ML20059M341

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Forwards TMI-2 Auxiliary & Fuel Handling Bldgs Exceptions to Pdms Radiological Goals,Representing Completion of Pdms Requirement & Commitment Item D.1 of NRC List of Pdms Requirements & Commitments
ML20059M341
Person / Time
Site: Crane Constellation icon.png
Issue date: 11/12/1993
From: Long R
GENERAL PUBLIC UTILITIES CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C-93-2271, C000-93-2271, C312-93-2078, NUDOCS 9311190041
Download: ML20059M341 (49)


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GPU Nuclear Corporation (y

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Route 441 South Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:

(717) 948-8400 November 12, 1993 i

C312-93-2078 C000-93-2271 US Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Three Mile Island Nuclear Station Unit 2 (311-2)

Operating License No. DPR-73 Docket No. 50-320 PDMS Requirement and Commitment Item D.I

Dear Sir:

Item D.I. of the NRC's " List of PDMS. Requirements and Commitments" (dated May 19,1993) states, " Licensee will meet established contamination level goals for entrance into PDMS for each area of the AFHB. If the decontamination goals cannot be met because of the unique.

situation at B11-2 or ALARA considerations, the licensee will provide an evaluation of the specific situation to the NRC. (SAR 5.3.1 and Supp. 3, Item A.11; TER p. 4-2)."

GPU Nuclear has completed the radiological and contamination surveys in the 311-2 Auxiliary and Fuel Handling Buildings (AFHB) and reported the results via Post-Defueling Monitored Storage (PDMS) Safety Analysis Report (SAR) Amendment 19 (GPU Nuclear letter C312-93-2084, dated November 12, 1993).

Each area that did not meet the radiological goals (general area dose rate and contamination level) set forth in the PDMS SAR received a specific evaluation. The evaluations for the n11-2 AFHB exceptions are attached and represent the completion ofItem D.I. The 19 exceptions represent less than 14% of the 136 cubicles / areas in the AFHB. In addition, there are two generic exceptions taken: one for certain enclosed / shielded areas within larger cubicles and one for the AFHB overheads (even though 92% of all the AFHB overheads pass their PDMS commitments goal).

Sincerely, R. L. Ieng Director, Services Dmsion/nfI-2

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EDS/dib Attachment cc: See page 2 (JO; 9311190041 931112 A

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PDR ADOCK 05000320 W

P-PDR d

GPU Nuclear Corporation is a subsidiary of General Pubbr Umbes Co potation

Document Control Desk November 12,1993 i

C312-93-2078 C000-93-2271 Page 2 e

cc:

M. G. Evans - Senior Resident Inspector, TMI T. T. Martin - Regional Administrator, Region I M. T. Masnik - Project Manager, PNDP Directorate i

L. H. Thonus - Project Manager, TMI i

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B1I-2 AFHB EXCEPTIONS TO PDMS GOALS RADIOLOGICAL The method for detennining when an exception from the PDMS radiological goals should be written is depicted on Figure 1. The purpose of the various steps is to ensure that a small portion of the subject cubicle / area being in excess of the goal does not fail the entire cubicle / area.

Answers to the following questions provide the basis and justification for each exception to the PDMS radiological goals.

r A.

What has been accomplished to date?

j B.

For what purpose (s) will entry into this area be required during PDMS7 Mentify frequency, number of people and impact on work if no further decontamination work is perfonned.

C.

Risk associated with performing additional decontamination work.

D.

Justification for not performing additional work.

E.

Recommended actions.

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FIGURE 1 START

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RADIOLOGICAL EXCEPTION LOGIC V

IS THE MEAN LESS NO THAN THE GOAL?

YES 1

1 IS THE ARE LESS T-TEST VALU THAN 5% OF LESS THAN 1.5 THE DATA POINTS TIMES THE GREATER THAN NO GOAL?

THE GOAL?

YES YES

[ WRITE EXCEPTION NO EXCEPTION NEEDED L--

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d Cubicle:

AX-003 Area 281' EL. ACCESS AREA I

Designation:

All exposure rates in the following table are in mR/h.

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2 All contamination levels in the following table are in dpm/100 cm PDMS Goal Current Status General Area Exposure Rate

< 2.5

~ 0.8 (mean) l Maximum IIot Spot

< 2,000

- 120 i

Smearable Contamination

< 1,000

~ 2,900 (mean)

Below 7 ft.

l Smearable Contamination in

< 10,000

~ 2,300 (mean)

Overheads > 7 ft.

i NOTE: Hot Spot-Current Status is maximum measured / reported in PDMS Survey (s).

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A.

What has been accomolished to date?

The 281' El. Auxiliary Building Access Area (AX-003), is located in the basement of the Auxiliary Building. This area became contaminated during the March of 1979 accident predominately from system leakage in the area and from other nearby cubicles. In addition, overflow from floor drains in this cubicle and other adjacent areas caused additional surface contamination of this cubicle. This area was the site of many work cvolutions during the clean-up phase of the Unit-2 accident, including work in the " Kelly Enclosure." The Kelly Enclosure is a large thin walled ponable stmeture used to isolate contaminated work effons from uncontaminated work areas. The Kelly Enclosure will continue to be used during the PDMS period.

Early decontamination work in AX-003 included low pressure water spmys and hands-on decontamination effons. Sections of the floor of this area have been scabbled to remove the upper layer of concrete. The floor and some equipment surfaces have been painted or scaled to fix or retard surface contamination movement. Some lead shielding has been placed over area or equipment hot spots to reduce geneml area exposure rates.

The average general area radiation level is about 0.8 mR/h which is below the PDMS SAR goal. The contamination levels are slightly above the PDMS SAR goal for this area.

B.

For what pumose(s) will entry into this ama be reouired duringPDMS? '

Entry into the AX-003 area is anticipated. Access to perimeter cubicles, inspection of area equipment and work in the Kelley Enclosure will be necessary during PDMS.

Routine surveys will be used to determine if contamination or radiation levels are changing and to detennine if contamination is spreading to adjacent areas.

C.

What is the risk associated with perfonning additional decontamination work?

Additional decontamination effons could cause re-contamination of adjacent areas that already meet or exceed PDMS goals.

D.

Justification for not perfonnine additional work.

The justification for not performing additional decontamination work in this cubicle, is that the additional work mquired to lower the contamination levels to (or below) the PDMS goal would requim an estimated expenditure of appmximately 60 man-hours, and result in approximately 0.05 man-rem to those personnel involved. In addition, this area will be used to perform various work evolutions during PDMS. Because of the low exposure rate and small contamination levels, additional decontamination work is not justified.

E.

Recommended Etions.

Allow this cubicle to remain "AS IS" during PDMS.

A i

Cubicle:

AX-004 Area i

Destination: SEAL INJECTION VALVE ROOM i

All exposure rates in the following table are in mR/h.

2 All contamination levels in the following table are in dpm/100 cm i

PDMS Goal Current Status General Area Exposure Rate

< 1,000

~ 120 (mean)

Maximum Hot Spot

< 2,000

~ 4,000 Smearable Contamination

< 50,000

~ 68,000 (mean)

'I Below 7 ft.

Smearable Contamination in

< 50,000

~ 750,000' (mean) i Overheads > 7 ft.

8 This value is based on a limited number of smear data points.

NOTE: IIot Spot-Current Status is maximum measured / reported in PDMS Survey (s).

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f A.

What has been accomplished to date?

i The Seal Injection Valve Room (AX-004) was severely contaminated during the March of 1979 accident largely due to leaking valves and instrumentation, permitting primary

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coolant to enter this cubicle. In particular, the beta dose rate was very high because of the high strontium content of the isotopic mix. Seveml decontamination efforts expending l

about 150 man-rem were employed to reduce the contamination levels in this cubicle.

l Ilowever, the porous nature of the concrete floor absorbed the mdioactive materials.

The first method used to decontaminate the cubicle was a water flush. Later efforts l

included removal of the top layer of concrete floor by scabbling. Finally, the floor was j

covered with a layer of concrete to reduce the exposure rate and allow for more extended l

entries. The overall effectiveness of the total decontamination effon reduced the general area exposure rate from about 20 R/h in 1984 to approximately 120 mR/h currently.

l B.

For what purpose (s) will entry into this area be required during PDMh?

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Unless otherwise determined, entry into this area during PDMS will be only for the i

containment isolation verification surveillance. Radiological Controls surveys performed at the time of these surveillance activities may be used to document that mdiological conditions have not degraded with time, or additional surveys may be perfonned as deemed necessary to determine that boundary areas are not becoming contaminated from routine surveillance activity.

C.

What is the risk associated with oerformine additional decontamination work?

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The risk associated with perfonning additional decontamination is that contamination could spread to the adjacent hallway or other areas which may meet the PDMS goals.

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Justification for not performine additional wori;.

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The justification for not performing additional decontamination work in this cubicle is j

that additional work required to lower the contamination and exposure rates to (or below) the PDMS goals would require an estimated expenditure of approximately 160 man-hours l

and result in approximately 16 man-rem to those personnel involved.

E.

Eecommended actions.

I Allow this cubicle to remain "AS IS" during PDMS.

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' Cubicle:

AX-006 i-;

Ama Designation:

MAKE-UP PUMP IB f

All exposure rates in the following table am in mR/h.

2 All contamination levels in the following table are in dpm/100 cm PDMS Goal Current Status General Area Exposure Rate

< 500

~ 60 (mean)

Maximum Hot Spot

< 2,000

-800 3

Smearable Contamination

< 50,000

~ 88,000 (mean)

Below 7 ft.

Smearable Contamination in

< 50,000

~ 29.000 (mean)

Overheads > 7 ft.

i NOTE: Hot Spot-Current Status is maximum measured / reported in PDMS Survey (s).

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i A.

What has been accomplished to date?

The Mak.e-up & Purification Pump Room IB (AX-006), located in the basement of the Auxiliary. Building, was contaminated during the March of 1979 accident when water overflowed from the Door drains in the cubicle. In addition, some pump and valve l

leakage provided an additional source of surface contamination.

Early decontamination work in this cubicle included high pressure water spmys and a

hands-on decontamination efforts. The floor of the cubicle has been scabbled to remove the upper layer of concrete. The cubicle floor and some equipment surfaces have been painted or sealed to Ox or retard surface contamination movement.

s The average general area radiation level is about 60 mR/h which is below the PDMS SAR goal. There is about 70 grams of reactor fuel (UOy, still retained in the pump and associated piping.

B.

For what purpose (s) will entry into this area be required during PDMS?

No entry into this cubicle is anticipated during PDMS. Routine surveys may be used to determine it' contamination and mdiation levels are changing and contamination is spreading to adjacent areas.

C.

What is the risk associated with performing additional decontamination work? '

Additional decontamination efforts could cause re-contamination of adjacent hallways or other areas that already meet or exceed PDMS goals.

D.

Justification for not performing additional work.

The justification for not performing additional decontamination work in this cubicle, is that the additional work required to lower the contamination levels to (or below) the PDMS goal would require an estimated expenditure of approximately 60 man-hours, and msult in approximately 3.5 man-rem to those personnel involved. No plans for removal of the internally deposited reactor fuel have been considered at this time, due to the difEculty involved with disposing of radioactive waste materials of this type. In addition, removal of the fuel debris would require a significant man-rem commitment, E.

Recomptented actions.

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Allow this cubicle to remain "AS IS" during PDMS.

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i Cubicle:

AX-012 i

Area AUXILIARY BUILDING SUMP PUMP & TANK ROOM

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Designation:

I All exposure rates in the following table are in mR/h.

2 All contamination levels in the following table are in dpm/100 cm PDMS Goal Current Status l

i General Area Exposure Rate

< 50

~ 560 (mean)

Maximum Hot Spot

< 2,000

-2,800 j

Smearable Contamination

< 5,000

~ 390,000 (mean)

Below 7 ft.

f Smearable Contamination in

< 50,000

~ 68,000 (mean)

Overheads > 7 ft.

i NOTE: Hot Spot-Current Status is maximum measured / reported in PDMS Survey (s).

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A.

What has been accomplished to date?

The Auxiliary Building Sump Pump & Tank Room (AX-012), was sevemly contaminated during the March of 1979 accident by primary coolant water received from the overflow of the Miscellaneous Waste Tank. Accident genemted water was also collected in the l

sump at high isotopic concentrations from other evolutions during the clean-up effort.

i Early decontamination work in this cubicle included high pressure water sprays and hands-on decontamination effons. Sections of the cubicle have been painted or sealed to fix or retard surface contamination movement. The accident generated water has been removed from the sump and processed and the tank has been drained. The sump (and possibly the tank) will be used during the PDMS period to collect in-leakage and other r

sources of water around the AFHB. The average general area radiation level in this cubicle is currently above the PDMS SAR goal, and will vary as the level of the sump water changes. The highest average geneml area radiation 1cvel occurs when the sump is near empty, and is about 560 mR/h. There is about 100 grams of reactor fuel (UO ),

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still retained in this cubicle.

B.

For what ournosg(s) will entry into this area be required during PDMS?

Quarterly entry into this cubicle is anticipated during PDMS for operations surveillance effons according to operations surveillance No. OPS-S-063. Radiological controls will provide job coverage as deemed necessary for the opemtors performing these surveillances. Routine surveys during these entries may be used to determine if the l

contamination and radiation levels are changing and if as a result of these entries, I

contamination is spreading to adjacent areas.

C.

What is the risk associated with performing additional decontamination work?

Additional decontamination effons could cause re-contamination of adjacent hallways or other areas that almady meet or exceed PDMS goals.

D.

Justification for not performing additional work.

The justification for not performing additional decontamination work in this cubicle, is that the additional work required to lower the contamination levels to (or below) the PDMS goal would require an estimated expenditure of approximately 250 man-hours resulting in 140 man-rem to those personnel involved, not including tank desludging and

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fuel debris removal. Also, plans for removal of the internally deposited reactor fuel have not been considemd at this time, due to the difficulty involved with disposing of radioactive waste materials of this type. This cubicle will be in service during the PDMS j

period. System use will make this area a collection point for additional contaminated water volumes.

Therefore, this area need not be scheduled for continued decontamination effons.

E.

Recommended actions.

Allow this cubicle to remain "AS IS" during PDMS.

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Cubicle:

AX-020 I

J Area REACTOR COOLANT BLEED TANK CUBICLE IB & IC l

Designation-I All exposure rates in the following table are in mR/h.

l All contamination levels in the following table are in dpm/100 cm2 PDMS Goal Current Status l

General Area Exposure Rate

< 500

~ 160 (mean)

Maximum Hot Spot

< 2,000

- 1200 Smearable Contamination

< 50,000

~520,000 (mean)

Below 7 ft.

Smearable Contamination in

< 50,000

~200,000 6r._'n)

Overheads > 7 ft.

f NOTE: - Hot Spot-Current Status is maximum measunxt/ reported in PDMS Survey (s).

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4 A.

What has been accomplished to dale?

The Reactor Coolant Bleed Tank Cubicle IB & IC (AX-020), was severely contaminated during the March of 1979 accident. The overnow of the auxiliary building sump and subsequent floor drain overflow in the auxiliary building, as well as cubicle valve leakage j

contributed to the levels of contamination encountered in this cubicle.

Accident generated water was collected in these tanks during the accident, generating significant general area radiation levels in this cubicle.

Early decontamination work in this cubicle included high pressure water sprays and hands-on decontamination efforts. Most of the floor ama has been scabbled to remove the upper layer of concrete surface that retained the highest contamination levels.

Sections of the cubicle have been painted or sealed to fix or retard surface contamination movement.

The accident generated water has been removed from the tanks and processed. The tanks have been drained and will not be used during the PDMS period.

The average general area radiation level in this cubicle is curmntly below the PDMS SAR goal, but is still about 160 mR/h. Some of the radiation exposure rate is generated j

by the fission products associated with the ~3500 grams of reactor fuel (UO), still 2

retained in the two bleed tanks. Removal of this material has not been planned because of the significant effort involved and the expected man-rem expenditure for this work.

In addition, continued difficulty in disposing of this material as radioactive waste has also deterred further removal effons.

i B.

For what pumose(s) will entry into this area be reouired durine PDMS7 No entry into this cubicle is anticipated during PDMS.

j C.

What is the risk associated with perfonning additional decontamination work?

i Additional decontamination effons could cause re-contamination of adjacent hallways or l

other areas that already meet or exceed PDMS goals.

l D.

Justification for not nerfonnine additional work.

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The justification for not performing additional decontamination work in this cubicle, is that the additional work required to lower the contamination levels to (or below) the PDMS goal would require an estimated expenditum of approximately 125 man-hours and result in approximately 20 man-rem to those personnel involved (not including the removal of fuel debris materials).

No plans for removal of the internally deposited reactor fuel have been considered at this time, due to the difficulty involved with disposing of radioactive waste materials of this type and the significant expenditure of man-rem involved. The general area radiation level in AX-020 is currently below the PDMS goal, but not insignificant.

E.

Recommended actions.

Allow this cubicle to remain "AS IS" during PDMS.

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s Cubicle:

AX-023 Area BASE OF AUXII'ARY BUILDING ELEVATOR SHAFT Designation:

1 All exposure rates in the following table are in mR/h.

2 All contamination levels in the following table are in dpm/100 cm PDMS Goal Current Status General Area Exposure Rate

< 10

~ 14 (mean)

Maximum Hot Spot

< 2,000

-100 i

Smearable Contamination

< 50,000

~ 25,000 (mean)

Below 7 ft.

Smearable Contamination in N/A N/A Overheads > 7 ft.

NOTE: Hot Spot-Current Status is maximum measured / reported in PDMS Survey (s).

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I A.

What has been accomplished to date?

The elevator shaft extends from about the 275' El. to the 364' El. in the Unit-2 Auxiliary Bu9 ding. This area is divided into several building designations. The lowest of the.e e!cvations (including the elevator pit area), is AX-023.

During the TMI-2 accident, the elevator pit area was Dooded with highly contaminated accident generated water. The unpainted concrete surfaces absorbed and retained the l

radioactive materials making decontamination effons difficult.

The methods used to decontaminate this area included concrete surface removal (scabbling), high pressure water flushing, and hands-on wiping of selected surfaces.

Sections of this area were painted to Ex contamination and reduce airborne radioactivity j

levels, and localized areas of the floor and walls were covered with lead shielding. The overall effectiveness of the total decontamination and shielding effon reduced the general area exposure rate in AX-023 from 140 mR/h in 1985 to approximately 14 mR/h currently (the PDMS goal for this area is 10 mR/h).

B.

For what pumose(s) will entry into this area be required durine PDMS?

Entry into this area during PDMS will not be necessary unless there is a need to service the elevator or elevator equipment.' Radiological Controls surveys performed at the time of this activity may be used to document that radiological conditions have not degraded with time, and additional surveys may be performed as deemed necessary to verify that 7

boundary areas are not becoming contaminated over time or from elevator use.

C.

What is the risk associated with perfonning additional decontamination work?

l The risk associated with performing additional decontamination is that ccmtamination f

could spread to the adjacent hallway or other areas which may already meet the PDMS i

goals.

r D.

tustification for not performing additional work.

The justification for not performing additional work in this cubicle, is that the additional l

shielding work required to lower the radiation levels to (or below) the PDMS goal wculd require an estimated expenditure of r9 proximately 50 man-hours and rc:, alt in approximately I man-rem to those personnel involved. Since the original PDMS goal l

was 10 mR/h, the additional effon required to reduce the general ama exposure rate by 4 mR/h (from 14 mR/h), is not justified at this time.

E.

Recommended actions.

l Allow this cubicle to remain "AS IS" during PDMS.

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Cubicle:

AX-025 Ama LESA AREA Designation:

l All exposure rates in the following table are in mit/h.

2 All contamination levels in the following table am in dpm/100 cm PDMS Goal Current Status General Area Exposure Rate

< 500

~ 3.5 (mean) l Maximum Hot Spot

< 2,000

-400 Smearable Contamination

< 1,000

~ 1,000* (mean) l Below 7 ft.

j Smeamble Contamiaation in

< 10,000

~ 310 (mean) -

Ovesheads > 7 ft.

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  • Based on limited survey data and does not include cork seam contamination levels.

NOTE: Hot Spot-Current Status is maximum measured /reponed in PDMS Survey (s).

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A.

What has been accomplished to date?

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The Area betwan the Service and Control Buildings (LESA AREA-AX-025) was contaminated during the March of 1979 accident from floor drain overflow and leakage j

from the cork seam water seal. Initially (post accident), this area was used as a storage j

area for high radiation, accident genemted waste materials.

j Early decontamination work in this cubicle included high pressure water sprays and hands-on decontamination effons. Sections of the floor area have been scabbled and i

painted or sealed, to fix or retard surface contamination movement. The cork seam area is the site of on-going activity, and will continue to be so while engineering personnel l

continue to repair the cork seam water seal.

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The average general area radiation level in this area is currently well below the PDMS SAR goal. The floor area at the cork seam is contaminated. No effon to decontaminate this area is planned while the cork seam area is under evaluation and repair.

B.

Epr what pumose(s) will entry into this area be reautred during PDMS?

Quarterly entry into this area is anticipated early in PDMS for operations surveillance

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effons, according to surveillance procedure 4210-SUR-3244.01. EventuaUy, yearly surveillance is anticipated. Radiological controls will provide job coverage as deemed necessary for the aperators performing these surveillances.

In addition, GPUNC personnel will be implementing repairs to the waterstop at the cork seam site. Routine surveys during these entries may be used to determine if the contamination and mdiation levels are changing, and if as a result of these entries, contamination is spreading to adjacent areas.

C.

What is the risk associated with performine additional decontamination work?

There is little risk associated with performing additional decontamination work.

However, additional decontamination work will not be performed until the cork seam evaluations and repair are completed.

q D.

Justification for not performing additional work.

No additional decontamination effons are planned while cork seam evaluations and repair are underway. This evolution is expected to last well into the PDMS period.

E.

Recommended actions.

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Allow this cubicle to remain "AS IS" until the cork seam work is completed.

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- Cubicle:

AX-112 i

Area SEAL RETURN COOLERS & FILTER AREA i

Designation:

i All exposure rates in the following table are in mR/h.

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- All contamination levels in the following table are in dpm/100 cm PDMS Goal Current Status General Area Exposure Rate

< 1,000 99 (mean)

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Maximum Hot Spot

< 2,000

~ 6,000 i

Smearable Contamination

< 50,000

-350,000 (mean)

Below 7 ft.

Smeae.Sle Contamination in

< 50,000

~ 38,000 (mean)l Overheads > 7 ft.

NOTE: Hot Spot-Current Status is maximum measured /reponed in PDMS Survey (s).

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A.

What has been accomplished to date?

i The Seal Return Coolers & Filter area (AX-112) is located on the 305' El. of the Unit-2 Auxiliary Building. The original function of the coolers and filter was to reduce water temperature and filter bleed-off from seal injection water flow prior to passing water on to the make-up tank for retention and reuse by the Make-up System. As part of the.

Make-up System, the coolers as well as the filter were subject to high concentrations of radioactivity during the March of 1979 accident. System leakage constituted the major source of surface contamination in this cubicle.

As a resuh of the accident, reactor fuel debris collected ir die Make-up System.

Approximately 300 grams is present in the systems in this cubicle.

High pressure water spray and hands-on decontamination have been used to reduce the surface activity in this cubicle. The floor has been scabbled to remove the upper layer j

of contaminated concrete. The system has been drained and surfaces within the cubicle j

have been painted to retard surface contamination movement.

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B.

For what pumose(s) will entry into this area be reauired during PDMS?

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No entries into this cubicle are anticipated during the PDMS period.

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C.

What is the risk associated with perfonning additional decontamination work?

The risk associated with performing additional decontamination is that contamination could spread to the adjacent hallway or other areas which may meet the PDMS goals.

-i D.

Justificatian for not oerforming additional work.

i The justification.for not perfonning additional decontamination work in this cubicle is j

that additional work required to lower the contamination levels to (or below) the PDMS l

goal would require appmximately 120 man-hours (not including removal of the fuel debris), and result in an expenditure of approximately 12 man-rem. The general area radiation level in AX-Il2 is well below the goal set in the PDMS SAR for this area.

1 Removal of the reactor fue~1 debris has not been considered due to the difficulty involved l.I with disposing of radioactive waste materials of this type.

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Recommended actions.

Allow this cubicle to remain "AS IS" during PDMS.

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Cubicle:

AX-116 r

Area MAKE-UP TANK ROOM Designation:

All exposure rates in the following table are in mR/h.

2 All contamination levels in the following table are in dpm/100 cm l

t PDMS Goal Current Status '

General Area Exposure Rate

< 500

~ 60 (mean)

Maximum Hot Spot

< 2,000

-600 1

Smearable Contamination

< 50,000

~310,000 (mean)

Below 7 ft.

Smearable Contamination in

< 50,000

~ 23,000 (mean)

Overheads > 7 ft.

NOTE: Hot Spot-Current Status is maximum measumd/reponed in PDMS Survey (s).

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l A.

What has been accomolished to date?

q The Make-up Tank Room (AX-116) is located on the 305' El. of the Unit-2 Auxiliary Building. The original functions of the Make-up Tank were to pmvide a supply of water for the Make-up System, serve as a surge tank for the Make-up Pumps and provide a chemical addition point. During the March of 1979 accident, reactor fuel debris and-fission products were deposited in the Make-up Tank system. System leakage in this cubicle provided the main source of surface contamination.

High pressure water sprays and hands on decontamination were the main decontamination methods used in this cubicle. The tank and tar.k piping am reported to contain about 310 grams of reactor fuel materials (UO). This cubicle has also been used to store two l

2 neutron start-up sources (AmBe) for Unit-1.

B.

For what pumose(s) will entry into this area be reauired during PDMS?

No entries into this cubicle are anticipated during the PDMS period except for biannual neutron source inventory and leak tests.

l C.

What is the risk associated with performing additional decontamination work?

The risk associated with performing additional decontamination is that contamination could spread to the adjacent hallway or other areas which may meet the PDMS goals.

D.

Justification for not performing additional work.

The justification for not performing additional decontamination work in this cubicle is that additional work requimd to locer the contamination levels to (or below) the PDMS l

goal would mquire approximately 60 man-hours and result in an expenditure of approximately 3.6 man-rem. This does not include the mmoval of the fuel debris e

materials. No plans for removal of the fuel debris have been considered because of the l'

continued difficulty with disposal of this material as radioactive waste. The general area radiation level in AX-Il6 is currently below the goal set in the PDMS SAR for this cubicle.

E.

Recommended actions.

Allow this cubicle to mmain "AS IS" during PDMS.

l j

1 I

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i i

Cubicle:

AX-131 Area MISC. WASTE HOLD-UP TANK ROOM 305' EL.

i Designation:

All exposure rates in the following table are in mR/h.

2

+

All contamination levels in the following table are in dpm/100 cm 3

PDMS Goal Current Status General Area Exposure Rate

< 50

- 120 (mean)

Maximum Hot Spot

< 2,000

~ 4,400 Smearable Contamination

< 5,000

- 1,900 (mean)

Below 7 ft.

Smearable Contamination in

< 50,000

~ 6,500 (mean)

Overheads > 7 ft.

NOTE: Hot Spot-Current Status is maximum measured / reported in PDMS Survey (s).

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A.

What has been accomplished to date?

t During the March of 1979 accident, the Miscellaneous Waste Hold-up Tank room (AX-l 131) was contaminated via the room ventilation system and some cubicle valve leakage.

The contamination levels were reduced by decontamination efforts such as hands-oi: vripe j

downr and low pressure water spmys. Radiation shielding was added to reduce cuoicle exposure mtes.

i The remaining contamination levels are below the goal set for this cubicle. However, the tank continues to retain reactor fuel debris (about 30 grams), and significant levels of radioactivity, such that contact readings on the bottom of the tank are as high as 4.4 i

R/h. This residual activity in the tank drives the average general area exposum rate to

[

about 120 mR/h.

The Misc. Waste Hold-up Tank is used to collect waste water (for processing) from around the AFHB. The tank capacity is about 20,000 gallons and AFHB in-leakage water collec'. ion is assumed to be about 5,000 gallons per year. This system will be operational during PDMS.

B.

For what nurpose(s) will entry into this area be reouired durine PDMS7 1

Entry into this area during PDMS will be for valve line-up when necessary for a

processing or transferring water in the AFHB. These valve line-ups will be scheduled i

on a yearly basis or as needed. Radiological Controls surveys performed at the time of these activities may be used to document that radiological conditions have not degraded

{

with time. Additional surveys may be performed as deemed necessary to determine that boundary areas are not becoming contaminated fmm these activities.

C.

What is the risk associated with nerformine additional decontamination work?

l The risk associated with performing additional decontamination is that contamination could spread to the adjacent hallway or other areas which may meet the PDMS goals.

?

D.

Justification for not ocrformine additional work.

The justification for net performing additional decontamination work in this cubicle is that additional work mquired to lower the exposure rates to (or below) the PDMS goals i

would mquire that the tank be opened and flushed through a water processing and/or complex vacuum system capable of handling high contamination levels, while collecting

- and retaining fuel debris. The waste would be difficult to dispose of at this time. In addition, this effort would require an expenditum of approximately 75 man-hrs and result j

in an exposure of about 9.2 man-rem to those involved. The general area smear survey j

levels in AX-131 are currently below the goal set in the PDMS SAR.

[

E.

Recommended actions.

l l

t Allow this cubicle to remain "AS IS" during PDMS.

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Cubicle:

AX-501 i

i Area REACTOR BUILDING SPRAY VAULT "A" l

Designation.

i i

All exposure rates in the following table are in mR/h.

i 2

All contamination levels in the following table are in dpm/100 cm PDMS Goal Current Status i

l General Area Exposure Rate

< 25

- 17 (mean) l Maximum Hot Spot

< 2,000

~600 Smearable Contamination

< 5,000

~ 370,000 (mean)

Below 7 ft.

Smearable Contamination in

< 50,000

~ 2,100,000* (mean)

Overheads > 7 ft.

  • Survey data unavailable. Reported as 2 sigma + the mean value below 7'.

NOTE: Hot Spot-Current Status is maximum measured / reported in PDMS Survey (s).

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A.

What has been accomplished to date?

i The Reactor Building Spray Vault "A" cubicle (AX-501), was severely contaminated during the March of 1979 accident. The overnow of the auxiliary building sump and subsequent floor drain overCow, as u cll as decay heat valve leakage prior too, during, and after cycling, contributed to the levels of contamination encountered in this area.

Early decontamination work in this cubicle included high pressure water sprays and hands-on decontamination efforts. Most of the Door area has been scabbled to remove the upper layer of concrete surface that retained the highest contamination levels.

Sections of the cubicle surface area have been painted or sealed to fix or retard surface contamination movement.

The avemge general area radiation level in this cubicle is below the PDMS SAR goal, but the contamination levels are well above the SAR PDMS goal. There is about 10 grams of mactor fuel retained in the systems in this cubicle. Removal of this material has not been planned because of the significant level of effort involved and the resulting man-rem expenditure for this work. In addition, continued diffic'dty in disposing of this material as radioactive waste has deterred further removal efforts.

B.

For what ouroose(s) will entry into this area be required durine PDMS?

No planned entry into this cubicle is anticipated during PDMS.

C.

What is the risk associated with performing additional decontamination work?

Additional decontamination efforts could cause re-contamination of adjacent hallways or other areas that already meet or exceed PDMS goals.

l D.

Justincation for not performing additional work.

The justification for not performing additional decontamination work in this cubicle is that the additional work required to lower the contamination level to (or below) the PDMS goal would require an estimated expenditure of approximately 60 man-hours and result in approximately 1 man-rem to those personnel involved (not including the removal of fuel debris materials).

t No plans for removal of the internally deposited reactor fuel have been considered at this time, due to the difficulty involved with disposing of radioactive waste materials of this type and the significant expenditure of man-rem involved to remove it. The average radiation level in this cubicle is currently below the PDMS SAR goal, but significant levels of contamination are present.

E.

Recommended actions.

i

{

Allow this cubicle to remain "AS IS" during PDMS.

i Cubicle:

AX-502 Area REACTOR BUILDING SPRAY VAULT "B" Designation:

All exposure rates in the following table are in mR/h.

2 All contamination levels in the following table are in dpm/100 cm PDMS Goal Current Status General Area Exposure Rate

< 25

~ 31 (mean)-

Maximum Hot Spot

< 2,000

~ 300 Smearable Contamination "AS IS"

~ 110,000 (mean)

Below 7 ft.

Smearable Contamination in "AS IS"

~ 540,000* (mean)

Overheads > 7 ft.

  • Reported as 2 sigma + the mean below 7'.

NOTE: Hot Spot-Current Statu:: is maximum measuredhrported in PDMS Survey (s).

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A.

What has been accomplished to date?

1 The Reactor Building Spray Vault "B" cubicle (AX-502) was severely contaminated during the March of 1979 accident. The overflow of the auxiliary building sump and subsequent Door drain overDow as well as decay heat valve leakage prior too, during, and after cycling, contributed to the levels of contamination encountered in this cubicle.

Early decontamination work in this cubicle included high pressure water sprays and hands-on decontamination efforts. Most of the floor area has been scabbled to remove the upper layer of concrete surface that retained the highest contamination levels.

Sections of the cubicle surface area have been painted or sealed to fix or retard surface contamination movement.

T The average general area radiation level in this cubicle is slightly above the PDMS SAR goal. The contamination levels are high but meet the PDMS SAR goal ("AS IS").

There is about 10 grams of reactor fuel retained in the systems in this cubicle. Removal of this material has not been planned because of the significant level of effon involved and the expected man-rem expenditure for this work. In addition, continued difficulty in disposing of this material as radioactive waste has deterred further removal effons.

B.

For what puroose(s) will entry into this area be required during PDMS?

No planned entry into this cubicle is anticipated during PDMS. In addition, this cubicle may be inspected from above without entering the cubicle.

l C.

What is the risk associatul with performine additional decontamination work?

Additional decontamination or shielding effons could cause m-contamination of adjacent hallways or other areas that already meet or exceed PDMS goals.

D.

Justification for not performing additional work.

The justincation for not performing additional shielding work in this cubicle is that the j

additional work required to lower the radiation level to (or below) the PDMS goal would require an estimated expenditure of approximately 2 man-hours and result in approximately 0.06 man-rem to those personnel involved (not including the removal of

.j fuel debris materials). Since entry into the cubicle is not necessary for inspection purposes, the need to reduce radiation and contamination levels has a reduced imponance for the PDMS period.

No plans for removal of the internally deposited reactor fuel have been considered at this time, due to the difficulty involved with disposing of radioactive waste materials of this type, and the significant expenditum of man-rem involved to remove it. The average contamination level in this cubicle meets the PDMS SAR goal, but is not insignincant.

E.

Recommended actions.

)

Allow this cubicle to remain "AS IS" during PDMS.

)

i

l Cubicle:

FH-003a Area

' SOUTH MAKE-UP DISCHARGE VALVE ROOM Designation:

All exposure rates in the following table are in mR/h.

2 All contamination levels in the following table are in dpm/100 cm t

PDMS Goal Current Status General Area Exposure Rate

< 1,000

~ 69 (mean) i Maximum Hot Spot

< 2,000

~ 2,000 Smearable Contamination

< 50,000

~ 140,000 (mean)

Below 7 ft.

l Smearablo Contamination in

< 100,000

~ 77,000 (mean)

Overheads > 7 ft.

r NOTE: Hot Spot-Current Status is maximum measured / reported in PDMS Survey (s).

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4 A.

What has been accomplished to date?

i The Make-up Discharge Valve Rooms (FH-003a & b), located in the basement of the Fuel Handling Building, were contaminated during the March of 1979 accident predominately from valve leakage. In addition, overflow fmm floor drains caused additional surface contamination of these cubicles.

r Early decontamination work in FH-003a included low pressum water sprays and hands-on decontamination efforts. Sections of the floor in the cubicle have been scabbled to remove the upper layer of concrete. The cubicle floor and some equipment surfaces have been painted or sealed to fix or retard surface contamination movement. Some lead shielding has been placed over area or equipment hot spots to reduce general area exposure rates.

The average general area radiation level is about 69 mR/h which is below the PDMS

[

SAR goal. There is about 10 grams of reactor fuel (UO ), still retained in the cubicle 2

piping.

B.

For what purpose (s) will entry into this area be required during PDMS7

.No entry into the FH-003a cubicle is anticipated during PDMS. Routine surveys may be used to determine if contamination and radiation levels are changing and contamination is spreading to adjacent areas.

C.

What is the risk associated with performine additional decontamination work?

Additional decontamination efforts could cause re-contamination of adjacent hallways or other areas that already meet or exceed PDMS goals.

D.

Justification for not performing additional work.

The justification for not performing additional decontamination work in this cubicle is that the additional work required to lower the contamination levels to (or below) the

~

PDMS goal would require an estimated expenditure of approximately 60 man-hours and result in approximately 4.1 man-rem to those personnel involved. No plans for removal i

of the internally deposited reactor fuel have been considered at this time, due to the difficulty involved with disposing of radioactive waste materials of this type. In addition, removal of the fuel debris would require a significant man-rem commitment.

l E.

Recommended actions.

1 Allow this cubicle to remain "AS IS" during PDMS.

1 i

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-+

m b

I Cubicle:

FH-003b Area NORTH MAKE-UP DISCHARGE VALVE ROOM l

Designation:

l All exposure rates in the following table are in mR/h.

2 All contamination levels in the following table are in dpm/100 cm PDMS Goal Curmnt Status.

General Area Exposure Rate

< 1,000

~ 220 (mean)

Maximum Hot Spot

< 2,000

~ 10,000 Smearable Contamination

< 50,000

~ 510,000 (mean)

Below 7 R.

Smearable Contamination in

< 100,000

~ 180,000 (mean) t Overheads > 7 ft.

NOTE: Hot Spot-Current Status is maximum measured / reported in PDMS Survey (s).

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A.

What has been accomolished to date?

l The Make-up Discharge Valve Rooms (FH-003a & b), located in the basement of the l

Fuel Handling Building, were contaminated during the March of 1979 accident predominately from valve leakage. The by-pass valve (MU-V155) for the Make-up flow control line in the FH-003b cubicle was identified as a significant contamination source.

~

In addition, overflow from floor drains caused additional surface contamination of these cubicles.

Early decontamination work in FH-003b included low pressure water sprays and hands-on decontamination efforts. The systems were drained and flushed several times.

Sections of the floor in the cubicle were scabbled to remove the upperlayer of concrete.

The cubicle floor and some equipment surfaces have been painted or scaled to fix or-retard surface contamination movement. Several lead shields have been placed at/around cubicle components and piping to reduce the general area exposure rates.

The average general area radiation level is about 220 mR/h which is below the PDMS SAR goal. There is about 100 grams of reactor fuel (UO ) still retained in the cubicle 2

valves and piping.

l B.

For what purpose (s) will entry into this area be recuimd durine PDMS?

No entry into the FH-003b cubicle is anticipated during PDMS. Routine surveys may f

i be used to determine if contamination and radiation levels are changing and contamination is spreading to adjacent areas.

C.

What is the risk associated with performine additional decc.ntamination work?

Additional decontamination efforts could cause re-contamination of adjacent hallways or other areas that already meet or exceed PDMS goals.

4 D.

Justification for not performing additional work.

The justification for not performing additional decontamination work in this cubicle is that the additional work required to lower the contamination levels to (or below) the

.i PDMS goal would require an estimated expenditure of approximately 160 man-hours and result in approximately 35.4 man-rem to those personnel involved. No plans for removal -

of the internally deposited reactor fuel have been considered at this time, due to the difficulty involved with disposing of radioactive waste materials of this type. In addition, l

removal of the fuel debris would require a significant man-rem commitment.

E.

Recommended actions.

Allow this cubicle to remain "AS IS" during PDMS.

l i

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l Cubicle:

FH-006

.i Area 281' EL. DECAY HEAT SERVICE COOLERS AREA

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Designation All exposure rates in the following table are in mR/h.

2 All contamination levels in the following table are in dpm/100 cm PDMS Goal Current Status j

.i General Area Exposure Rate

< 500

~ 6.4 (mean) j Maximum Hot Spot

< 2,000

~400 l

Smearable Contamination-

< 1,000

~ 1,100 (mean)

Below 7 ft.

Smearable Contamination in

< 10,000

~ 1,400 (mean) j Overheads > 7 ft.

l NOTE: Hot Spot-Current Status is maximum measured / reported in PDMS Survey (s).

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A.

What has been accomplished to date?

The Decay Heat Service Coolers area (FH-006), is located in the basement of the Fuel Handling Building. This area became contaminated during the March of 1979 accident predominately from system leakage in the area and from other nearby cubicles. In j

addition, overDow from floor drains in this cubicle and other adjacent areas caused i

additional surface contamination of this cubicle. This area is the site of several additions and modifications to the Decay Heat Removal System that was used during the post-accident period.

j Early decontamination work in FH-006 included low pressum water sprays and hands-on decontamination efforts. Sections of the floor of this area have been scabbled to remove i

the upper layer of concrete. The floor and some equipment surfaces have been painted or scaled to fix or mtard surface contamination movement. Some lead shielding has been placed over area or equipment hot spots to reduce general area exposure rates.

The average geneml area radiation level is about 6.4 mR/h which is well below the PDMS SAR goal. The contamination levels are slightly above the PDMS SAR goal for this cubicle.

B.

For what purpose (s) will entry into this area be required durine PDMS?

Entry into the FH-006 area during PDMS is anticipated. Access to perimeter cubicles i

and inspection of ama equipment may be necessary during PDMS. Routine surveys will be used to determine if contamination or radiation levels are changing and to determine if contamination is spreading to adjacent areas.

C.

What is the risk associated with perfonning additional decontamination work?

l 4

Additional decontamination efforts could cause re-contamination of adjacent areas that already meet or exceed PDMS goals.

D.

Justification for not performine additional work?

The justification for not performing additional decontamination work in this cubicle is that contamination levels in this cubicle are virtually at the goal and the additional work j

required to lower the contamination levels below the PDMS goal would require an

-i estimated expenditure of approximately 100 man-hours and result in approximately 0.6.

-l man-rem to those personnel involved. In addition, this area.has been used to store contaminated equipment and lead during the PDMS period. These materials would have to be relocated prior to performing additional decontamination work.

E.

Recommended actions.

Allow this cubicle to remain "AS IS" during PDMS.

. Cubicle:

FH-101 Area MAKE-UP & PURIFICATION VALVE ROOM, 305' EL. FHB Designation:

All exposure rates in the following table are in mR/h.

2 All contamination levels in the following table are in dpm/100 cm PDMS Goal Current Status i

General. Area Exposure Rate

< 500

~ 200 (mean)

Maximum Hot Spot

< 2,000

~ 2,600 Smearable Contamination

< 50,000

- 850,000 (mean)

Below 7 ft.

Smearable Contamination in

< 50,000

~ 14,000,000 (mean)'

Overheads > 7 ft.

NOTE: Hot Spot-Current Status is maximum measured /repcrted in PDMS Survey (s),

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A.

What has been accomplished to date?

The Make-up and Purification Valve Room (FH-101) was severely contaminated during the March of 1979 accident, largely due to valve leakage that permitted primary coolant to enter this area.

Early decontamination effons in this cubicle included the removal of the block orifice which contained about 400 grams of reactor fuel debris. The presence of this material so near the entry to the cubicle provided exposure rates that did not permit extended entries. Once the block orifice was removed, several decontamination efforts reduced but did not succeed in eliminating contamination levels in the mrad /h range. These decontamination efforts included low pressure flushing and hands-on wipe-downs.

B.

For what pumose(s) will entry into this area be required durine PDMS?

No entry into this cubicle is anticipated during PDMS.

C.

What is the risk associated with cerforming additional decontamination work?

This cubicle contains significant contamination leveIs. Additional decontamination efforts could cause re-contamination of adjacent hallways or other areas that already meet or exceed PDMS goals.

l.;.

Justification for not performine additional work.

The justification for not performing additional decontamination work in this cubicle is that the additional work mquired to lower the contamination levels to (or below) the PDMS goal would require an estimated expenditure of approximately 100 man-hours and result in approximately 20 man-rem to those personnel involved. The general area radiation level in FH-101 is currently well below the goal, but is not insignificant.

E.

Recommended actions.

Allow this cubicle to remain ' AS IS" during PDMS.

Cubicle:

FH-110 Area SPENT FUEL POOL "B" Designation:

All exposure rates in the following table are in mR/h.

2 All contamination levels in the following table are in dpm/100 cm l

PDMS Goal Current Status General Area Exposure Rate

< 2.5

~ 6.9 (mean)

Maximum Hot Spot

< 2,000

~300 Smearable Contamination

< 1,000

~ 180,000 (mean)

Below 7 ft.

SmeadM Contamination in N/A N/A Overheads > 7 ft.

l NOTE: Hot Spot-Current Status is maximum measured / reported in PDMS Sun'ey(s).

i l

i -

A.

What has been accomplished to date?

The FHB Fuel Pool "B" (FII-l10) was an extmmely important area with respect to the clean-up of TMI-2. After the March of 1979 accident, the Fuel Pool area was modified to accommodate the Submerged Demineralizer System (SDS). This water clean-up system was used to remove the bulk of radioactive contaminants fmm the accident generated water (AGW). By 1988, SDS was no longer needed and was consequently decommissioned.

l During the operation of SDS, the "B" Fuel Pool area was used to contain the ion j

exchangers needed for processing the AGW. Small leaks in SDS and resin liner couplings 1

contaminated this area.

{

After the defueling of the Unit-2 Reactor Vessel had been completed, the "B" Fuel Pool f

was drained and covered to reduce the possibility of spreading contamination from the l

pool to other areas. Prior to covering the pool, other contaminated hardware from the defueling effort was placed into the "B" Fuel Pool for storage during the PDMS period.

The average general area radiation level in the pool is approximately 6.9 mR/h, and the contamination levels are above the PDMS goal.

i B.

For what pumose(s) will entry into this area be recuired durine PDMS7 l

I

^

No entry into this area is anticipated during PDMS.

C.

What is the risk associated with performing additional decontamination work?

Additional decontamination efforts could cause re-contamination of adjacent hallways or i

other areas that already meet or exceed PDMS goals.

j D.

Justification for not performine additional work.

The justification for not performing additional decontamination work in this area is that the additional work required to lower the contamination and radiation levels to (or below) the PDMS goals, would require appmximately 200 man-hours and result in about 1.4 man-rem of exposum to personnel. Clean-up of the "B" Fuel Pool area is complicated j

by the large amount of contaminated hardware that would have to be removed and decontaminated or shipped as radioactive waste. In addition, the "B"_ Spent Fuel Pool l

was covered to isolate the contamination fmm the remainder of the plant.

I E.

Becommended actions.

Allow this area to remain "AS IS" during PDMS.

l 4

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_ _ _. _ _ ___,---- - --m-

Cubicle:

FH-111 Area FUEL CASK STORAGE AREA Designation:

1 All exposure rates in the following table are in mR/h.

All contamination levels in the following table are in dpm/100 cm l

2 PDMS Goal Current Status General Area Exposure Rate

< 1,000

-0.3 (mean)

Maximum Hot Spot

< 2,000 UNKNOWN Smearable Contamination

< 1,000

~ 150,000 (mean)

Below 7 ft.

Smearable Contamination in N/A N/A Overheads > 7 ft.

NOTE: Hot Spot-Current Status is maximum measured /reponed in PDMS Sun'ey(s).

I s,

I

'i

A.

What has been accomplished to date?

The FHB Fuel Cask Storage area (FH-111) was an extremely important area with respect to the clean-up of TMI-2. After the March of 1979 accident, the Fuel Cask Storage area was modified to accommodate the Submerged Deminemlizer System (SDS). This water clean-up system was used to remove the balk of radioactive contaminants from the accident generated water (AGW). By 1988, SDS was no longer needed and was consequently decommissioned.

During the operation of SDS, the Fuel Cask Storage area was used to de-water, seal and prepare the resin liners for shipment to DOE facilities. Small leaks in SDS and resin liner couplings contaminated this area.

After the defueling of the Unit-2 Reactor Vessel had been completed, the Fuel Cask Storage area was drained and covered along with the "B" Spent Fuel Pool to reduce the possibility of spreading contamination to other areas, since these two areas cannot be isolated from each other without extensive modifications. Some contaminated SDS mlated haniware remains in this area for storage during the PDMS period.

The avenge general area radiation level in FH-lll is appmximately 0.3 mR/h, which is well below the PDMS goal.

B.

For what purpose (s) will entry into this area be reauired during PDMS7 No entry into this area is anticipated during PDMS.

C.

What is the risk associated with performing additional decontamination work?

Additional decontamination efforts could cause re-contamination of adjacent hallways or other areas that already meet or exceed PDMS goals.

D.

Justification for not performing additional work.

The justification for not performing additional decontamination work in this area is that the additional work required to lower the contamination levels to (or below) the PDMS goals, would requim approximately 100 man-hours and result in about 0.03 man-rem of exposure to personnel. Clean-up of the Fuel Cask Storage area is complicated by the contaminated hardware that would have to be removed and decontaminated or shipped as radioactive waste. Further, the "B" Spent Fuel Pool would need to be decontaminated along with the Fuel Cask Storage Area. The total man-rem estimate for both tasks would be approximately 1.43 man-rem.

E.

Recommended actions.

Allow this area to remain "AS IS" during PDMS.

i Cubicle:

FH-301 Area AREA ABOVE THE "A" FUEL POOL (347' EL) i Designation:

r i

All exposure rates in the following table are in mR/h.

2 f

All contamination levels in the following table are in dpm/100 cm

-f I

PDMS Goal Current Status j

General Area Exposure Rate

< 2.5

~ 3.9 (mean) i Maximum Hot Spot

< 2,000

~ 18 Smearable Contamination

< 1,000

~ 240 (mean)

Below 7 ft.

t Smearable Contamination in

< 10,000

~ 300 (mean)

Overheads > 7 ft.

-i NOTE: Hot Spot-Current Status is maximum measured / reported in PDMS Survey (s).

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A.

What has been accomplished to date?

The FHB Upper Fuel Pool "A" ama (FH-301) was an extremely important area with respect to the clean-up of TMI-2. After the March of 1979 accident, the Upper Fuel Pool ama was modified to accommodate the Submerged Demineralizer System (SDS).

This water clean-up system was used to remove the bulk of radioactive contaminants fmm the accident generated water (AGW). By 1988, SDS was no longer needed and was consequently decommissioned.

The Upper "A" Fuel Pool area is directly above and along the perimeter of the "A" Spent Fuel Pool. It became contaminated fmm leaks from the operation of SDS and airbome contamination releases. This ama was decontaminated by hands-on cleaning and low pressure water flushing. The avenge contamination level is well below the PDMS SAR goal but the average general area radiation level is above the PDMS goal because of the high radiation area below the "A" Fuel Pool cover. The "A" Fuel Pool cover was designed to limit the spmad of contamination but was not designed as a radiation shield.

B.

For what pumose(s) will entry into this ama be recuired durine PDMS?

Limited entry into this area is anticipated during PDMS under containment isolation procedure 4210-SUR-3244.01.

C.

What is the risk associated with performing additional decontamination work?

Contamination levels already meet PDMS goals.

D.

Justification for not performing additional work.

The justification for not performing additional shielding work in this area is that the additional work required to low:r the radiation levels to (or below) the PDMS goal, would require approximately 100 man-hours and result in about 0.4 man-rem of exposure to personnel. Additional shielding work necessary to reduce the average general area mdiation level is not necessary, because there is no need for personnel to mutinely access this area. In addition, the "A" Fuel Pool cover was not designed to support shielding materials.

E.

Recommended actions.

Allow this area to remain "AS IS" during PDMS.

Cubicle:

AX-001a, FH-102a, FH-105a & AX214a Area AFHB ENCLOSED / SHIELDED AREAS

- Designation:

I All exposure rates in the following table are in mR/h.

2 All contamination levels in the following table am in dpm/100 cm PDMS Goal Curmnt Status l

General Area Exposum Rate

< 2.5

~5.4 (mean) l i

Maximum Hot Spot

< 2,000

~ 320 Smearable Contamination

< 1,000

~ 61,000 (mean)

-l Below 7 ft.

Smearable Contamination in

< 10,000

~ 6,500* (mean)

Overheads > 7 ft.

  • Overhead value for AX-001a only. No overheads in the other areas.

NOTE: Hot Spot-Current Status is maximum measured / reported in PDMS Survey (s).

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A.

What has been accomp.lished to da_tg?

The four (4) areas listed on page one of this exc-ption are located in the 281',305' and 347' El. of the AFHB. These amas are described below.

1 Area AX-001a is the WGP-1 Shielded Enclosure. This enclosure was built after the TMI-2 accident and houses the WGP-1 pump. It is constmeted of lead and steel and has been sealed for the dumtion of the PDMS period. The enclosure is located in the basement of the Auxiliary Bui Jing and is pan of the Reactor Building Emergency a

Cooling Booster Pumps Area (AX-001).

Area FH-102a is the Unit 2 Chemistry Shielded Storage Cage. This enclosure was built after the TMI-2 accident and housed highly radioactive plant chemistry samples. It is constructed of lead and has been scaled for the dumtion of the PDMS period. The enclosure is located on the 305' El. of the Fuel Handling Building and is pan of the East Corridor Area (FH-102).

Area FH-105a is the Bomnometer Shielded Enclosum. This enclosure was built during plant constmetion of TMI-2. It was used to house the boronometer which monitored baron levels in Unit 2 water systems. It is constmeted of concrete and steel and is covemd with lead blankets and has been sealed for the duration of the PDMS period.

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The enclosure is located on the 305' El. of the Fuel Handling Building and is part of the Model Room (FH-105).

i Ares AX-214a is the Internal Area of the Decontamination Facility Tanks. The Decon

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Facility was built after the TMI-2 accident and was used to decontaminate various pieces of equipment during the clean-up phase. The six tanks inside the Decon Facility have been covered and scaled for the duration of the PDMS period. These tanks are located on the 347' El. of the k 3iary Building and are part of the Decon Facility (AX-214).

No decontamination work has been performed in AX-001a, FH-102a, or FH-105a. The Decon Facility Tanks have been drained, flushed and hand-wiped. Some lead shielding has been placed over the FH-105a enclosure.

i The avenge general area radiation level inside these enclosures is about 5.4 mR/h which is above the PDMS SAR goal. The contamination levels are also above the PDMS SAR goal for these enclosures, using the goals set for the larger cubicle or area where these -

enclosures reside.

B.

Egr what pumose(s) will entry into this area be reouired darine PDMS7 t

Entry into these enclosures is not anticipated. Access to perimeter facilities or areas including inspection of area equipment may be necessary during PDMS. Routine surveys will be used to determine if contamination or radiation levels am changing and to determine if contamination is spreading to adjacent areas.

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d C.

What is the risk associated with performing additional decontamination work?

Additiona. decontamination efforts could cause re-contamination of adjacent areas that already meet or exceed PDMS goals.

D.

Justification for not perfonning additional work.

Thejustification for not performing additional decontamination work in these enclosures is that the additional work required to lowe-r the contamination levels te (or below) the PDMS goals wotild require an estimated expenditure of about 500 man-hours and result in appmximately 2.7 man-rem to those personnel involved. In addition, these enclosures l

are sealed to prevent entry and movement of radioactive materials.

There is no anticipated need to open these areas.

E.

Recommended actions.

Allow these areas and equipment to remain "AS IS" during PDMS.

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Cubicle:

GENERIC OVERHEADS EXCEPTION (>7')

Area AFHB OVERHEADS Designation:

q All exposure rates in the following table are in mR/h.

All contamination levels in the following table are in dpm/100 cm 2

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PDMS Goal Current Status General Area Exposure Rate N/A N/A i

Maximum Hot Spot N/A N/A Smearable Contamination N/A N/A Below 7 ft.

~

Smearable Contamination in See Attached See Attached i

Overheads > 7 ft.

NOTE: Hot Spot-Current Status is maximum measured / reported in PDMS Survey (s).

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A.

What has been accomplished to date?

j The Overheads (> 7') survey data for each AFHB cunicie is shown on the attached i

sheet. In general, most overhead areas in the AFHB cubicles have had at least a low pressure gross water flush performed. In some areas (where exposure rates permitted),

l overhead cubicle piping, cable trays and other miscellaneous equipment have been l

decontaminated to < 7' values. In other cases, cubicle exposure rates have not permitted entry into the cubicle or cubicle overheads.

As a result of this effon 105 l

(90%) of the 117 AFHB locations / cubicles having overhead areas, listed on the attachment to this exception report, meet the PDMS SAR goals.

l For purposes of this radiological exception, all AFHB overhead areas are included in this

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1 exception regardless of whether they meet or do not meet the goals outlined in the PDMS SAR.

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B.

For what pumose(s) will entry into this area be required durine PDMS?

Quanerly entries into some overhead areas are anticipated during PDMS for valve line-up and containment isolation verification. Access to perimeter facilities or areas including l

i inspection of area equipment may be necessary during PDMS but are not planned at this

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time. Routine and surveillance surveys will be used to determine if contsmination or i

mdiation levels are changing during these entries and to determine if contamination is spreading to adjacent areas.

C.

What is the risk associated with performing additional decontamination work?

Additional decontamination efforts could cause re-contamination of adjacent areas or j

areas below 7 feet in cubicles that already meet or exceed PDMS goals.

j D.

histification for not performine additional work.

The justification for not performing additional decontamination work in these areas is that j

i the additional work required to lower the contamination levels to (or below) the PDMS l

l goals would require an estimated expenditure of from 4000 to 6000 man-hours and result j

in a significant expenditure of man-rem to those personnel involvea.

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i E.

Recommended actions.

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Allow these areas and equipment to remail: "AS IS" during PDMS.

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OVERNEADS Aux /FHB SURVEY

SUMMARY

SHEET 11/11/93 NUMBER OF ROOMS MEETING OVERHE AD PDMS SAR GOALS >

105

% Meeting PDMS SAR Requirements *=s>

90%

t NOTE 1: One generic exception was written for all AFHB overhemos.

NOTE 2: Cubicles with "M" designator are overhead nezzanines.

NOTE 3: A mean smear activity denoted by on "*" was calculated by adding 2 Sigma to the mean smear value below 7'.

r NUMBER OF MEAN SMEAR NUMBER SMEAR SMEAR $

SMEAR T-TEST OF RESULT ABOVE ROON Ati!VITY RESULTS SMEARS GOALS GOAL PASS / FAIL 1 Ax001 2450 3987 12 < 10000 1

PASS 2 Ax001a 6500 41227 2 < 10000 1 PASS 3 Ax002 1263 1810 10 < 10000 0 PASS 4 Ax002a N/A N/A N/A N/A

.N/A 5 Ax003 2298 3913 16 < 10000 1

PASS f

6 Ax004 754500 1468783 4 < 50000 4 FAIL 7 Ax005 29600 53051 15 < $0000 3 PASS 8 Ax006 28667 61760 3 < 50000 0 PASS 9 Ax007 21222 30312 9 < 50000 0 PASS 10 Ax008 3378050*

"AS IS" PASS 11 Ax009 5998344*

"AS !$"

PASS 12 Ax010 5116317' "AS IS" PASS 13 Ax011 4900 6722 10 < 50000 0 PASS 14 Ax012 67500 171732 4 < 50000 1

FAIL

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15 Ax013 138 226 4 < 10000 0 PASS 16 Ax014 8100 12684 10 < 50000 0 PASS 17 Ax015e 8667 10613 3 < 50000 0 PASS 18 Ax015b 13000 24073 16 < 50000 1 PASS 19 Ax015-M 5534 7769 44 < 50000 0 PASS 20 Ax016 13000 24073 16 < 50000 1

PASS 21 Ax017 8667 10613 3 < 50000 0 PASS 22 Ax018 14444 20192 18 < 50000 1

PASS 23 Ax019 5692 7153 13 < 50000 0 PAS $

i 24 Ax020 202111 326398 9 < 50000 5 FAIL 25 Ax021 11579 14897 19 < 50000 0 PASS 26 AX022 N/A N/A N/A N/A N/A 27 Ax023 N/A N/A N/A N/A N/A 28 Ax024-M 10775 17483 12 < 50000 0 PASS I

29 Ax025 311 577 10 < 10000 0 PASS 30 Ax026 1077 1214 13 < 50000 0 PASS 31 Ax027 N/A N/A N/A N/A N/A I

32 Ax101 110 156 8 < 10000 0 PASS e

33 Ax102-M 4164 7049 75 < 50000 2 PASS 34 Ax103 478 553 10 < 10000 0 PASS 35 Axt D4 471 548 10 < 10000 0 PASS 36 Ax105 530 530 10 < 10000 0 PASS 37 AxtD6 530 530 to < 10000 0 PASS 38 AX107 530 530 10 < 10000 0 PASS 39 Ax108 501 554 10 < 10000 0 PASS i

40 Ax109 128 159 10 < 10000 0 PASS

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41 Ax110 129 182 10 < 10000 0 PASS i

42 Ax111 406 478 10 < 10000 0 PASS 43 Ax112 37800 83029 5 < 50000 1 PASS i

44 Ax113-6400 11336 5 < 5n000 0 PASS 45 Ax114 34078*

"AS IS" PASS j

46 Ax115 279586*

"AS IS" PASS 47 Ax116 23143 40242 7 < 50000 2 PASS 48 Ax117-M 2414 3252 29 < 50000 0 PASS 49 ' Ax118 3017 6224 11 < 10000 1'

PASS

'I 50 Ax119 332 564 12 < 10000 0 PASS

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51 Ax120 M 1045 1930 50 < 10000 1

PASS l

52 Ax121 N/A N/A N/A N/A N/A

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53 Ax122 N/A N/A WA N/A' N/A 54 Ax123 139 178 25 < 10000 0 PASS 55 Ax124 1846 2290 13 < 50000 0 PASS I

56 Ax125 1000 1000 11 < 50000 0 PASS 57 Ax126 155 226 11 < 50000 0 PASS 58 Ax127 691 1201 20 < 50000 0 PASS

~

59 Ax128 1273 1767 11 < 50000 0 PASS 60 Ax129

$9E 736 13 < 50000 0 PASS 61 Ax130 519 540 8 < 50000 0 PASS

-l 62 Ax131 6500 11599 10 < 50000 0 PASS I

63 Ax132 97 99 10 < 10000 0 PASS l

64 Ax133 N/A N/A N/A N/A N/A 65 Ax134 45457 90930 14 < 50000 2 P/15 66 Ax135 115 128 20 < 10000 0 PASS

'l 67 AX201 N/A N/A N/A N/A 0

N/A l

68 AX202 480 480 5 < 10000 0 PASS l

69 AX203 455 501 11 < 10000 0

Pt.SS i

70 AX204 480 480 14 < 10000 0 PASS 71 Ax205 129 1 74 17 < 10000 0 PASS t

72 AX2D6 N/A N/A N/A N/A N/A 73 Ax207 N/A N/A N/A N/A N/A 5

74 AX208 N/A N/A N/A N/A N/A 75 AX209 N/A N/A N/A N/A N/A 76 AX210 N/A N/A N/A N/A N/A i

77 AE211 N/A N/A N/A N/A N/A i

78 AX212 93 93 20 < 10000 0 ' PASS I

79 Ax213 117 147 15 < 10000 0 PASS 80 AX214 96 96 10 < 10000 0 PASS i

81 AX215 N/A N/A N/A N/A N/A

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82 AX216 N/A N/A N/A N/A N/A f

83 AX217 3 74 479 14 < 10000 0 PASS 84 AX218 1000 1000 0 < 50000 0 PASS I

85 AX219 5878 10156 10 < 10000 2 PASS I

86 AX220 357 604 10 < 10000 0 PASS i

87 AX221 878 1349 16 < 10000 0 PASS 88.AX222 N/A N/A N/A N/A N/A

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89 Ax223 448 525 to < 10000 0 PASS 90 Ax301 168 225 10 < 10000 0 PASS 91 Ax302 480 480 5 < 10000 0 PASS f

92 Ax303 505 505 21 < 10000 0 PASS 93 Ax304 505 505 2 < 10000 0 PASS 94 AX305 358 1129 2 < 10000 0 PASS h

95 Ax401 N/A N/A N/A N/A N/A L

96 Ax402 231 362 10 < 50000 0 PASS 97 Ax403 127 158 10 < 50000 0 PASS 98 Ax501 2116677*

< 50000 FAIL 99 Ak502 537437*

"As IS".

PASS 100 AX503 280427'

< 50000 FAIL 101 Ax504 88735*

< $0000 FAIL f

102 FN001 89143 168619 7 < 50000 2 FAIL 103 FH002 1455 2278 11 < 10000 0 PASS 104 FH003a 76667 130400 6 < 100000 2 PASS 105 FH003b 180000 306280 2 < 100000 2 Fall 106 FN004 1124769 3052021 13 < 50000 3 FAIL 107 FH005 1500 2677 4 < 50000 0 PASS 108 FH006 1418 1875 26 < 10000 0 PASS 109 FH007 459 666 12 4 10000 0 PASS 110 FH008 4650 9243 10 < 50000 0 PASS 111 FH009 8250 -14792 4 < 50000 0 PASS 112 FH010 6250 9669 12 < 50000 0 PASS 113 FH011 19500 43525 4

  • 5000J 1 PASS 114 FH012-M 1163 1620 40 < 50000 0 PASS 115 FH013 06 96 10 < 10000 0 PASS 116 FH014 7500 10657 2 < 50000 0 PASS I

117 FH101 14100000 31905480 2 < 50000 2 Fall 118 FH102

-31369-45',43 to < 10000 8 FAIL y

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i 119 FH103 1600 2223

'10 < 50000 0 PASS 1

120 FH104 103 105 12 < 10000 0 PASS 121 FH105 101 101 10 < 10000 0

PASS'

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122 ~TH106 107 116 28 < 10000 0 PASS j

123 FH107 129 155 10 < 10000 0 PASS l

124 FH108 71 71 11 < 10000 0 PASS 125 FH109 N/A N/A N/A N/A~

N/A 126 FH110 N/A N/A N/A N/A-N/A l

127 FH111 N/A N/A

.N/A

-N/A N/A 128 FH112 843 2172 7 < 50000 0 PASS 129 FH201 9356 18629 10 < 10000 2 PASS 3

130 FH202 492 497 3 < 10000 0 PASS 131 FH203 INACCES$1BLE

< 50000 FAIL

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132 TH204 1000 1000 9 < 10000 0 PASS 133 FH205 5450 13559 7 < 50000 0 PASS 134 FH301 298 1513 2 < 10000 0 PASS 135 FH302 402 4 75 20 < 10000 0 PASS 136 FH303 155 208 17 < 10000 0 PASS 137 FH304 2167 3454 3 < 50G00 0 PASS 138 FH305 900 1663 17 < 10000 0 PASS E

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