STATE. OF ASH 

DEPARTMENT OF HEALTH
OFFICE OF RADIATION PROTECTION
I [sme/ Road SE PO Box 4 732 7' Obit-rpm. Was/Imng 98504-783 7
TDD Relay Service: 

July 26, 2017

Mike Davis

Energy Northwest

Columbia Generating Station

PO. Box 968, North Power Plant Loop
Richland, Washington 99352-0968

Dear Mr. Davis: Permit 

This letter refers to a shipment of radioactive waste material sent to the commercial low-level
radioactive waste disposal site operated by US Ecology Washington, Incorporated, near Richland,
Washington. The material, listed as Radioactive Material - Low Speci?c Activity, (LSA II) Fissile
Excepted, on shipment number 17-51, was shipped on July 20, 2017, and was received on July 20,
2017. Inspections of your shipment revealed the following violation of US Ecology Radioactive
Materials license and the Washington Administrative Code:

Container Number Summary of
or Description Violations
Liner Washington Administrative Code (WAC) 

and US Ecology Radioactive Materials License 
License Condition 22 require in part that waste containers
received at the facility do not show an increase in in the external
radiation levels recorded on the manifest, within instrument
tolerances.

Contrary to these requirements, during the manifest review and
un-packaging of this Class A Unstable container, it was observed
that the measured surface radiation level was 1.1 R/hr on contact,
and the manifest recorded surface radiation level was 12 mR/hr.

Shipment #17?51 WAC 246-249?0906) states in part that: Certi?cation. An
authorized representative of the waste generator, processor, or

Mr. Mike Davis
July 26, 2017
Page 2 of 3

collector shall certify by signing and dating the shipment manifest
that the transported materials are properly classified, described,
packaged, marked, and labeled and are in proper condition for
transportation according to the applicable regulations of the
Department of Transportation, the US. Nuclear Regulatory
Commission, and the department

Contrary to this requirement, during the manifest review of this
Class A shipment the following errors were observed:

(1) NRC Form 540 Block 5: incorrect carrier;

(2) NRC Form 540, 541, and 541A: incorrect total shipment
activity;

(3) NRC Form 54lcolumn 6: incorrect container type;

(4) NRC Form 54lcolumn 7: incorrect container volume;

(5) NRC Form 54lcolum11 8: incorrect container weight;

(6) NRC Form 54lcolumn 15: incorrect isotope activities for Co?
58, 211-65, Mn?54, Cm-242, and e-55.

Because of the nature of the violations found in this shipment, authorization to use the commercial
low?level radioactive waste disposal site by Energy Northwest has been suspended inde?nitely.
Shipments in transit prior to 3 :00 pm. (Paci?c Time) July 20, 2017, will be admitted to the site.
Further shipments will be refused until your site use permit is reinstated.

If you wish to reestablish site use privileges, you must allow a point?of-origin inspection conducted
by the state of Washington, with all expenses paid by Energy Northwest. You must also respond in
writing to: 

Kristen Schwab, Supervisor

Waste Management Section

Of?ce of Radiation Protection
PO. Box 47827

Olympia, Washington 98504-7827
(Phone: 360.236.3241)

Your response must:
0 Describe the actions you have taken or plan to take to bring your activities into full
compliance with all applicable state and federal regulations.
I Ensure quality assurance by addressing the root cause of each violation and the requirements
of WAC 246?249?090 for a program to ensure compliance with waste forms and waste
classi?cation.

Mr. Mike Davis
July 26, 2017
Page 3 of 3

The department is also requiring you to participate in a management meeting. This meeting will be
scheduled, by the department, after receipt of your root cause investigation and description of
corrective actions. The department is requesting you submit, to the department, a schedule of your
actions so the department can ensure staff availability. 

If no response is received within 90 days, your site use permit will be terminated.

Sincerely,

Kristen Schwab, Supervisor
Waste Management Section

cc: US Ecology, Richland, WA
Jeremy Groom- USNRC Sr. Resident Inspector, CGS
David Pratt, UTC
Patric Lease, US. DOT
Leigh Ing, Texas LLRW Disposal Compact, Executive Director
Eileen Kramer, DOH, Site Use Permits