Workplace safety is at the forefront of CDI’s focus in all aspects of our businesses. Our approach to personnel safety is intended to focus each employee on their personal responsibility for their safety and the safety of their co-workers. This inward focus is enhanced with regular safety training, a safety incentive program, recognition of individual safety efforts and the active involvement of executive management. Safe decommissioning resides at the core of CDI’s business.
As such, CDI maintains an Environmental Health and Safety/Quality Program (EHS&Q) and has developed a standard set of procedures that define the minimum requirements to comply with the U.S. Code of Federal Regulations under 10 CFR 1904, 1910 and 1926. These programs and procedures can be grouped into the following key elements: Industrial Hygiene, Occupational Medical Surveillance, Occupational Safety, Hazardous Waste Site Operations, Fire Protection, and Health and Safety Infrastructure. CDI uses corporate EHS&Q policies as a guideline for site-specific programs because attempting to modify existing procedure sets used during operations may introduce the preventable hazards stemming from not incorporating past lessons. Our experience with managing decommissioning projects has taught us the value in implementing a robust safety structure on day one at a new facility.
Safety in Transition – Plant Operations to Decommissioning Activities
The safety of employees and the community is paramount as a plant transitions from operations to decommissioning. CDI has dedicated programs, policies and behavioral training mechanisms that focus on concerns specific to decommissioning, with added experience and lessons learned from past projects. This includes transitioning staff used during plant operation by teaching and providing the tools to understand best practices. This helps to ensure appropriate work conducted under a vastly different set of objectives during plant dismantlement is always completed with the protection of employees, communities and the environment.
Radiation Protection – As Low As Reasonably Achievable (ALARA)
CDI maintains a Radiological Protection Program to ensure occupational and public doses are maintained well below regulatory limits and that all activities are performed following the objective to maintain dose as low as reasonably achievable (ALARA). The program includes qualification of individuals and Radiation Protection Management under an ANSI 3.1 and Regulatory Guide 1.8.
The program establishes CDI’s requirements for operations involving exposure to ionizing radiation and radioactive materials. The program includes and ties directly to: personnel protection, airborne monitoring (debris and particulate), and observation of best practices for radioactive waste management.
CDI’s Quality Assurance Program guides the Company’s overall approach for the control of quality of products and services. This approach is based on ASME NQA-1-2008 with the NQA-1a-2009 Addenda, Part I, Requirements for Quality Assurance Programs for Nuclear Facilities. Under equity and asset transfers (operating as a decommissioning general contractor), the site 10 CFR 50, Appendix B Quality Assurance Program (QAP) will be adopted for use during decommissioning. As the decommissioning site plant status evolves, the QAP will be modified for compliance with the requirements of 10 CFR 50.54 (a) change process.
Nuclear Safety Culture
The principal responsibility of CDI’s entire leadership team is to foster an atmosphere that emphasizes safety over competing goals, assuring that the protection of people and the environment come before project schedules and profits. The core values and behaviors of safety espoused by CDI set the expectations for the conduct of decommissioning operations and establish a safety-conscious work environment (SCWE), in which workers are able to raise nuclear safety concerns without fear of retaliation. CDI’s Nuclear Safety Culture includes traits that describe patterns of thinking, feeling, and behaving that emphasize safety, particularly in goal conflict situations, such as when safety goals conflict with production, schedule or cost goals. The decommissioning of nuclear power plants continues to be a challenge for many licensees. It is of utmost importance to the CDI executive management team to maintain a positive safety culture during the decommissioning phase.