IR 05000160/1996002
| ML20134C672 | |
| Person / Time | |
|---|---|
| Site: | Neely Research Reactor |
| Issue date: | 09/09/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20134C670 | List: |
| References | |
| 50-160-96-02, 50-160-96-2, NUDOCS 9609270352 | |
| Download: ML20134C672 (2) | |
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NOTICE OF VIOLATION (Revised)
Georgia Institute of Technology Docket No. 50-160 Atlanta, Georgia License No. R 97 During an NRC inspection conducted on April 22 24, May 7, 23, 29 31, and June 4,1996, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C, the violations are listed below: Technical S>ecification 4.2.a requires that the channels listed in Table 4.2 s1all be calibrated as indicated. Table 4.2 specifies an ^
annual known parameter source calibratio Technical Specification 1.27 specifies that the frequencies of periodic surveillance tests, checks, calibrations, and examinations shall be i performed within the specified intervals. These intervals may be adjusted by plus or minus twenty five percent (t 25%). !
Contrary to the above, the licensee failed to calibrate the G M gas l monitor within the annual period * 25% in that the gas monitor was I calibrated on October 20, 1993 and not calibrated again until March 3, 1995, a period exceeding the allowable time period specified in the Technical Specification This is a Severity Level IV violation (Supplement IV). CFR 71.5 requires each licensee who transports licensed material outside the confines of its plant or other place of use to comply with the applicable requirements of the Department of Transportation.(DOT) in 49 CFR Parts 170 through 18 CFR 172.704(a) specifies the general awareness, function specific, and safety training requirements for hazmat employee CFR 172.704(c) s)ecifies that a hazmat employee em)1oyed after July 2,1993 shall )e initially trained prior to Octo)er 1,1993 and at least once every two years thereafte CFR 172.704(d)(4) requires certification that the hazmat employee has been trained and tested as required by this subpar CFR 171.8 defines a hazmat employee as an individual employed by a hazmat employer who, during the course of employment, loads or unloads or handles hazardous materials; prepares hazardous material for transportation: is responsible for safety of transporting hazardous materials; or tests, reconditions, modifies, marks, or otherwise represents containers, drums, or packagings as qualified for use in the transportation of hazardous material Enclosure 2 9609270352 96o909 DR ADOCK 0500 0
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il 49 CFR 172.702(d) requires each hazmat employer to ensure that each hazmat employee is tested by appropriate means on the training subjects covered in 49 CFR 172.70 Contrary to the above, since January 31, 1996, the licensee failed to train and appropriately test all hazmat employees on the subjects covered in 49 CFR 172.704 in that the hazmat employees had not received
, the specified training with the exception of one employee who was i trained on the safety portions of the requirements of 49 CFR 172 in
- December 1995.
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This is a Severity Level IV violation (Supplement V).
I Pursuant to the provisions of 10 CFR 2.201, Georgia Institute of Technology is
- hereby required to submit a written statement or explanation to the U.S.
1 Nuclear Regulatory Commission, ATTN: Document Control. Desk Washington, D.C.
j 20555 with copies to the Regional Administrator, Region II, and the Chief,
' Fuel Facilities Branch, Region II, within 30 days of the date of the letter j transmitting this Notice of Violation (Notice). This reply should be clearly
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marked as a " Reply to a Notice of Violation" and should include for each
! violation: (1) the reason for the violation, or, if contested, the basis for
- disputing the violation,-(2) the corrective steps that have been taken and the
! results achieved (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an
- adequate reply is not received within the time specified in this Notice, an i
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order or Demand for Information may be issued as to why the license should not be modified, susanded, or revoked, or why such other action as may be proper
should not be ta(en. Where good cause is shown, consideration will be given to extending the response time.
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i Dated at Atlanta Georgia
} this 9th day of September, 1996 i
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NEELY NUCLEAR RESEARCH CENTER
\ ;N[...a [ 900 ATLANTIC ORIVE
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July 18, 1996 U.S. Nuclear Regulatory Commission Washington, Attention: Document Control Desk Subject: Georgia Institute of Technology License No. R-97. Docket No. 50-160 Reply to a Notice of Violation Inspection Report No. 50-160/96-02 Gentlemen: 1 Pursuant to 10 CFR 2.201, please find Attachment I, A Response to (
Two Notices of Violation in Inspection Report No. 50-160/96-02 and !
Attachment'II, A Response to a Notice of Deviatio Should you have any question, please call me at (404) 894-360
Sincerely,
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l R.A. Karam, Ph.D., Director Neely Nuclear Research Center Enclosure cc: Mr. S. Ebneter U.S. Nuclear Regulatory Commission, Region II 101 Marietta Street, Atlanta, GA 30323 l Chief Fuel Facilities Branch, Region II i
Dr. John White, Dean of Engineering 4 l Dr. Jean-Lou Chameau, Vice Provost I Mr. Alfred L. Evans, Senior Asst. Attorney General l Mr. Randy Nordin, Chief Legal Advisor
- eleu $42507 ".;TAIOCAATL Fax: t04 653-93 5 (Ventv A%894 3500i
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, ATTACHMENT I l
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Georgia Institute of Technology Reply to Notice of Violation 50-160/96-02 l
Violation 50-160/96-02-A Technical Specification 4.2.a requires that the channels
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listed in Table 4.2 shall be calibrated as indicated. Table .
4.2 specifies an annual known parameter source calibratio . Technical Specification 1.27 specifies that the frequencies of
- periodic surveillance tests, checks, calibrations, and examinations shall be performed within the specified interval These intervals may be adjusted by plus or minus twenty-five percent (1 25%).
Contrary to the above, the licensee failed to calibrate the G-t M gas monitor within the annual' period 25% in that the gas monitor was calibrated on October 20, 1993, and not calibrated again until March 3, 1995, a period exceeding the allowable time period specified in the Technical Specification This is a Severity Level IV violation (Supplement IV).
Reolv 1.- Admission or denial of violation:
The Georgia Institute of Technology admits the violation as state . The reason for the violation:
The health physicist responsible for the gas monitor calibration failed to calibrate the gas monitor in a timely manne The reason. given by the HP technician is simple oversight. In reality, this staff member was planning for his retirement and that may have contributed to the oversigh . Corrective steps which have been taken and results achieved:
A meeting was held with all the Office of Radiation Safety staf The importance of compliance with all regulatory requirements was stressed to al Also stressed was the need
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l to communicate among the staff that if slippage in schedule is l unavoidable, the Director of the facility must be informed.
l In this case, the Manager of the Office of Radiation Safety l
knew about the slippage but did not inform the Director. The Director stressed that non-performance by anyone will not be tolerated!
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, The retired HP technician was replaced with a well-trained health physicist with an MS degree in Health Physics. All HP staff were sensitized to the need to meet all regulatory requirement . Corrective steps which will be taken to avoid further violations:
See answer to item 3 abov . Date when full compliance will be achieved:
Full compliance was achieved 3/3/9 Violation 50-160/96-02-B CFR 71.5 requires each licensee who transports licensed material outside the confines of its plant or other place of use to comply with the applicable requirements of the Department of Transportation (DOT) in 49 CFR Parts 170 through 18 CFR 172. 704 (a) specifies the general awareness, function specific, and safety training requirements for hazmat employee CFR 172.704 (c) specifies that a hazmat employee employed after July 2, 1993, shall be initially trained prior to October 1, 1993, and at least once very two years thereafte .
49 CFR 172. 704 (d) (4 ) requires certification that the hazmat employee has been trained and tested as required by this ,
subpar l 49 CFR 171.8 defines a hazmat employee as an individual employed by a hazmat employer who, during the course of employment, loads or unloads or handles hazardous materials; prepares hazardous material for transportation; is responsible for safety of transporting hazardous materials; or tests, ,
reconditions, modifies marks, or otherwise represents i containers, drums, or packagings as qualified for use in the transportation of hazardous material CFR 172. 702 (d) requires each hazmat employer to ensure that each hazmat employee is tested by appropriate means on the training subjects covered in 49 CFR 172.70 Contrary to the above, since October 1, 1993, the licensee f ailed to train and appropriately test all hazmat employees on the subjects covered in 49 CFR 172.704 in that the hazmat employees had not received the specified training with the exception of one employee who was trained on the safety portions of the requirements of 49 CFR 172 in December 1995. .
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Reply
. Admission or denial of violation:
The Georgia Institute of Technology admits that all employees at the Neely Nuclear Research Center were agt all trained and appropriately tested for safe handling, packaging, and shipping of hazardous material. One staff member was however trained in OSHA-approved " Hazardous Material Control and Emergency Response" cours The course covered not only safety portions of 49 CFR 172 requirements but also the general awareness, function specific, and emergency response requirements. The staff member was not only trained but also tested and certified in all requirements of 49 CFR 172.704 Until January 31, 1996, when the Georgia Institute of Technology shipped the unirradiated fuel to Oak Ridge, no hazardous material was shipped from NNRC under the license l from the Nuclear Regulatory Commissio All shipments l containing radioactive material from Georgia Tech were made l under the broad license from the State of Georgi Consequently, Georgia Tech is wondering why NRC Region II issued this violation. It would be appreciated to receive clear and well-defined boundaries specifying jurisdictional areas of responsibility between NRC and the Stat We are also concerned about the statement, "
...the licensee f ailed to train and appropriately test all hazmat employees on subjects covered in 49 CFR 172.704..." Does this mean that f_ll NNRC employees need to be trained and certified? We have in place a detailed procedure covering radioactive material i shipment, Procedure 9510 (appended). All of Georgia Tech's I health physics staff were trained on this procedur It is believed that this procedure covers regulatory requirements of j NRC and DOT adequatel It is our belief that our training of the material covered in Procedure 9510 meets or exceeds requirements in 4 9 CFR l'72. 70 A deficiency however exists in that we did not test the trainees on their proficiency of all relevant materials in Procedure 951 This deficiency will be removed by June 199 . Reasons for the violation:
No violation was committed under NRC licens A violation may be cited under State of Georgia regulations based on the fact that our training did not include testin . Corrective steps which have been taken and results achieved:
One staff member was trained in an OSHA-approved course and certifie All appropriate personnel were trained in Procedure 9510. All shipments under NRC's license were made in compliance with all regulation .
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, Corrective steps which will be taken:
All personnel who ship radioactive materials will be enrolled in the OSHA-approved course by January 1, 199 Retraining and testing of personnel will be instituted at NNRC by June 199 . Date when full compliance will be achieved:
June 199 i J
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< Attachment II Georgia Institute of Technology Reply to a Notice of Deviation l
During an NRC inspection conducted on April 22-24, May 7, 23, 29-31, . and June . 4, 1996, a deviation of written commitments was identifie In accordance wi:h the " General Statement of Policy and Procedure for NRC Enforcement Actions, " 10 CFR Part 2, Appendix l C, the deviation is listed below- -
i In a response dated June 19, 1995, to a Notice of Violation, .;
.the licensee committed . to revise Procedure 3600, "Special- ,
Nuclear Material Inventory," and submit the revision to the ]
Nuclear Safeguards Committee for review and approval by July 20, 199 )
Contrary to the above, as of April 24, 1996, Procedure 3600 had not been revised and had not been submitted to the Nuclear Safeguards Committee for review and approva Reolv Admission or denial of deviation:
The Georgia Institute of-Technology admits the deviation as ,
state ' Reasons for the deviation:
Simple oversigh . Corrective steps taken and results achieved:
Procedure 3600 was revised, submitted to the Nuclear Safeguards Committee and approved on June 13, 199 . Corrective steps which will be taken to avoid further deviations:
Non . Date when full compliance will be achieved:
Full compliance was achieved 6/13/9 .
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NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 1 of 21 PURPOSE To describe a method for packaging and shipping of radioactive materials to ensure that package integrity'
is maintained during transponation and to ensure compliance with DOT /NRC regulations regarding the transportation of radioactive material .0 SCOPE This procedure is applicable to offsite shipments of TYPE A, Limited Quantity, Surf ace Contaminated Objects (SCO), and Low Specific Activity (LSA) radioactive material from the Georgia Tech campus.
l RESPONSIBILITIES It is the responsibility of individuals involved with the packaging and shipment of radioactive material and waste to ensure that the instructions of this procedure are followed and that the critoria specified this procedure for packaging, surveying and
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l in l documenting each snipment is me ,
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l It is the responsibility of the Manager, Office of l Radiation Safety (MORS), or her/his designee, to review all shipping documentation prior to shipment to ensure accuracy and adequacy of the paper .O REFERENCES 1
, Requirements and Specifications j I
4. CFR, Parts 100-199, Department of Transportation ;
Regulations
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4. CFR 71, Packaging and Transportation of Radioactive 1 Materials t 4. CFR 124, Postal Service Regulations l
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4. State of Georgia, Rules and Regulations for )
. Radioactive Materials, Chapter 391-3-1 l
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NEELY NUCLEAR RESEARCH CENTER
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Minor Change Procedure 9510
Revision 03
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Number: Approved 4/11/96 By: RADIOACTIVE MATERIAL SHIPMENT Page 3 of 21 Date: / /
spontaneously emits ionizing radiation and has a specific activity in excess of 70 Bq/g (0.002 pCi/g)
of materia .
5.2. Radioactive Material Soecial Form - Sealed sources' ;
th&t primarily represent a direct radiation hazard rather than a contamination hazard because of its high physical integrit .2. Radioactive Material Normal Form - Any radioactive '
material that does not qualify as Special Form, i. e., loose radioactive materia .2. A1 Activity - The maximum activity of Special Form radioactive material that may be transported in a Type A package (various radionuclides have different permissible activities - see 49 CFR 173.435). l 5.2. A2 Activity - The maximum activity of Normal Form radioactive material, other than special form, Surf ace i Contaminated Objects (SCO), or Low Specific Activity -
(LSA) radioactive material that is permitted in a Type A container (various radionuclides have different ;
permissible activities - see 49 CFR 173.435).
5.2. Tvoe B Ouantities - A quantity which exceeds the A or 1 l A value for the radionuclide (s) of interest (see MOKS
for such shipments).
5.2. LSA Radioactive Material - Materials in which the ,
radioactivity specific activity meets the following i i
limits:
5.2.1. LSA-I, naturally occurring radioactive cres, depleted :
uranium, material where A is unlimited, contaminated
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soil, concrete, rubble that has uniformly distributed I radioactivity less than 10-' A /9- 2 l
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5.2.1. LSA-II, tritiated water; less than (0.8 TBq/L or x 10 12 Bq/L) (20 Ci/L) and radioactive material less l than 10-* A /g for solids and gases and less than 10-5
A 2 /g for liquid l l
5.2.1. LSA-III, radioactive material distributed in solid is insoluble and specific
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(concrete / ceramic, etc), l activity is less than 2 x 10-3 A /g . 2 f I
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Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: -/ / Page 4 of 21 5.2. Packace - Represents the packaging together with its radioactive contents as presented for transport ( excepted, Type A, Type B and Industrial I, II, & III) .
5.2. Transoort Index - A dimensionless number (rounded up'
to one decimal place) placed on the label of a packrge to designate the degree of control to be exercised by the carrier during transportation and represents the maximum radiation level in ((msv/hr)x100) (mrem /hr) at one meter from the external surface of the packag .2.1.10 Surface Contaminated ob iect - Surface Contaminated object (SCO) is a solid object which is not itself radioactive but has radioactivity distributed on its surfaces in one of two groups of surface activity:
SCO-I: Contamination that does not exceed 4 Bq/cm Beta / gamma or 0.4 Bq/cm2 alpha for non-fixed contamination or 40,000 Bq/cm' Beta / gamma or 4,000 Bq/cm alpha for fixed contaminatio SCO-II: Contamination that exceeds SCO-I but :
does not exceed 400 Bq/cm beta / gamma or 40
f alpha for non-fixed or 8x10 5 Bq/cm 2 '
Bq/cm beta / gamma or 8x104 Bq/cm 2 alpha for fixed.-
(See 4 9 CFR 173 . 4 03 for details and exceptions).
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-I 5. Shipment Preparation j
NOTE: A Quality Assurance Checklist is attached as Appendix B to assist in '
the preparation of radioactive materials for transportatio This Form, RS-88, shall be utilized in ;
preparation of radioactive materials !
for shipment and shall be redained l along with copies of the shipping
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papers as permanent facility record .2. Preparation of packages of radioactive materials for i
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shipment will normally be carried out in the HP laboratory facilitie Preparation of waste for l
shipment will normally take place in the Bar l
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NEELY NUCLEAR RESEARCH CENTER
Minor Change Procedure 9510 Revision 03 Number: Approved 4/11/96 By: RADIOACTIVE MATERIAL SHIPMENT Page 5 of 21 Date: / /
5.2. Each container of radioactive material which is to be transported shall have an inner lining in addition to the external container so that in the case of breach one layer of of the inner or the outer package, packaging will remain intact to ensure that the radioactive material is not disbursed to the'
environmen .2. The majority of packages shipped from the NNRC are of the type defined as Limited Quantity or Low Specific Activity (LSA) material and consequently, are dealt with specifically belo NOTE: For preparation of shipments of highway controlled quantities, Type B, or fissile material, contact the MORS for further informatio .2. Ensure that shipping papers, Form RS-87, are completed appropriatel All radiological units are to be reported in SI units followed by customary units in parenthesi (49 CFR 172.203 (d) (4) ) .
Limited Quantity Shipments (49 CFR 173.421 and 5.2. .425)
Definition -
Limited quantity shipments are 5.2.2. radioactive materials whose activity per package does not exceed the limits specified in 49 CFR 173.425 (Table 7) and which are excepted from DOT specification packaging, shipping paper and certification, marking and labeling requirement .2.2. The radioactive material shall be packaged in strong, tight packages that will not leak under conditions normally incident to transportatio .2.2. The package shall have two layers of packaging, i. e. ,
an inner lining as well as the external packaging itself, i. e., the containe The outside of the inner lining shall be marked 5.2.2. " RADIOACTIVE."
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. Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 6 of 21 5.2.2. Enclosed in the package shall be a notice which provides the name and address of the shipper (NNRC)
and which states (enclosing a copy of Appendix C will fulfill this requirement) : ,
"This package corJorms to the conditions and limitations specified in 49 CFR 173.421 for excepted
- radioactive material, limited quantity, n.o.s., UN 2910; or 49 CFR 173.424 for excepted radioactive material, instruments and articles."
5.2.2. The removable contamination on the external surface of the package shall not exceed 0.41 Bq/cm (2200 dpm/100 cm ) for beta / gamma emitting radionuclides or 0.04 Bq/cm 2 (220 dpm/100 cm ) for alpha emitting radionuclide (49 CFR 173.443) i
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l 5.2. Transport Requirements for Low Specific Activity and Surface Contaminated Radioactive Material (49 CFR 173.427) l
! l l 5.2.2. Low specific activity (LSA) is defined in 5. 2.1. l Surface contaminated objects (SCO) are defined in .
5.2.1.1 .2.2. The LSA and SCO radicactive materials shall be packaged in strong, tight containers, or in industrial j packages specific for each LSA :.yp .2.2. Radiation levels and removable contamination levels shall meet the criteria specified in Steps 5.2.8 and 5. .2.2. shipments must be loaded by consignor (Georgia Tech)
or contractor and unloaded by consigne .2.2. The exterior of each package must be stenciled or
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marked " RADIOACTIVE - LSA." or " RADIOACTIVE - SCO",
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espectively.
NOTE: Once the radioactive materials are appropriately labeled for transport,
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the " Radioactive Material" labeling requirements of 10 CFR 20.1904 are no
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NEELY NUCLEAR RESEARCH CENTER
. Minor Change Procedure 9510 Number: Revision 03 By.: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 7 of 21 5.2.2. There must be no leakage of radioactive materials from the package during transpor Therefore, a careful visual inspection shall be made of each empty drum or box prior to loading in the vehicle to ensure its, integrity (radioactive waste truck surveys shall be performed before and aC:er loading of the radioactive material as applicable - common carriers are exempt from surveys.).
5.2.2. The truck shall be radiologically clean, i. e., no ;
measurable removable radioactivity above background !
level ,
l 5.2.2. All shipments of LSA and SCO material shall be consigned as exclusive use. The truck shall display I placards that state: " RADIOACTIVE." l 5. Shipping Papers (49 CFR 172.202) 1
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5.2. Shipping papers shall be prepared for all shipments of radioactive material, including waste, in accordance -
with the requirements of 49 CFR 172.202 and shall include the information referenced in Form RS-87, Radioactive Materials Shipment Papers, as appropriat .2.3. Determine that the intended recipient has a license on file at the NNRC. Specify the license number and the expiration date of the license on the shipping paper If a license is not on file, the radioactive material shall not be sen NOTE: For a waste shipment, the license of the Burial facility must be on fil .2.3. The license of the recipient shall be checked to ensure that possession of the radionuclide to be shipped is permissible and to ensure that the quantity of the radionuclide to be shipped is allowed by the licens .2.3. List the name and address of the shipment recipien .2.3. Each shipment of radioactive material shall have a unique numbe The number shall consist of five digits, the first two of which will represent the calendar year and the last three will represent the number of the shipment for the calendar yea .
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NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 8 of 21-EXAMPLE: Shipment #90-001 is the first shipment made during the calendar year, 199 ,
5.2.3.. 5 Determine the proper shipping r.ame and identification nutrber preceded by "UN" (49 CFR 172.101) using the assistance provided in Appendix A. Write the proper shipping name and identification number preceded by UN number on the appropriate blank of the shipping pape .2.3. Enter the physical and chemical forms of the material to be shipped on Form RS-8 .2.3. List the name and quantity of each radionuclide (49 CFR 173.435) in S.I. Units (e.g. TBq, Bq) for each packag .2.3. Specify the total quantity of radionuclides that are present in the entire shipmen .2.3. The category of label applied to each package, i. e.,
Radioactive White-I, Radioactive Yellow-II or Radioactive Yellow-III shall be specified on the shipping paper .2.3.1.10 The . Transport Index tradiation level in [(mSv/hr)x100 (mrem /hr) .at 1 meter) for each package bearing Radioactive Yellow-II or Radioactive Yellow-III label, shall be stated on the shipping papers and the two (2 label .2.3.1.11 For a package approved by the USNRC, a notation of t he ,
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package identification marking as prescribed in thi applicable USNRC approval shall be specified (ex. , Type B USA /5507/BF) (49 CFR 172.203 (d) (vii) and 173.471).
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5. Shipper's Certification (4 9 CFR 172. 204 )
5.2. The shipping papers shall contain a certificatial statement which attests to the fact that the materia: !
being offered for transport is ready for shipmen NOTE: The statement shall read: "This is tc certify that the above named materials are i
properly classified, described, packaged, marked and labeled, and are in proper )
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. Minor Change Procedure 9510 !
Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 9 of 21 condition for transportation according to the applicable regulations of the Department of Transportation (DOT)." !
5.2. For shipments being made by passenger-carrying, '
aircraft, in addition to the requirement for a T. of < 3, and the certification stacement specified in Step 5. 2. 4.1, an additional certification is required l which states:
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"I certify that this shipment contains !
radioactive material intended for use in, or incident to research, medical diagnosis or ,
treatment."
5.2. The certification statements required by Step 5.2. !
and/or Step 5.2.4.2 shall be signed by an appropriate l NNRC staff or management person, usually the Manager, Office of Radiation Safet . Marking of Packages (4 9 CFR 172. 3 01 and 172. 310)
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5.2. Each person who offers hazardous materials fo:
! transportation with a weight in excess of 50kg (lic pounds) shall mark each package, freight container anc transport vehicl .2. The markings required include proper shipping. name, j identification number preceded by "UN," gross weight, anc l
the Type of packaging, i. e., Type A or Type B.
l l 5. Labeling (4 9 CFR 172. 4 0 0)
5.2. No person may offer for transportation any package bearinc a hazardous material label unless the package actua113 contains the hazardous material specified on the labe '
5.2. Any material classified as radioactive material that alsc meets the definition of another hazard class shall be labeled as required for both hazard .2. The proper label for a package of non-fissile radioactive
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material is based on the radiation level at the surf ace of the package.
i 5.2. There are three categories of labels (49 CFR 172.403)
based on the level of radiation at the surface of the package:
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. Minor Change Procedure 9510 Number.: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: -/ / Page 10 of'21 5.2.6. White-I -
Radiation Level s 0.005 mSv/hr ( mrem /hr);
5.2.6. Yellow-II -
Radiation Level is > 0.005 mSv/hr ( mrem /hr) but s 0.5 mSv/hr (50 mrem /hr) ; and 5.2.6. Yellow-III - Radiation Level is > 0.5 .nSv/hr (50 mrem /hr) but 1 2 mSv/hr (200 mrem /hr).
NOTE: For fissile material, see 49 CFR 172.40 .2. The label specifications for each label type is specified in 49 CFR 172.436, 172.438 and 172.44 . Placarding (4 9 CFR .172. 5 00 )
5.2. No placard may be displayed on a vehicle unless the vehicle actually contains the hazardous material specified on the placar .2. The vehicle must be placarded on each end of the vehicle !
and on each side with a placard reading " RADIOACTIVE" l l
(only LSA and SCO, and Radioactive Yellow-III shipments, i
[4 9 CFR 172. 504) , Table 1 are required to be placarded) .
5.2. It is the responsibility of the shipper to provide the I placards and ensure that the placement on the shipment is correc If the carrier has placards, these may be use . Radiation Levels (49 CFR 173.441)
5.2. Packages loaded for transport may not have radiation levels at any point on the surface of a package (contact .
dose rate readings) in excess of 2 mSv/hr (200 mrem /hr) !
and may not exceed 0.1 mSv/hr (10 mrem /hr) (T. I. = 10) at '
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one meter from the package unless the packages are transported in an exclusive use, closed transport vehicl .2. Use of a closed, exclusive vehicle permits transportation of packages with radiation levels up to 10 mSv/hr (1000 mrem /hr) at the surface of the package provided that the package is secured within the vehicle so that it remains fixed during transport and provided there is no loading / unloading between the beginning and end of ,
transportatio !
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NEELY NUCLEAR RESEARCH CENTER ( , Minor Change Procedure 9510
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Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 11 of 21 5.2. In the case of the closed, exclusive use vehicle, radiation levels at the outer surface of the vehicle l
may not exceed 2 mSv/hr (200 mrem /hr) (including both ;
i top and bottom of the vehicle) and the dose rate may'
l not exceed 0.10 mSv/hr (10 mrem /hr) at any point 2 l meterc from the outer lateral surfaces (excluding the top and bottom).
l l l 5.2. In addition to the above, the dose rate in any space which is normally occupied by personnel, i. e., the l cab of the truck shall be less than 0.02 mSv/hr I (2 mrem /hr) .
5.2. All radiation level readings for each package and exclusive-use vehicles shall be documented on Form RS-l 28, Miscellaneous Survey Form. Appropriate survey maps I shall be draw . Contamination Control (49 CFR 173.443)
l 5.2. Contamination control data shall be collected and documented using Form RS-28, Miscellaneous Survey ;
Form, to show where smears were take Actual count I data shall be documented on Form RS-35 (see attached
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5.2. The smear surveys taken shall be sufficient in number to demonstrate that each package was adequately l survcye Exclusive use vehicles shall be surveyed before anc after loadin :
5.2. Non-exclusive Use Vehicle 5.2.9. The level of removable contamination by smears from the external surface of each package shall not exceed )
0.41 Bq/cm2 (2200 dpm/100 cm2 ) for beta / gamma !
emitting radionuclides, radionuclides with half-lives
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less than ten days, and natural uranium / thoriu .2.9. For other alpha emitting radionuclides, the level of removable contamination by smears from the external surface of each package shall not exceed 0.04 Bq/cm (220 dpm/100 cm), 2 (
5.2. Exclusive Use Vehicle l
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- Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 12 of 21 5.2.9. When transporting via exclusive use vehicle, the permissible removable contamination at the beginning of transport may not exceed those levels specified in Step 5.2.9.3.1 and 5.2.9. .2.9.' At any time during transport, the removable'
contamination levels may not exceed ten times the levels specified in Step 5.2. .2.9.4.3' For vehicles used under the provisions of Step 5.2.9.4, a vehicle may not be returned to service until the dose rate at each accessible surf ace is less than 0.05 mSv/hr (5 mrem / hour) fixed contaminatio .2.9. Step 5.2.9.4.3 does nct apply when the enclosed, exclusive use vehicle is dedicated for the sole use of transportation of radioactive material by highwa In this situation, the vehicle must be stenciled with a sign that states: "For Radioactive Material Use only." RECORDS Forms RS-28, RS-35, RS-87 and RS-88 or equivalent shall be completed during the preparation of radioactive materials for transpor .2 A copy of Form RS-87, Radioactive Materials Shipping Papers, and the original of Form RS-88 or equivalent, Transportation Quality Assurance Checklist, shall be maintained for the life of the facility. Forms RS-28 and RS-35 which contain the survey data for the shipment shall be maintained along with the shipping papers for the life of the facilit . . . . _ . . _ -- . .- - . . . - . - . - . . - -
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Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 13 of 21 APPENDIX A ,
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PROPER NAME AND RELATED PARAMETERS .
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l RADIOACTIVE MATERIAL, N.O.S., UN 2982 Shipping name used when no other category is appropriate.
I Activity / package shall not exceed the A value for a Type
A package (4 9 CFR 173 . 4 3 5 ) .
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i l j RADIOACTIVE MATERIAL, EXCEPTED PACKAGE, N.O.S., UN2910 )
j Activity / package shall not exceed the limits specified in
- 49 CFR 173.423, Table 7
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Radiation Level <0.005 mSv/hr (< 0.5 mrem /hr) on package surface
! < 15 grams U-235/ package l Container shall be strong, tigh Excepted packages of instruments, articles, DU , Natural uranium, limited quantities and " empties".
! RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY, N.O.S., UN2912 l Radioactivity uniformly dispersed.
l Activity concentration shall not exceed that of Step i l 5.2.2.5.1 l ;
1 RADIOACTIVE MATERIAL, SPECIAL FORM, N.O.S. UN2974 Activity of special form material shall not exceed the "A3 value for a TYPE A packag . NOT CLASSIFIED AS RADIOACTIVE Activity is uniformly distribute Specific activity is c 70 Bq/g (0.002 pCi/g)
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- RADIOACTIVE MATERIAL, SURFACE CONTAMINATED OBJECT, SCO, UN 2 913
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See surface contamination definition 5.2.1.10
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RS-87 NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03
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By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 14 of 21 RADIOACTIVE MATERIAL SHIPPING PAPERS Neely Nuclear Research Center Georgia Institute of Technology 900 Atlantic Drive Atlanta, GA 30332 (404) 894-2500 (Georgia Tech Police)
Date NNRC Shipment N TO: Carrier:
Shipped Via:
Waybill No.:
PROPER SHIPPING NAME/ID NO.:
PRINCIPAL RADIONUCLIDES AND QUANTITIES:
PHYSICAL FORM : Solid Liquid Gas Weight CHEMICAL FORM:
Normal Form: Special Form: Limited Quantity TRANSPORT INDEX: PACKAGE TYPE (A/B/ STRONG, TIGHT)
(Excepted, Industrial I, II or III)
LABEL (S) APPLIED TO PACKAGE (S):
PLACARDS TENDERED: YES PO Radiation Surveys -
Surface of Inner Container mSv/hr Beta Gamma
- Surface of Outer Container mSv/hr Beta Gamma Smearable Contamination Outer Container Bq/cm2
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Beta / Gamma Alpha ;
1 CERTIFICATION -
This is to certify that the above named materials are l
properly classified, packages, described, marked and labeled & in proper l condition for transportation according to the applicable regulations of I the Department of Transportation. This shipment is within the limitation prescribed for passenger / cargo aircraft onl )
l Certified by: Date l Reviewed by: Date
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FORM RS-88 i NEELY NUCLEAR RESEARCH CENTER
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Minor Change Procedure 9510 *
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.By: Approved 4/11/96 Date: / / Page 15 of 21 i l Page 1 of 4 APPENDIX B [
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TRANSPORTATION QUALITY ASSURANCE CHECKLIST ;
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] Directions: All blanks shall be complete For those' i
- inscances in which a designated activity has been completed for the j
-, shipment under consideration, initial the blank to the right of the :
} statemen For those activities which are not performed for a * particular shipment, _ write N/A in the blank to the righ l
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- Date
- Shipment No.: i
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[ Intended Recipient license.is on file !
- Specify expiration date i
j Package provided inner linin l j LIMITED QUANTITY SHIPMENTS l i
i Strong, tight package Inner Lining marked " Radioactive" Step 5.2.2.5.5 Notice Enclosed in Package Removable Contamination Below Limits
< 0.41 Bq/cm2 (2200 dpm/100 cm') beta /gannna
< 0.04 Bq/cm2 (220 dpm/100 cm') alpha Direct Radiation < 0.005 mSv/hr (0.5 mram/hr)
external surface LOW SPECIFIC ACTIM h OR SURFACE CONTAMINATED OBJECTS
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SHIPMENTS
- DOT Specification 7A, TYPE A package or Industrial Package if not exclusive use vehicle Strong, tight package if exclusive use vehicle Removable Contamination Below Limits
< 0.41 Bq/cm2 (2200 dpm/100 cm') beta / gamma
< 0.04 Bq/cm2 (220 dpm/100 cm') alpha . _ _ _ _ _ _ _ _ _
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Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 16 of 21 Form RS-88, page 2 of 4 External Radiation levels <2 mSv/hr (200 mrem /hr)
at 1 meter (for non-exclusive use vehicle) T. I. s 10 [(0.1 mSv/hr) x 100] or (10 mram/hr)
NOTE: A T.I. = ((msv/hr) X 100) at 1 muter For closed, exclusive use vehicle, see 49 CFR 173.441 Shipment loaded by Consignor or contractor Exterior of each package marked:
" RADIOACTIVE - LSA" or " RADIOACTIVE -SCO" Visual inspection of package - intact Vehicle " clean" (no smearable activity) Shipment braced to prevent movement Placards applied to truck " RADIOACTIVE" PREPARATION OF SHIPPING PAPERS Name & address of shipper affixed Name & address of recipient affixed ;
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' Proper Shipping Name Identified (see Appendix A) Special/ Normal form identified Physical form identified i
! Major Nuclides & Quantity (Bq (mci)] listed j l List Label applied to each package l i T. for each package specified ; If USNRC approved package, specify approval Certification completed ,
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Minor Change Procedure 9510 Number: Revision 03 ,
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By: EADINATIVEN.P]G2iT Approved 4/11/96
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Date: / / Page 17 of 21
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- Form RS-88, page 3 of 4
' If placards tendered, indicate on papers !
i 6. ' LABELING l ,
l More than Radioactive Hazard '
l Radioactive White - I
- Radioactive yellow - II {
. i i Radioactive yellow - III {
i l " Radioactive" - Outside Inner Package for Ltd Qty-
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! PLACARDS TENDERED - LSA, SCO AND RADIOACTIVE YELLOW - III ,
' RADIATION / CONTAMINATION SURVEYS COMPLETE PACKAGE MARKINGS: (On Outside of Package) Type of Package ( A/B ) ) Type A (> 13 mm (1/2") high) : Name & Addreas of Consignee or Consignor
- Proper Shipping Name, # (UN #) ,
l Gross weight if > 50 kg (110 lbs) If liquid present: "This End UP" With dry ice present: "ORM-A" on one side below proper shipping nam ) OTHER LABELS AS REQUIRED
" CARGO AIRCRAFT ONLY" (if > 3.0)
" CORROSIVE" (nitric acid solutions of UF)
" OXIDIZER" (Reg 173.419) (solid U or Th nitrates)
"PYROPHORIC" (Reg 173.418)
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Minor Change Procedure 9510 Number: Revision 03
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l By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 i Date: / / Page 18 of 21 Form RS-88,.page 4 of 4 l OTHER REQUIREMENTS:
i Security Seal (s) Type & N Absorbent material for liquids (2x volume capacity)
T. < 3.0 for passenger aircraft and
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following statement included: "This l shipment contains radioactive material intended for use in, or incident to, research, medical diagnosis or treatment."
T. >3.0 for cargo aircraft only and " CARGO AIRCRAFT ONLY" label applied to package.
l For air shipment, send 2 copies of shipping papers l
Vehicle placarded (if Radioactive Yellow-III l SCO or LSA) - Check " Placards Tendered" on the shipping papers.
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Notify Police Department that package has been shipped and give details of shipment.
l Prepared by: Date:
Reviewed by: Date:
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NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 19 of 21 APPENDIX C GEORGIA INSrirurs OF TECHNOLOGY NEELY NUCLEAR RESEARCH CENTER ,
900 ATLANTIC DRIVE ATLANTA, GA 30332 (404) 894-2500 (Georcia Tech Police)
"This package conforms to the conditions and limitations specified in 49 CFR 173.421 for excepted radioactive material, limited quantity, n . o . s . , UN 2 910 ; or 4 9 CFR 173 . 4 24 for excepted radioactive material, instruments and articles."
LIMITED QUANTITY SHIPMENT
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NEELY NUCLEAR RESEARCH CENTER
Minor Change '
Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 20 of 21 RS-28 MISCELLANEOUS SURVEY MAP FORM DATE TIME RWP #
SURVEY SERIAL # CAL DUE-INS l l
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COMMENTS PERFORMED BY: DATE REVIEWED BY: DATE I
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. NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510
Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 21 of 21 RS-35 (5-90) SURVEY DATA SHEET Job Descriotion Power Level Date Time Counter Used Alpha Efficiency Bkg .
Cal Due Date Beta Efficiency Bkg Survey Inst Model Serial # Cal Due Date Background Location Smear Resmear dpm/100 cm2 dpm/100 cm2 mR/hr cpm aloha beta /camma aloha beta /camma
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Comments:
Performed by: _ Date:
Reviewed by: Date:
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