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[Fwd: RE: Apparent Illegal Shipment - Follow-up Clarification]



The following is posted with the permission of the author.

Bill Lipton

liptonw@dteenergy.com



-------- Original Message --------

From: "Iannaccone, Mario (DPH)" <Mario.Iannaccone@state.ma.us>

Subject: RE: Apparent Illegal Shipment - Follow-up Clarification

To: 'William V Lipton' <liptonw@dteenergy.com>



FYI: Although the discussion has been very interesting, a clarification

of

the originating circumstances is in order. I am the originator of the

DOT-E

which apparently was subsequently reported in the NRC Daily Events;

referenced in the message below. Chagrined, I'll eat crow and admit that

this was an inadvertently sent to the NRC Operation Center rather than

the

CRCPD OED - root cause - human error - mine. A follow-up was reported to

the

NRC identifying the error. In actuality this was a routine rejected "Hot

Load" reported to the MA RCP and processed through channels i.e. a CRCPD

transportation exemption (DOT-E 11406, waste) was issued. MA RCP was

fully

aware of the situation, however due to the NRC report Mr. Lipton refers

to

he was not. I routinely use the verbiage "w/o stops" to assure the load

goes

directly to the destination to be appropriately isolated until

mitigated.

After 17 yrs in the field I finally made the funny papers, my apologies

for

the ruckus.



Mario Iannaccone, RCO, MA DPH-RCP 



-----Original Message-----

From: William V Lipton [mailto:liptonw@DTEENERGY.COM]

Sent: Friday, February 13, 2004 8:20 AM

To: radsafe@list.vanderbilt.edu

Subject: Apparent Illegal Shipment





I noticed the attached event in the NRC Daily Event Report.  A truck

arriving at a waste incineration facility alarmed a radiation monitor

and was found to be reading 0.13 mrem/hr.  According to the report,

"...The driver of the truck was told to return the load back to its

origin, BFI facilities, in Peabody, MA without any stops...."  This

implies that the site made a radioactive materials shipment without the

required  DOT controls.  Assuming the material shipped would qualify as

a "Limited Quantity", they needed the required notice, and the driver

had to be hazmat employee trained.  It does not seem that this was done,

although I say, "apparent," because the report may be incomplete.  This

would be a violation of DOT regulations.  If the contamination is

identified as NRC licensed material, this would also be a violation of

NRC regulations.  It does not seem that anyone involved, including the

MA regulators, noticed this.



Recognizing that this type of shipment represents a low degree of

hazard, DOT has issued exemptions, which may allow this shipment to

procede without meeting all of the normal DOT requirements (DOT-E 11406

for waste, DOT-E 10656 for scrap metal).  These exemptions require

approval by state authorities.  Again, I say "apparent," since one of

these exemptions may have been used and not noted in the report.



I'd appreciate further information on this.



The opinions expressed are strictly mine.

It's not about dose, it's about trust.

Curies forever.



Bill Lipton

liptonw@dteenergy.com



General Information or Other Event Number: 40511

Rep Org: MA RADIATION CONTROL PROGRAM

Licensee:

Region: 1

City: HAVERHILL State: MA

County:

License #:

Agreement: Y

Docket:

NRC Notified By: MARIO IANNACCONE

HQ OPS Officer: CHAUNCEY GOULD  Notification Date: 02/10/2004

Notification Time: 11:12 [ET]

Event Date: 02/10/2004

Event Time: [EST]

Last Update Date: 02/10/2004

Emergency Class: NON EMERGENCY

10 CFR Section:

AGREEMENT STATE

 Person (Organization):

KENNETH JENISON (R1)

ROBERTO TORRES (NMSS)





Event Text



LOAD OF WASTE ARRIVING AT A WASTE-TO-ENERGY FACILITY SET OFF RADIATION

MONITORS



A load of waste or recycle materials that had been transported to

Covanta Haverhill, Inc (a waste-to-energy facility) in Haverhill, MA had

a radiation measurement of 0.13 mrem/hr when it entered the facility.

The driver of the truck was told to return the load back to its origin,

BFI facilities, in Peabody, MA without any stops. Once at the origin of

the shipment, the load is to be isolated until mitigation by a

consultant. A report detailing material identification and disposition

shall be submitted to the MA Radiation control Program.





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