Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555
December 28, 1988
Information Notice No. 88-101: SHIPMENT OF CONTAMINATED EQUIPMENT
BETWEEN NUCLEAR POWER STATIONS
Addressees:
All holders of operating licenses or construction permits for nuclear power
reactors.
Purpose:
This information notice is being provided to remind addressees of their re-
sponsibilities to properly package, prepare for transport, and describe on
shipping paper documents, packages containing contaminated equipment being
offered for transportation between different stations. It is particularly
applicable to transfers of leased equipment which is used consecutively by
several licensees. It is expected that recipients will review this informa-
tion for applicability to their facilities and consider actions, as
appropriate, to preclude violations of transportation safety requirements.
However, sug-gestions contained in this information notice do not constitute
NRC requirements; therefore, no specific action or written response is
required.
Description of Circumstances:
Two past events are described below, each of which involved the shipment of
contaminated equipment between operating power stations. In each case, vio-
lations of the Department of Transportation (DOT) regulations occurred:
x In October 1985, a contaminated control-rod blade cutter was de-
livered by the Oyster Creek Nuclear Generating Station in New Jersey
to a common carrier for transport to the Quadrex Corporation
facility in Oak Ridge, Tennessee. This cutting equipment, which is
leased consecutively to different plants, was being returned for
servicing. Upon arrival at the receiver's facility, a radiation
survey of the vehicle indicated that the radiation limit, at two
meters from the outer edges of the vehicle, had exceeded the 10
millirem/hour (mrem/h) limit at several points by as much as 50
percent. Upon disassembly of the equipment, a small segment (2.5"
long x 3/16" diameter) of a boron tube from a control-rod blade was
unexpectedly found to be present, having a contact dose rate of 40
roentgen/hour (R/h). The shipper's survey records indicated that
the maximum dose rate at two meters from the edges of the vehicle
had been slightly below
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IN 88-101
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the 10 mrem/h limit at the time of the shipment. It was
subsequently determined that the small segment of boron tube had
shifted from its original position (at the time of survey) within
the internals of the blade cutter, resulting in the elevated
radiation levels. The licensee was subsequently issued a Notice of
Violation for failure to maintain radiation levels on the vehicle
below the DOT regulatory limit of 49 CFR Subsection 173.441(b).
x In May 1987, during a receipt inspection and survey of two packages
of low specific activity (LSA) material received by the Brunswick
Steam Electric Plant in North Carolina, external radiation levels of
1500 mrem/h and 1800 mrem/h, respectively, were discovered on
contact beneath the packages. The shipment, from Nine Mile Point
Unit 1 in New York, consisted of two boxes; one containing a con-
taminated control-rod blade-shearing machine and its associated
equipment/hoses, and the other, a support platform used in the
underwater operation of the shearing equipment in the fuel pool.
The equipment is used consecutively by several different licensees
to shear highly activated stellite rollers from boiling water
reactor (BWR) control-rod blades, and thus is transferred frequently
from one power reactor to another. The shipping records associated
with the shipment listed cobalt-60 as the only radionuclide present.
Other material control records of the licensee, however, indicated
that at least one other nuclide (iron-55) was also present in
comparable quantities. Review of the circumstances surrounding the
radiation level problem indicated that the licensee had not properly
removed hot particles and chips from the internals of the equipment
(causing an increase in radiation levels when the particles became
dislodged and shifted position during transit). The licensee had
also assumed, without further assessment, that only cobalt-60 was
present in an amount required to be reported on shipping documents.
The shipper licensee was subsequently assessed with a $2500 civil
penalty for violation of 49 CFR Subsection 173.441(a).
Discussion:
Each of the above cases is a prime example of the importance of making careful
evaluations before packaging and shipment of items which may potentially
contain internal radioactivity. In each case, the absence of such activity
was not apparent in the preshipment surveys. Each of the above shipments was
made by the licensee after making assumptions that the measured dose rates
were from fixed activity on the surfaces of the equipment. Each case,
however, clearly indicates a potential for small sources of irradiated
material to inadvertently remain within the internals of such equipment, with
the higher radiation levels being masked by intrinsic shielding, later to
produce elevated radiation levels when the material shifts during transport.
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IN 88-101
December 28, 1988
Page 3 of 3
It is important that each licensee shipper make a "reasonable effort" to
determine the identities and activities of the radionuclides present in any
radioactive materials shipment. The DOT regulations require that the identity
(49 CFR Subsection 172.203(d)(i)) and radioactivity (49 CFR Sub-section
172.203(d)(iii)) of the contained radionuclides be included in shipping
papers. In meeting these requirements, DOT has issued guidance indicating
that radionuclides accounting for one percent or more of the total activity
shipped are to be indicated and quantified in the shipping papers.
Determination of the identities and activities of each contaminated article in
a shipment will not only involve direct measurements, but also inferential
information based on the use of the contaminated equipment in the licensee's
plant and plant historical data (including 10 CFR Part 61 radiochemical
analyses).
No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the technical
contact listed below or the Regional Administrator of the appropriate regional
office.
Charles E. Rossi, Director
Division of Operational Events Assessment
Office of Nuclear Reactor Regulation
Technical Contact: A. W. Grella, NMSS
(301) 492-3381
Attachment: List of Recently Issued NRC Information Notices
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