ML20057D450

Informs That on 930920,set of Liquid Std Samples Shipped to B Hart of Univ of Western Ontario Instead of Geological Samples.No Formal Procedure Exists for Shipping of Radioactive Matl.Draft Procedure Encl

ML20057D450
Person / Time
Site:	University of Illinois
Issue date:	09/28/1993
From:	Holm R ILLINOIS, UNIV. OF, URBANA, IL
To:	Cox C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 9310040230
Download: ML20057D450 (8)

Text

r Univ 0rsity cf Illinois at Urbana-Chrmpaign i

Nucl r R ctor Labors.ttry j

Department of Nuclear Eng6neering / Col;ege of Engineering 4

' 214 Nuclear Engineering Laboratory 217-333-7755/0866 103 South Goodwin Avenue 217-333-2906 fax Urbana,IL 61801 i

September 28,1993 Docket No. 50-151 Mr. Charles Cox Region 111 U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Cox,

At approximately 0830 on Monday, September 27.1993 Brian Hart of the University of Western Ontario called to inform us that the set of samples that we shipped to him on 9/20/93 by Federal Express were not his samples. He had mistakenly been sent a set of liquid standard samples instead of the geological samples we had irradiated for him. The shipment was analyzed by gamma spectroscopy and the isotopes identified prior to shipping, but due to the variance in some of the previous samples the differences from prior analysis were not considered significant. The shipping papers were correct except for the listing of the physical form as " geological samples in solid form" when in fact they were liquid standard samples. The shipping container used was a double encapsulated US DOT 7A Type A so the requirements for shipping liquids were met. All nuclide, radioactivity and radiation lesels listed were also correct. The samples that should have been sent are still present in the building.

At approximately 1030 I placed a courtesy call to Jim McCormick-Barger at Region 111 and relayed the above information to him.

ROOT CAUSE When samples are retrieved from an irradiation facility they are placed in a wooden rack and stored in a lead cave for decay while still in the TRIGA irradiation vials.

During this period the box the sample vials are in has no indication of what the samples are, the sample identification card is on a status board in the control room showing where the samples are located.

No formal procedure exists for shipping of radioacti se material.

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9 CORRECTIVE ACTLON Each set of samples to be stored for decay in TRIGA vials will have a radioactive material sticker placed on the rack that identifies the sansples and the date and time irradiated.

A draft procedure for shipping of radioactive material is included with this report.

At this point in time it would appear that we may be in violation of the DOT and IATA shipping regulation regarding the description of the physical form entered on the Shippers Declaration for Dangerous Goods. If there are any questions please call me at 217-333-7755.

Respectfully, l

4 Richard L. Holm Reactor Supervisor Enc.

cc: B. Jones, Head Department of Nuclear Engineering J. McCormick-Barger, USNRC - Region 111 i

A. Adams. USNRC File I

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Draft University of Illinois Nuclear Reactor Laboratory NRLilPP-13 Rev. Date: 9/93

Title:

Transportation of Radioactive Material On and Off Campus.

Periodicity: Whenever samples are prepared for delivery.

Required By: Campus " Radiation Safety Manual."

Department of Transportation (DOT) Regulations 49 CFR 171 & 173.

International Air Transport Association (IATA) Dangerous Goods Regulations.

Comments: This procedure does not attempt to recreate all the requirements of the above listed documents.

Only those individuals who have been trained in accordance with 10 CFR 71.5; which requires NRC licensees to comply with DOT's hazardous material regulations codified at 49 CFR Part 172, Subpart 11, Sections 172.700-172.704, "llazardous Material Employee Training"; may prepare or ship samples Off Campes. On Campus shipments may be prepared and delivered by the Reactor 11ealth Physicist, Reactor 11ealth Physicist Assistant, or the Reactor Supervisor. No other individuals are allowed to release radioactive material from this laboratory.

Procedure:

All Irradiated Sample Unloading Verify with a reactor operator that the reactor is shutdown and < 8 kW for unloading samples from the Lazy Susan Rotating Specimen Rack (LS) and < lkW for unloading a sample from the Central Thimble (CT). The Neutron Activation Tube (NAT) and the Cadmium Lined Neutron Activation Tube (CLNAT) may be unloaded immediately after verifying that the reactor is shutdown. After unloading the NAT or CLNAT ensure that the trap door covering the open position in the core is closed and locked.

1. LS Unloading: ensure that the motor driving the rotation is shutoff and the sample position indicator is at Position 1. Verify the number of samples to be unloaded by retrieving the " Sample Certification Card" from the " Irradiation Facilities Status Board" and place the vial labeled "Stop Here" at the very next position.

Open the door to the main cave. Turn on a portable ion Chamber and locate it near the unloading bin, don rubber gloves, then unload the samples into a wooden sample holding box. Remove rubber gloves and dispose in the radioactive waste container labeled " gloves only." When all the samples have been unloaded check the dose rate on the closed box, place a radioactive material sticker on the box indicating when the samples were irradiated, to whom they belong, including the irradiation request authorization number and the dose rate, then place them in the main cave for decay. Close the door to the cave. Check the dose rate on the cave exterior.

2. CT Unloading: obtain the key to the CT lock from the key locker in the Control Room. Verify the sample to be unloaded by retrieving the " Sample Certification Card" from the " Irradiation Facilities Status Board."

Proceed as above with the exception that the sample shall be held for decay in one of the lead pigs located on the reactor top instead of in the main cave. In addition, it is not advisable to place a radioactive material sticker on a " hot" sample that is also contaminated, so place it on the exterior of the lead pig that the sample is stored in. Lock the CT and return the key to the key locker.

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3. NAT & CLNAT Unloading: obtain the key as noted above and remove the appropriate tube from the core, i

dose and lock the trap door, and lock the lock on the rotating shaft mechanism. Without gloves, remove the lid on the device. Don rubber gloves, turn on an Ion Chamber and locate appropriately, then remove the sample td the sample preparation table. Remove the sample from the aluminum wire and place the sample in a clean plastic bag and the wire in its holding bin. Take a dose rate on the sample and label accordingly with a radioactive material sticker and place the sample in one of the " Rectangular Caves" for decay.

ti On Campus Irradiated Samole PrerAration l

A. PREREOUISITES

1. A current authorization in the form of a Radiation Permit issued by the UIUC Radiation 11azards Committee to allow the receipt and possession of the material that the user wishes to procure from the reactor. This permit will also indicate the maximum activities releasable per radionuclide.

2. A completed TRIGA Reactor " Irradiation Request" that specifies the target material type and quantity, along with the conditions of the irradiation. This request must be approved by the Reactor Supervisor and the Health Physicist prior to the irradiation of any sample (s).

3. A completed " Sample Certification Form," submitted with the sample (s), verifying that it is of the type and quantity approved on the " Irradiation Request."

4. A transportation container that is appropriate for the level of activity associated with the samples upon release from the reactor building and which will result in an external contact exposure rate of < 200 mR/hr at contact.

a) Ensure that you have retrieved the " Sample Certification Form" (see attachment) for the samples you intend to prepare and deliver, or ship, from either the " Irradiation Facilities Status Board" or the " Reactor-Top Sample Storage Status Board." Fill in the appropriate information in the "Irrad. Date" and "Irrad. Time" blocks by obtaining that information from the Reactor Operator's Logbook.

i b) Verify the location and the number of samples you are preparing, retrieve the samples and check the dose rate with an lon Chamber. Be sure that you know what the expected dose rate should be for that type of i

sample. Don rubber gloves and unload the sampies in the sample preparation area on the desk at tile Reactor Top.

c) Remove one glove and, while holding a clean open plastic bag over the contaminated side of the table and using the long-handled tweezers, cmmt the number of samoles as you place them into the bag. Visually check the samples to verify that they are of the type you should be preparing, i.e., geologicals look dark while liquid samples look clear.

d) Remove the other glove and dispose in the appropriate container, close the bag and take it to the Truck Bay frisking area to resurvey. Take an alcohol soaked smear on the exterior of the bag and count on the RM-2 14/ lip 210T to verify that the contamination is < 1000dpm/cm. Label the bag with radioactive material tape and take an open and closed window reading, with an lon Chamber, at contact and one foot. Record this i

information on a radioactive material sticker along, with the prospective isotopes and sample authorization number, and affix the sticker to the bag such that it will have to be removed for the bag to be opened. If the sample is for shipment off campus also take a smear on the sample exteriors inside the bag and calculate removable beta / gamma and alpha activity on the BC-4 and SAC-4 respectively.

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e) Complete all the information requested within the boxed in areas of the " Sample Certification Form."

Ensura that the individual picking up the sample (s) signs, dates, and indicates the time that the samples were received. 'For on campus deliveries also complete a Health Physics Office (H.P.O.) " Radioactive Materials

. Receipt Record Notification of Shipment" (attachment) and notify the invest: gator that their sample is ready.

Record the inventory (1) number on this form also if the HPO has issued one for this type of irradiation.

j Ensure that their Radiation Permit allow:, them to have that isotope, at that activity, and verify that they are l

wearing their personal dosimetry when they arrive to pick up the sample. Place the sample in the appropriate transport container and resurvey for contamination if necessary. Take a contact reading on the container and i

verify that it is < 200 mR/hr. When either or both forms have been completed, distribute the copies as follows:

i.) One copy to the person receiving samples.

ii.) One copy to the health physics file.

iii.) One copy tc the HPO.

P Off Campus irradiated Sampre Preparation 1

A. PREREOUISITES

1. A completed TRIGA Reactor " Irradiation Request" that specifies the target material type and quantity, 1

along with the conditions of the irradiation. This request must be approved by the Reactor Supervisor and the Reactor Health Physicist prior to the irradiation of any sample (s).

2. A completed " Sample Certification Form," submitted with the sample (s), verifying that it is of the type and quantity approved on the " Irradiation Request."

3. Obtain a letter verifying the existence of a radioactive material license wat includes the isotopes in the quantity to be sent (or a copy of the license), license number, and expiration date from the licensee to whom the material is being shipped.

4. A transportation container which is appropriate for the level of activity associated with the samples upon release from the reactor building and which will comply with the packaging and labeling requirements of i

49 CFR and IATA.

5. For Off Campus Domestic ship'ments prepare in accordance with 49 CFR. For International shipments prepare in accordance with the IATA Dangerous Goods Regulations. Be sure that the statement "this shipment contains radioactive material intended for use in, or incident to, research, medical diagnosis or treatment" appears on the Air Waybill or Shippers Declaration Of Dangerous Goods if the package qualifies for shipment on passenger aircraft.

a) Perform a Gamma Spectroscopy analysis of the samples and using the gamma ray constants from the 1993 Radiological and Health Physics Handbook apportion the activity as appropriate to the isotopes identified.

b) Package the samples in the appropriate container and survey for dose rates using an lon Chamber. Use a Geiger-Mueller Tube to obtain the one meter dose rate if required. Label according to the DOT or IATA Reguhtions, as appropriate. Smear survey the exterior of all containers. Complete and copy survey forms, gamma spectroscopy analysis, and Declaration For Dangerous Goods and/or Shipping Company's Waybill and include in Type A or other package before sealing with Security Label, as appropriate.

References:

1. U.S. Nuclear Regulatory Commission, Title 10, Chapter 1, Code of Federal Regulations, Part 71,

" Packaging and Transportation of Radioactive Material," A. gust 30,1991.

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2. U.S. Department of Transportation, Title 49, Chapter 1, Code of Federal Regulations, Part 173, Subpart

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I--Radioactive Materials, Revised Edition, October 1,1986.

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3. U.S. Department of Transportation, Materials Transportation Bureau, Office of llazardous Materials Operations, "A Review of the Department of Transportation (DOT) Regulations for Transportation of Radioactive Materials," October 1977.

4. U.S. Department of Energy, " DOE Evaluation Document for DOT 7A Type A Packaging," MLM-3245,'

DOE /DP/00053-lil, March 1987.

5. International Air Transport Association, " Dangerous Goods Regulations," 4th Edition, January 1993.

6. The llealth Physics and Radiological Health llandbook, Revised Edition, edited by Bernard Shleien, Scinta, inc.,1992.

Written By:

Reviewed By:

Date Approved by Reactor Committee:

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RADIOACTIVE MATERIALS RE CO RD P.

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(To be posted at the Reactor Top sample Preparation Area)

' Sample Removal & Preparation Reminders

1. Always verify that the Reactor is Shutdown and < 8 kW to unload j

the LS and < IkW for the CT.

2. Label all Samples, placed in storage caves or pigs for decay.

3. Verify that the CT and NAT devices are locked before and after loading or unloading samples.

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4. Retrieve the " Sample Certification" card from the " Irradiation Facilities Status Board" or the " Reactor Top Sample Storage Status Board."

5. Fill in the appropriate information in the "Irrad. Date" and "Irrad. Time" blocks.

8. Verify the location and the number of samples you are preparing.

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7. Always count the number of samples you are preparing to deliver or ship and verify this against the " Sample Certification" card.

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8. Visually check. that the samples are the right type, i.e., geologicals look dark while liquid samples look clear.

9. Retrieve the samples and check the dose rate with an Ion Chamber.

l Be sure that you know what the expected dose rate should be for that type of sample.

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10. Don rubber gloves and unload the samples in the sample preparation area on the desk at the Reactor Top.

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