ML20065P635

Responds to NRC Re Violations Noted During Insp of License R-103 on 900815-1001.Corrective Actions:Surveying Requirements Reviewed W/Health Physics & Shipping Personnel Including Trainees

ML20065P635
Person / Time
Site:	University of Missouri-Columbia
Issue date:	12/07/1990
From:	Gunn S, Mckibben J, Reilly W MISSOURI, UNIV. OF, ROLLA, MO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9012130391
Download: ML20065P635 (3)

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Research Reactor Facmty k$CWCIIhMk Colomina M4soon (Mt1 UNIVERSITY OF MISSOURI COLUMBIA keP'y ydyQ Decemler 7,1990 U.S Nuclear Regulatory Commission Woshington, DC 20555 A1TENTION: Document Controf Desk

REFERENCE:

Docket 50-186 University of hilssouri Research Reactor License R 103 SUl4ECT: Reply to Notice of Violation, as per 10 CFR 2.201.

Dear Sir:

This is the written statement required by the provisions of 10 CFR 2.201 in response to the Notice of Violation in your letter dated Octoter 10,1990 concerning the August 15 through Octoter 1,1990 inspection of the University of hilssouri Research Reactor (hiURR). NRC Region til granted a 30-day extension in the required filing deadline. The violations were identified as the following:

i. 10 CTR 71.87t]) requires that prior to each shiprnent of licensed rnalerial, the licensee deterrnine that external radiation levels around the package will not extred the lirnits specified in 10 CTR 71.47 at any tirne during transportation.

10 CTR 71.47 requires, in part, that radiation levels not exceed certain litnits at any point on the external surface of the package.

Contrary to the above, on August 8,1990, prior to a shiprnent of licensed unatcrial containing 9.72 curies of antirnony-124, the licensee did not deterrnine that external radiation levels around the package would not exceed the livnits specified in 10 CTR 7147 at any tirne during transportation. Specifically, the licensee did not perforrn a radiation survey of the bottorn of the paclage prior to shiprnent.

The licensee acknowkdges a failure to perform a radiation survey of the bottom of the package prior to shipment occurred on Au, gust 8,1990. This failure was caused by a combination of training and communication errors which have subsequently been corrected.

Radioactive shipments are packaged in accordance with detailed QA check sheets that are part of an appcoved 10 CFR ?! Subpart H Quality Assurance program. Completion of the check sheet for each shipnent is used to document compliance with 10 CFR part 71, and 49 CFR parts 172 and 173 for packag.ng, marking. labeling, placarding, monitoring and shipping papers by certified shippers.

Shippin), personnel at hiURR are in training for six to nine months prior to being certified to sign the release paoers for hiURR shipments. Surveys of shipments are performed in accordance with Health Physics procedure 1IP-16 Rev.12. Technicians are qualified to perform IIP 16 before they are certified to sign release papers for hiURR shipments.

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The shipment in question was properly packaged in accordance with the appropriate QA check sheet,

. The shipment in question was surveyed by a technician who was approved to perform HP 16, but not I certified to sign for release of shipments. '!he certified shipper reviewed all paperwork and d.'scussed the radiation survey with the technician prior to signing the release for the shipment, but failed to question the technician atout the dor.e rate on the lettom of the cask. A Health Physics Technician ,

also discussed the radiation survey with the technician prior to surveying the exclusive use vehicle. I The vehicle was surveyed directly under the cask by a llealth Physics Technician and wu found to read less than 200 millirem per hour on contact with the vehicle.

The following corrective action was taken to prevent future violations: I immediate

+ Shipping }wrsonnel were instructed to record on the QA check rheet readings taken on the top, tettom and sides of the package. This was in effect for the next type B shipment on August 13,1990.

• Curveying requirements were reviewed with all health physics and shipping personnel, inchiding trainees.

LongTemt

• A revised survey (heck sheet was implemented on October 1,1990. The form includes spaces to record the survey readings taken on the top, bottom and sides of the package. This fonn is included with the shipping documents.

• Future training will stress the importance of surveying all surfaces including the bottom of shipping containers.

The University of Missouri has been in full compliance since August 13,1990 and has completed all stated corrective action,

11. 10 CTR 71.47 requires that a package be prepared for shiprnent so that the radiation level does not exceed 200 rnillitern per hour at any point on the external surface of the package and the transport index does not exceed 10 unless it is shipped as exclusive use by highway. Exclusive use, as defined in 10 CFR /1.4, uncans the sole use of a conveyance by a single consignor and for which all initial, interrnediate, and final loading and unloading are carried out in accordance with the direction of the consignor or consignee.

Contrary to th? above, on August 8,1990, a package containing 9.72 curies of antirnony 124 was prepared by the licenser for shiprnent and shipped by highway, and the radiation level exceeded 200 unillisern per hour on the criernal surface of the package and the transport index exceeded 10. Specifically, radiation levels of 340 and 1000 unillivern per hour were rneasured on the external surface of the package and the transport index was 17.S. Elecause the vehicle containcJ packages frorn another consignor, the shiprnent was not exclusive use.

The licensee acknowledges the fact that the vehicle contained packages from another consignor.

It was known in advance that this shipment would exceed 200 millirem on the external surface of the package and an exclusive use shipment was scheduled. Associated Couriers informed us that the vehicle would contain a consignment of computer paper, but assured us that we would be the sole user from the time it left our loading dock until it was unloaded by our consignee. At this point, reference was made to 10 CFR 71 A7 to determine if it was acwptable for the conveyance to contain another package.

Pak,e ;, of 3 l

l The measured radiation levels and the transport index of 17.8 met the 10 CPR 71.47 requirements for  ;

exclusive use. With the understanding that the ninveyance would tv under our exclusive control during  !

allinitial, intermediate and finalloading and unloading, we detennined that this thipment met the requirements for exclusive use The vehicle was scakd prior to leaving our loading dock to insure no intermediate stops were made. The seals were intact when the vehicle arrived at its destination.

As noted on page 12 of NRC Report No. 50-186/90-Ol(DPR) dated October 5,1990,"Ihe root cause of this violation is personnel error through a rnisinterpretation of the regulations."

The following corrective action was taken to prevent future violations:

Immediate

• Shipping personnel were instructed to ensure that no other con .ignments are in a vehicle usal for exclusive use.

• '!he 10 CFR 71.4 definition of exclusive use was reviewed with all shipping personnel.

• Shipping personnel were cautioned to always check the definitions for phrases that modify or add to tristructions in the regulations.

• All the above actions were completed by August 16,1990 when the last shipper returnal from vacation and prior to any further exclusive use shipments.

longterm

• The importance of definitions will be stressed in future training.

The University of Missouri is now in full compliance and has completed all stated corrective action.

Sinceryly,

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Stephen L Cunn Reactor Service Engineer Endorsement: r' /)

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4N William F. Reilly J. Charles McKibben Assistant Directos, Fiscal /Reacto Services Associate Director xc: Reactor Advisory Committee Reactor Safety Subcommittee NRC Region !!!

STATE OF MISSOURI)

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COUNTY OF BOONE )

I hereby certify that J. Charles McKibben. Associate Director, signed the foregoing to the best of his knowledge anc, . lief, on this 7th day of December, 1990.

S .d19.2 Notary Public

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My commbs;on e,pg %bharon Wen My Commission expirest 2-21-90 8Nno County, f,%j 4

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