Latest revision as of 00:04, 10 January 2025

Text

3 to EN-RW-102, Radioactive Shipping Procedure
	ML16132A510
Person / Time
Site:	Waterford
Issue date:	10/15/2015
From:	Mitchell F; Entergy Operations
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML16132A496	List: ML16132A494; ML16132A506; ML16132A507; ML16132A508; ML16132A509; ML16132A510; W3F1-2016-0038, UNT-005-014, Rev. 306, Offsite Dose Calculation Manual;
References
	W3F1-2016-0038 EN-RW-102, Rev 13
	Download: ML16132A510 (47)
	v • d • e

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 1 OF 47 Radioactive Shipping Procedure Procedure Contains NMM ECH eB REFLIB Forms: YES NO Procedure Revision Type: New NON-Editorial Editorial TC Cancellation HQN Effective Date Procedure Owner:

Title:

Site:

Frank Mitchell Manager, RP IPEC Governance Owner:

Title:

Site:

Reid Tagliamonte Manager, Fleet RP HQN 10/15/15 Site Site Procedure Champion Title ANO Donnie Marvel Manager, RP BRP N/A N/A CNS Chris Sunderman Manager, RP GGNS Roy Miller Manager, RP IPEC Frank Mitchell Manager, RP JAF Robert Heath Manager, RP PLP David Nestle Manager, RP PNPS Alan Zelie Manager, RP RBS Shannon Peterkin Manager, RP VY Michael Pletcher Manager, RP W3 Daniel Frey Manager, RP HQN Reid Tagliamonte Manager, Fleet RP For site implementation dates see ECH eB REFLIB using site tree view (Navigation panel).

Site and NMM Procedures Canceled or Superseded By This Revision None Process Applicability Exclusion:

All Sites:

Specific Sites: ANO BRP CNS GGNS IPEC JAF PLP PNPS RBS VY W3 Change Statement The primary purpose of this revision is to issue identified in CR-HQN-2015-00751 regarding notification of Reactor Engineering of non-waste shipments containing SNM.

Attachments 9.2, 9.3, 9.4, 9.5, 9.6, 9.7, 9.8, 9.9: replaced NRC form 540/541 with the manifest Updated section 8 with information provided by the GGNS Commitment Review Added missing document numbers for W3 and RBS entries in section 8.

Added commitment number for GGNS entry in section 8 regarding GNRI-92/00195 Deleted W3 commitment P-11757 from section 8 per W3 Commitment Review response.

Associated PRHQN #: 2015-00363 Procedure Writer: Ron Schwartz Contains Proprietary Information: YES NO

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 2 OF 47 Radioactive Shipping Procedure TABLE OF CONTENTS Section Title Page 1.0 PURPOSE

................................................................................................................. 3

2.0 REFERENCES

................................................................................................................. 3 3.0 DEFINITIONS................................................................................................................. 4 4.0 RESPONSIBILITIES............................................................................................................ 4 5.0 DETAILS

................................................................................................................. 5 5.1 PRECAUTIONS AND LIMITATIONS.................................................................................... 5 5.2 GENERAL REQUIREMENTS............................................................................................... 8 5.3 WASTE CLASSIFICATION................................................................................................ 17 5.4 WASTE CHARACTERISTICS............................................................................................ 17 6.0 INTERFACES............................................................................................................... 18 7.0 RECORDS

............................................................................................................... 18 8.0 SITE SPECIFIC COMMITMENTS....................................................................................... 19 9.0 ATTACHMENTS............................................................................................................... 20 ATTACHMENT 9.1 RADIOACTIVE SHIPMENT DOCUMENT CHECKLIST......................................... 21 ATTACHMENT 9.2 SHIPPING CHECKLIST - LSA/SCO/EXCLUSIVE USE & DOMESTIC.................. 23 ATTACHMENT 9.3 SHIPPING CHECKLIST - TYPE A.................................................................. 26 ATTACHMENT 9.4 SHIPPING CHECKLIST - TYPE B.................................................................. 28 ATTACHMENT 9.5 SHIPPING CHECKLIST - LIMITED QUANTITY.................................................. 32 ATTACHMENT 9.6 SHIPPING CHECKLIST - EMPTY PACKAGING................................................ 33 ATTACHMENT 9.7 SHIPPING CHECKLIST - INSTRUMENTS AND ARTICLES.................................. 34 ATTACHMENT 9.8 SHIPPING CHECKLIST - ARTICLES CONTAINING NATURAL/DEPLETED URANIUM OR NATURAL THORIUM................................................................ 35 ATTACHMENT 9.9 SHIPPING CHECKLIST - LIMITED QUANTITY - NEUTRON METERS................... 36 ATTACHMENT 9.10 PACKAGING REFERENCE TABLES............................................................... 37 ATTACHMENT 9.11 RADIATION & CONTAMINATION SURVEY LIMITS FOR RADIOACTIVE MATERIAL SHIPMENTS

............................................................................................................... 40 ATTACHMENT 9.12 VEHICLE INSPECTION CHECK SHEET........................................................... 42 ATTACHMENT 9.13 RADIOACTIVE MATERIAL SHIPMENT TRUCK SURVEY FORM - TYPICAL........... 43 ATTACHMENT 9.14 INSTRUCTIONS FOR MAINTENANCE OF EXCLUSIVE USE SHIPMENT CONTROLS 44 ATTACHMENT 9.15 APPENDIX A: NOTIFICATIONS - SITE SPECIFIC............................................. 45

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 3 OF 47 Radioactive Shipping Procedure 1.0 PURPOSE The purpose of this procedure is to provide guidance for shipping radioactive material or waste in accordance with applicable regulations. No required Technical Specification surveillances or non air international shipments are covered in this procedure.

2.0 REFERENCES

[1]

Code Of Federal Regulations, Title 10, Parts 20, 30, 61 & 71

[2]

Code Of Federal Regulations, Title 40, Parts 240-246

[3]

Code Of Federal Regulations, Title 49, Parts 107-178 & 393

[4]

International Air Transportation Association (IATA) Dangerous Goods Regulation

[5]

Regulations For Radioactive Waste Transportation, Mississippi Code Of 1972; Section 45-14-67, Mississippi Radioactive Waste Transportation Act, Latest Revision -

Mississippi Emergency Management Agency (MEMA)

[6]

Branch Technical Position On Radioactive Waste Form, Classification, Concentration Averaging, And Encapsulation

[7]

NRC I.E. Notice 79-19, Packaging of Low-Level Radioactive Waste for Transport and Burial

[8]

Energy Solutions Inc. State of Utah Radioactive Material License, UT2300249, Latest Revision

[9]

Energy Solutions Inc. Containerized Waste Facility (CWF) Waste Acceptance Criteria (WAC), TSC-2, Latest Revision

[10]

WMG/P-045, RADMAN Software & WMG/P-009, RAMSHP Software

[11]

NRC Generic Letter 91-02

[12]

NuReg 1608

[13]

25 Texas Administrative Code §289.252 "Licensing of Radioactive Material" and

§289.257 "Packaging and Transportation of Radioactive Material"

[14]

10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material

[15]

INPO Event Report Level 2 11-1, Inadequate Collective Radiation Exposure Performance Improvements

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 4 OF 47 Radioactive Shipping Procedure 3.0 DEFINITIONS

[1]

Transportation definitions are found in 49CFR173.403 and 49CFR171.8.

[GGNS P-18744]

[2]

Validation - an independent review of the package characterization using the Radwaste Shipping Computer Program.

[3]

Bulk packaging means a packaging, other than a vessel or a barge, including a transport vehicle or freight container, in which hazardous materials are loaded with no intermediate form of containment. A Large Packaging in which hazardous materials are loaded with an intermediate form of containment, such as one or more articles or inner packagings, is also a bulk packaging. Additionally, a bulk packaging has:

(a) a maximum capacity greater than 450 L (119 gallons) as a receptacle for a liquid; (b) a maximum net mass greater than 400 kg (882 pounds) and a maximum capacity greater than 450 L (119 gallons) as a receptacle for a solid; or (c) a water capacity greater than 454 kg (1000 pounds) as a receptacle for a gas as defined in §173.115.

[4]

Freight container means a reusable container having a volume of 64 cubic feet or more, designed and constructed to permit being lifted with its contents intact and intended primarily for containment of packages (in unit form) during transportation.

4.0 RESPONSIBILITIES

[1]

The RPM Peer Group is responsible for the implementation of this procedure and must approve any changes or revisions to this procedure.

[2]

Each site Senior Nuclear Executive (SNE) is responsible for ensuring that necessary site staff implements this procedure.

[3]

The Low Level Radwaste (LLRW) Focus Group is responsible for evaluating and recommending changes and revisions to this procedure.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 5 OF 47 Radioactive Shipping Procedure 4.0 continued

[4]

The Requestor (the individual requesting shipment of radioactive material from site) is responsible for informing the Radwaste Shipper (SHIPPING SUPERVISOR), to ensure proper radioactive material shipping classification and required supporting documentation be generated. The SHIPPING SUPERVISOR SHALL ensure all aspects of this procedure, applicable DOT, NRC, and burial site requirements are complied with, which includes:

(a)

Assign a Radiation Protection technician to perform tasks delineated in this procedure.

(b)

Inform the Reactor Engineering Manager should any fissile materials need to be shipped.

[5]

The person designated & qualified to complete shipments (normally the RP specialist) is responsible for completing the shipment in accordance with this procedure and all state and federal regulations.

5.0 DETAILS 5.1 PRECAUTIONS AND LIMITATIONS

[1]

The provisions within 49CFR173.436 are not to be used, unless approved by the Radiation Protection Manager (RPM) or designee.

[2]

Evaluate material for Category 1 and 2 Quantities of Radioactive Material in accordance with EN-RW-106, Integrated Transportation Security Plan, AND ensure all security issues have been satisfied in accordance with EN-RW-106.

[3]

Category 1 and 2 Quantities of Radioactive Material require significant lead time (at least 2 weeks) due to additional requirements for the physical protection of Category 1 and 2 Quantities of Radioactive Material. Refer to 10 CFR Part 37 AND EN-RW-106 for further details.

[4]

The following is applicable to specification packages above the general design packaging. Ensure non-waste shipments containing liquid material contains an inner lining OR enough absorbent material to absorb at least two times the volume of liquid in the shipment or so to contain liquid within an over-pack or other containment device, should leakage occur. See 49CFR173.412(k)

[5]

Sources to be shipped need to be checked to see if they fall under the requirements of the National Source Tracking System in 10 CFR 20.2207. IF the source meets the activity limits of Appendix E of 10 CFR 20, THEN ensure a transaction report is completed, using NRC Form 748 (or equivalent).

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 6 OF 47 Radioactive Shipping Procedure 5.1 continued

[6]

A receipt copy of the Radioactive Shipment Manifest from the burial site or waste processor shall be received within 20 days of shipment departure, confirming waste shipment delivery.

[7]

IF receipt copy of the Radioactive Shipment Manifest is not received from the burial site or waste processor, THEN an investigation shall be initiated to locate the shipment [10 CFR 20, appendix G]. This investigation shall include tracing the shipment and filing a written report with the NRC regional office within two weeks of the completion of the investigation.

[8]

As required by NRC Generic Letter 91 02, a report to the NRC's Director of the Division of Low Level Waste Management and Decommissioning AND to the designated State disposal site regulatory authority is required IF any of the following conditions result from handling of radwaste. The report shall be prepared and mailed within 30 days of the incident (a)

The failure of high integrity containers used to ensure a stable waste form.

Container failure can be evidenced by changed container dimensions, cracking, or damage resulting from mishandling (e.g., dropping or impacting against another object).

(b)

The misuse of high integrity containers, evidenced by a quantity of free liquid greater than 1 percent of container volume, or by an excessive void space within the container. Such misuse is prohibited by 10 CFR 61.56.

(c)

The production of a solidified Class B or C waste form that has any of the following characteristics:

Contains free liquid in quantities exceeding 0.5 percent of the volume of the waste Contains waste with radionuclides in concentrations exceeding those considered during waste form qualification testing accepted by the regulatory agency, which could lead to errors in assessment of waste class Contains a significantly different waste loading than that used in qualification testing accepted by the regulatory agency Contains chemical ingredients not present in qualification testing accepted by the regulatory agency, AND those quantities are sufficient to unacceptably degrade the waste product.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 7 OF 47 Radioactive Shipping Procedure 5.1[8](c) continued Shows instability evidenced by crumbling, cracking, voids, softening, disintegration, non-homogeneity, or dimensional changes Evidence of processing phenomena that exceed the limiting processing conditions identified in applicable topical reports on process control plans, e.g., foaming, temperature extremes, premature or slow hardening, and production of volatile material

[9]

For an outgoing shipment, the 10 CFR 20 postings shall be removed prior to the vehicle leaving site.

[10]

High Risk Shipments - When preparing shipments that contain tools and equipment that may have been subjected to discrete radioactive particle (DRP) contamination, site is to utilize as many of the following actions to ensure compliance with 49CFR173.441 (a)

Validate personnel who package the material have had appropriate function specific training (on-site or vendor) to load radioactive packages that may contain DRP contamination.

(b)

Use an enclosed transport vehicle or overpack to provide a greater margin associated with contact dose rates on the container. (When any package on a conveyance exceeds 160 mR/hr contact, RPM approval is needed for shipment without use of an enclosed transport vehicle or over pack). This approval must be documented on the appropriate radiological survey form. (See additional survey requirements in step 5.2[17] when dose rates exceed eighty percent administrative limit.)

(c)

Sealing of equipment with appropriate wrapping material to prevent migration of residual DRPs (d)

Hydrolazing the equipment prior to removal from pool for packaging (e)

Use of a robust/shielded container to preclude the adverse effects associated with Discrete Hot Radioactive Particle migration during transport (f)

Use of fixatives such as a strippable or dissolvable coating to positively entrain and affix DRPs (g)

IF particles are suspected, THEN consider disassembling the equipment for inspection

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 8 OF 47 Radioactive Shipping Procedure 5.1 continued

[11]

For shipments that contain resin OR other known or suspected methane-producing waste, an explosive gas test may be required in accordance with the applicable cask Certificate of Compliance.

[12]

For shipments of material that exceed 1 R/hr at three meters from the unshielded material, the material must be packaged in an NRC approved Type B package, and the Proper Shipping Name will be UN 3329, Radioactive material, Type B(M) package, fissile, UN 2917, Radioactive material, Type B(M) package non fissile or fissile-excepted, UN 3328, Radioactive material, Type B(U) package, fissile, OR UN 2916, Radioactive material, Type B(U) package non fissile or fissile-excepted.

The material IS no longer LSA or SCO.

[13]

[For GGNS Only] Any Grand Gulf contracts written for the free release of radioactive material must include the requirement that any material not free released must be returned to the site for final disposition.

5.2 GENERAL REQUIREMENTS

[1]

As a prerequisite to loading any shipment as exclusive use ensure the transport vehicle has been radiologically surveyed IAW 49 CFR 173.443 (c).

[2]

Flowchart steps may be performed non-sequentially provided the applicable regulations are satisfied prior to shipment. All regulatory requirements are met prior to using a specification packaging for transporting radioactive material.

[3]

Ensure lifting devices are inspected prior to use and /or annually by qualified personnel. ALARA considerations may limit inspection (camera usage is an available option).

[4]

The requirements of 49CFR173.410 through 417, 10CFR71 & applicable NRC Certificates of Compliance for each specification packaging are met and/or verified prior to loading and transport radioactive material/waste in them.

[GGNS P-18754,18756,32586,32606]

[5]

All applicable shipper permits for the appropriate states and regulatory bodies have been obtained (this list may not be all inclusive).

(a)

Mississippi Emergency Management Agency (MEMA) Waste Transport Permit (as required)

(b)

Department of Transportation Hazardous Material Certificate of Registration (c)

Tennessee Waste Delivery Permit

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 9 OF 47 Radioactive Shipping Procedure 5.2[5] continued (d)

Utah Waste Permit (e)

Notifications per EN-RW-106 for Category 1 Quantities of Radioactive Material

[6]

Notify Reactor Engineering for initiation of a Special Nuclear Material accounting record prior to shipment of any quantity of U-233, U-235 or plutonium as required by 10CFR74.19.

[7]

Verify DOE/NRC Form 741 evaluation has been completed by Reactor Engineering prior to shipment of one gram or more of U-233, U-235, or Plutonium as required by 10CFR74.15. 49CFR173.434 can be used in the calculation of activity-mass relationship for uranium and natural thorium.

[8]

All applicable state, federal, burial site and processor notifications are made.

[9]

WMG Software or equivalent computer software is available.

[10]

All personnel working under this procedure are trained to the specific level required in 49CFR172.700 Subpart H, I.E. Notice 79-19, applicable computer software training &

40CFR262 (when applicable). [W3 P-11759], [RB P-14510]

[11]

WHEN utilizing transport casks as a specification package, THEN handle in accordance with the respective vendor manual and/or Certificate of Compliance. A site procedure may be used in lieu of the vendor manual, IF qualified by the appropriate site group and management.

(a)

Complete applicable cask users check off sheet - perform step validation (verify that the container procedure steps that implement the Certificate of Compliance implementing requirements has a second verification step performed) as a part of vendor oversight when shipment is made by the appropriate Certificate of Compliance.

(b)

Procedures or instructions needed to safely open the cask/package are to be sent to the consignee or verified that possession exists.

(c)

The transport cask may be used as a general design package versus its approved specification level (e.g. Industrial Package II, Type A, Type B).

[12]

Document compliance with applicable regulations by using the appropriate checklists (Category 1 and 2 Quantities of Radioactive Material have additional checklists in EN-RW-106). The level of review and validation of shipping paperwork is performed by personnel trained per Step 5.2[10]. Shipments that require placarding are reviewed prior to the departure of the conveyance from the site.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 10 OF 47 Radioactive Shipping Procedure 5.2 continued

[13]

Radioactive material AND waste loaded into packages must meet appropriate requirements of 10CFR71.87, 49CFR173.410-417, 49CFR173.475, 49CFR173.24, 24a, 24b & 25a. [GGNS P-18738,18741,18742,18743]

[14]

Specification communications (Shipment documentation, Marking, Labeling, Placarding, and Emergency Response) are to be completed in accordance with appropriate sections of 49CFR172 Non-specification markings are to be applied in accordance with designated reference document (i.e. burial site waste class, Radioactive-LSA, Radioactive-SCO & Radioactive / UN ID number on appropriate excepted packages for limited quantities).

(a)

Specification Marking is to be completed in accordance with 49CFR172.300-338. IF an overpack is used to consolidate radioactive packages, THEN compliance with 49CFR173.448(g) is required. IF a sunscreen or personnel barrier is being used over a specification package, THEN the package itself is required to have the UN ID number markings applied directly to the package surface as well as the sunscreen or personnel barrier.

(b)

Specification Labeling is to be completed in accordance with 49 CFR 172.400-450

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 11 OF 47 Radioactive Shipping Procedure 5.2[14] continued (c)

Placarding is to be completed in accordance with 49CFR172.500-560. Use the following table for guidance on Placarding requirements.

Packaging Type Placards on Package Placards on Vehicle Reference Non - Bulk None 4 Placards 172.504: 172.516:

173.427(a)(6)(v)

Bulk < 640 ft3 (non-freight container) 4 Placards 4 Placards 172.504: 172.514:

173.427(a)(6)(v) 2 Placards 4 Placards 172.504: 172.514(c) 2 Labels 4 Placards 172.504: 172.514(c)

Bulk >640 ft3 (non-freight container) 4 Placards 4 Placards 172.504: 172.514(a):

173.427(a)(6)(v)

Freight Container <640 ft3 4 Placards None if visible

172.504: 172.516(a) 2 Placards 4 Placards 172.504: 172.514(c) 2 Labels 4 Placards 172.504: 172.514(c)

Freight Container > 640 ft3 4 Placards None if visible

172.504: 172.512(a):

172.516(a)

If not visible, then 4 Placards are required on the transport vehicle (there is no prescribed preference for application of the placarding requirements)

(d)

Emergency Response Information is completed in accordance with 172.600 -

606, and consists of documented emergency response information provided with the shipping papers, and an emergency response telephone number that is monitored at all times the hazardous material is in transportation. The requirement for a monitored phone line may be met either on site (ie. Control room), or by a contracted agency or organization such as Chem-trec.

[GGNS P-24924]

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 12 OF 47 Radioactive Shipping Procedure 5.2 continued

[15]

Tritium gun sights are handled per EN-NS-225, Tactical Engagement Simulation System.

(a)

Security officers may transport individual gun sights in performance of their normal duties with no restrictions.

(b)

Transportation of gun sights in Entergy-owned MILES trailers may be accomplished by security personnel or contracted common carriers meeting the requirements Section 5.0 of EN-NS-225. The following should be met:

(1)

Security will affirm to RP that the individual gun sights are operational.

(2).7 will be completed (no shipment paperwork is required to accompany the shipment but a bill of lading may be utilized at the sites RP department discretion)

(c)

Transportation of gun sights under the direct control of DOE personnel is exempt from these requirements.

[16]

Ship radioactive material AND/OR waste in accordance with the Flow Charts 1 and 2 AND complete all applicable attachments.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 13 OF 47 Radioactive Shipping Procedure 5.2[16] continued Flow Chart 1: Radioactive Waste Radwaste for shipment Initial package evaluation (dose/contamination/isotopic)

Determine D.O.T & waste classification IAW 49CFR173 &

10CFR61 Satisfy conditions of Section 5.1 - 5.2 Ensure Receivers license IAW 10CFR30.41 Does package satisfy contamination &

radiation limits?

49CFR173 Subpart 1 Decontaminate and/or repackage material (as needed)

Ensure package label & marking IAW 49CFR172 (for example White I, Yellow II, or Yellow III label, Reportable Quantity-RQ, Type A, Type B, Gross Mass )

Is waste being shipped for burial?

Meets processor site criteria Meets burial site criteria Load/shore/brace package(s) on vehicle Complete vehicle inspection &

survey Complete shipping documentation Ship waste Record information in waste tracking program (RW Liability Spreadsheet)

Acknowledgement of receipt IAW 10CFR20 App G No Yes No Yes Determine if Category 1 or 2 Quantities of Radioactive Material per EN-RW-106.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 14 OF 47 Radioactive Shipping Procedure 5.2[16] continued

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 15 OF 47 Radioactive Shipping Procedure 5.2[16] continued

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 16 OF 47 Radioactive Shipping Procedure 5.2 continued

[17]

Surveys of packages and conveyances are completed with instrumentation similar to the facility receiving the material/waste. Instrumentation normally utilized for shipments are those that contain GM detectors.

[18]

The radiation surveys for shipments and packages covered under the requirements of 49CFR173.421, 424, 426, 428, 49CFR177.842, 10CFR71.47 and 49CFR173.441 are not to exceed eighty percent of the levels outlined in the appropriate requirement.

Radiation Protection Supervision may grant permission to ship packages or conveyances above the eighty percent administrative limit, in Attachment 9.11, Radiation & Contamination Survey Limits for Radioactive Material Shipments, provided the guidelines listed in 5.2[18] (a) and 5.2[18] (b) are performed.

(a)

The dose rate survey is performed independently by at least two qualified (ANSI qualifications required) Radiation Protection Technicians utilizing different survey instruments of similar types.

(b)

The verification survey instrument utilized in step listed above is to be source checked prior to shipment departure.

[19]

After unloading exclusive use vehicles, surveys must be performed prior to releasing the vehicle back to an in-service status. The radiation dose rate at every accessible surface is 0.5 mR/hr or less and the removable contamination is less than the levels in 49 CFR 173.443(a).

[20]

All packages and conveyances are to meet the contamination levels of less than 1000 dpm/100 cm2 of non-fixed beta-gamma and less than 20 dpm/100 cm2 of non-fixed alpha. Radiation Protection Supervision may authorize the shipment of packages and conveyances exceeding these limits up to those listed in 49CFR173.443.

[21]

The carrier to be used for shipments placarded Radioactive, Type A, Type B or Highway Route Controlled Quantity (HRCQ) maintains a Transportation Security Plan covering applicable requirements of 49CFR172.800-804. The use of contractual agreements may be a method to ensure this is met. Category 1 and 2 Quantities of Radioactive Materials require additional transportation security measures, which are addressed in EN-RW-106, Integrated Transportation Security Plan.

[22]

Each fissile material, controlled shipment must be transported in accordance with 49CFR177.842(f) and applicable fissile requirements of 10CFR71.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 17 OF 47 Radioactive Shipping Procedure 5.2 continued

[23]

Packages required to be loaded by Entergy on to conveyances under the requirements of 49CFR173.427(a)(6)iii, 49CFR173.441(b)(1)ii, 49CFR177.842, 49CFR173.448(a) or applicable Certificate of Compliances are to be accomplished to meet the applicable requirements of the consignee performing the off-loading at the shipments final destination. The package blocking, bracing and shoring is performed in conjunction to support the carrier in meeting the requirements for associated parts of 49CFR393.

(a)

On-site securement of loads while on company owned property is covered by EN-IS-120 including steps 5.3 and 5.9.

[24]

ALARA should be considered when loading packages. Load packages with higher dose rates in the center with the lower dose rates facing outward whenever possible.

Dose rate surveys should be performed during the loading process to ensure DOT requirements are met.

5.3 WASTE CLASSIFICATION

[1]

Determination of concentration in waste containers may be performed by direct sampling or indirect measurements.

[2]

Classification of waste is to be accomplished in accordance with the requirements of 10CFR61.55.

5.4 WASTE CHARACTERISTICS

[1]

Waste shipments sent to disposal facilities are to meet the applicable requirements of 10CFR61.56, Certificate of Compliance (if shipment required), burial site criteria and burial site by-product radioactive material license.

[2]

Waste shipments sent to processors of radioactive waste must meet the applicable portions of 10CFR61.56, Certificate of Compliance (if shipment required), processor waste acceptance guidelines/criteria AND processor by-product radioactive material license.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 18 OF 47 Radioactive Shipping Procedure 6.0 INTERFACES

[1]

Entergy Quality Assurance Program Manual Control

[2]

EN-RW-106, Integrated Transportation Security Plan

[3]

EN-LI-102 Corrective Action Process

[4]

EN-RP-143, Source Control

[5]

EN-NS-225, Tactical Engagement Simulation System

[6]

EN-IS-120 Motorized Vehicle Safety 7.0 RECORDS

[1]

Retain records in accordance with 49CFR173.415, along with 10CFR20 Appendix G and 10CFR30.51.

[2]

Transfer all applicable records to site-specific permanent plant files. If files require modification, both the original and modified files will be retained and sent as an official file per this section. These records include the following as applicable:

NRC Forms 540 and 541.1 (used for shipments with notifications - with page 2 of 2 being optional)

Attachments 9.2 through 9.9.12 Emergency Response Documentation Exclusive Use Documentation Package and Vehicle Surveys State Notifications Packaging and Dewatering Checklists RADMAN Documentation/Isotopic Information

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 19 OF 47 Radioactive Shipping Procedure 8.0 SITE SPECIFIC COMMITMENTS Site Document Commitment Number or Reference NMM Procedure Section/Step All 49 CFR 173 421, 422 & 423 Att 9.5, 9.8, 9.9 All 49 CFR 173 424 Att 9.7 All 49CFR 173 426 Att. 9.8 All 49 CFR 173 427 (a) (6) (i) - (iii) & (iv),

(vi) &(b)

Att 9.2 All 49 CFR 173 428 Att 9.6 All 49 CFR 173 433 5.2[16]

All 49 CFR 173 435 5.2[16]

All 49 CFR 173 441 (a) (b) & (c) 5.2[18]

All 49 CFR 173 443 (a) & (b) 5.2.[18]

All 49 CFR 173 441 (c) 5.2[18]

All 49 CFR 173 448 (a) & (g) 5.2 [23]

All 49 CFR 173 465, 466 Att. 9.3 All 49 CFR 173 475 (a), (b), (c), (e), (f) & (i)

Att 9.3 All 49 CFR 173 471 (a), (b)

Att. 9.4 All 49 CFR 173 475 5.2 [11]

All 49 CFR 177 842 (a), (b), (c), (d) & (f) 5.2[16], [22]

All 49 CFR 177 843 5.2[19]

All 49 CFR 178 350 (a) & (b)

Att 9.3 All 10 CFR 20 1501 (a) 5.2[18]

All 10 CFR 20 2001 (a) 5.3 and 5.4 All 10 CFR 20 2101 (a), (b) & (c) 5.2[14]

All 10 CFR 20 2005 (a), (c) 5.3 and 5.4 All 10 CFR 20 2006 (b) - (d) 5.3 and 5.4 All 10 CFR 20 Appendix G 5.3 and 5.4 All 10 CFR 30 41 (c) & (d) 5.2[12]

All 10 CFR 61 55 5.3 and 5.4 All 10 CFR 61 56 5.3 and 5.4 All 10 CFR 61 57 5.3 and 5.4 All 10 CFR 71 5(a) (1) (iv) & (vi), 5(b)

5.2[10],[14]

All 10 CFR 71 87 a-k All 10 CFR 71 97 (a), (b), (c)

Att 9.2,Att. 9.4

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 20 OF 47 Radioactive Shipping Procedure Site Document Commitment Number or Reference NMM Procedure Section/Step Grand Gulf FSAR 11.4.1.2 S7 5.2[14]

Grand Gulf FSAR 11.4.2.3.C.S 3,S 4 5.2[14]

Grand Gulf FSAR 11.4.2.4.3 5.2[14]

Grand Gulf FSAR 11.4.2.4.5.S 4 5.2[14]

Waterford 3 W3P83-2211 P-11759 5.2[10]

River Bend RBF1-96-0284 P-14510 5.2[10]

All Reg. Guide 1.21 Appendix A C. S1, S2 & S3 5.2[14]

All ANSI N13.2 4.7.4 5.2[14]

All GNRI-91/00117 IN 91-35 5.2[14]

Grand Gulf GNRI-92/00195 P.3OF4, PARA 2 P-24924 5.2[14] (d)

Grand Gulf GNRI-92-00149 92-24 5.2[14] (d)

Grand Gulf QAPM A.1.C Grand Gulf QAPM B.7.D Grand Gulf 49CFR172 Grand Gulf 49CFR173.24 P-18738 5.2[13]

Grand Gulf 49CFR173.25(A)(2-4)

P-18741,18742,18743 5.2[13]

Grand Gulf 49CFR173.403 P-18744 3.0[1]

Grand Gulf 49CFR173.411(A)

P-18754 5.2[4]

Grand Gulf 49CFR173.415(A)S1 P-18756 5.2[4]

Grand Gulf 49CFR173.410 P-32586 5.2[4]

Grand Gulf 49CFR173.411B P-32606 5.2[4]

Covered by directive as a whole or by various paragraphs of the directive.

9.0 ATTACHMENTS 9.1 Radioactive Shipment Document Checklist 9.2 Shipping Checklist - LSA/SCO / Exclusive Use & Domestic 9.3 Shipping Checklist - Type A 9.4 Shipping Checklist - Type B 9.5 Shipping Checklist - Limited Quantity 9.6 Shipping Checklist - Empty Packaging 9.7 Shipping Checklist - Instruments and Articles 9.8 Shipping Checklist - Articles Containing Natural/Depleted Uranium or Natural Thorium 9.9 Shipping Checklist - Limited Quantity - Neutron Meters 9.10 Packaging Reference Tables 9.11 Radiation & Contamination Survey Limits for Radioactive Material Shipments 9.12 Vehicle Inspection Check Sheet 9.13 Radioactive Material Shipment Truck Survey Form-Typical 9.14 Instructions for Maintenance of Exclusive Use Shipment Controls 9.15 Appendix A: Notifications - Site Specific

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 21 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.1 RADIOACTIVE SHIPMENT DOCUMENT CHECKLIST Sheet 1 of 2 (sample form)

Shipment Number:

Date of Departure:

Description:

Destination:

Notifications:

(Date/Time)

Vermont (48 hr / 2 hr)

/

Mass (24 hr / 2 hr)

/

Gill MA (48 hr / 2 hr)

/

Mississippi (4 days)

/

N/A SC (72 hrs)

/

N/A Arkansas (Prior to leaving site)

/

N/A Emergency Response information delivered to appropriate location (i.e., Control Room, RP Office)

Total Activity:

mCi Carrier:

Completed By:

Print/Sign Date Reviewed By:

Print/Sign Date Document Package Completed:

Print/Sign Date

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 22 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.1 RADIOACTIVE SHIPMENT DOCUMENT CHECKLIST Sheet 2 of 2 Limited Quantity Shipments Consignee Driver Shipper Manifest / Shipping Record (if required)

Isotopic Analysis - Nuclide Concentration (if performed)

Chain of Custody (if required)

NRC/DOT Messages (RAMSHP)(if performed)

DOT Classification (RAMSHP)(if performed)

DOT Shipment Classification (RAMSHP)(if performed)

Package Characterization Report (RAMSHP)(if performed)

Package Survey (if required)

Radioactive Materials Shipment Consignee Driver Shipper Manifest / Shipping Record Isotopic Analysis - Nuclide Concentration (if performed)

Chain of Custody (if required)

NRC/DOT Messages (RAMSHP)(if required)

DOT Classification (RAMSHP)(if required)

DOT Shipment Classification (RAMSHP)(if required)

Package Characterization Report (RAMSHP)(if required)

Package Survey Emergency Response Information(if required)

Truck Survey / Exclusive Use Statement(if required)

Vehicle Mechanical Inspection Report State (i.e. Ark, Mass) Notification (placarded vehicle only)(if required)

Driver Routing Instructions(if required)

Bill of Lading (if Required)

Notice of Shipment(if required)

Material Processor Shipment Consignee Driver Shipper Manifest (NRC 540/540A, 541/541A)

Isotopic Analysis - Nuclide Concentration (if performed)

Dewatering System Sequence Check Sheet (VYOPF 2153.01)

NRC/DOT Messages (RADMAN)(if performed)

DOT Classification (RADMAN)(if performed)

DOT Shipment Classification (RADMAN)

Package Characterization Report (RAMMAN)(if performed)

Nuclide Concentration Summary (RADMAN)(if performed) 10 CFR Part 61 Documentation (RADMAN)

Package Survey Emergency Response Information Truck Survey / Exclusive Use Statement Vehicle Mechanical Inspection Report State (i.e. Ark, Mass) Notification (placarded vehicle only)(if required)

Driver Routing Instructions(if required)

Waste Profile Form (i.e. Energy Solutions, Studsvik, Waste Control Specialists)

Bill of Lading (if Required)

Notice of Shipment(if required)

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 23 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.2 SHIPPING CHECKLIST - LSA/SCO/EXCLUSIVE USE & DOMESTIC Sheet 1 of 3 Shipment Number:

1.

IF shipment meets Category 1 and 2 Quantities of Radioactive Material levels, THEN refer to EN-RW-106, Integrated Transportation Security Plan, in addition to this checklist.

NOTE The licensee is required to use the Licensee Verification System (LVS) developed by the NRC or contact the regulatory agency (NRC or Agreement State) to verify that the license is valid before shipping a category 1 or 2 quantity of radioactive material. Refer to EN-RW-106.

[CR-WF3-2014-05098]

2. Verified transferees license authorizes the receipt of the type, form and quantity of byproduct material to be transferred via one of the methods listed in 10CFR30.41(d) 1 through 5 or DOE Prime Contractor exempt status shall be kept on file.

Consignees License Number:

Expiration date

3. The package(s) meet the definition of LSA/SCO per 49CFR173.403:

4. If radiation level at 3 meters from unshielded material does not exceed 10mSv/hr (1 Rem/hr) then select one of the following packaging options (indicate option chosen by circling one):

49CFR173.427 Table 6 (IP-1, 2 or 3) meeting the requirements of 49CFR173.411, 49CFR173.410 & 49CFR173.24, 24a & 24b

-OR-Specification 7A Type A meeting the requirements of 49CFR178.350If a sunscreen or personnel barrier is being used over a specification package then the package itself is required to have the markings applied directly to the package surface as well as the sunscreen or personnel barrier.

-OR-If package does not exceed A2 quantity limit, packaging meeting the requirements of 49CFR173.24, 24a & 49CFR173.410 is allowed for domestic transport only:

o Non-specification marking in accordance with 49CFR173.427(6)(vi) Exterior of package marked Radioactive-LSA or Radioactive-SCO Exterior of package containing a hazardous substance marked RQ o

Package is excepted from Specification marking, and labeling, However the following are required:

Shipping Papers Emergency Response Information Placarding (required whenever Label is Yellow III or Excl Use LSA)

-OR-

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 24 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.2 SHIPPING CHECKLIST - LSA/SCO/EXCLUSIVE USE & DOMESTIC Sheet 2 of 3 Shipment Number:

For LSA-I and SCO-I transported in a closed vehicle, bulk packaging meeting the requirements of 49CFR173.24, 24a & 24b is allowed

-OR-For LSA-I and SCO-I transported unpackaged in accordance with 49CFR173.427(c)

5. Conveyance activity within limits of 49CFR173.427 Table 5

6. Specific written instructions for maintenance of exclusive use shipment controls included with the shipping papers in accordance with 49CFR173.403 Instructions for Maintenance of Exclusive Use Shipment Controls

7. Radiation levels within limits of 49CFR173.441, all EN-RW-102 requirements for radiation levels met

8. Contamination levels within limits of 49CFR173.443, all EN-RW-102 requirements for contamination levels met

9. Specification communication is in accordance with 49CFR172 Subpart C, F& G (Shipping Papers, Placarding, and Emergency Response Information respectively).

10. Complete Bill of Lading (if applicable) - highlight the emergency response information on non-computerized generated forms

11. Complete Vehicle Inspection

12. (If applicable) Complete MEMA 5-3 and MEMA 5-4, fax MEMA 5-3 no later than four days prior to shipment. Notify MEMA of all changes prior to shipment leaving site.

13. Complete the applicable HIC Certification for Disposal and Checklist, as applicable.

14. For shipments that contain resin or other known or suspected methane producing waste, perform an explosive gas test as required in accordance with the applicable cask Certificate of Compliance.

15. If waste shipment for burial, the package:

a. Is classified using the criteria of 10CFR61.55

b. Meets the requirements for waste characteristics of 10CFR61.56

c. Is labeled in accordance with 10CFR61.57

d. Meets the acceptance requirements of the Burial Site Criteria and License

16. If waste shipment to processor, the package:

a. Meets the acceptance requirements of the Processor Criteria and License

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 25 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.2 SHIPPING CHECKLIST - LSA/SCO/EXCLUSIVE USE & DOMESTIC Sheet 3 of 3 Shipment Number:

17. If package is an IP-3, the requirements of 49CFR173.412(a)-(j) are met, including a tamper indicating feature installed on the package or may be installed on the cargo compartment if the shipment is closed vehicle exclusive use

18. General transportation requirements of 49CFR173.448 are met, including cargo secured to prevent shifting

19. The package meets the requirements of 49CFR173.475 prior to shipment.

20. If any portion of the transportation is to be by air, the applicable requirements of IATAs Dangerous Goods Regulations have been met

21. Complete the applicable Advance Notification Form (if applicable) for shipments to processor EnergySolutions - Oak Ridge, TN Studsvik Processing Facility LLC - Erwin, TN EnergySolutions - Clive, UT

22. The carrier maintains a Transportation Security Plan covering applicable requirements of 49CFR172.800-804. The use of a contractual agreement may be utilized to ensure this is met.

23. IF shipment contains sources applicable to National Source Tracking System in 10 CFR 20.2207 and meets the activity limits of Appendix E of 10 CFR 20, ensure a transaction report is completed, via NRC Form 748

24. WHEN shipment involves Category 1 Quantities of radioactive material, THEN, perform advance notification per EN-RW-106.

25. IF material classified LSA III, ensure all applicable documentation is completed IAW 49CFR173.468.

26. IF material contains measured quantities of Special Nuclear Material (U-233, U-235 or plutonium),

THEN forward a copy of the manifest to Reactor Engineering.

Checklist Completed By:

Date:

Validation/Review Completed By:

Date:

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 26 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.3 SHIPPING CHECKLIST - TYPE A Sheet 1 of 2 Shipment Number:

1.

IF shipment meets Category 1 and 2 Quantities of Radioactive Material levels, THEN refer to EN-RW-106, Integrated Transportation Security Plan, in addition to this checklist.

NOTE The licensee is required to use the Licensee Verification System (LVS) developed by the NRC or contact the regulatory agency (NRC or Agreement State) to verify that the license is valid before shipping a category 1 or 2 quantity of radioactive material. Refer to EN-RW-106.

[CR-WF3-2014-05098]

2. Verified transferees license authorizes the receipt of the type, form and quantity of byproduct material to be transferred via one of the methods listed in 10CFR30.41(d)1 through 5 or DOE Prime Contractor exempt status shall be kept on file.

Consignees License Number:

Expiration date

3. Package activity does not exceed limits of 49CFR173.431(a)

4. Packaging is a Type A package meeting the applicable requirements of 49CFR173.410, 49CFR173.24, 24a & 24b, 49CFR173.412, 49CFR173.415, 49CFR173.418, 49CFR173.419 and 49CFR173.442

5. Radiation levels within limits of 49CFR173.441, all EN-RW-102 radiation level requirements met

6. Contamination levels within limits of 49CFR173.443, all EN-RW-102 contamination level requirements met

7. Specification communication IAW 49CFR172 Subparts C, D, E, F & G are complete:

a. Shipping Papers - highlight the emergency response information on non-computerized generated forms

b. Emergency Response Information

c. Labeling

d. Marking

e. Placarding (required whenever Label is Yellow III)

8. If a sunscreen or personnel barrier is being used over a specification package then the package itself is required to have the markings applied directly to the package surface as well as the sunscreen or personnel barrier.

9. If exclusive use, specific written instructions for maintenance of exclusive use shipment controls included with the shipping papers per 49CFR173.403 403 (Attachment 9.14 Instructions for Maintenance of Exclusive Use Shipment Controls)

10. Complete Vehicle Inspection if Exclusive use

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 27 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.3 SHIPPING CHECKLIST - TYPE A Sheet 2 of 2 Shipment Number:

11. If waste shipment for burial, the package:

a. Is classified using the criteria of 10CFR61.55

b. Meets the requirements for waste characteristics of 10CFR61.56

c. Is labeled in accordance with 10CFR61.57

d. Meets the acceptance requirements of the Burial Site Criteria and License

12. If waste shipment for processing, the package

a. Meets the acceptance requirements of the Processor Criteria and License

13. Complete the applicable Advance Notification Form (if applicable) for shipments to processor EnergySolutions - Oak Ridge, TN Studsvik Processing Facility LLC - Erwin, TN EnergySolutions - Clive, UT

14. For shipments that contain resin or other known or suspected methane producing waste, perform an explosive gas test as required in accordance with the applicable cask Certificate of Compliance.

15. A tamper-indicating feature is installed on the package or on the cargo compartment if the shipment is closed vehicle exclusive use per 49CFR173.412(a)

16. General transportation requirements of 49CFR173.448 are met, including cargo secured to prevent shifting

17. The package meets the requirements of 49CFR173.475 prior to shipment

18. If any portion of the transportation is to be by air, the applicable requirements of IATAs Dangerous Goods Regulations have been met

19. The carrier maintains a Transportation Security Plan covering applicable requirements of 49CFR172.800-804. The use of a contractual agreement may be utilized to ensure this is met.

20. If shipment contains sources applicable to National Source Tracking System in 10 CFR 20.2207 and meets the activity limits of Appendix E of 10 CFR 20, ensure a transaction report is completed, via NRC Form 748

21. WHEN shipment involves Category 1 Quantities of radioactive material, THEN, perform advance notification per EN-RW-106..

22. If Special Form, the following requirements are met:

a. Conforms to the definition of Special Form in 49CFR173.403

b. Satisfies the test requirements of 49CFR173.469

c. Satisfies the requirements of 49CFR173.476

d. Marked with the proper shipping name - 49CFR172.101

23. IF material contains measured quantities of Special Nuclear Material (U-233, U-235 or plutonium),

THEN forward a copy of the manifest to Reactor Engineering.

Checklist Completed By:

Date:

Validation/Review Completed By:

Date:

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 28 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.4 SHIPPING CHECKLIST - TYPE B Sheet 1 of 4 Shipment Number:

1.

IF shipment meets Category 1 and 2 Quantities of Radioactive Material levels, THEN refer to EN-RW-106, Integrated Transportation Security Plan, in addition to this checklist.

NOTE The licensee is required to use the Licensee Verification System (LVS) developed by the NRC or contact the regulatory agency (NRC or Agreement State) to verify that the license is valid before shipping a category 1 or 2 quantity of radioactive material. Refer to EN-RW-106.

[CR-WF3-2014-05098]

2. Verified transferees license authorizes the receipt of the type, form and quantity of byproduct material to be transferred via one of the methods listed in 10CFR30.41(d)1 through 5 or DOE Prime Contractor exempt status shall be kept on file.

Consignees License Number:

Expiration date

3. Package activity does not exceed limits of 49CFR173.431(b)

4. Packaging is a Type B package meeting the applicable requirements of 49CFR173.410, 49CFR173.24, 24a & 24b, 49CFR173.413, 49CFR173.416, 49CFR173.417, 49CFR173.442 &

10CFR71

5. Radiation levels within limits of 49CFR173.441, all EN-RW-102 radiation level requirements met

6. Contamination levels within limits of 49CFR173.443, all EN-RW-102 contamination level requirements

7. Specification communication IAW 49CFR172 Subparts C, D, E, F & G are complete:

a. Shipping Papers - highlight the emergency response information on non-computerized generated forms

b. Emergency Response Information

c. Labeling

d. Marking

e. Placarding (required when Label is Yellow III)

8. If a sunscreen or personnel barrier is being used over a specification package then the package itself is required to have the markings applied directly to the package surface as well as the sunscreen or personnel barrier.

9. If exclusive use, specific written instructions for maintenance of exclusive use shipment controls included with the shipping papers IAW 49CFR173.403

10. Complete Vehicle Inspection if Exclusive use

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 29 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.4 SHIPPING CHECKLIST - TYPE B Sheet 2 of 4 Shipment Number:

11. If waste shipment for disposal, the package:

a. Is classified using the criteria of 10CFR61.55

b. Meets the requirements for waste characteristics of 10CFR61.56

c. Is labeled in accordance with 10CFR61.57

d. Meets the acceptance requirements of the Burial Site Criteria and License

12. If waste shipment for processing, the package

a. Is classified using the criteria of 10CFR61.55

b. Meets the acceptance requirements of the Processor Criteria and License

13. Complete the applicable Advance Notification Form (if applicable) for shipments to processor EnergySolutions - Oak Ridge, Tn Studsvik Processing Facility LLC - Erwin, Tn EnergySolutions - Clive, Ut

14. The requirements of 10CFR71.43 are met, including a tamper indicating feature and positive fastening device

15. General transportation requirements of 49CFR173.448 are met, including cargo secured to prevent shifting

16. The package meets the requirements of 10CFR71.87 prior to shipment.

17. If any portion of the transportation is to be by air, the applicable requirements of IATAs Dangerous Goods Regulations have been met

18. The carrier maintains a Transportation Security Plan covering applicable requirements of 49CFR172.800-804. The use of a contractual agreement may be utilized to ensure this is met.

19. If Special Form, the following requirements are met:

a. Meets the definition of Special Form in 10CFR71.4

b. Satisfies the test requirements of 10CFR71.75

c. Satisfies the requirements of 49CFR173.476

d. Proper shipping name per 49CFR172.101

20. If Fissile Material not excepted by 49CFR173.453, all applicable requirements in 49CFR173 &

10CFR71 have been satisfied

21. If special instructions for safely opening the package are required, the requirements of 10CFR71.89 are met.

22. The requirements of 10CFR71.17 & 49CFR173.471 are met, including possessing a copy of the certificate of compliance, complying with all its terms and conditions, registering as a user of the packaging prior to first use and placing the package identification marking on each page of the shipping papers.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 30 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.4 SHIPPING CHECKLIST - TYPE B Sheet 3 of 4 Shipment Number:

23. When applicable, perform the advance notification per EN-RW-106, for Advance notification of Shipment of Category 1 Quantities of Radioactive Material and Highway Route Controlled Quantities (HRCQ) of Radioactive Material

24. If the material meets the definition of Highway Route Controlled Quantity in 49CFR173.403, the following requirements are met:

a. Yellow III labels applied per 49CFR172.403

b. Background placard used per 49CFR172.507(a)

c. Highway Route Controlled Quantity entered in association with the basic description on the shipping papers per 49CFR172.203(d)(4)

d. The requirements of 49CFR397 Subpart D have been met, including trained drivers, designated routes and a route plan

e. Notify QA/QP Department prior to shipment (if applicable)

25. For shipments that contain resin or other known or suspected methane producing waste, perform an explosive gas test as required in accordance with the applicable cask Certificate of Compliance.

26. If shipment contains sources applicable to National Source Tracking System in 10 CFR 20.2207 and meets the activity limits of Appendix E of 10 CFR 20,, ensure a transaction report is completed, via NRC Form 748

27. The records required by 10CFR71.91 are complete

28. Advance Notification Shipments: 10 CFR 71.97 NOTE Advance notification is required for radioactive waste material (not irradiated fuel) which:

a.

Requires Type B packaging b.

Is being transported to a disposal site or to a collection point for transport to a disposal site, AND c.

The quantity of licensed material in a single package exceeds 3000 times the A1 or A2 values as specified in Appendix A, Table A-1 or 27,000 curies.

Advance Notification Shipment Requirements include:

a.

Initiate the Advance Notification Waste Shipment Check-off Form,

b. Notify in writing, using the Advanced Notification of Nuclear Waste Shipment Form, each governor or governor's designee for those states through which the shipment will travel, and the Regional Administrator Region I Office listed in Appendix A of 10 CFR 73, giving the following information:

c. Update any change in written shipment details, to the governor's designee, by telephone, recording the update and individual contacted.

d. Forward a cancellation notice, if applicable, to the governor or governor's designee, and to the Regional Administrator Region I Office.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 31 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.4 SHIPPING CHECKLIST - TYPE B Sheet 4 of 4 Shipment Number:

e. Notify the consignee of the shipment and arrival dates, and any special loading or unloading instructions.

f.

The carrier route plan shall be received on-site before the departure of an Advance Notification Shipment. Any variation from the "as received" route plan, plus the reason for change, shall be received on-site prior to shipment departure.

29. IF material contains measured quantities of Special Nuclear Material (U-233, U-235 or plutonium),

THEN forward a copy of the manifest to Reactor Engineering.

Checklist Completed By:

Date:

Validation/Review Completed By:

Date:

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 32 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.5 SHIPPING CHECKLIST - LIMITED QUANTITY Sheet 1 of 1 Shipment Number:

1. Verified transferees license authorizes the receipt of the type, form and quantity of byproduct material to be transferred via one of the methods listed in 10CFR30.41(d)1 through 5 or DOE Prime Contractor exempt status shall be kept on file.

Consignees License Number:

Expiration date

2. The packaging meets the requirements of 49CFR173.410 and 49CFR173.24, 24a & 24b

3. Package activity does not exceed the limits of 49CFR173.425

4. No package contains greater than 15 grams of Uranium 235

5. The radiation level at any point on the external surface of the package does not exceed 0.004 mSv/hr (0.4 mRem/hour) within administrative limits of EN-RW-102

6. Radiation levels within limits of 49CFR173.421, all EN-RW-102 requirements met

7. Contamination levels within limits of 49CFR173.443, all EN-RW-102 contamination level requirements met

8. The outside of the inner packaging or if there is no inner packaging, the outside of the packaging itself bears the marking "Radioactive"

9. The outside of each package must be marked with the four digit UN identification number for the material preceded by the letters UN.

10. If the material meets the definition of another hazard class or division, the requirements of 49CFR173.423 are met

11. If any portion of the transportation is to be by air, the applicable requirements of IATAs Dangerous Goods Regulations have been met

12. IF material contains measured quantities of Special Nuclear Material (U-233, U-235 or plutonium),

THEN forward a copy of the manifest to Reactor Engineering.

Checklist Completed By:

Date:

Validation/Review Completed By:

Date:

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 33 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.6 SHIPPING CHECKLIST - EMPTY PACKAGING Sheet 1 of 1 Shipment Number:

1. Verified transferees license authorizes the receipt of the type, form and quantity of byproduct material to be transferred via one of the methods listed in 10CFR30.41(d)1 through 5 or DOE Prime Contractor exempt status shall be kept on file.

Consignees License Number:

Expiration date

2. The packaging is in unimpaired condition and is securely closed

3. Internal contamination does not exceed 100 times the limits of 49CFR173.443(a)

4. No package contains greater than 15 grams of Uranium 235

5. The radiation level at any point on the external surface of the package does not exceed 0.004 mSv/hr (0.4 mRem/hour) within administrative limits of EN-RW-102

6. Radiation levels within limits of 49CFR173.421, all EN-RW-102 requirements met

7. Contamination levels within limits of 49CFR173.443, all EN-RW-102 contamination level requirements met

8. The outside of each package must be marked with the four digit UN identification number for the material preceded by the letters UN.

9. Any labels previously applied in conformance with Subpart E of 49CFR172 are removed, obliterated or covered and the Empty label of 49CFR172.450 is affixed

10. If any portion of the transportation is to be by air, the applicable requirements of IATAs Dangerous Goods Regulations have been met

11. IF material contains measured quantities of Special Nuclear Material (U-233, U-235 or plutonium),

THEN forward a copy of the manifest to Reactor Engineering.

Checklist Completed By:

Date:

Validation/Review Completed By:

Date:

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 34 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.7 SHIPPING CHECKLIST - INSTRUMENTS AND ARTICLES Sheet 1 of 1 Shipment Number:

1. Verified transferees license authorizes the receipt of the type, form and quantity of byproduct material to be transferred via one of the methods listed in 10CFR30.41(d)1 through 5 or DOE Prime Contractor exempt status shall be kept on file.

Consignees License Number:

Expiration date

2. The packaging meets the requirements of 49CFR173.410 and 49CFR173.24, 24a & 24b

3. Package activity does not exceed the limits of 49CFR173.425

4. Each instrument's or article's activity does not exceed the limits of 49CFR173.425

5. No package contains greater than 15 grams of Uranium 235

6. The radiation level at any point on the external surface of the package does not exceed 0.004 mSv/hr (0.4 mRem/hour), or for exclusive use domestic shipments, 0.016 mSv/hr (1.6 mRem/hour) within administrative limits of EN-RW-102

7. The radiation level at 10 cm from any point on the external surface of any unpackaged instrument or article does not exceed 0.08 mSv/hr (8 mRem/hour) within administrative limits of EN-RW-102

8. Radiation levels within limits of 49CFR173.424, all EN-RW-102 requirements met

9. Contamination levels within limits of 49CFR173.443, all EN-RW-102 contamination level requirements met

10. The outside of each package must be marked with the four digit UN identification number for the material preceded by the letters UN.

11. If the material meets the definition of another hazard class or division, the requirements of 49CFR173.423 are met

12. If any portion of the transportation is to be by air, the applicable requirements of IATAs Dangerous Goods Regulations have been met

13. IF material contains measured quantities of Special Nuclear Material (U-233, U-235 or plutonium),

THEN forward a copy of the manifest to Reactor Engineering.

Checklist Completed By:

Date:

Validation/Review Completed By:

Date:

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 35 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.8 SHIPPING CHECKLIST - ARTICLES CONTAINING NATURAL/DEPLETED URANIUM OR NATURAL THORIUM Sheet 1 of 1 Shipment Number:

1. Verified transferees license authorizes the receipt of the type, form and quantity of byproduct material to be transferred via one of the methods listed in 10CFR30.41(d)1 through 5 or DOE Prime Contractor exempt status shall be kept on file.

Consignees License Number:

Expiration date

2. The packaging meets the requirements of 49CFR173.410 and 49CFR173.24, 24a & 24b

3. The outer surface of the uranium or thorium is enclosed in an inactive sheath of metal or other durable material

4. The radiation level at any point on the external surface of the package does not exceed 0.004 mSv/hr (0.4 mRem/hour) within administrative limits of EN-RW-102

5. Radiation levels within limits of 49CFR173.421, all EN-RW-102 requirements met

6. Contamination levels within limits of 49CFR173.443, all EN-RW-102 contamination level requirements met

7. The outside of each package must be marked with the four digit UN identification number for the material preceded by the letters UN.

8. The outside of the inner packaging or if there is no inner packaging, the outside of the packaging itself bears the marking Radioactive

9. DOE/NRC 741 evaluation completed

10. If any portion of the transportation is to be by air, the applicable requirements of IATAs Dangerous Goods Regulations have been met

11. IF material contains measured quantities of Special Nuclear Material (U-233, U-235 or plutonium),

THEN forward a copy of the manifest to Reactor Engineering.

Checklist Completed By:

Date:

Validation/Review Completed By:

Date:

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 36 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.9 SHIPPING CHECKLIST - LIMITED QUANTITY - NEUTRON METERS Sheet 1 of 1 Shipment Number:

1. Verified transferees license authorizes the receipt of the type, form and quantity of byproduct material to be transferred via one of the methods listed in 10CFR30.41(d)1 through 5 or DOE Prime Contractor exempt status shall be kept on file.

Consignees License Number:

Expiration date

2. Bag the meter in a plastic bag and mark the top surface Radioactive.

3. Package meter in a packaging which meets the requirements of 49 CFR 173.410, CFR 173.24, 24a, &

24b lined with cushioning material to effectively prevent movement of the inner packaging during transit.

4. The radiation level at any point on the external surface (contact) of the package does not exceed 0.004 mSv/hr (0.4 mRem/hr.) Document on appropriate form.

5. Contamination levels on the outside of the package are <1000 dpm/100cm2 and <20 dpm/100cm2

. Document on appropriate form.

6. Legibly and clearly mark the outside of the outer container with the UN identification number, UN2910, for limited quantity of radioactive material.

7. Domestic transport only is approved with use of this package.

8. The package has a tamper indicating seal placed on it after packaging is complete.

9. Two address labels with the consignor and consignee names and proper shipping locations are on at least the top and one side of the package.

10. Mark the weight on the package.

11. Fill out the appropriate Bill of Lading to be used with carrier, if applicable.

12. Inform the consignee of the shipment and expected time of arrival. This is to be done by phone or other method as long as acknowledgement is made by the consignee.

13. Ensure you have been trained on the use of this exemption and as required by 49 CFR 172.700 -

172.704.

14. IF material contains measured quantities of Special Nuclear Material (U-233, U-235 or plutonium),

THEN forward a copy of the manifest to Reactor Engineering.

Checklist Completed By:

Date:

Validation/Review Completed By:

Date:

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 37 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.10 PACKAGING REFERENCE TABLES Sheet 1 of 3 ACCEPTABLE SHIPPING CONTAINERS FOR RADIOACTIVE MATERIAL TYPE OF MATERIAL OUTER CONTAINER Radioactive Material LSA or SCO Shipped exclusive use/domestic Package contains a Type A quantity

(<1R/hr @ 3 meters unshielded)

Package contains > Type A quantity

(<1R/hr @ 3 meters unshielded)

LSA-I or SCO-I

(<1R/hr @ 3 meters unshielded)

>1R/hr @ 3 meters unshielded Acceptable Package (49CFR173.410, 24 and 24a)

Industrial Package I Industrial Package II Industrial Package III Dot 7A Type A (as applicable)

Bulk Packaging meeting the requirements of 49CFR173.24/24a/24b Type B Packaging (10CFR71 & 49CFR173.471)

Radioactive Material LSA or SCO Shipped non exclusive use/domestic Industrial Package I Industrial Package II Industrial Package III Dot 7A Type A (as applicable)

Radioactive Material Limited Quantity Excepted Package 49CFR173.410/24/24a/24b Radioactive Material Type A Quantity Type A Specification Package Radioactive Material Type B Quantity NRC Approved Type B Container

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 38 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.10 PACKAGING REFERENCE TABLES Sheet 2 of 3 EXAMPLES OF ACCEPTABLE SHIPPING CONTAINERS FOR RADIOACTIVE MATERIAL TYPE OF MATERIAL INNER CONTAINER OUTER CONTAINER Radioactive Waste LSA or SCO exclusive use/domestic shipment Resins

<Type A quantity

<1R/hr @ 3 meters unshielded Disposable Liner or HIC None required unless shielding is necessary due to dose rates.

Cask used as acceptable package per 49CFR173.410, 24, 24a Resins

> Type A quantity

<1R/hr @ 3 meters unshielded Disposable Liner or HIC Industrial Package I, II, III Type A Packaging Resins

>1R/hr @ 3 meters unshielded Disposable Liner or HIC NRC Approved Type B Cask Dry Active Waste (DAW)-compactable Drums or boxes None required unless shielding is necessary, then utilize an outer container that meets the applicable shipping requirements Dry Active Waste (DAW)-non compactable Drums or boxes None required unless shielding is necessary, then utilize an outer container that meets the applicable shipping requirements Liquids Drum Disposable Liner Oil bins or sealand meeting applicable requirements holding drums (2x absorbents may be considered)

Cask meeting applicable requirements

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 39 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.10 PACKAGING REFERENCE TABLES Sheet 3 of 3 EXAMPLES OF ACCEPTABLE SHIPPING CONTAINERS FOR RADIOACTIVE MATERIAL TYPE OF MATERIAL INNER CONTAINER OUTER CONTAINER Radioactive Material Limited Quantity Solids Liquids Plastic bag/wrapping Bottle, flask, metal sample container with the neck sealed with tape.

Excepted Package 49CFR173.410/24/24a/24b Same as previous Radioactive Material Type A Quantity Drums or Liner or HIC\\

(2x absorbents for liquids)

Type A Specification Package Radioactive Material Type B Quantity or Highway Route Controlled Quantity Drums or Liner or HIC (2x absorbents for liquids)

NRC Approved Type B Container

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 40 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.11 RADIATION & CONTAMINATION SURVEY LIMITS FOR RADIOACTIVE MATERIAL SHIPMENTS Sheet 1 of 2 RADIATION SURVEY LIMITS Packages in a Nonexclusive Use Vehicle TYPE PACKAGE CONTACT mR/hr Administrative (DOT) 1 METER (TI) mR/hr Administrative (DOT)

Limited Quantity 0.4 (0.5)

N/A Empty 0.4 (0.5)

N/A Instruments and Articles 0.4 (0.5) 8.0 (10) @ 4" unpackaged N/A Type A 160 (200) 8 (10)

Type B 160 (200) 8 (10)

LSA 160 (200) 8 (10)

Packages in Exclusive Use, Closed Vehicle Contact 1 Meter mR/hr 2 Meter mR/hr mR/hr (Package)

(Vehicle Surface)

Instruments & Articles 1.6 (2)

N/A N/A Type A, B 800 (1000)

N/A 8 (10)

LSA 800 (1000)

N/A 8 (10)

Packages in Exclusive Use, Open Vehicle Instruments & Articles 1.6 (2)

N/A N/A Type A, B 160 (200)

N/A 8 (10)

LSA 160 (200)

N/A 8 (10)

Note: 1. All numbers in parentheses ( ) are DOT limits

2. All units are listed in customary units. When using SI units, they are to be listed first with the customary units following in parenthesis. (examples of SI units include Sv/hr & mSv/hr)

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 41 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.11 RADIATION & CONTAMINATION SURVEY LIMITS FOR RADIOACTIVE MATERIAL SHIPMENTS Sheet 2 of 2 CONTAMINATION LIMITS Item Limits Beta/Gamma Alpha Set By External surface of packages, equipment DOT 220 dpm/cm2; also for all nuclides with T1/2

< 10 days; natural U; natural Th; 22 dpm/cm2 for in radioactive U-235, U-238, Th-228, Th-230 and Th-232 all material shipments alpha emitters Admin 1,000 dpm/100 cm² 20 dpm/100 cm² Internal surfaces of packages involved in DOT 22000 dpm/cm² 2200 dpm/cm² shipment, having previously contained radioactive material Admin 1,000 dpm/100 cm² 20 dpm/100 cm² Notes: 1.

See 49CFR173.403, for radioactive contamination limits for contaminated, non radioactive solids qualifying as Class 7 radioactive material - Surface Contaminated Object (SCO)

2.

All units are listed in customary units. SI units are to be listed first with the customary units following in parenthesis. (examples of SI units include Bq/100 cm2 &

mBq/100 cm2).

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 42 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.12 VEHICLE INSPECTION CHECK SHEET Sheet 1 of 1 (Sample Form)

Shipment Number:

Truck/Tractor Number: _______________

Trailer Number: _______________

Inspection Item Satisfactory Unsatisfactory Driver(s) has a current DOT Hazardous Material Endorsement Vehicle and trailer have a current yearly inspection Vehicle tires are free from obvious defects.

Vehicle windshield and mirrors are not cracked or broken to the extent it could impair vision.

Vehicle lighting is operational.

Vehicle horns are operational.

Safety equipment is readily available (i.e. fire extinguisher, flags, etc.)

No unsecured materials on the vehicle prior to release for shipment.

Note: Check appropriate column for satisfactory or unsatisfactory Comments If items affecting safe transportation of the shipment (inspector's judgment) are found, the problem will be resolved by the Shipper prior to vehicle release.

Vehicle Inspection is satisfactory and shipment release from site is acceptable.

Shipper Name (Printed): _

Shipper (Signature):

/

Date

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 43 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.13 RADIOACTIVE MATERIAL SHIPMENT TRUCK SURVEY FORM - TYPICAL Sheet 1 of 1 Reason for Survey Incoming Outgoing Date & Time Tractor Number Survey Number Trailer Number Shipment Number Instruments Used Serial Number Cal. Due Date

Background

MDA Highest Contact dose rate reading on package mr/hr Highest 1 Meter dose rate reading on package mr/hr Contamination (dpm/100cm2)

No.

Location 1

2 3

4 5

6 7

8 9

10 11 12 Surveyed by:

/

Print Signature KCN Date Verified by:

/

Print Signature KCN Date Reviewed by:

/

Print Signature KCN Date

Contact:

mr/hr 2 meter: mr/hr Inside Cab: mr/hr Bottom:

mr/hr

Contact:

mr/hr 2 meter: mr/hr

Contact:

mr/hr 2 meter: mr/hr

Contact:

mr/hr 2 meter: mr/hr

Contact:

mr/hr 2 meter: mr/hr

Contact:

mr/hr 2 meter: mr/hr

Contact:

mr/hr 2 meter: mr/hr Top of trailer: mr/hr Front of trailer

Contact:

mr/hr 2 meter: mr/hr

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 44 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.14 INSTRUCTIONS FOR MAINTENANCE OF EXCLUSIVE USE SHIPMENT CONTROLS Sheet 1 of 1 Shipment Number:

Carrier:

You are advised per these instructions to transport the items defined on the attached shipping documents under EXCLUSIVE USE provisions.

Exclusive Use (also referred to as Sole Use OR Full Load as used in IAEA regulations) means:

Sole use by a single consignor of a conveyance for which all initial, intermediate, and final loading and unloading are carried out in accordance with the direction of the consignor or consignee Special Remarks Concerning Exclusive Use (provided by shipper when deemed appropriate):

The consignor and the carrier must ensure that any loading or unloading is performed by personnel having radiological training and resources appropriate for safe handling of the consignment This consignment is subject to the survey requirements of 49CFR173.443 (c) as applicable, DO NOT transfer shipment from originating carrier vehicle.*

DO NOT load other packages on originating carrier vehicle.

DO NOT change the vehicle configuration / fifth wheel setting.

Deliver shipment DIRECTLY to consignee.

Emergency Phone Numbers:

IF transfer from originating carrier vehicle is necessary, THEN maintenance of exclusive use provisions are required for EACH subsequent carrier vehicle.

Date:

Drivers Signature

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 45 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.15 APPENDIX A: NOTIFICATIONS - SITE SPECIFIC Sheet 1 of 3 1.0 Vermont 1.1 The State of Vermont requires prior notification of certain radioactive shipments at least two working days in advance, with final update of all required information no later than two hours prior to shipment. Initial and final notifications should be made by phone, reporting all information requested on the Vermont Radioactive Materials Shipment Report. This report can be faxed. Vermont requires notification for shipments meeting any of the following criteria:

1.1.1 Radioactive waste shipped for disposal. Radioactive material requiring advance notification (10 CFR 71.97).

1.1.2 Spent fuel.

1.1.3 Authorization to deviate from any Vermont Regulation may be granted only by the individuals outlined.

1.1.4 During off-hours, weekends, and holidays, Vermont notifications should be made.

1.2 Initial and Final Notifications 1.2.2 802-865-7730 Fax: 802-863-7745 1.3 Authorizations concerning Radioactive shipments:

1.3.2 (Health Commissioner) 1.4 Off-Hours, Weekends and Holiday Notifications 1.4.2 802-658-0384 1.4.3 802-863-7280 1.4.4 802-874-4025 2.0 Massachusetts 2.1 The Commonwealth of Massachusetts requires prior notification of certain radioactive shipments passing through Massachusetts at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in advance, with final update of all information, as required on the Massachusetts Radioactive Shipment Report, approximately two hours prior to shipping.

2.2 Massachusetts shall be notified of all radioactive shipments requiring placarding.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 46 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.15 APPENDIX A: NOTIFICATIONS - SITE SPECIFIC Sheet 2 of 3 2.3 Laundry shipments through Massachusetts are excluded from notification per letter dated 11/30/89.

2.4 Massachusetts notifications should be made by faxing a Massachusetts Radioactive Materials Shipment Log.

2.5 Initial and Final Notifications:

2.5.1 Fax: 617-242-3457

2.5.2 Voice

617-242-3035 3.0 Gill, Massachusetts 3.1 The Town of Gill, Massachusetts requires prior notification of certain radioactive shipments passing through Gill at least 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months prior to shipment, with final update of all information listed on the Mass. Radioactive Shipment Report two hours prior to shipping.

3.2 Gill, MA shall be notified of all radioactive "waste shipments".

3.3 Notifications to Gill, MA should be made faxing a Massachusetts Radioactive Materials Shipment Log.

3.4 Initial and Final Notifications:

3.4.1 Fax: 413-863-3657 413-863-9804 413-665-7759 413-863-8955 or VY Nuclear Alert System 3.4.2 Off-Hours, Weekends and Holiday Notifications 413-863-9804 MA State Police 413-566-4500

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 47 OF 47 Radioactive Shipping Procedure ATTACHMENT 9.15 APPENDIX A: NOTIFICATIONS - SITE SPECIFIC Sheet 3 of 3 4.0 Connecticut 4.1 The State of Connecticut requires a hard-copy of the Connecticut Radioactive Material Transportation Permit, to accompany all waste and placarded radioactive shipments passing through Connecticut.

4.2 A completed Connecticut Permit Application shall be faxed to the Connecticut DOT. Permit requests are accepted during normal business hours (0800-1600) only.

4.3 Connecticut Radioactive Materials Transportation Permit criteria:

4.3.1 Only routes stated on the permit may be traveled.

4.3.2 Travel is restricted to daylight hours (0900-1600).

4.3.3 No travel is permitted on weekends or holidays.

4.3.4 The driver shall have the hard-copy permit in his possession.

4.4 Permit Application - Phone 203-594-2880 Fax: 203-665-8335 5.0 Arkansas 5.1 The State of Arkansas requires that the Arkansas Department of Health be notified of placarded radioactive shipments.

5.2 This information may be faxed to 501-661-2136, normally within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of shipment departure.

6.0 Mississippi 6.1 Prior to transport of nuclear waste into, within or through MS. The shipper shall provide advance notification to the agency (MEMA) using Agency Form Rad 5-3 Radioactive Waste Shipment Advance Notification and Manifest.

6.1.1 If mailed it must be postmarked 7 days prior to entry into the state.

6.1.2 If faxed or sent by messenger it must be received at least 4 days prior to entry into the state.

6.2 Manifest shall also include the shippers certification - Agency Form Rad 5-4 Radioactive Waste shipment Certification with the shipment 7.0 Texas 7.1 Five (5) Days prior to making a shipment to the Texas Low level radioactive waste disposal facility each shipper shall notify DSHS providing a copy of the waste manifest and the date of shipment. The requirements can be found in Texas Department of Health Services, Radiation Safety Licensing Branch Regulatory Guide 2.19 (12/1/11)Section VI.

7.2 Five (5) Days prior to making the shipment to the Texas Low level radioactive waste disposal facility, the shipper shall notify WCS per disposal site license/waste acceptance criteria &

TCEQ requirements

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 1 OF 47 Radioactive Shipping Procedure Procedure Contains NMM ECH eB REFLIB Forms: YES NO Procedure Revision Type: New NON-Editorial Editorial TC Cancellation HQN Effective Date Procedure Owner:

Title:

Site:

Frank Mitchell Manager, RP IPEC Governance Owner:

Title:

Site:

Reid Tagliamonte Manager, Fleet RP HQN 10/15/15 Site Site Procedure Champion Title ANO Donnie Marvel Manager, RP BRP N/A N/A CNS Chris Sunderman Manager, RP GGNS Roy Miller Manager, RP IPEC Frank Mitchell Manager, RP JAF Robert Heath Manager, RP PLP David Nestle Manager, RP PNPS Alan Zelie Manager, RP RBS Shannon Peterkin Manager, RP VY Michael Pletcher Manager, RP W3 Daniel Frey Manager, RP HQN Reid Tagliamonte Manager, Fleet RP For site implementation dates see ECH eB REFLIB using site tree view (Navigation panel).

Site and NMM Procedures Canceled or Superseded By This Revision None Process Applicability Exclusion:

All Sites:

Specific Sites: ANO BRP CNS GGNS IPEC JAF PLP PNPS RBS VY W3 Change Statement The primary purpose of this revision is to issue identified in CR-HQN-2015-00751 regarding notification of Reactor Engineering of non-waste shipments containing SNM.

Attachments 9.2, 9.3, 9.4, 9.5, 9.6, 9.7, 9.8, 9.9: replaced NRC form 540/541 with the manifest Updated section 8 with information provided by the GGNS Commitment Review Added missing document numbers for W3 and RBS entries in section 8.

Added commitment number for GGNS entry in section 8 regarding GNRI-92/00195 Deleted W3 commitment P-11757 from section 8 per W3 Commitment Review response.

Associated PRHQN #: 2015-00363 Procedure Writer: Ron Schwartz Contains Proprietary Information: YES NO

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 2 OF 47 Radioactive Shipping Procedure TABLE OF CONTENTS Section Title Page 1.0 PURPOSE

................................................................................................................. 3

2.0 REFERENCES

................................................................................................................. 3 3.0 DEFINITIONS................................................................................................................. 4 4.0 RESPONSIBILITIES............................................................................................................ 4 5.0 DETAILS

................................................................................................................. 5 5.1 PRECAUTIONS AND LIMITATIONS.................................................................................... 5 5.2 GENERAL REQUIREMENTS............................................................................................... 8 5.3 WASTE CLASSIFICATION................................................................................................ 17 5.4 WASTE CHARACTERISTICS............................................................................................ 17 6.0 INTERFACES............................................................................................................... 18 7.0 RECORDS

............................................................................................................... 18 8.0 SITE SPECIFIC COMMITMENTS....................................................................................... 19 9.0 ATTACHMENTS............................................................................................................... 20 ATTACHMENT 9.1 RADIOACTIVE SHIPMENT DOCUMENT CHECKLIST......................................... 21 ATTACHMENT 9.2 SHIPPING CHECKLIST - LSA/SCO/EXCLUSIVE USE & DOMESTIC.................. 23 ATTACHMENT 9.3 SHIPPING CHECKLIST - TYPE A.................................................................. 26 ATTACHMENT 9.4 SHIPPING CHECKLIST - TYPE B.................................................................. 28 ATTACHMENT 9.5 SHIPPING CHECKLIST - LIMITED QUANTITY.................................................. 32 ATTACHMENT 9.6 SHIPPING CHECKLIST - EMPTY PACKAGING................................................ 33 ATTACHMENT 9.7 SHIPPING CHECKLIST - INSTRUMENTS AND ARTICLES.................................. 34 ATTACHMENT 9.8 SHIPPING CHECKLIST - ARTICLES CONTAINING NATURAL/DEPLETED URANIUM OR NATURAL THORIUM................................................................ 35 ATTACHMENT 9.9 SHIPPING CHECKLIST - LIMITED QUANTITY - NEUTRON METERS................... 36 ATTACHMENT 9.10 PACKAGING REFERENCE TABLES............................................................... 37 ATTACHMENT 9.11 RADIATION & CONTAMINATION SURVEY LIMITS FOR RADIOACTIVE MATERIAL SHIPMENTS

............................................................................................................... 40 ATTACHMENT 9.12 VEHICLE INSPECTION CHECK SHEET........................................................... 42 ATTACHMENT 9.13 RADIOACTIVE MATERIAL SHIPMENT TRUCK SURVEY FORM - TYPICAL........... 43 ATTACHMENT 9.14 INSTRUCTIONS FOR MAINTENANCE OF EXCLUSIVE USE SHIPMENT CONTROLS 44 ATTACHMENT 9.15 APPENDIX A: NOTIFICATIONS - SITE SPECIFIC............................................. 45

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 3 OF 47 Radioactive Shipping Procedure 1.0 PURPOSE The purpose of this procedure is to provide guidance for shipping radioactive material or waste in accordance with applicable regulations. No required Technical Specification surveillances or non air international shipments are covered in this procedure.

2.0 REFERENCES

[1]

Code Of Federal Regulations, Title 10, Parts 20, 30, 61 & 71

[2]

Code Of Federal Regulations, Title 40, Parts 240-246

[3]

Code Of Federal Regulations, Title 49, Parts 107-178 & 393

[4]

International Air Transportation Association (IATA) Dangerous Goods Regulation

[5]

Regulations For Radioactive Waste Transportation, Mississippi Code Of 1972; Section 45-14-67, Mississippi Radioactive Waste Transportation Act, Latest Revision -

Mississippi Emergency Management Agency (MEMA)

[6]

Branch Technical Position On Radioactive Waste Form, Classification, Concentration Averaging, And Encapsulation

[7]

NRC I.E. Notice 79-19, Packaging of Low-Level Radioactive Waste for Transport and Burial

[8]

Energy Solutions Inc. State of Utah Radioactive Material License, UT2300249, Latest Revision

[9]

Energy Solutions Inc. Containerized Waste Facility (CWF) Waste Acceptance Criteria (WAC), TSC-2, Latest Revision

[10]

WMG/P-045, RADMAN Software & WMG/P-009, RAMSHP Software

[11]

NRC Generic Letter 91-02

[12]

NuReg 1608

[13]

25 Texas Administrative Code §289.252 "Licensing of Radioactive Material" and

§289.257 "Packaging and Transportation of Radioactive Material"

[14]

10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material

[15]

INPO Event Report Level 2 11-1, Inadequate Collective Radiation Exposure Performance Improvements

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 4 OF 47 Radioactive Shipping Procedure 3.0 DEFINITIONS

[1]

Transportation definitions are found in 49CFR173.403 and 49CFR171.8.

[GGNS P-18744]

[2]

Validation - an independent review of the package characterization using the Radwaste Shipping Computer Program.

[3]

Bulk packaging means a packaging, other than a vessel or a barge, including a transport vehicle or freight container, in which hazardous materials are loaded with no intermediate form of containment. A Large Packaging in which hazardous materials are loaded with an intermediate form of containment, such as one or more articles or inner packagings, is also a bulk packaging. Additionally, a bulk packaging has:

(a) a maximum capacity greater than 450 L (119 gallons) as a receptacle for a liquid; (b) a maximum net mass greater than 400 kg (882 pounds) and a maximum capacity greater than 450 L (119 gallons) as a receptacle for a solid; or (c) a water capacity greater than 454 kg (1000 pounds) as a receptacle for a gas as defined in §173.115.

[4]

Freight container means a reusable container having a volume of 64 cubic feet or more, designed and constructed to permit being lifted with its contents intact and intended primarily for containment of packages (in unit form) during transportation.

4.0 RESPONSIBILITIES

[1]

The RPM Peer Group is responsible for the implementation of this procedure and must approve any changes or revisions to this procedure.

[2]

Each site Senior Nuclear Executive (SNE) is responsible for ensuring that necessary site staff implements this procedure.

[3]

The Low Level Radwaste (LLRW) Focus Group is responsible for evaluating and recommending changes and revisions to this procedure.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 5 OF 47 Radioactive Shipping Procedure 4.0 continued

[4]

The Requestor (the individual requesting shipment of radioactive material from site) is responsible for informing the Radwaste Shipper (SHIPPING SUPERVISOR), to ensure proper radioactive material shipping classification and required supporting documentation be generated. The SHIPPING SUPERVISOR SHALL ensure all aspects of this procedure, applicable DOT, NRC, and burial site requirements are complied with, which includes:

(a)

Assign a Radiation Protection technician to perform tasks delineated in this procedure.

(b)

Inform the Reactor Engineering Manager should any fissile materials need to be shipped.

[5]

The person designated & qualified to complete shipments (normally the RP specialist) is responsible for completing the shipment in accordance with this procedure and all state and federal regulations.

5.0 DETAILS 5.1 PRECAUTIONS AND LIMITATIONS

[1]

The provisions within 49CFR173.436 are not to be used, unless approved by the Radiation Protection Manager (RPM) or designee.

[2]

Evaluate material for Category 1 and 2 Quantities of Radioactive Material in accordance with EN-RW-106, Integrated Transportation Security Plan, AND ensure all security issues have been satisfied in accordance with EN-RW-106.

[3]

Category 1 and 2 Quantities of Radioactive Material require significant lead time (at least 2 weeks) due to additional requirements for the physical protection of Category 1 and 2 Quantities of Radioactive Material. Refer to 10 CFR Part 37 AND EN-RW-106 for further details.

[4]

The following is applicable to specification packages above the general design packaging. Ensure non-waste shipments containing liquid material contains an inner lining OR enough absorbent material to absorb at least two times the volume of liquid in the shipment or so to contain liquid within an over-pack or other containment device, should leakage occur. See 49CFR173.412(k)

[5]

Sources to be shipped need to be checked to see if they fall under the requirements of the National Source Tracking System in 10 CFR 20.2207. IF the source meets the activity limits of Appendix E of 10 CFR 20, THEN ensure a transaction report is completed, using NRC Form 748 (or equivalent).

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 6 OF 47 Radioactive Shipping Procedure 5.1 continued

[6]

A receipt copy of the Radioactive Shipment Manifest from the burial site or waste processor shall be received within 20 days of shipment departure, confirming waste shipment delivery.

[7]

IF receipt copy of the Radioactive Shipment Manifest is not received from the burial site or waste processor, THEN an investigation shall be initiated to locate the shipment [10 CFR 20, appendix G]. This investigation shall include tracing the shipment and filing a written report with the NRC regional office within two weeks of the completion of the investigation.

[8]

As required by NRC Generic Letter 91 02, a report to the NRC's Director of the Division of Low Level Waste Management and Decommissioning AND to the designated State disposal site regulatory authority is required IF any of the following conditions result from handling of radwaste. The report shall be prepared and mailed within 30 days of the incident (a)

The failure of high integrity containers used to ensure a stable waste form.

Container failure can be evidenced by changed container dimensions, cracking, or damage resulting from mishandling (e.g., dropping or impacting against another object).

(b)

The misuse of high integrity containers, evidenced by a quantity of free liquid greater than 1 percent of container volume, or by an excessive void space within the container. Such misuse is prohibited by 10 CFR 61.56.

(c)

The production of a solidified Class B or C waste form that has any of the following characteristics:

Contains free liquid in quantities exceeding 0.5 percent of the volume of the waste Contains waste with radionuclides in concentrations exceeding those considered during waste form qualification testing accepted by the regulatory agency, which could lead to errors in assessment of waste class Contains a significantly different waste loading than that used in qualification testing accepted by the regulatory agency Contains chemical ingredients not present in qualification testing accepted by the regulatory agency, AND those quantities are sufficient to unacceptably degrade the waste product.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 7 OF 47 Radioactive Shipping Procedure 5.1[8](c) continued Shows instability evidenced by crumbling, cracking, voids, softening, disintegration, non-homogeneity, or dimensional changes Evidence of processing phenomena that exceed the limiting processing conditions identified in applicable topical reports on process control plans, e.g., foaming, temperature extremes, premature or slow hardening, and production of volatile material

[9]

For an outgoing shipment, the 10 CFR 20 postings shall be removed prior to the vehicle leaving site.

[10]

High Risk Shipments - When preparing shipments that contain tools and equipment that may have been subjected to discrete radioactive particle (DRP) contamination, site is to utilize as many of the following actions to ensure compliance with 49CFR173.441 (a)

Validate personnel who package the material have had appropriate function specific training (on-site or vendor) to load radioactive packages that may contain DRP contamination.

(b)

Use an enclosed transport vehicle or overpack to provide a greater margin associated with contact dose rates on the container. (When any package on a conveyance exceeds 160 mR/hr contact, RPM approval is needed for shipment without use of an enclosed transport vehicle or over pack). This approval must be documented on the appropriate radiological survey form. (See additional survey requirements in step 5.2[17] when dose rates exceed eighty percent administrative limit.)

(c)

Sealing of equipment with appropriate wrapping material to prevent migration of residual DRPs (d)

Hydrolazing the equipment prior to removal from pool for packaging (e)

Use of a robust/shielded container to preclude the adverse effects associated with Discrete Hot Radioactive Particle migration during transport (f)

Use of fixatives such as a strippable or dissolvable coating to positively entrain and affix DRPs (g)

IF particles are suspected, THEN consider disassembling the equipment for inspection

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 8 OF 47 Radioactive Shipping Procedure 5.1 continued

[11]

For shipments that contain resin OR other known or suspected methane-producing waste, an explosive gas test may be required in accordance with the applicable cask Certificate of Compliance.

[12]

For shipments of material that exceed 1 R/hr at three meters from the unshielded material, the material must be packaged in an NRC approved Type B package, and the Proper Shipping Name will be UN 3329, Radioactive material, Type B(M) package, fissile, UN 2917, Radioactive material, Type B(M) package non fissile or fissile-excepted, UN 3328, Radioactive material, Type B(U) package, fissile, OR UN 2916, Radioactive material, Type B(U) package non fissile or fissile-excepted.

The material IS no longer LSA or SCO.

[13]

[For GGNS Only] Any Grand Gulf contracts written for the free release of radioactive material must include the requirement that any material not free released must be returned to the site for final disposition.

5.2 GENERAL REQUIREMENTS

[1]

As a prerequisite to loading any shipment as exclusive use ensure the transport vehicle has been radiologically surveyed IAW 49 CFR 173.443 (c).

[2]

Flowchart steps may be performed non-sequentially provided the applicable regulations are satisfied prior to shipment. All regulatory requirements are met prior to using a specification packaging for transporting radioactive material.

[3]

Ensure lifting devices are inspected prior to use and /or annually by qualified personnel. ALARA considerations may limit inspection (camera usage is an available option).

[4]

The requirements of 49CFR173.410 through 417, 10CFR71 & applicable NRC Certificates of Compliance for each specification packaging are met and/or verified prior to loading and transport radioactive material/waste in them.

[GGNS P-18754,18756,32586,32606]

[5]

All applicable shipper permits for the appropriate states and regulatory bodies have been obtained (this list may not be all inclusive).

(a)

Mississippi Emergency Management Agency (MEMA) Waste Transport Permit (as required)

(b)

Department of Transportation Hazardous Material Certificate of Registration (c)

Tennessee Waste Delivery Permit

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 9 OF 47 Radioactive Shipping Procedure 5.2[5] continued (d)

Utah Waste Permit (e)

Notifications per EN-RW-106 for Category 1 Quantities of Radioactive Material

[6]

Notify Reactor Engineering for initiation of a Special Nuclear Material accounting record prior to shipment of any quantity of U-233, U-235 or plutonium as required by 10CFR74.19.

[7]

Verify DOE/NRC Form 741 evaluation has been completed by Reactor Engineering prior to shipment of one gram or more of U-233, U-235, or Plutonium as required by 10CFR74.15. 49CFR173.434 can be used in the calculation of activity-mass relationship for uranium and natural thorium.

[8]

All applicable state, federal, burial site and processor notifications are made.

[9]

WMG Software or equivalent computer software is available.

[10]

All personnel working under this procedure are trained to the specific level required in 49CFR172.700 Subpart H, I.E. Notice 79-19, applicable computer software training &

40CFR262 (when applicable). [W3 P-11759], [RB P-14510]

[11]

WHEN utilizing transport casks as a specification package, THEN handle in accordance with the respective vendor manual and/or Certificate of Compliance. A site procedure may be used in lieu of the vendor manual, IF qualified by the appropriate site group and management.

(a)

Complete applicable cask users check off sheet - perform step validation (verify that the container procedure steps that implement the Certificate of Compliance implementing requirements has a second verification step performed) as a part of vendor oversight when shipment is made by the appropriate Certificate of Compliance.

(b)

Procedures or instructions needed to safely open the cask/package are to be sent to the consignee or verified that possession exists.

(c)

The transport cask may be used as a general design package versus its approved specification level (e.g. Industrial Package II, Type A, Type B).

[12]

Document compliance with applicable regulations by using the appropriate checklists (Category 1 and 2 Quantities of Radioactive Material have additional checklists in EN-RW-106). The level of review and validation of shipping paperwork is performed by personnel trained per Step 5.2[10]. Shipments that require placarding are reviewed prior to the departure of the conveyance from the site.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 10 OF 47 Radioactive Shipping Procedure 5.2 continued

[13]

Radioactive material AND waste loaded into packages must meet appropriate requirements of 10CFR71.87, 49CFR173.410-417, 49CFR173.475, 49CFR173.24, 24a, 24b & 25a. [GGNS P-18738,18741,18742,18743]

[14]

Specification communications (Shipment documentation, Marking, Labeling, Placarding, and Emergency Response) are to be completed in accordance with appropriate sections of 49CFR172 Non-specification markings are to be applied in accordance with designated reference document (i.e. burial site waste class, Radioactive-LSA, Radioactive-SCO & Radioactive / UN ID number on appropriate excepted packages for limited quantities).

(a)

Specification Marking is to be completed in accordance with 49CFR172.300-338. IF an overpack is used to consolidate radioactive packages, THEN compliance with 49CFR173.448(g) is required. IF a sunscreen or personnel barrier is being used over a specification package, THEN the package itself is required to have the UN ID number markings applied directly to the package surface as well as the sunscreen or personnel barrier.

(b)

Specification Labeling is to be completed in accordance with 49 CFR 172.400-450

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 11 OF 47 Radioactive Shipping Procedure 5.2[14] continued (c)

Placarding is to be completed in accordance with 49CFR172.500-560. Use the following table for guidance on Placarding requirements.

Packaging Type Placards on Package Placards on Vehicle Reference Non - Bulk None 4 Placards 172.504: 172.516:

173.427(a)(6)(v)

Bulk < 640 ft3 (non-freight container) 4 Placards 4 Placards 172.504: 172.514:

173.427(a)(6)(v) 2 Placards 4 Placards 172.504: 172.514(c) 2 Labels 4 Placards 172.504: 172.514(c)

Bulk >640 ft3 (non-freight container) 4 Placards 4 Placards 172.504: 172.514(a):

173.427(a)(6)(v)

Freight Container <640 ft3 4 Placards None if visible

172.504: 172.516(a) 2 Placards 4 Placards 172.504: 172.514(c) 2 Labels 4 Placards 172.504: 172.514(c)

Freight Container > 640 ft3 4 Placards None if visible

172.504: 172.512(a):

172.516(a)

If not visible, then 4 Placards are required on the transport vehicle (there is no prescribed preference for application of the placarding requirements)

(d)

Emergency Response Information is completed in accordance with 172.600 -

606, and consists of documented emergency response information provided with the shipping papers, and an emergency response telephone number that is monitored at all times the hazardous material is in transportation. The requirement for a monitored phone line may be met either on site (ie. Control room), or by a contracted agency or organization such as Chem-trec.

[GGNS P-24924]

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 12 OF 47 Radioactive Shipping Procedure 5.2 continued

[15]

Tritium gun sights are handled per EN-NS-225, Tactical Engagement Simulation System.

(a)

Security officers may transport individual gun sights in performance of their normal duties with no restrictions.

(b)

Transportation of gun sights in Entergy-owned MILES trailers may be accomplished by security personnel or contracted common carriers meeting the requirements Section 5.0 of EN-NS-225. The following should be met:

(1)

Security will affirm to RP that the individual gun sights are operational.

(2).7 will be completed (no shipment paperwork is required to accompany the shipment but a bill of lading may be utilized at the sites RP department discretion)

(c)

Transportation of gun sights under the direct control of DOE personnel is exempt from these requirements.

[16]

Ship radioactive material AND/OR waste in accordance with the Flow Charts 1 and 2 AND complete all applicable attachments.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 13 OF 47 Radioactive Shipping Procedure 5.2[16] continued Flow Chart 1: Radioactive Waste Radwaste for shipment Initial package evaluation (dose/contamination/isotopic)

Determine D.O.T & waste classification IAW 49CFR173 &

10CFR61 Satisfy conditions of Section 5.1 - 5.2 Ensure Receivers license IAW 10CFR30.41 Does package satisfy contamination &

radiation limits?

49CFR173 Subpart 1 Decontaminate and/or repackage material (as needed)

Ensure package label & marking IAW 49CFR172 (for example White I, Yellow II, or Yellow III label, Reportable Quantity-RQ, Type A, Type B, Gross Mass )

Is waste being shipped for burial?

Meets processor site criteria Meets burial site criteria Load/shore/brace package(s) on vehicle Complete vehicle inspection &

survey Complete shipping documentation Ship waste Record information in waste tracking program (RW Liability Spreadsheet)

Acknowledgement of receipt IAW 10CFR20 App G No Yes No Yes Determine if Category 1 or 2 Quantities of Radioactive Material per EN-RW-106.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 14 OF 47 Radioactive Shipping Procedure 5.2[16] continued

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 15 OF 47 Radioactive Shipping Procedure 5.2[16] continued

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 16 OF 47 Radioactive Shipping Procedure 5.2 continued

[17]

Surveys of packages and conveyances are completed with instrumentation similar to the facility receiving the material/waste. Instrumentation normally utilized for shipments are those that contain GM detectors.

[18]

The radiation surveys for shipments and packages covered under the requirements of 49CFR173.421, 424, 426, 428, 49CFR177.842, 10CFR71.47 and 49CFR173.441 are not to exceed eighty percent of the levels outlined in the appropriate requirement.

Radiation Protection Supervision may grant permission to ship packages or conveyances above the eighty percent administrative limit, in Attachment 9.11, Radiation & Contamination Survey Limits for Radioactive Material Shipments, provided the guidelines listed in 5.2[18] (a) and 5.2[18] (b) are performed.

(a)

The dose rate survey is performed independently by at least two qualified (ANSI qualifications required) Radiation Protection Technicians utilizing different survey instruments of similar types.

(b)

The verification survey instrument utilized in step listed above is to be source checked prior to shipment departure.

[19]

After unloading exclusive use vehicles, surveys must be performed prior to releasing the vehicle back to an in-service status. The radiation dose rate at every accessible surface is 0.5 mR/hr or less and the removable contamination is less than the levels in 49 CFR 173.443(a).

[20]

All packages and conveyances are to meet the contamination levels of less than 1000 dpm/100 cm2 of non-fixed beta-gamma and less than 20 dpm/100 cm2 of non-fixed alpha. Radiation Protection Supervision may authorize the shipment of packages and conveyances exceeding these limits up to those listed in 49CFR173.443.

[21]

The carrier to be used for shipments placarded Radioactive, Type A, Type B or Highway Route Controlled Quantity (HRCQ) maintains a Transportation Security Plan covering applicable requirements of 49CFR172.800-804. The use of contractual agreements may be a method to ensure this is met. Category 1 and 2 Quantities of Radioactive Materials require additional transportation security measures, which are addressed in EN-RW-106, Integrated Transportation Security Plan.

[22]

Each fissile material, controlled shipment must be transported in accordance with 49CFR177.842(f) and applicable fissile requirements of 10CFR71.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 17 OF 47 Radioactive Shipping Procedure 5.2 continued

[23]

Packages required to be loaded by Entergy on to conveyances under the requirements of 49CFR173.427(a)(6)iii, 49CFR173.441(b)(1)ii, 49CFR177.842, 49CFR173.448(a) or applicable Certificate of Compliances are to be accomplished to meet the applicable requirements of the consignee performing the off-loading at the shipments final destination. The package blocking, bracing and shoring is performed in conjunction to support the carrier in meeting the requirements for associated parts of 49CFR393.

(a)

On-site securement of loads while on company owned property is covered by EN-IS-120 including steps 5.3 and 5.9.

[24]

ALARA should be considered when loading packages. Load packages with higher dose rates in the center with the lower dose rates facing outward whenever possible.

Dose rate surveys should be performed during the loading process to ensure DOT requirements are met.

5.3 WASTE CLASSIFICATION

[1]

Determination of concentration in waste containers may be performed by direct sampling or indirect measurements.

[2]

Classification of waste is to be accomplished in accordance with the requirements of 10CFR61.55.

5.4 WASTE CHARACTERISTICS

[1]

Waste shipments sent to disposal facilities are to meet the applicable requirements of 10CFR61.56, Certificate of Compliance (if shipment required), burial site criteria and burial site by-product radioactive material license.

[2]

Waste shipments sent to processors of radioactive waste must meet the applicable portions of 10CFR61.56, Certificate of Compliance (if shipment required), processor waste acceptance guidelines/criteria AND processor by-product radioactive material license.

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 18 OF 47 Radioactive Shipping Procedure 6.0 INTERFACES

[1]

Entergy Quality Assurance Program Manual Control

[2]

EN-RW-106, Integrated Transportation Security Plan

[3]

EN-LI-102 Corrective Action Process

[4]

EN-RP-143, Source Control

[5]

EN-NS-225, Tactical Engagement Simulation System

[6]

EN-IS-120 Motorized Vehicle Safety 7.0 RECORDS

[1]

Retain records in accordance with 49CFR173.415, along with 10CFR20 Appendix G and 10CFR30.51.

[2]

Transfer all applicable records to site-specific permanent plant files. If files require modification, both the original and modified files will be retained and sent as an official file per this section. These records include the following as applicable:

NRC Forms 540 and 541.1 (used for shipments with notifications - with page 2 of 2 being optional)

Attachments 9.2 through 9.9.12 Emergency Response Documentation Exclusive Use Documentation Package and Vehicle Surveys State Notifications Packaging and Dewatering Checklists RADMAN Documentation/Isotopic Information

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 19 OF 47 Radioactive Shipping Procedure 8.0 SITE SPECIFIC COMMITMENTS Site Document Commitment Number or Reference NMM Procedure Section/Step All 49 CFR 173 421, 422 & 423 Att 9.5, 9.8, 9.9 All 49 CFR 173 424 Att 9.7 All 49CFR 173 426 Att. 9.8 All 49 CFR 173 427 (a) (6) (i) - (iii) & (iv),

(vi) &(b)

Att 9.2 All 49 CFR 173 428 Att 9.6 All 49 CFR 173 433 5.2[16]

All 49 CFR 173 435 5.2[16]

All 49 CFR 173 441 (a) (b) & (c) 5.2[18]

All 49 CFR 173 443 (a) & (b) 5.2.[18]

All 49 CFR 173 441 (c) 5.2[18]

All 49 CFR 173 448 (a) & (g) 5.2 [23]

All 49 CFR 173 465, 466 Att. 9.3 All 49 CFR 173 475 (a), (b), (c), (e), (f) & (i)

Att 9.3 All 49 CFR 173 471 (a), (b)

Att. 9.4 All 49 CFR 173 475 5.2 [11]

All 49 CFR 177 842 (a), (b), (c), (d) & (f) 5.2[16], [22]

All 49 CFR 177 843 5.2[19]

All 49 CFR 178 350 (a) & (b)

Att 9.3 All 10 CFR 20 1501 (a) 5.2[18]

All 10 CFR 20 2001 (a) 5.3 and 5.4 All 10 CFR 20 2101 (a), (b) & (c) 5.2[14]

All 10 CFR 20 2005 (a), (c) 5.3 and 5.4 All 10 CFR 20 2006 (b) - (d) 5.3 and 5.4 All 10 CFR 20 Appendix G 5.3 and 5.4 All 10 CFR 30 41 (c) & (d) 5.2[12]

All 10 CFR 61 55 5.3 and 5.4 All 10 CFR 61 56 5.3 and 5.4 All 10 CFR 61 57 5.3 and 5.4 All 10 CFR 71 5(a) (1) (iv) & (vi), 5(b)

5.2[10],[14]

All 10 CFR 71 87 a-k All 10 CFR 71 97 (a), (b), (c)

Att 9.2,Att. 9.4

NUCLEAR MANAGEMENT MANUAL QUALITY RELATED EN-RW-102 REV. 13 INFORMATIONAL USE PAGE 20 OF 47 Radioactive Shipping Procedure Site Document Commitment Number or Reference NMM Procedure Section/Step Grand Gulf FSAR 11.4.1.2 S7 5.2[14]

Grand Gulf FSAR 11.4.2.3.C.S 3,S 4 5.2[14]

Grand Gulf FSAR 11.4.2.4.3 5.2[14]

Grand Gulf FSAR 11.4.2.4.5.S 4 5.2[14]

Waterford 3 W3P83-2211 P-11759 5.2[10]

River Bend RBF1-96-0284 P-14510 5.2[10]

All Reg. Guide 1.21 Appendix A C. S1, S2 & S3 5.2[14]

All ANSI N13.2 4.7.4 5.2[14]

All GNRI-91/00117 IN 91-35 5.2[14]

Grand Gulf GNRI-92/00195 P.3OF4, PARA 2 P-24924 5.2[14] (d)

Grand Gulf GNRI-92-00149 92-24 5.2[14] (d)

Grand Gulf QAPM A.1.C Grand Gulf QAPM B.7.D Grand Gulf 49CFR172 Grand Gulf 49CFR173.24 P-18738 5.2[13]

Grand Gulf 49CFR173.25(A)(2-4)

P-18741,18742,18743 5.2[13]

Grand Gulf 49CFR173.403 P-18744 3.0[1]

Grand Gulf 49CFR173.411(A)

P-18754 5.2[4]

Grand Gulf 49CFR173.415(A)S1 P-18756 5.2[4]

Grand Gulf 49CFR173.410 P-32586 5.2[4]

Grand Gulf 49CFR173.411B P-32606 5.2[4]

Covered by directive as a whole or by various paragraphs of the directive.