The team reviewed a self-revealing, noncited violation of
10 CFR 71.5, which occurred when the licensee failed to ship radioactive material correctly. A radioactive shipment classified as an excepted package-limited quantity exceeded the external dose rate limit of 0.5 millirem per hour on the surface of the package. The package recipient identified dose rates of 0.9 millirem per hour on the exterior surface of the package and notified the licensee of the problem. The licensee revised its procedure to correct for this problem by limiting the inner package dose rate to 0.3 millirem per hour, thus reducing the risk for the external dose rate to be more than 0.5 millirem per hour. The finding was placed into the licensees corrective action program as Smart Form SMF-2006-2403. The finding is greater than minor because it was associated with a
Public Radiation Safety cornerstone attribute (transportation program) and it affected the associated cornerstone objective because the failure to correctly ship radioactive material decreases the licensees assurance that the public will not receive unnecessary dose. However, this finding cannot be evaluated by the
Public Radiation Safety Significance Determination Process because it did not involve radioactive shipments classified as Schedule 5 through 11, as described in
NUREG-1660, and it did not fit traditional enforcement. Therefore, the finding was reviewed by NRC management using
Inspection Manual Chapter 0609, Appendix M, and determined to be of very low safety significance because the package was not accessible by the public. Additionally, this finding has a cross-cutting aspect in the area of human performance, work practices component, because the worker preparing the shipment did not use self checking as an error prevention technique to ensure that the package did not exceed the dose rate limit (
H4.a).
