UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001

January 10, 2002

NRC INFORMATION NOTICE 2002-03: HIGHLY RADIOACTIVE PARTICLE CONTROL

PROBLEMS DURING SPENT FUEL POOL

CLEANOUT

Addressees 

All holders of operating licenses for nuclear power reactors, holders of licenses for permanently

shutdown facilities with fuel onsite, and holders of licenses for non-power reactors.

Purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert

addressees to recent issues involving evaluation and control of radioactive particles generated

during removal of material from a spent fuel pool prior to shipping the material offsite for

disposal. The issue emphasized in this notice is that highly radioactive (hot) particles represent

a radiological hazard not just in terms of shallow dose to the skin or an extremity but also as a

deep or whole-body dose. It is expected that recipients will review the information for

applicability to their facilities and consider actions, as appropriate, to avoid similar problems. 

However, suggestions contained in this information notice are not NRC requirements; therefore,

no specific action or written response is required. 

Description of Circumstances

Toward the end of a 5-month spent fuel pool cleaning project, the Susquehanna Steam Electric

Station completed compacting irradiated components that had been temporarily stored in the

pool. Working under water remotely, the licensee had used an ìadvanced crusher and shearerî

(ACS) unit to compact control rod blades and local power range monitors. On October 12,

2000, the ACS was removed from the cask storage pit with a crane after apparently inadequate

cleaning with a high-pressure spray Hydrolazer. The ACS was moved over the refueling floor

and into the reactor head washdown area for further decontamination prior to shipment offsite. 

The ACS was not totally wrapped or sealed during this movement. Also, access to the ACS

pathway over the refueling floor was not radiologically controlled during the move. 

During the movement of the ACS, the refueling floor local area radiation monitor began to

alarm. The cause was a previously unidentified highly radioactive particle which had fallen from

the ACS. The particle was later determined to be a 2.78 gigabecquerel (Gbq) [75 millicuries

(mCi)] Co-60 particle, reading approximately 8 sievert/h (Sv/h) (800 rem/h) at contact. 

ML011790547
IN 2002-03

Page 2 of 4

The licensee stopped work, shielded and captured the particle, and initiated radioactive particle

control zone coverage for the entire refueling floor. Additional actions undertaken at that time

included formation of a root cause event review team. The teamís work led to upgraded

controls, surveying, more management oversight and more detailed planning and work

procedures for handling high specific activity particles.

A search was then begun for additional hot particles on the refueling floor. Workers in particle

control zones were surveyed for particles every 15 minutes, and more protective clothing (PC)

was required for certain work activities. The 15-minute control was a default stay time, and not

based on dose calculations for the high-activity particles known to be present.

During the cleanup activities, more than 30 radioactive particles were found on the refueling

floor. Two high activity radioactive particles found on September 9 and December 6, 2000, had

resulted in shallow-dose equivalent (SDE) exposures of 0.12 and 0.17 Sv (12 and 17 rem),

which is below the annual SDE limit of 50 rem. The licensee discovered two more high-activity

particles, a 0.78 Gbq (21 mCi) particle on November 28, and a 0.7 Gbq (19 mCi) particle on

December 4, 2000; these particles did not result in significant exposure to personnel. No actual

exposures in excess of any annual dose limits occurred during the cleanup activities.

During a scheduled NRC health physics, rad-waste transportation, baseline inspection during

December 11-15, 2000 (Inspection Report Nos. 05000387/2000-009 and 05000388/2000-009,

ADAMS Accession No. ML010250469), the NRC inspector identified significant weaknesses in

the licenseeís particle control program. The inspector noted that the licensee had failed to

identify that conventional hand-held survey instruments using standard survey methods were

underestimating the contact dose rates of the particles, thus underestimating the radiological

hazards not just to the skin but in terms of whole body exposure. 

The licenseeís evaluation had failed to consider properly and account for the potential for

substantial dose to personnel from the high-activity particles. Specifically, the 15-minute worker

stay time was not adequate to prevent potential overexposures from the particles known to be

present in and around the refueling floor. The stay time would have allowed both SDE and total

effective dose equivalent (TEDE) annual exposure limits to be exceeded.

Four of the particles found ranged from 0.7 to 2.78 Gbq (19 to 75 mCi). Had the particles been

directly on the workersí PCs, the TEDE annual limit of 0.05 Sv (5 rem) could have been

exceeded in 25 seconds to 2 minutes, and the SDE limit exceeded in 6 to 21 seconds,

depending on the activity of the individual particle.

In response to the NRC findings and a 0.17 Sv (17 rem) SDE exposure on December 6 from a

particle on a workerís boot, licensee management stopped all high-risk work, initiated a

comprehensive events evaluation, requested on-site assistance by an industry expert team, and

implemented improved training and communication of lessons learned in this area. 
IN 2002-03

Page 3 of 4

Discussion

During previous similar processing of irradiated components at Susquehanna in 1991,

radioactive particles had been identified with external gamma dose rates greater than

100 rem/hr. However, the plant failed to incorporate fully this previous experience and industrywide experience into the planning for the 2000 fuel pool clean out project. (NRC Information

Notice No. 90-33, ìSources of Unexpected Occupational Radiation Exposures at Spent Fuel

Storage Pools,î also concerns highly radioactive particles.)

Prior to the NRC baseline inspection, after the initial event, the work controls that the licensee

had implemented were not sufficient under the circumstances to evaluate and control the

potential radiological challenges posed by these extremely high activity particles. A Notice of

Violation (failure to conduct adequate evaluation and survey) associated with a White finding

(using the Significance Determination Process) was issued. These actions were taken because

of the substantial potential for exposure in excess of the annual limit for TEDE even though no

worker dose limits were exceeded.

During the regulatory conference for this violation, the licensee stated that it needed to improve

its hot particle surveying, identification, handling, and control. The improvements included

more effective use of remote handling techniques, proactive staging of particle control zones,

and aggressive treatment of potential sources of particles by using decontamination and

filtration on systems that communicate with the spent fuel pool.

The licensee noted that in cases like this where a contractor was used for a challenging

radiological evolution, plant management oversight was essential. That oversight must focus

on, and have sufficient resources to implement and maintain a sense of an acceptable radiation

culture and acceptable practices and standards for radiation work. According to the licensee, 

this can best be accomplished by direct ownership for significant, high-risk projects

demonstrated by the visible presence and direct oversight of the work by utility managers.

Most importantly, this occurrence demonstrated a need to strengthen procedural controls to

focus attention on the large potential doses from these challenging radiological work

environments. The worker training program and job oversight must emphasize the most

important lesson learned from the eventóthat radioactive particles can present not only

shallow-dose risks but, at higher activity levels, whole body dose risks, which can be much

more significant.
IN 2002-03

Page 4 of 4 

This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact one of the technical contacts

listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

/RA/

William D. Beckner, Program Director

Operating Reactor Improvements Program

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Technical contacts: James E. Wigginton, NRR James D. Noggle, Region I

301-415-1059 610-337-5063

E-mail: jew2@nrc.gov E-mail: jdn@nrc.gov

Attachment: List of Recently Issued NRC Information Notices
IN 2001-03

Page 4 of 4 

This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact one of the technical contacts

listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

/RA/

William D. Beckner, Program Director

Operating Reactor Improvements Program

Division of Regulatory Improvement Programs

Office of Nuclear Reactor Regulation

Technical contacts: James E. Wigginton, NRR James D. Noggle, Region I

301-415-1059 610-337-5063

E-mail: jew2@nrc.gov E-mail: jdn@nrc.gov

Attachment: List of Recently Issued NRC Information Notices

Distribution:

PUBLIC

IN File

ADAMS ACCESSION NUMBER: ML011790547

*See previous concurrence

OFFICE REXB Tech Ed IOLB SC:REXB RORP

NAME EGoodwin* PKleene* GTracy* JTappert* Wbeckner*

DATE 12/20/2001 6/19/2001 8/20/2001 6/26/2001 01/08/2002

OFFICIAL RECORD COPY
______________________________________________________________________________________

OL = Operating License

CP = Construction Permit

Attachment 1

IN 2002-03

Page 1 of 1

LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

_____________________________________________________________________________________

Information Date of 

Notice No. Subject Issuance Issued to

_____________________________________________________________________________________

2002-02 Recent Experience with

Plugged Steam Generator

Tubes

01/08/2002 All holders of operating licenses

for pressurized-water reactors

(PWRs), except those who have

permanently ceased operations

and have certified that fuel has

been permanently removed from

the reactor.

2002-01 Metalclad Switchgear Failures

and Consequent Losses of

Offsite Power

01/08/2002 All holders of licenses for nuclear

power reactors.

2001-19 Improper Maintenance and

Reassembly of Automatic Oil

Bubblers

12/17/2001 All holders of operating licenses

for nuclear power reactors,

except those who have

permanently ceased operations

and have certified that fuel has

been permanently removed from

the reactor vessel.

2001-18 Degraded or Failed Automated

Electronic Monitoring, Control,

Alarming, Response, and

Communications Needed for

Safety and/or Safeguards

12/14/2001 All uranium fuel conversion,

enrichment, and fabrication

licensees and certificate holders

authorized to receive safeguards

information. Information notice is

not available to the public

because it contains safeguards

information.

2001-17 Degraded and Failed

Performance of Essential

Utilities Needed for Safety and

Safeguards

12/14/2001 All uranium fuel conversion,

enrichment, and fabrication

licensees and certificate holders

authorized to receive safeguards

information. Information notice is

not available to the public

because it contains safeguards

information.

2001-08,

Sup. 2

Update on Radiation Therapy

Overexposures in Panama

11/20/2001 All medical licensees.

2001-16 Recent Foreign and Domestic

Experience with Degradation of

steam

Generator

Tubes and Internals