Title
10 CFR 71.5 requires that each licensee shall comply with the applicable requirements of Department of Transportation regulations in 49 CFR 171 through 180. Title 49 CFR 173.443(c) requires that each transport vehicle used for transporting Class 7 (radioactive) materials as an
exclusive use shipment that utilizes the provisions of paragraph (b) of this section be surveyed with an appropriate radiation detection instrument after each use. The vehicle may not be returned to service until the radiation dose rate at each accessible surface is 0.005 mSv per hour (0.5 mrem per hour) or less, and there is no significant removable (non-fixed) radioactive surface contamination as specified in paragraph (a). Contrary to the above, on August 24, 2009, an
exclusive use vehicle delivering Class 7 material was allowed to leave the licensees site without the licensee conducting an appropriate survey. This was identified by the licensee within a few hours and the contract carrier was called to return the vehicle to the site for the required survey. The vehicle returned directly without taking on an additional load and the required survey was conducted. No non-fixed radioactive surface contamination was identified and the radiation dose rates on the accessible surfaces of the vehicle were less than the required limit for free release of the vehicle. The issue was documented in the stations corrective action program (
CAP 069233). Corrective actions included changing procedures to require notification of the shift health physics technician and the radwaste shipping coordinator when any and all radioactive shipments arrive on the site.
They are considered subject matter experts in radioactive material shipping requirements and can provide the required technical response. Additionally, warehouse personnel were trained on the provisions for exclusive use as defined in 49 CFR Part 173 and the new procedural requirements.
The finding was more than minor because: an inadequate (not conducted) survey was performed for the vehicle that was released. It was fortuitous that the required follow-up survey concluded that the vehicle did not contain radioactive material indistinguishable from background. While the finding involved control of radioactive material associated with transportation, it was determined to be of very low safety significance because it did not involve a
10 CFR Part 61 finding, package radiation limits in excess of the allowable limits, a breach of a package, a failure to make a required notification or provide emergency information, or a non-compliance with a Certificate of Compliance.
