ML20092C626
| ML20092C626 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/08/1984 |
| From: | CBI SERVICES, INC. (FORMERLY CHICAGO BRIDGE & IRON |
| To: | |
| Shared Package | |
| ML20092C619 | List: |
| References | |
| API-1, NUDOCS 8406210275 | |
| Download: ML20092C626 (8) | |
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INSTRUCfl0N API #1 RJV. NO. 2 A!. ARA PROGRAM INSTRUCTION #1 CON f RACT 14540
_T I'l LE GENT:RAL PROGRAM INSTRUCTION FOR MAINTAINING OCCUPATIONAL EXPOSURE TO RADI ATION AS LOW AS PAGE NO. I ~
of 8 IS REASONADLY ACillEVABLE ( Al. ARA) BY DATE P RE PA RED MAN 2-8-84 PRODUCT RECIRCULATION AND HilR P! PING REPLACEMENT - PEACil BOTTOM UNIT 2 CHECKED MJG 2-8-84 REVISED HAN 6-8-84 1.0 Purposo Thv purpose of this instruction in to define the Chicago Bridge and Iron (Cnt) ALAHA Program for the ruplacumont of the Hectreulation and HilR piping at Pvach Bottom Atmole Power Station Unit 2.
2.0 Motoreneo 2.1 USNRC Hugulatory Culde 8.8, "Information Reluvunt To t;nsuring That I Occupational Radiation Exposure At Nuclear Power Stations Will Do As Low As !s Hensonably Achlovable".
2.2 USNHC Hegulatory Culdo 8.10, " Operating Philosophy For Maintaining occupational Radiation Exposuro As I.ow As is Hensonably Achievablo."
2.1 Codo of Fodoral Hogulations, Titto 10 Part 20 " Standards For Protection Agalnst Had!ation."
2.4 Codw of Fodoral Hogulations, Titie 10 Part 50, Appendin 1, "Numorical Guides For Design Objectivos And 1.imitlng Conditions For Oporation To Moot The Critorlon As Low As !s Hvanonably Achivvnble For Hadloactive Maturlal in 1lght-Water Cooled Nuclear Power Itonctor Ef fluents."
2.5 ANSI NIH.1 - 1971 "Soloetion And Training Of Nucionr Power Plant Pureonno!."
2.6 Peach Bottom Administrative Procedure A-81, "AIARA Program Administration Procedure."
2.7 Peach Bot tom livalth Physics Proceduro llP0/CO-100 " Health Physica t.ulde Used In The Control Of Exposure To Hadlonctive Haturla!".
2.H Peach nottom llcalth Phystem Proceduro llP0/CO-10A " Conduct In Controlled Area - Hlnimigo Enposuro."
2.9 NUHl:0 0041 "Hanual of Hospiratory Protection Agalnnt Airborno Hadloactivo Hatorials".
Conorn!
Thin Inntruction la to be unod an a guido whenever the Hevirculation and HilH Piping repincoment involven work in a rndlntlost or contaminated area.
3.0 l,nt roduc t 1o:1 All efforts to perform tasks in a radiation environment with minimum onposure to pornonnel oro rollectively called Al.AHA (An low as rodaunably achievablo). An Al.AHA program should not imposo quantitive timita on caposure but rather ontablisho d philosophy to maintain onponuren an low dn redsondhle by onomining all ponalble alterndtIvon prior to avlection of a work mothod.
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4 I Nf>T RUCi t 0N API #1 REV. No. 2 ALARA PROGRAM INSTRUCTION di CONTRACT 14'140 TITLE GENERAL PROGRAM INSTRUCTION FOR MAINI'A!NING OCCUPATIONAL EXPOSURE TO RADIATION AS LOW AS PAGE NO. 2__ of 8 IS REASONABLY AClllEVABLE ( Al. ARA)
PRODUCT RECIRCUllTION AND THR PIP!NG REPLACEMENT - PEACll BOTTOM UNIT 2 Introdnettont Con't.
The " Reasonably Achievable" aspect of the ALARA Program must take into account parameters such as cost, time, and quality in order for ALARA to be realistic and practical.
The following description of the CBI ALARA Program discusses the planning, preparation, and implementation ef forts which will be used for the replacement of the Recirculation and RilR piping at Peach Bot Lom Power Station Unit 2.
4.0 !!cinet ton of Methosts. Prorossou and Techniqiie,s, Prior to establishing written proevdures, various methods, processes, and techniques will be avaluated. The group or groups responsible for review will exam'no the attornativos presented, point out the advantaron and the disadvantages of each alternative, and decide the most desirable choice.
Four paramotors that will be considered aret 4.1 Radiat f ori Exposure - Each technique discussed will be evalunt.sd on the basis of collective radiation doso emphted, as well as individual exposure estimates. A total cettmato of radiation caposure will be compared to other alternativWs. A technlque that causes #NCessiv#
exposure compared to another equally acceptable alternative will be discarded as not mcatinr, AIARA objectives.
4.2 Cost - The cost of a particular Choitu minst be conaldurwd in any analysis. Execesive costs to save a lit (10 esposure may nnt he a
" Reasonably Achievablu" attornative. Provlous esperience on m4jor repair and maintenance outages at Nisclear Power Plant a shows that most radiologleal control practices are cost of fective in the final analysis.
4.1 Time - The time spent to complete a aparlfic technique or method can be approached from two viewpoints. The first viewpoint looks at the length of flme a partirular technique wlll take (how long it will retend the otstagn as compared with other alternatives). The second viewpoint looks at the length of timo a particular technique requires personnel to remain in radlaflon or contalml nation arease The more time a method or technique can sAv#, the Mdre attractive It may bW from an Al. ARA standpoint.
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i IN87MUCfl0N API il NKV. NO. 2 ALANA PRnCRAM IN5fMUCTION #1 CONT _RACT 34140 T ITLt. C5NEMAl. PMOGNAM IN!iTRUCTION tr0N MAINTAINING OCCUPATIONAL EXPOSURE TO MADI ATION AS LOW AS PAGE NO. 1 of ~
A i 18 REASONAHLY ACHlf,VABLE ( ALANA)
I PRODUCT NECIRCULATION AND RHR PIPING I REPLACEMENT - PEACH BOTTON UNIT 2 4.4 Quality Control - The quality control aspect of a particular tvehnique la of utmost leportance if there la a direct impact on plant safety or integrity. Ilowever, if items worked on are to be scrapped, quality control will be of little or no significance.
5.0 3delnlatrative l Control 5.1 The CBI AI.ANA Administrator la assigned to serve as a member of the Project Team. The ALARA Administrator will attend the Plan of the Day and Dally Progress Hvetings and act as a lialsen betwoon CBI Administration / Craft and the CAI Radiological Kngineers. Attend Plant ALANA Co.emittop Hveting to Report and discuss the the Progress of the CA!
ALARA Program. The CBI ALARA Adtninletrator or his designated alternate will call Chi proplanning meetings during the outage with the radiological Engineers and craf t personnel to discuss ALARA objectives and radiological poroblems associated with the job.
Hectine will be called whenevert 5.1.1 A major task la about to be undertaken.
5.1.2 A line or system is about to be breached which could const(tute a significant radiological hasard.
5.1.3 Nadiation levels in the work areas have significantly changed.
5.2 Pre planning meetings will be held in order to discuss the following methods to reduce esposure.
5.2.1 Identifying areas where esposures can be reduced.
5.2.2 Dividing the job into smaller, ma'aler to handle work patkages.
5.2.3 Identification of high radiation areas around work areas.
b 2.4 Assigning responsibilities for netions to be taken.
5.2.5 Neview of particular job assignments to ensure individuals understand job functions.
5.2.6 Review with workers radiation protection r#<luirements and not i fleat ions.
5.1 Af ter completion of work, a post-tank ALANA review will be held. The Ahlf t Radiological t"gineer will schedule and chair the meeting, and discuss the success of the actions ta6en as a result of the prs = job planning, and suggeseted improvempt t o l
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INSTNUCfl0N API fl RJ.V. NO. 2 l .
Al.ANA PNOCRAM INSTRUCTION fl CONTRACT 14540 l
TITLE GtNF. mal. PMOGNAM INSTMUCTION FON MAINTAINING OCCUPATIONAL. EXPOSUME 10 PADI ATION AS LOW AS PAGE NO. 4 of 8
- IS REASONARLY ACHIEVABLE ( ALAMA)
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PRODUCT REclRCULATION AND MilR P! PING
! ItEPLACEMENT - PEACil BOTTON ifNIT 2 f l
i 6.0 M ponsibilities -
6.1 The Radiological Engineers main Job functions are as follows:
1 6.1.1 Maintain an overall knowledge of work in progress, and the .
general radiological conditinns associated with that work. !
6.l.2 Attend Plan-Of-The Day and/or Daily Progress Montings and serve l as llason between functional groups pertaining to matters of radiation safety to include liaison with the Program AI. ARA .I Coordinator, the PECO Senior livalth Physicist, Support Health l Physicist, and applied llealth Physicist. ;
6.l.3 Provide technleal assistance concerning radiological safety i problems.
6.l.4 Keep Site Manager informed of radiological safety problems, }
and the set tons being taken to resolve those probleme. ;
6.l.1 Review radiological surveys performed by llealth Physics "
Personnel so that general esposure levels and local hot spots in the work area are identified. Review shleiding.
containments, ventilation, and other methods of reducing !
radiation and contamination levels.
6.l.6 Discuss most ef fielent ingress and egress routes for personnel at work sites.
6.1.7 Noview work on a continuing basis. The Radlological Pngineers '
will work closely with plant llealth Physics and Craf t Poremen to ensure they are aware of saan= rem hudgets. and actual totale for the various portions of work being performed.
6.l.M Peep track of individual and collective esposures on a routine l hasis. Work with CRI Project and Plaid Pngin era and Craf t t Poremen to effectively utillas er,ift labor, i-f
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INSTRUCTION API #1 REV. NO. 2 ALARA PFOGRAM INSTRUCTION #1 CONTRACT 34540 TITLE GENERAL PROGRAM INSTRUCTION FOR MAINTAINING OCCUPATIONAL EXP3SURE TO RADIATION AS LOW AS PAGE NO. 5 of 8 IS REASONABLY ACllIEVABLE ( ALARA)
PRODUCT RECIRCUL.4 TION AND RHR PIPING REPLACEMENT - PEACH BOTTOM UNIT 2 6.1.9 Ensure that CBI personnel and subcontractor personnel are adhering to Radiation Work Permit (RWP) procedures for their particular job assignments.
6.1.10 Keep personnel informed about current radiological conditions.
6.1.11 Ensure that personnel understand their job function and job location.
6.1.12 Ensure RWP's for the day /sh!.f t/ job are written and initiated to support the work schedule.
7.0 Man-Rem Estimate 7.1' An estimate of collective radiation exposure for the Recirculation and RHR Piping Replacement will be made in order to establish man power needs. 'The estimate will assist management in determining areas of emphasis for shielding and decontamination.
7.2 Man-Rem subtotals for each task will be used as a guideline for comparing actual man-rem accumulations during the course of the piping replacement.
7.3 Changes to the job scope will be evaluated when comparing actual and estimated man-rem totals. 8 i
7.4 Temporary shielding will be used in areas where it c'an be shown to be e f fec tive . When temporary shielding is being considered, it must be shown that shielding installation, maintenance and removal will not exceed the projected man-rem savings.
7.5 Reviews to determine the necessity for shielding will include the following factors:
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INSTRUCTION API #1 REV. NO. 2 ALARA PROGRAM INSTRUCTION #1 CONTRACT 34540 TITLE GENERAL PROGRAM INSTRUCTION FOR MAINTAINING OCCUPATIONAL EXPOSURE TO RADIATION AS LOW AS PAGE NO. 6 of 8 IS. REASONABLY ACHIEVABLE ( ALARA)
PRODUCT RECIRCULATION AND RHR PIPING REPLACEMENT - PEACH BOTTOM UNIT 2 7.5.1 Detailed radiation surveys of the work areas to identify the general levels, radiation levels at 12 to 18 inches from the surface of the radiation source, and contact radiation levels.
7.5.2 Estimates will be made of the number of individuals who will occupy a particular work area and length of time spent in those areas.
-7.5.3 The number of skilled craftsmen needed to complete a job in certain areas will be given consideration.
7.5.4 ' Flushing of " Hot Spots" or specific area decontamination will be considered as an alternative to shielding. In some instances, flushing and decontamination will be atteopted before shielding is erected.
7.5.5 Required controls will be applied to all areas which are classified as high radiation areas. Access to such areas will be restricted to keep personnel from receiving unnecessary exposures.
8.0 Radiation Training All personnel will be required to attend the General Employee Training and Radiological Safety Class at the Peach Bottom Training Center. Specific task training will be specified on a case by case basis.
9.0 Specialized Equipment Pipefitters and welders will be given extensive training on specialized equipment such as pipe cutting machines and automatic welding equipment.
Training will concentrate on set-up and removal operations for the equipment. Since the set-ur and removal times are usually time consuming, significant radiation exposure savings will be achieved by performing those operations as efficiently as possible.
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INSTRUCTION API #1 REV. NO. 2 ALARA PROGRAM INSTRUCTION #1 CONTRACT 34540 i TITLE GENERAL PROGRAM INSTRUCTION FOR MAINTAINING OCCUPATIONAL EXPOSURE TO RADIATION AS LOW AS PAGE NO. 7 of 8 IS REASONABL,Y ACHIEVABLE ( ALARA)
RECIRCULATION AND RHR PIPING PRODUCT REPLACEMENT - PEACH BOTTOM UNIT 2 10.0 Mock-up Training ;
A' mock-up facility will be fabricated on site in order to simulate the work area around the Recirculation and RHR piping and associated systems.
The training in the mock-up will include the use of anti-contamination and respiratory protection equipment prescribed for work in the drywell. The mock-up training will also include glove bag and tent training whenever required. Mock-up training is intended to accomplish the following objectives:
10.1 Familiarize workers with the physical orientation and restraints of the work area.
10.2 Confirm that tools and equipment will function as intended and no additional items are needed.
10.3 Identify possible ways of improving or simplifying the task from the standpoint of job performance, quality control, and radiological control.
10.4 Determine that temporary. shielding or contamination control arrangements will function as intended and will not be counter productive with respect to ALARA objectives.
11.0 Radiation I Control Man power will be estimated on the basis of the existing radiation levels, and historical dose exposure during drywell entries.
Routine evaluations will be performed as a planning aid to determine the adequacy of craft manpower to perform skilled work in high radiation areas. Radiation exposures will be measured daily and added to previous accumulations in order to control individual exposures within the established limits for each calendar quarter. Daily exposures will also be grouped under various job categories so that estimated man-rem exposures can be measured and compared to existing man-rem in order to evaluate the
' ef fectiveness of the ALARA Program.
Considerable pre-insta11a' tion work will be accomplished. Weld preps and other machining will be done on piping spool pieces and elbows outside of radiation areas, whenever pessible.
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INSTRUCTION API #1 REV. NO. 2
_ _ _ , _ ALARA PROGRAM INSTRUCTION fl CONTRACT 34540 TI TLE GENERAL PROGRAM INSTRUCTION FOR MAINTAINING OCCUPATIONAL EXPOSURE TO RADIATION AS LOW AS PAGE NO. 8 of 8 IS REASONMBLY ACHIEVABLE ( ALARA)
PRODUCT RECIRCULATION AND RHR PIPING REPLACEMENT - PEACH BOTTOM UNIT 2 12.0 Contamination Control 12.1 Anti-contamination clothing and equipment will be worn routinely for entry into the drywell and other designated areas. Additional protective equipment will be prescribed on the Radiation Work Permits for unusual conditions which may be encountered.
12.2 The Recirculation and RHR piping will be decontaminated in order to reduce radiation and contamination Icvels.
12.3 Portable filtered ventilation units will be used as a control measure to reduce the possibility of airborne contamination during certain operations.
12.4 A general policy of wrapping contaminated materials, will be followed. This practice is effective in minimizing the spread of contamination when items are transported from one area to another.
Emphasis will be placed on good housekeeping throughout the project to maintain clean and safe work areas.
13.0 . Airborne Activity Control and Respiratory Protection The airborne activity levels of work areas vill have an overall effect on the accomplishment of work from an ALARA standpoint.
Routine air samples along with job specific air samples will be taken and evaluated to determine the respiratory protection requirements for the workers.
Constant air monitors will also be used to determine airborne activity levels during long term jobs and for alerting personnel to immediate increases in activity.
The objective of the Respiratory Program will be to limit potential internal uptake due to airborne radioative material, when it is impossible to apply process or other engineering controls to limit the concentration of radioactive materials in air.
14.0 Radioactive Material Handling, Packaging, and Shipping Requirements
'All handling and packaging of radioactive materials will be in strict accordance with Peach Bottom Station procedures. In addition, CBI Radiological Engineers will require specific packaging, isotopic anaylsis, and surveying for certain materials prior to turn-over to station personnel.
The packaging and shipping of radioactive materials will comply with Nuclear Regulatory Commission, Department of Transportation, and Peach Bottom Station requirements.
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