1. Moving Beyond Time, Distance and Shielding: Developing the Concept of Organizational ALARA Kenneth Ohr Quad Cities Generating Station – Exelon 2008 ISOE International Symposium 13 November 2008

2. 2 What is THIS?

3. 3 Discussion Points Background Defining the Concepts Impact of Each Concept Applying the Concepts: Quad Cities Assess Yourself Closing Comments and Questions

4. 4 Background on “Organizational ALARA” What is it? Google Results –+Organizational +ALARA yields ~41,200 hits Most are documents/manuals with a focus on the two distinct topics independent of each other –+“Organizational ALARA” yields 4 hits Best document covers basic structure of an ALARA program INPO 05-008 –No direct definition –Hits upon several of the main concepts, but these concepts are not collected into a unified vision

5. 5 A New Definition Organizational ALARA – –A collection of principles supporting the long- term performance of plant operations in a manner that maintains Collective Radiation Exposure (CRE) ALARA –Higher level focus areas of plant performance and accountability that have the over-riding effect on CRE

6. 6 What It Is Not Organizational ALARA is not the traditional “Big 3” (or four) –Time, Distance, Shielding, and Planning These concepts of Practical ALARA application exist to support individual projects/tasks to achieve ALARA performance These concepts do not (or only narrowly) define the playing field for overall CRE

7. 7 Clichés “Cannot see the forest for the trees” “Winning the battles but losing the war” ALARA Analog: “Beat every RWP/ALARA Plan estimate, but exceeded the outage dose goal” –We frequently achieve success in application of Practical ALARA techniques, but…

8. 8 Organizational ALARA versus Practical ALARA Practical ALARA Techniques: –Time –Distance –Shielding –Planning Impacts: –A Job, Task, Evolution Organizational ALARA Focus Areas: –Source Term Reduction –Equipment Reliability –Worker Engagement –Strategic Planning Impacts: –Site collective performance

9. 9 Organizational ALARA versus Practical ALARA Practical ALARA Ownership: –The Radiological Engineer –ALARA Coordinator –Radiation Protection Mgr –Station ALARA Committee (SAC) Organizational ALARA Ownership: –Station ALARA Committee –Plant Health Committee –Project Review Committee –Chemistry Department –Engineering Organization –Maintenance Organization –Operations –Corporate ALARA Council –Radiation Protection –And the list goes on…

10. 10 Organizational ALARA Concepts Source Term Reduction Equipment Reliability Worker Engagement Strategic Planning

11. 11 Source Term Reduction (STR) Establishes the playing field in which all plant activities take place In its fundamental form, Source Term is one-half of the equation for dose manifesting itself as the Dose Rate in the working area Dose = Time x Dose Rate Source Term (and activities to reduce its impact) affects every job taking place in the Radiologically Controlled Area (RCA) Source Term Reduction must be the primary focus

12. 12 Principal Owners Chemistry –Identifies, tracks, and trends isotopes of interest –Manages injection/addition of chemicals to achieve chemistry regimes that favor continued reduction in source term Depleted Zinc Oxide (DZO), Hydrogen Addition, even Noble Metals –Optimizes resin recipes and use in Demineralizers for effective source term removal –Manages Chemical Decontamination applications

13. 13 Principal Owners Operations –Operates the plant in a manner that maintains stable chemistry parameters –Focuses on Reactor Water Clean-Up (RWCU) availability, Hydrogen Addition availability and trips –Manages unit down-powers and is cognizant of equipment/systems that support Chemistry –Effectively processes RadWaste streams for removal of source term

14. 14 Principal Owners Engineering –Ensures that introduction of new Source Term- generating materials to the plant are minimized or eliminated (Stellite, Inconel) –Ensures that plant modifications / alterations are developed with Source Term removal mechanisms incorporated –Designs and approves shielding remedies for localized areas where source term resides

15. 15 Contributing Owners Other Groups of Interest: Nuclear Fuels –Fuel Reliability (or the converse, Fuel Failure) can trump other STR efforts without effective mitigation Maintenance –Post-maintenance cleanliness issues on internal valve/pump work where Stellite (Cobalt-59) is present can result in more introduction of Source Term than would otherwise be seen through normal erosion/corrosion Procurement –Materials received for installation into the plant must be verified to be Cobalt-Free

16. 16 Equipment Reliability (ER) Equipment Reliability drives the scope of work that is performed at a plant and the conditions in which the work takes place –Material Condition is another term that may be used in conjunction with this focus area Effective ER monitors plant equipment and results in smaller work scopes performed in a preventive manner and reduces the impact of Emergent work The reliability of plant equipment (its Material Condition) governs the amount of work required in a work week, a fuel cycle, or (most acutely) an outage

17. 17 Equipment Reliability (ER) Dose 1 = Time 1 x Dose Rate 1 Dose 2 = Time 2 x Dose Rate 2 Dose PM = Time PM x Dose Rate PM Dose Mod = Time Mod x Dose Rate Mod Dose Rework = Time Rework x Dose Rate Rework Dose Emergent = Time Emergent x Dose Rate Emergent CRE = Dose 1 + Dose 2 + …+ Dose Rework + Dose Emergent ER Determines the scope that drives CRE

18. 18 Principal Owners Engineering –Generally, the owners of a site Plant Health Committee (PHC) or equivalent, which includes: System Monitoring and Health Reporting Program Engineering (ISI, FAC, IVVI, MOV) Site equipment repair/modification priority list (such as Focus Areas, Top Ten Tactical Lists, etc.) –Design (or Modification) Engineering sets the stage for future installations and has a key role in minimizing future installation and maintenance dose impacts

19. 19 Principal Owners Maintenance –A customer and stakeholder in the Plant Health Committee that has the ability to impact priorities –Provides direct input in PM frequency –May include a Component Maintenance Optimization (CMO) branch with a specific function of establishing the optimal preventive maintenance scope and periodicity –Most importantly, Maintenance craftsmanship directly affects rework rates and efficiency of in-field work activities

20. 20 Additional Owners Equipment Reliability touches many other groups, some of which are called out directly in models such as INPO’s “Bubble Chart” They include: –Chemistry (again) –Stores and Procurement –Operations

21. 21 Worker Engagement (WE) Every site has it to some extent, but Engagement that achieves a state of free-flowing communication and worker ownership of the plant and their activities results in performance job-by- job that can smash dose estimates and achieve Dose Goals Worker Engagement can be seen as directly impacting the other half of the dose equation being the Time required to complete work in the RCA Dose = Time x Dose Rate

22. 22 Worker Engagement (WE) Healthy engagement is characterized by: –A healthy feedback system (ALARA Suggestions) –Habitual use of Post Job Reviews to improve performance –Ownership of dose at the personal/crew/departmental level –Effective role of ALARA/Radiological Engineering as stewards of dose versus sole estimator, assignor, and accountant Worker engagement continues up to the senior management levels with departmental dose accountability and a continual understanding of current performance versus goals

23. 23 Principal Owners Radiation Protection –RP must truly own and foster Engagement through multiple, open communication channels –RP (and better, the SAC) must have and share a vision of both the behaviors expected and the goals to be achieved –Even if dose accountability is achieved down to the individual worker, RP still must maintain an ownership that exceeds the best department and knowledge that is at least one additional level deep –RP must foster an environment of Continuous Improvement

24. 24 Principal Owners Plant Management –Crossing into every department, desired Engagement has roles for every level of the organization –Individual Worker –First Line Supervisor –Superintendent –Department Head or Senior Manager –Plant (General) Manager and Site Vice President Do they know their role? How do you know?

25. 25 Strategic Planning (SP) Strategic Planning (or Business Planning or Long- Term Planning) serves to sustain performance Effectively utilized, SP acts as a radiological “Shock Absorber”, dampening the peaks and valleys of work scope and Modification activities as developed by ER –Some best-performing ALARA plants have effective plans out 10 years or more Plants can achieve a Top Quartile outage without it, but how about 4 or 5 consecutively?

26. 26 Strategic Planning (SP) Long Term CRE = CRE Outage1 + CRE On-Line1 + CRE Outage2 + CRE On-Line2 + CRE Outage3 + CRE On-Line3 + and so on...

27. 27 Principal Owners Site Senior Management –Must provide an effective integration of required PM work, programmatic inspections, corrective maintenance, and capital modifications –Dose must be evaluated, even if only by order of magnitude The Corporation –Where there exist multi-site corporations, this long- view of each site must be effectively weighed and balanced

28. 28 Organizational ALARA Defined

29. 29 Radiological Hierarchy of Needs Akin to Maslow’s Hierarchy of Needs, CRE is affected in this basic order: Source Term Reduction –Fundamentally underlies all CRE performance Equipment Reliability –Defines the amount of work and challenges to effective planning Worker Engagement –Can improve the Time required to complete work Strategic Planning –Can sustain performance and shave off the CRE peaks

30. 30 “Do I Need All Four?” It Depends - How far do you want to go? Source Term Reduction is a must –Good performing Source Term, intentionally or by accident, can mask the impact of the other three Equipment Reliability (Material Condition) determines your shots on goal –The most engaged organization can excel in an event- free Steam Dryer repair, but it is still a Steam Dryer repair (or an Emergent MSIV, or LSIV, etc…)

31. 31 Insights None of these concepts are new Recognition of their combined impact unlocks the potential for dramatically different CRE performance Critical to this end is achieving a conscious understanding of the import of each area on site dose performance Target: Gain non-RP departments as true allies and stakeholders in CRE reduction

32. 32 Case Study: Quad Cities 2 Unit BWR-3 Mark I containment Commercial operation commenced in 1973 Following application of Noble Metals on each unit in 1999, a source term transient occurred that increased dose rates in the Drywell and communicating systems by 3x to 5x High source term loading in-vessel was transported ex-vessel after Zinc response to Noble Metals chemistry regime was incorrectly diagnosed and managed

33. 33 Case Study: Quad Cities Dose rates increase on the secondary side (Turbine side) by 8x to 10x due to Design Capacity deficiencies in the Steam Dryer (Moisture Carry- Over) Extended Power Uprates were conducted on both units in 2002 to increase capacity by 17% –Resulted in failures of both Steam Dryers, increases in Vibration levels that affected reliability of ERVs, SRVs, MSIVs, and other Turbine-side components

34. 34 Case Study: Quad Cities Source Term Reduction: –Recovery effort commenced with development of the Exposure Reduction Charter establishing 6 teams lead by RP, Chemistry, Engineering, Nuclear Fuels, and Corporate organizations –Results were achieved that halted the Source Term increases, reversed the trend, and jump-started the recovery –This has been discussed in various forums over the past 4 years

35. 35 Case Study: Quad Cities Equipment Reliability: –EPU Recovery matured from actions treating symptoms (adding a thicker plate to the Steam Dryers and hardening ERV actuators) to more effective diagnosis of the underlying cause –Implementation of the Acoustic Side Branch modification on the Steam Lines resolved a 30+ year old issue –Steam Dryer replacement increased capacity in concert with the uprated power

36. 36 Current State: Quad Cities Source Term Reduction –Exposure Reduction Charter adapted into living 5-Year Plan with SVP ultimate signature approval –Chemistry parameters are in the site management common vocabulary and are discussed daily –Operational focus on Hydrogen Water Chemistry, Zinc Injection, RWCU Availability –Measures such as Cobalt-to-Zinc ratio are driven to beat minimum industry guidance (2e-5) and drive for best identified performance (<5e-6)

37. 37 Current State: Quad Cities Equipment Reliability –Plant vibrations at EPU now less than 50% of those at old full power –Technical Human Performance philosophy and principles developed that govern engineering activities –Component Maintenance Optimization (CMO) organization formed –Dose is a required value utilized in Plant Health Committee discussions of mod prioritization –Dose integrated into Tactical ER Lists

38. 38 Current State: Quad Cities Worker Engagement –Individual dose accountability established including a structure for assigning dose goals to individual level daily –RWP Trip Tickets implemented that force determination and accounting of dose individually –FLS ownership of crew estimating, performance, and feedback established –Management accountable to 10 micro-Sv (1 mrem) overages in Plan of the Day (POD) meetings

39. 39 Current State: Quad Cities Strategic Planning –Fleet dose now monitored with aggregate over/under performance accounted for –Corporate ALARA Committee (CAC) established with site ownership for dose at the Plant Manager level –Long-term Planning includes population of dose impact of future jobs (out 5 years) as part of decision-making process

40. 40 Red line represents 160 rem (1.6 Sv) – our path to Top Quartile dose performance Impact: Quad Cities-1 (Outage)

41. 41 Impact: Quad Cities-1 (Outage) Red line represents 160 rem (1.6 Sv) – our path to Top Quartile dose performance

42. 42 Impact: Quad Cities-1 (Outage) Red line represents 160 rem (1.6 Sv) – our path to Top Quartile dose performance

43. 43 Impact: Quad Cities (On-Line)

44. 44 Assess Yourself Where do you stand on each of the topics? Have you successfully made true believers of your peer departments? Are you that good or that lucky? What do the low level indicators tell you? Are you listening? Each fundamental area of Organizational ALARA has its measurements, indicators and anecdotes of performance

45. Thank You. Questions? Comments?