Cindy Connelly, Sr. Evaluator RP 2020 and ALARA Update Cindy Connelly, Sr. Evaluator

Agenda RP 2020 Standardization Initiative Collective Radiation Exposure Importance of the Goal Current Performance Action Plan ALARA Observations Benchmarking the Best Practices

RP 2020 INPO’s Role

RP 2020 – INPO’s Role Determine Feasibility of Standardization INPO project due in June 2009 Create objective set of criteria to choose what to standardize and priority Determine product format and method of implementation/enforcement Develop business case NSIAC approval = Feasible Why Standardize? In 2002-2003, it was identified that many of the significant problems in Radiation protection were due to human performance errors made by supplemental or contract radiation protection technicians or craft workers. Investigation of the causes indicate that the differences in practices from station to station contributed to the errors. Therefore, one of the RP 2020 goals was to standardize appropriate RP practices to reduce errors including potential for unplanned dose or overexposures. There were two papers developed for standardization (one on survey conventions was approved and posting standard was drafted). However, the project was taken on as level of effort by the stations and without the necessary support and backing from senior managers, most stations did not implement the new standard programs. Feedback from the industry and especially the RPMs is that this is still important aspect of improving our performance. For that reason, INPO has taken on the project of determining the feasibility of going forward. The determination will be made in June of this year. A committee with representatives from several of the stations will prepare a presentation for NSIAC Nuclear Strategic Issues Advisory Committee that is made up of CNOs from all of the stations. The committee will create objective criteria for choosing and prioritizing RP activities, determine the final format (type of document) and how implementation will be enforced. Audits/ assessments? And who will do the audits. They will develop a business case and present the project to NSIAC. If NSIAC approval is obtained then standardization will move forward and implementation plans will be developed.

Feasibility of Standardization Plan Feb 2009 - Committee to develop the plan March 2009 – RPMs provide written comments from PM and VP April 2009 present results to NEI working group present results to INPO SLT June 2009 – present business case to NSIAC This is the time line.

Collective Radiation Exposure

Collective Radiation Exposure Importance of the Goal / Why Reduce Dose? Radiological Health ALARA - Regulatory Requirement Skilled Craft Availability Position for Future Revision to 10 CFR 20 Dose Limits

Industry Goal BWRs PWRs 50% of the BWR units achieve 120 Rem (annualized cycle average) by end of 2010 PWRs 50% of the PWR units achieve 60 Rem (annualized cycle average) by end of 2010 Because of its importance as mentioned on the previous slide, in 2005, the industry chose collective dose goals for 2010. BWRs 120 Rem, PWRs 60 Rem. Progress is reevaluated at the end of each year. To meet the 2010 ALARA goal 2009 and 2010 are critical years. Dose during the next two years, primarily outage dose, will determine if your station meets the 2010 goal.

US BWR Collective Radiation Exposure Cycle Median Values 3rd Quarter 2008 As of 3rd quarter 2008, BWRs are not on target to meet their goals. Only 12 of 35 units (34%) are meeting the goal. Some major challenges have been Controls of outage work (scope, duration, rework) Power uprates Maintaining adequate cleanup during outages Equipment reliability Source Term Issues cobalt mitigation, Zinc injection, hydrogen addition, Noble Metals, system decons

US PWR Collective Radiation Exposure Cycle Median Values 3rd Quarter 2008 As of the end of the 3rd quarter, (35 of 69) 50% of the PWRs were meeting the goal. With continued improvements in outage planning and scheduling, PWRs should be able to continue to reduce collective dose. Most of the high dose jobs are complete: Alloy 600 mitigation, containment sumps, SG and reactor head replacements. However additional alloy 600 work (rx. Hot and cold leg nozzles) is pending. To stay on target, RP personnel need to continue to work with other station managers and craft to continue to prepare good ALARA plans, incorporating the best dose reduction techniques.

BWR Outage Dose Performance 15 outages Avg.– 193 rem Quartiles 1st – 149 rem Median – 163 rem 3rd – 197 rem 2008 BWR (Prelim) 16 outages Avg. – 173 rem Quartiles 1st – 117 rem Median – 151 rem 3rd – 185 rem The 2008 data is still being assembled. This is the 2007 data. As you can see, outages account for the majority of the dose. Careful ALARA planning and execution of outages are required to reduce cycle dose. Outage managers and maintenance managers are some of the key players. The 2009 outages and 2010 outages will determine if you station meets the 2010 goals.

PWR Outage Dose Performance 35 outages Avg.– 119 rem Quartiles 1st – 78 rem Median – 109 rem 3rd – 148 rem 2008 PWR (Prelim) 31 outages Avg. – 85 rem Quartiles 1st – 64 rem Median – 75 rem 3rd – 105 rem The 2008 data is still being assembled. This is the 2007 data. As you can see, outages account for the majority of the dose. Careful ALARA planning and execution of outages are required to reduce cycle dose. Outage managers and maintenance managers are some of the key players. The 2009 outages and 2010 outages will determine if you station meets the 2010 goals.

INPO CRE Action Plan Completed Items Ongoing Items CRE Dose Reduction Meetings June 2008 – All October 2008 – BWR Outage Dose CRE Checklist CRE Webcast Ongoing Items Quarterly Newsletter / Benchmarking Contacts Send us your successes – we’ll use them in the newsletter and in meeting presentations.

INPO CRE Action Plan – 2009/2010 Outage Dose Reduction Meetings PWR Dose Reduction Mtg. – Jan. 27-28 P/BWR Dose Reduction Mtg. – Jul. 20-24 Cross-Discipline Meetings 2009 Outage/Maintenance/Operations Managers Working Meetings Assistance Outage Visits Identify major dose jobs / review ALARA plans

ALARA Observations

CRE Areas For Improvement Reasons for the AFIs Dose greater than industry median, significantly over goal with no documented actions to minimize the overage. ALARA plans not reviewed at the appropriate levels by SAC for challenge In-progress reviews and post job critiques not performed and lessons learned not captured and not incorporated into future plans No long range ALARA plan or the items not approved and funded or not worked as scheduled. ALARA plans treated as recommendations – not followed – some are not even available at the job site Workers and RP do not take ownership of dose – not discussed in meetings – no goals set for RCA entries – no accountability for departments not meeting their dose goals (Day, Week, Job)

Benchmarking the Best Practices

Dose Savings Successes – Project / High Impact Teams Assemble teams Water management Shutdown sequence Scaffolding ISI Fuel Floor (Reactor Assembly/Disassembly) Containment/ Drywell Coordination Major Projects/Modifications In this and the next few slides we’ll identify some of the ways stations have found to reduce dose. These slides are being presented to the Maintenance and Outage Managers in presentations. I include them here so you can also emphasize them when you go back to your stations. #1 Is project or HIT teams – some of the major teams are listed here.

Dose Savings Successes – Project / High Impact Teams Expectations Start Early – ALARA is an iterative process Incorporate the basics Time Distance Shielding Involve RP and Craft Work with your outage managers. They need to set clear expectations for the HIT teams. Plans need to be developed well in advance of the outage to allow time to incorporate improvements. ALARA is an iterative process. It starts with a dose estimate based on time in the area, the number of workers and the dose rates. Then it is refined to incorporate engineering/technical improvements, shielding applications, remote tooling, faster methods, and so forth. Items to remember include: plans must incorporate the basics – minimize time in the area and number of workers, use remote or long handled tools and use shielding. Involve the craft. Often those closest to the work come up with the most innovative ideas. For example, maintenance personnel at Columbia designed and engineered a new tool to save numerous hours required for opening reactor pressure vessel shield doors for ISI inspections. They saved dose by significantly reducing time in high radiation areas. An early start also allows time for benchmarking. Finally, ensure that the teams are involved in work scheduling and look beyond their immediate job to identify and eliminate possible interferences. (Who else is working in the area? What resources will we share? Is there enough room?)

Dose Savings Successes – Project / High Impact Teams Expectations (cont.) Benchmark for additional improvements Evaluate impacts of other jobs in the area Scaffolding and shielding interferences Crowded work area Utilities Laydown/staging areas An early start also allows time for benchmarking. Finally, ensure that the teams are involved in work scheduling and look beyond their immediate job to identify and eliminate possible interferences. (Who else is working in the area? What resources will we share? Is there enough room?)

Dose Savings Successes – Team/Technology Considerations Permanent shielding and scaffolding Permanent storage of shielding /scaffolding in containment/drywell Test, inspect, inventory equipment before taking it into containment Quick clips on mirror insulation Use of hydraulics for nut installation on components Laser scanning Cameras/Remote Monitoring Augmented demineralization / filtration Managers should challenge the teams to insure that they have included savings that can be incorporated for this or future outages. Some of these items include: (read the bullets) For example: Brunswick installed about 170 permanent shielding packages. The DW shielding on suction and discharge piping, recirculation risers, undervessel sumps and heat exchangers is estimated to save 40 rem per outage. Another great example is Catawba: They installed a computer based system that allows personnel to view plant areas in 2 or 3 dimensions. It also incorporates real time dose data. The system has resulted in an estimated 30% dose savings for some jobs and is used for planning and prejob briefings. Stations have also used specialty resins and additional filtration to minimize dose rates by reducing the source term in primary systems such as reactor water, cavity and spent fuel pool.

Dose Savings Successes – Help the Worker Succeed Assign work based on expertise (e.g. shared resources may be more efficient than supplemental workers for certain tasks) Use mockups Include RP technicians Hold points Emphasize ALARA considerations Oversight and Coaching In addition to the tangible improvements, managers (especially maintenance managers) need to consider people issues. Are we assigning the right workers to the right tasks? Are we using mockups? Mockups are an excellent way to save dose and improve performance. Last and of great importance, Management oversight in the field is required to ensure work is going as planned and that appropriate adjustments are made.

Dose Savings Successes – Work Package Details Clear instructions (new tasks/ new workers) Maps, pictures showing the component location and area dose rates Comprehensive list of tools and equipment Check tools before entering higher dose areas Contingency planning Lessons from previous work Do new workers have the appropriate guidance? We need to provide clear instructions for the new workers. Maybe we can’t justify the cost of an elaborate computer system such as that installed at Catawba – but other options are available. Some stations use existing pictures, maps and technology and current RP surveys to provide thorough worker briefings.

Dose Savings Successes – The Schedule Allocate time for mockups and ALARA briefings Logic Ties Use water-filled systems to provide shielding Flushing and decontamination Finally the schedule is of utmost importance to ensure that work proceeds smoothly without wasting dose. Be sure that the schedule allocates time for mockups an ALARA briefings, uses logic ties to properly sequence work, uses water-filled systems as shielding when possible, flushing and system or decontamination activities

Dose Savings Successes – The Schedule (cont.) Crud burst management Soft shutdown Cleanup to activity endpoint Slow fill of reactor vessel minimizes crud transport (OE19775) Maximize cleanup system use – limit out of service time Cross-functional schedule review It should include: include provisions for minimizing and managing crud Possibilities include soft shutdown, cleanup controls and logic ties, and slow fill of the reactor vessel. ensure cleanup systems are maximized and remain in service And finally, cross functional review of the schedule should be required with signoffs by the various work groups

Where Can I Find More Information and Benchmarking Contacts?

On INPO Web page, chose Plant Operations and Support

Strengths and other good practices that we have identified in the industry.

A list of some of the CRE meetings A list of some of the CRE meetings. When you click on the summary, there will be links to the presentations.

Questions