RP-AA-401Revision 9

MAP 09-57

ATTACHMENT 9Micro ALARA Plan (MAP) Work Sheet

RWP Number:

Job Description:

Oriqinal Estimates:

Exposure:

MAP Estimates:

Exposure:

OC-1 -09- MAP Number: 2009-57 WO Number: C202107100057

Excavation of Underground Piping West of Turbine Building Due to SuspectedLeakage

5 Millirem

5 Millirem

Time:

Time:

0 RCA person-hours

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, toevaluate 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

Utilize Low Dose Area

Use Experienced Craft

System Flushing

.Hydrolasing

Shielding Installation

Remote Monitoring

Remote Tooling

Robotics

TEDE ALARA / RRPCE

El

0

0

0

El

0

0

El

El

0

0

0

0

0

'0

0

Modify System Configuration

Use Mock-up Training

Re-Sequence / Schedule

Improve Physical Work Area

Remove Component to LDA

Use HEPA Ventilation

Develop High Rad Trash Plan

Use Teledosimetry

Scaffold Type Review

Work Bundling

0

0

0

0

0

0

0l

0l

0

0

0

0

0

00l

El

El

0

0

0

0

0

0

0

0

RP-AA-401Revision 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 recentlychecked, Radiation Protection will perform radiation surveys during the excavation work.

0 Currently, the excavation areas are not Radiologically Controlled or Radioactive MaterialsAreas. However, dose rates in excess of 1.6 mR/hour may exist due to the presence ofunderground contaminated piping. IF 1.6 mR/hour is detected in the excavation, THENworkers will require personnel dosimetry. RP Department will stop work and notify workersif > 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 aRadiation Work Permit.

* Soil removed from the excavation shall not be removed form the Oyster Creek ProtectedArea. Soil shall be stored on a waterproof tarp and covered with a separate waterprooftarp.

* Soil shall be sampled by Chemistry Department at approximately each one foot of depthduring the excavation.

Peer review by RP personnel at another Exelon site was performed. Based on previousexperience dealing with tritium leakage, it was indicated that tritium concentration in excessof 1 E+07 picocuries per liter would require institution of controls such as personnel andequipment contamination monitoring. The highest level detected in ground water as of thiswriting was 4.7E+06 picocuries per liter. 1 E+07 picocuries per liter equals 1 E-02microcuries per milliliter, which exceeds the tritium concentration in suspected leakagesources 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 inprotecting buried piping. Plant evaluations identified that monitoring, inspections, and processes thatcontrol the environment around the exterior of piping systems are not being implemented well, whichincreases the station vulnerability to pipe failure. Degradation of buried piping can adversely affect plantsafety and reliability, especially if the degradation remains undetected for a long period of time. Leaksin some buried piping have also contaminated the soil with tritium and fuel oil, which could leak intoground water or nearby lakes and rivers.

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

RP-AA-401Revision 9

MAP 09-57from fouling, but it does not provide interior piping protection. The pipe exterior can be protected byusing 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 buriedpiping can be found in the following links: 2006 ER2 and 2006 ER3. The following is a summary of2006 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 voltageranges.

" 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 acceleratedcorrosion 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 cathodicprotection 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 systemwas considered a backup to pipe wraps and coatings.

RP-AA-401Revision 9

MAP 09-57

Approvals: (signature)

Originator: G. Seals/Print/Sign

Task Manager: R. Korker/Print/Sign

RP Supervisor: R. HeffnerPrint/Sign

Date: 4/17/09

Date:

Date:

RADIATION WORK PERMIT

F ACILITY: OC 1 YEAR: 09 RWP NUMBER: 00057 REVISION: 01 TYPE: WGR

LOCATION: MULTI 000 ELEVATION:TITLE: MECHANICAL MAINTENANCE/ELECTRICAL MAINTENANCE

ROOM: AREA:

INITIATED: 01/22/09 SCHEDULED START: 01/26/09 EXPECTED COMPLETE: 01/01/10ALARA CATEGORY : 0

PROTECTIVE CLOTHING AND RESPIRATORY PROTECTION REQUIREMENTS

DOSIMETRY REQUIREMENTS

EXTREMITY - HANDS :EXTREMITY - FEET :ALARMING DOSIMETER: Y

MULTIPLE DOSIMETRY:RELOCATE DOSIMETRY: ION CHAMBERSET TO ALARM AT: 15 MREM OR AT: 40 MREM/HR

ADMINISTRATIVE / EXPOSURE CONTROL REQUIREMENTS

MINIMUM TEDE BALANCE OF 2(PRE-JOB MEETING REQUIRED : NWORK ORDER NUMBER REQUIRED: N

00 MREM REQUIRED FOR ENTRYAUTO ENTRY/EXIT PERMITTED : YSIGNATURE CHECK AT SIGN-IN: Y

HEALTH PHYSICS COVERAGE AND MONITORING PERIOD

SURVEY FREQ: 1 ROUTINE SURVE REQD-IF: UPON CHANGE OF RADIOLOGICAL CONDITHP 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 WEDGEAPPROXIMATELY 5" X 2", DROPPED INTO THE SERVICE WATER BAY DUE TO INADEQUATEFME BARRIERS DURING PUMP MAINTENANCE.

APPROVALS / TERMINATION

Name Date SignaturesPREPARED BY : BUCHTA,J 01/22/09WORK SUPERVISOR: MECH MAINT 01/22/09HP SUPERVISOR : RPS 01/22/09TERMINATED 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

000

700

500

DESCRIPTION

OPS - OTHER

MAINT - OTHER

R&T/I&C - OTHER

*** END OF WORK PERMIT REPORT *

V

RP-AA-401Revision 9

ATTACHMENT 9MicroALARA Plan (MAP) Work Sheet

MAP 08-068

RWP Number: OC-1-(068

)9- MAP Number: 09-068

nderground Piping Weld and Hot Tap

WO Number: , C2021075

Job Description: CST U

Original Estimates:

Exposure: 2

MAP Estimates:

Exposure: 2

Exposure Challenge Goal:

Millirem

Millirem

Time:

Time:

43

43

person-hours

person-hours

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, toevaluate 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-401Revision 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 ifnegative pressure inside of the tent is lost. Reestablish prior to restarting work. DischargeHEPA 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 oneRCA 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 demobof tent and area. Contamination was at base of tent and approximately 1/2 square foot. Areaoutside tent is posted RA,RMA,RWP.

Immediate actions taken:notified supervision, duty station mgr, RPM,WWM and duty shift mgr. deconof affected area

Recommended Actions:continuation of demob to see if any contamination is under the floorboards.

Operable Basis:Page 2 of 5

RP-AA-401Revision 9

ATTACHMENT 9Micro ALARA Plan (MAP) Work Sheet

MAP 08-068N/A

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

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

Reviewed by: 09/25/2007 07:35:21 CDTReviewer Comments:9/25/07 VJF > direct frisk of pavement inside and outside posted areashowed no detectable activity above background. Smear of contaminated areawas 6-8K dpm/100cm2. Contamination was deconned to no detectable activity.

SOC Reviewed by: JERE E FREEMAN JR 10/12/2007 09:11:23 CDTSOC Comments:09/25/07 Follow-up RP

Close to WGE, to RP - WGE to address cause of contamination event. WGEdue 10/09/07.

Follow-up RP

09/28/07 KB - returned by MRC for RP to conduct a WGE.Department reviewperformed by: 10/02/2007 08:09:08 CDTEvaluation Comments:Condition/Problem Statement: Contamination found on pavement outsidecontamination area at Torus Water Storage Tank (TWST). Contamination wasinside radiological area posted Radiation Area/Radioactive Material Area(RA/RMA). Condition was found during demobilization of area while takingdown the containment tent at the TWST manway.

Statement of Cause: Sludge from the tank was placed into drums inside thecontainment tent at the manway. Due to rain and the front entrance to thetent not being sealed, water entered the tent, and some of the sludge onthe herculited containment tent floor migrated through a failed seam andfound 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 nocontamination was found in adjacent areas inside and outside the postedRA/RMA. No other containment tents are currently in use in the plant andthe area at the TWST was demobed and down posted to an RMA at the TWST

Page 3 of 5

RP-AA-401Revision 9

ATTACHMENT 9Micro ALARA Plan (MAP) Work Sheet

MAP 08-068fence.

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

Manager review performed by: JOHN A RENDA 10/09/2007 09:25:51 CDTManager Comments:Action item #2 updated to include use of a sealed containment tent and/ordrip pan and add lessons learned to the Alara plan post job review.

MRC Reviewed by: TIMOTHY SEXSMITH 10/10/2007 11:18:28 CDTMRC 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 aspill of radioactive material to the environment. This is a very low dose evolution. Duediligence by the work group and Rad Protection is required to avoid any unmonitored releasesor spills of radioactive material to the environment.

Page 4 of 5

RP-AA-401Revision 9

Approvals:

ATTACHMENT 9Micro ALARA Plan (MAP) Work Sheet

MAP 08-068

(signature)

Originator: Jeanette Raby/ -s- Date:

Task Manager: Gary True/-s- Date:

RP Supervisor: Bob Heffner/-s- Date:

4/22/09

4/26/09

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:TITLE: CST UNDERGROUND PIPING WELD AND HOT TAP

ROOM: AREA:

INITIATED: 04/21/09 SCHEDULED START: 04/25/09 EXPECTED COMPLETE: 01/01/10ALARA CATEGORY : 0

PROTECTIVE CLOTHING AND RESPIRATORY PROTECTION REQUIREMENTS

DOSIMETRY REQUIREMENTS

EXTREMITY - HANDS :EXTREMITY - FEET :

MULTIPLE DOSIMETRY:RELOCATE DOSIMETRY: ION CHAMBER :

ADMINISTRATIVE / EXPOSURE CONTROL REQUIREMENTS

MINIMUM TEDE BALANCE OF 2(PRE-JOB MEETING REQUIRED : YWORK ORDER NUMBER REQUIRED: N

)0 MREM REQUIRED-FOR ENTRYAUTO ENTRY/EXIT PERMITTED : YSIGNATURE CHECK AT SIGN-IN: Y

HEALTH PHYSICS COVERAGE AND MONITORING PERIOD

SURVEY FREQ: 1 ROUTINE SURVE REQD-IF: BREACH OF SYSTEMHP 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 SignaturesPREPARED BY : FIONA M.ROBERTS 04/21/09WORK SUPERVISOR: RABY, J 04/21/09HP SUPERVISOR : HEFFNER, ROBERT 04/21/09TERMINATED 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

104

DESCRIPTION

HP - JOB COVERAGE

*** END OF WORK PERMIT REPORT ***