2. Commonality Initiatives in US Nuclear Power Plants to Improve Radiation Protection Culture & Efficiency W. David Wood Director, Environmental & RP American Electric Power

3. US Commonality Initiatives  Deregulation of US electric industry  Created need to improve efficiency US nuclear power plants US nuclear power plants  Trend of formation of multi-unit operating organizations/companies

4. Purpose of Commonality Initiatives  Streamline common policies and procedures among all plants in the fleet  Avoids confusion among contractors providing technical services to the various sites.

5. Goals of Commonality Initiative  Achieves better efficiency in work practices which reduces occupational dose. dose.  Facilitates benchmarking among plants within the fleet. within the fleet.

6. Facilitates Problem Identification  Assists in identifying weak areas of an individual plant’s program of an individual plant’s program warranting increased management warranting increased management attention. attention.  Supports new US self-assessment programs. programs.

7. Current US NPP Management Challenges  Reduction in available contract radiation protection technician pool for outages. protection technician pool for outages.  Aging of experienced radiation worker population within US NPPs. population within US NPPs.  Ambitious 2005 INPO Dose Goals for US PWRs & BWRs. US PWRs & BWRs.

8. US Alliance Membership  D.C. Cook is a member of the USA Alliance which includes 18.7% of the US nuclear industry: nuclear industry:  12 utilities  19 reactor units  20,093 Megawatts

9. USA Alliance Goals  Reduce operating costs.  Increase operational efficiencies.  Exchange operating good practices.  Share operating lessons learned.

10. USA Alliance Methods  Develop collective purchasing agreements with suppliers.  Borrow refueling outage equipment.  Loaned employee program to support refueling outages. refueling outages.

11. Example of Savings  Cooper Nuclear Station avoided spending nearly $350,000 (US) in 2001 by borrowing:  Lead Blankets  Votes Testing System  Aircet Testing System  Air Pallets & Light Photometer

12. Co-Owned Equipment  USA Alliance members co-owned shared equipment, for example: shared equipment, for example: scaffolding used in refueling outages. scaffolding used in refueling outages.

13. US NRC Region III Companies: Exelon Nuclear  Exelon Nuclear = 17 units, 10 sites  Strong initiative for common procedures at all sites.  Significant reduction in company employees per site  Implementation of European refueling outages starting in 1994 at Limerick

14. Gap Analysis  Refueling Outage Gap Analysis is the practice of selecting the shortest time interval for each refueling outage critical path work element from all fleet units.  Individual “best of fleet” elements are pasted together to form the ideal refueling outage work sequence time line.

15. Radiation Protection Outage Check List  Exelon plants have developed a refueling outage readiness checklist.  All units carefully evaluate their preparations to support the refueling outage schedule based on this fleet-wide check list.  Check list is a living document updated with lessons learned and good practices.

16. US NRC Region III Organizations: Nuclear Management Company  NMC is composed of 8 units, 5 sites.  Share employees for outages.  Perform self-assessments on RP program at other plants within NMC.  Negotiate system-wide contracts to achieve volume discounts.

17. Industry Results of Commonality Initiatives  Operational improvements are clearly visible:  82% US Availability Factor in 1991  91% US Availablity Factor in 2001  Refueling Outage Duration=  45-50 days in 1991 US industry trend  25-30 days in 2001 US industry trend

18. US Occupational Dose Trends Lower annual doses for PWRs and BWRs in 2001 with the exception of BWR noble metal challenges & PWR reactor head inspections & Steam Generator Replacements

19. The FUTURE

20. INPO 2005 Dose Goals  PWRs = 650 person-mSv/year  BWRs = 1200 person-mSv/year

21. The FUTURE US RPMs are developing 5-Year Dose Reduction Plans to Achieve Further Successes in Plant Safety and Efficiency. The D.C. Cook Plan will be discussed as an example of this RP management initiative.

22. INPO Challenge for 2005  The Cook Radiation Protection Department has prepared a detailed Management Plan to achieve the 2005 INPO Dose Goal.  Many ISOE member utilities have requested information on the Cook 5-Year Dose Reduction Plan to assist 5-Year Dose Reduction Plan to assist in develop of their dose reduction plans. in develop of their dose reduction plans.

23. 5 Year Dose Reduction Plan W hat is it?  Summarizes the existing programs for dose reduction.  Outlines exposure reduction activities to be implemented.  Provides a vehicle to prioritize, direct, and track dose saving/ALARA initiatives.  Periodically reviewed and revised as the station and industry demands change.

24. Reason for D.C. Cook 5 Year plan  Primary purpose is to establish exposure reduction activities which will help achieve dose reductions; projecting D.C. Cook into the first quartile of dose performers.  Additionally, the Nuclear Regulatory Commission, the Institute of Nuclear Power Operations, American Nuclear Insurers, and others use cumulative radiation exposure as an indicator of nuclear plant performance.

25.  Executive Summary  Introduction  Statement of Purpose  Plant Dose History and Projection  DC Cook’s Current 3 year Average  Industry Median  Industry Upper Quartile  Administrative ALARA Program  ALARA Procedures  Training  ALARA Committees  Departmental Dose Reduction Plans  Shielding  Hot Spot Tracking  ALARA Cost Benefit Analysis Index

26. Index (continued)  Benchmarking  Source Term Reduction  Source Term Reduction Team  Hot Spot Removal  Cobalt Reduction  Chemistry Program  Foreign Material Exclusion Program  Worker Productivity Enhancements  ALARA Work Planning  ALARA In-progress and Post Job Reviews  ALARA Suggestion Program  Mock-ups  Exposure Trending  Contaminated Square Footage

27. Index (continued)  Effective Exposure Reduction Practices  Design Changes/System Enhancements  Remote monitoring  Exposure Reduction Projects to be Investigated

28. DC Cook Dose History and Projections The table below shows DC Cook’s dose history and projections, and shows the gap we must bridge to reach median and upper quartile collective radiation dose values.

29. Annual Dose Projection Breakdowns  2002 Dose (250 person-rem)  U2C13 - 110 person-rem  U1C18 - 90 person-rem  CRDM inspection - 15 person-rem each unit (30 total)  Non-outage dose - 20 person-rem (routine and DCP work)

30. Annual Dose Projection Breakdowns  2003 Dose (240 person-rem)  U2C14 - 90 person-rem  U1C19 - 88 person-rem  Removal of RTD lines - 20 person-rem each unit (40 total)  Installation of S/G platforms - 6 person-rem each unit (12 total)  DCP work - 2 person-rem  Non-outage dose - 8 person-rem Outage dose reductions will be achieved through the use of PRC-01 Resin, Zinc injection, and outage efficiencies. Non-outage dose reductions will be achieved through optimization of PM schedules, use of remote monitoring equipment, and continued improvements in worker efficiencies.

31. Annual Dose Projection Breakdowns  2004 Dose (6 person-rem)  Non-outage dose - 6 person-rem  No outages and 0 DCP dose A reduction in the annual non-outage dose will be attained by continued optimization of PM schedules and increased remote monitoring.

32. Annual Dose Projection Breakdowns  2005 Dose (126 person-rem)  U2C15 - 54 person-rem  U1C20 - 54 person-rem  Non-outage dose - 6 person-rem A reduction in Outage dose will be realized by the loss of RTD lines, and a continued benefit from the use of Zinc injection and PRC-01 Resin (reducing source term).

33. Annual Dose Projection Breakdowns  2006 Dose (108 person-rem)  U2C16 - 51 person-rem  U1C21 - 51 person-rem  Non-outage dose - 6 person-rem Estimating approximately a 5 percent reduction attributed to the continued use of Zinc injection and PRC-01 Resin along with continued efficiencies in remote monitoring, PM scheduling and rad worker practices.

34. Administrative ALARA Program  ALARA Procedures  Recently revised  Top tier procedures (signed by Plant Manager)  Clarification of responsibilities (management’s ownership of dose budgets, ALARA Committees)  Lower thresholds for ALARA reviews  ALARA In-Progress Reviews  ALARA Suggestion/Incentive Program

35. Exposure Reduction Techniques being investigated for implementation Exposure Reduction Techniques being investigated for implementation 2002 – 2006 (within the next five years)

37. ALARA Logos