ML030660221
| ML030660221 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 02/25/2003 |
| From: | Jernigan D, Wisla S Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML030660215 | List: |
| References | |
| Download: ML030660221 (32) | |
Text
St. Lucie Plant Radiation Safety Excellence Program Presentation for NRC Region II February 2003 Atlanta, Georgia Enclosure 2
Introduction To Provide A Status On The Radiological Events During SL1-18 And Progress Of Radiation Safety Program Improvements Presented by:
- Don Jernigan - Site Vice President
- Stan Wisla - Radiation Protection Manager
Radiation Safety Conditions Prior to SL1-18 POSITIVE ATTRIBUTES NEGATIVE ATTRIBUTES
- Top quartile ALARA
- Radiation Protection personnel performance did not properly use the Condition Report process to
- Good recent outage identify low threshold events performance
- Little benchmarking and few
- Implemented lessons learned self-assessments from Davis Besse radiological
- Low turnover in RP staff event
- Internal and external assessments failed to detect
- Pre-planned first time declining trend evolutions; Rx Head decon, Rx
- Weak procedures for response to Head inspection off-normal radiological conditions
SL1-18 Radiological Events
- Reactor Head Decontamination
- 33 unplanned uptakes
- Incore Detector Removal
- Created unplanned locked high radiation area
- 2 Instance of Radioactive Material Outside the Protected Area
- These Events Resulted in Significant Media Exposure
Regulatory Response
- Three Green NCV - Occupational Exposure Cornerstone
- Failure to follow procedures for control of access to HRA, airborne areas, LHRA
- Failure to follow procedures to survey personnel (extremity monitoring, DRP monitoring)
- Several examples of failure to follow procedures for posting areas (HRA, radiation area, airborne areas)
Regulatory Response (continued)
- Two Green NCV in Public Exposure Cornerstone
- Failure to follow procedures for personnel monitoring (release of material offsite)
- Failure to have adequate procedures for surveys (release of material offsite)
- Occupational Exposure Performance Indicator Occurrence (failure to control access to LHRA).
FAQ submitted for clarification
Organization Effectiveness
- Weak Leadership Within the RP Organization
- Untimely resolution of contractor issues
- Did not use Condition Report process
- Poor decision making
- Lower cavity event, modesty garments, release of contaminated individuals
- Poor outage planning
- Lack of execution, lack of consumables, ICI removal, head decon, facilities preparedness
- Low Radiation Protection standards
- Personnel decon with non-approved materials
- Poor work practices not addressed
Organization Effectiveness (continued)
- Weak ALARA Review Board Process
- Reluctance of organization to strive for top dose
- Weak Oversight of RP Contractors
- Poor communications
- Late ramp-up resulted in less training. Technicians lacked site specific orientation
- Low returnee rate
- Failed to address technician concerns early in the outage.
Most concerns were validated
- Poor contract supervision personnel
Improving Performance With A Three Pronged Attack
- Personnel Performance Improvements
- Training
- Field monitoring and coaching
- Control of contractors
- Process Improvements
- Radiation Protection, Maintenance and Ops procedure improvements
- Facilities (Plant) Improvements
- Instrumentation, control points
Personnel
- Training Improvements
- Enhanced Radiation Worker Training: 2 day hands-on to include practical factors
- Contractor Training: early outage ramp-up, provide JIT and site specific plans. Increased number of authorized contractors
- RP Staff training (OJT and TPE for process improvements).
JIT (outage lessons learned) during 1st quarter
Personnel (continued)
- Clarification of Roles and Responsibilities in Radiation Safety for Radiation Workers and RP Personnel
- OCC Roles and Responsibilities Have Been Clarified Including Communications Protocol
- RP Staff Stop Work Authority Emphasized in Training and Through Field Coaching
- RP Supervisors performing daily field technician performance management
- Use of radiological restriction process for poor performance in the RCA. Involving line organization in process
- Focus staff on radiation safety first (include job-site setup, pre-job briefings)
Personnel (continued)
- Organizational Changes
- RPM is Now a Direct Report to the Site Vice President
- Increase Radiation Protection participation in FRG and CROG (highly visible program at PSL)
- Increased RP staff - new senior RP position to provide oversight of RP operational personnel.
- Dedicated individuals for outage planning and execution
Personnel (continued)
Health Physics Organization Site Vice President RPM RP Ops RP Tech Supv ALARA W/C Outage RP HPSS HPSS (night) Radwaste Instrumentation Rad Engineer Dosimetry (1 Vacant) (1 Vacant) Transportation (Vacant)
Rad Material Control Performance Tech RPT Planning SC RPT RPT RPT Crewleader RPT RPT Dosimetry Techs RPT Utilityworkers
Personnel (continued)
- Contract Technicians
- Fully staffed for SL2-14 RFO
- 79% are FPL returnees
- 85% > 5 years senior RP experience
- Outage staffing ramp
- 5 weeks prior for supervisors
- 2 weeks prior of RP technicians
- All will attend Enhanced Radiation Worker Training
- JIT training on outage events
Process Improvements
- Radioactive Material Controls
- Independent verification for release of materials
- Protected Area material controls strengthened. Survey or evaluation required for protected area material release
- Access To and Control of Work in HRA. Clearly Defined Access Requirements, Clarified Use of Boundaries and Barricades
- ALARA Review Board is Chaired By the Site VP With Greater Focus on High Risk Evolutions Together With Collective Dose Jobs.
Process Improvements (continued)
- Independent verification for release of personnel alarming monitors
- New control point facilities including decon brigade
- Flow chart developed for all contamination events
- Control Point Dosimeter Alarm Response Strengthened
- ALARA Review Board Greater Focus on High Risk Evolutions
- Low collective dose together with a lower collective dose estimates (0.200 Rem task reviews)
- Release of Materials from the Protected Area
- All material requires survey or evaluation
Process Improvements (continued)
- Radiation Protection Outage Plan Developed
- RP outage organization
- Responsibilities and functions of the various RP staff positions
- Work scope overview and detailed radiological controls
- Specific area posting and barricade plan
- Supply matrix with quantities and locations
- Containment instrumentation logistics
Process Improvements (continued)
Added RP Hold Points To Risk Significant Procedures P ro c e d u re N u m b e r T itle 2 -M -0 0 3 6 R e a c t o r V e s s e l M a in t e n a n c e -
S e q u e n c e o f O p e r a tio n s 1 -M -0 0 1 5 R e a c t o r V e s s e l M a in t e n a n c e -
S e q u e n c e o f O p e r a tio n s 1 -M M P -0 6 .0 2 R a d io a c t iv e F ilt e r C a r t r id g e R e p la c e m e n t 2 -M M P -0 6 .0 2 R a d io a c t iv e F ilt e r C a r t r id g e R e p la c e m e n t 1 -M M P -0 8 .0 3 P r o v id in g A c c e s s T o T h e U n it 1 S te a m G e n e ra to r S e c o n d a ry S id e 2 -M M P -0 8 .0 3 P r o v id in g A c c e s s T o T h e U n it 2 S te a m G e n e ra to r S e c o n d a ry S id e
Process Improvements (continued)
Added RP Hold Points To Risk Significant Procedures P ro c e d u re N u m b e r T it le M -0 0 4 5 R e m o v e a n d R e p la c e C o r e S u p p o r t B a r r e l M -0 9 2 2 R e m o v a l O f I r r a d ia t e d C o m p o n e n t s (In c o re D e te c to rs ) F ro m T h e S p e n t F u e l P o o ls F o r D is p o s a l 2 -M M P -0 1 .0 1 P r e s s u r iz e r H e a t e r R e p la c e m e n t 1 -IM P -6 5 .0 3 I n c o r e I n s t r u m e n t a t io n O u t a g e T a s k s 2 -IM P -0 6 .0 3 I n c o r e I n s t r u m e n t a t io n O u t a g e T a s k s 1 -1 4 0 0 1 9 1 H e a t e d J u n c t io n T h e r m o c o u p le ( H J T C )
R e p la c e m e n t
Process Improvements (continued)
Added RP Hold Points To Risk Significant Procedures P ro c e d u re N u m b e r T itle 2 -N O P -0 2 .0 2 C h a rg in g A n d L e td o w n 1 -N O P -0 2 .0 3 C h a rg in g a n d L e td o w n H P P -1 R a d ia tio n W o rk P e rm its 2 -M M P -0 1 .0 5 U n it 2 S te a m G e n e ra to r P rim a ry S id e M a in te n a n c e 1 -M M P -0 1 .0 5 U n it 1 S te a m G e n e ra to r P rim a ry S id e M a in te n a n c e
Process Improvements (continued)
- Strengthened Surveillance of Material Leaving the Protected Area
- Non-personal items leaving the Protected Area require a gate pass. RP evaluates each gate pass to determine if survey of material is required
- RP searches vehicles leaving site and performs surveys as appropriate using uR/hr meter and beta scintillation detector
Plant Improvements
- Control Points
- Locker Room and Personnel Decon Facility Upgrades Including Gender Specific Improvements.
- Protective Clothing Improvements
- Single use PCs (heat stress mitigation, eliminate large number of particle contamination events)
- Operation Clean Sweep
Plant Improvements (continued)
- Portal Monitors at RCA and Protected Area Exits
- Stop and Count Mode - 75 nCi
- Personnel Contamination Monitors
- RCA Exit - <5,000 dpm/100 cm2
- Whole Body Counter
- Termination Whole Body Counts - 3 to 4 nCi
- Small Article Monitors
- < 5,000 dpm/100 cm2
Plant Improvements (continued)
Whole Body Counter Relocated Inside the Protected Area
Plant Improvements (continued)
New Small Article Monitor for Use at the Whole Body Counter
Plant Improvements (continued)
Portal Monitors at the Protected Area Exit
Plant Improvements (continued)
Portal Monitor at Radiation Controlled Area Exit
Plant Improvements (continued)
Large Area Beta Sensitive Scintillation Detectors to Enhance Contamination Surveys
Plant Improvements (continued)
Vehicle Monitor On Site Target Completion:
12/2003
Current Situation 2003 Performance
- Initiated Operation Clean Sweep
- To date, 3 items in the Protected Area (outside of the RCA)
- 2 Instances of Contaminated Tools Identified Via Gate Pass Procedure
- Prevented release from the Protected Area
- Response to Alarms Has Been Rigorous
- Timely and thorough response to personnel contamination monitor and electronic dosimeter alarms
- Positive Control Over Entries Into High Radiation Areas and No Unplanned Exposures
- Daily Management Observations Focused on Procedure Compliance and Performance
Going Forward
- Increased Use of Self-Assessment
- Pre-outage assessment scheduled by independent CHP
- Two week independent outage assessment
- Strengthened use of Operating Experience. Utilize all lessons learned from OE or formal justification required for not implementing lessons learned
- Targeted benchmarking completed for radioactive material control and outage preparation
- Target Top Decile Performance in ALARA
- Initial 2003 target - 100 Rem (includes a 90 Rem outage)
- Error free outage
- Zero tolerance for unplanned doses and uncontrolled radioactive materials
- Completion of Over 100 Excellence Plan Actions Prior to SL2-18
- QA is Performing Targeted Effectiveness Review of Corrective Actions
Summary
- The Station Did Not Recognize the Latent Organizational Issues in RP. Issues Emerged During the Stress of a Short Outage
- To Ensure Other Organizations Are Not in a Similar Condition, Excellence Plans Are in Development for the Operations and Maintenance Organizations
- These Plans Will Be Rolled Up Into a Station Wide Excellence Plan
- The plans will include the following initiatives
- Supervisory Enhancement Program
- Increased emphasis on the station management observation program including coach the coach sessions
- Strengthening the Condition Report process to enhance ability to detect negative trends through the use of leading indicators