Radiological Services Radiation Protection Technician Development Program

Transcription

1 Radiological Services Radiation Protection Technician Development Program Revision: 1 Effective Date:

2 Table of Contents 1.0 Introduction Purpose Scope and Applicability General Requirements Performance Improvement Program Initial Training Program Training to Improve Performance Performance Assessment Improve Performance Through Risk Mitigation Individual Performance Progression 6 Attachment 1 - Performance Investigation Guide....7 Attachment 2 -Technician Development Plan.. 9 Attachment 3 -JR Radiation Protection Technician Experience Guide.21 Attachment 4 - Safety and Performance observations..23 Attachment 5 - Site Manager/Supervisor/Observer Preparation List..24 Attachment 6 - Observation Plan Development Guide..27 Attachment 7 - Resume Review Guidelines 31

3 1.0 Introduction 1.1 Purpose This procedure describes the program for continuous performance improvement in the DZ Radiological Services Division. The objective of the program is to maintain high performance of DZ personnel at the stations by effective training, observations, and coaching. The goal of the program is to provide accurate performance feedback to employees, and provide a structured method for performance improvement, if required. 1.2 Scope and Applicability This procedure applies to both Radiation Protection and Decontamination Technicians. It provides guidance for the initial qualification of personnel, and a structured approach to personnel development. It is designed to give the Site Manager a consistent method to observe performance in the radiological services area, and to assist the employee in improving their performance by identifying performance issues early, and developing corrective action plans for improvement. This procedure describes how performance issues are to be communicated across the DZ RP fleet quickly to prevent performance issues at other sites. 2.0 General Requirements 2.1 When an individual has been assigned the duties as a Site Manager, or any other position which will be completing field performance observations, use Attachment 5, Site Manager/Supervisor/Observer Preparation List, as a tool to ensure the necessary actions at the station are completed. 2.2 The Site Manager should develop an outage observation plan using Attachment 6, Observation Plan Development Guide. The observation plan, once developed, must be approved by the Site RPM and Regional Director. 2.3 The Senior Director of Radiological Services will establish a routine conference call to discuss DZ safety and performance at the sites. All Regional and Site Managers are expected to attend the call. The purpose of the call is to detect performance issues early through observations and make immediate improvements. Providing safety and performance data to other Site Managers can prevent the issue from occurring at other locations. 2.4 The Site Manager should complete Attachment 4, Safety and Performance Observations prior to each conference call. This will include a review of upcoming high risk work activities and the specific action being taken by the Site Manager to ensure those work activities are completed successfully. Use section 3.4 to help assess the risk for upcoming activities. 2.5 The Site Manager is required to report all safety issues in accordance with the DZ EHS program. The Site Manager should communicate to the Regional Managers, and the Senior Director of Radiological Services, within 12 hours, of any of the following safety events Personnel injury listed as first aid or greater Near miss safety event where personnel could have been seriously injured A safety issue in the plant, which if not resolved could seriously injure DZ personnel, which has been brought to the attention of the station but not resolved Serious personnel medical issues that occur on site Page 1 of 31

4 2.6 When communicating safety issues the following information should be supplied Current status of the employee and any assistance needed Description of the event Was the employee using all required PPE and following site safety procedures Actions that have been taken at the site to prevent additional injuries or resolve the unsafe condition in the plant Description of how this issue is being communicated to other DZ personnel at the station to increase awareness, and prevent additional injuries. 2.7 The Site Manager should communicate to the Regional Managers and the Senior Director of Radiological Services, within 12 hours, of any RP performance issue listed below Failure to complete an adequate radiological survey that resulted in a dose or dose rate alarms Failure to complete an adequate radiological survey so that the area was not properly posted, and controlled in accordance with station procedures Failure to control contamination at the source causing additional plant equipment or personnel to become contaminated Failure to provide job coverage in accordance with the RWP requirements, or station procedures, that resulted or could have resulted in a dose or dose rate alarm or significant spread of contamination Failure to maintain control of access to a HRA\LHRA including the control of keys Failure to obtain air samples as required by procedures that resulted in internal contamination events Failure to properly survey material for free release that resulted in radioactive material being released outside the RCA Failure to properly brief personnel on radiological conditions that resulted in dose or dose rate alarms Failure to implement ALARA controls that resulted in additional personnel exposure Any performance issue that could result in a NRC violation. 2.8 When communicating performance issues the following information should be provided by the Site Manager. Use Attachment 1, Performance Investigation Guide, to collect information and determine immediate actions Description of event including what specific performance was not completed (e.g. failed to survey room prior to allowing access resulting in EAD dose rate alarm) Current status of the work area and the immediate actions taken to close the performance gap Critical information from Attachment 1, Performance Investigation Guide Observations of the conditions at the job site which could have impacted the performance. 2.9 Performance Improvement Plans should be implemented when investigations into events, or observed performance, indicate that the technician is not performing work that meets the Page 2 of 31

5 required standard and failing to correct the performance could result in significant events such as unposted radiological hazards Performance Improvement Plans should be documented on Attachment 2, Technician Development Plan, Section 4. All improvement plans must be approved by Regional Managers and Senior Director of Radiological Services Based on the consequences (or potential consequences) of an event it may be appropriate for the qualifications to perform work independently in that area be removed until the performance issues has been corrected and validated through observations that it meets the required standard The decision to remove qualifications based on performance issues will be made by the Senior Director of Radiological Services. The qualifications that are removed will be documented on Attachment 2, Technician Development Plan, Section 4 and removed in PADS. 3.0 Performance Improvement Program 3.1 Initial Training Program Radiation Protection Technicians will be trained and qualified based on the requirements in NISP- RP-12, Training and Qualification of Supplemental Radiation Protection Personnel NISP-RP-12, Training and Qualification of Supplemental Radiation Protection Personnel, defines the requirements for a qualified JR Radiation Protection Technician. Those requirements include the following; a. Completion of Fundamentals for JR Task Qualification b. Completion of JR RP Task RP2.01-RP While it is preferable that a JR complete all 10 JR Task during initial training this may not always be practicable. At a minimum the individual should complete JR Task RP2.01-RP2.04 and RP2.06- RP2.07. This provides the individual the skills, and knowledge to support the sites in a wide range of job tasks. The remainder of the JR qualifications will be completed during annual RP training Initial training provides the knowledge to correctly perform the task. Each STE includes both a knowledge test and a performance evaluation. However, experience is a critical element in development of highly skilled supplemental personnel. Attachment 3, JR Radiation Protection Experience Guide will be used to ensure the technician gets experience over a broad cross section of the radiation protection field Each Technician will receive an Attachment 3, JR Radiation Protection Technician Experience Guide, which will provide the oversight for ensuring the technician gets a wide range of experience The Site Manager will review Attachment 3 for each individual assigned at the station and work with the Site Management to ensure the technician receives as broad experience as possible. Page 3 of 31

6 3.1.7 Completion of Attachment 3, JR Radiation Protection Technician Experience Guide is the responsibility of the individual with support from the Site Manager. 3.2 Training to Improve Performance Training is used to improve and maintain performance by establishing the standards for the performance of work and validating those standards through testing or practical exercises Due to the hazards associated with nuclear power, individuals are required to perform at a high level of performance to ensure regulations and standards are properly implemented. Doing so ensures the workers and the public are protected from the hazards of radiation exposure Performance is evaluated during training through testing or observations of skills during practical exercises It is essential that some performance standards are implemented correctly each time they are performed due to the critical nature of the activity. Each training class, where they are observed or tested, critical performance steps will be defined. Some of the typical critical performance steps are: a. Posting high radiation area when identified b. Stopping work based on stop work criteria c. Performing an adequate survey to define all of the radiological hazards Gaps in performance will be corrected during training through coaching, re-training, and/or retesting Gaps in performance of critical steps, which could have resulted in a significant issue had it occurred at the station, will be documented on Attachment 2, Technician Development Plan, Section One, by the trainer Attachment 2, Technician Development Plan, Section One, will describe critical performance gaps and the additional actions that are to taken by the Site Manager to ensure the performance is at acceptable level while working at the station Critical step performance gaps, identified during training, will be observed to be performed correctly by the Site Manager or Station Supervision Prior to the start of the outage the Site Manager will review the applicable data from Attachment 2, Technician Development Plan, Section One, with the station RPM. It is critical the station be aware of the performance gaps and the plan to improve performance. The station should be encouraged to provide oversight of individuals and support the observation program. Observations of training performance gaps should be completed as soon as practicable. 3.3 Performance Assessment The goal of Performance Assessment is to help the employees maintain performance at the highest level possible by providing positive feedback for work that meets the standards for performance and coaching for items which need improvement During outage work periods the Site Manager will complete an evaluation of the employee s performance and document the evaluation by completing Attachment 2, Technician Development Plan, Section Three It is the Site Manager s responsibility to complete an assessment of every DZ RP Technician performance and provide that feedback to the technicians. Page 4 of 31

7 3.3.4 It is the Site Manager s responsibility to frequently provide feedback to the stations RPMs on performance issues identified during field observations and the corrective actions being taken to improve performance. As a minimum, the Site Manager should discuss performance with the RPM weekly The Performance Assessment will include field observations and review of documentation completed by the employee Observations made by Station personnel should be included in the assessment of the individual s performance. Feedback from Station personnel must be documented on Attachment 2, Technician Development Plan, and Section Three At the end of each outage period the Site Manager will review Attachment 2, Technician Development Plan, Section Three, with each employee. The employee will acknowledge the feedback on performance by signing the document. 3.4 Improve Performance Through Risk Mitigation The Site Manager can directly impact performance by correctly assessing the risk of activities and taking actions to ensure the successfully outcome INPO uses three risk categories; High, Medium, and Low, to help the management team focus on those work activities which have the highest potential for unwanted consequences High risk activities are normally those that have the potential for creating a significant radiological issue if they are not executed correctly such as diving, radiography, power entries or removal of vessel internals The site work package and ALARA planning process normally will assess the risk for each work activity. The Site Manager should understand how the station identifies risk on the work schedule. This gives the Site Manager the opportunity to help prepare the DZ RP technicians to be successful in the field There are many actions the Site Manager can take to ensure successful completion of high risk work however, the following should always be considered a. Does the technician understand the current and expected radiological conditions? b. Does the technician understand how to monitor conditions in the field including radiation, contamination and airborne activity? c. Does the technician understand the stop work criteria for the task? d. Does the technician have the proper equipment for monitoring conditions in the field? e. Has the technician read and understood the controlling documents for the work such as the RWP, ALARA plan or procedure? In some situations the most risk significant activity may not be associated with high dose rates. For example a large amount of equipment being surveyed for free release may have a higher risk to the station. The Site Manager should assess risk in a broad view and consider all the activities being performed by DZ employees The Site Manager should avoid the assumption that no risk significant activity is taking place. There are always activities which have potential to cause adverse impacts to the site if not executed correctly. Page 5 of 31

8 3.5 Individual Performance Progression 3.1 There are two factors that determine the level of work than an individual can perform at the site, ANSI experience and qualifications. DZ is responsible for tracking and assessing both categories when we hire individuals to work at the site. 3.2 The resume is the primary tool used to assess ANSI time. The resume must be detailed enough to clearly explain the work history of the individual as it pertains to NISP-RP-12, Training and Qualification of Supplemental RP Technicians, Attachment 5, Credited Experience for ANSI Qualification. Use Attachment 7, Resume Review Guidelines, as a tool to evaluate a resume. 3.3 If an individual has acquired enough time to progress from one performance level to another (e.g. for a JR to an 18.1 SR) the recruiter should request a resume review by one of the individual approved to perform this task. This will be completed by documenting the review on Attachment 5, Credited Experience for ANSI Qualification. Prior to be submitted to PADS for entry Attachment 5 shall have a peer review completed by a separate approved individual. 3.4 Qualifications will be determined by first running a PADS training report. The qualifications from the report will be compared to the requirements of NISP-RP-12, Training and Qualification of Supplemental RP Technicians, Attachment 2, PADS Codes for CIRP Task Qualifications. 3.5 If an individual has the required ANSI time for that position AND has completed the required training requirements, then they are fully qualified for that position. 3.6 If PADS does not reflect all training as being completed then contact the approved individual in DZ that can assess other training for potential equivalency evaluation. Page 6 of 31

9 Attachment 1 Performance Investigation Guide The following actions should be taken by the Site Manager when investigating a performance issue. The objective of the investigation is to determine why the performance issue occurred and what actions should be taken to prevent additional errors. The investigation should be completed as quickly as possible but must be thorough. During the investigation the Site Manager must consider if this is a single event or could other similar errors have occurred and been unnoticed until now. If the potential exist for other errors to have occurred additional investigation actions should be taken. The following questions can be completed in any order as appropriate considering the event. They are not all inclusive but should help the Site Manager collect enough information to come to a conclusion on cause of the event and the necessary corrective actions. Obtain condition report and review information, if applicable. During the investigation the Site Manager must determine if the individual knew the standard to which he was to perform the task. If the individual did not understand the standard for performance then the cause of the event may be the result of a lack of training or effective communication. Some events may be caused by the individual making a poor decision while performing work. Decision making is part of performance. Willful actions by an employee that violates company or site procedures as determined by DZ management will be handled in accordance with DZ company policies. At the end of the investigation the Site Manager is required to state the cause event and the corrective actions necessary to improve performance. The performance plan may be related to the individual or could involve the all DZ employees at the site. 1. Describe the event and the consequences, or potential consequences, which have occurred. Include the location, time and individuals involved. 2. Validate the condition has been corrected in the field and is currently in compliance with station procedures. 3. Ask the individual(s) to provide a written statement describing the events. 4. If the event was a dose or dose rate alarm ask the site to provide you the histogram from the dosimeter. The histogram will provide critical information that can help determine the actions that were being taken in the field. 5. Validate the key elements from the individual s statement, if possible. For example were they on the right RWP number or have the correct EAD set points for the work activity 6. Determine if the correct pre-job actions had been taken. For example was the instrument in use source checked? Did they read their RWP prior to entry and understand critical steps such Page 7 of 31

10 as stop work criteria? Did they review the latest survey of the work area prior to entry? Did they attend the pre-job brief if one was required? 7. Was there any reason for the radiological conditions to change since the last survey was performed in the area? Did the technician understand the potential for change? 8. Ask the station if there is video of the work as it was taking place. If so, review the video to determine if correct actions were taken in the field. 9. Determine if the correct actions were taken once they arrived at the job site. Was a radiological survey completed? Did it evaluate all the hazards including gradient dose rates? Were there any changes in conditions the technician should have noticed? Did the technician inform the workers of the as-found conditions? 10. Determine if the correct actions were taken during the course of the work activity. Were the requirements of the RWP implemented? Did the technician continue to perform surveys as required? Was an air sample required and was it taken in the proper location. Was contamination controlled at the source? Did the technician monitor his and the workers exposure? 11. Determine if the correct actions were taken at the end of the work activity. Were all surveys documented? Was the proper communications on the status of the work completed by updating station logs and informing supervision or turnover to the following shift? Were all instruments returned to the proper location? 12. Based on the information obtained determine if there is the potential for this issue to have occurred previously with this individual, or others in the work group. If so, perform additional investigation to determine the scope of the performance issues. Page 8 of 31

11 Attachment 2 Technician Development Plan Name Employee Number Position SR RP JR RP Section One - Training Performance The following performance gaps were identified during training and requiring following while working at the station. Site Manager will perform observations to validate the performance is meeting the standard or will provide additional actions or coaching as necessary. The goal is to help the employee achieve and maintain the highest level of performance while working at the station. Performance Gap List the specific gap that the employee needs to focus on based on performance during training Immediate Action Indicate the immediate actions taken during training to help the employee understand the correct standard for performance. Coached Employee Re-tested Employee Required Reading of Procedures Page 9 of 31

12 Site Manager Follow Up Actions List the specific actions the Site Manager will need to perform to validate performance is meeting the standard at the station. An action is required for each performance gap noted Employee Acknowledgment I understand that performance gaps were identified during RP training that will require follow up actions on the job site by the DZ Site Manager. I understand the expectation for performance while at the station. I acknowledge these areas needs my individual attention to ensure the performance improves, and I will support the DZ Site Manager to ensure follow up actions are completed. Employee ID Number Trainer Date Date Page 10 of 31

13 Site Manager Observations Plan Section Two - Training Follow up Observations None Required Site Employee name Site Manager is required to perform observations of technician performance to ensure the performance gaps identified during RP training have been corrected by the employee. In most cases, Section Two observations should be completed prior to Section Three Observations, to ensure known performance gaps found in training have been corrected. Observations can be completed by DZ or Site Supervision. Observations should include the performance of the activity, and associated documentation. If no performance gaps were identified; then check None Required box above. Performance Gap 1. Date Observed Observer Activity observed Performance meets the standard Yes No Documentation met the standard Yes No Follow up actions required by technician Performance Gap 2. Date Observed Observer Activity observed Performance meets the standard Yes No Documentation met the standard Yes No Page 11 of 31

14 Follow up actions required by technician Performance Gap 3. Date Observed Observer Activity observed Performance meets the standard Yes No Documentation met the standard Yes No Follow up actions required by technician Employee Acknowledgment I understand that performance gaps were identified during RP training and that observations have been completed on my performance at the station. I have been given the feedback of my performance, and acknowledge completion of any follow up actions required by me. Employee ID Number Date Site Manager Date Page 12 of 31

15 Section Three - Site Manager Performance Observations Each employee s performance is required to be observed to ensure it meets the standard for performance. The Site Manager should be observant for performance not meeting the standard in all areas. Providing coaching when performance gaps are first identified helps the employee maintain their performance at the highest level. Capturing the performance helps to identify trends that may need to be a future focus area. Survey Performance The Site Manager is required to review 4 surveys performed by the technician at any time during the outage. An air sample can be used for one of the survey requirements. The survey review should be completed as soon as possible to identify performance issues early so coaching can be provided, if required. If the technician is not assigned to an area where surveys are performed document this in the section below. Note: A minimum of 2 surveys performed by personnel with identified performance training gaps are required to be reviewed. Survey description (location, purpose, etc.) Date Observer Radiation hazards properly identified Yes No Not required Contamination hazards identified Yes No Not required Gradient dose rate obtained Yes No Not required Beta dose rate obtained Yes No Not required Alpha monitoring Yes No Not required Timely survey documentation Yes No Not required Radiological hazards properly posted Yes No Not required Air sample taken in right location Yes No Not required Air sample taken right time in job Yes No Not required Air sample documentation correct Yes No Not required Comments Coaching Provided Yes No Page 13 of 31

16 Survey description (location, purpose, etc.) Date Observer Radiation hazards properly identified Yes No Not required Contamination hazards identified Yes No Not required Gradient dose rate obtained Yes No Not required Beta dose rate obtained Yes No Not required Alpha monitoring Yes No Not required Timely Survey documentation Yes No Not required Radiological hazards properly posted Yes No Not required Air sample taken in right location Yes No Not required Air sample taken right time in job Yes No Not required Air sample documentation correct Yes No Not required Comments Coaching Provided Yes No Survey description (location, purpose, etc.) Date Observer Radiation hazards properly identified Yes No Not required Contamination hazards identified Yes No Not required Gradient dose rate obtained Yes No Not required Beta dose rate obtained Yes No Not required Alpha monitoring Yes No Not required Timely survey documentation Yes No Not required Radiological hazards properly posted Yes No Not required Air sample taken in right location Yes No Not required Air sample taken right time in job Yes No Not required Air sample documentation correct Yes No Not required Page 14 of 31

17 Comments Coaching Provided Yes No Survey description (location, purpose, etc.) Date Observer Radiation hazards properly identified Yes No Not required Contamination hazards identified Yes No Not required Gradient dose rate obtained Yes No Not required Beta dose rate obtained Yes No Not required Alpha monitoring Yes No Not required Timely Survey documentation Yes No Not required Radiological hazards properly posted Yes No Not required Air sample taken in right location Yes No Not required Air sample taken right time in job Yes No Not required Air sample documentation correct Yes No Not required Comments Coaching Provided Yes No Page 15 of 31

18 Exposure Control (Personnel Monitoring) Date Observer The Site Manager shall perform observations of all technicians to ensure individuals are observant of their own exposure, and station procedure requirements for logging in and exiting the RCA are being met. The observation can be made by asking questions of the technicians while in the field. The technician should be aware of the amount of dose they have received, the current dose rate, the set points for their RWP, and when they should exit the area. Also, technicians should utilize low dose rate areas while working in the field. Exposure control expectations are being met Yes No Coaching Provided Yes No Job Coverage Date Observer The Site Manager is to perform an observation of job coverage activities, and ensure that performance is meeting standards in the following areas. Control of High Radiation Areas Yes No RWP requirements are properly implemented Yes No Workers briefed on current conditions Yes No Adequate radiological surveys performed Yes No Contamination controlled at the source Yes No Comments Coaching Provided Yes No Page 16 of 31

19 Employee Acknowledgment The Site Manager has reviewed with me the observations of my performance. I understand that I have been given feedback to help me maintain my performance at the highest level possible. Any performance improvement items have been clearly explain to me. Employee ID Number Date Site Manager Date Employee Comments Date Page 17 of 31

20 Section Four - Performance Improvement Plan The purpose of the Performance Improvement Plan is to provide the technicians with a structured pathway to improve performance, and include observations that validate the performance is acceptable. DZ management should be notified prior to utilizing this plan, and notified upon employee completion on the plan. The Site Manager should implement the use of a Performance Improvement Plan based on observations of performance, or investigation of performance events, where the actions taken caused, or could have caused a significant radiological event. The performance gap should be clearly stated as well as the specific actions that must be taken by the technician to improve. The Performance Improvement Plan should, where appropriate, address knowledge, skills or decision making performance issues. Based on the seriousness of the performance it may be necessary to remove an individual s qualifications until the actions required by the Performance Improvement Plan have been completed. This means the individual will no longer be able to perform task independently until the remediation has been completed and performance validated. Page 18 of 31

21 Employee Performance Improvement Site Name Date Description of performance gap List the NEI or STE qualification that has been removed if required; List the specific remediation actions that are required; List the observations that are required to be completed to validate that performance is meeting standards; Employee Acknowledgment I understand that performance gaps have been identified that require my immediate attention to correct. I acknowledge the remediation action that I have to complete to improve my performance, and I understand that observations will be made to validate my performance is acceptable. Employee ID Number Date Site Manager Date Page 19 of 31

22 Attachment 3 JR Radiation Protection Experience Guide Purpose The purpose of the JR Radiation Protection Experience Guide is to provide a structured means of ensuring technicians receive a broad range of experience prior to reaching ANSI 3.1 qualification. This attachment is not intended to be a qualification card. Qualifications are obtained by completing the requirements listed in NISP-RP-12. This attachment is designed to help Site Managers, and Technicians make decisions on work assignments so the proper experience can be gained. It is the Site Manager s responsibility to observe the work of the employee, and review the completion of documentation while they are working in an assigned area. The purpose of this attachment is to gain experience that will assist the technician in making field decisions before they become an ANSI 3.1 SR Technician. Completion of a single task in an area is typically not sufficient to sign off an area as meeting the intent of this guideline. You want to observe performance over a broad range of conditions prior to signing off that section as complete. For example; the posting a single radiation area would not be sufficient to sign off posting of radiological areas. Acknowledgement I understand it is my responsibility to use this attachment to gain experience over a broad cross section of the radiation protection field. It is my responsibility to bring to the attention to the Site Manager when I have been assigned work that is included in this performance guide. I understand that the Site Manager will review work I perform, and will only sign off that section as completed based on my proficiency of performing the task. The goal is provide me with experience that will support my performance as an ANSI 3.1 SR Technician. Employee ID Number Date Page 20 of 31

23 Attachment 3 JR Radiation Protection Experience Guide The Site Manager should initial the task after the technician has demonstrated the ability to perform the task with proficiency, and under various conditions. Observations of actual performance and a review of documentation are required to validate the performance meets the standard. The purpose of this guide is to help the JR develop proficiency in the various areas necessary to perform at the Senior Technician level. Task should not be signed off with just one observation since the objective of the guide is to look for repeatable performance level. The guide should be used by the Site Manager to communicate with the station where the JR Technician should be assigned to gain needed experience. The Site Manager can delegate the observation of an activity to an SME (Subject Matter Expert) for specific tasks or when an individual will have an opportunity to evaluate the JR Technicians performance over a specific time frame. The SME will initial the completion box. Employee ID Number Date 1. Performance of radiation surveys a. General area radiation surveys SM Date b. Contact radiation surveys SM Date c. Beta radiation surveys SM Date d. Gradient surveys SM Date e. Underwater surveys SM Date f. Discrete particle survey SM Date g. B/G Contamination survey SM Date h. Alpha contamination survey SM Date i. Direct frisk survey SM Date j. Alpha frisk survey SM Date k. Neutron survey SM Date 2. Performance of radiological posting a. Post radiation area SM Date b. Post contamination area SM Date c. Post radioactive material area SM Date d. Post airborne area SM Date Page 21 of 31

24 3. Performance of job coverage a. Area was properly surveyed SM Date b. Workers briefed on conditions SM Date c. RWP controls implemented SM Date d. Conditions validated during work SM Date e. Dosimeter placement validated SM Date f. Stop work requirements understood SM Date g. Contamination controlled at source SM Date h. ALARA properly implemented SM Date 4. Access control a. Control of HRA/LHRA keys SM Date b. Effective boundary control guard SM Date c. Effective briefs prior to access SM Date 5. Air sampling a. Air sample location appropriate SM Date b. Air sample take at appropriate time SM Date c. Accurate documentation SM Date d. Noble gas sample SM Date e. Tritium sample SM Date f. Alpha air sample SM Date g. Iodine sample SM Date 6. Control of Radioactive Material a. Material properly tagged SM Date b. Material stored properly SM Date Page 22 of 31

25 Attachment 4 - Safety and Performance Observations Purpose of the call is to improve performance. Report small indicators or performance issues. Safety issues defined in Section 2.3 Performance issues as defined in Section 2.5 Observations Number completed since last call Positive Observations provided to technicians Coaching provided Performance Trends Action Plan Weekly performance discussion completed with the RPM on Forward look at high risk activity What high risk activity is scheduled involving DZ personnel? What specific actions are being taken to ensure the high risk activities will be completed successfully? Page 23 of 31

26 Attachment 5-Site Manager/Supervisor/Observer Preparation List Purpose: This list of items are reminders that will help a Site Manager/Supervisor/Observer be successful performing field and survey observations, field and survey observations tracking, interaction with site RP Management, and observation feedback briefings. This list is not all inclusive but will help the RP Supervisor/Observer prepare for their assignment so that he/she is not spending precious observation time trying to figure out site processes. A) Observation Implementation Plan! Develop the Site Observation plan to present to the Site RPM for approval using Attachment 6. This plan should consist of activities to be observed and who is scheduled to perform the observation. Include specific radiological high risk activities (with subset tasks to monitor with the high risk activity i.e. preparation for job, pre-job briefing, Alara briefing. Job coverage, etc...), routine activities (i.e. routine surveys, control point duties, etc ), and any special activities (i.e. shipping surveys, equipment hatch coverage, Radwaste group, etc ). Your plan will concentrate on Radiological Safety so ensure you add an overview of the other items you will observe such as Industrial Safety and HU tool usage. B) Request Access for Site Programs! Access to Site Electronic Survey Program. Need the ability to review surveys for re-work corrections and to ensure surveys meet the DZ Manual Nuclear Promise Commitments.! Access to Site Electronic Logbook to review RP Entries.! Access to Site Observation Program Database. Sites require a certain number of supervisor observations to be put into their database for department trending.! Access to Nuclear Management Procedures and Site Procedures.! Access to Condition Report Database. Page 24 of 31

27 C) Create Standard Forms for Completing Observations! Access to the DZ RP Observation Database is required to input observations for technicians on site.! Ensure you have copies of the survey observation form to ensure consistency for all observers when reviewing surveys.! Consider a standardization format for inputting field observations. This could look like an entry part for positives and an entry part for deltas in the comment section of the DZ database. This will help when you roll up the observation data for trending purposes. Also it will help us be more critical of our observations. This can show how deep we are going in the observation process to get deltas we need to prevent performance trends.! Develop a RP Survey Self Check Sheet to assist the RP techs in performing and documenting surveys. Using a form such as this will ensure the DZ Nuclear Promise Commitments and site requirements are met. Also this self-check tool for the RP techs will reduce the number of rework surveys returned for correction, improve the efficiency of QC and Supervision reviews, and provide timely documentation to the RP staff for briefing plant workers.! Develop a tracking form with all the technicians names with space for initial of observer and date of observation for field observations and survey observations. This form is very helpful to keep track of who has been observed and who needs to observed so that we level our contact time to be able to give feedback to everyone. Everyone to be observed as much as possible to be able to improve their performance. In addition, the form will serve as an aid for keeping track of all the field and survey observations for the twice weekly morning DZ phone call.! Develop a survey tracking form to be able to document how many surveys a technician has performed week to week. You can do this to ensure we do not have a problem like what occurred in the past when a 3.1 Senior RP Technician was at a plant for an outage and did not document one survey. This goes back to our performance so this form will help you keep track of one of our most important roles as RP. Page 25 of 31

28 ! Create a template for a mid-outage refocus briefing for the RP/Decon Group. Even if there have not been any major issues, roll up the minor issues so that the team remains focused to complete the outage strong.! Have observation roll up documents that consist of the positives and deltas with graphs detailing totals of all observations and a breakout of observation category attributes. Be prepared to meet with the RPM or Plant GM to discuss the observations, trends and what your data is telling you.! After week one, perform a roll up of all your observation data and put into the above document. Then before each DZ Corporate phone call, roll up your data and document it so that you stay on top of any performance trends. This makes it easier to manage the data if you do it frequently.! After week one, create a roll up data one minute brief for the Decon and RP technician morning/evening turnover meeting. Base this document off the observed data from your site. You can also include any lessons learned or issues from another site. The purpose of the roll up minute is to get the lessons learned out to all of the Decon and RP technicians in a concise format. You can do it for the whole week so everyone is talking on the same topic every day. This will ensure that the feedback you are providing to one technician or decon person gets out to the entire group. That way we can make a change more quickly to prevent a trend from occurring. D) Contingency Plans! Have an injury prevention plan you can take out and modify if you end up having an injury problem. Remember to over react to the small issues so they do not become a big issue where someone has a major injury.! Keep any presentations, recovery plans, and data that may help you in any future assignments. Also be prepared to share this data with any other site RP Supervisors/Observers, RP Site Managers, and DZ Corporate, if requested, to help our team have a successful outage season. Page 26 of 31

29 Attachment 6 - Observation Plan Development Guide Hazard and Risk Assessment An effective observation plan will ensure work is completed safely and performance is maintained high. However, it is not possible for the Site Manager to observe every activity during an outage. The purpose of the Observations Plan is to determine those activities that need to be observer and who in the outage organization is responsible for that oversight. The development of the plan starts by assessing the radiological hazards and risk during the outage. Answer the following questions about the activities that are scheduled during the outage. Note the location of the activity and the date when it is schedule to occur. 1. Is there any radiography during the outage? 2. Where/when is the greatest safety issue for RP Technicians? 3. What safety issues have occurred with RP Technicians in past outages? 4. Is diving scheduled? 5. Are there plans to remove/replace any large contaminated pumps or valves? 6. Are steam generator inspections required? 7. What LHRA work is scheduled? 8. What work activity will involve the highest contamination levels? 9. What work activity has the highest potential for the radiological conditions to change during the activity? 10. Where do we have assigned personnel with the least amount of experience? 11. What work activity has the potential for the highest alpha activity? 12. What work activity has the potential to generate air borne activity? 13. What performance issues where noted by RP during the last outage? 14. Are there areas which are understaffed which might impact performance? 15. Where/when in the plant are dose rates expected to increase? 16. Where/when is the greatest potential for loss of control of radioactive material? 17. What work is planned on removal of high dose components such as incores or LPRMs? 18. What is the highest radiological risk activity during the disassembly of the reactor for defueling? 19. What is the highest radiological risk activity during the re-assembly of the reactor vessel? 20. What work activity has the potential for gradient dose rates which would require the technician to validate dosimetry is in the proper location? Page 27 of 31

30 Develop Observation Schedule Once the hazards and risk assessment has been completed develop an observation plan. The plan must include scheduled observations of anyone who has a Performance Improvement Plan documented in Attachment 2, Section 4. The RPM and Site Supervisors should be made aware of any technician who has a documented plan and how our oversight is going to ensure performance is maintained at a high level. The observations should include pre-job briefing and setup as well as observations in the field while the work activity is taking place. It is critical that a review of required documentation is completed. The observer can be DZ or station personnel. In many cases work activities may continue over several shifts. List the activity so that the station and individuals understand what is to be observed and who is responsible. Outage Week One Date Observer Work Activity Page 28 of 31

31 Outage Week Two Date Observer Work Activity Outage Week Three Date Observer Work Activity Page 29 of 31

32 Outage Week Four Date Observer Work Activity Approved Site RPM Approved DZ Regional Manager Page 30 of 31

33 Attachment 7 Resume Review Guidelines 1. The resume must show the start and stop date of all work activities. The maximum time allowed to be assigned is 50 hours a week. If the individual were working less than 50 hours per week, then the actual hours should be assigned. 2. The description of the work activity must clearly indicate that it involved radiation protection activities and should describe where it took place (e.g. refueling floor). A good description provides two functions, it helps to accurately assess the activity against the requirements of NISP-RP-12, Attachment 5, and helps the station understand what activities the individual has performed so they can be properly assigned at the station. 3. The description of work activities may include the performance of surveys, providing radiological job coverage, air samples, release and control of radioactive material, shipping of radwaste, and providing radiological briefings. The resume must not contain vague statements such as supported the outage on the refueling floor. See the example below. 4. The resume should include a description of any education completed by the individual. Education can be given credit towards experience but not until the individual has reached the 18.1 level. Example of good work description I supported the station by doing initial entry surveys in containment as soon as the unit went off line. I worked on the refueling floor providing job coverage for the disassembly of the reactor vessel including taking surveys, air samples, and tagging radioactive material. I performed underwater surveys for the removal of incores and supported cavity decon by performing post decon surveys. I briefed workers for high rad and locked high rad entries into the refueling cavity. Example of poor work description. I was assigned to support the outage in the aux building and did various RP activities including routines and worker briefings. I posted areas when required to do so. Page 31 of 31