JApluto,
I do have to agree with you that night sift was much better than days. My friends on nights said that they didn't have near the problems that days did....however "Teflon Jon" and his trusty sidekick were on days. I know a lot of people think that when we get on here and voice our opinions, we are just bitching. But some of us actually do care and take our job seriously....so much so that we are willing to give up the $$$$ for a couple extra weeks of work solely based on principles. Like a wise man once said, "If you don't stand for something, you'll fall for anything."
This is a letter from a tech who just left there. It's a columnation of everything that was going on at P.I. I won't disclose who wrote it, but I can attest for almost everything that was written....some things happened after I left.
To whom it may concern, December 13, 2006
Over the past two refueling outages (U2R24 and U1R24), there have been many deficiencies observed in the Prairie Island radiation protection program. However, these observations are not solely mine. They are a collection from several concerned technicians, many of whom were uncomfortable to come forward themselves for fear of retaliation of some sort. And while I respect their decision for anonymity, I must voice my concerns over the many shortcomings of this program. These observations range from flagrant procedural violations by RP management, to posting inconsistencies and many things in between. This is the most deficient radiation protection program I have ever worked in. The management of this department does not display the guidance or leadership qualities that you would expect at a facility such as this. I am voicing these concerns in the hope that will bring to light some of the serious deficiencies that plague this program. Hopefully, hearing the many concerns and issues from techs who have worked at this facility, will bring about some positive changes.
Below is an assemblage of the practices, policies and behaviors, specific to the RP department, from the last two refueling outages that technicians are concerned about, and found to be unacceptable.
RP management was informed by house techs months in advance of U2R24, that no specific work orders contained an RWP which allowed entry in a posted Airborne Radioactivity Area. By the start of the outage nothing had been done to correct this. After U2 containment was posted ARA, all workers on site used one generic work order to enter containment, rendering dose tracking for any work groups impossible.
When U2 containment was initially posted ARA due to Xe-133, workers were permitted by RP management, to continue work without being on an RWP that allowed entry into a posted ARA.
RP supervision instructed technicians to not evacuate U2 containment after they received concurrent data of .4 DAC particulate, a direct violation of site procedure, RPIP 1204 1.4.1.
RP supervision allowed workers to enter a posted Airborne Radioactivity Area while being on an RWP that did not have a stop work airborne limits, a violation of RPIP 1204 1.4.4.
By not evacuating containment after several air samples were recorded at >.3 DAC, RP management knowingly gave over forty workers uptakes of Co-58. This was a hazard craft workers were not aware of because containment had been posted “Airborne Radioactivity Area” for several shifts previous due to a XE-133 issue, which the workers were told was relatively harmless.
OCC has taken stop work authority away from the qualified RP techs in the field, by overruling them on radiological issues on several different occasions.
During times the OCC overruled the RP tech’s stop work authority, plant management displayed a “production over radiological safety” mentality.
At times, LHRA briefs were conducted by someone other than the coverage tech assigned to the job. Giving the coverage tech no idea of what was discussed in the brief, such as: work scope, duration, area dose rates ect.
High risk evolutions were being covered by techs who were not involved in the formal pre-job brief for that job. In some cases the ALARA plans for these jobs (i.e. cavity decon) were several years old.
RP supervision reduced dress requirements for a job, after the formal pre-job brief, without conferring with coverage techs. The techs didn’t find out about the new instructions until they were in containment preparing to dress the workers, who refused to dress according to requirements discussed in the pre-job brief.
Budget minded RP management understaffed its supplemental RP workforce, but expected the same production as if they’d hired a sufficient number of augmented staff. They hired only enough techs to cover containment. When those techs came out of containment, they were expected to work the auxiliary building and RCA access. This wide range of work assignments put many techs in unfamiliar areas of the plant, performing unfamiliar evolutions with little or no guidance from RP supervision.
Five Sr. RP techs quit only a week into the U2R24 outage due to working conditions, the way their radiological questions and concerns where handled, and management’s apparent disregard for any suggestions on areas for improvement. They were told by the RPM (name deleted), that if they didn’t like the way Prairie Island did business, they could leave. Technicians had legitimate radiological concerns, and that’s what they were told by their department head. Some felt so strongly about these issues that they went to the employee concerns program prior to leaving site.
Dayshift and nightshift RP supervision constantly provided conflicting guidance and directives to the technicians. On one occasion, management’s expectation for basic dress requirements in containment changed several times in one shift.
I was directly instructed by RP supervision that an LHRA boundary guard did not need to be present at the boundary to adequately perform his duty. I was told that having the guard simply observe the boundary via camera was acceptable. I told supervision I would not allow the guard to perform his duty unless he was able to maintain positive control of the LHRA access point by being stationed at the boundary.
RP supervision directed techs to put flashing light on HRA postings. A directive of this nature is inconsistent with other HRA posting throughout the plant (and the industry) and is certain to confuse inexperienced rad workers. I removed several flashing lights from HRA postings in the U2 annulus and also in the auxiliary building.
Communication from RP management to technicians was very poor. Many times the craft workers were aware of new RP policy changes and expectations before the RP techs were. On several occasions, craft workers coached technicians, including myself, on the “new” expectations, when we attempted to enforce the “old” management expectations in the field.
RP management allowed LHRA reach-ins on S/G secondary side hand holes without constant RP coverage.
I was told by RP supervision that for ALARA purposes, to have the LHRA boundary guard and timekeeper be the same individual. I had to remind supervision that such a directive is a clear violation of the PINGP 1470 form, which is required per RPIP 1135, and that we must have separate individuals to perform these tasks.
Around the industry red flashing lights are synonymous with LHRA boundaries. However, red flashing lights have a wide array of meanings at Prairie Island. Some of the uses for red flashing lights that I observed are as follows: Operation’s postings for protected train, radiography informational postings, heaving lift warning signs, parking lot speed limit signs, and LHRA postings.
There are no specified colors required by procedure for flashing lights used for LHRA postings, so they use all sorts of colors: red, orange, green and blue. In many cases, there were different color lights on the same posting. This is the very definition of inconsistency. Blue, another color that is known throughout the industry, is by and large associated with ALARA low dose waiting areas. There was one case in particular, where a worker exited containment and came to RP control point. He commented that he was unaware of any low dose waiting area in on 695’ elevation (the basement) in containment. He said that he needed to take a minute to review his paperwork, and when he saw the blue flashing lights on the regenerative heat exchanger gate; he thought he would be radiologically conscious and read his material by the low dose area. Once he reached the gate, he noticed the LHRA posting and exited the area. Dose rates in front of the gate at that time were 90-120mR/hr.
The electronic dosimeter set points used at Prairie Island, in many cases, are worthless. They are set so high that the average worker will never receive a dose rate alarm. This defeats the entire purpose for which EDs were designed. The craft workers are not meter qualified. So when they are working in areas with elevated dose rates that do not require constant RP coverage, an ED is their tool used to inform them that radiological conditions have changed, that it may be unsafe and that they need to exit the area immediately. Sending every worker entering a HRA into containment with a dose rate set point of 500mR/hr, with no regard for their actual work area, defeats the purpose of the tool we have given these workers. Generic, not job specific tasks, on many RWPs for LHRA entries had dose rate alarms as high as 6000-8000mR/hr.
Several times workers were permitted to work in HRAs and even RAs on LHRA RWPs, basically ensuring they could work all shift, anywhere they pleased, and never receive an alarm of any kind. This is not radiation protection.
There was frequent down posting of areas without documented survey data to verify posting changes. The questions and concerns about these situations came from concerned techs, not RP supervision.
The RP department’s organizational method for archiving documented surveys is terrible. It is nearly impossible to find historical data if necessary. That is due, in part, to the fact that management’s requirements for accurate and thorough survey documentation are very lacks to begin with. There were several cases where areas (including LHRAs such as the transfer canal and regen heat exchanger room) had to be resurveyed because the documentation for the surveys performed the shift prior, could not be found.
At times, we were instructed to post areas HRA or LHRA, when the radiological conditions for the majority of the area, did not meet the posting criteria. A practice which is not in accordance with RPIP 1120 17.0.
Workers were required to frisk themselves with an RM-14, at the step off pad after exiting containment. The friskers, however, were set on the X10 scale and signs on the friskers informed workers that the purpose of those friskers was to check for hot particles. At no time was any portion of containment posted “Hot Particle Control Area” and at no time was there an issue or a concern with hot particles in containment. Yet RP supervision had all workers monitoring for hot particles we didn’t have, and not low level loose contamination that could have been tracked all the way down the PCMs.
RP management allows laborers, untrained in radiation protection site procedures, to perform a task as significant as LHRA timekeeping.
Site procedure RPIP 1303 G 1.0, allows workers to carry personal items with them through the friskalls (Prairie Island’s version of a personal contamination monitor), if they have not been in a contaminated area and if they have kept the item(s) with them the entire time. This “honor system” by which RP management controls unconditional release of these items from their RCA is ridiculous. The only person, who knows for sure if those requirements were maintained, is the worker, who often has the conflicting interest of ensuring his items make it out of the RCA. On many occasions I have coached workers about keeping items close to the detectors, while in the friskall, so that they can be accurately monitored to ensure radioactive material is not leaving the RCA. I have also observed workers purposefully keeping items away from the detectors in an effort to clear their belongings. For all the times these workers are caught, how many times have they gotten items through unmonitored? Another issue is that the workers have been observed placing their notebooks and binders in front of their body while in the friskall. While the individual may be making an honest attempt to follow procedure and ensure his book gets monitored, he is managing to shield part of his body from the detectors in the process.
Friskalls, the archaic monitors Prairie Island utilizes at RCA access, do not adequately perform their function of accurately monitoring individuals for contamination prior to egress from the RCA. To begin the monitoring process, the friskalls employ a foot pedal which an individual applies pressure to when standing in the monitor. The problem with the pedal is that it is the only sensor used during the monitoring process. Once pressure is applied to the pedal there are no other controls in place to ensure the individual maintains proper body position within the friskall to achieve an accurate count. On numerous occasions, myself as well as other technicians, have observed workers intentionally attempting to circumvent the friskall’s monitoring process by leaning away from the detectors. In newer model PCMs, this would not be possible, because multiple sensors require workers to maintain a designated body position to allow the monitor to accurately detect contamination.
RP management allowed RP lead techs to transfer and maintain control of the sump c key, which is a VHRA key. This is a violation of RPIP 1008 13.3 and RPIP 1001 7.5.3 that was brought to light, not by a member of RP management or supervision, but by a technician with a questioning attitude. This is yet another illustration of how contract RP techs, who were unfamiliar with some of the site’s RP procedures, were directed to perform tasks that were blatant procedural violations, because RP management at Prairie Island does not exhibit a strong knowledge of the procedures to which they hold ownership.
In the auxiliary building truck bay, there is a roped off area which is posted as a “No Loose Surface Contamination Area”. Any items entering the NLSCA, according to RP management, must have smearable contamination levels <100 DPM/100cm2 (which is the same criteria as items to be unconditionally released). There is no procedure that addresses this posting. As an RP tech, there is no document which I can access for guidance, which outlines the requirements for this area. RP management says the NLSCA is controlled as a clean area, yet vehicles in this area must have the tires frisked prior to exiting, just as they would if they left any other location within the RCA. As far as I have found, there is no special criteria for this area that is more restrictive than any general area in the auxiliary building (which is also required to be <100 DPM/100cm2). The posting doesn’t seem to serve any real purpose, and often, maintaining the cleanliness of this area within the auxiliary building, is very time consuming and slows down work.
The lead shielding aspect of the ALARA program is, at best, unsystematic. During the U1R24 outage, many shielding packages were installed and removed from containment without documented surveys. The same can be said of the shielding packages removed during the end of U2R24. In all these cases, only minimal documentation can be produced for the past unit one or unit two outages of 2006. The lack of documentation does not leave RP management with the means to show that they are in compliance with RPIP 1716 6.1, 6.2, 6.6 or 6.17.
During U2R24, containment RP rovers were tasked with covering S/G secondary side hand hole reach-ins. They were directed to cover the job in a manner that I feel was unacceptable. The RP rover was to provide remote coverage via camera. However, the only camera that was available, viewable only from a monitor on the 735’ elevation, belonged to the work crew. The only headsets available also belonged to, and were already being utilized by the work crew. The worker in the generator vault was on teledosimetry, but the readout could only be viewed at the S/G RP control point, down on the 715’ elevation. So, the coverage tech could see the worker on the monitor, but not communicate to him, except through his co-worker. The worker was wearing teledosimetry, but while watching the worker on the monitor, the tech could not view the workers dose, unless he ran downstairs (at which point he would no longer have a visual contact with worker). The S/G RP could view the worker’s dose, but had no monitor to view the worker, and had no communication with the coverage tech on the 735’ elevation. That was Prairie Island’s poor excuse for remote RP job coverage.
Again during U1R24, there were two RP techs working the S/G control point. Various work activities were taking place on both generator platforms simultaneously. During the same time period, one worker needed to be cut out of his paper suit at the HCA step off pad, while two more workers were checking in at the check point, preparing to enter the platforms. I was at the S/G control point observing the monitors during this time. One of the techs called the S/G RP lead who was outside of containment at the time, to explain the situation. He said that with this much work going on with only two techs, he felt uncomfortable covering that many different activities and also felt an error likely situation was right around the corner. He asked his lead to call the OCC and have them prioritize work, so they could properly cover one job at a time. His lead told him that he would not call the OCC and that they just needed to deal with it. A tech shows the cognizance and foresight to call and ask for work prioritization to enable him to properly and safely cover work and that is how his concern is handled. This is just another example of how contract RP techs have had to deal with disregard for radiological safety while working at Prairie Island.
On several occasions during the U2 outage, when RP management needed to take the lead on critical decisions such as stoppage of work, or more importantly, the evacuation of containment, the radiation protection manager (name deleted), was nowhere to be seen. He was quick to criticize the wrong decisions made by his technicians in the field, but not so quick to make a decision of any radiological significance himself. Certain radiological significant decisions should be the responsibility of RP supervision, or the RPM. (name deleted) would rather remain in the background, to allow the technicians who work for him to make the tough calls. Then, when the chaos has subsided, he emerges to show himself as the assertive department head that is primed to resolve these situations. It is not difficult to lecture on the proper course of action once the moment has passed. Hindsight, as they say, is 20/20.
The bottom line is that you can not run a proficient radiation protection department without seasoned RP technicians at the helm. The current RP management at Prairie Island has no previous RP field experience to speak of. You can not go to individuals who are charged with providing you with oversight, and ask them specific questions pertaining to job coverage, dress requirements or how to handle an unanticipated radiological issue, if they’ve never been there themselves. I have never worked in an environment such as this, were management delegated critical decision making responsibilities to the technicians. It creates a very difficult work environment when most of the techs know that their knowledge level, in this field, exceeds that of those who are supposed to provide them with guidance and oversight. In many cases, RP was nothing more than a speed bump on the road to production. It is difficult to go into the field, work hard to do things the right way and care about the job you’re doing, when in so many instances, you are overruled or ignored.
In closing, I would ask that you pay these matters serious attention. The aforementioned issues are not angry ramblings from disgruntled employees attempting to lash out. Rather, they are heart felt concerns, from people who take very seriously the task of being responsible for the radiological safety of workers in the plant. They are the concerns of people who take pride in what they do. If they did not, these types of issues would not bother them. They would simply collect there check, and move on to the next plant. But this is not the case. I implore you to take a good hard look at this program. Numerous unchecked deficiencies of a minor nature are the precursors to a significant radiological event.
Edited by pwh
Poll
