United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 88-101: Shipment of Contaminated Equipment Between Nuclear Power Stations

                                  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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          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 
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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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Page Last Reviewed/Updated Tuesday, November 12, 2013