Suppression Pool Diving Dose Reductions at Limerick Generating Station. January 2015 Tom Mscisz Exelon Nuclear Limerick Generating Station

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Suppression Pool Diving Dose Reductions at Limerick Generating Station January 2015 Tom Mscisz Exelon Nuclear Limerick Generating Station

Typical Suppression Pool Diving Scope 1 Vacuuming (desludging) of underwater surfaces every outage Visual and UT inspections of underwater surfaces every other outage Debris & condition inspection of ECCS suction strainers Spot coating repairs of pitted areas Large area preparation and recoating as committed to the NRC for plant life extension Removal, inspection, and reinstallation of selected ECCS suction strainers Construction and removal of dive and control platforms to support 4 divers (2 per platform) Miscellaneous support for setup & demobilization

Diving Exposure History at Limerick 2 Outage (Year) 2R10 (2009) 1R13 (2010) 2R11 (2011) 1R14 (2012) 2R12 (2013) 1R15 (2014) Total Dose (Rem) Average Dose Per Dive (mrem) Diver Support # Dives # Filters Used Underwater Filters Filter Disposal Dose (P-Rem) Filter Dose Rate (R/hr) Catwalk Diver Average Max External Filter Usage 17.118 70 127 56 144 2.8 1.9 7.5 22.6 None 6.305 43 43 35 48 0.7 0.5 7.2 19.2 None No Diving Water Level Below Bracing (Low) Below Bracing (Low) Dive Platform Type Scaffold (Two Platforms) Scaffold (One Platform) Work Performed Full Inspection, 100% Cleaning, Spot Repair 50% Cleaning, Minor Spot Repair N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A No Diving 12.825 35 43 97 78 1.6 0.9 7.1 16.2 5.261 23 15 76 72 1.3 0.6 6.5 12.8 2.667 9 10 68 0 N/A N/A N/A N/A <3 hrs for Polishing Only 3 Days for Polishing Only Below Bracing (Low) Scaffold (Two Platforms) Above Two Floating Bracing Platforms (High) 9 Days for Above Two Floating Polishing and Bracing Platforms Desludge (High) Full Inspection, 100% Cleaning, Spot Repair Full Inspection, 100% Cleaning, Spot Repair 100% Cleaning, 1D C/S Strainer Removal, Spot Repair, Recoat of 938 ft2

Water Level Effects 3

Low Water Level 4 Dose rates with previously submerged structural supports: Contact with surfaces: up to 65 mr/hr Dive platforms 25 45 mr/hr Upper catwalk areas 5-12 mr/hr Requires significant decon of exposed surfaces Power washing using long-handled wands Potential for personnel contamination events Safety concerns

Exposed Support Bracing 5

High Water Level 6 Dose rates with highly contaminated structural supports submerged: Contact with surfaces: up to 6 mr/hr Down from 65 mr/hr Dive platforms 2-4 mr/hr Down from 25-45 mr/hr Catwalk areas 0.5-3 mr/hr Down from 5-12 mr/hr

High Water Level 7 Water Management challenges Ensure water level remains stable throughout Extra 100,000+ gallons of water in the pool causes storage issues Need to lower water level to accept reactor cavity drain down later in the outage Contingency actions listed in ALARA Plan in the event of water level changes Raised or lowered level affects ladder position Lowered level causes possibility for platform blocks setting directly on bracing supports

Dive Platform Types 8

Traditional Scaffold Platforms Requires water level to be below the support bracing to accept scaffold poles and decking Higher dose rates on previously submerged surfaces High contamination levels on bath tub ring requires carpenters to be in full plastic suits Requires significant decontamination Safety concerns for initial entry below catwalk level Foreign material concerns during removal of dive platforms Dose for installation and removal: ~1.25 person-rem 9

Traditional Scaffold Platforms 10

Traditional Scaffold Platforms 11

Floating Platform Material 12 Normally used in non-nuclear applications Can easily construct platforms to any size or shape Single block (20 x 20 x 16; 14 lbs) holds up to 220 lbs Double block (40 x 20 x 16; 24 lbs) holds up to 400 lbs Blow molded, seamless construction, high impact, puncture resistant high density polyethylene Weather, chemical, fire and UV resistant No leaching or disintegration Non-skid surface, no sharp edges, stable work surface Partially pre-assemble scaffold material used for railing and dive ladders 2 Platforms purchased for under $5,000 (blocks and connectors) Dose for installation and removal: 0.350 person-rem

Floating Platforms 13

Floating Platforms 14

Floating Platforms (jetfloat.com) 15

Floating Platform Benefits Less workers, time, and dose to construct/remove All parts float or can be made to float if dropped Mock-ups are recommended and can easily be performed Sections can be pre-assembled then lowered down Needs less than 3 inches of water draft Material can be re-used 2013 material disposed of due to high contamination that was not readily removed 2014 material not highly contaminated due to filtration Dose for installation & removal ~25% of traditional scaffold 16

Floating Platform Mock-up 17

Filtration Types 18

Suppression Pool Cleanup System Permanent plant system Can only be used during plant operation Low flow (350 gpm) Directs water to condenser hotwell Operational restrictions based on suppression pool water temperature 19

Underwater Vacuum Filters 20

Underwater Vacuum Filters Significant set-up time required One vacuum pump has 8 filters (4 or 8 filters replaced based on manifold differential pressure or dose rates) Average filter dose rate 7 R/hr contact (max 22.6 R/hr) Divers handle each one individually, transporting to hanging storage location (controlled as locked high rad areas) RP/Decon personnel manually transport filters from the suppression pool to shipping cask Only 80 filters fit into a cask liner Higher dose rate filters put into center of cask Dropped filter(s) require additional dive to retrieve Rock catchers (strainers) remove debris that can damage pumps 21

External Filter Use in 2014 RFO The Diversified Technologies Services (DTS) Solids Collection Filter (SCF ) system remained in continuous operation for 9 days during diving and desludging Three separate underwater desludging pumps connected to 2 cam-lock connections on the DTS designed submersible pump suction shroud (3 open ports for water polishing) Submersible pump maintained > 500 gpm even when filters were loaded from suppression pool desludging work System d/p was maintained <35 psid by shutting down the transfer pump for short periods (less than 20 minutes every 4-5 hours) Total throughput was 5,586,000 gallons by totalizer readings Water clarity maintained > 3 feet with as much as 12-18 visibility 22

External Filter Use in 2014 RFO Used 2 micron filtration media Spare filter on site but not needed 6 Piping/hoses with cam-lock fittings to/from filter Inlet hose shielded (max 7 mr/hr contact below shield) Reduced water activity led to lower contamination levels on platform sections and diver umbilical cords The single SCF replaced the need for up to 80 underwater vacuum filters during desludging Remote radiation monitors placed at top and side of cask to monitor for high rad areas and shipping restrictions 23

Diversified Technologies Services SCF Filter 24

Diversified Technologies Services SCF Filter 25

External Filter Shielding 26

Potential Enhancements Install dive control stations outside of suppression pool Easier construction in radiologically clean area Can be constructed and outfitted before suppression pool opened Gets divers in water faster once floating platforms installed and outfitted Construct only one (larger) dive platform that can handle up to 4 divers Potential for charcoal filter to reduce TOC leached from coating material Do not drain reactor cavity water to suppression pool Evaluate mod for permanent dive platforms 27

Questions? 28 Contact Information: Tom Mscisz 610-718-2241 thomas.mscisz@exeloncorp.com Exelon Nuclear Limerick Generating Station 3146 Sanatoga Road Pottstown, PA 19464