ML20128Q973

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Radiation Control Program
ML20128Q973
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 05/31/1985
From:
VERMONT YANKEE NUCLEAR POWER CORP.
To:
Shared Package
ML20128Q946 List:
References
PROC-850531, NUDOCS 8506040362
Download: ML20128Q973 (42)


Text

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ATTACHMENT A TABLE OF CONTENTS VERMONT YANKEE

~ RADIATION EXPOSURE CONTROL PROGRAM 1.0 Introduction

- 2.0 Recirc Replacement Project Organization 2.1 Vermont Yankeb Health Physics Responsibilities 2.2 Morrison-Knudsen Health Physics Responsibilities 3.0 ~ Procedural Controls 3.1 Controlled Work Packages 3.2 Radiation Work Permits 3.3 Exposure Control Procedures 4.0 ALARA 4.1 Introduction 4.2 Pre-project Planning 4.3 ALARA Estimate Process 4.4 Evaluation of Drywell Radiation Fields 4.5 Radiation Zones and Dose Rate Projections 4.6 Initial ALARA Estimate 4.7 Controlled Work Package ALARA Reviews 4.8 ALARA Tracking 4.9 Ongoing ALARA Reviews 4.10 Post Job ALARA Reviews 4.11 ALARA Briefings 5.0 Engineering Controls 5.1 Pipe Chemical Decontamination 5.2 Nozzle Hydrolasing 5.3 In-vessel Set Up Considerations 5.4 Shielding 5.5 Ventilation 5.6 Field Welds 6.0 Contamination Control 6.1 Control of Contamination Generation 6.2 Control of Drywell General Area 6.3 Control of Contamination and Airborne Radioactivity 6.4 Contamination Containment Areas 6.5 Control of Contaminated Tools and Equipment 6.6 Miscellaneous Contamination Containment Areas 6.7 Respiratory Protection Considerations

'6.8 Alpha Contamination

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TABLE OF CONTENTS VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM 7.0 Facilities and Equipment 7.1 Facilities 7.2 Equipment 8.0 Additional Health Physics Support 8.1 Electrical Support 8.2 Communications 8.3 Training 8.4. Radioactive Waste Disposal i

y PAGE 1 0F 23 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM

1.0 INTRODUCTION

Vermont Yankee Nuclear. Power Corporation is planning to replace IGSCC susceptible piping in the Recirculation and portions of the RHR systems at its 540 MW Nuclear Generating Station. Replacement of this piping will be the primary scope of work planned for an outage scheduled

-to commence in September, 1985.

Because the drywell work is of unprecedented magnitude, manpower intensive, and will be implemented under hard radiological conditions, a Radiation Exposure Control Program (RECP) has been developed to address the specific demands of the Replacement. Project.

The ultimate goal of the RECP is to ensure an integrated exposure control and reduction program that will enable Vermont Yankee and

-contractor personnel to function as a unit. This holistic approach will ensure that occupational exposures to ionizing radiation are maintained as low as reasonably achievable in accord-ance with requirements of 10CFR Part 20.

~PAGE 2 0F 23 VERMONT YANKEE-RADIATION EXPOSURE CONTROL PROGRAM 2.0 RECIRC REPLACEMENT PROJECT ORGANIZATION Two principal organizations comprise the Vermont Yankee Recirculation Piping Replacement Project: Vermont Yankee Nuclear Power Corporation and Morrison-Knudsen Company, Inc. (referred.to as contractor).

Vermont Yankee Nuclear Power Corporation has established a dedicated Recire Project Team to manage and represent the interests of Vermont Yankee with regard to the Replacement Project. The Vermont Yankee Nuclear Power Station Organization is shown in Attachment 1.

The Vermont Yankee Recirc Project Team organization is depicted in Attachment 2.

The Morrison-Knudsen Recirc Replacement Project Management organization is depicted in Attachment 3.

2.1 Vermont Yankee Health Physics Responsibilities The Vermont Yankee Health Physics staff will control operational radiation protection, and has the ultimate responsibility to maintain exposure as low as reasonably achieveable. Vermont Yankee will manage health physics personnel providing radiological coverage and performing routine and RWP-related radio-logical surveys. Vermont Yankee Health Physics will provide all normal health physics support, including:

respiratory protection equipment, protective clothing, dosimetry processing and dose tracking, radiological survey and counting instrumentation, etc.

2.2 Morrison-Knudsen Health Physics Responsibilities The Morrison-Knudsen Health Physics staff will provide radiological engineering and ALARA support. Morrison-Knudsen Health Physics will also interface between Morrison-Knudsen work groups, Vermont Yankee Health Physics staff, and other health physics contractors.

Morrison-Knudsen's primary responsibilities prior to the outage have been to assist in the development of an in-tegrated Radiation Exposure Control Program. Although the contractor has reviewed all major aspects of radiation protection during RECP development, major efforts have been concentrated in the areas of ALARA estimates, health physics procedures, contamination control, shielding, health physics support, pipe chemical decontamination, and disposal of the removed recirculation piping.

r PAGE 3 0F 23 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM 3.0 PROCEDURAL CONTROLS The Radiation Exposure Control Program is designed to use existing Vermont Yankee health physics procedures and policies whenever possible. However, if existing procedures do not adequately address the specialized requirements of the Replacement Project, supplementary procedures will be implemented. Additional procedures will be written and approved prior to the beginning of the outage whenever anticipated.

If necessary, procedures will'also be upgraded or developed during the outage to provide Radiation Exposure control over unexpected deviations in project.

3.1 Controlled Work Packages The overall approach to work control will be based on an engineering work package concept.

The contractor has in-corporated each identified work function into a controlled engineering work package. Work packages normally consist of a Site Work Instruction, Material Data Sheets, Process Control Documents (such as Weld Data Cards), and drawings.

All controlled work packages are evaluated with respect to technical, radiological, and practical construction con-siderations during development. All contractor work pack-ages are reviewed and approved by Vermont Yankee. Attach-ment 4 depicts the typical flow path for the life cycle of the contractor's work packages. The inherent, integrated review cycle of the work packages ensures involvement of all disciplines in determining the most effective manner of executing the work so as to maintain exposures as low as reasonably achievable.

3.2 Radiation Work Permits The contractor's controlled work package preparation process ensures incorporation of "ALARA" concerns and considerations in long range pre-planning. The Vermont Yankee RWP. procedure will ensure carry through of identified long range concerns and will provide an additional, current ALARA review immediately prior to undertaking the work.

The Vermont Yankee RWP procedure requires the Health Physics Assistant preparing the RWP to review the proposed work for ALARA considerations and to note ALARA requirements on the permit.

PAGE3J!of23 3.3 Exposure Control Procedures-In addition -to the Radiation Work Permit' process, Vermont Yankee uses other health physics procedures to ensure effec-tive ' control and minimization of exposure.

Examples of critical areas governed by procedures include,- but are not limited to:

-Criteria and guidelines for appropriate dosimetry badging of personnel as stated in AP0506; Personnel Monitoring.- These

' guidelines' ensure that the personnel monitoring requirements of 10 CRF 20 are observed.

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PAGE 4 0F 23 VERMONT YANKEE

' RADIATION EXPOSURE CONTROL PROGRAM

-Administrative exposure control limits and exposure upgrade authorization process as stated in AP0501; Radiation Protection Standards..

This mechanism ensures that super-visory personnel carefully review exposure considerations when planning assigning tasks to their personnel.

-Requirements for establishing and posting of controlled areas' as stated in AP0503; Establishing and Posting Controlled Areas.. These requirements serve to ensure that the post-ing requirements of 10 CFR 20 are observed in addition to minimizing exposure to personnel.-

-Requirements concerning tne selection and use of respira-tory protection equipment as stated in AP0505; Respiratory P rotection. These requirements serve to ensure the proper implementation and application of respiratory protection equipment when radiological conditions dictate so as to maintain potential for internal exposure to radioactive materials as low as reasonably achievable.

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PAGkT5 0F 23 VERFONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM

~4.0 ALARA 4.1 Introduction During normal operations and routine outages-Vermont Yankee

.successfully ensures that occupational exposure to ionizing radiation is maintained as low as reasonably achievable through worker awareness supported by an aggressive operational radiation protection program. The Vermont Yankee Radiation Exposure Control Program for the 1985 Replacement Outage provides additional administrative and engineering functions designed to estimate, track, and~further reduce both individual and collective occupational radiation exposures.

4.2. Pre-project Planning 4.2.1 1984 Investigation Outage In June 1984, Vermont Yankee shutdown for a normally scheduled refueling outage. During this shutdown, carefully planned investiga-tion of drywell physical and radiological con-ditions was conducted by the contractor. The contractor's activities were governed by investi-gation work packages that addressed the scope of investigative worjt. These work packages were reviewed and approvbd by Vermont Yankee.

Subsequent to the outage, an Outage Report was prepared by the contractor.. This report pre-sented the contractor's data and findings in an organized manner for use in pre-planning for the Replacement Project.

4.2.2 " Management Plan s

Following completion of the 1984 Outage Report, a Management Plan was prepared by the contractor.

The Management Plan described the contractor.'s de-tailed approach to performing the preparatory work required for an effective state of readiness for the 1985 Replacement Outage. The Management Plan was re-viewed and approved by Vermont Yankee.' The contractor!s

's approved Management Plan serves as an " umbrella" docu-ment that is referenced to ensure that necessary pre-parations for the outage are not only accomplished, but accomplished on schedule.

r-PAGE 6 0F 23 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM 4.2.3 Historical Research The Recirc Project Team began identifying specific areas of ALARA concern in the Fall of 1984 by actively seeking historical radiological information related to previous recirc pipe replacement projects as well as making numerous field trips to observe other pipe replacement projects in progress. Historical research is an ongoing adjuct to the outage preparation process. As information is received, it is reviewed, analyzed, and incorporated into outage preparations. This conscious effort to learn from industry experience will greatly assist Vermont Yankee in ensuring that exposures to personnel are maintained as low as reasonably achievable.

4.3 ALARA Estimate Process An ALARA estimate consists of an assessment by radiological per-sonnel of the expected total person-Rem that will be accrued during the performance of an activity. ALARA estimates identify those activities which will contribute most significantly to accumulated personnel radiation exposure. These activities then receive greatest attention with respect to finding and applying exposure reduction techniques.

ALARA estimates are performed and used by the contractor to assist in pre-job planning and decision-making during the pre-outage work package development process.

During the outage the current ALARA estimate will serve as a bench-mark by which exposure reduction efforts will be measured.

Activities that appear to be significantly exceeding their respec-tive estimates will be reviewed to determine whether the estimate is incorrect or exposure reduction methods are failing. Estimates will be adjusted and further exposure reduction techniques will be employed as necessary.

The overall ALARA estimate process (see Attachment 5) is based upon establishing an initial, working ALARA estimate associated with the performance of the activities on the outage baseline schedule. This initial ALARA estimate is then refined and revised through ongoing analysis at critical points in the project.

PAGE 6A of -23 Work package preparation for the Replacement Project began in early 1985. An ALARA review has been an integral part of work package development. ALARA reviews were performed by MK health Physics supervisors, the Recirc Project ALARA Engineer and if reqLested, by the Plant. Health Physics Supervisor.

ALARA reviews focus on exposure reduction methods, indentifi-cation of major radiological concerns, and refinement of exposure estimates. As a specific work procedures take shape within a work package, more accurate assessments are made concerning worker time in area and specific area of work.-

PAGE 7 0F 23 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM Once the 1985 Replacement Outage begins, a review of radiation survey data and a revision to the ALARA estimate will be made based on actual drywell dose rates. Additional reviews and revi-sions will take place subsequent to post pipe decontamination sur-veys and post pipe removal surveys. Other reviews and revisions will be made as deemed necessary by outage health physics management.

ALARA estimates and estimate revisions performed by the contractor are submitted to Vermont Yankee for review and approval.

4.4 Evaluation of Drywell Radiation Fields During the 1984 Vermont Yankee refueling outage extensive gamma radiation surveys were conducted in the drywell to obtain baseline levels for dose rate projections for the Replacement Project.

Normally, radiation surveys were taken on contact and at 18" from piping / components exhibiting significant radiation levels.

General area radiation dose rates were also taken. When appli-cable, pipe, component, and system status were documented to pro-perly reflect the environment surrounding and contributing to radiological conditions.

In an effort to estimate radiation fields after the plant has operated on an additional fuel cycle, survey results were increased by an average buildup factor based on previous fuel cycle results.

4.5 Radiation Zones and Dose Rate Projections The Vermont Yankee drywell was divided into zones for use during dose rate projections and exposure estimates.

During the Replacement Outage, several major evolutions will occur that result in relatively predictable, significant changes.in radiation levels. These changes in conditions were addressed and specific dose rates were assigned to each zone for each major change of condition.

Vermont Yankee plans to conduct an in-situ chemical decon-tamination of the Reactor Recirculation System piping. Therefore, it was necessary to assess the impact on projected radiation levels by the planned chemical decon.

Although component specific decontamination factors (DFs) of 100 or greater can be obtained, they are a poor means of analyzing changes in overall general area dose' rates. Thus, the evaluation of DFs was restricted to general raea decontamination factors.

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r PAGE _8 0F 23 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM General area DFs historically range from a low of 2 to a high of

15. A general area DF of 5 was chosen as a reasonable, conser-vative figure for use in the initial ALARA estimate with respect to drywell elevations 238', 252', and 269'.

A DF of 2 was applied to the nozzle regions due to historic difficulties in achieving significant dose reductions in these areas.

4.6 Initial ALARA Estimates The initial ALARA estimate was generated based upon analysis of estimated exposure accrued per task. Total occupational radiation exposure for replacement of piping at Vermont Yankee in accordance with Morrison-Knudsen's current baseline schedule is estimated to be 1392 person-Rem.

Exposure estimates by work package are sum-marized in Attachment 6.

This estimate represents the first milestone in an evaluation pro-cess that will be continued up to and throughout the recirc pipe replacement project. The data base established to generate this estimate will be updated as decisions are made and more infor-mation is received.

For the most part, exposure estimates were based on currently planned Morrison-Knudsen controlled work packages. When appli-cable, work packages were broken down into major activities. Dose was assigned based upon the specific craft / manpower resources needed to support a given activity.

Certain dose contributing functions exist that are not covered by a planned Morrison-Knudsen controlled work package.

" Dummy" work package numbers have been assigned to these functions for exposure estimate and tracking purposes.

4.7 controlled Work Package ALARA Reviews Controlled work package ALARA reviews are conducted by health phy-

' sics personnel. These reviews provide the opportunity to reflect major radiological concerns within the body of a work package via health physics hold points. This facet of the work package ALARA review program is meant to supplement the use of Vermont Yankee Radiation Work Permits, not substitute for them.

PAGE '9 0F 23 VERMONT. YANKEE RADIATION EXPOSURE CONTROL PR'0 GRAM

-Additionally, the'Morrison-Knudsen controlled work package proce-dure requires that the applicable-Discipline Engineer complete an ALARA Review Checklist for each of his assigned work packages.

This requirement ensures that the engineer.gives consideration to exposure concerns and exposure reduction methods in the course of work package preparation.

The ALARA Checklist.is reviewed by Health Physics to ensure con-sistent,-thorough, documented reviews. The ALARA Review Checklist reflects ALARA criteria and considerations found in Reg Guides 8.8 and 8.10 as well as other experience based concerns.

4.8 ALARA Tracking ALARA tracking will be initiated'on a daily basis during the 1985 Replacement Outage. The ALARA tracking system will compare actual exposures.and' time in areas to current estimates. Significant overruns of actual exposure or time in area versus current estima-c tes will be identified and investigated. When practicable, steps will.be taken to reduce overruns to within or below estimate

-levels.

4.9 Ongoing ALARA Reviews ALARA reviews will take place while work is in progress. There are several aspects to ongoing _ ALARA reviews.

Health Physics technician input to Vermont _ Yankee and Morrison-Knudsen Health Physics management will be used as a con-tinuous, inherent part of the.ALARA review process.

Vermont Yankee and Morrison-Knudsen Health Physics management will periodically inspect work areas with regard to evaluating radiolo-gical control work practices' and identifying additional exposure i

4 reduction methods.

-ALARA reviews will be initiated to investigate anomolies iden--

tified by-the ALARA tracking report. When applicable, lessons learned in the performance of an activity will be projected for-

. ward _to similar activities by way of work package or RWP modifica-tions.

4.10 Post Job ALARA_ Reviews Post job ALARA. reviews will be conducted on significant, dose intensive activities. These reviews will include information gathered during ongoing reviews as well as post job analysis.

Lessons identified during post job reviews will also be projected forward whenever possible.

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. VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM 4.11 ALARA Briefings Providing worker briefings and ensuring their understanding of radiological conditions and protective clothing requirements is a normal part of the Vermont Yankee RWP issuance. process. Prior to major, dos ~e intensive evolutions, more extensive briefings will be provided to the personnel involved.

In addition to significant texposure considerations,.these extended briefings will concentrate heavily on providing 'an overall understanding of the evolution.

This will enable individuals to better understand the potential effects of their actions with respect to the activity as a whole.

This will assist in mitigating unnecessary exposure to personnel due to misunderstanding and interface problems.

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n PAGE 11 0F 23 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM

.5.0 ENGINEERING CONTROLS Vermont Yankee and the contractor will be implementing various methods of engineering control to ensure that personnel exposures are maintained as low as ' reasonably achievable during the Replacement Project.

5.1 Pipe Chemical Decontamination An in-situ dilute chemical decon will be performed on Vermont

. Yankee's Recirculation Piping System and drywell portions of Residual Heat Removal System. Reactor. Water Clean Up System piping in the drywell may also be decontaminated.

The effectiveness of this technique in significantly reducing per-sonnel exposures to ionizing radiation when a large amount of drywell work is necessary.has been clearly demonstrated at other-plants and at Vermont. Yankee.

In addition to the obvious exposure reduction: benefit, the chemi-cal decon will substantially reduce the potential for airborne radioactivity problems when the "old" recirculation pipe is cut and. transported.

Finally, radioactive shipping requirements for disposal of-the pipe will be simpler'and~1ess' expensive because of the lower acti-vity on the pipe.

15.2 Nozzle Hydrolasing Vermont Yanke'e currently. plans to hydrolase the back side ~of the N2 nozzle thermal sleeve areas (from the reactor vessel side)~

prior to any significant work on the N2 nozzles. This technique was employed by Vermont Yankee in 1983 and resulted in a substan-tial dose reduction in the general area-of the nozzles.

5.3 In-vessel Set Up Considerations The Recirc Project Team is evaluating options associated with set up-of'the vessel in order to optimize overall exposure reduction.

Although subject to change pending receipt of new information, the current approach is described below and is representative of the areas being considered.

PAGE 12 0F 23 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM 5.3.l'.The in-shroud water level will be maintained just below the jet pump slip joint to take advantage of the shielding.

5.3.2.The control rods will be positioned so as to minimize the impact of dose rates in the N2 nozzle region from the stellite balls.

5.3.3 The N1 nozzles will be shielded from the reactor side via installation of.a shield plug.

5.3.4 The reactor vessel will be ventilated to reduce the poten-tial for airborne radioactivity.

5.3.5 It is expected that at least one layer of cavity shielding will be replaced when the reactor vessel is drained for the pipe replacement'in order to minimize dose rates on the refuel floor.

5.4 Shielding

-Morrison-Knudsen is developing a program for installation of shielding in the drywell in order to reduce radiation levels from-sources uf radiation that Jare significantly contributing to expo-sure levels in the areas of work.

-The criteria for determining use of shielding includes:

-Ensuring that the person-Rem required to install the shielding is justifiable in light of anticipated exposure savings.

-Minimizing movement / relocation of shielding once installed (i.e.;

ideally shielding should only be removed upon completion of work in~the area).

-Ensuring that the shielding is properly supported and does not affect the integrity of components or piping.

Areas being reviewed for application of shielding include:

-localized hot spots.

-open ends of pumps and majcr valves being left in the drywell.

-framework area around the N1 and N2 nozzles.

-internal N2 nozzle shielding.

PAGE 13 0F '23 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM The shielding program will be conducted in accordance with Vermont Yankee's procedures. Vermont Yankee will review and approve the contractor's shielding program prior to implementation.

5.5 - Ventilation

-The nature of the work to be performed, as well as recirc pipe replacement' history, dictates that reliable, local.HEPA ven-tilation capability be available in the drywell. Local HEPA ven-tilation aids in the' effective control of loose surface and airborne contamination.

Currently, it is planned to provide a nominal 16,000 SCFM local ventilation capability in the~drywell. Manifolds and multiple suction lines will be used in order to maximize availability of ventilation in immediate work areas.

Existing drwyell ventilation will be used to the extent prac-ticable to assist in providing for continuous air turn over in the drywell. This will allow movement of air from less contaminated areas to more contaminated areas.

Additional, portable HEPA units (nominally 1,000 and 2,000 SCFM capacity) will be available to support localized activities outside the drywell (eg: decon areas, contaminated equipment rework ares, etc.).

All HEPA units will be maintained, tested, and serviced in accor-dance with existing Vermont Yankee procedures.

5.6 Field Welds The number of field welds required in the drywell nas been kept to a minimum. The size of spool pieces being rigged into the drywell will be as large as possible in order to reduce the

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1arge amount of exposure associated with well preps and the actual welding process.

PAGE 14 0F 23 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM 6.0 Contamination Control The Radiation Exposure Control Program deals with contamination control in three areas:

control of contamination generation, control of drywell general area contamination levels, and control of contaminated tools and equipment.

By minimizing the generation and spread of contamination, inci-dence of personnel contamination will be maintained as low as reasonably achievable.

6.1 Control of Contamination Generation Morrison-Knudsen will exercise control of contamination generation through preferential use of mechanical cutting versus plasma arc whenever practicable and application of engineering controls. The entire scope of work has been evaluated to identify the activities likely to contribute significantly to loose surface and/or air-borne contamination. This evaluation is used by Morrison-Knudsen engineering and construction personnel as a reference during work package development.

Radiological engineering methods that will be selectively applied to control the production of loose surface and airborne con-tamination include:

-localized HEPA ventilation units.

-portable HEPA vacuum cleaners.

-pre-manufactured glove bags.

-field erected containment " tents".

-local decontamination prior to work.

6.2 Control of Drywell General Area Centamination Two concerns are being reviewed with regard to drywell general area contamination control. A method will be selected to support an overall, major drywell decon effort. Methods are also being evaluated to employ in maintaining an ongoing, daily general area drywell decon effort.

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-se VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM 6.3 Control of Contamination and Airborne Radioactivity Emphasis will be placed on control of loose surface contamination and potential airborne radioactivity generating situations.

Contamination and airborne control methods to be used include:

-A crew per shift available for decon work in the drywell.

-Use of general area and job. specific HEPA ventilation.

-Minimization of grinding, flapping, buffing, welding, etc. on ID of contaminated piping.

In most cases where this is likely to occur, a mechanical counterbore will already have been performed;

'thus, rendering the majority of the work surface free from high level fixed contamination. Airborne and loose surface con-tamination created during polishing / flapping on old pipe / valve surfaces 'will be controlled through use of contamination contain-ment areas.

-Preferential use of mechanical cutting methods for pipe removal.

Mechanical cuts will be supplemented with aforementioned HEPA units, catch trays for shavings, and general area drop cloths.

-Capping / covering of contaminated piping as soon as practicable after completion of cutting.

-Maintaining good housekeeping practices in the drywell and throughout applicable areas of the job site.

6.4 Contamination Containment Areas Contamination containment areas will be used primarily in conjunc-tion with radioactive airborne generating activities:

grinding,-

buffing, flapping, welding, etc. on heavily contaminated piping.

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VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM 6.5 ' Control of Contaminated Tools and Equipment An area will be established in the immediate proximity of the drywell for small tool decon and to. serve as a contaminated tool crib.- Information obtained from other replacement projects indi-cates that considerable time and exposure could have been saved if such areas had been established.

Shielding will be provided as-necessary to ensure that personnel exposure in these areas is maintained as low as reasonably achievable.

6.6 Miscellaneous Contamination Containment Areas Containment areas will be ereted as necessary outside the drywell to accommodate tool and equipment decon, supplementary pipe cutting prior to disposal, and minor work on contaminated items removed from the drywell.

6.7 Respiratory Protection Considerations Vermont Yankee health physics intends to conduct their. respiratory protection program in accordance with existing procedures with due regard for potential effects of.an outage of unusual magnitude.

The respiratory protection area is being evaluated to define any areas where additional capabilities or increased efficiency may be desirable.

6.8 Alpha Contamination Vermont Yankee health Physics has determined that a faster-method of alpha contamination identification procedures be available during the outage. This decision was based 'on findings at other plants performing a similar project as that proposed at Vermont Yankee. The actual work associated with setting up such a program has been contracted in order to be in place prior to the start of the outage.

PAGE 17 0F 23 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM 7.0 Facilities.and Equipment 7.1 Facilities 7.1.1' Construction Office Building and Containment Access Building The Construction Office Building (COB) serves as the outage planning center for the Morrison-Knudsen engineering and construction personnel and the Vermont Yankee Pipe Replacement Project personnel. This arrangement permits a fast, efficient transfer of ideas and requirements between the two groups' involved in the project. The COB will also serve as the base for-craft training prior to the outage.

During the outage the COB will house the contractor's engi-neering and construction management personnel as well ~as Vermont Yankee Recirc Project Team personnel. This con-tinued direct interface will facilitate production and minimize problems that could lead to unnecessary exposure to persennel. The COB will also contain project dedicated dress-out, health physics, and respirator issue areas.

The Containment Access Buidling-(CAB) will connect the COB and the Reactor Building equipment airlock. This will pro-

-vide a functional flow path for personnel and equipment.

Mock-up training will be performed in the CAB prior to and -

as needed during the outage. Machining and staging of the replacement spool pieces will take place in the CAB.

7_.1.2 Auxiliary Health Physics Checkpoint The Auxiliary Health Physics Checkpoint will be located in the C08. The checkpoint will be manned by health _ physics personnel who are familiar with.the work, radiological con-ditions, and radiation work permits involving the i

Replacement Project. The health physics personnel will answer questions concerning RWP requirements and personnel exposure control, issue special monitoring dosimetry, and monitor personnel and equipn.ent entering and exiting the RCA. Sample counting and radiation monitoring equipment will be located at this checkpoint.

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RADIATION EXPOSURE CONTROL PROGRAM-7.1.31 Dedicated-Dress-Out and Respirator Issue Area

'The project dress-out and respirator issue area will-be-located in the C08. The Dress-out area will contain all the protective clothing needed by project personnel and.

will be replenished on an as needed basis. The respirator issue area will contain an ongoing supply of full-face airline and negative pressure respirators. The dress-out and respirator issue-area is located directly across and -in direct -line-of-sight from the Auxiliary Health Physics Checkpoint. The location will provide an additional check

-for proper dress' prior to entering the reactor building.

7.1.4 Dedicated Personnel Flowpaths The establishment of dedicated personnel flowpaths will provide.for the processing of personnel in the shortest time practicable consistent with maintaining an effective exposure control program. This will increase project effi-ciency and reduce non-productive time spent in the RCA.

Pre-planning of personnel traffic flow helps in, identifying additional shielding and controls ~that will be required during certain evolutions in the outage in order to ensure that personnel exposures are maintained as low as reason-ably achievable.

7.2 Equipment ~

i The use of remotely operated cutting and welding equipment will i

ensure-that personnel exposures to ionizing radiation are main-tained as low as reasonably achievable.

l The cutting / machining equipment is supplied with pendant controls.

g which allow the operators to control the activities in lower radiation areas when the radiologica1' environment and work I

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requirements permit.

ID and OD welding will be centrolled outside the drywell using remote controlled equipment and viewed using optics mounted on the welding heads.

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j The cutting, machining, and welding of the thermal sleeves to jet pump risers are the most critical and dose _ intensive activities in the project. The cutting, machining, and welding equipment to be used in this critical area mounts and operates on a stationary, self-centering, internally mounted mandrel. The mandrel allows the activities within the nozzle to be performed without any undue movement or relocation of equipment. This increases-the accuracy of the activities and eliminates the need for repositioning which would be time consuming and dose intensive.

Remotely operated TV cameras with monitors located outside of the drywell will also be in use during the outage. This will allow Health Physics supervisory personnel to view work progress without having to remain in the drywell for extended periods of time.

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- PAGE '19 0F 23 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM 8.0 ' Additional Health Physics Support Additional health physics support functions encompass miscellaneous areas

. that _ play an important, ' supplementary role in maintaining exposures as low as reasonably achievable.

8.1 Electrical Support Lack of ~ sufficient ;1ighting and sources of electric power have historically presented problems ~during major nuclear outages.

Unnecessary occupational radiation exposure is of ten accrued due to increased time spent in high radiation areas looking for a con-

venient source of electric power.

Inadequate local lighting can

-significantly increase job performance time due to poor visibility and the. effects of shadows on the work area. Such-as situation inevitably results in increased personnel exposure.

In orddr to ensure that-' electrical'pmver and lighting con-siderations do not unnecessarily contribute to personnel exposure, M-K health physics and electrical engineering personnel reviewed

.the electrical requirements for the drywell for the Replacement Project. A plan for the installation of temporary electrical sup-port power has been generated to address-these needs.-

8.2 Communications Reliable communication systems are a proven method for reducing time spent in radiation fields. Morrison-Knudsen health physics and engineering personnel are evaluating communication techniques and equipment for use during the 1985 outage. Areas and activi-ties that would significantly benfit from the availability of' field installed communication systems are being identified. Both audio and visual communication media will be employed.

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PAGE 20 0F '23 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM 8.3 Training 8.3.1 General Employee Training (GET)

All personnel reporting to the Vermont Yakee site for work inside the Radiologically Controlled Area receive General Employee Training. GET for badged radiation workers in-cludes instructions regarding the procedures and policies governing the safe performance of their work in a radiolo-gical environment. The. concept of ALARA is stressed in this training, including the fact that it is ultimately the responsibility of each individual.

8.3.2 Mock-up Program for the Replacment Project Extensive mock-up training of work crews is essential to efficient performance in the field. Training of both-supervisory and. craft personnel will ensure that everyone on.the project understands the objectives, policies, and work methods. The Morrison-Knudsen training program begins when personnel start work on the project..The program covers topics such as project orientation, safety, security, project work rules, quality program indoctrina-tion and health physics training. Additional classroom training is scheduled as deemed necessary by supervision.

Because complicated operations are to be carried out in high radiation areas, extensive mock-up training will be used in preparation for the project. The first objective is to accustom personnel to performing their assigned work under the conditions anticipated in the field.

Morrison-Knudsen's approach is to perform a portion of mock-up training fully suited out in protective clothing and in the expected configurations. The second objective is to develop effective work methods. Methods will be per-fected and mistakes corrected during mock-up training.

This approach will minimize field problems, thus,-improving the quality of the work and reducing radiation exposure.

Training on full scale mock-ups will be used to obtain the following:

-Verification of the suitability of planned methods and techniques and of the ability of the equipment to perform as designed.

-Final determination of parameters to be used in the field, such as cutting speeds and weld machine settings.

-Verification that scheduled work can be completed within the projected time duration estimates.

r PAGE 21 0F 23 VERMONT. YANKEE

-RADIATION EXPOSURE CONTROL PROGRAM

-Familiarization of workers with expected field conditions, including interfaces and access difficulties.

-Development of worker proficiency in the operation of spe-cial tooling to reduce time spent in radiation exposure areas.

-Development of worker's abilities to perform work in full protective clothing for those operations anticipated to require it.

-Documentation of practical training by each worker to meet the requirements of the ALARA program.

-Selection of the most !! killed and proficient workers for the performance of critical tasks.

Potential major mock-ups are listed below:

-Multiple nozzle mock-up for training for the installation, use, and removal of remotely operated cutting and weld pre-paration equipment. The cutting mock-ups will include cutting on previously welded mock-up coupons to simulate actual conditions.

-A mock-up of the riser for learning the templating method to be used.

~

-A mock-up to simulate the pump and valve casings for learning remotely operated cutting, weld preparation, and automatic welding.

8.3.3 General Training Program for Cutting of Piping, Safe Ends and Thennal Sleeves Individual training records for each worker including spe-cific work operations for which he has been trained, results of examinations and tests, as well as times to com-plete tasks in mock-ups will be maintained.

The following machining / cutting equipment should be available for training:

-0.D. machining (clamped on pipe)

-safe end and thermal sleeve 0.0. and I.D. machining (clamped on the nozzle)

-I.D. machining (clamped on the pipe)

PAGE 22 0F 23 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM The training of each individual wi'l include familiariza-tion with the various equipment, et up and use of the equipment to cut the piping, and specific training to cut off safe ends, prepare weld ends, and to cut and machine thermal sleeves.

For cutting, the individuals will be trained to:

-install, align, and clamp the equipment to the pipe and/or nozzle.

-install and change the various tool bits.

-operate the equipment visually as well as from the remote control station monitoring the equipment by T.V.

-disassemble and remove the equipment.

For weld preparation, the individuals will be trained to:

-install, align, and clamp the equipment to the pipe and/or nozzle.

-install and change the various tool bits.

-machine the weld prep.

-machine the inside of a pipe and/or nozzle.

After the completion of this general training program, the instructors will be in a position to decide on the makeup of the teams that will work together. Further training of the teams on mock-ups corresponding to plant conditions will then be provided. Thus, the team members will become familiar with each other, their assigned tasks, and the conditions to be expected in the drywell. The training provided will be thorough enough so that individuals and teams who complete the program will be fully qualified to perform the assigned activities efficiently, thus mini-mizing radiation exposure to themselves and their fellow workers.

8.4 Radioactive Waste Disposal Morrison-Knudsen is repsonsible for arranging and overseeing the disposal of the old reactor recirculation and RHR piping being removed from the drywell.

Some radioactive waste (eg:

small bore piping, insulation, etc.)

will be disposed of with the old recirculation pipe if feasible under the final arrangements for pipe disposal.

PAGE 23 0F 23 i

1 VERMONT YANKEE RADIATION EXPOSURE CONTROL PROGRAM Replacem' nt Project.related compactible radioactive waste will be e

bagged / packaged by Morrison-Knudsen personnel under health physics direction.

This waste will be processed by Vermont Yankee under existing procedures for disposition of DAW.

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7 ATTACHMENT # 2.

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Varmont Ycnkos

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Recirculation Pipe'Replecement Projset..Taam~

Vice' President'

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'MK Project Project Manager..

YNSD Manager Services-

.YNSD MK Project (Contracted)

VY Corp.

OQAD Mngt (Att.3)

Assist..to the Finance Project Manager i

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QA Engineering Construction Project Decon &

Finance & Admin.

Suparvisor

' Supervisor _.

Supervisor Restoration Super.

Supervisor Construction Records Project Engineers Engineers Clerks Sr. Project ALARA Engineer Engineer I

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gMORRISON-KNUDSEN COMPANY,INC.

ATTACintENT # 3 PrcJoct Manogomont PROJECT HANACER l

CCHSULTING ENCINEEH SECRETARY i

ASSISTANT PROJECT HANAGER

OJECT CONTROL.S RilSINESS CENERAL ENGINEERINC TRAINING HP PROJECT QtlAI.lTY MANACER MANACER SUPERINTENDENT HAHACER MANACER HANACER HANAGER l

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I _ F s. c cr,*ic. 1 - ATTAa 'rST #6 e MORRISON LNUDSEN VERMONT =YANLEE RECIRC PIPING REPLACEMENT EXPOSURE ESTIMATE BY WORL PACLAGE L WORL PACKAGE' DESCRIPTION TOTAL ESTIMATED WORK PACKAGE EXPOSURE (TOTAL mR) I'

    • WORK PACLAGE NO. 1111 RMV WHIP RSTNT'RCR SIDE A

++ Subtotal ** 11130.0 -** WORK PACKAGE NO. 1112 RMV WHIP RSTNT RCR SIDE B

    • Subtotal **

11130.0

    • WORK PACKAGE NO. 1121 INSTALL WHIP RSTNTS - A RECIRC
    • Subtotal ++

7673.6

    • WORK PACKAGE NO. 1122 INSTALL WHIP RSTNTS - B RECIRC
    • Subtotal. **

7o73.6

    • b!ORK PACKAGE NO.

1211 RMV SUCT PIPE SIDE A

    • Subtotal **

27065.0

    • WORK PACKAGE NO.

1212 RMV SUCT PIPE - SIDE B

    • Subtotal 29927.9
    • WORK PACKAGE NO. 1213 l

RMV DISCH PIPE - EIDE A

    • -Subtota! **

54546.4 i '*+ WORK PACKAGE NO. 1214 RMV DISCH PIPE - SIDE B

  • + Subtotal **

42328.0

    • WORK PACKAGE NO. 1221 INSTALL RECIRC SUCT PIPE SD A
  • + Subtotal ++

66270.4

    • WORK PACFAGE NO.

1222 INSTALL RECIRC SUCT PIPE SD B 56230.6 t

r a g e

  • <c.

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,n n. U.ST #6 MORRISON tNUDSEN i, '

VERMONT YANNEE RECIRC FIFING REPLACEMENT EXPOSURE ESTIMATE BY WORF. PAC). AGE WORE PACI. AGE DESCRIPTION TOTAL ESTIMATED WORL F ACITAGE EXFOSURE (TOTAL mR) ++ WORI:. FAC). AGE NO. 122; IN' STALL DISCH PIPE - A

    • Subtotal ++

58038.5 ++ WORL PACFAGE NO. 1224 INSTALL DISCH-PIPE - B

    • Subtotal **

48333.6 ++ WORE PACIAGE NO. 1312 RMV SPRING HGRS RCR SYS

    • Subtotal ++

7208.0

    • WORK PACKAGE NO. 1322 INSTALL SPF.ING HGRS RCR SYS
  • + Subtotal *+

5170.0

    • WORK PACKAGE NO.

1410 MACH SLVE t-SE - A (N-2-F) +* Subtotal 6044.0 WORL Pact:. AGE NO. 1411 MACH SLVE t SE - A (N-2-G) ++ Subtotal 6044.0 ++ WORK PACT. AGE NO. 1412 MACH SLVS E-SE - A (N-2-H)

  • - Subtotal
  • +

6044.0 -- WORI'. PACKAGE NO. 1410 MACH SLVS.5 SE - A (N-2-J) ~++ Subtotal ++ 6050.O ++ WORK PACLAGE NO. 1414 MACH SLVS R: SE - A (N-2-E) 6050.0 4

.F#ge No. 0. A. : A.'.di'NT //6 MORRISON MNUDSEN VERMONT VANI.EE RECIRC PIPING REPLACEMENT EXPOSURE ESTIMATE BY WORK'FSCLAGE WORU PACKAGE DESCRIPTION TOTAL ESTIMATED WbRt: PACI: AGE EXPOSURE (TOTAL mR)

    • WORK F ACl: AGE NO.

1415 MACH SLVS b SE - B (N-2-A) [

    • Subtotal-*+

6039.5 ++ WORK PACKAGE NO. 1416 MACH SLVS L SE - B (N-2-B)

    • Subtotal +-

6039.5

    • WORK PACF. AGE NO.

1417 MACH SLVS & SE - B (N-2-C)

    • Subtotal *+

6129.5

    • WORK PACKAGE NO.

1418 MACH SLYS & SE-B (N-2-D)

    • Subtotal ++

6039.5 s

    • WORK PACKAGE NO.

1419 MACH SLVS L SE - B (N-2-E)

    • Subtotal +-

6039.5 V' WORK PACKAGE NO.. 1420 (

  • +

i INSTALL SLV 5 SE - A (N-2-F)

    • Subtotal *+

E475.5

    • WORK PACVAGE NO.

1421 } , INSTALL SLV & SE - A (N-2-G) i

    • Subtotal **

L E475.5 l l-i

    • WORK PACKAGE NO.

1422 ( INSTALL SLV E SE - A (N-2-H)

  • + Subtotal

+- f 8255.0 L-i

    • WORK PACLAGE NO.

1423 INSTALL SLV b SE.- A (N-2-J) 9037.5 l s

F'e g g ido. - 6 ATTM i. ;EST #6 MORRISON kNUDSEN VERMONT YANLEE RECIRC PIFING REPLACEMENT EXFOSURE ESTIMATE BY WORK FACLAGE . WORK PACVAGE~ DESCRIPTION TOTAL ESTIMATED WORL FACIAGE EXFOSURE (TOTAL mR)

    • WORK PACl. AGE NO. 1424 INSTALL SLV t SE - A (N-2-K)
  • + Subtotal ++

9037.5

    • . WORl'. PACKAGE NO.

1425 INSTALL SLV t-SE - B (N-2-A)

    • Subtotal **

7809.0

    • WORK PACI: AGE NO.

1426 INSTALL SLV t, SE - B (N-2-B)

    • Subtotal

++ 7809.0

    • WORK PAC! AGE NO. 1427

-INSTALL SLV & SE - B (N-2-C)

  • + Sub t ot al '+ +

7931.5 i

    • WORK PACKAGE NO.

1428 INSTALL SLV t-SE - B (N-2-D)

    • Subtotal **

8029.5

    • WORK PACKAGE NO. 1429 I

INSTALL SLV O SE - B (N-2-E)

    • Subtotal **

8029.5

    • WORK PACKAGE NO.

1430 MACH A - SUCT NOZZLE (N1)

    • Subtotal

++ 14352.0

    • WORK PACKAGE NO.

1431 MACH B - SUCT-NOZZLE (N1)

    • Subtotal

++ 14232.0

    • WORI, -' PACKAGE NO. 1510 MACH-RECIRC PUMP F-18-1A 2695.0

I ri,ge No. 5 AiTM"* *ivl #6 ~ MORRISON l.NUDSEN

  • ~

VERMONT YANIEE RECIRC PIPING REFLACEMENT EXPOSURE ESTIMATE BY'WORL PACLAGE WORl; PACIAGE DESCRIPTION TOTAL ESTIMATED WORK PACKAGE EXPOSURE (TOTAL mR)

    • WORL PACIAGE'NO. 1520 MACH RECIRC PUMP P-18-1B
  • * - Subtotal * +

1727.4

  • + WORl: PACl: AGE NO.

1602 MACH VLV V2-43-A

    • . Subtotal ++

2501.0

    • WORK PAC). AGE NO. 1604 MACH VLV V2-43-B
    • Subtotal ++

~ 2908.0 '** WORK PACKAGE NO. 1606 ( MACH VLV V2-53-A

    • Subtotal ++

2123.0 ++ WORK' PACKAGE NO. 1608 MACH VLV V2-53-B

    • Subtotal

+- 1718.6

    • WORK PACKAGE NO.

1610 MACH VLV V10-81-A ' ** Subtotal ++ 3036.0

    • WORK PACKAGE NO.

1612 MACH VLV V10-81-B ' ** Subtotal ++ 1592.0

    • WORK PACKAGE NO.

1614 MACH VLV V10-46-A

    • Subtotal ++

2791.0

  • + WORK PACKAGE NO. 1616.

MACH VLV V10-46-B 3222.0 s

"~ reg 2"No. 6 ATTAC1D;ENT #6 MORRISON ANUDEEN VERMONT YANLEE RECIRC PIFING REPLACEMENT EXFOSURE ESTIMATE BY WORK PACLAGE WORI. PACKAGE DESCRIPTION TOTAL. ESTIMATED WORL PACLAGE EXFOSURE (TOTAL mR) +* WORK PACLAGE NO. 1618 MACH VLV V10-18

    • Subtotal ++

2244.0 ++ WORK PAC) AGE.NO. 1620 MACH VLV V10-88 ++ Subtotal ++ 3294.O -++ WORK PACi: AGE NO. 2215 RMV RHR 20

    • Subtotal

~ 11830.9 ++ WORK PACLAGE NO. 2216 RMV RHR ~1

    • Subtotal ++

5589.5 ++ WORK PACEAGE NO. 2217 r RMV RHR-32

    • Subtotal *-

8796.0

    • WORK PACKAGE NO. 2225 INSTALL RHR-30
  • + Subtotal *+

12541.4

    • WORK PACKAGE NO. 2226 INSTALL RHR-31

'++ Sub t ot al, ** 9458.8 +* WORK PACKAGE NO. 2227 INSTALL RHR-!2 Subtotal ++ ++ 14922.9~ . WORK PACF. AGE NO. 2250 ++ MACH EXISTIN3 RHR-30 4782.5

r-Iac2'No. / ATTAGMT:;T #6 MORRISON 6:NUDSEN VERMONT YANIEE RECIRC PIPING REPLACEMENT EXPOSURE ESTIMATE BY WORI. F AC). AGE . WORI. FACIAGE DESCRIPTION-TOTAL ESTIMATED WORL PACI: AGE EXPOSURE (TOTAL mR)

    • WORit PACIAGE NO. 2231 MACH EXISTING RHR-31
    • Subtotal +-

2567.0

    • WORK PAC). AGE NO. 2331 INSTALL SPF.ING HGRS RHR SYS
    • Subtotal ++

19063.0

    • WORK PACLAGE NO. 4110 REMOVE PIPING INSULATION
    • Subtotal

++ 04185.0 +* ! ~ RK PACl. AGE NO. 4120 INSiALL PIPING INSULATION

    • Eubtotal

++ 27740.2

    • WORK PACI: AGE NO. 4000 DRYWELL SHIELDING
    • Subtotal ++

14e32.0

    • WO'K PACl. AGE NO.-4910 R

ESTABLISH D.:.YWELL ACCESS

    • Subtotal +*

5087.O

    • WORK PACLAGE NO. 5000 INTERFERENCE' REMOVAL
    • Subtotal **

5ev55.:

    • WORK PACLAGE NO. 5100 CHEMICAL DECON OF PIPE
    • Subtotal

+- 7179.5

    • WORK PACKAGE NO. 5110 DRYWELL DECON AND CLEAN UP 10959E.E l

s

..yaga Nog E A1TAOi'ENT #6 MORRISON bNUDSEN VERMONT YANFEE RECIRC PIPING REPLACEMENT EXF OSURE EST IMATE BY WORL PAC). AGE ' WORD. PACl: AGE DESCRIPTION TOTAL ESTIMATED WORF PACIAGE EXPOSURE (TOT AL anR)

    • WORl: PACIAGE NO. 5200 PIPE DISPOSAL
    • Subtotal

++ 49610.O

    • WORi; PACIT AGE NO. 5200'

-SYSTEM HYDRO ++ Subtotal ++ !.76. 0 ++ WORI: FACLAGE NO. 5400 CLEARANCE INSPECTION +- Subtotal ++ 811.6 ++ WORI: PACIAGE NO. 5506 IHSI

    • Subtotal'++

t.S ?OS. O ++ ' WORI: PACI:. AGE NO. 5600 - DEMOB I L I Z AT I ON .++ Subtotal ++ 14418.0 ++ WORK PACl; AGE. NO. 8000 .ELEC/ COMMUNICATION MAINTENANCE

    • Subtotal +-

28800.0 +- WORK. PACL AGE NO. 9000 ' GEN INSPECTION / SUPERVISION

    • : Subtotal

++ 127620.O

    • -WORI. PACIAGE NO. 9100 HP INSF ECTION/ CONTROL POINT

++ ~ Subtotal +- 45000.O

    • WORl: PACI. AGE NO. 9200 DRYWELL SECURITY 7200.O h

-s'

r T / ^ 9 'J N o'. I Al T A n t:!!;l #6 MORRISON lNUDEEN ~ VERMONT YANI.EE RECIRC PIFING REPLACEMENT EXPOSURE ESTIMATE BY WORK F ACt. AGE WORl; F ACl. AGE DESCRIPTION TOTAL ESTIMATED WORI.. PACIAGE EXPOSURE (TOTAL mR) ++ WOAl. PACKAGE NO. 9000 FIRE WATCH / INSPECTION 74400.0 ++ Subtotal ** 74400.0

  • ++ Total *++

IC91041.0 I i i i I. s i}}