ML17158B625

Observation

and Findin

s

Procedural

Guidance

Procedure

HP-TP-602,

"Survey and Release

of Tools,

Equipment

and

Material," Rev.

15, specifies

survey requirements

and criteria for the

release

of materials

from the

Items are considered

acceptable

for

release

from the

RCA when loose

and fixed contamination levels are less

than

100 net counts

per minute direct frisk, and loose contamination

is

less

than

1000 dpm/100 cm', using

an Eberline

RM-14 with a HP-210

pancake

Geiger-Mueller

(GM) probe or equivalent,

or there is no

20

indication of contamination

using

an automated

tool monitor.

Also,

since

items with fixed contamination

are routinely painted

magenta/purple,

there is an expectation that purple/magenta

painted

tools cannot

be released

from the

RCA, although this

requirement/expectation

was not specifically defined in procedures.

Improper Re1ease

of Naterials

From the

CR No.96-106

was written to investigate

a contaminated

3/8-inch socket

found outside of the

RCA in a tool box located in the South Building.

During the investigation

by the licensee's

staff, additional

contaminated

items were found outside of the

The scope of the

review was significantly expanded

to identify the root causes for the

failure to control the release

of radioactive materials

from the

RCA, to

identify materials that may have

been improperly released

from the

and to recommend corrective actions to minimizes the risk of recurrence.

Licensee staff members

indicated that items could have

been improperly

released

from the

RCA in the following ways:

Inadequate

surveys

performed during the release

of tools/equipment

at the end of a refueling outage;

Items carried in pockets

and coats,

and not detected

during

personal

contamination monitoring;

Inadequate

surveys

performed

by non-health

physics

personnel

without health physics oversight;

Intentional

removal of materials without health physics oversight;

and

Items not detected with an HP-210

GM probe,

but detected

with an

automated tool monitor.

During this review, the licensee

developed

a "Contaminated

Item Survey

Strategy"

and

made

an initial determination that

22 onsite

and

27

offsite locations, all controlled by the licensee,

had the potential for

r'eceiving tools

and equipment

from the

RCA at SSES.

Each of these

locations

was then evaluated to determine

the potential for such

receipt,

and

a survey strategy

was developed.

The selected

survey

strategy for a specific location could include walk-through inspections,

computer record reviews,

interviews with cognizant personnel,

or actual

radiological

surveys.

The search for radioactive materials

and

contaminated

tools/items

was also directed

toward other

PP&L locations

where tools or equipment

were sent for storage

or as excess

inventory.

PP&L management

stated that they would investigate

and monitor,

when

appropriate,

tools or equipment that were sold to individuals or

organizations.

As of Narch,

28 1996, the licensee

had compiled

a list

of 73 items that were found to be improperly released

from the

Based

on

a review of this list, the inspectors

made the following

observations:

'I

21

15 of the

73 items

had contamination

less

than the licensee's

release

levels using

an HP-210

GN pancake

probe.

However, these

.

items were determined to have

been

improperly released

from the

RCA because

they contained

remnants of magenta

or purple paint;

ll oF the

58 contaminated

items

had contamination levels of 400-

2,200

ncpm direct frisk.

The item with the highest contamination

was

a 3/8-inch socket, with 2,200

ncpm,

and was found in a tool

box located in the South Building at

SSES facility;

47 items

had minor contamination levels

above the minimum

detectable

level but < 300 ncpm by direct frisk;

t

7 items

had loose or smearable

contamination;

The majority of items (approximately

75%) were small

hand tools;

The majority of items (approximately

72X) were found at two

locations;

South Building and the

Combo Shop (both buildings are

within the protected

area

fence of SSES facility); and

Al'1 of the items identified as contaminated

were found on property

controlled

by the licensee

(owner controlled area).

Based

on

a review of contamination levels,

the licensee

determined that

if.an individual used the tool with the highest contamination level

every work-day for a year, the individual would receive

a dose of

approximately 1.2 millirem.

Event Review Team Report

In response

to

CR No.96-106,

a multi-disciplined

ERT was commissioned

including an expert in the area of root cause

analyses.

The

ERT was

tasked with identifying the root causes for the failure of mechanisms

that control the release of radioactive materials

from the

identifying materials that

may have

been improperly released

from the

and recommending corrective actions to minimize the risk of

recurrence.

ERT members dedicated

over 640 hours0.00741 days 0.178 hours 0.00106 weeks 2.4352e-4 months of collective effort

in the review of contamination control practices

at

SSES.

The inspectors

noted that the

ERT report for CR 96-106 took a very

critical look at contamination control practices

at

SSES,

and included

very detailed root causes

and causal

factors.

The major identified root

causes

included the following:

System

and practices

for control of releases

from the

RCA were not

globally understood,

effectively communicated,

or consistently

implemented;

The radiological tool control

program

and implementation (e.g.,

training and procedures)

had deficiencies

which resulted in the

release of radioactive material

from the

RCA; and

22

Inadequate training, supervision

and work environment contributed

to performance errors resulting in the release

of radioactive

material

from the

The licensee

recently purchased

a large area

probe to help identify

areas of radioactive contamination

on personnel,

materials,

or

equipment.

At the time of this inspection,

there were

no procedures

or

training for the radiation protection technicians

regarding the use of

the large area

probe.

Although more sensitive

than the standard

small

area

probe,

the licensee

was not sure what minimum detectable

contamination

could be reliably monitored with the

new probe.

Therefore,

the licensee

was attempting to use the probe under limited

conditions until the technical

basis for its use

was completed.

Based

on the identified root causes

and causal

factors,

the licensee

initiated the following short term corrective actions:

~

Staffed

RCA egress

control points with management

personnel

on

a

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day basis;

Provided instructional job aids at

RCA exits including

a

description of materials that can

be monitored with the automated

personnel

monitor, personnel

items which can

be monitored

by

personnel

with a frisker,

and items which must

be monitored

by the

health physics staff;

Conducted

("stand-down") training to inform all station personnel

of changes

to control the release

of radioactive material

from the

radiologically-controlled area;

Upgraded

and 'standardized

controls associated

with RCA doors

(exits);

and

~

Reduced the number of active control points for access

to and

egress

from the

The inspectors

noted that

ERT also

recommended

16 major long term

corrective actions,

with a goal of full implementation prior to the next

refueling outage.

Examples

included the following:

Establish

automated tool monitors

as the primary method for

monitoring contamination

on tools at

RCA exits (i.e., reduce the

use of manual frisking);

I

Modify current staffing and practices for personnel

access

to and

egress

from the

RCA;

Establish surveillance

and self-as'sessment

programs to monitor

performance of individuals entering

and exiting the

RCA;

. 23

'pgrade

health physics

survey practices (i.e.,

expand

use of tool

monitors

and large area probes,

and discontinue the practice of

task qualifying Level I technicians

to perform release

surveys);

~

Clarify the station's

contamination control policies (e.g.,

management

expectations,

definition of personal

items, minimize

materials

brought into the

and clarify radiological controls

for clean systems);

~

Install local door alarms

on

RCA boundary doors;

~

Revise Maintenance

Instruction HI-AD-002 to be

a higher level

document

and include clarification on proper monitoring protocol

for tools versus

personal

items;

~

Identify SSES tools in the

RCA with paint or etchings;

~

Establish

a maintenance

tool coordinator responsible for all tools

in the

RCA;

~

Relocate

the tool room to the Unit 2 side of the facility;

~

Test revised procedures

for compatibility with personnel

practices;

~

Increase

the knowledge

and skill of RCA workers;

and

~

Increase

the knowledge

and define the expectations

for first and

second line supervisors

with respect to radioactive material

control.

It

Based

on

a review of these corrective actions,

the inspectors

pointed

out that additional review/guidance

was warranted for the survey of

tools that could possibly have internal contamination,

that

may be self-

shielding

and not easily detected

by direct survey with a "frisker" or

tool monitor (e.g.,

a Barton transmitter

was released

to the Susquehanna

training center with internal contamination).

The licensee

acknowledged

the inspector's

observations,

and informed the inspectors that procedure

HP-TP-602,

"Survey and Release

of Tools,

Equipment,

and Haterials,"

Rev.

15 was currently undergoing

review and revision.

The inspectors

noted that the

ERT report included

a very critical self-

evaluation,

was broad in scope,

thorough,

and included very detailed

root causes

and causal

factors.

The inspectors

also noted that the

identified short term and long term corrective actions constituted

a

substantial

improvement for controlling and preventing the release

of

contaminated

tools

and equipment.

The inspectors

concluded that the

licensee's

overall response

was commendable.

24

c.

Conclusion

Based

on this review, the inspectors

made the following conclusions:

The collective failure to perform surveys,

identified through the

58 items with radioactive contamination that were released

from

the radiologically-controlled area,

is

a violation of 10 CFR 20. 1501,

"Surveys

and Honitoring" in that "surveys that were

reasonable

under the circumstances

to evaluate

concentrations

or

quantities of radioactive material" were not made.

However, this

violation was identified by the licensee's

staff.

The staff also

identified appropriate corrective

actions

and implemented the

actions

in a timely manner.

Therefore, this license-identified

and corrected violation is being treated

as

a Non-Cited Violation,

consistent

with Section VII.B.1 of the

NRC Enforcement Policy.

~

Potential radiation exposures

to personnel,

resulting from the

improper release of contaminated

materials

from the

radiologically-controlled area at Susquehanna,

were minor.

~

Additional review/guidance is warranted for the survey of self-

shielding tools/equipment with potential for internal

contamination.

The licensee's

overall response

to the subject of "contaminated

materials

improperly released

from the

RCA at SSES,"

included

a

very critical self-evaluation,

was broad in scope,

thorough,

and

included very detailed root causes

and causal

factors.

The

identified short term and long term corrective actions constituted

a substantial

improvement for controlling and preventing the

release

of contaminated

tools

and equipment,

and the licensee's

overall

response

was commendable.

R1.2.2

Release of Mater Tanker

from the

a ~

Ins ection

Sco

e

The inspectors

reviewed

a draft

ERT report written to investigate

and

evaluate

the release of a water tanker from the

RCA (CR No. 96-0217),

inspected

various water tankers within the

RCA including

a visual

examination of the insides of a water tanker,

and interviewed

members of

the

ERT.

b.

Observations

and Findin

s

Water tankers

are routinely used to collect and release

lower grade

water fe.g., water with sediment

such

as service water or condensate

storage

tank

{CST) berm water] at the Susquehanna

Station.

On February

21,

1995, tanker no.

255216

was used to collect

approximately

1000 gallons of CST berm water.

The tanker

was brought

back into the

RCA to prevent accidental

release

of the contents prior to

25

sampling,

and

a radioactive material

label

was placed

on the tanker to

signify. that the tanker

contained water that required'ampling prior to

unrestricted

release.

On March 1,

1995, the tanker

was taken outside of

the

RCA, additional

CST berm water

was collected,

and the tanker

was

then brought

back inside the

On March 2,

1995, the tanker contents

were sampled

and found to exceed

the lower limit of detection for

effluents.

The contents of the tanker were allowed to "settle out" and

on March 7,

1995,

approximateIy

300 gallons of water were removed from

the tanker in order to remove bottom sediment.

The water in the'tanker

was then recirculated,

sampled,

and the liquid contents

were determined

to be below the effluent lower limit of detection

(LLD).

A survey of

external portions of the tanker was performed

and the tanker

was

released

from the

On March 10,

1995, the contents

were discharged

to the cooling tower basin in accordance

with approved procedures.

According to chemistry records,

during the period between April 1,

1995

through September

11;

1995, the tanker

was used four, additional

times to

release

water to the cooling tower basin.

These

uses

included the

following:

April 1,

1995, clean

system drain;

Hay 25,

1995,

CST berm water;

July 28,

1995, service water;

and

September ll, 1995, service water.

On September

14,

1995, the tanker was released

From the plant, in

accordance

with procedure

HP-TP-602,

"Survey and Release of Tools,

Equipment,

and Materials,"

Rev.

14, without an internal survey.

Shortly

thereafter

(the exact date is unknown), the tanker

was transported

to

New Jersey.

On September

19,

1995,

the tanker

was sold by the owner,

and

on September

21,

1995, the tanker

was cleaned

at Lancaster

Truck

Wash, located in Lancaster,

Pennsylvania.

On September

22,

1995, the

tanker

was transported

back to SSES.

Later, the tanker

was relocated

by

the owner to Montreal,

quebec

Canada.

On February

29,

1996,

a

radioactive material label

was discovered

on the tanker,

and the

discovery

was reported to the licensee.

On March 1,

1996, Condition

Report.96-0217

was initiated to investigate the failure to remove the

radioactive material label

from the tanker.

After questioning

by the

NRC resident

inspector,

the scope of CR-217 was

expanded

to investigate

the potential for the release of detectable

radioactive contamination

from the site.

During the investigation,

the

ERT identified

a similar water tanker

(255-12) that

was still in use at

'the site.

The tanker

was brought inside the

and radiological

surveys

were performed

on the tanker internals.

A deposit of material

, at the bottom of the tanker, similar to damp course

sand,

was found to

have

a direct "frisker" reading of 120 - 230 net counts per minute with

a direct frisk.

The site criteria for unrestricted

release

from the

radiologically-controlled area,

was

100 net counts per minute

as

specified in procedure

HP-TP-602,

"Survey and Release

of Tools,

26

Equipment,

and Materials,"

Rev.

14.

Short

and long-term corrective

actions

were identified. to prevent further release

of materials in this

manner.

These

included the following:

Secure

tankers with chain locks to prevent release

from the

protected

area;

Survey internal

surfaces

of similar tankers;

Inspect tankers for radioactive material labels;

Survey internal surfaces of used

drums outside of the

RCA, but

within the protected

area or waste accumulation yard;

Revise procedures

to address/clarify

the use

and removal of

radioactive material labeling,

and provide training;

and

Revise

procedures

to require that internal surfaces

of empty.

containers

(e.g.,

tankers

and drums)

are surveyed for radioactive

materials prior to exiting the security gate.

c.

Conclusions

Although the licensee

determined that the quantity of radioactive

material

in a similar, representative,

tanker was less than the quantity

that would be defined

as

an exempt quantity as defined in 10 CFR 71,

and

would not be classified

as radioactive material

per 49

CFR 173, the

material

was detectable

as radioactive material

using conventional

techniques

of frisking, with 120

230 net counts per minute (ncpm).

The site criteria for unrestricted

release

from the radiologically-

controlled area,

was

100 net counts per minute

as specified in procedure

HP-TP-602,

"Survey and Release of Tools,

Equipment,

and Materials,"

Rev.

14.

Accordingly, the failure to perform contamination monitoring for water

tankers with the potential for radioactive contamination of the tank

internals,

is

a violation of 10 CFR 20.1501,

"Surveys

and Monitoring" in

that "surveys that were reasonable

under the circumstances

to evaluate

concentrations

or quantities of radioactive material" were not made.

Subsequently,

the licensee potentially disposed of licensed radioactive

material

by inappropriate

release of effluents in excess of NRC

regulations

as per

10 CFR 20.2001(a).

(VIO 50-387/96-04-03;50-388/96-04-03)

Rl;2.3

Control of Clean Areas within the

Clean areas

are established

within the

RCA when providing drinking

stations (for heat stress),

when performing maintenance

on systems

which

interface with clean

systems

(e.g.,

heat exchangers),

and when extending

clean

area

boundaries

at the entrance

to the

27

a.

Ins ection

Sco

e

83750

The inspectors

reviewed licensee

methods for control of clean

(uncontaminated)

areas within the

The inspectors

reviewed

procedure

HP-TP-310,

"Posting

and Labeling," Rev.

15, condition report

nos.

CR 96-160

and

CR 96-289,

and radiation work permit no.

RWP 1996-

0090.;

inspected

clean-area

boundaries

at

RCA entrances;

and interviewed

cognizant personnel.

b.

Observations

an'd Findin

s

The inspectors

noted that health physics procedure

HP-TP-310,

"Posting

and Labeling," Rev.

15, Attachment A, included guidelines for the set-up

of a temporary clean area within a

However,

no clear guidance

was

provided for boundary set-up or contamination monitoring requirements.

The inspectors

also noted there

was

no standard

practice or procedure

in

place to provide clear

guidance

on required contamination controls for

work on clean

systems

in the

This lack of clear guidance,

in part,

contributed to the events

described

in condition report numbers

CR 96-

160 and

CR 96-289, written to address

inadequate

controls for preventing

potential

contamination

from entering into clean (non-radioactive

systems).

On February

13,

1996,

CR 96-160 was written when operations

personnel

loaded

Amer tap condenser

tube cleaning balls into the

Amertap system without contamination monitoring by health physics

personnel.

~

On March 18,

1996,

CR 96-028 was written when maintenance

personnel

were observed

working on the internals of the Amertap

system with tools that were not surveyed for contamination prior

to use.

In response

to these condition reports,

RWP 1996-0090, entitled "Breach

of Clean

Systems/Components

in the Radiologically Controlled Area," was

approved

on March 21,

1996 to control work on clean

systems

including

circulating water, service water, service air, emergency

service water,

residual

heat

removal service water,

and auxiliary steam.

The

RWP

included the following requirements:

Notification of health physics for a radiological briefing prior

to work on the

RWP;

Establishment

of a clean

area prior to work or inspection of clean

system/component

internals;

Personnel

contamination monitoring with a,.PCM immediately prior to

work;

I

Contamination monitoring for all tools introduced into the clean

area;

and

1H

4

28

~

No purple painted tools/equipment,

PC's or potentially

contaminated

items are allowed in the clean area.

c.

Conclusion:

Based

on this review, the inspectors

concluded

the following:

I

RWP 1996-90

"Breach of Clean Systems/Components

in the

Radiologically Controlled Area" included appropriate radiological

controls

such

as contamination monitoring and notification of

health physics prior to starting work in/on clean

(non-

contaminated)

areas/systems.

The licensee's

response

to CR-96-160, written on February

13,

1996,

was inadequate

in that it failed to prevent

a similar

occurrence

on Harch 18,

1996,

namely

CR No.96-289,

"Work on the

Amertap system with unmonitored tools";

and

~

The lack of clear guidance for control of clean areas/systems

within radiologically controlled areas

is

a weakness

which

. deserves

management

attention.

However,

no release

.of radioactive

material

was attributed to this weakness.

Recei t of Radioactive Haterials

R1.2.4

'a ~

b.

Observations

and Findin

s

Procedural

Guidance:

Ins ection

Sco

e

83750

The inspectors

performed

a review of practices

and controls for receipt

of radioactive materials.

The scope of the review included

an

evaluation of procedural

guidance,

a review of recent condition reports,

and interviews with cognizant personnel.

The inspectors

reviewed

NDAP-(A-0648, "Shipping/Receiving of Radioactive Haterial," HP-TP-650,

Rev. 2, "Surveys for Receipt/Shipment

of Radioactive Haterial/Waste,"-

Rev.

13 and NDAP-(A-0201, Rev. 2, "Haterial Control Activities."

The

inspectors

also reviewed Condition Report Nos.

CR 96-153

and

CR 96-180,

and interviewed

members of the Event Review Team who were assigned

responsibility for responding to

CR 96-153

and

CR 96-180.

The inspectors

noted that NDAP-(A-0648, Rev.

2 requires exclusive

use

shipments

to be received at the North and South Gatehouses,

and

prohibits exclusive

use shipments

from being received or unloaded at the

warehouse.

In addition, instructions

are provided for warehouse

personnel

to contact health physics

immediately

upon receipt of a

radioactive material

package,

and to i'nspect radioactive material

packages

for signs of damage.

If damage is found or suspected,

the

procedure

requires

storeroom personnel

to secure

access

to the packages,

areas

and/or vehicles

as appropriate.

The inspectors

were informed that

additional instructions pertaining to receipt of radioactive material

29

are provided at the warehouse

"offload" facility in the form of a 18-

inch x 24-inch sign entitled,

"Radioactive Haterial Receipt Process."

The inspectors

reviewed

a copy of this sign

and noted that specific

instructions

were provided for individuals to notify the health physics

staff upon receipt of the radioactive material, to suspend

un'loading

activities if damage is detected,

and to control

access

to the materials

to minimize worker exposures.

Condition Reports:

The licensee

experienced

several

events

in 1995 associated

with the

failure to perform

a radiological

survey

on

a radioactive material

package

as required

by procedure.

One example

was

CR 95-0440,

"Limited

quantity of radioactive material

was delivered to the effluents trailer

without an

HP survey first being performed."

Two additional

events

occurred in February

1996, in which there were failures to perform

radiological receipt surveys

on empty packages

with "radioactive"

markings,

and appear

as follows:

CR 96-153:

Februar

9

1996

Two SeaLand

containers

were ordered

from SEG to support

a first-time use

of the "Green-is-Clean"

(GIC) program for survey

and free release

of

materials.

Effluents management

indicated that

no radiological receipt

survey was required,

even after questioning

by the security

organization.

After processing

and entry into the protected

area,

"radioactive" markings were found

on both SeaLand containers.

Although

no contamination

was found during follow-up surveys,

materials with

"radioactive" markings were required

by procedure to have

a receipt of

radioactive material

survey.

Identified Root Cause:

Security Material/Vehicle Authorization Form NDAP-gA-0906-1 was

filled out as

"no HP survey required

based

on the assumption that

Green-is-Clean

meant non-radioactive material."

Identified Causal

Factors:

Inadequate

planning

and communication,

confusing nomenclature

(i.e., "green-is-clean" ), and inadequate

self-checking following a

prompt by security personnel.

Primary Action To Prevent

Recurrence:

Revised

NDAP-gA-0906 to require the security organization to

inspect the exterior-of vehicles for radioactive labels or

markings,

and,

when identified, deny access

to vehicles until form

NDAP-gA-0648-1 is completed

by a representative

from health

physics.

30

CR 96-180:

Februar

16

1996

An .empty sample container

(black pail) was received

from Teledyne

isotopes

at the warehouse.

Receiving personnel

failed to identify

"radioactive" markings,

and the pail was processed

and brought onsite

without a receipt of radioactive material

survey.

Identified Root Cause:

Receiving personnel

did not look for radioactive material

markings

on all surfaces of the package.

Identified Causal

Factors:

Black pail

samples

have routinely been received

as clean

(non-

radioactive)

packages

with radioactive labels

and markings

removed.

In this case,

the vendor

removed radioactive material

labels but,failed to remove

a radioactive material marking.

Primary Action To Prevent

Recurrence:

Implement

an interim corrective action to use colored stickers to

ensure

packages

have

been

checked for radioactive markings;

retrain warehouse

personnel

on NDAP-gA-0648;

and initiate a review

of package receipt program to include

a positive measure

to

indicate

packages

have

been

checked for radioactive material

markings,

and increase

personal

awareness

and accountability.

Although these

containers/packages

did not contain radioactive material,

and no exposures

or contamination

events

occurred during receipt of

these

packages,

an

ERT was

assembled

to investigate

these

events

due to

similarities with events

in 1995 involving failures to perform receipt

of radioactive material

surveys in a timely manner.

The inspectors

noted that the

ERT report included

a summary of previous occurrences,

event time lines,

a barrier analysis,

a cause

and effect analysis,

a

human performance

causal

factor review, actions to prevent recurrence,

and

a review of generic

issues

associated

with the receipt of

radioactive materials.

Also, staff briefings were conducted to inform

responsible

work groups of program changes.

c.

Conclusion

The inspectors

noted that procedural

guidance

and instructional

postings

provided sufficient guidance for the safe receipt of radioactive

materials,

and were adequate

to allow warehouse/supply-room

personnel

to

minimize their exposure

during receipt of radioactive

materials at the

warehouse.

The licensee's

response

to two recent

events

(CR-153

and CR-180)

involving the failure to survey

an empty package/container

with

radioactive material

markings

was very good in that the review was

31

thorough,

causal

factors

and root cause

were appropriately identified,

and corrective actions

appeared

sufficient to prevent recurrence.

Rl.2.5

Contaminated

Items

During discussion with health physics

management

concerning controls for

radioactive materials

and contamination,

the inspectors

were informed

that the licensee

had received

and subsequently

disposed of a radiation

dosimetry device, with low level contamination,

that was received

by a

PP&L supervisor during

a business trip to the Kursk nuclear

power plant

in Russia.

a

~

Ins ection

Sco

e

83750

The inspectors

interviewed several

supervisory

personnel

in health

physics to determine'details

of the receipt of this material, to

evaluate radiation exposures (if any) associated

with this material,

and

to determine

the present location of the contaminated

items.

b.

Observations

and Findin

s

The inspectors

were informed that in July of 1993,

a

PP&L supervisor

.

visited the Kursk nuclear

power plant in the Russia,

and

was provided

the following items

as gifts from officials at the Kursk nuclear

power

plant.

Russian geiger-mueller radiation, detection meter

a geiger-mueller

tube

two thermoluminescent

dosimeters

a new,

bagged

and sealed,

paper dust

mask (respirator)

sample

environmental air filter

These

items were placed in a box, brought back to the United States

in

luggage

on

a commercial air flight, brought to SSES,

and passed

around

to interested

persons for information purposes.

The items were then

placed

on

a shelf for storage.

At some point, health physics

technicians

suggested

that Russian officials may have different

contamination

release criteria than

used

as

SSES,

and that these

items

should

be surveyed for radioactive contamination.

Upon survey,

one of

the TLDs was found to have approximately

1,200 counts per minute of

fixed beta-gamma radioactivity on the surface of the TLD, as measured

with an HP-210 geiger-mueller

probe.

Upon discovery, this item was

brought into the radiologically controlled area,

and disposed of as

,radioactive trash.

Licensee staff reported that these materials

were not brought into the

radiologically controlled area prior to contamination

being found,

and

it was not clear

how these materials

became

contaminated.

Since the

contamination

appeared

to be fixed (not easily removable),

and there

were

no reports of personnel

contamination

by personnel

who handled the

contaminated

TLD, and subsequently

entered

the radiologically controlled

area

and performed contamination monitoring, the licensee

concluded that

32

the contamination

was fixed and no personnel

contaminations

occurred

as

a result of handling the contaminated

TLD.

In addition,

based

on the

low level radioactivity (1,200 counts per minute beta-gamma activity),

and short handling times (approximately several

minutes),

the licensee

determined that radiation exposures

would have

been less

than

one

millirem for the highest

exposed individual.

c.

Conclusion:

Based

on this review, the inspectors

concluded that radiation exposures

associated

with the receipt

and handling of the contaminated

TLD from

Russia

were low (less than I millirem to the maximally exposed

individual),

and all materials that were determined to be contaminated,

were disposed of as radioactive waste.

R2

Status of RPSC Facilities

and Equipment

a.

Ins ection

Sco

e

83750

The inspectors

performed tours in Unit I and Unit 2 reactor

and turbine

buildings, the radwaste building, dry active waste

(DAW) trailer, the

exterior grounds to the reactor

and turbine buildings,

and the

Low Level

Waste Holding Facility to evaluate radiological control boundaries,

housekeeping

and cleanliness,

and industrial safety.

The .inspectors

also toured the turbine building tool storage

area,

the

South Building,

Combo Shop, Effluents Garage,

Effluents Trailer, Route

11 Warehouse,

and the Susquehanna

Training Center,

to examine the

locations identified as areas

where tools from the

RCA were improperly

released.

b.

Observations

and Findin

s

Plant Tours

In general,

radiological

boundaries

were clearly delineated,

well

maintained,

and informative.

The inspectors

noted

good use of

informational postings,

such

as radiation dose rate signs,

"Do Not

Loiter," and

"Low Dose

Rate Area" signs.

Work areas

were well

illuminated and walkways

and aisles

were clear

and free of debris.

The

inspectors

pointed out the following discrepancies:

There

was

an improperly installed drip bag near the Unit I

'B'eactor

feed

pump, located in the turbine building on

676'levation;

The radwaste building 646'levation,

collection/surge

tank

pump

room,

was locked and posted

as

a high radiation area.

However,

the door had

a small informational posting with the words,

"Please

leave this door unlocked";

33

~

There

was

a yellow drum in the unit I turbine condensate

resin

regeneration

room on 676'levation with no radioactive labels;

~

Some radiological

and informational postings

on exterior doors,

from the outside,

to the turbine building were not standardized.

One example

was the laundry storage trailer which only contained

the phrase

"Radioactive Material,

No Eating, Drinking, or

Smoking";

and

There were multiple locations within the radwaste

building where

tools

and equipment

were observed,

within work areas,

lying on the

floor.

Upon notification, licensee staff took immediate action to address

concerns

raised

by the, inspectors.

Tours Outside the

During tours of areas

outside the

RCA, the inspectors

did not identify

any indications of improperly released

materials

from the

RCA, such

as

magenta-painted

tools, or radioactive material labels.

However, the

inspectors

did note that health physics technicians identified loose

smearable

contamination

on panels

used for the drywell control point in

reactor .building, which were stored at the Route ll warehouse.

These

items were decontaminated,

and the radioactive materials

were

immediately transported

to the radiologically controlled area at SSES.

Follow-up surveys

indicated that no contamination

was spread within the

Route ll warehouse.

c.

Conclusions

Radiologically controlled boundaries

were well delineated

and

maintained;

conditions of housekeeping

were generally

good with minor

exceptions

in the radwaste building;

and the licensee

took immediate

actions to address

identified deficiencies

including contamination

found

outside of the radiologically controlled area.

R5

Staff Training and Performance

in RPKC

R5.1

~Briefin s

a.

Ins ection

Sco

e

83750

The inspectors

discussed

worker briefings with the independent

safety

evaluation services

(ISES) group,

and observed radiation work permit

briefings conducted

by the radiological controls staff.

b.

Observations

and Findin

s

The

ISES group

had documented

a surveillance of workers'ctivities

and

the number of workers

who had received

a proper briefing prior to

working in the

The surveillance report indicated that

)

0

.34

approximately

20 percent of all workers were receiving briefings prior

to work in the

Licensee

management

pointed out that individuals performing the

surveillance

assumed

that

RWP briefings were required for each

entrance,

when many

RWPs only required

a briefing at the job start.

The

inspectors

were informed that Health Physics

Level II training had been

revised to clearly assign the responsibility for obtaining

a

RWP

briefing to,the worker.

In addition, the health physics staff was

reviewing

RWPs to evaluate

instructions pertaining to briefings.

The inspectors

observed

several

RWP briefings provided for work and

noted that briefings were thorough

and comprehensive.

The inspectors

also

made the observation that, in terms of human factors,

the majority

of maintenance

and craft personnel

enter the plant from the Unit 2

turbine building access.

The licensee

stated that future plans included

moving the health physics control point to the Unit 2 access

point.

c.

Conclusions

At the time of the inspection,

the requirements

for

RWP briefings did

not appear to be globally known by licensee staff,

and there

was

a

perception that required

RWP briefings were not being performed..

Licensee staff was addressing this concern

by adding clarifications to

radworker training and radiation work permits,

and by initiating plans

to relocate the health physics control point.

Radiological briefings observed

by the inspectors

were performed

by

health physics staff and were thorough

and c'omprehensive.

R5. I

Effluents Radioactive Naterial Handlers

a.

Ins ection

Sco

e

83750

The inspectors

noted that effluents radioactive material

handlers

were

responsible

for transporting radioactive material

such

as waste

and

laundry within the