ML102710736

Lr - Information for Unescorted Access for DCPP

ML102710736
Person / Time
Site:	Diablo Canyon
Issue date:	08/04/2010
From:	- No Known Affiliation
To:	Division of License Renewal
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Download: ML102710736 (32)

Text

1 DiabloCanyonNPEm Resource From:

Soenen, Philippe R [PNS3@PGE.COM]

Sent:

Wednesday, August 04, 2010 11:19 AM To:

Pick, Greg Cc:

Kaminski, Cindy; Grebel, Terence

Subject:

Information for unescorted access for DCPP Attachments:

GPAA102.doc; GPAA101.DOC Greg, Below is the information that is needed to get your team into the system for the inspections. Please respond to Cindy Kaminski, who I have copied on this email, with the information requested. Please also provide a list of the members of your inspection team so that Cindy can make sure we have the information for all of the individuals.

Full Name Date of Birth Social Security Number US Citizen: Yes or No Sex If contractor for NRC - name of company Attached are the read and signs they will need to complete (just last page) and return to Cindy so that she can enter them into PIMS.

<<GPAA102.doc>> <<GPAA101.DOC>>

Thank you, Philippe Soenen Pacific Gas & Electric 142 Cross St. Suite 200 San Luis Obispo, CA 93401 Office: 805.781.9782 Cell: 805.459.3701

Hearing Identifier:

DiabloCanyon_LicenseRenewal_NonPublic Email Number:

1333 Mail Envelope Properties (AB871DDFF8461C4EB4A812A3F51DDAA8DFB03F)

Subject:

Information for unescorted access for DCPP Sent Date:

8/4/2010 11:19:17 AM Received Date:

8/4/2010 11:19:42 AM From:

Soenen, Philippe R Created By:

PNS3@PGE.COM Recipients:

"Kaminski, Cindy" <CMSA@PGE.COM>

Tracking Status: None "Grebel, Terence" <TLG1@PGE.COM>

Tracking Status: None "Pick, Greg" <Greg.Pick@nrc.gov>

Tracking Status: None Post Office:

exchange18.Utility.pge.com Files Size Date & Time MESSAGE 818 8/4/2010 11:19:42 AM GPAA102.doc 879680 GPAA101.DOC 362048 Options Priority:

Standard Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Recipients Received:

June, 2008 (Rev. 13)

GPAA-102 Self-Paced Radiological Controls Area Training INSTRUCTIONS:

This handout provides abbreviated training for unescorted access into the Radiological Controls Area. If you have questions or comments about this handout, please feel free to contact the DCPP General Employee Training Group.

SITE SPECIFIC RADIATION PROTECTION TRAINING JUNE 2008 PAGE 1 REV. 13 PAA 102 Objectives

1.

List the rights and responsibilities of radiation workers concerning radiation exposure.

2.

Recognize the postings and list the entry requirements for each of the radiological areas and the correct response to radiological alarms.

3.

Describe the methods used for measurement of contamination, including the units used and the limits for contamination.

4.

Define and recognize the postings for Hot spot, Cold area, Localized radiation area, and Changed radiological conditions.

5.

Define the classes of individuals for exposure limit purposes.

6.

State the reason for having station limits, and the actions taken if they are being approached.

7.

List the devices used to measure radiation exposure at DCPP.

8.

Explain the actions to be taken if dosimetry is lost or damaged and the radiological consequences.

9.

Describe the types of RWPs used at DCPP.

10.

State the radworkers responsibilities concerning RWP instructions and the correct worker response to radiological or work conditions not described on the RWP.

INDEX Section Page Basics 2

Geographical Boundaries for Radiological Control 2

Radiological Controls Posted Within RCAs 3

External Exposure Limits 5

Personnel Dosimetry 6

Entering And Exiting The RCA 7

SITE SPECIFIC RADIATION PROTECTION TRAINING JUNE 2008 PAGE 2 REV. 13 I. BASICS A. Health risks associated with exposure to radiation are readily measurable at high doses (e.g., bomb blast or medical treatments). At low doses, such as those received occupationally at nuclear power plants, the effects are not clearly measurable. However, the concept of ALARA (as low as reasonably achievable) is born from the assumption that there is some risk in any exposure to radiation. It is generally assumed that the higher the dose, the higher the risk.

You are responsible to keep your dose ALARA.

B. All areas of the plant where radiological hazards exist are clearly posted. These postings use the colors of magenta (purple) on a yellow background. They also have the trefoil (3-bladed) symbol(s) on them.

C. The boundaries of any radiologically controlled area are clearly marked by barriers of magenta and yellow colored rope, tape, or ribbon or locked gates.

D. All workers have the responsibility to keep their exposure as low as possible while at DCPP.

E. Workers have the right to be informed of radiological conditions at their worksite and to discuss concerns about radiological conditions to an RP tech or supervisor.

II. GEOGRAPHIC BOUNDARIES FOR RADIOLOGICAL CONTROL A. Unrestricted Area: Any area not controlled for radiation protection purposes.

B. Restricted Area: Any area to which access is controlled by PG&E for purposes of protecting individuals from radiation exposure.

C. Radiological Controls Area (RCA): An area which requires written authorization (on a radiation work permit) to enter due to increased potential for personnel exposure to radiation and/or radioactive materials.

unit 2

reactor unit 1

reactor control room 140' RCA access 85' Turbine Building Fuel Handling Bldg RAD WASTE BUILDING RCA

SITE SPECIFIC RADIATION PROTECTION TRAINING JUNE 2008 PAGE 3 REV. 13 III. RADIOLOGICAL CONTROLS POSTED WITHIN RCAs Radiation Protection (RP) uses a standard posting method called C-A-R. The CAR posting uses three (3) colored inserts in descending order (from top down) for Contamination, Airborne, and Radiation, respectively. These contamination, airborne, and radiation inserts on postings use a simple colored scheme as follows:

1. Green - refers to little or none present (i.e., good to go)

2. Yellow - refers to low to medium levels (i.e., caution, contact RP if you are unsure of the requirements or precautions)

3. Red - refers to high levels present (i.e., warning, contact RP before entering)

For contamination, green means it is clean

(<1000 dpm/100cm2), yellow means <100,000 dpm/100cm2, red is >100,000 dpm/100cm2 or discrete particles present.

For airborne, green means none present, red means it is an airborne area (airborne will not have a yellow insert).

For radiation, green means <5 mr/hr, yellow means 5 - 100 mr/hr, and red means over 100 mr/hr (i.e., a high or locked high rad area).

Definitions:

A. Radiation Area: An area accessible to personnel with radiation levels that could result in an individual receiving a deep dose equivalent (DDE) of greater than 5 mrem in one hour measured at 30 cm (about 12 inches) from the radiation source or from any surface which the radiation penetrates. Posted as a yellow insert in the bottom (lowest) place of a CAR posting.

B. High Radiation Area (HRA):

1 An area accessible to personnel with radiation levels that could result in an individual receiving a DDE of greater than 100 mrem in one hour measured at 30 cm (12 inches) from the radiation source or from any surface that the radiation penetrates.

Posted as a red insert in the bottom (lowest) place of a CAR posting.

2. Area is also posted with a HRA pink stop sign with white lettering.

Workers need the following additional protection:

a. An alarming dosimeter preset to an integrated radiation dose and be knowledgeable of the conditions.

OR

b. An accompanying Radiation Protection technician with a dose rate monitoring device.

SITE SPECIFIC RADIATION PROTECTION TRAINING JUNE 2008 PAGE 4 REV. 13 C. Locked High Radiation Area (LHRA):

1. An area accessible to personnel with radiation levels that could result in an individual receiving a DDE of greater than 1000 mrem PER HOUR measured at 30 cm (~12 inches) from the radiation source or from any surface that the radiation penetrates.

Posted as a red insert in the bottom (lowest) place of a CAR posting.

2. Areas are normally locked.

Radiation Protection Foremen have keys.

3. If not locked, areas must be posted with a LHRA pink stop sign with black lettering and flashing yellow/amber warning lights.

4. A Radiation Protection technician is required for continuous coverage.

D. Very High Radiation Area (VHRA):

1. An area accessible to personnel with radiation levels that could result in an individual receiving an absorbed dose of greater than 500 rads in one hour measured at one meter from the radiation source or from any surface that the radiation penetrates.

2. VHRA will be locked and posted with GRAVE DANGER warning signs.

3. There will be no entry into these areas.

E. Radioactive Materials Area:

Any area storing licensed radioactive material exceeding 10 times the quantity listed in App. C of 10 CFR

20.

F. Airborne Radioactivity Area:

An area where airborne contamination is 1.0 DAC or greater.

We normally post airborne areas at DCPP at 0.3 DAC. If airborne is present, a red insert is used in the middle place of a CAR posting.

G. Contamination Area (CA):

1. An area where the smearable contamination exceeds 1000 dpm/100cm 2 beta/gamma; or 20 dpm/100 cm 2 alpha. If contam-ination is present, but less than 100,000 dpm/100 cm 2 a yellow insert is used in the top place of a CAR posting. If contamination is greater than 100,000 dpm/100 cm 2 a red insert is used in the top place of a CAR posting.

2. Step-off pads and personal frisking provide contamination control at CA boundaries. (Single step-off pads are not contaminated at DCPP).

3. Radiation Work Permits list the type of protective clothing that is required.

Note: Radiation work permits are covered in Section VI.

4. Properly remove protective clothing at the CA boundary and perform a frisk as instructed by the postings on the step-off pad.

H. Discrete Particles:

1. Discrete particles can exist within a CA. These CAs will use contam-ination area signs (with a red insert at the top).

SITE SPECIFIC RADIATION PROTECTION TRAINING JUNE 2008 PAGE 5 REV. 13 I. Other Radiological signs:

1. Hot Spot signs are posted to warn personnel of areas to avoid (source of radiation exposure).

2. DCPP also uses Localized Radiation signs, indicating an area that has a substantially higher dose rates than the surrounding areas, but which does not meet the definition of a hot spot.

These are usually large tanks or pipes containing radioactive water.

3. In contrast, Cold Area signs are posted in areas where personnel should hang out within a given area (e.g., to read, take notes, talk things over, etc.).

4. Radiological Conditions changed -

a sign used to alert workers to emphasize that some aspect of radiological conditions has changed.

IV. EXTERNAL EXPOSURE LIMITS A. The NRC has exposure limits which DCPP must not exceed, therefore DCPP has administrative exposure limits (set at 90% of the NRCs limits) for radiation workers:

1. Whole Body Dose of 4.5 rem TEDE per year with an administrative guideline of 2.0 rem TEDE per year.

2. Extremity limit of 45 rem/yr.

3. Skin limit of 45 rem/yr.

4. Organ limit of 45 rem/yr.

5. Eye limit (lens of eye) of 13.5 rem/yr.

You are responsible to ensure no limit is exceeded.

B. Total accumulated lifetime occupational exposure (TEDE) should not exceed the numerical value (in rem) of an individual's age (in years). DCPP employees who have already exceeded their age-adjusted lifetime dose limit should be restricted to 1 rem TEDE per year.

C. Emergency exposure limits for rad workers fall under Environmental Protection Agency (EPA) Guidelines.

1. Authorization: Emergency limits may be authorized by:

a. The Site Emergency Coordinator.

b. The Recovery Manager.

2. Emergency Exposure Limits:

a. 10 rem TEDE for protective action.

b. 25 rem TEDE for life saving action.

HOT SPOT R

HR LOCALIZED RADIATION NO LOITERING IN THIS AREA THE RADIATION LEVEL HERE IS THE LOWEST IN THIS AREA CAUTION RADIOLOGICAL CONDITIONS HAVE CHANGED READ AND COMPLY WITH POSTINGS BEFORE ENTERING THIS AREA

SITE SPECIFIC RADIATION PROTECTION TRAINING JUNE 2008 PAGE 6 REV. 13 D. Prenatal Exposure:

1. For Declared Pregnant Workers, radiation dose is limited to 450 mrem during the term of the pregnancy, and, to the extent practical; the exposure will be distributed evenly over the term of the pregnancy.

2. This limit applies IF a worker has declared her pregnancy. The declaration must be in the form of a written statement to the Radiation Protection section.

3. It is the right of the female NOT to limit exposure (i.e., no written declaration of pregnancy is made) during this period if she so desires.

A pregnant female may change her status (declared/not declared) at any time during the pregnancy.

4. If you have concerns or need more information on pre-natal issues, you may call the Radiation Protection (RP) managers secretary at 4325 to arrange an appointment to discuss your concerns with an RP engineer.

V. PERSONNEL DOSIMETRY A. To obtain your dosimetry (after passing through the search train and leaving the security building) pick up your TLD from the slot with your keycard number from the Administration Building Annex. Your TLD needs to be attached to either a lanyard clip or a dosimetry plastic orientation card. Stop and look to make sure it is yours by checking for your name on the TLD label. It is your responsibility to check for your own TLD for RCA access.

B. Each person entering the RCA shall wear appropriate personnel monitoring devices according to their radiation work permits. This normally consists of both a TLD (see below), and a Personal Electronic Dosimeter or PED (see next page).

C. TLD - Thermoluminescent Dosimeter.

1234567 01/01/99

1. To be worn on the front upper third of the body unless directed otherwise by Radiation Protection.

The TLDs clip should be facing towards the body (i.e., beta window facing away from the body).

2. If your TLD is lost or damaged, leave the RCA immediately and notify Radiation Protection.

3. TLDs will normally be read once per quarter, or when an employee (or visitor) no longer needs RCA access.

SITE SPECIFIC RADIATION PROTECTION TRAINING JUNE 2008 PAGE 7 REV. 13 D. PEDs - Personal Electronic Dosimeters:

Diablo Canyon uses Siemens brand PEDs which are normally issued at access control. They have the ability to measure both gamma and beta radiation dose.

1. Check to make sure your PED reads zero when you receive it (the PED should have a digital reading of 0.0)

2. Wear the PED next to your TLD; the PED must also be worn with the clip facing towards the body.

3. You should check the reading on your PED about every 15 minutes. If lost or damaged, exit the RCA immediately and notify Radiation Protection.

4. If you are approaching your guideline dose per entry as specified on your radiation work permit, you need to leave the RCA. The PED will alarm continuously if you reach your guideline dose.

5. The PED also has the ability to measure dose rates and will beep rapidly when the wearer enters an area where the dose rate is 80% of the maximum allowed by the radiation work permit. Backing away from the high dose rate area will silence the alarm.

VI. ENTERING AND EXITING THE RCA A. Dosimetry Office requirements include:

1. Signed Radiation Exposure History.

2. Your previous exposure records if available.

3. A Whole Body Count (this can be waived).

4. Form NRC-4.

B. Radiation work permits are the written authorization (cover the RP requirements) for entry into the RCA.

1. Routine Work Permit (RWP)

a. RWPs are located at Access Control. They govern routine work in the RCA.

b. Workers must sign an RWP the first time they use it, after any revision, and quarterly. Their signature indicates they have read, understood, and will comply with the RWP.

C. General procedure for RCA entry:

1. Ensure you are authorized for entry.

Read and sign the appropriate RWP/SWP with an RP technician at access control.

2. Log in at a self-serve RCA access computer terminal. This involves taking a PED (from the rack on the wall) and placing it into one of the computer terminal PED readers.

Next, place the bar code on your keycard in front of the laser scanner, and then enter the RWP/SWP number using the keypad. When prompted, place the bar code on your TLD into the laser scanner.

SITE SPECIFIC RADIATION PROTECTION TRAINING JUNE 2008 PAGE 8 REV. 13 When the computer screen turns to a green PROCEED screen, then remove your PED.

3. A last check to ensure that you are legal to enter the RCA is the RCA entry turnstile. To go through this turnstile, simply place your PED into the vertically mounted PED reader at the turnstile. The reader checks that the PED is functioning, and if so, a red light goes out while a green light turns on. You will also hear a click indicating the turnstile is free to rotate for 1 person to enter. Simply walk through the turnstile to enter the RCA.

4. Entry into High Radiation Areas may require additional dosimetry, etc., as indicated on the RWP/SWP.

Contamination Area (CAs) entries will require the use of protective clothing. Ask the RP technician at access control for assistance with any of the above requirements (always contact RP before entering any posted area having a red insert).

5. Workers are responsible for following the RWP requirements and llimitations.

6. Workers are responsible for notifying RP immediately if conditions change significantly, if they cant comply with the RWP, or other radiological problems arise.

D. Procedures for RCA exit

1. When leaving a Contamination Area (CA), properly remove any protective clothing and follow the frisking instructions on the step-off pad.

2. You must remove all items from your pockets for contamination monitoring by a Radiation Protection Tech before stepping into the PCM at the RCA exit.

3. Use the PCM-1B Half Body Frisker to check for contamination when leaving the RCA.

SITE SPECIFIC RADIATION PROTECTION TRAINING JUNE 2008 PAGE 9 REV. 13 PCM 1-B

a. If you alarm the PCM 1-B, finish your frisk and then try another PCM 1-B.

b. If you alarm the PCM 1-B during the second frisk, finish your frisk and a Radiation Protection Technician will assist you.

4. To log out of the RCA, first place your PED into one of the computer terminal PED readers. Next, place the barcode on your keycard in front of the laser scanner. When the computer screen turns to a green PROCEED screen, then remove your PED and return it to the rack on the wall.

E. Area Radiation Monitors:

1. These detectors measure general area gamma radiation dose rates.

2. The alarm is a constant, high-pitched squeal; a red light actuates simultaneously.

3. Upon hearing the alarm:

a. Proceed immediately to Access Control.

b. Inform Radiation Protection Personnel.

F. Constant Air Monitors (CAM):

1. These units constantly monitor airborne radioactivity.

2. The alarm is a rotating red light accompanied by a bell or horn.

3. Upon hearing the alarm:

a. Proceed immediately to the nearest area of known low airborne radioactivity.

b. Inform Radiation Protection personnel.

G. Unfamiliar Alarm:

Proceed immediately to Access Control and report the alarm to Radiation Protection.

H. Emergencies in the RCA:

Emergencies (including significant personnel injuries requiring immediate first aid) always take precedence over normal radiation and contamination controls.

SITE SPECIFIC RADIATION PROTECTION TRAINING June, 2008 (Rev. 13)

PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT SELF-PACED Radiation Protection Training Course: GPAA-102 Date:

I have read and will comply with the preceding instructions. I understand this training is only sufficient to allow me to observe non-hazardous work activities.

I am not allowed to perform any "hands-on" work or work with any hazardous materials.

Should it become necessary for me to perform or observe any hazardous work, such as handling toxic chemicals or entering confined spaces, I will contact plant management to ensure I am properly trained before hand.

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GPAA-101 Self-Paced Protected Area Access Training INSTRUCTIONS:

This handout provides abbreviated training for unescorted access into the Protected Area. If you have questions or comments about this handout, please feel free to contact the DCPP General Employee Training Group.

AUGUST 2009 (Rev. 15)

NPG LEARNING SERVICES AUGUST 2009 1 OF 18 REV. 15 OBJECTIVE #1 State the methods used to implement the AA and FFD program.

OBJECTIVE #2 Identify the three types of Security Areas, the types and purposes of the keycards used at DCPP, including how they are worn, and what action to take if they are lost.

OBJECTIVE #3 Explain escort responsibilities, including the procedure ror transferring escorts, and actions when an Unescorted Visitor is encountered.

OBJECTIVE #4 Identify the alarms associated with a fire emergency, actions required upon discovery of a fire, and describe the correct response to each.

OBJECTIVE #5 State the appropriate use for each communication system at DCPP.

OBJECTIVE #6 Describe the emergency alarm associated with DCPPs emergency plan and your required response.

OBJECTIVE #7 List the four Classifications of Emergencies incorporated into the Emergency Plan at DCPP.

OBJECTIVE #8 Identify safety barriers, signs, labels, and state worker responsibility for adherence to permits and safety instructions.

OBJECTIVE #9 State the colors and symbols used on radiological postings that identify radiological areas and your actions should these areas be encountered.

OBJECTIVE #10 Identify and state the difference between a hazardous material and a hazardous waste.

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 2 OF 18 REV.15 INTRODUCTION This handout addresses Plant Layout and Administration, Radiation Control Standards and Procedures, Fire and Industrial Safety, Fitness For Duty, Security, Hazardous Materials/Waste Handling, Quality Assurance and Emergency Plan response.

Collectively, these information sources contain the minimum knowledge an individual in a observatory capacity must have to ensure personal safety and the safety of others. This instruction is not sufficient to allow close observation of potentially hazardous activities, such as welding, toxic chemical handling, live electrical work, and confined space entries. This instruction does not allow for any independent work activities or any "hands on'" work to be performed.

A brief quiz may be required (after reading this handout) to ensure adequate comprehension of this material.

This instruction is for an individual who possesses generic nuclear power plant knowledge and thus it is generally less in scope than normal training for unescorted access to the Plant Protected Areas (or Radiological Controls Areas). Only the plant specific standards and procedures for proper conduct as an observer are covered in this handout.

Table of Contents Topic Page number Fitness for Duty 5

Security 6

Enter/Exiting the PA 7

Escorting visitors 9

Vehicle rules 10 Fire Protection 10 Emergency Plan 12 Safety 13 Hazardous Material 15 First Aid 15 Quality Programs 16 Checklist 17

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 3 OF 18 REV. 15 MAJOR SECTIONS AND THEIR LOCATIONS (See map on next page)

Learning Services (#11,#18)

Bldgs. 109/119 Mech. Maint. Shop (#15)

U-2 Cold Machine Shop Elect. Maint. Shop (#15,#6)

U-2 Cold Machine Shop and TM Shop I&C Shop (#6)

TM Shop Hot Shop (#5) 140' Fuel Handling Bldg.

Radiation Protection (#5) 85' Aux. Bldg. Center, West Control Room (#5) 140' Aux. Bldg. Center, West Security Offices (#9)

South entrance, Protected Area NRC Office (#8)

Admin. Bldg., 5th Flr., East End Document Control (#8)

Admin. Bldg., 4th Flr., Center Work Planning Ctr. (#8)

Admin. Bldg., 2nd Flr., South Human Resources (#8)

Admin. Bldg., 3rd Flr., East End Emergency Planning Emergency Opeations Facility (EOF)

Safety (#8)

Admin. Bldg., 4th Flr., SE corner Quality Assurance/Quality Control (#8)

Admin. Bldg., 3rd Flr.

Medical Facility (#6)

TM Shop, 1st Flr.

Access/Dosimetry (#18)

Maintenance Shops Bldg. #119, 1st Flr. East Reg. Compliance (#8)

Admin. Bldg., 5th Flr., East Technical Support Center (#29)

South Buttress Bldg., 2nd Flr.

Plant Management (#8)

Admin. Bldg., 5th Flr., West

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 4 OF 18 REV. 15 LOT 1 LOT 8

LOT 7 LOT 2 LOT 4

LOT 6 LOT 5 LOT 9

13 1

2 3

4 5

6 7

10 12 15 16 17 19 20 21 22 23 23 24 25 26 27 28 31 30 29 To 500KV Switchyard xxxxxxxxxxxxxxxxxxx x

x x

x x

x x

x x

x x

x x

x x

x x

x x

x x

xxxxxxxx xx x

x x

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xxxxxx x

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8 14 27

1. Construction Offices

2. Construction Security

3. Security Badge Control Center

4. Eng. services

5. Power Block/Auxiliary Bldg

6. I&C/T-Com/Medical Facility

7. Discharge Structure

8. Administration Bldg

9. Security Bldg

10. Intake Structure

11. Learning Services/Simulator

12. Turbine Generator Equip Whse

13. Whse B

14. Main Whse

15. Unit 2 Cold Machine Shop

16. Laundry and Radwaste Bldg

17. Auxiliary Boiler Enclosure

18. Learning Services Shop Bldg

19. Construction Fabrication Shop

20. Haz Mat Whse

21. Gas Cylinder Storage

22. Biology Lab

23. FFD Facility

24. Oceanography Lab

25. Building Mechanic Shop

26. Whse A

27. Haz Waste Handling Facility

28. Blast & Paint Facility

29. Turbine Bldg

30. U-1 Containment

31. U-2 Containment xx Permanent RCA

== Protected Area Fence Emergency Assembly Area N

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 5 OF 18 REV. 15 I. FITNESS FOR DUTY (FFD)

Federal Law (10 CFR 26) requires that each utility licensed to operate a nuclear facility establish a written FFD policy that will:

provide reasonable assurance that station personnel will perform their duties in a reliable and trustworthy manner and are not under the influence of any substance, legal or illegal, or mentally or physically impaired from any cause which in any way may adversely affect their ability to safely and competently perform their duties have a goal to create an environment free of drugs, alcohol, and their effects provide reasonable measures for the early detection of persons who are not fit to perform duties within the scope of the program provide individuals with assistance for FFD-related problems IMPLEMENTATION OF FFD PROGRAM The primary tools used to implement FFD are:

1. Drug/chemical testing,

2. Employee Assistance Program (EAP)

3. Behavioral Observation.

4. Training All employees are expected to be alert for aberrant (abnormal) behaviors. This includes behaviors considered inappropriate at a nuclear facility (e.g., the DCPP incident in which a realistic looking fake bomb was constructed as a prank).

Report aberrant behaviors (e.g., smell of alcohol on someones breath) to your supervisor or site contact immediately.

CHEMICAL TESTING

1. Pre-access samples to be conducted within 30 days prior to granting unescorted access.

2. Random testing will be conducted at various times of the day, night, weekends and holidays.

3. For cause testing will be conducted as soon as possible following any observed behavior indicating possible substance abuse or industrial accident.

4. Follow-up testing will be conducted for any employee who has been reinstated after testing positive for drugs or alcohol to verify continued abstinence from the use of drugs or abuse of alcohol.

SEARCHES Personnel, vehicle, and work area searches may be conducted at any time. These searches may be conducted only with the approval of the Plant Manager.

DCPP FFD PROGRAM POLICIES The sanction for violating the FFD program policy is suspension of site access as a minimum. Severe program violations may result in permanent revocation of site access.

Workers must abstain from alcohol at least 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> prior to scheduled work. A blood alcohol concentration (BAC) of 0.04% is considered unfit for duty (i.e., a confirmed positive).

DCPP policy is that prescription medications should be kept in their original container, OR, you carry a copy of your prescription. Notify your supervisor or contact if you are taking any medications (even over-the-counter) that may affect your FFD (i.e., cause drowsiness).

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 6 OF 18 REV. 15 DCPP has a Work Hour Controls program in accordance with 10CFR26. If you are a visitor or NRC, you are a NON-COVERED worker.

II.

SECURITY PURPOSE Federal regulations (10 CFR 73.55) requires PG&E to establish and maintain an on-site physical protection system in order to:

1. protect plant personnel

2. prevent radiological sabotage

3. guard against theft of nuclear material THREE TYPES OF SECURITY AREAS

1. Owner Controlled Area Starts at the Avila main gate.

2. Protected Areas The main plant protected area.

The intake protected area.

3. Vital Areas Located inside the protected areas.

Contain systems important to the safe operation and shutdown of plant.

Access requires use of keycard with proper security access level.

TYPES OF SECURITY OFFICERS Site Access Officers - man the main gate and assist in traffic control (only during normal work hours in non-outage periods, continuously during outages).

Nuclear Security Officers - man the Security Building and monitor the protected area boundaries, carry weapons and respond to security violations.

Alarm Station Operators - man the alarm stations, monitor for security violations and dispatch officers to respond to alarms.

DCPP SECURITY POLICIES:

Individuals with unescorted access authorization are responsible for informing the access office of any arrests, past, present or future (10 CFR 73.56).

In addition, employees must report any malicious or suspicious activities (e.g.,

sabotage), bomb threats, or tampering immediately to security at 3330.

The following items are prohibited from the Owner Controlled Area (plant site):

1. Firearms

2. Explosives

3. Illegal drugs

4. Alcohol Pepper spray and mace are permitted on the plant site but must be left in employees vehicles (i.e., do not bring pepper spray or mace into the protected area).

Cellular phones are prohibited from all power block buildings.

Photography is permitted for business purposes only. Unauthorized photography will result in confiscation of film or erasure of photo files.

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 7 OF 18 REV. 15 III. ENTERING and EXITING THE PROTECTED AREA (PA)

SEARCH TRAIN All entries into the protected area require first going through the search train. The security search train consists of three separate detectors.

Explosives Detector Metal Detector X-ray (For all hand carried items)

If the explosives detector alarms, the process is repeated. If the detector alarms again, you will be asked to consent to a pat search. Pat searches are voluntary. If consent is not given, protected area access is denied.

If the metals detector alarms, empty as much metal off your person (and place on the X-ray conveyor belt) before going through the metals detector again. This process can be repeated several times. Continued failure requires consenting to a manual search with a metal hand wand otherwise access will be denied.

Diablo Canyon uses one style keycard for all unescorted personnel. The keycard has your picture on the face. This keycard has two functions:

1. Identification - Your keycard picture should accurately reflect your appearance. If your appearance has changed, please have your picture updated.

2. Access level - The magnetic strip on the back has your keycard number encoded on it. This number is transmitted to the computer that will verify access for the area into which you are keycarding.

OBTAINING YOUR KEYCARD New employees (or visitors) must first enroll in the handreader system. Bring two picture identifications (e.g., new keycard and drivers license) to the security counter next to the search train to enroll.

PROCESSING THROUGH PA ENTRY TURNSTILES Verify the red light on the card reader is flashing slowly (this indicates the reader is operable and ready to process a card).

Present your keycard to the card reader by holding it steady within two to three inches from the face of the reader.

The position lights on the hand reader will illuminate and the display window will read, "place hand."

Place your hand on the platen against the metal stop pegs.

If you have placed your hand properly, the lights on the position diagram will go out. The display window should read "ID VERIFIED". You will see a GREEN light on the HAND READER and hear a click, which means the computer has unlocked the turnstile.

Enter and push the turnstile forward, it will automatically stop once you are through.

If any problems are encountered or access is denied, notify a security officer in the access area.

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 8 OF 18 REV. 15 WORKER RESPONSIBILITIES REGARDING KEY CARDS Keycard must be in your possession at all times while on site.

Keycard is to be attached on a lanyard, and worn on the front upper third of the body of the outermost garment.

If, while in the plant, you discover your keycard is missing, notify security immediately at Ext. 3330.

If you notice someone on site without a keycard (or site/visitor badge), ask him or her where it is. If they cannot locate it, notify security immediately at Ext. 3330.

EXITING THE PROTECTED AREA Re-rack your TLD (if used) into the slot that corresponds to your keycard number at the administration building annex.

At the Security Building, you will pass through a turnstile requiring use of your keycard.

When you are ready to leave site for the final time, turn your keycard in at the last day drop box as you are exiting the Protected Area.

Exit the Security Building through the portal radiation monitor and free spinning turnstile.

APPROVED WAY TO ENTER CARD-READER CONTROLLED AREAS Card readers control many of the doors in the plant, including vital areas. The process to enter is similar to that of the Security Building turnstiles Stand in front of the card reader and verify the red light is flashing slowly Present your keycard to the reader by holding it steady within two to three inches from the face of the reader.

You will hear a quick chirp when the reader "reads" the keycard, followed quickly by a short then long chirp and a flashing green light on the reader. You must see a flashing red light prior to presenting your card or you will not be properly logged into the area.

Proceed through the door.

You will see a flashing green light and hear a click or buzz, which indicates the security computer has unlocked the door.

Simply push or pull the door open without turning the doorknob.

If access is refused, you will get a short chirp when the card reader "reads" the keycard followed quickly by three long chirps and a solid red light. If refused access (i.e., you receive a solid red light),

do not proceed through the door. Stop and call security at extension 3193.

Going through a card reader controlled door without properly using your keycard is called tailgating, and is a security violation.

DO NOT turn the doorknob to open or shut the door. Allow the door to close on its own, all plant doors have hydraulic closers, which will automatically close the door. Do not help push or pull doors shut. After going through the door, unless others are coming through after you, allow the door to fully close on its own, then challenge the door (i.e. push or pull on it to ensure it is latched and secured).

If a door is not fully latched and secured, after 10 seconds there will be a series of audible chirps. This chirping will last approximately 10 seconds. This sound is to assist you in ensuring the door is secured properly before security receives a door alarm at that location.

IV. ESCORTING VISITORS

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 9 OF 18 REV. 15 If you have unescorted access to the Protected Area (PA), then you are eligible to escort visitors wherever you have access.

y First, you must obtain an escort pass and a visitors keycard, issued at the security information counter, for each person you are escorting.

y Assist the escorted personnel through the search train. After picking up your keycard, tell the security officer in the area that you need to escort in personnel. The officer will assist you.

y Keep your visitor(s) within eyesight and speaking distance the entire time that you are in the protected area, including the administration building (with the exception of restrooms that have only one way in or out).

To transfer escort responsibilities, simply have someone sign and take possession of the escort pass that now makes them responsible for the visitor(s).

The escort must notify Security immediately at Ext. 3193 if s/he becomes separated from a visitor.

y A person may escort up to 10 people in non-vital areas, but only up to five people in vital areas.

When going through card reader controlled doors (or turnstiles), within the PA, only the escorts keycard is used.

When exiting the PA, the visitor(s) must use their keycard(s) first, then the escort follows the visitor(s) out of the PA. Remember, the only time a visitors keycard is used is when exiting the PA.

y Once inside the exit vestibule, drop off the escort passes, the visitors keycards, and see the visitors through the exit turnstiles.

Once they are out of the protected area they no longer need escorting.

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 10 OF 18 REV. 15 V. VEHICLE OPERATION

1. Vehicle Pass:

a. Temporary vehicle passes are issued to previously cleared vehicles at the Avila Main Gate.

b. The Access Authorization Office located in the Maintenance Shop Building will issue permanent vehicle passes to workers.

c. A vehicle pass is to be used only by the person to whom it has been issued.

d. During non-outage periods, Security officers only man the Avila Gate during normal work hours. Site visits outside of these normal work hours requires the use of a vehicle keycard to activate the automated gates when entering. The gates automatically open to all exiting vehicles. Consult your plant contact for more information if needed.

e. ALL vehicle passes must be displayed in the vehicle AT ALL TIMES while the vehicle is on site.

f. Lost passes must be reported immediately to the Badging Office.

2. Diablo Ocean Drive (the access road):

a. The access road has posted speed limits. The maximum speed limit is 50 MPH and in some areas the speed limit is lower. Speed limits are radar enforced.

b. PASSING IS PROHIBITED on the Access Road.

c. Turnouts should be used by slow vehicles when necessary.

d. Do not stop on the access road except in an emergency.

e. Drivers and passengers must stay with broken down vehicles until assistance is rendered.

3. Parking Lot Regulations:

a. Speed limit: 5 MPH.

b. Park only in MARKED vehicle parking areas. RIDE SHARE spots are reserved for authorized car pools. DO NOT park in driving lanes or other areas not designated for parking.

VI. FIRE PROTECTION Smoking Areas: Smoking is prohibited indoors in general, unless an area is clearly posted as a DESIGNATED SMOKING AREA. Smoking is also prohibited in some outdoor areas such as flammable or combustible liquid storage areas, the RCA, and wherever posted as a 'NO SMOKING AREA'.

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 11 OF 18 REV. 15 FIRE FIGHTING The plant Fire Brigade performs fire fighting at DCPP. Assistance of the California Department of Forestry/San Luis Obispo County Fire Department is available.

To report a fire:

1. Go to the nearest telephone in a safe area.

2. Dial 779 to report the fire.

a. Stay on the line.

b. The control room will answer. The fire alarm will sound after 4 rings if not picked up.

c. Report the fire location (usually posted on an engraved sign next to the plant phone), any personnel injuries, and the nature of the fire if you know it. Indicate any probable hazards.

3. The Fire Brigade will come and fight the fire.

Plant Fire Signal - (and Medical Emergencies):

1. A 30 second monotone signal.

Tested every Thursday at 12:05 PM

2. When you hear this alarm, check to see if the fire is in your vicinity. If it is not, continue working. A public address system will announce the fire location. If the fire is in your area, stay calm and evacuate the area (best to leave the building). If a fire is in your area and you are in the RCA, then report to Access Control for instructions on exiting the RCA.

FIRE PROTECTION SYSTEMS The major fire protection systems include:

1. Total Flooding CO2 Systems: rooms protected by this system are flooded with CO2 automatically when heat-sensing devices within the rooms cause the system to activate. A 30 second pre-discharge alarm (a shrill siren) warns personnel in the room of imminent discharge. Leave the building immediately if the pre-discharge alarm sounds. The system is also equipped with a wintergreen odorizer to warn personnel that a discharge has taken place.

2. Halon 1301 System: This fire suppression system is installed in areas where electrical, communications, and computer equipment are concentrated. It also has a 30 second pre-discharge alarm (a two-tone alarm). Leave the building immediately if the pre-discharge alarm sounds.

3. Sprinkler systems, hand-held hose reels and fire extinguishers are also available for fire suppression.

The key to fire protection is still fire PREVENTION. YOU ARE THE KEY TO FIRE PREVENTION.

DCPP COMMUNICATIONS SYSTEMS

1. The public address system at DCPP is only used for emergencies by the control room, security, and upper management.

2. The normal means of contacting a supervisor or co-worker is by using a digital pager. We have no Gai-tronics system.

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 12 OF 18 REV. 15 VII. EMERGENCY PLAN The purpose of the DCPP Emergency Plan is to protect the health and safety of site workers and the general public in the event of a radiological emergency.

DCPP personnel who have specific responsibilities to respond to and mitigate emergency conditions are classified as Emergency Response Personnel.

Personnel who are not required for response during an emergency are classified as Non-Emergency Response Personnel. The training you are receiving now is for Non-Emergency Response Personnel.

In general, if a radiological emergency is declared at DCPP, all Non-Emergency Response Personnel should follow the instructions provided by:

The Public Address System.

Radiation Protection personnel.

Security personnel.

Other designated Emergency Response personnel.

If the Site Emergency Signal sounds and you are unsure whether it is a drill or a real emergency, then you must treat it as the REAL THING! Public address announcements follow the sounding of the Site Emergency Signal so you will quickly become aware if it is only a drill.

A. Site Emergency Signal:

1. An electronic warbler that sounds a series of falling tones. Flashing red lights are provided in high background noise areas.

Tested every Thursday at 12:10 PM

2. If you are in the RCA, exit the RCA, and proceed to your designated assembly area (normally the security building).

B. Containment evacuation signal:

1. This signal alarms only inside containment and uses the same lights and electronic warblers as the Site Emergency Signal.

VIII. EMERGENCY CLASSIFICATIONS The four emergency classifications in order of severity (least to most) are:

1. Unusual Event.

2. Alert.

3. Site Area Emergency.

4. General Emergency.

1. An Unusual Event is a situation in which potential degradation of the level of safety in the plant exists. No release of radioactive materials is anticipated unless the severity of the situation increases.

Normally no response is required from personnel not directly involved with the event.

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 13 OF 18 REV. 15

2. An Alert is a situation in which there has been some degradation of the level of safety in the plant.

All onsite and offsite Emergency Response personnel groups are activated.

3. A Site Area Emergency is a situation in which major failures of plant functions needed for protection of the general public have occurred.

Any releases of radioactive materials are not expected to exceed EPA Protective Action Guidelines outside the immediate site area.

The site emergency signal is normally sounded at the Site Area Emergency level or higher.

Personnel should assemble at their normal work location (i.e., where they normally report at the beginning of their shift).

4. A General Emergency is a situation in which there has been substantial reactor core degradation with potential loss of containment integrity.

Releases of radioactive materials can be reasonably expected to exceed EPA Protective Action Guidelines outside the immediate site area.

Visiting NRC inspectors should check with the senior resident NRC inspector on where to report during an emergency.

Escorted visitors should be taken out of the power block (preferably back to their escorts normal reporting location).

IX. DISMISSAL OF NON-EMERGENCY RESPONSE PERSONNEL The preferred method of dismissing non-emergency response personnel during an emergency is through an Early Work Release. This is an orderly drive out the normal access road when no release of radioactivity has occurred.

Once a release of radioactive material has occurred, an Evacuation is necessary.

Personnel will be directed which access road from the plant (North or South) to take, and where to assemble to be checked for possible radioactive contamination.

Lastly, concerning the release of information to the news media during an emergency, we expect all plant personnel to direct any inquires to the PG&E Managers in charge of the emergency. It is critically important that any news release be accurate and timely, hopefully preventing any undue panic.

X. SAFETY HAZARD BARRIERS AND WARNINGS Known hazards are posted as follows:

1. Yellow and Magenta ropes or tape identifies radiological areas. Do not cross these barriers unless you have passed the radiation control classes, are wearing devices to measure your radiation exposure, and are on a Radiation Work Permit.

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 14 OF 18 REV. 15

2. Yellow and black barrier tape:

identifies energized electrical hazard.

Do not cross these barriers. If your activities involve electrical observations, you may be allowed entry into electrical work areas with the consent of the lead electrical craftsperson, and by observing the personnel protective equipment required for the level of hazard as prescribed in the site electrical safety procedure OM6.ID12. Training on the electrical safety program is available on CBT if required.

3. Red and white barrier tape: indicates a general safety hazard. After identifying the hazard, you may go through the barrier with caution.

4. Yellow and magenta barrier tape/rope: identifies Radiological Controls Areas. You may not go through the barrier without proper training and written permission (on a radiation work permit).

5. Caution tape: Three inch wide yellow plastic tape with "CAUTION" imprinted in black. This barrier may be crossed once you evaluate the potential hazard.

6. Danger tape: Three inch wide red plastic tape with "DANGER" imprinted in black letters. This barrier must not be crossed due to extreme hazards.

EQUIPMENT TAGS Tags provide important information about equipment during the Clearance Process.

1. A CLEARANCE is a written work authorization to remove plant equipment from service, rendering it safe to perform work/maintenance.

2. DANGER TAGS: Danger Tags indicate a clearance point.

Components with a Danger attached should not be operated in any way or physically removed.

3. RED TAGS: These tags are hung with Danger Tags. They are part of the work order to further ensure worker safety while working on cleared equipment.

4. CAUTION TAGS: Indicate that tagged equipment shall not be operated without specific permission from the person whose name is on the tag.

If you ever find any of the above tags unattached to plant equipment, call the Shift Foreman at ext. 3600 PERSONAL PROTECTIVE EQUIPMENT Personal Protective Equipment (PPE) should be worn as recommended by the manufacturer. Lamicoid (i.e., plastic engraved) signs indicate areas where hard hats, frontal eye protection, and hearing protection are required.

Available PPE includes:

1. Hard hats: ALL PERSONNEL shall wear hard hats in posted areas.

2. Frontal eye protection: Required in posted areas. Company approved safety glasses or approved prescription glasses with side shields are considered acceptable frontal eye protection except when otherwise specified by your job.

(continued on next page)

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 15 OF 18 REV. 15

3. Hearing Protection: All personnel must wear earmuffs or earplugs in posted areas during equipment operation. Personnel may also wear hearing protection in non-posted areas if the noise levels bother them.

4. Footwear: Personnel shall wear appropriate shoes or boots in the plant or construction areas. In general, high heels, open-toed sandals, or synthetic sneakers are not allowed in plant areas.

5. Protective Clothing: Wear clothing appropriate for the work performed and existing conditions. All-natural fiber or other fire-resistent clothing is required for electrical work. Long-sleeved shirts are required for working on or near energized equipment.

XI. HAZARDOUS MATERIALS /

HAZARDOUS WASTE Remember, this training is not sufficient for you to be directly involved with, nor directly observe any hazardous material evolutions. It is intended as Right to Know information in case you witness a hazardous material accident.

Hazardous Material is any material which might cause harmful effects to people or pose a threat to our environment.

Hazardous Waste is any hazardous material for which PG&E has no further use. All spilled hazardous materials as well as those hazardous materials intended for disposal or recycling are considered hazardous waste.

The key to proper handling and use of hazardous materials/waste at the job site is the worker, whose responsibility is to:

stay informed by reading the information on the manufacturer's label, DCPP green labels, and/or Material Safety Data Sheets (MSDS).

heed the instructions from pre-job briefings and the labels.

properly label (using DCPP green labels) all breakdown containers.

Spills: If you discover a spill, you should:

1. Report the spill by calling EXT. 779 and stay on the line.

2. Contain the spill (only if you are trained and cognizant of the material hazards), by damming it up, or placing a leaking container into another container.

3. Stay up wind and up hill of the spill.

XII. FIRST AID On site first aid facilities are provided.

Qualified personnel are available to give treatment and to maintain required records. If you discover an injured person, render first aid you are qualified to give without putting yourself at risk.

Report ALL injuries immediately no matter how minor. Treatment will be provided and the incident will be documented.

To report a medical emergency:

1. Dial 779.

2. Stay on the line.

3. Tell the Shift Foreman your location and the nature of the medical emergency. The location is normally posted next to most plant phones.

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 16 OF 18 REV. 15 Stay alert to your surroundings. Locate the Emergency Resources at your job site BEFORE starting the job. There are eye wash stations, showers, telephones, first aid kits, and emergency respirators throughout the plant. It is difficult to try to locate these resources during an emergency.

XIII. QUALITY PROGRAMS Pacific Gas and Electric Company, as owner and operator of Diablo Canyon Power Plant, is responsible for its safe operation. To fulfill this responsibility, PG&E has instituted comprehensive Quality Assurance and Quality Control Programs covering all safety-related aspects of plant design, construction, and operation.

Our Quality Assurance (QA) and Quality Control (QC) programs conform to federal requirements and also implement commitments made to the Nuclear Regulatory Commission. All activities affecting the quality of safety-related structures, systems, and components are strictly controlled.

It is the responsibility of all badged individuals (including visitors), to report potential or actual problems concerning Nuclear Safety.

PG&E and the NRC share the expectation that employees report problems to PG&E management or the Employee Concerns Program (ECP) first, before bringing problems to the NRC (unless an employee is unwilling to share problems with PG&E management). It is the companys responsibility to maintain an environment where employees feel comfortable bringing up problems without fear of reprisal or harassment.

The most efficient and expeditious method of reporting concerns is directly to PG&E supervision. The Employee Concerns Program (ECP) acts as an internal safety net for those instances where the employee is not satisfied with PG&Es actions, or for instances where the employee is not comfortable reporting the problem to PG&E supervision.

The NRC also serves as a safety net for reporting problems. All employees have the legal right to report problems to the NRC at any time.

The ECP may be contacted by:

Personal contact with the ECP Staff (Administrative Building, 3rd floor, cube 327)

Phone - x4994 (offsite 1-805-545-4994)

E-mail:

Onsite - DCPP ECP Hotline Offsite - ecphotline@pge.com or:

US Mail:

DCPP ECP 3/327 Bldg. 104 PO Box 56 Avila Beach, California 93424 XIV. Last Day at Diablo Important note: When your visit is complete, then on your last exit from the protected area (i.e., the last time you will need your keycard),

deposit your keycard in the Last Day Drop Box. This clearly marked drop box is just to the left of the second set of exit turnstiles when leaving the Security building. Please also inform your main DCPP contact, or call the Access and Badging office at 3040, that you are terminating your visit.

SELF PACED PLANT ACCESS TRAINING GPAA-101 AUGUST 2009 17 OF 18 REV. 15 CHECKLIST The following checklist will help you through the process of gaining access into the protected area.

____ Contact DCPP General Employee Training (GET) Department (x3029 or x3434) if you have any questions about this handout.

____ Sign the Acknowledgment Roster (next page) and take the quiz if required.

TRAINING REQUIREMENTS FOR PROTECTED AREA ACCESS:

____ You have read and understand this Handout.

BADGING REQUIREMENTS:

____ Keycard Picture: If this is your first visit, Access Authorization Office personnel will take your keycard picture (Badging is located in the Maintenance Shop Bldg.).

AUGUST 2009 18 OF 18 REV. 15 PACIFIC GAS AND ELECTRIC COMPANY DIABLO CANYON POWER PLANT SELF-PACED PROTECTIVE AREA ACCESS COURSE: GPAA-101 DATE:

I have read and will comply with the preceding instructions. I understand this training is only sufficient to allow me to observe non-hazardous work activities.

I am not allowed to perform any "hands-on" work or work with any hazardous materials. Should it become necessary for me to perform or observe any hazardous work, such as handling toxic chemicals or entering confined spaces, I will contact plant management to ensure I am properly trained before hand.

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