ML082660725

University of Missouri Request for Extending Use of Expiring Transportation Packages

ML082660725
Person / Time
Site:	University of Missouri-Columbia
Issue date:	08/22/2008
From:	Rhonda Butler Univ of Missouri - Columbia
To:	Brach E NRC/NMSS/SFST
References
RIS-08-018
Download: ML082660725 (87)

Text

{{#Wiki_filter:1513 Research Park Drive Research Reactor Center Columbia, MO 65211 University of Missouri PHONE 573-882-4211 FAX 573-882-6360 WEB http://web.missouri.edu/-murrwww 22 August 2008 E. William Brach Director, Division of Spent Fuel Storage and Transportation Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C., 20555-001

Subject:

Request for Extending Use of Expiring Transportation Packages

Dear Director Brach,

This letter. serves as a request from the University of Missouri Research Reactor (MURR) to the U.S. Nuclear Regulatory Commission (NRC) that NRC grant MURR permission to continue using packaging for the shipment of Type B quantities of radioactive materials beyond October 1, 2008, when authorization to use those packages is set to expire. Specifically, MURR requests permission for continued, but limited, use until October 1, 2010 of the existing Type B packages currently in service. These packages were built and are maintainedto U.S. Department of Transportation (DOT) specifications 20WC and 6M conforming in all aspects to the requirements of 49 CFR Subchapter C, in effect on October 1, 2003.. On or before October 1, 2010 it is expected that a fleet of radioactive materials packages compliant with 10 CFR 71 will be in service at MURR. Per NRC Regulatory Issue Summary 2008-18 "Information on Requests for extending use of Expiring Transportation Packages," the following information is provided. Please note that this same request for extended use of the packages has been submitted under separate cover to DOT, in accordance with 49 CFR 107.105.

1. Package Information Please refer to Table I below for a comprehensive listing of the DOT specification package fleet currently operated by MURR, along with their serial numbers, model, and year of manufacture.

MURR Packaging Extension Request Page 1 of 14 22 August 2008 Ao,ý- (D FIGHTING CANCER wrrIH ToMoRxow's TECHNOLOGY

Table 1 DOT Specification Packaging Operated By MURR Serial Year of Number Model Manufacture 4016 20WC-1 1996 4018 20WC-1 1996 4021 20WC-1 1996 4023 20WC-1 1996 4001 20WC-1 2000 4002 20WC-1 2000 4003 20WC-1 2000 4004 20WC-1 2000 1802 6M (15 gallon) 1997 1803 6M (15 gallon) 1997 1820 6M (15 gallon) 1997 1824 6M (15 gallon) 1997 1863 6M (30 gallon) 1997 2256 6M (10 gallon) 1999 2162 6M (10 gallon) 2000 2257 6M (10 gallon) 2002 1866 6M (10 gallon) 2003 2161 6M (10 gallon) 2003 1864 6M (10 gallon) 2004 2160 6M (10 gallon) 2004 2165 6M (30 gallon) 2004 2991 6M (10 gallon) 2004 2992 6M (10 gallon) 2004 2993 6M (10 gallon) 2004 2994 6M (10 gallon) 2004 MURR Packaging Extension Request Page 2 of 14 22 August 2008

2995 6M (10 gallon) 2004 2996 6M (10 gallon) 2004 2998 6M (10 gallon) 2004 2999 6M (10 gallon) 2004 2258 6M (10 gallon) 2004 2990 6M (10 gallon) 2004 2997 6M (10 gallon) 2004

2. Identification of Shipments. (a) Number of shipments; (b) number of packages per shipment; (c) packaging serial numbers; (d) package contents; (e) end use of the radioactive material; (f) shipment origin and destination; (g) mode; (h) general timeframe (e.g., first quarter 2009); and (i) date last shipment will be completed.

MURR is the primary or sole domestic source for many radionuclides used daily in cancer-fighting radiopharmaceuticals, research techniques and industrial applications. These shipments are made on a regular, ongoing basis and will continue until new packages are available in October 2010. Table 2 gives, a breakdown and summary of those shipments and Table 3 provides details on the use of the radioactive material shipped. All shipments originate at MURR, located in Columbia, Missouri. The packaging serial numbers will vary as packages are rotated in and out of service, though the general package type (either 6M or 20WC) will be the same for each shipment. Please see Table 1 for a complete list of serial numbers for each package in service at MURR. Table 2 Shipment of Type B Quantities of Radionuclides from MURR Packages Current Isotope Shipped Package Form Mode/Destination/Distance per Week Used Sm-153 1 6M Solid Charter Air/1 300 miles/Boston Area Ground (truck)/multiple destinations - New Orleans Area, Boston Area, Southern California/1 000 miles - 1700 miles Ir-194 Solid Impurity, see Table 3 Ba- 1 20WC Solid Ground (truck)/Seattle area/2000 135m miles Ba-131 Solid "Impurity," see Table 3 Cs-131 Solid "Impurity,"see Table 3 MURR Packaging Extension Request Page 3 of 14 22 August 2008

Table I Use of Radionuclides Shipped in Type B Quantities Isotope Form Use Sm-153 Solid (powder in quartz vial in canister) Cancer Treatment Ir-192 Solid (wires or buttons in aluminum Cancer Treatments, block or confinement) Industrial Radiography Ir-194 Solid (wires or buttons in aluminum Impurity with Ir-192 block or confinement) Ba-135m Solid (powder in canister) Impurity with Ba-131, dominant isotope for shipping Ba-131 Solid (powder in canister) Parent of Cs-131 Cs-131 Solid (powder in canister) Cancer Treatment, daughter from Ba-131 P-32 Solid (powder in canister) Tracer for biomedical research Yb-169 Solid (powder in quartz vial in canister) Cancer Treatment

3. Reasons for Requesting Extended Use. Justification for extending the use of expiring packages must describe why acquiring replacement packages is not practical and why shipments cannot be made before the October 1, 2008, expiration date. The justification must demonstrate that: (a) there are no alternative domestically approved packages available; (b) the contents cannot be reconfigured such that transport can be conducted in accordance with the regulations; and (c) the transport schedule cannot be adjusted so as to be conducted in accordance with the regulations. The justification must also describe any good-faith efforts to acquire replacement packages that meet the current package performance requirements, including a detailed description of past activities and the current status of acquiring replacement packages. In addition, any adverse impacts that will result if the shipment is not conducted should be fully described.

MURR has attempted to meet the regulations in a timely manner. Upon the implementation of the new regulations in 2003, it was expected that industry would provide packages to the 10 CFR 71 standard. MURR, as a research institution and producer of medical, industrial and research radioisotopes, planned to purchase approved designs in the open market. MURR Packaging Extension Request Page 4 of 14 22 August 2008

Industry did not step forward and no designs meeting the varied research, medical and industrial radioisotope needs of MURR have been approved by the NRC as of this writing. Unsuitability of Alternative or Currently Approved Packages There are some packages that are currently permitted for use after October 1, 2008 that were considered by MURR as possible base designs to transport the radionuclides shown in Table 2 and Table 3. These include:

   "   MIDUS approved under NRC Certificate of Compliance 9320

• ES-3100 approved under NRC Certificate of Compliance 9315
• MDS Nordion USA/0126/B(U)-96 under NRC Certificate of Compliance 0126
• A variety of packages dedicated to special form material, such as the SPEC-1 50 (CoC 9263), SPEC-300 (CoC 9282) and the IR-100 (CoC 9157)

The MIDUS package comes close to meeting many of the needs for a 20WC-1 replacement package. MIDUS is designed to transport Mo-99 as natrium molybdate in liquid form. The package weighs 330 kg (727 Ibs) but is well-shielded and the basic design is approved. The manufacturer of the MIDUS submitted a response to the RFP issued in 2007, however the proposed cost structure was far too expensive for MURR's budget. This was unexpected as MURR had initially assumed that this proven design would require a relatively inexpensive refit to expand the contents and serve as a 20WC-1 replacement. The ES-31 00 is designed for fissile material transport and weighs 190.5 kg (420 Ibs). In its current form, it is too heavy to replaced the 6M, yet too lightly shielded (using a stainless steel containment vessel) to transport the high-activity radionuclides required by MURR's clients and research partners. A similar package, the 9977 B(M)F-96, was submitted in response to the second Request for Bid issued in 2005, but the cost structure proposed for a 6M replacement design and refit for 20WC-1 ireplacement was far too expensive. The MDS Nordion package designated USA/0126/B(U)-96 is an excellent analog of the 20WC-1 and meets the needs for that type of packaging. It weighs 148 kg (326 Ibs) and is approved for multi-radionuclide use. Using the design, investing in getting U.S. regulatory approval for domestic use and then building the packages through MDS Nordion was an early idea for meeting at least a portion of MURR's packaging needs. MDS Nordion consistently rejected MURR's inquiries over several years on grounds that the design is proprietary and that MDS Nordion saw no business interest in allowing MURR to license and/or buy the design. The various special form packages are all highly specialized packages and dedicated to specific source types. In addition, many of these packages are designed by the companies that produce or ship the special form material and are considered proprietary designs. In addition, such designs are not easily reworked to ship solids and liquids rather than special form material. Such work and expense would be better spent on packages designed for the purpose. In summary, while some packages that have been granted a Certificate of Compliance by NRC would appear to be good base designs to help meet MURR's packaging needs, none would MURR Packaging Extension Request Page 5 of 14 22 August 2008

meet even a small portion of the Type B package replacement needs today and even with significant work and efforts to upgrade the designs, they fall far short of the replacement packages currently under contract for design and delivery. Reconfiquringq the Contents MURR investigated the possibility of dividing the radioactive material currently shipped in Type B quantities into multiple Type A shipments. Due to ALARA concerns, the nature of the material shipped and a variety of handling issues, this was not regarded as feasible ALARA Concerns - Applies to Sm-153, Ir-192 (Ir-194), Ba-135m (Ba-131, Cs-131), P-32, Yb-169 As an NRC licensee, MURR is required to adhere to an "As Low As Reasonably Achievable" policy in regards to radiation exposure to staff per 10 CFR 20.1101 (b). After the designated irradiation period for the material in question, the material is allowed to decay for a period of time and then the canisters are removed from the reactor pool. In the case of the material encased in quartz vials, the canisters are opened inside of a hot cell and the quartz vial removed. This quartz vial is enclosed in a shielded container which is then placed in a Type B package for shipment. In the case of material that is stored in only the aluminum canister, the canister is placed directly into the Type B package, after being cleaned. To require MURR to open a welded can containing open radioactive powder, or the break open a quartz vial containing radioactive powder in order to divide the material into multiple Type A shipments invites a host of potential exposure problems, including:

    "   Free powder can contaminate the hot cell in which the work is being performed. This dramatically increases the chances that the material will contaminate the manipulators and various surfaces in the hot cell, requiring hours or days of decontamination and survey work and consequently more radiation exposure to staff.

• Iridium wires or buttons are encased in aluminum blocks for irradiation positioning and shipping purposes. To saw, cut or dissolve the aluminum would require hours of work with intensely radioactive materials and an increase in the radioactive waste stream, generating mixed waste if the dissolution method was chosen.

    " The extra hours spent on this process requires the hot cell workers to endure more exposure. Currently, typical exposure rates for hot cell workers are 5-10 mR per hour.

Adding hours of processing time or decontamination work would quickly increase the radiation exposure to those workers.

• Each package must be surveyed after loading. Instead of five to seven Type B packages to survey, the shipping and health physics staff would now have at least twenty or more Type A packages to survey, increasing the exposure time.

MURR Packaging Extension Request Page 6 of 14 22 August 2008

Exposure rates would increase dramatically under any plan that required MURR to break the materials into Type A quantities prior to shipping. Material and HandlingIssues - Applies to Sm-153, Ir-192 (Ir-194), Ba-135m (Ba-131, Cs-13 1), P-32, Yb-169 The materials shown in Table 2, above, are sealed in welded aluminum canisters and leak-tested prior to being irradiated. Some materials, such as Sm-1 53, are first sealed in quartz vials before being welded into the canisters. Other material, such as Ba-131/Ba-135m/Cs-131 product are sealed directly into the welded canister and not encased in a quartz vial. A variety of handling issues also arise in subdividing radioactive material into Type A quantities. Any increase in complexity can have a direct impact on safety. Some issues include:

• The increased workload would result in a bottleneck in getting packages out the door as the number of packages shipped by MURR increased dramatically. This would result in delays and reduced efficacy of the radionuclides when used in cancer treatments, research or industrial uses.
• For our radiopharmaceutical clients, breaking the quartz vial and parceling out the radioactive powder into smaller quantities would make it unusable in a radiopharmaceutical that has been approved by the Federal Drug Administration (FDA).

Some of our clients require a specific target material and sample size as part of their processing procedures as approved by the FDA or other regulatory bodies. Their quality programs require the use of a single discrete sample etched with a QA number that must be confirmed by the radiopharmaceutical manufacturer before production can begin. Subdividing such quantities is not realistic for our clients' and partners' intended, approved, use.

• Similarly, the radionuclides that are used in medical applications are sterilized by the intense gamma radiation exposure they experience during irradiation at MURR.

Opening these sealed containers (to separate the material into Type A quantities) in a non-sterile environment allows for the introduction of both biological and non-biological contaminants. This invites a host of contamination issues and likely renders the samples unusable. The ALARA and materials handling issues raise significant concerns for workers and end-users, including patients. As a result, it is not feasible to subdivide all of MURR's Type B shipments into a greatly increased number of Type A shipments. Readiusting the Transport Schedule As MURR serves medical, research and industrial customers on an ongoing basis, a readjustment of transportation schedules would not help alleviate the need for permission from the NRC to continue using the DOT specification packages on and past October 1, 2008. MURR Packaging Extension Request Page 7 of 14 22 August 2008

Efforts to Meet the ReQulations It became clear over the course of 2004 that industry would not be stepping forward to design, gain approval for, and manufacture packages suited to the varied needs of MURR's research, medical and industrial partners. MURR then attempted to prod the market by initiating contract bids. Over the course of 2005, MURR initiated two Requests for Bid, soliciting industry for a contract to design, test and fabricate packages meeting 10 CFR 71. The first bid met with no response. The second bid produced one response that could not be implemented due to excessive costs. In 2006, MURR then formed an investigative team to determine the feasibility of obtaining the necessary licensing to design, test and build packages to the 10 CFR 71 standard in-house. This was not a feasible solution in terms of expertise, experience and financing. The above efforts having met with no success, MURR then issued a Request for Proposal in March of 2007 which resulted in four vendor responses. A vendor was awarded a contract in August of 2007 and work is underway for the design, testing and fabrication of Type B Packages that will satisfy 10 CFR 71. The NRC has issued a docket number for each design. The 6M replacement has a docket number of 71-9337 and the 20WC-1 replacement has a docket number of 71-9338. Details on the project itself are provided in Section 5, below. Adverse Impacts If MURR is denied permission to continue using DOT specification packaging, it will result in a severe impact on the domestic supply of radioisotopes for medical uses, industrial applications and research and will have dramatic consequences for MURR as it currently operates. MURR relies on Type B DOT specification package shipments for roughly 30% of its Products & Services revenue. Losing this revenue will result in significant, unsustainable budget shortfalls. Such a significant loss of revenue, combined with the large sums already spent and budgeted for the Type B package replacement project could not be absorbed by MURR. Having the ability to ship in DOT specification packaging becomes even more critical if some of MURR's partners and customers lose the ability to ship in their DOT specification packaging come October 1, 2008. If MURR is allowed to continue to ship, we can fill the gap for those customers of ours who choose not to apply for, or are denied, permission to operate DOT specification packages past the deadline. The shipment details provided in Table 2 above do not include shipments made in customer-owned packages, some of which are DOT specification packages. Effects on Individual Isotopes MURR is the sole domestic source for Sm-1 53, Ir-1 92, Cs-1 31, P-32, and Yb-1 69. MURR's relatively high flux (4E14 n/cm 2-sec), consistent operating schedule (averaging 150 hours/week, 52 weeks per year since the late 1970's) and our central geographic location make us the only MURR Packaging Extension Request Page 8 of 14 22 August 2008

reliable and efficient source for the high-activity radionuclides needed for medical, industrial and research use. The Sm-153 provided by MURR is the radioactive component of a cancer-fighting radiopharmaceutical, Quadramet. Without the ability to ship the Sm-1 53 in a DOT specification package, that product can not be produced and provided to cancer victims. The Ir-192 provided by MURR is used by a variety of companies for both brachytherapy applications and industrial radiography needs. These companies could rely on foreign reactors for this material, but MURR is a preferred supplier to them due to our reliable schedule. Without the ability to ship Ir-192 in DOT specification packages, the United States loses a major domestic source of this isotope, and the only source that can reliably produce it week in and week out. The Cs-1 31 provided by MURR is used as the radioactive component for a variety of cancer treatments. We are the sole domestic source for this radionuclide. If we lose the ability to ship this radionuclide in DOT specification packaging, the manufacturer of the cancer therapy agents will be forced to turn to foreign reactors for supply. MURR is the sole domestic source for P-32. Other reactors can provide it to our customer, but at the cost of relying solely on foreigner reactors for this critical component of biomedical research. Yb-169 is supplied to a customer for continuing cancer medicine research and therapies. As with the other radionuclides, MURR is the sole domestic source for this material. If MURR loses the ability to ship these radioisotopes in DOT Type B specification packaging, the ripple effects will extend into various industries and into the lives of patients receiving cancer therapies.

4. Safety Justification for Continued Use and Proposed Compensatory Measures.

Since the expiring package designs may lack safety enhancements included in newer designs, the request must include a safety justification for continued use and a description of compensatory measures that will be used to provide an equivalent level of safety. Examples of compensatory measures that may be considered are: (a) special package inspections, tests, or determinations that ensure that the packaging is in unimpaired physical condition; (b) transport by exclusive use; (c) transport during time of low road usage; and (d) accompaniment of shipment by escort equipped to effect a recovery in an emergency situation or in case of a transportation accident. MURR operates, and will continue to operate, the existing fleet of DOT specification packages in compliance with 49 CFR 173.416(c), which requires MURR to conform "in all aspects to the requirements of this subchapter in effect on October 1, 2003." Adherence to the applicable regulations is governed by MURR SOP AP-SH-001 (Administrative Procedure, Radioactive Material Shipping). MURR Packaging Extension Request Page 9 of 14 22 August 2008

Compliance with the DOT regulations is demonstrated through a variety of inspection, operation and maintenance programs. In addition, MURR operates the package fleet under an NRC-approved Quality Assurance (QA) program. Please note that all Standard Operating Procedures referenced below, as well as the QA/QC Program Service Applications and official checklists are reproduced in full in Appendix A. Inspection Upon the return of a DOT specification package to MURR by a customer, the package is first surveyed for contamination, per MURR SOP RP-HP-110 (Survey and Decontamination of Returned Shipping Containers). The package is then inspected by a Certified Shipping Technician and the condition recorded on the "Type B Cask Inspection Log" which is kept for each DOT specification package. Every single DOT specification package must be inspected in this manner when it returns to the facility. If there is a need for minor repairs or maintenance, this is noted and the maintenance is performed under the appropriate procedure. Operation MURR operates the packages in a manner that ensures safe operation of the fleet and provides for constant inspections of the packages themselves by both a worker and reviewer.

    "    BPB-SH-002 (20WC-1 Packaging and Shipment of Type B Non-Waste Radioactive Material) o    FM-35 (Control Checksheet for Type B USA DOT 20WC-1 Radioactive Material Shipment) o    MURR-SAS-00007 (QA/QC Program: USA DOT 7A Inner Cask)
                    " Attachment 1 (Control Checksheet for DOT 7A Inner Cask Lid Gasket)
                    " Attachment 2 (Control Checksheet for DOT 7A inner Cask Lid Hold Down Bolt)

• BPB-SH-005 (DOT 6M Packaging and Shipment of Type B Non-Waste Radioactive Material) o FM-74 (Control Checksheet for Type B USA DOT 6M Radioactive Material Shipment)

Maintenance The DOT specification packages are integrated into MURR's facility-wide preventive maintenance program. MURR utilizes a standard industry software package (MAXIMO) for MURR Packaging Extension Request Page 10 of 14 22 August 2008

scheduling and tracking preventive maintenance. This software generates automatic notices of when maintenance is due, assigns the task to a responsible party and allows for tracking and status reports of the work. The preventive maintenance items currently scheduled for the DOT specification packages are annual replacement of gaskets in the DOT 7A Inner Cask used by the 20WC-1 packagings and for calibration and inspection of the torque wrenches and other tools used in working with the packages. Maintenance and inspection is intimately tied to Operation, requiring a constant review of all packages in service to assure that they meet the regulations governing packaging. NRC Quality Assurance Program MURR operates the DOT specification package fleet under NRC QA Certification No. 71-0108, Revision No. 8 and the associated QA Plan. This plan may be found in Appendix C. This QA program allows for maintenance, repair and use of the packagings. The QA plan provides a framework for compliance with 10 CFR 71, Subpart H. This QA Program applies to all activities affecting the DOT specification packages and their components. The program comprises the planned and systematic actions necessary to provide confidence that the package will perform satisfactorily while in service. The Program In summary, each package is subject to a complete inspection every time it is used and returned to MURR. This program allows for the constant monitoring of the fleet and provides for immediate action to repair the packages or replace components when necessary. This constant review of the packages helps to ensure that the fleet is maintained in at least fair condition at all times.

5. A Plan and Schedule to Acquire Replacement Packages or Complete Necessary Shipments. Details about the planned acquisition of replacement packages must be provided, along with key milestones, and proposed implementation dates, unless the licensee can show why acquiring a replacement package is not practical and why shipments cannot be made before the October 1, 2008, expiration date.

The University of Missouri Research Reactor (MURR) signed a $2 million contract (in response to University of Missouri RFP #C032907) with a package design and manufacturing vendor, Croft Associates, Ltd. on 22 August 2007. This contract requires the vendor to design, build and gain NRC and DOT approval of two new Type B package designs. These designs are:

1. The SAFKEG-LS, which will replace the 6M DOT specification package and weigh less than 68 kilograms (150 pounds) fully loaded MURR Packaging Extension Request Page 11 of 14 22 August 2008

2. The SAFKEG-HS, which will replace the 20WC DOT specification package Please refer to Appendix B for specification sheets describing each package design in general terms.

MURR has spent over $320,000 to date on the Type B Package Replacement Project and is projected to spend over $2 million total (for contracted and off-contract expenses) by the end of the contract. Please note that we have split the program into separate production tracks for the LS and HS designs. There are substantial lead times involved in acquiring the depleted uranium (DU) necessary for the HS design. The LS design faces no such production challenges and the Safety Analysis Report for Packaging (SARP) for the LS will be submitted to the NRC several months in advance of the HS SARP. It is hoped that the experience gained from the LS SARP review will speed the approval of the HS SARP by NRC, though this obviously cannot be guaranteed. Key Accomplishments to Date To date, the vendor has completed the following major tasks:

• Package Designs are complete, manufacturing drawings have been prepared for the designs
• Materials studies have been compiled for the stainless steel and DU components. Full testing of the proposed packing material is scheduled for August
• Extensive work has been done on describing and evaluating the means to contain the nearly 50 radionuclides that MURR will require to be listed on the eventual Certificate of Compliance, including the design of shielded re-usable containers that will be packed in the containment vessel

    "   Finite Element Analysis (FEA) for Stress has been performed for the package designs, analyzing the outer stainless steel shell, packing material and inner containment vessel

• Shielding calculations have been performed for the package designs using worst-case scenarios for placement and activity of radioactive material

    " Orders have been placed with a specialty manufacturer to forge depleted uranium shields for the HS prototype

• The vendor's Quality Assurance program was audited by the NRC in May of 2008 and approval granted to conduct all design, testing and SARP work
• Drop tests have been performed at both ambient temperature and -40 0 C, from 9 meters, on a "pre-prototype" unit to confirm structural properties of the stainless steel and MURR Packaging Extension Request Page 12 of 14 22 August 2008

packing material, as well as to acquire g-loadings for use in further FEA Stress calculations Significant progress on a draft SARP for each design has been made The above tasks are merely highlights of the work conducted to date. Upcoming Tasks Some key upcoming task items and due dates are provided in Table 4 below. Table 4 Key Upcoming Tasks for MURR Type B Package Replacement Project Estimated Task Etioate Completion Date Comments LS Prototype 29 August 2008 Manufacture LS Prototype Tests 13 October 2008 Includes steady state thermal testing and all drop tests and comparison to computer models LS SARP 23 March 2009 Completion date is the expected submission date Compilation of Rev 0 to NRC Issuance of SER This is an estimate and dependent upon the NRC and Certification by January 2010 review process. NRC LS Manufacturing May 2010 This is entirely dependent upon the NRC review process HS Prototype 12 December Manufacture 2008 HS Prototype Tests 23 January 2008 Includes steady state thermal testing and all drop tests and comparison to computer models HS SARP 11 May 2009 Completion date is the expected submission date Compilation of Rev 0 to NRC Issuance of SER This is an estimate and dependent upon the NRC and Certification by March 2010 review process. NRC HS Manufacturing July 2010 This is entirely dependent upon the NRC review process MURR Packaging Extension Request Page 13 of 14 22 August 2008

Please refer to Appendix C for a complete Project Plan and Gantt chart that has been provided to MURR by the vendor. The Gantt chart provides a detailed list of both accomplished tasks and future work. Conclusion The University of Missouri Research Reactor has made every effort to obtain compliant packaging so that we may continue our safe and responsible shipment of Type B quantities of radioactive materials throughout the United States. This request provides information and background material supporting the request that NRC allow MURR to continue to operate its existing fleet of 6M and 20WC packages for two (2) years past the October 1, 2008 deadline. As MURR serves radiopharmaceutical companies with materials shipped in Type B quantity, we would appreciate the NRC notifying MURR as soon as practicable with their response to this request. MURR is obligated to provide our customers with as much lead time as possible to help them arrange for an orderly shutdown of production and for notification of cancer patients scheduled to receive treatments. Your time and attention to our request is appreciated. If you have any questions or concerns, please do not hesitate to contact me at the address, phone number or email address above. In addition, you may contact Mr. Michael Flagg, the technical point of contact for this project at MURR, via email at FlaggM@missouri.edu or by phone at 573-882-5364. Sincerely, Ralph A. Butler Dat' Director, University of Missouri Research Reactor MURR Packaging Extension Request Page 14 of 14 22 August 2008

Appendix A NRC Approved QA Plan and Relevant Standard OperatingProcedures MURR Packaging Extension Request F " x"x

                                                                         ý,August 2008

UNIVERSITY OF MISSOURI-COLUMBIA RESEARCH REACTOR FACILITY SHIPPING QUALITY ASSURANCE PROGRAM FOR TYPE B SHIPPING CASKS 1513 Research Park Drive Columbia, MO 65211 (573) 882-4211

TABLE OF CONTENTS I. Introduction ..................................................................................................................................... 3 II. Quality A ssurance ................................................................................................................................. 3

1. Organization ............................................................................................................................. 3

2. Q uality A ssurance Program .............................................................................................. 5

3. Procurem ent D ocum ent Control ....................................................................................... 6

4. Instructions, Procedures, and Draw ings ........................................................................ 6

5. Docum ent Control ........................................................................................................... 6

6. Control of Purchased M aterial, Equipm ent, and Service ................................................. 7

7. Identification & Control of Materials, Parts, and Components ...................................... 8

8. Control of Special Processes .............................................................................................. 8

9. Inspection and Test Control ............................................................................................... 8

10. Control of M easuring and Test Equipm ent ...................................................................... 9

11. H andling, Storage, and Shipping ...................................................................................... 9

12. Inspection, Test, and Operating Status ............................................................................ 10

13. N on-Conform ing M aterials, Parts, and Com ponents .................................................... 10

14. Corrective A ction ................................................................................................................... 10

15. Q uality A ssurance Records ............................................................................................... 11

16. A udits ................................................... , .................................................................................. 11 Appendix A. QA Personnel Responsibilities B. References C. Shipping QA Organization Chart Page 2 of 11

I. INTRODUCTION By this document the University of Missouri Research Reactor (MURR) establishes a Shipping Quality Assurance (QA) Program in accordance with 10 CFR 71, Subpart H. The MURR Shipping QA Program establishes requirements applicable to procurement, use, maintenance, and repair of packaging used in transport of licensed material in excess of a Type A quantity. The program includes the purchase, handling, shipping, storing, cleaning, assembly, inspection, testing, operation, maintenance, and repair of Type B shipping containers regulated by 10 CFR 71. The Shipping QA Program applies to those activities affecting the casks and their components, which are significant to safety. Quality assurance comprises those planned and systematic actions necessary to provide adequate confidence that a system or component will perform satisfactorily in service. Shipping casks regulated by 10 CFR 71 will be released for shipping only after they have satisfactorily met the requirements of the MURR Shipping QA Program.

11. QUALITY ASSURANCE I. Organization The Associate Director of the MURR Regulatory Assurance Group (RAG) is responsible for the Shipping QA Program and shall assure the program complies with 10 CFR 71, Packaging and Transportation of Radioactive Material. The Associate Director (RAG) will have the following minimum qualifications:

Bachelors degree in Engineering or related field; Certified Health Physicist (CHP); five years experience with reactors; and general knowledge of all aspects of research reactor operation. The Associate Director (RAG) shall designate individuals, in writing, as Shipping QA Supervisors who have the responsibility to ensure that all work in their assigned area complies with 10 CFR 71, Subpart H-Quality Assurance. The Associate Director (RAG) shall designate in writing Shipping QA Inspectors, who have the responsibility to ensure that all requirements of Shipping QA procedures have been performed and verified. The Shipping QA Supervisor and Shipping QA Inspector positions may be collateral duties of the designated staff members. Page 3 of 11

All Shipping QA Supervisors, Inspectors, and Performers have the authority to stop unsatisfactory work in order to comply with federal regulations and MURR Shipping QA procedures. If a difference in opinion or a safety concern occurs between a Shipping QA Inspector and other Shipping QA personnel concerning compliance with the Shipping QA Program, the work evolution involved shall be stopped and put in a safe condition. The Shipping QA Inspector shall show the individual(s) the basis for the requirement. If the difference of opinion still exists, the appropriate Shipping QA Supervisor shall resolve the difference after consultation with the Associate Director (RAG). MURR has divided the Shipping QA Program into four responsible groups: Hot Cell Operations, Radioactive Materials/Shipping, Reactor Operations and Hazardous Waste/Health Physics. Each group has a Shipping QA Supervisor to ensure that work in their assigned area meets the requirements of the MURR Shipping QA Program. The Supervisor, Hot Cell Operations, is responsible for the packaging of Type B radioactive by-product materials and their preparation for shipment. The Supervisor, Hot Cell Operations is designated as a Shipping QA Supervisor. The Health Physics Manager is designated as an alternate Shipping QA Supervisor for Hot Cell Operations. The Manager, Radioactive Materials/Shipping is responsible for all Type B shipments except for shipments of reactor spent fuel, fissile material and radioactive waste. The primary responsibility of the Manager, Radioactive Materials/Shipping is the safe transportation of Type B quantities of by-product radioactive materials. The Manager, Radioactive Materials/Shipping is designated as a Shipping QA Supervisor. The Health Physics Manager is designated as an alternate Shipping QA Supervisor for Radioactive Materials/Shipping. The Assistant Reactor Manager-Physics is responsible for Type B shipments of reactor spent fuel and/or fissile material. The primary responsibility of the Assistant Reactor Manager-Physics is the safe shipment of reactor spent fuel. The Assistant Reactor Manager-Physics is designated as a Shipping QA Supervisor. The Assistant Reactor Manager-Engineering is designated as an alternate Shipping QA Supervisor for spent fuel and/or fissile material shipments. Page 4 of 11

The Hazardous Waste Coordinator/Health Physicist is responsible for Type B shipments of radioactive waste. The main responsibility of the Hazardous Waste Coordinator/Health Physicist is the safe shipment of radioactive waste. The Hazardous Waste Coordinator/Health Physicist is designated as a Shipping QA Supervisor. The Health Physics Manager is designated as an alternate Shipping QA Supervisor for the Hazardous Waste Coordinator/Health Physicist. Per MURR Technical Specification 6.1, the Health Physics Manager shall annually review and approve the procedures for preparation of radioactive materials for shipping and the shipping of by-product material. The Assistant Reactor Manager-Physics shall annually review and approve all procedures for preparation and shipment of Type B radioactive materials of reactor spent fuel and/or fissile material.

2. Quality Assurance Program The MURR Shipping QA Program establishes requirements applicable to procurement, use, maintenance, and repair of packaging used in transport of licensed material in excess of a Type A quantity. Where appropriate, procedures will be in place to ensure the implementation of the MURR Shipping QA Program requirements. Any action or procedure that could significantly affect the ability of any structure, system, or component to perform safely and as specified, falls within the scope of the MURR Shipping Quality Assurance Program.

The Shipping QA Program will be applied in a graded approach to an extent consistent with the importance to safety. Because MURR does not design or manufacture Type B shipping casks, the regulations in 10 CFR 71, Subpart D-Application for Package Approval, Subpart E-Package Approval Standards and Subpart F-Package, Special Forms, and LSA-II1 Tests are not applicable to the MURR Shipping QA Program. Prior to use and shipment of Type B shipping packages, it is the responsibility of the appropriate Shipping QA Supervisor to ensure that MURR is registered with the NRC as an authorized user of the package and the shipment shall be made in accordance with the conditions of the NRC Certificate of Compliance. For international shipments of Type B packaging, it is the responsibility of the appropriate Shipping QA Supervisor to ensure that MURR is registered with the U. S. Certificate of Competent Authority as an authorized user of the package and the shipment shall be made in accordance with the conditions of the U. S. Certificate of Competent Authority. Page 5 of 11

All Shipping QA Supervisors and Shipping QA Inspectors will have their training and experience documented by completion of the appropriate training records. In their assigned areas, each Shipping QA Supervisor shall ensure that all personnel who perform work in accordance with their Shipping QA procedures are adequately trained and qualified to perform this work.

3. Procurement Document Control Prior to the purchase of Type B shipping packages, it is the responsibility of the appropriate Shipping QA Supervisor to ensure that the manufacturer of the packaging supplies all appropriate certifications verifying the designated packaging (model and serial number) was manufactured under the control of an NRC-approved QA program, identifies the type of verification activities required during use and maintenance, and designates other pertinent documentation to be furnished with the packaging (certificate of compliance, as-built drawings, use and maintenance manuals, photographs).

Prior to the purchase of replacement parts for Type B shipping casks, all parts important to safety will be reviewed by the appropriate Shipping QA Supervisor to ensure that all technical and QA requirements are included in purchase orders. When applicable, purchase orders shall be placed with suppliers/manufacturers previously qualified during fabrication of the packaging. For the purchase of replacement parts from suppliers/manufacturers not previously identified as qualified sources, it is the responsibility of the appropriate Shipping QA Supervisor to ensure that the replacement parts meet requirements at least as stringent as the original criteria.

4. Instructions, Procedures, and Drawings Administratively controlled procedures shall be established for the use, maintenance, repair and preparation for transport of all Type B packaging.

5. Document Control Control will be exercised for Shipping QA documents. Shipping QA documents consist of procedures, manuals, audits, instructions, specifications, training records, and drawings used in the procurement, use, maintenance, and repair of Type B shipping casks.

Page 6 of 11

Prior to use, the Health Physics Manager will review and approve all Shipping QA procedures and revisions for the preparation and shipment of Type B quantities of by-product material. Prior to use, the Assistant Reactor Manager-Physics will review and approve all Shipping QA procedures and revisions for preparation and shipment of Type B quantities of reactor spent fuel and fissile material. Controlled copies of approved Shipping QA procedures will be made available to persons responsible for using those documents. In their assigned area, it is the responsibility of each QA Shipping Supervisor: to ensure the accuracy of all Shipping QA documents; to ensure that all personnel performing QA work are adequately trained and qualified to perform this work; and to ensure that all personnel performing QA work are aware of any revisions to the procedures. It is the responsibility of each Shipping QA Supervisor to ensure this training is completed and documented.

6. Control of Purchased Material, Equipment, and Services It is the responsibility of the appropriate Shipping QA Supervisor to ensure that purchased material, equipment, and services, whether purchased directly or through contractors, conform to the procurement documents. Source surveillance, audits of records, inspection and examination of products on delivery shall be performed as appropriate to ensure that the design and fabrication of Type B packaging was performed under the control of NRC-approved QA programs.

The appropriate Shipping QA Supervisor shall ensure that Type B packaging received at MURR is accompanied by appropriate documentation as identified in the purchase order. All documents that are referenced in the certificate of compliance, relate to the use and maintenance of the packaging, and identify necessary actions to be taken prior to the delivery of licensed material to a carrier for transport shall be present. Contractors and suppliers are selected on the basis of references, past performance to MURR, reputation and other investigation. Appropriate credentials, and licenses if required by law, code or regulation, will be furnished and retained on file. No deviations from procurement documents are allowed without written request by the vendor and approval by the Associate Director of the MURR Regulatory Assurance Group (RAG) or his designated representative. Page 7 of II

7. Identification and Control of Materials, Parts, and Components The appropriate Shipping QA Supervisor shall ensure that materials, parts, and components used for repair of Type B packaging are adequately identified and controlled to prevent use of incorrect or defective items. When replacement of limited-life items is specified, the appropriate Shipping QA Supervisor shall ensure that no materials, parts and components are used whose shelf life or operation times have expired.

8. Control of Special Processes The appropriate Shipping QA Supervisor shall ensure that all major repairs or inspections of Type B packaging requiring special processes such as welding or nondestructive testing be performed in accordance with the following criteria: all procedures, equipment, and personnel are qualified in accordance with applicable codes, standards, and specifications; the operations are performed by qualified personnel and accomplished in accordance with written process sheets with recorded evidence of verification; and qualification records of procedures, equipment, and personnel are established, filed, and kept current.

9. Inspection Control The appropriate Shipping QA Supervisor or Shipping QA Inspector will perform a visual inspection of all Type B packaging upon receipt at MURR to ensure compliance with procurement documents. These visual inspections should include inspection of surface conditions; weld and structural integrity; the condition of flange faces or sealing areas, gaskets, seals, gauges, rupture disks, valves and pressure relief devices; the condition of tie-down members; labeling and marking; and leaktightness of the packaging.

Any Type B packaging that does not comply with the procurement specifications or fails the visual QA inspection will be in noncompliance and immediately reported to the appropriate Shipping QA Supervisor and the Associate Director (RAG). Procedures shall ensure adequate maintenance of Type B packaging. They shall identify the items to be maintained, criteria for acceptability or replacement, and the frequencies of inspection assigned to each item. Page 8 of I1

The appropriate Shipping QA Supervisor shall establish checklists to ensure that inspections are performed to verify that the following items have been complied with prior to each use:

1. Type B packages are properly assembled.

2. Valves are set to specifications.

3. All shipping papers are properly completed.

4. Type B packages are conspicuously and durably marked as required by DOT regulations.

5. Authorized individuals shall sign the shipping paperwork prior to release for shipment.

Procedural steps which require an independent QA inspection will be completed by a Shipping QA Inspector or a Shipping QA Supervisor who is not performing the activity being inspected.

10. Control of Measuring and Test Equipment The appropriate Shipping QA Supervisor shall ensure that measurement and test equipment (gauges, fixtures, reference standards, and devices used to measure product characteristics of Type B packages) will be calibrated, adjusted and maintained at established intervals. Measurement and test equipment should be labeled or tagged to indicate the planned date of its next calibration, and the calibration records should be identified and traceable. Calibration shall be traceable to nationally recognized standards; or, where nationally recognized standards do not exist, provisions shall be established to document the basis for calibration.

Measurement and test equipment that fail calibration will be removed from service, and tagged as out of calibration equipment until repaired or replaced.

11. Handling, Storage and Shipping The handling, storage, and shipping of Type B packaging will be controlled to assure safety, minimize degradation, damage and/or loss.

Page 9 of 11

12. Inspection, Test, and Operating Status A tag, label, marking, a log entry or other documentation will indicate the status of Type B shipping containers. The records will indicate when periodic surveillance tests have been performed. No deviation from required inspection, test or other critical operations are authorized without the approval of the Associate Director (RAG).

13. Non-Conforming Materials, Parts, and Components The appropriate Shipping QA Supervisor shall ensure that nonconforming items for completed packaging, replacement parts or components shall include the following principal elements:

(1) proper identification, (2) segregation of discrepant or nonconforming items, (3) disposition of the items of nonconformance, and (4) evaluation of the items of nonconformance. All items or components found to be in noncomformance by procedure, inspection, testing or operations is to be immediately reported to the appropriate Shipping QA Supervisor. Nonconforming items will be quarantined or placed in a controlled hold area until disposition is completed. After designated repair, the appropriate Shipping QA Supervisor shall ensure that the acceptance of nonconforming items is verified by re-inspection or re-test against the original specifications. Final disposition of nonconformances shall be identified and documented. Nonconformance reports should be analyzed by QA personnel to determine quality trends for appropriate management review and assessment.

14. Corrective Action For activities important to safety concerning use, maintenance and repair of Type B packages, the appropriate Shipping QA Supervisor shall ensure that conditions adverse to quality (e.g., those resulting from failures, malfunctions, deficiencies, deviations and defective material and equipment) are promptly identified and reported to appropriate levels of management. In the case of a significant condition adverse to quality, a root cause of the condition will be determined and corrective actions taken to preclude recurrence.

Page 10 of I1

15. Quality Assurance Records The appropriate Shipping QA Supervisor shall ensure the maintenance of QA records that are to be retained for the lifetime of packaging. These records include appropriate design and production-related records that are generated throughout manufacturing and furnished with packaging; records demonstrating evidence of operational capability; records verifying repair, rework and replacement; and audit plans, audit reports, corrective actions and records that are used as a baseline for maintenance.

Records showing evidence of delivery of packages to a carrier and proof that all NRC and DOT requirements have been satisfied should also be retained with their retention times identified. The Associate Director (RAG) is responsible for the prompt replacement of a record that is lost or damaged and for assessing and controlling records in MURR's possession. QA records shall be maintained in storage locations that minimize the risk of damage.

16. Audits The Associate Director (RAG) shall ensure that audits are performed in accordance with pre-established written procedures or checklists and are conducted by qualified personnel not having direct responsibility in the areas being audited. The audit shall verify compliance with all aspects of the Quality Assurance program and determine the effectiveness of the program.

The procedures or checklists shall list activities to be audited and the frequency at which each activity is to be audited. The frequency of audits should be based on the importance of the activity to safety; however, each activity should be audited at least once each year. It is the responsibility of the appropriate Shipping QA Supervisor to ensure that corrective actions resulting from audits are completed and documented on a timely basis. Deficient areas shall be re-audited on a timely basis to verify implementation of corrective action. Page 1l of 11

OA PERSONNEL RESPONSIBILITIES Associate Director of the MURR Regulatory Assurance Group (RAG): The Associate Director (RAG) is responsible for the development and implementation of the MURR Shipping Quality Assurance Program. Health Physics Manajzer: The Health Physics Manager shall annually review and approve the procedures for preparation of radioactive materials for shipping and the shipping of by-product material. Also designated as an alternate Shipping QA Supervisor for Radioactive Materials/Shipping, Hot Cell Operations and Hazardous Waste Coordinator. Assistant Reactor Manager-Physics: The Assistant Reactor Manager-Physics is responsible for Type B shipments of reactor spent fuel and/or fissile material. Also shall annually review and approve all procedures for preparation and shipment of Type B radioactive materials of reactor spent fuel and/or fissile material. Manager, Radioactive Materials/Shipping: The Manager, Radioactive Materials/Shipping is responsible for all Type B shipments except for shipments of reactor spent fuel, fissile material and radioactive waste. Hot Cell Operations The Supervisor, Hot Cell Operations, is responsible for the packaging of Type B radioactive by-product materials and their preparation for shipment. Hazardous Waste Coordinator: The Hazardous Waste Coordinator/Health Physicist is responsible for Type B shipments of radioactive waste. Assistant Reactor Manager-Engineering: The Assistant Reactor Manager-Engineering is designated as an alternate Shipping QA Supervisor for spent fuel and/or fissile material shipments. Shipping QA Supervisors: Shipping QA Supervisors are responsible for ensuring that work in their assigned area meets the requirements of the QA Program. Shipping QA Inspectors: Shipping QA Inspectors shall perform the required QA inspection and have the authority to stop work not meeting the requirements of the QA Program. Page I of I Appendix A

REFERENCES

1. 10 CFR 71

2. Regulatory Guide 7.10 (Rev. 1), June 1986, "Establishing Quality Assurance Programs for Packaging Used in the Transport of Radioactive Material"

3. ANS - 15.8 (N402) - 1976, "Quality Assurance Program Requirements for Research Reactors" (Reaffirmed December 15, 1986)

Page I of I Appendix B

SHIPPING QA ORGANIZATION Page I of I P Appendix C

AP-SH-O01 Revision 5 I MURR SHIPPING PROCEDURE MASTER COPY AP-SH-001 ISSUED FEB 1 6 2007 ADMINISTRATIVE PROCEDURE RADIOACTIVE MATERIALS SHIPPING RESPONSIBLE GROUP: Product & Service Operations, Shipping PROCEDURE OWNER: Mike Kilfoil APPROVED BY: Ronald J. Dobey, Jr. 4 1Date /-4*",*"< APPROVED BY: Kenneth W. Brooks Z Date This procedure contains the following: Pages 1 through 10 Attachments through 2 Tables None through Figures None through Appendices None through Check-Off Lists None through

AP-SH-001 Revision 5 TABLE OF CONTENTS Section Page Number 1.0 PURPO SE ............................................................................................................................ 3 2.0 SCO PE ................................................................................................................................. 3 3.0 DEFIN ITION S ..................................................................................................................... 3 4.0 RESPON SIBILITIES .................................................................................................... 3 5.0 PROCEDURE ..................................................................................................................... 7 5.1 G EN ERA L G UID ELIN ES ................................................................................. 7 5.2 SPECIFIC DUTIES AND RESPONSIBILITIES ............................................. 9 6.0 REFEREN CES .................................................................................................................. 10 7.0 RE CORD S ......................................................................................................................... 10 8.0 ATTACHM EN TS .............................................................................................................. 10 2

AP-SH-001 Revision 5 ADMINISTRATIVE PROCEDURE - RADIOACTIVE MATERIALS SHIPPING 1.0 PURPOSE 1.1 To establish the administrative guidelines necessary for the shipment of radiological isotopes, excluding shipments of fuel and waste, produced at the MURR facility. This procedure also defines general and technical terms and responsibilities that apply to radioactivematerials shipping duties as performed by the Shipping Dept. and groups within MURR that have shipping related functions. 1.2 To provide general guidance to all persons having administrative and technical responsibilities that support or enhance the daily work activities of the shipping process. 2.0 SCOPE 2.1 Ensures that shipping activities comply with all applicable Code of Federal Regulations (CFR) and the InternationalAir TransportAssociation (IA TA) DangerousGoods Regulations. 2.2 Establishes management's expectations regarding shipping activities of radioactivematerials. 2.3 Ensures that Shipping Technicians can accurately interpret and correctly apply specific duties and responsibilities to procedural requirements. 3.0 DEFINITIONS 3.1 Refer to List of Definitions (Attachment 8.2) for a list of key words, terms or phrases that have a particular meaning to the shipping group. 4.0 RESPONSIBILITIES 4.1 Reactor Manager: 4.1.1 Provides 24-hour emergency response information concerning radioactive material shipments from MURR. 4.1.2 Notifies the Radioactive Materials/ShippingManager or designee of all incidents. 3

AP-SH-00 1 Revision 5 4.0 RESPONSIBILITIES (CONT.) 4.2 Health Physics Manager: 4.2.1 Maintains the Radiation Protection Program. 4.2.2 Provides administrative, technical and operational support to the Shipping Department. 4.2.3 Maintains the Radiation Safety Program in support of the multi-faceted research, service and educational programs conducted at MURR. 4.2.4 Ensures that radiological survey and monitoring equipment and the required I documentation used in the MURR Type B Quality Assurance Program are maintained in accordance with facility programs and procedures. 4.2.5 Reviews existing procedures and programs for their effectiveness and revise as necessary. 4.3 Radioactive Materials/ShippingManager: 4.3.1 Maintains the equipment, procedures and required documentation used in the MURR Shipping Quality Assurance Program for Type B Shipping Casks. 4.3.2 Ensures all shipments of radioactivematerial, excluding shipments of fuel and waste, conform to applicable regulations of 10 CFR, 49 CFR, MURR Shipping Quality Assurance Program for Type B Shipping Casks and IA TA. 4.3.3 Provides properly certified packages for shipment of radioactive materials. 4.3.4 Provides administrative, technical and operational support to personnel assigned to the Shipping Group. 4.3.5 Coordinates or specifies a training program to ensure that the hazmat employee has familiarity with the regulations governing the shipment of hazardous materials. This program includes:

               " The ability to recognize and identify the Hazardous Materials shipped from MURR

• Knowledge of applicable requirements
• Knowledge of Emergency Response Information
• Self-protection measures
• Accident prevention methods and procedures 4

AP-SH-00 I Revision 5 4.0 RESPONSIBILITIES (CONT.) 4.3.6 Supervises Shipping Technicians shipping activities. 4.3.7 Ensures assigned personnel are qualified to perform the duties of a Shipping Technician including but not limited to the following:

               " Identify initial training and recurrent training needs

• Schedule and implement required training

               " Maintain documentation of completed training 4.3.8  Ensures all radionuclides are reported to the 9 5 th percentile in accordance with 49 CFR 173.433(g) - Shipping Papers And Labeling, at the time of shipment for ground shipments only.

4.3.9 Maintains an expertise in domestic and international regulations governing the shipping process. 4.3.10 Provides emergency response information concerning radioactivematerial shipments from MURR. 4.4 Shipping Technician: 4.4.1 Has multiple responsibilities for control of samples throughout the shipping process until finally released to the courier. 4.4.2 Reports all radionuclides to the 9 5 th percentile in accordance with 49 CFR 173. 4 33(g) at the time of the shipment for ground shipments only. 4.4.3 Performs the duties of a Shipping Technician (Shipper). This includes but is not limited to the following tasks:

• Handling radioactive materials
• Pre-assembling shipping containers
• Preparing shipping documents and associated shipping labels
• Properly packaging radioactivematerial for shipment 4.4.4 Ensures that radioactive material is shipped in accordance with approved procedures.

4.4.5 Ensures properly certified packages are used for shipment of radioactive material. 5

AP-SH-00 1 Revision 5 4.0 RESPONSIBILITIES (CONT.) 4.4.6 Performs work activities in accordance with approved procedures or as directed by Supervision. 4.4.7 Reviews existing procedures and programs for their effectiveness and revise as necessary. 4.4.8 NOTIFIES Supervisor of any problem or condition that could affect the safety of the facility, public or environment. 4.5 Irradiations Group: 4.5.1 Approves shipping activities for all non secondaryprocessedsamples. 4.5.2 Provides sample and consignee information, including isotope information required to be reported on the shipping paperwork for non-secondary processedsamples. 4.5.3 Calculates all radionuclides to the 9 5 th percentile in accordance with 49 CFR 173.433(g) at the time of the shipment for non-secondary processedsamples. 4.6 Secondary ProcessingGroups: (Analytical Chemistry, Research & Development Radioisotopes, etc.) 4.6.1 Approves all shipping activities for samples originating in their departments. 4.7 Associate Director, Product and Service Operations (PSO): 4.7.1 Provides technical and administrative support to the Shipping Group as required. 4.7.2 Ensures that information which is required for reporting on shipping paperwork is provided to the Shipping Technicians. 4.8 Associate Director, Regulatory Assurance Group (RAG): 4.8.1 Maintains the MURR Shipping Quality Assurance Program for Type B Shipping Casks, Approval No. 0108. 6

AP-SH-00 1 Revision 5 5.0 PROCEDURE 5.1 GENERAL GUIDELINES 5.1.1 All persons participating in the shipping process of irradiated samples shall:

a. Meet the qualifications of a Shipping Technician.

b. Maintain personnel exposures "As Low As Is Reasonably Achievable (ALARA)." Under normal conditions of work, exposures must not exceed levels specified in 10 CFR 20 - Standards For Protection Against Radiation (Reference 6.1).

c. Have familiarity with the regulations governing the shipment of hazardous materials. For the Shipping Group this will include:

the ability to recognize and identify Hazardous Materials shipped from MURR

• knowledge of specific requirements applicable to functions performed by the Shipping Technician
• knowledge of Emergency Response Information
• self-protection measures
• accident prevention methods and procedures 5.1.2 Consignees of MURR shipments of radioactive materials must be authorized to receive the type, form, and quantity of such material in accordance with provisions of 10 CFR 31 - General Domestic Licenses For Byproduct Material (Reference 6.1).

5.1.3 A package of radioactivematerialshall not be transported unless it is properly described, classed, marked, packaged and labeled in accordance with 49 CFR 173 - Shippers, General Requirements For Shipments And Packagingor the IATA Manual.

a. If the radioactivematerialexceeds any of the applicable limits of 10 CFR - Energy, 49 CFR - Transportation, or IATA Manual, then the Radioactive Materials/Shipping Manager or designee must be immediately notified.

b. Radioactive material cannot leave MURR until applicable limits of 10 CFR - Energy and 49 CFR - Transportation or IA TA Manual have been meet.

7

AP-SH-00 I Revision 5 5.0 PROCEDURE (CONT.) 5.1.4 The University of Missouri Research Reactor must use an approved Departmentof Transportation(DOT) carrier for transport of hazardous material requiring placarding in accordance with 49 CFR, Subpart A. 5.1.5 All beta-gamma dose rate survey, contamination counting or gamma radioisotope instrumentation used during the preparation and shipping process must have a current calibration sticker attached to the survey equipment or have verification that the instrument is calibrated. 5.1.6 Each container or cask used in the shipment of radioactive materialsshall conform to the appropriate regulations and specifications. 5.1.7 Non-fixed contamination on any external surface of any package shall be kept ALARA and under normal conditions of transport and must not exceed levels specified in:

• 49 CFR 173.441 - RadiationLevel Limits
• 49 CFR 173.443 - Contamination Control
• Applicable 1ATA Regulations 5.1.8 Radioactive materialshaving other hazardous characteristics shall be allocated Packing Groups I, II and III, as appropriate by application of the grouping criteria in accordance with:
• 49 CFR 172.202 - Description Of Hazardous Material On Shipping Papers 0 IATA, Dangerous Goods Regulations 5.1.9 The Performerof a shipping process and Inspector must not be the same individual. The Inspector must also be qualified to perform the assigned task.

5.1.10 The PrimaryHazard Label is used to identify the governing hazard for a package. Radioactivity is usually the governing hazard for packages shipped by MURR. 8

AP-SH-001 Revision 5 5.0 PROCEDURE (CONT.) 5.1.11 Radioactive materialshall be labeled in accordance with the following categories (Reference 49 CFR 172.403 - Class 7 Radioactive Material or IATA, Dangerous Goods Regulations):

a. White I: The maximum radiationlevel at any point on the external surface is 0.5 mrem/hr. The TransportIndex (TI) is zero.

b. Yellow II: The maximum radiationlevel on any point on the external surface is more than 0.5 mrem/hr but not more than 50 mrem/hr. The TI is more than zero (0) but not more than one (1).

c. Yellow III: The maximum radiationlevel at any point on the external surface is more than 50 mrem/hr, but not more than 200 mrem/hr. The TI is more than I but not more than 10.

d. Packages with contact dose rates greater than 200 mrem/hr or with a TI greater than 10, shall be shipped as an Exclusive Use Shipment.

NOTE: The following specific duties and responsibilities help to establish management's expectations regarding preparation of radioactive materials for use within MURR labs or shipment from MURR. 5.2 SPECIFIC DUTIES AND RESPONSIBILITIES 5.2.1 All personnel who are directly or indirectly involved in the shipping process must:

• maintain a safe work place at all times
• employ the concepts of time, distance and shielding to keep radiation exposure ALARA
• identify and correct procedural problems that could adversely affect the preparation of radioactivematerials for shipment from the MURR facility 9

AP-SH-001 Revision 5

6.0 REFERENCES

6.1 10 CFR, Energy

• 10 CFR 20 - Standards For Protection Against Radiation
• 10 CFR 31 - General Domestic Licenses For Byproduct Material
• 10 CFR 71 - Packagingand Transportation of Radioactive Material 6.2 InternationalAir TransportAssociation (IA TA) Dangerous Goods Regulations 6.3 49 CFR, Transportation 7.0 RECORDS None 8.0 ATTACHMENTS 8.1 Typical Shipping Flow Chart 8.2 List of Definitions 10

AP-SH-001 Revision 5 TYPICAL SHIPPING FLOW CHART The above flow chart is a simplified explanation of the shipping preparation process. Specific shipping tasks are detailed in appropriate procedures. Page I of I Attachment 8.1

AP-SH-00 1 Revision 5 LIST OF DEFINITIONS The following is a list of key words, terms or phrases that have a particular meaning to the Shipping Group. A table of A1 and A 2 values for radionuclides can be found in 49 CFR and the IATA Regulations.

1. Activity: The rate at which a material gives off radiation.

• A1 - The maximum activity of "Special Form" radioactive materialpermitted in a Type A package.
• A 2 - The maximum activity of "Normal Form" of radioactive materialpermitted in a Type A package.

2. Becquerel (Bq): The SI unit of activity and is defined as one (1) atomic transformation per second. The Becquerel is such a small unit that the larger multiple units are used in shipping.

The conversions are as follows:

• Kilobecquerel: 1 KBq = 103
• Megabecquerel: 1 MBq 106
• Gigabecquerel: 1 GBq = 10 9
• Terabecquerel: 1 TBq = 1012

3. Capsule: Aluminum secondary containment system for material run in the reactor region.

4. Code of FederalRegulations (CFR): Regulations published by the Federal Government.

The CFR contains TITLES (volumes) each of which is numbered and contains regulations pertaining to a specific subject, for example:

• 10 CFR, Energy
• 29 CFR, Labor
• 49 CFR, Departmentof Transportation

5. Concurrent Verification: Inspection and corroboration of performance of a step at time it is completed.

6. Consignees (receivers): A company/organization authorized to receive material shipped from MURR.

7. Department of Transportation(DOT): Designated United States authority on the transport of hazardous materials.

8. Emergency Call List (Shipping): A list maintained in the Emergency Response Notebook of individuals to be notified in case of a transportation incident involving packages prepared and shipped from MURR.

Page I of 6 Attachment 8.2

AP-SH-00 1 Revision 5 DEFINITIONS (CONT.)

9. Emergency Response Notebook: A Notebook provided to Operations by the Shipping Group that contains the following:

• Copy of the shipping documentation
• Copy of the Emergency Response Information Sheet
• A current copy of the Emergency Response Guidebook
• The Emergency Call List

10. Equivalent: A system, component, device or material that meets the design requirements for purpose and/or function of a specified system, component, device or material.

11. Excepted Packages: Limited quantities of radioactivematerials,instruments and articles, articles containing natural uranium, natural thorium or depleted uranium, and empty radioactive materialspackaging. These packages are exempted from certain labeling, marking and paper work requirements.

12. Experiment: Any device or material that is exposed to significant radiation from the reactor and is not a normal part of the reactor or any operation designed to measure or monitor reactor characteristics or parameters.

13. External Contamination: Is radioactive contamination on any external surface of any package. It must be kept as low as practical and, under normal conditions of transport, shall not exceed the levels specified in the governing regulations.

14. Fissile Material: Material consisting of Plutonium 239, Plutonium 241, Uranium 233, Uranium 235, or any combination of these radionuclides. This does not apply to unirradiated natural uranium and depleted Uranium, and natural uranium or depleted uranium that has been irradiated in a thermal reactor.

15. Host Can: A multi-carrier of capsules, which may be from:

• previously irradiated Host Cans
• stored material
• new Capsules(s)
• empty Spacer Capsules

16. Hot Cell: A sealed, shielded, and controlled area used to process radioactive materials.

17. Hot Laboratory: A controlled area to process radioactivematerials containing a hood which exhausts to the facility ventilation exhaust system and may contain a drain connection to the radioactive liquid waste and disposal system.

18. Incident: Events that may affect safety or that have resulted in non-compliance with regulations.

Page 2 of 6 Attachment 8.2

AP-SH-00 1 Revision 5 DEFINITIONS (CONT.)

19. Independent Verification: Inspection and corroboration that is separated by distance and time to insulate the verifier from the worker's performance and/or influence.

20. Inspector: See Shipping Technician.

21. InternationalAir TransportAssociation (IA TA) Dangerous Goods Regulations: Contains all of the requirements for the InternationalCivil Aviation Organization (ICAO) regulations, and has included additional requirements, which are more restrictive. This reflects the industry standard practices or operational considerations.

22. InternationalAtomic Energy Agency (IAEA): Develops guidance for the safe transport of radioactive materials.

23. InternationalCivil Aviation Organization(ICAO): Uses the 1AEA recommendations as the basis for developing the regulation for the safe transport of dangerous goods by air.

24. Low Specific Activity (LSA) Material: Material with limited specific activity, which satisfies specified descriptions and limits in applicable regulations.

25. Meter: Refers to instruments used in taking dose rate measurements.

26. Meter Stick: A ruler, one meter in length used to determine the transportindex.

27. MURR IdentificationNumber (MURR ID. No.): A unique number assigned to each radioisotope sample processed at MURR.

28. Must: A term equivalent to "SHALL" and is used to denote requirements imposed by MURR management which are above and in excess of and in addition to regulator requirements.

29. Non-fixed Radioactive Contamination: Contamination that can be readily removed from a surface by wiping with an absorbent material.

30. Normal Form Radioactive Material: Material, which has not been categorized nor qualified as "Special Form Radioactive Material."

31. Nuclear Regulatory Commission (NRC): The United States government agency established to regulate all the licensing and related regulatory functions of the nuclear industry.

32. Package: The packagingtogether with its radioactive contents as presented for transport.

33. Packaging: The assembly of components that make up a containment system for hazardous materials transport.

Page 3 of 6 Attachment 8.2

AP-SH-001 Revision 5 DEFINITIONS (CONT.)

34. Performer: See Shipping Technician

35. Primary Hazard: The governing hazard for a package.

36. Primary ProcessedSamples: Samples that have been under the continuous control of the Hot Cell and Shipping Groups after removal from the reactor pool. These samples are shipped without any further processes performed on them.

37 Quality Assurance (QA): Those actions related to control of the physical characteristics and quality of the material or component to predetermined requirements.

38. Quality Event: Operational problem, non-conformance, or conditions adverse to quality that, if not corrected, may lead to an incident.

39. Radioactive Contents: A radioactive material, together with any contaminated liquids or gases within the package.

40. Radioactive Material: DOT defines radioactivematerialas any material containing radionuclides where both the activity concentration and the total activity in the consignment exceed the values specified in the table 49 CFR 173.436 or values derived according to the instructions in 173.433. NRC defines as material (except special nuclear material) yielded in, or made radioactive by exposure to the radiation incident to the process of producing or utilizing special nuclear material.

41. RadiationLevel: The radiation dose-equivalent rate expressed in millirem(s) per hour or mrem/h.

42 Receivers: see Consignees

43. RUR: Reactor Utilization Request. A programmatic process that permits the reactor to be used for neutron irradiation and isotope production in accordance with the Hazard Summary Report. The RUR ensures that each experiment requested is reviewed to ascertain whether the experimenter possesses the experience and equipment to cope with the expected radiation level and whether the irradiated material may be safely used in the particular environment suggested by the experimenter. If the experiment is within acceptable limits of the reactor the Reactor Manager then approves it. (HSR 8.0)

44. Sample: The chemical or physical makeup of the target material or combination of target and encapsulation.

45. Secondary ProcessingGroups: Groups that submit samples for shipping other than Irradiations Group. Specifically: Analytical Chemistry, Research & Development Radioisotopes, Regulatory Assurance Group, Education and Research, Radiochemical Production and Silicon Group.

Page 4 of 6 Attachment 8.2

AP-SH-001 Revision 5 DEFINITIONS (CONT.)

46. Secondary ProcessedSamples: Samples submitted for shipment by groups other than Irradiations Group. These samples must utilize FM-27, "In-House Radioactive Shipping Request Form," to transmit sample information to the Shipping Group.

47. Shall: A term used to denote legally binding requirements to which MURR is committed, for example:

0 Technical Specifications (TS) S Hazards Summary Report (HSR) S Regulatory Guides 0 American National Standards Institute (ANSI) standards 0 Code of Federal or State Regulations

48. Shippingz Technician: Is defined as one of the following:

    " Trainee:             Can neither inspect nor perform a task except under the direct supervision of a Inspector or QA Inspector.

• Performer: An individual who has successfully completed the required training for specific tasks.

    " Inspector:           An individual who has successfully completed all required training in shipping tasks applicable to shipment of Type A or lower quantities of radioactive materials.

• QA Performer: An individual who has successfully completed the required training for specific tasks associated with the Type B shipping program.
• QA Inspector: An individual who has successfully completed all required training in all the shipping tasks applicable to shipment of Type B quantities of radioactivematerial under the MURR Quality Assurance Program for Type B containers.
• QA Supervisor: An individual designated in writing by the Associate Director (RAG) who is responsible for shipments within their assigned areas of byproduct material, waste, or spent fuel. Responsibility includes ensuring that personnel performing shipments under their assigned areas are trained and ensuring that shipment, procurement, inventory control, maintenance, testing, handling, and storage are conducted according to applicable procedures and in compliance with the MURR Type B QA Program.

49. Should: Not required, but would be highly desirable to accomplish.

50. SI: Units of measurement to be used in the transport of dangerous goods are those specified by the InternationalSystem (51).

51. Specific Activity: The activity of the radionuclide per unit mass of that nuclide.

Page 5 of 6 Attachment 8.2

AP-SH-00 1 Revision 5 DEFINITIONS (CONT.)

52. Surface ContaminatedObject (SCO): A solid object which is not itself radioactive but which has radioactivematerialdistributed on any of its surfaces.

53. Transfer Cask: Various sizes and configurations of shielded containers used to move radioactive samples from the reactor pool to predetermined handling areas.

54. TransportIndex (TI): The dimensionless number placed on the label ofapackage to designate the degree of control to be exercised by the carrier during transportation. TI is the dose rate number rounded up to the next tenth mRem/hr at 1 meter from the hottest side.

55. Type A Quantity: A quantity of radioactive materialwhich does not exceed A&, for Special form material, or A2 for normalform material.

56. Type B Quantity: A quantity of material, which is greater than Type A.

Page 6 of 6 Attachment 8.2

RP-H, 9-110 Revis ion 4 MURR MASTER COP y hUCA RADIATION PROTECTION ISSUED APR 18 2007 RP-HP-110 SURVEY AND DECONTAMINATION OF RETURNED SHIPPING CONTAINERS RESPONSIBLE GROUP: Reactor Health Physics PROCEDURE OWNER: Manuel Diaz APPROVED BY: Ronald J. Dobey, Jr..Date _____ This procedure contains the following: , Pages 1 through 7 Attachments None through Tables None through Figures None through Appendices None through Check-Off Lists None through

RP-HP-1 10 Revision 4 TABLE OF CONTENTS Section Page Number 1.0 PURPO SE ........................................................................................................................... 3 2.0 SCOPE ................................................................................................................................ 3 3.0 DEFIN ITION S .................................................................................................................... 3 4.0 PRECA UTION S AN D LIM ITATION S ........................................................................ 3 5.0 SPECIA L TOOLS OR EQ UIPM EN T .......................................................................... 4 6.0 PROCEDURE ..................................................................................................................... 4 6.1 DOT 6M CA SK ................................................................................................ 4 6.2 DOT 20 W C-1 / N ORD ION / CIS-U S ............................................................... 5 6.3 O THER CA SKS ............................................................................................... 7 7.0 REFEREN CES ................................................................................................................... 7 2

RP-HP-1 10 Revision 4 SURVEY AND DECONTAMINATION OF RETURNED SHIPPING CONTAINERS 1.0 PURPOSE 1.1 To establish a standard method for performing the decontaminationof returned shipping containers used for the shipment of radioactive materials. 2.0 SCOPE 2.1 Contains procedural steps and precautions necessary to decontaminate returned radioactive materials shipping containers. 2.2 Establishes methods used for the decontaminationof various types of containers. 2.3 Defines Reactor Health Physics interaction with Shipping Technicians to accomplish the process. 3.0 DEFINITIONS 3.1 Decontamination- The reduction or removal of contaminating radioactive material from a structure, area, object, or person. Decontamination may be accomplished by:

           " treating the surface to remove or decrease the contaminationand / or

• letting the material stand so that the radioactivity is decreased as a result of natural radioactive decay (Reference 7.1).

3.2 Contamination- Undesired radioactive material that is deposited on the surface or inside of structures, areas, objects or people (Reference 7.1). 4.0 PRECAUTIONS AND LIMITATIONS 4.1 Radiation work is only performed by persons informed about the work in compliance with 10 CFR 19.12 and ALARA concerns (Reference 7.2). 4.2 If any gross reading is greater than 25 mR / hr, the procedure must be stopped and the Reactor Heath Physics Manager must be notified. 3

RP-HP-I 10 Revision 4 5.0 SPECIAL TOOLS OR EQUIPMENT

• Applicable hand-held dose rate survey instrument

       " End window or pancake probe GM Frisker

• Masslin or soft absorbent paper towels
• Radioactive contamination marking tape
• Indelible marker
• Cotton tip swabs
• Preprinted, "Internal / External Contamination Survey" stickers
• Swipe Paper - normally 4.25 Whatman Qualitative Filter Paper
• Rubber gloves
• Applicable size zip-lock type plastic bag
• Radiac Wash or equivalent 6.0 PROCEDURE 6.1 DOT 6M CASK:

NOTE: The BC-4 Swipe Counter, located in the basement, is the preferable instrument for counting contamination swipes. However, any individual swipe that is greater than 1000 cpm on the GM Frisker must not be counted on the BC-4 swipe counter. i NOTE: All gross dose rate surveys are performed with an open window. ] CAUTION: If any gross reading is greater than 25 mR / hr, the procedure MUST be stopped and the Reactor Heath Physics Manager notified. 6.1.1 WHEN Shipping Technician has removed clamping ring securing the barrel lid, THEN MONITOR dose rate while technician removes lid. 6.1.2 WHEN technician has exposed the top of the DOT 2R container, THEN MONITOR while technician opens 2R container. 4

RP-HP-1 10 Revision 4 6.0 PROCEDURE (CONT.) 6.1.3 IF pig is present, THEN

a. remove pig from cask,

b. perform normal swipe of outside of pig, AND

c. IF swipe is greater than 220 dpm, THEN decontaminate AND re-swipe until less than 220 dpm.

6.1.4 MONITOR dose rate while technician opens pig. 6.1.5 Perform normal swipe of interior of 2R container. 6.1.6 IF swipe is greater than 220 dpm, THEN decontaminate AND re-swipe until less than 220 dpm. 6.1.7 Wipe inside of pig using a Masslin or moist paper towel. 6.1.8 IF wipe is greater than 1000 cpm (measured through a glove), THEN decontaminate AND re-wipe until less than 1000 cpm. 6.1.9 Wipe inside of pig using a Masslin or moist paper towel. 6.1.10 IF wipe is less than 1000 cpm (measured through a glove), THEN pig can be returned to service. 6.1.11 Fill out applicable information and initial "Internal / External Contamination" sticker AND place on cask. 6.2 DOT 20 WC-1 / NORDION / CIS-US: NOTE: The BC-4 Swipe Counter is the preferable instrument for counting contaminationswipes. However, any individual swipe that is greate than 1000 cpm on the GM Frisker must not be counted on the BC-4 swipe counter. NOTE: All gross dose rate surveys are performed with an open window. CAUTION: If any gross reading is greater than 25 mR / hr, the procedure MUST be stopped and the Reactor Heath Physics Manager notified. 5

RP-HP-I 10 Revision 4 6.0 PROCEDURE (CONT.) 6.2.1 WHEN Shipping Technician has removed nuts securing over-pack lid, THEN MONITOR dose rate while technician removes lid. 6.2.2 WHEN technician has removed fiberboard THEN perform gross internal survey. 6.2.3 Perform normal swipe survey on top exterior of DU container. 6.2.4 IF swipe is greater than 220 dpm, THEN decontaminate AND re-swipe until less than 220 dpm. 6.2.5 MONITOR dose rate while technician opens DU container. 6.2.6 Using caution, remove 2R, etc. container. 6.2.7 Perform normal swipe of outside of 2R container. 6.2.8 IF swipe is greater than 220 dpm, THEN decontaminateand re-swipe until less than 220 dpm. 6.2.9 MONITOR dose rate while technician opens 2R container. 6.2.10 Wipe interior of 2R container with a Masslin or moist paper towel. 6.2.11 IF wipe is greater than 1000 cpm (measured through a glove), THEN decontaminate again AND re-wipe until less than 1000 cpm. 6.2.12 WHEN wipe is less than 1000 cpm, THEN 2R container can be returned to service. 6.2.13 RECORD applicable information and initial "Internal / External Contamination" sticker AND place on shipping container. 6

RP-HP-I 10 Revision 4 6.0 PROCEDURE (CONT.) 6.3 OTHER CASKS: NOTE: The BC-4 Swipe Counter is the preferable instrument ýfor counting contaminationswipes. However, any individual swipe that is greater than 1000 cpm on the GM Frisker must not be counted on the BC-4 swipe counter. NOTE: All gross dose rate surveys are performed with an open window. CAUTION: If any gross reading is greater than 25 mR / hr, the procedure MUST be stopped and the Reactor Heath Physics Manager notified. 6.3.1 MONITOR dose rate while Shipping Technician opens outer package. 6.3.2 MONITOR dose rate while technician opens inner container. 6.3.3 Perform normal swipe of exterior of inner container. 6.3.4 IF swipe is greater than 220 dpm, THEN decontaminate AND re-swipe until less than 220 dpm. 6.3.5 Wipe interior of inner container with Masslin or moist paper towel. 6.3.6 IF wipe is greater than 1000 cpm (measured through a glove), THEN decontaminateagain AND re-wipe until less than 1000 cpm. 6.3.7 When wipe is less than 1000 cpm, THEN inner container can be returned to service. 6.3.8 RECORD applicable information and initial "Internal / External Contamination" sticker AND place on shipping container.

7.0 REFERENCES

7.1 Nuclear Regulatory Commission, "Glossary of Nuclear Terms" 7.2 10 CFR 19.12, "Instruction to Workers" 7

BPB-SH-002 Revision 7 I MURR

                                                                      ~TERftPý1       Z0q1 1~Iu~xl1~

SHIPPING PROCEDURE ISSt JED BPB-SH-002 20WC-1 PACKAGING AND SHIPMENT OF TYPE B NON-WASTE RADIOACTIVE MATERIAL RESPONSIBLE GROUP: Product & Service Operations, Shipping PROCEDURE OWNER: J. Mike Kilfoil APPROVED BY: Ronald J. Dobey, Jr. Date 6* ,P APPROVED BY: Kenneth W. Brooks Date g9 -1, -o(. This procedure contains the following: Pages 1 through 9 Attachments 1 through 1 Tables None through Figures None through Appendices None through Check-Off Lists None through

BPB-SH-002 Revision 7 I TABLE OF CONTENTS Section Page Number 1.0 PURPO SE ......................................................................................................................... 3 2.0 SCO PE ...............................................................................  :.............................................. 3 3.0 D EFIN ITION S.................................................................................................................. 3 4.0 RESPON SIBILITIES .................................................................................................. 3 5.0 PRECA UTION S AN D LIM ITA TION S ...................................................................... 4 6.0 PREREQUISITES AND INITIAL CONDITIONS .................................................... 4 7.0 SPECIA L TO O LS AN D EQ U IPM EN T ...................................................................... 5 8.0 PRO CEDURE ................................................................................................................... 6 9.0 REFEREN CES ......................................................................................................... 8 10.0 RECO RD S ........................................................................................................................ 9 11.0 ATTA CH M EN TS ....................................................................................................... .9 2

BPB-SH-002 Revision 7 20WC-1 PACKAGING AND SHIPMENT OF TYPE B NON-WASTE RADIOACTIVE MATERIAL 1.0 PURPOSE 1.1 Provide instructions for packagingType B (DOT 20WC-1) non-waste radioactive materials containers. 2.0 SCOPE 2.1 Procedural steps for final packagingof a depleted uranium (DU) container containing radioactivematerial in a 2R Shipping Container and 20WC- I Overpack Container. 2.2 This procedure ensures compliance with all applicable regulations prescribed in the following:

• 10 Code of FederalRegulations (CFR) 71, Energy (Reference 9. 1)
• 49 CFR, Transportation (Reference 9.2)
• InternationalAir TransportAssociation (IA TA) Dangerous Goods Regulations (Reference 9.3)
• MURR Type B QualityAssurance Program (Reference 9.5) 3.0 DEFINITIONS 3.1 Refer to AP-SH-001, "Administrative Procedure" (Reference 9.7) for list of definitions.

4.0 RESPONSIBILITIES 4.1 Refer to AP-SH-001, "Administrative Procedure" (Reference 9.7) for list of responsibilities. 3

BPB-SH-002 Revision 7 5.0 PRECAUTIONS AND LIMITATIONS 5.1 A package of radioactive materialshall not be transported unless it is properly described, classed, marked, packaged and labeled in accordance with 49 CFR 173 or the IATA Manual, and the MURR Type B Quality Assurance Program.

        "    If the radioactivematerial exceeds any of the applicable limits of 10 CFR, 49 CFR, or IATA Manual, then the Radioactive Materials/Shipping Manager or Designee must be immediately notified.

• Radioactive materialmust not leave MURR until the requirements of 10 CFR, 49 CFR, or L4TA Manual have been meet.

5.2 Survey instrumentation used during the performance of this procedure must have a valid "Calibration Current" sticker displayed. 5.3 The Performerof a shipping process and QA Inspector must not be the same individual. Additionally, the QA Inspector must be qualified as a Performer 6.0 PREREQUISITES AND INITIAL CONDITIONS 6.1 A person participating in any aspect of this procedure must meet the qualifications of a Shipping Technician as defined in AP-SH-001, "Administrative Procedure" (Reference 9.7). 6.2 Consignees (receivers) of MURR shipments of radioactive materialsare authorized to receive the type, form, and quantity of radioactive material in accordance with the provisions of 10 CFR 71 - Packagingand Transportation of Radioactive Material. 6.3 A QA Inspector must review the customer's Container/Cask and accompanying documentation prior to first use and ensure that the package is part of the MURR Type B QA Program. NOTE: Liquid shipments MUST be made using a 20WC-1 with an external 2R only. 6.4 For liquid shipments, ensure external 2R shipping container has been leak checked in accordance with procedure BPB-SH-001, "2R Shipping Container Leak Check" (Reference 9.4). 6.5 Torque wrench has a valid "Calibration Current" sticker. 4

BPB-SH-002 Revision 7 I 7.0 SPECIAL TOOLS AND EQUIPMENT 7.1 Tools

• 1-1/8 in. socket (External 2R Container Only)
• 12 in. drive socket extension or equivalent (1/2 in.)
• 5/8 in. deep well socket
• 3/4 in. deep well socket
• Manual ratchet
• Material handling equipment capable of lifting a minimum of 500 lbs.
• Pliers or crimping tool
• Rigid Flex-head handle, 1/2 in. drive (breaker bar)
• Speed handle
• Special 2R lid alignment tool (External 2R Container Only)
• Special 2R positioning rods (2 each) (External 2R Container Only) 0 Torque wrench (0 to 75 ft-lbs)
• Wire cutters 7.2 Equipment
• Absorbent wiping material
• Luting compound
• Contamination barrier material
• Personal protective equipment

        "     Radiation survey equipment

• Tamper-Proof Seals 5

BPB-SH-002 Revision 7 8.0 PROCEDURE NOTE: FM-35, "Control Checksheet for Type B USA DOT 20WC-1 Radioactive Materials Shipment" (Attachment 11.4) requires verification of specific actions in this section. FM-35 is written to be used as a stand-alone procedure for preparing 20WC-1 shipments. This procedure provides additional information to complete this process. 8.1 NOTIFY Reactor Health Physics (HP) to conduct radiological surveys during the assembly process. 8.2 ENSURE by visual inspection that the 2R shipping container cavity does not contain foreign material. CAUTION: The DU shield weighs approximately 200 lbs. Use appropriate material handling equipment when removing the DU shielding. 8.3 Attach material handling equipment to DU shield lifting eye. 8.4 HP Technician:

a. If not already performed, MONITOR radiationlevel on DU shield as it is lowered into the 2R Shipping Container.

b. Work at a safe distance to maintain exposures As Low As Is Reasonably Achievable (ALARA).

c. Follow facility guidelines for radiationlevel limits.

8.5 Working quickly to comply with ALARA, carefully lower DU into the wooden overpack. 8.6 Remove lifting device from the eye on the DU shield and move material handling equipment out of the immediate work area. 6

BPB-SH-002 Revision 7 8.0 PROCEDURE (CONT.) 8.7 ENSURE DU shield lid bolts are torqued to 15 ft-lbs. 8.8 ENSURE luting compound applied to 2R threads (if applicable). 8.8.1 For liquid shipments, torque the 2R lid to 75 ft-lbs. 8.9 Install 2R lid 8.10 Carefully, place 20WC-1 lid onto bottom portion of 20WC-1 over-pack.

a. Use care to align holes in 20WC-1 lid with all-thread rods.

b. Use alignment mark on bottom portion of 20WC-1 to aid with the proper alignment, if necessary.

NOTE: A gap between the top and bottom portions may indicate foreign material on the mating surface of the 20WC-1 overpack. 8.11 ENSURE 20WC-1 lid is properly seated and there are no gaps between top and bottom portions of over-pack. 8.12 ENSURE each all-thread rod has a flat washer and hex locknut, or equivalent locking device. 8.13 Using an alternating pattern, torque each nut on the 20WC-1 lid to 15 ft-lbs. Example: Typical torque pattern. 7

BPB-SH-002 Revision 7 8.0 PROCEDURE (CONT.) NOTE: A tamper-proof seal is required on any 20WC-1 shipping container containing radioactive material. Seals are optional on empty 20WC-1 shipping containers. 8.14 Place a tamper-proof seal on end of one all-thread rod. NOTE: All packages left in the staging area must have a radiation symbol and maximum contact dose rate clearly visible on the package. 8.15 ENSURE all previous shipping labels have been removed from the 20WC-1 surface.

a. PLACE package in final staging area awaiting courier pickup only after completion of shipping documentation and Final Package Checkout.

b. ENSURE work area is posted with appropriate radiation signs to warn other personnel.

8.16 Follow facility procedures and regulatory requirements to ship the 20WC-I.

9.0 REFERENCES

9.1 10 CFR 71, Energy 9.2 49 CFR, Transportation 9.3 InternationalAirTransportAssociation (IA TA) Dangerous Goods Regulations 9.4 BPB-SH-001, "2R Shipping Container Leak Check" 9.5 MURR Type B Quality Assurance Program 9.6 AP-SH-001, "Administrative Procedure" 9.7 DOT Package Specification 8

BPB-SH-002 Revision 7 10.0 RECORDS 10.1 FM-35, "Control Checksheet for Type B USA DOT 20WC-1 Radioactive Materials Shipment" 11.0 ATTACHMENTS 11.1 FM-35, "Control Checksheet for Type B USA DOT 20WC-I Radioactive Materials Shipment" 9

BPB-SH-002 Revision 7 FM-35 Revision 9 CONTROL CIIECKSHEET FOR TYPE B USA I)01" 21WC-1 RAI)IOAMTIVE MATERIAIS SHIPMENT Petrformer and 0.4 Inspectorcannot be the sante individuaL AII QA Supevi.sors, QA 1ns*petor and Pe;frrniers have the authority to stop unsatisfactory work in orderto comply 'withfederal regulationsand AfMR Shipping proceebtres. All items or components found to be in non'ofbirnianceby procedure,inspection, testing or operation are to be imnediately reportedto the appropriateShippingt QA Supe'viso?. Affix shipment preprinted identification label here. (Shipment Destination, Isotope(s). MURR Identification Number(s) and Activity) QA Inspector Performer Step (Initials) (Initigls No. Action/ Verification N/A . Pe nedk k test of itmer shipping container (fbr liquid shipments only). N/A............ .R., Dit -ollowing information: n r ontainer Serial Number: W)erpack mbe: N/A 3E IRE abNS ben male al is placed in DU Container. (For liquid shipments only) _() rac mple lo ation and Inner Cask sample informalion are correct and in t ng co* od a lied to In Shipping Container threads. C(ENSURE -el -ring' installed' Inner Shipping Container lid.

7. r ipping C ntai r gas'- c did ' (circle one)

                                              'atisf ton,                ac~

If repla d.u. te e app) inat u history-o! .r. (Proper gasket is identified in Technical Drawin . S8Sample rat q als i Qtdi oc

9. DU shield bo s r ed to 1 S. 'A libration quired)

10. 2R lid torqued to 7 fl-lb, 0W -1 ' ntain,, ith a R external to the DU).

(QA Calibration i ar.

11. 20WC-I Overpack lid s 1 1 (Ito 15 fi- . (QA all ra it* Required)

S12. Tamper-proof seal placet en ) one -thread ro

13. RlCORID 20WC-I 0\cerpack os ra s. ( r',r on R utired)

Face Plate

14. 20WC-1 Overpack is <6600 dpm/ 300 cm,2 3y & <660 dpm/ 0 cm 2

N!A

15. Con'ect shipping name and UN Number label (RADIOACTIVE M. 'ERIAL, TYPE B(U) PACKAGE UN2916) affixed on opposite sides of container.

(Include "RQ" before or after if applicable) N/A 16. Gross weight plainly and indelibly marked on outside of 20WC-I Overpack container. N/A 17. "TYPE B" is plainly and indelibly marked on outside of 20WC-1 Overpack container. N/A 18. "-REFOIL"is plainly and indelibly marked on outside of20WC-1 Oxverpack conlainer. N/A 19. Specification / certification is plainly and indelibly marked on outside of 20WC-1 Overpack container. Page 1 of 2 Page I of 2 Attachment 11.1

BPB-SH-002 Revision 7I "M -3 5 Revision 9 QA Inspetor Performer Step (IntiWi) (lnitials) No. ActionVerification

20. The inflormation for this shipment is recorded on FM-44, "MURR Request for Radioisotope Shipment."

a. License number, issuing agency and expiration date specified,

b. VERIFY that isotope and activity is approved per Precautions and Limitations of AP-SHI-001, "Radioactive Materials Shipping."

c. Shipping address is correct.

21- Emergency Response Inftrmation Sheet(s) are attached to the Shipper's Declarationi Straight Bill of Lading. N/A priate entries made in the Cask History Log. Ilabels verified, in place on opposite sides of the container and "r rate thilose list information measurements.from each label. must bte the shipper releasing the container.) TI:

24. The appi yvebeen placed adjacent to the primary

25. itification label agree and are affixedWaybill(s),

Shipment to package. a( beýsl~ N/A 26. Sodium Iodide Spectrum co led. N/A 27. Consignee notified of shipment prior to NiA 28. All steps in the procedure have been init ( Shipment approved for release by:____ QA Inspector Signatulrx/ -

• ate Package and paperwork reviewed flb accuracy by: _ __ _ -

Health Physics Signat u Date This package is category Yellow III and requires vehicle placards. (Circle ot Yes / No I accept this shipment, and if this shipment is Yellow I[[,I have been offered radioactive placards at the time the package was offered for transportation. Shipment accepted by:_ Courier Signature Date Page 2 of 2 Page 2 of 2 Attachment 11.1

MURR-SAS-00007 Service Applications QA/QC Program: USA DOT 7A Inner Cask SERVICE APPLICATIONS: QA/QC PROGRAM: USA DOT 20WC-1 1.0 PURPOSE AND SCOPE The purpose of this QA/QC Procedure is to ensure that the purchasing, testing, use, repair, handling, shipping, storing, inspection, and maintenance of USA DOT 20WC-1 shipping container complies with IOCFR7 1. 2.0 PRECAUTIONS AND LIMITATIONS Refer to Service Applications Departmental Administrative-Shipping Procedure, MURR-SAS-00. 3.0 MATERIALS AND EQUIPMENT NOTE. All maintenance materials and supplies shall be stored in a specified locked Quality Control location and designated as such. Access to this location shall be restricted to approved individuals. 3.1 DOT 7A Inner Cask 3.1.1 DOT 7A Inner Cask Lid Gasket. 3.1.2 Reference Drawing MURR # 1294. 3.1.3 DOT 7A Inner Cask Lid Hold Down Bolts. 4.0 DEFINITIONS Refer to Service Applications Departmental Administrative-Shipping Procedure, MURR-SAS-00. 5.0 RESPONSIBILITIES Refer to Service Applications Departmental Administrative-Shipping Procedure, MURR-SAS-00. 6.0 QC CONTROL PROGRAM FOR DOT 7A INNER CASK 6.1 QC for DOT 7A Inner Cask Lid Gasket 6.1.1 Per Quality Assurance Plan: All Procurement Documents must contain the following statement: The University of Missouri has the right of access to the Suppliers' Facilities and Records for Source Inspection and Audit. Rev. 0_2 SA. RM Z Date: 04 April 1997 MURR-SAS-00007 paige 2 of 4' CONTROL CHECK SHEET USE PROCEDURE

Service Applications QA/QC Program: USAS DOT 7A Inner cask MURR-SAS-00007 6.1.2 To order a DOT 7A Inner Cask Lid Gasket, prepare the Purchase Order with the following specifications:

• Material: Neoprene.

               - Thickness: 1/8 inch.
               - 60/70 Shore Duromiter.
               - Include along with the Purchase Order, MURR reference Drawing number 1294 for dimensions.

6.1.3 The Control Lot Number for tracking purposes shall be the purchase order number followed by a dash and the year (e.g., C12345-95). 6.1.4 Initiate and maintain a QC Packet containing a copy of the purchase order indicating the Control Lot Number. 6.1.5 Upon receipt of the ordered gasket(s), perform an Acceptance Inspection using the Quality Control Inspection for DOT 7A Inner Cask Lid Gasket (Attachment 1). 6.1.6 Perform the Acceptance Criteria; Steps 1 through 4. 6.1.7 Sign and Date; Indicating the Acceptance Criteria is true. 6.1.8 Upon acceptance of the gasket(s), complete the QC Document; Top Portion of Attachment 1, by inserting the following data:

• Control Lot #,

              - Accepted by,
              - Date.

6.1.9 Fold the QC'Document (Attachment 1) as indicated by the fold lines so that the data of Step 6.1.8 is clearly visible; place a copy of the QC Document into a poly bag along with each of the accepted gasket(s). 6.1.10 Heat seal the poly bag and store in the approved QC Storage location. 6.1.11 Rejected gaskets must be discarded or returned to the manufacturer at the discretion of the Service Applications-Section Leader. 6.1.12 Upon completion of the gasket task, record the gasket change out in the Cask Log Book. 6.1.1 3 Place the Gasket QC Sheet into the Shipment Folder. 6.2 QC for DOT 7A Inner Cask Lid Hold Down Bolt 6.2.1 Per Quality Assurance Plan; All procurement documents must contain the following statement: The University of Missouri has the right of access to the suppliers'facilitiesand recordsfor Source Inspection and Audit. Rev. 02 SA J RM \WC!ý Datc: 04 April 1997 MURR-SAS-00007 page 3 of/X' CONTROL CHECK SHEET USE PROCEDURE

MURR-SAS-00007 Service Applications QA/QC Program: USA DOT 7A Inner Cask 6.2.2 To order DOT 7A Inner Cask Lid Hold Down Bolts, prepare the Purchase Order with the following specifications:

• Grade 8 or 8A 304 Stainless Steel,
• 3/8 inch by 16 bolt,

                 *1/2 inch to I inch length.

6.2.3 The Control Lot Number for tracking purposes shall be the purchase order number followed by a dash and the year (e.g., C 12345-95); 6.2.4 Initiate and maintain a QC Packet containing a copy of the purchase order indicating the Control Lot Number. 6.2.5 Upon receipt of the ordered bolt(s), perform an Acceptance Inspection using the Quality Control Inspection for DOT 7A Inner Cask Lid Hold Down Bolt (Attachment 2). 6.2.6 Perform the Acceptance Criteria; Steps I through 3. 6.2.7 Sign and Date; Indicating the Acceptance Criteria is true. 6.2.8 Upon acceptance of the bolt(s), complete the QC Document; Top portion of Attachment 2, by inserting the following data:

                - Control Lot #,
                - Accepted by,
                , Date.

6.2.9 Fold the QC Document (Attachment 2) as indicated by the fold lines so that the data of Step 6.2.8 is clearly visible; place a copy of the QC Document into a poly bag along with the accepted bolts. 6.2.10 Heat seal the poly bag and store in the approved QC Storage location. 6.2.11 Upon completion of the task, record the change out in the Cask Log Book. 6.2.12 Forward the QC Sheet to the QA Supervisor for filing in the appropriate cask file. 6.2.13 Rejected bolts must be discarded or returned to the manufacturer at the discretion of the Service Applications-Section Leader. ATTACHMENTS A. Quality Control Inspection: Control Check Sheet for DOT 7A Inner Cask Lid Gasket (Attachment 1). B. Quality Control Inspection: Control Check Sheet for DOT 7A Inner Cask Hold Down Bolt (Attachment 2). Rev. 02 SA...*L RM \ Date: 04 April 1997 MURR-SAS-00007 page 4 of X5S CONTROL CHECK SHEET USE PROCEDURE

MURR-SAS-00007 Service Applications QA/QC Program: USA DOT 7A Inner Cask REFERENCES

                *... 0-. .. . ..
               -0

. i A.- 10CFR71. B. .. ANSI No. N323-1978. C. SA-QA-Jo. 4 Rev. 0_2 SA . RM________ Date: 04 April 1997 MURR-SAS-00007 page5 of/5 CONTROL CHECK SHEET USE PROCEDURE

0 QUALITY CONTROL INSPECTION: CONTROL CHECK SHEET FOR DOT 7A INNER CASK LID GASKET Acceptance Criteria:

1. You are an Approved Inspector for this procedure.

2. Verified: Gasket material is black neoprene by reference to Shipping Documents and visual inspection.

3. Verified: Gasket contains no cracks or cuts.

4. Verified: Gasket size and thickness meets specifications of MURR Drawing number 1294.

All the above Acceptance Criteria is true:

                                                           /

Signature/Date FOLD LINE QC CONTROLLED PART: DOT 7A INNER CASK LID GASKET I F Control Lot # 0 1 L D L Accepted by: II N E Date: Rev. 00 SA AVY RM \M"' Date: 04 April 1997 MURR-SAS-00007 Attachment 1. CONTROL CHECK SHEET USE PROCEDURE

QUALITY CONTROL INSPECTION: CONTROL CHECK SHEET FOR DOT 7A INNER CASK LID HOLD DOWN BOLT Acceptance Criteria:

1. You are an Approved Inspector for this procedure.

2. Verified: Bolt material is Grade 8 or 8A Stainless Steel by reference to Shipping Documents and visual inspection.

3. Verified: Bolt is 3/8 by 16; 1/2 inch to 1 inch length.

All the above Acceptance Criteria is true:

                                                          /

Signature/Date FOLD LINE QC CONTROLLED PART: DOT 7A INNER CASK LID HOLD DOWN BOLT. IF Control Lot # 0 1 L D L Accepted by: II N IE Date: Rev. 00 SA RM W'%*Date: 04 April 1997 MURR-SAS-00007 Attachment 2. CONTROL CHECK SHEET USE PROCEDURE

BPB-SH-005 Revision 5 MURR MASTER COPY ISSUED flFC 0 7-M07 WAXPW SHIPPING PROCEDURE BPB-SH-005 DOT 6M PACKAGING OF TYPE B NON-WASTE RADIOACTIVE MATERIAL RESPONSIBLE GROUP: Product & Service Operations, Shipping PROCEDURE OWNER: J. Mike Kilfoil APPROVED BY: Ronald J. Dobey, Jr /*/ 4 ate /2-APPROVED BY: Kenneth W. Brooks. Date ,---' This procedure contains the following: Pages 1 through 6 Attachments 1 through 1 Tables None through Figures None through Appendices None through Check-Off Lists None through

BPB-SH-005 Revision 5 I TABLE OF CONTENTS Section Page Number 1.0 PURPO SE ........................................................................................................................... 3 2.0 SCOPE ................................................................................................................................ 3 3.0 DEFIN ITION S .................................................................................................................... 3 4.0 RESPON SIBILITIES .................................................................................................... 3 5.0 PRECAUTION S AN D LIM ITATION S........................................................................ 3 6.0 PREREQ U ISITES AND IN ITIA L CON DITION S....................................................... 4 7.0 SPECIA L TOOLS OR EQU IPM EN T ................................................................................ 4 8.0 PROCED URE ..................................................................................................................... 5 9.0 REFEREN CES ................................................................................................................... 6 10.0 RECO RD S .......................................................................................................................... 6 11.0 ATTACHM ENTS ........................................................................................................ 6 2

BPB-SH-005 Revision 5 DOT 6M PACKAGING OF TYPE B NON-WASTE RADIOACTIVE MATERIAL 1.0 PURPOSE 1.1 Provide instructions for packaging of USA DOT 6M Type B non-waste radioactivematerials containers. 2.0 SCOPE 2.1 Procedural steps for the final packaging of the DOT 6M container. 2.2 This procedure ensures compliance with all applicable regulations, including:

• 10 Code of FederalRegulations (CFR) .71, Energy (Reference 9.1)
• 49 CFR, Transportation (Reference 9.2)
• InternationalAir TransportAssociation (IA TA) Dangerous Goods Regulations (Reference 9.3)
• MURR Type B Quality Assurance (QA) Program (Reference 9.4) 3.0 DEFINITIONS 3.1 Refer to AP-SH-001, "Administrative Procedure" (Reference 9.6) for list of definitions.

4.0 RESPONSIBILITIES 4.1 Refer to AP-SH-001, "Administrative Procedure" (Reference 9.6) for list of definitions. 5.0 PRECAUTIONS AND LIMITATIONS 5.1 A package of radioactive materialshall not be transported unless it is properly described, classed, marked and labeled in accordance with 49 CFR 173 or the JATA Manual, and the MURR Type B QA Program.

          "     If the radioactive materialpackageexceeds any of the applicable limits of 10 CFR, 49 CFR, or IATA Manual, then the Manager of Radioactive MaterialsShipping or Designee must be immediately notified.

• Radioactive materialmust not leave MURR until the requirements of 10 CFR, 49 CFR, or IA TA manual have been met.

5.2 Survey instrumentation used during the performance of this procedure must have a valid "Calibration Current" sticker displayed. 3

BPB-SH-005 Revision 5 5.0 PRECAUTIONS AND LIMITATIONS (CONT.) 5.3 The Performerof a shipping process and the QA Inspector must not be the same individual. Additionally, the QA Inspector must be qualified as a Performer. 6.0 PREREQUISITES AND INITIAL CONDITIONS 6.1 A person participating in any aspect of this procedure must meet the qualifications of a Shipping Technician as defined in AP-SH-001, "Administrative Procedure" (Reference 9.6). 6.2 Consignees (receivers) of MURR shipments of radioactive materials are authorized to receive the type, form, and quantity of radioactive material in accordance with the provisions of 10 CFR 71, Packagingand Transportation of Radioactive Material. 6.3 A QA Inspector must review the customer's container and accompanying documentation prior to first use and ensure that the package is part of the MURR Type B QA Program. 6.4 Cask has been prepared in accordance with RP-HP-1 10, "Survey and Decontamination of Returned Shipping Containers" (Reference 9.5). 6.5 ENSURE all previous shipping labels have been removed from the surface of the container. 7.0 SPECIAL TOOLS OR EQUIPMENT 7.1 Tools 0 Speed wrench

• 15/16" Socket 7.2 Equipment

        "   Luting compound
        "   Personal protective equipment
        "   Radiation survey equipment
        "   Tamper proof seal 4

BPB-SH-005 Revision 5 I 8.0 PROCEDURE NOTE: FM-74, "Control Checksheet for Type B USA DOT 6M Radioactive MaterialsShipment" (Attachment 11.1) requires verification of specific actions in this section. FM-74 is written to be used as a stand alone procedure for preparing DOT 6M shipments. This procedure provides additional information to complete this process. 8.1 ENSURE 2R cavity does not contain foreign material. 8.2 ENSURE luting compound applied to 2R threads. 8.3 NOTIFY Reactor Health Physics to conduct radiological surveys on inner shipping container prior to its loading into the 2R. 8.4 Working quickly to comply with ALARA, carefully lower inner shipping container into 2R. 8.5 Secure screw top lid onto 2R. 8.6 ENSURE centering media is in place. NOTE: If the closure ring does not sit snugly against the lid then tap the closure ring with a nonmetallic hammer until tight. 8.7 Secure lid with closure ring. 8.8 Place a tamper proof seal around locking bolt. NOTE: All packages left in the staging area must have a radiation symbol and a maximum contact dose rate clearly visible on the package. 8.9 Placepackage in final staging area awaiting courier pickup only after completion of shipping documentation and final package checkout. 8.10 ENSURE work area is posted with appropriate radiation signs to warn other personnel. 8.11 Follow facility procedures and regulatory requirements to ship the DOT 6M. 5

BPB-SH-005 Revision 5 I

9.0 REFERENCES

9.1 10 CFR 71, Energy 9.2 49 CFR, Transportation 9.3 International Air Transport Association (IATA) Dangerous Goods Regulations 9.4 MURR Type B QualityAssurance Program 9.5 RP-HP-1 10, "Survey and Decontamination of Returned Shipping Containers" 9.6 AP-SH-001, "Administrative Procedure" 9.7 DOT Package Specification 10.0 RECORDS 10.1 FM-74, "Control Checksheet for Type B USA DOT 6M Radioactive Materials Shipment" 11.0 ATTACHMENTS 11.1 FM-74, "Control Checksheet for Type B USA DOT 6M Radioactive Materials Shipment" 6

BPB-SH-005 Revision 5 FM-74 Revision 9 CONTROL Clt(CKSIEET FOR T UPE DoTr 6M I USA RAI)IOA(ITrIVE MATERIALS SHIPMENT l'e..form~er a QA In.pector canot be ihe .some indlividua4 All QA Super'isois, QA Inspectorsand J'erfonners have the authoriy to stop tnsautis/iwtor, work in order to comply ',ithftcdral regulationsandMUtRR Shipping procednrox All items or components[bund to be in nonconfformance by poevedrn,, inspection, testing or operationare to be imnnwdiately reported to the appropriateSihipping QA Supervi.)r. Affix shipment preprinted identification label here. (Shipment Deitination, Isotope(s), MWRR Identification Number(s) and Activity) Inspector Pdrformcr Step (Initials fl No

                         ,.e--.                                           Action / Verification rd Container Serial Number:

N/A_ -shield identified per I-IC-PSO-002, "Hot Cell.Preparation of Radioactive Material for inunl."

                                          =i,      Iinformation e              and inner shield label agree.

(n%.~am.,oun~l atmtIid to 21 Container threads. 7. 8.

9. Security sea] in place. -"-,

10. Record highest dose rate and I Required)

Side,______ TI* 2 N!A 11. DOT 6M is <6600 dpw/ 300 cm t O & <660 dpm/ 300 cmz C.

12. Correct shipping name and UIN Number label (RADIOACTIVE MATERIAL, TYPE B(IJ) PACKAGE UN2916) affixed on opposite sides of container.

(Include "RQ" before or after if applicable) My!A 13. "TYPE B" is plainly and indelibly marked on outside ofcontainer. N/A_ 14. "TREFOIL." is plainly and indelibly marked on outside ofcontainer. N/A 15. Specification / certification is plainly and indelibly marked on outside of DOT 6M conlainer. N"'A 16. All appropriate entries made in the cask history log. N.1A 17. Place package in staging area prior to completion of BP-SH1-052. (Attached to Procedure: BPH-SH-X)5) Page 1 of 1 Page 1 of I FM-74 Attachment 11.1

Appendix B Specification Sheets for the SAFKEG-LS and SAFKEG-HS Type B Multi-Radioisotope Package Designs MURR Packaging Extension Request M August 2008

Package Design No 3979A Package Name - Safkeg-LS CROFT Package Type Re-usable Type B package for the shipment of solid and liquid radioactive materials. Certification The Safkeg-LS package is being certified by the USNRC as a B(U) Package - the package meets all the requirements of 1 OCFR71 and the IAEA Regulations for the Safe Transport of Radioactive Material, TS-R-I. Description The Safkeg-LS package is designed to be robust and simple to use. The package consists of a stainless steel outer keg which carries a stainless steel and lead shielding pot within cork packing. The outer keg is fabricated in stainless steel and having a flange type lid fastened by studs and nuts. The shielding pot is a lead filled vessel having a fabricated stainless steel shell and cavity walls and having a flange type lid fitted with double O-ring seals and fastened by screws. Containment The containment system is the shielding pot with the containment being provided by the welded stainless cavity walls and the flange closure fitted with double O-ring seals. The pot lid is provided with a test point for leakage testing the containment system in accordance with ANSI N14.5.

KEG Approved Contents The contents are solid or liquid radioactive materials carried in suitable primary containers to prevent contamination of the shielding pot. The shielding pot may be fitted with additional shielding where required. The radioactive contents are limited by the shielding and contents maximum heat output of 15 W. Physical Data _ Safkeg-LS Package Outer Keg Inner Cork Packing Inner Shielding Pot External Diameter 16.69" 424 mm 6.89" 175 mm External Height 19.45" 494 mm 7.99" 203 mm Internal Diameter 9.68" 246 mm 2.54" 64.5 mm Internal Height 11.26" 286 mm 4.29" 109 mm Tare Weight 77.3 lb 35.1 kg 8.6 lb 3.9 kg 47.6 lb 21.6 kg (May 08] Weight of empty package - 134 lb (61 kg). Maximum weight of Safkeg-LS package (including contents) - 149 lb (68 kg). Further Information Contact: Don Edling dedling*cinsightbb.com Telephone: 502-896-8597 Bob Vaughan bob.vaughancacroftltd.com Telephone: +44 1865 407740 Croft Associates Ltd, F4 Culham Science Centre, Abingdon, Oxon, OX14 3DB, UK Tel: (01865) 407740 Fax: (01865) 407449 E-mail: salespcroftltd.com Web site: www.croftltd.com

                                        \\Terastation\Docs-Approve\DATA Sheets\3979\3979A-Safkeg-LS-Data Sheet-May 2008.wpd

Package Design No 3977A Package Name - Safkeg-HS CROFT Package Type Re-usable Type B package for the shipment of solid and liquid radioactive materials. Certification The Safkeg-HS package is being certified by the USNRC as a B(U) Package - the package meets all the requirements of 10CFR71 and the IAEA Regulations for the Safe Transport of Radioactive Material, TS-R-1. Description The Safkeg-HS package is designed to be robust and'simple to use. The package consists of a stainless steel outer keg which carries a stainless steel and DU shielding pot within cork packing. The outer keg is fabricated in stainless steel and having a flange type lid fastened by studs and nuts. The shielding pot is a DU filled vessel having afabricated stainless steel shell and cavity walls and having a flange type lid fitted with double O-ring seals and fastened by screws. Containment The containment system is the shielding pot with the containment being provided by the welded stainless cavity walls and the flange closure fitted with double O-ring seals. The pot lid is provided with a test point for leakage testing the containment system in accordance with ANSI N14.5.

KEG Approved Contents I i574c The contents are solid or liquid radioactive materials carried in suitable primary containers to prevent contamination of the shielding pot. The shielding pot may be fitted with additional shielding where required. The radioactive contents are limited by the shielding and contents maximum heat output of 15W. Physical Data Safkeg-HS Package Oute Keg Inner Cork Packing Inner Shielding Pot External Diameter 16.69" 424 mm 7.87" 200 mm External Height 23.03" 585 mm 11.85" 301 mm Internal Diameter 9.68" 246 mm 2.71" 68.9 mm Internal Height 14.76" 375 mm 6.12" 155.5 mm Tare Weight 90 lb 40.9 kg 8.6 lb 3.9 kg 234.3 lb 106.5 kg IMay 081 Weight of empty package - 333 lb (152 kg). Maximum weight of Safkeg-HS package (including contents) - 356 lb (162 kg). Further Information Contact: Don Edling dedlingq'insightbb.com Telephone: 502-896-8597 Bob Vaughan bob.vaughan@croftltd.com Telephone: +44 1865 407740 Croft Associates Ltd, F4 Culham Science Centre, Abingdon, Oxon, OX14 3DB, UK Tel: (01865) 407740 Fax: (01865) 407449 E-mail: sales@croftltd.com Web site: www.croftltd.com

                                       \\Terastation\Docs-Approve\DATA Sheets\3977\3977A-Safkeg-HS-Data Sheet-May 2008.wpd

Appendix C Project Plan and Timeline for MURR Type B Package Replacement Project Croft Associates, Ltd. WMI MURR Packaging Extension Request Xx August 2008

ID 10 ]Task Name I Duration Start Finish Predecessors 6/18 Jul6 1 Design review and optimization 43 days Mon 9/3/071 Wed 10/31/07 2 IM Stage 1 43 days Mon 9/3/07 Wed 10/31/07 3 Keg prototype 194 days Thu 1111/07 Tue 7/29/08 4 Prototype manufacture 69 days Thu 11/1/07 Tue 2/5/08 5 [] Keg prototype manufacture 69 days Thu 11/1/07 Tue 2/5/08 2 6 Testing 110 days Wed 2/27/08 Tue 7/29/085 7 in Keg prototype 9m drop tests #1, 2 & 3 at normal temps 1 day Wed 2/27/08 Wed 2/27/08 8 5. Keg prototype 9m drop test #4 at -40C with accel 1 day Wed 5/28/08 Wed 5/28/08 7 9 [ Keg prototype 1.2m & 9m drop test #5 & 6 at -40C with accel 2 days Mon 7/14/08 Tue 7/15/08 8 10 Compile test report 10 days Wed 7/16/08 Tue 7/29/08 9 11 Contents definition for LS & HS 226 days Mon 913107 Mon 7/14/08 12 [ Data collection 100 days Mon 9/3/07 Fri 1/18/08 13 [ Report CTN 2008/01 Issue A 30 days Mon 1/28/08 Sat 3/8/08 14 14 Determination of insert dimensions 10 days , Mon 9/3/07 Fri 9/14/07 15 L3 Report CTN 2008/01 Issue B 50 days Mon 3/17/08 Fri 5/23/08 16 Revised iinsert dimensions 10 days Mon 5/26/08 Fri 6/6/08 15 17 [ Report CTN 2008/01 Issue C 20 days Tue 6/17/08 Mon 7/14/08 16 18 Tungsten inserts for LS and HS 51 days Mon 6123108 Mon 9/1/08 19 i] Complete outline drawings 10 days Mon 6/23/08 Fri 7/4/08 16 20 Complete manufacturing drawings 20 days Mon 7/7/08 Fri 8/1/08 19 21 [ Manufacture prototypes 20 days Tue 8/5/08 Mon 9/1/08 20 22 SAFKEG LS 622 days Mon 9/3/07 Tue 1/19/10 23 [] Complete maufacturing drawings 77 days Thu 2/14/08 Fri 5/30/08 2 24 [] Compile manufacturing specs 21 days Mon 6/2/08 Mon 6/30/08 23 25 LS Prototype manufacture 65 days Mon 6/2/08 Fri 8/29/08 26 Prototype manufacture 65 days Mon 6/2/08 Fri 8/29/08 23 27 Analysis 96 days Mon 7/14108 Mon 11/24/08 28 [] Stress analysis - final for SARP 30 days Mon 7/14/08 Fri 8/22/08 23 29 [ Shielding analysis - final for SARP 30 days Mon 7/14/08 Fri 8/22/08 23 30 Thermal analysis - final for SARP 30 days Tue 10/14/08 Mon 11/24/08 33 31 Testing 30 days Tue 9/2/08 Mon 10/13/08 32 LS steady state thermal test 15 days Tue 9/2/08 Mon 9/22/08 26,10,21 33 LS NCT & HAC drop tests + 800C thermal test 15 days Tue 9/23/08 Mon 10/13/08 32 34 35 LS SARP compilation 406 days Mon 9/3/07 Mon 3/23/09 36 17 Generating data for the SARP 140 days Mon 9/3/07 Fri 3/14/08 37 Drafting SARP Chapters 65 days Mon 8/25/08 Fri 11/21/08 28,29,36,17 38 Add test data to SARP 10 days Mon 11/24/08 Fri 12/5/08 37,33 39 Add thermal calc results to SARP 10 days Mon 12/8/08 Fri 12/19/08 30,38 40 SARP supporting docs + add to SARP 30 days Mon 12/22/08 Fri 1/30/09 39 41 Assemble complete SARP 10 days Mon 2/2/09 Fri 2/13/09 40 42 Croft review of complete SARP 15 days Mon 2/16/09 Fri 3/6/09 41 43 MURR review of complete SARP 15 days Mon 2/16/09 Fri 3/6/09 41 44 Final revisions 10 days Mon 3/9/09 Fri 3/20/09 43 45 Submission of SARP to NRC at Rev 0 1 day Mon 3/23/09 Mon 3/23/09 44 46 LS SARP review by the NRC and update 216 days Tue 3/24109 Tue 1/19/10 47 NRC-1 st review and issue of RFI 100 days Tue 3/24/09 Mon 8/10/09 45 48 Croft response to RFI 35 days Tue 8/11/09 Mon 9/28/09 47 49 NRC-2nd review and issue of RFI 40 days Tue 9/29/09 Mon 11/23/0948 50 Croft response to RFI 20 days Tue 11/24/09 Mon 12/21/09 49 51 NRC-Compile SER & CoC 20 days Tue 12/22/09 Mon 1/18/10 50 52 NRC-Issue of CoC 1 day Tue 1/19/10 Tue 1/19/10 51 53 SAFKEG HS 657 days Mon 9/3/07 Tue 3/9/10 54 [ Complete maufacturing drawings 152 days Thu 11/1/07 Fri 5/30/08 2 55 Compile manufacturing specs 21 days Mon 6/2/08 Mon 6/30/08 54 56 HS prototype 140 days Mon 6/2/08 Fri 12/12/08 57 E3 DU procurement 110 days Mon 6/2/08 Fri 10/31/08 54 58 E] Prototype manufacture - parts 65 days Tue 7/1/08 Mon 9/29/08 55,61,63 59 Prototype manufacture - assembly 30 days Mon 11/3/08 Fri 12/12/08 57,58 60 Analysis 338 days Wed 11121/07 Fri 3/6/09 61 [] Preliminary Stress analysis 129 days Wed 11/21/07 Mon 5/19/08 62 [ Stress analysis - final for SARP 30 days Mon 7/14/08 Fri 8/22/08 2,8,61 63 [ Preliminary Shielding analysis 60 days Wed 11/21/07 Tue 2/12/08 64 [ Shielding analysis - final for SARP 30 days Mon 7/14/08 Fri 8/22/08 2,14,63 65 [ Thermal analysis - final for SARP 30 days Mon 1/26/09 Fri 3/6/09 67,68 66 Testing 30 days Mon 12/15/08 Fri 1/23/09 67 HS steady state thermal test 15 days Mon 12/15/08 Fri 1/2/09 59,10,21 68 HS NCT & HAC drop tests + 800C thermal test 15 days Mon 1/5/09 Fri 1/23/09 67 69 HS SARP compilation 441 days Mon 9/3/07 Mon 5/11109 70 [ Generating data for the SARP 247 days Mon 9/3/07 Tue 8/12/08 71 [ Drafting SARP Chapters 65 days Mon 8/25/08 Fri 11/21/08 62,64,13,70 72 [ Add test data to SARP 10 days Mon 1/5/09 Fri 1/16/09 67,71 73 [ Add thermal calc results to SARP 10 days Mon 3/9/09 Fri 3/20/09 72,65 74 [ SARP supporting docs + add to SARP 30 days Mon 11/24/08 Fri 1/2/09 71 75 Assemble complete SARP 10 days Mon 3/23/09 Fri 4/3/09 74,73 76 [ Croft review of complete SARP 15 days Mon 4/6/09 Fri 4/24/09 75 77 MURR review of complete SARP 15 days Mon 4/6/09 Fri 4/24/09 75 78 [ Final revisions 10 days Mon 4/27/09 Fri 5/8/09 77,76 79 Submission of SARP to NRC at Rev 0 1 day Mon 5/11/09 Mon 5/11/09 78 80 HS SARP review by the NRC and update 216 days Tue 5/12/09 Tue 3/9110 81 [ NRC-1 st review and issue of RFI 100 days Tue 5/12/09 Mon 9/28/09 79 82 Croft response to RFI 35 days Tue 9/29109 Mon 111/16/09J81

IJanuary I Apri 10/22 12/3 1/14 2/25 4/7 5/19

                              - - - -- - - - - -- - - - - - -- - .- --..- - - - - -- - - - - -- - - - - -- --                                                                                             . . .    . . ..          . .- .- --. .- .- .-
                                                                                                                                                                                                                                                     - --- - .- .- - .--. .- - .- .- .---.. . . .--... .. . .       . ..    . .. .      . . .   .. . .    . ..
               ..............-                                                                            I----------.                                                 - ----- ---                               ........
                                                                                                                                                                                                                   -------                 . ....  ---      -----........................................-                                                       -

2/27 0 1197 5/288r8

        .... .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . -- - - -------------..                                           11/18 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .-                                                             -- . . . . . . . . . . . . 5. /2 - -------------.
                                 ~                    ~
                            . . . . . . .. . . . . . . . . . . . . .       ~             ~                 --  . .- .--   . . . .-. . . . . . . .                                 .--. -. --    . .- .- .- .- .- .- .- .- .- .-. -. .                                       . . . . . . . . . ... . . . . . 5126              . . .             . . . . .
                                          . . . .. . .,. . . .. . .. . . ..   . . .   . .. .       . . . :, . . .        .. . .        . . .      . . .        . . . . . . . ., . . . . . . . . . . .            .     .    .      .     .   .     .   ..    .    .     .    .      .    .    .    .   .   .    .   .   .   .   .    .    .   .   .   .    .

6/2

       .. . .. . . . . . . . . . . . . . . .. . . . . . . . ..-                                                    . .. . . . .... . ... . . .                             4.-                                                                          ---   *,,:,-- **,,
                                                                                                                                                                                                                                                             --                 --,*- *-*,*-. ,-,,:- -: ,* -----. *                                     . . .

2/14+-- - - - -

                              --- --I- - -             --      --       -- -- - .- .- - .--. .- - .- .- --..
                                                                                                         .                              . . . . . . . . .. ....
                                                                                                                                                             .    .    .    .   .    .    .   .      .    .   .    .      .     .     .    .    .    .                  . . . . . .... .    .   .    .   .    .   .   .   .   . - --
                                                                                                                                                                                                                                                                                                                              -    . -  . - - - -- -- - --
             . .. . . . . . . . .... . . . . . . . . . . . . . . . . . . . . . . . . . . . .-. . . . . . . . . . . ----                                         . . . . . . . . . . . --                      . .- .-. --          . .- .-. -.-                       . . . . . . . . . . . . ..... . . . . . . . . . . . . . .
          . . .. . . .-                               . . . .        . .- .- . .- - . - . .- - . - . - .- - . - .- -. - . - . -. - . - .-                  .    .   .       .   .    .    . .   .       . .   . . .       .--
                                                                                                                                                                                                                            . - .- - .--..   . - .-    .--.  .    .    . . .        .     . . . . . . . . . ..      . --. - -
                                                                                                                                                                                                                                                                                                                            . --. -- . - -.
                                                                                                                                                                                                                                                                                                                                          .                      .
            , .-- . -. - . --.                .-    .- -. -. - . - . -. - .-          .- .-     .- - . - - . - .-        .- .-      .-    .    .     .     .    .   .     .   .    .    .   .   .       .   . -- . -. --
                                                                                                                                                                                                                       .. . -
                                                                                                                                                                                                                            ....
                                                                                                                                                                                                                              . -. - - - -- - -         - - -- - - - - -- - -.                                  . . . . . . . . . . . ..-

6/

           . .. . .. .....           . . . .     .. ..         . ..       . . . .   . .. .       . . .   *     .    .   .     .      .   .     .     .    .     .   .    .    .    .   .    .   ... . . . . -. ..-.             -.. .      .    .    .       . . . . .. .. . . . .                . . . . . . . . . .. .    .   .     .   . .   .   .   .    .   .
                      --       1-1--   2-1---        - -       --                   -- -         -    -    --       -     - -        -- -         -     - --                                                                --        -    - -       -               -     - - - ----                ~      ---    --
                                                                                                                                                                                                                                                                                                                    - -     -   -
                                                                                                                                                  -- -         - -- - - - -- - - - ---                                                     -- - - - -- - - -                                             --- --          -- --           --- --- --
                            . .. . . .. .. . .. .. .. ..                                                              ........                                                        2 . . .. --      . .-------
                                                                                                                                                                                                            . .. .. . .. .. . . .. . . .                     . .. . .--..  . . . .. . . . . . . . . . . . . . . .. .. . . . .. . . . . .
          --------------------. . . . --                                          . . . -. -  . . - - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..--                                               - . . . . . . . ... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . .
      . . .. .        .       .       ..    .    .    .     .     .     . .   .   .    .   .     .    . 2 ... . .. . .. . . . . . . ... . . . . . .. . ... . . . . ....
                                                                                                                                                                     . . . - -.                                                                                .     . .     .      .    . .    .    .   ..     .   .   . .   .    .    . .   .   .   . .     .  .

. . . . . . . . . . . . .. . . . . .. . . . .. . . . . . . . . . ..--

                                                                                    --.                          .    .. . . . . .           . . . . . ..         . .. . . . .       .. . . . . .         . . . . .--
                                                                                                                                                                                                                   . ...... -
                                                                                                                                                                                                                            .      -     -   --      -    - -- - - - - -- - - . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
                                                                                                                                                                                                                                                                                ---------- ---------------
                                                                                                                                                                                                                                                                                --------------------------
                                                                                                                                                                                                                                                                                              ---------------------
                                                                                                                                                                                                                                                                                                ....................
                                                                                                                                                                                                                                                                                                           -I----     ---   ---   ---     -
                                                                                                                                                                                                                                                                                --------------------------

    ---------------------------------------------------------  ................
       ------------------ --------
                                                              -----------

12/8

                                                                -----

4/6 416

               -----------
               ................                                   iii 5/1(2

IOctober IJanuary IApril 8/24 10/5 11/16 12/28 2/8 3/22

                  . .. .. -- - - - - - - - - - - - - - - - - - - - - - - - . . . .
             .. ...                                                                                                           - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - -
 -------------------- ----------
                                                                                                                                                  ---------------

---

----------------

                                                                                                                                                                                     -------    ------
              ----------- ----------------

---

---------------- ------------------ ------------------- --------------

                 -----------------

---

....... ---------

                                                                                                                                               ----------------
                                                                                                                                                 ------------- I
                                                                                                                                                    ------------
    .  . .    .    ..         9/28 9/29         -                                              .. I) 2*!*:

11123 #  !, 2/ 1 .. . .. . ... ... .. .. . . .. ............ - --- - 11124122 12122 11

                 ..........
           -------------                                                                                     ----------------------- ----------------------------------------
                                                                                                                                            ---------------------------------------- ------------
                  ................                                                                                                               ------------------------------------------------
------------                                                                                                                                       --------------------------------- ------------
   ----------- ------ -----------                                                                                                      ------------------- ------------- - ---------
  -------------------------                                                                                                                                               -----------------------
  ................................                                                                                                                                        -----------------------
                                                                                                                                                                                 ----------------

9 /298..........................11................. ..................... 9 /2 9 ý --- -- -- -- -- -- - -- - - -- - - - -- - --- - - - - - - -- - - - -- - - -- - - - ----------------}}