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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20212L0711999-10-0505 October 1999 Ack Receipt of ,Which Transmitted Changes to Oregan State Univ Triga Reactor Physical Secuirty Plan.Based on Determination That Changes Do Not Decrease Effectiveness of Security Plan,Nrc Approval Not Required ML20211B2711999-08-17017 August 1999 Forwards Revs & Updates to OSTR Physical Security Plan,Iaw Provisions of 10CFR50.54(p).Safeguards Effectiveness of Plan Is Not Reduced by Adoption of Changes.Encl Withheld,Per 10CFR2.790(d) ML20210S1501999-08-12012 August 1999 Ack Receipt of Which Transmitted Changes to Oregon State University Triga Reactor Physical Security Plan Submitted Under Provisions of 10CFR50.54(p) ML20210G3491999-07-28028 July 1999 Forwards Copy of Results of Operator Initial Exam Conducted at Oregon State Univ on 990628 ML20212J0381999-06-21021 June 1999 Informs That SA Crail,License OP-70160,will Resign Position on 990630.Termination of License Requested ML20207H1151999-06-0909 June 1999 Ack Receipt of ,Which Transmitted Changes to Oregon State Univ Triga Reactor Physical Security Plan Submitted Under Provisions of 10CFR50.54(p) ML20207F6071999-06-0707 June 1999 Forwards Insp Rept 50-243/99-201 on 990510-13.No Violations Noted.Insp Consisted of Selective Exams of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20207F6201999-06-0202 June 1999 Sixth Partial Response to FOIA Request for Documents.Records in App J Encl & Will Be Available in Pdr.App K Records Withheld in Part (Ref FOIA Exemptions 7) & App L Records Completely Withheld (Ref FOIA Exemption 7) ML20206F3051999-04-29029 April 1999 Forwards De/Nrc Forms 742, Matl Balance Rept & 742C, Physical Inventory Listing for Special Nuclear Matl for Reporting Period 981001-990331.DOE/NRC Form 241, Nuclear Transmission Rept Also Encl.Without Encls ML20206B6621999-04-20020 April 1999 Informs of Violation of Provisions of OSTR Physical Security Plan.Revs & Updates to Licensee Physical Security Plan,Encl Per 10CFR50.54(p).Details of Violation & Revs to Plan, Withheld IAW 10CFR2.790(d) ML20205Q6671999-04-16016 April 1999 Informs That Written & Operating Exams Scheduled for Wk of 990628.Matls Listed in Encl 1 Requested in Order to Meet Schedule ML20205K4211999-04-0606 April 1999 Informs That Federal Government Funding for Conversion of OSTR from HEU to LEU Cannot Be Certified & No Further Action to Be Taken at Present Time ML20205D7971999-03-30030 March 1999 Ack Receipt of ,Which Transmitted Changes to Oregon State Univ Triga Reactor Emergency Response Plan Submitted Under Provisions of 10CFR50.54(q).Based on Info Provided,Nrc Approval Not Required ML20204F4181999-03-0505 March 1999 Reports Recent Incident in Which Violation of 10CFR74.13(a)(1),occurred.Failure to Submit Matl Balance Rept by Deadline of Oct 30.Importance & Specific Details of Regulatory Deadlines Emphasized,Reviewed & Clarified ML20206R9601999-01-20020 January 1999 Ack Receipt of Which Transmitted Changes to Osu Triga Reactor Physical Security Plan,Per Provisions of 10CFR50.54(p).No NRC Approval Is Required Since Changes Do Not Decrease Effectiveness of Plan ML20199E8581999-01-12012 January 1999 Informs That SRO License SOP-50284-1,of Jf Higginbotham, Became Inactive on 981231 Due to Individual Not Meeting Operational Requirements of OSTR Requalification Plan During 1998 ML20202E1501999-01-11011 January 1999 Forwards Revised Osu Radiation Ctr & Triga Reactor Emergency Response Plan, Per 10CFR50.54(q).Changes Do Not Reduce Emergency Response Effectiveness,Based on Evaluations ML20206R6871999-01-0808 January 1999 Ack Receipt of ,Which Transmitted Changes to Oregan State Univ Triga Reactor Emergency Response Plan. NRC Approval Not Required,Based on Determination That Changes Do Not Decrease Effectiveness of EP ML20198Q8121999-01-0404 January 1999 Forwards Insp Rept 50-243/98-202 on 981130-1203.No Violations Noted.Various Aspects of Safety Program Were Inspected Including Selective Exams of Procedures & Representative Records & Interview with Personnel ML20195B6471998-11-10010 November 1998 Forwards Amend 17 to License R-106 & Safety Evaluation. Amend Clarifies TS 3.8.e Requirements on Quantity & Type of Radioactive Matl Allowed in Experiments ML20155E8011998-10-23023 October 1998 Forwards Annual Rept of or State Univ Radiation Ctr & Triga Reactor for 970701-980630 ML20154G8391998-10-0707 October 1998 Requests That Mailing Address Be Corrected as Listed ML20154B6441998-10-0101 October 1998 Ack Receipt of Ltr Dtd 980807,which Transmitted Changes to Oregon State Univ Triga Reactor Physical Security Plan Submitted Under Provisions of 10CFR50.54(p).NRC Approval Not Required in Accordance with 10CFR50.54(p) ML20154D4321998-09-30030 September 1998 Responds to RAI on 980727 Application for Proposed Amend to TS 3.8.e.Notification of Changes to Personnel Shown in Organization Chart of TS 6.7.c.3,also Provided ML20153C5421998-09-18018 September 1998 Ack Receipt of ,Which Transmitted Changes to Oregon State Univ Triga Reactor Physical Security Plan Submitted Under Provisions of 10CFR50.54(p) ML20151X9571998-09-15015 September 1998 Forwards RAI Re Amend Request for Amended License R-106 for Oregon State Univ Triga Research Reactor,Submitted on 980727.Response Requested within 30 Days of Ltr Date ML20237D1891998-08-0707 August 1998 Forwards Revs & Updates to OSTR Physical Security Plan IAW 10CFR50.54(p).Licensee Concludes That Effectiveness of OSTR Program Is Not Reduced by Adoption of Changes.Encl Withheld Per 10CFR2.790 ML20236X7401998-07-31031 July 1998 Discusses Insp Rept 50-243/98-201 on 980218-20,0506 & 11-13 & Forwards Nov.Insp Was follow-up on 980217 Event Involving Operation of Triga Mark-II Reactor W/O TS Required Scrams Being Operable ML20249C4561998-06-24024 June 1998 Responds to NRC Re Violations Noted in Insp Rept 50-243/98-201.Licensee Requests That NRC Refrain from Issuing Civil Penalty & NOV Due to Noted Reasons ML20249C7691998-06-19019 June 1998 Informs of Discovery of Error in Analyzer Efficiency Calculation in Gaseous Effluent Data in 1996-97 OSTR Annual Rept.Corrected Data Will Be Reported in 1997-98 OSTR Annual Rept.Corrected Table V.B.2 Encl ML20249B8041998-06-19019 June 1998 Forwards Insp Rept 50-243/98-201 on 980218-20 & 0506 & 11-13.Two Apparant Violations Identified & Being Considered for Escalated Enforcement Action ML20216F5101998-04-0808 April 1998 Forwards Certificates to Na Carstens & Gm Wachs,New Licensed Individuals at Oregon State Univ ML20216F2821998-04-0808 April 1998 Forwards License Certificates for Na Carstens & Gm Wachs. W/O Encl ML20217E9601998-03-24024 March 1998 Forwards Copy of Results of Operator Initial Exam Conducted at Oregon State Univ on 980303-04.W/o Encl ML20217Q3481998-03-0606 March 1998 Submits Formal Comments on Written Exam Conducted at Facility on 980303 for G Wachs & N Carstens ML20217P2571998-03-0303 March 1998 Informs That Federal Government Funding for Conversion of OSTR from HEU to LEU Cannot Be Certified.No Further Action Towards Conversion Will Be Taken at This Time.Ltr from DOE, Encl ML20203D5631998-02-20020 February 1998 Forwards Revisions & Updates to OSTR Physical Security Plan IAW 10CFR50.54(p).Encl Withheld ML20236K7071998-02-17017 February 1998 Responds to 980217 Telcon Re Licensee Performing Full Investigation to Find Most Basic Root Cause of Failure to Scram on Demand Which Occurred on 980217 ML20199F9671998-01-28028 January 1998 Forwards Amend 16 to License R-106 & Safety Evaluation. Amend Removes gender-specific Wording from TS 6.1a,updates Organizational Titles in TS 6.1 & Removes References to Region V from TS Reporting Requirements ML20199A5651998-01-21021 January 1998 Forwards Original & 3 Copies of Summary of Paper Regulatory View of Non-Power Reactor License Renewal, to Be Presented at 1998 ANS Annual Meeting.W/O Encl ML20198K3081997-12-29029 December 1997 Submits Formal Rept of Changes IAW 10CFR50.54(q),as Result of Annual Review of OSTR Emergency Response Plan Completed on 971219 ML20198G3751997-12-24024 December 1997 Informs That Written & Operating Exams Are Scheduled for 980223.Matls Listed in Encl Requested to Be Furnished in Order to Meet Schedule ML20197H9001997-12-19019 December 1997 Responds to RAI Re Proposed Amends to OSTR Ts.Replacement Pages to Amends Proposed in ,Encl.Changes to Personnel Shown in Encl Organization Chart of OSTR Ts,Per TS 6.7.c.3,noted ML20197K0111997-12-10010 December 1997 Forwards RAI Re Amend Request for License R-106 for Oregon State Univ Research Reactor,Submitted on 971125 ML20212D4491997-10-27027 October 1997 Forwards Annual Rept of Oregon State Univ Radiation Ctr & Triga Reactor,960701-970630 ML20212B0161997-10-16016 October 1997 Forwards Corrections Made in Pen & Ink on Attached NRC Form 741 for 970912 Submittal ML20217N4691997-08-20020 August 1997 Submits Revs & Updates to or State Univ Triga Physical Security Plan,Iaw Provisions of 10CFR50.54(p).Plan Withheld ML20149D5341997-07-11011 July 1997 Provides Notification of Changes to Personnel Shown in Organizational Chart of OSTR Triga Reactor TS as Required by T.S.6.7.c.3 ML20149E8241997-07-10010 July 1997 Ack Receipt of Transmitting Changes to OSTR Emergency Response Plan Submitted Under 10CFR50.54(q).NRC Approval Not Required ML20138H5981997-05-0202 May 1997 Forwards Insp Rept 50-243/97-01 on 970317-20.No Violations Noted 1999-08-17
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20211B2711999-08-17017 August 1999 Forwards Revs & Updates to OSTR Physical Security Plan,Iaw Provisions of 10CFR50.54(p).Safeguards Effectiveness of Plan Is Not Reduced by Adoption of Changes.Encl Withheld,Per 10CFR2.790(d) ML20212J0381999-06-21021 June 1999 Informs That SA Crail,License OP-70160,will Resign Position on 990630.Termination of License Requested ML20206B6621999-04-20020 April 1999 Informs of Violation of Provisions of OSTR Physical Security Plan.Revs & Updates to Licensee Physical Security Plan,Encl Per 10CFR50.54(p).Details of Violation & Revs to Plan, Withheld IAW 10CFR2.790(d) ML20205K4211999-04-0606 April 1999 Informs That Federal Government Funding for Conversion of OSTR from HEU to LEU Cannot Be Certified & No Further Action to Be Taken at Present Time ML20204F4181999-03-0505 March 1999 Reports Recent Incident in Which Violation of 10CFR74.13(a)(1),occurred.Failure to Submit Matl Balance Rept by Deadline of Oct 30.Importance & Specific Details of Regulatory Deadlines Emphasized,Reviewed & Clarified ML20199E8581999-01-12012 January 1999 Informs That SRO License SOP-50284-1,of Jf Higginbotham, Became Inactive on 981231 Due to Individual Not Meeting Operational Requirements of OSTR Requalification Plan During 1998 ML20202E1501999-01-11011 January 1999 Forwards Revised Osu Radiation Ctr & Triga Reactor Emergency Response Plan, Per 10CFR50.54(q).Changes Do Not Reduce Emergency Response Effectiveness,Based on Evaluations ML20155E8011998-10-23023 October 1998 Forwards Annual Rept of or State Univ Radiation Ctr & Triga Reactor for 970701-980630 ML20154G8391998-10-0707 October 1998 Requests That Mailing Address Be Corrected as Listed ML20154D4321998-09-30030 September 1998 Responds to RAI on 980727 Application for Proposed Amend to TS 3.8.e.Notification of Changes to Personnel Shown in Organization Chart of TS 6.7.c.3,also Provided ML20237D1891998-08-0707 August 1998 Forwards Revs & Updates to OSTR Physical Security Plan IAW 10CFR50.54(p).Licensee Concludes That Effectiveness of OSTR Program Is Not Reduced by Adoption of Changes.Encl Withheld Per 10CFR2.790 ML20249C4561998-06-24024 June 1998 Responds to NRC Re Violations Noted in Insp Rept 50-243/98-201.Licensee Requests That NRC Refrain from Issuing Civil Penalty & NOV Due to Noted Reasons ML20249C7691998-06-19019 June 1998 Informs of Discovery of Error in Analyzer Efficiency Calculation in Gaseous Effluent Data in 1996-97 OSTR Annual Rept.Corrected Data Will Be Reported in 1997-98 OSTR Annual Rept.Corrected Table V.B.2 Encl ML20217Q3481998-03-0606 March 1998 Submits Formal Comments on Written Exam Conducted at Facility on 980303 for G Wachs & N Carstens ML20217P2571998-03-0303 March 1998 Informs That Federal Government Funding for Conversion of OSTR from HEU to LEU Cannot Be Certified.No Further Action Towards Conversion Will Be Taken at This Time.Ltr from DOE, Encl ML20203D5631998-02-20020 February 1998 Forwards Revisions & Updates to OSTR Physical Security Plan IAW 10CFR50.54(p).Encl Withheld ML20236K7071998-02-17017 February 1998 Responds to 980217 Telcon Re Licensee Performing Full Investigation to Find Most Basic Root Cause of Failure to Scram on Demand Which Occurred on 980217 ML20198K3081997-12-29029 December 1997 Submits Formal Rept of Changes IAW 10CFR50.54(q),as Result of Annual Review of OSTR Emergency Response Plan Completed on 971219 ML20197H9001997-12-19019 December 1997 Responds to RAI Re Proposed Amends to OSTR Ts.Replacement Pages to Amends Proposed in ,Encl.Changes to Personnel Shown in Encl Organization Chart of OSTR Ts,Per TS 6.7.c.3,noted ML20212D4491997-10-27027 October 1997 Forwards Annual Rept of Oregon State Univ Radiation Ctr & Triga Reactor,960701-970630 ML20217N4691997-08-20020 August 1997 Submits Revs & Updates to or State Univ Triga Physical Security Plan,Iaw Provisions of 10CFR50.54(p).Plan Withheld ML20149D5341997-07-11011 July 1997 Provides Notification of Changes to Personnel Shown in Organizational Chart of OSTR Triga Reactor TS as Required by T.S.6.7.c.3 ML20138D0231997-04-24024 April 1997 Forwards Revisions & Updates to or State Univ Triga Reactor Physical Security Plan IAW Provisions of 10CFR50.54(p). Changes to Plan Have Been Reviewed by Physical Security Staff & Approved by Reactor Operations Committee.W/O Encls ML20147E6921997-03-12012 March 1997 Informs of Failure to Perform Shield Survey at Power After Removing Wooden Plug & Incomplete Closing of Lead Shutter on Beam Port 2 Following Insp of Beam Tube ML20136G7491997-03-12012 March 1997 Submits Proposal Describing Current Efforts Re Conversion of OSTR from HEU to LEU Fuel.Will Take No Further Action Re Conversion at This Time ML20134A8231997-01-15015 January 1997 Represents Formal Rept of Changes IAW 10CFR50.54(g),as Result of Annual Review of OSTR Emergency Response Plan Which Was Performed on 961206 ML20134E3971996-10-28028 October 1996 Forwards Annual Rept of Oregon State Univ Radiation Ctr & Triga Reactor for Period 950701-960630 Which Addresses Number of Different Interests ML20117H2241996-08-29029 August 1996 Submits Revs & Updates to OSTR Physical Security Plan IAW Provisions of 10CFR50.54(p).Plan Withheld ML20101H4961996-03-25025 March 1996 Submits Proposal Describing Current Efforts Re Converting or State Univ Triga Reactor from HEU Fuel to LEU Fuel ML20095E5611995-12-0808 December 1995 Informs That Js Bae Resigned Position,Effective 951130 & Request License Be Terminated,Effective 951201 ML20094P2781995-11-22022 November 1995 Forwards Briefing Info for AEOD 951129-30 Visit ML20093M9681995-10-24024 October 1995 Forwards Annual Rept of Oregon State Univ Radiation Ctr & Triga Reactor June 1994-June 1995. Annual Rept 1994-1995 Continues Pattern Established Over Past Few Yrs & Includes Info About Entire Radiation Ctr ML20094B3551995-10-23023 October 1995 Forwards Annual Rept of Changes,Tests & Experiments Performed Per 10CFR50.59 for Period Jul 1994 - June 1995. There Were Four Changes to Reactor Facility & Four Changes to Reactor Procedures Conducted Per 10CFR50.59 for Period ML20093A9941995-09-22022 September 1995 Forwards Revised Oregon State Univ Radiation Ctr & Triga Reactor Emergency Response Plan. Attachment B Includes All of Current Replacement Pages for Plan ML20087J2511995-08-14014 August 1995 Forwards Revs & Updates to Physical Security Plan.Encls Withheld (Ref 10CFR2.790(d)) ML20081H0701995-03-20020 March 1995 Forwards DOE Notifying Licensee That Funding for Conversion of Reactor to LEU Fuel Not Available for FY95 ML20081E3521995-03-15015 March 1995 Submits Proposal in Response to Commission Regulations Requiring Conversion of OSTR from HEU Fuel to LEU Fuel ML20081A4411995-03-0202 March 1995 Forwards Revs & Updates to Univ Triga Reactor Physical Security Plan.Encl Withheld ML20076L4291994-10-25025 October 1994 Submits Annual Rept of Changes,Tests & Experiments Performed Under Provisions of 10CFR50.59 for or State Univ Triga Reactor for Period Covering Jul-June 1994 ML20078C1471994-10-24024 October 1994 Forwards Annual Rept of or State Univ Radiation Ctr & Triga Reactor,930701-940630 ML20076G3141994-10-10010 October 1994 Forwards Revised Oregon State Univ Radiation Ctr & Triga Reactor Emergency Response Plan ML20024J0681994-08-29029 August 1994 Submits Rev & Update to Physical Security Plan Per Provisions of 10CFR50.54(p),for Review & Acceptance ML20072L1141994-08-19019 August 1994 Informs That Tv Anderson Retired 940731 & Requests That SRO License SOP-764-12 Be Terminated Effective 940801 ML20072D5331994-08-10010 August 1994 Forwards Corrected Replacement Page for Proposed Revs to TS, Correcting Typo in Basis of Spec 3.7.1 Where Word Times Mistakenly Written as Items ML20070H2201994-07-14014 July 1994 Informs of Listed Personnel Changes Which Became Effective 940701,w/respect to TS 6.7.c.3 ML20065M4141994-04-18018 April 1994 Informs That Three Listed Licensed Operators Have Changed Home Addresses ML20064L4351994-03-22022 March 1994 Informs That SE Birney,Holder of Operator License SOP-3421-5,has Not Chosen to Renew His License When License Expires on 950115 ML20064N4231994-03-21021 March 1994 Responds to 940302 Request for Addl Info Re Proposed Amend to License R-106,revising Organization Chart & Retaining Original Wording of TS 4.3.1.e & Adding Listed Sentence ML20064C7691994-03-0101 March 1994 Forwards Proposal Describing Current Efforts Relating to Converting OSTR from HEU Fuel to LEU Fuel.Licensee in Process of Drafting Proposed Changes to License R-106,TS, Sar,Emergency Response Plan & Physical Security Plan ML20063F7951994-02-0202 February 1994 Submits Formal Comments on Written Exam Conducted at Facility on 940131,per Procedures Specified in 1999-08-17
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IMDINMON CINII;R Oni:GON STA'It Usivrusity Radiation Center Al(o Cervalls Oregon 97331 SW3
'lelephone $03 737 2Mt Ib $03 737 NHO April 12,1991 Document Contre! Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Oregon State University TRIGA Reactor (OSTR), Licenso No. R 106, Docket No.
50 243; written report filed by the OSTR as a follow up to telephone conversat!ons with USNRC stalf.
Gentlemen:
On April 8,1991, A. G. Johnson, Director of the OSU Radiation Contor, tolophoned Mr. Al Adams, OSTR Project Manager at U.S. Nuclear Regulatory Commission (NRC) headquarters to discuss an event involving the shipment of a small quantity of radioactivo motorial, which occurred on January 16,1991, in addition, on April 5,1991, Dr. Brian Dodd, Reactor Administrator at the OSTR, contacted Mr. Wondell Carriker, Roscarch and 1 Special Programs Administration, US Department of Transportation, Washington, D.C. to report the event to the USDOT. Relativo to reporting,it should also be noted that on April 5 A. G. Johnson attempted to contact Mr. Adams at NRC headquarters, and Mr. Phil Qualls and Mr. Leroy Nordorhaug who are the OSTR contact personnelin the NRC's Rogion 5 offico. None of those individuals were availablo on April 5 and thus the first NRC telephone contact was made with Mr. Adams on April 8,1991. {
The purposo of the tolophone calls to the DOT and the NRC was first to describe the event to the agenciss and then to determino whether or not there woro formal reporthy requiromonts for Iabeling and shipping paper discrepancios which woro detected af ter tho-fact for a shipment of 140 Ci of radioactivo material which went from the OSTR to another licenseo. The DOT representativo indicated that their regulations had no clear reporting requirements for the event describod, and Mr. Adams telephoned A.G. Johnson on April 8 to report that there did not appear to be any 6pplicablo NRC reporting requirements for such on event. However,in kooping with the OSTR policy of open communication with the NRC on matters which wo believe to be of mutualinterest, we have decided that it would be appropriate to submit a report of the event.
In addition to verbal notification of NRC headquarters, tolophone colla were also completed to the NRC's Region V Offico, to the Oregon Department of Energy, to the Oregon Radiation Control Section, to the carrior (Federal Express) and to the recipient of the shipment, Renssolaer Polytechnic Institute (RPl). In the latter caso, the notification s
9104190054 910412 sO, PDR ADOCK 05000243 J 4 4 . S PDR l Ji+ -
USNRC 2- April 12,1991 was made to the RPI Radiation Safety Officer, which is where the package was shipped.
Notifications to the specified organizations were made on April 8 and April 10,1991.
A description of the event itself, including our analysis of its cause: corrective actions and measures implemented or planned to prevent or reduce the possibility of reoccurrence; lessons learned; and specific conclusions regarding the event are allincluded as part of this report, Furthermore, the information submitted in this report, including the corrective /
preventative actions, has been reviewed and opproved by a quorum of the OSTR Reactor Operations Committee (ROC). -
BACKGROUND INFORMATION The Oregon State University Radiation Conter routinely ships small quantities of radioactive material to other licensed users on the OSU campus and to users at other locations throughout the country. All shipments are made in full accordance with applicable regulations of the US Department of Transportation and the State of Oregon.
Normally, the quantitles of radioactive material shipped are in the microcurio rango and fall into the DOT " Limited Quantity" category. The remainder of the shipments are USDOT
- Type A Quantitles" and normally require a White I or a Yellow ll radioactive matoriallabel.
Upon very rare occasion, the Radiation Center may ship a package requiring a Yellow lli radioactive materiallabel.
As part of the Radiation Center's program for shipping radioactive material, training sessions are conducted for each individual authorired to make such shipments. Upon completion of the training, individuals have their name entered on a list of certified radioactive material shippers. To retain this certification, individuals must participate in an j annual retraining program. l Another part of the shipping program includos quarterly audits of all shipments. One ,
such audit is n*? formed by the OSU Radiation Safety Of ficer, while a separate quarterly audit of shipm from the OSTR is performed by the ROC. 1 The R$diation Center also has several different types of containers which have been tested to meet USDOT container Specification 7A. Records of these container tests me maintained permenently on file at the Radiation Center.
Detailed written procedures for packaging and shipping radioactivo material are also part of.the Radiation Center's shipping program. These procedures are available to all
- individuals authorized to make such shipments and are reviewed for accuracy at least annually by the OSTR Reactor Operations Committee, !
1 DESCRIPTION OF OCCURRENCE AJD_POSSIBLE CAUSES i As noted previously, part of the Radiation Center's program for shipping radioactivo materialincludes a quarterly audit which is performed by the OSU Radiation Safety Of fmer.
On Friday, March 29 the OSU Radiation Safety Officer terformed the routino quarterly _
. . i USNRC 3- April 12,1991 audit of shipments mado during the first quarter of 1991 and identified a discrepancy in a radioactive material shipment made on January 10,1991. The discrepancy is described below:
On January 16,1991, the Radiation Center's Radiation Protection Technologist packaged a shipment containing 140 pCl of iron 59 (Fe 59) for shipment to Renssoleer Polytechnic Institute (RPl). The radioactivo material was contained in thin geologic samplos which had boon irradiated in the OSTR thermal column, and the majority of the radioactivity at the timo of shipmont is !
belloved to have been due to flux monitors present with the samplos. The shipment was modo from OSTR License R 106 to RPI's Now York Stato License NYS 1035. The 140 pCl of radioactivity was well within the DOT limit for a Limited Quantity shipment, but the material was actually packaged in a container mooting USDOT Specification 7A, which qualifies the container to carry a Type A Quantity of radioactive material. The maximum radiation levelin contact with the packago was 4 mrom/hr, while the radiation level at 1 motor (i.e., the transport index) was O mrem /hr. The packago was distinctly labeled Radioactive Material, Limited Quantity n.o.s., UN 2010, which was consistent with the quantity of radioactivo material being shipped, but was not consistent with the maximum radiation level at contact with the package. Considoring the 4 mrem /hr present on the packago surface, the packaga should have boon labeled with a Radioactive Yellow ll label and classified as Radioactivo Material, n.o.s., UN 2982. In addition, the shipping papers which accompanied the ,
package reflected the fact that the package was classified and labelod as a '
Limited Quantity, and consistent with this laboling the papers indicated that the package was industrial, strong and tight rather than Specification 7A. As a l reminder, a USDOT Specification 7A package was actually used to make the shipment, but the shipment was not being considered a Type A Quantity. All other DOT requirements applicable to the shipment were mot, and after the packtDo was prepared it was transferred to Federal Express for shipment to
- RPl. The shipment arrived without incident at its intended destination. ,
The individual who prepared this shipment for the OSTR was cortified to ship radioactivo material and is a very capable and conscientious member of the i Radiation Center's staff. Thero are no indications that the discrepancies occurred due to carolossness on the part of the individual involved. The person making the shipment had successfully shipped a large number of radioactive material packages from the Radiation Centor, and af ter discussing the matter i' with the individual, we can only conclude that the mistake was duo simply to human error. We have every confidence that this employoo will recognize the significanco of this occurrence and will benefit from tho additional training and l other follow up activities associated with this event. 1 I
, , .- . , , , , , - , = , ,, -----a , y
USNRC 4- April 12,1991 CORRECTIVE SUCH AN EVENT ACTIONS AND MEAS 3).flES TAKEN TO PREVENT THE REOQCURRERCLQI The Contor's program for shipping radioactive materialis very rnuch a part of our day to day operation and we believe that it must be carried out in a safe and professional mannor. As indicated previously, the Radiation Contor conducts a formal training program associated with the authority to ship radioactive materials. The training involves many dif ferent topics including the writton shipping procedures, practical shipping oxorcisos, and other factors designed to assuro full compliance with all USDOT and Stato of Oregon requirements. However,in view of the event described in this report, the Contor has implemented two additional actions which we believe will significantly help to provent the rooccurrence of any further discropancy during the shipment of radioactivo material. The two correctivo measures are as follows:
- 1. The Radiation Conter procedure for transfor, packaging, and transport of radioactivo material has boon revised to require an indopondent review by a second individual of all packages and shipping papers before they are offered for shipment, The review will be conducted by an individual cortified to ship radioactivo material, but the reviewer will not be the same individual who packaged the shipment and prepared the shipping papers.
- 2. All Radiation Contor staff members certified to packago and ship radioactivo matorial participated in a special retraining program conducted on April 9,1991. During this training session the event being reported was reviewed along with the now requirement for a secondary review of shipping papers and packages. Other aspects involved in the shipping of radioactivo material were also reviewod.
LESSONS LEARNED The concept of performing a second independent review of logs and checklists is common throughout the research reactor community. Based on this event,it would appear that an independent review of radioactive material packages and shipping papers prior to actual shipment would be a wise addition to all shipping proceduros which do not currently requiro such a review, CONCLUSIONS The quantity of radioactivo materialinvolved in this event was quito small and the associated radiation levels were very low. Consequently, the discrepancies identified are primarily regulatory in naturo. Furthermore, safety 'vas not an issuo in this occurrence.
Nevertholoss, the OSTR staff regrets that this event took placo and wishes to assure the NRC, the DOT and the State of Oregon that safety and compliance with regulatory requirements arn of the utmost importanco in all aspects of our program. We also wish to mako it clear thet we are fully committed to implomonting the previously identified correctivo actions in order to prevent a rooccurrence of this event.
f l -
l J
USNRC 5- April 12,1991 In conclusion, we would like to summarize for your consideration soveral key factors relating to our report.
- 1. The amount of radioactive material shipped (140 pCl) was well within the I DOT's curie limit for a
- Limited Quantity" shipment. l l
- 2. The radioactivo material was packaged in a container mooting USDOT container Specification 7A, which was a fully appropriate container for the radioactive material shipped.
- 3. The primary discrepancies were in the labeling of the packago and in the previously identified errors on the accompanying shipping papers; however, '
those latter errors were consistent with the labeling discrepancy.
- 4. The maximum radiation lovel at the package surface was only 4 mrom/hr and at 1 meter was O mrom/hr. Thus, there were no radiation safety Isoues associated with handling or transport of the package.
- 5. All other USDOT regulatory requirements applicable to this shipment woro complied with in full.
- 6. There does not appear to be any clear requirement for reporting this type of event. However, this report is being submitted to maintain open communications with the NRC and other regulatory agenclos which have jurisdiction over our program.
Should there be questions rogarding the information in this report or should you require more information, please let me know. It is our intent that this report be as complete and helpful as possible.
Yours sincoroly, i
A. G. h son Direct '
. ogydd/ntc/1 16.91 cc: NRC Region V NRC Al Adams ODOE David Stewart Smith State of OR, Radiation Control Section-Martha Dibblee SEB BD JFH TVA SMC DSP RHF i
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