ML100740148

Attachment 9 Micro ALARA Plan Work Sheet, Rev. 9

ML100740148
Person / Time
Site:	Oyster Creek
Issue date:	02/24/2010
From:	- No Known Affiliation
To:	Office of Information Services
References
FOIA/PA-2009-0214, RP-AA-401, Rev 9 MAP 09-57
Download: ML100740148 (13)

Text

RP-AA-401 Revision 9

MAP 09-57 ATTACHMENT 9 Micro ALARA Plan (MAP) Work Sheet RWP Number: OC-1 MAP Number: 2009-57 WO Number: C2021071 00057 Job

Description:

Excavation of Underground Piping West of Turbine Building Due to Suspected Leakage OriqinalEstimates:

Exposure: 5 Millirem Time: 0 RCA person-hours MAP Estimates:

Exposure: 5 Millirem Time: 0 RCA person-hours Exposure Challenge Goal: 5 millirem Note: MAP Estimates at or above 1000 millirem (1.0 rem) require formal ALARA Plan documentation.

Review Work Scope, utilizing job site walkdowns and craft input meetings as necessary, to evaluate the following Micro ALARA Planning controls and concepts:

MAP Concept/ Control Yes No N/A MAP Concept/ Control Yes No N/A Minimize Crew Size Modify System Configuration 0 El Utilize Low Dose Area 0 Use Mock-up Training 0 0 0

Use Experienced Craft 0 Re-Sequence / Schedule 0 0 0 0

System Flushing Improve Physical Work Area 0 0 0 0

.Hydrolasing 0 Remove Component to LDA 0 0 El El Shielding Installation Use HEPA Ventilation 0 0 0 0 0 El Remote Monitoring Develop High Rad Trash Plan 0 0 0 Remote Tooling Use Teledosimetry 0 0l 0 El '0 Robotics Scaffold Type Review 0l 0 El TEDE ALARA / RRPCE 0 Work Bundling 0l 0

RP-AA-401 Revision 9

-MAP 09-57 ATTACHMENT 9 Micro ALARA Plan (MAP) Work Sheet Describe Micro ALARA Plan controls implemented and expected benefits:

• Minimize the number of personnel entering the work area to those required to do the work.

" Due to the presence of underground piping with dose rates that have not been recently checked, Radiation Protection will perform radiation surveys during the excavation work.

0 Currently, the excavation areas are not Radiologically Controlled or Radioactive Materials Areas. However, dose rates in excess of 1.6 mR/hour may exist due to the presence of underground contaminated piping. IF 1.6 mR/hour is detected in the excavation, THEN workers will require personnel dosimetry. RP Department will stop work and notify workers if > 1.6 mR/hour is detected.

" IF dose rates of > 5 mR/hour are detected, THEN a Radiation Work Permit will be required.

RP Department will stop work and personnel will be required to be briefed and sign in on a Radiation Work Permit.

• Soil removed from the excavation shall not be removed form the Oyster Creek Protected Area. Soil shall be stored on a waterproof tarp and covered with a separate waterproof tarp.

• Soil shall be sampled by Chemistry Department at approximately each one foot of depth during the excavation.

Peer review by RP personnel at another Exelon site was performed. Based on previous experience dealing with tritium leakage, it was indicated that tritium concentration in excess of 1E+07 picocuries per liter would require institution of controls such as personnel and equipment contamination monitoring. The highest level detected in ground water as of this writing was 4.7E+06 picocuries per liter. 1 E+07 picocuries per liter equals 1E-02 microcuries per milliliter, which exceeds the tritium concentration in suspected leakage sources such as Condensate, CRD, and Core Spray.

Review / Include applicable Operating Experience, Lessons Learned, and job history:

OE An INPO OE Digest summarizes areas for improvement (AFIs) written because of weaknesses noted in protecting buried piping. Plant evaluations identified that monitoring, inspections, and processes that control the environment around the exterior of piping systems are not being implemented well, which increases the station vulnerability to pipe failure. Degradation of buried piping can adversely affect plant safety and reliability, especially if the degradation remains undetected for a long period of time. Leaks in some buried piping have also contaminated the soil with tritium and fuel oil, which could leak into ground water or nearby lakes and rivers.

It is important to protect buried piping as stations extend their operating life. The pipe interior can be protected by adding chemicals to reduce the corrosion rates and prevent the buildup of biological organisms and by applying coatings. Mechanically cleaning the pipe interior can'reduce operational risk

RP-AA-401 Revision 9 MAP 09-57 from fouling, but it does not provide interior piping protection. The pipe exterior can be protected by using exterior coatings and cathodic protection systems. One station is currently replacing, coating, or

-lining all of its raw water pipes - including buried piping - at a cost of over $250 million.

In 2006, plant evaluation teams have identified eight ineffective programs for protecting buried piping, resulting in AFIs. This adverse trend continues in 2007. Descriptions of the 2006 AFIs related to buried piping can be found in the following links: 2006 ER2 and 2006 ER3. The following is a summary of 2006 AFIs.

Problems

• Pipe degradation was not being monitored for some important buried piping.

"Portions of the cathodic protection system were inoperable for an extended time.

• The cathodic protection system did not operate within the desired impressed current and voltage ranges.

"No strategy had been implemented for long-term asset preservation of buried piping.

Consequences

• vulnerability to undetected degradation

" unexpected through-wall leaks "excessive impressed voltage that can cause disbonding of pipe coating, resulting in accelerated corrosion rates

• forced shutdowns

• unplanned system unavailability and limiting condition of operation "exceeding environmental liquid release limits (radioactive liquid, fuel oil), resulting in permit violation Causes o Managers were not aware of the extent of degradation.

"System health reports did not provide sufficient details, or there was no health report for the cathodic protection system.

" Because no pipe failures have occurred, there is overconfidence that coatings will not degrade.

• No actions have been taken to improve cathodic protection system performance because the system was considered a backup to pipe wraps and coatings.

RP-AA-401 Revision 9 MAP 09-57 Approvals: (signature)

Originator: G. Seals/ Date: 4/17/09 Print/Sign Task Manager: R. Korker/ Date:

Print/Sign RP Supervisor: R. Heffner Date:

Print/Sign

RADIATION WORK PERMIT F ACILITY: OC 1 YEAR: 09 RWP NUMBER: 00057 REVISION: 01 TYPE: WGR LOCATION: MULTI 000 ELEVATION: ROOM: AREA:

TITLE: MECHANICAL MAINTENANCE/ELECTRICAL MAINTENANCE INITIATED: 01/22/09 SCHEDULED START: 01/26/09 EXPECTED COMPLETE: 01/01/10 ALARA CATEGORY : 0 PROTECTIVE CLOTHING AND RESPIRATORY PROTECTION REQUIREMENTS DOSIMETRY REQUIREMENTS EXTREMITY - HANDS : MULTIPLE DOSIMETRY:

EXTREMITY - FEET  : RELOCATE DOSIMETRY: ION CHAMBER ALARMING DOSIMETER: Y SET TO ALARM AT: 15 MREM OR AT: 40 MREM/HR ADMINISTRATIVE / EXPOSURE CONTROL REQUIREMENTS MINIMUM TEDE BALANCE OF 2( 00 MREM REQUIRED FOR ENTRY PRE-JOB MEETING REQUIRED  : N AUTO ENTRY/EXIT PERMITTED : Y WORK ORDER NUMBER REQUIRED: N SIGNATURE CHECK AT SIGN-IN: Y HEALTH PHYSICS COVERAGE AND MONITORING PERIOD SURVEY FREQ: 1 ROUTINE SURVE REQD-IF: UPON CHANGE OF RADIOLOGICAL CONDIT HP COVERAGE: INTERMITTENT SPECIAL INSTRUCTIONS / REMARKS MECHANICAL & ELECTRICAL MAINTENANCE.

• KNOWLEDGE OF RAD CONDITIONS REQ'D PRIOR TO ENTRY TO RCA W/OUT RPT ESCORT.

• WORKERS SHALL WEAR DOSIMETRY SO THEIR EXPOSURE CAN BE MONITORED IN THE RCA.

• PC REQUIREMENTS PER RADIOLOGICAL POSTINGS OR PER RP.

• SEE RADPRO RP JOB STANDARDS FOR RESIN CHARGE TO CATION TANK.

• CONTACT RPS PRIOR TO SYSTEM OPENING FOR SURVEY CONSIDERATION.

• THIS RWP IS NOT VALID FOR HRA,LHRA,VHRA.

• REF. 0E22661 - INADEQUATE FME BARRIERS.

DURING THE DISASSEMBLY OF SERVICE WATER PUMP "A", A THREE POUND BRASS WEDGE APPROXIMATELY 5" X 2", DROPPED INTO THE SERVICE WATER BAY DUE TO INADEQUATE FME BARRIERS DURING PUMP MAINTENANCE.

APPROVALS / TERMINATION Name Date Signatures PREPARED BY  : BUCHTA,J 01/22/09 WORK SUPERVISOR: MECH MAINT 01/22/09 HP SUPERVISOR  : RPS 01/22/09 TERMINATED BY  :

POST JOB REVIEW:

RADIATION WORK PERMIT FACILITY: OC 1 YEAR: 09 RWP NUMBER: 00057 REVISION: 01 TYPE: WGR LOCATION: MULTI 000 ELEVATION: ROOM: AREA:

TITLE: MECHANICAL MAINTENANCE/ELECTRICAL MAINTENANCE TASK NBR DESCRIPTION 000 OPS - OTHER 700 MAINT - OTHER 500 R&T/I&C - OTHER

• • • END OF WORK PERMIT REPORT

• V RP-AA-401 Revision 9 ATTACHMENT 9 MicroALARA Plan (MAP) Work Sheet MAP 08-068 RWP Number: OC-1-( )9- MAP Number: 09-068 WO Number: , C2021075 068 Job

Description:

CST Underground Piping Weld and Hot Tap OriginalEstimates:

Exposure: 2 Millirem Time: 43 person-hours MAP Estimates:

Exposure: 2 Millirem Time: 43 person-hours Exposure Challenge Goal: 1 Millirem Note: MAP Estimates at or above 1000 millirem (1.0 rem) require formal ALARA Plan documentation.

Review Work Scope, utilizing job site walkdowns and craft input meetings as necessary, to evaluate the following Micro ALARA Planning controls and concepts:

MAP Concept/ Control Yes No N/A MAP Concept/ Control Yes No N/A Minimize Crew Size X El El Modify System Configuration E17 r7 X Utilize Low Dose Area E E_ X Use Mock-up Training __ X El

'Use Experienced Craft" X ri CI Re-Sequence / Schedule 17 rl X System Flushing C X 1"3 Improve Physical Work Area E_J X rl Hydrolasing Cl El X Remove Component to LDA rl 7l X Shielding Installation E X Use HEPA Ventilation X El El Remote Monitoring r 17 X Develop High Rad Trash Plan 11 X E-7 Remote Tooling El 1. X Use Teledosimetry Eu rl X Robotics _ Il X Scaffold Type Review E X TEDE ALARA / RRPCE El El7 X Work Bundling El E X Page 1 of 5

RP-AA-401 Revision 9 ATTACHMENT 9.

Micro ALARA Plan (MAP) Work Sheet MAP 08-068 Describe Micro ALARA Plan controls implemented and expected benefits:

• This MAP is for contamination control outside of the main RCA. Activities covered are CST Underground Piping Weld and Hot Tap, and RP support

• No system breach allowed during inclement weather (i.e., rain, high winds).

• Erect a tent or similar enclosure at cutting location. Tent will have a non-porous floor.

" Ensure that all discharge line mechanical fittings have secondary containments.

Periodically monitor discharge hoses to verify no leaks.

• Hepa ventilation will be used to create a negative pressure inside of the tent. Stop work if negative pressure inside of the tent is lost. Reestablish prior to restarting work. Discharge HEPA to a monitored release path, TB has been used in the past.

• RPT will perform survey to verify dose rates and. contamination levels.

• RP Tech will brief all personnel of dose rates before entry.

• RPT to verify area is properly posted.

• RPT (or other individual authorized by RP Supervision) to escort RAM movement from one RCA to another.

o Obtain at a minimum, one breathing zone air sample during system breach.

• Obtain a low vol air sample inside of the tent.

Review / Include applicable Operating Experience, Lessons Learned, and job history:

AR # 674916 Condition

Description:

4-6K dpm/LAW found on pavement outside CA at TWST during demob of tent and area. Contamination was at base of tent and approximately 1/2 square foot. Area outside tent is posted RA,RMA,RWP.

Immediate actions taken:

notified supervision, duty station mgr, RPM,WWM and duty shift mgr. decon of affected area Recommended Actions:

continuation of demob to see if any contamination is under the floor boards.

Operable Basis:

Page 2 of 5

RP-AA-401 Revision 9 ATTACHMENT 9 Micro ALARA Plan (MAP) Work Sheet MAP 08-068 N/A Reportable Basis:

Contamination was found outside of a posted contamination area but inside of an RCA. This is not reportable per the Exelon report-ability manual.

Reviewed by: CARL J SUCHTING 09/25/2007 00:02:21 CDT Reviewer Comments:

Reviewed by: 09/25/2007 07:35:21 CDT Reviewer Comments:

9/25/07 VJF > direct frisk of pavement inside and outside posted area showed no detectable activity above background. Smear of contaminated area was 6-8K dpm/100cm2. Contamination was deconned to no detectable activity.

SOC Reviewed by: JERE E FREEMAN JR 10/12/2007 09:11:23 CDT SOC Comments:

09/25/07 Follow-up RP Close to WGE, to RP - WGE to address cause of contamination event. WGE due 10/09/07.

Follow-up RP 09/28/07 KB - returned by MRC for RP to conduct a WGE.Department review performed by: 10/02/2007 08:09:08 CDT Evaluation Comments:

Condition/Problem Statement: Contamination found on pavement outside contamination area at Torus Water Storage Tank (TWST). Contamination was inside radiological area posted Radiation Area/Radioactive Material Area (RA/RMA). Condition was found during demobilization of area while taking down the containment tent at the TWST manway.

Statement of Cause: Sludge from the tank was placed into drums inside the containment tent at the manway. Due to rain and the front entrance to the tent not being sealed, water entered the tent, and some of the sludge on the herculited containment tent floor migrated through a failed seam and found its way outside the containment tent onto the pavement.

Extent of Condition: Contamination wasý contained to a small 0.5 ft2 area.

This area was immediately deconned and survey CAA-07-06888 was done and no contamination was found in adjacent areas inside and outside the posted RA/RMA. No other containment tents are currently in use in the plant and the area at the TWST was demobed and down posted to an RMA at the TWST Page 3 of 5

RP-AA-401 Revision 9 ATTACHMENT 9 Micro ALARA Plan (MAP) Work Sheet MAP 08-068 fence.

Evaluation of any SOC Comments: Work Group Eval complete and action item (674916-02) created to evaluate the use of a sealed containment tent and/or use of a drip pan under the containment tent in the future and captured lessons learned in ALARA plan post-job review.

Manager review performed by: JOHN A RENDA 10/09/2007 09:25:51 CDT Manager Comments:

Action item #2 updated to include use of a sealed containment tent and/or drip pan and add lessons learned to the Alara plan post job review.

MRC Reviewed by: TIMOTHY SEXSMITH 10/10/2007 11:18:28 CDT MRC Comments:

10/10/07 - KB - returned by MRC to incorporate comments Comments / Discussion:

The major concerns with this evolution are the potential to have an unmonitored release or a spill of radioactive material to the environment. This is a very low dose evolution. Due diligence by the work group and Rad Protection is required to avoid any unmonitored releases or spills of radioactive material to the environment.

Page 4 of 5

RP-AA-401 Revision 9 ATTACHMENT 9 Micro ALARA Plan (MAP) Work Sheet MAP 08-068 Approvals: (signature)

Originator: Jeanette Raby/ -s- Date: 4/22/09 Task Manager: Gary True/-s- Date: 4/26/09 RP Supervisor: Bob Heffner/-s- Date: 4/22/09 Page 5. of 5,

RADIATION WORK PERMIT FACILITY:- OC 1 YEAR: 09 RWP NUMBER: 00068 REVISION: 00 TYPE: SPC LOCATION: COND23 CBA ELEVATION: ROOM: AREA:

TITLE: CST UNDERGROUND PIPING WELD AND HOT TAP INITIATED: 04/21/09 SCHEDULED START: 04/25/09 EXPECTED COMPLETE: 01/01/10 ALARA CATEGORY : 0 PROTECTIVE CLOTHING AND RESPIRATORY PROTECTION REQUIREMENTS DOSIMETRY REQUIREMENTS EXTREMITY - HANDS  : MULTIPLE DOSIMETRY:

EXTREMITY - FEET  : RELOCATE DOSIMETRY: ION CHAMBER  :

ADMINISTRATIVE / EXPOSURE CONTROL REQUIREMENTS MINIMUM TEDE BALANCE OF 2( )0 MREM REQUIRED-FOR ENTRY PRE-JOB MEETING REQUIRED  : Y AUTO ENTRY/EXIT PERMITTED : Y WORK ORDER NUMBER REQUIRED: N SIGNATURE CHECK AT SIGN-IN: Y HEALTH PHYSICS COVERAGE AND MONITORING PERIOD SURVEY FREQ: 1 ROUTINE SURVE REQD-IF: BREACH OF SYSTEM HP COVERAGE: INTERMITTENT SPECIAL INSTRUCTIONS / REMARKS MICRO ALARA PLAN#09-068-ALL PERSONNEL TO READ AND COMPLY WITH M.A.P.

• DOCUMENT BRIEFING ON PROC. RP-AA-401 (ATT.4).

• KNOWLEDGE OF RAD CONDITIONS REQ'D PRIOR TO ENTRY TO RCA W/OUT RPT ESCORT.

• PERSONNEL MONITORING PER RP.

• SURVEY REQUIRED AT SYSTEM OPENING.

• AIR SAMPLING PER MICRO ALARA PLAN #09-068.

• WORKERS SHALL WEAR DOSIMETRY SO THEIR EXPOSURE CAN BE MONITORED IN ANY RCA.

• PC REOUIREMENTS PER RADIOLOGICAL POSTINGS OR PER RP.

• ERECT A TENT OR SIMILAR ENCLOSURE AT CUTTING LOCATION PER THE MICRO ALARA PLAN #09-068

• HEPA UNIT REQUIRED TO CREATE A NEGATIVE PRESSURE INSIDE OF THE TENT. PER MICRO ALARA PLAN #06-068.

(SPECIAL INSTRUCTIONS ARE CONTINUED ON NEXT PAGE)

APPROVALS / TERMINATION Name Date Signatures PREPARED BY  : FIONA M.ROBERTS 04/21/09 WORK SUPERVISOR: RABY, J 04/21/09 HP SUPERVISOR  : HEFFNER, ROBERT 04/21/09 TERMINATED BY  :

POST JOB REVIEW:

RADIATION WORK PERMIT FACILITY-: OC 1 YEAR: 09 RWP NUMBER: 00068 REVISION: 00 TYPE: SPC LOCATION: COND23 CBA ELEVATION: ROOM: AREA:

TITLE: CST UNDERGROUND PIPING WELD AND HOT TAP SPECIAL INSTRUCTIONS / REMARKS

• OE- AR#674916 CONTAMINATION FOUND OUTSIDE CONTAMINATION AREA. BUT IN RCA

. . . . . . . . . . . . . . . . . . . .... .. r . . . .

TASK NBR DESCRIPTION 104 HP - JOB COVERAGE

• • • END OF WORK PERMIT REPORT ***