ML20116A967

Responds to Violations Noted in Insp Rept 50-160/96-02. Corrective Actions:Conducted Meeting W/Radiation Safety Staff Re Regulatory Requirements & Replaced Retired Health Physicist Technician w/well-trained Health Physicist

ML20116A967
Person / Time
Site:	Neely Research Reactor
Issue date:	07/18/1996
From:	Karam R Neely Research Reactor, ATLANTA, GA
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9607290047
Download: ML20116A967 (27)

Text

i Georgia Institute of Technology

/,". . . . .'.,' 3 .

g - NEELY NUCLEAR RESEARCH CENTER

, g . ... g - g / 900 ATLANTIC ORIVE I ,, ' 'm ' g8 ATLANTA, GEORGIA 30332-0425 l USA (4o4)s94-3600 l

l July 18, 1996 i

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 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:

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 Deviation.

Should you have any question, please call me at (404) 894-3600.

Sincerely, 1 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, N.W.  !

Atlanta, GA 30323  ; U_ ' ,

Chief Fuel Facilities Branch, Region II j Dr. John White, Dean of Engineering 7 Dr. Jean-Lou Chameau, Vice Provost Mr. Alfred L. Evans, Senior Asst. Attorney General ,

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Mr. Randy Nordin, Chief Legal Advisor \g 9607290047 960718 PDR ADOCK 05000160 G PDR Telex:542507 GTRIOCAATL Fax:404453-9325 (venfy 404 894 3600)

A Unst of tre Univers;tv System ni Geoga An Ecual Education and Empiovmont Opportunr'v lest8Jt.on

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ATTACHMENT I Georgia Institute of Technology Reply to Notice of Violation 50-160/96-02 l

Violation 50-160/96-02-A A. Technical Specification 4.2.a requires that the channels listed in Table 4.2 shall be calibrated as indicated. Table 4.2 specifies an annual known parameter source calibration.

Technical Specification 1.27 specifies that the frequencies of periodic surveillance tests, checks, calibrations, and examinations shall be performed within the specified intervals. These intervals may be adjusted by plus or minus twenty-five percent ( 25%).

Contrary to the above, the licensee f ailed to calibrate the G-M gas monitor within the annual period 25% in that tne 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 Specifications.

This is a Severity Level IV violation (Supplement IV).

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1. Admission or denial of violation:

The Georgia Institute of Technology admits the violation as stated. ,

2. The reason for the violation:

The health physicist responsible for the gas monitor calibration failed to calibrate the gas monitor in a timely manner. The reason given by the HP technician is simple oversight. In reality, this staf f member was planning for his retirement and that may have contributed to the oversight.

3. Corrective steps which have been taken_and results achieved:

i A meeting was held with all the_ Office of Radiation Safety l staff. The ' importance of compliance with all regulatory I

requirements was stressed to all. Also stressed was the need to communicate among the staff that if slippage in schedule is unavoidable, the Director of the facility must be informed.

In this case, the Manager of the Office of Radiation Safety l knew about.the slippd.ge 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 l health physicist with an MS degree in Health Physics. All'HP l i staff were sensitized to the need to meet all regulatory I requirements.

4. Corrective steps which will be taken to avoid further l

violations:

See answer to item 3 above.

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5. Date when full compliance will be achieved:

Full compliance was achieved 3/3/95.

i Violation 50-160/96-02-B B. 10 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 189.

49 CFR 172. 704 (a) specifies the general awareness, function specific, and safety training requirements for hazmat employees.

49 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 thereafter.

49 CFR 172. 704 (d) (4 ) requires certification that the hazmat employee has been trained and tested as required by this subpart.

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 containers, drums, or packagings as qualified for use in the transportation of hazardous materials.

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 172.704.

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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1. Admission or denial of violation:

The Georgia Institute of Technology admits that all employees at the Neely Nuclear Research Center were not all trained and L 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" course. 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 from the Nuclear Regulatory Commission. All shipments containing radioactive material from Georgia Tech were made under the broad license from the State of Georgia.

Consequently, Georgir 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 State.

We are also concerned about the statement, " ...the licensee failed to train and appropriately test all hazmat employees on subjects covered in 49 CFR 172.704..." Does this mean that all NNRC employees need to be trained and certified? We have in place a detailed procedure covering radioactive material shipment, Procedure 9510 (appended). All of Georgia Tech's health physic, staff were trained on this procedure. It is believed that this procedure covers regulatory requirements of NRC and DOT adequately. It is our belief that our training of the material covered in Procedure 9510 meets or exceeds requirements in 49 CFR 172.704. A deficiency however exists in that we did not test the trainees on their proficiency of all relevant materials in Procedure 9510. This deficiency will be removed by June 1997.

2. Reasons for the violation:

No violation was committed under NRC license. A violation may be cited under State of Georgia regulations based on the fact that our training did not include testing.

3. Corrective steps which have been taken and results achieved:

One staff member was trained in an OSHA-approved course and certified. All appropriate personnel were trained in Procedure 9510. All shipments under NRC's license were made in compliance with all regulations.

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4. Corrective steps which will be taken:

All personnel who ship radioactive materials will be enrolled in the OSHA-approved course by January 1, 1997. Retraining and testing of personnel will be instituted at NNRC by June 1997.

5. Date.when full compliance will be achieved:

June 1997.

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L Attachment II Georgia Institute of Technology Reply to a Notice of Deviation During an NRC inspection conducted on April 22-24, May 7, 23, 29-31, . and June 4, 1996, a deviation of written commitments was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the deviation is listed below:

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 l Nuclear Safeguards Committee for review and approval by July l 20,.1995.

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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 approval.

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1. -Admission or denial of deviation:

The Georgia Institute of Technology admits the deviation as L stated. '

! l l 2. Reasons for the deviation: '

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l Simple oversight. ]

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-3. ' Corrective steps taken and results achieved: j Procedure 3600 was revised, submitted to the Nuclear l Safeguards Committee and approved on June 13, 1996.

j 4. Corrective steps which will be taken. to avoid further deviations:

None.

L 5. Date when full compliance will be achieved:

Full compliance was achieved 6/13/96.

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NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVF MATERIAL SHIPMENI Approved 4/11/96 Date: / / Page 1 of 21 1.0 PURPOSE To describe a method for packaging and shipping of radioactive materials to ensure that package integrity is maintained during transportation and to ensure compliance with DOT /NRC regulations regarding the transportation of radioactive materials.

2.0 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.

3.O RESR_ONSIBILITIES 3.1 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 criteria specified in this procedure for packaging, surveying and documenting each shipment is met.

3.2 It is the responsibility of the Manager, Office of Radiation Safety (MORS), or her/his designee, to review all shipping documentation prior to shipment to ensure accuracy and adequacy of the papers.

4. 0- REFERENCES 4.1 Requirements and Specifications 4.1.1 49 CFR, Parts 100-199, Department of Transportation Regulations 4.1.2 10 CFR 71, Packaging and Transportation of Radioactive Materials 4.1.3 39 CFR 124, Postal Service Regulations 4.1.4 State of Georgia, Rules and Regulations for Radioactive Materials, Chapter 391-3-17.

NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 2 of 21 4.2 Related Procedures 4.2.1 Procedure 9056, Calibration and Operation of the Ludlum 2000 Scaler 4.2.2 Procedure 9151, Calibration and Operation of the Tri-Carb 2000 Series Liquid Scintillation Counter 4.2.3 Procedure 9.?50, Facilities Contamination Surveys 4.2.4 Procedure 9304, Roucine Facility Radiation Surveys 4.3 Others 5.3.1 None ,

5.0 PROCEDURES / REQUIREMENTS  :

i 5.1 Equipment / Materials Required l 5.1.1 Disk smears and Masslin smears 5.1.2 Calibrated survey meters (dose rate and count rate  :

meters)  ;

5.1.3 Ludlum 2000 scalers with GM and/or alpha scintillation detectors or equivalent 1

5.1.4 Liquid Scintillation Counter  !

5.1.5' Shipment forms (Forms RS-87, RS-88, RS-35 and RS-28 or equivalent)

[ 5.1.6 Labels, placards and security seals, as required l

5.2 Procedure 5.2.1 Definitiont 5.2.1.1 Radioactive Material - For transportation purposes, radioactive material is defined as material which

NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 3 of 21 spontaneously emits ionizing radiation and has a specific activity in excess of 70 Bq/g (0.002 pCi/g) of material.

5.2.1.2 Radioactive Material Soecial Form - Sealed sources th&t primarily represent a direct radiation hazard rather than a contamination hazard because of its high physical integrity.

5.2.1.3 Radioactive Material Normal Form - Any radioactive material that does not qualify as Special Form,

i. e., loose radioactive material.

5 . .n . 4 A1 Activity - The maximum activity of Special Form radioactive material that may be transported in a Type A package (various radionuclideo have different permissible activities - see 49 CFR 173.435).

5.2.1.5 A2 Activity - The maximum activity of Normal Form radioactive material, other than special form, Surf ace Contaminated Objects (SCO), or Low Specific Activity (LSA) radioactive material that is permitted in a Type A container (various radionuclides have different i permissible activities - see 49 CFR 173.435). l I

5.2.:.6 Tvoe B Ouantities - A quantity which exceeds the A2 or A, valuc for the radionuclide (s) of interest (see MORS for such shipments).

5.2.1.7 LSA Radioactive Material - Materials in which the l . radioactivity specific activity meets the following limits:

5.2.1.7.1 LSA-I, naturally occurring radioactive ores, depleted

.ranium, material where A2 is unlimited, contaminated .

soil, concrete, rubble that has uniformly distributed l radioactivity less than 10-' A 2/9-

, 5.2.1.7.2 LSA-II, tritiated water; less than (0.8 TBq/L or 0.8 x 10 12 Bq/L) (20 Ci/L) and radioactive mar rial less than 10-* A2 /g for solids and gases and let ; than 10-5 ,

A 2 /g for liquids.

5.2.1.7.3 LSA-III, radioactive material distributed in solid (concrete / ceramic, etc), is insoluble and specific activity is less than 2 x 10-' A 2/9-

NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 4 of 21 5.2.1.8- Packace - Represents the ' ckaging together with its radioactive contents as pt .. anted for transport (e.g.

excepted,. Type A, Type B r

• Industrial I, II, & III) .

5.2.1.9 Transoort Index - A dimensionless number (rounded up to one decimal place) placed on the label of a package 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 package.

5.2.1.10 Surface Contaminated Obiect - 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/cm2 Beta / gamma or 0.4 Bq/cm 2 alpha for non-fixed contamination or 40,000 Bq/cm Beta 2

/ gamma or 4,000 Bq/cm2 alpha for fixed contamination.

SCO-II: Contamination that exceeds SCO-I but does not exceed 400 Bq/cm' beta / gamma or 40 Bq/cm2 alpha for non-fixed or 8x105 Bq/cm 2 beta / gamma or 8x10 4 Bq/cm2 alpha for fixed.-

(See 49 CFR 173.403 for details and exceptions).

5.2.2 Shiprant Preparation FOTE: A Quality Assurance Checklist is attached as Appendix B to assist in the preparation of radioactive materials for transportation. This Form, RS-88, shall be utilized in preparation of radioactive materials for shipment and shall be retained along with copies of the shipping papers as permanent facility records.

5.2.2.1 Preparation of packages of radioactive materials for shipment will normally be carried out in the HP laboratory facilities. Preparation of waste for shipment will normally cake place in the Barn.

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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 5 of 21 5.2.2.2 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 of the inner or the outer package, one layer of packaging will remain intact to ensure that the i radioactive material is not disbursed to the environment.

5.2.2.3 The majority of packages shipped frcm the NNRC are of l the type defined as Limited Quantity or Low Specific Activity (LSA) material and consequently, are dealt with specifically below.

NOTE: For preparation of shipments of l highway controlled quantities, Type B, or fissile material, contact the MORS for further information.

l l 5.2.2.4 Ensure that shipping papers, Form RS-87, are completed appropriately. All radiological units are to be reported in SI units followed by customary units in parenthesis. (49 CFR .172.203 (d) (4)) .

5.2.2.5 Limited Quantity Shipments (49 CFR 173.421 and 173.425) 5.2.2.5.1 Definition -

Limited quantity shipments are radioactive materiM r ' hose activity per package does not exceed the limits rpecified in 49 CFR 173.425 (Table 7) and which are excepted from DOT specification packaging, shipping paper and certification, marking and labeling requirements.

5.2.2.5.2 The radioactive material shall be packaged in strong, tight packages that will not leak under conditions normally incident to transportation.

5.2.2.5.3 The package shall have two layers of packaging, i. e. ,

an inner lining as well as the external packaging l itself, i. e., the container.

l l l 5.2.2.5.4 The outside of the inner lining shall be marked

" RADIOACTIVE." ,

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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 6 of 21

.2.2.5.5 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) : l "This package conforms 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."

5.2.2.5.6 The removable contamination on the external surface of the package shall not exceed 0.41 Bq/cm (2200 2

dpm/100 cm2 ) for beta / gamma emitting radionuclides or 0.04 Bq/cm2 (220 dpm/100 cm2 ) for alpha emitting radionuclides. (49 CFR 173.443) 5.2.2.6 Transport Requirements for Low Specific Activity and Surface Contaminated Radioactive Material (49 CFR 173.427) 5.2.2.6.1 Low specific activity (LSA) is defined in 5.2.1.7.

Surface contaminated objects (SCO) are defined in 5.2.1.10. [

5.2.2.6.2 The LSA and SCO radioactive materials shall be '

packaged in strong, tight containers, or in industrial packages specific for each LSA type.

5.2.2.6.3 Radiation levels and removable contamination levels shall meet the criteria specified in Steps 5.2.8 and )

5.2.9.

5.2.2.6.4 Shipments must be loaded by consignor (Georgia Tech) or contractor and unloaded by consignee.

5.2.2.6.5 The exterior of each package must be stenciled or .

marked " RADIOACTIVE - LSA." or " RADIOACTIVE - SCO", ,

respectively.

i NOTE: Once the radioactive materials are appropriately labeled for transport, the " Radioactive Material" labeling requirements of 10 CFR 20.1304 are no longer applicable.

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NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 I Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96  !

Date: / / Page 7 of 21 5.2.2.6.6 There must be no leakage cf radioactive materials from t the_ package during transport. 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 af ter loading of the radioactive .

material as applicable - common carriers are exempt i from surveys.). .

5.2.2.6.7 The truck shall be radiologically clean, i. e., no measurable removable radioactivity above background  :

levels. ,

i 5.2.2.6.8 All shipments of LSA and SCO material shall be i consigned as exclusive use. The truck shall display  ;

placards that state: " RADIOACTIVE."

5.2.3 Shipping Papers (49 CFR 172.202) t 5.2.3.1 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 - 8 7, Radioactive Materials Shipment Papers, as appropriate.  ;

5.2.3.1.1 Determine that the intended recipient has a license on i file at the NNRC. Specify the license number and the  !

expiration date of the license on the shipping papers.  !'

If a license is not on file, the radioactive material shall not be sent.  ;

NOTE: For a waste shipment, the license of  !

the Burial facility must be on file.

l 5.2.3.1.2 The license of the recipient shall be checked to ensure that possession of the radionuclide to - be 1 shipped is permissible and to ensure that the quantity  ;

of the radionuclide to be shipped is allowed by the r license.

5.2.3.1.3 List the name and address of the shipment recipient.  ;

5.2.3.1.4 Each shipment of radioactive material shall have a unique number. 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 year.

NEELY NUCLEAR RESEARCH CENTER ,

Minor Change Procedure 9510 l 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, 1990.  ;

5.2.3.1.5 Determine the proper shipping name and identification number preceded by "UN" (49 CFR 172.101) using the assistance provided in Appendix A. Write the proper j l shipping name and identification number preceded by UN number on the appropriate blank of the shipping paper. ,

5.2.3.1.6 Enter the physical and chemical forms of the material to be shipped on Form RS-87.

5.2.3.1.7 List the name and quantity of each radionuclide (49 CFR 173.435) in S.I. Units (e.g. TBq, Bq) for each i

! package.

5.2.3.1.8 Specify the total quantity of radionuclides that are l

present in the entire shipment. ,

5.2.3.1.9 The category of label applied to each package, i. e.,

j Radioactive White-I, Radioactive Yellow-II or i Radioactive Yellow-III shall be specified on the l shipping papers. ,

i 1 5.2.3.1.10 The Transport Inde.x (radiation level in [(mSv/hr)x100] l (mrem /hr) at 1 meter) for each package bearing a i Radioactive Yellow-II or Radioactive Yellow-III labels i shall be stated on the shipping papers and the two (2) labels.

5.2,3.1.11 For a package approved by the USNRC, a notation of the

, package identification marking as prescribed in the l applicable USNRC approval shall be specified (ex. , Type B, USA /5507/BF) (49 CFR 172.203 (d) (vii) and 173.471).

l 5.2.4 Shipper's Certification (49 CFR 172.204) i 5.2.4.1 The shipping papers shall contain a certification

statement which attests to the fact that the material j being offered for transport is ready for shipment.

] NOTE: The statement shall read: "This is to i certify that the above named materials are properly classified, described, packaged, marked and labeled, and are in proper A

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l NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 9 of 21 i condition for transportation according to the applicable regulations of the Department of Transportation (DOT)."

5.2.4.2 For shipments being made by passenger-carrying l aircraft, in addition to the requirement for a T. I. ,

of < 3, and the certification statement specified in  !

Step 5.2.4.1, an additional certification is required l which states:  ;

i "I certify that this shipmert contains radioactive material intended for use in, or +

incident to research, medical diagnosis or l treatment."

5.2.4.3 The certification statements reqaired by Step 5.2.4.1 f and/or Step 5.2.4.2 shall be signed by an appropriate NNRC staff or management person, usually the Manager, Office of Radiation Safety.

! 5.2.5 Marking of Packages (49 CFR 172.301 and 172.310) ,

5.2.5.1 Each person who offers hazardous materials for transportation with a weight in excess of 50kg (110 pounds) shall mark each package, freight container and

• ransport vehicle.

5.2.5.2 The markings required include proper shipping name,

• identification number preceded by "UN, " gross weight, and  ;

the Type of packaging, i. e., Type A or Type B.

i 5.2.6 Labeling (4 9 CFR 172. 4 00) l l 5.2.6.1 No person may offer for transportation any package bearing a hazardous material label unless the package actually ,

contains the hazardous material specified on the label.

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5.2.6.2 Any material classified as radioactive material that also meets the definition of another hazard class shall be labeled as required for both hazards.

5.2.6.3 The proper label for a package of non-fissile radioactive ,

material is based on the radiation level at the surf ace of the package.

5.2.6.4 There are three categories of labels (49 CFR 172.403) based on the level of radiation at the surface of the  ;

package:  !

6 . __ __ . ._. - _.- _. ._

f .g j ,.a- ha 46+-- -a Aa.-_aa4 _ w. -.a.es.-4 .m(a- L4-d. * -.s - --e.-e +A -eeJ-.5mA =J. **.s l

NEELY NUCLEAR RESEARCH CENTER  ;

Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: /_ / Page 10 of 21 ,

5.2.6.4.1 White-I -

Radiation Level s 0.005 mSv/hr (0.5 mrem /hr);

5.2.6.4.2 Yellow-II - Radiation Level is > 0.005 mSv/hr (0.5 mrem /hr) but s 0.5 mSv/hr (50 mrem /hr) ; and

'5.2.6.4.3 Yellow-III - Radiation Level is > 0.5 mSv/hr (50 mrem /hr) but s 2 mSv/hr (200 mrem /hr) .

NOTE: For fissile material, see 49 CFR 172.403. I 5.2.6.5 The label specifications for each label type is l specified in 49 CFR 172.436, 172.438 and 172.440.

5.2.7 Placarding (49 CFR 172.500) 5.2.7.1 No placard may be displayed on a vehicle unless the r vehicle accually contains the hazardous material specified on the placard.

5.2.7.2 The vehicle must be placarded on each end of the vehicle ,

and on each side with a placard reading " RADIOACTIVE "

(only LSA and SCO, and Radioactive Yellow-III shipments, l

[49 CFR 172.504) , Table 1 are required to be placarded) .  !

t 5.2.7.3 It is the responsibility of the shipper to provide the placards and ensure that the placement on the shipment is .

correct. If the carrier has placards, these may be used. '

4 5.2.8 Radiation Levels (4 9 CFR 173.441) 5.2.8.1 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 one meter from the package unless the packages are )

transported in an exclusive use, closed transport vehicle. 1 l

j 5.2.8.2 Use of a closed, exclusive vehicle permits transportation l

, 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 i fixed during transport and provided there is no i loading / unloading between the beginning and end of transportation.

l a # l NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03 I By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 11 of 21 5.2.8.3 In the case of the closed, exclusive use vehicle, radiation levels at the outer surface of the vehicle may not exceed 2 mSv/hr (200 mrem /hr) (including both top and bottom of the vehicle) and the dose rate may not exceed 0.10 mSv/hr (10 mrem /hr) at any point 2 meterL from the outer lateral surfaces (excluding the top and bottom).

5.2.8.4 In addition to the above, the dose rate in any space which is normally occupied by personnel, i. e., the cab of the truck shall be less than 0.02 mSv/hr (2 mrem /hr).  ;

5.2.8.5 All radiation level readings for each package and exclusive-use vehicles shall be documented on Form RS-28, Miscellaneous Survey Form. Appropriate survey maps shall be drawn.

5.2.9 Contamination Control (49 CFR 173.443) 5.2.9.1 Contamination control data shall be collected and documented using Form RS-28, Miscellaneous Survey Form, to show where smears were taken. Actual count data shall be documented on Form RS-35 (see attached forms).

5.2.9.2 The smear surveys taken shall be sufficient in number to demonstrate that each package was adequately surveyed. Exclusive use vehicles shall be surveyed before and after loading.

5.2.9.3 Non-exclusive Use Vehicle 5.2.9.3.1. The level of removable contamination by smears from the external surf ace of each package shall not exceed 0.41 Bq/cm2 (2200 dpm/100 cm2 ) for beta / gamma emitting radionuclides, . radionuclides with half-lives j less than ten days, and natural uranium / thorium.

l 5.2.9.3.2 For other alpha emitting radionuclides, the level of

. _ removable contamination by smears from the external -

4 surface of each package shall not exceed 0.04 Bq/cm2 (220 dpm/100 cm2 ),

i

! 5.2.9.4 Exclusive Use Vehicle 1

l NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 l Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: /. / Page 12 of 21 j 5.2.9.4.1 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 5.2.9.3.2.

5.2.9.4.2 At any time during transport, the removable i contaminatiotr levels may not exceed ten times the [

levels specified in Step 5.2.9.3.

5.2.9.4.3' For vehicles used under the provisions of Step e 5.2.9.4, a vehicle may not be returned to service until the dose rate at each accessible surface is less than 0.05 mSv/hr (5 mrem / hour) fixed contamination.

5.2.9.4.4 Step 5.2.9.4.3 does not apply when the enclosed, ,

exclusive use vehicle is dedicated for the sole use of transportation of radioactive material by highway.

In this situation, the vehicle must be stenciled with a sign that states: "For Radioactive Material Use Only." ,

l 6.O RECORDS I 6.1 Forms RS-28, RS-35, RS-87 and RS-88 or equivalent shall be completed during the preparation of radioactive materials for transport.

l 6.2 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 l shipment shall be maintained along with the shipping  ;

papers for the life of the facility. '

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u i i f

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NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03 i By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 11 of 21 APPENDIX A l PROPER NAME TaND RELATED PARAMETERS

1. RADIOACTIVE MATERIAL, N.O.S., UN 2982 Shipping name used when no other category is appropriate.

Activity / package shall not exceed the A 2 value for a Type A package (4 9 CFR 173 . 43 5 ) .

2. RADIOACTIVE MATERIAL, EXCEPTED PACKAGE, N.O.S., UN2910 Activity / package shall not exceed the limits specified in '

49 CFR 173.423, Table 7 Radiation Level <0.005 mSv/hr (< 0.5 mre 7/hr) on package surface '

< 15 grams U-235/ package Container shall be strong, tight.

Excepted packages of instruments, articles, DU, Natural uranium, limited quantities and " empties".

3. RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY, N.O.S., UN2912 Radioactivity uniformly dispersed.

Activity concentration shall not exceed that of Step 5.2.2.5.1

4. RADIOACTIVE MATERIAL, SPECIAL FORM, N 0.S. UN2974 Activity of special form material shall not exceed the "A 2 value for a TYPE A package.

5. NOT CLASSIFIED AS RADIOACTIVE Activity is uniformly distributed.

Specific activity is < 70 Bq/g (0.002 pCi/g)

6. RADIOACTIVE MATERIAL, SURFACE CONTAMINATED OBJECT, SCO, UN 2 913 See surface contamination definition 5.2.1.10

l I

r <

,RS-87 NEELY NUCLEAR RESEARCH CENTER  ;

Minor Change Procedure 9510 ]

Number: Revision 03 l By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 14 of 21 RADIOACTIVE MATERIAL SHIPPJNG PAPERS Neely Nuclear Research Center Georgia Institute of Technology 900 Atlantic Drive Atlanta, GA 30332 (404) 894-2500 (Georgia Tech Police) l Date NNRC Shipment No.

TO: Carrier:

l Shipped Via:

Waybill No.: I PROPER SHIPPING NAME/ID NO.:  ;

PRINCIPAL RADIONUCLIDES AND QUANTITIES: ,

l PHYSICAL FORM : Solid Liquid Gas Weight l

l 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 _ NO Radiation Surveys - Surface of Inner Container mSv/hr i Beta Gamma l

I -

Surface of Outer Container mSv/hr

! Beta Gamma l '

Smearable Contamination Outer Container Bq/cm*

- Beta / Gamma Alpha CERTIFICATION -

This is to certify that the above named materials are  ;

properly classified, packages, described, marked and labeled & in proper condition for transportation according to the applicable regulations of the Department of Transportation. This shipment is within the limitation prescribed for passenger / cargo aircraft only.

Certified by: Date l l

Reviewed by: Date __

l l

l l

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4 FORM RS-88 NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 15 of 21 Page 1 of 4 APPENDIX B TRANSPORTATION OUALITY ASSURANCE CHECKLIST Directions: All blanks shall be completed. For those instances in which a designated activity has been completed for the shipment under consideration, initial the blank to the right of the statement. For those activities which are not performed for a particular shipment, write N/A in the blank to the right.

t Date: Shipment No.:

1. Intended Recipient license is on file Specify expiration date

2. Package provided inner lining.

3. LIMITED QUANTITY SHIPMENTS l

a. Strong, tight package

b. Inner Lining marked " Radioactive" ,

l

c. Step 5.2.2.5.5 Notice Enclosed in Package

d. Removable Contamination Below Limits

< 0.41 Bq/cm (2200 2

dpm/100 cm ) beta 2

/ gamma

< 0.04 Bq/cm (220 dpm/100 cm') alpha 2

e. Direct Radiation < 0.005 mSv/hr (0.5 mrem /hr) external surface

[

4. LOW SPECIFIC ACTIVITY OR SURFACE CONTAMINATED OBJECTS SHIPMENTS

a. DOT Specification 7A, TYPE A package or i Industrial Package jf not exclusive use vehicle i

i

b. Strong, tight package if exclusive use vehicle t c. Removable Contamination Below Limits

< 0.41 Bq/cm 2(2200 dpm/100 cm*) beta / gamma '

< 0.04 Bq/cm (220 dpm/100 cm') alpha 2

l

l NEELY NUCLEAR RESEARCH CENTER 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

d. External Radiation levels <2 mSv/hr (200 mrem /hr) at 1 meter (for non-exclusive use vehicle) l l e. T. I. < 10 [(0.1 mSv/hr) x 100] or (10 mrem /hr) l NOTE: A T.I. = [(mSv/hr) X 100] at 1 muter 1

i f. For closed, exclusive use vehicle, see ,

49 CFR 173.441

g. Shipment loaded by Consignor or Contractor L h. Exterior of each package marked: .

. " RADIOACTIVE - LSA" or " RADIOACTIVE -SCO" l i. Visual inspection of package - intact

j. Vehicle " clean" (no smearable activity)

k. Shipment braced to prevent movement

! 1. Placards applied to truck " RADIOACTIVE" l

5. PREPARATION OF SHIPPING PAPERS

a. Name & address of shipper affixed

b. Name & address of recipient affixed

c. Proper Shipping Name Identified (see Appendix A)

d. Special/ Normal form identified

e. Physical form identified

( ,

f. Major Nuclides & Quantity [Bq (mci)] listed

g. List Label applied to each package

h. T. I. for each package specified j i. If USNRC approved package, specify approval

, j. Certification completed i

I NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 17 of 21 Form RS-88, page 3 of 4

k. If placards tendered, indicate on papers

6. LABELING

a. More than Radioactive Hazard

b. Radioactive White - I

c. Radioactive yellow - II

d. Radioactive yellow - III

a. " Radioactive" - Outside Inner Package for Ltd Qty

7. PLACARDS TENDERED - LSA, SCO AND RADIOACTIVE YELLOW - III

8. RADIATION / CONTAMINATION SURVEYS COMPLETE

9. PACKAGE MARKINGS: (On Outside of Package)

a. Type of Package ( A/B )

b. Type A (> 13 mm (1/2") high)

c. Name & Address of Consignee or Consignor

d. Proper Shipping Name, I.D. # (UN #)

e. Gross weight if > 50 kg (110 lbs)

f. If liquid present: "This End UP"

g. With dry ice present: "ORM-A" on one side below proper shipping name.

8. OTHER LABELS AS REQUIRED

" CARGO AIRCRAFT ONLY" (if T. I. > 3.0)

" CORROSIVE" (nitric acid solutions of UF)

" OXIDIZER" (Reg 173.419) (solid U or Th nitrates)

"PYROPHORIC" (Reg 173.418)

=

• NEELY NUCLEAR RESEARCH CENTER Minor Change- Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 Date: / / Page 18 of 21 Form RS-88, page 4 of 4

9. OTHER REQUIREMENTS:

Security Seal (s) Type & No.

Absorbent material for liquids (2x volume capacity)

T. I. < 3.0 for passenger aircraft and i following statament included: "This i shipment contains radioactive material intended for use in, or incident to, research, medical diagnosit or treatment."

T. I. >3.0 for cargo aircraft only and " CARGO AIRCRAFT ONLY" label applied to package.  !

For air shipment, send 2 copies of shipping papers Vehicle placarded (if Radioactive Yellow-III SCO or LSA) - Check " Placards Tendered" on the shipping papers.

Notify Police Department that package has been shipped and give details of shipment.

Prepared by: Date:

Reviewed by: Date:

1 l .

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! NEELY NUCLEAR RESEARCH CENTER Minor Change Procedure 9510 Number: Revision 03 By: RADIOACTIVE MATERIAL SHIPMENT Approved 4/11/96 1 Date: / / Page 19 of 21 I l

APPENDIX C  ;

l l

GEORGIA INSTITUTE OF TECHNOLOGY I NEELY NUCLEAR RESEARCH CENTER  !

900 ATLANTIC DRIVE j ATLANTA, GA 30332 (404) 894-2500 (Georcia Tech Police) l l

I "This package conforms to the conditions and limitations specified in i j 49 CFR 173.421 for excepted radioactive material, limited quantity,  ;

l n . o . s . , UN 2 910 ; or 4 9 CFR 173 . 4 24 for excepted radioactive material, l instruments and articles."

l l

LIMITED QUANTITY SHIPMENT l

k

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 i INST.

I r

l k

t 9

l a

, COMMENTS l 2

i i

2 1

PERFORMED BY: DATE i

3 REVIEWED-BY: DATE i .

1-i 4

I i  !

. 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 Description 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 l

l Comments: __

Performed by: Date:

Reviewed by: Date: