Approved 10/27/97 REQUIREMENT D. Loss of Control of Radioactive Material/Spread of Radioactive Contamination Off-Normal (3) Identification of radioactive contamination onsite that is not located within a Controlled Area, Fixed Contamination Area, or Soil Contamination Area, and is in excess of two times the total contamination levels in 10 CFR 835, Occupational Radiation Protection, Appendix D. For tritium, until a total contamination value is specified by 10 CFR 835 Appendix D, report contaminations in excess of 2 times 10,000 dpm/100cm2. INTERPRETATION An instrument that needed calibration was surveyed by Radiological Control, declared free of contamination and transported to the central calibration shop in an unregulated vehicle on site roads. When the instrument was received by the calibration shop, it was found to have fixed contamination on the probe that exceeded the table limits. An Off-Normal occurrence was declared using criteria of Group 10.C -Potential Concerns/Issues. Because the contamination was fixed, no additional immediate actions were required. Should this also be classified using the criteria in Group 1.D. - Loss of Control of Radioactive Materials/Spread of Radioactive Contamination, since the instrument was transported in an unregulated vehicle on site roads? Intent: The Group 10.C -Potential Concerns/Issues was intended to be used only when the event does not meet other reporting criteria thresholds. This event appears to meet other criteria. The justification that the contamination was fixed and no additional immediate actions were required should not be considered when determining reportability when specific levels are identified in the criteria. Additional Information: Reporting under Group 1.D - Loss of Control of Radioactive Materials/Spread of Radioactive Contamination would be appropriate if, as this event appears, the minimum threshold is met for radioactive contamination onsite but outside of a controlled area. Reporting under Group 6 - Transportation would be appropriate if there was a potential violation of DOT requirements. Did the shipping papers incorrectly identify the hazards? Were the shipping papers or an approved vehicle/driver for hazardous material transportation required? Generally, shipments on roads for official site use only are not governed by DOT regulations, but if they are available for public use then shipments are usually governed by DOT regulations. |
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