The inspectors identified a finding of very low safety significance and associated non-cited violation (
NCV) of
10 CFR 71.5 for the failure to correctly complete radioactive waste shipping documents for radioactive shipments containing condensate resins. The shipment documentation failed to include the radionuclide
Am-241, which was present within the shipment. This issue was entered into the licensees corrective action program (
CAP) as
AR 01369367. The licensee is improving the supervisory approval mechanism for radioactive shipment documentation to ensure shipping papers are adequately completed. The performance deficiency was determined to be of more than minor safety significance in accordance with Inspection Manual chapter (IMC) 0612, Appendix B, Issue Screening, because, if left uncorrected, it would have the potential to
lead to a more significant safety concern. Specifically, incorrect shipment documentation could
lead to incorrect Department of Transportation (
DOT) and NRC transport classifications or incorrect waste classifications in accordance with
10 CFR 61. The inspectors also reviewed the guidance in
IMC 0612, Appendix E, Examples of Minor Issues, and did not find any similar examples. In acco rdance with
IMC 0609, Appendix D,
Public Radiation Safety Significance Determination Process, the inspectors determined that the finding had very low safety significance (Green) because the finding did not involve: (1) radiation levels exceeded, (2) a breach of package during transit, (3) a certificate of compliance issue, (4) a low-level burial ground nonconformance, (5) or the failure to make notifications or provide emergency information. The primary cause of this finding was related to the cross-cutting aspect of human performance with the component of work practices. The licensee ensures supervisory and management oversight of work activities, including contractors, such that nuclear safety is supported.
