Outage ALARA Report: R3C15

Page 1 of 51


To:ALARA Committee

ALARA Working Group

Subject:Unit 3 Cycle 15 Refueling Outage ALARA Report

Executive Summary

The Unit 3 Cycle 15 (R3C15) refueling outage began on October12, 2008 @ 2335, and was completed 66days, 2 hours, and 24 minutes later on December18, 2008 @ 0058. The outage was originally scheduled to complete on November20, 2008, a schedule of 40 days (Rev. 0).

The ALARA Committee established a challengingALARA goal of79.0 Rem (the lowest ALARA goal ever for a SONGS outage prior to this outage was 90.0 Rem [R2C15]). The total exposure for the R3C15 outage was 94.516 Rem (by Electronic Dosimeter). Exposure from emergent work or added scope totaled approximately 13.505Rem, which is included in the total.

A goal of 60 PCEs was established for the R3C15 outage with an actual of 43 which represents continuous improvement. SONGS previous best PCE performance was R2C15 with 58 PCEs.

Although the ALARA goal was exceeded and expectations not met, R3C15 was our best outage ALARA performance ever for Unit 3 with our previous Unit 3 best occurring during the R3C14 outage at 116 Rem. R3C15reflects 2nd quartile “outage” industry performance in 2008 (Reference: INPO).Current industry averages were approximately 85 Rem for2008PWR outages (Reference: INPO).

On 10/31/08, the ALARA Committee met and approved a dose goal revision (1) from 79.0 Rem to 89.0 Rem to account for the scope expansion of the Hotleg WOL Project and the scope addition of the U3 Containment Spray pump #12 overhaul.

On 11/11/08, the ALARA Committee met and approved a dose goal revision (2) from 89.0 Rem to 96.5 Rem to account for the scope addition of the CEDM #64 weld repair and scope expansion of the S31204MU029 overhaul.

An outage ALARA Plan was developed prior to the outage which included short term and long range goals, ALARA initiatives, shutdown cooling flow path maps, shutdown chemistry plan, temporary shielding packages, low dose waiting area plans and maps, and summaries of the > 1 Rem projects.

Note: Dose data for this report was obtained from IHPS and daily dose tracking Excel spreadsheets.

U3 Outage Dose History and Projections

A review of the implementation of the Outage ALARA Plan found that it was successfully implemented. SONGS Unit 3 will continue to strive and maintain a trend of decreasing outage dose. The following graph reflects how R3C15 exposure compares to the unit’s past performance. Over the last several outages, the station’s chemistry controls have improved and extensive efforts have been made in the area of reactor coolant system (RCS) purification, specifically the implementation of an elevated (7.1) pH Program during cycle 14. These efforts have resulted in lowering the dose rates in containment. With the installation of the new steam generators during R3C16 and a new reactor head during R3C17, continued improvement in outage duration and exposure reduction area expected.

RCA Person-Hours:

Radiologically Controlled Area (RCA) hours for R3C15 were 167,656. The effective exposure rate for R3C15 (total exposure divided by RCA hours) was 0.57 millirem per RCA-hour. This is slightly lower from the previous Unit 3 outage.

The U3 effective dose rate history is as follows:

  • U3C15 – 0.57 millirem per RCA-hour
  • U3C14 – 0.65 millirem per RCA-hour
  • U3C13 – 1.13 millirem per RCA-hour
  • U3C12 – 1.05 millirem per RCA-hour
  • U3C11 – 1.19 millirem per RCA-hour
  • U3C10 – 1.75 millirem per RCA-hour
    Personnel Contamination Events (PCEs)

To continue the effort to heighten workers awareness and track improvement in the area of reducing personnel contamination events (PCEs), a PCE goal was developed and broken down by division based on risk. An industry wide benchmark was conducted using Powernet, resulting in 48 responses. The benchmark requested outage REP hours, outage dose, outage duration and outage PCEs. Based on the results of the benchmark, the average PCE performance for outages was 65. A goal of 60 PCEs was established for the R3C15 outage with an actual of 43 which represents continuous improvement for SONGS and above average industry outage. Details related to the 43 PCEs are on the following pages. SONGS previous best PCE performance was R2C15 with 58 PCEs.

Personnel contaminations events during the R3C15 outage were:

  • Level 1 (>100 cpm) – 42
  • Level 2 (>5,000 cpm) – 1
  • Level 3 (>50,000 cpm) – 0
  • Total – 43

PCE Reduction Strategy:

  • Individual division dose goals were developed and tracked on a daily basis
  • Project Owners of jobs estimated at 1 Rem required an ALARA Plan to be developed which included a PCE reduction plan and goal based on the risk.
  • Refueling Maintenance Project plan had a goal of 10 PCEs their actual was 5. In years past they would receive 60-100 PCEs
  • Maintenance and Construction Services issued a Spot Light on PCE Prevention when a PCE was received
  • PCE Prevention tools were discussed to the station at the R3C15 All Hands Meeting in October 2008
  • New harnesses were purchased
  • A harness survey/maintenance program was implemented to ensure
  • A prescriptive protective clothing protocol was issued for PCE prevention and communicated to the station
  • More aggressive housekeeping in clean areas
  • More aggressive decontamination efforts in contaminated areas
  • Use of air supplied suits for Steam Generator jumpers
  • Purchase and use of disposal knee pads
  • Every PCE is investigated and involves worker supervision

Outage ALARA Report: R3C15

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R3C15 Outage PCE Summary – Daily (Final)
10/13/08 – 12/18/08 (6:00 a.m.)

PCE#

/ Notifications/Order / Unit / Body
Location(s) / ncpm
(Max) / Class /

Work Area or Job

/ Work
Group / Remarks

081013-1

/ 200175900 / 3 / Head – Face / 4,000 / Skin / A0617080001
U/3 Containment putting lights into the side of the 63’ pool for lighting of the upper cavity. / Bechtel
(Refueler) / Full PCs, modesties, extra gloves, rubber shoe covers.
Sweating – may have used back of hand to wipe sweat from chin.
Body harness (from gang box at refuel deck area) brushed against face while donning. Kneeled on ground (plastic) to lower lights – no water on ground.

081016-1

/ 200181194 / 3 / Head – Neck / 200 / Skin / 800049450
Supporting transfer of RCP insulation removed from the pumps to storage area outside Bioshield on 30’ and 17’ elevations. / Curtom-Metalclad / Wore full set of ProTech PCs over modesties. May have contaminated neck when wiping sweat from neck using PC hood.

081016-2

/ n/a / 3 / Extremity – Left Foot / 2,000 / Clothing / A0617080047
Offloaded Carpenter’s conex boxes of scaffold material at Equipment Hatch. Also supported offload of Pb blankets in same area. / Bechtel
(Carpenter) / Wore full PCs, modesties, rubber shoe covers. Contamination may have been inside shoecover or on SOP.

081016-3

/ n/a / 3 / Head – Face / <100 / INJURY / A0617080022
Individual hit ladder crossbar with head while wearing hardhat, safety glasses scraped nose and resulted in minor bleeding. / SCE – HP / Non-contamination injury – first aid only.Full PCS, modesties rubber shoe covers.

081018-1

/ n/a / 3 / Head – Face/Nose / 400 / Skin / 800078125
U/3 containment 63’ upper cavity with a grinder with sanding disk grinding on seal ring surface. / Bechtel
(Refueler) / Full PCs, modesties, Casi-suit, faceshield, power visor, double rubber shoe covers, extra gloves. Hot, and heavy sweating. Contaminated power visor.

081018-2

/ n/a / 3 / Arm – Right, Tricep Rear / 200 / Skin / 800078125
Grinding on the Cavity Seal Ring stud bolts to prep them for the cavity seal ring installation in U/3 containment. / Pci Energy Services / Full PCs, modesties, rubber shoe covers, extra gloves; power visor and knee pads were also worn.
Worker used elbow to support himself while grinding on the cavity seal ring stud bolts. Sweating profusely.

081019-1

/ n/a / 3 / Extremity – Right Knee and Below / 140 / Clothing / 800078200
U/3 containment 63’ Refuel Deck laying out and cutting the seal ring. / Bechtel
(Refueler) / Wore regular PCs, no other protective clothing were worn.
Was on knees, on his side, and sitting on top of the seal ring while cutting.
R3C15 Outage PCE Summary – Daily (Final)
10/13/08 – 12/18/08 (6:00 a.m.)

PCE#

/ Notifications/Order / Unit / Body
Location(s) / ncpm
(Max) / Class /

Work Area or Job

/ Work
Group / Remarks

081020-1

/ 200191493 / 3 / Leg – Right, Thigh Back / 700 / Clothing / A0617080027
U/3 Containment inside Bio E089 Hot Leg platform, installing ROGER / Areva / Wore ProTech/Casi suit, disposable face shield, double shoe covers and gloves, and knee pads on both knees. Had to be on knees for installation of ROGER and move equipment on platform – contact to the knees.

081020-2

/ 200191493 / 3 / Leg – Right, Thigh Front
Extremity – Left Knee and Below / 250 / Clothing/
Clothing / A0617080027
U/3 Containment inside Bio E089 Hot Leg platform, installing ROGER / Areva / Wore ProTech/Casi suit, disposable face shield, double shoe covers and gloves, and knee pads on both knees. Had to be on knees for installation of ROGER and move equipment on platform – contact to the knees.

081020-3

/ n/a / 3 / Extremity – Left Elbow, Forearm / 3,200 / Skin / A0617080050
U/3 Containment 17’ inside Bio by the cavity drain line erecting scaffolding in support of insulation / Bechtel
(Carpenter) / Did not have papers or any other protective clothing. Hot, and heavy sweating. While tightening down the planks with nine wire, had to reach over and leaned against a large piece of steal (pork chop).

081020-4

/ 200191493 / 3 / Extremity – Right Knee and Below / 2,300 / Clothing / A0617080027
U/3 Containment 30’ inside Bio on SG89 installing ROGER / Areva / Papers over protective clothing, disposable faceshield, double shoe covers and gloves, wore knee pads on both knees. Light sweating; water on the platform, knelt on the oil cloth under the opening.

081020-5

/ n/a / 3 / Extremity – Right Elbow
Extremity – Left Elbow / 200 / Skin/Skin / A0617080074
U/3 Containment 17’ E089 Hot Leg side, inside Bio installing bump guards and inspecting pipe supports. / Volt Info Services / ProTech PCs. Did not wear any other protective clothing – only extra gloves. Heavy sweating; tight work area.

081020-6

/ n/a / 3 / Extremity – Left Elbow, Forearm / <100 / INJURY / A0617080074
Walking inside bioshield of U/3 Containment performing visual inspection of 17’ E089 Hot Leg near P002. / Bechtel
(Refueler) / Non-contamination injury –first aid only.
Single set of PCs. Scraped elbow on scaffolding.

081021-1

/ 200191493 / 3 / Back – Buttocks / 400 / Clothing / A0617080027
U/3 containment 30’ inside bio E088 Hot Leg platform completing installation of ROGER and setup of EDDY current testing. / Areva / ProTech/paper/Casi Suit PC, disposable faceshield with glasses, double shoe covers and gloves, dosimetry vest. Heavy sweating; had to be on knees while installing ROGER.
R3C15 Outage PCE Summary – Daily (Final)
10/13/08 – 12/18/08 (6:00 a.m.)

PCE#

/ Notifications/Order / Unit / Body
Location(s) / ncpm
(Max) / Class /

Work Area or Job

/ Work
Group / Remarks

081021-2

/ n/a / 3 / Back – Buttocks / 800 / Clothing / 800078125
U/3 containment 63’ upper cavity pre-heating the flanges for welders to weld. / Bechtel
(Refueler) / Orange electrical PCs, burning faceshield and leather gloves, knee pads. Kneeling on one knee to pre-heat flange. Mild sweating.

081021-3

/ n/a / 3 / Extremity – Right Elbow, Forearm
Extremity – Left Elbow, Forearm / 1,400 / Skin/Skin / A0617080073
Worker performing non-destructive exam (NDE) on drain line of 89 HL, U/3 containment inside bioshield. / Welding Services, Inc. / Single set of PCs. Work in tight area required worker to be on elbows for a long period ot time. Work area conditions changed during day and debris had fallen in area.

081022-1

/ n/a / 3 / Back – Buttocks / 600 / Clothing / A06170800065
U/3 containment elevations 17’, 45’, and 63’ outside the bio removing shims underneath base plate and prepping for drilling holes on columns in support of SGR. / Bechtel / ProTech PC, knee pads and extra leather gloves.
Kneeling, and at times, on one knee. Wore tool belt on 17’ el. Small area to perform task; was hot; used fan to reduce temp in area.

081022-2

/ 200190653 / 3 / Head – Face / 2,800 / Skin / 08040411000
U/3 containment 63’ lower cavity performing dye penetrant on wells for the upper guide structure. / SCE – NDE / ProTech with paper PC, power visor, double shoe covers, gloves. Had to reposition visor often was on knees, on side and had face close to UGS for visual inspection. Area was wet; heavy sweating.

081022-3

/ n/a / 3 / Back – Upper Back
Back – Buttocks / 300 / Clothing/ Clothing / A0617080047
Erecting scaffolding outside of bioshield in “Valve Alley” in the overhead 7’ from deck. / Bechtel / PCs, modesties, rubber shoe covers. Sweating. Climbing upon equipment to erect scaffold, leaning on wall and pipes and pipe supports. Tight work area requires crawling over piping and supports; lots of dust.

081023-1

/ n/a / 3 / Extremity – Left Foot / 400 / Clothing / A0617080018
Supporting movement of IST equipment that had been smeared and released from U/3 Containment’s CA, and was staging the gear in U/3 FH (posted RA) until it could be transferred to 335B. Dressed out and entered U/3 CO and inspected Carwash setup at 17”. Exited CO and proceeded to the Men’s Locker Room. / SCE – Health Physics / Full PCs, modesties, rubber shoe covers. Contamination may have come from sticky pad or from clean area floor outside U/3 FH before entering U3 CO.
R3C15 Outage PCE Summary – Daily (Final)
10/13/08 – 12/18/08 (6:00 a.m.)

PCE#

/ Notifications/Order / Unit / Body
Location(s) / ncpm
(Max) / Class /

Work Area or Job

/ Work
Group / Remarks

081023-2

/ n/a / 3 / Head – Neck
Extremity – Left Foot / 1,200 (P) / Skin/Clothing / A0617080027
U/3 CO 89 H/L Platform S/G Inspection / Areva / Full PCs, modesties, faceshield, double rubber shoecovers, rainsuit, extra gloves. Sweating. Contamination may have occurred when he reached in with the universal poll reaching into the manway; may have touched his chin to his shoulder.

081024-1

/ 200101642 / 3 / Extremity – Left Hand / 600 / Skin / 800049427
U/3 Containment all elevations outside bio and 45’ inside bio performing coating inspections. / Arizona Public Service Company / ProTech PCs, rubber shoe covers, modesties.
While doffing protective clothing reached into left hand with rubber glove.

081025-1

/ 200191653 / 3 / Extremity – Right Knee and Below / 320 / Clothing / 800056951
Fin/Safer group retrieving hoses from the 63’ Ops cage to U/3 containment / SCE – Maintenance / Personal clothing.
Worker was carrying hoses on his right side against his right leg.

081026-1

/ 200191648 / 3 / Back – Buttocks / 600 / Clothing / 800048755
U/3 Containment 30’ over hauling S31208MR025 in overhead. / SCE – Maintenance / Wore single PCs, modesties, rubber shoe covers.
Sat on scaffolding while reaching in overhead to overhaul valve.

081028-1

/ n/a / 3 / Back – Lower Back / 500 / Clothing / A0617080073
U/3 containment had to access E089 platform via 17’ el. Work on repairing wires on the surge line, on E088 platform tightening connections of weld head on the shutdown cooling nozzle, and 17’ el. Checking weld head connections inside the bioshield near the cement wall, and 45’ outside bioshield sitting on bench in work area. / Welding Services, Inc. / ProTech/regular yellow paper suit, modesties, rubber shoe covers. Back was against a 4” pipe. Could have leaned against the Visqueen in the area. Work area was hot; small area with not much room to move.

081028-2

/ n/a / 3 / Leg – Right, Thigh Front / 320 / Clothing / A0617080073
U/3 containment 17’ el. Welding overlay on hot leg surge line. / Welding Services, Inc. / Full PCs, modesties.
Possibly contaminated while climbing in overhead. His PCs got really dirty.

081030-1

/ 200200483 / 3 / Head – Face / 400 / Skin / A0617080027
U/3 containment 30’ el. Loading Tool Head on Manipulator in S/G 88 H/L. / Areva / Double Case, faceshield, headset and airhose.
Sweating. Pushed headset under faceshield when it was coming off and accidently touched his face.
R3C15 Outage PCE Summary – Daily (Final)
10/13/08 – 12/18/08 (6:00 a.m.)

PCE#

/ Notifications/Order / Unit / Body
Location(s) / ncpm
(Max) / Class /

Work Area or Job

/ Work
Group / Remarks

081031-1

/ n/a / 3 / Back – Buttocks / 300 / Clothing / A0617080027
S/G 89 Platform, removal of manipulators and equipment demobilization / Areva / Extra large bubblehood, modesties, PCs, rubber shoe covers, extra gloves.
Bubble suit was too small, ripped down the back in the seat area, and IMUX came out of the fanny pack and rubbed on seat between PCs and fanny pack.

081031-2

/ n/a / 3 / Extremity – Left Foot / 700 (P) / Clothing / A0617080009
Refuel FME supervisor performed inspections and closure of FME Zone around reactor cavity. / SCE – Security / Wore modesties and full set of PCs.
Unknown how/where worker picked up particle

081031-3

/ n/a / 3 / Head – Face / 2,000 / Skin / A0617080081
WSI worker removing PZR heaters from U/3 PZR / Welding Services Inc. / Full PCs, modesties, faceshield, rubber shoe covers, extra gloves, Casi Suit, and extra shoe covers.
Became contaminated on his face at the chin while working the platform.

081031-4

/ n/a / 3 / Head – Face / 100 / Skin / A0617080081
Cutting out PZR Heaters on the U/3 PZR platform. / Welding Services Inc. / Full PCs, modesties, faceshield, rubber shoe covers, extra gloves, Casi Suit, and extra shoe covers. Became contaminated while working on the platform.

081103-1

/ n/a / 3 / Leg – Right Thigh, Back / 1,600 / Clothing / A0617080072
U/3 containment, 30’ inside bio, E089 platform cold leg, jumping S/G, removal of nozzle dams. / SCE – Maintenance / ProTech PC and bubblehood, double shoe covers, and gloves. Heavy sweating. Contamination possibly occurred when bubblehood plastic was removed by HP Tech.

081103-2

/ n/a / 3 / Head – Neck
Extremity – Left Knee and below
Chest – Left / 1,000 (P) / Skin/ Clothing/ Skin / 800063968
U/3 containment, 30’ inside bio on top of scaffold to support MU029 valve work; underneath the valve drilling swing pins and reach into body of the valve to remove swing check valve disk. / SCE – Maintenance / ProTech PC, extra gloves, plastic top cover neck to thigh area, Herculite on the ground. Tight area, hot, sweating. Completely underneath the valve with head against the wall and had to be on side position to drill pins and remove disk.

081104-1

/ 200206690 / 3 / Head – Face / 500 / Skin / A0617080041
U/3 containment, 63’ refuel deck under the RX head performing nozzle 64 inspection. / SCE – Maintenance / ProTech PC, plastic suit, hard faceshield, double shoe covers and gloves, P100 mask.
Contamination may have come from Head2 packet worn.
R3C15 Outage PCE Summary – Daily (Final)
10/13/08 – 12/18/08 (6:00 a.m.)

PCE#

/ Notifications/Order / Unit / Body
Location(s) / ncpm
(Max) / Class /

Work Area or Job

/ Work
Group / Remarks

081104-2

/ 200206831
(Trend) / 3 / Abdomen – Chest to Groin / 300 / Clothing / 800063968
U/3 containment, 17’ inside bio under P003 cleaning and taking measurement of MU029 disk. / SCE – Maintenance / ProTech PC, long sleeves, disposable faceshield, double gloves.
Handling the PED to check reading by HPT, transferring of PED from the pocket to the lanyard. Sitting on top of clean plastic bags, handling the measurement tools near the front abdomen area.

081105-1