shipping violation?

[William V Lipton <liptonw@dteenergy.com>]

Please see that attached incident report and its "retraction."  This
retraction may be premature.  The wipe of an arriving RAM shipment
showed 4442 dpm, which was reported as above the shipping limit of 2.2
dpm/cm2.  This now has been retracted on the basis that, since the
surface area of the package is 2990 cm2, the average contamination level
is less than the limit.

********* WRONG******************************

Before making regulatory decisions please read the regulations:

49 CFR 173.443 Contamination Control

" ... The level of non-fixed radioactive contamination  ... must be
determined by either:  (1) Wiping an area of 300 square centimeters of
the surface concerned ... or (2) Using other methods of assessment of
equal or greater efficiency ..."

i.e., the contamination must be averaged over 300 cm2, NOT 2990 cm2.
There could very well be a hot spot on the packge which was over the
limit.

Who reviews these reports before they're published??

The opinions expressed are strictly mine.
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com






!!!!!!!!! THIS EVENT HAS BEEN RETRACTED. THIS EVENT HAS BEEN RETRACTED
!!!!!!!
+------------------------------------------------------------------------------+

|Other Nuclear Material                           |Event Number:
37062       |
+------------------------------------------------------------------------------+

+------------------------------------------------------------------------------+

| REP ORG:  SOUTH COAST MEDICAL CENTER           |NOTIFICATION DATE:
06/06/2000|
|LICENSEE:  SOUTH COAST MEDICAL CENTER           |NOTIFICATION TIME:
19:04[EDT]|
|    CITY:  LAGUNA BEACH             REGION:  4  |EVENT DATE:
06/06/2000|
|  COUNTY:                            STATE:  CA |EVENT TIME:
14:30[PDT]|
|LICENSE#:  0920-30               AGREEMENT:  Y  |LAST UPDATE DATE:
06/07/2000|
|  DOCKET:
|+----------------------------+
|                                                |PERSON
ORGANIZATION |
|                                                |JOHN PELLET
R4      |
|                                                |WILLIAM BRACH
NMSS    |
+------------------------------------------------+
|
| NRC NOTIFIED BY:  JOSE BRUNO
|                             |
|  HQ OPS OFFICER:  JOHN MacKINNON
|                             |
+------------------------------------------------+
|
|EMERGENCY CLASS:          N/A
|                             |
|10 CFR SECTION:
|                             |
|BAAA 20.1906(d)           SURFACE CONT/ EXT RAD
|                             |
|
|                             |
|
|                             |
|
|                             |
|
|                             |
+------------------------------------------------------------------------------+

                                   EVENT TEXT
+------------------------------------------------------------------------------+

| WIPE TEST OF PACKAGE EXTERIOR RESULTED IN A COUNT LEVEL OF 4442
DPM          |
|
|
| A package containing technetium - 99m (NaTcO4) delivered by NYCOMED
Amersham |
| to South Coast Medical Center was found to have surface contamination
level  |
| above the 2.2 DPM per square centimeter limit.  The wipe of the
outer        |
| surface of the package (metal canister) was placed in a well counter
and the |
| counter indicated the that total count on the  wipe was 4442 +/-149
DPM.     |
| The outer dimensions of the metal canister are 15 centimeters by
25          |
| centimeters by 29 centimeters. The licensee will contact NYCOMED
Amersham    |
| located in Anaheim, CA, and ask them to pickup the package.  The
package was |
| not opened.   Activity of the technetium-99m (NaTcO4) was originally
25      |
| millicuries and the quantity is 2.4838
milliliters.                          |
|
|
| * * * RETRACTION ON 06/07/00 AT 1152 ET BY JOSE BRUNO TAKEN BY
MACKINNON * * |
|
*
|
|
|
| The licensee is retracting this event because the surface
contamination of   |
| the metal container in DPM per square centimeter is below the
reportable     |
| limit of 2.2 DPM per square centimeter.  The surface area of the
metal       |
| container was 2990 square centimeters and the count of the wipe was
4442     |
| DPM.  Therefore the average surface contamination per square
centimeter is   |
| 1.49 DPM which is below the reportable limit of 2.2 DPM per
square           |
| centimeter. NMSS EO (Josie Piccone)  & R4DO (John Pellet)
notified.          |
+------------------------------------------------------------------------------+

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