A self-revealed finding preliminarily assessed to be greater than Green and an associated apparent violation (
AV) were identified for the failure to prepare a package of radioactive material for shipment, so that under conditions normally incident to transportation, the radiation level does not exceed 200 millirem/hour at any point on the external surface of the package. Package surface radiation levels in excess of 200 millirem/hour were identified by a waste processing contractor upon receipt of the shipment from the licensee. The finding was more than minor because it was associated with the Program and Process attribute of the
Public Radiation Safety Cornerstone, and affected the cornerstone objective of ensuring adequate protection of public health and safety from exposure to radioactive materials released into the public domain. Also, the issue involved an occurrence in the licensees radioactive material transportation program that was contrary to NRC and Department of Transportation (
DOT) regulations. The finding was determined preliminarily to be of low to moderate safety significance because the transportation problem involved an external package radiation level that exceeded limits by 25 percent and because the area of elevated radiation on the package was determined to be accessible to a member of the public during conditions normally incident to transportation. To address this issue, the licensee planned to revise procedures to require load plans and to specify which survey instrumentation is to be used for package surveys, and to provide training to its staff involved in radioactive material shipments
