NOTE TO FILE

FROM: James Kottan, Senior Health Physicist, Branch 2, Division Of Nuclear Materials Safety (DNMS)

John Kinneman, Chief, Branch 2, DNMS

CONTAMINATED ARTICLES (FENCE POST CAPS) DISCOVERED DURING ROUTINE INSPECTION OF INCOMING SHIPMENT AT THE PORT OF BALTIMORE

At approximately 2:OO PM on January 14, 2004, NRC Region I was notified by the EPA Region 3 office that U.S. Customs at the port of Baltimore, during a routine inspection of an incoming shipment, selected a container for additional inspection, and this container caused the Customs’ radiation monitoring instrumentation to alarm. Customs conducted a preliminary investigation, and then contacted the EPA Region 3 office for assistance. The EPA then contacted the NRC Region I office.

When the 20 foot container was opened and inspected by Customs, a pallet in the rear of the container triggered the alarm of Customs’ radiation monitoring instrument. Radiation surveys of the remaining cargo in the container were performed, and no radioactive material was detected. The rear pallet consisted of small parts which were hot-dipped galvanized structural fence post caps. The parts were contained in packages, stacked in layers ten high, with approximately 14 packages in each layer. Custom unstacked the layers and determined that the radioactivity was contained in the bottom four layers. These packages were opened, and the individual fence post caps were surveyed. The cap survey results indicated 5 to 9 mWhr for the individual caps. Gamma ray spectra were obtained using a portable sodium iodide detector, indicating the source of the radiation to be Co-60.

Eight of the fence post caps were sent to the NRC contract laboratory, Oak Ridge Institute for Science and Education (ORISE), for analysis. The samples were received at ORISE on February 3, 2004. The samples were analyzed by high resolution gamma spectroscopy. The analytical results indicated that the fence post caps contained 350*20 pCi/g of Co-60. Additionally, the analyses determined that the concentration of (20-60 in each fence post cap was consistent from cap to cap.

The importer of the fence post caps was:

Global Hardware Systems 10776 Tucker Street Beltsville, MD (301) 595-5325.

The exporter was:

I. J. Tools&Castings(P), Ltd. 321 New Jawajar Nagar Jalandhar India.

The fence post caps were placed under “formal detention” and were properly secured and under Customs’ control. The fence post caps have been exported back to India. (Based on discussions with Customs’ Assistant Port Director in Baltimore on April 1, 2004.)

Attachments: 1. U.S. Customs’ photographs 2. ORISE analytical results

AlTACHMENT 1

AlTACHMENT 2

February 24,2004

Distribution approval and concurrence: Technical Management Team Member

0

Initials I Date . a / a 4 / 3 4

R S E O A K R I D G E INSTITUTE F O R S C I E N C E A N D E D U C A T I O N

'04 27 p 7 ,.os CI

Mr. Jim Kottan U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406

SUBJECT: ANALYTICAL, RESULTS FOR GALVANIZED FENCING CAPS FROM UNITED STATES CUSTOMS, BALTIMORE, MARYLAND (RFTA 04-001)

Dear Mr. Kottan:

The Environmental Survey and Site Assessment Program ( E S S A P ) of the Oak Ridge Institute for Science and Education (ORISE) received eight galvanized fencing caps on February 3,2004 that were shipped by United States Customs personnel. The samples were analyzed by gamma spectroscopy (Procedure CP 1, Revision 13). A case narrative is included to explain the steps taken to generate the data for these samples. The quantitative data for the concentration of cobalt 60 (Co-60) in one of the caps is presented in Table 1. The qualitative data generated to determine the homogeneity of the Co-60 contamination between the caps is presented in Table 2.

ESSAP's Quality Control (QC) requirements were met for these analyses. The QC files are available for your review upon request.

Please contact me at (865) 241-3242 or Wade Ivey at (865) 576-9184 should you have any questions.

Sincerely,

Dale Condra Laboratory Manager Environmental Survey and

Site Assessment Program

RDC:wPI:ar Enclosure

cc: T. McLaughlin, NRC/NMSS/TWFN 7F27 E. Abelquist, ORISE/ESSAP E. box-Davin, NRC/NMSS/TWFN 8A23 File11 600

T. Vitkus, OMSEESSAP

P. 0. BOX 1 17, OAK RIDGE, TENNESSEE 3783 1-01 17

Operated by Oak Ridge Associated Universities for the U.S. Department of Energy

CASE NARRATIVE

Mr. Jim Kottan (NRCRegion I) indicated during the initial phone conversation that the suspected contaminant in the samples that would be sent to the ORISE laboratory was cobalt-60 (Co-60). If CO-60 was confirmed to be the contaminant, the concentration, in pCi/g of material, was to be determined.

Once the samples were received, a qualitative gamma count was performed and CO-60 was confirmed as the contaminant.

After obtaining initial weights on all the samples, one sample (M001) was then placed into 4 M HC1 and allowed to soak overnight. The HC1 was decanted into a 1 L graduated cylinder and diluted to volume with distilled water. The remaining undissolved portion of the sample was dried and re-weighed. The difference between the initial and final weights was calculated to determine the quantity of metal that was dissolved. The dissolved portion of the sample was gamma counted overnight yielding a CO-60 concentration of 1 10 pCilg. Since the initial dissolved material contained the outer zinc coating plus any steel that had been dissolved, there was a concern that the concentration of Co-60 might be underestimated for the entire cap.

It was decided that three sections would be obtained from sample MOOl . Using a portable band saw, three sections weighing about 8 g each were cut from the sample. Each section was placed in 4 M HCI, heated until dissolved, diluted to 1 L with deionized water, placed in a 1 L Marinelli, and submitted for counting.

A one hour gamma count was performed on each fraction and the data were presented to Mr. Kottan for comment. The Co-60 concentrations from each fraction were statistically equal to the average value of 350 * 20 pCi/g. Mr. Kottan requested that the samples be counted for a longer time to reduce the uncertainties of the measurements. Each fraction was then recounted overnight for 16 hours and those data are presented in Table 1.

Mr. Kottan further requested that sample MOOl and the remaining seven samples be counted in the same geometry to determine homogeneity between the samples. While the results from these counts would not be quantitative, the generated concentrations should be statistical with uniform contamination. The samples were counted 10 cm from the detector to determine if the contamination was consistent between samples. The results presented in Table 2 indicate the contamination concentration is consistent from sample to sample.

ORISE TABLE 1

ESSAP Sample ID

COBALT-60 CONCENTRATIONS IN METAL SAMPLE

BY GAMMA SPECTROSCOPY CP1, REVISION 13

UNITED STATES CUSTOMS BALTIMORE, MARYLAND

CO-60 NRC Region I

Sample ID Concentrationsa (pCi/g dry weight)

1600M001A

1600M001B

#1 361 f 12b

# I 348* 1 1

11 1600M001C I #1 I 354* 12 -11 ?he average MDC for a 16 hour count of 1L Marinelli for Co-60 is 1.2 pCi/g.

bncertainties represent the 95% confidence level, based on total propagated uncertainties.

OIUSE TABLE 2

1600M007 #7 153.2 f 7.6

~ 1600M008 #8 150.1 f 5.7

QUALITATIVE COBALT-60 CONCENTRATIONS FOR HOMOGENEITY DETERMINATION

IN METAL SAMPLES BY GAMMA SPECTROSCOPY

CP1, REVISION 13 UNITED STATES CUSTOMS BALTIMORE, MARYLAND

ESSAP Sample ID Co-60 Qualitative

@Ci/g dry weight)

NRC Region I Sample ID Concentrationsa

1600M001 I #1 I 148.9It 6.2 11 1600M002

1600M003

#2 147.7 f 5.6

#3 156.9 f 7.9

1600M004

1600M005

1600M006 I ~ #6 ~ I 156.7 f 7.8 (1

#4 156.5 f 5.9

#5 147.4 f 7.4