ML20010E879
| ML20010E879 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/31/1981 |
| From: | Barrett L Office of Nuclear Reactor Regulation |
| To: | Hovey G METROPOLITAN EDISON CO. |
| References | |
| CON-NRC-TMI-81-049, CON-NRC-TMI-81-49 NUDOCS 8109080455 | |
| Download: ML20010E879 (44) | |
Text
_ _ _
DISTRIBUTION:
I l WHro-320 o
NRC PDR Local PDR TERA TMI Site r/f TMI HQ r/f L. Barrett August 31, 1981 BSnyder i
NRC/THI 81-049 AFasano RConte LChandler, ELD Docket No. 50-320 Licensing Asst.
ACRS (16)
DBrinkman Mr. Gale K. Hovey 0 Lynch Vice President and RWeller Director of THI-2 HDenton s,
l Metropolitan Edison Company.
P.O. Box 480 I&E (3)
GKalman Middlet?wn, PA 17057
(
RBellamy
Dear Hr. Hovey:
Mferenco:
(a) Technical Plan for Reactor Building Gross Decontamination (b) Technical Data Book Volume 2 Dscontamination Tec' ology 7
We have reviewed your react $r' building decontamination plan as outlined in the above referenced documents.
Our comments as well as those of our contractor, Battelle Pacific florthwest Laboratories, are enclosed.
Battella Pacific was used to assist in our review due to th61r experienc=
in decontamination techniques. The comments generated by these reviews are forwarded to you for use in fonnulating the final reactor building decontamination plan.
If you desire, both my staff and contractor personnel are available to meet with your staff to discuss the attached cumnents.
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Liko it. Barrott'T Lake H. Barrett Deputy Program Director TMI Program Office cc: See Service Distribusion ' List d
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e COMMENTS ON REACTOR BUILDING DECONTAMINATION 1.
Reference, Decontamination Technology, Sections 3.0 and 4.0.
The conclusions following the decontamination tests performed during reactor building entries four, five and six state that a comparison of direct beta measurements on the surface before and after the decontamination experiment is an effective method for measuring the effectiver..ss of a decontamination operation.
Accordingly, decon-tamination factors (DF) for these tests were based on the ratio of direct beta measurements before and aftor the decontamination tests.
The recommendations following u tse tests state that the in 4
situ decontamination test program shoulc be completed by performing a high pressure water spray test.
The recommendations again reiterate that direct beta measurements should be used to measure the effective-ness of a decontamination operation.
However, when the high pressure test was conducted to complete the series of decontamination tests, the criteria for measuring decontamination effectiveness based on direct beta measurements was not used (see item 2 below).
2.
Reference, Decontamination Technology, Large Scale Decontamination Test, Sections 2.0 and 3.0.
Using the decontamination criteria recommended in item 1 above (comparison of direct beta measurements before and after the decontamination test), the decontamination factor obtained following the large scale high pressure water spray test was 1.25 Your conclusions following the large scale decon-tamination test list decontamination factors in the range 20 to 30.
However, these decontamination factors are based on the ratio of smear survey measurements before and after the tests and not on direct beta readings. Smear surveys are very dependent on smear technique and therefore are not good indicators of decontamination e f fecti veness. Why was the method of computing decontamination effectiveness changed in the middle of the testing program? Addi-tionally, the target established for decrease the smearable activity to 10ghe large scgle test was to DPM/100 cm.
The conclusion states that all areas, with the exception oF the floors, had activity levels below the target value after completion of the decontamination Prior to the test, in all aregs except the floor, smearable tests.
activity was already approximately 10 DPM or below.
The effectiveness of the large scale decontamination test does not appear to have been evaluated in terms of meaningful criteria.
3.
Reference, Decontamination Plan, Section 3.2.2.
The recommended techniques for decontaminating the reactor building include low and high pressure water spray.
Based on the decontamination test data, the effectiveness of these decontamination techniques is questionable.
The test data indicates that decontamination with a strong decon-taminating solution appeared most effective. What is the basis for recommending the water spray technique?
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4 Reference, Decontamination Plan, Section 3.2.2.5.
" Chemicals will not be used on the 305' or 347'-6" elevations prior to initial removal of liquids on the 282'-6" elevation without GPU approval".
Ruling out the use of chemicals, which appeared the most promising following the decontamination tests, may be premature without first evaluating the ability of the Submerged Demineralizer System (SDS) to process the chemicals.
Compatibility of a chemical decontamination solution with the SDS can be tested using a resin column prior to using the solution in the reactor building.
Decontaminat compiled by the Electric Power Research Institute (EPRI) {on data indicates that a high pressure spray containing chemical additives is a more effective decontamination method than a hydrolaser with water alone.
This approach should be considered in an attempt to combine the speed with which the reactor building could be decontaminated using a hydrolaser and the decontamination effectiveness of a chemical decontamination agent.
If chemicals are used to decontaminate the reactor building, the effect on the SDS and on subsequent waste disposal should be evaluated.
The waste disposal evaluation should include problems which may be encountered by DOE when processing chemically contaminateddSDSiresins.
Also, if chemical cleaning is used, efforts should be made to obtain chemical agents without chelating agents such as EDTA or DTPA to avoid incompatibility with waste burial requirements.
5.
Reference, Decontamination Plan, Section 5.2.2.
Shielding recommendations in numerous areas were stated to be "less than general area levels".
This criterion is ambiguous because the sources to be shielded themselves are main contributors to the " general area radiation levels".
Shielding criteria should also consider trade-offs between man-rem for shield installation and the expected dose reduction during decontamination, i. e., a man-rem comparison estimate should be provided for the optimum degree of shielding for each of the recommended areas of shielding.
The term " general area levels",
should be completely defined.
6.
Reference, Decontamination Plan, Section 5.2.4.
The statement on page 5-10
" Frisking stations can delay time for exiting personnel, thus resulting in unnecessarily high radiation exposure" is inappropriate.
Frisking stations should not be set up in areas where there are significant exposure rates.
In thses areas the background is too high for effective frisking and personnel will be receiving unnecessary exposure while frisking.
7.
Reference, Decontamination Plan, Table 5-1.
The requirement of wet suits, two sets of PCs, two hoods, and multiple plastic boot covers may cause unnecessary encumberance of the worker, and contributes to inefficiency and higher man-rem because of longer occupancy time necessary for the job. When cumbersome protection requirements are prescribed, proper justification should be provided.
1.
Plant Decontamination Methods Review, EPRI NP-ll68, TPS78-816, May, 1981.
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3 or an alternative approach for the job should be devised.
Experience has shown that decontamination operations such as those contemplated at THI-2 may result in personnel contamination occurrances.
Thus experience also has shown that the results of such personnel contamination (with-the exception of facial contamination, where ingestion probability is high), using proper personnel decontamination techniques, are inconsequential, with whole body skin doses no more than a small fraction of the allowable 7500 mrem / quarter. Overzealous concern for personnel contamination should not be allowed to result in
'significantly increased whole body doses or to create industrial hazards by exposing personnel to the dangers of heat' exhaustion and/or heat stroke because of excessive and restrictive requirements Tcr protective clothing.
8.
General. Man-hour and man-rem estimates for each proposed decon-tamination evolution should be niade prior to finalizing a decon-tamination plan.
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f1RC CONTRACTOR COMMENTS ON TM1 REACTOR JUILDING GROSS DECONTAMINATION DOCUMENT
GENERAL COMMENT
S 1.
My comments are on the basis of a review of tfie plan.
I spent little or no time with the appendix.
In general, the plan is adequate for a planning documerit. However, there are many areas that I believe need to be embellished if this document is to be of the value that it could be.
2.
The ultimate goals for the gross decontamination are not wel1 defined.
There are some loose motherhood statements but basically I believe a goal should be established for each area that is being decontaminated.
3.
The storage of material resulting from the decontamination is to be done in the reactor vessel.
It is prudent to get this material out of what is already a crowded space and into some area where it can be more easily handled and will act subject the pe,rsonnel to further exposure.
It would be my recommendation that all materials resulting from 'the decontamination, be they pickup materials or whatever, be imediately removed from the containment building.
4.
There are certain areas which are designated to be covered over and left intact for decontamination at a later date.
This approach should be evaluated since decontamination at a later date may subjected the entire area to recontamination. Only those areas that are absolutely needed to maintain the safety of the reactor should be covered over during the gross b'uilding decontamination.
1
e 5.
Without sufficient detail it is difficult to comment on a technical p
base document. More infomation is needed.
At least an outline of what the plans are should be included.
6.
I realize that this is a technical base document and as such there is no organizational plan associated with it. However, I believe a technical plan must have include enough of the organizational plan so that it can be determined how the plan is to be implemented. This is not the case with this document.
l 7.
There are no requirements in the technical base document that historical infomation be retained and documented.
If there is going to be any ger.cric benefit, a document should be prepared which can be used at other installations.
For this reason I believe the technical base document must include some provisions for a historical record being kept of the effectiveness of the various operations, for example.
The decontamination director s'hould appoint a historian who sole dity will be to retaiis all of the infomation about the operational p'roblems that are encountered at the various stages of the gross decontamination.
A definitive report may be prepared at a later date so that an adequate transfer of infomation can be achieved.
8.
Some of the working goals are given in micro-curies per square foot.
This can be converted to milligrams or grams but the important thing the operating people will be 'looking at is the MR reading at a specific location.
Tlus, all goah should be given and as millirads or millirems.
9.
I fi d no recommended use of dyking during flushing with either low-pressure or high-pressure water.
We found that it was very effective 'in working vertical surfaces to dyke the area imediately beneath the vertical surface so that the water does not recontaminate the entire floor area.
10.
I see little indication that there is any redundacy being planned in the various ventillation systems which will t,e required during the gross decontamination.
Ventillation is key to any decontamination effort if you are going to avoid or control recontamination of surfaces.
A base document must delineate those areas where ventillation redundancy is a requirement.
2
- 11. Consideration should be given to decontaminating the reactor cooling t
system prior to doing hands or, decontamination following the gross decontamination. It is entirely possible that the radiation resulting from the cooling system will be so high that hands on decontamination may not be practical in many areas of the reactor fa'cility.
- 12. The plan of misting and humidification of the 280'6" level is unique enough that I believe more details are warranted in this document.
- 13. With the amount of plastic greenhousing anticipated it would be well to incorporate auxillary fire protection systems in the various areas.
If nothing else, portable extinguishers should be considered.
- 14. The technical base document spells cuc lighting and venti 11ation in general terms only.
Somewhere the specifics of what lighting and venti 11ation l
will be required must be addressed.
The venti 1ation requirement of l
125 linear feet per minute through-openings is an OSHA ' requirement and j
far exceeds that which, for er mple, the industrial hygenist requires j
in carcinogen hoods. They only require 85 linear feet per minute.
This might impact favorably on venti 11ation requir'ements.
15.
I noted in going through the airlock sketches that many of the doors j
swing in towards the confined areas. This is a violation of the fire
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code and consideration should be given to seeing that the doors swing out from the intennost areas.
- 16. There are many coments about shielding design.
In a technical base i
document you should at least delineate the areas where it is felt that such designs will be required and where the design capabilities are l
going to be found.
4 17.
j In those decontaminations we have conducted we found it absolutely mandatory to establish a design change process. Any time a piece of equipment was l
removed or added to the reactor regardless of how small or insignficant l
it might appear, a-design change was instituted. We were thus able to get the reactor back into an operable shape in a demonstratable and documented way during restartup. Consideration must be given at this time to establishing.a design change system to make sure that nothing is overlooked during the decontamination and restartup of the reactor.
- 18. The integration,of the waste handling and the decontamination operations was not very well defined in the document.
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Consideration must be given to steam cleaning in lieu of high-pressure a
c1 caning. We found that steam cleaing was particularly effective on cranes, oily pumps, etc. What was the basis for not considering steam cleaning?
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- 20. The technical bases did not provide any specific health physics followup;ff;
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this should not be left to a exposure control document. df terall, the gross decontamination can only be as good as the radiation measurement followup and also a great deal of work may be done needlessly if there is an attempt to clean beyond established goals.
- 21. Health and safety considerations during this effort are mentioned. That is about all they are, because they have not really been considered in each one of the phases of work.
It seems to me that this has to be recognized before you get into the details of doing the job, otherwise something will be certainly overlooked.
22.
In may opinion, the logistics of this operation have not bhen fully con-sidered.
In moving materials in and out of the facility should you be depending on cart and dollies or overhead hoists so you are not dragging a reel out?
There is a variety of similar items that I believe a base document should consider that have been overlooked.
23.
In all likelihood, there will be some areas in this facility which will be so " hot" that probably the exposure will be limited to, at best, a minute or two per day per man. On this basis some consideration should be given to the use of robots.
Such devices have been a very effective and even very' expensive, might in the long run, be less costly than buying manpower under those conditions.
24.
I do not see any plans for debriefing of the operators following their day to day decontamination efforts.
Such debriefings are vital in maintaining morale and acquiring operational as well as generic infonnation.
- 25. Shielding is treated with motherhood statements.
I believe that the amount of shielding required should be defined to a point of what reading are you trying to attain in that certain area, what type of shielding do you propose using, how is it to be placed and what are the design requirements. These
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certainly should not wait for detailed design before consideration is focused upon them. There was a brief mention in the document that cooling units could be iristalled in some of the suits where heat stress was likely.m.
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No evidence ytas found that consideration had been given that these cooling.^
units would require a great Aleal'more air p'eIperson per minutetidNonnb..[;;.E.*I
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respitory protection requires and also the effect on the ventillation system of having 4 or 5 people with these suits. working in a confined Trea ~ i'l~Cl might have.
- 27. Comunications were covered in rather a casual fashion; they were not defined i
for each, area. Two TV' cameras is inadequate for required surveillance.
'l Each area should have TV cameras and in fact there should be a network of I
them so the personnel in the reactor can be monitored d a*41 times for 3
l radiation exposure as well as safety.
Monitoring' will be covered in more detailed in the sections giving specific comer.ts on the' subject document.
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l SPECIHC COMMENTS The coments that follow are directed to -specific parts of the subject document.
Section and page numbers for each coment are provided to help identify that particular topic and part of the report being addressed.
Section 1 - Summary, Page 1-1 On the bottom of the third paragraph on page 1 the suggeste'd average target activity is listed as a 1/2 a micro-curies per square foot. To be meaningful
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this should be stated as millirads exposure.
S Page 1-l_
The fifth paragraph indicates that significant amounts of ' alpha contamination
- 4lOf have not been detected.
It might be well to define what significant amounts are.
Sumary - Page 1-2 The second paragraph indicates that the high-pressure spraying will be at less than two thousand pou' rids psi which is rather nebulous.
However, as you go above a thousand psi the spray will actually loosen large slabs of paint and peel it from the surfaces and this will probably further complicated the prcblem _.
of disposing of the waste water. This will be particularly true on the polar crane.
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- Consideration might be given to high pressure spraying of the prcmises with an organic which would evaporate rather rapidly and leave the material removed as a
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rather dry form of sludge.
This was particularly effective on the Redox crane wh'ere the paint had to be pealed off in order to get down to radihtion levels
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where personnel could approach the crane for maintenance.u-Irn f:.;6md:-fdduc:.n.d n.
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It might be well to conta'in the water fror. high and low-pressure sprays' behind g.c -
dykes. There is a possibility that the water might even be reused' rather than " ',~+
feeding it down to the 282 foot levtl.
The bottom paragraph on page 1-2 indicates that there should be a'dequateI vent-
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illation. Adequate does not really cover the required redundancy.
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Sumary - Page' l-3 This document should incorporate some mention of required documentation ~ to l maintain a historical record of the decontamination effort so that the industry.-
'may benefit from the cleanup operations.
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Section 2 - Introduction page 2-1 s
Hands-on-decontamination may not be possible following the gross decontamina-tion if the reactor coolant system radiation levels are high. One of the
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first considerat;ons that has to be given is that a chemical decontamination of the reactor coolant system may be required.
Introduction - Page 2-2 The first bulleted item indicates that the highly contaminated wat.r has been ',
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l removed.. processed.and.. returned. Some consideration must be given to how m
rapidly the material.in the sludge ' leached into the processed water so that,.[ :
,1 j there will be some feel for the time available to do a gross decontamination':Mhg depending on the shielding' afforded by this "cleane'd" ~ water. ' : D M+.[g.W i OE n.
sy The third bulleted item addressed air borne contamination; it is to be controlled 5
by misting and humidification.
Since there are no details it is hard to comment.
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We have not found this to be an effective way of controlling contamination at
\\ Hanford.
The fourth bulleted item indicates that the reactor cooling system is not con-tributing much to the radiation within the D rings. At least, the basis of this assumption should be evaluated _
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j The second bulleted item under constraints indicates that decon'tamination methods
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must not jeopardize the capability of a facility, component'or structure to 6
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- perform its operation or safety function. That may not be a very valid statement because certainly some of the units may be temporarily taken out of service.
For example, the polar crane might be returned to service after decontamination.
1ne third bulleted item seems to be a motherhood statement by saying the chemicals r-i.
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will 'oe kept to a minimum as they may impair the operation of the SDS.
It is -
,1 much more likely that they should be forbidden or if they are used they must be..,.
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contained so that they do not get into the SDS system.
Summary - Page 2-3 1
The first bull,eted item indicates a certain amount of flexability as being necessary during the decontamination phase but no mention is made of who
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will be capable of making decisions which change the planning procedures. T.,s is a cood place to delineate that very clearly.
The second bulleted item indicates that administrative procedures will be developed to implement the ' decontamination plan. This is backward; it would
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appear that the organization should be established first and thon they would develop a plan which they could implement.
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A fourth bullet should be added at this point to indicate the documentation, reports and papers that should be prepared and presented as a result of this work. The nuclear industry should share in the fruits of this effort.
Section 3 - Technical Consideration for Plan Development i
Section 3.1.2 - Isotopic Characterization d
The second paragraph indicates that tritium will be limited in the water 9
being used for decontamination.
In the accident ' water which is being i:lcaned up,,I this is not the case.
If it is not the case, then somebody should' consider that' ;.
the people doing the high-pressure spraying are apt to be icgged with this
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tritium containing witer. Tritium is easily absorbed into the body particularly if you perspire, so that special precautions may be required.
This becomes a health physics rather than a operational problem to ascertain whether or not people are being exposed to tritium.
This, cf course, can be done with bio-J assays.
Section 3.1.2 fourth parargraph indicates that sludge samples must be taken to determine that fuel particles are not present in the' reactor building.
These have been done and plutonium has been found in the sludge.
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s 3.2.1 - Technique Development _
Under operational factors such things as training, recontamination problems and.
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perimeter sensitivity should be included.
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Section 3.2.2.1 - 1.ow pressure water spray _,,
Water at 180 degrees can scald and, for this reason the upper limited should be _,
If there is not a great deal of infonnation regarding the temperature ;,_,,d, evaluated.
etfcct, this should be sought prior to the decontamination. Also, the possibility -
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~U of dyking these areas so that the water can be reused or it can be diverted'in N
such a way that if paint is conting loose it can be filtered prior to introducing it to the mate' rial at the 282 foot 6 inch level should be considered.
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Section 3.2.2.2 - High Pressure Water Spray Enough has not been mentioned about the physical hazard of using high-pressure
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water systems and particularly at the elevated temperature of 180 F.
The high-With the overlay'of high-pressure system by itself can be quite hazardou's.
temperature it is hazardous.
-l 3.2.2.3 Vacuuming U
The first paragraph is a little hard to understand, but I assume that it means...
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that the vacuuming equipment brought into the reactor building should be capable j
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Any vacuuming system introduced should be designed so of wet and dry vacuuming.
that the exhaust goes into the ventilation system so that there is no danger.', }. j,; N
..-~l-l of recontaminating the surfaces should there be a filter breakdown. - The fact
.Qj that the vacuum system contains high efficiency particulate filters is.of some
.s concern, because certainly in wet vacuuming they do-water log and fail. Also,',Q M.7-the wet vacuuming may not be very effective following high-pressure
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.."~~-'.c where there may be large sheets of paint which have to be collected.
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3.2.2.4 Scrubbing
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Yt is generally true where you have to use hands on scrubbing action you will require scaffolding; I will mention it other places in the report but it 9
We have found that we may be well to consider the use of hydraulic manlif ts.
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can get 30 to 40 foot elevations with these devices which can be run either from air
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The use of.
cylinders, building air or in some cases hydraulic systems.
mechanical drives can be positively dangerous if proper scaffolding is not used, and even then it can be dangerous.
I personnaly was almost pitched 8
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cff scaffolding using one of those devices. And of course, any of those u-
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devices increase the chance of airborn.e recontamination a great deal.
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Under cloth, wipes I. noticed that use of. a muslin cloth.In our deco $ta
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looked upon as A ' $sUo'nsideration.
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c we found it fairly effective to use simply the bailed waste clothes provided-
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to industry.-2
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On page 3-6 the first paragraph indicates that a rinse of the surface is required af ter using a floor scrubber with chemicals.
I don't believe this is necessarily
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There are some floor s'. rubbers that pick upihe material very effectively c.'{
the case.
and use a flush at the time,they are doing it.
I would look into that type ~
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of a machine.
q 3.2.2.5 Chemicals a
l It seems that this would be a reasonable good point to put into a section on
~
required administrative controls to ensure that chemicals do not get. into the.
w reactor vessel except under specific conditions. Again, I am concerned with
- . t'4
.o 180 F will scald. 5 j-;
the discharged temperature of the chemical sprays and foams.
w I also find it a little hard 'a accommodate.a residence time for a chemical spray p.3y 1
l For foam applications I would' encourage a look at th'e of up to an hour.
I believe that there is a limit ofi gg; requirements for air under those conditions.
. m m.m.,
30 psi rather than 60 psi, unless you have a pipe system with special' safety}.p y [g:y. i mgm;.,.,Q
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l conditions.
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3.2.2.6 Strippable Coatings l.
l:j I would certainly encourage the electrical powered rather than the air powered un because any time a st.rippable coating is sprayed on rather than painted on I have 2
the chance of recontamination of the nrrounding areas is very great.
seen great decontamination efforts ruined with a few minutes of trying to apply stip coating with a spray nozzle.
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'3.3 INDUSTRIAL. IlYGIENE
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This sector should be more appropriately called Industrial Health and Safety,N.a... ' JJ
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rather than Industrial Hygiene because the hazards mentioned here also concern @Pe;.'
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. industrial ' safe'ty"as well as health related matters me.W WE.1", J.~.'rr!z.td"MW
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This entire section is weak and probably should be worked over by a safety - "'-j i
professional or by a certified industrial hygienist.
However, I believe their f appraisal of heat stress il appropriate and cooling suits will be requirhd.' n"
'~
Again I caution as I did earlier that this ' requires a great deal more than theN 1
.:.e nonnal breathing air and can present some problems. Also it seems to me that if there is no elevator or hoist available for work on the 347 and 382 levels y
consideration should be given to providing hoists to get material in and out of The physical act oI carrying material can be both exhaustin6 as well as
~
there.
dangerous whin you are fully suited in radiation clothing.
/-
3.3.2 This section almost defies connent in as much as it is too loose-to be of practical value and full of motherhood and platitudes which really have very,
little meat or. substance to them.
I' notice that the GPU Industrial Hygienist Bulletins are in place and their adequacies will be reviewed.
I would encourage-work by a third party who is a certified safety professional or a certifi,ed v (c.
,.D Industrial hygienist or both to review and document their findings? ' y' '. ' I
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On page 3-9 it indicates that these procedures will be reviewed to ensure that.C.
all aspects of gross decontamination are covered.
It dcesn't say who reviews :
them, when or how he should respond.
It could be an operator and still be _ -f,.
legal according to this report.
This part needs b be defined more charly.
4
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3.5.3 Isolation Barrhers Elsewhere in the report fire retardent materials were mentioned but in.this.
particular section there does noc seem to be any concern with the fire hazards.
]
I believe in an undertaking of the magnitude proposed here, a great deal of care must be taken to ensure that fire will not wipe out all of the efforts.,
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..s, There have been many instances of construction fires in plastic materials
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and for this reason I encourage that barriers are fire proof or fire resistant.
~
The disposal of fire' resistant piastic presents a reasonable problem, be~causeT',T.~~;~'.m
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About.the only thing t, hat can be.done...,.m K "y./
obviously.it' can,not,,be' i.ncinerated.
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- with it is to ' compact *it. ' Also, a consideration for isolation barriers, is-
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that as soon as 'the barriers'are in place you have a change._in ventilation,.
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and you have a change in lighting. And both of these must be corrected.,
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....t do not see any mention on page 3-11 where they probably would be handled.
....3 The design of these units and particularly the design of the seal [to tiie wall -. :: -
becomes very complicated.
Obviously the first thought is tape.
In this case, '
" N where the barriers will be in place for a number of months and possibly years..ce,'
i taping should not be considered for holding the barriers in place. a.c.
I 3.5.4.2 Step Off Pads
/
~'
I have seen more problems develop from lackadaisical administrative control of step off pads than probably any other facet of the decontamination operation.
,j This is an item that has to be " nailed down" and at one time I can recall that we had to make it an offense subject to discharge if anyone crossed a step off
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pad without going through the, appropriate procedurcs.
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g3 3.5.5 Waste Generation L..
.*? Q 5y It is not sufficient to identify the sources of waste; you must also 1,de' e
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Otherwise it is entirely possible that waste will,be i,
the disposal methods.
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generated which has no acceptable disposal. method.
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The fourth bulleted item indicates that 125 linear feet per minute will be m
I know that this is the NRC Standard but as a safety :,- Wn.(:l: n e
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required at openings.
professional and an industrial hygienist for many years I feel that this' level....V-In many instances 125 linear feet per minute will estab'lish' eddy '
is too high.
currents at the corners of the openings which will actually pull material out into the area which is to be clean.
It seems to me that the industrial hygienist...
have taken a better approach and are using 85 linear ft/rmn. even in hoods containing' highly carsinogenic material.
Consideration should be given-to asking.
f for a waver for the 125 linear ft./ min. requirement.
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4" 4.0 Gross Decontamination Plan '
p The third paragraph defines a number of areas which are considered in the gross l
i -
decontamination'pl.an? I believe that additional items should be~ added,'~one w'aste handling,;c'ano.ther fo.r logist..ics and a third one for sa.fe..ty.v.;The lastha..=.;_m.,,:., g w
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paragraph on page 4;l.really does not indi.cate any need for infonnation transferCM. IL,
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~or the maintenance ouecor,ds. And this might be again a good placelto have some{
. '.,...n :1 L requirement for the maintenance of jom nals and etc., so historical data can~~
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l be dug out when required.
It might be well also to have a safety professional ?~ J. ~ f or an industrial hygienist aboard during the gross decontamination' to handle L
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unique safety as well as certain unique health problems._...
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i Step One - Installed Enclosure from Personnel Airlock #2 to Enclosed Stairwell #2 2 a n
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Under the discussion of the step sequence it indicates that the area trash pic.kup
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E will be stored at location'#4. " I would encourag'e that this material" be moved 9
immediately because it will o'nly be in the way of future decontainination efforts.
If it can be taken outside of the containment vessel it will be much better for the J,;
I entine program.
I also. note that the drains are to be checked for proper operation but there should be more detail.
Is water to be run onto the floor to see if the,
i It'.[.".[.
floor slopes in a particular direction or is water to be run down the ' drains?...
O w
has been nly experien'ce that the American construction worker will always see that..t the drain is the highest point on any floor.. This may require additional work '~
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for the planner. Again I encourage the use of dykes to. control the flow of.D 75%
waterwherevernecessary!-
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I am confused about the interaction between the third.. paragraph from the bottom and; w w.,.m-g - :y.g.g.,3
. n.n the first paragraph from the bottom where decontamination.at the 3051 eve 1 1,sygg ;-
going to run onto the ceiling of the 347 foot level.
Specifically under drainage 7 "
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it says the roof of the enclosure (assuming they mean the 347 foot level), should j
be designed to allow shedding of water that may drain on top of the enclosure' n,.dic :{
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during the decontaminatica of the overheads from the 305 level.
I'must be j
missing something the're.
o What are the plar.s for assuring water control within an area? For example, it 1
is easy to say th'at the floor of the enclosure should be designed so that the
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water' will not collect as a result of liquid flows from the surrc nding areas.
but just exactly how is this to be done? The design of a constructed building :
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.C page 4-3 Support Systems".v.s.
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.. - - - Besides process' water.. air and electricity, ventilation,should b'e includ'e'do,.,.g.,,,s,
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' The airlocks ard frequ'ently overlooked and they' can become sweat' bixes~'tInlysi[Ef
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they are appropriately ventilated, particularly when changing clothes; there's '
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considerable activity, there's a number of people in a relatively smal,1 arcayQ.j'I i s
and body heat generatea, voless it is removed, can create a real problem.-
Figure 4-2, Step One - Enclosure from Airlock to Stairwell-... f f;; J_'.
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Item 1.6 requires hosin[of the overhead piping, ducting and electrical trays.'.I.' /
I assume the power has been, turned off the power in those areas. Also unde s m-1.8 - 1.10 there are some design considerations which should be,noted. Also, '
- )
in the write up I did not see any end points or survey requirements. These -
should be delineated in these steps very clearly.
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Under 1.12 the airlock between section A of area 12..This should read section Cy;$';'h rather than section A.
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Under discussion of step sequences I believe it should.say that.the poser mus M p.
x.~. u.-,.c be turned off and it must be ascertained that it is off in the elevator '.,
b.
machine room while it is being decontaminated.
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-. N r,., i In the second paragraph under discussion of step sequence, it is indicated that.j,by painting the walls would' control' the spread of decontamination. This might wellf.,,3. j be but I believe that.at this stage of the program, strippable coatings should %.
be used in lieu of paint.
If you do get into a painting program, it is well
[~.
to consider that you may have a craft problem while the application of strip ~
coating can come under operational techniques.
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In the discussion o.f step sequences in the third paragraph, pads' are to placed ~, Q... op on the stairs to help keep the stairwells free of contamination..Does this mean' 1 g
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step.off pads or sometype of walking pad'l If you do I would highly racc=.:.nd that again you go to3Eipcoat bhcause you can always cut out a piece of stripb-- -. T
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coat and reapply if if'it becomes contaminated.
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'Under special considerations I note considerable concern about the continued '
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k,- idecontaminati..on after...tpe'.h,a.--. -rrier,,.has been set.in place.p Considerations
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- - be given to designing a U trTp or_P. trap.which_would alloV continued,draina
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P in the 282 area and still trap the liquid and contain the contami,natio'n in'the *.~ *
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=-m.x : - 3 28'2 level.._-.~;.,
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Under special considerations and shielding I believe the type of shielding expected. 7 t to be used sho'uld 'be identified.
It might very well be that.5 gallon water cans,w ev -
l
~ stacked up like a b'rihk wall might be effective. We found this to be particular1ye--
effective in several of the decontamination efforts that I have been involved ' ~
s.
/'.
One of tiie a'd' vantages of this is that the water is readily disposed and, t
with.
of course, the cans can be,<: rushed flat for final disposal. --
f Finally under special considerations I believe yoiu have to co.nsider.ventila, tion l
along with process water, air and electricity as being part of your support systems.
Figure 4-3, Step 2, Decontamination Enclosed Stairwell l'
Item 2.4 - Be sure that the power is turned off. in the elevator during the a,
decontamination and the circuits are meged to make certain.that they are no i
.[
longer going to ground because they are wet prior to activating the system.F
_.S f Also,.under 2.5, were you planning on hosing the area with high-pressure spray? s The elevator machine rooms that I have been familiar with ge'nerally are fa
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greasy and the impact of grease on the SDS system should be ascertained beforeff l
hd.@hy:dMdC,. M l
you add this to thejater,in the 282 level.se,,}.; E N, z-Q n
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Under 2.9 I think consideration should be given to.the safety of placing 'pa5s l
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If these become loose they can present a tripping hazard and it;. ' g'7%
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on the steps.
ris is much better to have a strip coating than it is to place individual pads on..~.q s...
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the stairs.
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i Step 3 - Decontaminate and Enclose the Area Around the Stairwell No. 2 Door.
4
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l This particular step seems to me to be somewhat in conflict with Step One but 1
t maybe I really don't understand the program.
Discussion of the Step Sequence Again the waste is being stored in the containment vessel and I believe 'this material i
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should be brought out as scon 'as possible to reduce expcsure and provide more room to operate' -
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Under shielding ~at the ISottom of the paragraph the level of decontamination _ g;g.g'jpg FJG required'should be del.i.neated.-.If it is a beta problem, it is possible,l of*M.. -
c.ourse, to shield but'again'.the' required level should be delineat
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' Undei supporIs"ysTem,s,' ventilaEion and comunications should be added'to ~pioce'ss6d.d m.
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water, air and electricity.. --
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Step 4 - Gross Decontamina' tion of Polar Crane Access
~ 7 7'N Z
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I'believe that.. consideration must be given to the physical condition of the cre0.T.yf 3 used in this step since 'it will have to climb the 241/2 foot stairs plus a y M.,r,J:-
4'O foot ladder'to get in,to position.
In protective clothing this can be most
^[3
~
~cxhausting and you could very we.11 have a fataliti unless one has a well acc.limated --C and physically sound crew./ Again I would encourage you where possible to use man N lifts to get into your position.
Use of manlif ts will also allow you to retreat,f from areas of high exposure in a relatively rapio fashion.
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Under personne1' access I sould encourage the installation of a hoist,on. the 41[.'g crane as soon as possible to facilitate getting equipment up to the are'a toTht6 l.':
. n..,.au v u.! +.Q carrying $v
- 7,l be decontaminated.
It is most difficult to climb a forty foot ladder,ki$n'ih k
or pulling a variety of material.
In fact. -if I were the decontamina
..:.e e a.A.. W 3
director I would make it the first order of business 'after a bridge had been Q'
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.. n established from the crane to get an adequate hoist into place to bring. iip M
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the hoses and the other equipment that will be required for decontaminating this
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Figure 4-5 Step 4 Gross Decontamination Polar Crane Accessf.' ;.
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My general impression of this whole step is that you are planning a greatyQ
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.w deal of hant, on decontamination.
I am not certain that this is going to,begf..
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the most effective from an ALARA standpoint.
From personal experience I know M,em..,'W.
that the water wands 'and remote decontamination can be very effective when compared!. -
...,..1 with hands on methods and are probably as effective from an exposure and a cost' '
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'V Step 5 - Gross Decontamination Polar Crane Rails as Required.
There are no illustrations of this and I believe it is vtay important th'at you
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rails so that you can ascertain what p'roblems:-Q.g,p.
get a cross section of these.
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o g might be associated with decontaminating the rails as tell as the ' areas behind them and around them and whether or not there has been corrosion in this area
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It is possible that contamination may have settled in behind tiie
...,-:.'0' or not.
rail which would cause some real decontamination problems.
This whole problem v:.a4 :(
~
has been given cursory consideration.
Whether or not to operate' with th'e power i::_d 7,....
w,,.. w a.:.:w 7:
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'off, which of course has to'be done 'is not indicated.
Also th,e..re i:s no in. n c c. d
. ~ '
dication that there will be a ~ requirement to look for corrosion and inspect thed,gr electrical systems for continuity and integrity. This was one of the poorest, '
..j sections of the document.. It may very well be that in order to decontaminate 1.?.y the rail you will need an auxilary motor to drive the polar' crane 'so you can' ca m '."
I get around in all areas of the polar crane rail.
,q F_inurd 4-6 Step 6 Gross Decontaminate Polar Crane Activity 6.2 requires cove' ring critical components of the crane to prevent
- damage by water splashing.
It will not be very pioductive since there has been " rain" in the containment vessel for some time; the crane more than likely has been damaged as much from water as it can be.
Also, if the exposure permits it would be ideal to flush the dome and sidewalls while on the polar crane.
Thus, this other flushing effort would not recontaminate the work already done at a later date.
At the bare minimum, the potential from.
the dome should be assessed at this ~ point.
' ". '. '4
~.
It would seen to me that steam cleaning should be considered for the polar crane.
because this would provide a reduced volume of liquid and still give a fine.d.. 3..,
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- y, method of cleaning on a fairly greasy piece of equipment..
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~ bb Step 7 Gross Decontaminate llorizn.Lal Surfaces on the 347' 6" Elev
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I do not understand why one would attempt to get just the horizonta..l surfaces? It*C would seem to me to be productive to get the horizontal and the veritical,because".%
v-,.
. v...... fu 5 as you wash the horizontal surfaces obviously the material will run down t
,Fs @>
t vertical surfaces.
Also, I feel that the general trash picked up should be,.'C ". N nh w.
removed and stored at location 1.
It would be well to ensure that the drainageY: ~.I is adequate towards the floor drains as well as the floor drains being opera 3 tional. Also under the support systems I believe that ventilation, lights and[.
conmunication should be added.
~~
Step 8 Gross Decontaminate Exterior of D Rings.
~
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Under the discussion of Step Sequences it might be well to consider using manlif ts to get the personnel into position to do spraying in this are'a.
16 j
f
i Consicheration should be given to covering components of the fue'. nandling.
^
~
bridge crane to insure that no further damage occurs.
It seems to me that you.
- .J would want to have this crane cleaned in the open.
It has aircady been " rained"
4
-...W on for many months and the.refo.re it woul.d be productive to.. decontaminate as my;-. 3
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further damage is 'unlikely.liIn a'n'y~: cient' before' the crane. is activated the ele-WNb
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. critical circui.ts should b'e megged out. m. m 7. r....,
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Figure 4-8, Step 8 - Gross Decontaminate Exterior of the Rings.-
m.
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x Activity 7.12 calls for trash to be stored within the reactor containment vessel.M;;..'
I believe that. this iis a mistake.. It is much better to remove trash both from
-* =~c a safety standpoint and the fact that it will cause further exposure to personnel.
.2 in the area. Again, the levels or goals to be attained have not been stated.,..'.#.5 This is important; I brought it up under the general considerations, but I 7. ':.c. a believe it merits repeating at this point.
1 Step 9 - Gross Decontamination Refueling Canal, Step Sequence Discus _sion._
c-.-
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7 Decontamination of fuel handling crane bridge and reactor head control rods is
+
performed by a low-pressure, hot water flush. Steam cleaning should be con -
sidered and also the levels to which they should be cleaned should be noted.
Under support systems I believe lights, ventilation and comunications should be, e
added.
. e..._
Figure 4-9, Step 9 - Gross Decontaminate Refueling Canal.
- 3. :
Something should be added to indicate that the p
'p of the fuel handling crane.
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e ; 9 :. n s :.
Step 10 - Gross Decontaminate Open Stairs to the 305 E1e'vatihn.[Y,hh.hhh.!
hh Again the acceptable effectiveness for the flushes has not been identif..ied.,I% *g
- . y...fy t.;w.yy:y v..l Ee.1
.~
would also recommend the using of strip coat in this area to protect it rather.M,. '_
than using paint.
Under support systems ventilation, lighting and comunication' [
- ",$1. M ~ -h'~ '. f.h., '.
Y should be added.'
Step 11 - Seal off the 347' 6" Elevation.
Discussion of the Step Sequence.
.1 Ratner short mention is made that the air flow will be interrupted through the D ring when these openings are sealed off. The impact ori the ventilation through-g.,
out the facility could be significant and should be discussed. Alsotheeffect'W$
of sealing off the remainder of the opening such as the seismic gap' and the
~ ~
.... w 17
- 1 *J**8,
+
l y
-c
- 7Q
e r i
i i*
s diamond plate grading could create ventilation problems and certainly these i
e
' ~
should be discussed in a base document of this type.
2 _
Step 12 - Gross Decontaminate llorizontal and Vertical Surfaces on 'the 305 -..,ys.A c.F
,..... q l-Elevation._
2..
.:uw'. e=:'A:aW'=2&....
s
._......-m.,
- w?..=v.,;-7 a i %.
l i.
., c L-Under discussion of steps of sequence, again I believe that the, trash should #m M t
..;. 9..
..a..
- . a n ;
- .- w.y W
be removed rather than stored at location 4.,,,
~., w. ;...
Who will detennine what cSponents have potential for damage by water spray?.......W.;
It seems that these areas have been pretty well wet down already.
Plus the. r.. ;% :.1 l
fact that when you cover an area and have to comeback and decontaminate it latern m.-- H on this creates some problems.
I believe that this should be considered in the a-technical basis document and a discussion of the problem of getting these areas n.,1 W
decontaminated at a later date should be worked on.
/
It is entirely possible that the' equipment'is loca'ted in Seciton A will have more internal radiation than woul'd be flushed off the exterior.
Some thought should
~
I be given to taking care of this problem.
The bottom paragraph on page 4-16 indicates, that the air coolers will act as plat-forms for flusing air ducts etc.
There may be safety hazards associated with that ..y approach and possibly the installation of guard rails should be contemplated to %,%.,'?
be in compliance with OSHA codes.
. 4<l $ $
4;; a.
i On page 4-17 the first paragraph indicates that the platfonns around the core /?'.b.M..r,.
' flood tanks allow access for flushing.
Consideration should be given to hydraulic WW a.q t or sneumatic air lifts get people in place to perform.these tasks.' G - @#. --F;6),S.O y.
- 9:u?xy Unde 1pport systems lighting, ventilation and communication sh'ould be added.D Me i
. p:.;
[.% g. u.-;.}p *,[ ' y,'"[
Step 13 ical off 305 Elevation.
~
J.'. N.g-No consent.
^ f '. J.N ?'J'.M. g',,.. 3
- y.,
e 4.
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Step 14 - Buii Staging Enclosure at Equipment Hatch.
.,;q..,.,py
',V ;..
- W.;
- D.,.f. W Under support se tions add ventilation, lighting and comunications..-
F Step 15 - Gross Decontaminate Inside of D Rings.
Discussion of Step Seg'uence..
}
It seems to me that the safety of the operations contained in Paragraph 1 and 2 has not been fully considered.
Some sections should be added that are devoted 7,. ( _
to the safety aspects of doing these. operations. Also, under support systems # W lighing, ventilation and communications should be added.
t
~ l
.n
..c-T 18
[
s
, _-._sm&i4
)
3 s
1_
i a
.g Step 16 - Gross Decontaminate Inside Elevator Shaft.
Discussion under Step.
~.e.
.Z
.~4
~ ' - ~ -. x !
Sequence _.
-., w ~ ey z
. - L v.. --., - - -.
w:-a,.A,,
-.~
tro e.cl
. This is m,o.stly motherh.o. o.,d,nand th.ey. haven..'r.t...re. ally ~got d. o.wn' to th,e,.v".n.~i t.ty gri t.t..y."
nw r.
ma..
..-r.
...t-of looking at this problem from a practical standpointZ. I.beliqve that this
- W'*
~i whole section needs to be redone and rethought before. it.would be acceptable'.~.s,3,....a;.;;j
.-z..-
r...;-..?O.]
l Step 17 Drain Sump Shield Water.
Discussion of Step Sequence..-..r.
.~.
1 believe that some consideration should be given to slurring this material '"^,j'i ',q l
while the water is being drained. And by placing it in the slurry and moving-'
it through a filter cask the job of sludge removal later might be simplified. [A.h ".v.. ^
Also under support systems ventilation, lighting and communication should be
~
added.
.J Figure 4-17 Step 17 - Drain Sump Shield Water _.
i Activity 17.6 indicates that a small opening will be made in the.. isolation- - - --
barrier.
It would seem to' me that it would be appropriate to install an airlock at this time to make certain that there it not an air flow rcversal.
1 Step 18 - Move Sludge Away from Stairwell Number 2.
- f. 6 ' %. * *. ':
s I redlize that from step 17 i.hrough24 there are some problems that are not '?T,'M'N
-zu fully known and/or defined and therefore it is very difficult to make plans.. A.;.f..:-
In this particular plan the thinking is alright but I believe there are basic J. ~..m m.
g.'. Q details that are missing and should be added. Undersupportlystems','bicath'ing3;g,r,p.
. m.
,. w. =,.M ig l
mc
-- v,.>.
a.?,
, ir, lights and communication should be included. Also, I.f.ind it difficultM,VPt'&.
\\'
a
... r., u,. c..%
p.
to understand why the sludge would remain.in section C and'D and, that.it wou
~
~F
...., p. :.
a..... a.r.t.p.2,,.,
q,
~
be reasonable to installing dykes at a later date.
Dyking should be..'u g.e con-S don p
s.w
~
c
,w currently with the wokk.
Design will probably influence how this 1,s don _e,e u,andj$ g.;g probably should be noted in this document.
..' ' ?;.'s " ? ".
d.
- .y S_tep 19 - Gross Decontaminate Stairwell Number 2 to the 282' 6" Elevation.M l'. :.d..E d V,.'h;.' ;..'
j...
The objective calls for the area to be realitvely free of contamination. However, I believe that an en'd' point must be established at this time., Also,'un' der the -
discussion of step sequences I again see where painting is to be used.
I would recommend strip coating because it can be applied by operational personnelQ,,., [.y :
With painting one may 'get into a jurisdictional dispute with crafts.
I think'
]
that painting should be done only if radiation levels are so low that it.would be a final operation.
Under. support systems, communication, ventilation and.,_;,cy,
.O.-
19 N
.=
,Q
^
'^
l-N.
h should be added.
In my experience it is y,;-
e
, strip coat and possibly cheeseclot
?-
?
~ itell worth putting'~ strip coat on with a layer of cheesecloth under it
~
l ease of removal at a later hte. Th'is is' particularly true if the strip coat -
~'Y-
' " ~ ',
,[G
,a is lef t in place for~ several months. -
.A Step 20 '- Isolate' Staging' Area for.282', 6" Elevation...
. :Je hw.-.ma 4 Z * ~
m.
- u..
.n L :1~ - ~
p.-. g.g
~ - -
that the trash shouldy s-nny a
. Again I feel that under the discussion of step sequences be removed from 1_ocation 4 inmediately.
M.C In the second paragraph it indicates that liquid generated should be
...T e
7
^"N
._ I believe that we need to take this a step further. -
with a wet vacuum system.
What is one to do with the wet material collected?
J
.. j;_
The final paragraph on page 4-26 calls for installation of enclosures ove
'~"
This will perturb the ventilation and could create some real staging platfonns.
On page 4-27 the first paragraph indicates that'
/
problems should be considered.
My experience leads -
it would be a simple matter,to' install a sludge barrier.
- ~
me to believe that it isn't simple and that the design of the sludge barrier Under the special considerations subsection 2
should be considered carefully.
it and on shielding I believe the logistics of getthg shielding into place, removing
'. n.
}.,
decontaminating it (if necessary) at a later date should be looked at during On page 4-27 under.
]
the design stage to insure that one has a useable product.
$(, ' f[.q drainage it indicates that the roof should be designe Generally speaking there see drain on to it.
it should be routed to a given point?
is uncovered and I[reaiik( Q
, great deal of work done in this area while the sludgeBut basically
~ ~ we.su ; m l
that these are tenative plans.
l active the concept may have to be revised to accommodate realistic expo l
3.jy;Q.'g.Qt,Q, x4,
, z' ' ~ r.gg',p;
- %.).
.m, Step 21 - Remove Sludge From Outside D-Rings.
n;; ?.M L
%~
In the step sequence subsection consideration should be given to the us j
I don't like to see personnel working from floating platforms, particula
. : ~. w. 4 =;,
Certainly the safety of this approach should be analyzed,e robots.
~
in high radiation zones.
The vacuuming of the sludge may not be practical because control of i*-
carefully.
the vacuum wand requires some hand holds reasonably close to the vacu!
the sludge passing the operator at that point there could be unacceptable expo The final paragraph on page 4-28 indicates that following sludge remo
~
It seems.. ' l spray should be activated to flush residue off the walls and equipment.
f to me that this should be done before the sludge is removed so that you won't
^ d' :
. )...h.
..w.
-m6 Awe'**v * '
Rm L
mee m.-
1 i
s j
Generally speaking in this entire l
going through the. exercise a second time.
section it appears to me that the logistics of the operation have not been completelf.
thought out and probably more time should be devoted to.tae precise movement of o < s 71 e
.,,t l
-r
- d u ^
~
material and men.1 ' '
s
" i ',t.
,c.-Myq'
'A
- 7... ;. ;. c.,
.;; v,,
~ J,. ;... n. P "" "
'd A
~
Step 22 - Gross Decontaminate Area Outside D '- Ringsz-. - -.
Again I do not see why the debris is collected rather than moved out of the <-'
.j i,
c containment vessel. Again, the radiation levels have not been determined at the :.
. i point the strip coating need's to be added. 110 wever, it occus to me that strip j '
l There coating an entire lower elevation like this might be counter productive.
are certain tiines when it isn't that much more difficult to reflush an area.' ~~
'}
.s.
And the removal of strip coat is not an easy matter particulary af ter it has been in place for some time. Lights, communication and ventilation abould be added to the support systems subsection.
Step 23 - Remove Sludge Froin Areas Inside D-Rings.
The discussion in the step sequence subsection is so tentative 5 hat I cannot connent at this time.
Step 24 - Gross Deco _ntaminate Inside Floor Areas of the D-Rings.
l In discussion of step sequence subsection it says liquid that has been collected,,
from these decontamination operations will be stored in location #3 until it isi.,
i, removed from the reactor building.
It seems to me that this is a," cop-out"
. ' '. ( C. ' - [
because this liquid is going to have to be treated and is going <to have to be G..;y T.
P
~;,..,,,... g m
~
J moved to some location.
It will likely be highly radioactive.and it certainly L 7..
.+'.q l
..t
~...... '.
should be moved out of the facility so that extra exposure tii pers'ons working' J i.f Rj MN/jh; M..a,.:~:/
??!-4
-a w
. y Q f. m in the area does not occur.
1
..: g r y M : n ;.
- .L
. v.
, c. y y9 h ! g n.. t ;y s
Figure 4-29_
-l,
,y.
~'
The door swings of the airlock should be checked to make sure that the doors fj 1
~
swing out from the enclosed areas to meet fire codes.
,o 3
g.,
- a.,-
,.T nr ;,^:'
' ~ '
?
~ '
Figure 4-32_
9 The isometric drawings shows that there could be a free fall out of the door-to the left of the stairway.
If this is the case maybe the door should not be placed where it is.
0n the other hand, I may be misreading the drawing.
j In any event, the door opening is 5'5" which would be a real " head knocker"
~
for the average operator.
S i
e 21
~,
A
.__..,m._m
Hgur'e4-35 5'gaincheckthedoorswingstomakesuretheyareincompliancewithfirecodes.
Table 4.1
~..
- i
. l..,.
I believ'e the items which are covered should be very carefully reviewed and;.
.s
- ., rJ.
r
. s.n. c.a.. a.,... a. x.w,
- -. ~
..should be only those ~ items which are required for maintenance of core safety." gg p' 0,therwise, decontamination at a later time will create additional problems..i.21 y c..U..E
..L -
It is much simplier to take every thing in ahead of you when you are moving 2
in for your initial gross decontamination.
It will be necessary in many in. --
stances to cut the electrical power temporarily while the flushing is in progress.-
But the electrical circuits can be meggered at a later date and reactivated when they have dried out appropriately.
Table 4-1
.i
/
~
There are many painted, surfaces that are being flushed with low-high pressure fluids. There are some areas where the paint may have been burned.
- It' might be useful to list those areas in the table so.that appropriate decontamination methods might be used on those surfaces.
Section 5 - Implementatior, of Support Requirements 5.1.2 - Waste Categories
.J
~
- v tiotice on page 5-2 that polyethelene sheets are proposed for use.
Fire' 7 3
'. [: '
retardent material sh'ould be used.
4-
, [.Nb}?- Q 5.1.3 - Waste Transport.
',g:fQf.y.),4:s c
,t
.. - '... r. ;. g. ~,
This subsection might be expanded a little bit to provide some indication of:/:T..; d -S
-t
.e f,N '.;:Q.? j. 2}.
the various. liquids leaving the building.
n- -w:
g g.
~
~ ' A. ~-l/ ly.
3 n ]y.."p. y 5.1.4 - Waste Processing
~. -
Under gaseous waste it indicates that Krypton and tritiated water vapors
~
be vented. An estimate of the amount should be given at this point in the document.f.'
2..:,f' c ^.
' T 5-
~
Page 5-4, t.ast Paragraph lias the DOE agreed to' accept this material for ultimate disposal?
5.2.1 - Personnel and Equipment tiovement
. p.':..
I do not see any provisions for debriefing personnel or a command center having
- J~
T.V. surveillance of the entire facility.
.g
."['ic, 22
/
r.
,1
.\\
C
.1
'Py e;5-7
~
a The 4th bulleted item assumes a maximum of 15 people entering and exiting.
It
~
. :j seems to me that this would be a very difficult way to keep control of.
o i..
the exposure of this number of people in high exposure areast -
..,.._..~.__. _. N. 4 U EA _'I-..TM " ~.T Pace 5 - S M Ic r 4 E
~
y I't might be well to' add at this ' point that the ' door swings will' conform with * -"-j fire codes when airlocks are discussed.
-~ -
5.2.2 - Shielding Requirements
~
~
_ ((. ',-
1
~
I It seems that this would be an ideal point to indicate where radiation levels will require...ielding, to what lcvel they should be shielded and the type of.
g shields to be used.
~
]
5.2.3 Ventilation Requirements
~
I believe the figure in que,stion in that paragraph is 5-4 rather than 5-5.
5.2.4 - Radiation Monitoring Requirements tio mention is made of the requirement of redundancy of the final exhaust systems.
And since it is almost certain that this will be required it probably should be identified at' this point.
5.2.5 - Radiological Control Suppot t
~ '
As noted earlier heat stress will mWe 'wan likely be one of the problems associa.,
ted with protective clothing and.x; Cts do require extragir.
Some mention,}.,.. s., %t
..~..:
should be made again of this a M e 'his place in the report.
It is also,r O f.ri
. c.
c :
c.
appropriate to include with t.a rauivugical control T.V. surveillance of.
~JA'.Mi i
personnel to prevent monitors from having ta enter with each'operatin[m.;. 'NeIhh
^
cr health physicist should coment on this subsection, but it seems to me that.aeu:g,.p,. w g n,A m.
4
. x
- 2. m. wo s
~. v t c.,
once a week update of radiation readings is inadequate.t "' - Q :- * :m.G P ' '.
a
~
J 5.2.6 - Change Area Requirements
[
~
Also, it is unclear whether the locker room facilities, etc.' for men aniwomen ' # +.
and shower facilities. includes that which is necessary for staff or if this is just for operating people actually conducting the work. Management will need lockers to go in and survey the situation first hand from time to time.
5.3.2 - GPU Procedures The bottom paragraph is a well delineated paragraph indicating responsibility
- )
of the project manager and I -think it is well done.
3.-
23 1y a
7 J
,Y
%,a.. -
a,
l, ~~
e 5.3.2 - Personnel Training ~ -
, ~,
..,. =
1 do not see any requirement for documentation of the training that is to be used..v w
~
The lis. ting is a token at the very best arid 'certainly there are man.y areas wh,ic,h.~~"n a u.-
must be covered.
Some obvious ones are problems, contaminatiors control, and ' dressing,
~
v
.-. and undressing; thes.e all ' require training.
This section really needs# " beefing-- ~ ^..
p -.
up".
Also, I don't see any requirements for training in reporting, debriefing..
a-
.2 etc. at the end of work on each small cleanup task.
~
5.5 - Emergency Planning No plans have been included for the removal of an injured person from a' contaminated area.-
/
5.6 - Support Systems _
It would be appropriate to e'xpand a litte bit on water needs.
For example, j
there should be sanitary, fire and accident water.
Under electricity there
-(
certainly should be lighting as well as emergency lighting.
Under air there should be such things as breathing air (according to code), instrument air, T.,
process air a, well as ventilation. Under instrumentation or communication a
should be T.V., public address systems, radio and telephone.
Incidently, radio v.t M.
. w.
generally is ineffective in a facility because there will be many dead spots -
-." J c m,":-...
that you don't recognize.
Sound power phones were found to be more effective
,1[. ':-
,3-in my experience.
~ 4..,- >;., u. p.M ',@_' f
- ...:. ' 9l:,;;
4.
. _M Y YM l
5.6.1 - Water Supply o.
4 M.w It is a vio'lation to add other systems to the fire water system. - It'is 'a code'.'is 95dj, m :.e.n m g g %
u
~..
violation. Secondly any time that you draw water you may trip the flow slarms'.r - p r' and send your entire building into a fire alann situation.
I(( h2,k
,h.r,s:~ ~f
. 'g '
r 5.6.3 - Compressed Air Supply,
.. j; s.
Check the OSHA code for' compressed air, particularly that which h'as to do with O v 's T.
<c.
9 t
breathing air and process air.
The load for compressed air of 330 SCFM is.
- lM,Q.C'!
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7
^
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e J
p
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24 a., y m
'yx
~
n'Sj
, ;.~
@. ),
- s.
n._.
~.
d: -
- L ' l.
o high considering that this air has to be exhausted. Water jets have been 9
.found to be effective and to control contamination' a little bit better one m se J.cr. o.
f~
might want to investigate"tfiem. Also,jrcathing air'ofTSCFifddes meet c' ode,'7 s Ath
~~
~
~
~
~1r I remember co~rrectly.: Also, I note that no additional air, has been. include'd, w..s u:m.p-
... -.. ~
~.-..
......_.~.m for cool' suit'use.
The breathing air should be separated entirely fr.om.the miy. gm_.
Other system. particularly in an area that has been contaminated like the interior -er of the reactor containment' vessel. Air powered stripable coa' ting applichtdrs shoIbEC not be used.
Every' time that we used a spray applir ' tor for strippable coating we.....
spread more contamination than we were able to contain.
5.6.4 - Communication Systems' y.
a I recommend that a T.V. network through out the entire facility be added so
.A there can be,a surveillance of all arc as from a comand post. ' As I mentioned earlier radios are not a " cure all" since.t'here are many dead spots and you have an eerie feeling frequently.that you are not getting through.
The current number of T.V. cameras certainly will not be adequate for an all out gr'oss decontamination effort.
5.7. - Supplies Very little consideration appears.to have beer, given to the logistics associated..
with the movement of the decontamination machinery, equipment and some of the ' c' u '. f personnel.
- . ne.c;.o; e
m-c.
3.
.a...; v.. :. _
d:.Ls :
x c
<1*W46 R b3..; '?" J' M $l~
.. : a. w 5.7.1 - Chemicals ~
..L
'5 W~
$.. w w..
.,. y;~BJ f
I don't believe that it is very realistic to consider bringing these in fivebJp.,.'gf4,@
.y p gallon con' tainers c'onsidering the amounts of it that will be,...used as:~ strip v@..:.AB P.-
..s Certainly 55 gallon drums would be a more.x~ r...c 3.* cur (g %w@
W coating.
suitable container; h r*.
[
y t.
mm
- .gf 7 g 7 W.2. :
g
.y gg g:
5.8 - Organizational Interfaces
-..c c': W
..c.A This might be an excellent point to indicate the need for maintenance of histories 9,9f and log books. Recomend appointing a historian to preoare the. finaT repo.rm. :.4mm krt based R.i 5
.,n..n on?a Nedetenninedeoutline which should be agreed upon by all parties that are '
1.'.'. -
.r
-?. ~.
supporting the prograN in any way.
~
b
Table 5-1: Radiological Protection Requirements for Decontamination Techniques
.,, n.. -, f
.n o,
Again I believe that cool suit harnesses are needed for some of the high-pressureI P water spray work.
Consideration must be given to a respirator that will.not
.t water log in the fog that occurs with high-pressure sprays.
The asterisks show
- hic
.. o..
.. ;.7 1
3
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=
25
~,
D 4..
- 1-
,9
T two h' cods and two sets of protective coveralls under the wet suit.
Consideration must be given that more is not necessarily better in this type of activity and
.~
the main object is to keep these people cool.
If they start perspiring in an i
[h.1"
$1; : ' :
atmosphere which has some tritiated water they may start absorbing some of the - ^ ]
~
l
- s~ubstance,
- ,2
=
~
- v. :*' ~
S S :_a y co....T: 7 :..
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V*~
Table 5.2 - Decontamination Crew Requirements
_ _. 7, y
~
I assume this is operating' crew size and' certainly not' backup. This could b'e
^'.'T.C
~
the tip of the iceberg and does not indicate crew size and probably a sheet should be included which would give the overall crew size requirements.
Table 5-3 The maximum rates are tremendous flows and would be most difficult to control.
It might be well to reduce this maximum to the point that one would have some
(
better control of air flows.
Figure 5-3 This figure is oriented differently that the associated other fi3ures and for this reason I feel it should be reoriented to conform to their configuration for ease of reading.
OVERVIEW
.-Q Basically it is not a bad' document.
On the contrary it is p~robably a very good;
.T "
"first cut" but I believe that there are topics that need to be " brushed up" and/ ?.M There is strong evidence that the planner are not thinking theirR.p$[d or included.
They are doing some " pre planning" that looks good on q:.m -
- g problems through entirely.
s x.
paper but before we get down to the " nit,ty gritty" there are many loose, ends that,'W'"
s
.. v w u-6 have to be worked out in. a little more detail so that the people doing and approving
.r-
. m.. +. p.,m w the work will feel more confortable. Also, there seems to be very little attempt!
here to put a program together which would be useful to the rest of the nuclear %n,F f.
.s industry. Since it is not likely that TMI will be able to finance their decon -
tamination they will require outside help and if they require outside help they.. f,,.,..W r
will have certain obligations to provide infonnation to the industry.
I believe.
7 if they take some tim'e to further delineate their plan and program they will have '.
a more saleable commodity than this rather basic first cut at a technical basis.
I hope that this review will be of some value at Ti1I.
i e
e
- 1. k 26
?.. ;.t
.J 9.
.-t
- ' ~. -
f.
nWil10..AL !.RC 00..ad.LiUR Cu;.1!.is ua. Irg IECH:iiCAL PLAi; _
-.e 1-1 and 2-1 Pac 2
The use of a " target" level of 0.5 pCi/ft should not imply that decon will proceed no further if this is reached with little or no effort.
1 When high pressure washing will further reduce smearable contamination -
~
is should be done to eliminate skin contaminations and airborre problem.
1-1 A skimmer may be required for scum removal, not just an u'nderwater vacuum.
1-3 Heat stress is the preferred term.
Should minimizing waste volumes l
be one of the limitations listed?
2-1 Support decontamination
" maintaining acceptable contamination IcVels" makes a better goal.
2-2 Constraints Should a statement be made to qualify the first bullet - something like " equipment may be adopted or developed for this specific application provided principals have been demonstrated.
Rather than just keeping chemicals to a minimum how about "Only chemicals whose effect on the SDS is known to be acceptable will be used."
~
Page 3-4 Throughout the document there is a distinct lack of criteria as to when to use low pressure water flush and when to use high pressure flush.
It is not really clear to me why one would ever do a low pressure flush of the overhead areas for instance.
High pressure gives better decon, uses less water, etc., and the contamination should come down with no l
problem.
High pressure nozzle must have a " dead man" (passive) shut off and a wand long enough to prevent the operator from shooting himself with it (accept maybe a boot).
page 3-5 3.2.23 Vacuuming' Your vacuum is not sized to handle much flush water, 2-5 minutes maybe.
Sone kind of a drain valve and hose might help, especially since there is not much help in the way of forklifts, hoists, etc.
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s It would be best to design the vacuum so the operator does not hold the hose, but a seperate handle.
hose hose g-4
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1 Ordinary Vacuum Suggested Model This will alleviate all but whole body dase rate concerns i.e. higher dose. to hands or gonads during vacuum use.
3.2.2.4 Scrubbing Electrical equipment or circuits should have Ground Fault circuit interpretation (GFCI or GFI).
Page 3-7 Section 3.3 is mostly industrial safety. Title should reflect this.
Section 3.3.1 Electrical hazards should be included.
Page 3-8 The principal defense against heat stress should be ventilating and cooling the area. The second defense should be limiting work times.
(almost anything is tolerable for 5 minutes without adverse physiological effects provided 55 minutes or so is allowed between exposures).
There are also air cooled and water cooled suits.
Only as a last resort should one decide to put up with a certain number of skin contamination rather than specify the required number of layers and proper waterproof characteristics of protective clothing.
A physicians assessment of workers ability to tolerate work in such an environment will be invaluable.
Section 3.4.
I suggest " goals" be labeled " limits" and the wording changed.
If these are goals they are not agressive enough.
Appropriate goals might be:
no internal depositions in excess of 5%
of the maximum pennissible body burden; no unplanned exposures; each job completed within 25% of the exposure allocated; no workers sent home with skin contamination or held over for decontamination, etc.
Section 3.4.2.1. Air samplers should be placed to be representative of workers breathing air and to detect trends early e.g. near probable sources of airborne activity. The area radiation monitors location
.are not n.ecessarily the best place for the air monitors. Also you are looking for " fixed" as well as loose contamination on people.
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Page 3-9
- 1) Would it be clearer to say:
6 Care will be taken to ensure that decontamination to the specified goal does not require the expenditure of an unwarranted amount of radiation exposure.
I suggest the use of pocket alarming dose integrating devices.
Thek alams when a worker has reached a predetemined amount of exposure.
They contribute to ALARA in that exposure of monitoring personnel is decreased, and they allow a much closer approach to the quarterly control limit, saving cost.
Page 3-7 and 8 This section omitts two very important components of exposure reduction.
They are discussed briefly elsewhere.
I suggest you add:
Workers will receive training and an opportunity to f
become familiar with the equipment and working condi-tions they will be involved with through trial in non-radiation' areas.
Pre-job briefinas will be used to ensure that each '
worker knows F exact job assignment and what help and support he can expect from other crew members.
Feedback from workers will be carefully analyzed to expedite the decon and avoid duplication of efforts.
Workers will be supervised primarily through closed circuit television to correct inefficiencies and maintain work continuity which conserving supervisors exposure.
Page 3-11 Fire Retardant Materials A careful review should be made of what is adequate fire retardation.
for this application.
Most cord wood passes many of the fire resistant /
fire retardant standards.
Material used on verticle surfaces is of far greater concern than on horizontal surfaces.
Enclosures Design should include emergency agress provisions and utility equipment.
Enclosure assembly should be repeated in non-radiation areas until it is efficient.
Consideration should be given to partial assembly in the lower dose rate areas of the reactor building prior to moving into positions in higher dose rate areas.
3.5.4 administrative controls also include training and work sequencing. lJ
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Page 3-12
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Section 3.5.4.2.
h Where contamination levels are such that workers proceeding to normal step off pads would cause the spread of contamination special work area step off pads should be established for the removal. of the outennost l
clothing at the work site.
s If personnel contamination from clothing removal practices becomes a problem consideration will be given to providing undressing assistance and preundressing surveys or frisks to warn of " hot spots" on protective clotbing.
Section 3.5.5.
- Provisions for tP.e decontamination and reuse of tools equipment and protective clothing.
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Section 3.5.6. General Ventilation j
Maintaining acceptable working temperatures should be a goal.
Page 4-1 l
The whole '" drain-refill" plan for the 268'6" level bothers me.
If 1
4 there is significant disturbance of sediment or dissolution of sediment the plan would be totally ineffective.
There are more detailed suggestions later, but I suggest the use of I
self propelled, random scanning " pool sweeps" to get rid of the j
majority of the sludge long before refill.
Also a continuous feed and bleed and special attention to any " bathtub ring".
E Figure 4-1 Steps 7 and 8 concurrently does not match written description.
l Page 4-2 The tenn " unrestricted access" means the general public' I am sure this is not intended.
I am not sure if you mean withgut RWP controls 10,dpm/100 cm will probably
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5 or just without such strict controls.
require "SWPs", but maybe not masks.
l It would certainly be best to get the trash out not just stock pile it when it can become a dose rate and fire problem.
How do you inspect a drain? Should it be tested and the trap filled with clean water?
Figure 4-25 did not illustrate this area north of area 1 to drain 5 very well.
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7-Page 4-3 Shielding 6
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This really talks about exposure rates.
be This says unless doses are " reduced to about 5 mr/hr" restriction will be aw-required.
This is a bit missleading. There is no "about" about it.
10 CFR 20.202 se.ction 2 says.
"If a major portion of the body could receive 5 mr in an hour or 100 mr in 5 consecutive days" this is a radiation area.
Over 2.5 mr/hr the area must be posted and access must be control-led.
Fiaure 4-2 1
Will the lighting survive the later flushes?
Is the order correct-l particularly 1.5,1.6, -and 1.157 l
i Page 4-4 Step Sequence He have " potential particulates" several places in the report.
Should'nt this be "any particulates that may fall from overhead."
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Pads" need more explanation.
Shielding I am not convinced that shielding would be the way to deal with this problem.
It would just postpone the real problem.
If-you do choose to shield a concdpt should be given e.g. lead bricks, water filled bladder or?
Support Systems A common air supply for tools and breathing air is generally not
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acceptable.
a Page 4-17 i
This lif ting mechanism sounds pretty sophisticated since it lifts from I
the bottom up 42 feet.
Details would help.
Is " stairwell" the right word for an opening without a staircase in it?
Last sentence - gloves and shoecovers sounds like less than full RWP coverall etc.
Wouldn't it be safer to say personnel will wear protective clothing.
Page 4-8 Specify an equipment hoisting line permanently tied off at the top.
Figure 4-5 Would'nt it be be'tter to do the overhead washing (4.7) before you establish a waste staging area below it (4.3)?
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Page 4-9 Personnel Access So - are we going to give them long handled mops? Are we going h
to require safety lines? Are ve going to ensure adequate lighting se and supervision? Are we going to use the bu-ddy system? Or are
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we just going to tell them "be careful".
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Page 4-10 Personnel Access What is so " extremely difficult" about a rung ladder? With additional n
care in personnel selection, protective clothing fit, life lines and
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the cage or other fall preventer on the ladder which is required by OSHA it should be a " piece of cake".
Figure 4-6 Lighting provisions?
6.2 - Do we need to cover any critical equipment below crane?
i.e. fuel transfer crane?
6.6 - Write up says we use rags. /
Figure 4-10 10.2 - are we really flushing bottom to top?
l Page 4-17 "rst two paragraphs I could not follow on drawings.
Figure 4-12 I
Sections 12.5 and 12.6 were sequential not concurrent in all other areas.
Why does only C get H.P. flush?
Page 4-18
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What is the relatinnship between the " diamond pl. ate access hatch" 1
(page 4-18) the " equipment hatch" (page 4-19) and the " removable hatch to 282'-6" level" (figure 4-25)?
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Page 4-19 Do we mean airlock 1 in objective and airlock 2 in step sequence? Some general information on strippable coatings earlier in the report would help. They are i
generally not very abrasion resistant and can be difficult to remove when abraded.
We recommend placement of a net like material underneath and additional protection and high traffic areas with paper, plastic, etc.
Figure 4-14 Steps 14.8 and 14.9 are in greater detail than other figures.
Page 420
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A high pressure roating ball type nozel has been used successfully for decon of tight areas at 100 N.
Contact W. G. (Bill) Westover, UNC for details.
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Spray header and D ring design seems a lot clearer to the author than the reader.
How about an illustration?
h Page 4-21 and Ficure 4-16 w
This section needs a great deal more planning.
Saying personnel access is required is hardly a procedural step. This really sounds like a job f
where a little special equipment is needed.
For instance an omni direc-tional high pressure sprayer with a right angle bend which could be operated either up or down from the 347'6" level might be appropriate.
Special provisions such as a safety line, or barricade across to keep workers from entering the shaft should be included.
procedures / equipment for smear tests should be provided.
If you want to address the possibility of putting people into the shaft - which I do not believe is appropriate until you can move the elevator - lets give enough details to do it right.
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i.e. safety lines; loser scaffold sections, then lower people to assemble them; or cantilever a platform at the 374 6" level clear across and use ladders up and door and hanging scaffold down - or whatever.
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Page 4-23 Step 17 Objective If its shield water it provides shielding, therefore, its removal will increase radia, tion levels.
I suggest the sump should be delt with in the following ways.
Begin ear]y in the cleanup program with the following steps:
s
- 1) Install a liquid cleanup system with a zeolite ion exchange sys+.em.
The system should have a shielded disposable prefilter a shield-remote-disconnect ion exchange cp.umn.
Zeolon 900 has been shown to work well on nondemineralized water system at N-reactor.
Return treated water to reactor.
(.If step 1 is not considered feasible drop Zeolon 5100 or other Cs specific resin into the sump to absorb cesium and be vacuumed out with the rest of the sludge).
2). Install a swimming pool vacuum system with a sand filter and zeolite IX system.
A unit such as the " pool sweep" would randomly vacuum the floor and aquire little or no ecosure.
- 3) Evaluate dose rates from the surface a: ea or " bathtub ring".
If necessary install a skimer.
If the air water interface is a problem as soon as dose rates allow coat the area above the present water level with a high quality water proof paint or strippable coating.
Something like vasoline would work, but cleinup dictates comething else.
Then raise the water level a foot or two to shield the old
" bathtub ring" and use frequent cleaning of the painted surface to keep a new one from forming.
Once decontar ination efforts have proceeded to Step 17
- 4) Map the contamination under water.
This can be done using an instrument such as a "teletech" from above or using a sophisticated remote reading instrument.
Radiological conditions will dictate which should be done..
)
Contamination should be mapped both vertically and horizontally.
If the " bathtub ring" is requiring extra v ster depth it should be scrubted from above using powered devices such as air operated wire brushes on 1ong poles.
If underwater sludge that has been uneffected w
by the pool, sweeps is the problem it should be vacuumed using a small underwater vacuum who's lines are underwater or otherwise shielded.
Air operated wire brushes may be used to dislodge more severly fixed "t 1 contamination on the bottom.
High pressure water may also be of some benefit in dislodging the sludge.
During these activities water clarity may be a serious problem. The sizing -
of the filtration system should be sufficient to deal with this. It may -
also be necessary to add floculants or filter aids either to the sand filter or the liquid in the reactor building to settle the solids..
Personnel rafety and access during these activities may be a serious problem. Scaffolding from over head, a " bosuns chair" hung on a nonorail, 4
and floatable devices are all options.
c.
Once these efforts have been exhausted the probable Jose ratcs should be assessed and slow draining of the sump can proceed.
Dose rate action levels should be established above which draining should stop until the r
cause of the high dose rate is kncwn and remedied.
In the case of severly contaminated large equipment removal using underwater cutti.ng techniques or shielding by placing lead sheet under water should be considered.
Shielding What justification could you have for not using long handled equipment?
Page 4-34 Storing decon solutions that close to a stairway does not appear ALARA.
Figure 4-25 It is difficult to tell what is there and what is being added.
u Why is area 7 not shown?
Does the shadding imply sequence?.
Section A/Section B signs look in one place like drafting sections.
Also " Area 12.0 Section B" is confusing.
Legend should show " floor drain" not " flood drain".
Figure 4-29
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It is difficult to tell phase 1 construction from phase 2.
Figure 4-30 Do we really have an equipment storage area with no doors?
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- sin if this structure goes iiside or outside of containment.
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- 'i Page 5-2 Paragraph 3 " solid waste stream"?
Is not the " container" category (last) really a subset of "colpactable/
combustable" (the firrt)?
Page 5-3 Gaseous Waste _ - Is buildup of particulates on filters expecte.d to be either a radiation dose or plugging problem?
Sludge Waste _ - The description "high total suspended and disolved solids and colloids" is not very precise.
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Chemically Contaminated Decontamination Sulution_
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Evaporator bottoms will be a slurry.
Non compactable- " processed" is vague.
Do you mean "sectioneJ?
disolved?
Page 5-4 Contamined tools....
do not write off vibratory finishing as a decon option.
j Section 5.1.5 Will not most of the waste f.
pross decon be liquid or slurry at least prior to treatment or dilutio:
.nd release?
From the order of the last paragraph it is not clear what waste will be put in interim storage.
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Page 5-6_.
Where is the tritium going? Gaseous effluents? This is 18% of the total. -
Are we discharging and/or evaporating 18% of the 600,000 gallons?
4 Page 5-7_
Who is inspecting the cleanup crews for what?
Seccnd sentence.
Paragraph 2 Area l' not labled in Figure 5-1.
Most of the You have gone to great lengths to justify an assumption.
The information is good, justification is more unjustified assumptions.Why not just say, "The following
! :loes not hang together logically.
but estimates of personnel access needs were made in air lock design.
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The fact that the seccad part of the fourth bullet is an assumption
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may be some cause for concern Last sentence - what pari. of travel routes are you covering? Floors? Walls?
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J Handrails?
Page > 8
-w Moving personnal through " sealed" boundaries sounds like shades of science fiction.
5.22 Area 1 - The description of 6 mr/hr us "very limited" seems strange.
A persons can legally spend 600 hrs /suarter there. The number is probably okay.
SeccM Bullet _ - This really does not sound like an area.
Third Bullet _ - Shielding waste makes less sense than removing it if possible.
t Fifth Bullet - The goal should be to shield it so that it does not make l
a substantial contribution to exposure.
It is'not alara and protably not i
possible to shield it to "less than general area levels".
Page 5-8 Section 5.2.2
" Shielding" is used through this document to mean " exposure reduction" l
or " exposure control".
p There are 3 (and only 3) methods of reducing exposure:
I 1.
Time 2.
Shielding j
3.
Distance All else works by one of these.
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Page 5-9 Ventilation _'
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l Should figure be 5.47 Some I am having a hard time getting a picture of the ventilation.
description is needed.
i.e. clean air enters the reactor confinement dome through either of the two airlocks helping to maintain a contamina-j From there it may pass through to the
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tion free area in.the enclosure.
347' level which is maintained at negative pressure relative to the 305'
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level, etc.
Radiation Monitoring
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You.must monitor " exposure of individual workers".
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As a rough draft suggestion:
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The radiation exposure of each worker will be mor..tored by a personnel whole body gamma dosimeter and various devices for detecting localized beta dose such as a finger ring dosimeters and dosimeter taped to safety glasses and other areas as detennin2d w
to be necessary by the nature of the work.
While the thermolumi-D-
nescent dosimeter (TLD) or film badge will provide the official
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exposure record, self reading pencils or alarming dose integrating.
_ J devices may be used to maximized productivity and assu're limits are not*exreeded.
Internal exposure to workers from tritium and other airborne
~y contaminants will also be recorded and documented by ar. air sampling program and time measurements from the data recorded on each entry.
Appropriate protection factors will be applied for the respiratory equipment used.
Pre employment and annual in vivo dosimetry will be applied to assure exposures are not understated.
I do not kncs how to " constantly monitor" contamination.
How about frequent contamination surveys instead?
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The last paragraph seems not too weli thought out from an ALARA standpoint.
i 5-10 (and page 5-7)
You finally gave up trying to passify the feminist and switched from
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" persons" to " men".
I prefer " workers" but you should at least be consistant.
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Radiation surves. These are minimum frequencies?
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Page 5-11 5.2.6 f
You have just explained that you have sized for more workers than you
,4_f can control. Why?
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5.3 c I Define " Key Personnel" somewhere.
Is this critical exposu,re, crafts?-
~j Page 5-11, 5-12 Methods should also consider:
Training requirements Decision points Maximize beneficial shielding
_Page 5-12 f
Data acquisition requirements include:
Airborne radionuclide concentration Respirat' ay protection used
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Page ' 13 5.3.2 e
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It is not satisfactory to have the entire R.C. function report to the P.M.
It is appropriate to give him ALARA responsibility, but then he
- ;1; has to have the talent, training, and experience within his organization
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to make those decisions.~.
Last Paragraph-It may be advisable to acknowledge that ALARA considerations may, from 0
time to time, slow or stop work.
If decon is not as effective as expected, or-if conditions are different, if tasks will greatly exceed time or exposure estimates its time to " drop back and regroup" - reevaluate
~f planned methods priorities, work order, etc.
That is ALARA.
Page 5-14 You need to address phys'ical qualifications.
They may need to be even l 31 i
more severe than for normal radiation workerse Consideration should
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. Tolerance for heat i
Ability to use a respiratory ~%
Physical conditions for stair climbing and lifting
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Adequate visual acuity Adequate hearing (instructions, emergency signals, etc.)
Ability to read procedures, warnings, etc.
Absence of skin disease etc. that nay complicate skin decontamination Absence of acrophobia (fear of heights) or claustraphobia (working in small spaces or using respirators), etc.
Specialized skills include running tenporary electrical, air and water service.
I am unconvinced if errecting enclosures and airlocks falls into this category.
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Page 5-14 and Table 5-2 Decontamination Crew All should be trained in radiation work procedures, routin'e and emergency communication, respirator use, recognizing unusual or unsafe conditions, procedures for equipment malfunctions.
Maybe even first aid.
Either a " laborer" class or one worker per shift should be designated
" runner" to deliver supplies and equipment and provide undressing assitance to avoid skin contamination.
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electrica' supply needs 11.6 amps 0 ll5V + a few H.'P. at 240.
It seems inopportune that the reactor has 115 and 480V so you have 7
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specified 240V equipmen.t.
It may be best to have an H.P. water..
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system specially made to use 480V.-
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Page 5-22
.a Breathing air hoses and fittings should not be compatable with anything l
l else on plant.
41 t
l Table 5-2 Crew requirements seem unbalanced. One procedure called for vacuums, r
. 1j none called for floor scrubbers, foam applications, or reagents, yet you have 5 or 6 people doing this and only 3 doing water flushes.
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Table 5-3 t
Thes specifications are required for " personnel safety"(page 5-171 Does this mean the H.P. flush is unsafe?
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