Text

Exam Final Jpms. September 17-21, 2001
	ML012990212
Person / Time
Site:	Browns Ferry
Issue date:	10/18/2001
From:	Ernstes M; Division of Reactor Safety II
To:	Scalice J; Tennessee Valley Authority
References
	-RFPFR, 50-259/01301, 50-260/01301, 50-296/01301
	Download: ML012990212 (491)
	v • d • e

FINAL SUBMITTAL BROWNS FERRY EXAM 50-259, 260, 296/2001-301 SEPTEMBER 17-21, 2001 FINAL AS-GIVEN JPMs FOR EACH WALK-THROUGH TEST

FINAL SUBMITTAL FINAL AS-GIVEN JPMs FOR EACH WALK-THROUGH TEST

ES-301 Administrative Topics Outline Form ES-301-1 (R8, S)

Facility: Browns Ferry Date of Examination: 9/17-9/19-2001 Examination Level (circle one): RO / SRO Operating Test Number: 1 Administrative Describe method of evaluation:

Topic/Subject 1. ONE Administrative JPM, OR Description 2. TWO Administrative Questions A.1 Conduct Of RO-JPM NRC Operations A.1.a DETERMINE REACTOR VESSEL WATER LEVEL.

(K/A 2.1.28)

Shift Staffing RO - NRC-JPM-02 (NEW),

Requirements EVALUATE OVERTIME ELIGIBILITY (K/A 2.1.3, 3.0/3.4)

A.2 Equipment RO - JPM A.2 Operability DETERMINE COMPONENT POSITIONS FOR VALVE LINE Requirements UPS AND TAG ORDER PERFORMANCE. (K/A 2.2.1, 3.6/3.8)

A.3 Control of DETERMINE BUILDING VENTILATION NOBLE GAS RELEASE Radiation RATE. JPM #131, KA 271000A4.05, 3.2/3.9 Releases A.4 Emergency 1. RO QUESTION: KNOWLEDGE OF ABNORMAL CONDITION Plan PROCEDURES.( K/A: G2.4.11)

2. RO QUESTION: KNOWLEDGE OF THE RO'S RESPONSIBILITIES IN EMERGENCY PLAN IMPLEMENTATION. (K/A G2.4.39)

ES-301 Administrative Topics Outline Form ES-301-1 (R8, Si)

Facility: Browns Ferry Date of Examination: 9/17-9/19 2001 Examination Level (circle one): RO / SRO Operating Test Number: 1 Administrative Describe method of evaluation:

Topic/Subject 1. ONE Administrative JPM, OR Description 2. TWO Administrative Questions A.1 Conduct of QUESTION ON FITNESS FOR DUTY. (K/A 2.1.6,4.3)

Operations DETERMINE THE CONDITION CLASSIFICATION FOR RCIC INOPERABLE. (K/A 2.1.33, 3.4/4.0)

Shift Staffing SRO - NRC-JPM-02 (NEW), EVALUATE OVERTIME ELIGIBILITY Requirements (K/A 2.1.3, 3.0/3.4)

A.2 Equipment SRO - JPM A.2 DETERMINE COMPONENT POSITIONS FOR VALVE Operability LINE-UPS AND TAG ORDER PERFORMANCE. (K/A 2.2.1, 3.6/3.8)

Requirements A.3 Control of DETERMINE BUILDING VENTILATION NOBLE GAS RELEASE Radiation RATE. JPM #131, (KA 271 000A4.05, 3.2/3.9)

Releases A.4 Emergency JPM -181 CLASSIFY THE EVENT PER THE REP (GASEOUS Plan RELEASE RATE-0SI-4.8.B.I.A.1) (K/A 2.4.38, 4.0)

Handout to Applicant A handout of SR-2 readings and an attachment is given. The following is an explanation of the conditions, followed by two question.

During the past 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months the Unit 2 has cooled down from 212 degrees F to 100 degrees F bulk moderator temperature.

2-SR -2 recorded the indicated water level on FRIDAY while at 212 deg F. Readings were again recorded on SATURDAY with moderator temperature at 100 degrees F. The readings for Narrow Range Compensted and Uncompensted columns and are provided (provide marked up copy of page 24 and 46 of the SR, and Attachment 4).

1. The Unit Supervisor has requested that you utilize the reading and Attachment 4 of 2-SR-2 to determine corrected water level , and determine the actual net change in reactor water level over the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period starting when the reactor was a 212 degrees F and ending when the reactor was at 100 degrees F.

2. Assume the rate of change is the same over the next 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, determine the actual water level exoected on SUNDAY.

Examiner Noter: Give applicant the conditions handout and the marked up copy of SR-2 (Instrument Checks and Observations) and Attachment 4 A handout of SR-2 readings and an attachment is given. The following is an explanation of the conditions, followed by two question.

During the past 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months the Unit 2 has cooled down from 212 degrees F to 100 degrees F bulk moderator temperature.

2-SR -2 recorded the indicated water level on FRIDAY while at 212 deg F. Readings were again recorded on SATURDAY with moderator temperature at 100 degrees F. The readings for Narrow Range Compensted and Uncompensted columns and are provided (provide marked up copy of page 24 and 46 of the SR, and Attachment 4).

1. The Unit Supervisor has requested that you utilize the reading and Attachment 4 of 2-SR-2 to determine corrected water level , and determine the actual net change in reactor water level over the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period starting when the reactor was a 212 degrees F and ending when the reactor was at 100 degrees F.

2. Assume the rate of change is the same over the next 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period, determine the actual water level expected on SUNDAY.

Solution - Corrected Water Level for both sets of readings is 35 inches on both Friday and Saturday, should be the same for Sunday, so Net Change is Zero.

KA 2.1.28 (3.2/3.3) Knowledge of major system components and controls.

INFORMATION FOR THE SR-2 READINGS At beginning of cooldown:

Narrow Range Compensated 2-LIS-3-53, 60, 206, and 253 indicated 41 inches (listed as Friday Readings)

Narrow Range Uncompensated 2-LIS-3-184, 185, 203(A-D), and 208 (A-D) indicated 48 inches (listed as Friday Readings)

Following the cooldown Narrow Range Compensated 2-LIS-3-53, 60, 206, and 253 indicated 44 inches (listed as Saturday Readings)

Narrow Range Uncompensated 2-LIS-3-184, 185, 203(A-D), and 208 (A-D) indicated 51 inches (Listed as Saturday Readings) on following page.

ATTACHMENT 4 (Page 1 of 1)

Reactor Water Level Indication Correction The Reactor Water Level Instrumentation tables in Attachment 2 are arranged such that only instruments in the same compensation group are compared. However, determination of corrected level indication may be required during operation at off-normal conditions or if desired to compare instruments from different compensation groups.

Corrected level indication may be used for satisfying MAX DEV criteria provided the following are observed:

The parameter correction is appropriately applied to all instruments being compared.

Both the indicated and corrected level indications are recorded and annotated in Attachment 2 along with the bases for the corrected level indication.

Corrected level indication can be determined from the following table which provides commonly needed corrections or from Technical Instruction 2-TI-149. The following table presents Reactor Water Level as: indicated, corrected for Reactor Vessel Temperature 100lF, and corrected for Reactor Vessel Temperature 212'F for various water level instruments. Enter the indicated Rx water level and find the correct instrument column and use the closest Rx vessel temperature. (Matching corrected levels between instruments and subtracting the associated indicated levels will yield an approximate deviation value in inches between those instruments. i.e. If the Narrow Range Compensated Instrument is reading 38", the corrected level would be 34.5". Also, using a corrected value of 35.5" in the Narrow Range Uncompensated column shows the instrument should be reading 46". Therefore, a deviation of approximately 8" would be expected between the Narrow Range Compensated instrument and the Narrow Range Uncompensated instrument.)

INDICATED CORRECTED LEVEL LEVEL Indicated Narrow Range Narrow Range Wide Range Post Accident Floodup Wide Ran Reactor Compensated Uncompensated 2-LI-3-58A 2-LR-3-62 2-LI-3-55 2-LI-3-46 Water Level 2-LIS-3-53(60)( 2-LIS-3-184, (B), 2-LIULIS-3-52 Level (B) 206) 185,203(A-D), 2-LIS-3-56A 2-LULIS-3-62A Level (253) Level 208(A-D) (D) Level Level Level 1000 2120 1000 2120 1000 2120 1000 2120 100' 2120 50 39 42 34.5 37 49 50.5 48 38 40 33 35 47 48.5 46 36.5 39 31.5 34 45 46.5 44 35 37 30 32.5 43 44 42 33.5 36 29 31 No 41 42 No 40 32 34 27.5 29.5 Note Note Calculated 39 40 Calculatc 38 31 33 26 28 1 2 Correction 37 38 Correctic 36 29.5 31.5 24.5 26.5 Value 35 36 Value 34 28 30 23 25 33 34 32 26.5 28.5 22 23.5 31 32 30 25 27 20.5 22 29 30 28 24 25.5 19 20.5 27 28

Notes:

(I) Indicates >60" if actual Water Level is >14".

(2) Indicates >60" if actual Water Level is >8".

BFN INSTRUMENT CHECKS AND OBSERVATIONS 2-SR-2 UNIT 2 Rev 0026 SURVEILLANCE PROCEDURE DATA PACKAGE MODES 1, 2, & 3 - DAY SHIFT Page 24 of 129 WEEK: -/i/ to 9/7/0/ ATTACHMENT 2 (Page 10 of 77)

TABLE 1.9 REACTOR WATER LEVEL INSTRUMENTATION NARROW RANGE (COMPENSATED)

APPLICABILITY: Readings are required at all times.

(REFER TO P&L step 3.2)

(Note 2)

Criteria Source: FSAR 7.10.4 LOCATION: Panel 2-9-5 Review Initials Reference Leg A B C D MAX DEV All Data is Unit 2-LI-3-53 (in.) 2-LI-3-60 (in.) 2-LI-3-206(in.) 2-LI-3-253(in.) Note 1 SAT/UNSAT UO Supvr Friday 41 _ _

Saturday - SL Sunday Monday 3.0 inches Tuesday ________ ________ ________ _______________________

W ednesday ________________ ________ ________ _________ _____ ____

Thursday Note:

1) REFER TO Attachment 4 during off-normal operating conditions.

2) Reactor vessel water level indications from the four water level channels can be compared during operation (and are compared automatically by the RFWCS) to detect instrument malfunctions.

(

BFN INSTRUMENT CHECKS AND OBSERVATIONS 2-SR-2 Rev 0026 UNIT 2 SURVEILLANCE PROCEDURE DATA PACKAGE MODES 1, 2, & 3 - DAY SHIFT Page 46 of 129 WEEK: 9/q /o/ to q//?lD i ATTACHMENT2 (Page 32of 77)

TABLE 1.32 REACTOR WATER LEVEL INSTRUMENTATION NARROW RANGE (UNCOMPENSATED)

Part 1 - APPLICABILITY: Modes 1, 2 & 3(REFER TO P&L step 3.2) Mode 3 (REFERTO P&L step 3.2)

Readings are required at all times Readings are required at all times. Review Surveillance Requirements: 3.3.1.1.1(f4), 3.3.6.1.1(f2a,5h 3.3.6.2.1(fl), 3.3.7.1.1(fl) 3.3.6.1.1(f6b) Initials Reference Leg C/D Instruments Leg A/B Instruments MAX Leg D C B A DEV LOCATION 2-9-86 2-9-85 2-9-84 2-9-83 (AC) All Data Unit 2-LIS-3-203D in.) 2-LIS-3-203C (in.) 2-LIS-3-203B in. 2-LIS-3-203A in.) Note 3 SAT/UNSAT UO supvr Friday gly 4 ________

Saturday 51/ 5 / '5.0 inch Sunday Deviation Monday ,Between Tuesday All Instruments W ednesday AND Thursday AND Part 2- APPLICABILITY: Mode l and Modes 2 & 3 when Reactor steam dome pressure >150 psig (REFER TO P&L step 3 2) Readings are required at all times 3.5 inch Surveillance Requirements: 2-LIS-3-208A-D = 3.3.2.2.1, 3.3.5.1.1(f3c), 3.3.5.2.1(f2) Deviation 2-LIS-3-184 & 185 = 3.3.5.1.1(f4d,5d) Between Reference Leg C/D Instruments Lec A/B Instruments All Instrumjents Leg C D C B B A on the A/B Leg LOCATION 2-9-82 2-9-81 2-9-82 2-9-81 All Data Unit 2-LIS-3-185 2-LIS-3-208D 2-LIS-3-208C 2-LIS-3-208B 2-LIS-3-184 2-LIS-3-208A AND SAT/UNSAT UO Supvr

_in.) (in.) n. _in.)

Friday 21,17K47 . -_r , 3.5 inch Saturday 5/ / / Z

,/- Deviation Sunday Between Monday All Instruments Tuesday on the C/D Leg Wednesday Thursday Notes:

1) REFER TO Attachment 4 during off-normal operating conditions.

2) IM's may obtain voltage readings, corrected for level indication, to assist in operability determination.

3) Ail instruments on the AB(C/D) Leg should read wilhin 3.5 inches of each other AND within 5.0 inches of C/D(A/B) Leg instruments.

BFN INSTRUMENT CHECKS AND OBSERVATIONS 2-SR-2 UNIT 2 Rev 0026 Page 125 of 129 ATTACHMENT 4 (Page 1 of 1)

Reactor Water Level Indication Correction The Reactor Water Level Instrumentation tables in Attachment 2 are arranged such that orily instruments in the same compensation group are compared. However, determination of corrected level indication may be required during operation at off-normal conditions or if desired to compare instruments from different compensation groups.

Corrected level indication may be used for satisfying MAX DEV criteria provided the following are observed:

"* The parameter correction is appropriately applied to all instruments being compared.

"* Both the indicated and corrected level indications are recorded and annotated in Attachment 2 along with the bases for the corrected level indication.

Corrected level indication can be determined from the following table which provides commonly needed corrections or from Technical Instruction 2-TI-149. The following table presents Reactor Water Level as: indicated, corrected for Reactor Vessel Temperature 100F, and corrected for Reactor Vessel Temperature 212°F for various water level instruments. Enter the indicated Rx water level and find the correct instrument column and use the closest Rx vessel temperature. (Matching corrected levels between instruments and subtracting the associated indicated levels will yield an approximate deviation value in inches between those instruments. i.e. If the Narrow Range Compensated Instrument is reading 38", the corrected level would be 34.5". Also, using a corrected value of 35.5" in the Narrow Range Uncompensated column shows the instrument should be reading 46". Therefore, a deviation of approximately 8" would be expected between the Narrow Range Compensated instrument and the Narrow Range Uncompensated instrument.)

INDICATED CORRECTED LEVEL LEVEL Indicated Narrow Range Narrow Range Wide Range Post Accident Floodup Wide Range Reactor Compensated Uncompensated 2-LI-3-58A 2-LR-3-62 2-LI-3-55 2-LI-3-46A Water Level 2-LIS-3-53(60) 2-LIS-3-184, (B), 2-LI/LIS-3-52 Level (B)

(206) 185,203(A-D), 2-LIS-3-56A 2-LI/LIS-3-62A Level (253) Level 208(A-D) (D) Level Level Level 1000 2120 1000 2120 1000 212- 100- 1 212- 100- 2120 50 39 42 34.5 37 49 50.5 48 38 40 33 35 47 48.5 46 36.5 39 31.5 34 45 46.5 44 35 37 30 32.5 43 44 42 33.5 36 29 31 No 41 42 No 40 32 34 27.5 29.5 Note Note Calculated 39 40 Calculated 38 31 33 26 28 1 2 Correction 37 38 Correction 36 29.5 31.5 24.5 26.5 Value 35 36 Value 34 28 30 23 25 33 34 32 26.5 28.5 22 23.5 31 32 30 25 27 20.5 22 29 30 28 24 25.5 19 20.5 27 28 Notes:

(1) Indicates >60" if actual Water Level is >14".

(2) Indicates >60" if actual Water Level is >8".

Handout to Applicant A startup is planned for the following shift. One Reactor Operator must be held over two hours for startup. The following is the work history (excluding shift turnover time) of the available reactor operators on shift(hours reflect those worked PRIOR to the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months holdover). A break of at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months occurreed between all work periods.

DAY 1 2 3 4 5 6 7 8 (Today)

Operator

1 0 0 13 11 14 10 14 10 Operator

2 0 3 10 12 12 12 8 14 Operator

3 0 0 12 12 12 8 8 15 Operator

4 0 8 12 10 10 8 10 12 Operator

5 0 4 12 10 10 14 10 12 Evaluate the work histor for all 5 operators. Determine which ooerator(s). if any. can be held over for two hours without prior overtime approval, and determine which operators CANNOT be held over for two hours without prior overtime approval.

A1.2 TASK CONDITIONS:

A startup is planned for the following shift. One Reactor Operator must be held over two hours for startup. The following is the work history (excluding shift turnover time) of the available reactor operators on shift (hours reflect those worked PRIOR to the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months holdover). A break of at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months occurred between all work periods.

DAY 1 2 3 4 5 6 7 8 (Today)

Operator

1 0 0 13 11 14 10 14 10 Operator

2 0 3 10 12 12 12 8 14 Operator

3 0 0 12 12 12 8 8 15 Operator

4 0 8 12 10 10 8 10 12 Operator

5 0 4 12 10 10 14 10 12 Evaluate the work history for all 5 operators Determine which operator(s), if any, can be held over for two hours without prior overtime approval, and determine which operators CANNOT be held over for two hours without prior overtime approval.

Task Standard:

GEN 2.1.3 (3.0/3.4) Knowledge of shift turnover practices CFR 41.10 RO and SRO SOLUTION:

Step Description Standard SATIUNSAT 1 Reference SPP-1.5 Current Revision SPP-1.5 2 Evaluate Operator 1 Determine Operator #1 would exceed Critical 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period and and would exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in a 7 day period and would require overtime PROOT:_ a uthorization PROMPT:

If asked, inform applicant that operator I received authorization for exceeding 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period between days 4 and 5.

3 Evaluate Operator 1 Determine Operator exceeded 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period between dlays 5 and 6 4 Evaluate Operator 2 Determine Operator #2 would exceed Critical 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in a 7 day period and would "requireovertime authorization 5 Evaluate Operator 3 Determine Operator #3 would exceed Critical 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in a 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months period and would "require overtime authorization 6 Evaluate Operator 4 Determine that Operator #4 would not exceed any overtime guidelines 7 Evaluate Operator 5 Determine Operator #2 would exceed Critical 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in a 7 day period and would require overtime authorization

Tennessee TITLE SPP-1.5 Valley Authority Rev. 2 Page 1 of 10 TVAN STANDARD OVERTIME RESTRICTIONS Quality Related ED Yes C] No PROGRAMS AND (REGULATORY) PORC Required Z Yes [I No PROCESSES 10CFR50.59 Review Z Yes C1 No Effective Date 11/15/99 RESPONSIBLE PEER TEAM: Plant Managers Organization APPROVALS Dennis L. Koehl 10/29/99 Primary Sponsor Date For Nuclear Assurance Sponsored SPPs N/A N/A General Manager,NA Date Karl W. Singer 11/9/99

Senior Vice President,Nuclear Operations Date Site-specific changes are approved by Site Sponsor and Site Vice President (see PCF)

Page 1 of 1 SPP 2 1-1 [12-01-971 TVA 40480 [12-97]

TVAN STANDARD SPP-11.5 OVERTIME RESTRICTIONS (REGULATORY) Rev. 2 PROGRAMS AND Page 2 of 10 PROCESSES REVISION LOG Revision Effective Pages Description Number Date Affected of Revision 0 10/8/97 All Replaces STD-1.7, SSP-11.7 at SON and BFN; and SSP-1.07 at WBN.

1 5/20/99 2, 4-10 Revised to allow Plant Manager or Site Vice President to delegate approval of exception to overtime during outages, and modified requirements for review of the monthly overtime exception report.

2 11/15/99 2,5,8,9 Added exception to paragraph 3.B.3 and adjusted Forms SPP-1.5-1 and SPP-1.5-2 accordingly (minor/editorial change).

TVAN STANDARD SPP-1.5 PROGRAMS AND OVERTIME RESTRICTIONS (REGULATORY) Rev. 2 PROCESSES Page 3 of 10 TABLE OF CONTENTS Section Title Page R e v is ion Lo g ............................................................................. I......................................................... 2 Ta b le of C o nte nts ................................................................................................................................ 3 1.0 P UR P O S E .............................................................................................................................. 4 2 .0 S C O P E ................................................................................................................................... 4 3 .0 INST R UC T IO NS ..................................................................................................................... 4 4 .0 R E C O R D S .............................................................................................................................. 6 4 .1 QA R e c o rd s ...................................................................................... ........................... ....... 6 4 .2 No n-Q A R eco rd s ..................................... .............................................................................. 6 5 .0 DE F INIT IO NS ................................................................... ..................................... .......... 6 APPENDIXES Overtime Limitation Exception Report Processing Flowchart ................ 7 Appendix A FORMS SPP 1.5-1 Overtime Limitation Exception Report ................................ 8 SPP 1.5-2 Overtime Limitation Exception Report for Extended Shutdown Periods ......... 9

TVAN STANDARD SPP-1.5 PROGRAMS AND OVERTIME RESTRICTIONS (REGULATORY) Rev. 2 PROCESSES Page 4 of 10 1.0 PURPOSE This SPP establishes TVAN's regulatory overtime program to meet regulatory requirements and as specified in individual plant Technical Specifications.

The intent of these controls are to prevent situations where fatigue could reduce the ability of operating personnel to keep the reactor in a safe condition, and to assure that critical plant operating personnel are not assigned to shift duties while in a fatigued condition which could significantly reduce their mental alertness or decision making ability.

2.0 SCOPE A. The following personnel are required to meet the limitations specified in this SPP:

Senior Reactor Operators (SRO), Reactor Operators (RO), Nuclear Assistant Unit Operators (NAUO), Onshift RADCON Personnel, Operations Shift Managers, Shift Technical Advisors, Onshift Fire Operations Personnel, Unit Operators, Unit Supervisors, and key maintenance personnel (see 5.0 Definitions), including craft and contractors performing safety-related activities in the capacity of the TVA positions listed.

B. Although not specifically restricted by Technical Specifications, the limitations specified in this SPP should be used as a guide for all personnel performing work.

3.0 INSTRUCTIONS A. Expectations are that critical personnel work a nominal 40-hour week with minimal overtime. When overtime is required, it shall be assessed and monitored to ensure the below-listed restrictions are met. Assignment of overtime is made after consideration of such factors as on going activities, expected duration, and personnel involved, with the intent to minimize potential impact on safety-related activities.

B. For plant conditions which require substantial amounts of overtime to be used, or during temporary periods of work such as refueling outages, major maintenance projects or plant modifications, the following restrictions apply:

1. An employee may work no more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight, excluding shift turnover time (for exceptions, see 3.0-C below).

As an example an employee has worked on shift 16 continuous hours. At the end of the shift it takes one hour for shift turnover which means the employee has worked 17 continuous hours. Since the one hour over 16 was for shift turnover, an authorization for deviation from the overtime limitation is not required.

2. An employee may work no more than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24-hour period, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in a 48-hour period, or 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7-day period, excluding shift turnover time (for exceptions, see 3.0-C below).

For example a 7-day period is any combination of 7 consecutive days or rolling days (such as Monday through Sunday or Tuesday through Monday). Hours worked over 72 require authorization for exception to the limitation, excluding shift turnover (for exceptions, see 3.0-C below).

TVAN STANDARD SPP-1i.5 PROGRAMS AND OVERTIME RESTRICTIONS (REGULATORY) Rev. 2 PROCESSES Page 5 of 10

3. Employees are to receive at least an 8-hour break between work periods, including shift turnover time (for exceptions, see 3.0-C below).

4. During normal plant operations, the use of overtime is not for an entire staff working on a shift. It is considered on an individual basis. In the case of an extended shutdown for refueling, major maintenance, or major plant modification, approval may be made on a group basis.

5. When a control board operator must work in excess of the overtime guidelines, every effort must be made to remove the operator from the responsibility of operating the control room board.

C. The Plant Manager or Site Vice President may authorize deviations from the overtime restrictions on the Overtime Limitation Exception Report (Form 1.5-1). Their designees may approve deviations other than exceeding 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months straight. During outages, the Site Vice President or the Plant Manager may delegate the authority to exceed 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months to the Outage Manager or the Assistant Plant Manager. Form 1.5-2 will be used during periods of extended shutdown for refueling major maintenance, or major plant modification as determined by Plant Manager. The deviation will be based on the following criteria:

1. Unusual circumstances exist.

2. Significant reduction in personnel effectiveness would be highly unlikely.

D. The exact work to be performed is specified in the Overtime Limitation Exception Report in sufficient detail for the authorizing manager to review and conclude that significant reduction in personnel effectiveness would be highly unlikely.

E. The form must be filled out and approved before the individual(s) exceeds the overtime limit. If approval is received by telecon, the preparer shall document that approval was via telecon, initial, date, and given by whom.

F. Each month the Plant Manager or designee compiles the Overtime Limitation Exception Report forms approved for that month. Plant Manager or designee reviews the approved Overtime Limitation Exception Report forms for:

1. Excessive number of approvals/exemptions

2. Excessive exemptions for the same individuals and

3. Excessive group approvals (i.e., blanket approvals for whole groups or organization entities)

G. The Plant Manager documents that the review has taken place. The Overtime Limitation Exception Report forms and review documentation are sent to RIMS/EDM as non-QA records.

H. Business and Work Performance (B&WP) periodically checks the ATR report against the forms generated to ensure that no key personnel covered by the overtime procedure have worked hours exceeding limits without prior approval.

TVAN STANDARD SPP-11.5 PROGRAMS AND OVERTIME RESTRICTIONS (REGULATORY) Rev. 2 PROCESSES Page 6 of 10 4.0 RECORDS 4.1 QA Records None.

4.2 Non-QA Records Overtime Limitation Exception Report Overtime Limitation Exception Report for Extended Shutdown Periods 5.0 DEFINITIONS Key Maintenance Personnel - The term applies to all TVAN and contractor personnel who are subject to performing maintenance, repair, calibration or testing of safety-related structures, systems or components or personnel who are directly supervising such activities.

TVAN STANDARD SPP-1.5 PROGRAMS AND OVERTIME RESTRICTIONS (REGULATORY) Rev. 2 PROCESSES Page 7 of 10 APPENDIX A Page I of I OVERTIME LIMITATION EXCEPTION REPORT PROCESSING FLOWCHART Need Identified To Exceed SPP 1.5 Overtime Limitations Supervisor Provides Justification and Signs Form I

Site Vice President, Plant Mgr Site Vice President Or Plant Manager, or Their Designee Approves for extended shutdowns Form SPP 1.5-2 J

I Plant Manager or designee compiles the approved forms for Plant Manager monthly review

TVAN STANDARD SPP-1.5 PROGRAMS AND OVERTIME RESTRICTIONS (REGULATORY) Date 11-15-99 PROCESSES Page 8 of 10 OVERTIME LIMITATION EXCEPTION REPORT Page 1 of I The following employees (three or less) are authorized to work overtime in excess of the overtime limits specified in paragraphs 3.8.1 and 3.8.2 of SPP-1.5. This report must be maintained and available for NRC review.

Name SSN Organization Hours Exceeding Requirements Date # Hours Time Limit Will Be Exceeded

a. Time:

b. Time:

c. Time:

1. Specify specific reason for cause of overtime (i.e., another employee on S/L, unexpected job, etc.).

2. Specify requirement to be exceeded: E] 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months continuous (*NOTE 1) [5 8-hour work break E5 16 hrs. in 24 [] 24 hrs. in 48 E] 72 hrs. in 7-day period

3. Specify exact work to be performed and brief description (include procedure number, workplan number, work request number, or support of other specific activity):

4. State justification for exceeding the overtime limits. Justification should address considerations and actions taken to minimize potential impacts on safety-related activities (i.e., rescheduling of task, assignment of alternate employee to task, etc.) and reasoning for the determination that a significant reduction in effectiveness of the personnel involved will not result. This analysis should include considerations such as the total amount of time worked/anticipated, break periods taken/planned, type of activity to be performed, etc. for personnel to ensure that fatigue is not/will not be a factor Prepared by Print Name Date Time Ext..

Prepared by Signature THE ABOVE ACTIVITY IS CONSIDERED AN UNUSUAL CIRCUMSTANCE AND WARRANTS EXCEEDING THE OVERTIME RESTRICTIONS.

Approved by Print Name/Position Date Approved by Site Vice President/Plant Manager/Authorized Designee Signature FOR ADDITIONAL SPACE, USE REVERSE SIDE OF THIS FORM.

Distrib'uted to: Plant Manager's Office Originator (Employees Section Manager)

NOTE 1 Requires Site Vice President/Plant Manager approval, cannot be delegated.

TVA 40551 [11-1999] Page 1 of 1 SPP 1 5-1 [11-15-19991

TVAN STANDARD SPP-1.5 PROGRAMS AND OVERTIME RESTRICTIONS (REGULATORY) Date 11-15-99 PROCESSES Page of 10 9

OVERTIME LIMITATION EXCEPTION REPORT FOR EXTENDED SHUTDOWN PERIODS Page 1 of 2 The following attached list of employees are authorized to work overtime in excess of the overtime limits specified in paragraphs 3.B.1 and 3.1.2 of SPP-1.5. This report must be maintained and available for NRC review.

1. Specify specific reason for cause of overtime (i.e., another employee on S/L, unexpected job, etc.).

2. Specify requirement to be exceeded: El 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months continuous (*NOTE 1) [] 8-hour work break

[] 16 hrs. in 24 E] 24 hrs. in 48 El 72 hrs. in 7-day period

3. Specify exact work to be performed and brief description (include procedure number, workplan number, work request number, or support of other specific activity):

4. State justification for exceeding the overtime limits. Justification should address considerations and actions taken to minimize potential impacts on safety-related activities (ie., rescheduling of task, assignment of alternate employee to task, etc.) and reasoning for the determination that a significant reduction in effectiveness of the personnel involved will not result. This analysis should include considerations such as the total amount of time worked/anticipated, break periods taken/planned, type of activity to be performed, etc. for personnel to ensure that fatigue is not/will not be a factor.

Prepared by Print Name Prepared by Date Time Ext.

Signature THE ABOVE ACTIVITY IS CONSIDERED AN UNUSUAL CIRCUMSTANCE AND WARRANTS EXCEEDING THE OVERTIME RESTRICTIONS.

Approved by Print Name/Position Approved by Date Site Vice President/Plant Manager/Authorized Designee Signature FOR ADDITIONAL SPACE, USE REVERSE SIDE OF THIS FORM.

Distributed to: Plant Manager's Office Originator (Employees Section Manager)

NOTE 1 Requires Site Vice President/Plant Manager approval (can be delegated to Outage Manager or Assistant Plant Manager during outages).

SPP 1 5-2 (11-15-1999]

TVA 40552 [11-19991 Page 1 of 2

TVAN STANDARD SPP-1.5 PROGRAMS AND OVERTIME RESTRICTIONS (REGULATORY) Date 11-15-99 PROCESSES Page 10 of 10 OVERTIME LIMITATION EXCEPTION REPORT FOR EXTENDED SHUTDOWN PERIODS Page 2 of 2 Name SSN Organization Hours Exceeding Requirements Date # Hours Time Limit Will Be Exceeded

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Page 2 of 2 SPP 1.5-2 [11-15-1999]

TVA 40552 [11-1999]

Handout to Applicant It is 3:00am on January 1. Following a declaration of an unusual event, several people are responding to the event. You are the shift manager, security has informed you that they have a reasonable belief that an NRC resident inspector, may have recently used alcohol and may be unfit for duty. In addition a deputy sherif, TVA pipe fitter and a contract pipe fitter that are responding onsite to the NOUE have stated that they consumed alcohol at midnight although the three of them appeared to be unimpaired. All the above individual have unescorted access (badged) with the exception of the deputy sheriff.

In reference to allowing these individual onsite, what action are required?

NRC Resident Inspector Deputy Sherrif "TVA Pipe Fitter Contract Pipe Fitter

Al.la SRO ONLY It is 3:00am on January 1. Following a declaration of an unusual event, several people are responding to the event. You are the shift manager, security has informed you that they have a reasonable belief that an NRC resident inspector, may have recently used alcohol and may be unfit for duty. In addition a deputy sherif, TVA pipe fitter and a contract pipe fitter that are responding onsite to the NOUE have stated that they con sumed alcohol at midnight although the three of them appeared to be unimpaired. All the above individual have unescorted access (badged) with the exception of the deputy sheriff.

In reference to allowing these individual onsite, what action are required?

Solution:

K/A 2.1.6 CFR43.5 (2.1/4.3) Ability to supervise and assume a management role during plant transients and upset conditions. SRO ONLY Reference allowed.

NRC employee must be granted escorted access, the regional administrator must be called and the NRC Operations Center must be notified. (2.0 B. TVA may not deny access but shall escort the individual. In any instance of this occurrence, the NRC Region IIAdministrator must be notified immediately by telephone. During other than normal working hours, the NRC Operations Center must be notified)

Deputy Sherif (This SPP does not apply to NRC employees, law enforcement personnel, or non-TVA offsite emergency response personnel while responding onsite.) Law enforcement while not covered by this SPP, should not be allowed to enter the protected area. There are no statutory requirements to allow local law enforcement onsite. It would be permissible to escort these individuals if their presence were actually necessary.

TVA employee - must have saliva test administered. (*SPP-1.2, Fitness for Duty, section 3.14, Call-in for Unscheduled Work, 3.14.1 .A.4, if the answer to the alcohol consumption question -is "yes" then Nuclear Security on site should be notified and be requested to administer a saliva test to the -employee. This test must be administered as soon as the person arrives on site.)

Contract Employee - must have saliva test administered or access denied. Typically, these contractors, if badged, will participate in the TVA FFD program, and the requirements are the same as for a TVA employee.

Tennessee TITLE SPP-1.2 Valley Authority Rev. 4 Page 1 of 30 TVAN STANDARD FITNESS FOR DUTY Quality Related [I Yes S No PROGRAMS AND PORC Required C] Yes Z No.

PROCESSES 100FRS0.59 Review C3 Yes Z No Effective Date 11/30/99 RESPONSIBLE PEER TEAM: B&WP Organization APPROVALS Chris Kelly 11/19/99 Primary Sponsor Date For Nuclear Assurance Sponsored SPPs N/A General Manager,NA Date Karl W. Singer 11/24/99 Senior Vice President,Nuclear Operations Date

Site-specific changes are approved by Site Sponsor and Site Vice President (see PCF)

SPP-2 1-1 [12-01-971 TVA 40480 (12-97] Page I of 1

TVAN STANDARD SPP-11.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 2 of 30 REVISION LOG Revision Effective Pages Description Number Date Affected of Revision 0 2-18-97 All Replacing STD-1.6.

1 10-24-97 All General revision to update and clarify FFD policy and requirements. Changed the definition of Emergency Response Center to incorporate wording found in 10CFR26.2.

2 8-5-98 2, 3, 5, 6, Deleted references to Health Services due to organization 10-13, changes. Shifted and clarified FFD Program responsibilities 15-18,19 *r3, due to organization changes. Minor editorial changes and FFD 20, 21, 23 Program clarifications. Added 10CFR26.27(d) information 24-27 regarding NRC employees. Added information regarding TVA's contract Employee Assistance Program. Shifted and clarified responsibilities for non-QA FFD Program records due to organization changes.

02-12-99 All General revision.

4 11/30/99 2,3, 11, 12, Added Form SPP-1.2-1, "Call-InForm for Unscheduled Work" 14, 16,17, that may be utilized to document unscheduled call-ins as 19, 21-24, corrective action for SQN PER 99-007109-000. Deleted 26, 27, 30 reference to hand held breathalyzers. Clarified requirements for alcohol and drug testing. For emphasis, added information contained in Section 3.7 "Penalties for Violation(s) of the FFD Program" table, regarding refusal to fully cooperate in the testing process, to Section 3.8 "Resulting Actions for Other Violations of this Procedure (or SPP)".Clarified appeals.

Minor/editorial changes.

"TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 3 of 30 TABLE OF CONTENTS Section Title Page Revision Log......................................................................................................................... .. ............... 2 Table of Contents ............................................................. 3 1.0 PURPOSE 4 2.0 SCO PE 4.....................

4 3.0 INSTRUCTIO NS 5......................

5 3.1 Responsibilities 5.....................

5 3.2 Standards of Conduct 6 3.3 Alcohol and Drug Testing 1.................................

1.1 ....

3 .4 A p p e a ls ...............................

................................. 1.7 ......

3 .5 T ra in in g ................................................................................................................... 18 ......

3.6 Em ployee Assistance Program ................................................................................ 19..

3.7 Penalties for Violation(s) of the FFD Program ........................................................ 20.

3.8 Resulting Actions for other Violations of this Procedure (or SPP) ............................. 21.

3.9 Fitness for Duty Requirem ents for Unescorted Access ............................................. 21 3.10 Transfer of Fitness for Duty Certification ............................... .............................. 21..

3.11 Em ergency Response Center ........................... .............................................. 21...

2..

3.12 Fitness for Duty Program Integrity .......................... ....... .................................... 22..

3.13 Contractor/Vendor Program s ........ 2.................................

23...

3.14 Call-in for Unscheduled W ork .................................................................................. 23...

3.15 Contracts and Purchasing ........................................................................................ 24...

3 .1 6 A u d its ..................................................................................................................... 2 4 ......

3 .1 7 R e p o rtin g ................................................................................................................ 2 4 .....

4.0 RECORDS ............................................................................................................ 25 .....

4.1 QA Records ............................................................................................................ 25 .....

42 Non-QA Records ..................................................................................................... 25 ....

5.0 DEFINITIO NS ................................................................................................... 27 ...

APPENDIXES Appendix A: Contracts/Purchasing FFD Requirem ents ........................................... 29 FORMS SPP-1.2-1 Call-In Form for Unscheduled W ork .................... .................................. 3Q

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 4 of 30 1.0 PURPOSE The Fitness For Duty (FFD) Program was established to ensure that each employee has a safe, drug-free workplace and to provide reasonable assurance that personnel supporting the TVA Nuclear (TVAN) program will perform their tasks in a reliable and trustworthy manner. In addition, the FFD Program provides assurance that employees are not under the influence of any legal or illegal substance or mentally or physically impaired frorn any cause which in any way could adversely affect their ability to safely and competently perform their duties. The program is administered in accordance with Regulation 10 CFR Part 26 issued by the Nuclear Regulatory Commission (NRC).

2.0 SCOPE The requirements of this SPP apply to:

A. All TVAN employees B. TVA employees located at TVAN sites or projects C. Contractor and vendor employees located at TVAN work locations D. All persons who have unescorted access at TVA nuclear plants E. Persons required to report to the emergency response centers F. Those who by the nature of their jobs, as determined by the Chief Nuclear Officer and Executive Vice President, TVAN, could affect the safe operation of TVA's nuclear plants G. NRC contractor employees Exemptions:

A. This SPP does not apply to NRC employees, law enforcement personnel, or non-TVA offsite emergency response personnel while responding onsite.

B. If TVA has a reasonable belief that a NRC employee may be under the influence of any substance, or otherwise unfit for duty, TVA may not deny access but shall escort the individual. In any instance of this occurrence, the NRC Region II Administrator must be notified immediately by telephone. During other than normal working hours, the NRC Operations Center must be notified.

C. Short-term contractors who do not require entry to the protected area are exempt from Subsections 3.3.1(A), 3.3.1(C), and 3.5.

D. Bellefonte Nuclear Plant (BLN) is exempt from Subsections 3.3.1(C.2.b.) and 3.5. Only those BLN employees who are required to report to the Emergency Response Center, BLN employees maintaining unescorted access at another TVAN site, or BLN supervisors/managers responsible for performing continual behavioral observation are required to meet the requirements of Section 3.5.

E. Additional exemptions which do not affect regulatory requirements and commitments may be granted on a case-by-case basis by the Manager, Nuclear Security.

WVAN STANDARD SPP-11.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 5 of 30 3.0 INSTRUCTIONS 3.1 Responsibilities 3.1.1 The Corporate Nuclear Security organization is responsible for:

A. Regulatory interpretations and decisions B. Policy Development C. Overall direction of the program administration D. Organizational interfaces E. Management of the random testing program F. Procedures coordination G. Reporting requirements H. Monitoring of FFD training

1. Disposition of positive test results J. Consistent implementation K. Consulting with experts concerning drugs of abuse in the Tennessee Valley L. Maintaining contracts with primary and backup Substance Abuse and Mental Health Services Administration (SAMHSA) certified laboratories.

3.1.2 The Site Medical Office/Corporate Nuclear Security FFD Staff is responsible for:

A. Notifying supervisors/designees regarding employees selected for random testing B. Specimen collection/chain of custody C. Training of collectors D. Records from breath analysis equipment (maintenance/calibration/repair)

E. Review of test results 3.1.3 The Health & Safety Organization is responsible for maintaining Employee Assistance Program (EAP) contract(s)

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 6 of 30 3.2 Standards of Conduct 3.2.1 General All persons under the scope of this SPP shall ensure that they are fit to perform their duties in a reliable and trustworthy manner. It is their duty to keep alcohol and illegal drugs off TVAN property and immediately report persons on TVAN property who may not be fit for duty to the appropriate management/supervisor or Nuclear Security.

A. All persons under the scope of this SPP are responsible for reporting to the Site Medical Office/Corporate Nuclear Security FFD Staff and to their immediate supervisor any health problems which may impair their ability to safely and competently perform work or impair fitness for duty. Examples include:

1. Medications (prescriptions and over-the-counter)

2. Mental or emotional problems

3. Personal problems

4. Fatigue or stress

5. Physical illness or condition B. If there are indications of drug or alcohol abuse or indications that an individual is unable to safely and competently perform his/her duties, the individual's management supervisor is responsible for:

1. Informing the employee of the assistance available through the EAP, and

2. Referring the person to the Site Medical Office/Corporate Nuclear Security FFD Staff for a fitness for duty evaluation in accordance with Subsection 3.3.1.E.

3. When applicable, requesting a for-cause alcohol and drug test which must be approved by the Vice President, General Manager or his/her designee in accordance with Subsection 3.3.1 .D.

3.2.2 Illegal Druas and Alcohol All employees and workers under the scope of this procedure shall not possess, use, or sell illegal drugs on or off of TVA property.

All employees and workers under the scope of this procedure shall not possess, use, or sell alcohol on any TVA property.

WVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 7 of 30 All employees and workers are prohibited from reporting to a TVAN work location under the influence of illegal drugs or alcohol at or above the cutoff levels established in 10 CFR 26, Appendix A, or more stringent TVAN cutoff levels as described in Subsection 3.3.2.C.

3.2.3 Offsite Alcohol Consumption A. Off-site consumption of alcohol is prohibited under the following conditions;

1. If a person leaves the work location with the intent of returning that day or shift.

2. If the person is attending an off-site business meeting.

3. If a person is scheduled to report for work within five hours.

NOTE Excessive consumption of alcohol before the five hour abstinence period can cause a positive breath test.

4. If a TVA vehicle will be driven following consumption of the alcohol.

B. The consumption of alcohol is not prohibited after completing official business, if done in accordance with applicable local laws and the guidelines above.

3.2.4 Handling of Drugs and Illegal Substances Found at Nuclear Plants All employees, employee vehicles, personal belongings, offices, lockers and company property are subject to search. Refusal to submit to a search will subject the employee to immediate disciplinary action. To provide a means to detect or deter drug activity on-site, each TVAN station may use canines to facilitate searches.

A. Discovery of Suspected Controlled Substance or Illegal Drugs - OUTSIDE THE PROTECTED AREA (PA)

1. Security Supervisor will:

Immediately take positive possession and control of the substance using caution not to spill or contaminate the substance.

Take appropriate actions to secure the general area.

Notify the Site Security Manager (SSM)/Shift Coordinator

Evaluate the overall situation and take whatever action is required to contain the situation and minimize its impact.

Initiate a Chain of Custody (COC) form. (Ask the Site Medical Office/Collection Facility for assistance with COC)

2. Site Medical Office/Collection Facility will:

0 Package the substance for shipment to laboratory.

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 8 of 30

Lock the packaged substance in the Medical Office/Collection Facility refrigerator until forwarding to laboratory for analysis.

Separately package excess or remaining amounts of the substance with another COC form.

NOTE Excess amounts of the substance may be maintained in the Medical Office/Collection Facility refrigerator or by Security in an evidence safe until laboratory analysis is complete. If results are positive, the remaining substance may be turned over to OIG, LLEA, other authorities, as appropriate. If results are negative, the remaining substance may be returned to owner, if known, or discarded.

3. SSM or Designee will:

Upon receiving information that a suspected substance has been found and confirming it was outside the PA, make the following contacts, explaining that this is not a reportable event.

Site Management (Site VP, Plant Manager, Site Human Resource Manager)

Manager, Nuclear Security OIG (determine if OIG will initiate investigation)

Informally brief Resident Inspectors and Region II Inspectors of investigation, explaining that this is not a reportable event--awaiting lab results.

Inform contacts that the substance will immediately be sent to the contract laboratory for analysis or to the lab of OIG's choice, as appropriate.

Inform contacts of laboratory analysis results immediately upon receipt.

4. Manager, Nuclear Security, or Designee will:

Make corresponding contacts to Nuclear Corporate Management.

Notify the SSM of contract laboratory analysis results immediately upon receipt.

If the results are negative, notify management and the NRC of the results and refer to OIG for determining if a follow-up investigation is necessary.

If the results are positive, notify management and the NRC of the results, this is not a reportable event, and refer to OIG for a follow-up investigation. Keep management and the NRC informed of the status of the investigation.

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 9 of 30 B. Discovery of Suspected Controlled Substance or Illegal Drugs - INSIDE THE PROTECTED AREA (PA)

1. Security Supervisor will:

Immediately take positive possession and control of the substance using caution not to spill or contaminate the substance.

Take appropriate actions to secure the general area.

Notify the SSM/Shift Coordinator.

Evaluate the overall situation and take whatever action is required to contain the situation and minimize its impact.

Initiate a Chain of Custody (COC) form. (Ask the Site Medical Office/Collection Facility for assistance with COC)

2. Site Medical Office/Collection Facility will:

Package the substance for shipment to laboratory.

Lock the packaged substance in the Medical Office/Collection Facility refrigerator until forwarding to laboratory for analysis.

Separately package excess or remaining amounts of the substance with another COC form.

NOTE Excess amounts of the substance may be maintained in the Medical Office/Collection Facility refrigerator or by Security in an evidence safe until laboratory analysis is complete. If results are positive, the remaining substance may be turned over to OIG, LLEA, other authorities, as appropriate. If results are negative, the remaining substance may be returned to owner, if known, or discarded.

3. SSM or Designee will:

Upon receiving information that a suspected substance has been found and confirming that it was inside the PA, make the following contacts;

- Site Management (Site VP, Plant Manager, Site Human Resource Manager)

- Manager, Nuclear Security

- OIG (determine if OIG will initiate investigation)

. Resident Inspectors and Region II Inspectors "courtesy call"

Inform all contacts that the substance will immediately be sent to the contract laboratory for analysis or to the laboratory of OIG's choice, as appropriate.

NOTE The substance cannot be confirmed as an illegal drug without laboratory analysis.

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 10 of 30 Inform all contacts that if the laboratory confirms the substance, this will be classified as a significant FFD event under requirements of 10CFR26.73(a) and will be reported to the NRC Operations Center by telephone within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of the confirmation.

Inform all contacts of laboratory analysis results immediately upon receipt.

4. Manager, Nuclear Security, or Designee will:

Make corresponding contacts to Nuclear Corporate Management. Advising that the event is under investigation and will be reportable to the NRC if the laboratory confirms that the suspected substance is an illegal drug.

Assist in investigation of incident as appropriate.

Upon receipt of the laboratory test results, the Manager, Nuclear Security will make the following contacts if negative:

Inform the SSM of contract laboratory analysis results immediately upon receipt. The SSM or designee will brief Site Management and the NRC that the laboratory test was negative and that the event is not reportable. The SSM will notify the OIG if necessary and request investigative assistance if appropriate.

Inform Nuclear Corporate Management that the event is not reportable.

Assist in investigation of incident if requested.

Upon receipt of the laboratory test results, the Manager, Nuclear Security will make the following contacts if positive:

Inform the SSM of contract laboratory analysis results immediately upon receipt. The SSM or designee will brief Site Management and the NRC that the laboratory test was positive and that the event is reportable. The SSM will notify the OIG and request investigative assistance.

Inform Nuclear Corporate Management that the event is reportable.

Contact Corporate Licensing and arrange to complete 24-hour notification to the NRC operations center within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of receipt of the laboratory results.

Assist in investigation of incident if requested.

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 11 of 30 3.3 Alcohol and Drua Testing 3.3.1 General Alcohol and Drug testing shall be conducted in accordance with I OCFR26 and the TVAN FF0 Procedure Manual.

A. EmploymentJTransfer Alcohol and Drug Testing This type of initial testing applies to:

1. Outside applicants for a WAN position.

2. TVA employees transferring to a TVAN position.

3. Contractors and vendors applying for WVAN work.

Employment/transfer testing is not required under the following conditions:

1. When a person has been tested within the previous 60 days by TVAN, another nuclear licensee, or a WVAN-approved FFD testing program.

2. When a person has been subject to random alcohol and drug testing in TVAN's, another nuclear licensee's, or TVAN-approved FFD testing program within the last 30 days. The person must have completed an initial alcohol and drug test.

Individuals who have had a confirmed positive alcohol or drug test or have refused to be tested under a federal or state regulated FFD/alcohol and drug testing program within the past three (3) years will not be considered for employment.

B. Pre-access Alcohol and Drug Testing (Testing Prior to Granting of Unescorted Access)

Testing must be completed by TVAN prior to granting of unescorted access except in the following situations:

1. When a person has been tested within the previous 60 days by TVAN, another nuclear licensee, or a TVAN-approved FFD testing program.

2. When a person has been subject to random testing in TVAN's, another nuclear licensee's, or a TVAN-approved FFD testing program within the past 30 days. The person must have completed an initial alcohol and drug test.

C. Random Alcohol and Drug Testing

1. Random alcohol and drug testing is applicable to:

a. Those with unescorted access.

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 12 of 30

b. Employees who report for emergency response centers.

c. Those with an official station of a nuclear plant or project.

d. TVAN employees and contractors (TVAN employees or contractors with clerical-related salary administration plans may be excluded unless other criteria in this section apply).

e. Those who remain in the random program in order to maintain eligibility for an unescorted access badge.

f. Those responsible for administering the FFD program (Program Integrity).

g. NRC contractor employees.

2. Random testing is conducted at an annual rate equal to at least 50 percent of the population. Each person has an equal chance of being selected for testing every day that testing is conducted, from all shifts. Random testing is conducted:

a. Various times of the day

b. Several days of the week

c. On weekends and holidays

3. Notification will be made by the Site Medical Office/Corporate Nuclear Security FFD Staff through the individual's supervisor or designee. The person selected is responsible for reporting promptly (without delay) to the medical/collection facility.

Supervisors/designees are responsible for:

a. Notifying individuals of their selection. Some flexibility exists regarding notifying the individual of his/her selection if the selected individual is involved in critical activities (e.g., inside containment or involved in Technical Specification testing/action, etc.). Delayed notification must be coordinated with and approved by the appropriate Site Medical Office/Corporate Nuclear Security FFD Staff; NOTE No advance notification/warning will be given. Notification to report shall not be left on answering machines, voice mail, notes on desks, etc.

b. Ensuring that the selected individual reports promptly (without delay) to the medical/collection facility;

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 13 of 30

c. Ensuring that knowledge of the individual's selection is kept private and restricted to the absolute minimum number of appropriate persons necessary to facilitate prompt testing.

D. For-Cause Alcohol and Drug Testing All for-cause testing must be approved by the Vice President, General Manager or his/her designee: Rationale for for-cause testing must be verified to be in compliance with this procedure's requirements and must be thoroughly documented by the appropriate supervisor/manager. In addition, all for-cause testing should be reported to the FFD Manager within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months (Monday - Friday) of test completion.

1. For-cause testing shall be conducted when there is reasonable suspicion that the worker's behavior involved a failure of performance that contributed to:

a. Radiation releases or exposure of radioactivity in excess of regulatory limits.

b. Actual or potential substantial degradations of the level of safety of the plant.

c. An accident involving serious injury or death or significant damage to property or equipment.

d. A 'near miss" which could have resulted in serious injury, death, or significant damage to property or equipment.

2. For-cause testing may also be conducted under the following conditions:

a. When aberrant behavior is exhibited.

b. When a person is reasonably suspected of:

(1) Recent use of controlled substance(s) or alcohol.

(2) Engaged in illegal drug activities.

(3) Possession of illegal drugs or alcohol.

c. After receiving credible information or credible allegations of drug/alcohol abuse against:

(1) An individual (2) A work unit determined to be a critical nuclear employment area when:

The number or proportion of positive results is found to be significant, and

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 14 of 30 When activities are confirmed by testing or otherwise (for example, Inspector General's investigations) for a number of employees.

d. As part of an investigation involving an accident (vehicle or personal) in which safety precautions were violated or unusually careless acts were performed.

e. When an employee's work record indicates a history of accidents or "near misses" or accidents which are the fault of the employee.

f. When an excessively high accident rate is observed in a particular location.

E. Follow-up Alcohol and Drug Testing Follow-up testing is required for TVA employees for whom unescorted access has been reinstated and who have been returned to work following a confirmed positive test result.

Employees in the follow-up testing are subject to the following:

1. Follow-up testing on a random basis of at least once every month for the first four months; and at least once every 3 months for the next 2 years and eight months.

2. Random testing program.

F. Witnessed Collections Witnesses must be of the same gender as the individual providing the specimen and must be trained as a urine drug screen collector or witness.

Program Integrity Clearance is required for witnesses.

Specimen collections may be witnessed if:

1. The individual has presented a urine specimen that falls outside the normal temperature range, or

2. The collector observes an attempt to substitute or adulterate the urine sample, or

3. The individual has previously been determined to have used a substance inappropriately or without medical approval and the particular test is being conducted as a part of a rehabilitation program or on return to service after evaluation and/or treatment for a confirmed positive test result.

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 15 of 30 G. FFD Evaluations FFD Evaluations will be conducted in accordance with the specific working principles and procedures as contained in the TVAN Cormorate Nuclear Security Psychological Screening Manual and the Medical Examiner's Guide.

FFD evaluations are performed when changes in behavior (on or off the job - based upon circumstances) or performance are indicated. These evaluations are also performed on return to work following a positive alcohol or drug test. A FFD Evaluation is requested by the employee's management supervisor or Corporate Nuclear Security. The evaluation consists of medical and psychological evaluations for purposes of establishing eligibility for special nuclear security clearances.

Evaluations for return to work following a positive alcohol or drug test will include an alcohol and drug test. When applicable and when approved by the Vice President, General Manager, or his/her designee, a drug and alcohol test may also be conducted in accordance with Subsection 3.3.1 .D.

3.3.2 Processes and Cut-Off Levels Chemical and alcohol testing will be conducted in accordance with 10CFR26 and the TVAN FFD Procedure Manual.

A. Chemical Testing Process

1. The chemical testing process shall screen for the following drugs of concern:

marijuana

cocaine

opiates

phencyclidine

amphetamines

2. TVAN will utilize a "split" specimen/sample process.

3. TVAN will utilize strict chain-of-custody procedures to ensure the integrity of specimens.

4. TVAN will utilize a Department of Health and Human Services (DHHS) certified laboratory to confirm all positive drug test analyses.

5. TVAN will submit blind performance test specimens which contain known negative and positive quantities of drugs to ensure continued quality control is maintained by the laboratory.

6. An initial screening test will be performed on ALL urine samples for testing, utilizing an immunoassay procedure. The immunoassay screen tests for drugs or drug metabolites, indicating a 'preliminary positive" or negative result.

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 16 of 30

7. Negative specimens will be eliminated from further testing.

8. A "confirmatory test" using gas chromatography/mass spectrometry (GC/MS) will be performed when an initial screening test indicates drugs in a person's urine. GC/MS is a sophisticated analytical technique that accurately identifies substances and amounts.

9. In for-cause, follow-up, witnessed, or return to work tests, the following drugs will also screened for:

methaqualone

methadone

benzodiazepines

barbiturates

propoxyphene

10. A physician designated as the Medical Review Officer (MRO) will interpret and evaluate "analytical" confirmed positive test results from the laboratory together with the individual's medical history and other relevant biomedical information. It is important to note the following:

Hemp food products, such as "Seedy Sweeties" or "Hemp Liquid Gold," may cause a positive test for marijuana:

however, consumption of these products is not a legitimate medical explanation for a positive drug test result.

Coca leaf teas, such as "Health Inca Tea," can cause a positive cocaine drug test result. This type of tea is now illegal and will not be considered a valid explanation for a positive drug test result.

Although some states allow for the medicinal use of marijuana based on a physician recommendation, a physician recommendation is not considered a legitimate explanation for a positive marijuana test result under federal drug testing programs.

11. If there is no information to suggest a legitimate reason for the presence of the drug in the individual's urine, the MRO shall declare the result confirmed positive.

12. For MRO-confirmed positives, at the tested individual's request, the original testing laboratory will forward the split specimen to another TVAN approved DHHS certified laboratory for analysis. A MRO will review the results of split specimen analyses to facilitate appropriate disposition.

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 17 of 30 B. Alcohol Analysis Process

1. Breath samples will be provided for alcohol analysis.

2. Individuals being tested will provide a minimum of two samples.

Breath-alcohol test results will not be considered accurate unless each breath measurement is within plus or minus 10% of the average of all the measurements.

3. In accordance with 10CFR26, a breath alcohol content indicating a blood alcohol concentration of 0.04% or greater shall be considered a positive test result.

4. If the individual being tested disputes the results of the breath alcohol analysis, he/she may request the test to be confirmed by using gas chromatography analysis of his/her blood.

NOTE Failure of the individual to request the blood test within 15 minutes of the confirmed positive breath alcohol test will constitute acceptance of the breath alcohol results. The individual will remain in the medical/collection facility between breath alcohol and blood testing.

C. Cut-off Levels TVAN will use preliminary initial cut-off levels and confirmatory test cut-off levels for the above substances as described in 10CFR26, Appendix A, Section 2.7, with the following exceptions, which are more stringent:

1. The initial test cut-off level for marijuana metabolites is 50 ng/ml and the confirmatory test cut-off level is 15 ng/ml. In addition, if the creatinine level for a specimen is below 20 mg/dl and the marijuana is negative at a cut-off level of 50 ng/mi, the contract laboratory will test the specimen for marijuana using a 20 ng/ml cut-off. If the specimen is positive on the initial screen at or above 20 ng/ml and up to 50 nglml, the confirmation test will be at the limit of quantitation - which the GC/MS technology supports.

2. Alcohol test results between 0.02 and 0.039 BAC will be reviewed for appropriate action - see Subsection 3.7 (Table)

- Penalties for Violation(s) of the FFD Program.

3.4 Appeals An opportunity to appeal the confirmed positive test result, subversion or refusal to fully cooperate in the testing process is provided to any current TVA employee or contractor/vendor.

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 18 of 30 3.5 Training 3.5.1 General FFD Program information as required by 10CFR26 and Behaviorar Observation Program information and techniques as required by 10CFR26 and 10CFR73.56 "Personnel Access Authorization Requirements for Nuclear Power Plants," will be included in FFD Training.

All persons under the scope of this procedure shall be subject to the training requirements of this section. This is regardless of whether or not the person is subject to the random alcohol and drug testing portions of the program.

Training shall be administered under the policy and procedures established by TVAN Training.

Medical Review Officers and psychologists are normally not required to take Fitness for Duty Training because of the nature of their training, education, and experience.

A. Completion of Training FFD training MUST be completed prior to the granting of unescorted access, prior to assignment to an Emergency Response Center or within 90 days of assignment to supervisory duties.

For all other employees, it must be taken within four months of assignment to TVAN.

B. Expiration of Training Training expires annually at the end of the quarter in which it comes due.

If training expires one or more of the following actions will normally occur:

1. Unescorted access is promptly suspended;

2. The person will be restricted from Emergency Response Center participation.

3. Denial of access to a site or TVAN work location and placement in a TVAN non-work status until the training has been completed.

NOTE Actions 1 and 2 above occur automatically within applicable computer programs.

Employees who do not have unescorted access and are not tasked with emergency center response who have valid reasons for failing to complete required FFD training within the specified quarter may preclude Action 3.

placement in a TVAN non-work status, if:

- The responsible supervisor documents the valid reason(s) for the employee's failure to complete the required training. This documentation should be placed in the employee's personnel file with copies forwarded

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 19 of 30 to the applicable Human Resources Office and to the Nuclear Security FFD Program Manager.

- The responsible supervisor ensures the employee completes the required training immediately upon return to work.

Valid reasons for failure to complete required training within the-specified quarter include extended medical/sick leaveextended A/L due to hardship; temporary assignment to Institute of Nuclear Power (INPO) or to another utility.

Supervisors should encourage employees not to schedule required training near quarter ending. Taking scheduled annual leave the last week of the quarter is not a valid reason for failing to complete required training.

Upon successful completion of the course as determined by WVAN training policy, the person may be returned to work, and activities in actions (1) and (2) above may be reinstated.

3.6 Employee Assistance Proqram 3.6.1 General TVA has a contract Employee Assistance Program (EAP) which provides assistance to TVA employees experiencing substance abuse, financial, marital, or other similar problems. Confidential assistance to employees is provided consistent with applicable laws and requirements.

A. The EAP offers the following for TVA employees and their families with problems that could adversely affect performance of job duties:

1. Assessment

2. Short-term counseling

3. Referral services

4. Treatment monitoring B. The EAP provides TVA employees with confidential access to trained counselors. Confidentiality is assured except in cases where a person's condition constitutes a hazard to himself/herself or others, or could adversely affect the safe operation of TVAN's facilities. In these cases, the EAP shall contact TVA's Manager, Clinical Services, Health & Safety, who in turn will inform TVAN Personnel Security, without identifying the person as an alcohol or drug treatment patient.

TVAN STANDARD SPP-11.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 20 of 30 3.7 Penalties for Violation(s) of the FFD Proaram TABLE OF PENALTIES ISSUE TVAN EMPLOYEE OTHER TVA EMPLOYEE CONTRACTOR WORKER Positive Alcohol & Druo Test Applicant/Badging Employment Denied Badging-Return to TVA organization Restricted from TVAN work Pre-Access (Restricted for 3 years minimum) (Restricted for 3 years minimum) (Restricted 3 years minimum)

A&D Test Random 1st Positive-Minimum Return to TVA organization for Restricted from TVAN work A&D Test 14-day suspension & EAP action (3-year minimum restriction (3-year minimum restriction (Return subject to conditions) from TVAN) from TVAN)

Follow-up; For-Cause; Termination Restricted from TVAN work Permanent restriction from 2nd Random (Permanent TVAN (Permanent TVAN restriction) TVAN work activities A&D Test; restriction)

Subversion Use, Sell, Possession (TVAN will support criminal prosecution by law enforcement agencies for all USP violations) of Illegal Drugs &

Alcohol Onsite Termination Return to TViA organization Immediate removal from TVAN (Permanent TVAN (Permanent TVAN restriction; (Permanent TVAN restriction; Restriction; 5 year restriction nuclear 5 year restriction 5 year restriction industry) nuclear industry) nuclear industry)

Offsite Disciplinary action Return to TV A organization Restriction from TVAN work (Alcohol Excluded) up to and including (Minimum 5 rear restriction) (Minimum 5 year restriction) termination Repeat violations will result in a permanent work restriction in the nuclear industry.

0 02-0.039% BAC Referral to EAP Referral to EAP Referral to Contractor for Random Alcohol Test (Subject to disciplinary (Subject to be returned to TVA action (Subject to restriction actions & FFD Evaluation) Removed organization) Removed from work for to TVAN) Removed from work from work for remainder of shift. remainder of shift. for remainder of shift 0 02-0,039% BAC Employment Denied Pre-employment/ (Restricted for 3 years minimum) Badging-Return to TVA organization Restricted from TVAN work Badging Alcohol Test minimum) (Restricted for 3 years minimum) (Restricted 3 years minimum.)

"Refusal to fully cooperate in the testing process including refusal to provide a specimen or deliberately attempting to evade the detection of substance abuse (subversion) will result in for-cause termination and permanent restriction from TVAN work.

Any positive alcohol and drug test will result in immediate denial of Unescorted Nuclear Plant access or other security clearances and participati in the Emergency Response Program, Employees testing random positive for the first time must complete EAP assessment and initiate any rehabilitation program deemed appropriate prior to being considered for reinstatement. Restoration of Unescorted Nuclear Plant Access or othe security clearances and Emergency Response will be determined by Personnel Security following reapproval of medical and psychological eligibility for special security clearances.

Excludes temporary employees - temporary employees will be terminated.

"-In instances where entire work units/groups are tested for-cause due to circumstances outlined in Subsection 3.3.1 D those testing positive v as a minimum, receive a 14-day suspension and EAP with return subject to conditions.

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 21 of 30 3.8 Resulting Actions for other Violations of this Procedure (or SPP)

Management actions for any violation of this procedure other than confirmed positive tests shall be based on all the circumstances of the particular violation and shall be consistent with the purpose of this procedure. Resignations prior to removal for violation of WVAN FFD policy concerning drugs must be recorded as removal for-cause. Refusal td fully cooperate in the testing process, including refusal to provide a specimen or deliberately attempting to evade the detection of substance abuse (e.g., subversion by substituting or adulterating a urine specimen) will result in for-cause termination and permanent restriction from TVAN work.

3.9 Fitness for Duty Requirements for Unescorted Access For an individual to obtain and maintain authorization for unescorted access:

A. Complete a suitable inquiry into fitness for duty history prior to or within 180 days following the granting of unescorted access.

B. Successfully meet alcohol and drug test requirements.

C. Psychological approval for unescorted access to nuclear plants must be obtained.

D. Fitness-for-Duty training must be completed.

3.10 Transfer of Fitness for Duty Certification An employee of any contractor, vendor, or industry group whose FFD Program has been approved by WVAN to Subsection 3.13 of this SPP, or any employee of any nuclear utility licensee currently subject to the 10 CFR Part 26 FFD of that licensee, may be approved for unescorted access or emergency response duties without additional drug testing, training, or suitable inquiry being performed.

This Subsection shall not apply in cases of transfer of employment to TVA or to a person in a follow-up testing program.

These persons shall be subject to the TVAN FFD program, including random testing.

3.11 Emeraency Response Center All persons designated by name or position to respond to an Emergency Response Center are subject to a suitable inquiry and alcohol and drug test prior to being assigned.Should adverse information be developed prior to or during the assignment, the person's approval to participate in emergency center operations may be denied.

A. The Manager of Radiological Emergency Preparedness shall identify to Personnel Security those persons required to respond to emergency centers.

B. Personnel Security shall conduct the appropriate reviews for those individuals requested and approve or deny an individual's participation based on FFD criteria.

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 22 of 30 3.12 Fitness for Duty Program Integrity 3.12.1 Obtaining Proaram Integrity Clearance All persons responsible for administration of drug and alcohol testing program must obtain Program Integrity (PI) Clea'ance prior to assignment. Initial PI will entail successful completion of:

A background investigation; fingerprinting and criminal history check through the Federal Bureau of Investigation; psychological testing and interview (as appropriate); alcohol and drug test with subsequent enrollment in the random drug test population; FFD Training (annually). PI updates will be performed every subsequent three years. Individuals in PI will also be subject to a behavioral observation program designed to assure that they continue to meet the highest standards for honesty and integrity.

Health & Safety, Information Services, Human Resources, and other applicable organizations shall identify to Corporate Nuclear Security those persons within their organizations responsible for administering the testing program. At a minimum, these persons will include:

A. Personnel selecting and notifying individuals to be tested.

a. Personnel collecting specimens and/or conducting the alcohol and drug testing.

C. Personnel with access to the automated drug screening program.

D. Personnel with authorization to modify the automated drug screening program.

E. Personnel trained to witness urine drug screens.

NOTE Normally, couriers contracted for specimen transport will not be required to obtain PI Clearance. Examples include couriers who work for the Postal Service, Federal Express, Airborne Express, United Parcel Service, and pilots and crews of aircraft.

3.12.2 The Manager, Personnel Security, is responsible for the following:

A. Conducting background investigations of personnel responsible for administering the testing program, including those listed above, upon initial assignment and updated every three years thereafter.

B. Requesting a psychological evaluation to be completed upon initial assignment and updated every three years thereafter.

C. Issuing or withdrawing clearance approval to participate in program activities based on investigative, psychological and FFD information.

"TVAN STANDARD SPP-11.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 23 of 30 3.13 Contractor/Vendor Programs All contractors, vendors, or industry groups having personnel who will require unescorted access to protected areas, will be designated by name or position to staff an emergency center, or will be located at TVAN work locations must be subject to a FFD' program which meets the requirements of 10 CFR Part 26.

TVAN may, at its discretion, accept, either whole or in part, FFD programs administered by contractor, vendors, or industry groups. All such programs must meet the minimum requirements of 10 CFR 26.

Corporate Nuclear Security shall be responsible for review and approval of any such programs.

3.14 Call-in for Unscheduled Work 3.14.1 General An employee is expected to not consume alcohol 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months prior to reporting for SCHEDULED work and to report fit and within FFD guidelines. If called for unscheduled work the employee's suitability for work must be determined.

A. The following must be done whenever a worker is being called in for unscheduled work.

1. The caller will ask and will document (on Form SPP-1.2-1 or similar type form) the worker's response to the following two questions.

a. Are you fit to report to work?

b. Have you consumed alcohol within the past 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months ?

If the answer to the last question is yes, and the individual is called in, document how much alcohol was consumed and when.

NOTE Contractor employees will not report if alcohol has been consumed within the past five hours except in rare emergency situations.

2. The worker must advise the caller and the supervisor if he or she believes that he/she is unfit to report for work.

3. The caller will then decide whether or not to have the person report to work.

4. If the answer to the alcohol consumption question is "yes" then Nuclear Security on site should be notified and be requested to administer a saliva test to the employee. This test must be administered as soon as the person arrives on site. The test shall be administered outside the Protected Area.

"WVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 24 of 30

5. If the test results are 0.039 or below, the employee's responsible supervisor shall determine if the employee can be permitted to work. The employee will not be subject to disciplinary action.

6. If the results are 0.040,or above the employee will not be permitted to work. The employee can be paid callout pay. This will NOT be considered a positive test for FFD purposes.

B. Emergency Response Center Personnel Emergency Response Center Personnel who are called by an automated electronic system are responsible for:

1. Advising the center if he/she believes that they are unfit to report for duty.

2. Advising the center on reporting if alcohol has been consumed within the past five hours.

3.15 Contracts and Purchasing The requirements of Appendix A apply to companies which provide services to TVA under Personal Services Contracts, Code III; Consultant Agreements, Code Ill; Loan Agreements, Code Ill; and Cooperative Agreements, Code II and to contracts for purchase of personal property and services other than personal. This Subsection does not apply to state and local contract emergency response personnel responding to an emergency at a TVA nuclear plant site.

3.16 Audits The General Manager of Nuclear Assurance (NA) conducts an annual audit of the TVAN FFD Program as required by 10 CFR Part 26, and in accordance with the TVAN Quality Assurance Plan and NADP-2, "Audits." At the request of Nuclear Security, NA will audit the FFD programs of contractors and vendors.

The audit will use professional support as necessary to ensure the technical aspects of the program are thoroughly reviewed.

TVAN may accept audits of contractors and vendors conducted by other licensees or industry groups. TVAN shall maintain a copy of the audit report to include findings, recommendations and corrective actions.

3.17 Reporting 3.17.1 Semiannual Report Corporate Nuclear Security shall prepare a semiannual report for submittal to the NRC. The report shall include the following:

A. A statistical summary of the testing during the period submitted on the standard form.

B. A summary of the significant FFD events.

WVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 25 of 30 3.17.2 Twenty-Four Hour Reoort A telephonic report will be made by Corporate Nuclear Security to' the NRC Operations Center within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of discovery of any of the following events:

A. Sale, use, or possession of illegal drugs within the protected area.

B. Any of the following acts by persons licensed under 10 CFR Part 55 to operate a power reactor, or by any supervisory personnel with unescorted access to a TVAN nuclear power plant, or supervisory personnel required to report to a TVAN Emergency Response Center in accordance with TVAN emergency plans and procedure.

1. The use, sale or possession of illegal drugs within the protected area.

2. Confirmed positive test results.

3. Use of alcohol within the protected area.

4. A determination of unfitness for scheduled work due to the consumption of alcohol.

5. Any other significant FFD event as determined by Corporate Nuclear Security.

Twenty-four hour reporting is done in accordance with 10 CFR 26.73 rather than 10 CFR 73.71, one hour reporting.

4.0 RECORDS TVA personnel and medical records, including associated FFD Program information, are maintained and protected in accordance with the Privacy Act of 1974, as amended, and 10 CFR Part 26.

4.1 QA Records None.

4.2 Non-QA Records All records pertaining to this program shall be maintained in a secure and confidential area.

A. The Site Nuclear Training Manager is responsible for official records of training attendance and examination results, retained for five years and maintained by Document Control and Records Management.

B. The Manager, Nuclear Security, is responsible for the following records:

1. Reports of Medical Review Officer confirmed positive drug and alcohol tests and management actions retained for at least five years.

2. Disciplinary records in connection with violations of the FFD Program retained for at least five years.

"WVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 26 of 30

3. FFD Program performance data and analyses retained for four years.

4. Background investigation reports including evidence of suitable inquiry retained for five years following termination of the person's access authorization.

5. Employee Release of Information forms

6. Records of persons ineligible for three years or longer for unescorted access or reporting to any TVA emergency response center, retained until termination of the Nuclear Regulatory Commission license for which access or reporting was denied.

7. Audit reports of TVAN-approved contractor, vendor, and industry group FFD Programs when industry group audits are endorsed, or when TVAN performs the audit - retained for three years after the audit.

8. The results of psychological assessments generated after February 28, 1998. These records are retained for at least five years following termination of an individual.

9. Drug and alcohol test results and MRO documentation related to those results generated after March 31, 1998. These records are retained for at least five years.

C. The Manager of Health & Safety is responsible for the following records:

1. Medical examination and evaluation results.

2. The results of psychological assessments generated before March 1, 1998.

3. Drug and alcohol test results and MRO documentation related to those results generated before April 1, 1998. These records are retained for at least five years.

4. Alcohol and drug test information in accordance with 10 CFR Part 26 generated before April 1, 1998.

5. Employee Assistance Program records in accordance with USC Title 42, Section 290dd.

D. The Contract Administration Manager is responsible for the following records:

Written agreements between TVAN and contractors or industry groups which require the contractor or industry group to adhere to TVAN's FFD Program or require contractors or industry groups to implement their own FFD Programs which have been reviewed and approved by TVAN-retained for the life of the contracts.

E. The Site Vice President is responsible for records of unscheduled call-in forms, retained for one year, maintained at the department level.

"WVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 27 of 30 F. The Site Security Manager is responsible for saliva testing results for persons called in for unscheduled work. These records are maintained for one year.

5.0 DEFINITIONS Aberrant Behavior - Behavior deviating from the established norm for an individual.

Blood Alcohol Concentration - (BAC), which can be measured directly from blood or derived from a measure of the concentration of alcohol in a breath specimen, is a measure of the mass of alcohol in a volume of blood such that an individual with 100 mg of alcohol per 100 ml of blood has a BAC of 0.10 percent.

Chain-of-Custody - Procedures to account for the integrity of each specimen by tracking its handling and storage from the point of specimen collection to final disposition of the specimen.

Collection Site - A place designated by TVAN where individuals present themselves for the purpose of providing a specimen of their urine, breath, and/or blood to be analyzed for the presence of drugs or alcohol.

Collection Site Person - A person who instructs and assists individuals at a collection site and who receives and makes an initial examination of the specimen(s) provided by those individuals. A collection site person shall have successfully completed training to carry out this function or shall be a licensed medical professional or technician who is provided instructions for collection under 10CFR26 and certifies completion as required. In any case where: (a) a collection is observed or (b) collection is monitored by non-medical personnel, the collection site person must be a person of the same gender as the donor.

Confirmatory Test - A second analytical procedure to identify the presence of a specific drug or drug metabolite which is independent of the initial screening test and which uses a different technique and chemical principle from that of the initial screening test in order to ensure reliability and accuracy. For determining blood alcohol levels, a "confirmatory test" means a second test using another breath alcohol analysis device. Further confirmation upon demand will be by gas chromatography analysis of blood.

Confirmed Positive Test Result - The result of a confirmatory test that has established the presence of drugs, drug metabolites, or alcohol in a specimen at or above the cut-off level, and that has been deemed positive by the Medical Review Officer after evaluation. A "confirmed positive test" for alcohol may also be obtained as a result of a confirmation of blood alcohol levels with a second breath-analysis without Medical Review Officer evaluation.

Contractor - For the purpose of this procedure (or SPP), any company or individual with which TVA has contracted for work or service to be performed on TVAN property.

Cut-Off Level - The value set for designating a test result as positive.

TVAN STANDARD SPP-11.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 28 of 30 Emergency Response Center - The Technical Support Center (TSC), Operations Support Center (OSC), or Central Emergency Control Center (CECC) at which TVA employees, contractors, or vendors are required to physically report in accordance with the Radiological Emergency Plan and procedures.

Follow-Up Testing - Chemical testing at unannounced intervals to ensure that an employee is maintaining abstinence from the abuse of drugs or alcohol.

HHS - Certified Laboratory - A urine and blood testing laboratory that maintains certification to perform drug testing under the Department of Health and Human Services (HHS) "Mandatory Guidelines for Federal Workplace Drug Testing Program" (53 FR 11970).

Illegal Drugs - Those drugs included in Schedules I through V of the Controlled Substances Act (CSA), but not when used pursuant to a valid prescription or when used as otherwise authorized by law.

Initial or Screening Test - An immunoassay screen for drugs or drug metabolites to eliminate "negative" urine specimens from further consideration or the first breathalyzer test for alcohol.

Medical Review Officer - A licensed physician responsible for determining fitness for duty and receiving laboratory results generated by TVA's drug testing program. The Medical Review Officer has knowledge of substance abuse disorders and has appropriate medical training to interpret and evaluate a person's positive test result together with his or her medical history and any other relevant biomedical information.

Random Test - A system of unannounced drug testing administered in a statistically random manner to a group so that all persons within that group have an equal probability of selection.

Reasonable Suspicion - A suspicion based on specific facts and reasonable inferences from those facts in light of experience or training which indicates that an individual may be using or has recently used alcohol or drugs, or may be in the possession of alcohol or drugs, or may have engaged in illegal drug activities. Reasonable suspicion may be based on reliable statements made by other employees or tips from informants. Actual observation of impaired behavior on the job is not necessary.

Split Sample - A portion of a urine specimen that may be stored by the licensee to be tested in the event of the appeal.

Suitable Inquiry - Best-effort verification of employment history for the past five years, but in no case less than three years, obtained from contacts with previous employers to determine if a person was, in the past, tested positive for illegal drugs, subject to a plan for treating substance abuse, removed from or made ineligible for activities within the scope of 10 CFR Part 26, or denied unescorted access at any other nuclear power plant or other employment in accordance with a fitness for duty policy.

TVAN Work Location - Any TVA nuclear plant site/project and any WVAN work location or facility.

Vendor - For the purpose of this procedure (or SPP), any company or individual not under contract to TVA providing services in the protected area of TVA nuclear plant sites.

"WVAN STANDARD SPP-1i.2 PROGRAMS AND FITNESS FOR DUTY Rev. 4 PROCESSES Page 29 of 30 APPENDIX A Page 1 of I CONTRACTS/PURCHASING FFD REQUIREMENTS 1.0 The Contracts Administration Manager shall ensure that all contracts that supply personnel to work at TVAN work locations require the contractor to:

A. Comply with this FFD SPP.

B. Notify Personnel Security of any contractor employee working on TVA assignments who has violated a fitness for duty policy.

C. Allow authorized representatives of the NRC to inspect, copy, or take away copies of any contractor's records, documents, or reports related to the implementation of TVAN's or the contractor's TVAN approved FFD Program.

2.0 The contract officer shall notify the site plant access whenever a contractor employee becomes a supervisor. He shall also notify Corporate Nuclear Security of any contractor employee working on a TVA assignment who has violated a FFD policy.

3.0 The Contracts Administration Manager shall obtain written approval from Corporate Nuclear Security before allowing any contractor employee who has previously been denied access to or removed from work at any nuclear plant as a result of violations of any FFD program to perform work at TVAN work locations or report to an Emergency Response Center.

TVAN STANDARD SPP-1.2 PROGRAMS AND FITNESS FOR DUTY Date 11-30-1999 PROCESSES Page 30 of 30 CALL-IN FORM FOR UNSCHEDULED WORK Page 1 of I Date:

Duty Person Calling:

Department/Section:

TIME ALCOHOL FIT TIME NEEDED 5 HOURS FOR NAME OF PERSON CALLED TO PRIOR TO DUTY DUTY OFFICIAL COMMENTS CALLED REPORT REPORT (Y/N)

(YIN)

SSPP-1.2, Fitness for Dutysection 3.14, Call-in for Unscheduled Work, 3.14.1 .A.4, if the answer to the alcohol consumption question is "yes" then Nuclear Security on site should be notified and be requested to administer a saliva test to theemployee. This test must be administered as soon as the person arrives on site.

TVA 40774 11-1999] Page I of 1 SPP-1 2-1([11-30-19991

Handout to Applicant Unit 2 is in Mode 1 During a board walkdown, it is discovered that the RCIC flow controller indicates downscale.

Subsequent investigation reveals that the automatic function of the flow controller is failed, Determine the PER Level that should be manual function is still working. Using SPP 3.1, assigned.

Al.lb SRO ONLY In accordance with SPP 3.1 Determine the Condition Classification (PER Level) for the following condition. Procedure reference is allowed.

Unit 2 is in Mode 1 During a board walkdown, it is discovered that the RCIC flow controller indicates downscale.

Subsequent investigation reveals that the automatic function of the flow controller is failed, manual function is still working. Determine the PER Level that should be assigned.

Solution Classification is C since LCO is involved.

KA Generic 2.1.33 SRO-4.0

WVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 23 of 49 APPENDIX D Page 1 of 8 CONDITION CLASSIFICATION CRITERIA NOTE Appendix D provides guidelines for management consideration when assigning PER condition levels to aid in achieving consistency and ensuring appropriate actions and levels of review are assigned. Typical examples are provided for each classification level, but this list is not intended to be all inclusive. PERs may be classified at the discretion of management upon MRC review; PERs may be assigned classification as Level C or D based upon management judgment in allocating resources.

1.0 LEVEL A - SIGNIFICANT (USUALLY SAFETY RELATED) CONDITIONS - RCA Required A. A major safety-related or QA program condition that has occurred with a frequency as to indicate that past recurrence control has been lacking or ineffective.

B. Confirmed adverse trends in quality activities identified by trend analysis. These adverse trends would normally be associated with the administrative control programs and would represent a major breakdown.

C. A programmatic breakdown which negates quality controls or places doubt on the integrity of the affected program.

D. Repetitive or deliberate occurrences of procedural violations that have a direct and detrimental effect on safety or quality.

E. Conditions which impact the plant's ability to mitigate design basis accidents.

F. An adverse condition which merits increased upper management attention:

G. Falsification or unauthorized changes to quality assurance records (completed or in process).

H. Unplanned reactor/turbine trips as required by management.

1. A fatality or serious accident/incident.

J. NRC Performance Indicators (PI) associated with the revised "Reactor Oversight Process" that falls within the white, yellow or red band.

NOTE RCA is required.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 24 of 49 APPENDIX D Page 2 of 8 CONDITION CLASSIFICATION CRITERIA LEVEL A PER CONDITION EXAMPLES Nuclear Safety Personnel Safety Environmental Impact Economic/Operational Impact Emergency Plan declaration of Death Immediately reportable spills with Extensive equipment damage alert or higher. potential to harm environment. (e.g., required replacement or Major disability injury significant repairs to major equipment Fuel damage due to misoperation NPDES releases resulting in such as the turbine generator, reactor or mishandling. Serious near miss incident with significant threat to human health coolant pump, MFW pump).

potential for death or environment, PCB fire or Reactor trip explosion. Conditions resulting in significant power reductions, outage delays or Turbine trip PCB release - 1 lb. or more to extensions.

environment.

Event requiring use of safety Lengthy unplanned outage or operation systems. Atmospheric asbestos at significantly reduced power.

contamination.

Unusual plant transients Repeat failures of surveillance or post

- operator actions inhibited ACM removal without notification modification tests to detect non

- extraordinary actions required 260 linear ft. 160 sq ft. 35 cubic ft. conforming equipment or systems.

- inappropriate actions Leaking underground diesel fuel Repeat NRC notices of violations.

Significant operating/design tank or ancillary piping.

violations of Tech/Specs/FSAR, Repeat INPO findings.

e.g. Operate system with prohibited

- reactivity mismanagement refrigerant [>30 days & >35% leak Repeat Nuclear Assurance findings.

- inaccurate accident analyses rate (process equip) or >15% (pers comfort)]. Repeat occurrences of organizational Loss of entire safety function or programmatic breakdowns excluding momentary entry per Intentional dumping of hazwaste.

L.C.O,3.0.3 of low safety Repeat missed Tech Spec significance Surveillance requirements (unless missed surveillance requirement is a Unplanned radioactive release or result of a conditional Tech Spec action).

exposure to radioactive material greater than regulatory limits.

Numerous repetitive failures to Common cause failures that implement or maintain commitments to could affect multiple safety regulatory agencies.

systems/components.

Major safety-related or OA program No barriers remaining (only luck condition that has occurred with a frequency that indicates past averted an accident).

recurrence control has been lacking or Notices of Level 1,11,and Ill ineffective.

violations NRC PI and findings in the yellow or red band

__________________ I _________________ .1

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 25 of 49 APPENDIX D Page 3 of 8 CONDITION CLASSIFICATION CRITERIA 2.0 LEVEL B - ISSUES (SIGNIFICANT. IF RCA IS REQUIRED)

A. Identified conditions which do not meet the criteria of Level A but which require further evaluation.

B. Quality-related deficiencies which require identification of apparent cause and action to correct the condition in accordance with the Nuclear Quality Assurance Plan.

C. Human errors (inappropriate actions) which could have, under different circumstances, caused a significant plant event or serious personnel injury.

D. Responses to regulatory identified issues which did not result from a Level A event.

E. Recurring events not classified as significant which retain the potential for causing a plant event or personnel injury. That is, a negative trend which does not meet the above criteria of Level A, Section 1.0 (A), (B), and (D).

F. Events or conditions which require recurrence control or for NRC reportable issues requiring a formal written response. These include Licensee Event Reports, NRC cited violations, and audit findings. Other examples include adverse trends from plant process equipment history and failure trending on recurring plant process equipment problems.

NOTE Apparent cause is required and may require Root Cause Analysis as determined by Senior Management.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 26 of 49 APPENDIX D Page 4 of 8 CONDITION CLASSIFICATION CRITERIA LEVEL B PER CONDITION EXAMPLES Nuclear Safety Personnel Safety Environmental Impact EconomiclOperational Impact Emergency Plan declaration of Lost time accident. Repeated major failures such as Major equipment damage to pumps, spills of chems or oil, improper valves, or piping.

unusual event.

Serious near miss incident storage, failed secondary Fuel handling incidents with no (RCA required) containments, etc.. Conditions resulting in power reductions, forced outages or outage fuel damage. delays/extensions or Ž_one day.

Individual exceeds regulatory NPDES permit noncompliance.

Reactivity mismanagement that dose limits.

Stormwater permit exceeded. Unusual conditions such as damage by does not violate Tech Spec. High radiation areas not lightning, physical impact from other properly controlled. PCB spill/leak less than reportable. equipment, corrosion, flood, or other Inadvertent actuation of environmental conditions, safeguards equipment.

Violation of a stop work order. Exceed annual ACM permitted limit. Repeat events indicative of an Plant transients resulting in organizational or programmatic

Ž_10% power change due to BOP Multiple or other significant personnel contamination Improper storage or disposal of breakdown (e.g., design change control, failures. warehousing, adherence to procedures, instances. chems, solid waste or hazwaaste, etc.).

Events that exceed administrative guidelines concerning plant Significant violations of Other events resulting in state radiological control procedures. NOVs. Adverse safety trends (i.e., near misses, operations, reactivity minor injuries, etc.).

management, and radioactivity Venting Refrigerant Intentional is releases. Notices of violation requiring formal prohibited.

response.

Excessive quantities of Work by uncertified personnel on radioactive material found outside Significant INPO findings.

equipment containing prohibited the Radiation Controlled Area.

refrigerant.

Conditions detected by independent Loss or theft of Source or assessors that represent a significant Special Nuclear Material. Uncontrolled or unidentified hazwaste satellite storage area. organization or programmatic barrier breakdown.

Events or conditions requiring a formal response to the NRC with Failure of multiple administrative and/or the exception of special reports equipment protection barriers such that required by Tech Spec, FSAR, few or as little as one barrier remains.

etc.

Failed detection by surveillance or post Placement of maintenance testing or failed systems/components in administrative barriers with 2nd paragraph (a)(1) of the verification.

Maintenance Rule due to functional failures. A missed Tech Spec Surveillance requirement.

Placement of systems/components in paragraph (a)(1) of the Maintenance Rule due to exceeding Performance Criteria.

NRC PI and findings in the white band. I

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 27 of 49 APPENDIX D Page 5 of 8 CONDITION CLASSIFICATION CRITERIA 3.0 LEVEL C - ISSUES (Routine problems warranting additional corrective evaluation and action.)

A. Conditions which do not meet the criteria in Levels A or B but do identify a problem which warrants tracking to closure.

B. Conditions where structures, systems and components are degraded or nonconforming.

C. Conditions which identify a problem that requires issuance of a special report.

D. Human performance problem trends with little consequence and little potential to cause a plant event but require improvement.

E. An incident resulting in a recordable injury or which under different circumstances could have resulted in an injury.

F. Minor violations, non-cited violations, or NRC findings in the green band or has no color

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 28 of 49 APPENDIX D Page 6 of 8 CONDITION CLASSIFICATION CRITERIA LEVEL C PER CONDITION EXAMPLES Nuclear Safety Personnel Safety Environmental Impact Economic/Operational Impact A Balance of Plant (BOP) Radiation areas not properly Failure of tank containing oil or Minor equipment damage < $1OK.

transient that did not result in a posted. chemical to secondary

>10% perturbation to plant power containment but not the Small fires.

or did not challenge any Individual exceeds environment.

engineered safety features. administrative dose limits. Unavailable fire protection equipment.

NPDES permit criteria threatened Equipment failures/malfunctions Minor spills or spread of by a discharge. Maintenance rework items.

resulting in Tech Spec LCO radioactive material.

entry (with no loss of Stormwater best management Condition identified by management.

system/train safety function). Valve/system leaks resulting in practices not in use or maintained release of radioactivity/spread in good repair. Conditions detected by independent Component failure which does of contamination, assessors that do not represent a not result inthe loss of a train of Failure to maintain secondary significant organizational or a maintenance rule system. Uncontrolled water or containment for chemical/oil, programmatic barrier breakdown.

condensation inside the RCA.

Other conditions: Repeat cases of missing labels Failed administrative barrier or Radiation exposure in excess on drums issued or chemical significant equipment protection

- design qualification issues of that projected by the RWP. containers. (additional administrative or other

- procedure deficiencies protective barriers remain).

- personnel errors Personnel contamination Release of radioactive or

- violation of requirements events occurring from hazardous materials in excess of Violation of Administrative

- failure to follow procedure procedural violations or poor administrative limits. Requirements, e.g. Incorrect

- valves, switches, breakers radworker practice. procedures, drawings, etc. Adverse found in wrong positions trends in equipment, programmatic or

- radioactive material found Recordable injury/near miss human performance that do not directly outside the RCA incident challenge safety, regulatory compliance or reliability.

Minor violations, non-cited violations, or NRC or PI findings in the green band or has no color

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 29 of 49 APPENDIX D Page 7 of 8 CONDITION CLASSIFICATION CRITERIA 4.0 LEVEL D - ISSUES (RESOLVED/CLOSED AND TRENDED. Routine Problems which are adequately addressed by immediate actions or the work control Process. Used for documentation and trending)

A. Conditions which do not meet the criteria in Levels A, B, or C and immediate actions taken were sufficient to resolve the condition.

B. Conditions which do not affect operability, are not reportable, and are not potentially generic.

C. Conditions which do not involve ASME Section III hardware or processes (construction plants only).

D. Human performance problems of low importance but require documenting and trending.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 30 of 49 APPENDIX D Page 8 of 8 CONDITION CLASSIFICATION CRITERIA LEVEL D PER CONDITION EXAMPLES Nuclear Safety Personnel Safety Environmental Impact Economic/Operational Impact Minor conditions that can be Problems that are corrected Isolated spills of less than Immediately correctable minor equipment resolved by immediate action immediately: reportable quantities damage Examples include:

Minor personnel hazards Missing labels from drums or Small easily extinguished fires

- personnel errors that do not chem containers impact plant equipment Minor personnel contamination Immediately correctable inoperable incidents resulting from Stormwater best management equipment

- failure to follow minor procedural violations or poor practices failed but were administrative procedural radworker practices. promptly repaired. Minor condition identified by any employee requirements Missing/Inadequate Secondary

- fuse found blown during test containments for temp storage performance, fuse replaced and are promptly put into place checked Other minor violations of Env.

- WOs processed without Program.

properly annotating the "M&TE Used" field inthe computer Drawing Deviations

Tennessee TITLE SPP-3.1 Valley Authority Rev. 2 Page 1 of 49 TVAN STANDARD CORRECTIVE ACTION PROGRAM Quality Related 0 Yes [] No PROGRAMS AND PORC Required 0 Yes [I No PROCESSES 10CFR50.59 Review N Yes 0 No Effective Date 8/14/2000 RESPONSIBLE PEER TEAM: Business and Work Performance Organization CONCURRENCES Larry V. Parscale for D. Nelson 8-1-00

Primary Sponsor Date R. Purcell 8-4-2000 PeerTeam Mentor Date APPROVAL For Nuclear Assurance Sponsored SPPs R. J. Adney 8/7/00 General Manager,NA Date Karl W. Singer 8/9/00

Senior Vice President,Nuclear Operations Date

Site-specific changes are approved by Site Sponsor and Site Vice President (see PCF)

TVA 40480 [05-2000] Page 1 of 1 Orr-' - L - - I

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 2 of 49 REVISION LOG Revision Effective Pages Description Number Date Affected of Revision 0 04/06/98 All Initial issue. Replaces STD-3.4, "Corrective Action Program". General restructure in order to enable the plants to have similar program.

1 7/15/99 2-27, 30, Further standardized the Corrective Action Program 32-35, 37-39 between TVAN sites and clarified statements.

2 8/14/00 2-45,47-49 Re-ordered Appendices; created new Appendices F and J; re-located pertinent sections from procedure body to Appendices; re-worded for clarity and usability.

Incorporated guidance from SPP-3.6 into new Appendix J.

Added template information to improve direction to user on which template to use in the electronic system for selective sections of the process. Added information on how generic reviews will be handled. Provided examples for each classification of a PER and added trend analysis guidelines.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 3 of 49 TABLE OF CONTENTS Page 1 of 2 Section Title Page R e v is io n Lo g .............................................................................. I......................................................... 2 T a b le of C o nte nts ................................................................................................................................ 3 1 .0 P UR PO S E .............................................................................................................................. 5 2 .0 S C O P E ................................................................................................................................... 5 3 .0 INS T R UC T IO NS ..................................................................................................................... 5 3 .1 P E R In itia tio n .......................................................................................................................... 6 3 .2 S upe rv iso ry R ev iew ................................................................................................................ 7 3.3 Reportability and Operability Review ...................................................................................... 8 3.4 Management Review Committee (MRC) ................................................................................. 8 3.5 Corrective Action Plan Development and Approval ................................................................. 9 3.6 Extension Requests 12..............

12 3.7 Corrective Action Implementation ........................................................................................... 12 3 .8 P E R C lo s u re .................................................. .. ............ . 1................

12 3 .9 R e v isin g P E R s 13..............

13 3 .10 G e n e ric R e v ie w ........................................................................................................ ........... 13 3 .1 1 E s c a la tio n .......... 14..............

14 3 .12 T re nd A na lysis 14..............

14 3.13 Program Monitoring .................................................................................... 1........4......

14 4.0 RECORDS ............................................................. 15 QA Re co rd s ............................................................................. 1................

15 4 .1

.................................. .1......... ... 15 4 .2 N o n-Q A Re co rd s .................................................................

5 .0 DE F INITIO NS ......................................................................................................................... 15 APPENDIXES Appendix A Recognized Administrative Control Programs (ACP) .......................... ..... 18 Appendix B Inactive Unit PERs (BFN-1 and W BN-2) ...................................................... 19 Appendix C Guidelines for Potential Operability Determinations ........................................ 21 Appendix D Condition Classification Criteria ................................... 23 Appendix E Recommended Screening Criteria for Posting Operating Experience (OE)

Messages on Nuclear Network .................................... 31 Appendix F Controlling Nonconforming Materials, Parts, or Components .......................... 32 Appendix G Cause Determination and Corrective Action Development Guidelines ............ 33 Appendix H Resolution of Degraded and Nonconforming Conditions ............................ 36 Appendix I PER Closure ................................................................................................. 40 Appendix J Trend Analysis Guidelines 41.............

41 Appendix K PER Initiation ............................... 43

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 4 of 49 TABLE OF CONTENTS Page 2 of 2 Section Title Page FORMS SPP-3.1-1 Problem Evaluation Report (PER) .................................................................. 44 S P P-3.1-2 E xtension R equest ......................................................................................... 49

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 5 of 49 1.0 PURPOSE This SPP describes the TVA Nuclear Corrective Action Program, and establishes the processes, requirements, and responsibilities for documenting and resolving problems, including adverse conditions.

The overall objectives of the Corrective Action Process are to:

"* Improve plant performance

"* Provide all employees with an effective method for raising issues with equipment, programs or processes that may affect safety, regulatory compliance, reliability, or human performance,

"* Assure that priorities and resources are properly aligned based on significance of the issue

Clarify and reinforce standards

Provide a means to collect data for trend analysis.

2.0 SCOPE The TVA Nuclear Corrective Action Program identifies and corrects problems. The program is designed to address problems in a manner consistent with the nature of the condition and its importance to plant safety, personnel safety or plant reliability. This SPP contains the detailed requirements for Problem Evaluation Reports (PERs) and applies to all TVA Nuclear and to non TVA Nuclear organizations involved in nuclear power activities.

Other Administrative Control Programs (ACPs) that report and disposition problems are recognized by the overall TVAN Corrective Action Program. A list of ACPs and pertinent requirements is included in Appendix A.

NOTE I PERs identifying problems with inactive units will be handled in accordance with Appendix B.

NOTE 2 Whenever "PER coordinator" is specified, the responsible organization's PER coordinator or designee is implied.

3.0 INSTRUCTIONS It is the responsibility of ALL PERSONNEL TO PROMPTLY DOCUMENT AND REPORT problems and adverse conditions for evaluation and corrective action.

PERs shall not be invalidated, destroyed, canceled, or otherwise prevented from receiving supervisory/management review once they are documented and assigned a number. All PERs shall be entered and tracked to closure in TROI/EMPAC.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 6 of 49 3.1 PER Initiation NOTE 1 PERs should be generated, processed, and tracked using the electronic EMPAC system (Appendix K). This does not prohibit the manual initiation of PER forms, however, information will, eventually be entered into the electronic system (when available at site) for processing. In addition, help text is available and can be utilized to aid in the electronic processing of the PER.

NOTE 2 Site PER conditions identified by offsite personnel should be initiated and processed by personnel assigned by the affected site (including Corporate).

A. Personnel shall promptly document problems including adverse conditions using the appropriate corrective action document. PERs shall be initiated for problems in any area of the site, for programs, processes, recurring or unexpected equipment issues, or human performance issues. If unsure of which document to use, document the condition on a PER form.

B. Any employee identifying a problem or adverse condition shall promptly notify the Shift Manager (SM) when the condition may affect:

1. The reliable operation of the plant which includes technical specification operability and the balance of plant features required for power generation.

2. The health or safety of employees or the public when it involves a significant safety incident/condition or a serious personal injury.

3. A significant radiological or security problem.

NOTE Appendix K may be used as necessary by the initiator to aid in PER initiation.

C. The initiator shall:

1. Describe the problem or adverse condition in clear, concise language.

Identify NAME of your immediate supervisor under the drop down field called "Planner/Supervisor." The final step performed before saving PER information is to select the department that you work for under the drop down field called "Department." Finally, save the information on the initiator's template.

2. Identify any notifications made or immediate actions taken on the PER.

3. Use paper forms if electronic system is unavailable.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 7 of 49

4. Promptly notify the supervisor for review of the PER.

3.2 Supervisory Review (Promptly, shall not exceed 3 working days from the initiation of PER).

NOTE When it is apparent that a condition is generically applicable to other TVAN sites or corporate, the affected site or corporate organization will be notified via EMPAC reports.

A. The supervisor shall:

1. Review the PER to determine if a problem/adverse condition exists.

2. Review the PER for clarity and completeness and to ensure that adequate information is available for subsequent management review.

3. Take immediate action if the condition described may affect the safety of personnel or plant equipment. Evaluate condition for potential operability using Appendix C and potential reportability using SPP-3.5, "Regulatory Reporting Requirements", then:

a. Provide prompt verbal notification of the condition to the Shift Manager (SM) of the affected unit.

b. Initiate and/or support the completion of any required immediate action(s).

4. Determine if PER condition potentially affects plant process equipment and notify Operations Shift Manager (SM) provided a WR/WO has not already been generated. If WR/WO has been generated, document in immediate actions section of the PER.

5. If immediate actions are required, initiate actions, and document the action(s) taken.

6. If the condition described is determined to not be a problem and no action is required, then disposition and/or document justification.

Recommend the PER be closed. PERs determined to be a non-PER condition should be discussed with the initiator. PERs determined to be more appropriately processed by an ACP may be processed by that ACP.

7. Recommend a classification for the PER condition level in accordance with Appendix D.

a. If the PER is recommended as Level A, B, or C, coordinate with responsible organizations, then continue to process.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 8 of 49

b. If the PER is classified as Level D then complete associated templates and any appropriate human performance template fields.

8. Mark if ASME hardware, processes, or programmatic problems are involved. This includes a violation of the Code. Identify the affected systems, and which unit is involved (ANI involvement is restricted to ASME Code driven requirements only).

9. For potential drawing deviations not utilizing SPP-9.8:

a. Perform a verification by confirming the potential drawing deviation condition is valid and that there is no ongoing work that would explain the differences.

b. Confirm affected documents are included and marked up to reflect the actual plant configuration.

c. Evaluate the condition against criteria for Level A and B PERs, take necessary actions.

d. If the condition is valid, sign the PER form. The supervisor signature documents second party verification that the condition is valid and that the enclosed marked up documents accurately reflect the plant configuration.

10. Ensure supervisor's template is completed.

3.3 Reportability and Operability Review A. Operations shall review (immediately, as required by plant Technical Specification) all PERs potentially affecting operability and shall document the operability determination and actions necessary to change plant operating mode on the Operation's template. Appendix C provides guidelines for potential operability determinations.

B. For PERs determined to affect operability, Operations shall document on the Operation's template. If operability potentially affects an offsite licensed site(s),

notification will be made electronically through EMPAC reporting system. Offsite Operation's staff will document their evaluation on the "PER L Reviews template" designated as operability review.

C. Operations and/or Licensing Manager shall take actions in accordance with SPP 3.5, "Regulatory Reporting Requirements" when PERs are determined reportable and document the reportability determination on the Operation's template.

3.4 Management Review Committee (MRC) (should not exceed three working days from the initiation of the PER)

A. The MRC shall:

1. Review and determine the classification level of the PER.

"WVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 9 of 49

2. Determine if a root cause analysis (RCA) is required.

3. Indicate if Nuclear Assurance (NA) approval is required.

4. Assign the responsible organization.

B. MRC should:

1. Review the potential operability and reportability determinations.

2. Determine any additional interim actions necessary.

3. Determine whether the events or conditions described by the PER should be reported to the Nuclear Industry by issuance of an INPO Nuclear Network OE Newsgroup entry. (Reference Appendix E).

4. Confirm if the PER should be reviewed by other TVA plants for operability and/or generic applicability.

3.5 Corrective Action Plan Development and Approval NOTE If during the course of the RCA, extent of condition, or development of corrective action plan, the condition is found to be more significant than initially reported, consideration should be given to returning the PER to Management Review Committee (MRC) for upgrading and re-evaluation of the operability and reportability determinations.

A. If applicable, immediately initiate control of nonconforming materials, parts, or components per Appendix F.

B. Twenty working days from MRC review of the PER is allowed for responsible organizations to develop and obtain approvals of corrective action plans. The time period allotted may be reduced to support licensing submittals. Up to five additional working days is allowed for NA to evaluate the Corrective Action Plan for PERs requiring NA approval. NA will review corrective actions for all audit findings.

1. Apparent cause determination is required for all PER Levels, unless Root Cause Analysis (RCA) is required.

2. corrective action plans may consist of corrective actions and/or enhancements.

NOTE The PER completion date is the long lead corrective action date.

C. The responsible organization shall perform the following for Level A and B:

1. Implement interim actions, if required, to control the situation prior to the development, approval, and implementation of the corrective action.

Consider evidence preservation of hardware and other data that may be needed for the RCA. Document interim actions in the PER.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 10 of 49

2. Perform RCA utilizing qualified individuals and a structured process for all Level A PERs, and for Level B PERs when requested by MRC.

Conclusions and basis of the RCA shall be part of the PER along with the RCA work sheets. (Reference BP-236, "Event Critique and Root Cause Analysis".) An individual is considered qualified if he has received training/re-training, or'has performed a root cause analysis within the last 36 months.

NOTE Refer to Appendix G for guidance in assignment of cause and corrective action.

3. Perform a review of previous similar events for the detection of corrective actions which should have prevented this problem. This review may consist of TROI/EMPAC/NERPEPIX/Maintenance History database searches and should include industry operating experience if applicable. The term "previous similar events" are conditions that involved the same root cause, failure, or sequence of events.

4. Identify an apparent cause for Level B PERs which do not require RCA.

Provide a description of why the event occurred.

5. Determine if the PER is potentially generic and document the determination and affected locations. The extent-of-condition analysis, generic review, and corrective action developed for a Corporate PER shall address all sites unless site-specific PERs have been initiated.

6. Perform an extent of condition review to bound the identified problem.

Investigate, as applicable, whether the identified condition affects other units, systems, components, documents, organizations, etc. The level of detail of this investigation should be consistent with the significance of the condition. If during extent of condition a wide spread problem is discovered, a root cause analysis (and consequently actions to prevent recurrence) shall be performed and returned to MRC for review.

7. Determine specific actions necessary to correct the condition and causes (Refer to Appendix G). For PERs which receive RCA, actions to prevent recurrence are required. When action is required by organizations other than the responsible organization, obtain concurrence with schedule dates.

8. Obtain MRC concurrence.

9. Complete Responsible Organization, Cause, CA/RC, and CAP Concurrence templates. As applicable, complete Human Performance (HP) template.

D. For Level C PERs, the responsible organization shall:

NOTE Refer to Appendix G for guidance in assignment of cause and corrective action.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 11 of 49

1. Determine and document the apparent cause and specific actions to be taken to correct the PER condition and an apparent cause(s), as applicable. Evaluations of lower-significant problems focus on correcting the immediate (or apparent) cause and may not address the root cause. For very simple problems, the cause may be obvious and does not need more rigorous ahalysis to determine corrective actions.

For other lower-significant problems, corrective actions may correct the immediate situation but not prevent recurrence. If similar problems occur, potential adverse performance and/or common causes will be identified through trend analysis.

2. Document any interim actions needed to control the condition until corrective action implementation. Provide schedule completion dates which have been coordinated with implementing organizations.

3. Determine if the PER is potentially generic.

E. For degraded or nonconforming conditions as defined in Section 5.0, annotate the PER as appropriate, and follow the requirements of Appendix H.

F. Coordinate PERs which potentially affect reactivity management with Reactor Engineering personnel. Refer to SPP-10.4, "Reactivity Management Program,"

for determining applicability.

G. If condition is a human performance condition, fill out the necessary fields on the HP template as applicable.

H. For approval of corrective action:

1. Managers of the action organizations approve the due dates for actions assigned to them.

2. Site VP or direct reports (e.g., Plant Manager, Engineering and Support Services Manager) approves Level A PERs.

3. Responsible Organization's Department Manager (e.g., Maintenance and Modifications Manager, Operations Manager) approves Level B PERs.

4. Responsible Organization's Supervisor approves Level C PERs.

5. NA approves audit findings PERs and PERs designated by NA or MRC.

6. Authorized Nuclear Inspector (ANI) reviews PERs involving American Society of Mechanical Engineering (ASME) section XI code-related equipment or activity as documented on the PER A Supervisor's template. The PER is provided by the responsible supervisor as a copy of original or by an automatic printout from the data base. Approval by ANI for corrective action plans is not required.

7. MRC as directed by management.

8. PER completion date is the long lead corrective action date.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 12 of 49 3.6 Extension Requests A. If the corrective action plan development, approval, or PER completion date cannot be completed by the due date, the responsible organization shall request an extension. Extension requests shall be approved consistent with levels of approval outlined in Section 3.5.H, and PERs updated accordingly.

B. The action organization shall coordinate extension to any CA/RC item date change with the responsible organization. Individual CA/RC item dates do not require extension requests. Only the CAP concurrence and PER completion dates required extension requests.

NOTE Extension of corrective action development may not be approved prior to the determination if interim actions are required. Justification should include an evaluation of why the proposed extension does not affect nuclear safety.

3.7 Corrective Action Implementation A. Responsible organization implements and/or monitors the implementation of the approved corrective action plan.

NOTE If new information is obtained indicating causes different than originally identified, consider the need for revision of corrective action and re-review operability and reportability determinations.

B. If a revision to the approved corrective action becomes necessary, the responsible organization shall initiate the revision and obtain the required approvals in accordance with Section 3.9.

3.8 PER Closure A. The action organization(s) ensures that any supporting documentation that provides evidence of completion of the corrective action is either attached or referenced on the original PER. If the documentation is not attached it must be readily retrievable. (Recommend electronically including all documents to support PER closure)

B. Responsible organization verifies completion of the PER corrective actions by the action organization using the guidelines of Appendix I and closes the PER by completing the verification template.

C. The responsible organization ensures that the Authorized Nuclear Inspection Agency (ANI, ANII, or ANIIS) review or acceptance is obtained, if the PER involves an American Society of Mechanical Engineer (ASME) Code-related program activity.

For ASME Section Xl program activities, the completion of the ANI fields on the verification templates signifies review and (when applicable) verification that the activity has been performed in accordance with the owner's repair program (SPP-9.1, "ASME Section XI").

TVAN STANDARD SPP-3.1I PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 13 of 49 D. Audit finding PERs and PERs identified as needing NA verification should be verified by NA within 10 working days.

E. The responsible organization shall ensure that all Level A PERs and those Level B PERs determined by MRC receive an effectiveness review after completion of corrective actions (do not wait to close PER if the only action left is the effectiveness review). The schedule for completion of this review shall be commensurate with the nature of the corrective actions and should not exceed one year following corrective action plan closure. The responsible organization shall enter their effectiveness review action item and completion date into a tracking data base. If corrective actions are determined to have been ineffective by the review, a new PER should be initiated and reference to the old PER and the old PER should be supplemented with a reference to the new PER.

F. The responsible organization completes verification and closure, then submits PER closure package to EDMS.

3.9 Revising PERs NOTE 1 Extensions approved in accordance with this SPP do not constitute a revision.

The responsible organization should coordinate date changes with those other organizations affected.

NOTE 2 The electronic process will provide history of changes as required by SPP-2.4.

A. When revising PERs, the action/responsible organization indicates the revised portions on the Revision, CA/RC and Supervisor's templates.

1. Obtain approvals required on the Revision and CA/RC templates for the sections of the PER affected by the revision. For revisions to the PER Description of Condition, the revised PER shall be processed the same as a new PER.

NOTE Personnel approving the revision must consider the need for reevaluating generic applicability, reportability, and effect on operability. If the need for reevaluation is identified, actions shall be assigned to ensure they are accomplished.

2. Obtains concurrence signatures from action organizations affected by the change.

3. Forwards the revised PER to the PER Coordinator.

3.10 Generic Review NOTE Generic applicability determination should be made as soon as the responsible organization receives the PER for corrective action development.

A. PERs determined to be potentially generically applicable are designated on the Responsible Organization template. The offsite PER L Reviews template shall be used to document offsite responses (both generic and operability reviews).

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 14 of 49 NOTE Corporate organizations may be specified to perform the generic reviews for issues associated with design criteria, design methods, selected major component groups, and multi site programs or programmatic issues.

B. The PER Coordinator of affected sites/brganizations obtains the PER for evaluation. Level C PERs are provided for information only, with response limited to acknowledgment. (Note that all fields on the generic template for the offsite organizations need to be addressed for all potential generic PERs).

C. Managers of the affected sites/organizations should evaluate the Level A or B PER within 20 working days of review of the EMPAC report, showing potential generic conditions, by their PER Coordinator.

1. If a generic condition is determined to exist, the identification number of the PER used to correct the condition is recorded on the affected organization's evaluation.

2. If a generic condition is determined not to exist, a justification is documented on the affected organization's evaluation.

NOTE Generic review issues may exist at BLN, but, because of the incomplete state of the project and programs, the issue will be tracked in TROI/EMPAC for future consideration as a generic applicability review item.

D. The originating PER Coordinator, verifies the affected organization's evaluations and checks the evaluations for consistency and apparent problems. If the check identifies any problems, initiate actions to ensure they are resolved.

3.11 Escalation The responsible organizations or NA may escalate PERs as needed.

3.12 Trend Analysis Appendix J provides guidelines for performing trend analysis to identify if potential adverse trends exist and to identify areas where improved performance can be achieved.

3.13 Program Monitoring A. Periodic self-assessments are scheduled and performed in accordance with SPP-1.6, MTVAN Self-Evaluation Program", to monitor program health and effectiveness.

B. Indicators are assigned to key program activities and are routinely reported to management.

C. Information concerning outstanding program key actions and age (backlog) is routinely reported to management.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 15 of 49 D. Effectiveness reviews are performed as required, and document what was reviewed, and provide evidence of corrective action effectiveness as documented in individual PERs. Evidence of ineffective corrective actions or inadequate recurrence control shall be reported to site management.

4.0 RECORDS 4.1 QA Records Problem Evaluation Reports - Template Information (with the exception of trend data),

Audit Trail Information, and Supporting Attachments.

Complete generic review packages 4.2 Non-QA Records None 5.0 DEFINITIONS Accept-As-Is - A hardware disposition which may be imposed for a nonconformance when it can be established that the discrepancy will result in no adverse condition and that the item under consideration will continue to meet all engineering functional requirements including performance, maintainability, fit and safety. Meeting all engineering functional requirements may not mean meeting all FSAR or configuration requirements. A design change may be required as a result of the accept-as-is disposition.

Adverse Conditions - Deficiencies including nonconforming material, parts, or components; failures; malfunctions; deviations; hardware problems involving noncompliance with licensing commitments, specifications, or drawing requirements; abnormal occurrences; and non-hardware problems such as failure to comply with the operating license, technical specifications, licensing commitments, procedures, instructions, or regulations.

Adverse Trend - An undesirable change in a quality indicator statistic of such magnitude as to require analysis of the information to ascertain if it requires management attention.

Apparent Cause - A problem or condition cause determination based on the evaluator's judgment and experience, and where reasonable effort is made to determine WHY the problem occurred. This might include fact finding, analysis, interviewing, benchmarking, reviewing data or maintenance history, or other methods as appropriate.

Degraded Condition (Generic Letter 91-18) - A condition of a system, structure or component (SSC) in which there has been any loss of quality or functional capability, within the scope defined in section 2.0 of Appendix H.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 16 of 49 Examples of degraded conditions are:

0 Heat exchanger fouling has reduced heat removal capability below the FSAR or design value.

Pump flow rate is below the value used in the FSAR analysis.

0 Valve stroke time is greater than listed in the FSAR.

NOTE All the above examples reference the FSAR, however, the intent and scope is further clarified in section 2.0 of Appendix H.

Drawing Deviation (DD) - is the method used to resolve differences between design output and the actual plant configuration. The plant is correct. The condition does not potentially affect reportability, operability, and is not potentially generic.

Enhancements - Within the scope of this procedure an action that is not required to be performed to satisfactorily correct or prevent recurrence of conditions adversely affecting regulatory compliance, plant reliability or personnel/nuclear safety.

Management Review Committee - A group of key managers designated to review PERs for legibility, clarity, completeness, whether it is an example of a previously identified adverse condition, and determination of responsible organization.

Near Miss - An incident which given different circumstances, could have resulted in an injury/illness or property damaged.

Nonconformances - A deficiency in characteristics, documentation, or procedures which renders the quality of a hardware item unacceptable or indeterminate. Examples of nonconformances include: physical defects, test failures, incorrect or inadequate documentation or deviation from prescribed manufacturing processing, inspection, or test procedures.

Nonconforming Condition (91-18) - A condition of an SSC in which there is failure to meet requirements or licensee commitments within the scope of Section 2.0 of Appendix H, such as:

1. There is failure to conform to one or more applicable codes or standards specified in the FSAR.

2. As-built equipment, or as-modified equipment, does not meet FSAR descriptions.

3. Operating experience or engineering reviews demonstrate a design inadequacy.

4. Documentation required by NRC requirements such as 10CFR50.49 is not available or deficient.

Operable - Operability - A system, subsystem, train, component, or device shall be operable or have operability when it is capable of performing its specified safety function(s). Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal or emergency electrical power sources, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s).

PER Coordinator - Individual within the various line organizations including NA that will be the primary contact within that organization, department, or group for coordination of actions for

'PERs and submitting necessary documentation for closure of PERs to EDMS.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 17 of 49 Repair - A hardware disposition which restores a nonconforming characteristic of an item to a condition such that the capability of an item to function reliably and safely is unimpaired even though the item still does not conform to design requirements.

Responsible Organization - The organization with lead responsibility for resolving a PER including developing the corrective action, determining potential generic applicability, implementing corrective action, and closing.

Rework - The process by which a nonconforming item is made to conform to a prior specified requirement by completion, re-machining, reassembling, or other corrective means.

Root Cause - The fundamental cause(s) and associated corrective action(s) that, if corrected, will prevent recurrence of an event or an adverse condition.

Scrap - A hardware disposition to discard the item in a controlled manner.

Serious Near Miss - A near miss incident with significant probability that a serious injury/illness or extensive property damage could have occurred.

Significant Problem - A condition or trend which meets the significance criteria as described in Appendix D.

Trend Analysis - A formal evaluation of data to determine the direction of movement in the course of time of a statistically detectable change. Also, trend analysis is the evaluation of data that has been compiled or grouped onto charts, diagrams, reports, or other formats such that the prevailing tendency of selected parameters can identify areas that need improving and areas of past successes. (Refer to Appendix J.)

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 18 of 49 APPENDIX A Page 1 of I RECOGNIZED ADMINISTRATIVE CONTROL PROGRAMS (ACP)

In order to be recognized as an ACP by this procedure, the ACP must address the following issues:

"* A procedure must be established describing the ACP. I

"* Procedural guidance must be established for what conditions constitute a PER versus processing in accordance with the ACP procedure.

"* The tracking method (e.g. database) must be specified.

"* Trending of the problems (refer to Appendix J for additional guidance).

"* Supervisor review must be established to ensure PER thresholds are consistent.

ACP Program Maintenance Work Orders SPP-6.1, MMDP-1 (Equipment Failure Trending)

Drawing Deviations SPP-9.8 Safeguard Event Reports SPP-11.3 Receiving Unsatisfactory Reports SPP-4.2

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 19 of 49 APPENDIX B Page 1 of 2 INACTIVE UNIT PERS (BFN-1 and WBN-2) 1.0 PURPOSE This appendix establishes the minimum requirements and responsibilities for inactive PERs.

2.0 SCOPE The requirements of this appendix apply to PERs identified by this procedure and to conditions documented on currently open reporting documents tracked in the TROI/EMPAC system previously placed in a "hold status" (e.g., PERs) identified in previous revisions of the corrective action program.

3.0 DEFINITIONS Inactive unit PERs - PERs placed on inactive status when the activity has been deferred for an extended period of time.

4.0 RESPONSIBILITIES A. The Responsible Organization is responsible for:

1. Reviewing the open PER in accordance with Section 5.0 of this appendix to determine if the PER is to be processed through to closure or placed in inactive status.

2. Completing a continuation form providing justification and approvals for placing the PER in inactive status and forwarding a copy to the Tracking Organization.

3. Ensuring that the documentation package for the inactive unit PER is stored in accordance with this appendix.

B. The Tracking Organization is responsible for:

1. Updating TROI/EMPAC to reflect the status of the inactive unit PER.

5.0 REQUIREMENTS A. PERs, as a minimum, shall be processed through the following actions in accordance with this procedure prior to being placed in inactive status:

1. Management Review or applicable approval.

2. Determination of potential reportability.

3. Potential generic implications.

4. Assignment of trend codes and specification of apparent cause.

5. Determination of any interim actions necessary to control the issue during inactive status.

"WVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 20 of 49 APPENDIX B Page 2 of 2 INACTIVE UNIT PERS (BFN-1 and WBN-2)

B. PERs which impact the following activities should remain in active status:

1. Preservation

2. Layup

3. Security

4. Regulatory Requirements and Commitments

5. Nuclear Safety

6. Personnel Safety

7. Startup or operation of an active unit 6.0 RECORDS A. The original PER (for inactive status) shall be stored by the tracking organization and a copy submitted to EDMS.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 21 of 49 APPENDIX C Page 1 of 2 GUIDELINES FOR POTENTIAL OPERABILITY DETERMINATIONS 1.0 OPERABLE-OPERABILITY A. Without information to the contrary, once a component or system is established as operable, it is reasonable to assume that the component or system should continue to remain operable. However, whenever the ability of a Safety-Related/Technical Specification SSC to perform its specific function is called into question, operability must be determined from a detailed examination of the deficiency.

B. The determination of operability is to be made promptly, with a timeliness that is commensurate with the potential safety significance of the issue. In most cases, the operability determination can be made immediately (e.g., loss of motive power, etc.). In other cases when the determination takes engineering input/analysis, a preliminary determination should be made within approximately 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of discovery even though complete information may not be available. Some cases may take longer. The Shift Manager shall set the due date for the final operability evaluation.

C. A system, subsystem, train, component, or device shall be operable or have operability when it is capable of performing its specified safety function. Implicit in this definition shall be the assumption that all necessary attendant instrumentation, controls, normal or emergency electrical power sources, cooling seal water, lubrication, or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its specified safety function are also capable of performing their related support function D. Generally, to determine potential effect on operability is to ascertain if the condition described in the PER affects the operability of a system or component required by the technical specifications such that it cannot perform its function (Technical Requirements Manual, Offsite Dose Calculation Manual, Safe Shutdown Requirements of Fire Protection Plan, Technical Specifications, etc.). A clear conclusion is needed regarding whether the system or component will perform its safety function, or whether it will perform its safety function with limitations (state limits), or whether it will perform its safety function by taking credit for alternative functional capability, or whether it will not perform its safety function.

D. Design-related deficiencies are to be investigated through calculations, evaluation, communication with vendors, or other means to determine whether the deficiency renders the affected equipment inoperable.

E. Confirmed degradation, damage, failure, malfunction, or loss of plant equipment performed functions important to safety are conditions which may potentially affect unit operability.

F. Failure to follow or create standards to comply with Code of Federal Regulation 10 CFR 50, Appendix B or TVA criteria is not in itself a condition potentially affecting unit operability.

G. ASME Section Xl pumps and valves must be declared as potentially affecting operability when performance data fails in the required action range.

H. Safety-related and quality-related piping and pipe supports found to be degraded or nonconforming required classification as potentially affecting operability.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 22 of 49 APPENDIX C Page 2 of 2 GUIDELINES FOR POTENTIAL OPERABILITY DETERMINATIONS If the degraded condition of the SSC causes any loss of quality of functional capability, then evaluate whether system operability can be justified by taking credit for alternative functional capability (such as manual operation or diverse automatic operation).

Describe why the alternative, or limitations, do not create new or different concerns.

NOTE Where a limiting safety system setting is specified for a variable on which a safety limit has been placed, the setting is chosen so that the automatic protective action will correct the abnormal situation before a safety limit is exceeded. It is therefore, not appropriate to take credit for manual action in place of automatic action for protection of safety limits in considering equipment operable. The use of operator action to put the plant in a safe condition is always appropriate, but operator action cannot be used as a substitute for automatic safety limit protection unless the action has prior concurrence from the NRC.

J. The fact that an SSC is not fully qualified does not necessarily render the SSC unable to perform its intended function. Treat qualification and operability of SSCs separately to ensure that the primary focus is on nuclear safety. Returning the component to fully qualified status should be considered to be a corrective action for a nonconforming/degraded condition.

K. The use of probabilities (i.e., PSA) of the occurrence of accidents or external events shall not be used as the primary source for making operability assumptions. It may be used as supplemental data to support conclusions.

TVAN STANDARD SPP-3.1 PROGRAMS AND CORRECTIVE ACTION PROGRAM Rev. 2 PROCESSES Page 23 of 49 APPENDIX D Page 1 of 8 CONDITION CLASSIFICATION CRITERIA NOTE Appendix D provides guidelines for management consideration when assigning PER condition levels to aid in achieving consistency and ensuring appropriate actions and levels of review are assigned. Typical examples are provided for each classification level, but this list is not intended to be all inclusive. PERs may be classified at the discretion of management upon MRC review; PERs may be assigned classification as Level C or D based upon management judgment in allocating resources.