization of Yankee Atomic Electric Company.
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Routing Instructions:
State authorities in Massachusetts and Vermont have been notified of the following routes.
No deviation from these routes is authorized.
In the event of an emergency, accident, or contemplated deviation
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from any of the above instructions, notify Yankee Atomic Electric Company at:
(413) 625-6140 or (413) 424-5261.
5.
Analysis The McCormack's Highway Transporation trailer containing the LSA radioactive waste from the Yankee Rowe Nuclear Power Station as received at the Chem-Nuclear Systems, Inc. Barnwell Waste Management Facility had a radiation level at the surface of the trailer in excess of the 200 mR/hr limit given in 49 CFR 173.393(j).
The source of the radiation in excess of 200 mR/hr was a wooden box of waste. When the box was loaded on the trailer, the radiation survey made by Yankee Rowe showed a maximum radiation level of 100 mR/hr from a location in the middle of a side surface of the box.
The wooden box of waste was moved from the position it originally occupied by McCormack's Highway Transportation to redistribute the weight over the axles to meet State requirements.
The box was moved so that the side with the highest radiation level was next to the surface of the trailer.
If the radiation level at the surface of the box was 100 mR/hr, repositioning of the box next to the surface of the vehicle would not have caused the radiation at the surface of the trailer to be in excess of 200 mR/hr.
For the radiation level to increase from 100 mR/hr to the level greater than 200 mR/hr, either the radiation at the surface of the package changed or the radiation survey performed by Yankee Rowe was inadequate or incorrect.
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Yankee Rowe maintains that the radiation level from the side of the box changed after the box left their facility.
They claim that a piece of waste with high radiation moved closer to the surface of the box, when the box was repositioned by the carrier.
The fact that Yankee Rowe stated cn the Barnwell Waste Management Facility Radioactive Shipment Record Form that the box contained compacted dry waste would tend to refute this, because it would be difficult for a piece of waste to move through the compressed waste.
Yankee Rowe stated that the box actually contained noncompressible waste rather than compacted waste, contrary to the statement made of the Radioactive Shipment Record Form.
They felt that a piece of waste with high radiation could move in a box containing noncompressed waste.
They felt that this movement probably occurred when the box was moved by the carrier.
It is probable that, if the box had not been relocated and the piece of waste moved, the radiation level at the surface of the vehicle would have been less than 200 mR/hr.
There probably would have been sufficient distance between the source of the radiation in the box and the surfaca of the vehicle to cause the radiation level at the surface of the veh'cle to be within the limit.
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Corrective Action The licensee has taken the following corrective action which should prevent recurrence of this situation.
The licensee's procedures now call for measuring the radiation from
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individual pieces of waste prior to placing the waste in the box.
The licensee's procedures now call for packaging the waste so that
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no shifting of the contents can occur during transport.
The licensee's procedures now call for insuring that the load is prop-
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erly blocked, braced, or otherwise secured to prevent any shifting or damage due to conditions normally incident to transportation.
The licensee's procedures now call for a second independent vehicle
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survey for any placarded shipment within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to shipment time.
The licensee has revised the " Exclusive Use" Vehicle Instructions to
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Carrier to include the following statements which would control the movement of containers in a vehicle.
"Any removal, addition to, or movement of, any material in this shipment by anyone, except the consignee, shall constitute a violation of federal laws.
A closed van shipment shall not be opened, nor shall any shipment be changed or modified in any manner, except by the consignee, without prior authorization of Yankee Atomic Electric Company."
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7.
Findings The causes for the McCormack's Highway Transporation trailer containing Yankee Atomic Electric Company LSA waste having radiation levels at the surface of the trailer in excess of 200 mR/hr, when received at the Chem-Nuclear Systems, Inc. Barnwell Management Facility appear to be es follows.
Yankee Atomic Electric Company placed a piece of noncompressible waste having radiation in excess 200 mR/hr in a wooden box containing noncompressible waste in such a manner that the piece was not fixed in position. While the waste shipment was in transit, the piece of waste moved closer to the surface of the box and the radiation level at the surface of the box exceeded the 200 mR/hr level.
McCormack's Highway Transporation moved the wooden box so that the surface of the box with the high radiation level was next to the inside surface l
of the trailer.
The surface of the box with the high radiation was placed close enough to the surface of the trailer so that the radiation
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at the side of the trailer excaeded 200 mR/hr.
The packaging of the piece of waste in such a manner that it moved and caused the radiation level to exceed 200 mR/hr was not contrary to DOT regulations. The waste was LSA radioactive waste transported in an " exclusive use" vehicle, and under 173.392(b) and (c), Low specific activity radioactive material, was exempt from specifications, packaging, marking, and labeling provided certain requirements were met.
The specific requirements to be met did not require that internal bracing must be adequate to assure that, under the conditions normally incident to transportation, the distance from the radioactive material to be the outside wall of the package remains within limits (49 CFR 173.393(d)(1)).
Yankee Atomic Electric Company was the consignor and shipper of the waste shipment.
And, as required by 49 CFR 173.389(o), Radioactive materials; de-finition " exclusive use", Yankee Atomic Electric Company was the single consignor having the exclusive use of the McCormack Highway Transporation tractor-trailer, and Yankee Atomic Electric Company provided the loading of the trailer.
Yankee Atomic Electric Company as consignor and shipper of the waste was also responsible for assuring that the requirements of 49 CFR 173.392(b) and (c), Low specific activity radioactive material, were met.
Yankee Atomic Electric Company did provide the specific instruc-tions for maintenance of exclusive use shipment controls to the carrier as required by 49 CFR 173.392(c)(9). However, these instructions did not specifiy th&t the packages in the shipment could not be moved by the carrier without prior authorization by Yankee Atomic Electric Company.
It appears that Yankee Atomic Electric Company did meet the requirements of 49 CFR 173.392(c)(9) and there was no item of noncompliance involved in the instructions to the carrier.
It is important to note that the licensee did change the specific instruction for maintenance of exclusive use shipment controls to the carrie. _ -_.
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Yankee Atomic Electric Company and Chem-Nuclear Systems, Inc. are not conducting the activities involved in the loading of waste on transport vehicles and transporation of the waste to the Barnwell burial site in accordance with the purchase order dated May 8, 1979, issued to Chem-Nuclear Systems, Inc. by Yankee Atomic Electric Company and acknowledged by Chem-Nuclear Systems, Inc. Also, Yankee Atomic Electric Company and Chem-Nuclear Systems, Inc. do not agree on when possession of the radioactive waste and responsibility to the waste transfers from one company to the other company.
8.
Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on February 20, 1980. The inspector j
presented the scope and findings of the inspection.
The inspector indicated that the licensee's failure to provide specific instructions to the carrier which would prevent the carrier from the changing the location of the packages inside the trailer appeared to be
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an item of noncompliance with 49 CFR 173.392(c)(9).
Review of the situation with the Regional Office and Headquarters resulted in the decision that the licensee had met the requirements of 49 CFR 173.392(c)(9).
However, the licensee should and did change his specific instructions to the carrier to provide more adequate " exclusive use" shipment controls.
This information was given to the licensee in a telephone call on March 10, 1980.
The inspector also indicated that the purchase order dated May 8, 1979, issued by Yankee Atomic Electric Company to Chem-Nuclear Systems, Inc.
and acknowledged by Chem-Nuclear Systems, Inc. caused some questions as to which company was actually the consignor for the waste shipment.
Review of the entire situation shows that Yankee Atomic Electric Company was the consignor for the waste shipment.
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