ML20207F172
| ML20207F172 | |
| Person / Time | |
|---|---|
| Site: | University of Wisconsin |
| Issue date: | 03/03/1999 |
| From: | Bresell R WISCONSIN, UNIV. OF, MADISON, WI |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9903110186 | |
| Download: ML20207F172 (17) | |
Text
1 UNIVERSITY OF WISCO N SIN M A D I S O N 3 March if 99 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Re: Response to Inspection, Docket No.50-156
Dear Sirs:
Reference Non-Power Reactor and Decommissionir.g Project Directorate inspection results letter of 18 February,1999. Attached is our reply to the violations noted.
If you have any questions penaining to this information, please contact me. ,
Sincerely, l C Ronald R. Bresell Radiation Safety Officer
.i .
U.S. Nuclear Regulatory Commission, Region III !
Attn: Mr. Darrel G. Wiedeman Division of Nuclear Materials Safety Lisle, Illinois 60532 U.S. Nuclear Regulatory Commission Non-Power Reactor and Decommissioning Project Directorate ,
Division of Regulatory Requirement Programs l Office of Nuclear Reactor Regulation !
l Washington, D.C. 20555-0001 ,j j 1
University of Wisconsin, Madison ATTN: R. J. Cashwell, Reactor Director l 143 Engineering Building 9903110186 990303 FI rd\000 -
! PDR ADOCK 05000156 'I l G PDR -
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Safety Department i University of Wisconsin-Madison 30 North Murray Street Madison Wisconsin 53715 - 2609 608/262-8760 http://wlscinfo.dott.wisc.edu/ safety FAX 608/262-6767
- . l The Code of Federal Regulations 10 CFR 75.5(a) requires that NRC licensees who :
, transport licensed materials outside the site of usage, as specified in the license, or l where transport is on public highways, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirement of the Department of !
. Transportation regulations in 49 CFR Parts 170 through 189 appropriate to the mode of transport. Contrary to the above, the licensee failed to meet the following requirements: ,
l
- a. 49 CFR 173.441(c) requires that special written instructions be provided to drivers ;
of exclusive use shipments. On December 11,1998, the licensee failed to provide !
written instructions to the driver for exclusive use shipments. l Reason for the violation: The root cause of this, and the second cited violation is !
communication failure. An earlier, similar shipment to Point Beach Nuclear Plant !
was performed on 4 June 1998 (Enclosure 1). During that shipment, the several !
individuals involved with the shipment performed various tasks such as surveys, i completing shipping paper, briefing driver, etc. The Safety Department thought that i the 11 December 1998 shipment was "to be just like the prior (4 June) shipment." ;
Some persons present at the previous shipment were not present for this shipment. :
The lack of continuity resulted in the omission of the exclusive use instruction letter.
Corrective steps that have been taken and results achieved: A revised :
Shipper's Declaration for Hazardous Materials has been drafted (Enclosure 2). j This form includes entries for all possible exclusive use shipments to power :
reactors from our reactor (e.g., LSA, Yellow-ll, Yellow-lll). The block which records j the acknowledgment of the drivers instructions includes additional handling ;
information required for exclusive use shipments. ;
1 Corrective steps that will be taken to avoid further violations: The written I instructions for exclusive use are included in the shippers declaration of hazardo us materials. This shipping paper will be used for all exclusive use shipments from the reactor.
Date of full compliance: 16 December 1998
- b. 49 CFR 172.203(d)(10) requires that shipping papers for exclusive use packages must designate the shipment as exclusive use. The shipping papers for the December 11,1998, Sodium-24 shipment to Braidwood did not contain such a designation.
Reason for the violation: As noted above, the root cause of this omission is miscommunication. The shipping papers for the similar shipment of Sodium-24 to Point Beach Nuclear Plant on 4 June 1998 (Enclosure 1) included Exclusive Use Shipment - LSA ll designation. Initially the Safety Department was under the belief that this shipment would be identical. However, prior to the shipment, the reactor staff reported that this shipment would not be " exactly like" the prior shipment. This material would be shipped as small containers each with 1.6 grams of 2'NaOH
- i. 1 crystalline powder instesd"6f 'several liters of 8dNaOH in solution and the shipping i
.- container was not as well shielded (the 4 June container weighed 3320 pounds; this j
- container weighed 744 pounds). Based upon this information, the Safety l
~ Department attempted to revise the shipping paper to allow for a Radioactive !
. Material, n.o.s. (e.g., Yellow-ll or Yellow-Ill) shipment (instead of LSA) and, in the ;
process of revising the paper to delete the phrase LSA-II, the entire line " Exclusive !
Use Shipment -- LSA II" was unwittingly deleted. At the reactor the shipper noted l
that each sample had a mass of 1.6 gram, verifying that, because of activity concentration, the shipment could not be shipped as LSA. Once the samples were j inserted into the shipping container, the survey revealed that the radiation exposures both on the surface and at 1-meter were such that exclusive use vehicle was required. This requirement was acknowledged on the shipment checklist :
(Enclosure 3) but, because the words " Exclusive Use" had been unknowingly - l deleted from the shipping paper, their absence was not noticed. i I
. Corrective steps that have been taken and results achieved: Realizing that !
such an omission may be indicative of a procedural void, the Safety Department created a " Radioactive Shipment Exclusive Use Worksheet" and, as noted above, revised the Shipper's Declaration for Hazardous Materials. This revised shipping paper contains all possible entries, the shipper need merely cross out unneeded entries.
Corrective steps that will be taken to avoid further violations: Again, this shipping paper will be used for all shipments from the reactor.
Date of full compliance: 16 December,1998,
- c. 49 CFR 173.441(b((2) requires that package surface dose rates for exclusive use shipments not exceed 10 mSv/hr (1000 mrem /hr) during transportation. The December 11,1998, shipment to Braidwood was reading up to 1840 millirem per j hour on contact when it arrived at its destination.
' Reason for the violation: The difference in surface dose rates is indicative of instrument and geometry constraints. Measurements by the Safety Department were made using a Victoreen Model 450B lon chamber. This meter uses a large chamber and the box is approximately 4-inches wide. The sensitive volume of this meter is thus at least 2-inches from the package surface. Since the radiation size was a pencil-like beam, the inverse square and ion chamber to beam size ratios could reasonably produce exposures at least 4-times those n'easured with the ,
Victoreen 450B. The shipping cask configuration with 4 securing bolts (Enclosure !
- 4) precluded measuring surface doses at some points on the surface. Surface i measurements using a calibrated ion chamber instrument indicated maximum !
surface exposures of 480 mR/hr at 7 A.M.
Corrective steps that have been taken and results achieved: The Safety Department designed a " Radioactive Shipment Exclusive Use Worksheet" to l l
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I provide for better documentation of the shipping container surface and 3.3-feet (1-meter) dose rates. Physical limitations of the large ion chambers was discussed during the Safety Department's 16 December corrective action meeting and smaller (e.g.,6 cc) volume ion chambers suitable for a wide range of energies will be used to monitor exclusive use packages.
1 Corrective steps that w'll be taken to avoid further violations: All personnel !
involved in shipping of radioactive material from the reactor will be informed of the i appropriate meter to use for monitoring packages from the reactor. j 1
Date of full compliance: 16 December,1998.
l l
It should be noted that we realized that administrative errors were made in this ;
shipment and less than one week later, on 16 December,1998, the Safety Department :
held a corrective action meeting (Enclosure 5). The group reviewed the 11 December j shipment and promulgated several checklists to insure this type of violation does not l occur in the future. The key was to centralize all information and required actions in the j hands of a single person, the person completing the shipping papers. The two forms i
discussed (Radioactive Shiptrent Exclusive Use Worksheet and Shippers Declaration j for Dangerous Goods) have been revised based on feedback (e.g., recommendations ;
of recent NRC inspection). We believe that these forms significantly reduce the risk of {
errors. The Safety Department is considering purchasing additional meters with a i smaller volume ion ( hamber and is in the process of reviewing systems which have i wide response (e.g. 35 kVp - 2 MeV) and applicability. However, contracting for such a !
system may take about 6 months. )
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... i UNIVERSITYOF ,
WISCONSIN M A D I S O N SHIPPER'S DECLARATION FOR DANGEROUS GOODS FROM: l Univ.of Wisconsin-Madison Radiation Safety Dept. -
30 North Murray St.
Madison,WI 53715 USA TO:
Wisconsin Electric Power Co. 1 Point Beach Nuclear Plant 6610 Nuclear Road l i
Two Rivers, WI 54241 !
EXCLUSIVE USE SHIPMENT LSA 11 NATURE AND QUANTIT/ OF DANGEROUS GOODS l.
Proper Shipping Class UN Pack- Subsid- Quantity and type of Packing Authorization Name or orID ing lary Packing Inst. l Divi- No. Group Risk {
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Radioactive Material, 7 UN2912 One strong tight LSA, n.o.s. package; Na - 24; M 72 4400 MBq a00=kdf mci ;
,@ NaO dissolvedin 3
water; Visight= 3324 lbs.
Dimensions 13 % in. X 13 % in X 63 in Emergency Telephone Number: (608)262-4524 EMERGENCY RESPONSE INFORMATION ON BACK I hearby declare that the contents of this consignment are fully and ax.urately described above by the proper shipping name, and are classified, packaged, marked and labeled / placarded, and are in all respects in proper condition for transport according to applicable intemational and national governmental regulations.
Signature .
Name/ Title ofSignsfory - Leola DeKock / Health Physicist Place and Date- Madison, WI June 4,1998 I
I have received the above-specified shipment indicated above and drivers instructions and understand its content as described.
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Safety Department Signature and Date University of Wisconsin-Madison 30 North Murray Street Madison, Wisconsin 53715-2609 608/262-8769 FAX: 608/262-6767 kg, (
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University of Wisconsin NUCLEAR RE ACTOR LA80RATORY ADDRESS:
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r This shipment of LSA (Low Specific Activity) radioactive l material must be transferred as " exclusive use" material under l Title 49 Part 173.425.
l This requires that no other material may be shipped on.the i vehicle with this shipment, and that no loading or unloading of the material be done except under the direction of the consignee or consignor. )
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z UNIVERSITY OF l WISCONSIN M A D I S O N l 1 1 SHIPPER'S DECLARATION FOR HAZARDOUS MATERIALS Exclusive Use Shipment LSA-ll From: University of Wisconsin -- Madison To: Nuclear Engineering Reactor Lab l Radiation Safety Department 30 North Murray Street Madison,WI 53715 USA Nature and Quantity of Dangerous Goods i Proper Class or UN or Pack- Subsi- Quantity and Type of Packing Packing Author Shipping Division ID No. ing diary Inst. ization Name Group Risk Radioactive 7 UN2982 Material, Nuclide: (_, ) White I Physical / Chemical Form: Yellow 11 RO One strono tiaht / Type A package Yellow lil GBq = mci TI = Weight = kgm ( lbs) Dimensions = cm x cm X cm Emergency Telephone Number: (UW Police & Security) (608) 262-2957 EMERGENCY RESPONSE INFORMATION ON BACK I hearby declare that the contents of this consignment are fully and accurately described above by the p oper shipping name and are classified, packaged, marked and labeled / placarded, and are in all respects in proper condition for transport according to applicable international and national govemment regulations. Signature: Name/ Title of Signatory - Leola DeKock / Health Physicist Place and Date -- Madison, WI Additional Handling Information: Exclusive use means sole use by a single consignor of a conveyance. Ensure that any loading or unloading is performed by personnel having radiological training and resources appropriate for safe handling of the consignment. Provide a copy of the Radioactive Shipment, Exclusiw Use Worksheet to the Consignee. Unless otherwise stated, do not pick up any other shipment nor passengers. Limit stops to those necessary and pari away from high pedestrian traffic areas. I have received the above-specified shipment and drivers instructions and understand its content. l Printed Name Signature and Date Safety Department University of Wisconsin-Madison 30 North Murray Street 608/^62-8769 http://wlscinfo. dolt.wlsc.edu/sofety Modison Wisconsin 53715--2609 FAX 608/262-6767 h h.
' Emergency Response Information
- 1. Proper Shipping Name: Radioactive Material, N.O.S.,7, UN2982
- 2. Health Hazards: Radiation may present a minimal to moderate risk to persons during trahsportation accidents and radioactive materials may be released if packages are damaged in severe accident. Depending upon label, packages may contain life endangering amounts of radioactive material. Undamaged packages are safe; damaged packages or materials released from packages may be external and internal radiation hazards. It is prudent to expect contamination. Some packages may only have the word Radioactive in the package marking. l These Limited Guantity labels indicate the material should be considered safe in all conditions. Radioactive White-Ilabels indicate radiation levels outside undamaged package ,
are very low; Radioactive Yellow-II labeled packages have higher radiation levels; l Radioactive Yella-IIIlabeled packages have potentially significant radiation levels. The transport index (TI) on the label identifies the maximum radiation level in mrem /hr at one , meter from the undamaged package. Commonly available radiation detecting instruments can ; detect most of these materials. Call UW Police (608) 262-2957 or UW Radiation Safety (608) , 262-8769 for emergency assistance.
- 4. Immediate Precautions: Priority response actions may be performed before taking radiation measurements. The priorities of response are (1) life saving, (2) control of fire and l other hazards, and (3) routine first aid. For Radioactive Yellow-III packages, remove all I persons from the immediate area. Regardless of label, isolate hazard area and deny entry. I Notify Radiation Safety of accident conditions. Radiation Safety Officer, Ron Bmsell(608) j 262-9178 [home (608) 274-8449] must be notified of accident conditions and is responsible for j radiological decisions. Keep unnecessary people at least 150 feet upwind of spill; greater i distances may he recessary for people downwind or if advised by Radiation Safety. Detam !
uninjured persons, isolate equipment with suspected contamination, and delay final cleanup ) until instruction or advice of Radiation Safety. ):
- 5. Fire: Do not move damaged packages; move undamaged packages out of fire zone. Positive )
pressure self-contained breathing apparatus (SCBA) and structural firefighter's protective j clothing will provide adequate protection against internal radiation exposure. Extemal l radiation hazards may exist for Yellow-Il and Yellow-III packages. Treat fire as appropriate. ; Smallfres use dry chemical, CO2, water spray or regular foam. Iorgefires use water spray, l fog (f'ooding amounts). For massive fires in cargo area, use unmanned hose holder or monitor ! nozzles. Water from carso fire control is expected to be contaminated. I
- 3. Risk o' Fire or Explosion: Material is not considered to be a fire nor an explosion hazard.
Use any suitable means for extinguishing surrounding fire. In the event of a fire, wear full protective clothing and self-contained breathing apparatus with full facepiece.
- 6. Spill or Leak: Do not touch damaged packages or spilled material. Slightly damaged or damp outer s*ces seldom indicates leakage. Small liquid spills can be absorbed with sand, (
earth or oW . m teombustible absorbent material. Cover powder spill with plastic sheet or l tarp to mi aize shifting or spreading. If source is identified as being out of package, stay ; away and am advice from Radiation Safety. Notify Radiation Safety of action and dispose : of contaminated waste per instructions from Radiation Safety. l
- 7. Emergency First Aid: Do not delay care and transport of a seriously injured person. Use first aid treatment according to the nature of the injury. Persons exposed to radioactive !
material may become contaminated with radioactive material. If not affecting injury, remove i and isolate suspected contaminated clothing and shoes. Wrap victim in sheet or. blanket before ; transporting. If there is no injury, remove and isolate suspected contaminated clothing and l shoes, assist person to shower with soap and water; always blot dry, do not abrade skin.
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- .. ': k }l hk ] 1 CONTAINER PRODUCT.S CORPORATION 112 North CollegeItoad P.O. Box 3767 Wilmington,NC 28406 l
. Tek QI0)392-6100 Far @l0)392-6778 Web Page: http://www.c-p-c.com E-matt cyc@c-p-c.com , QCOP-3001 CERTIFICATE OF COMPLIANCE AND FINAL INSPECTION REPORT 9, ' ~ +++++++++++++++++++++++++++
THE SPECIFICATION U.S.A. D.O.T. 7A TYPE A CONTAINERS SUPPLIED BY CONTAINER PRODUCTS CORPORATION AS NOTED BELOW HAVE BEEN DESIGNED AND MANUFACTURED IN COMPLIANCE WITH TITLE 49 CODE .OF FEDERAL l REGULATIONS; 49 CFR PARTS 178.350; 173.24; 173.410; 173.411; 173.412; 173.415; ! 173.461; 173.462; 173.463; 173.465; 173.474; 178.608 ; DOE EVALUATION DOCUMENT MLM-3245; WHC-EP-0558. WELDED BY CERTIFIED PERSONNEL IN ACCORDANCE , WITH ASME SECTION IX AND AWS D1.1; DI.3. INSPECTED BY CERTIFIED INSPECTION ~ PERSONNEL UTILIZING A QUALITY CONTROL SYSTEM BASED UPON 10 CFR PART 50 APPENDIX B, NQA-1 AND MIL-I-45208A. THE CONTAINERS LISTED BELOW HAVE BEEN l INSPECTED AND CERTIFIED TO MEET ALL THE ABOVE REQUIREMENTS AT TIME OF DESIGN, CONSTRUCTION AND INSPECTION IN ACCORDANCE WITH APPLICABLE QUALITY CONTROL PROCEDURES AND INSTRUCTIONS. CUSTOMER: NWT COR'PORATION P.O.NO: 8059 NOMENCLATURE: SSB-1.14-1-7A-BRN DRAWING NO: 01-1739-2-01 QUANTITY: 1 PAYLOAD: 1,000 POUNDS l SERIAL NOS: 984766 W 9
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12/16/1998 Meeting
, . Na-24 Shipment on 12/11/98 i
l Present: Ron Bresell, RSO Abdul BenZikri, ARSO I Leola DeKock, HP l Ralph North, HP Jeff Orwin, Waste Spec. Sprv. RSO indicated that the Na-24 shipment was done safely, bt.' there are some procedural mistakes. The RSO discussed these mistakes, and presented corrective actions so that this will not happen again, see attached. 1 The RSO also indicated that in excess of 200 mR/hr @ surface radioactive packages must be shipped usmg i an exclusive use vehicle. In addition a work shee6 (or such shipments has been established and must be { used to confirm procedures and implement corrective actions, we attached worksheet. . l The Health Physicist staffindicated that the package design for this part.cular shipment was not optimum, in that it allows pencil beam radiation to escape the shield with out attenuation. To guard against this problem, the staff recommended using a survey meter with a handheld probe. Hence, when monitoring for radiation exposures, packages with non-flat and uneven surfaces can be easily monitored at contact. The l RSO concurred, and directed the heal:h Physicist staff to purchase a new survey meter with appropriate l probe and scale if one is needed. i l 4 i l l i i l yb- ! 5 :
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16 December,1998 Darrel: . Talked to John Madera on Tuesday. He noted that the shipping incident would be given to the Reactor Branch, but that Byproduct may be asked to assist and that the entire packet was given to -
. you for future investigation. Just so you don't think we view this event as not being serious, we reviewed both what we heard occurred with this shipment and our shipping procedures. Our beliefis that the radionuclide was shipped safely, but that we made some significant procedural errors.1We believe the attached form (or one very similar; we have been reviewing it for several days) will go a long way to eliminate some of those errors. Some of the issues we are .
I addressing: l i
- 1. Exclusive Use. Our understanding of the shiprnent was that it would be exdunve use. l Originally our reactor people had indicated that the shipment wotild be similar to one we made this summer to Point Beach or Kewanee. In that instance we dissolved NaOH in about 2 liters of H2O and shipped it in a 3000 pound cask as LSA. The activity values that the reactor targeted (0.1 A2) also suggest that this was the case. As you know, LSA requires exclusive use. When irradiation was completed at 7 AM, we placed the two plastic capsules
- each containing a 540 mci 8'NaOH pellet in the shipping cask and noticed first that exposures were high and second that the mass per pellet was only 1 gram of Na. Thus; this could not fit the uniform concentration for 13A. Consequently we opted for a Yellow III since the -
container furnished us for the project by Braidwood's consultant was labeled as a DOT Type A. We were later informed by the reactor people at Braidwood that they saw'no indication from the transfer cmpany's papers that this was an exclusive use shipment.' Fix number 1: we will require a copy of the contract for all LSA and Type III shipments from the UW to verify that we are dealing with exclusive use. All of Safety's on-campus shipmehts are exclaive use.
- 2. Exposures. We measured relatively high surface exposures (480 mrem /hr at 7:10 AM which decreased to about 340 mrem /hr at 8 AM when we shipped). Given our belief that the vehicle was exclusive use, we elected to ship it a Yellow III and monitored the vehicle to verify acceptable exposure rates._ We measured maximum exposure levels in the cab of 1 mR/hr; at the surface of the _ vehicle of 9.7 mR/hr and at 3 feet of 4.3 mR/hr. These exposures were acceptable for exclusive use; but documentation was spotty. Fix number 2: our revised fonn carries a schematic of the tmck and cab and the surveyor will enter the surface and 6-foot exposures (measuring at 3 feet was an error; but the values were so much below the maximum 200 miem/hr surface and 10 mrem /hr 6-foot reading that we felt it was not significant) as well as the cab exposure and verify they are within acceptable exposure levels for exclusive use.
- 3. Package Exposures. Kevin asked about package exposures. We told him we did not see how Braidwood could get 1700 mrem /hr on any surface. But he inquired why our paperwork only indicated one (actually two; our initial [7:10 AM] first high surface measurement of 370 was topped by a 480 mR/hr reading at another spot on the surface, so we crossed the former and i entered the latter). Even though regulations only require the maximum surface and 3.3-foot reading; a single number may not appear to be adequate. Fix number 2: our revised form l
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l carries survey locations all around each of several package configurations and has places to l . record the maximum surface and 3.3-foot exposures at each point.
- 4. Miscellaneous. Our belief that this was exclusive use resulted in our briefing the drivers about stopping en route, etc. This briefing was not interpreted by the driver as an instmetion.
Fix number 4: our revised form has locations for the surveyor to record that the driver was briefed (maybe we should get the driver to sign off7) about stopping, loading other products, etc., as well as to record that placards were installed and the load blocked and braced.
- 5. Package. Our reactor people would have preferred a different package and isotope physical- ,
form (e.g., LSA liquid) but were given this shipping container as suitable. The Braidwood reactor HP suggested the shipping container was suitable for a single plastic capsule of I Ci of "Na with additional packing material on top to insure the source remained at the bottom of the container. Two capsules may have changed the source geometry sufficiently that transport could result in a shifting of the sources. Fix number 5: Safety will evaluate the shielding of each of these special case packages using mock sources to determine geometry and packing procedures and then calculate worst case expected surface and 1 meter exposures. We will be discussing the incident, corrective form and procedures a bit further today; but we believe these items should reduce the risk of further screw ups with potentially greater hazard.
- i. ..
Date: Radioactive Shipment -- Exclusive Use Worksheet
. Isotope: Activity: Shipper:
Trucking Company: Measure all surfaces of the package and label the appropriate drawing with exposure rates at both the surface and 1 meter. LSA and Yellow III packages with surface levels in excess of 200 mrem /hr must be shipped in closed transport exclusive use vehicle. Sketch location of package in truck, monitor all 6 sides and passenger compartment, record each result. Exposures must be:
< 2 mrem /hr in the cab, < 200 mrem /hr at the vehicle surface and < 10 mrem /hr @ 6.6 feet.
Select type package used mark package location top [ l y 4 A - cab - V front t jt front
, top 9Be Z F~
right le,ft _ ,_, F _ __ _ _ g 7g 'right - - -
} a side i
O(p ; back Radiation Levels (mrem /hr) Exclusive Use Checklist Contract states " Exclusive Use" Contact @ 3.3 feet Load blocked & braced, placards in place Left Written Exclusive Use Instructions to driver Right Truck Radiation Levels (mrem /hr) Front Contact @ 6.6 feet Back Left Top Right Bottom Front Back must be < 1000 Top Meter: make/model Bottom
'g must be < 200 < 10 Driver's cab must be < 2 mrem /hr L}}