ML20147J242
| ML20147J242 | |
| Person / Time | |
|---|---|
| Issue date: | 07/31/1978 |
| From: | Grella A, Nussbaumer D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS), TRANSPORTATION, DEPT. OF |
| To: | |
| References | |
| STAT-780731, NUDOCS 7810270308 | |
| Download: ML20147J242 (202) | |
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\p Transportation of Radioactive Material I Joint Study Group U.S. Nuclear Regulatory Commission U.S. Department of Transportation I. Ex,ecutive Summary July 1978
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TRANSPORTATION OF RADI0 ACTIVE' MATERIAL
Background
In September 1977, an accident involving a truck shipment of uranium ore concentrate;(yellowcake) occurred near Springfield, Colorado. Several tons of yellowcake were spilled on tha ground. Although the effects of thisspillonthepublichealthandsafetywerevery.small,M the unusually large amount of. material spilled combined with uncertainties in the overall management of the incident focused public attention on the trans-portation of yellowca'ke in particular and of all radioactive materials in general. Congressman Wirth of Colorado' requested the Nuclear Regulatory Commission (NRC) and the Department of Transportation (DOT) to review and assess the regulations and practices related to package integrity and to E
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emergency response to transportation accidents involving radioactive ,,,
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materals. Anagendaoftopicsforthestudy,E given in Table I, was agreed upon for between the staffs of the NRC, the DOT, and Congressman l
Wirth. The study was to take about six months.
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Letter-from A. J. Hazle, Direc. tor, Radiation and Hazardous Wastes Control, Colorado Department of Health, to R. P.'Pollock, Director, The Citizen's
. Movement' for' Safe and Efficient Energy (January 16,1978). '
2 The general: subject areas examined in this study have been recently l analyzed, publicly reviewed, and reported in the NRC environmental impact statement " Transportation of Radioactive Materials by Air and Other Modes," NUREG-0170, which was published in December 1977. The present study represents a' reexamination of certain' specific topics as
. identified in the study agenda.
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TABLE I. TRANSPORTATION OF RADI0 ACTIVE MATERIAL STUDY AGENDA l
The following is a list of actions related to safety in transportation of radioactive materials which the NRC will evaluate in coordination with DOT. The evaluation will include consideration of feasibility, practi-cality, authorities and cost-benefits.
i (1) A modification of NRC rules to require licensee shippers to prepare and maintain emergency procedures to be followed in the event noti-fication is received that a licensee's shipment is involved in a ;
transportation accident. This will include development of the '
various elements which the emergency plan should contain. Agreement States would be encouraged to adopt similar requirements.
(2) Require that changes be made in the method of shipping LSA materials i including specifically natural uranium oxide, to increase surviva- .
bility in transportation. A short-term study (about 6 months) will '
be undertaken to investigate what changes might be made. Changes to be investigated will include: (a) heavier gauge drums; (b) improved drum closure methods; (c) tie-down systems; and (d) type of vehicles ;
to be used. l i
(3) Require that ap information packet accompany each shipment of i hazardous materials (radioactive). The package would contain infor-mation concerning the hazardous nature of the material in the ship- I ment, the precautions to be taken in the event of leakage or spillage under normal or accident conditions of transport, and -
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notification requirements.* ~
34 (4) Require routing control for certain types of shipments; e.g. , so as to avoid densely populated areas and adverse road conditions.
(5) Clarify Federal, State, local, carrier and shipper response and responsibilities in the event of an accident.* .
(6) Clarify financial responsibility for coping with accidents, including clean-up and recovery.
(7) Develop a system for obtaining up-to-date transportation data; e.g.,
types, quantities, etc.
(8) Develop a system for advance notification of shipments of radioactive materials.
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. TABLE I (Continued)
(9) Increase the DOT inspection capability'for transportation of hazardous- I
materials.*
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(10) Other facets'of emergency preparedness not mentioned above.
r Time Table:
.The above s'tudy is expected to be. completed in about six months. Imple- !
mentation of recommendations for changes may take a year or longer, where changes-in DOT.or NRC regulations are necessary. ~
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"In the study,. consideration.is limited to radioactive materials from the full spectrum of hazardous materials.
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.h A Study Group comprised of' representatives from the NRC and the DOT was formed to consider the items on the agenda and to report on those con-siderations. The report consists of two parts: an executive summary and a more detailed discussion. In the executive summary, each item is briefly discussed to identify problems, summarize issues, and express conclusions of the Study Group. The recommendations of the Study Group are given at the end of the executive summary.
Discussion The observations and conclusions of the Study Group for each agenda item are s:nmarized below:
Observations and Conclusions Item (1) A modification of NRC rules to require licensee shippers to _
prepare and maintain emergency procedures to be followed in the ., .;
event notification is received that a licensee's shipment is " -
involved in.a transportation accident. This will include development of the various elements which the emergency plan should contain. Agreement States would be encouraged to adopt similar requirements.
Item (5) Clarify Federal, State, local, carrier and shipper response and l responsibilitiesinthpeventofanaccidentinvolvinglow-level radioactive materials E Although the discussion is ' restricted to low-level radioactive materials, 1
many of the general principles also apply to all radioactive materials.
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]f Items (1) and.(5) will.be discussed together, since the resolutions of 1
each are interdependent. Four substantially different parties are' involved in emergency response to a transportation accident .
involving any radioactive material: the Federal government, State (including both Agreement States and non-Agreement States) '
and local governments, the carrier, and the shipper. The l
responsibilities shared by these parties related to trans-portation accidents are complex and can be formalized through regulations or guidanc'e for shippers and carriers and through 1
formal agreements among Federal, State, and local agencies.
Our present views on the primary responsibilities of each party are given as follows: l l
,y (a) The Federal government (primarily the NRC and the 00T) is '#
1 responsible for regulating safety aspects of carrier and shipper activity; designating prior to an accident responsi-bilities in emergency response to the accident; supplying guidance and assistance to State and local governments in planning effective response to transportation accidents when they occur; advising response personnel at the scene of an accident on request (this function is primarily executed by the Department of Energy, see Item (10)); and inv'estigating the
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causes of an accident, taking-steps to prevent recurrence,'and o
enforcing compliance of carriers and shippers with Federal regulations.
(b) State and local governments are responsible for regulating certain aspects of carrier and shipper activity within their j borders (vehicle weights, speed limits, routing away from weak roads or bridges, etc.); controlling the scene of an accident, implementing protective action if necessary; and developing emergency response plans for protection of public health and safety. State and local agencies, such as emergency crews, police, health and environmental departments, should have emergency plans both to advise and assist the carrier and to take appropriate control actions at the scene to assure protec- ,
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tion of public health and safety. These agencies are expected 4 to exercise their police and emergency powers to control traffic, provide communications, direct evacuation and sheltering actions if necessary, and direct cleanup of private property. !
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1 (c) Under existing Federal regulations, the carrier is responsible j i
for promptly notifying the shipper, the State and local govern- !
i ments, and the Federal government of accidents; controlling the f
. i spread of radioactive material in the cargo; isolating the 1
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1 ikli radioactive material from the populace; and cleaning up any spilled radioactive ~ material. In practice, the carrier.usually relies on expertise and services of others to accomplish these duties. - The carrier would depend on advice from the shipper (including the procedures in the shipper's plan described below), an Interagency Radiological Assistance Program team, or-State and local agency teams or representatives who may respond to the accident scene.
(d) In an accident, the shipper is clearly the most appropriate carty for'providing hazards information on a shipment of radioactive material.
(c,d) To fulfill its responsibility for emergency response actions
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most effectively, the carrier should be required to p'repare, '
8 maintain and execute an emergency response plan for these actions. To most effectively use its knowledge in emergency response actions, the shipper should be required to prepare and maintain an emergency plan for promptly conveying hazards information to the carrier and government authorities. The shipper plan should describe clearly and simply the hazard associated with the material, a recommended procedure for isolating any spilled material from the popul' ace, precautions
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! ., . . . . . . . . . , b ifor handling'each package orLspilled material , equipment; i ~
. required;(including'n'ew' packages).for cleanupjand availability '
a of(such[ equipment:, Land sources of advisory an'd cleanup personnel.- .
The_ shipper plan shouldi be available at a11l times;so shipper-
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_ personnel can knowledgeably and promptly inform,7 say;by telephone, y inon'-ship'per personnel requesting adviceabout.an accident.
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,j Item-(2) iRequire that changes be_made in the' method of~ shipping LSA .
- materials including specifically. natural ' uranium oxide, to_ .
lincrease. survivability'in transportation. A short-term' study ,
. (about 6' months) will be undertaken to investigate what changes- i might be made.~ Changes to be investigated will' include: 3 (a)' heavier' gauge' drums; (b): improved drum closure methods; i (c) tie-down systems; and (d) type of vehicles to be' used. l r
At present,clow specific activity'(LSA) materials, such as yellowcake, . j
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.are most. commonly transported.in' exclusive-use vehicles and in strong, )i tight- industrial packaging to prevent leakage under normal transportation ,j conditions.- The risk'of transportation of LSA; materials is very sma11L Mi although.the number of LSA packages shipped each year _ is large. Assess-
-ment of the health and safety consequences.of'an accidentalfspill of such material indicates (that a requirement for more accident resistant packaging than currently'u' sed.is-not'necessary. Improvements'in closure methods of
-steel. drums, which are used to-transport yellowcake, to increase their l
- integrity lare feasible, but.not cost-effective and therefore should not
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be. required.
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(a) As for requiring heavier gauge drums, the strength of a material generally increases with thickness of the material, especially against uniform axial, internal pressure, external; pressure, and crush loading, but not necessarily against. impact loading. Since accident experience (Colorado 1977) and package testing (Sandia Laboratories 1976)'do not indicate that failure of material walls or seams is significant compared to loss of lids, improving drums oy requiring heavier gauge construction does not appear to be necessary or advantageous and should not be required.
(b) Accident experience and package testing do show that loss of lids on drums used to transport yellowcake contributes to spillage of contents in severe accidents. Improvements'in lid closure methods are feasible, but do not improve safety significantly, essentially because any ,,
spilled material has low concentration of radioactivity. The equipment ~
costs are comparable to or exceed the decontamination cost of a severe accident and exceed a reasonable expenditure for saving dose from a severe accident. The minimum equipment costs are realized only from effective cost control practices. Thus, such improvements are only marginally cost-effective. For these reasons, requirements for such improvements should not be imposed.
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- (c) Current' DOT regulations (49 CFR Parts 174, 177, and 393) require.
. restraints against shifting or loss of cargo under conditions normally incident to transportation. For LSA' materials, tiedown requirements exceeding those in force.are technically feasible, but do not improve safety significantly, since any spilled material has low concentration of radioactivity. Such improvements are not cost effective because both equipment and installation labor costs exceed the decontamination cost of a severe accident and exceed a reasonable expenditure for saving dose from a severe accident. For these reasons, tiedown requirements exceeding those in force should not be imposed.
(d) Requirements for specially designed vehicles must be coupled with requirements for tiedown devices or package closure improvements . .,
capable of withstanding the forces generated in severe accidents to "l realize a reduction in the quantity of LSA material.that might be spilled. As the latter improvements are generally not cost-effective, requirements for specially designed vehicles are even less cost-effective. )
Item (3) Require that an information packet accompany each shipment of radioactive materials. The package would contain information l concerning the hazardous nature of the material in the shipment, I the precautions to be taken in the event of leakage or spillage
.under normal or accident conditions of transport, and notifica-tion requirements.
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FT i Present 00TIregulations (49 CFR 172.200-172.203) require that shipments of radioactive materials be . accompanied by a description of each radio-
- nuclide contained, its.. chemical and physical form,.its radioactivity, the ,
' label' category and transport' index (measure of external radiation levels), -
and whether the package is Type A or Type B (accident resistant). According to accident experience, a change in the DOT regulations to require additional hazards information, for instance the nature of the material or precautions to be taken in the event.of its leakage or spillage, above that already required on shipping papers, vehicle placards, package labels, or other package markings is not necessary. However,-the addition of an emergency telephone number on package labels or shipping papers could assist emergency response in the event'of an accident and should be required.
Item (4) Require. routing control.for certain types of shipments; e.g.,
so as to avoid densely populated areas and adverse road conditions. i 1
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- 1 Current DOT regulations (49 CFR 397.9) require that "Unless there is no practical alternative, a motor vehicle which contains hazardous materials must be operated over routes which do not go through or near heavily populated areas...." Almost all of the large cities on the limited i number of highways over which yellowcake is transported have by passes j which would be considered " practical alternatives" to passing through the city centers. Any yellowcake shipments seen passing through densely ]
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populated areas should be reported to the DOT for investigation and i possible enforcement-action.
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Ih St'te a and lecal agencies currently designate roads with adverse conditions as unsafe for transportation and limit use of such roads if necessary.
The risk to public health and safety from shipments of LSA material, including yellowcake, is very small essentially because of the low con-centration of radioactivity distributed throughout the material. In view of the limited number of routes normally used and of the low risk, no additional routing controls appear to be necessary for yellowcake ship-ments.
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For other radioactive materials, the matter of routing control is presently under separate studies: the NRC environmental statement on transportation of radionuclides through urban environs and the D0T public rulemaking proceeding on the routing of highway movements of radioactive mata. rials.
The draft NRC environmental statement is expected to be published for '
comment this fall. The DOT rulemaking proceeding can be anticipated to take about two years.
Item (6) Clarify financial responsibility for coping with accidents, including clean-up and recovery.
Ultimate financial responsibilty for damages resulting from a transporta-tion accident involving radioactive material depends on the particular circumstances associated with the accident and is usually settled in the courts. If the origin or destination of the radioactive material being
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transported _is an indemnified facility (e.g., a nuclear power plant),
then the provisions of the Price-Anderson Act [42 USC 2210] assure a source of funds ($560 million per nuclear incident) for personal injury or property damage resulting from the transportation accident. These funds would be provided by a combination of facility licensee insurance and federal government indemnity. However, transportation of many types of radioactive material, particularly yellowcake, is not covered by the Price-Anderson Act. In the event of an accident involving transportation of these radioactive materials, liability for damages would be determined I according to the applicable state tort law.
1 Aside from the question of ultimate financial responsibility for a trans-portation accident involving radioactive material, the carrier should be prepared to assume initial costs required to discharge his responsibilities ,y
[ listed in discussion of Items (1) and (5)] and the State or local agency '
involved should be prepared to assume initial costs incurred because of protective actions required by the agency as in other emergency situations, e.g., fires, ficods, etc.
Item (7) Develop a system for obtaining up-to-date transportation data; e.g., types, quantities, etc.
Collection of radioactive material shipment data does not directly improve transportation safety. However, such information is ne.cessary to estimate, either on a national or regional basis, the risks to society from transporta-tion and the impact of changes in the safety regulations on shipments.
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An occasional survey involving a significant sample'of shipments made in the U.S. may be sufficient to' satisfy.this need for such information. A
. system for maintaining up-to-date transportation' data would not contribute 1
more in terms of safety than an occasional survey because the volume of shipments is large and does not vary significantly from year to year. If any one type of' shipment increases significantly, a separate survey may be conducted to obtain information on that specific type of shipment.
Based on the previous shipment survey conducted in 1975, the cost to obtain up-to-date information for all shipments of radioactive materials in the U.S. appears prohibitively expensive, probably more than one million dollars per year. Accordingly, a system for maintaining I up-to-date transportation data should not be imposed. l l
Item (8) Develop a system for advance notification of shipments of radioactive materials. _
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Here advance notice from a shipper to a State or local agency of a ship-ment of radioactive material does nothing to improve public health and safety. If the advance notice is coupled with some followup action, such as a police escort of the shipment, independent surveillance of the shipment, or notice to emergency response teams along the route, then safety might be improved. In view of the low overall risk to public health and safety from transportation of radioactive materials, as esti-matedinarecentNRCenvironmentalstatement,M little. increase in E " Transportation of Radioactive Materials by Air and Other Modes,"
NUREG-0170 (December 1977).
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hgfg safety would result from such actions. .However, some States desire to obtain.s'uch information. State or local requirements for advanced notification of shipments of formula quantities of special nuclear '
material, as defined in 10 CFR Part 73, or of classified material should not be imposed; such requirements conflict with Federal requirements and may compromise physical security measures.
Item (9) Increase the DOT inspe radioactivematerialspioncapabilityfortransportationof The compliance efforts of the 00T in transportation of radioactive materials are an integral part of the Department's overall program in compliance and enforcement of the hazardous materials transportation regulations. Radioactive materials therefore are not specially singled i out and treated. separately in this activity. Experience indicates that such materials have been transported very safely. When measured against. ,, ,
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actual experience therefore, the present staff level of compliance and enforcement in transportation of radioactive materials is appropriate. l Item (10) Other facets of emergency preparedness not mentioned above.
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Many activities are focusing on emergency response to accidents in trans- i portation of all radioactive materials. The Federal government conducts 1
E etter L from J. M. Hendrie, Chairman, U.S. Nuclear Regulatory Ccamission, to the Honorable T. E. Wirth, U.S. House of Representatives (January 10, 1978). This item is addressed by the 00T since it relates solely to their staffing requirements. ;
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an Interagency Radiological Assistance Program. The Department of Energy, as lead agency in this nrogram, operates and maintains extensive capability to respond to. radiological accidents. These response teams can advise
-the State and local agencies and carriers responsible for protective actions on radiological matters. The NRC and the DOT sponsor a training course for response to radiological accidents, including transportation accidents, at the Department of Energy Nevada Test Site. The American National Standards InuJtute drafted a standard entitled, " Emergency Response Procedurt ior Highway Transportation Accidents Involving Radio-active Materials," i-692. Communication between Federal and State
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governments on all aspects of transportation of radioactive materials has been improved through the State surveillance program jointly sponsored by the NRC_and the DOT and through the establishment of State Liaison Officers.
The State surveillance program in which 12 States have participated ., ;
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serves to familiarize them with transportation of radioactive materials #
and its emergency response requirements and to augment the Federal inspection capability in a significant way.
Recommendations The Study Group makes the following recommendations concerning emergency response to transportation accidents involving radioactive materials.
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1.- . State and. local agencies, such as emergency
-crews, police, health'and environmental departments, should have emergency plans to
-both advise and assist the carrier and to-take' appropriate control actions _at the scene to protect public health and safety.
The NRC and the DOT should foster develop--
ment'of-these plans.
- 2. Carriers of radioactive material should be required.by'the DOT regulations.to prepare, maintain, and execute.an emergency response-plan for promptly notifyin'g the shipper and government authorities, controlling the spread of radioactive material in the cargo, segregating the radioactive material from the populace, and cleaning up any spilled radioactive material.
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- 3. .The shipper should be required by NRC and DOT regulations to prepare, maintain, and execute an emergency response plan for promptly convey-ing hazards information about the shipment to the carrier and ~ government authorities. This i plan should be'available at all times so shipper ,!
personnel can respond knowledgeably and promptly .
when they receive notice of an accident and- '
are asked for advice.
- 4. Addition of an emergency telephone number on package labels or shipping papers should be required by DOT regulations.
- 5. The carrier should be prepared to assume !
. initial costs for his responsibilities and l
. State and local agencies should be prepared to assume initial costs for protective actions involving. radioactive material as with other emergencies where protection of public health
-and safety is involved. .
- 6. The NRC and the DOT should initiate discussions with States on the merits of advance notice requirements for shipments
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of radioactive material. If an' advance .
notice requirement is. judged necessary, a J
national requirement is preferred over a conglomeration of: State requirements.
7.- ' Efforts:of-the NRC and the DOT to cooperate with
.the States in the surveillance program to evaluate.
compliance with the Federal regulations for safe '
transportationfof. radioactive materials should
- continue.
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' TRANSPORTATION OF RADI0 ACTIVE MATERIAL- t P
Joint Study Group. ..
U.S. Nuclear Regulatory Commission- 'l U.S. Department of Transportation 'l 1
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. II. . Study Report ~ . .
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' July 1978 "l .
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TABLE OF CONTENTS o P_ag_e ,
' EXECUTIVE
SUMMARY
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I. PRELIMINARY...............................................
II. -ASSESSMENT OF REGULATORY ASPECTS OF' TRANSPORTATION -
ACCIDENTS INVOLVING RADI0 ACTIVE MATERIAL.................. 1 5
LA. Preparation of Radioactive Material for Shipment.....
'1. Packaging of Low Specific Activity Radioactive !
Mater 1al........................................
- a. Material Form..............................
- b. . Package' Designs............................
- 2. Shipment Configuration..........................
- a. Tie-Down Systems...........................
- b. Vehicle Design.............................
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- 3. Shipment; Planning............................... -
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- a. Routing Contro1............................
b .- Speed Control.............................. ;
- c. Advance Notification....................... ~
- d. Up-to-Date Transportation Data System......
4.- Hazards Information.............................
- 5. Inspection of Regulatory Compliance.............
- a. NRC~ Inspection and Enforcement.............
- b. 00T Compliance Assurance...................
B. Transportation 1of Radioactive Material...............
-1. Review of Past Events........................... '!
- 2. Description of the Colorado Accident............
'3. Emergency. Response..............................
- a. Safety Responsibilities....................
- b. Financial Responsibi1 ties.................. )
- c. Role of the Federal Government.............
- d. Other Facets of Emergency Response......... ,
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, LIST OF TABLES P_ age I.. Transportation of Radioactive Material Study-Agenda.................................................. >
II. . Key Between Agenda Item and Report Section(s)...........
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III. Summary of Test Results and Cost Information on Closure Designs'for Drums Containin Radioactive Materia 1...........................g.....................
IV. Conclusions of Sandia Drum. Test Study...................
V. Closure. Techniques. Rated by Categories..................
VI. Estimated Annual Costs'for Yellowcake-Shipment
. Restraining' Systems.....................................
VII. DOT Compliance and Enforcement Activities............... -
LIST OF FIGURES-
- 1. Attachment of 6-Inch Extension to Standard Lid...........
- 2. Packaging with.6-Inch Internal Lid.........'.............. - J. ,
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3a. C-Clamp with: Lock Ring...................................
3b. C-Clamp without Lock Ring................................ .
4a. Details of Top and Bottom Clips Welded to Lock Ring......
4b. Extension of Lock Ring...................................
S. Sketch of Drum' Closure Design _(U.S. Reg. Pat.
No.'3,790,020) z APPENDICES I.- Joint Study Group Members...............................
II Instructions for Emergency Action Included in the
- Shipment which was Accidentally Spilled in Colorado '
September' 27,1977.......................................
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.ppw mgh0 b hlb APPENDICES (Cont'd)
Pafte III.' Department of Transportation Regulations (49 CFR) Pertaining to Hazards Information Accompanying a Shipment of Radioactive Material.........
IV. Some Correspondence Concerning the Colorado Accident....
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I. PRELIMINARY' In Septimber 1977, an accident involving a shipment of uranium' ore concen- !
trateL(yellowcake) occurre'd near Springfield, Colorado. Several tons of i
yellowcake were spilled on the ground. .Although the effects of'this
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spill 'on the public health and safety were'.very small,M the. unusually large amount of-material spilled combined with uncer?.ainties in the overa11' management of the incidt-t focused public attention on the.trans-portation of. yellowcake in particular and of all radioactive materials in general. . Congressman Wirth of Colorado request'ed the Nuclear Regulatory Commission (NRC) and the Department of Transportation (DOT) to review and' assess the regulations and practices related to package integrity and to emergency response to transportation accidents involving radioactive materials. An agenda of' topics for the study, given in Table I, was agreed upon between the staffs of the NRC, the 00T, and Congressman Wirth. - _J.,
The study was to take about six months. '
These two agencies formed a joint study group to accomplish this review and assessment.asLreported in this document. The members of the joint
. study group are named in. Appendix I. For continuity of discussion, the report'is organized somewhat differently than'the agenda. To aid the
' reader, a. key between agenda item and section(s) of the report is given in Table II. '
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From-its inception in January'1975, the NRC has reviewed the existing regulationsand procedures for' transportation of. radioactive materials.
l As'part of this. review, the NRC. initiated in June 1975 a public rule-making proceeding regarding the packaging.and transportation of radio- '
active materials. With the technical; assistance of Sandia Laboratories,
- the NRC prepared an environmental impact statement to assess the impacts ;
' associated with the transportation of radioactive materials, including !
crelative costs and benefits'of alternative modes'of-transportation. .
.Information-derived from research'into the accident-resistant properties of-packages used for shipping plutonium and information from the NRC's 1975. Radioactive Material Shipments Survey were used in preparing the i
statement. The draft statement entitled " Transportation of Radioactive Materials by. Air and Other Modes," (NUREG-0034), was made available for l public comment in March 1976. About 30 letters of comment were received. ;
- p The final statement (NUREG-0170) was released to the public in December '
..H 1977.E
.I The study indicates that transportation of radioactive materials is being conducted under.the present regulatory system in an adequately safe manner. 'For example, routine shipments may be expected to add only one l latent cancer fatality per year and accidents only one case per 200 years, assuming 1975 accident and shipping rates. By 1985, it is expected that these' estimates might increase three-fold as a result of an increased I
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volume ~of. shipments. These. rates compare to a nationwide total of 300,000 cancer. deaths per year from all.causes.
. Consequently, many of the genera 1Lsubject. areas-referenced in the agenda for this joint' study have been' analyzed, publicly reviewed,'and reported in NUREG-0170. The present study represents a reexamination of certain i specific-topics as identif.ied in the study agenda. Accordingly, the. -l basic document'NUREG-0170 is' referenced freely in this report. l l
l Radioactive materials, packaged and offered for transportation, appear in
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'1 many forms. The radiological. hazard posed by the contents of these 1
packages varies over some eight orders of magnitude, depending on how the radiotoxicity.is measured. Some materials, such as spent fuel from nuclear. reactors, waste generated by reprocessing spent fuel, or irradiated .
,, g components of nuclear reactors or other fuel cycle facilities, are highly radioactive and must be well-shielded and well-contained by packaging when in the transportation system. In contrast a variety of materials appear at'the low hazard extreme of the spectrum and accordingly are not required to;be so well-contained when in the ' transportation . system, since factors other than packaging provide assurance of-safaty.
This report deals primarily with this.last category of materials. As may be expected, some of these low hazard materials are found in-nature and o
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' Table I TRANSPORTATION OF RADI0 ACTIVE MATERIAL STUDY AGENDA The following is a31ist of actions.related to safety.in transportation of radioactive materials which the NRC will evaluate'in coordination with .
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00T. The evaluation will include. consideration of. feasibility, practicality, authorities and' cost-benefits.
- 1. A' modification of NRC rules to require licensee shippers to prepare' and maintain. emergency procedures.to be followed in the event -)
notification'is.receited that a. licensee's shipment is involved in a .l transportation accident. This will include development of~the '
various elements which the emergency. plan should contain. Agreenient States'would be encouraged:to adopt similar requirements.
- 2. . Require _that changes'be'made in the method of shipping LSA' materials including specifically natural uranium oxide, to increase surviv-ability-in transportation. A short-term study (about 6 months) will ,
be undertaken to investigate what changes might be made. Changes tc !
be. investigated will include: (a) heavier gauge drums; (b) improved drum closure methods; (c) tie-down systems; and (d) type of vehicles to be used. ,
~
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- 3. . Require that an information packet accompany each shipmentiof '
u , ' u; hazardous' materials (radioactive). The packet would contain infor-mation concerning.the hazardous nature of the. material in the shipment, the precautions to be taken in the event of leakage or i spillage under normal or accident conditions of transport, and- 1 notification. requirements.*
- 4. Require' routing ' control for certain types of shipments; e.g. , so as to avoid densely populated areas and adverse road conditions.
~
- 5. -Clarify' Federal,. State, local, carrier and shipper response and responsibilities in.the event of an accident.*
- 6. Clarify financial responsibility;for coping with accidents, including clean-up and recovery.
- 7. . Develop'a system for obtaining'up-to-date transportation data; e.g., l
' types,1 quantities, etc.
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'8. sDevelopia . system: for:advanceinotification'of shipments--of radioactive.
materials.
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- 9. ; Increase the DOT inlspection capability for. transportation'of hazardous' - !
' materials.*-
j 10.-l0therLfacets.of emergency preparedn'ess'not. mentioned above.
j 1
~ Time' Table-1 The.above study-is expected to be completed'in about'six months. .Imple- -
1
--mentationi of recommendations" for changes may take a year or longer, where '
changes;in DOT 1or'NRC regulations'are necessary.
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"In the study, consideration is l'imited to radioactive materials from -
Lthe full spectrum of hazardous. materials.
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Table'II-KEY: BETWEEN AGENDA ITEM AND REPORT SECTION(S) -
.s Agenda' Item Report Section(s)
- 1. Emergency Planning Requirements II.B.3
- 2. Packaging Improvements .II.A.1,2
- 3. Hazards-Information Requirements II.A.4
- 4. . Routing Controls. II.A.3.a
-5. Safety Responsibilities II.B.3.'a
- 6. Financial Responsibilities. .II.B.3.b
- 7. ~Up-to-Date Transportation Data System II.A.3.d
- 8. Advance Notification System II.A.3.c-
- 9. Increase in DCT Inspection Capability II.A.5
- 10. 0ther Facets of Emergency Response .
II.A.S.b .
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also are transported in much larger volumes than are materials of greater hazard. Thesa low hazard materials include ores of uranium and thorium, which are basic fuel materials for nuclear reactors, concentrates of uranium or thorium oxides produced from processing those ores, purified uranium or thorium which has not been irradiated, aqueous solutions containing tritiated water, liquid and consolidated wastes, and activated solid materials. In addition, this category of materials has been expanded to include contaminated objects, for example, pipes and machinery which ordinarily would not be radioactive, but which bear radioactive material on their surfaces.
These low hazard materials may appear in many physical forms in the transportation system. Ores and concentrates are commonly shipped in bulk quantities, ores being unpackaged and concentrates being packaged.in.
containers'such as 55 gallon drums before being placed in cargo ~ spaces. '
3- l Larger containers, such as tanks, are also used. Liquids may be shipped in small packages, drums, or tank cars. Consolidated was'te or activated solid materials are usually shipped in drums, boxes, or concrete l containers. The common forms of lowly radioactive waste generated in the )
i nuclear power industry are evaporator concentrates, spent resins, filters, )
and miscellaneous solid material such as paper and rags. These wastes are solidified, dewatered, or compressed and shipped as consolidated wastes.
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Since these low hazard materials appear in theLtransportation system in much greater volum's e than do materials of relatively. greater hazard, and s'ince they:do not pose the degree of; safety concern that materials of greater hazard present, _ then for reasonable regulation of the' transpor-tation of these materials, the package standards for the low hazard-materials are made'less stringent than the package standards for higher
' hazard materials. Such a regulatory stance appears reasonable from both the_ views of properly protecting the public health and safety and of refraining from imposing undue economic burden on individuals'using the transportation system for commerce in these materials.
This stance was adopted many years ago by the regulatory bodies in the United States Federal government and by foreign nations through the International Atomic Energy Agency (IAEA). The IAEA has adopted a signi ,
.- 9 ficant number of definitions, rules, and advisory concepts which provide, '
- 1 for safe transportation of low hazard radioactive materials without requiring exacting package standards. Several nations have adopted outright or have essentially incorporated the IAEA regulatory system into their regulatory systems. TheUnitedStatesisoneofthesenations.E l
i In the United States, the U.S. Department of Transportation (DOT) and the U.S. Nuclear Regulatory Commission (NRC) share the responsibility for regulating safety in the transportation of radioactive ' materials. Other i
+
government entities, such as the U.S.. Postal Service, the States, and.
some local governments, also regulate this activity, but their regula-tions in most instances are compatible with the regulations of the 00T and the NRC. The DOT and the NRC partition their overlapping responsi-bilities by means of a Memorandum of Understanding, agreed to in March 1973, but now under revision. The regulations of these two bodies regarding the transportation of such low hazard materials as those discussed above are essentially patterned after the 1967 IAEA regula-tions. As explained in Footnote 3, the IAEA has revised some of these regulations in 1973 and the 00T and the NRC are now in the process of revising their regulations to reflect the changes.
Briefly, the current regulations of the U.S. agencies apply to a class of materials called Low Specific Acti ity (LSA) material, which includes.by , _ _, p definition unenriched uranium ano thorium ores and concentrates, materials '
l in which the radioactivity per unit mass or per unit volume is less than prescribed limits, and solids bearing surface contamination in less than prescribed densities. The concept underlying the regulation of the safe l transportation of these LSA materials is that-the concentration of radio- ,
l activity is low enough to obviate the requirement for rigorous packaging standards. The low concentration of radioactivity conceptually renders the material " inherently safe," considering radiological effects of the l
1 material, because it is highly unlikely, under any circumstances arising i i
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1 in the transportation of these materials,. including accidents in which I the material-'is released to.the. environment, that a person could take in
- enough material.to produce'a significant ' radiological effect.
Consequently, only minimal packaging standards are.necessary; operational.' controls may be.used to supplement these standards'to achieve safety in transportation.
~
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- II. ' ASSESSMENT 0F. REGULATORY ASPECTS OF TRANSPORTATION ACCIDENTS INVOLVING. !
RADIOACTIVE MATERIAL A. ' Preparation of Radioactive Material-for Shipment
- 1. Packaaina of Low Specific Activity Radioactive Material
- a. Material Form (1) Bulk material ,
Bulk solid low-level radioactive material may mean o ores of uranium or thorium (material as it.comes out of the ground), ,
._ p or '
o concentrates, physical or chemical, of ores of uranium or thorium (material--commonly called yellowcake.or greencake-- subjected to physical or chemical extractive processes and which may be granular, fine or. chunky, or evaporated precipitate), or o extracted product uranium or therium (material.that has been refined, l
but not enriched or irradiated and which could be monolithic metal j orgranular. solid),.or.
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[ : o' ' radioactivelmaterial in which the' radioactivity is essentially. .
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- tration.
Packaging; requirements for.this material are minimal'becauseof the small; j radioactivity; involved and because of the solid nature of the materia 1L y
~
Bulk liqu'id low-1evel. radioactive ; material may mean 1,
o- Radioactive water (tritium oxide)'in, aqueous solutions, or j o- Slurries of ores of uranium or thorium or concentrates'of these ores, or:
o . Aqueous solutions of. unenriched,- unirradiated uranium or thorium, or:
o .. -; Aqueous. solutions of. radioactive source, byproduct, special ' nuclear,.
or waste l material in which the' concentration of radioactivity is. .
-._ , a-
- smaller than. regulatory limits. "
Packaging: requirements.for this material are minimal because of the small concentration'of. radioactivity involved. Since the liquid-form increases the probability of release, some types of-shipments require preventive
,i
-measures,fsuch asiuse of a Type B' package or use of.-binding materials or l
- enough absorbent material to1 soak up twice the volume of the liquid ?
radioactive: contents of a package. Liquid radioactive ma'terial does not' differ much;from. sol'id radioactive material with respect to health' effects.
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~
' fuel. cycle facility process p.iping, ventilation ducts,'. housings, manu-
. facturing equipment,?and other components. Such material could also be empty vials of radioisotopes used in the practice of medicine or.any number of waste items. Packaging requirements for these materials are
' the -same as those for bulk material. Limits are set on fixed surface contamination ~, since. health effects from contaminated solids released from a . package. in an accident are limited primarily to radiation' field effects and. skin contamination transferred by touching the contaminated , -
m.- .
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. ,w , a .o solids. Under the regulatory requirements, the surface radioactivity is '
not readily dispersible and the amount of radioactivity.is small; conse- -l 1
quently, health effects are very small. 1 b - Package Designs.
.(1) . Philosophy The required integrity-of-the packaging should rightly be a function of the hazardithat' the radioactive material represents- to people. The radioactivo materials!for which packaging improvements are under study in
- this report are: called: low-level. radioactive materials because either the l
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or. the; concentration' of radioactivity is small by virtue of the; uniform-
- or'nearly uniform diNribution Ef. radioactivity throughout the material.
~
Sma110totalEradioactivity.andsmallconcentrationof-radioactivityboth i
mean)smalllhealth'. effects,evenwithithepremise'th'atno'thresholdexists. .
f inLthenumber.of. health.ef'fectspredicted~from'agivendoseofradiation..
Consequently,l packaging.r'equirements for low-level radioactive materials .
areLless' stringent than those for ma'erials t containing larger quantities
.ofJradioactivity.<
i In;1959, the regulations.in force for the safe transportation of radio-active;mateEial provided a'means whereby radioactive ores, slag or residues from' processing could be' carried in bulk or.in sacks or:other packaging suliject:to a. radiatiion control limit. When the IAEA panel convened in! _ ,
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1959 to review the international ' regulations for' transportation ~of such LSA materials,.both considerable experience and increasing shipping .
requirements' existed.
i The panel faced.the-problem of deriving a definitive basis by which
' transportation lof these materials:would be regulated safely but not be'
. unduly.restrictede :The panel'.s solution.was the~ concept that LSA
- materials must.be. inherently) radiologically safe,.that is, under any
, circum'stancesiarising'in transportation the~ possibility must be incon -
iceivable:of.LaLperson 'taking .in enough~ radioactive material to-cause-
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significant~ internal radiological health effects.
The resulting main purpose of the packaging is to facilitate such handling and transporta-tion.
The initial thinking was that ' inhalation of more than 10 milligrams (mg) of any radionuclide by any individual during a single exposure was unlikely. Inhalation by a working person of this much material requires breathing for 50 minutes an atmosphere laden with 10 mg of the radionuclide 3
for every cubic meter (m ) of air, assuming the breathing rate for a working person is 20 liters per minute (P/ min). .
Inhalation by a non-working person of this much material would require twice as much exposure time; for heavy exertion the breathing rate would increase by about 50 percent so the exposure time would decrease from 50,
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minutes to about 30 minutes.
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Such a concentration represents an extremely dusty atmosphere, as might occur'nsidebuildings.El For comparison, a typical dusty industrial 3
atmosphere has a dust concentration of about 0.33 mg/m . {/ and the average dust concentration in' metropolitan districts is 1.4 mg/m
- E [
Inhalation by a working person of 10 mg of dust in these atmospheres would require exposure times of 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> and six hours, respectively.
Vigorous agitation of dust producing materials can produce dust burdens 3
of 5000 mg/m , bat most of the dust settles to the ground within five
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l minutes.EI- IfL a working person were to breathe 'in this atmosphere for five minutes'he would inhale about 500 mg of dust. '
9 If the' Colorado' accident had produced a uniform dusty atmosphere comparable 5
to that produced from vigorous -agitation of dust producing materials, the volume of air with'this large a concentration can be seen to be small. !
Assuming all the material spilled on'the ground, 7000 lb,-was uniformly distributed in a hemisphere above a plane surface with a concentration of 3
5000 mg/m , one finds the radius of the hemisphere to be about 70 m (220 ft or 75 yd).
'The earliest reported measurementE/ofthelargestconcen'trationof .
uranium in air at the' site of the accident-(enclosed area sample) was about.6.1 x 10-10 mci /ml,. which is equivalent to 2 mg/m3 . During the. .
course of the cleanup operations, this measurement increased to about F
3.8 x 10 -8 mci /ml, equivalent to 125 mg/m3 . The largest reported open area measurement was about 3.1 x 10 -10 mci /ml, equivalent'to 1.0 mg/m3, The largest measurement on the perimeter of the working site was about t 1.1 x 10 -10 mei/ml, equivalent to.0.3 mg/m 3, which can be compared to the typical dusty industrial-atmosphere above. However, this concentration is a peak valub. The arithmetic average of- all 26 perimeter measurements reported'is about eight percent of this peak value.
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. I
Considering the long exposure times required to inhale 10 mg of a radio-nuclide'for the. low atmospheric concentrations actually measured in the
' 1977 Colorado yellowcake accident, the initial thinking of the IAEA panel about the small chance of such inhalation is confirmed for tais case. l However, the~ IAEA panel eventually chose an arbitrary upper limit of one mg for possible individual inhalation as the basis for defining LSA.
materials in the 1961 IAEA regulations. The reason for this change in i basis had to do with differences in dose commitment assumptions in establishingtheradiotoxicityclassificationschemeforradionuclides.M l
The 1973 revision of the IAEA regulations introduce further changes in the definition of LSA material. Each radionuclide is individually ]
classified by radiotoxicity instead of by groups of radionuclides.
Generally speaking, the concentration limits for most LSA materials are ,- . . - .
- ' 1 increased, since the previous concentration limits for each transport group were restricted by the most radiotoxic member. This relaxation is compensated by a decrease in the volume permitted in the definition of LSA material to the minimum volume to which the material can be reduced under conditions likely to occur in transportation, such as dissolution I in water with subsequent recrystallization, precipitation, evaporation, combustion, abrasion, etc. The environmental impacts of these changes arejudgedtobenegligible.E I
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(2)' Drums-One packaging design for transporting low-level . radioactive material'is a 1
metal. drum. In.the Colorado accident,_55 gallon steel drums with lids secured by bolted steel ring closures were used for a shipment by Exxon
- - Minerals Company of bulk solid uranium concentrate, commonly' called yellowcake, which is LSA' material by definition. Twenty nine of the 50 drums failed'in the accident by loss of the lid. Some 12,000 lb of the 40,329 lb total load were actually spf11ed, so that failure of 58 percent of'the drums resulted in a spill of 30 percent of the load. The average loss from each opened drum must have been about 414 lb, meaning that the average release fraction-from each drum was about 52 percent, since the average content of.each drum was about 800 lb. Undoubtedly some of the drums might have been severely smashed and possibly ruptured, say by failure of a wall seam or bottom weld, but the 1id loss is clearly the
_ .'n-* ; g mechanism chiefly responsible for such a large' release fraction.
- J' (a) Closures Tests have been carried out to study ways of improving drum closure methodstopreventsuchspillsinaccidents.E/ These tests were conducted on a drum of slightly different design than the strong industrial drum
)
involved'in the Colorado accident, but significant error will probably ]
I not be introduced in applying the results of these tests to an ordinary l 55 gallon steel drum.
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Most of the tests in the program consisted of free drops of the loaded drum from a height of 30 feet (9 meters) onto a flat, essentially-unyielding surface with the drum oriented in such a way as to maximize the probability of maximum damage. The package design must also pass a thermal test in which the package is exposed to a radiation environment of 1475F (802C) temperature for 30 minutes. However, since thermal tests ,
for each container were not feasible in the program, a failure criterion was established by which the package would be considered failed if the Celotex packing material within the drum was visibia after the drop test, since it would then be vulnerable to a fire in a real accident. This failure criterion allows use of the test results for nonspecified indus-trial drums, since failure of only the drum component of the test package is indicated.
-.5
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Sufficient testing was performed to determine the maximum or minimum
values of weight of the package required to observe this failure criterion.
Different methods of drum closure were tested; these methods are described as follows:
- 1. Standard lid with bolted lock ring;
- 2. Standard lid and bolted lock ring with a steel sheet extension welded onto the inner side of the lid and which fits inside the drum (Figure 1);
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Spot Weld Figure 1. - Attachment of 6-Inch Extension to Standard Lid
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- 3 .' JStandard lidLand bolted lock ring with' an inner lid inside the drum. 'I
/ }The inner . lid is a flat' steel sheet with a steel sheet extansion of .!
- varying width . welded onto the underside of the inner lid'(Figure '2);
4.- Standard lid' fastened to drum with' varying number of equally spaced C-clampswith and without the bolted lock ring (Figures 3a,3b);
- 5. Standard lid with a modified bolted lock ring, either by clips
! welded to the' underside of..the lock ring, by clips welded to the top-and bottom of.the lock ring and alternately spaced,.or by a steel sheet extension fitting around the outside of the barrel and welded onto'the underside of the lock ring (extended lock ring; Figures ,
4a,4b) i l
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- 6. Standard lid with a' bolted extended lock ring with moulded' rebber 9 4 gasket fitted tightly over the lid / container interface and compressed underneaththeextendedlockring(Figure 5).N/
Crush tests'were also conducted on specimens representing closure methods 1-4. :These tests consisted of applying static loads to loaded drums lying)on' the side, noting deflections and structural reactions with increasing' loads.until the failure criterion of visible internal packing was obtained. The-load was evenly distributed over the drum by means of an aluminum plate.
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Figure 3b. C-Clamn Without Lock Ring
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i Figure 4a. . .iDetails ' of Top and Bottom Clips Welded to Lock Ring I, 5 .
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t Figure 5. . Sketch of Drum Closure Design
' (U.S. Reg. Pat'.=No.. 3,790,020)-
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The test results.are summarized in Table II for our assessment purposes j here. More complete discussion of the tests, packages, and closure designs is given in Reference 10.
i i
For comparison, two drums which would be considered strong industrial i
packaging were subjected to the 30-foot drop test. At package weights of 800 and 600 pounds, the lock ring and lid were completely pushed off the drum, a severity of failure that was not experienced by the D0T Specifica-tion 17C drums in any of the other tests. These two data points suggest that packages meeting Type A package standards (normal transportation conditions) are significantly more accident resistant than are strong .
industrial packages. The magnitude of the weight for failure, however, !
is approximately the same for the 17C and industrial containers, so these data points also weakly support the hypothesis that these 17C test results , .... g v , .J can be transferred adequately to a strong industrial drum. ~l f
The Sandia report lists several conclusions and rates the different closure methods according to several criteria. These conclusions and
]
ratings are reproduced in Tables IV and V.
These conclusions and ratings indicate that feasible means to increase J accident resistance of LSA drums are available'. Such simple closure .I method improvements would not prevent accidental spills entirely, but they would limit the accidentally spilled material to small quantities. ;
1
' l 1
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Table III ,
SUMMARY
OF TEST RESULTS AND COST INFORMATION a
ON CLOSURE DESIGNS FOR DRUMS CONTAINING RADI0 ACTIVE MATERIAL Closure Design Modification PackageWeight(lgs)for Static Force (1bs) for Failure Estimated Unit Cost ($)
Modification to to Standard Failure Criterion to be Criterion to be Observed 100 Unit 1000 Unit St"ndard Lid Lock Ring Observed in Impact Testc in Crush Testd Order Order
- 1. None None > 600 110,000
- 2. Extension None >1500 120,000 (failure 45.00 33.75 shirt, 6-inch at , bottom of drum)
- 3. None, plus None skirted. inner -
lid
- a. 4-inch skirt 975 -
- b. 6-inch skirt >1000 120,000 (failure 60.00 45.00 of bottom of drum)
- 4. None C-clamps
- a. 6 C-clamps >1000 . 105,000 15.00 15.00 with lock-ring
- b. 12 C-clemps with 1000 -
9.00 9.00 no lock ring Adapted from Otts, John V., "Special Closure for Radioactive Shipping Container," SAND 75-0517, Sandia Laboratories, Albuquerque, NM 87115, (March 1976).
b If the internal packing material was visible after the impact or crush test, the package was considered failed, since it then would be vulnerable to fire.
c Thirty foot (9m) drop of the loaded package onto a flat, essentially unyielding surface, with package in orientation deemed to produce the most damage.
d Static load applied to loaded drums lying on the side, the load being evenly distributed over the drum by means of an aluminum plate. (,
9 e
Table III (Continued)
Closure Design Modi fication Package Weight (lbs) for Static Force (1bs) for Failure EstimatedUnitCost($_[
Modification to to Standard Failure Criterionb to be Criterion to be Observed 100 Unit 1000 Unit St~ndard Lid Lock Ring Observed in Impact Teste in Crush Testd Order Order
- 5. None Clips and extensi'cn skirt
- a. 6 clips under-neath standard lock ring 700 -
45.00- '33.75
- b. No clips with extended lock ring 700 -
45.00 33.75
- c. 8 clips alternately above and below standard lock ring 750 -
60.00 45.00
- 6. None Extended lock ring plus inserted moulded rubber gasket (U.S. Reg.
Pat. No. 3,790,020) >1000 , 14.00 e 12.60" e
Correction to Reference a included in a letter from Harry H. Fine Associates to Mr. Charles E. MacDonald, U.S. Nuclear Regulatory Commission, dated May 4,1978.
7 1.
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,d
' CONCLUSIONS,OF.SAa0IA DRUM. TEST STUDYa -
o
,a 1. The critical container weight of a' standard 17C closurejis 600 pounds.. !
L2. The criticaliciontainer weihht of a standard 17C container, neglecting i closure,;is' a minimum;of 1000 pounds.
3; : Thel"six-inch lid' extension" technique strengthens the '17C closure to a(critical container. weight'of 1500 pounds minimum, j
- 4. The""six-inch internal' lid" technique strengthens.the 17C closure to j
.a-critical container weight of-1000 pounds minimum.. A four-inch j internal. lid protects to 1000 pounds maximum.. ;
- 5. The'"C-clamp" technique' strengthens the'17C closure to:
- a. . 1000 pounds minimum with six'C-clamps over the lock ring, and b.. 950 pounds maximum with'12 c-clamps and no lock' ring.
- 6. The " clip" technique, using.eight clips,on the top and bottom of the lock ring, strengthens the closure to'800 pounds' maximum. :The. technique was '
not pursued beyond this point. -- -
m _ ,9
< , c.a
- 7. The-closure manufactured under U.S. Reg. Pat. No. 3,790,000 strengthens the~
17C closure: to a' critical container weight of 1000 pounds minimum.
- 8. The 17C lid closure fails a crush test at'110,000 pounds static load, -
.while' the 17C container bottom fails at 120,000 pounds. J
- 9. .Both the "six-inch lid extension" and "six-inch internal lid" techniques
- extend the 17 C closure failure beyond the container l bottom capability ,
of 120,000 pounds ~ static . load. i
- 10
- Using :six C-clamps and lock. ring, the "C-clamp" technique. fails to
.. improve the normal lid closure crush limit of 110,000 pounds.
s t
- a0tts',LJohn V.,f"Special Closure for Radioactive Shipping Container,"- ;
j; , SAND .75-0517, Sandia Laboratories, Aubuquerque, NM 87115-(. March 1976).
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Table-V a
CLOSURE TECHNIQUES RATED BY CATEG0FI'tS Vulnerability- .
Impact .
Static Added Redesign Ease of to Operator !
Protection _ Protection Cost Required: Assembly Error ..
6" Lid. - b '-
, Extension .1 1 2 No 1 1~
6" Inner l Lid .2 1 3 No 2 1 6 C-Clamp' on Lock-Ring 3 2 1 -No 3 2 l (Moulded Rubber Gasket & Extended Lock Ring c 2 ? 1 No 3 2 1
a 0tts, John V., "Special Closure for Radioactive Shipping Container,"
SAND 75-0517, Sandia Laboratories, Albuquerque, NM 87115 (March 1976).
b Category 1 is the best of three categories.
'- '---;. ~$
c
~
i 31 This closure was designed and patented under U.S. Reg. Pat. No. 3,790,020.
i i
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The risk to public health and safety from accidents to shipments of LSA materials is quite small. In NUREG-0170 (Table 5-9, p. 5-34), the highest such risk is represented by an annual expectation of 7.x 10 -4 latent cancer fatalities per year for 1975. This risk derives from transportation accidents to shipments of packages of mixed fission products and mixed corrosion products (MF + MC (LSA) in Table 5-9). The corresponding risk from yellowcake shipments 38 (U 0 in Table 5-9) is nearly ten times smaller.
This discussion illustrates that the value of taking regulatory action to protect against accidents involving LSA shipments can vary depending on '
the details of the shipments, but in no cace is the existing accident risk or the consequences of a single accident so high that action need be i taken without regard for its cost-effectiver ass. '
l l
The cost-effectiveness of requiring these improvements in drum closure
_. g methods may be examined by comparing the cost of the improvements with ~ '- ,
the possible savings in radiological dose and with the cost of decon-taminating the area affected by the spill. In this cost-benefit analysis, .
1 different parties pay the costs or reap the benefits. The shipper might be assesced the cost of improving drum closures, but the public as well as carrier and rescue personnel, who might be Federal, State, local
~
government, or possibly shipper employees are saved the radiological doses from spills that the closures would minimize; the carrier is saved l
most of the cost of decontamination from the resulting minimization of spills.
-I34.-
2AFI From Table III, the cost of improving drum closures varies from $12.60-$60 per drum.' This cost is significant when compared to the probable price '
S range'of $10-$20 for a' single drum. The drum contains valuable material, t but this value does not enter the cost effectiveness consideration because none of the material would be-lost:in an accident in which the spilled material is recovered. In the standard shipments model developed in NUREG-0170, a standard shipment of drummed yellowcake was estimated to hold 40 drums. In the Colorado accident, the trailer was loaded with 50 drums; which is probably as large a shipment as occurs. The cost of providing all. improved packages for one shipment is then $500-$3000.
In the Colorado accident, a total of 44 persons were. exposed to uranium and 126 samples of urine'were taken. Nine of these samples showed concen-tr ations larger than the detectable limit of 10 micrograms uranium per , .- -- p
. ~- , ..
liter of, urine (pg/1),'but the maximum concentration was 18.1'pg/2.
For comparison, the normal concentration in individuals with no known exposuretouraniumhas.beenfoundtovary-from0.03-0.3pg/2.5/ In guidance.nowunderdeveopment,E!avalueof130pg/tobtainedwithintwo weeks following a single intake of.yellowcake is used to indicate possible chemical ~ damage to kidney tissue. This value roughly corresponds to a '
blood content of 2.7 mg uranium, which corresponds'to a weekly average of the limiting concentration for kidney damage (3 pg uranium /g kidney). In the literature, "one case of acute inhalation exposure 'seemed to produce i
L ).
y j
albuminuria [ water soluble protein in the urine]' where the urinary excretion rate was 2 mg/1, which is equivalent to 4.2 mg instantaneously injected'intotheblood."E! Other estimates of blood content ranging from one mg to 14 mg with either no observed effects or observed effects judgedassafehavebeendiscussedintheliterature.E#
The maximum concentration detected translates to a lung. dose commitment (total radiation dose-equivalent to the lung that will be received from an intake of radioactive material during the 50 year period following the intake)ofabout450 millirem (mrem),EI a small lifetime dose. The total population lung dose from this accident is estimated to be 7.5 man-rem. To convert these lung doses to whole body doses, we note that inhalation of one microcurie (pCi) of yellowcake dust results in a lung doseof47.3remsandawholebodydoseof1.7 rem.E/ Applying this .
,, . ;p ratio to the lung doses above, the largest individual whole body dose is '
- i found to be 11 mrem and the total population whole body dose is found to be 0.19 man-rem.
l The NRC regulations provide that until better information becomes avail- l
'able, measures taken to reduce population exposure from nuclear reactors neednotcostmorethan$1,000perman-rem.E In the case of the Colorado accident then, improvements in drum closure methods are not cost-effective unless they are sure to save 0.2 man rem for each accident of the Colorado severity and do,not cost more than $200 for each such accident. i l
l l
h
.. . +
. - 36'-
The' cost of; cleaning up the Colorado accident has been estimated at
$150,000-$200',000.EI For.this particular shipment', the cost of drum enclosures appears worthwhile. However,fsince every shipment does not ~
encounter an accident, more than one. shipment's worth'of drums must be a
improved to realize'the savings in cleanup costs _or radiological dose.
If enough drums were improved for one year of shipments, which was'esti-mated in the standard shipments model of NUREG-0170 as.5.4'x 104 drums by truck'and 6.6 x'.104 drums by rail, or .120,000 drums in all, the cost-
.would be 1.5-7.2 million dollars.
Some of these drums could be used'more than once. For a' projected mill.
capacityof1000tonsoforedaily,E/about25shipmentsarerequired per year. If.the' cost of. improving drum closures is incurred only for.
the first of these shipments, then the optimal annual cost is -
-.y
$60,000-$290,000. The actual. costs probably lie between these extremes. '
If a typical package is'used for ten shipments, the annual drum closure improvement cost would be $150,000-$720,000.
Comparison of these costs of improving drum closures to the estimated costs of. cleanup for the Colorado spill of yellowcake-indicates that such an improvement is cos3-effective only .if the least expensive closure
~
method'is used and if' individual 'drL < are reused sufficiently often.
The actual management of drums.may work against these efficiencies. For
t t
- 37 example, some'. drums-of.yellowcake may.be stored temporarily at the con- l versionJplant rather than: dead headed-(returned empty) back'to the mill, I
- as.is necessarily assumeci in'.these' estimates. Such, storage would either
- require-t. hat new' drums be outfitte'd with new closures or that the. improved clo'ures s be removed from the drums' going into storage and reused on drums
?
.actually in transit. .The stored drums must then be outfitted with standard closures. All these extra operations would increase the costs.
Finally, these-improvement costs hold only under the assumptions that l l
either an accident as severe as the Colorado accident happens every year or.that a year's supply of improved closures can be used every year l 1
between accidents. -Since the. severe accident rate implies that the time
'between such accidents is about 10 years 20/both assumptions appear invalid. .
~-
_, q In summary, the actual costs of improving drum closures exceed the value-of the benefits that can be derived except possibly under the most care-fully controlled circumstances. This alternative is at best only margin-ally cost-effective.
(b) Gauge :
The strength of a package' constructed with a specific shape and material is defined ~ by failure criteria' associated with differen't types of loading.
i .
i
(
4 4 1
Since'many types and combinations of loads can be produced in a transporta-tion accident, it is' not possible to give specific statements about strength as a ' function of gauge thickness but, in general, strength of a material increases with thickness of the material. For a thin walled cylindrical vessel (e.g., a drum), the strength with respect to uniform axial and internal pressure loads increases linearly with thickness. The buckling of long thin cylinders with respect to axial loads also varies linearly with thickness but for external pressure loads, the buckling
- varies with the cube of thickness. bnderaccidentc'rushconditions,the deformations of a thin-walled cylinder would usually be local and the bending strength of the cylinder would be most significant. Bending strength of a material generally increases with the square of the thick-ness of the material. Under impact loading, increase in strength with wall thickness is probably not as important as for these static loads., . ,
_9,
' ' ~
For drop tests of drums of LSA material, a much greater fractio ~n of'the '
energy absorbed by the package during impact may go into deformation of the contents than of the drum walls. The effect of increasing wall thickness may thus not be significant.
- 2. Shipment Configuration
- a. Tie-Down Systems For an exclusive use shipment of packaged LSA material, the 00T requires bracing to prevent leakage or shift of lading under con'ditions normally l
l l
I~
t s . r.
I incident to transportation (49 CFR 173.392(c)(5,6)') and prohibits any loose radioactive material in the vehicle. dsually these requirements are met by close packing ~of closed packages. No tie-down system is
.specifically. required to meet these requirements.
Assuming'the Colorado shipment was braced according to DOT rules, the bracing was. partially effective in keeping some of the barrels in the
. truck. If tiedowns had been required, all the barrels would likely have remained in the truck. Would the top of the truck have been punctured?
If not, then'even if the barrels had spilled their contents, the contents
~
would have, stayed in'the truck. If so, then the tiedown requirements would not be as effective as planned because material would still be spilled on;the ground, although the amount of spillage would probably be decreased'from that which actually occurred in the Colorado accident.
_~ ;
, ~g Two possible simple arrangements of restraining apparatus are considered i here. Other arrangements are conceivable but probably would be more complicated and thus less cost-effective. 0ne arrangement is a bar or .i cable placed across the top of a row of drums in each layer of drums' within the' cargo space of the vehicle. Another arrangement is a bar or ,
cable separating groups of drums, say two rows in each layer, to spraad crushing forces evenly among a number of drums thereby preventing damage ,
to drtims loaded.in the front of the vehicle from the crush loads of those ,
' pushing forward from the rear.
.)
b
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- 1 i
Ei.ther arrangement of such restraining apparatus is estimated to cost
$1,000 for a single vehicle (truck or rail car), but could be reused perhaps 25 times a year (for a typical uranium mill) and may last 20 years. In the standard shipments model of NUREG-0170, the number of yellowcake shipments is estimated to be 3,000 for 1975 and 12,000 for l l
. 1985. Assuming a constant rate of increase and assuming that restraining devices are requirrid, the number of vehicles that would have to be out-fitted the first year (1975) is 120 and for each of the first 20 years ;
afterward is 36. During the second 20 year period, the number of annual i
installations would be increased by the number of installations made 20 i
years before. For example, in 1995 the number of installations would be '
'i 156 and in each successive year of the second 20 year period, the number of installations would be 72. Consequently, the annual cost of such restraining devices would vary from $120,000 in-the first year to $36,000 . .- --..d '
? s. , .,
in each of the second to twentieth years to $156,000 in the twenty first i
year to $72,000 in each of the twenty second to fortieth years and so on.
)
However, the cost of the apparatus is probably not the deciding factor in determining the cost-effectiveness of such a system. The crucial costs i i
would probably be the manpower needed to in tall the apparatus, which may i i
vary from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (for both ends of the trip) for a rudimentary system ;
I where the. restrainers could be connected quickly and the separators are l simply set in place, to perhaps 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> where the apparatus is carefully bolted in, place and perhaps prestressed to provide an engineered tiedown j
. 4 I
1
I i
sytem clearly capable of withstanding accidents. At an average cost of
$5 an hour for three persons, the. rudimentary system could be installed for $1b per shipment and the engineered system could be installed for $75 per shipment. The estimtated equipment and installation costs are i summarized in Table VI. None of these estimates includes the effects of inflation, which would increase the costs.
As estimated earlier, the population lung dose commitment from the Colorado 1
accident is 7.5 man-rem. In NUREG-0170, the annual expected number of i l
latent cancer facilities from accidents to yellowcake shipments is est1- l mated to be 8.2 x 10 -5 for 1975 and 3.4 x 10 -4 for 1985. These estimates correspond to annual population lung doses of 3.7 and 15 man-rem, respec-1 tively. The corresponding annual population whole body doses are 0.09 and 0.38 man-rem, respectively. According to the NRC guide of not spendi.ng l
,p more than $1,000 per man-rem to save that nuch dose, the tiedown systemh '
are not cost-effective unless they are sure to save 0.09 man-rem per year for 1975 and 0.38 man-rem for 1985 and do not cost more than $90 per year l for 1975 and $380 per year for 1985.
l If a transportation accident as severe as the Colorado accident occurs no l
more often than once every ten years, as predicted from the known accident '
rates, then the cleanup costs taken from the Colorado experience, averaged 1
over that recursion period, would be $15,000-$20,000 pe'r year. From the i foreging discussion, the costs of tiedown systems clearly exceed this I l
l
=
cy ;
-142- 7
-TABLF VI -
' ESTIMATED ANNUAL' COSTS FOR YELLOWCAKE.
t- : SHIPMENT RESTRAINING SYSTEMS 1
. _ . Irista11ation Costs ($K) .
, No~' Systems
. Equipment: . audimentary Engineered Year No. ShipmentsL Installed Costs (5K) j{$75/ Shipment)'
(515/Shiomen.tl 1975 3,000 120 120' 45 225-1976 3,900 36 36 58 292 t
1985- 12,00b 35 35 18b 90b 1994 20,100- 36 36 302 1,508 1995 .21,000. 156 156 315 l'575 1996' L21,900- 72 72 328 .1,642
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trangefof? values.: Therefore, ; requi ringi tiedown ', systems i for yellowcake. or ;
,s a
lLSA?matierial Ldipmentsidoes. not appear t'o be a cost-e'ffective' alternative.
, o ibh . Vehicle Design.
>The elements' offvehicleidesign of; chief interest in this study ~ pertain to-whether the' cargo space is'open, closed,'or partially closed. A'partiallyi -
closed cargolspace is : exemplified by- a truck bed with high walls but- no
' top. oThe DOT ' requires 'that' unpackaged bulk' LSA material' be transported in a' closed vehicle' consigned to the exclusive'use of the consignor
'(shipper), but for packaged bulk material a closed vehicle cargo space is not require'. d If requirements 1for tie-down' systems were'to be introduced without con-comitant hardening of the package de' signs, then requirements for closed .,
- n. - .--;p vehicles mightfalso be; desirable to. minimize spillage'from the ' vehicle. ' ' '
- ~i For.the~ restraining systems discussed above,,the vehicle may impose an ;
' additional structural ~ constraint. .For example, trucks in normal trans-
- portation usage may be able to accommodate' the rudimentary quick-connect' system of;ba'r or cables, but may have to be specially designed to accom-modate'theLengineered pre' stressed system. The.use of specially designed
~ trucks could be'very expensive. We have not developed information on-V thisSfactor,since.the engineered.tiedown; system does not. appear to be
-" cost-effective, at least not tfor.yellowcake shipments. ) 1 pa s !
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- 3. Shipment Planning
- a. Routing Control The Department of Transportation (DOT) has broad authority to regulate !
safe transportation of all hazardous materials, including radioactive materials, in interstate and foreign commerce. Routing control as related t.o safe transportation is within DOT's broad author.ity.
1 The Interstate Commerce Commission (ICC) regulates economic aspects of surface carriers, approving or disapproving routes and rates requested by carriers. The approval is based on public interest and on noninterference with other carriers.
The NRC regulates the receipt, possession, use and transfer, including transportation, of byproduct, source, and special nuclear materials. In ,
view of the regulatory controls exercised over common and contract carriers '
r 1
by the DOT, the NRC exempts these carriers from its regulations. In terms of routing control, the NRC could impose routing requirements on its licensees and thus indirectly control the carrier routing. Otherwise, ;
rule changes would be required to control routing.
The shipper licensee may control routing when he transports his own material or when a contract carrier transports his material. The shipper may not be able to control the routing of a common carr'ier because a ship'p er-specified route may or may not be authorized by the ICC for that
= -~
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- carrier. The'.ICC.'classificationLrecognizes-two general types'of common
- carriers: . regular route'carrierst and irregular route l carriers'. Regular. ;
t=
route carriers have fixed! routes and, in general, fixed schedules'.
1 IrregularLroute;carriersfarel authorized to transport goods between origin-. c tand.destina' tion with no restrictions on routing. LIf a carrier wants additionaliroutes, he.ma'y-request ICC approval on either, temporary H
-(emergency) or permanent bases.'- j The DOT's motor' carrier safety. regulations (49 CFR 397.9) require that Unless;.there is no practieable alternative, a motor vehicle which contains' hazardous materials must~be' operated over routes which'do not go.through or near h'eavily' populated:a'reas,-p1 aces
- where crowds.are" assembled,Jtunnels, narrow streets, or' alleys.
Operating convenience is not a basis for determining whether it
- is'practicablefto operate a motor vehicle in'accordance with
.this. paragraph.
.' a - -~ h Although the intention.of the-requirement is well" defined, it i's noi
- -f
.known how vehicle operat' ors. implement-this requirement.- Furthermore, only token efforts are'made-to determine whether carriers are obs'erving
'the requiremant. Almost all of the large cities on the limited number of
~
highways overlwhich yell.owcake is transported have by passes which would be considered " practical al'ternatives" to passing through the city -
~ centers. JAny yellowcake shipments seen passing through densely populated areas'should be reported to the DOT for investigatio'n and possible ,
Lenforcement action? '
b l
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- t I.' l 1
)
I In terms of safety, it'is desirable to have shipments of radioactive material transported along routes which present minimum risk. Two of the shipment variables which directly bear on risk are the population environ-ment of an accident and the probability of a severe accident. Consequently, two ways to minimize risk are to route shipments to avoid densely populated areas and to avoid adverse road conditions.
It is not practical to prohibit all shipments of radioactive material ,
from all densely populated areas because the benefits from the use of the material frequently occur in the cities (e.g., in hospitals and universi-ties). Furthermore,'it is not necessarily true that routing around densely populated areas would have the effect of reducing risk.
In NUREG-0170, " Final Environmerital Statement on the Transportation of- -p Radioactive Material by Air and Other Modes," one alternative to the '
present transportation system considered was the restriction of radio- l active material transportation to avoid high population zones by routing i shipments around cities and routing air shipments into suburban. airports rather than urban airports. This alternative produced very small changes I l
in the estimated radiological risk, but relatively large increases in the estimated monetary costs of delivering the packages.
l I
. ,c ,
NUREG-0170 also showed that the consequences of greatest severity accidents involving major releases of highly toxic radioactive materials, such as ,
plutonium or polonium in densely populated areas (extremely low prob-ability' events) could produce serious injuries and up to 150 latent cancer fatalities over a 30-year period. Because such shipments are infrequent and made in accident resistant packages, such a major release '
is very improbable, and thus contributes little to the national average
' annual impact of transportation activities. Selective routing of high-consequence shipments might be useful in reducing apprehension about such accidents, t,ut would have very little effect on the overall risk.
It is desirable for shipments of radioactive material to avoid routes that are designated dangerous by local or state authorities, for example, highways covered by snow and ice, highways covered by oil or other chemicals,. ..g
.g routes under attack during civil unrest, highways with load limitations, '
weak bridges, narrow passages, or roads under flood or landslide. Routing restrictions regarding local temporary conditions are generally imposed by local authorities and are not considered further here. 1 1
- Based on the detailed assessment in NUREG-0170, the risk to public health and safety from shipments-of LSA material, including yellowcake, is very small essentially because of the low concentration of radioactivity distributed throughout the material. In view of the limited numbar of
routes normally_used and of the low risk, no additional controls appear to be'necessary for yellowcake shipments.
For other radioactive materials, the matter of routing control is presently under separate studies: the NRC environmental statement on transportation of radionuclides through urban environs and the DOT public rulemaking proceeding on the routing of highway movements of radioactive materials.
The draft NRC environmental statement is expected to be published for comment this fall. The DOT rulemaking proceediag can be anticipated to take about two years.
- b. Speed Control One of the fundamental causes of transportation accidents is excessive speed. All State and local governments post speed limits to control both- -q the accident rate and the~ severity of accidents that do happen. The Federal government supports State speed limits on its system of inter-state highways through its funding of State maintenance programs on these highways. The possibility of additional Federal controls on speed has beensuggestedinCongress.b However, in view of the existing speed limits, any additional regulations or licensing conditions on this matter appear to be unwarranted.
~
i 4
- c. Advance Notification- ;
The DOT has the authority.to require carriers or shippers'to notify the
~DUT of shipments'of radioactive materials.in interstate and foreign commerce. The NRC has the authority to require its licensees to do the f'
same for shipments of NRC licensed materials. . State and local juris-Ldictions can also, under their police powers'for protecting their citizens, require shippers or carriers to. notify.them in advance of shipments of ;
radioactive materials passing through their respective jurisdictions.
h
~
In the 1960's, the Atomic Energy Commission (AEC), on a trial' basis, ,
required licensees to notify it in advance of each shipment of spent i fuel. The AEC in turn notified each State through or into which each shipment'would go. Afterafewmonths!theprocedurewasdiscontinued because the States seldom used the information and soon expressed lack of--
. ._. p interest in that information. The effort required to administer this
~~
notification system was significant for the small number of shipments involved, primarily because of frequent changes in~the timing and _rjo.uting_. !
of the shipments.
I The NRC currently requires licensees to notify NRC Regional Offices seven days in advance.of shipments cont:ining strategic quantities of special nuclear, materials (10 CFR 75.72).
Upon such notification, the Regional
- Office may inspect'these shipments in terms of physicaT security require-ments.
4 E
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- CD -
Recently, several States have. required advance notification of certain shipments.' ,They'have-imposed such requirements through State. legislative -
or other procedures or in some cases obtained such Lcommitmen'ts through
. 1 informal' agreements.with individual reactor operators. State or local '
requirements for advanced notification of. shipments of formula quantities-1 of special nuclear material, as defined in 10 CFR Part 73, or of ]
classified material should not be imposed; such requirements conflict l with' Federal requirements.and may compromise physical security measures.
1 i
In the IAEA regulations for the safe transport of radioactive materials.
(1973. revision), advanced notification of the national competent authority t is required for transporting large shipments of radioactive material through or into a country. The DOT is working on amendments to its regulations to make them consistent with the 1973 IAEA regulations. A. . .
D requirement for advanced notification of international shipments similar -
to the IAEA requirement will likely be proposed by the DOT.
Advance notification may or may not affect safety, depending on the subsequent' actions taken by State or local jurisdictions in response to s'nh notification. For example, upon notification, if the State takes action such as'to provide police escort, to notify State and local health authorities, or even to keep a close watch on the shipment, the notifica-tion could' reduce the likelihood of an incident and could assure early l
L
\.
responde of emergency crews if an incident did occur. However, based on the assessment of NUREG-0170, such improvement in safety would be small.
On the other hand, if no action is taken, the notification would merely represent a transfer of information and no imp'rovement in safety would result.
The cost of notification would be high if all types of shipments were included in the procedures. About 2.5 million packages of radioactive 2
material are shipped each year in the United States. _4/ However, shipments of small quantities or shipments with limited potential consequences even though released, such as those on which this report is focused, could be excluded from such a requirement. Due to the documented E arge l number of shipments of low-level radioactive material compared to shipments of high-level radioactive material, notification
_q for shipments of low-level radioactive material does not appear- '-
cost-effective.
- d. Up-to-Date Transportation Data System Collection of shipment data does not directly improve transportation safety. However, such information is nec'essary to estimate, either on a national or regional basis, the risks to society from transportation and the impact of changes in the safety regulations on shipments. An occasional survey involving a significant sample of shipments made in the
, : \[f:
t
'U.S.'may be~. sufficient to' satisfy this need for such'information. A i
. system,for' maintaining up-to-date transportation data would not contribute more in terms of safety than an occasional survey because the volume of [
shipments is large and'does not vary'significantly from year to year. ~If any type of shipment increases significantly, a separate survey may be conducted to'obtain information on that specific type of shipment. I The NRC has the authority to require licensees to' report data on shipments l of licensed mater _ials. However, any reporting requirement must be cleared through the General Accounting Office (GAO). The GA0 will consider each request for approval'on criteria such as: the need and purpose for
{
requesting the information, availability of that information from other sources, justification for each item requested, the burden on industry in providing.the information, and the cost to'the Eederal government for.-
. . . __"; d collecting the information. .
f In 1975 the NRC contractea with the Pacific Northwest Laboratory (PNL) to conduct a one-time survey.of radioactive material shipments.in the U.S. l The data have been used in NUREG-0170E as the basis for evaluating the environmental impact'of the transportation of radioactive materials.
An ongoing study of the environmental impact of transportation of radio-active material-through urban' areas will.also use the information t
- i
- - i
,~
- i
-- t extracted from the data collected from the PNL survey. Both regional and national information may be obtained from the data base through thc computer program system maintained at Sandia Laboratories.
'As part of the NRC safeguards program, a Nuclear Material'Information System (NMIS) is maintained at the Oak Ridge National Laboratory by the Department of Energy (DOE). Each licensee who transfers one gram or more of special nuclear material,1,000 kg or more of source material, or certain quantities of byproduct materials, must complete Form NRC-741 an'd submit copies to the DOE Oak Ridge Operations Office and to the shipper within 10 days after the material is received (10 CFR 70.54). In addition, advance notification of NRC Regional Offices is required for shipments containing strategic quantities of special nuclear material (10 CFR 73.72). I The cost to obtain up-to-date information for all radioactive material ~ ~
.3 i shipments in the U.S. appears to be prohibitively expensive. A previous one year shipment survey conducted in 1975 cost $165,000 in contract I
funds, not including the cost to the industry in providing the requested j information. l This study contacted about one seventh of NRC and Agreement i l
State licensees. Except for special nuclear materials and source materials for which'the survey period was one year, the survey period for byproduct j materials varied from one week (for shippers with large shipping activi-ties) to six months (for shippers with infrequent shipp'ing activities).
I
For a continuous system to collect up-to-date shipment information, the contract cost is estimated to exceed one million dollars annually.
Accordingly, a system for maintaining up-to-date transportation data should not be imposed.
- 4. Hazards Information A basic aspect in the management of the on-scene situation during hazardous materials transportation incidents is the communication of information to interested parties on the type of hazardous material, its properties, and l the health and safety hazards of the material. One means by which basic ,
information on hazardous materials shipments is conveyed is given by Hazardous Materials Communications requirements of 49 CFR Part 172.
. j These regulations require that shipments of radioactive materials be I 1
accompanied by a description of each radionuclide contained, its chemical. . __
~
, 1 and physical form, its radioactivity, the label category and transport '
index (measure of external radiation levels), and whether the package is j Type A or Type B (accident resirtant). These requirements involve a system of labels for packages, placards for vehicles, shipping paper '
description and other package markings. In general, however, these requirements do not specify the inclusion of detailed information concerning the nature of the material or precautions to be taken in the event of its leakage or spillage. The question discussed here is whether i
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there should be a regulatory requirement that each shipment of radio-active materials be accompanied by an information packet, with the packet containing-information concerning the hazardous nature of the material, precautions to be taken in the event of leakage or spillage in normal or accident conditions, and notification requirements.
In many cases, however, detailed handling instructions are provided voluntarily by the shippers such as in the Colorado yellowcake spill (See ,
1 Appendix II). Another example is in the case of U.S. government shipments of uranium hexaflouride where it is customary for the shippers to actually l post a set of instructions on the side of the transport vehicle. These l
types of instructions can and have been very instrumental in providing early detailed information on how to handle the material in a spill.
Clearly, however, early information on how to contact the shipper can also accomplish the same result.
For radioactive materials shipments the DOT regulations (49 CFR 172.203(d))
contain an extensive list of required information (See Appendix III).
This information is in addition to that required for all hazardous materials shipments pursuant to 49 CFR 172.200 through 172.202 (See Appendix III). Examination of those sections indicates that considerable additional shipping paper detail is already required for radioactive materials that is not required for other hazardous materials.
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It isinot clear from the. history of past incidents involving. low-level radioactive materials that a lack of detailed information beyond that already available .from shipping paper descriptions has. been a' serious contributing factor to either..the severity of the event or to its manage -
ment.
r The Department,of Transportation has previously considered the adoption of a Hazard Information System (HI) which would enhance the communication of information on the nature of the hazards of a material during normal and accident' conditions of transportation. .The first prop'osal in 1974 for a HI system scheme was withdrawn in 1975 in. favor of a request for public advice on that system and on a number of alternative schemes. A large number of public comments have also been received. At the United Nations (UN), the Group of Experts on Transport of Dangerous Goods has been considering the adoption of an HI system for several years. It now appears that the UN group will not adopt a formal HI number scheme but will base its emergency response information needs on the UN Serial Number _which is assigned and peculiar to each listed hazardous material.
The foregoing discussion serves to' illustrate the complexity of.the
. matter. In this particular' issue, the question really. involves more than
- the-HI system itself, i.e. , whether to require something additional to
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labels, placards and shipping paper descriptions, in the form of a HI code number,.-but going beyond that to require provisions for an "instruc-tion sheet" on the hazards of the material involved. In the Colorado.
.yellowcake incident, the' shipper had provided such information (See
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Appendix II), cnd.the availability of.this data sheet was reportedly very helpful in enabling the sheriff, first arriving at the scene to contact the shipper quickly for early advice and instructions.
'There does not appear to be a need to amend DOT regulations at the present timelto include requirements for shippers.to provide, and carriers to maintain during transport, emergency personnel detailed instructions on
.the hazards of low-level radioactive materials. The existing require-
'ments for inclusion of shipping paper descriptions. appear to be adequate.
Efforts by shippers to provide such information voluntarily, especially in the case of bulk cargos, should however be encouraged. The future development and implementation of a regulatory requirement for additional communications on the hazards of the materials by means of the UN Serial Number may provide another means of supplementing the information currently provided by shipping papers. However, the addition of an emergency telephone number on package labels or shipping papers could assist emergency response in the event of an accident and should be required.
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l S. Inspegion of Regulatory Compliance Both the'NRC and the DOT conduct programs of inspection and enforcement to assure compliance with their respective regulations. Overlaps in responsibilities and activities of the two agencies in regulating the safe transportation of radioactive materials are addressed in a i Memorandum of Understanding to avoid unnecessary duplication of regula-tion. This Memorandum of Understanding is now under revision.
- a. NRC Inspection and Enforcement The NRC Office of Inspection and Enforcement approaches this aspect of regulation by means of two types of inspection--a routine, formal, frequently repeated investigation and a nonroutine, informal response to accidents, alleged situations, and inquiries. Routine inspections are conducted in five areas: nuclear reactors, fuel cycle facilities, materials, safeguards, and vendors. Each of these areas involve inspections of l packaging and shipment of radioactive material. Particular tran3 port,ation inspections involve checking quality control in package fabrication, use of packaging techniques, requirements of marking, labeling, and placarding, procedures for opening and closing packages, package mainte. nance, records of shipments, and reports of accidents, incidents, and defective packages.
Since 1973, the NRC, through its Office of State Programs, has been conducting with the DOT a State Surveillance Program. Under this program, i
individual' State and local governments contract with the NRC to inspect packages of radioactive material, the vehicles in which they are shipped, and the facilities in which they are handled. Twelve States and local governments _have participated in this program. The program provides a means for these governments to become familiar with transpectation of radioactive materials and with the Federal regulations andiFolides significant inspection assistance to the Federal government. The primary program objectives are: (1) to obtain data on the physical condition of packages containing radioactive material and the degree of compliance with existing regulations, (2) to gather information and data concerning.
radiation levels in the transportation systems work places, (3) to determine radiation doses received by personnel in such work places, and (4) to obtain data on the extent personnel comply with instructions and regulations for handling radioactive material packages.
In general, the surveillance programs do not indicate a significant
'ealth h or safety Eszard W eargo hhndlers or members of the.public_due_..
to the transportation of radioactive materials. Compliance with the D0T regulations is observed in most cases. In those reported instances of non-compliance, none of the violations had any-immediate health and safety. significance. These programs have detected a problem with the routine exposure of employees of freight forwarder firms. The partic-ipatingStatesrecommendthattheprogramcontinue.E
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,. i b .' 00T Compliance Assurance The' general! objectives.of the DOT radioactive materials compliance assur-ance program are:to' assure that such shipments are offered in' compliance-with the' regulations, and.that packagings'are manufactured,' marked, and maintainedias prescribed:in the regulations. These compliance objectives-are fulfilled by the programs offthe modal operating administrations of D07. (i~ e. , .the Federal Aviation Administration, Cdast Guard, Federal RailwayiAdministration,.and' Federal-'H ighwayAdministration), supplemented-
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by the efforts of the Materials Transportation Bureau (MTB). Specifically, one'of' the' MTB's compliance objectives is to perform inspection, compliance, l
and surveillance in the areas'not covered by the DOT operating administra- l tions in their normal . operations,.particularly intermodal shippers and
- packaging or container manufacturers, sellers, reconditioners, and repairers. -
This> involves a specialization of. personnel in the areas of multi-modal regulations and container manufacturer's requirements.
The-operational approach t'aken in the'MTB's hazardous material compliance program'is believed to be representative of that taken by the other DOT
-operating administrations. It is basically as follows:
- Analyr.is' Activity Analysis of compliance information for indication of noncompliance. The L(HMI) Hazardous Materials Incident Reports (DOT Form 5800.1) are the.
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primary source of data. Indications of carrier violations are transmitted to the appropriate operating administration. Indications of shipper violations are handled by the MTB or forwarded to the appropriate modal operating administration. Other sources of information include MTB field operations, complaints from the public, and information from other agen-cies such as NRC.
Inspection Activity Information is gathered during compliance surveys of shippers and container manufacturers as well as by observations of shippers, consignees, and l 1
carriers to detect noncompliance. l l
Investigation Activity Information is developed from HMI reports, field operations and complaints from the public.
Enforcement Activity Civil forfeiture and criminal cases, as well as compliance orders, are prepared and issued as cases warrant.
Accident Investigation Such activity is principally in selected cases, sometimes where technical expertise is needed concerning the material or packaging involved.
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. 3 The compliance effsts'of' DOT in' transportation of. radioactive materials-are:an integral. part of the Department's overall program in compliance /
' enforcement!oflthe hazardous materials transportation regulations. f t
Radioactive materials therefore are not specially singled out-and treated.~ .
s'eparately!in this activity. As. mentioned earlier, these efforts are -
' carried outLin the programsLof.the modal operating administrations, '
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. supplemented by. the MTB program. . In Table VII, . the. personnel resources of the Department for 1976-1977 are indicated.
Experience in transportation of radioactive materials indicates that such materials have been transported very safely. At the present time, the volume of radioactive shipments is about 2.5 million packages per year in theU.S.A.El During the period 1971-1975, i.e., the first five years of operation.of the DOT.'s hazardous materials incident reporting system
-(HMI), more than 32,000 HMI' reports were submitted by carriers for all ]
}.; types of hazardous materials. ~Only 144 reports, or 0.45 percent, were indicatedtoinvolve.radioactivematerials.E/ By comparison, 16,406 reports involved flammable liquids and 10,672 involved corrosives, or 51 and'33 percent of the total,-respectively. Of the 144 radioactive i
materials reports, only 36 reports indicated any release of materials from its containment, or unusual radiation levels. The majority of the- i incidents involved only minor leakage and radioactive contamination. '
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TABLE VII -
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DOT COMPLIANCE AND-ENFORCEMENT ~' ACTIVITIES -
, s-Operating - : Compliance and. Full-Time Hazardous .Part-Time Hazardous .-Total:Inspectos
. Administrations ,. -Enforcement Materials Inspectors Materials Inspectors: :. Person-Years ~- .
Person-Hours-M 3
1976- 1977 1976 1977 1976- 1977 1976= 1977- :.-..
M No. % Time -No.-% Time
$CoastGuard. _249,840: 193,680' 0 0 :694. 20 717; 15 '- 138;8 '107.6.
Federal' Aviation" Admin. 115,200 . .~.117,360 - 22 20. 109 39 129: 35 64' '65.2 ;
.-Federal Highway' . .
s Admin. 62,280.. 62,280 9 9 128 20 '128 20- : 34.6 . _34.6: ,
-Federal Railway
-Admin. 54,540 40,140- 18 16 82 '15~ 42 .15: 30.3 22.3- .-
Materials Trans.-
~ Bureau 1,800 9,360' 0- 5 4 25 3 '6- -l ! 5.21 Totals. 483,660'. 422,820 49 50 1 ,01 7 -- 1,019- .
268.7. 234.9.
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I 4 (WhenLmeasured'againstfactualexperiencetherefore,theDOT:believesthat' (thelpresent level of compl'iance/ enforcement in transportation of radio-
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j activematefialslis-appropriate;asiistheintegrationofsuchefforts
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into?its'overa11Lhazardous materials program.
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B. Transportation of the Radioactive Material
- 1. ' Review of-Past Events SinceL1975, threeLincidents have drawn a' lot ~of attention, two in. North 1
Carolina.and one in. Colorado.
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The first was a truck incident involving a l'l load of low specific. activity' material being' shipped from the-Millstone: 1 Nuclear-facility in Connecticut'to Savannah River. When the driver ')
pulled-into~a truck stop in North Carolina he noticed that the lid of one of the crates'was loose. He immediately called the State Highway Patrol i
who-in turn called a representative..of the Radiological Health' office of '
North Carolina. This' office. responded to the scene and determined that a leakage Lhad. occurred of about three tablespoons of water which was slightly -
ra'dicactive.and came.from' condensation on'.'some of the metal parts in the box. The. driver ~was'slightly contaminated but was able.to clean himself off by washing. He_then p'ut-the lid b'ack on the crate and the truck proceeded on'its way.
This incidentLis a good example of the problem of. maintaining perspective'
.in: transportation accidents involving. radioactive materials. News stories 1
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-sentbacktoConnecticutihdicatedthatarelatively~1arge.amountof' tradioactivitylwasfreleasedandthattheradiological' health.officerwas
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'" deluged" with: contaminated water. The elected officials in Connecticut- ,
a became concerned because the shipment briginated there. : An NRC inspector, however,Lindicated that in'his. professional' judgment'the amount of radio-activity released'was insignificant. The State radiological health- f
. officer concurred with this opinion. In this example, concern was gene-rated byl1.ack.of. adequate communications and understanding rather than by health consequences; in shorti perspective 'was -lost. Connecticut subse-t
.quently urged the NRC'and the DOT to improve reporting'of incidents l
involving nuclear wastes. The actual response capabilities of the State,
'the. shipper, or-the carrier were not questioned.
.l The second incident involved a derailment of 29 cars from a Seaboard l Coastline train at' 7:30.a.m. , on March 31, 1977, near Fort Bragg and ;
Rockingham,; North Carolina. Include'd in the shipment were four 16-ton
.h casks'of unenriched uranium'hexafluoride enroute to the Paducah, Kentucky, !
I gaseous diffusion plant. The UF6casks were slightly damaged in the j accident'and.in.the resulting fire, but no radioactivity was released. A large number of agencies responded to this incident.
The; Division ~ of Civil: Preparedness'of. North Carolina was notified at -
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8:30 ~a.m. of..this accident and the Radiation Protection Branch of the l 1
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-North Carolina Department.of. Human Resources was notified at-8:45 a.m.
After preliminary' inquiries to'the designated consignee, Union Carbide in Paducah;. Kentucky, and to the carrier, Seaboard Coastline in Raleigh,_.the North Carolina Radiation Protection Emergency' Team departed by Highway Patrol helicopter, arriving at the accident site at 11:00 a.m. Before this Team arrived, however, the-following groups of people had arrived:
(1) State Highway-Patrol, (2) County Sheriff, (3) Civil Preparedness Area Coordinator, (4) Seaboard Coastline officials,. (5) Fire Department, (6) ,
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. ambulance and rescue squad, (7) news reporters, and (8) the Fort Brag 0 l Emergency Ordinance Disposal Team.
l As. assessment and recovery' operations proceeded, the following groups of people a'rrived at the accident site: (1) Energy Research and Development Administration (ERDA) team from Oak Ridge, Tennessee, (2) ERDA team from Savannah River in South Carolina, (3) South Carolina Division of Radiolo- I gical Health Mobile Laboratory, (4) EPA representative from Atlanta, (5)- "
NRC. representative'from At1anta, (6) National-Transportation' Safety Board l representative from Washington, (7) North Carolina Department of Natural and Economic. Resources, Fayetteville Regional Office representative, L(8). Union Carbide representative from Oak Ridge, Tennessee, and (9)
'Transnuclear, Inc.,' representative (shipper).
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1 The' biggest problem noted in the-response ~to this accident was the lack of adequate communications. In addition, a critique of responses following !
1 the accident' revealed that (1) without fail all Federal, State and local I agencies are willing and anxious to respond and provide available. resources j to cope with radiation accidents, (2) the prior development of written emergency response plans and standard operating procedures does dramati- j cally improve the speed and effectiveness of response by all agencies 'f concerned,-(3) failure to continually update and periodically test emer-gency plans and standard operating procedures does detract from an agency's ability to respond during emergencies,-(4) formal critique of response to actual radiation accidents represents an effective means of identifying weaknesses and improving emergency response capabilities, and (5) more exercises are required, especially ones involving the activation of the State Emergency Operating Center in conjunction with field units.
Nr .e mentioned ths thippers. snauld develop a response capability.
l The third incident v.s the spilling of considerable amounts of yellowcake (uranium oxide) in Colorado in September of 1977 when the truck carrying ,
the caterial collided with three horses. This incident precipitated this study and-is described more fully below. Although no radiological casu-alties resulted from this incident, some people thought the general response to,the' accident was inadequate and that the material should have beentransportedinbetterpackaging.2_F .
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- 2. ' Description of'the Colorado. Accident
-A transportation accident occurred near Springfield, Colorado, about one l o' clock the morning of September 27, 1977, which-involved a spill of radioactive materia 1Lealled yellowcake (uranium oxide concentrate).'26,27/ t A tractor rig with enclos'ed trailer struck three horses and overturned.
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i The trailer was ~1oaded with 50 steel drums of yellowcake being shipped from a uranium mill at Highland, Wyoming, to a plant'at Gore,.' Oklahoma, for conversion to a form suitable for enrichment and fabrication into fuel.for nuclear power reactors.
The' driver and his companion were pinned inside the tractor. After they were extricated, they were taken by ambulance to a nearby hospital where they were decontaminated and treated for cuts and fractures. As learned '
from later bioassays, the drivers did not show uranium in urine samples. l As a result of the truck's overturning and subsequent sudden stop when it slid into an excavated sump for a drainage culvert, 32 of the 50 drums were thrown through-the top of the trailer near the front. These drums came to rest on the shoulder of the highway. Drum lids, which were secured to the drums.by bolted steel ring closures, came off 17 of the 32 drums which left the trailer. Lids also came off 12 of the 18 drums which rewined in the trailer.-
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A total of about 12'000 pounds of' concentrate spilled from the-opened drums. About 5,000 pounds of this spilled material was contained in the overturned trailer. The remaining 7,000 pounds were spilled on the ground'withinanareaof3,000to'4,000 square' feet.2Z/___
a The bill of71ading in the truck was accompanied by written detailed 1 emergency-instructions, which had been' prepared by the shipper.of the l
'yellowcake, Exxon Minerals Company. In-Reference 27, Exxon indicates '
I that it prepares such emergency instructions for each of'its yellowcake shipments. .These instructions directed the individuals who. arrived first at the scene, personnel- from the Baca County Sheriff's Office, to notify the' shipper and to. cover the spilled material with tarpaulins or heavy plastic sheeting to prevent airborne dispersion. Before any shipper personnel departed for the accident site, the Sheriff's Office advised them that the. spill was completely covered with no short-term risk of air dispersion.
The shipper ' dispatched Highland Mill personnel by commercial airline from Casper, Wyoming, at 7:50 a.m. on the 27th with several large boxes of emergency equipment. The' shipper dispatched a truck with 20 drums and.
additional' equipment shortly thereafter. The first shipper personnel ar' rived at the accident site.at 3:30 p.m. on the 27th. <
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Thespilliwas'moreextensivethaninitiallyreporthdtotheshipper,'so'-
?the amounttof equipment'thatithe shipper took to the a'ccident site was' o
i inade'qu'aieforcleanup.offthe'; spill. Because'the-risk of the material i
' 1 l spreading (into)the environment was minimized,-h' o wever, sufficient time- l 1
.was. availableland was taken to plan the cleanup.
I The Colorado Department of Health also responded to the accident site.
- Since .theLStAte -of. Colorado is an Agreement State.(see Glossary) with the- .)
l NRC, it'hasithe authority and responsibility to require safety precautions -i
-in an'uccidentt of.,this. nature. After being notified of the accident at - ,
4:00 a.m. on'the 27th, the Department 1 dispatched personnel to thefaccident 1
site.at .10:00' a.m. and arrived there at 2:30 p.m 28/ The initial protec- _
tivel actions of. covering the spilled yellowcake; notifying all i'nterested 4
parties, includiag the' local:.p'olice agency, the State. radiological health
. agency,.the shipper, the carrier, and'the cognizant Federal agencies; and
. directing traffic around the scene of the accident had been done. The remaining job was to clean up the spilled yellowcake and to decontaminate and resto're the scene to its original condition.
The' cleanup'was'not started as soon as.possible.
A planning meeting was held:the: evening:of: September 27,lin the Baca County Sheriff's office in
" Springfield, Colorado [ Thel cleanup' procedure decided on was to pick up i the 'yellowcake' andLtopsoil with a front end loader and ' transfer it to 'new
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drums,'using water spray to control dust and hand shovel transfer if windy conditions were encountered. Workers were to use protective clothing and respiratory equipment. An air sampling program was to be conducted to aid evaluation of air concentrations of uranium dust.
On the morning of September 28, the Colorado Department of Health estab-lished requirements for the cleanup operation. The yellowcake was to be hand shoveled into new drums within a portable shelter covering about 100 sq. ft. of spill area. The portable shelter was constructed of lumber and plastic sheeting. The spill area outside the housing was to remain covered. Contamination surveys, continual air monitoring, respiratory protection, and personnel monitoring were to be performed. Cleanup was to continue until background radiation levels were achieved. To prevent l
spread of the yellowcake, a dike and wind break were to be constructed i i
around the spill. To comply with these requirements, hcwe>ar, the l cleanup ope"ation was delayed until the afternoon of September 30.
Work progressed slowly. By the evening of October 2, five drums of dirt 2
and yellowcake had been barreled S and eleven drums of the 50 on the shipmenthadbeenrecovered.S/ Vacuum cleaning and ventilation equipment was ordered October 3 to speed the cleanup. That day was also taken for more planning and for rest. On October 4, a snow fence lined with plastic sheeting was set up to reduce wind velocity in the work area and the vacuumcleaningandventilationequipmentwasinstalled.S!
Calm weather and a light mist on October 5 allowed work to proceed out-side the portable shelter.E All the 32 drums outside the trailer were recovered by the end of that day. Work on October 6 and 7 concentrated on the yellowcake spilled in the trailer. All 50 drums of the shipment were recovered and removed to the storage area by the end of work on October 7.
During October 8-10, final decontamination of the truck, the spill area, and the equipment was done. Topsoil replacement and grass reseeding was completedbytheColoradoDepartmentofHighways.S Final surveys indi-cated several areas with readings ranging from 20 pR/hr to 100 pR/hr, which were subsequently decontaminated. The acceptable standard con-sistent with NRC guidancc 29/ is60pR/hr.2_g/ After all operations, the average exposure in the area was less than 20 pR/hr with a few spots readingupto30pR/hr.2_g/ All equipment was decontaminated to standards required for further unlimited use.g/ The Colorado Department of Health representative released the entire spill area for unrestricted use the afternoon of October 10.
The results of the air sampling program are discussed in Section II.A.1.b(1) on philosophy of package designs. The arithmetic mean of all the 26 measurementsS/reportedfortheboundaryoftheworkareafromSeptember 30 to October 10, which value is of most significance for public health
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.t and-safety, was about 9 x 10 -12l pCi/m2. .The magnitude'of annual average-air concentration of soluble uranium dust in an unrestricted area from likely effluents of NRC-licensed operations incident to the possession, use, or transfer of soluble uranium must not exceed 5 x'10-12 pCi/m2l(10 CFR'20.106). The accidental concentration averaged over a short period of time compares well with the limiting concentration that might be ,
e'xpected under normal conditions averaged over a year. This comparison illustrates the limited hazard associated with an accidental spill of yellowcake.
The results of the urinalysis program to detect uranium intake of persons involved in response to the accident are discussed in Section II.A.1.b(2) on improvements to drum clostre' methods. Clear interpretation of the health effects from uptake of uranium signified by urine concentration measurements does not directly follow from a limited number of samples, such as were taken'.in this program bioassay program, but experience indicates that'no observable health effects would be expected from small urinary. concentrations as'were meaured in this bioassay program.
, 3. -
Emergency Response o
- a. . Safety Responsibilities
- Under DOT, NRC, and State regulations, the shipper is responsible for complying with~all applicable regulations in packaging, labeling, marking F
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andotherwise'preparinganygoodsfortransportation.E For. hazardous materials,'D0T regulations require the shipper to certify on the shipping -
o papers that the goods are properly identified, packaged and prepared for carriage and to inform the carrier of any special precautions for the goods.
t The activities involved in responding to transportation accidents are divided among several. agencies and persons. For purposes of this discus- ,
sion, the response.can be broken down into four phases: the initial .
phase, the confinement phase, the cleanup phase, and the cost recovery phase.
(1) Initia? Phase During the first fifteen to thirty minutes after the accident occurs, emergency action may be required for saving lives, attending to the injured and identifying the threat and the action required to prevent further damage to life or property. Local public safety officials invariably are the persons who exercise this responsibility. The carrier has'a responsibility for action in this initial phase, as in all phases, includingnotifyingtheD0T,b State and local authorities, the shipper, and the driver's own management at the earliest practicable moment.
However, the driver.and helpsr..are often victims in the accident and may
.or may not be able to act. In the latter case, others may report the i
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- accident.- Furthermore,'in some cases they may not have immediately available siifficient information of_the details about the cargo to assess the hazard..
These.reportinghequirementsdonotnecessarilyprovideradiological
. monitoring assistance in the event of a transportation accident. To obtain such assistance, any person may call upon the services of the i Interagency Radiological' Assistance Plan (IRAP) operated by the U.S.
Department'of Energy. The DOT requirements for shipment description on i
the shipping papers' accompanying the shipment provide certain basic '
information which can be used as a lead to obtaining more information from Chemical Transportation Emergency Center (CHEMTREC) via an "800" i
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' number. Both the IRAP and CHEMTREC services are described below in 'l Sections ILB.3.c and d, respectively.
State and local police and emergency crews are usually recognized as the parties most likely to take early action in a transportation accident. l They have authority and responsibility for protecting the health, safety,
, 1 and welfare of the general public, and will take necessary. actions, for I et mple to control traffic, extinguish small fires, call firemen, rescue theinjured,etc. At_ this early stage,_ State and local capabilities to-handle radiation incidents or incidents with materials-of unknown hazard
.are often tested, since-assistance from persons hhving' specialized radio-p
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'l logical knowledge or chemical safety expertise is rarely available during the early period following the incident. For this reason local emergency response; planning must provide,for the proper initial emergency actions.
Some State and local police and emergency response crews are trained and equipped with simple radiation detection instruments and are aware of CHEMTREC, IRAP or other resources of information. These capabilities may be part of any local or regional plan.
(2) Confinement Phase In addition to assuring that the shipper and the DOT are notified in the event of fire, accident, breakage, or suspected radioactive contamination, the carrier must also segregate packages and spilled radioactive materials !
from personnel contact and assure that vehicles, area, or equipment in which radioactive material may have spilled, are not placed in service j againuntiltheyhavebeendecontaminatedandsurveyed.b In carrying 1
out his responsibility for cleanup and decontamination, the carrier most often must utilize the technical services cf others, such as State health I department personnel, nearby technicians from hospitals or military installations, etc., or other radiological safety experts. In any event l the regulations place on the carrier the burden of responsibility for cleanup.
_ ,,_ BMFT State and local police equipped and trained to monitor radiation can help to identify the location and extent of any existent radiation hazard.
These agencies are expected to exercise their police and emergency powers to control traffic, provide communications, direct evacuation and sheltering actions if necessary. The IRAP teams mentioned earlier are also available as a secondary advisory resource.
The shipper is required by DOT regulations to provide the carrier, when shipment is made, information on any special precautions required for safe shipment of his material. If called in case of an accident, the shipper is also expected to provide whatever details about his shipment that are necessary for its safe control and cleanup. Since the shipper could be involved in a liability suit later, he may offer assistance in confining and cleaning up any accident involving his shipment.
In the highly unlikely event where a release of radioactive material in a transportation ac'cident necessitates a decision concerning evacuation of persons from certain areas, the decision and subsequent actions would be made by responsible local public safety officials. These same officials also make similar decisions as a result of transportation accidents involving other hazardous materials.
. (3) Cleanup Phase This phase includes the removal of any radioactive material, contamina-tion, or other residue cf the accident to restore as nearly as possible or as practical the scene of the accident to its original state. The J
carrier has the basic responsibility to see that cleanup is completed.
Since, in many cases, the carrier will have neither technical expertise, 1
nor the experience and equipment to handle radioactive or hazardous
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materials, the carrier may find it necessary to contract with others to I perform certain functions in the cleanup. In many cases, the shipper will provide such expertise and equipment, however, the basic burden of assuring that such provisions are made remains with the carrier. Since I in most releases of radioactive material, handling of unshielded, uncon-tained radioactive material (repackaging, disposal, or removal) is neces-sary, some responsible person must be present who is experienced and equipped to handle the radioactive material. Such experience would normally be evidenced by an NRC or State license to perform such cleanup and handling activities. That person would need the authority of the carrier to take necessary and appropriate actions at the scene and might be the consignor-licensee, the consignee-licensee, or someone licensed for such activity and working under contract to the consignor, carrier, or consignee.
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-The' State .or-local; government agencies, such as emergency crews, police, t health and environmental departments,-are. expected to exercise their.
police and emergency powers to direct cleanup of both public and private-J property..
General [ standards'forcleanuparebeingdevelopedbytheEnvironmental a Protection Agency (EPA).. Some contamination'11mits are given in the DOT j regulations for vehicles, facilities, and ec,uipment. -General standards !
for exposure control and contamination limits are given in the NRC regulations and regulatory gaides.
(4) Cost Recovery Phase :
The' cost of cleanup and any: liability for damages to life or property ' ;
resulting from a transportation accident are borne in most cases initirilly !
by the carrier. -Furthermore, in most cases,-the fixing of such costs and of the real responsibility for them will.be determined in the courts. In I
more than 20 years of experience with t wtation of radioactive s materials,only 12 incidents have be ne nuclear insurance i
pools.. Of.these. incidents, nine a personal injury {
.. claims. Further discussion of.the cos gnase is included in
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Section b below. -
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In summa'ry, present regulations do not include definitive requirements for emergency response to transportation accidents involving radioactive materials. State and local government authorities, under their inherent police powers, have the ultimate decision making responsibility to protect the public. The carrier has certain basic responsibilities for confining the immediate threat and for notifying the public authorities. The shipper has no specific responsibilities for sending expert personnel to the accident scene but is expected to provide on request expert advice on the hazards of the shipment and any necessary precautions. ,
- b. Financial Responsibilities (1) Applicable Federal Statutes The present provisions of the Price-Anderson ActEI furnish a statutory basis for private funds and covernment indemnity, up to an aggregate.
amount of $560 million, to pay public liability claims resulting from certain transportation accidents involving radioactive materials. Although carriers may purchase $140 million in third party liability insurance from the nuclear insurance pools (Suppliers and Transporters Form), they are not required by the NRC or the DOT to purchase any insurance. The insurance and indemnity applicable to transportation accidents is ancil-lary coverage having its basis in the financial protection agreementsE/
executed by Commission licensees. This insurance and indemnity protection afforded the public while radioactive materials are in'the course of l
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transportation tofor from an indemnified facility is part of the-so-called
'" omnibus"coverageofthePrice-AndersonAct.E Fe'deral law requires that any. person iss'ued a construction permit for or a license to operate i a'producton or utilization facility' E! aveh and maintain financial protec-
' tion'andgovernmentindemnityasrequiredby.theNRC.E! For nuclear .;
power' plants having'a rated' capacity of.100 electrical megawatts or more, the amount of financial protection that must be maintained by licensees of these plants must equal the maximum amount of . liability insurance available'at reasonable cost and on reasonable terms.from private
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sources.E For all other Commission licensees, the Commission in the exercise of its licensing and regulatory authority and responsibility may i require, but is not compelled by statute to require, that other classes of licensees'have and maintain financial protection _in such amounts as the;Commissionconsiders'appropriatetocoverpublicliabilityclaims.E Whenever the Commission' requires a licensee to have and maintain financial protection,-the licensee must execute an indemnity agreement with the .
l l Commission.E Prior to the most recent amendments to the Price-Anderson Acte ,.the Commission'had never exercised its discretionary authority to require
'licenseesi-(other,than production or utilization facility licensees speci-
~fically: required by: statute) to maintain-_ financial protection and govern-
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ment' indemnity. However, the NRC regulations implementing these amend-ments' require that plutonium processors and fuel fabricators licensed,.
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pursuant _to 10 CFR Part-70, to possess or process specified quantities of plutoniumhaveandmaintain$125millioninfinancialprotection.SI
- Since then the amount of financial protection required of these licensees hasincreasedto$140million.SI Neither persons delivering radioactive materials to a carrier for transport
(" shippers") nor carriers, exempted from Commission licensing require-mentsS/ ecause b they are regulated by the Department of Transportation, have been specifically required to have and maintain financial protection and government indemnity solely on the basis that radioactive material licensed by the Commission or an Agreement State is being transported from point.X to point Y. For the provisions of the Price-Anderson Act to apply to the transportation of radioactive material, in the postulated hypothetical situation, an indemnified production or utilization facility or a plutonium processing and fuel fabrication plant (for which the NRC, in the exercise of its discretionary authority, requires that financial protection be maintained) would have to be located at either point X or point Y. If this condition were not met, any damages resulting from an accident during the transportation of radioactive material from point X to point Y could not be matched by funds otherwise available under the Price-Anderson Act. Generally, the transportation of special nuclear material'(i.e., plutonium and certain isotopes of enriched uranium)SI between two Commission licensees authorized "to transfer or receive in L
interstate commerce, transfer, ... acquire, possess, own, [or] receive possession of..." such material $ s not i covered by the Price-Anderson Act.
The NRC staff is currently studying the issue of whether Price-Anderson coverage shou'd be extended, pursuant to the Commission's discretionary authority, to other areas of NRC-licenssd activities. Upon completion of this study and consideration of the staff's recommendations, the Commis-sion will take such action as it deems appropriate.
After enactment of the 1975 amendments to the Price-Anderson Act, the Commission published in the Federal Register E a notice of intent to implement the provisions of the new law through the rule making process. '
The Commission invited public comments and suggestions with respect to eight specific issues. The notice stated that the Commission was parti-cularly interested in receiving views, together with the bases therefor, on, among other issues, the extension of Price-Anderson to specifically cover the transportation of radioactive materials. The notice stated:
- 8. Under the present Price-Anderson system, no separate insurance contracts or indemnity agreements are issued to cover transportation of nuclear materials. Carriers are, however, covered under the " omnibus" feature of licensee financial protection and. indemnity. It has been suggested that transportation be separately covered. The Commission invites comments with respect to any advantage to the public and/or the carrier that would result from such coverage by
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!the Price-Anderson'Act, as contrasted with present coverage
.under the omnibus featuresLof:the Price-Anderson Act. In ,
this respect, deficiencies, if any, in public protection under
_present coverage should be identified.
Interested persons are' invited to submit written-comments and suggestions, with supporting documentation,
.ontheforegoingmatters,or~onanyothermatteg.
pertinent to.the subject matter of this notice.-
Twenty three sets of comments were received in response to this notice.
Of those=commenters addres' sing the transportation issue, none expressed the need for or desirability'of covering transportation by separate ,
insuran~ce'and indemnity agreements.
When the proposed rule to implement j the 1975 amendments'to the Price-Anderson Act was published on September 20, 1976 (41 Fed. Reg. 40511), the following' statement appa red in the preamble to the proposed rule:
- 9. Under the present Price-Anderson system, no separate insurance contracts or indemnity agreements are issued to cover liability arising from the transportation of-nuclear materials. Carriers are, however, covered under the " omnibus" feature of licensee financial protection and indemnity--that is, transporters are covered for liability with respect to nuclear incidents occurring during shipments j
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to or from all existing indemnified facilities. 1 It has been. suggested that transportation be separately covered. .The Commission has considered whether any advantage to the public or.the carrier would result from such coverage '
and whether there are any deficiencies in public protection !
<under..the present coverage.
Comments. received on this issue generally expressed the ';
view that the '! omnibus" provisions of licensee financial 1
- protectionLplus indemnity' coverage are adequate. Additionally, I it was felt that.if areas of' difficulty with the existing system were identified, remedies to such areas should be 1
- de.veloped within.the existing framework rather than be developed l
within the context of.a separate additional system of policies and indemnity agreements for transportation. No contrary views were received. .
Concerns had been expressed previously about the existence i of potential gaps in the existing system in such situations as l transportation of materials. The Commission believes that these concerns do not warrant changing the existing system by initiating separate transportation coverage, because present coverage under the " omnibus" provision of existing financial protection and indemnity is extensive. Additionally, Suppliers and Transporters' liability coverage is available to a maximum of $125 million.
Another consideration against extension of coverage to transportation of nuclear materials is an insurance industry concernthatsuchcoveragemayleadto,pyramidingofcoverage. l Currently, transporters are covered through the omnibus" provisions of the financial protection and indemnity agreement with facilities. If, during transportation, an accident arose which involved multiple indemnity agreements because of multiple transporters, a confused legal situation might ensue. It might be difficult to determine which policy or agreement applied.
One expressed concern--that it would b6 difficult to relate injuries occurring as a result of exposures to radio-active material, without accident, to particular shipments--
is overstated. It is difficult to see how this situation would be rectified by separate transportation coverage.
Finally, the Commission's discretionary authority to provide indemnity coverage extends only to materials licensees.
Common carriers are exempted from licensing under present Commission regulations. In order for the Commission to indemnify such carriers either new authority under the Price-Anderson Act would have to be provided by Congress or common carriers would have to be licensed.
Consecuently, the Commission does not intend to extendseparaRcoverageunderthePricgndersonAct to transportation of nuclear materials.-
The Price-Anderson Act does not preempt applicable State tort law. Only in the ovent of an extraordinary nuclear occurrence (ENO) $does the Act
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. -i require-that'facilitylicenseeswaivecertaindefensesSI(e.g.,short .
. statute of limitations,. contributory. negligence and assumption of risk) that would otherwise be available~to the licensee, thereby creating'a l 1
situation where the licensee is, in effect, subject to a strict liability standard. In the event of an ENO, the Act also provides for consolida-tion of a11' claims resulting from the nuclear incident in the U.S. '
' district court in the district in which the incident occurred.S/
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(2) Liability in Situations to Which the Price-Anderson Act Does Not Apply .
As previously discussed, Price-Anderson coverage does not apply to all, or even'to most, shipments of radioactive materials. Should a transpor- 1 tation accident resulting in the release of radioactive material occur, l there would be no sure source of funds (except for insurance carried by the shipper or carrier) available to pay public liability claims arising
]
from the accident. ,The applicable State tort laws would determine the 1 i
l respective liabilities of the shipper and carrier.
- c. Role of the Federal Government (1) Response and Advice 1 The Interagency Radiological Assistance Plan (IRAP) was developed in 1961 by an interagency committee of Federal agency representatives as a means for providing rapid and effective radiological assistance in the event of apeacetimeradiologicalincident.S! The IRAP provides a means whereby i
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, the participating FederalLagencies may' coordinate their radiological l
=. . Y Lemergency related activities.with those of State and' local health,. police, 3
- , fire,land civil' defense' agencies. The. plan provides operating guidelines l
- i. forfinteragencyradiologicalemergencyoperationsandtrainingandis "
t'. . . . .
-t intended to use existing' Federal, State and local capabilities to most . j
, effectively. protect the public health and safety from radiological hazards. :
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The IRAP is coordinated by the' Department of Energy (DOE). Response .
teams consisting'of Federal personnel.are located at all of the national '
DOE laboratories and at laboratories and offices of other Federal agencies
-scattered across.the' country. When any individual needs help in a radio-logica1' matter he can call the nearest radiological health office to contact the-IRAP. The IRAP then takes the information and decides what action is'needed. 'In many cases, however, the IRAP will actually send a r team to respond.to the incident to help and advise the authorities in charge. 'This plan has b'een used many times since its inception in 1961.
i (2) ' Guidance The NRC is involved with the DOT and six other Federal agencies in a cooperative Federal. effort to provide guidance and training to State and
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local governments'for' radiological incidents involving fixed facilities
. and: transportation accidents. E The NRC is the lead agency in the
= program andiis responsible for:
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o.. Issuance of guidance'to other Federal agencies concerning their respo'nsibilities and. authorities-in radiological incident emergency f response planning ~and in providing planning' assistance to State and- !
local governments..
o . Development'and promulgation of guidance to State and local govern-ments in coordination with other Federal agencies for the prepara- >
tion of radiological emergency response plans.
i o Review and concurrence in'such plans. (Proper correlation among State,. local government, licensee, and national plans is an element of this review.)
o' Determination of the accident potential at each licensed fixed nuclear facility, o Issuance of guidance for establishment of effective systems of
. emergency radiation detection and measurement.
' The Department of. Transportation is responsible for:
o Providing guidelines',.in cooperation with NRC and other Federal agencies, and consistent with NRC guidance, for the development of
'that' portion of State'and local emergency plans pertaining to transpor-l
'tation incidents involving radioactive materials.
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-o Assistance.to S' tate and local governments-in emergency planning-for such transportation incidents. ..
L The NRC has not yet developed in final form its guidance on planning for transportation accidents. In the. interim, the NRC is advocating guidance developed by other groups. Y The'D0T also unofficially supports this guidance. This document was given to all States. It is currently being updated by.the DOT and is scheduled for publication in revised form I before the end of calendar year 1978. In addition, the DOT is scheduled to publish by end of calendar year 1978 an operations manual for use by those. emergency personnel who actually respond to radiation emergencies. '
A proposed standard for emergency response plans to accidents in the transportation of radioactive materials is being developed by the American !
l National Standards Institute with review and comment by the pertinent i Fede'ral' agencies. E -
The NRC has a contract with Sandia Laboratories to develop scenarios for i
transportation accidents involving radioactive materials. This program 1
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- is' designed to expand the data base from which practical emergency plans and response procedures can be developed at the State and local government level. -To provide a greater data base than presently exists, the following
' tasks will be performed: l
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o Selection'of Transportation Accidents - A limited number of poten-tial transportation accidents involving radioactive materials will be selected to provide _a complete spectrum'of accidents. The selec-tion will be based on the likelihood of the accident involving radiation exposure of-individuals, magnitude-of radiological conse-quences, nature of radiol.ogical hazard and pathway of exposure to man, physical and chemical form of radioactive material, and loca-tion of the accident. ,
o Characterization of Radiological Environment - The radiological environment resulting from transportation accidents involving radio-active material will be characterized in terms of:
i o Time-dependent airborne and ground surface concentrations of radioactive materials, o Potential radiation doses to individuals and the potential pathway of exposure.
o Size of area likely to be contaminated above levels of concern.
t o Post-Accident Responses - Following a transportation accident involving radioactive materials, the possible actions to be taken by responsible
. officials will most .likely be limited to recovery measures. Therefore, the. time-in which recovery measures should be initiated following L H o
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-the different transportation accidents utilized.in'the previous task will be estimated.
The information obtained from these tasks will be used to write a series j of accident scenarios which will describe mechanistically the postulated accidents'and their consequences.
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This contract is scheduled for comple . .,
tion.in September 1978.
t In addition,. the NRC is preparing a questionnaire to be sent to State governments for assessment of the response capabilities of the States for transpo.tation related radiation emergencies to recommend the most efficient'and cost-effective ways in which State and Federal response !
i capabilities can be coordinated. The questionnaire is scheduled to be '
l sent out early in FY79.
l l
Finally, the EPA, as one of the agencies with which NRC and DOT have been coordinating their en:ergency--planning activities, has published a " Manual )
of. Protective' Action Guidt.S and Protective Actions for Nuclear Incidents." l l
The manual will eventually have-eight chapters covering all types of
~
radiation emergencies, and Chapter.8 is devoted to Protective Acton Guides for transportation incidents. According to the EPA, the first draft of Chapter 8 will be available for interagency review by the end of ;
calendar year 1978z !
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, (3) uTraining^
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~ Several Federal agencies are developing a series of training programs for State and' local government emergency response personnel. .These programs are'.gearidtfor response to radiological emergencies and'are furnished at no cost to the State and local-government personnel. Initially, the !
~
funding'came from several~of th'e involved Federal' agencies, but beginning in FY.1979 the entire funding will-be provided by the NRC.
. One of the courses; developed to date is an eight-day course.on radio-logical emergency-response operations. The curriculum includes such topics as basic concepts of nuclear science, biological and medical implicationsjof. radiation, air sampling techniques,. area' monitoring and 1
control protective action guides, DOT' regulations, sample collection and analysis, a'nti-contamination equipment..and procedures, and emergency team
- organization and procedures. The first three days consist of classropm lectures which provide the participants with basic information on radio '
logica1' emergencies. These sessions are primarily intended for individuals with'little or no health physics expertise but also serve as a review for the more experienced individuals. The second part of the <
course consists of field exercises. Students break up into teams and respond;to: simulated radiologcial emergencies involving a nuclear power i
plant,la transportation. accident, and an industrial accident.
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The course:is conducted at the Department of Energy's Nevada Test Site -
and was-originally scheduled to be presented 10 times per. year. However, because offthe demand, NRC'is investigating the possibility of providing more sessions. - To date, approximately 200-250 State and local emergency response personnel have attended the course (class size is limited to 20 students per session). >
l The Department of Transportation, through a contract with the National l 1
Fire Protection Association,'has developed a 20-hour training course Tor firemen and_ policemen who would be responding to transportation accidents involving any hazardous material. Because of the demand for more specific training on radiation emergencies, however, a supplement is being developed
-to that_ course which will deal primarily with radiation hazards. A request for proposal has recently been' published'by D0T. The schedule calls for completion of the course no later than 12 months after awarding 1 the cotract.- It is estimated that the contract will be awarded before the end of FY 1978 so that the course should be completed by September 1979. ,
I
- d. Other Facets of Emergency Response j The chemical industry through a system called ChemtrecE5! maintains information on hazardous chemicals, including radioactive materials. '
'I 9 - y er T- 94
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1This service prov_ ides a telephone number @ for receipt a't'all times of direct-dial toll-free calls from'any point in.the continental United ,
States.-
Separate' numbers are maintained for receipt of calls originating within the District of Columbia and outside the continental U.S. This service by design is confinedito dealing with transportation emergencies.
Chemtrec can usually provide hazard information warnings and guidance when given only the name of the product and the natu,re of the problem.
For more detailed information and assistance, especially if the product isL unknown, the caller must provide as much information as possible: his name and the callback telephone number, the location of the problem, the shipper or manufacturer, the container type, the rail car or truck number, the carrier name, the consignee name, and local conditions.
In the Colorado accident, the Colorado Department of Health considered the shipper to be responsible for emergency actions and for cleanup of the spill.because the shipper is most knowledgeable of the hazards of the material, is most capable of h'andling the material, and has most vested interestinthematerial.E This State agency recommended that the NRC amend its rules to require-licensee shippers (specifically uranium mill !
operators) to have an emergency response plan and an emergency response team which could be transported immediately to the site of an accident
' involving. material owned by the mill.N i
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0ther States do not necessarily.' hold'the same view. South Carolina for . .
example recently wrote that.it is generally satisfied with the arrange- ,
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.ments that currently exist for the transportation of radioactive materials, that the containers developed under NRC;and D0T regulations are ade'quate, -
that this activity is adequately regulated and more restrictive regula- 1 q
tions are not necessary,, and that no documentation exists of problems .to 'l
-justifyconsiderationofspecial' routes.S# In addition, the Vermont Agency of: Transportation has recommended the development of a centralized !
hazardous material emergency response capability within the Department of PublicSafety.EI In its report, however, the. Vermont agency did not mention the need'to require an. emergency response capability of a shipper.
l Several' aspects of transportation of radioactive materials have recently -
been reviewed'in a study sponsored by the DOE,E i/ ncluding the principal Federal. activities affecting transportation of radioactive materials, the State and local activities that may affect such transportation, transpor-tation of these materials by rail, emergency response planning and imple-mentation, transportation safeguards and security, insurance issues, and labor relations.
l Wi.th respect.to emergency response, the re, port states that although -
1 elaborate plans of response to transportation accidents are now being i formulated, it appears.that the primary. responsibility may very well rest e __- - _ =
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with! local policemen and fire depe-tments who'are the ones most likely to be the first on the scene. In the unlikely event of a-transportation accident that involves a serious release of radioactive material, even a !
few minutes'are important. Thus, greater efforts are needed to assure l
that. local response capabilities are upgraded.
, . . I A studyb erformed p for the State of Illinois on highway transportation of hazardous materials indicates that emergency response coordination is 1 a most critical area needing State attention. A review of State regula-tory programs throughout the country and of the Illinois experience in I particular revealed that the response to an emergency becomes less effec-tive from lack of response coordination, inadequate crowd control, lack !
of accurate information, and conflicting goals and instructions of parti-cipating officials. I l
With-respect to radioactive materials, the Illinois report concludes that 1 normal highway transportation hazard to the Illinois gen dal public is essentially zero. It further concludes that worst case releases of radioactive materials are nearly impossible. In the event of such releases, the catastrophic consequences ' popularly fea' red and often alleged will not ensue. The resulting deaths,' injuries and property damage will not begin 1
. to approximate the casualties and damage that have actually and frequently
- accompanied accidents involving bulk transportation of'other kinds of hazardous' materials, man-caused disasters, and natural disasters.
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LThe-Illinois report also found that the safe. transportation of nuclear
- materials relies primarily on packaging rintegrity under both normal and b
' accident conditions. .It' states.that the safety standards of the Nuclear Regulatory. Commission'and the Department of; Transportation do not rely on restriction of routing'and similar' measures to assure safety in transport. !
-l Outside Illinois, various State and local authorities have proposed or taken, action to impose various routing restrictions and. prohibitions on' I the highway movement of radioactive material, ostensibly to increase safety. Apart from~the legal status of such actions, the report states that these restrictions cannot be justified as safety enhancing measures. !
The contractor's investigation indicates no need in Illinois for the enactment ~of, legislation or promulgation of regulations to restrict or prohibit highway transportation of radioactive materials in the interests of health'and safety.
A second important finding of the report is that from the perspective of highway. transportation, State agencies are well aware of, and have responded promptly to, surveillance, enforcement, emergency response, and related requirements called for by existing traffic and shipping practices. ,
These agencies;have further developed close and effective working relation-i ships"with. Federal regulatory agencies in improving existing regulations
.and in designing new regulations.
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0 ETheNRChas1receivedapetition5SI to modify its. rules and require
' licensee' shippers'tofprepare and maintain emergency procedures to be h
-followe'Lin d the event.of:a transportation accident.-
i Inconclusion,various' individuals'andgovernment'entitiesihavedifferent' opinions.aboutLemergency response to transportation' accidents. involving
. radioactive materials. .In'our opinion, the shipper should.not be respon- !
sible for? handling transportation accidents or for cleaning up spills of radioactive material that might result from such accidents, but should'be
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i responsible.for' proper packaging and for communicating hazards informa- ;
tion'if; requested. ;
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REFERENCES'
- 1. Letter from A. J. Hazle, Director, Radiation and Hazardous' Wastes Control,- Colorado Department'of Health, to R. P. Pollock, Director, The Citizen's Movement for Safe and Efficient Energy (January 16, 1978).
- 2. " Final Environmental Statement on the Transportation of Radioactive Material'by Air and Other Modes," NUREG-0170, Office of Standards Development, U.S. Nuclear Regulatory Commission (December 1977). l 3 .- The present United. States' regulations reflect the 1967 edition of the IAEA regulations. The IAEA published in 1973 a revision of its regulations, and the U.S. is considering incorporating the 1973 regulations, but has not yet done so. In the interim, the U.S.
National Competent Authority (the U.S. Department of Traasportation) is revalidating foreign package certificates according to the 1973 IAEA regulations so as not'to unnecessarily impede international commerce in radioactive materials.
- 4. "A Basic Toxicity Classification of Radionuclides," International-Atomic Energy Agency Technical Reports Series No' .15 (1963).
- 5. Aspinall, K~ J. and A. Fairbairn, "The Classification of Radio-nuclides for Transport Purposes and the Deriviation of Activity Limits in Relation to Package Requirements," AHSB (RP)R 23, United Kingdom Atomic Energy Authority (1963).
- 6. Fairbairn, A. and N. J. Dunning, "The Classification of Radioisotopes for Packaging," Notes on Certain Aspects of the Regulations for the Safe Transport of Radioactive Materials, .IAEA Safety Series No. 7 (1961).
- 7. Baumeister, T. and L. S. Marks, eds: Standard Handbook for Mechanical
-Engineers, Seven.th Ed.,.McGraw-Hill Book Co., New York (1967), p.
7-80.
- 8. " Clean-up of Natural Uranium Concentrate Spilled in a Transportation Accident near Springfield, Colorado on September 27, 1977," Exxon Minerals Company,-U.S.A., Technical Report (March 1978), p. 10.
- 9. " Environmental Impact Appraisal of Changes to Radioactive Material Packaging and Transportation Regulations," U.S. Nuclear Regulatory Commission staff working draft paper.
T 100 -~~ *
- 10. Otts, John V., "Special Closure for Radioactive Shipping Container,"
SAND 75-0517, Sandia Laboratories, Albuquerque NM 87115 (March 1976).
- 11. This closure was designed and patented under U.S. Reg. Pat.
No. 3,790,020.
- 12. Eisenbud, M., Environmental Radioactivity, Academic Press, New York
-(1973),p.'169.
- 13. " Bioassay at Uranium Mills," U.S. Nuclear Regulatory Commission, Office of Nuclear Material Safety and Safeguards, Fuel Processing and Fabrication Branch, Staff Technical Position (June 1978).
- 14. Alexander, R. E. , " Applications of Bioassay for Uranium," WASH-1251 (June 1974).
- 15. Ibid, Fig. IV-12. l
- 16. "A Methodology for Calculating Radiation Doses from Radioactivity l Released to the Environment," ORNL-4492 (March 1976), Table 4-2. I 1
- 17. " Numerical Guides for Design Objectives and Limit '1 Conditions for Operation to Meet the Criterion 'As Low as Reasi .'y Achievable' l
for Radioactive Material in Light-Water-Cooled haiear Power Reactor Effluents," 10 CFR Par't 50, Appendix I,Section II.D.
l
- 18. Ortloff, G. D., Exxon Minerals Company, U.S.A., Response to question l l
at Fifth International Symposium'on Packaging and Transportation of Radioactive Materials, Las Vegas, Nevada, May 8-12, 1978.
- 19. " Draft Environmental Statement Related to Operation at Bear Creek Project," NUREG-0124 (January 1977).
- 20. NUREG-0170,' Chapter V and Appendix A. Severe accidents as used here include Categories IV-VIII for which LSA drum release fractions (Model II) are estimated at unity.
- 21. Hearings before the Subcommittee on Energy and Power of the Committee on Interstate and Foreign Commerce, U.S. House of Representatives, on the Nuclear Regulatory Commission Authorization, Alderson Reporting Co., Inc., Washington, D.C. (February 15,1978).
- 22. NUREG-0170, Appendix A.
- 23. " Summary Report of the State Surveillance Program.on the Transporta-tion of Radioactive Materials," NUREG-0393 (March 1978).
- 24. " Transport of Radioactive Material in the U.S.--A Detailed Summary of Survey of Radioactive Material Shipmen'a in the United States,
.BNWL-1972," U.S. Nuclear Regulatory Commission, NUREG-0073 (May 1976).
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3 217 ~ ~ .
25; Grella, A. W., "A Review of Five Years Accident' Experience in the USA Involving Nuclear Transportation.(1971-1975)," IAEA-SR-1015 (August.1976).
L26. Letter from R. D. Siek, Associate' Director of Environmental Programs, !
Colorado Department of Health, to S. Meyers, Director, Division of Fuel Cycle and. Material Safety, U.S. Nuclear Regulatory Commission (October 3, 1977)..
- 27. ' Letter from G. Ortloff,-Regulatory Affairs Manager, Exxon Minerals l Co., U.S.A., to S. Meyers, Director, Division of Fuel Cycle and l
Material Safety, U.S. Nuclear Regulatory Commission (December 12,. j
.1977). ,
- 28. " Radiation Incident Report: Uranium ' Yellow Cake' Spill, 1 September 27,1977, . Southeastern, Colorado," Colorado Department of l
Health, Enclosure to letter from A. J. Hazle, Director, Radiation '
and Hazardous Wastes Control Division, to-the Honorable Gary Hart, U.S. ' Senate (November 1,1977).
l
.29. " Termination of Operating Licenses for N5 clear Reactors," Regulatory u Guide 1.86, U.S. Nuclear Regulatory Commission (June-1974).
- 30. Barker,.R..F.,: - " Regulatory and Other Responsibilities as Related to Transportation Accidents," NUREG-0179 (June 1977).
- 31. See'49 CFR 171.15,'171.16, 174.750, 175.45(a)(4), 176.48(b), and 177.861(a).
- 32. 42 USCA S 2210 and pertinent definitions in S 2014.
33.- 10 CFR 140.91.
- 34. 10 CFR 140.92.
- 35. See 42 USCA SS 2014(y), (cc).
- 36. 42 USCA SS 2210(a),.(c).
.37. .'42 USCA S12210(b).
38.. 42 USCA 2210(a).
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- 39. I_d .
, .d,.-
._. .) ' ;.
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- 40. Pub. L.94-197, 89 Stat. 1111 (1975).
41, 10 CFR.140.13a, see 42 Fed. Reg. 49 (January 3, 1977).
- 42. 42 Fed. Reg. 20139 (April 18, 1977).
- 43. 10 CFR 30.13, 40.12, 50.11(c),-and 70.12.
- 44. 42 USCA 9 2014(aa).
- 45. 43 USCA 6 2073(a). See also 10 CFR Part 70.
- 46. 41 Fed. Reg. 11327 (March 18, 1976).
- 47. Id. at 11328. '
- 48. 41 Fed. Reg. 40515 (September 20,1975).
- 49. 42 USCA 6 4014(j).
- 50. 42 USCA 6 2210(n).
l
- 51. 42 USCA g 2210(o). l
- 52. ." Interagency Radiological Assistance Plan," ERDA-10 (Revised April 1975). ,
- 53. " Radiological Emergencies," Federal Register 40, 59495 (December 24,
~~
1975).
- 54. " Guide and Example Plan for Development of State Emergency Response Plans and Systems for Transportation-Related Radiation Incidents,"
Regional Training Committee, Region VIII, Conference of Radiation Control Program Directors, and Western Interstate Nuclear Board (now Western Interstate Energy Board; April 1975).
- 55. " Emergency Response Procedures of Highway Transportation Accidents
-Involving Radioactive Materials," Proposed American National Standard, American National Standards Institute Committee N-14, Task Group N-692 (November 23, 1976).
- 56. Chemical Transportation Emergency Center, operated by the Manufac-turing Chemists Association,1825 Connecticut Ave. , N.W. , Washington DC 20004.
- 57. From any point in the continental U.S., the number is 800-424-9300.
The long distance access number should be added if required. From within the District of Columbia, the number is'483-7616. From without the continental U.S., the number is 202-483-7616.
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- 393 T 1
- 58. Priester,; L. E. , Jr. , Deputy Commissioner for Environmental ' Health l
and Safety,-South Carolina Department of Health and Environmental j Control, letter to R. G. Ryan, Director, Office of State Programs, 1 U.S. Nuclear Regulatory Commission (February 22,1978). l
' Agency of Transpnrtation (September 1977). ;
. 60. Lippek,' H. E. and~C. R. Schuller, " Legal, Institutional, and Political. Issues in-Transportation of Nuclear Materials at the Back l End of the: LWR Nuclear Fuel Cycle," PNL ,2457, . Study sponsored by .
. Energy Research and Development Administration, Savannah River ,
-Operations Office, (September 30,1977). '
- 61. Bierlein, L. W. , " Transportation of Hazardous Materials by Highway in Illinois," Study sponsored by Illinois Department of'Transporta-
' tion (March 1977).
- 62. Hon. T. S. Weiss and Hon.'T. E. Wirth, U.S. House of Representatives ,
and R. P. Pollock and W. B. Schultz, Critical Mass Energy Project, ' ~
" Petition for Rulemaking in the Matter of Amending the Nuclear Regulatory Commission's Regulations Pertaining to Licensee Responsi- !
bility for Emergency Response Planning and Transportation Accidents," '
(November 1, 1977). .
i l
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> I GLOSSARY Agreement State: 'An Agreement State is one entering into an agreement with the NRC by which the NRC relin-quishes its authority under the Atomic Energy
'Act of 1954,.as amended, to regulate within the borders of the State the receipt, possession, l use and transfer (including transportation) of {
source material (including yellowcake) byproduct material, and subcritical configurations of l special nuclear material.
Byproduct Material: Radioactive material (except special nuclear material) yielded in or made radioactive by exposure to the radiation incident to producing or using special nuclear material (See 10 CFR 30.4(d)).
Conversion Plant: A facility for producing uranium hexafluoride (UF6 ) fr m yer ;wcake (U380 )*
Curie: A unit of radioactive decay defined as 3.7 x 10 10 disintegrations per second.
Enriched Uranium: Uranium in which the U-235 content has been increased above its natural abundance of 0.72%
by weight (see " Natural Uranium").
Evaporator Concentrate: The radioactive residue left after evaporating the water from contaminated liquid wastes.
Fuel Facility: A place where nuclear reactor fuel is manufac-tured or fuel materials are processed.
Latent Cancer Fatality: A radiation induced cancer death which occurs more than one (often many years) year after exposure to the radiation.
Low Specific Activity Material in which radioactivity is distributed Material (LSA): essentially uniformly in small limited concentra-tions. LSA material includes natural uranium compounds, low level reactor wastes, and contam-
- inated solids. (See 10 CFR 71.4(g)).
Modal: Refers to the transportation vehicle--rail car, truck, barge, aircraft, etc.
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- . Natural Uranium: Uranium'which contains the-natural: abundance of U-235,LO.72% by weight. Also called " Unenriched". '
3
, .,Radiog'raphy: f
.The examination'ofithe' structure of materials
- using; radiation from sealed radioactive' sources.
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/Radionuclide: 'Anlatomi(such as Co-60 or U-235) which is radio- !
active.
.l Radioactivity: The property of emitting particles, such as '!
, . alpha or beta particles, or' radiation,'such 'I
.as gamma: radiation, from an atomic nucleus, -
such as uranium. ,
REM (Roentgen'EquivaC Afunit of dose equivale'nt which is numericall'y
, lent' Man): equal to the dose.in rads (a unit of absorbed dose.for.any ionizing radiation; one rad is !
100 ergs energy absorbed.per gram of absorbing ,
substance) multiplied by appropriate modifying "
factors. '
- Resins:
~
Ion. exchange substances used in nuclear power 1 ' plants to. remove unwanted radionuclides-from the primary system water. Afterfuse, resins may be '
highly radioactive.
I Source Material: Uranium or. thorium in any physical-form, including ore containing more than 0.05% by weight of _
uranium or. thorium. Source Material does not include Special Nuclear. Material (See 10 CFR 40.4(h)).
1 Special Nuclear Plutonium, U-233,.U-235 or any material artifi-
, Material: cally enriched.in these'nuclides'(See 10 CFR 70.4(m)).
Spent.(or Irradiated) ,Special nuclear material which is not readily. ;
LFuel: separable from other radioactive material and l which has a total external radiation dose rate ;
.' . in excess of 100 rems per hour at a distance of i one, meter (three feet) from any acce.ssible sur- j face without intervening shielding. 1
' Type A Packagei A package containing.a: limited quantity of.
radioactive material, and designed to withstand the rigors of normal transportation.
Type B- Package: .A' package designed to.contain its radioactive !
" contents and to maintain adequate radiation a i 1 1 d;t 3 3. ,
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shielding effectiveness.the' event'of a. severe- i accident during transportation. ;
u- 0- . .
Uraniuni..Hexafluoride: - The uragium. compound used in the enrichment - ;
process. ;
Yellowcake'- 'A uranium ore concentrate, consisting mostly of ;
uranium' oxide (U20 yellowgreeninto$o)r. It is usually
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I-1 Appendix 1. Joint Study Group Members Nuclear Regulatory Commission D. A. Nussbaumer (Chairman), Assistant Director for Material Safety and Licensing, Division of Fuel Cycle and Material Safety, Office of <
Nuclear Material Safety and Safeguards (ONMSS)
C. V. Hodge (Technical Coordinator), Transportation Branch, ONMSS R. F. Barker, Chief of Transportation and Product Standards Branch, "
Office of Standards Development (OSD)
H. E. Collins, Assistant Director for Emergency Preparedness, Office of State Programs (0SP)
E. E. Jakel, Regulations Division, Office of the Executive Legal Director A. N. Tse, Transportation and Product Standards Branch, OSD D. R. Hopkins, Transportation and Product Standards Branch, 090 l C. E. MacDonald, Chief of Transportation Branch, ONMSS 1
R. W. DeFayette, OSP i I. P. Dinitz, Antitrust and Indemnity Group, Office of Nuclear Reactor 4 Regulation ;
D_epartment of Transportation A. W. Grella, Chief of Research and Development Management Division, l Materials Transportation Bureau, Office of Hazardous Materials Operations ,
1
c II-1 Appendix II INSTRUCTIONS FOR EMERGENCY ACTON INCLUDED IN THE SHIPMENT WHICH WAS ACCIDENTALLY SPILLED IN COLORADO SEPTEMBER 27, 1977 YOUR CARGO IS Uranium Concentrate .
THIS MATERIAL:
- 1. Is not explosive.
- 2. Will not burn. -
- 3. Is a naturally radioactive material of low specific activity. It should not be inhaled, eaten, or allowed to get into an open wound.
- 4. Can be approached without danger of injury from external radiation.
IN THE EVENT OF ACCIDENT, AS 500N AS POSSIBLE:
- 1. Take preliminary precautions below. Display these instructions as necessary to local authorities on the scene to obtain their help (see 2 below).
- 2. Call (or have local authority call for you) the Manager, Administrative Superintendent or Purchasing Agent, EXXON COMPANY, U.S.A., Telephone (307) 358-3244, Douglas, W' y oming collect. If possible have local law or civil authority participate in call.
- 4. Make no other statements or phone calls except on instructions from your dispatcher or EXXON COMPANY, U.S.A.
PRELIMINARY PRECAUTIONS CONTAINERS ARE NOT LEAKING, and are not seriously damaged. Container may or may not be thrown from vehicle. Vehicle may or may not be damaged.
- 1. Cautior, people not to tamper with the containers. Use civil authorities ;
to help you if necessary. '
- 2. It is'not necessary to have a specific distance between humans and !
the containers or truck, but for ease of controlling the situation, ask people to stay back 10-15 feet.
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II-2 Appendix II (Cont'd)
- 3. :If closed containers are lying on the road, obtain assistance from whatever civil authority is available to move containers to the side of the road.
- 4. ' Assure local authorities that there is no danger in handling closed containers.
CONTAINERS ARE LEAKING OR DAMAGED T00 SERIOUSLY to be moved. Truck or railroad car may or may not be damaged.
- 1. Caution humans to stay away from the material. Keep them at a distance of at least 25 feet. Extreme distance is not necessary.
Use civil authorities to help if necessary.
- 2. Assure local authorities that there is no danger from radiation but that people should avoid breathing any dust from the material.
- 3. Avoid trackage of material by humans or vehicle. Obtain help from local civil authorities if necessary to reroute traffic around the ,
spill area.
- 4. Keep material from running into streets, gutters, sewers, etc., if possible. A simple method for doing this might be to dig a trench around the material or throw up an earthen dike several inches high.
- 5. Prevent the material from being scattered by the wind by carefully covering it with canvas or dirt.
- 6. Avoid breathing dust from the material. When covering the material, obtain a simple respirator if possible. If none is available, work the material in such manner as not to stir up excessive dust.
FIRE involving vehicle or in immediate vicinity of vehicle l
- 1. Isolate the vehicle from other hunans and property if possible. Use civil authorities for help.
- 2. Obtain fire fighting help from local group.
- 3. The material you are hauling will not burn.
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II-5 Appendix II (Cont'd) !
- 4. . Keepf fire 'away from uranium containers'if possible.
. 5. Use respirator:if:necessary to' avoid breathing smoke from any. fire
- involving ~your cargo because of possibility offairborne particles,- '
Lif the drums are ruptured.
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- 6. Do not spray water into o n or. leaking containers. There is no reaction with' water but' P'avy stream of water will spread the .
. material and'make clear' o 'e difficult.
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III-1 APPENDIX III DEPARTMENT OF TRANSPORTATION REGULATIONS (49 CFR) PERTAINING TO HAZARDS INFORMATION ACCOMPANYING A SHIPMENT OF RADI0 ACTIVE MATERIALS i i
Chapter I---Materials Transportation Bureau 5 172.202 l Subpart C-Shipping Papers shipping description may not contain Sotraca: Amdt. 172-29A. 41 FR 40677, any code or abbreviation. ,
Sept, 20,197e, unless otherwise noted. (4) A shipping paper may contain additional information concerning the 6 172.200 Applicability. material provided the information is not (a) Description o/ hazardous materials inconsistent with the required descrip-
- equired. Except as otherwise provided tion. Unless otherwise permitted or re-in this subpart, each person who offers quired by this subpart, additional infor- ,
l a hazardous material for transportation mation must be placed after the basic shall describe the hazardous material on description required by i 172.202(a) (1) the shipping paper in the manner re- and (a) (2) .
quired by this subpart. (1) When appropriate, the entry (b) Exceptions. This subpart does not "IMCO" may be entered immediatell apply to any material that is-- following the class in the basic descrip.
(1) An CRM-A, B, or C, unless it is tion.
offered or intended for transportation by (11) For a material meeting the defini-air when it is subject to the regulations tion of more than one hazard class, the pertain'.ng to transportation by air as additional hazard class or classes may be specified in I 172.101; or entered after the hazard class in the (2) An ORM-A. B, or C, unless it is basic description.
offered or intended for. transportation (b) Name of shipper. A shipping by water when it is subject to the regu- paper for a shipment by water must con-lations pertaining to transportation by tain the name of the shipper, water as specified in i 172.101: or [ Amdt.172-29A, 41 FR'40677, Sept. 20.1978 (3) An ORM-D unless it is offered or as amended by Amdt.172-29B, 41 FR 57067, intended for transportation by air. Dec. 30.19781 8 172.201 General entries. 6 172.202 Description of hazardous ma.
(a) Contents. When a description of terial n shipping papers.
hazardous material is required to be in. (a) Each description of a hazardous cluded on a shipping paper, that de- material on the shipping paper must scription must conform to the following include--
requirements: (1) The proper shipping name pre-(1) When a hazardous material and a scribed for the material as required by material not subject to the requirements i 172.101.
of this subchapter are described on the (2) The class prescribed for the ma-same shipping paper, the hazardous ma- terial as required by 8172.101. When the terial description entries required by words of the proper shipping name are 1 172.202 and those additional entries identical (excluding the entry "n.o.s.")
that may be required by i 172.203. with the words of the class, the inclusion (1) Must be entered first,or of the class is not required.
(ii) Must be entered in a color that -(3) [ Reserved]
- clearly contrasts with any description of (4) Except for empty packagings, the a material not ;ubject to the require- total quantity (by weight, volume, or as ments of this s.abchapter on the ship- otherwise appropriate) of the hazard-
. ping paper except that a description on a ous material covered by the descrip-reproduction of a shipping paper may be tion.
. highlighted, rather than printed, in a (b) The basic description specified in
. contrasting color (The provisions of this paragraphs (a)(1) and (a)(2) of this paragraph apply only to the basic de- section must be shown in sequence ex-scription required by i 172.202(a) (1) cept that the technical name of the ma-and (2).) or terial may be entered between the
- (111) Must be identified by the entry of proper shipping name and the class. For an "X" placed before the proper ship- example: " Gasoline, Flammable liquid":
ping name in a column captioned "IGI" or " Flammable so11d. n.o.s."; or "Cor.
(2) The required shipping description rosive 11guld, n.o.s. (capryly! chloride),
on a shipping paper and all copies corrosive material."
thereof used for transportation purposes, (c) The total quantity of the material must be legible and printed (manually covered by one description must appear or mechanically) in English. before or after, or both before and after.
(3) Unless it is specifically authorized the description required and authorized or required in this subpart, the required by this subpart.
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o III-2 ;
- O 1 APPENDIX III-(Cont'd)
- 6 172.203 e - - Title 49-Tronsportation ._
- (1) Abbreviations may be used to spec- sile Class. III Shipment. Do not Load . ,
'ify the type of packaging and weight or More Than ? *
- Packages per Vehicle."
' volume. For example: 40 cyl. Nitrogen. (Asterisks to be replaced by appropriate
- Non-flammable Gas-800 pounds: 1 box number.) "In loading and Storage Areas,
' Cement, liquid n.o.s., Flammable 11guld,, ; Keep at Least 20 Feet (6 Meters) from ,
25 lbs. - Other Packages Bearing Radioactive La- '
, .(2) The type of packaging may be en- bels." .
'tered in any appropriate manner.. . . (D) If a Fissile C1hs III shipment is
. to be transported by water, the supple--
.j !$ 172.203 L Additional,, description , re. mentary notation must also include the N " '" following statement: "For shipment by
.. (a) Exemptions. Each shipping paper water . only one Fissile Class III ship-issued in connection with a shipment ment is permitted in each hold."
made under an exemption must bear the (vil) For a package approved by the notation " DOT-E" followed by the ex- U.S. Energy Research and Development emption number assigned and so located Administration (ERDA) or U.S. Nuclear
.that the notation is clearly ~ associated Regulatory Commission (USNRC), a no-with the description to which the exemp- tation _ of : the package identification 4 tion applies. . -- marking as prescribed in the-applicable i
! -(b) Limited atmntities. The descrip-tion for a material defined as " limited ~- ERDA 393a oforthe USNRC approval. (See i173.-
subchapter.)
i i i quantities" in this subchapter must in- (viii) For an export shipment or a :
clude the words " Limited Quantities" or shipment in a foreign made package, a !
"Ltd. Qty." following the basic descrip- notation of the package identification
" tion. , - marking as prescribed in the applicable (c) Blasting caps. The description for International Atomic Energy Agency a shipment of blasting caps must have an (IAEA) Certificate of Competent Au-entry stating the number of caps in the thority which has been issued for the .
shipment, either before or after the basic package. (See i 173.393b(a) (3) of the 1 description. subchapter.) 4 (d) Radioactive materfaf. (1) The de- (e) Empty packagings. For other than '
scription for a shipment of radioactive material must include the following ad . aping tankpaper car, for theandescription on the con-empty packaging ship-ditional entries as appropriate: taining the residue of a hazardous ;
(1) The name of each radionuclide in . material may . contain the word (s) -
the radioactive material that is listed in " EMPTY": or ' " EMPTY, Last con.
I 173.390 of this subchapter. Abbrevia- tained * * *" followed by the name of tions, e.g., ""Mo" are authorized.. the hazardous material last contained (11) A description of the physical and in the packaging. This entry may be chemical form of the material, if the before or af ter the basic description. For material is not in special form. empty tank cars, see i 174.25(c) of this (iiD The activity contained in each ' subchapter, package of the, shipment in terms of (f) I'ransportation by air. When a
' curies, mil 11 curies, or microcuries. Ab- package containing a hazardous mate-brevations are authorized. . - - rial is offered for transportation by air -
' (tv) The category of label applied to and this subchapter prohibits its trans.
. each package in the shipment. For exam- portation aboard passenger-carrying air ;
. ple: " RADIOACTIVE WHITE-I." craft, the words " Cargo-only aircraf 6 L (v) The transport index assigned to must be entered after the basic descrip-each package .in the shipment bearing tion. '
RADIOACTIVE YELLOW-II or RA- (g) Transportation by rai!, (1) The
' DIOACTIVE YELLOW-III labels. shipping paper for a rail car containing 3(vi) For a shipment of fissile radioac- , a hazardous material must contain the ;
i tive materials.- , notation " Placarded" followed by the '
(A) The words Fissile Exempt," if the ' name of the placard required for the
, - package is exempt pursuant to i 173.396 rail car.
i . (a) of this subchapter, or' ,
(2) The shipping paper for each spect-
. (B) If hot exempt. the fissile class of fication DOT 112A or li4A tank car each package in the shipment, pursuant (without head shields) containing h to 1173.389(a) of this subchapter; and . flammable compressed gas must contain
-(C) For a Fissile Class III shipment, the notation " DOT 112A" or " DOT i
, the additional notation: " Warning-Fis- 114A." as appropriate. and either "Must l l
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III-3 APPENDIX III-(Cont'd);
1
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J be handled'in'accordance with FRA E.O.
No. 5" or " Shove to rest per E.O. No. 5."
(h) Transportation by hightoay Foi-lowing the basio description for a haz-ardous material in a specification MC
. 330 or MC 331 cargo tank. made of ,
quenched and tempered steel, there must ,
be entered for . .
(1) Anhdyrous ammonia. (1)' The words "O.2 per cent water" to indicate
' the ' suitability for shipping anhydrous 1
- ' ammonia in the cargo tank as author- !
ized by 1 177.817 of this subchapter, or ;
(11) The words *'NOT FOR Q AND T-
. l TANKS" when the anhydrous ammonia s does not contain 0.2 per cent or more !
. water by weight.
(2) Liquefied petroleum pas.The word "Non-corrosive" or *Non-cor" to indicate the suitability for shipment of the "Non-corrosive" liquefied petroleum gas of-fered for transportation by cargo tank as authorized by 1173.315(a)(1) Note 15 of this subchapter.
(1) Transportation by water. (1) Each .
shipment by water must have the fol-lowing additional shipping paper :
- entries:
(1) Identification of the type of pack-ages such as barrels, drums, cylinders.
and boxes, . '
(11) The number of each type of pack-age including those in a freight container or on a pallet, and (iii) The gross weight of each type of a package or the individual gross weight of each package. ;
(2) The shipping paper for a hazardous ';
material offered for transportation by water to any country outside the United 1 States must have in parenthesis the tech- l nical name of the material following the proper shipping name when the material is described by a "n.o.s." entry in i 172.- -
101. For Example: Corrosive liquid, n.o.s. j (caprylyl chloride), Corrosive material. '
However, for a mixture, only the techni- i cal name of any hazardous material giv- ;
ing the mixture its hazardous properties a must be identified. j
( Amdt.172-29A. 41 FR 40677, Sept. 20,1976. I he amended by Amdt.172-29B. 41 FR 87067, J Dec.30,1976l 4
6 '.
IV-1 APPENDIX IV SOME CORRESPONDENCE CONCERNING THE COLARDO ACCIDENT A. Letter from R. D. Siek, Associate Director of Environmental Programs, Colorado Department of Health, to S. Meyers, Director, Division of Fuel Cycle and Material Safety, U.S. Nuclear Regulatory Commission (October 3, 1977).
B. Letter from S. Meyers, Director,. Division of Fuel Cycle and Material Safety, U.S. Nuclear Regulatory Commission, to A. J.
Hazle, Director, Radiation and Hazardous Wastes Control, Colorado Department of Health (December 14,1977).
C. Letter from A. H. Hazle, Director, Radiation and Hazardous Wastes Control, Colorado Department of Health, to S. Meyers, Director, Division of Fuel Cycle and Material Safety, U.S. Nuclear Regulatory Commission (January 13,1978).
D. Lettr from A. J. Hazle, Director, Radiation and Hazardous Wastes Control, Colorado Department of Health, to R. P. Pollock, Director, The Citizen's Movement for Safe and Efficient Energy (January 16,
. 1978). ,
E. Letter from A. J. Hazle, Director, Radiation and Hazardous Wastes l Control Division, to the Honorable Gary Hart, U.S. Senate l (November 1,1977) and enclosure: " Radiation Inciden Report:
Uranium ' Yellow Cake' Spill, September 27, 1977, Southeastern Colorado," Colorado Department of Health.
F. " Fact Sheet - Transportation of Radioactive Material - Natural i Uranium 0xide (Yellowcake)," U.S. Nuclear Regulatory Commission.
G. Letter from G. Ortloff, Regulatory Affairs Manager, Exxon Minerals Co., U.S.A., to S. Meyers, Director, Division of Fuel Cycle and Material Safety, U.S. Nuclear Regulatory Commission (December 12, 1977). !
H. " Clean-up of Natural Uranium Concentrate Spilled in a Transportation Accident near Springfield, Colorado on September 27, 1977," Exxon Minerals Company, U.S.A., Technical Report (March 1978).
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. COLORADO DEPARTMENT OF HEALTH 4210 EAST 11TH avl?NUE . OCNVER, COLORADO 80220 PHONE 388-6111 Anthony Robbins. M.D., M.P.A. Executive Director October 3, 1977 Sheldon Meyers, Director .
Division of Fuel Cycle and Material Safety U.S. Nuclear Regulatory Commission Washington, D.C.- 20555 l i
Re: Truck Accident, September 27, 1977, which released 21 tons of yellowcake near Springfield, Colorado ]
Dear Mr. Meyers:
i l
On September 27, 1977, the Colorado Department of Health sent a response test to a site about 15 miles north of Springfield, Colorado on U.S. Highway 287. A Leeway Trucking Co. tractor /
enclosed trailer rig liad hit three horses and rolled on its side about 1:00 a.m. that morning. The truck was enroute from the Exxon l Mill at Highland, Wyoning to the Kerr-McGee Plant at Gore, Oklahoma with a load of 42,00t pounds of yellowcake. About 30 of the barrels penetrated the side and top of the trailer and ruptured on the ground. Most of the other 20 barrels remaining in the trailer also ruptured. It took about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to cut the cab open and remove the injured drivers. They were taken by ambulance to Southeast Colorado
. Hospital at Springfield, Colorado where they were decontaminated and treated for. cuts and fractures. Upon advice from the Exxon Corporation, Baca County Sheriff's Officers had the truck and the adjacent spill area (about- 50 x 100 f t.) covered with plastic tar-paulins soon after the accident. Two people from the Exxon Mill arrived at the scene about 3:30 p.m. on September 27, 1977 with one Geiger counter. They had the misconception that cleanup would be supervised and carried out by the Colorado Health Department Personnel.
They were not only improperly. instructed but inadequately trained and equipped for their mission. An Exxon Co. Industrial Hygienist who arrived on September 28, 1977 was similarily inadequate for the mission. Colorado Health Department personnel requested that cleanup not proceed until Exxon furnished adequately' trained and equipped personnel. This included someone equipped with and knowledgeable in the use of the gamma scintillometer and alpha survey w
a a '
,,i ,
-Sheldon Meyers,-Director October 3,~1977' Page 2 .
meters, and also trained in_the fitting and use of respirator equipment. In response to this, Exxon sent a Certified Health Physicist and respirators the evening of, September 29, 1977.
Cleanup commenced on September 30, 1977 in accordance with the following recommendations from the Colorado Department of Health.
- 1. Personnel be properly suited, and fitted with respirators.
(This is a very windy area).
l
.2. Provisions be made at the site for decontamination of ,
personnel and storage of contaminated clothing.
- 3. The yellowcake be moistened enough to prevent blowing while being hand shoveled into new barrels.
- 4. The old barrels be put into larger containers instead I of being patched up with tape as per Exxon's request. I
- 5. A truck or other construction be placed upwind of the site as a windbreak.
- 6. The truck be decontaminated at the site prior to removal.
- 7. The site be decontaminated to background levels as l measured with a calibrated scintillometer per Nuclear Regulatory Commission Criteria.
Colorado Department of Health personnel will be at the site until this cleanup is completed.
The Colorado Department of Health recommends that the U.S. NRC reappraise its licensing and regulatory program for uranium mills in order to insure the following:
- 1. All mill licensees be made aware of their responsibility for immediate response to control and cleanup of their materials in transit.
- 2. All mill licensees submit to the U.S. NRC or appropriate agreement state authority an acceptable emergency response plan for transportation accidents. Such plans should include at least the following:
- {' l' Sheldon~Meyers, Director October'3, 1977 Page:3 [
A. .A training program for a response team.
B. Provision of. adequate clothing and survey equipment for a response team.
C. Arrangement for transport of the response team to an i accident scene.
I D. Arrangement for an adequate number of trucks and enpty :
containers to be dispatched on very short notice to an accident scene.
E. . Provision for personnel and equipment to handle such l problems as covering spills, constructing windbreaks, l constructing water diversions (including pumping systems), and handling such other logistical problems l as decontamination, sanitation, security and communication l facilities. I F. Establishment of an adequate company command structure
< to ensure that the plan is promptly and effectively executed.
- 3. Shipments of uranium and thorium concentrates be made in containers sdequate to withsrand the hazards of truck and rail transport. It appears that the containers involved in this accident were completely inadequate.
- 4. Provisions be made for prompt reimbursement for expenses incurred by state and local agencies who respond and assist ;
at the scene of accidents involving fuel cycle material. !
Expenses at this particular accident include so far: I A. State Highway Patrol cars convoyed traffic on a detour for over a week during cleanup operations.
B. County Sheriff's personnel provided site security- I round the clock for over a week.
I C. The County Sheriff provided covering tarpaulins for !
the truck and contents.
I D. The State Highway Department provided equipment on l standby to dig diversion ditches in case of a rainstorm. I
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Sheldon Meyers, Director October 3, 1977 page 4 E. The State Department of Military Affairs provided tents to serve as decontamination and shower facilities.
F. The State Health Department personnel incurred transportation and per diem expenses .or over a week.
It is fortunate that this accident occurred in a remote, dry, level, '
open location. If it had occurred near a water course, in a metropolitan area, or in a mountain area, the problems would be compounded many fold. While many individuals responded with common sense to this accident, it is clear that preparedness for such an eventuality was inadequate. The Colorado Department of Health requests the Nuclear Regulatory Commission to take immediate steps to close this gap in their administration of the Nuclear Fuel Cycle.
i erely, o
W ^O J e
,R.D. Siek-Associate Director of Environmental Programs Office of Health Protection RDS:wsr CC: A.J. Hazle, Colorado Department of Health Gerald Ortloff c/o Highland Uranium Operation Exxon Corporation '
Box 3020 Douglas, Wyoming e
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.f; DEC' 14 1977
!r.'R. D. Siek Associate Director of t'
Environmental ProgramsL Office of Health = Protection '
~ Colorado-Department of Health 4210 East lith Avenue ,
~3 DwNer, Colorado . 80220
- L f
Dear Mr. Siek:
Than' k you for your letter of October 3,1977, describing the actions taken !
by your office in response to the recent transportation accident near '
Springfield, ard recommending various steps.to improve future emergency response. ' Your recomendations are being considered by the Nuclear
{
Regulatory Comission -(flRC).
1 The NRC and DOT have initiated a program to identify and study areas where l
possible improvements in the safety of transporting uranium oxide and
' other; low-level radioactive material might be achieved. We have developed
'a list of areas to be studied which considered those areas recomended in your letter. We have reviewed this list with Congressman Wirth and under-ss tand that he plans to send the list to the Governor with a request for coments from Color 6do.- We would appreciate receiving a copy of your re-
. port and other information dealing with the yellowcake accident and copies ,
of any photographs taken at the accident scene, particularly those showing i the condition of the drums. We are referring here to information that you !
- may not as yet have furnished to Mr. Wayne Kerr.
.' 3 i
We note that the Colorado Department of Health is an active member of the American flational. Standards Institute N692 task group which prepared a
' draft proposed ' standard, " Emergency Procedures for Highway Transportation Accidents Involving Radioactive Materials." We would like to know if you 3 are in agreement with the draft proposed standard and if have imple-
)
mented any part of it in your emergency response program.you We would also :
i- appreciate receiving your coments on the respective roles and interfaces
- j. --
-among Federal, State, local and licensee programs for emergency response.
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. We will keep your office informed of the progress and results of our study.
't- Sincerely, 2 '
'! Original signed by h SEEDON EH:RS, i
Sheldon Meyers Director '
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, Division of Fuel Cycle and Material Safety o . x l r . l'
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COLORADO DEPARTMENT ~0F HEALTH l
4210 EAST 11TH AVENUE . DENVER, COLORADO 80220 . PHONE 388-6111 g Anthony Robbins, M.D., H.P. A. Executive Director
' January 13, 1978 Sheldon Meyers, Director Division of Fuel Cycle and Material Safet,v U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Dear Mr. Meyers:
Thank you for your letter of December 14,1977, to Mr. R. D. Siek' regarding the Springfield, Colorado uranium spill, our report and photographs which were sent to Mr. Wayne Kerr several weeks ago. .
Mr. Siek is no. longer with our Department, therefore, I will attempt to answer the questions raised in your letter.
Mr. Jim Montgomery of my staff is chairman of the American National Standards Institute N692 task group and expects to be submitting the final standard for publishing within the next few weeks. We are, of course, in agmement with the draft proposed standard and have been conducting our emergency response program in accordance with the standard '
for several years.
It should be noted that the Standard addresses procedures to be followed by emergency response personnel in the event of an accident. Other ANSI Standards will have to appropriately address the transportation and packaging of. radioactive materials.
Mr. Montgomery is a member of the Inter-agency Task Force on Emergency Response which is working with the Office of State Programs to address the subject of Federal, State and local interfacing for emergency response.
The position of this Task Force will hopefully reflect the views of our Department and,-as such, should be responsive to the second to last sentence '
in your Decemb'er 14, 1977 letter.
~
If weLcan be.of further assistance, please contact this Divisio'n Sincerely
- MC -
Albert J. Haz e, Director Radiation and Hazardous l Wastess Control ,
,_ AJH:JLg:er
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- COLORADO DEPARTMENT OF HEALTH 4210 EAST !!TH AVENUE DENVER, COLORADO 80220 - PHONE 388 6111 Anthony Robbins, M.D.. M.P.A. Executivo Director January 16, 1978 Mr. Richard P. Pollock, Director The Citizens' Movement for Safe and Efficient Energy P.O. Box 1538 -
Washington, D. C. 20013
Dear Mr. Pollock:
This will acknowledge receipt of your letter of November 3,1977, which included a copy of an investigation report on the September 27, 1977 accident wnich involved uranium concentrate.
It is the purpose of this letter to provide additional information to clarify some of the statements made in your investigation report.
, . _ _ The local emergency personnel and the State Patrol who were first to arrive on the scene did an excellent job of rescuing the injured truck driver and passenger, covering the spilled yellowcake to prevent its spread, and securing the names and addresses of all persons who had stopped at the accident and might have been contaminated. This list of names was later used by the Exxon Company to contact everyone who had -
assisted *at the accident.
The Exxon Company had provided the trucking company with written instructions concerning themature of1he cargo and-listed exactly-what actions were to be taken in the event of an accident. These instruction.s were included "~
with the shipping papers. ~' ~
One of the Highway Patrolmen, and perhaps others who responded to the accident had' attended a hazardous materials workshop presented in cooperation with this Division in the southeastern part of the state. Because of the freq-uency of the highway use in this part of Colorado by trucks carrying yellow-cake, the handling of accidents involving yellowcake was discussed in detail at that workshop by Departmental staff.
The " general rules" to follow in emergency response are written in booklets '
provided by this Division to the local emergency personnel (see attached).
Each incident to which the Department must re.spond is unique and no specific
p _ _
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Mr. Fcichard P. .Pollock -
-I January 16,' 1978 t
- bage 2 written instructions all possible accidentscan. be given to the Health Physicists regarding l However, there is basic knowledge and training which Divisional personnel possess which applies to handling all aspects of the ~ accident and cleanup.
1 A letter has been sent to each producer of uranium ~ concentrate by this Department to notify them of the need to have equipment and personnel !
to respond immediately to such an accident, should their material be I o involved. Each producer's response plan will be reviewed by the Depart-j ment for. adequacy.
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The initial notification of this Division by the State Patrol Dispatcher j at 4:00 A. M. was incomplete and follow-up details were.to be provided as 1
they became;available. No further information concerning the severity. of the accident were received until after 8:30 A. M. that morning. It was ,
j not'until~ the Health Physicists arrived at the scene that the magnitude '
of the.' accident was known.
-}'i The Exxon Company was notified that a total of six to twelve barrels had j been. damaged,:and their response was to send two people with protective i clothing, respirators, a Geiger-Mueller Survey Meter, one air sampler and
! twenty barrels.
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The two Exxon people who responded were misinformed as to their responsi-
' bility for cleanup, having been sent to assist the. State of Colorado in doing the cleanup. After being informed that they (Exxon) would do the j cleanup, they took immediate action to comply.
There was no " quarreling" between state officials and the firms involved.
There were discussions between Health Department personnel and Exxon representatives concerning responsibility and cleanup techniques to be used.--These-were-not a'rgumentsrbut-were-statements-of-the Department's position 'and then. discussing how these requirements could be carried out.
The Exxon people were' very cooperative in meeting all demands. Th'efiamplied ~
with all requests and requirements as set by the Colorado Department of Health.
The trucking-company had financial responsibility for cleanup of the accident, however, the Department considered Exxon as the agency responsible for cleanup for the following reasons:
- 1) Exxon had personnel who were accustomed to working with yellowcake and knew. of its' hazards and the precautions to take in its handling. ,
- 2) The Exxon Company had personal protective gear and the equipment J
_ to use in. the cleanup., '
L; 3
- 3) The Exxon Company. had about $1.5 million in yellowcake spilled
. along 'the : roadway.
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- I Mr. Richard P. Pollock January 16, 1978' Pag'e 3 1 The trucking company provided payment for all rental and purchases of f equipment used during cleanup.
On September 27th, the day of the accident, the Exxon Company employed
' several local men to assist in the cleanup. However, it was the posi-l tion of the Department that:
- 1) The cleanup should not be attempted with a " front-loader" because of the continual wind in the area.
, 2) Adequate survey meters should be available to define the con-i
'tamination area and to determine the adequacy of cleanup. q
- 3) Continual air monitoring would be done during the cleanup operation .
i 4) Cleanup personnel would wear anti-contamination clothing and ;
1 " fitted" respirators. This required a Health Physicist or l l someone .knowledgable in fitting respirators. l
- 5) Personnel monitoring, i.e., bioassays, would be required on all I
! persons involved in the ir.itial rescue and in the cleanup. '
l 6) A dike was to be constructed around the spill to prevent rain I
- from washing across the area and spreading contamination.
7 i Exxon decided it would be easier to use it's own personnel for cleanup rather i than the local personnel and brought about twelve employees from the Highland Uranium Mill in Wyoming.
Since the spill was contained, with no risk of spreading into the environ .
ment and no radiation hazard to personnel, it was best to proceed slowly and deliberately with the cleanup to prevent the situation from becoming a larger problem. .
The first newspaper coverage was an article in the Pueblo Chieftan the _ .. . .. ._
morning of the day after the accident (September 28).
Thq Colorado Department of Health press release was issued on September 30, with general facts about the accident, initial response, plans for cleanup, i and informing people that bathing and washing of clothes would remove surface contamination (see attached).
2 Appropriate action has been taken within the Department to hasten press l releases should a similar situation re-occur. ,
The final . evaluation-of whether the Department's decision and action were justified should be made on _the basis of cleanup results.
- 1) 'There were no personnel exposures which approached any established
-limits.
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Mr.'RichaEd P. PollockL .!
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- 4. .16, L 1978 i
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- 2) The spill; was contained within. the . original accident area with no i contamination of additional-land. during- cleanup,as confirmed by '
4 3). the Thecontinual spill site air monitoring and' radiation surveys.levels, i.e.,
, i was. decontaminated to background
' after cleanup. .the- spill site radiation levels .were the same as ' adjacent'non-involved areas.
a We-hope that. this helps clarify some of the. statements which have been
-f, . made regarding the Springfield. accident. - !
f -
b ' - We' share the expressed l concerns regarding increasing numbers of. hazardous ;
l materials. shipments on heavily traveled highways and through metropolitan' ^
areas.-
Sincer ly, f, '
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i 1 AlberD,[d.fx),
Hazle i' tor 1 ;
Radiation and'lHa (zardous -
(. Wastes Control AJH:er I
- cc: Tom Vernon, M.D.
i
- Enclosure ,
i '
. Gear 41d D. . 0rhoff, Regulatory Affairs
, Exxon, Houston, Texas !
3 t
- A.-WrGreTla70ffite Vf71azardou~s MitEri~als Department of Transportation , Washington D. C. - - - --
s Carlton Kammerer,. Director, .0ffice of Congressional Affairs Nuclear Regulatory Comission i
' Washington, D. ' C.
o E. Morris Howard, Director
' Nuclear Regulatory Comission, Region IV ;
. l Arlington Texas - ,
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COLORADO ~ DEPARTMENT .0F HEALTH 4210 EAST 11TH AVENUE . OENVER. COLORADO 80220 . PHONE 388-6111 Anthony Robbins. M.D., M.P.A. Esecutive Director November 1,1977 i
~
, The Honorable' Gary Hart, Chairmen
' United States Senate -
254 Russell Senate Office Bldg. -
(
Washington, D.C.
20510 ATIN Kevin Cornell '
Dear Senator Hart:
Pursuant to'ydur request we are enclosing the summary report.cf the Colorado Department of Health on the uranium concentrate truck accident near Springfield, Colorado en September 27, 1977.
- Mr. Cornell of your office also requested the Department's ccaments on the U.S. Nuclear Regulatory Commission's (NRC) report to you dated October 12, 1977 and signed by Carlton Kammerer.
1..
On page 2 of their summary report they state that "the hazard to personnel is therefore relatively low since significant quantities occurs". Themust be taken into the body before damage to tissue ingestion and inhalation hazard of " yellow eske" as both a heavy metal poison and as a radioactive hazard is such that stringent precautions are required for those who routinely. handle it in processing under controlled conditions.
These precautions include the use of protective clothing, respirators, and restricted work periods. It was several days before such protective equipment was available for the uncon-
'crolled cogditions at the Springfield, accident. -
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- s. ~ Honorable _ Gary Hart; Chairman D 'i l United States Senata Page Two,JNovember 1, 1977- , , ..
- 2. L on'page 5 several statements are made about the "high improb-ability" Lof. a. person having an intake. .of .as much a's 10 or 17- :
!ailligrama of uranium concentrate due to a transportation accident.: .In the Springfield accident. situation finely' powdered i uranium concentrate was spread over an ' area of several thousand -
square .fest and as deep as a: foot. This was far worse than previous estimatas, of a maxima credible accident provided in
'- several NRC Environmental Impace Stacaments.' one rescus workar:
. reportedly efforts. Infall ~on hia' face in this material during early rascue 1 view of. Colorado's experience with uranium concen-
. trate aiccidents,. it would appear that the NRC underestimatae the accident potential'and the resultant-impacts.
3.:'
The NRC haa.in the past not required its licensees to prepars '
transportation accident contingency plans and.apparently-still '
- does' not feel inclined- to 'do so. While the carrier does have some legalJ responsibility under such circumstances, they car-
- tainly do not have the expertise, personnel and equipment to adequately respond in a timely nanner. The licenses however is in a position to respond and.also should protect its interests.
~Therefore, Colorado will be. requiring its uranium mill licensee to plan accordingly.
J 4.- .3 The reconmendations foi decontamination of the equipment and j accident site made by the NRC were based on the nuclear power plant decommissioning' criteria of MRC's Regulatory Guida 1.86. :
The Colorado Department of Health felt the application of such a criteriatinappropriata as the. situation could be easily decon- '
em=4 mated to levels well below those specified in 1.86. The "as low as reasonably achiavable " philosophy as required by Colorado
-allowed levels. decontamination of the equipment and sita to background
' Apparently the AEC's old philosophy of just requiring what the regulations specifically state still exists in the NRC. ;
The Rocky Flats Plant off-site-soil contamo stion and the old
-inactive uranium mill tailings pila legacy were a result of this regniatory stance. .,
As a side issue regarding item 4 above, the ERDA/E?A Phase II, Title'I final.
reports raquascad by Congress are now being published.
- action will. require in. excess of a.hundred sillion dollars.The appropriaca. Because this remedial
' situation' occurred as a result of the Federal procurement program and inada--
.. quata . regulation by the Federal Government, the State of Colorado, along with Lothar. states and jurisdictions, have taken. che position that any remedial !
measures.takan are to be at full' Federal expense.
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The Honorable Gary Hart, Chairman r. .
d United States-Senate: .
Page Three, November 1 1977 l
J l
Shoulii you have any questions' regarding the Department's Springfie1d Accident Report or our comments r4garding the NRC report,_ please do not l hesitate to contact this.offica. -
I i
Sincerely, *
, 1
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Albert J. Hazie Director, Radiation
&. Hazardous Wastes Control Division l AJE:els Enclosures 1
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COLOBADO DEPARIMENT OF' HEALTH
\ '
- RADIATION. DICIDENT REPORT URANIUM "YELLCE CAEE" SPILL '
3 SEPTEMBER 27, 1977'- SOUTH m TERN,' COLORADO 4
1 9/27/77-4:00 A.M. AColoradoStataPatroldispatchernotifh.edJimMontgeaieryofthe
. Colorado Department'of' Health that actzuck carrying uranium " yellow j caka".was' involved in an accident near Springfield, Colorado. The dispatcher was to . notify Jim Montgomery of further details as they-became known.
Sb30'A.M.
Jim Montgomery.. notified the Colorado Department of Health of:Iice "staff of the yellow caka".accident near Springf!sid, Colorado of a truck carrying Two: people were reported injurad and an unknown
. quantity of the yellow cake had been spilled. . Darral McDaniel and Chuck Mattson were delagacad. to respond for the ' Department. !
' Chuck Mattson called Bill Dunn, of the Colorado Department of Health l Laboratory Division, who said' he had been called by the Poison Control !
-Center concerning treatment of the vierims.
on-the truck accident. He had no more informacion-ichuck victims.Matitson called Poison Control Cancer and discussed the acc It was suggestad that urine and facal samples, and nasal
- wipes be taken to,indicata any ingestion of uranium. They wera informed that there was little radiation ha=ard, but a potential-
.for a heavy metal poisoning.
Anti-coe =de rion clothing, samoling and counting equipment was gathered together,. and Health Physicists Mattson and McDanial departed for Lamar at about 10:00 A.M.
.11:40 A.1 William Somers of the Colorado Department of Health received a phone call from Mr. Gersid Ortloff (713-6f6-42391 of Exxon Corporation concerning the cruck accident usar Springfield, Colorado. He infor=ad.
Mr. Somers that Lee Way Motor Preight of Oklahoma City was the carrier and was responsible for the clean-up. Mr. Ortloff stated that'he was sending the environmental Engina~er frem the zill,L Mr. Richard T.
Hornsby, and ona technician, Nancy Dennis, to the siti. They are
~
i equipped with a completa emergency kit and would check the undamaged drums for contamination befare loading them on another truck the.
carrier was; sending.
They would also coordinata the clean-up with the Department af Health staff at'tha' scans of-the accident. Exxon's
. intention was to moistan the yellow caka: to help prevent the spread of airborna contamination and recover the yellow caka and soil wet.
Twenty-55' gallon drums are being sent to the site to be used for.
pWY up tha yellow cake and soil. ,
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11:40 A.M.1 ( Mr. Ortloff asked aboue. evacuating nearby residents if the yellow-(cont.) caka was being blown towards them. William Somers stated that this could' be done with . Department sanecion if there was a definica risk.
Mr. Ortloff. then asked .about blocking the highway; to traffic and W. Somers stated.that would be up to the Colorado Stata Patrol. The conversation was concluded.at approximately 11:45 A.M.
- l2:30 P.M.-
Chuck Mattson-'and Darrel McDaniel arrived at accident sita and obe m ed. .
that.the truck and spill area had been covered with plastic sheets.-
It appeared ~that the majority of the drums had been thrown from the
- truck and the '.' shapes" of the covered drums indicated that many had i
- i been'saverely damaged. No one .from Exxon had arrived at the scene.
C. Mattson and D. McDaniel talkad to Baca County Sheriff's Deputies l
' and Mr. Waltars from co'lorado Eighway Department concerning the acci.
-- dent, accident victims, and rescus personnal. D. McDaniel stayed at the site whila C. Mattson and Mr. Waltars drove'into Springfield cc, inspect tha' hospital, victims and ambulance.
2:45 P.M.
A. gamma radiation, survey was performad at the accident scena using Colorado Department of Health micro-R matar U.S. AZC 139196. The following readings vara recordad: * (see figure 1) 3:30 P.M. Chuck Mattson arrived an hospital, introduced himself to the Ad= M ~
trator, Edna Chansweth, and was introduced to the ambulanca crew.
. The ambulanca was postad with a DO NCI E2 ITER sign and bags contai=ing ;
clothing of ambulanca personnel and the truck drivers were observed outsida the raar hospital . door.
A em,my with the- Ludium alpha radiation survey matar of the ambulance l
' indicated the floor, entry ways, and some equipment was cent - N tad '
to 400 cpm alpha. The incarier of the amoulance was vacuumad and scrubbed; and all the equipment was cleaned, after which there vara
-no readings on tha' mater.
The hospital shower rooms, emergency room, and the victim's rcom -
was free from contamination. ;
' Clothing in plastic bags was observed to be covered with the. yellcw '
caka and gave raadings to 100 pR/hr. with the gamma radiation scis-tillator.
Hospital personnel wara cold to leave the clothing in the bags until'it 'was decided how -J1ay would be cleaned or disposed of.
. Gamma and alpha radiation ~ surveys of the victims' hands, faces, and nasal wipes'showed no activity.-
- Natural background radiation levels were datarmined tu be 18-20 micro-R/hr. ..
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'4:00 P.M.
Rick. Hornsby and Nancy Dennis : of Exxon Corporation's Eighland Uranium
' Operations! arrived at the scene of tha incident. .Mr. Hornsby askad '
Mr. McDaniel how the Colorado Department of Health was going.to ennage the clean-up operation. Mr. McDaniel told him that the Colorado Depart ,
ment of. Health was at r.hei scene c to insure that the material was cleaned -
up properly and that the Department would'not'do theLactual clean-up.
- up.
Mr. Bornsby He -4"*=4_*ad asked questions concerning'the responsibili$y for tha clean ;
that'it should be' Lee Way's responsibility tc clean up; the spill. ' He was ' advised by the Colorado Department of Haalth that:
the yellow caka would have to be hand: shoveled into new' barrels, and -
moistanad when necessary to prevent blowing.-
4:10 P.M. Mr. Bornsby began making arrangements for security of the' truck and uranium barrels;during,the night.: "a also began == Mag. arrangements for equipment and manpownr for the clean-up operations which were to ,
begin at dawn, September 23, 1977..
4:15 P.M..
.Alex Ewing, Exxon Security Agent,.from Midland, Texas arrived at the scena.
4:20 P.M.
.Mr. Earnaby and Ms.-Dennis conducted an initial' inspection of the truck. .
and contents to determina the-extant of damage to the drums. Mr. ,
Mel'aniel was informed of the following: *
- 1. , A truck with twenty empty drums was being . dispatched from Wyoming so that tha uranium 'oxida could be shipped.back ~to the mill for reclamation, L Exxon was godng to buy all the co**=4-ted clothing from the ras:na personnel, and-
- 3. A,p1==4 : raati .g was to be held that evening to unka'all bgistics plans, t
5:15 P.M.
Darral McDandal tion clothing, and Rick encared theHor:sby, trailer to waarin;; respirators and anti-contami=a- ;
"-4a=. the extant of damage to '
. the: drums : that had not been thrown from it. Thera were 18 drcms in the trailer,'all damaged.co soma excent. At least half of cha 18 drums were visibly 1==W a! or had dumped tha yellow caka.
S:30'P.M. i
!A visual examination'of the E . W 4*: araa was mada by Ms. Dennis, j Mr. Hornsby and Mr. Md==4 =1 to datam4"= the. extant di blowing of 1
' thelyellow caka (wind from southeast).
that significant amounts of yellow; cake had Ihara was no conclusive evidence-blown. Rick Horusby in-
~
'formad Darral McDanial that.a_1)_ drums and yellow cake would have to be shipped back to Wyoming. Mr. Hornsby requestad assistanca from the
. Colorado Department. of Health for monitoring and release ~of equipment ,
after decontamination. Ha also requestad that traffic control.and
'dacision - W ar be in cooperation with the Colorado Departmentief Health. .
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6:00 P.M. ' Chuck Mattson left the hospital. Mr'. McDaniel perfor=ed a ga==a radiation survey of the area surrounding the accident scene to deter-4 e background. The following readings were coca4"ad with micro-R. =ecer - AEC 139196: (see figure 2) -
9/28/77 8:00 A.M. Darrel McDaniel and Chuck Mattson arrived'at the accident site. No progress had been =ade , coward clean-up. Mr. Hornsby drove to Sp-ing-field to telephone his office prior to making any decisions or answer-ing any questions. He was told that the Colorado Depart =ent of Health.
regarded Escron as the agency responsible for clean-up, and providing
- enough. trained personnel with proper equip =ent, to get the job done.
The re=ainder of the day was spent waiting for the person =el and equip-ment.
Mr. Mattson and Mr. McDaniel returned ec Denver late that evening.
4:15 P.M. Chuck Mattson phoned Rid.hard Ga=ewell at the Colorado Depar ~ "t of Health. Mr. Garnwell requested that bicassays be obta4-ad for a,firamn whq,_ reportedly had faller,_in_the vellow_ cake shortly after the accident.
4:30 P.M. Mr. Gamewell notified John Barry of the U.S. ERDA Radiological Assistance Tasm, Idaho Falls. Help was not requested. This was their inicial. notifi-catio:
4:35 P.M. Mr. Ga=ewell notified Frank locich, Director of the Colorado Depart =ent of Health Water Quality Control Division. Since local farmers u'se effluent from the Springfield sewer plant, Rozich decided te have it sa= pled.
9/29/77 9:00 A.M. Mr. Ga=ewell =ctified' Paul Smith, Region v'nT, U.S. F2A and Aca 31schard, Colorado Depart =ent of Health Air Pollution Control Division.
11:30 A.M. Floyd Nichols, Region 7III, U.S. IPA notified Mr. Ga=ewell of the Coloradc Depar ent of Health that a photo flight over the accident was planned that afternoon.
11:35 A.M.
Gerald Ortloff, N on, called the Colorado Depart =ent of Health (Ga=ewell, Mattson, and McDaniel). The Colorado Depa n nt of Health advised him of the desirability of getting people to the accident site who were thoroughly trained in t.he fitti=g of respirators and the use of sensi-tive radiation survey =eters.
11:40 A.M.
Mr. Ga=ewell updated Jim Montge=ary of the Colorado Depar==ent of Health, who requested that Chuck Mattson return 4-adiately to the site and that a press release be issued. .-
1:45 P.M. Mr. Ortloff telephoned the Colorado Depart =ent of Health and said two individuals, Marvin Smith, a certified Health Physicist, and Ed Foster, a Health Physics Technician, from E. con Nuclear at Richland, *4ashington would arr've in La=ar about 7:00 P.M. They will supervise the cienn-up job. They are also sam 4 g 2 Scott air packs and 10 full face = asks with fittings for co=oressed air bottics. It was ree - anded that they contact Chuck Mattson a:: the El Mar Metal, La=ar, Colorado.
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?3:40'P.L- 'Mr. . Gamave11~ of the Colorado Department of Health called Ms. Davis, '
Jin
' Head Nurse at Southeast Colorado Hospital'.in Spri=gfield,fabout bicasssys on'the drivers. . Urines wara.still being collected and v would be - senti for analysis' to the University of Colorado- Medical I Cantar, Denver (Dr. Robert Peterson). ' ,
5:30 P.M.-
. Jerry Hansel, U.S. EPA, advised Mr. Gamawell' of the Colorado Depart- q mant; of Health 'of sueca'ssful photo flight..
6:00 P.M. Chuckbfactsonarrivedataccident~ite-and. s talked.briafly'withRick
. Hornsby who was .on his way .co a dinner meeting with his Exxon crew.
Photos were taken of the accident scena. The only work which was.
- being done was improvement of roadsdde barricadas by the two evening guards. . Chuck Mattson zaturned'to 'ha mocal at 8
- 15 P.E
'11:50 P.M.- Chuck Mattson received a telephone call from Mr. Mary Smith who intro-
'duced himself as the Consult 1=g Health Physicist hired by Ezzon to assist in the clean-up. He had. worked. for Exzen befor's and-is on the ,
faculty of the Graduata Schcol of the University of Washingcon. He j
discussed his plans to build. sa anelosure as. a " wind shield" co' kamp
~
j tha dust down during clasn-ar. The faca masks whiet na recommandad '
that the clean-up crew wea:. were the full face, double emnn h ter type,
_' because' he had used these befera in plutonium work. An appointmant !
was made for br==Ma=c at 7:00 A.M.
9/30/77 7:00 A.M. Chuck Mattson introduced himself to Mary Smith, of Ezzon, and went'to the breakfast maeci.ug." Tan Exxon amployees, who'had been sent to assist in clean-up,'also attended the meeting.. Mr. Mattson'talkad briafly
- with Mr. Smith concerning his' plan' for the clean up d~1uding the build-
~1ng of a portable shaltar so that all clean-up work could'be dona without wind interfarence. The use of procactive clothing and full-face raspir-.
ators was also discussed.
8:30 A.M.
Mr. Gamave11 advised Albert J. Hazia, Colorado Depam of Haalth, of the situation.'
8:40 A.L Mr; well advised Robert D. Siak, Colorado Depaa-4 of Health, of the situation.
Regulatory Ccamission. Mr. Siak requested an immediata lattar to the U.S. Nuclear i 8:45 A.M.
Chuck Mattson arrived'at the accident sita. It was observed that a farmar and his dog wars on. guard.. A-1 Rantal Company employees vara.
. setting up-'a portable toilet.
19:30 A.M.'
' A gansna radiation survey of tha area was conducted with a Mcdel PPy.-7C survey matar. (see . figura ' 3) r l- '
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9:30 A.M.: :'Ed poster.was- using a Thyac III with" a pann =k= proba for all-(cont.)
' anvironmental. surveys. Mr. Ed Foster was the Health Physics l
Technician Specialist for' Exzen Nuclear, whers he had worked for '
6 years. Prior to this, he had four years azpariance at Battella (Hansford)'.. . His' training consistadl of ona year as a "trainas" 3 years as a!" monitor", and than experienca as a "journayman".,
Mary Smith talkad about " taping" holas in damaged barrels than
~
iwrapping in. plastic for' shipping. He stated this was prefarabia
.: to amptying .che barrals and handHng the yellow caka.
11:05 A.M.
- Chuck Mattsoulcalled the Department and related;the following:
- 1. 'The 2 Realth' Physicists from Richland, Washington have arrivad'.',
' 2. They are building a movable structura of 2 x 4's and ,
plastic'to. act as-a wind block around the spill.
- 3. A' shower andL h==gdng tant from the National Guard l was being sat up at'tha sita. !
- 4. Urina samples .of 13 persons involved in the rescua !
vara being collected and sent to U.S'. Testing Labora-tory for. analysis. . Easults should be'available on-aspyroximately 9/30/77.
5; Ezzon wants to tapa and car punctured barrels. 'It was recone=nd=d that they obtain Department of Transportation i and Colorado Department of Health approval.
6.
Workars would waar full face nasks with canistars suitable ,for plutonium.
l7. Mr. Mattson suggestad that contingency plans be mada to cope with rains and flooding -
11:30 A.M. 1
' Chuck Mattson stopped at .the Southeast Colorado Hospital. The !
W"4 atrator, Ms. Clianswath, ' relarad how the victims ' urina samples had not been . forwarded to the Colorado University Medical Cantar for analyses. She also indicated that the chalating agents had set bean' received from the supplier. A nurse had been told to collect i urina samplas_-for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the administration of the drug "caprimina".- She had understood that she was to sand in all samplas c together, iso sha had held onto them.
Mr.. Mattson talkad' to Dr. Robert Peterson at the Colorado University Medical' Cantar and was ~ asked questions about the victims condition and- -
'these questions wara f.rwarded to the physician at'the hospital. If there had been a heavy matal problem with either-victim, they would have already baan symptomatic. The Administrator was. asked to sand the
, samples byfthe fastast'means possible.for'analysas.
'. 12:15 P.M.
Mr. Mattson arrived back.at the accident sita.. The CIA 3 (USAF Qparating location _ Alpha ],ravo, Cheyenne Mountain), 947th Medical Company- (Army 15ational Guard) and the Lamar Fire Department vera complacing tha installation of'a tant for showering. A portable shaltar for barrel
,
- h= Ta was being constructed, s
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12:15 P.M.' Mr. 'Sinith stated. that he, h*ad talked' .to ' Department of Transportation- *
- (cont.)( ain Wr.shington, D.C..concerning the shipping of damaged drums. .Their reply according.to Mr. Smith was to use satisfaecory industrial c-4==rs, and to ship the yellow caka in a ' sole use vehicle' .
Thera.were no. specifications on the containers. ,
j
-1:50 P.M Gerald Ortlo0f, 'Ragulatory Affairs Manager, for Eaccon, arrived. at the ]
. site.
Mr. Ortloff is the Regulatory Affairs Manager for the Minerals ;
Deparemane of Ezzon, U.S.A.
He has worked in the Minerals Depar* nane .!
for 5 years. Prior to this he worked in the Ezzon Production Depart- '
ment as a chemical engineer. .
i . l 2:00 P.M. .
1 Mr.J A1 Hazia telephoned Dr. George Voelz, Los Alamos, New Mazico,' and- '
requested that ha call Southeast Colorado Hospital, Springfield, Colorado ~
- to datarmine whether. the bicassay methods being used vera appropriata. ;
' Mr. Hazia also requested that Dr. voelz advisa- the hospital of the i
proper procedures and methodt, to be used in an incident of-this type . I 2:30 P.M. Traffic was daccured arourut the site via Highway l'16, a dirt road about 1 mile east.of U.S. 287. It required one way craffic and an escore ;
be the Stata Patrol through the dateur. This detour would remain in.
affect, during daylight hours,.until clean-up was completed.- _
3:30 P.M.
The portable barrel =~ b age enclosure was see down on black carp over ;
one. barrel, and the outside sealed around the bottom. One man with.
protactive clothing and full face respirator went inside tha' enclosure.
r and cut the plastic cover. The barrel, dented .on the sida,' but not
- broken', was washed, lifted by front loadar, surveyed and than trana- i
. :farred to a decontaminacad-barrel area.
Two additional barrels were filled with yellow caka, dire, and weeds from the area-insida.the enclosure. These were then washed,' surveyed by wiping the outside and moved to the decontami=ated barrel area.
Woric continued until dusk.
4:00 P.M.
Tha Colorado Department of Health mailad out first press release. -
9:30 P.M..
Mr. Mattson'callad a'nd updated Mr. Gamewell. Mr. Mattson was requested to return to Denver on October 1st if the situation apoeared undar control.
10/1/77
'8:00 A.M.. Chuck Mattson arrived atLthe accident sita. A gamma radiation survey was ' dans' with a Micro-E matar (U.S. AEC 139196):' (see figure 4)
Work was: progressing slowly; the Health Physicist was being ;very con-- '
iservative;in the handling of the clean-up. The Haalth Physics Techni-cian appeared knowledgeable and conscientious with his surveys.
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4 12i30 P.M.. . Chuck Mattson talked'to' Gerald Ortliff and Rick Hornsby and requested-
'that they call'at 9:00 A.M. and 4:00 P.M. daily with a report.of .
progress, monitoring 'results, . bicassays ar.d. any problems encountered t during clean-up. Mr. Mattson then returned to Denver.
I, 10/2/77: '
' Chuck Mattson' received a . telephone call fron Nancy Dennis, who' provided
~
8:30 A.M.- f results' of urine analys,es' for the people involved in the' rescue. She ;
stated that the =4n4-= detectable amount was 10 pgms uranium per liter j
'of urine.. '
Two. persons' exceeded this =4*4 - detectable' amount:
- 16.4 pgms/1 '
- a. ,
.10.2 psms/1 - -
. . _ . t These levels are. considerably below Safety and Health Scandards.- ;
A Netd ul Guard cent had'.been used at the site as additional cover !
' for ti : ruck to prevent blowing of the yellow cake. '
A number of plastic bag' drum liners had been purchased.'
Five drums of dirt and yellow cake had.been barreled.
10/3/77- '
A' staff review.of the incident and'ciean-up atte pts to date.was 8:30 A.M.' conducted at the Colorado. Department of Health. Questions were-raised concerning~ responsibility for clean-up, adequacy of personnel and equipment, and the technique to be used for the final survey to-assure complete clean-up.
9:30 A.M. Call received at the Colorado Department of Health from the Lamar newspaper. The reporter was referred to the Colorado Department of Health Public Relations office.
l 10:30 A.M.
Chuck Mattson stopped at the Denver Federal Canter, 3uilding 53, l Room 32217,- and talked to Jerry Hansel concerning the aerial photo- ;
graphs of.the accident site. . All photor. were viewed and -15 were
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selected to be.sant' to the Colorado Department of Health.
. 2:30 P.Mi 'Darrel McDaniel received a celephone call from Mr. Coleman Smith of
-the' Oklahoma. Department-of' Health, occupational and Radiological. Health
- Way Servicetruck. (405) driver 271-5221.
named Harold - Mr.E.Smith Shea.indicated he had talked to a' Lee j
Mr'. Shea had stopped his truck at'the' accident' scene and was involved'in the rescue operations..- A
' urine bioassay had been taken from Mr. Shea and Mr. Smith wanted to 1 know where it should be. assayed. Mr. McDaniel told Mr. Smith that'he' j
- should talk to Mr. Gamewell of the Colorado Department'of Health Labora .
tory. .
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10/4/77 ; Chuck Mattson' arrived at the accident site. Mr. Blount and two '
L7:45 A.M.-. Exxon ' employees vara at tha ~ sita. ' They were working.on the electrical wiring.-
~~ A pickup truck from A-1 rental delivered a' compressor. Four more Edzon employees arrived with twelve rolls of plastic carp.
ASoutheastColoradoPowerAssociationcruckarrivedanhthemenbegan! '
to install a three-phase transformer'and two street lights on the power pelas.
Two Colorado' Highway Departmant' trucks deli $ered eight rolls of snow-
- ~
fence. This was used to encircia the accident sica. The fanca was than covered with plastic carps which served as a wind break.
Vacuum'cleanars,'f11 tars, and miscellaneous boxes of equipment were delivered during the day by taxi service from Pueblo.
10/5/77 1 3:00 P.E . ' Chuck Mattson returned to Denver.
4:00 P.E Darrel McDanial received a celephone call at the Colorado Department of i Haalth from Mr. Gerald Or:leff, Ezzon Corporation, to report the progress, of clean-up operations. Mr..Ortloff informed him that the contants of. '
.27 drums had been recovered and placed 'with 50 drums previously filled for. shipment backLeo Wyoming. He hoped that clean 4p would be completed !
~
by the weak =M and that final gradi=g and scraping would be finished by i the first of.the following week.
Mr. Ortloff also raportad the followi=g i=for:$ation:
Total activity on air filters in the clean-up area .
.(continuous sampling 7:30 A.M. to 11:30 A.M.) =
2.2 x 10-10 Ci/mi Activity on air filters sampled 50 fast downwind from work area (continuous . sampling 7:30 A.E to 11:30 A.M.) =
1.3 x 10-10 Ci/m.1 I
Urina sampla results from U.S. Testing Servica: -
All samplas for man doing clean-up wara less than the idades
.Lof detection .(i.a'. 410 pg/ml) .
Tan results had been recalved for tha, men involved in rescua \
work. Two of these were above the 14 4ts of detac: ion, one 10.2 ,ug/mi and the other 16j.tg/nl.
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10/6/77: ~
.Darrel McDaniel listened in on a phone conversation betwaan Don . -
11:00 A.M.' Hendricks, EPA,-Las Vegas and~ Chuck Mattson.- Mr. Hendricks was incarested in knowing about the accident and specific questions about the makeup lof the yellow caka, its solubility, and final calcining tamparatura.
He mentioned that ammonium diuranate was more soluble than ur= Min oxide. .
Mr. Hendricks offarad the use of soma Geiger-Mullar instruments that had baan calibrated for counting yellow cake on air filters. However, ;
wa declined an' that time, but Mr. Mattson callad back later and had two instrumants sent to the Colorado Department of Health.. ,
- - The attached handwritten nota.'from Mr. Albert Hazia contains cali-bration decon*==h= information for the E2A Gaictr-Muller instruments and also tion levels.,
2:00 P.M.
Margo' Hornblower, of Washington *?ost, called Chuck Mattson with request for an
'that time. interview with Al Hazia. Mr. Hazia' was not in the offica 'at 2:10 P.M. Mark Weaver, ofI EDEN radio, called Chuck Mattson for an incarview with Al Hazia, who was out of the office.
2:45 P.M.
Wayna Karr, U.S. NEC, calaphened and talked with Al Hazia concerning Representative Tim Wirth's questions about the ~ accident. Congressman.
Wirth had reportedly-requested a =aating with the NRC Commissioners for 10:00 A.M. the fol_ lowing morning.
.- Mr. E. Hattori of the Mitsubishi' Company requestad by celephone a copy.
' of the Departmant's final news ralassa concerning the spill. Ha read-about the incident in a Tokyo Japan newspaper.
3:00 P.M. Mr. David Range of Ezzon in-Richland, Washington talephoned Chuck 1 1
Mattson concerni=g the makeup and relativa solubility of their yellow cake product. Ha stated that their yellow ammonium diuranata is calcined ' .
at 10000 F which converts part of.the =atarial to the black U 08 3 The l product in the accident was an olive graan, and was estimated by Mr.
Range to be about 60". oxide and 40". diuranata. A probable cha=ical makeup of the product was stated to be:
U038 7 957.
. 383 H2O = T 2".
SO4 less than 1/2*. total of Si, ?, C1, and Mo.
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4:157 P.M.. i Mr[ Gerald 10rtloff called. Darrel McDaniel and informed him tha "
1 ithe 18 drums;on the trailer, 7 had.been placed in. plastic bags and
' moved to ths' storage area.- r The other 11 drums'had been turned right j
'upside and:upsecured.
in the trailer. All the loose yellow cake'had been picked !
4 !
He did not feel that there would be a. problem with yellow cake under j the trailer to be intact.' because' che' side 'of the trailer lying on the ground appeared -i
<Mr. Ortloff also stated that all of the damaged drums would be shipped by.a~" super tiger" coneminar truck while the new repackaged drums would- be shipped-back to Wyoming via conventional trucks. q
' ~Hedirt.
stated that eighteen" drums had been filled with yellow cake and' (
the dry The powder.vacuum cleaners were reportad worki=g well for pickup of Work had begun in the cruck, with seven drums having '
been removed.
was extensive. The walls'of the truck were sound, damage to the top ;
There was little dust problem, according to Mr. Ortloff.
. The micro-R. meter had nor yet been. received.
Tirenty-six persons were involved in the rescue after the accident and twenty-one of these had
- already been contacted and urine samples taken.. These samples had been sent.to U.S. Testing Corporation for uranium' analyses. .
- Jerry'Everett, of Region IV,.U.S. NRC, was at the site. Air samples had been taken and given pre 1 44*=*y analysis before shipment to Eighland, Wyoming for lab analyses..
Pre 144*- y analysis results were as follows:
2 Er.15 min. , - 1.3 x 10 C1/mi 2 Er. 15 min. - 1 x 10-10 5 min. - 1.9 x 10-10 C1/mi - (dowinrind - 50 ft.)
pC1/mi - in immediate verk area 10/7/77. '
9:00 A.M. Jerry Comba, from the E=argency ?reparedness 3 ranch, Depart =ent of Energy, the incident. called Chvek Mattson and requested a report and photos of 9:10 L M.
Jerry Everett, called Chuck Mattson and Richard Gameuell from Lamar.
Helsaid.he had talked to Marv Smith and Jerry Ortloff concerning his position on decontaminating the truck and soil. He quoted from the U.S. ' AEC' Regulatory Guide .1.86.
His recommendation' for soil was based on azi exposure of 0.5 Rem /yr.
toLthefgeneral'public.. ~
(gonadal region),'or 60 pR/hr. This translates to 0.06 mR/hr. at 3 ft.
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9:10 A.M.' Richard Gamawell and chuck Mattson qtioted the NRC MBranch Position '-- '
- (cont.);
Uranium Mill Tailings Management" from Wayna Karr.on 5/19/77, requir-
-ing decontamination to "assentially. background". Mr..Everett was told that'the Division would discuss this mattar and stata the Depart- ,
- mant's position at'the 4:00 P.M.; call. ,
Mr. Ortloff related a that the truck was to be cleaned out this day, l
- decon*==r4"=e d possibly' tomorrow, then released to Lee Way Trucking.
J i
He had talkad to the lamar Daily saws., . reporting' the yellow caka was 99 +7. cleaned up.- - !
i The plywood on the left side of ths- cruck was to be torn out End barreled, than' the truck, vacuumed, decontaminatad and turned upright.
The . tant used to cover the truck was purchased by Exzen from the Colorado Nat1onal Guard. D a radiation surveys of the incarier of
. face maska'and nasal wipestcontinua to be negative..
Weather is cloudy and cool, with no wind. I 4:15 P.M.
Call received at the Colorado Department of Enalth from Garald Orticff. l Be stated that a " super eiger" container had been loaded with 21 drums j and had daparted for Wyoming. The truck was to raturn to Springfield l at'about'.3:00 P.M. the following day for another 21 barrels.
The plywood lining ofiha cruck had been removed and the walls vara-being sexubbed with water and sponges. _
Plans were to upright the ;
' truck tha nazt day. All sides of the truck warm reported to be in j good condition, with the exception of the roof. L a area immediately l
around the:trailar had also been cleaned up. It was anticipated that the trallar would be islassed to Las Way no latar than Sunday. Field calonlations of the air samples indicated c=ncentrations of 20-65 x 10-11 faci /ml in the immediata area.perimatar, workyaa, 0.7 x 10-11 pC1/ml at the controlled and'13 x 10-I pC1/ml downwind (50 ft.)' frbs the con -
trolled araa.. ,
10/8/77 L3:30 P.M. Richard Gamewall arrived at the accident sita. He met with Rick Hornsby,-
Marvin Smith, Gerald Ortloff, an Exxon lawyer', and an Escson Public Rela-tions man.' na truck had been uprighead. Three Exxoti man', after vacuum- ,
. ing the insida 'of the trailar, were scrubbing it down with brushes,
- spongas and 2' gallon portable tree sprayers f111ad with water. Thera-was' plastic sheeti=g under the truck. Some of the water in the truck ')
'- was. being vacuumed up. - ne plywood' liner on the left side of the trailar
. :had been completaly removed, cut up and barreled. The opening i=cthe Wroofthathad;beencornbychayellowcakabarrelsonimpacthadbeen 1 ,
enlarged to facilitata decon*= * = tion. ; Alpha readings in the cruck vera ;
'dym/100 cm'fless than ?00, cpm which Mr. Smith calculated was equivalen
.. The raar and of the truck was' pulled about 6'faec west c,
and than the truck was towed forward about 75 fast. ne rear wheels ;
-showed. slight'conemmination.so they vara hosed off. The truck was towed w '
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'3:30 P.M. f ro-Springfield a'e 7:00 P.M. for transfer to a low boy truck and
-(cont.) _ J hauled- to Lee Way's main repair shop'in Oklahome. : Mr. Smith said they found no contamination in the cab. Sgt. Benson of the State
. Petrol said that the northern edge cf the. spill was about 6 fe, in i front. (south) of, the cab.
Some people might havel contaminated t.bem , ,
Lselves while standing-in the area but'he personally advised everyone to shower, and. leave chair clothes outdoors in plastic' bags until i they could be checked.for contamination.- He further.said that the Ldriver's_ leg was' pinned under the. cab and could not be moved until .
a drilling rig lifted-the whole cab off the ground. The driver was
't i
then pulled out through~ the top of the cair. . The-left front of the '
cab was completely mangled from impact with the culvert. The right
'- front and radiator of'the. cab were damaged from impact with the three Lhorses. Sgt. Benson believed that on the basis of the skid marks, l
~.-
the truck had notLbeen speeding.
Mr. Gamswell' took color slides' of the cruck and accident site. Damaged barrels were encased in plastic bags and shipped to the Highland Uranium Mill in Wyoming via che " super eiger" truck. The barrels ,
containing the clean-up' material were leaded on another Lee Way truck t .which left for Highland about 7:45 P.M. The load was over the front !
and< rear. sales.- Empty barrels and 2 x 4's were used as a spacer between the axle loads. Barrels were loaded with a fork lift with
- a barrel loading attachment. Ed Foster (Exzen) thoroughly wiped the '
top, bottom and sides of each barrel and checked the wipes with their. l
. Thyac II. Sgt. Benson said that both he and the Baca Sheriff had' benefited from the Colorado Hazardous Materials Safety Course which they attanded in Lamar two years ago. Sgt. Benson said that the Exxon shipping Copy papers were handed to him as soon as he arrived on the scene.
attached.
They briefly described the nature.of the-cargo, its
- 7 potential hazard, and a list of protective actions in case of accident. '
- Mr. Hornsby said the yellow' cake had been barreled between 8-4 and 9-18-77.
S:10 P.M.
' clean-up Gerald Ortloff called Chuck Mattson'at home in Denver to report the progress. L He said that the truck had been turned upright i and final decent-f acion was bei=g done prior to removal. '
The " super eiger" had been leaded with twenty-one drums of yellow cake and had left for Casper, Wyoming. It was scheduled cu raturn on Sunday morning for tha'r - 4"4": damaged barrels. ;
A I4e Way truck was at the accident site and was being loaded with apprawincely fifty drums.
' Air sample results were' reported and were stated co be less than 10-10r !
- n.
- gro C1/m1'in the immediate work area and no different ' from back- '!
at the restricted' area ban
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- ,l a The bioassay ' (urine analyses)' results were reported as: l I
- 41d uC1/1 (the deceetion limitL.
=
14 uci/1 41 pC$./1 ALlarge vacuum cleaner, a "Cyclovac" with self cleaning tag, had "
arrived at the site and would'ba'used in fina clean-up, if necessary.
" Newsweek had called'Mr. Ortloff and questioded him, in general terme, concerning the accident. .
10/9/77 10:20 A.M.
Rid Hornsby called Chuck Mattson at home an'd stated that all the drume i
~ had been removed from the truck, whL:h had undergone final decontamina-tion and been towed away.
e No'new information was received concerning bioassays or air monitoring.
. Rick Hornsbyjstated that all the yellow cake should be cleaned up this i day and.chey would be ready for their final survey early the next-morning.
Chuck Mattson told him he would be available the following morning survey. to assisc and to check their survey and to perform a final 10/10/77' s 6:50'A.M. . Chuck Mattson arrived'at accident site. Four people were observed shoveling dirt into barrels, one man driving the barrel loader, and i
Nancy Dennis. talking to a man from the highway department. Mr. Lampke ;
stated that there was a lot more clean-up.to be done, probably more
'than could be complaced in one day.
7:15 A.M..
- A survey of the area surrounding the accidene site was complaced. All
' ground readings were between 14 and'20 pR/hr. The filled barrels gave readings of 170 to 800 pR/hr.
't 9:30 A.M...
Chuck Mattson was introduced to Paul Plummer, Accorney of the Exxon l Legal Department, Houston, and Wil'ay Bragg, T.xxon Public Affairs Manager, Houston; both were' suited and shoveling dirt.
9:15 A.M.
Chuck.Mattson picked up a Springfield sewage sample with the. assistance of Mr. Tommy Litka, City of Springfield. {
10:00'A.M.
Chuck Mattson picked up a sample of water from the well at the house approximataly one half mile south of the accident site.
^ <
'It was- stated by the home owner that the well located 1/4 mile southeast '
of.the' accident was not operable due to a broken push rod, and was not
. going,to be used.
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- 00 A.M., Chuck Mattson assisted Marv Smith with a survey of the accident sita'.
There were , two patches of ground which showed:" green". which read to ' l
'100;uR/hr. .One of these was a parch of: asphalt which the crew' attempted',
to: clean, but it was decided it would be easier to break the asphalt and barrel it. ' Approval to. remove the asp, halt (approximacaly 3 feet by 5 feet) was granted by Mr. Waltars of the Highway Department. ,
(
.t Two areas;of approximately,2 feet'by 4. feet and one area measuring !
2 feet by 15 fast gave readings of about 45 pR/hr. Thesa areas vera -
staked to be~ ~ further decone==4,ated. All other readings wera. lass !
' than 20 pR/hr, as measured with a Ludium micro-R matar.- Clean-up !
continued on the r-4"4"g contamination. -
t A Lee Way truck was filled with barrels, each barrel having been checkad'for external contamination at loading. When filled ~ the cruck was postad as " radioactive", and was driven to Springfield for weighing. 1 11:45 A.M. A_ highway worker driving a U.S. Army road gradar broke up the con-taminated asphalt,.and the pieces were barrelad for shipment back to wyoming. -
.12:10.P.M. The.gradar was used to scrape the top of the-ground to a depth of one to two inches. ,
, 12:30 P.M. The " wind rows" built up by the road gradar were surveyed and the loose -
material which raad greater than 30 AR/hr. was-shoveled into drums.
The only fixed areas tihich read greater than background-vera areas on i which water had been used. These fixed areas were shoveled into drums.
2:15 P.M. '
Another.. h y indicated some small patches which read 30,uR/hr. These were pickad up and~ barreled as discovered.
3:00 P.M. No armas remained which read greater than 30AR/hr. A completa survey showed the average. exposure in the area to be less than 20 uR/hr, a few local areas of exposura ec 30 AR/hr. but none graatar.
A comparison of the Department's Ludium micro-R matar with the Exxon Ludium micro-R matar gave'idantical readings. 1 f
. ;1 A comparis*on of tha IPA Ludium/Thyac matar and that wiiich had been used by Ezzon was made. The readings diffarad slightly. 'The 7xxon matar had an' additional wire' screen added over the =ylar for procaccion. ,
Esadings with the EPA Ludium/Thyac matar over the area gave readings ,
varying from 0.05 mR/hr. to 'O.15 mR/hr. at the soil surface, over. t
-twenty-five.different locations. The background measured from 0.03 to.0.06'mR/hr.. '
l Masars.=Ortloff and Hornsby were told by Chuck Mattson that the area l appeared to have been adequataly decontaminated and the clean-up was j acceptable to this Department.
~
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Removal 'of ' the area decontamhmeten ' equipment and the lavaling and
'replantingLof the highway right-of-way was begun. . Mr. Waltars, of L
{
the-Colorado Department of Highways appeared to be in charge of this
- portion of the operation.
Chuck Mattson Inft for Denver just after 4:00 P.M.
L
'The complace list of Ezzon ampicyaas involved in the clean-up:
^ ;
Richard T. Hornsby Tony Santiascavans Nancy Dennis Larry Evans Carl lampka Mary Smith
' John Oscarman Ed Festar .
Marv Harmsen ' Don Crawford
' Laroy Moore '
Bill Mayer - Ezzan i Bill Tibbs Alex Ewing - Security, Midland, Texas
. Don Kaitar .
John Hunt - Security, Denver Enunat Bourquin Paul Plummer Wiley Bragg.
10/12/77 2:15 P.M. The Colorado Depa m e.of Health received a telephone call from*Toa Tassaigna, hazardous materials specialist with the National Transpor-tacion Safety Board. He asked ganaral questions concerning the accident and requestad a copy of our final report. His number was (202) 426-3872.
M *nE address: TE 40, Washington, D.C. 20094.
10/13/77 4:00 P.M. ~ Bob Luna of Sandia Laba called and requestad copies of our final report. i and also of. some slidas showing the smashed barrels and spilled yellow caka. His address is: Robert Lu=a, Division 5432, Sandia. Labs, Albuquerque, New Mexico 87115.
I 1:15 P.M. I Chuck Mattson received a call from Harry Calley of IPA who requestad a '
copy of the Colorado Depar ~ ant of Health news release.
Staps that should be taken to preclude futura uranium transportation accidents:
1.
All uranium mill licensaas be made aware of tilair responsibility for immediata response to control and clean-up of their materials i= tra= sit.
~2. Item 2, bottom of page 2,-A thru F of 10/3/77 letter from Robert D. Siak em S. Myers. -(see attach = ant)
- 3. ' .Alternate routes areas.
avoid populated for uranium crucks to take which i i
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Fact Sheet - Transportation of Radioactive Material - Natural Uranium 0xide (Yellowcake)
Regulations - The transportation of radioactive materials is regulated principally by the Department of Transportation (DOT) and by the Nuclear Regulatory Comission (NRC). Safety regulations for transporting radio-active material in the United States are based on standards developed internationally by the International Atomic Energy Agency (IAEA). The international standards were developed through the active participation ;
of IAEA member states. The United States participated through repre-sentatives from both NRC and 00T.
The enclosed Memorandum of Understanding delineates the respective responsi-bilities of NRC and DOT for regulating safety in transportation of radio-active naterials. Generally, the DOT is responsible for regulating safety in transportation of all hazardous materials, including radioactive materials, and the NRC is responsible for regulating safety in receipt, possession, use and transfer of byproduct, source, and special nuclear mat 1 rials. The NRC reviews and approves or denies approval of package designs for fissile materials or for other radioactive materials in quantities exceeMng Type A limits, as defined in 10 CFR Part 71 (copy enclosed), i.e., the more hazardous types and quantities of radioactive materials.
DOT regulations pertaining to shipment of radioactive material are contained in Title 49, Code of Federal. Regulations, Parts 171-189.
NRC regulations pertaining to shipmemt of radioactive materials are contained in Title 10, Code of Federal Regulations, Part 71.
\
From its inception in January 1975, the NRC has been reviewing the existing regulations and procedures it inherited from the AEC. As part of this review, the NRC initiated in June 1975 a public rulemaking l proceeding regarding the air transport of all nuclear materials, in-cluding plutonium and enriched uranium. With the technical assistance of Sandia Laboratories, a draft generic environmental impact statement l ,
was prepared to assess the impacts associated with the transportation of radioactive materials by air and other modes, including relative tosts and benefits of alternative modes of transportation. Information derived from research into the accident-resistant properties of plutonium shipping packages and data collected from the NRC's Radioactive Materials Shipments Survey were used in preparing the statement. The draft state-i ment (NUREG-0034, copy enclosed) was completed in March 1976 and made .
available for comment to the general public and other Federal and State agencies. About 30 letters of connent were received and analyzed, and changes to the statement are being made, as appropriate. The f' '
environmental impact statement is expected to be issued this ye .
As a follow-on, the NRC has undertaken a study of the special features of radioactive material transport -- under both normal and accident conditions -- in large, densely populated areas, that will result in a generic environmental impact statement on the transport of radionuclides in urban environs. The study will evaluate the effects, including radiological safety, of characteristics peculiar to large cities, such as high' population density, local meteorology, and numerous tall buildings.
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r Sandia Laboratories, the_ NRC contractor for this study, has begun f model formulation and preliminary data gathering. A draft statement is' 4 - expected to be issued in' the spring of.1978.
i All ' indications ~ from the present studies are.that the risk associated a e with the transportation is very low, is within established national guidelines, and is very small in comparison to other risks accepted by the general public, such as accidents involving motor vehicles and death associated with electrical shocks. .
o Uranium Concentrate Characteristics - Uranium concentrate (yellowcake) typically is produced from uranium are by a process in which the ore is crushed and ground, leached with sulfuric acid or sodium carbonate-bicarbonate, separated by filtration, decantation or centrifugation, further separated by a solvent extraction or ion exchange process and finally precipitated by neutralization with ammonia, magnesia or caustic soda.
The resultant product is a solid usually canary-yellow in color (though
-it may be dark brown or even black) and ranges in consistency from granular to powder. This material, commonly called "yellowcake," is what is shipped from uranium milling plants in the Western United States to two sites in the United States for conversion to uranium hexafluoride (UF6 )'
the feed for the enrichment process.
Shipping Requirements - Uranium concentrate is classified as low specific activity materials (LSA) according to the Department of Transportation
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'W - : Hazardo'us Material Regulations (49 CFR 173.389(c)) and,- due. to its' low-
- concentration of radioactivity,'is not required.to be shipped in special pack-
- aging. The ' typical packaging, which has been used for many years, is a 55-gallos
. steel drum. A' 55-gallon drum has a capacity of about 850 pounds, though
[ .
this.may : vary from-shipment to shipment depending upon the moisture con-tent of the concentrate. Where larger. capacity. drums are used, the' number:
~' shipped per vehicle is?.less and where smaller capacity drubs are used..
- t the' number' shipped per vehicle is more.
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When3 packaged and shipped in. transport vehicles which are for the sole use of the consignor, the following requirements (49.CFR 173.392(c)) must be met:
q
- .l. ,Matefials_must be packaged in strong, tight packages so that i .there will be no leakage of material under conditions normally I, ' incident to transportation.
~ ~ '
- 2. packages'must not have any.significant removable surface con-tamination. This.means the average amount of radioactive contamination which can be removed by wiping the external surface of<the package with an absorbent material, as measured on the l - wiping mat'erial, does not exceed 10-10 curie per square centi-
, meter beta-g'ansna 'and 10"Il curie per square centimeter alpha.
- 3. External radiation levels must not exceed the following:
'a. 1,000 millirem.per hour at three feet from the external
~
surface-of the package (applies to closed transport vehicles ~ only);
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- b. 200 millirem per hour at any point on the external surface of the vehicle (applies to closed transport vehicles only);
! c. 10 millirem per hour at six feet from the external surface i of the vehicle;
- d. 2 millirem per hour in any normally occupied position in t the car or vehicle (does not apply to private motor carriers).
f
- 4. Shipments must be loaded by the consignor and unloaded by the consignee from the transport vehicle in which originally loaded.
, 5. There must be no loose material in the vehicle.
- 6. Shipment must be braced so as to prevent leakage or shift of l 7
lading under conditions normally incident to transportation, i
- 7. The outside of each exterior package must be stenciled or l otherwise marked " Radioactive-LSA."
t
- 8. ' Specific instructions for maintenance of exclusive use (sole use) ;
~
shipment controls must be provided by the shipper to the carrier, j Such instructions must be included with the shipping paper !
information.
Packaging requirements for LSA materials are less restrictive than for l other radioactive materials because. safety factors reside in the low concentration- of radioactivity uniformly distributed in the material .
The basic premise behind this concept is the high improbability of the intake of 10 mg or more by any one person as a consequence of a transpor-tation accident. Although such naterial (LSA) nay be associated with a maximum permissible body burden, meaning a dote to organs of 15 rem per year, equivalent to a snell radioactivity (5 x 10-9 Ci for U-238 in L.- . . . . , - -
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I soluble' form). the corresponding mass of material (17 mg for U-238) would be so large that the intake of such a mass of material' as a result of a i
j ~
transportation accident is highly unlikely. The validity of the LSA classi-1 i fication depends on the high improbability of the intake of 10 mg or more by any one person as a consequence of a transportation accident.
- In addition, each shipment of nuclear fuel material is classified according to a. transport group. Uranium concentrate is in transport group III which means that the quantity of curies allowable in one package (strong, tight package) cannot exceed three (approximately 10 tons) to be subject only i
- to the regulations of the DOT. Depending on the purity of the concentrate and the size package used, the typical package of uranium concentrate has approximately .053 to .096 curies and is well below the limit where NRC would be involved.
{ ,
Estimated Quantities Shipped - Based on a Radioactive Materials Shipments !
Survey made by NRC in 1975, it is estimated that 45,000 MT of uranium concentrate-is shipped each year by truck and rail. There are no specific federal regulatory requirements with regard to routing of hazardous materials s
other than truckers carrying hazardous goods are required by DOT regulations to avoid-congested places insofar as is practicable. The transport of yellowcake is in the Central-Western States.
l Accident Probabilities - The probability of occurrence of a transportation i accident,.such as the recent spill of yellowcake near Springfield, Colorado, ;
is: small, about one' accident per million vehicle miles, and decreases with b increasing severity of the accident to about one severe accident per 100
.of b; E
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J, mill' ion vehicle ~ miles.' ' Assuming 2000 shipments per year at an. average: .
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E[ distance. of.1000. miles each, _ two accidents .could be expected per year -
A: ;
- ' with a severeL accident ' occurring approximately onceLevery 50 years at. the ;
- a. r assumed shipping rate. When1both the probability of occurrence and the
- f. extent ofcthe consequences are taken into account, the risk-to people and-
. , -l p . 1-J l the environment due to the radiological effect'from transportation accidents
.is negligibly small.
j' Transportation Incidents - The. enclosed "A Review of Five Years Accident-l t
~ Experience in the U.S.A. Involving' Nuclear. Transportation," discusses the j
] i
' recorded accident experience:during 1971-1975.. In that period, there !
r
[. were 32,000 Hazardous. Material Accident Reports submitted to the DDT of I
which 144 were related to radioactive material. -In 36 cases,'there was q
-an indicationlof release of contents or excess radiation levels. Also
- j. enclosed is a copy of NUREG-0179 which discusses functional responsibilities of the different parties involved in dealing with transportation accidents.
A summary of the accident involving uranium concentrate near Springfield, Colorado is enclosed.
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SUBJECT:
SUMMARY
REPORT, SPILL OF URANIUM CONCENTRATE NEAR l SPRINGFIELD, COLORADO l t
~
At 0130 hours0.0015 days <br />0.0361 hours <br />2.149471e-4 weeks <br />4.9465e-5 months <br />, September 27, 1977, a commercial carrier, carrying 50 steel I J
. i drums of uranium' concentrate (42,000' pounds) overturned near Springfield,.
Colorado. Twenty-nine drums lost. their lids and lost various amounts of i
! ' concentrate. Concentrate spillage was estimated ~to have been 10,000 pounds en the ground and 5,000 pounds in the truck trailer. -
Police and Fire Department personnel covered the truck and contaminated areas with canvas and heavy plastic sheets. The carrier (Leeway Lines), ,
the licensee (Exxon) and State of Colorado Health authorities were notified ,
by' the. Sheriff's Department. Region IV (Dallas) and DOT were notified by ,
the licensee on September 27, 1977.
Exxon ' personnel arrived on September 27 and working 'with the State of Colorado and' local. authorities' devised a decontamination plan. The operation ,
is now essentially complete with only minor cleanup of equipment and soil remaining. For the decontamination of soil, Colorado has insisted upon background levels.
Wind conditions at the time of the accident were calm. Other than at the
-time of initial spillage, airborne uranium concentration at the perimeter of the restricted' area has.been minimal.
The persons involved in the accident have been monitored ~for contamination.
Once' the restricted area around the spill was established by Exxon on .
. September 27,1977, exposures were limited ~ to Exxon personnel performing 1
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recovery oil.the yellowcake and decontamination:of the area. Exxon employees wore full anticontamination gear with respirators. Entrances
,I andfexits to the restricted area were monitored. Traffic on the highway A was detoured around the site to preclude resuspending any uranium. ;
i
't
' The licensee is not required by his license to have a plan for responding to transportation' accidents or incidents. The use of D0T approved containers and acceptance by an interstate carrier places the responsibility on the carrier for safe delivery and response to accidents.
- for such incidents,. with the closest location being at the' Department of Energy Rocky Flats facility. Region .IV (Dallas) contacted the Agreement State of Colgrado on September 27,.1977; Colorado
! advised that the situation was being handled and no help was needed. ,
1 On September 28, 1977, the EPA representative in Denver contacted Region IV l
requesting information concerning acceptable levels following cleanup and
? acceptable measuring. techniques. On October 6, a Region IV inspector observed and reviewed the licensees recovery operations.
The uranium concentrate (commonly referred to.as yellowcake) is a concen- j i
tration of the uranium isotopes which occur naturally in the environment. j This material is classified as a low specific activity material since the i radioactivith per unit weight is low. The hazard to personnel is therefore relatively low since.significant' quantities must'be taken into the body before damage'.to tissue occurs. For this reason, the DOT packagir.g. require-l ments are less stringent for yellowcake than for many of the other radioactive E
isotopes.
- RAT' ' Radiological Assistance Team - These special- Department of Energy teams may be' called by licensees and States to provide early advice and
)
n assistance for. radiological incidents.
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m' MN M!NERALS' COMPANY, U.S.Ar -
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1 December' 12,1977 .
.. M.ia2*ld.Y mt. .
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- , . c ti Mr. Sheldon Meyers, Directori . . -
. Division of Fuel Cycle and Material Safety '
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- U. S. Nuclear Regulatory Commission Washington, D. C. 20S55 ,
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Dear- Mr....-......:
Meiers: V-
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+ Mr. Robert D. Siek'of 'the Colorado Department of Health wrote to- .
1 you on October 3 regarding' a" transportation accident which occurred l near Springfield, Colorado on September 27,1977. The accident- - - *
~
l resulted in spillage of natural uranium concentrate which was in ~
~
transit by commonLcarrier from Exxon's High1and' uranium mill. - Un .
fortunately, thel copy of Mr. Siek's letter which he sent to me was l improperly addressed and was delayed by-some two weeks in reachin.g.
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' We do not believe that Mr.L Siek's. account of the accident 'and the-
~
ensuing clean-up operation. properly describes either Exxon's response 1
~
Jto the. situation or the role which the Colorado Department of Health chose to play; The,ericlosed report' provides a concise and accurate account'of the entire occurrence. please feel free t.o contact me if
.you have(any questions concerning the accident or the clean-up. :
. Sincerely, -
k.hl 1 GDO:mr -
H, Enclosure . .
c: :Mr. Robert D. Sick .bc- Mr.D.B.Acb
~
Colorado Dspartm'e nt1of Health Mr. J. W. Brd "Mr.'A. J. Hazle Mr. R. T. Hos
? ' Colorado l Department of Health ' Mr. .J.J.B.'Sha D. Pa%
.Mr; A. W. Grella. 1 . .
.Mr.
Office of Hazardous Materials t0perations. Mr. R. B. Spi '
U.JS Department of Transportation .'i
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URANIUM CONCENTRATE SPILL - BACA COUMTL COLORADO At about 1:00 A.M. MDT on September 27 1977, a tractor-trailer operated by Lee Way Motor Freight, Inc., a connon car,rier, overturned after colliding with three horses on U.S. Highway 287 in a sparsely populated farming and ranching area about 14 miles north of the town of Springfield in southeastern Colorado. The trailer was loaded with 40,329 pounds of Exxon's natural uranium concentrate (yellowcake) contained in fifty 55-gallon steel drums and was en route from the Highland uranium mill to the Kerr-McGee conversion .
facility at Gore, Oklahoma. The concentrate had been packaged, loaded, and '
shipped in full compliance with applicable regulations of the Nuclear Regulatory Commission and the Department of Transportation.
As a result of the truck's overturning and subsequent sudden stop when it slid into an excavated sump for a drainage culver.t,. 32 of the 50 drums were thrown through,the top of the trailer near.the front. .These. drums came to rest on the shoulder of the highway. Drum lids, which were secured to the drums by bolted steel ring closures, came off 17 of the 32 drums which left the trailer. l Lids also came off 12 of the 18 drums which remained in the trailer.
A total of about 12,000 pounds of concentrate spilled from the opened drums.
About 5,000 pounds of this spilled material sas contained in the overturned trailer. The remaining 7,000 pounds was spilled on the ground within an area of l 3,000 to 4,000 square feet. i The Highland Mine Manager was notified of the accident by a telephone call from the Baca County Sheriff.'s Office at about 2:00 A.M. MDT. The written-detailed emergency instructions' prepared by Exxon which accompany each bill of lading for our concentrate shipments had been found, and the mine had been called l in accordance with those instructions. At that time, efforts of law enforcement personnel and others were being directed primarily at extricating the driver, who was pinned in the tractor cab. Because of the concentration on the rescue of ;
the driver and the difficulty of assessment of the magnitude of the spill in the l darkness, the initial estimate relayed from the scene was not accurate. The '
estimate was that 6 to 12 of the drums had lost lids and part of their contents.
Highland responded quickly and appropriately to the notification. The Sheriff's office was requested to see that the truck and spilled concentrate were covered by tarpaulins or heavy plastic sheeting as soon as possible to prevent spreading of the concentrate by wind. Highland's Environmental Coordinator and one technician left Casper by commercial airline at 7:50 A.M. MDT, taking with them several large boxes of emergency equipment which included protective clothing, respiratot s, radiation monitoring and air sampling equipment. This equipment was appropriate and adequate for handling and monitoring the situation as reported. Prior. to leaving, the Environmental Coordinator had been advised by the Baca County Sheriff's Department that the spill had been completely covered by heavy plastic sheeting, and that there was no near-term risk of airborne migration of the-concentrate. Shortly after the departure of the Environmental Ceardinator by plane, an experienced mill shi,ft supervisor and an experienced operating technician left the mill in' a truck carrying 20 drums and additional equipment for use in recovering and repackaging spilled concentrate.
Min;rals Headqu:rters was advised of th1 accident by the Highland Mino Manng r at about 8:30 A.M. MDT. A sccurity ag:nt was dispatched to the sceno from Midland, Texas. Headquarters itedical was. notified and an Industrial Hygienist was sent to assist the Highland personnel.
~
Because the accident occurred while the concentrate was in interstate transport, notification of the Office of Hazardous Materials Operations, Depart-ment of Transpoi-tation, by the carrier was requirea' Exxon notified the carrier of its reporting obligation, then followed up with direct telephoned notification to the DOT. Exxon also telephoned the Office of Inspection and Enforcement, Region IV, U.S. Nuclear Regulatory Commission, and the Colorado Department of Health to notify those agencies of the accident and to advise them of the steps being taken by Exxon to mitigate the effects of.the spill. The Nuclear Regulatory Commission advised that since Colorado is an " Agreement State", it has the respon-sibility for replating source material within its borders, and that Exxon should work with the Culorado Department of Health in cleaning'up the spill. They requested that they be kept advised of developments, and advised that they would cottmunicate also with the Colorado Health Department.
I' < 'Soon after notification by' Exxon, the Colorado Department of HesitE sent two
~ hzalth physicists to the scene by automobile from Denver.
_ ,, [- , ,
. j.j The Highland Environmental Coordinator arrived at the scene at about 3:30 P.M.
MDT. He quickly determined that the spill was considerably more extensive than had been reported initially by the Baca County authorities. He also detarmined-that an excellent job of covering the truck and the spilled material had been done by the Sheri~" s Department. Because there was no significant remaining risk of spreading, there was time for proper planning for the clean-up and recovery.
i It was our expectation .that Exxon would work. closely with the Colorado Depart--
ment of Health in the clean-up operations. However, the two health physicists from -
the Heal *h Department at the scene declined to participate in detailed planning for-the clean-up. Instead, they indicated that the clean-up.was Exxon's responsibility and that the Health Department would observe the operation, set standards for final decontamination, and determine the adequacy of the clean up. .
Exxon personnel then proceeded to make detailed plans with full cooperation and assistance from the other state and county agencies - the State patrol, the State Highway Department, and the Sheriff's Department. The willing assistance of those agencies was greatly appreciated by our people. '
. s The plan which was developed included the use of a front-end ' loader to pick up the spilled material along with a thin layer of topsoil, transferring it to .
new drums. Water sprays were to be used to control dust, and an air sampling program was designed to evaluate airborne concentrations. All personnel were to be equipped with appropriate respiratory protectiw equipment and clothing which was already on site. .
. On the morning of September 28 the representatives of the Colorado Department of Health returned to the scene and set out detailed requirements they had decided "
upon in' dependently. They insisted that the clean-up be accomplished by hand shoveling with only a limited area uncovered at any one time to minimize the potential for airborne centamination of the surrounding area. They further required Exxon to conduct a thorough radiation survey outside the immediate spill e
-2.-
area to establish background radiation levels, which would then b2 set as .the Tiinit'for acceptable clean-up in the spill area. They laid out other requirements for air sampling, contamination surveys, respiratory protection, and bioassays.
They reiterated that the Colorado Department of Health would not assist in the clean-up, and that. their function was to set standards for Exxon to meet.
After conferring by telephone with Minerals Headquarters, the Environmental-Coordinator agreed to conduct the clean-up' operation in accordance with the direc-tives of' the Colorado Healf.h Department representatives. Those representatives then departed on September 28 for their headquarters in Denver. Four additional mill operating technicians were then sent by Highland via commercial airline to assist in the clean-up. -
On the following morning, September 29, Minerals Headquarters discussed the situation by telephone with several Colorado Health Department officials in .
D:nver.
Later in 'the day, Minerals Headquarters requested assistance from Exxon Nuclear Company. Exxon Nuclear sent their Consulting Health Physicist and a Health' Physics Technician from Richland, Washington to assist at the scene. Both
. arrived via chaitered aircraft'at Exxon's clean-up headquarters in Lamar late- 1 on' September 29, bringing with them additional respiratory protection equipment .
r and additional radiation survey equipment.
[^
The Regulatory Affairs Manager, Minerals Department, departed from Houston on the afternoon of September 29 to coordinate the clean-up operation and act as liaison with the Colorado Health Department and other interested government' agencies. ,
Clean-up operations began on September '30. In order to meet Health Department i 7equirements, ground decontamination was accomplished on about 100 square feet at a time under a specially constructed " greenhouse" while the remainder of the spill area' remained covered by plastic sheeting. Progress was very slow for several days..
Vacuum cleaning devices and greenhouse ventiTation equipment recommended by Exxon Nuclear arrived on October 4; employment of these devices increased the rate of -
progress materially. ,
On October 5, however, the Colorado Health Department ordered Exxon to abandon the greenhouse, uncover larger areas of ground and work in the open to accelerate the operation. The Health Department had come around to ordering Exxon to conduct the operation in a fashion similar to that planned originally by Er an Clean-up then proceeded in an orderly and rapid fashion. The truck was cleaned, righted and decontaminated on October 8, and the entire area was released by the H:alth Department.on October 10 after their final survey.
Damaged drums were double-bagged in heavy plastic bags prior to shipment to Highland i.n a special container designed for transport of high-level waste which was rented from Nuclear Engineering Company. Material which was repackaged in new drums was shipped to Highland in conventional common carrier tractor-trailer rigs assigned tc Exxon for exclusive use.
~
All eciuipment used in the operation was surveyed and decontaminated to meet
" all applicable standards before shipment to Highland or release for unrestricted
.use.
Final topsoil' replacement and any necessary replanting of grass in the ;
d: contaminated area will be completed by the Colorado Highway Department
. + - +
'. <-*- 1
- 1. . Jt should be noted that while natural uranium. concentrate is classified by tha ' Department of Transportation as a hazardous material, it is unlikely that the health of any members of the public - even those most intimately involved -
would be adversely affected by exposure to yellowcake spilled in a transportation accident.- l l
Radiation doses to the body from external exposure to yellowcake for hours I or days are insignificant. If yellowcake is ingested, the principal concern is j chemical toxicity rather than radiotoxicity; yet the chemical. toxicity of uranium 1 is lower than that of lead,' cadmium or mercury. Ingested yellowcake is rapidly eliminated from the body. While chronic yellowcake inhalation can cause uranium to build up to toxic levels in kidney tissue, there is no recorded occurrence of. detectable adverse health effects resulting from a single acute ingestion.
Urine specimens for uranium bicassay were obtained by Exxon from some 25 persons who were known to have been in the vicinity of the spill before it was !
covered. Results of the bioassays show that physically damaging uranium inges- l tion did not occur. Results of his bioassay are being reported by ---- letter to l
g each individual.:
' - ~
_In retrospect, the following ~ conclusions can be' drawn: ~';
- ' l l
1 2 -
- 1. Initial securing of the spilled concentrate was prompt and -
effective. ,
- 2. Exxon responded in a timely and appropriate manner to the accident, even though Exxon did not have the primary obligation for response.
- 3. Effective clean-up was delayed by the initial clean-up and recovery techniques insisted upon by the Colorado Department of Health.
Despite the delay, physical security.of the yellowcake was maintained and public health was .not endangered.
- 4. Other state and local agencies involved were most cooperative and fully supportive of Exxon's efforts.
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GDO:mr 12-6-77' .
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[ ERON MINERALS COMPANY, U.S.A. M
, ecsr omcr sex vaa rouston.rexAs nooi Sh #
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l Etiroa/hf E wacen March 15, 1978 Mr. Albert J. Hazle, Director Ridiation and Hazardous Wastes Control Colorado Department of Health ,
4210 East lith Avenue -
-Denver, Colorado 80220
Dear Mr. Hazle:
~
As agreed with Mr. Charles Mattson last October, we have prepared the 1 enclosed technical report on the clean-up of the uranium concentrate !
spill which resulted from the truck accident near Springfield, Colorado on September 27, 1977. The report presents the results of the enviror.- ,
mental and personnel monitoring programs which were conducted at the l accident site. It also contains the results of the bioassays which ,
were performed to assess the-intake of uranium by individuals who were l involved in the rescue of the injured truck driver and in the subsequent l yellowcake containment and clean-up operations.
1 We believe that this report provides useful documentation of the conditions
_which prevailed during the clean-up, the low levels of exposure of person-j 1 nel involved, and the completeness ~ of the removal of the spilled concentrate i J from the environment. d
- Sincerely, .
hLd/ *b GDO:mr Enclosure yw. '
. -c: Mr. Charles Mattson (Colorado Department of Haalth) f^ Mr. L. C. ' Rouse (Nuclear Regulatory Commission-Washington)
Mr. E. Morris Howard (Nuclear Regulatory Commission-Arlington)
Mr. R. Jerrel Everett (Nuclear Regulatory Cummission-Arlington)
Mr. A. W. Grella (Office of Hazardous Materials Operations, U. S. Department of Transportation)
(allw/ enclosure)
W2.
bc: 3 r. Warr c o t -Exxon Nuclear Company M 'r "
- Mr. D. B. Achttien
.M Mr. R. B. Spivey
]g% on.4r.c MC: or. son c> <uen cowen. u s 4. 4 emscu Mr. J. B.ee men ceuca4mu Shannon
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^10 ' EXXON MINERALS COMPANY,.U.S.A..
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TECHNICAL REPORT-
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V CLEAN-UP OF NATURAL URANIUM CONCENTRATE
.me hr SPILLED IN A TRANSPORTATION. ACCIDENT l i
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NEAR SPRINGFIELD, COLORADO ON. SEPTEMBER. 27, 1977
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. .1 TABLE OF CONTENT 3 I 9-
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Page l.
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' 1
.* -Introduction . . . ,
. . . . . . .. . .. . . . . . . 1 J
. Clean-up Methods and' Chronology '
.. .. . .. . . . . 5 -!
is '~
Health,: Physics-and Environmental Aspects'. . .. . . 10 MM!g :
Conclusions
"~OE > m . .C . . . . . .. . . . . . . . . .. . . . . 24 -
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Appendix . .
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_ INTRODUCTION
, 44
- h. E D.$ At.'about'.'1:00'A;M. MDT on September 27, 197.7, a t
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(. tractor-trailer operated by Lee Way Motor Freight, Inc.,- "
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, a common. carrier, overturned after. colliding with three
. f t
' horsesL on U.S. ' Highway,287. in a sparsely populated
, ,a ifarming and' ranching areaLabout~14 miles north of the l '
c' i _
4 town. of Springfield'in southeastern Colorado. The thi;.,. -
trailer.'.waseloaded with 40,329 pounds.of Exxon's natural'
- n. Q. .
1 j,4 -uranium concentrate.(yellowcake) contained in fifty . *j
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55-gallon' steel drums:and-was,en route'from the Highland gA :
- uranium mill.to the Kerr-McGee~ conversion facility at 9
%q%. Gore,; Oklahoma. .The concentrate had been packaged, i
loaded, . and shippe'd' in full compliance with applicable p.
.v.
regulations of the Nuclear Regulatory Commission and
. re the Department of Transportation.
.n. . .
f%l As a' result of the truck's overturning and subsequent W.s .
- 7 : sudden stop'when it slid into an excavated sump for a
%lny' 2;?:
f- drainage culvert, 32 of the 50 drums were thrown through
@, .,.. . < ., . .the top of the trailer near the front. These drums came
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'jtje to'restLon the shoulder of the highway. Drum lids, which
~
30 were secured to the drums by bolted steel ring closures, g.. ;
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came'.off 17 of..the 32 drums which left the trailer.
hi&
MM Lids
- gQV also came off.12 of theH18 drums which remained in the W4!' ' trailer.
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My ? A total of:ab'out 12,000 pounds of concentrate spilled an g from'the opened: drums.. Ab'ut o 5,000 pounds of this spilled
-.1 3' ; material:was, contained in the' overturned trailer. The h -
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rcm31ning 7,000 pounds was spilled on the ground within
./]
.i j an area of 3,000 to 4,000 square feet.
.The Highland Mine Manager was notified of the accident 2 T.;;[j by a telephone call from the Baca County Sheriff's Office
~
at about 2:00 A.M. MDT. The written detailed emergency instructions prepared by Exxon which accompany each bill
' ' i of lading for our concentrate shipments had been found, and 4,
the mine had been called in accordance with those instruc-f( ~~
tions. At that time, efforts of law enforcement personnel .
[ and others were being directed primarily at extricating the
- driver, who was pinned in the tractor cab. Because of the
',$D jv, concentra' ion on the rescue of the driver and the difficulty
,. , .of assessment of the magnitude of the spill in the darkness, th'e initial estimate relayed from the scene was not accurate.
\)
~
l The estimate was that 6 to 12 of the drums had lost lids and i part of their contents. I
,- Highland responded quickly and appropriately to the Cs notification. The Sheriff's Office was requested to see that lf
~:4L .(
the truck and spilled concentrate were covered by tarpaulins
- l -- or heavy plastic sheeting as soon as possible to prevent 77:
- .. ~
spreading of the concentrate by wind. Highland's Environ-
~3 .
! .M. . mental Coordinator and one technician left Casper by commer-a.s
'J 2;.t 3
cial airline at 7:50 A.M. MDT, taking with them several large n.
jp'f;;
p::a boxes of emergency equipment which included protective
' a-j_
clothing, respirators, radiation monitoring and air sampling f, . equipment. This equipment was appropriate and adequate for
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handling and. monitoring the situation as reported. Prior to
'Iidif - leaving, the Environmental Coordinator had been advised by 2%
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tho Baca County Sheriff's Department that the spill had
) been co.mpletely covered by heavy plastic sheeting, and that there was no near-term risk of airborne migration of the 4 concentrate. Shortly after the departure of the Environ- I mental Coordinator by plane, an experienced mill shift supervisor and an experienced operating technician left the j l
mill in a truck carrying 20 drums and additional equipment
_ for use in recovering and repackaging spilled concentrate.
g Minerals Headquarters was ad' vised of the accident by .
the Highland Mine Manager at about 8:30 A.M. MDT. A
' security agent was dispatched to the scene.from Midland, '
Texas.' Headquarters Medical was notified and an Industrial
. Hygienist was sent to assist the Highland personnel.
(3) Because the accident occurred while the concentrate was in interstate transport, notification of the Office of Hazardous Materials Operations, Department of Transportation, i
by the carrier was required. Exxon notified the carrier of j its reporting obligation, then followed up with direct i
, telephoned-notification to the DOT. Exxon also telephoned ;
the Office of Inspection and Enforcement, Region IV, U.S.
I Nuclear Regulatory Commission, and the Colorado Department e j
of Health to notify those agencies of the accident and to L advise them of the steps being taken by Exxon to mitigate
?s!' ,
\
T:!ig. the. effects of the spill. The Nuclear Regulatory Commission
- 1. J advised that since Colorado is an " Agreement State", it has the responsibility for regulating source material within its
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~ CLEAN-tip METHdDS' AND CHRONOLOGY s
l .
Detailed planning: of the clean-up . operation began on j theLevening of the accident,. September'27.
~
, 2 ,, The. planning session was. held.in the Baca_ County Sheriff's office in Springfield. Full-cooperation and assistance of the-
'6 ' State Patrol, State' Highway Department, Sheriff's Depart-
-ment, Springfield Police Department, and local merchants 1
] , during the planning ' session made'it possible- for clean-up ,
i operations. to cstart the next morning, September 28. On that morning,.however, Colorado Department of Health t .c
.i
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representatives informed Exxon of their clean-up requirements. '
The nature of'the requirements was such that Exxon.could not immediately proceed with the clean-up and comply with Health
. (h Department stipulations. Exxon's plans had included the use of a front-end' loader to pick up the spilled material along
~with a thin layer of topsoil, transferring it to new drums.
7 ,. If windy conditions. were encountered, clean-up would have
' t E; '
proceeded with hand' shovels instead of the loader. Water -
] sprays were to'be'used to control dust, and an air sampling
- program had;been designed to evaluate airborne concentrations.
'All' personnel were_to be equipped with. appropriate respiratory
,, f L protective equipment and clothing which was already on site.
of:Haalth representativesTon September 28, four additional.
mill; operating. technicians were flown to Lamar, arriving'on n, ! September 29. They joine'd two other mill employees (one mill
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, ; : oporating technician and one mill. shif t ' supervisor)! who ~ l
} had arrived. late on September 27.with a truckload of clean-up materials' . - Also on Septembbr 29 a' health
' b physicist ~and a' health physics technician from Exxon
! Nuclear-Company arrived in Lamar, bringing with them -
- additional; respiratory protection' equipment and additional radiation.s.urvey equipment. On September 30, Exxon's-
~
. Regulatory Affairs Manager arrived to serve as liaison
-with the Colorado Health D'epartment and other interested
. government: agencies.
Clean-up operations started on Se'ptember 30. Prior
, a..
to starting the clean-up a portable toilet was brought to the site, and a 16x 32' tent was erected to serve as a changehouse,-shower facility,_and storage area. A " green- .
{( ) house" was constructed of lumber, plywood and plastic sheeting. The purpose of the greenhouse was to minimize the potential for airborne dispersion of the concentrate as required'by the' Department of Health. C' lean-up was to
.L ,be conducted by. hand-shoveling within the greenhouse which covered an area of about 100 square feet. A radiation survey of.the' surrounding area was conducted to establish background radiation levels, which would then be set as the limit for1 acceptable clean-up in the spill area. Air sampling, y
[.:3 ;;v- . contamination surveys, respiratory protection, and bioassay programs were . set up. to comply with Health ' Department stipula-
-tions.
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.was very slow 1due to the difficulty of cutting through W -
grass:andLweeds.with shov.els to pick. .up-the concentrate, c
the confining nature 1of the. greenhouse work" area, heat in
. theTgreenhouse~ causing rapid . fatiguing of . clean-up person-
-nel, ' and Emuddy conditions 1 created by the use of water to reduce airborne dust inside:the greenhouse. Two trailers
- were rented to. serve as wind breaks- for .the work area. -
~
1Due to the location of the spill in a low area next to the '
thighway,Etwo earthen dikes and a diversion ditch were y constructed to prevent'possible spreading of the' concentrate
. : . .. byLrainfall and'run-off. Also, a road block and detour was
' ' ~ ~
set up.to eliminate traffic during work hours. During these threeLday's a total of 11 out of 50 drums on the shipment
- were recovered.- '
In order to accelerate the clean-up, vacuum cleaning
' devices and' greenhouse ventilation equipment were ordered October 3 and arrived October 4.
October 3 was spent in e . ,
7; detailed planning of future operations and as a day off for
.the fatigued clean-up crew. October 4 a snow fence lined with plastic sheeting was constructed around the spill site
' ~
'to reduce wind velocity in . the work area.
Use of'the vacuum
- 37. " : cleaners and ventil'ation eqalpment was initiated late on vs. .
awc. October 14Lwithipositive results. -
Qx-
.On October 5 the air was' calm-and a light mist was falling.
These: conditions permitted work in the open. Clean-up then proceeded in an orderly and rapid fasion using both hand-lf ' Lahoveling;and:the'vacuumLcleaners.- By,the end of the day the-
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Drcmaindariofi the 32" drums outsido-tho trailer had been recovered. , Damaged drums were double-bagged in. heavy
. 'plasticbagsLpriorto. shipment-to'Hikhlandinaspecial -
containerfdesigned_for~ transport of-high-level waste which wasicarried on a flat-bed. tractor-trailer., Shipments in this container. were classified as bulk shipments under DOT
. regulations. . Material .which .was repackaged ingnew drums was shipped to Highland.in conventional common carrier ~
tractor-trailer rigs assigned.to Exxon for exclusive use.
. Work on October 6 'and 7 was . concentrated ' on c1'eaning upithe : damaged trailer- and removing the 18 drums contained inside. 'The vacuum cleaners worked especially well'for this
~ purpose. .By'the end of the day October 7 all of t.he 50 drums on the shipment had been recovered and moved to'the f storage area.
- On. October 8 final decontamination of the trailer was. begun, using scrub brushes, water with detergent and
~
, a' water rinse.. By mid-afternoon the truck was righted.
Decontamination of the tractor and trailer was completed late infthe afternoon and it was hauled from the site.
-Final clean up of the ground in the spill area continued
'on October- .9 iand 10. The spill' area was bladed on October 10
.auni radiation surveys' located' a few remaining concentrations
-which were promptlyLcleaned up with shovels. All' equipment
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4 used in the: operation-was surveyed and decontaminated. to meet
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previously agreed upon standards before shipment to Exxon',s'
. Highland Uranium; Operation or release for unrestricted use.
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- By mid-afternoon'on October 10 the Health Department..
. conducted ~ a final radiation' stirvey and' the entire area wasJreleased'for unrestricted use. ' Final topsoil replace-i ment and reseeding in- the cleaned area was completed by the Colorado Department of Highways. '
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LHEALTH' PHYSICS.AND ENVIRONMENTALLASpECTS' r
- - 7' .
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LA ssessment of Accidental Radiation Exposures
, .The truckL upset and~ resultant spill probably caused.
suspension of' uranium' concentrate in thel air for a short '
period of timeLin'theEimmediate area'of the apill. The truck 1 driver,.h'is relief (driver, and.anyonelwho rendered
' assistance immediately after.the accident'until the sus- .
pended material settled would have been. exposed to this . ,y airbo:ne uranium. . An upper limit t'o the . airborne' yellow- h cake concentration that.could have existed during.this
-l , period is the: concentration of the dust that could be suspended in air. When vigorously agitated, dust burdens i of.up to about five grams per cubic meter a,re obtained.
- Due to . settling, 'however, within five minutes most of the d'ust would no longer be airborne. Breathing air containing
' five grams of uranium per cubic meter-for five minutes
..,;; would probably. result in a deposition in the lungs of
' ~
A about'O.045 sC1. Since the' material is eliminated from m ,-
v -the. body with a half-life of 30 days'or less, the body burden averaged over a year's time would be about 0.005 '
'hCi. The-International Committee on Radiation Protection 1
_ ,, .has recommended that the continuous, steady-state body y d .: -burden,of uranium be limited to less than 0.009.pC1. This d.
value, of course, was established to provide at least an
, !orderiof magnitude-margin to perceivable health effects.
i .Hence, it.is unlikely that anyone at the accident scene
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, 'r;ould' ba found .to bs: injured by inhalation of yellowcaka.
(j"'1qr This conclusion is ' borne out by the bioassay results,
.where'the rescue workers are found not to have inh'aled 4
. 'significant quantities of yellowcake. Those arriving more than one-half hour after the initial impact, the ambulance crew and the hospital emergency staff, were
" exposed to much lower concentrations of airborne uranium. I The Sheriff's Departme.nt. personnel and the State Police
- j
'\
who-were. involved.in covering the yellowcake were exposed ,i 1
tcr low levels of airborne uranium. '
I
'^
Bioassay Program Urine. specimens for uranium bionssay were obtained from 27 persons who were known to have been in the near (O vicinity of the spill, including the law enforcement and rescue personnel present during the time pe'riod following 'I the accident. Additionally, specimens were obtained from
~
'~
17' Exxon personnel who"were present during the clean-up-t n operations. Results of the bioassays are tabulated in Exhibit 1.and.show that physically' damaging uranium ingestion -
did not occur. Exhibit 2 summarizes the bioassay results .
and indicates that only 7% of all specimens submitted were i
~ .
above the detection level of 10.ug/1. It should be noted x,:.
gc..y . that bioassays for the.two truck drivers were arranged by the Colorado Department of Health and the medical personnel i atLthe1 Southeastern Colorado Hospital in Springfield, where 1
i the drivers were taken for treatment of their injuries and-A-
. M"pM ,.
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\
for obcarvation.- Wo havo bnen advised by the Colorado Department of Health that uranium was not detected in urine specimens from the drivers. ~
The highest uranium concentration observed, 18.1 sug/1, was found in the urine from one of the'rescUd- *
(personnel') This level is below the typical, nuclear
. ~ industry action level as shown in Exhibit 2. Uranium concentrations in urine of up to 50 ng/ liter are considered
, to be tolerated by the body with no effects. If 50sug/ liter is exceeded, then resampling is done; if the concentration .
exceeds 200sug/ liter, the person is restricted from working with uranium until the concentration in the urine drops below 50,ug/11ter. The chemical toxicity is the limiting o consideration with natural uranium. This toxicity is fJ compared to other heavy metals in Table 1.
TABLE 1
~
Element Threshhold Limit "d . ~. Uranium 0.2 mg/ meter 3 of air -
, , Lead 0.15 mg/ meter 3 of air
. Mercury 0.05 mg/ meter 3 of air Cadmium 0.05 mg/ meter 3 of air 7>
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>, n If,the concentrations do not exceed.these threshhold limits in a work _ location, personnel are permitted to work
.in the location without restriction for a 40-hour work week.
rs t i,
) - This would result in an. equilibrium concentration of '
s gr%::
,?
7f
[ger.y0k ~12-J N f'.L
3 milliontha of a gram of uranium por gram of kidney.
]; . The health effect of uranium is the result of a gradual buildup of toxic levels of uranium in tissue of the k
kidney. There is no recorded occurrence where a single acute exposure of a human to uranium has caused a detect-able health effect resulting from its chemical toxicity.
el The members of- the public involved in the rescue operation will not experience any phy sical effect as a result of their exposure to uranium.
In the letter notifying each person of the result of his urinalysis, Exxon offered to provide in-vivo chest l
, - counting for any persons who wanted this additional evaluation. As a result of this offer, eighteen chest .
e s
counts were performed on December 20, 19.77 in Lamar, Colo-(~' rado by Helgeson Nuclear Services, Inc. Springfield firemen, State patrol officers, and Highway Department. personnel who participated in the rescue of the truck driver or who
, were pres,ent during the clean-up operation were included in e the group. No detectable uranium lung burden.was found in l 1
. any person.
Radiological Safety program '
l The Certified Health physicist and Senior Health Physicist 1
Technician from Exxon Nuclear Company conducted the radiological l
'~
safety programs. They set up a restricted or controlled area l
which included all of the area in which yellowcake could be jgg detected by surveys. This controlled area was marked off t ..
, _jf using yellow and magenta rope, .and appropriate signs indicating xv. #
4 .
EM yroscace'of7 radioactive material were' hung from the l rcpo' The health physics personnel then conducted a
<- train'ing session for~all Exxon employees to be~ involved
!(V(^ .
T- in the' clean-up' operation. - -
)
Exhibit 3 summarizes the items covered in the l i
-training session.
'Throughout the clean-up. operation frequent radiation
, s urveys were made to insure that containment was maintained.
, In making:the contamination surveys the following guidelines I
~
were used: ,
l o
A "less than" value was used whenever contamination
- above background was not detected. !
o .\
l A value of 25 c/m was used as a minimum detection
. level when the unshielded probe was used. This-requires a very slow, methodical survey.
(}
f o A value of 100 c/m was used as a minimum detection level when a shielded probe was used. This probe generally was used.for large survey areas.
Radiation surveys made during the clean-up operation are documented in the Appendix.
Radiation doses to the skin and whole body from external
~
exposure to yellowcake were measured by thermoluminescent
' dosimeter badges (TLD's) worn by'the personnel who were directly-
- ,' . . involved in the clean-up. The maximum dose to any individual was MJ .less than 2% oi the quarterly limit 1 for the skin and less than 1,
} 45 of the quarterlyflimit l for the whole body.
' Environmental Sampling m
s,) . ,
' An air sampling program was. established to evaluate f.v. f" f,< n. - .
~ personnel exposures.to airborne yellowcake dust and to assess
- Jik.,-:C% @ ? ~
T 21'OCFR20.101(a)!
1 '
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-potontialidisparaion_of the concentrate. Threo types of
+:
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air l samples.were' collected: 'l) enclosed area samples I . 'ltaken faithe greenhouse and-the trailer';.2)..open area
~
samplesitaken inLthe1 work area; and.3);perimeterfsamples '
taken'close to the. boundary of the controlled area. The .
first two types'of samples'were.used to evaluate personnel exposures,Jwhile;the; perimeter samples were used to 1 evaluate l dispersion beyond the controlled' area. . Samples ,
, - .r 7, } used-.to-evaluate personnel exposures wereftaken with the . .
Jair'. sampler at breathing' elevation. Exhibit 4 summarizes
- the results of"the air samp1.ing program. -High concentra- '
c .tions.ofiairborne yellowcake dust were occasionally present.
w .-
)
, . in the" enclosed areas. Open area concentrations were {
relatively. low, while perimeter' concentrations were usually
.h h 'below maximum permissible concentrations (annual average) for unrestricted areas as set forth in Appendix B.of 10CFR20.
Air-sample data were used to. evaluate. exposures to u--
clean-up personnel. . In.the calculation of the exposures, 3.,
$ conservative protection-factors were assumed.for the 3,3 .
respirators. A' factor,of 10 was used for the half-face mask,: while a factor- of. 50 was used for the full-face mask.
' Individual cumulative exposurea during the clean-up opera-
.-tion;werecless than 20% of the weekly maximum permissible.
2.- .. occupational.l exposures to soluble'_ uranium compounds, as set
.f:r .. .. . .. .
/- ..
forth.in:10:CFR 20.103 and in Appendix B:of 10 CFR 20.
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bin ,
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In addition to environm:;ntal air sampling, soil and vegetation samples were taken in the spill area.
Results, which are shown in the Appendix, show that the
. q clean-up effectively.removad the spilled concentrate from the environment. The very effective job of covering .
the spill by the Baca County Sheriff's Department allowed a
time for effective clean-up measures to be established without airborne dispersion of the material.
Decontamination Program The decontamination program employed radiation surveys ;
of ground, personnel, and all equipment or supplies that could have been contaminated. Each person leaving the l
controlled area was surveyed. This included counting of h- nasal smears, facial areas, and the inside of the face mask.'
Showers were required as necessary at the site to insure decontamination of personnel. All personnel were surveyed to insure that they were darrying no detectable uranium offsite. All equipment used in the operation was surveyed and decontaminated to meet the standards set out below before shipment to Highland or release for unrestricted use.
All automobiles and motel rooms used by the clean-up person-nel were also surveyed and found to be uncontaminated.
Prior to release of the tractor-trailer from the restricted area, a complete contamination survey was conducted.
Before the tractor-trailer was hauled from the site, the
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" rolot:a?limite below:were achieved: .
2 Fixed? Alpha 5000 d/m/100 cm Smearable Alpha' 2 1000 d/m/100'em 4
r .
~ Beta-Gamma 0.2 mR/ hour at 1 cm These limits were also applicableLto a11'other surveyed
. equipment.
The: final site telease survey was conducted by a
.. health physicist f;om'the' Colorado Department of-Health,
~
Lusing a' sensitive gamma survey meter. The baseline survey conducted prior to the start of clean-up showed background gamma ' levels '.to be 'in' the 14-21 nR/ hour range. The final survey 1showed that all ground within the restricted area
-had been cleaned.up to.less than 30.uR/ hour gamma. On the afternoonLof October 10 the entire spill area was x(] .
seleased by.the-Health Department representative for unrestricted use.
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my[4) ' i , ]6, i EXilIDIT 1 . . - BIOASSAY (URINALYSIS) RESULTS . Individual - Date agU/1 Date igU/1 Date mgU/1 Date a gU / -
~
M::mber of Public #1 9/29/77 <10 Mr.mbar of Public #2 -9/29/77 10.2 M mber of Public .#3 9/29/77 <10 M:mber of Public #4 9/29/77 16.4 Member of Public #5 .10/4/77 <10 10/11/77 <10 Member of Public #G 9/29/77 <10 Member of Public #7 10/4/77 <10 Member of Public #8 9/29/77 <10 Member of Public #9 10/4/77 <10 Member of Public #10 10/4/77 <10 Member of Public #11 10/4/77 <10 Member of Public #12 10/4/77 18.1 Member of Public #13 10/4/77 <10 Member of Public #14 10/4/77 <10
- Member of Public #15 9/29/77 <10 Member of Public #16 10/4/77 <10 Member of Public #17 9/29/77 <10 '
Member of Public #18 9/29/77
<10 Member of Public #19 10/4/77 <10 Member of Public #20 10/4/77 <10 Member of Public #21 9/29/77 <10 Member of Public #22 9/29/77 <10 .
Member of Public #23 9/29/77 <10 Member of Public #24 9/29/77 <10 Member of Public #25 10/11/77 <10 - Member of Public #26 10/10/77 <10 - - Member of Public #27. 10/4/77 . <10 Exxon Employee #1 10/0/77 <10 10/7/77 <10
<10 10/8/77 <10 10/9/77 <1C 10/11/77 Exxon Employee #2 10/10/77 <10, Exxon Employeo #3 10/5/77- '<10 10/7/77 <10 <10*
Exxon Employee #4
<10 10/0/77
' 10/1/77 10/2/77 <10 10/4/77 <10 10/5/77 <lci 10/6/77 <10 10/8/77 <10 10/9/77 <10 10/10/77 sl CE
M y fv W ' 3.. . hj)7 u .s 3[ -. o
~
- EXHIBIT 1 CONTINUED -
qPc ' . , s- . Individual Date sugU/1
~
Date ,ugU/1 - Date- ,ugU/T Date .cgU/ Exxnn Employee #5 9/30/77 <10 10/1/77 <10 10/2/77 <10- <10
- 10/3/77 10/4/77 <10 10/0/77 <10 10/7/77 <10
~
Exxon-Employee #6 9/30/77 <10 10/1/77 .<10 10/2/77 <10
<10 10/3/77 < 1(_.
10/5/77 10/G/77 <10 10/7/77 <10 10/8/77 < 14 . ! 10/9/77 <10 10/10/77 <10 Exxon Employec_#7 9/30/77 <10 10/1/77 <10 10/2/77 <10 10/5/77 <10 10/6/77 <10 10/7/77 <10 10/8/77 <10 10/9/77. <10 10/11/77 <10 ' Exxon Employee #8 10/6/77. <10 10/7/77 <10 Exxon Employee #9 9/30/77 <10 10/1/77 <10 10/2/77 <10 10/3/77. <10 10/4/77 <10 10/5/77 -<10 10/6/77 <10 10/7/77. <1( . 10/9/77 <10 10/10/77 <10 Exxon Employee #10 9/30/77 <10 10/1/77 14.3 10/2/77 14.9 10/3/77 <lf . 10/4/77 <10 10/0/77 <10 ,10/7/77 <10 10/8/77 10.:. hExxon Employee #11 - 10/9/77 <10 10/10/77 <10 9/30/77 <10 Exxon Employee #12 10/1/77 <10 10/2/77 <10 10/3/77 <10 10/4/77 <l( L
'10/5/77 <10 10/0/77 <10 Exxon Employee #13 10/1/77 <10 10/2/77 <10 , 10/5/77 10/4/77 <10 <lt 10/6/77 <10 10/10/77 <10 10/11/77 <10 Exxon Employee #14 9/30/77 <10 10/1/77 <10 <10 10/2/77 10/5/77 < 1( -
10/6/77 <10 10/8/77 <10 Exxon Employee #15 10/10/77 <10
-Exxon Employee #16 10/6/77 <10 10/7/77 <10 10/9/77 <10 Exxon Employee #17 10/10/77 (l(
9/30/77 <10 10/1/77 12.4 10/2/77 13.0 10/3/77 41( 10/4/77 <10 '10/5/77 <10 10/7/77 <10 . e e *
, e
+ _ x . _ _ . _ _
.____A*-___
t ~
- 3' . . f',
~ EXHIBIT 2-
'f T
's a .
SUMMARY
OF BIOASS'AY SAMPLE RESULTS 1 a Total number of samples-submitted: 126- - -
~
Total number.of sample results above
. . detection level of-10 mgU/1 9 -
Maximum concentration.found: 18.1 mgU/1
~
TYPICAL NUCLEAR INDUSTRY ACTION LEVELS
- E For soluble. uranium compounds: ~ ~ Results > 50 mg/l requires
~
resampling until < 25 mg/1. i If'two resamples show 2 25 mg/l an internal ~ dose evaluation shall be. performed. For insoluble uranium compounds: Result > 25 mg/l requires resampling. If resample shows 2 10 ng/l an internal dose evaluation shall be performed.
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~
' EXHIBIT 3 RADIOLOGICAL SAi ETY TRAINING !!ECOuD (Subjects Covered @ ) D.i t e 9-30-77 '
x;
) .
J Redhtion l'rotectim itefp!rutory Predection - Itelative hazards of the various nranium and/or
% plutonium compounds that may be encountered.% Requirementx and pmcedures for Ihe use of respir:
protection equipment and devices. [ Definitions and boundaries of R::dioactive Materials. M Availability of respiratory ecpripment and devices. Radiation, intermediate and Clean Areas. P Ath oretpdpment and devices. O Radiation Work Procedures-
% C.m a = or etpiipmeni and devices.
T "rotective clothing requirements. , y Mask Guing and testing. Change Room Step-Ofr-Pad procedure. % M sk rnaintenance,repak,decontantination,cican and storage. Personnel survey instruments and requirements. Personnel and mask surveys required following uss O lasta!!cd radiation and radioactlye material monitorir.g
- respiratory orotection equipment and/or devices.
Instruments and alarms.
- 13ionssay and in-vs.vo measurement requirements. '
Air sampling and monitoring programs. 'l
. Special a.ir sampling requirements. 4 Radioactive material containment and contaminathan l l'rotection factors.
control programs. !
. ' O clovebox operations. O others
. O clovebox glove change procedure. O Radiation Exposure to Female Employees (Reg.M.13)
O clovebox han-in and bas out proccanre. K Training Aids used k Itetpiirements and procettures for rernoval of equipment or materials front Itadiation Areas. . fuli Iace Mask Perumnel and espdpment decontamination requirements .Jla.lf Mad . I and procedentes. I Protective C1nthino i P,ndioactive nuiterials puckaging and unpack::ging procedures. Portable Sorvav Instromant i O Re tuitements.and procedures for performing non-routine ' Air Sarnolers jobs.- Treatment of injuries incurred in Radiation Areas; Donald Keiter j protection for cuts and abrasions.
- 7. it Id, Personnel external radiation exposure controls.
William Tibbs'
. Personnel external radiation exposure dosimetry programs,
_ aMn Hamg and rcquirements. - - John Osterman h Bioassay and in-vivo measurement programs and Carl Lembke requuements. Radioactive waste disposal procedures. Nancy Dennis O Others Richard 11ornsby Emernney Procedures Leroy Moore
~ O ulg gasrelease, ,O Airborne uo2-
_O Airborne pluionium. .n O Plutonium contamination spread. Inst,ueio,(3) Edward L. Foster J O, Fire involving radioactive material
- 4. O criticality. - -
% f [,)C
~
@O others:- Date: September 30, 1977 j?fh& 3L
c;
,- ^\
, EXHIBIT <4-
" z . ' 'S F
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'~~
gl 7 : AIR SAKPI,ING PESUT.TS, i f ,
. Uranium' Concontration Date. (uci/ml'x 10-11)-
lEncloso'd Area Samplec 9/30 60.7 i 10/1' G.2 i
.10/1
- 3737.6 i 10/1 6.3 l 10/1 13G.7 8:
- 10/1 370.7 10/2 21.0 10/2 1G7.2
, 10/4 16.7
- 10/5 23.7' '
"10/5- 4.0 .
10/5 3.7 . 10/6- 2.4 10/6 41.1 10/7 2.2 open Area samples 9/30- 1.3
'lo/1 o3 .
^
10/2
- 1.3 10/4 1.3 10/5 0.2 10/5 14.2
- (n) -
10/5 1.9 10/6 2.7 10/6 1.2 10/6 30.8 10/7 . 0.6 10/7 O.2
' ~ 10/7 0.2 10/8 0.3 10/8 1.5 10/8 0.1 '
, 10/8 0.3 10/9 4.0 10/9 29.2 10/9 4.2 10/10 0.8
. . Perimeter Samples 9/30 0.56 10/1 -
0.04
~ , '. - ,
10/1 0.03
,3 s 10/1 0.06 10/2 0.03 10/2 0.02 10/2- 0.0; v- 10/4 O.13, 10/5 10.7 O..
Q_,. 10/5 1.91
.10/5 0.58 ' i f S .. ,
10/5:
- 1.01 t
9Ac 10/5- 0.08 pI[.j.; .
- U .10/6 2.80
- g My
- 10/G. 0.03
<qs/tf .
10/6' . - - - - - - -O.08- - --
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, 4 :-
Uranium'. '
-- qu < .;
4, , _i, Concentration-Da,t.c, luC1/ml x'10-ll) 1 irI 1 . L- 4 '
;Parir.1cter Samples Continued 10/7. ' .. ,_ o.02 ;
10/7_ o.10 e t
, 10/7 .O.02 '$
, i 10/8 0.29. -!
10/8- 0,03 -j 10/8: .0.05 i 10/9 1.12- ! 10/9 0.05 10/10.- .O.23 .) 10/10 o.o2 . -t
. I
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' CONCLUSIONS l
(,4 (v" , c, . 4 1). Initial = securing of the spilled yellowca.ke by . local' law enforcement officers was prompt and i i effective. ]
] a'
'2) The clean-up operation effectively removed the spilled' uranium concentrate from the environment.
l
.1 1
1
- 3) Intake.of-uranium by members of the public and by clean-up personnel was far less than'the intake . l l
. required to cause adverse-health effects.
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i i
. APPENDIX
\
l RADIATION SURVEYS ' 0' V 1 1 1 4 1 1 e i e l
.b 4
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a j o,o*'e
~a
~
,1 ^
% 4.5,
/
l t b 1 RADIATION SURVEY DETAILS OMITTED l O e G 1, I 1 l l l l l l 1 l i 1 l 1}}