On November 14, 1995, at the Mound Plant, the vice president for EGG Waste Management discovered a noncompliance with the safety authorization basis for the Waste Disposal facility. High activity cement-solidified tritium waste was not stored in Department of Transportation (DOT) Type B shipping containers and could not be exempted from the plant radiological inventory. This caused the total inventory to exceed the limits specified in the hazard classification determination document. This event is significant because lack of familiarity with technical requirements for DOT type B shipping containers caused the Waste Disposal facility to exceed the safety authorization basis. (ORPS REPORT OH-MB-EGGM-EGGMAT04-1995-0022)

On August 22, 1995, a waste handler was reviewing the inventory list of transuranic waste in Building 31A when he discovered that quantities in certain containers exceeded the limits in DOE-STD-1027-92, Hazard Categorization and Accident Analysis Techniques for Compliance with DOE Order 5480.23, Nuclear Safety Analysis Reports. The Standard states that radiological facilities are exempt from the requirements for safety analysis reports as directed in DOE 5480.23, Nuclear Safety Analysis Reports, and specifies the maximum allowable quantities of isotopes for a radiological facility. The Standard also states that, if the material is contained in a DOT type B shipping container, the contents may be excluded from the summation of the radioactive inventory. The handler determined that the containers were not certified as DOT type B and the inventory had to be counted against the allowable inventory. (ORPS Report OH-MB-EGGM-EGGMATO2-1995-0011)

To correct the August 22 situation, key personnel were trained on requirements for DOT type B shipping containers and investigators checked the plant inventory of transuranic waste. As a result of these corrective actions, the vice president discovered 54 sealed drums containing tritium waste that were not DOT certified. These drums were temporarily stored in the Waste Processing facility pending final disposal. In accordance with the DOE-STD-1027-92, the drum contents had to be counted against the plant inventory limits and violated the threshold of 0.1 grams of tritium.

Also, on November 14, Waste Management engineers determined that DOE-STD-1027-92 may be the appropriate safety authorization basis for 123 semi-trailers used for storage of low-level radiological waste. Investigators are checking the semi-trailers to ascertain if the Standard is applicable and if there are any additional noncompliances.

An OEAF engineer searched previous Weekly Summaries and found another instance in which the isotope inventory for a radiological facility exceeded the quantity allowed by the Standard. On February 1, 1995, waste handlers at Lawrence Livermore Laboratory, discovered that the threshold limit of 8.4 grams of plutonium-239 was exceeded for approximately six hours when six drums were moved into a building for radiography. To correct the situation, Laboratory managers developed procedures and controls to ensure that isotope inventories do not exceed limits established by the Standard. (OE Weekly Summary 95-08 and ORPS Report SAN--LLNL-LLNL-1995-0005)

These events illustrate the importance of understanding technical and implementation requirements of safety authorization basis documents. DOE-STD-1027-92, section 3.1 states that radiological facilities should have administrative controls in place to ensure that threshold values are not exceeded by introduction of new material. Waste handling managers at radiological facilities should verify that their programs ensure a level of control sufficient for compliancewith the Standard.