05000397/FIN-2016009-01
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Finding | |
|---|---|
| Title | Shipment of a Type B Quantity of Radioactive Material in a Type A Package |
| Description | TBD. The team reviewed a self-revealed finding and apparent violation of 49 CFR 173.427 associated with a shipment of low specific activity (LSA) material consisting of radioactive filters, irradiated components, and dry active waste. The licensee failed to ensure that the radioactive contents in a radwaste liner did not exceed the radiation level requirements for shipping. Specifically, the licensee transported a Type A package containing a Type B quantity of radioactive material as LSA even though it had an external radiation level of 2.1 rem/hr at a distance of 3 meters from the unshielded material, exceeding the 1 rem/hr at 3 meters limit for LSA. This issue was entered into the corrective action program as Action Requests 357593 and 360236. The failure to ensure that the radioactive contents of a radwaste container of low specific activity material did not exceed the requirements for shipping was a performance deficiency. The performance deficiency was more than minor because it was associated with the program and process (Transportation Program) attribute of the Public Radiation Safety Cornerstone and adversely affected the cornerstone objective of ensuring adequate protection of public health and safety from exposure to radioactive material released into the public domain. Specifically, the licensees failure to ensure that the contents of a radwaste container did not exceed the requirements for shipping resulted in radioactive material being transported in Type A packaging rather than the required Type B packaging. The finding was evaluated using NRC Inspection Manual Chapter 0609, Appendix M, Significance Determination Process Using Qualitative Criteria, because Inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, does not specifically address the situation where a Type A package was used to ship quantities of radioactive material requiring a Type B package. In accordance with Appendix M, an initial qualitative bounding evaluation was performed. This was accomplished using the Transportation Branch of 3 the Public Radiation Safety Significance De termination Process and examples from the Enforcement Policy. The finding has a cross-cutting aspect in the area of human performance, associated with conservative bias, because licensee personnel did not use decision-making practices that emphasized prudent choices over those that were simply allowable. Specifically, on several occasions throughout the radwaste processing and packaging evolution for shipment No. 16-40, decisions were made that did not exhibit the appropriate conservative bias [H.14]. |
| Site: | Columbia  |
|---|---|
| Report | IR 05000397/2016009 Section 4OA5 |
| Date counted | Mar 31, 2017 (2017Q1) |
| Type: | AV: |
| cornerstone | Pr Safety |
| Identified by: | Self-revealing |
| Inspection Procedure: | IP 93812 |
| Inspectors (proximate) | L Carson N Greene B Tharakanb Tharakanh Gepford L Carson N Greenel Carsonn Greene B Tharakan H Gepford |
| Violation of: | 49 CFR |
| CCA | H.14, Conservative Bias |
| INPO aspect | DM.2 |
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Finding - Columbia - IR 05000397/2016009 | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Columbia) @ 2017Q1
Self-Identified List (Columbia)
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