Text

Initial Exam 2010-302 Draft Administrative JPMs
	ML111020330
Person / Time
Site:	Brunswick
Issue date:	04/06/2011
From:	; NRC/RGN-II
To:	; Progress Energy Carolinas
References
	50-324/10-302, 50/325/10-302
	Download: ML111020330 (121)
	v • d • e

PROGRESS ENERGY CAROLINAS BRUNSWICK TRAINING SECTION JOB PERFORMANCE MEASURE ADMIN NRC ADMIN COO1 (RO/SRO)

LESSON TITLE: DC Ground Calculation REVISION NO: 2

DC Ground Calculation SPECIAL INSTRUCTIONS:

1. Provide marked up copy of 2OP-51, Section 8.1, DC Ground Isolation for Bus P, N and PN completed up to Step 10.

2. Provide a copy of Attachment 2, Data Sheet for Battery Ground Detection.

3. Provide a copy of Table 1, General Guidelines for Determining Which Bus Is Grounded.

4. A calculator should be made available to the trainee for required calculations

5. A copy of 0AI-155 available for SRO Candidates.

SAFETY CONSIDERATIONS:

1. None.

EVALUATOR NOTES: (Do not read to trainee)

1. The applicable procedure section WILL be provided to the trainee.

2. Point out the RO and SRO differences for JPM performance.

3. If this is the first JPM of the JPM set, read the JPM briefing contained in NUREG 1021, Appendix E, or similar to the trainee.

Read the following to trainee.

TASK CONDITIONS:

1. The Control Room has received annunciation of a ground on 125/250 VDC Battery Switchboard 2B.

2. The Turbine Building AO has reported the following Bus readings:

P Bus 0.46 mA.

PN Bus 1.51 mA.

N Bus 3.61 mA.

3. 2OP-51 Section 8.1 is complete through step 8.1.2.9.

INITIATING CUE:

You are directed to continue performance of 2OP-51, Section 8.1 and record the results of the following on the cue sheet.

1. Total resistance to ground for 125/250 VDC Battery Switchboard 2B,

2. The Battery Bus that is grounded.

3. Determine required actions to be taken for this ground level if it remains present. (SRO Only)

AOT-ADM-JP-051-05 Page 2 of 9 REV. 2

DC Ground Calculation ANSWER KEY

1. Total Resistance 16.3 K

2. Grounded Bus P

3. Required Actions (SRO Only)

1. Initiate a W/R for I&C to perform the following:

a. Inspect batteries and wipe down any spilled electrolyte.

b. Measure ground resistance.

2. Refers to 0AI-115 for the appropriate Action Level and Action Requirements.

3. Determines Action Level 1 (ground resistance 15k to 25k) Actions:

a. TBAO / RO Daily Check Sheet (DCS) item to perform ground checks once per shift.

b. Perform ground hunting / isolation activities around the clock until found or cleared.

0AI-115 Action Steps 6.2 Action Level 1 (<25k to >15k) 6.2.1 The ground current shall be measured once per shift per OP-51, to ensure that the ground resistance has not degraded to the Action Level 2 point.

6.2.2 Efforts shall be undertaken to isolate all circuits per OP-51 which can be isolated without affecting plant operation in an effort to locate the ground OR request maintenance assistance using ground detection equipment. Ground hunting will proceed in accordance with the requirements of ADM-NGGC-0104, Attachment 4, with an assigned priority of 2.

6.2.3 If the ground cannot be located as per 6.2.2 or ground hunting must be interrupted, notify the Manager - Operations. Additional ground hunting will be planned in accordance with the requirements of 0AP-025, considering the elevated risk.

6.2.4 Circuits identified with grounds should be corrected expeditiously, and if possible, placed under clearance while waiting correction.

AOT-ADM-JP-051-05 Page 3 of 9 REV. 2

DC Ground Calculation PERFORMANCE CHECKLIST NOTE: Sequence is assumed unless denoted in the Comments.

Step 1 - Obtains current revision of 2OP-51 Section 8.1 marked completed up to Step 10 and Attachment 2 marked up with initiating cue values and verify copy if applicable.

Current revision of 2OP-51 Section 8.1and Att. 2 obtained and verified if applicable.

SAT/UNSAT*

PROMPT: As SCO inform examinee that battery chargers 2B1 and 2B2 are both in FLOAT.

Step 2 - CONFIRMs data on Attachment 2 matches cue sheet.

Battery 2B readings match cue sheet values.

SAT/UNSAT*

Step 3 - PERFORMs calculation on Attachment 2.

Calculates 135 volts + 135 volts 50 K ohms = 16.3 K ohms 0.46 mA +3.61 mA

- CRITICAL STEP ** SAT/UNSAT*

Step 4 - Signs Attachment 2 as Performed by.

Signs and Dates Attachment 2.

SAT/UNSAT*

AOT-ADM-JP-051-05 Page 4 of 9 REV. 2

DC Ground Calculation Step 5 - Transfers Switchboard 2B resistance to ground value to cue sheet.

16.3 K ohms recorded on cue sheet.

SAT/UNSAT*

Step 6 - Determines grounded bus using Table 1.

Records P Bus as grounded bus due to P < N.

- CRITICAL STEP ** SAT/UNSAT*

TERMINATING CUE: When calculation is performed and the grounded bus is identified by being recorded on the cue sheet, the JPM is complete for RO candidates ONLY.

Comments required for any step evaluated as UNSAT.

PROMPT: Inform SRO candidates to determine actions required for this ground indication.

Step 7 - Recognizes ground to be less than 25 K.

Determines a Work Request is required to be written for I&C to inspect and wipe down batteries of any spilled electrolyte and to measure ground resistance SAT/UNSAT*

Step 8 - References 0AI-115 to determine Ground Action Level and required actions.

Determines ground value currently falls under Action Level 1.

- CRITICAL STEP ** SAT/UNSAT*

AOT-ADM-JP-051-05 Page 5 of 9 REV. 2

DC Ground Calculation Step 8a - Documents Action Level 1 Actions on cue sheet.

Determines ground current measurements are required once per shift to ensure Action Level 2 threshold is not entered.

- CRITICAL STEP ** SAT/UNSAT*

Step 8b - Documents Action Level 1 Actions on cue sheet.

Determines ground hunting / isolation activities are required.

- CRITICAL STEP ** SAT/UNSAT*

NOTE: JPM is not evaluating actions if ground is found, but the next step may be identified as part of 0AI-115 actions.

Step 8c - Circuits identified with grounds should be corrected expeditiously, and if possible, placed under clearance while waiting correction.

Identifies if ground is found, it should be corrected or placed under clearance.

SAT/UNSAT*

TERMINATING CUE: When calculation is performed, the grounded bus is identified, and required actions determined by being recorded on the cue sheet, the JPM is complete for SRO candidates ONLY.

Comments required for any step evaluated as UNSAT.

AOT-ADM-JP-051-05 Page 6 of 9 REV. 2

DC Ground Calculation RELATED TASKS:

263613B104 Perform DC Ground Isolation For Bus P, N, And P/N Per OP-51.

K/A REFERENCE AND IMPORTANCE RATING:

GEN 2.1.20 4.6/4.6 Ability to interpret and execute procedure steps GEN 2.1.7 4.4/4.7 Ability to evaluate plant performance and make operational judgments based on operating characteristics, reactor behavior, and instrument interpretation.

REFERENCES:

2OP-51, Section 8.1 0AI-115 125/250 VDC System Ground Correction Guidelines TOOLS AND EQUIPMENT:

Copy of 2OP-51 Copy of 0AI-115 Calculator ADMINISTRATIVE CATEGORY (from NUREG 1123, Rev 2. Supplement 1):

Admin - Conduct of Operations REASON FOR REVISION:

Modified to support HLC 2010-2 NRC exam for SRO evaluation of condition and determination of corrective actions.

AOT-ADM-JP-051-05 Page 7 of 9 REV. 2

DC Ground Calculation Validation Time: 20 Minutes (approximate)

Time Taken:

APPLICABLE METHOD OF TESTING Performance: Simulate Actual x Unit: 2 Setting: Classroom x Simulator (Not applicable to In-Plant JPMs)

Time Critical: Yes No x Time Limit N/A Alternate Path: Yes ___ No x EVALUATION Performer:

JPM: Pass Fail Remedial Training Required: Yes No Comments:

Comments reviewed with Student Evaluator Signature: Date:

AOT-ADM-JP-051-05 Page 8 of 9 REV. 2

TASK CONDITIONS:

1. The Control Room has received annunciation of a ground on 125/250 VDC Battery Switchboard 2B.

2. The Turbine Building AO has reported the following Bus readings:

P Bus 0.46 mA.

PN Bus 1.51 mA.

N Bus 3.61 mA.

3. 2OP-51 Section 8.1 is complete through step 8.1.2.9.

INITIATING CUE:

You are directed to continue performance of 2OP-51, Section 8.1 and record the results of the following on the cue sheet.

1. Total resistance to ground for 125/250 VDC Battery Switchboard 2B,

2. The Battery Bus that is grounded.

3. Determine required actions to be taken for this ground level if it remains present. (SRO Only)

Total Resistance =

Grounded Bus is Required Actions (SRO Only)

8.0 INFREQUENT OPERATIONS R

8.1 DC Ground Isolation for Bus P, N, and PN Reference Use 8.1.1 Initial Conditions

1. All applicable prerequisites listed in Section 4.0 are met.

8.1.2 Procedural Steps Battery 2B

1. PLACE HAND/AUTO switch on ground detector 2A(2B)-250VDC-GDT in HAND.

NOTE: Current readings should be allowed to stabilize for approximately 15-30 seconds before recording the reading in the following steps.

2. PLACE BUS SELECTION switch in P AND RECORD current reading on Attachment 2.

3. PLACE BUS SELECTION switch in PN AND RECORD current reading on Attachment 2.

4. PLACE BUS SELECTION switch in N AND RECORD current reading on Attachment 2.

NOTE: Failure to perform the following step will result in a ground being placed on the battery system.

5. PLACE BUS SELECTION switch in OFF.

6. PLACE HAND/AUTO switch on ground detector 2A(2B)-250VDC-GDT in AUTO.

7. DEPRESS AND HOLD RESET pushbutton for approximately 3 seconds.

2OP-51 Rev. 67 Page 51 of 235

8.1.2 Procedural Steps

8. IF SCR lights do NOT oscillate after the RESET is released, THEN GO TO Step 8.1.2.7.

9. CONFIRM with Unit CRS battery charger status AND RECORD the following voltages as appropriate on Attachment 2:

a. IF in FLOAT 135 volts

b. IF in EQUALIZE 140 volts

10. PERFORM calculation on Attachment 2.

11. IF resistance calculated in Attachment 2 is less than 25 K, THEN INITIATE a W/R for I&C to perform the following:

a. INSPECT batteries and wipe down any spilled electrolyte.

b. MEASURE ground resistance.

12. IF ground is no longer present, THEN RESET battery ground detector.

13. IF ground is still present, THEN refer to 0AI-115 for the appropriate Action Level and Action Requirements.

14. IF circuit isolation is required for ground hunting, THEN COMPARE the readings taken in Steps 8.1.2.2 and 8.1.2.4 to Table 1 to determine which bus is grounded.

15. PERFORM ground hunting, as necessary.

2OP-51 Rev. 67 Page 52 of 235

TABLE 1 Page 1 of 2 General Guidelines for Determining Which Bus Is Grounded I Information Use There will always be some resistance to ground which means there will always be a mA reading to ground on each bus. Also, one bus will typically have a larger mA reading to ground than the other, but unless the overall resistance of the system falls below the setpoint, this will generally be acceptable. IF a ground below 25 K is found to exist, these guidelines should be referred to for assistance.

mA Reading Grounded Bus P > N N P < N P

P N PN

The mA readings for the P Bus and N Bus should be 0.1 mA to 0.2 mA within each other to be considered approximately equal.

The following chart recorder information is to be considered general guidelines for helping to determine the following information:

- Which bus is grounded

- The type of ground present

- The severity of the ground

- The time the ground occurred

1. Due to the oscillating resistance within the ground detector, a wide trace, that represents voltage from the PN bus to ground, is produced at the output of the chart recorders. This trace will be positioned in the middle of the chart, around the zero axis, during conditions when there are no grounds present. This trace will also be relatively wide.

If a ground on the P bus were to occur, the entire trace would become narrower and shift toward the negative direction (left), which would represent a decrease in the voltage from the P bus to ground and an increase in voltage from the N bus to ground. Likewise, if a ground on the N bus were to occur, the entire trace would become narrower and shift toward the positive direction (right). If a ground were to occur on the PN bus, the trace would become narrower and remain in the middle of the chart.

2OP-51 Rev. 67 Page 201 of 235

TABLE 1 Page 2 of 2 General Guidelines for Determining Which Bus is Grounded

2. The chart recorder trace is helpful in determining what type of ground is present, such as, moisture related grounds, periodic grounds, grounds due to spikes on the system, or normal grounds.

A moisture related ground is usually an erratic trace that may increase or decrease in width, or slowly trend to a narrower band.

A periodic ground is one that comes in, goes away and comes in again at a later time. This is usually indicative of testing going on somewhere in the plant.

Grounds due to spikes will be indicated by single spikes on the chart recorder trace and are usually correlated with equipment changing states (i.e., diesel starts).

Normal grounds are characterized by a narrowing or shifting of the chart recorder trace for long periods of time. This can be either a gradual change or a step change.

3. The severity of the ground can be determined by the width of the chart recorder trace, but an actual value cannot be calculated. The ground detectors will provide the actual value.

4. An annotation trace is provided with the chart recorders that prints the date and time at periodic intervals on the chart. The length from the time reference mark to the start of the ground can be measured and divided by the chart speed to determine the time the ground occurred.

2OP-51 Rev. 67 Page 202 of 235

ATTACHMENT 2 R Reference Page 1 of 2 Use Data Sheet for Battery Ground Detection Date:

Today Time: Now NOTE: The "- 50" factor in the equation below accounts for the presence of a 50 K resistor in series with the milliamp meter.

NOTE: An example calculation is provided on the following page.

Battery 2A Current P bus:

N/A mA Current PN bus: mA Current N bus: mA Voltage 2A-1: VDC N/A Voltage 2A-2: VDC N/A 2A Resistance = VDC + VDC - 50 = K P (mA) + N (mA)

Battery 2B Current P bus:

0.46 mA Current PN bus: 1.51 mA Current N bus: 3.61 mA Voltage 2B-1: 135 VDC 135 Voltage 2B-2: VDC 2B Resistance = VDC + VDC - 50 = K P (mA) + N (mA) 2OP-51 Rev. 67 Page 214 of 235

ATTACHMENT 2 Page 2 of 2 Data Sheet for Battery Ground Detection NOTE: The following is provided as an example.

Battery 2B Current P bus: 2.15 mA Current PN bus: 0.08 mA Current N bus: 1.75 mA Voltage 2B-1: 135 VDC Voltage 2B-2: 140 VDC 2B Resistance = 135 VDC + 140 VDC - 50 = 20.5 K 2.15 (mA) + 1.75 (mA)

NOTE: Since the overall resistance (20.5 K) is below the setpoint (25 K), this suggests there is a ground on the system which must be verified. Once the ground has been verified, ground hunting activities should commence.

According to Table 1, the ground is located on the N Bus. AI-115 should then be referenced for monitoring activities which will show that Action Level 1 should be entered.

Date/Time Completed Performed By (Print) Initials Reviewed By:

Unit CRS/SRO 2OP-51 Rev. 67 Page 215 of 235

I BRUNSWICK NUCLEAR PLANT Information Use PLANT OPERATING MANUAL VOLUME I ADMINISTRATIVE INSTRUCTION UNIT 0

0AI-115 125/250 VDC SYSTEM GROUND CORRECTION GUIDELINES REVISION 8 0AI-115 Rev. 8 Page 1 of 8

1.0 DC GROUND POLICY STATEMENT It is the policy of Progress Energy to engineer, construct, and operate nuclear power plants without jeopardy to the health and safety of the public and of its employees.

The function of this procedure is to establish a set of criteria for actions which should be taken based upon the magnitude of grounds on the 125/250 Vdc distribution system. Completion of the various actions will provide a reasonable assurance that the 125/250 Vdc distribution system will continue to satisfy the CP&L policy.

It shall be the responsibility of all organizations at the plant and of all corporate support groups to provide support needed to ensure that the DC Ground program is successful.

2.0 PURPOSE AND SCOPE The 125/250 Vdc system at BNP is an ungrounded system. The system was designed as an ungrounded system so that the system could sustain one solid ground fault and still be able to meet all requirements for continued safe operation. On the ungrounded system, when the first ground fault occurs the system is degraded, but it is not degraded below an acceptable grounded level.

The dc ground detectors provide a means of monitoring the dc distribution system for significant grounds. If one ground occurs, the ground detectors will alert plant operations so that the ground can be corrected before a second more significant ground occurs.

The purpose of this document is to provide a set of guidelines for plant operations to use to determine the urgency of action and the actions to be taken to correct a known dc ground based upon the severity of the ground. The initial values selected for this document should provide a reasonable assurance that the operation of the dc distribution system will not be adversely affected.

The effectiveness of this document will depend on the full support of all levels of plant and corporate management. This includes the provision of adequate resources and a dedication to correcting grounds expeditiously as required by the action statements.

Changes to these guidelines will be made as the detailed evaluation of the dc distribution system continues and as refinements and improvements in the dc ground detection system dictate.

0AI-115 Rev. 8 Page 2 of 8

3.0 BASIS FOR ACTION LEVELS Electrical Evaluation BNP-E-6.116 was issued to provide a basis for the setpoint of the battery ground detectors. The value established by this evaluation is 25 kilohms (k). The ground detectors operate with a +/- 15% band, which corresponds to 21.3 - 28.8 K.

Electrical devices at BNP were researched and the most sensitive device of concern was determined to be GE HFA relays. These relays have a nominal dropout current of 3.75 mA. This value was utilized to derive an appropriate setpoint. Therefore, at ground levels just below 25 k, situations (involving two very strategically located grounds) could develop that might hold-in a normally energized relay.

At ground levels below 15 k, sufficient currents are allowed to develop which under the right conditions (involving two strategically located grounds) could result in picking up a de-energized relay. Since most relays in the system are normally de-energized relays, this level is considered the most urgent to correct.

When the ground detector alarm is clear (nominal 25 k), there are no required actions to be taken. Action Level 1 is between 25 k and 15 k and plant procedures should be entered to locate and correct the ground condition.

Grounds below 15k shall be considered the most severe condition (Action Level 2) and shall require the greatest degree of effort towards resolution.

This procedure provides guidance to plant operations as to prudent actions to be taken when dc system grounds are encountered. These guidelines do not necessarily ensure that a system operating problem will not occur if the guidelines are followed. However, due to the fact that very specific, isolated, and independent events must occur with the dc grounds on the system to create the potential for operational problems, the guidelines provide a relative degree of confidence that corrective actions can be completed before these system operating problems occur.

4.0 RESPONSIBILITIES 4.1 The Plant General Manager is responsible for assignment of specific responsibilities for the implementation of this program.

4.2 The Manager of Operations is responsible for ensuring that appropriate corrective actions are followed as outlined in this guideline.

0AI-115 Rev. 8 Page 3 of 8

4.0 RESPONSIBILITIES 4.3 The Manager of Maintenance is responsible for assuring prompt and effective assistance in ground hunting and repair of plant equipment with dc grounds.

4.4 The Manager of Brunswick Engineering Support Section is responsible for any support functions towards monitoring and/or repair of dc grounds.

5.0 DEFINITIONS 5.1 Action Levels Operation at or below the action-level 1 or 2 values presented in this document may not result in immediate misoperation of dc electrical equipment, however, the dc electrical equipment will be operating in a degraded condition.

5.1.1 Action Level 0 (ground resistance 25 k)

This is the achievable value which should be maintained by applying good operating and maintenance practices. Every effort should be made to operate with the dc grounds at or above this value.

5.1.2 Action Level 1 (ground resistance 15k to 25k)

This level represents the level of operation of the dc system below the ground detector alarm setpoint of 25k. Operation with one ground in this range will not result in the inadvertent pickup of a de-energized relay, but could result in the inadvertent hold-in of an energized relay if a second hard ground were to occur. Actions should be taken to restore the ground resistance to Action Level 0 values to minimize the possibility of continued degradation of the dc distribution system. (When a ground detector alarm is sealed in, proceed as per Action Level 1 even if above 25 K unless directed otherwise by Plant Management. Throughout this procedure when 25 k is used to define the boundary between Action Level 0 and Action Level 1 it refers to the point where the annunciator clears) 5.1.3 Action Level 2 (ground resistance 15k)

This level represents the level of operation that could result in the inadvertent pickup of a de-energized relay if a second ground 25k occurs. Prompt actions should be taken to restore the ground resistance to a minimum of Action Level 1 values prior to encountering a second ground 25k. Continuous investigation of possible grounds should be conducted until the ground is located and corrected.

0AI-115 Rev. 8 Page 4 of 8

6.0 ACTION REQUIREMENTS 6.1 Action Level 0 ( 25k)

At Action Level 0, the dc grounds are above the dc ground detector alarm point of 25k. No actions are required providing the dc ground detector alarms are operable.

If the dc ground detector alarms are determined to be inoperable, then the ground current shall be measured once per shift per OP-51, to verify that the grounds are above the alarm point.

6.1.1 If the DC ground annunciator alarms or ground current measurements demonstrate a ground, perform the following:

1. Note ground in Shift Supervisor's log along with any possibly related activity/evolution (e.g weather, equipment start, etc).

2. If ground measurement determines that ground is valid, Operations should perform ground hunting per OP-51 and appropriate action level OR initiate a Work Request for I&C support. Note that use of portable ground detection equipment by maintenance requires taking the bus ground detector out of service which will disable the associated annunciator.

6.2 Action Level 1 (<25k to >15k)

At Action Level 1, the dc grounds are above the point where de-energized relays may pickup if a hard ground occurs on the opposite bus. This action level shall be entered if ground current measurements demonstrate that a ground between 25k and 15k actually exists. Action steps for Action Level 1 are as follows:

6.2.1 The ground current shall be measured once per shift per OP-51, to ensure that the ground resistance has not degraded to the Action Level 2 point.

6.2.2 Efforts shall be undertaken to isolate all circuits per OP-51 which can be isolated without affecting plant operation in an effort to locate the ground OR request maintenance assistance using ground detection equipment. Ground hunting will proceed in accordance with the requirements of ADM-NGGC-0104, Attachment 4, with an assigned priority of 2.

0AI-115 Rev. 8 Page 5 of 8

6.0 ACTION REQUIREMENTS 6.2.3 If the ground cannot be located as per 6.2.2 or ground hunting must be interrupted, notify the Manager - Operations. Additional ground hunting will be planned in accordance with the requirements of 0AP-025, considering the elevated risk.

6.2.4 Circuits identified with grounds should be corrected expeditiously, and if possible, placed under clearance while waiting correction.

6.3 Action Level 2 ( 15k)

At Action Level 2 the dc grounds are at the point where de-energized relays may pickup or energized relays may dropout if another 25k ground occurs on the opposite bus. This action level shall be entered if measurement of the ground current demonstrates that the ground is less than or equal to 15k. Action steps for Action Level 2 are as follows:

6.3.1 The ground current shall be measured twice per shift to ensure that the ground resistance has not degraded or to determine if any worse grounds develop.

6.3.2 Efforts shall be undertaken to test with ground detection equipment OR to isolate per OP-51 all dc circuits which have not been isolated.

Maintenance will provide continuous support as required. The ground hunting effort will be conducted in accordance with the requirements of ADM-NGGC-0104, Attachment 4, with an assigned priority of 1.

6.3.3 Until the ground can be located, it should be recognized that a degraded or failed component may exist in the division with the low ground. A review of ongoing and scheduled work should be considered. For example, a clearance or surveillance test in the opposite division might need to be postponed based on potential risk.

6.3.4 If after seven days the ground has not been located notify the Plant General Manager. If unit startup is imminent, PNSC will evaluate risk.

6.3.5 Circuits identified with grounds should be corrected expeditiously, and if possible, placed under clearance while waiting correction.

0AI-115 Rev. 8 Page 6 of 8

7.0 REFERENCES

7.1 FP-84882, Battery Ground Detector 7.2 IEN 88-86, Operation with Multiple Grounds in Direct Current Distribution Systems, October 21, 1988 7.3 IEN 88-86, Supplement 1, Operation with Multiple Grounds in Direct Current Distribution Systems, March 31, 1989 7.4 SDCD-51, System Design Criteria Document for the DC Electrical System, April 9, 1988 7.5 Commonwealth Edison Company, Ground Task Force Final Report, May 25, 1989 7.6 Calculation BNP-E-6.116, Ground Detection Setpoint Basis for 125/250V DC System 7.7 ADM-NGGC-0104, Work Management Process 0AI-115 Rev. 8 Page 7 of 8

REVISION

SUMMARY

Revision 8 - Described use of Portable Ground Detection Equipment to assist in Ground Hunting. Clarified that when alarm is sealed-in, that this should be treated as Action Level 1 even if above 25 k.

Revision 7 - Updated cover page to reflect new PGN logo and format. Updated Section 4.1 to indicate that the Plant General Manager is responsible for assignment of specific responsibilities for the implementation of this program.

0AI-115 Rev. 8 Page 8 of 8

PROGRESS ENERGY CAROLINAS BRUNSWICK TRAINING SECTION JOB PERFORMANCE MEASURE ADMIN NRC ADMIN COO2 (RO/SRO)

LESSON TITLE: Evaluate Working Hour Limitations.

REVISION NO: 01

Evaluate Working Hour Limitations SAFETY CONSIDERATIONS:

None.

EVALUATOR NOTES: (Do not read to trainee)

1. ADM-NGGC-0206 will be provided to the trainee.

2. If this is the first JPM of the JPM set, read the JPM briefing contained NUREG 1021, Appendix E, or similar to the trainee.

Read the following to trainee.

TASK CONDITIONS:

1. Two Licensed Reactor Operators worked the following Dayshift on-line shift schedule.

2. 30 minutes of each shift were required for turnover each day.

3. Both operators were off three days before Day 1 and are scheduled three days off following Day 11.

DAY 1 2 3 4 5 6 7 8 9 10 11 12 Operator

1 12.5 12.5 12.5 14.5 10.5 Off 12.5 12.5 12.5 12.5 Off Operator

2 12.5 12.5 12.5 12.5 12.5 14.5 Off Off Off 12.5 12.5 NOTE: A break of at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months has occurred between all work periods INITIATING CUE:

Evaluate the work history for BOTH operators and determine if any working hour limitations have been violated.

LOT-ADM-JP-201-D01 Page 2 of 7 REV. 01

Evaluate Working Hour Limitations KEY DAY 1 2 3 4 5 6 7 8 9 10 11 12 Operator

1 12.5 12.5 12.5 14.5 10.5 Off 12.5 12.5 12.5 12.5 Off 72/75 72/75 72/75 72/75 58/60.5 60/62 No 34-hour break in 9-calendar day on Day #9 and #10 Operator

2 12.5 12.5 12.5 12.5 12.5 14.5 Off Off Off 12.5 12.5 74/77 62/64.5 50/52 50/52 50/52 50/51.5 LOT-ADM-JP-201-D01 Page 3 of 7 REV. 01

Evaluate Working Hour Limitations PERFORMANCE CHECKLIST NOTE: Sequence is assumed unless denoted in the Comments.

Step 1 - Obtain a current revision of ADM-NGGC-0206.

Current Revision of ADM-NGGC-0206 obtained.

SAT/UNSAT*

NOTE: Turnover time (.5 hour5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months each day) is not counted against Maximum Work Hours (MWH).

Identification of the violations are critical. The actual day(s) the violation occurred is not critical.

Step 2 - Evaluates RO#1 working hours.

Determines RO#1 violated the 34-hour break in 9-calendar day.

- CRITICAL STEP ** SAT/UNSAT*

Step 3 - Evaluates RO#2 working hours.

Determines Operator #2 violated Maximum Working Hours -exceeded 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in a 7 calendar day period.

- CRITICAL STEP ** SAT/UNSAT*

TERMINATING CUE: When the working hour violations have been identified, this JPM is complete.

Comments required for any step evaluated as UNSAT.

LOT-ADM-JP-201-D01 Page 4 of 7 REV. 01

Evaluate Working Hour Limitations RELATED TASKS:

341001B302 Conduct Shift And Relief Turnover Per 0OI-01.02 K/A REFERENCE AND IMPORTANCE RATING:

GEN 2.1.5 2.9/3.9 Ability to use procedures related to shift staffing, such as minimum crew complement, overtime limitations, etc.

REFERENCES:

ADM-NGGC-0206, Managing Fatigue And Working Hour Limits TOOLS AND EQUIPMENT:

Copy of ADM-NGGC-0206 Calculator ADMINISTRATIVE CATEGORY (from NUREG 1123):

A.1 - Conduct Of Operations REASON FOR REVISION:

Modified JPM for 2010-2 NRC Initial License Exam incorporating 10CFR Part 26, Subpart I

- Managing Fatigue.

LOT-ADM-JP-201-D01 Page 5 of 7 REV. 01

Evaluate Working Hour Limitations Time Required for Completion: 20 Minutes (approximate).

APPLICABLE METHOD OF TESTING Performance: Simulate Actual X Unit: 0 Setting: Classroom X Simulator ( Not applicable to In-Plant JPMs )

Time Critical: Yes No X Time Limit N/A Alternate Path: Yes No X EVALUATION Trainee:

JPM: Pass Fail Remedial Training Required: Yes No Did Trainee Verify Procedure as Authorized Copy?: Yes No (Each Student should verify one JPM per evaluation set.)

Comments:

Comments reviewed with Student Evaluator Signature: Date:

LOT-ADM-JP-201-D01 Page 6 of 7 REV. 01

TASK CONDITIONS:

1. Two Licensed Reactor Operators worked the following Dayshift on-line shift schedule.

2. 30 minutes of each shift were required for turnover each day.

3. Both operators were off three days before Day 1 and are scheduled three days off following Day 11.

DAY 1 2 3 4 5 6 7 8 9 10 11 12 Operator

1 12.5 12.5 12.5 14.5 10.5 Off 12.5 12.5 12.5 12.5 Off Operator

2 12.5 12.5 12.5 12.5 12.5 14.5 Off Off Off 12.5 12.5 NOTE: A break of at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months has occurred between all work periods INITIATING CUE:

Evaluate the work history for BOTH operators and determine if any working hour limitations have been violated.

I Information Use NUCLEAR GENERATION GROUP STANDARD PROCEDURE VOLUME 99 BOOK/PART 99 ADM-NGGC-0206 MANAGING FATIGUE AND WORKING HOUR LIMITS REVISION 6 ADM-NGGC-0206 Rev. 6 Page 1 of 89

TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE .................................................................................................................. 3

2.0 REFERENCES

........................................................................................................... 5 3.0 DEFINITIONS ............................................................................................................. 7 4.0 RESPONSIBILITIES ................................................................................................. 15 5.0 PREREQUISITES ..................................................................................................... 22 6.0 PRECAUTIONS AND LIMITATIONS........................................................................ 22 7.0 SPECIAL TOOLS AND EQUIPMENT ...................................................................... 22 8.0 ACCEPTANCE CRITERIA ....................................................................................... 22 9.0 INSTRUCTIONS ....................................................................................................... 23 9.1 Calculating Work Hours .................................................................................... 23 9.2 Covered Worker Work Hour Controls............................................................... 27 9.3 Establishing and Maintaining Covered Worker Status ..................................... 30 9.4 Creating/Adding Schedule Templates and Shift Cycles ................................... 31 9.5 Scheduling Work Hours .................................................................................... 33 9.6 Waivers............................................................................................................. 41 9.7 Fatigue Assessments ....................................................................................... 44 9.8 Managing Delegations ...................................................................................... 58 9.9 Documenting PGN Employees Hours Worked ................................................ 59 9.10 Documenting Contract Worker Hours Worked ................................................. 61 9.11 Annual Review.................................................................................................. 62 9.12 Annual FFD Program Performance Report ...................................................... 64 9.13 Disciplinary Actions .......................................................................................... 65 10.0 RECORDS ................................................................................................................ 66 11.0 ATTACHMENTS ....................................................................................................... 66 ATTACHMENT 1 - Authorization to Waive Work Hour Limits ................................... 67 ATTACHMENT 2 - Fatigue Assessment Form ......................................................... 69 ATTACHMENT 3 - Worker Fatigue Information and Countermeasures ................... 73 ATTACHMENT 4 - Risked Based Systems/Components ........................................ 76 ADM-NGGC-0206 Rev. 6 Page 2 of 89

1.0 PURPOSE

1. This procedure establishes Nuclear Generation Group processes for managing fatigue and controlling work hours in accordance with the 10 CFR 26, Subpart I, Managing Fatigue. The requirements of the procedure provide reasonable assurance that the effects of fatigue and degraded alertness on the ability of individuals to safely and competently perform their duties are managed commensurate with maintaining public health and safety.

2. This procedure establishes:

The responsibilities of badged personnel for managing fatigue

The process for authorizing a waiver of working hour limits

The process for scheduling, tracking and calculating work hours

The process for making a self-declaration of fatigue

The process for performing a supervisory fatigue assessment

The process for performing periodic reviews

The process for generating the required annual reports

The process for generating required records

3. The fatigue management program applies to ALL workers who are granted unescorted access or who are required to physically report to the Technical Support Center (TSC) or Emergency Operations Facility (EOF) in accordance with emergency plans and procedures.

ADM-NGGC-0206 Rev. 6 Page 3 of 89

1.0 PURPOSE (continued)

NOTE: PGN will implement these requirements conservatively. For workers who normally perform the duties below, all work hours will generally be considered covered work. Workers will not typically move in and out of a covered worker status except for extended work assignments such as shared resources during outages.

4. The work hour controls apply ONLY to workers who perform the following duties:

a) Operating or on-site directing of the operation of systems and components that a risk-informed evaluation process has shown to be significant to public health and safety (see Attachment 4) b) Maintenance or on-site directing of the maintenance of structures, systems, and components (SSCs) that a risk-informed evaluation process has shown to be significant to public health and safety (see Attachment 4) c) Health Physics or Chemistry duties required as a member of the on-site emergency response organization minimum shift complement d) Fire Brigade member responsible for understanding the effects of fire and fire suppressants on safe shutdown capability (Fire Brigade Team Leader/Site Incident Commander) e) Armed security force officer, alarm station operator, response team leader, or watchperson, (i.e., security personnel)

5. Work hour controls are applicable to management personnel if they assume the responsibilities of directing the operations or maintenance activities that a risk-informed evaluation process has shown to be significant to public health and safety.

6. Work hour controls do NOT apply during the following exceptions:

a) During declared plant emergencies as defined by the plants emergency plan (i.e., an emergency class declaration of Notification of Unusual Event or higher). Note that the hours worked during the emergency are included in the total hours worked but the work hour controls are not applicable b) Force-on-force NRC evaluated tactical exercises. PGN may exclude shifts worked by security personnel during the actual conduct of force-on-force tactical exercises evaluated by the Nuclear Regulatory Commission (NRC) when calculating the workers number of days off.

ADM-NGGC-0206 Rev. 6 Page 4 of 89

1.0 PURPOSE (continued) c) Common defense and security. PGN need not meet the work hour requirements when informed in writing by the NRC that these requirements, or any subset thereof, are waived for security personnel in order to assure the common defense and security, for the duration of the period defined by the NRC.

d) When a worker performs unscheduled work off-site (e.g.,

technical assistance provided by telephone from a workers home) provided the total duration of the work does not exceed a nominal 30 minutes during any single break period. The time associated with the unscheduled off-site work activity does not constitute a work period or work shift if less than 30 minutes.

2.0 REFERENCES

1. 10 CFR 26, Fitness for Duty Program

2. Federal Register August 26, 2005 (RIN 3150-AF12) pages 50442 through 50677

3. NEI-06-11, Managing Personnel Fatigue at Nuclear Power Reactor Sites

4. NEI-03-04, Guidelines for Plant Access Training

5. Federal Register March 31, 2008 (RIN 3150-AF12) pages 16966 through 17235

6. NRC Letter to All Holders of Operating Power Reactors dated June 8, 2009 regarding the Relaxation of Order for Compensatory Measures Related to FFD Enhancements Applicable to Nuclear Facility Security Force Personnel (ADAMS Accession No. ML091060882)

7. SEC-NGGC-2140 - Fitness for Duty Program

8. SEC-NGGC-2130 - Behavior Observation Program

9. SEC-NGGC-2141 - Fitness For Duty Unscheduled Work Callouts

10. CAP-NGGC-0200 - Corrective Action Program

11. NCR 275048, 10 CFR 26 Subpart I Change Management Plan

12. NRC Regulatory Issue Summary 2002-07: Clarification of NRC Requirements Applicable to Worker Fatigue and Self Declarations of Fitness for Duty ADM-NGGC-0206 Rev. 6 Page 5 of 89

2.0 REFERENCES

(continued)

13. Regulatory Guide 5.73 - Fatigue Management for Nuclear Power Plant Personnel

14. Workforce Computer Software a) EmpCenter Fatigue Management End User Guide b) Common Solution Functional Requirements including Addendum A- Fatigue Rules and Addendum B - Fatigue Rules Examples

15. Individual Plant Examination Probabilistic Safety Assessment Models

16. Maintenance Rule Database (PERMIT)

17. NCR 380631 - 10CFR26 Subpart I Exemption Request for Diversion Structure

18. NRC Frequently Asked Questions http://www.nrc.gov/reactors/operating/ops-experience/fitness-for-duty-programs/faqs/manage-fatigue.html

19. NEI Frequently Asked Questions http://atom.nei.org/Default.aspx?alias=atom.nei.org/workhourstf

20. NCR 375352 - Part 26 Application to E&C Supervisor

21. NCR 378309 - Self Assessment Procedure Deficiency for Part 26 regarding contract worker records

22. NCR 404637 - Unclear Guidance in ADM-NGGC-0206

23. NCR 400551 - SA #374321, D-1 Inaccurate Data in EmpCenter

24. CSP-NGGC-2505 - Software Quality Assurance and Configuration Control of Business Computer Systems ADM-NGGC-0206 Rev. 6 Page 6 of 89

3.0 DEFINITIONS

1. ACUTE FATIGUE - fatigue from causes (e.g., restricted sleep, sustained wakefulness, task demands) occurring within the past 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

2. ADVERSE TO SAFETY/SECURITY - unforeseen conditions which, in the informed opinion of the duty Shift Manager, could jeopardize the safety of the public, station, personnel, or environment. Waivers are considered appropriate if required to mitigate conditions adverse to safety. If rule compliance would result in the following type conditions, it would be appropriate to consider using the waiver process:

Violate other NRC requirements such as minimum on-site staffing.

Jeopardize the industrial or radiological safety of the public or plant personnel.

Delay recovery from a challenge to a safety system function.

Delay in recovering from actual or potential loss of reactor core cooling capability during outages

Cause a forced reactor shutdown, power reduction, or similar action as a result of exceeding a time limit for a Technical Specifications Limiting Condition for Operation

Delay recovery from any situation that has placed the unit in an orange or red risk classification

Cause or prevent mitigation of an environmental permit violation.

Compromise the ability to maintain the site secure from the actions of malicious groups or persons

Force undue risk to on-site or off-site station personnel as a consequence of an external event (e.g., security, fire, severe weather)

Any condition determined by Shift Manager to be adverse to public health and safety

3. ALERTNESS - the ability to remain awake and sustain attention.

4. APPROVAL AUTHORITY - the person who has the authorization to approve a waiver. At PGN, this will include the Shift Manager, Manager -

Nuclear Plant Security, Plant General Manager (PGM) or their designees.

This person must be a PGN employee.

5. BREAK - an interval of time that falls between successive work periods, during which the worker does not perform any duties for PGN other than one period of shift turnover at either the beginning or end of a shift but not both. This means that one part of the shift turnover can be considered as part of the break.

6. B34/9 - EmpCenter designation for required 34 hour3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months break every nine days.

7. CALENDAR DAY - a day reckoned from midnight to midnight. This is not necessarily the same as a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period.

ADM-NGGC-0206 Rev. 6 Page 7 of 89

3.0 DEFINITIONS (continued)

8. CALL IN - returning to the site when not normally scheduled for work.

9. CIRCADIAN VARIATION IN ALERTNESS AND PERFORMANCE - the increases and decreases in alertness and cognitive/motor functioning caused by human physiological processes (e.g., body temperature, release of hormones) that vary on an approximately 24-hour cycle.

10. CONTRACTOR/VENDOR (C/V) - any company or individual not employed by PGN who is providing work or services to PGN, either by contract, purchase order, oral agreement, or other arrangement.

11. COVERED WORKER - a worker subject to work hour controls. Any worker granted unescorted access performing covered work.

12. COVERED WORK includes the following duties:

Operating or on-site directing of the operation of systems and components that a risk-informed evaluation process has shown to be significant to public health and safety (see Attachment 4). Attachment 4 includes those systems in the Maintenance Rule database which have high safety significant functions as well as additional systems per the insights of NGG Probabilistic Safety Assessment.

Maintenance or on-site directing the maintenance of structures, systems, and components (SSCs) that a risk-informed evaluation process has shown to be significant to public health and safety (see Attachment 4)

Health Physics or Chemistry duties required as a member of the on-site emergency response organization minimum shift complement

Fire Brigade member responsible for understanding the effects of fire and fire suppressants on safe shutdown capability (Fire Brigade Team Leader/Site Incident Commander)

Armed security force officer, alarm station operator, response team leader, or watchperson, (i.e., security personnel)

13. CUMULATIVE FATIGUE - the increase in fatigue over consecutive sleep-wake periods resulting from inadequate rest.

14. DAY OFF - a calendar day in which a worker does not start a work shift.

15. DEVIATION - a departure from the requirements included in 10 CFR 26, Subpart I. Any deviation from the work hour controls will be documented in an NCR.

ADM-NGGC-0206 Rev. 6 Page 8 of 89

3.0 DEFINITIONS (continued)

16. DIRECTING - the exercise of control over a work activity by a worker who is directly involved in the execution of the work activity, and either makes technical decisions for that activity without subsequent technical review, or is ultimately responsible for the correct performance of that work activity. Considerations should include all of the following when determining if a worker is directing an operation or maintenance activity:

Is the activity on a risk significant structure or component?

Is the worker on-site?

Is the worker the first line supervisor/foreman/leader?

Is the worker directly involved in the execution of the work activity?

Is the worker making technical decisions for that activity without subsequent technical review?

Is the worker ultimately responsible for the correct performance of that work activity?

NOTE: Position alone should not be the deciding factor. For example a Shift Manager -

Operations is a second level supervisor, however, in practice and as defined in 10 CFR 26, has the authority to direct covered activities. Careful analysis, evaluating all the criteria, should occur prior to determining applicability or exclusion.

The following are examples of non-directing activities:

Normal engineering tasks

Supervision in the plant of the maintenance on a non-covered SSC

Supervision at the second level of supervision

Preparing a work or modification package

Procedure development and revisions

Review by senior management of work plans

Training of personnel during which time the trainee is not operating or performing maintenance activities

Providing recommendations from vendors and engineers on test performance, component and system operation, or other similar technical inputs

Review and approval of documents

Directing of any work that is not operations or maintenance on risk significant SSCs

Technical Staff providing only recommendation to control room staff

Administrative oversight of contractors (contract designated representatives who are not actually directing field activities)

ADM-NGGC-0206 Rev. 6 Page 9 of 89

3.0 DEFINITIONS (continued)

17. EMPCENTER - the computer software scheduling program that tracks 10 CFR 26 hours worked and determines if the worker will be in compliance with the rules (past and future). EmpCenter will track all covered workers unless authorized management allows an alternative method.

18. FATIGUE - the degradation in an individuals cognitive and motor functioning resulting from inadequate rest. See Attachment 3 for examples of fatigue symptoms and contributors.

19. INCIDENTAL DUTIES - those unscheduled work activities, required by PGN, performed off-site. Cumulative incidental time that falls within a single break between shifts is ignored by the MWH, MBBS, and B34/9 rules if the total is less than or equal to 30 minutes. Cumulative incidental time on the same calendar day is ignored by the MDO rules if the total is less than or equal to 30 minutes.

20. INCREASED THREAT CONDITION - an increase in protective measure level, relative to the lowest protective measure level applicable to the site during the previous 60 days, as promulgated by an NRC advisory.

21. MAINTENANCE - the following onsite maintenance activities:

Modification, surveillance, post-maintenance testing, and corrective and preventive maintenance of SSCs that a risk-informed evaluation process has shown to be significant to public health and safety.

22. MBBS - Minimum Break Between Shifts (8 or 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months )

23. MDO - Minimum Days Off.

24. MWH - Maximum Work Hours.

25. NAP OR RESTORATIVE SLEEP - a brief opportunity and accommodations for restorative, uninterrupted sleep of at least one half hour in a designated area.

26. NFR - Nuclear Fatigue Rule - term synonymous with 10CFR26 Subpart I used in Progress Energy Passport system and SSIS Access Request Form

27. NON-COVERED WORKER - a worker not subject to work hour controls.

ADM-NGGC-0206 Rev. 6 Page 10 of 89

3.0 DEFINITIONS (continued)

28. NON-COVERED WORK - work hour controls do not apply to the following workers and activities:

Maintenance activities on SSCs which are off-site.

Operation and maintenance activities on plant SSCs which a risk informed evaluation process has shown to NOT be significant to public health and safety. (See Attachment 4)

Training (classroom or offsite)

Office activities

The following field activities are not considered covered work:

Scaffold installation and removal

General cleaning, housekeeping, and decontamination activities

Painting on non-risk significant systems outside of the containment building

Shielding installation and removal

Radiological surveys

Fire watches

Escorting unbadged personnel

Quality control and quality assurance activities.

Contractor/vendors, who are not granted unescorted access (i.e, the worker is escorted), conducting work on a risk-significant system, structure, or component on-site

Emergency Response Personnel who do not perform health physics or chemistry duties required as a member of the onsite emergency response organization minimum shift complement.

Predictive maintenance activities that do not result in a change of condition or state of a SSC in a covered system may be excluded from covered activities. Examples of activities that may be excluded include, but are not limited to non-destructive analysis (NDE), thermography, vibration analysis, data collection and analysis.

Note: At times an activity requires starting or stopping a piece of equipment. The worker starting or stopping the equipment would be performing covered work under the operating category; however, the data collection activity would not be considered a covered work activity.

ADM-NGGC-0206 Rev. 6 Page 11 of 89

3.0 DEFINITIONS (continued)

29. NOMINAL - the limited flexibility that is permitted in meeting a scheduled due date for completing a recurrent activity that is required under 10 CFR 26, such as the nominal 12-month frequency required for FFD refresher training. Completing a recurrent activity at a nominal frequency means that the activity may be completed within a period that is 25 percent longer or shorter than the period required in 10 CFR 26. The next scheduled due date would be no later than the current scheduled due date plus the required frequency for completing the activity.

30. ON-SITE - within the owner controlled area of the nuclear power plant.

31. OFF-SITE - any area not considered on-site.

32. PROTECTED AREA - an area encompassed by physical barriers and to which access is controlled.

33. RISK-INFORMED EVALUATION PROCESS - an evaluation based on a probabilistic risk analyses approach such as the Maintenance Rule (50.65(a)(4)) or other similar process.

34. SECURITY PERSONNEL - armed security force officer, alarm station operator, response team leader, or watchperson.

35. SECURITY SYSTEM OUTAGE - a condition in which a security system or structure, (e. g. Security Computer System, Perimeter Intrusion Detection System, etc), is degraded, resulting in an impact on security resources to implement required compensatory measures to ensure compliance with the physical security and safeguards contingency plans.

These planned or unplanned outages could be a result of equipment maintenance, degradation/failure, adverse weather, loss of power, or structural damage to the system or structure.

36. SELF- DECLARATION - a specific statement by a worker to a supervisor declaring that they are unable to safely and competently perform their duties due to fatigue.

37. SHIFT CYCLE (EVALUTION PERIOD) - a series of consecutive work shifts and days off that is planned by PGN or a contractor working for PGN to repeat regularly, thereby constituting a continuous shift schedule.

A shift cycle cannot exceed 6 weeks for the purposes of calculating days off. PGN will normally use a 6 week rolling average for calculation of days off.

ADM-NGGC-0206 Rev. 6 Page 12 of 89

3.0 DEFINITIONS (continued)

38. SHIFT SCHEDULE a) EIGHT (8) HOUR - a schedule that averages not more than 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months per workday over the entire shift cycle.

b) TEN (10) HOUR - a schedule that averages more than 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months , but not more than 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , per workday over the entire shift cycle. This includes workers working the Alternate Work Schedules (alternate Fridays off) since these employees have non-paid lunch periods.

This will also apply to a 4-10 schedule.

c) TWELVE (12) HOUR - a schedule that averages more than 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months , but not more than 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months , per workday over the entire shift cycle.

39. SHIFT TURNOVER - only those activities that are necessary to safely transfer information and responsibilities between two or more workers between shifts. Shift turnover activities may include, but are not limited to, discussions of the status of plant equipment, and the status of ongoing activities, such as extended tests of safety systems and components.

With the exception of security personnel arming/disarming, any time coded as turnover must include a face to face transfer of information from an off going shift individual. Turnovers for supervisors may be more extensive than for workers and will therefore may be longer. Turnover may include the time required for security personnel to arm and disarm.

Only one period of shift turnover can be excluded from the calculation of break times between successive work periods. Turnovers within a shift period due to rotations or relief during a shift cannot be excluded.

a) PRIMARY TURNOVER - a shift turnover time segment in EmpCenter that is disregarded for both maximum work hours and determination of breaks.

b) SECONDARY TURNOVER - a shift turnover time segment in EmpCenter that is disregarded for maximum work hours but considered when determining that the minimum breaks have occurred.

40. SYSTEM ADMINISTRATOR- the NIT Analyst responsible for the configuration management of the EmpCenter software including, but not limited to, Security, Policies and Codes.

41. TACTICAL EXERCISE - a force-on-force simulation used to evaluate and demonstrate the capability to defend target sets against selected attributes and characteristics of an adversary. A force-on-force tactical exercise includes all key program elements of a stations protective strategy.

ADM-NGGC-0206 Rev. 6 Page 13 of 89

3.0 DEFINITIONS (continued)

42. UNIT OUTAGE - the reactor unit is disconnected from the electrical grid.

43. UNPLANNED OUTAGE - an outage with less than 14 days notification such that covered work schedules could be modified to meet fatigue rule requirements.

44. WAIVER - the process form used to obtain approval to exceed or deviate from the work hour controls

45. WEEK - a period of seven consecutive calendar days

46. WORK HOURS - the amount of time a worker performs duties for PGN.

This includes all work hours, with the following exceptions:

Shift turnover time. (only one period of turnover can be excluded for the purpose of determining the minimum break between successive shifts)

Within-shift break and rest periods in which there is reasonable opportunity and accommodations for restorative sleep (e.g., a nap).

Unscheduled work hours for the purpose of participating in unannounced emergency preparedness exercises and drills.

Incidental duties performed off-site provided the total duration of the work does not exceed a nominal 30 minutes. (See definition of incidental duties).

For security personnel, during periods defined in writing by the NRC when security personnel are required to work to ensure the common defense and security.

Personal time in which a worker is on-site but is off duty (i.e., before or after their normally scheduled work period in which work activities are performed for PGN) may be excluded. The worker may be reading the paper, in the on-site fitness center, eating breakfast, etc.

47. WORK HOUR CONTROLS - the regulatory requirements in 10 CFR 26.205 and this procedure.

ADM-NGGC-0206 Rev. 6 Page 14 of 89

4.0 RESPONSIBILITIES

1. Director - Nuclear Fleet Operations is responsible for:

a) Fleet ownership of the Part 26 program.

b) Designating a NGG Fleet Part 26 Program Coordinator.

2. Nuclear Regulatory Affairs is responsible for:

a) Submitting annual report to NRC as required by 10CFR 26.717.

b) Participating on NEI Work Hour Rule Taskforce.

3. Plant General Manager (PGM) is responsible for:

a) Site ownership of the Part 26 program.

b) Providing guidelines for overtime selection process, including those required by the union contract and the FFD requirements of this procedure and SEC-NGGC-2140, Fitness for Duty Program.

c) Communicate and ensure compliance with the requirements of this procedure to appropriate personnel within the department.

d) Ensuring staffing levels are adequate to ensure worker work hours are managed with the objective of preventing impairment from fatigue due to the duration, frequency, or sequencing of successive shifts.

e) Authorizing a work hour waiver if necessary to mitigate or prevent a condition adverse to safety or site security.

f) Providing resources from covered work groups (Operations, Maintenance, Chemistry, Health physics) to participate in the annual review required by this procedure.

g) Ensuring a Part 26 Program Coordinator is designated for each of the following organizations: Operations, Maintenance, Health Physics, Chemistry, and Security ADM-NGGC-0206 Rev. 6 Page 15 of 89

4.0 RESPONSIBILITIES (continued)

4. Nuclear Shift Manager - (SM) or a site senior level manager with requisite signature authority is responsible for:

a) Authorizing a work hour waiver if necessary to mitigate or prevent a condition adverse to safety.

b) As applicable, evaluating staffing levels to ensure individual work hours are managed with the objective of preventing impairment from fatigue due to the duration, frequency, or sequencing of successive shifts.

5. Manager - Nuclear Plant Security or designee with requisite signature authority is responsible for:

a) Authorizing a work hour waiver if necessary to maintain site security.

b) Evaluating staffing levels to ensure worker work hours are managed with the objective of preventing impairment from fatigue due to the duration, frequency, or sequencing of successive shifts.

c) Providing resources to support the annual review required by this procedure.

6. Manager-Support Services is responsible for:

a) Ensuring annual reviews are performed per this procedure by January 30 each year to evaluate the effectiveness of the control of work hours, to include:

(1) Evaluating staffing levels to ensure worker work hours are managed with the objective of preventing impairment from fatigue due to the duration, frequency, or sequencing of successive shifts.

(2) Evaluating the performance of workers to ensure individual work schedules prevent impairment from fatigue. This includes evaluating the duration, frequency and sequencing of the hours that are worked by each worker relative to individual performance.

(3) Reviewing the performance of the station in adhering to work schedules for covered work groups. Evaluate the number of schedule changes and reasons for the changes and assess whether or not the schedule is effectively being implemented.

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4.0 RESPONSIBILITIES (continued)

7. All Managers or Supervisors of workers with unescorted access are responsible for:

a) Designating covered or non-covered status on SSIS access request form for new employees, contract employees, or shared resources.

b) Performing fatigue assessments as required by this procedure.

c) Using EmpCenter to process fatigue assessments and waivers.

d) Transmitting any assessments, waivers or affidavits completed per this procedure to Document Services as Vital Records.

8. Manager or Supervisor for covered workers is responsible for developing and maintaining schedules for the crew and other supplemental personnel. Items a through f can be implemented by the unit scheduler.

This includes the following:

a) Ensuring workers schedules are updated in EmpCenter prior to assigning any covered work to employees or other supplemental personnel in the organization.

b) Ensuring covered workers long-term base schedules are loaded.

c) Ensuring covered workers base schedule is modified for known exceptional or regular work time at least 6 weeks in advance when possible.

d) Ensuring EmpCenter is updated for unplanned outages or security system outages.

e) Ensuring EmpCenter is updated as soon as possible after unplanned changes in work time, e.g. personnel sickness, schedule delays not resulting in the need for a waiver.

f) Ensuring NCRs are generated as required by this procedure for exceeding an average of 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months per week during on-line periods, exceeding any work control limits without a waiver, and documenting any manual deviation overrides in EmpCenter.

g) Ensuring a waiver to exceed working hour limits is completed prior to allowing a worker to exceed these limits.

h) Evaluating the employees fitness by performing a face-to-face fatigue assessment.

i) Evaluating the employees performance and continued fitness-for-duty while working under a waiver. (This can be done by any supervisor qualified to direct or oversee the work, e.g. Shift Managers and Control Room Supervisors.)

ADM-NGGC-0206 Rev. 6 Page 17 of 89

4.0 RESPONSIBILITIES (continued)

9. Contract Designated Representatives and Project Managers are responsible for:

a) Designating covered or non-covered status on SSIS access request form for contract employees reporting to site.

b) Informing contractors of fatigue management program and work hour controls.

c) Determining method of documenting contract workers schedules and actual work hours from the three options below:

(1) Providing hard copies to PGN for entry into EmpCenter by PGN employee or, (2) Contract representative entering schedules and actual work hours into EmpCenter or, (3) Contractor providing alternate method of schedule and actual work hour documentation. If contractor elects to provide documentation, the work hour calculations must be in accordance with this procedure and records must indicate actual start and stop times for each work period.

d) Providing oversight of contractor work groups to ensure effective implementation of the Part 26 requirements.

e) Ensuring required documents are transmitted to the Director -

Fleet Operations.

10. Site Part 26 Program Coordinators are responsible for:

a) Providing overall program oversight for their organization.

b) Maintaining a working knowledge of 10CFR 26 Subpart I.

c) Maintaining an expert knowledge of EmpCenter software.

d) Periodically (~ weekly) running reports to identify potential discrepancies and error messages.

e) Resolving and or assisting supervisors with resolving discrepancies and error messages.

f) Assisting contract designated representatives in fulfilling their responsibilities.

g) Coordinating resources to assist supervisor during high demand periods such as outages.

ADM-NGGC-0206 Rev. 6 Page 18 of 89

4.0 RESPONSIBILITIES (continued)

11. NGG Fleet Part 26 Program Coordinator is responsible for:

a) Providing overall program oversight for the fleet.

b) Maintaining a working knowledge of 10CFR 26 Subpart I.

c) Maintaining an expert knowledge of EmpCenter software.

d) Assisting Site Part 26 Program Coordinators with resolving discrepancies and error messages.

e) Assisting contract designated representatives in fulfilling their responsibilities.

f) Maintaining this procedure.

g) Implementing program changes.

h) Ensuring records are generated for work schedules and actual work time from EmpCenter per this procedure.

i) Transmitting records for work schedules and actual work time to Records Management.

j) Function as the Customer Liaison as defined in CSP-NGGC-2505.

k) Providing training as needed to supervisors and Site Part 26 Program Coordinators.

l) Maintaining the Fatigue Management Portal website.

m) Participating in EmpCenter user group activities.

n) Developing pre-defined schedules in EmpCenter.

12. The EmpCenter Scheduler is responsible for developing pre-defined schedules in EmpCenter.

ADM-NGGC-0206 Rev. 6 Page 19 of 89

4.0 RESPONSIBILITIES (continued)

13. All Personnel With Unescorted Access Authorization are responsible for:

a) Evaluating their personal fitness to work based on impairment from fatigue. Personnel are required to be fit-for-duty. Getting sufficient rest is required to ensure a person is not subject to fatigue. Personnel who make choices that result in less than adequate sleep to remain alert and avoid fatigue are not meeting expectations.

b) Managing their work hours consistent with the objective of preventing impairment from fatigue.

c) Making a self-declaration of fatigue and discussing their concerns with supervision or management in cases when they feel their performance may be impaired. Self-declarations of fatigue are encouraged to facilitate a healthy safety conscious work environment.

d) Monitoring and reporting concerns related to individuals fitness for duty based on impairment from fatigue (i.e., behavioral observation program).

e) Recording all work hours regardless of whether they are paid or unpaid.

ADM-NGGC-0206 Rev. 6 Page 20 of 89

4.0 RESPONSIBILITIES (continued)

14. Covered Workers are responsible for the following in addition to items in Section 4.13:

a) Understanding the maximum work hour, break, and day off requirements of this procedure and notifying management before any limits will be exceeded.

b) Working only scheduled hours unless a supervisor approves a schedule deviation.

c) Recording work time for phone calls or other incidental duties performed for PGN while offsite. This does not include hours worked at home which are not required by PGN.

d) PGN employees are responsible for updating work hours in Passport on a daily basis if worked hours or start/stop times deviate from the work schedule by more than 15 minutes (not just total hours, also changes to start/stop times). It is not necessary to update these times if the deviation results in a conservative change to the work time, i.e. shortens the shift length.

e) Contract employees are responsible for notifying their time keeper or Supervisor on a daily basis if worked hours or start/stop times deviate from the work schedule by more than 15 minutes (not just total hours, also changes to start/stop times). It is not necessary to update these times if the deviation results in a conservative change to the work time, i.e. shortens the shift length.

15. The Nuclear Oversight Department is responsible for performing the independent audit required by 10CFR26.203(f) and 10CFR26.41 once per each twenty four month interval and generating required reports.

16. The Nuclear Financial Services Section is responsible for monitoring exceptions in EmpCenter, correcting data entry errors prior to week closure and notifying NGG supervisors and management of unresolved discrepancies. (after 4/15/2010)

ADM-NGGC-0206 Rev. 6 Page 21 of 89

5.0 PREREQUISITES None 6.0 PRECAUTIONS AND LIMITATIONS

1. If EmpCenter software is not available:

a) The worker and supervisor are responsible to ensure any schedule changes will not violate the work hour limits of this procedure.

b) Waivers and assessments can be completed using attachments in this procedure and loaded to EmpCenter later.

c) Changes in employee schedules should be updated in EmpCenter as soon as possible.

7.0 SPECIAL TOOLS AND EQUIPMENT None 8.0 ACCEPTANCE CRITERIA 8.1 During on-line periods, work schedules should be developed to prevent any covered worker from exceeding an average of 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months per week over a shift cycle. If the average work hours exceed 54 hour/week, an NCR must be written to document the circumstances resulting in the increased work hours. This acceptance criterion does not apply to workers who are on-site less than 7 days.

8.2 Workers shall not exceed the work hour limits defined in the procedure unless authorized by a waiver. If it is determined that a worker has violated the requirements, an NCR must be written and, if applicable, the NCR number added to the comment fields in EmpCenter.

8.3 If EmpCenter shows a violation message, and due to special circumstances, it is determined that the violation is not valid, a manual deviation override admin code, (DEVOVR), can be used. If this override admin code is used for situations other than the five below, an NCR must be written to document why the override is acceptable. The NCR number should also be added to the comment field in EmpCenter.

8.3.1 AVG54 if the evaluation period is less than 7 days and the total hours is less than 54.

8.3.2 MDO-Fixed if the evaluation period is less than 7 days and the total number of work days is less than allowed for the activity and shift length.

8.3.3 MDO-Fixed if ALL work done in the evaluation period is non-covered.

8.3.4 MDO-ONL or MDO-OUT for rolling periods if ALL the work performed while in excess is non-covered.

8.3.5 MWH72/168 if work time (excluding turnover) is NOT greater than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in a 7 calendar day period.

ADM-NGGC-0206 Rev. 6 Page 22 of 89

9.0 INSTRUCTIONS 9.1 Calculating Work Hours 9.1.1 Items To Be Included In Work Hour Calculation

1. Work hours are calculated as the amount of time a worker performs any duties for PGN including but not limited to the following:

a) All within-shift break times and rest periods (including meal breaks) during which there is no reasonable opportunity or accommodations appropriate for restorative sleep (e.g., a nap);

b) Shift holdovers to cover for late arrivals of incoming shift members; c) Early arrivals of workers for PGN required meetings, training, or beginning of shift briefings or pre-job briefs for special evolutions (these activities are NOT considered shift turnover activities); and d) Holdovers for interviews needed for event investigations.

e) Travel time to alternate work locations in excess of 30 minutes must be included as non-covered work time. If the total time is less than 30 minutes, inclusion is not required. If greater than 30 minutes, all time spent traveling should be counted as work hours.

f) Intervening hours between end of shift and start of call-in work or between end of call-in work and beginning of next shift if no waiver is processed for insufficient break (see 9.1.3 below).

9.1.2 Items To Be Excluded From Work Hour Calculation

1. Pay for hours not worked:

a) Holiday time - this may be either time away from work or at work.

If the time is at work, then only the actual hours worked are included in the work hour calculation.

b) Vacation time c) Sick leave ADM-NGGC-0206 Rev. 6 Page 23 of 89

9.1.2 Items to be Excluded from Work Hour Calculations (continued) d) Personal leave - e.g., jury duty, rest time, family sickness e) Short term/long term disability

2. Unannounced emergency preparedness exercises and drills. PGN may exclude from the calculation of work hours the time associated with unscheduled work hours, above the normal scheduled work hours, for the purpose of participating in the actual conduct of an unannounced emergency preparedness exercise or drill. If a worker is on a day off, it is still considered a day off.

3. Commuting time to and from assigned work location.

4. All turnover time can be excluded from the total hours worked however only one period of turnover time per shift can be excluded for determining if the minimum break requirements are met.

5. Within-shift break and rest periods in which there is a reasonable opportunity and accommodations for restorative sleep (e.g., a nap) may be excluded.

6. The one hour time shift for daylight savings time required twice each year.

7. A workers work hours for unscheduled work performed off-site (e.g.,

technical assistance provided by telephone from a workers home) provided the total duration of the work, which is required by PGN, does not exceed a nominal 30 minutes. For the purposes of compliance with the minimum break requirements and the minimum day off requirements, such duties, if less than 30 minutes, do not constitute work periods or work shifts. See definition of incidental duties for more information regarding how the incidental time is accumulated for certain rules.

8. After hours study time not required by PGN.

9. Personal time spent at work.

ADM-NGGC-0206 Rev. 6 Page 24 of 89

9.1.3 Call-In

1. A call-in is considered an addition to the normal work schedule. The work hours can be accounted for using three different methods depending on timing and circumstances of the call-in work period.

a) The call-in hours can be considered a separate work period.

Using this method, only the hours worked for PGN will be counted. The method requires a 10-hour break before the call in period and after the call-in period.

b) The call-in hours can be considered an extension to the preceding or succeeding work period. Using this method, the intervening hours of the extended work period must be counted.

c) A waiver can be processed for the required 10-hour break between successive work periods. If a waiver is processed for the 10-hour break, the intervening hours need not be counted.

2. Commuting time to and from assigned work location for call-ins is excluded from work hour calculations.

9.1.4 Work Hour Calculations

1. For the purposes of calculating the average number of days off, the duration of the shift cycle shall not exceed 6 weeks and may be of a shorter duration. The actual repeatability of the rotation may exceed 6 weeks; however, the shift cycle used for calculating the MDO cannot exceed 6 weeks.

2. If a work hour limit will be exceeded, it shall be identified before the hours are worked Use the following to ensure the individual limits are not exceeded:

a. The periods of 24-hours, 48-hours, and 7-days are considered rolling time periods. Rolling means the period is not re-zeroed, or the clock reset following a day off, after obtaining authorization to exceed the limits or at the end of a pay period.

The 24-hours, 48-hours, and 7-days periods do not restart after a day off, the periods continue to roll.

b. Hours worked should be evaluated to determine if any limit will be exceeded based on the work schedule by picking a future time (T) on the work schedule and asking, how many hours will have been worked during the T-24 hours, T-48 hours, or T-168 hours (T-7days) (i.e., a backwards look at the number of hours that have or will have been worked based on a time in the future.)

ADM-NGGC-0206 Rev. 6 Page 25 of 89

9.1.4 Work Hour Calculations (continued)

c. Determine if the MDO requirements will be met using one of the following methods:

(1) Rolling - Calculate the MDO based on a backwards look of the of T- 42 days and a forward look of T+42 days to determine if the worker has had or will have the required number of days off using the MDO rates from the table in 9.2.1.3. (42 days is used here for illustration, the period may be shorter than 42 days)

(2) Fixed - Ensure that sufficient days off still exist (within the defined shift cycle) to meet the MDO requirements.

9.1.5 Transitioning on to a Shift or Between Covered Groups or Into a Covered Group

1. If an outage worker begins work for PGN within 9 days of performing outage work at another nuclear plant, the worker must:

a. Have had a 34 hour3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months break within the 9 days that precede the day on which the worker begins work for PGN.

b. Not have exceeded or will not exceed the MWH rules.

2. If a worker begins or resumes performing covered work during the calculation period, PGN shall include all work hours worked for PGN, including hours worked performing duties that are not covered work and control the individuals work hours in accordance with the following requirements:

a. Ensure worker meets the MWH rules

b. Ensure worker meets the minimum break requirements

c. A minimum of 1 day off in the preceding 7-day period for workers to begin or resume covered duties and for workers who have been working an 8-hr shift schedule, as either day or shift workers, and are transitioning (1) from a non-covered group to a covered group or (2) from a covered group to another covered group that has more stringent MDO requirements

d. A minimum of 2 days off in the preceding 7-day period for workers who have been working a 10- or 12-hr shift schedule, as either day or shift workers, and transition (1) from a non-covered group to a covered group or (2) from a covered group to another covered group with more stringent MDO requirements ADM-NGGC-0206 Rev. 6 Page 26 of 89

9.1.5 Transitioning on to a Shift or Between Covered Groups or Into a Covered Group (continued)

e. A minimum of 2 days off in the preceding 7-day period for operators at a multi-unit site with one or more units in an outage, if the operators have been working outage hours on 10 or 12 hr shifts before they transition to an operating unit as members of the minimum shift complement. This does not preclude short term relief of the on-line unit operators.

9.2 Covered Worker Work Hour Controls 9.2.1 On-Line Work Hour Limits

1. A workers work hours shall not exceed the following limits unless a waiver is issued.

a) 16 work hours in any 24-hour period (MWH16/24) b) 26 work hours in any 48-hour period (MWH26/48) c) 72 work hours in any 7-day or 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months period (MWH72/168)

NOTE: EmpCenter evaluates this rule on a rolling 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months window. The regulatory limit is actually 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7 calendar day period. If EmpCenter indicates a violation based on 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months , but the worker has not exceeded 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in the 7 calendar day period, the violation may be overridden.

2. A worker shall be provided the following breaks unless a waiver is issued.

a) A 10-hour break between successive work periods or an 8-hour break between successive work periods when a break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months is necessary to accommodate a crews scheduled transition between work schedules or shifts (MBBS10 or MBBS8) and b) A 34-hour break in any 9-day period (allows for two consecutive sleep periods without an intervening work period) (B34/9)

3. A worker shall average the following minimum days off during a shift cycle unless a waiver is issued. (MDO-ONL) The MDO rules are not applicable if the worker is on site less than 7 days.

Group 8- 9 hr shift >9-11hr shift >11-13 hr shift Maintenance 1 day/week 2 days/week 2 days/week Ops, HP, Chemistry, Fire 1 day/week 2 days/week 2.5 days/week Brigade Leader Security 1 day/week 2 days/week 3 days/week ADM-NGGC-0206 Rev. 6 Page 27 of 89

9.2.2 Outage Work Hour Limits

1. Evaluating work hours to outage rules versus on-line rules is optional.

Should a plant enter an unplanned outage, it is not necessary to reassign personnel to an outage schedule. Nor is it necessary to assign an outage schedule to personnel working on outage activities.

2. A workers work hours shall not exceed the following limits unless a waiver is issued.

a) 16 work hours in any 24-hour period (MWH16/24) b) 26 work hours in any 48-hour period (MWH26/48) c) 72 work hours in any 7-day or 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months period (MWH72/168)

NOTE: EmpCenter evaluates this rule on a rolling 168 hour0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months window. The regulatory limit is actually 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7 calendar day period. If EmpCenter indicates a violation based on 168 hours0.00194 days 0.0467 hours 2.777778e-4 weeks 6.3924e-5 months , but the worker has not exceeded 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in the 7 calendar day period, the violation may be overridden.

3. A worker shall be provided the following breaks unless a waiver is issued.

a) A 10-hour break between successive work periods or an 8-hour break between successive work periods when a break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months is necessary to accommodate a crews scheduled transition between work schedules or shifts; (MBBS10 or MBBS8) and b) A 34-hour break in any 9-day period (allows for two consecutive sleep periods without an intervening work period) (B34/9)

4. During the first 60 days of an unit outage or a planned security outage, a worker shall have the following minimum number of days off unless a waiver is issued. (MDO-OUT)

Group 8 - 9 hour1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months shift >9 - 13 hr shifts Maintenance 1 day/7days 1 day/7days Ops, HP, Chemistry, Fire 1 day/7days 3 days/15-day period*

Brigade Leader Security 1 day/7days 4 days/15-day period*

The 15 day periods are non-rolling.

ADM-NGGC-0206 Rev. 6 Page 28 of 89

PROGRESS ENERGY CAROLINAS BRUNSWICK TRAINING SECTION JOB PERFORMANCE MEASURE ADMIN NRC ADMIN EC (RO/SRO)

LESSON TITLE: Evaluate Jet Pump Performance Per PT-13.1.

REVISION NO: 01

Evaluate Jet Pump Performance Per PT-13.1.

Special Instructions Transfer the following data onto a current revision of PT-13.1:

Reactor power level 96.6%

Recirc Pump A speed 88%

Recirc Pump B speed 88%

Recirc Pump A Flow 52 gpm X 1000 Recirc Pump B Flow 43 gpm X 1000 Jet Pump Loop A 30 mlbm/hr Jet Pump Loop B 39 mlbm/hr Attachment 2, Work Sheet 1 Loop A Loop B JP 1 - 30% JP 40%

JP 32% JP 42%

JP 20% JP 39%

JP 33% JP 43%

JP 32% JP 40%

JP 33% JP 38%

JP 31% JP 39%

JP 32% JP 38%

JP 26% JP 39%

JP 31% JP 42%

(NOTE: Average of Loop A is 30.0%, Loop B is 40% - Do NOT fill this data in on PT-13.1)

LOT-ADM-JP-002-01 Page 2 of 9 REV. 01

Evaluate Jet Pump Performance Per PT-13.1.

SAFETY CONSIDERATIONS None EVALUATOR NOTES: (Do not read to trainee)

1. Marked up copy of 0PT-13.1 and 2OP-02 WILL be provided to the trainee.

2. Unit 2 Technical Specifications will be available for SRO candidates.

3. If this is the first JPM of the JPM set, read the JPM briefing contained NUREG 1021, Appendix E, or similar to the trainee.

Read the following to trainee.

TASK CONDITIONS:

1. Unit Two is operating at power.

2. 0PT-13.1, Reactor Recirculation Jet Pump Operability is being performed.

3. Another operator has recorded data required for the PT in Section 7.3, and on Attachment 2, Test Information Work Sheet 1.

INITIATING CUE:

You are directed to evaluate the data for Jet Pump performance, determine if acceptance criteria is met, and inform the Unit CRS of the results.

LOT-ADM-JP-002-01 Page 3 of 9 REV. 01

Evaluate Jet Pump Performance Per PT-13.1.

PERFORMANCE CHECKLIST NOTE: Sequence is assumed unless denoted in the Comments.

Step 1 - Obtain a current revision of 0PT-13.1 and 2OP-02.

Current Revision of 0PT-13.1 and 2OP-02 obtained and verified, if applicable.

SAT/UNSAT*

NOTE: The following steps require evaluation of curves located in 2OP-02, Figures 3.1, 3.2, 4.1, 4.2, 5.1, 5.2 and 6.1 through 6.10.

Step 2 - Confirm Recirc Pump A flow is within the band of the established curves.

Determine Recirc Pump A flow is NOT within the band of 2OP-02, Figure 3.1.

- CRITICAL STEP ** SAT/UNSAT*

Step 3 - Confirm Recirc Pump B flow is within the band of the established curves.

Determine Recirc Pump B flow is within the band of 2OP-02, Figure 3.2.

SAT/UNSAT*

Step 4 - Confirm Jet Pump loop A flow is within the band of the established curves.

Determine Jet Pump Loop A flow is NOT within the band of 2OP-02, Figure 4.1.

- CRITICAL STEP ** SAT/UNSAT*

Step 5 - Confirm Jet Pump loop B flow is within the band of the established curves.

Determine Jet Pump Loop B flow is within the band of 2OP-02, Figure 4.2.

SAT/UNSAT*

LOT-ADM-JP-002-01 Page 4 of 9 REV. 01

Evaluate Jet Pump Performance Per PT-13.1.

Step 6 - Calculate average jet pump % psid for each loop.

Determines Loop A average is 30% and Loop B average is 40%.

SAT/UNSAT*

Step 7 - Compare the % psid for each jet pump and calculated average jet pump % psid for each loop with the established curves (2OP-02, Figures 5.1 through 5.10).

Determine jet pump 3 falls outside the established curve in 2OP-02, Figure 5.2 (all other jet pumps within limits)

- CRITICAL STEP ** SAT/UNSAT*

PROMPT: Attachment 2, Work Sheet 2 results are the same as Attachment 1.

Step 8 - Inform Unit CRS that jet pump 3 fails to meet acceptance criteria.

Unit CRS informed jet pump 3 fails to meet acceptance criteria.

SAT/UNSAT*

PROMPT: For SRO candidates only, direct the examinee to determine any actions required by Tech Specs.

NOTE: The following step is applicable to SRO candidates only Step 9 - Evaluates Tech Spec implications due to inoperable jet pump.

Determines that LCO 3.4.2 is not met, Condition A applies, requiring the unit to be placed in Mode 3 in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

- CRITICAL STEP ** SAT/UNSAT*

TERMINATING CUE: When examinee has evaluated jet pump operability per PT-13.1 (and determined Tech Spec actions if applicable) this JPM is complete.

Comments required for any step evaluated as UNSAT.

LOT-ADM-JP-002-01 Page 5 of 9 REV. 01

Evaluate Jet Pump Performance Per PT-13.1.

LOT-ADM-JP-002-01 Page 6 of 9 REV. 01

Evaluate Jet Pump Performance Per PT-13.1.

RELATED TASKS:

202001B201, Perform Reactor Recirculation Jet Pump Operability Test Per PT-13.1 K/A REFERENCE AND IMPORTANCE RATING:

GEN 2.2.12 3.7/4.1 Knowledge of surveillance procedures.

REFERENCES:

0PT-13.1 2OP-02 TOOLS AND EQUIPMENT:

Copy of 0PT-13.1 Copy of 2OP-02 Calculator ADMINISTRATVE CATEGORY (from NUREG 1123):

Admin A1 - Conduct Of Operations REASON FOR REVISION:

Modified to support 2010-2 NRC Initial License Exam.

LOT-ADM-JP-002-01 Page 7 of 9 REV. 01

Evaluate Jet Pump Performance Per PT-13.1.

Time Required for Completion: 25 Minutes (approximate).

APPLICABLE METHOD OF TESTING Performance: Simulate Actual X Unit: 2 Setting: Classroom X Simulator ( Not applicable to In-Plant JPMs )

Time Critical: Yes No X Time Limit N/A Alternate Path: Yes No X EVALUATION Trainee:

JPM: Pass Fail Remedial Training Required: Yes No Did Trainee Verify Procedure as Authorized Copy? Yes No (Each Student should verify one JPM per evaluation set.)

Comments:

Comments reviewed with Student Evaluator Signature: Date:

LOT-ADM-JP-002-01 Page 8 of 9 REV. 01

TASK CONDITIONS:

1. Unit Two is operating at power.

2. 0PT-13.1, Reactor Recirculation Jet Pump Operability is being performed.

3. Another operator has recorded data required for the PT in Section 7.3, and on Attachment 2, Test Information Work Sheet 1.

INITIATING CUE:

You are directed to evaluate the data for Jet Pump performance, determine if acceptance criteria is met, and inform the Unit CRS of the results.

C BRUNSWICK NUCLEAR PLANT Continuous Use DATE COMPLETED FREQUENCY:

UNIT % PWR GMWE A. Prior to exceeding 25% rated thermal power SUPERVISOR REASON FOR TEST (check one or more) B. Once every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in plant Mode 1 with Routine Surveillance rated thermal power exceeding 25%

W/O # C. Within 4 hrs after associated recirculation Other (explain) loop is in operation, if not performed within the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months PLANT OPERATING MANUAL VOLUME X PERIODIC TEST UNIT 0

0PT-13.1 REACTOR RECIRCULATION JET PUMP OPERABILITY REVISION 39 0PT-13.1 Rev. 39 Page 1 of 10

1.0 PURPOSE 1.1 This test is performed to determine the operability of the reactor recirculation jet pumps in conformance with the requirements specified in Technical Specification SR 3.4.2.1.

1.2 This test involves observation and/or calculation of flow rates and differential pressures of the jet pumps.

2.0 REFERENCES

2.1 Technical Specifications 2.2 FSAR, Section 5.4.1 2.3 1(2)OP-02, Reactor Recirculation System 2.4 0SD-02, Reactor Recirculation System 2.5 EER 92-0155 3.0 PRECAUTIONS AND LIMITATIONS None 4.0 PREREQUISITES 4.1 No other testing or maintenance is in progress that will adversely affect the performance of this test.

4.2 The Reactor Recirculation System is in 2-pump operation per 1(2)OP-02.

4.3 The unit is in Mode 1 (Run).

5.0 SPECIAL TOOLS AND EQUIPMENT 5.1 Unit 2 only: A hand-held tachometer, if desired, for obtaining recirculation pump speed.

5.1.1 Tachometer ID number N/A 5.1.2 Tachometer model number 5.1.3 Tachometer serial number 5.1.4 Tachometer calibration date 5.1.5 Tachometer calibration due date N/A 0PT-13.1 Rev. 39 Page 2 of 10

6.0 ACCEPTANCE CRITERIA NOTE: The established curves located in 1(2)OP-02, Reactor Recirculation System Operating Procedure, have been determined using normal expected values, a bandwidth that includes expected data scatter, and the allowable percentages in Technical Specifications.

6.1 This test may be considered satisfactory when either of the following conditions exist for each operating recirculation loop.

6.1.1 Both recirculation pump flows are within the region bounded by the established speed-flow characteristic curves AND Both jet pump loop flows are within the region bounded by the established speed-flow characteristic curves.

OR 6.1.2 The diffuser-to-lower plenum % psid reading on all operating individual jet pumps is within the region bounded by the established curves.

7.0 PROCEDURAL STEPS Initials 7.1 OBTAIN permission from the Unit CRS to perform this test.

7.2 ENSURE that all prerequisites listed in Section 4.0 are met.

7.3 Jet Pump Operability Test 7.3.1 RECORD the following information:

1. Time of test NOW

2. Reactor power level 96.6%

NOTE: Normally, recirculation loop flows should be approximately the same. Unit 1 pump speed may be obtained from the Calculated Speed indicator on Panel P603. Unit 2 pump speed may be obtained from pump speed control percent speed indicator or hand-held tachometer. If a hand-held tachometer is utilized, a 100% reference speed of 1150 rpm should be used.

3. Recirculation Pump A speed 88 %.

4. Recirculation Pump B speed 88 %.

0PT-13.1 Rev. 39 Page 3 of 10

7.0 PROCEDURAL STEPS Initials NOTE: The preferred method of flow indication is from Flow Recorder B32-FR-R614.

If flow Recorder B32-FR-R614 is inoperable, Flow Indicators B32-FI-R613 and B32-FI-R617 should be used.

5. Recirculation Pump A flow 52 gpm x 1000.

6. Recirculation Pump B flow 43 gpm x 1000.

7. Jet Pump Loop A flow from Flow Indicator B21-FI-R611A 30 lbs/hr x 106.

8. Jet Pump Loop B flow from Flow Indicator B21-FI-R611B 39 lbs/hr x 106.

NOTE: The established curves for Steps 7.3.2 through 7.3.7 are located in 1(2)OP-02, Reactor Recirculation System Operating Procedure.

7.3.2 RECORD the current revision number of 1(2)OP-02, Reactor Recirculation System Operating Procedure.

142 Revision number 7.3.3 CONFIRM Recirculation Pump A flow is within the band of the established curves.

7.3.4 CONFIRM Recirculation Pump B flow is within the band of the established curves.

7.3.5 CONFIRM Jet Pump Loop A flow is within the band of the established curves.

7.3.6 CONFIRM Jet Pump Loop B flow is within the band of the established curves.

0PT-13.1 Rev. 39 Page 4 of 10

7.0 PROCEDURAL STEPS Initials NOTE: Individual jet pump % psid may be read directly from B21-PDI-R608 on Panel H12-P619 or may be calculated using Attachment 2, Work Sheet 2.

Work Sheet 2, however, should be used at either low recirculation flow, coolant temperature other than normal or, when higher accuracy is desired.

Work Sheet 2 is performed by I&C Maintenance, but may be discarded if not needed.

7.3.7 COMPLETE Attachment 2.

7.3.8 CONFIRM all individual jet pumps are within the band of the established curves.

7.3.9 ENSURE that the required information has been recorded on the cover page.

7.3.10 NOTIFY the Unit CRS when this test is complete or found to be unsatisfactory.

0PT-13.1 Rev. 39 Page 5 of 10

ATTACHMENT 1 Page 1 of 1 Certification and Review Form General Comments and Recommendations Initials Name (Print)

Performed by:

Exceptions to satisfactory performance Corrective action required (WR No: )

Test procedure has been satisfactorily completed.

Unit CRS/SRO:

Signature Date Test procedure has NOT been satisfactorily completed.

Unit CRS/SRO:

Signature Date Test has been reviewed by:

Shift Manager:

Signature Date 0PT-13.1 Rev. 39 Page 6 of 10

ATTACHMENT 2 Page 1 of 3 Test Information Work Sheet 1 CALCULATE AND EVALUATE Jet Pump operability as follows:

1. RECORD individual jet pump % psid.

2. CALCULATE average jet pump % psid for each loop.

3. DETERMINE acceptability of test.

a. COMPARE the % psid for each jet pump AND calculated average jet pump% psid for each loop with the established curves.

b. IF the jet pump is inside/outside the region bound by the established curves, THEN CIRCLE SAT/UNSAT as appropriate.

LOOP A LOOP B

% PSID SAT/UNSAT % PSID SAT/UNSAT (circle) (circle)

JP 1 30 SAT/UNSAT JP 11 40 SAT/UNSAT JP 2 32 SAT/UNSAT JP 12 42 SAT/UNSAT JP 3 20 SAT/UNSAT JP 13 39 SAT/UNSAT JP 4 33 SAT/UNSAT JP 14 43 SAT/UNSAT JP 5 32 SAT/UNSAT JP 15 40 SAT/UNSAT JP 6 33 SAT/UNSAT JP 16 38 SAT/UNSAT JP 7 31 SAT/UNSAT JP 17 39 SAT/UNSAT JP 8 32 SAT/UNSAT JP 18 38 SAT/UNSAT JP 9 26 SAT/UNSAT JP 19 39 SAT/UNSAT JP 10 31 SAT/UNSAT JP 20 42 SAT/UNSAT TOTAL TOTAL AVERAGE (TOTAL ÷ 10) AVERAGE (TOTAL ÷ 10) 0PT-13.1 Rev. 39 Page 7 of 10

ATTACHMENT 2 Page 2 of 3 Test Information Work Sheet 2 Unit 1 CALCULATE Jet Pump % psid per the following:

1. RECORD mV reading for dP transmitter output for each jet pump.

The preferred locations to obtain data are Test Point 1 and Test Point 2 of the associated square root converter.

2. SUBTRACT 10.00 mV from reading taken in Step 1.

3. MULTIPLY the number calculated in Step 2 by 0.72 to convert mV to dP.

4. MULTIPLY the number calculated in Step 3 by 2.78 to convert dP to

% psid.

5. TRANSFER the number calculated in Step 4 to Work Sheet 1.

STEP 1 STEP 3 STEP 4 FT STEP 2 (mV-10.00) (mV-10.00)

OUTPUT mV - 10.00 (0.72) (0.72) (2.78)

JP 1 - B21-FY-K600A JP 2 - B21-FY-K600C JP 3 - B21-KY-K600E JP 4 - B21-KY-K600G JP 5 - B21-FY-K600J JP 6 - B21-FY-K600L JP 7 - B21-FY-K600N JP 8 - B21-FY-K600R JP 9 - B21-FY-K600T JP 10 - B21-FY-K600V JP 11 - B21-FY-K600B JP 12 - B21-FY-K600D JP 13 - B21-FY-K600F JP 14 - B21-FY-K600H JP 15 - B21-FY-K600K JP 16 - B21-FY-K600M JP 17 - B21-FY-K600P JP 18 - B21-FY-K600S JP 19 - B21-FY-K600U JP 20 - B21-FY-K600W 0PT-13.1 Rev. 39 Page 8 of 10

ATTACHMENT 2 Page 3 of 3 Test Information Work Sheet 2 Unit 2 CALCULATE Jet Pump % psid per the following:

1. RECORD mV reading for dP transmitter output for each jet pump.

The preferred locations to obtain data are Test Point 1 and Test Point 2 of the associated square root converter.

2. SUBTRACT 10.00 mV from reading taken in Step 1.

3. MULTIPLY the number calculated in Step 2 by 0.74 to convert mV to dP.

4. MULTIPLY the number calculated in Step 3 by 2.70 to convert dP to

% psid.

5. TRANSFER the number calculated in Step 4 to Work Sheet 1.

STEP 1 STEP 3 STEP 4 FT STEP 2 (mV-10.00) (mV-10.00)

OUTPUT mV - 10.00 (0.74) (0.74) (2.70)

JP 1 - B21-FY-K600A JP 2 - B21-FY-K600C JP 3 - B21-KY-K600E JP 4 - B21-KY-K600G JP 5 - B21-FY-K600J JP 6 - B21-FY-K600L JP 7 - B21-FY-K600N JP 8 - B21-FY-K600R JP 9 - B21-FY-K600T JP 10 - B21-FY-K600V JP 11 - B21-FY-K600B JP 12 - B21-FY-K600D JP 13 - B21-FY-K600F JP 14 - B21-FY-K600H JP 15 - B21-FY-K600K JP 16 - B21-FY-K600M JP 17 - B21-FY-K600P JP 18 - B21-FY-K600S JP 19 - B21-FY-K600U JP 20 - B21-FY-K600W 0PT-13.1 Rev. 39 Page 9 of 10

REVISION

SUMMARY

Revision 39 is an editorial change that re-formats Acceptance Criteria 6.1.1 for clarity.

Either both items in 6.1.1. or 6.2.2. must be met.

Revision 38 is an editorial correction for verb use.

Revision 37 incorporates PRR395440 for EC 68547 which revises Section 5.0 equipment list and a Note identifying Calculated Speed as the parameter to use for obtaining Unit 1 Recirc Pump speed, incorporates PRR325270 by adding SAT/UNSAT to each Jet Pump on Page 1 of Attachment 2, incorporates PRR337228 by adding place keeping boxes on Attachment 2, and changes miscellaneous management titles. These procedure changes are classified as Editorial Corrections.

Revision 36 incorporated PRR306780 by moving step for recording revision number of 1(2)OP-02 to prior to use.

Revision 35 is an editorial change that added the tachometer ID number in Section 5.0 and changed the procedure from Desdemona font to the latest format.

Revision 34 removes the single loop surveillance requirements. A new Periodic test specific for single loop operation has been developed.

Revision 33 adds specific acceptance criteria for operation in single loop, clarifies the established criteria is for operating loops, and deletes "use single tap jet pumps only" from Work Sheet 2.

Revision 32 clarifies the frequency by adding, "if not performed within the previous 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " to the within 4 hrs after associated recirculation loop is in operation requirement.

The term Condition was changed to Mode.

0PT-13.1 Rev. 39 Page 10 of 10

FIGURE 3.1 Page 1 of 1 Recirculation Pump A Speed-Flow Characteristic Curve 2OP-02 Rev. 142 Page 90 of 157

FIGURE 3.2 Page 1 of 1 Recirculation Pump B Speed-Flow Characteristic Curve 2OP-02 Rev. 142 Page 91 of 157

FIGURE 4.1 Page 1 of 1 Jet Pump Loop A Speed-Flow Characteristic Curve 2OP-02 Rev. 142 Page 92 of 157

FIGURE 4.2 Page 1 of 1 Jet Pump Loop B Speed-Flow Characteristic Curve 2OP-02 Rev. 142 Page 93 of 157

FIGURE 5.1 Page 1 of 1 Jet Pumps 1 and 2 % PSID vs. Loop A Average % PSID 2OP-02 Rev. 142 Page 94 of 157

FIGURE 5.2 Page 1 of 1 Jet Pumps 3 and 4 % PSID vs. Loop A Average % PSID 2OP-02 Rev. 142 Page 95 of 157

FIGURE 5.3 Page 1 of 1 Jet Pumps 5 and 6 % PSID vs. Loop A Average % PSID 2OP-02 Rev. 142 Page 96 of 157

FIGURE 5.4 Page 1 of 1 Jet Pumps 7 and 8 % PSID vs. Loop A Average % PSID 2OP-02 Rev. 142 Page 97 of 157

FIGURE 5.5 Page 1 of 1 Jet Pumps 9 and 10 % PSID vs. Loop A Average % PSID 2OP-02 Rev. 142 Page 98 of 157

FIGURE 5.6 Page 1 of 1 Jet Pumps 11 and 12 % PSID vs. Loop B Average % PSID 2OP-02 Rev. 142 Page 99 of 157

FIGURE 5.7 Page 1 of 1 Jet Pumps 13 and 14 % PSID vs. Loop B Average % PSID 2OP-02 Rev. 142 Page 100 of 157

FIGURE 5.8 Page 1 of 1 Jet Pumps 15 and 16 % PSID vs. Loop B Average % PSID 2OP-02 Rev. 142 Page 101 of 157

FIGURE 5.9 Page 1 of 1 Jet Pumps 17 and 18 % PSID vs. Loop B Average % PSID 2OP-02 Rev. 142 Page 102 of 157

FIGURE 5.10 Page 1 of 1 Jet Pumps 19 and 20 % PSID vs. Loop B Average % PSID 2OP-02 Rev. 142 Page 103 of 157

PROGRESS ENERGY CAROLINAS BRUNSWICK TRAINING SECTION JOB PERFORMANCE MEASURE ADMIN NRC ADMIN EPOO1 (SRO)

LESSON TITLE: Make Protective Action Recommendations Per PEP-02.6.28 REVISION NO: 00

Protective Action Recommendations SAFETY CONSIDERATIONS:

None.

EVALUATOR NOTES: (Do not read to performer)

1. If this is the first JPM of the JPM set, read the JPM briefing contained NUREG 1021, Appendix E, or similar to the performer.

2. The examinee will be provided a copy of FG1.1 Emergency Notification Form. (The DRILL box is filled in to ensure no confusion of ENF at anytime following JPM)

3. The examinee will be provided a copy of 0PEP-02.6.28 & 0PEP-2.6.21.

4. A clock must be available in the classroom in view to examiner and examinees.

5. Copies of all remaining PEPs should be available upon request.

6. Task standards (i.e. pass/fail criteria) for each JPM step are ITALICIZED below the step.

7. Emphasize to candidates that this is a Time Critical JPM and that following cue sheet review the evaluator will designate the START TIME on the board and stop the JPM at the applicable critical time.

Read the following to the JPM performer.

TASK CONDITIONS:

- This is a Time Critical JPM**

Time begins when directed by the evaluator You are the Control Room Site Emergency Coordinator (SEC) just declaring a General Emergency based upon EAL# FG1.1 - Loss of any two barriers AND Loss or potential loss of the third barrier (Table F-1) due to low RPV water level causing fuel failure.

The following conditions exist:

1. Unit One is operating at 100% power.

2. Unit Two was shutdown 20 minutes ago.

3. Wind Direction is from 356 degrees.

4. Wind Speed is 5 mph.

5. No rain with a Stability Class of B.

6. No radiological releases have occurred.

INITIATING CUE:

As the Control Room Site Emergency Coordinator (SEC), complete the Emergency Notification Form (ENF) for the General Emergency conditions above, to allow notifications to be made by the Emergency Communicator.

SOT-ADM-JP-301-A17 Page 2 of 10 REV. 00

Protective Action Recommendations ANSWER KEY SOT-ADM-JP-301-A17 Page 3 of 10 REV. 00

Protective Action Recommendations PERFORMANCE CHECKLIST NOTE: Sequence is assumed unless denoted in the Comments.

Step 1 - Obtain a current revision of PEP-02.6.28 and PEP-02.6.21 if required.

Current Revision of PEP-02.6.28 and PEP-02.6.21 obtained.

SAT/UNSAT*

PROMPT: Ensure a clock is visible for candidates. Announce and Write the Start Time on the board.

NOTE: State and County notification of GE and PAR within 15 minutes of Declaration is Critical.

ENF completion / approval within 15 minutes is not critical.

TIME START ___________

NOTE: The order in which the ENF is filled out is not critical.

Step 2 - References PEP-02.6.28, Attachment 1.

Determines no impediments to evacuation.

SAT/UNSAT*

Step 3 - References PEP-02.6.28, Attachment 1.

Determines evacuation of Zone A,B, and 10 miles downwind and shelter per Attachment 2.

SAT/UNSAT*

SOT-ADM-JP-301-A17 Page 4 of 10 REV. 00

Protective Action Recommendations Step 4 - Evaluates ENF for missing required information.

Fills in INITIAL block for Step 2.

SAT/UNSAT*

NOTE: When the SEC has determined that an EAL threshold has been exceeded, a peer check done, and the event declared, it is acceptable for the SEC, prior to having a completed Emergency Notification Form, to direct the Control Room Emergency Communicator to get the state and local governmental agencies on the phone and verbally communicate the Emergency Classification. When the Emergency Classification has been communicated to at least one offsite agency the notification time is recorded for documentation on the Emergency Notification Form. If the event is classified as a General Emergency the verbal communication must also include the Protective Action Recommendations.

Step 5 - Evaluates ENF for missing required information Fills in EVACUATE block for Step 5, PROTECTIVE ACTION RECOMMENDATIONS.

- CRITICAL STEP** SAT/UNSAT*

Step 6 - Determines areas to evacuate from PEP-02.6.28, Attachment 2.

Enters Zones A,B,C,M,N on EVACUATE line for Step 5 based on wind direction of 356 degrees.

- CRITICAL STEP** SAT/UNSAT*

Step 7 - Evaluates ENF for missing required information Fills in SHELTER block for Step 5, PROTECTIVE ACTION RECOMMENDATIONS.

- CRITICAL STEP** SAT/UNSAT*

Step 8 - Determines areas to shelter from PEP-02.6.28, Attachment 2.

Enters Zones D,E,F,G,H,J,K,L on SHELTER line for Step 5 based on wind direction of 356 degrees.

- CRITICAL STEP** SAT/UNSAT*

SOT-ADM-JP-301-A17 Page 5 of 10 REV. 00

Protective Action Recommendations Step 9 - Evaluates ENF for missing required information Fills in NONE block for Step 6, EMERGENCY RELEASE.

- CRITICAL STEP** SAT/UNSAT*

Step 10 - Evaluates ENF for missing required information Fills in Not applicable block for Step 7, RELEASE SIGNIFICANCE.

SAT/UNSAT*

NOTE: GE is the highest emergency classification and therefore Degrading would not be correct.

Step 11 - Evaluates ENF for missing required information Fills in Stable block for Step 8, EVENT PROGNOSIS.

SAT/UNSAT*

NOTE: Approval of the Emergency Notification Form and initiation of off-site notifications should not be delayed for an Initial Notification if the information for Items 9 and 14 thru 16 of the Emergency Notification Form is not readily available. If these items are initially omitted, a follow-up notification shall be made as soon as the information can be obtained.

Step 12 - Evaluates ENF for missing required information and may fill in Step 9 Meteorological Data Wind Direction from 365 degrees Wind Speed 5 mph Precipitation 0 or None Stability Class B box filled in SAT/UNSAT*

Step 13 - Evaluates ENF for missing required information Fills in DECLARATION block for Step 10 AND fills in time (JPM Start) and todays date.

- CRITICAL STEP** SAT/UNSAT*

SOT-ADM-JP-301-A17 Page 6 of 10 REV. 00

Protective Action Recommendations NOTE: Unit 2 is in a GE which affects the Brunswick site. Identifying the affected unit is not critical.

Step 14 - Evaluates ENF for missing required information Fills in 2 block for Step 11, AFFECTED UNIT(S).

SAT/UNSAT*

NOTE: Status of unaffected Unit is not required for initial notification.

Step 15 - Evaluates ENF for missing required information Fills in A block for Step 12, UNIT STATUS and enters 100%

SAT/UNSAT*

Step 16 - Evaluates ENF for missing required information Fills in B block for Step 12, UNIT STATUS and enters 0% with Shutdown at Time 20 minutes prior to declaration time and todays date.

SAT/UNSAT*

Step 17 - Evaluates ENF for missing required information and may enter remarks.

May provide clarifying information in Step 13, REMARKS.

SAT/UNSAT*

SOT-ADM-JP-301-A17 Page 7 of 10 REV. 00

Protective Action Recommendations NOTE: Approval of the Emergency Notification Form and initiation of off-site notifications should not be delayed for an Initial Notification if the information for Items 9 and 14 thru 16 of the Emergency Notification Form is not readily available. If these items are initially omitted, a follow-up notification shall be made as soon as the information can be obtained.

Step 16 - Approves Emergency Notification Form Signs Step 17 APPROVED BY and enters SEC in Title along with the current time and todays date.

- CRITICAL STEP** SAT/UNSAT*

APPROVAL TIME ___________

Step 17 - Gives Emergency Communicator completed ENF or directs EC to communicate GE with appropriate PARs within required the required time (Approved Time minus Declaration Time < 15 minutes).

ENF approval or verbal notification of GE with PARs < 15 minutes of Declaration Time (JPM Start Time).

- CRITICAL STEP** SAT/UNSAT*

TERMINATING CUE: When the ENF is approved, ready for transmittal to State & County with applicable PARs, this JPM is complete.

TIME COMPLETED _____________

NOTE: Comments required for any step evaluated as UNSAT.

SOT-ADM-JP-301-A17 Page 8 of 10 REV. 00

Protective Action Recommendations RELATED TASKS:

344005B102 Recommend Protective Actions To States And Counties per PEP-02.6.28.

K/A REFERENCE AND IMPORTANCE RATING:

GEN 2.4.44 2.4/4.4 Knowledge of emergency plan protective action recommendations.

REFERENCES:

0PEP-02.6.28, Rev. 10 0PEP-02.6.21, Rev. 55 TOOLS AND EQUIPMENT:

Copy of 0PEP-02.6.28 Copy of 0PEP-02.6.21 Copies of ALL PEPs available.

ADMINISTRATIVE CATEGORY (from NUREG 1123, Rev 2., Supp.1):

Admin - Emergency Procedures / Plan REASON FOR REVISION:

New JPM for HLC 2010-2 NRC License Exam.

SOT-ADM-JP-301-A17 Page 9 of 10 REV. 00

Protective Action Recommendations Validation Time: 15 Minutes (approximate).

Time Taken:

APPLICABLE METHOD OF TESTING Performance: Simulate Actual X Unit: 2 Setting: In-Plant Simulator Admin X Time Critical: Yes X No Time Limit 15 min Alternate Path: Yes No X EVALUATION Performer:

JPM: Pass Fail Remedial Training Required: Yes No Comments:

Comments reviewed with Performer Evaluator Signature: Date:

SOT-ADM-JP-301-A17 Page 10 of 10 REV. 00

TASK CONDITIONS:

- This is a Time Critical JPM**

Time begins when directed by the evaluator You are the Control Room Site Emergency Coordinator (SEC) and have just declared a General Emergency based upon EAL# FG1.1 - Loss of any two barriers AND Loss or potential loss of the third barrier (Table F-1) due to low RPV water level causing fuel failure.

The following conditions exist:

1. Unit One is operating at 100% power.

2. Unit Two was shutdown 20 minutes ago.

3. Wind Direction is from 356 degrees.

4. Wind Speed is 5 mph.

5. No rain with a Stability Class of B.

6. No radiological releases have occurred.

INITIATING CUE:

As the Control Room Site Emergency Coordinator (SEC), complete the Emergency Notification Form (ENF) for the General Emergency conditions above, to allow notifications to be made by the Emergency Communicator.

ATTACHMENT 2 Page 1 of 7 Guidance for Completion of Emergency Notification Form LINE NO. INSTRUCTIONS NOTE: Electronic copies of the ENF are accessed and processed via computer using WebEOC.

Attachment 7, WebEOC User Guide, provides guidance. Hard copies of the ENF are also available for use if electronic copies are not available.

NOTE: If using WebEOC there are two BNP NP Events (Incidents) available for use (Brunswick NP Event and Brunswick NP Event 01). (Example; if one event is terminated and shortly after that another event is declared before the first event can be archived.)

NOTE: Completed/approved ENFs will be evaluated in accordance with NEI 99-02, Regulatory Performance Indicator Guideline.

ALL Fill in (blacken) all blocks, as appropriate.

1 A Drill or B ACTUAL EVENT - Mark appropriate block If using WebEOC the MESSAGE NUMBER will be automatically entered. If previous message was hard copy, the Message Number can be changed to the next sequential number.

If hard copy assign a numerical MESSAGE NUMBER. The first notification message is message Number 1, and all others are numbered sequentially.

2 INITIAL OR FOLLOW-UP - Mark appropriate block. INITIAL is the first notification following an upgrade, downgrade or termination. All other messages are FOLLOW-UP until the next change in emergency classification.

NOTIFICATION TIME/DATE - Complete block (in military time) when emergency classification has been verbally communicated to at least one (1) local or State agency. This is considered the official time for initial notifications (within 15 minutes of classification.) If the event is classified as a General Emergency PARs must also be communicate within 15 minutes of the classification.

If using WebEOC information is entered on the Government Agencies Notified form located in the Notifications link. Notification Time/Date can be imported. Verify information is correct, correct if necessary.

If an agency has to be contacted separately for either an Initial or Follow-up Message, then the time the agency is contacted should be documented on Part B of Attachment 1-A or Attachment 1-B, as appropriate.

AUTHENTICATION # - Block is completed when the message is being transmitted. Ask the State if they want to authenticate. Authentication is required if communication method other then Selective Signaling is used to make notification.

If using WebEOC the number provided is entered on the Government Agencies Notified form located in the Notifications link. Number is entered in space provided and the Get Authentication Code button is clicked to obtain the correct code word which is provided to the State. If authentication is not required, enter N/A and click the Get Authentication Code button.

If hard copy request an authentication number from the State. Refer to the associated code word from the code list located in your emergency facility, and mark the block with the appropriate number, or N/A if no authentication is required.

0PEP-02.6.21 Rev. 55 Page 27 of 54

ATTACHMENT 2 Page 2 of 7 Guidance for Completion of Emergency Notification Form LINE NO. INSTRUCTIONS 3 SITE - Verify that Brunswick is entered or enter if necessary.

CONFIRMATION PHONE NUMBER - Enter a phone number which can be dialed from offsite for verification of message authenticity.

If using WebEOC click on the drop down and select appropriate number or enter number using keyboard.

4 EMERGENCY CLASSIFICATION - Mark block for Emergency Classification declared.

BASED ON EAL # -. Complete block with appropriate EAL number from 0PEP-02.1. Enter the specific EAL exceeded which caused the emergency to be declared.

EAL DESCRIPTION - Complete block with description of the EAL (reason for declaring the event).

If using WebEOC click on the dropdown and select the appropriate EAL #, this will also automatically populate the EAL Description.

No other information shall be entered. Additional information associated with the emergency can be entered in the Remarks section.

NOTE: When the site has declared an event due to exceeding an EAL threshold and, subsequently, another EAL of equal or lesser value is exceeded on either unit, it is not required, however permissible, to annotate in the Remarks section of the next ENF any additional EAL(s) which have been met. The site should NOT declare another emergency classification NOTE: For Line 5, once the EOF has responsibility, the RCM is the source for this information.

5 PROTECTIVE ACTION RECOMMENDATIONS - Determined using 0PEP-02.6.28, Offsite Protective Action Recommendations. If the event is classified as a General Emergency PARs must be communicated within 15 minutes of the classification.

If using WebEOC and importing Met Data to determine Protective Action Recommendations (PARs) you must first complete Line 6, 7, and 11, then select Import Plant/MET Data. Imported Met Data for Line 9 is current data.

Met Data entered/imported on Line 9 must match Met Data used for PAR determination. Met Data on Line 9 may need to be changed to match data used for PAR determination.

Mark Block A - NONE for Unusual Event, Alert, and Site Area Emergency classifications.

For General Emergency, mark Block B - EVACUATE and/or Block C - SHELTER; list each of the zones for which the recommendation applies (for example: A, B, C, D, etc...)

Mark Block D - CONSIDER THE USE OF KI (POTASSIUM IODIDE) IN ACCORDANCE WITH STATE PLANS AND POLICY if distribution of KI to the general public is recommended (5 Rem CDE is the North Carolina Limit for checking this box.)

Mark Block E - OTHER if applicable and indicate what the other recommendations are.

(Example: Areas beyond the 10 miles will be considered only on an ad-hoc basis and will be directly communicated with the offsite agencies through the ERM.)

0PEP-02.6.21 Rev. 55 Page 28 of 54

ATTACHMENT 2 Page 3 of 7 Guidance for Completion of Emergency Notification Form LINE NO. INSTRUCTIONS NOTE: For Line 6, 7 and 8, once the EOF has responsibility, the RCM, TAM and EOF SRO are a source for the information.

6 EMERGENCY RELEASE - mark the appropriate block as follows:

Mark block A - None if there is no release occurring. If marked, mark Line 7 A - NOT APPLICABLE and skip Lines 14 through 16.

If using WebEOC Line 7 A will automatically be selected.

If there is an ongoing release which is in excess of the release occurring prior to the event, select Block B - Is Occurring.

If a release has occurred based on the event, select Block C - Has Occurred.

7 RELEASE SIGNIFICANCE - complete blocks as follows:

Mark Block A - Not Applicable if there is no release.

If using WebEOC A will automatically be selected if Line 6 A None was selected.

Mark Block B - Within normal operating limits if release is within normal ODCM limits.

Mark Block C - Above normal operating limits if release is above normal ODCM limits.

Mark Block D - Under evaluation if there is a release, but dose projections have not been completed skip Lines 14 through 16.

8 EVENT PROGNOSIS - mark the appropriate block.

If plant conditions are improving in the direction of a lower emergency classification or a termination of the event, mark A - Improving.

If plant conditions are not degrading and the emergency is under control (Emergency core cooling systems, equipment, plans, etc... are operating as designed; it is not imminent that the situation will worsen), mark B -- Stable.

If plant conditions continue to degrade and it is evident that the situation will worsen; a higher emergency classification is imminent, mark C - Degrading.

0PEP-02.6.21 Rev. 55 Page 29 of 54

ATTACHMENT 2 Page 4 of 7 Guidance for Completion of Emergency Notification Form LINE NO. INSTRUCTIONS NOTE: Information for Line 9 may be obtained from the STA (if in the Control Room) or the Radiological Control Manager (if in the EOF).

9 METEOROLOGICAL DATA If using WebEOC and importing Met Data you must first complete Line 6, 7, and 11, then select Import Plant/MET Data. Imported Met Data is current data.

Enter lower wind direction and wind speed if completing hard copy ENF.

CAUTION: Met Data entered on Line 9 must match Met Data used for PAR determination. Met Data on Line 9 may need to be changed to match data used for PAR determination.

NOTE: Information may not be available for Initial Notifications.

Access information from ERFIS, National Weather Service or a meteorological service provider (see EPL-001, Emergency Phone List, for telephone numbers) to complete information as follows.

Enter Wind Direction in degrees. Note: Wind direction must be from.

Enter Wind Speed in mph.

Enter Precipitation in inches.

Mark appropriate block for Stability Class.

10 DECLARATION (time for classification on Line 4) or TERMINATION - mark appropriate block and indicate the time of the declaration or termination in the Time / Date space.

If using WebEOC verify that the Declaration Time/Date is correct, correct if necessary.

Termination messages do not require Lines 11 through 16 to be completed; however, it is advisable to describe the bases for the termination in Line 13.

11 AFFECTED UNIT(S) - mark appropriate block. If event affects both Units, indicate Unit 1 and 2.

If using WebEOC and event affects Unit 1 and Unit 2 mark Both 0PEP-02.6.21 Rev. 55 Page 30 of 54

ATTACHMENT 2 Page 5 of 7 Guidance for Completion of Emergency Notification Form LINE NO. INSTRUCTIONS NOTE: For Line 12 once the EOF has responsibility, the TAM and EOF SRO are a source for the information 12 UNIT STATUS - information for Unit(s) specified on Line 11. If both Units, then include status for both.

NOTE: Unaffected Unit status is not required for Initial Notifications. Must be provided in a Follow-Up notification as soon as information is available

Complete blocks A and B for current reactor power level.

If using WebEOC imported Plant/Met Data Unit Status will be entered for both units If using WebEOC and imported plant data, verify that the % Power does not exceed 100%.

If % Power exceeds 100% change to indicate 100%.

If reactor is shutdown, indicate the time/date of shutdown.

If using WebEOC the actual shutdown time/date must be determined and manually entered.

NOTE: For off-site notification purposes, the reactor is considered SHUTDOWN (under all conditions) by any ONE of the following:

1. All control rods fully inserted.

2. All control rods fully inserted with the exception of 1 (one) control rod at any withdrawn position.

3. All control rods fully inserted with the exception of up to 10 (ten) control rods withdrawn to position 02.

4. As determined by Reactor Engineering.

13 REMARKS - Complete section with a short narrative of the event in progress in laymans terms. Do Not use acronyms. Include the following types of information:

BNP emergency response actions underway, for example, site evacuation.

Requests for offsite assistance, for example, ambulance or fire support.

Facility activation status, i.e., Technical Support Center, Operational Support Center, Emergency Operations Facility, Joint Information Center.

0PEP-02.6.21 Rev. 55 Page 31 of 54

ATTACHMENT 2 Page 6 of 7 Guidance for Completion of Emergency Notification Form LINE NO. INSTRUCTIONS NOTE: Information for Lines 14 through 16 may be obtained from the STA (if in the Control Room) or the Radiological Control Manager (if in the EOF).

NOTE: If an Initial Notification and information for Lines 14 thru 16 is not readily available, it may be omitted so the notification is not delayed. A follow-up notification shall be made after the information is obtained.

14 RELEASE CHARACTERIZATION - mark the following information:

TYPE - mark the appropriate block for type of release as follows:

o A - Elevated - if release is from the stack mark block.

o B - Mixed applies to Robinson Plant only.

o C - Ground - if release is from a location other than the stack, or if release is airborne, and the location is unknown, mark block.

If using WebEOC option D - Elevated & Ground is also available. If selected, Dose projection date will not import. Information must be entered manually.

UNITS Mark block A to describe release magnitude in Curies.

If using WebEOC A will automatically be selected.

MAGNITUDE - complete block as follows:

o Mark N/A for Noble Gases, Iodines, and Particulates (unless the State makes a request for that information.)

o Using the dose projection output, enter total curies released under Other.

If using WebEOC and importing dose projection data Other will auto populate with total curies released. N/A for Noble Gases, Iodines, and Particulates should also auto populate.

Mark the appropriate block describing FORM - mark the appropriate block describing the form of release A - Airborne or B - Liquid, and record Start - Time/Date, and Stop

- Time/Date.

If using WebEOC and selecting Get Start Time/Date and Get Stop Time/Date verify the information is correct, correct if necessary.

15 PROJECTION PARAMETERS - complete information as follows:

If using WebEOC, and importing dose projection data, projection parameters will auto populate.

Verify Projection performed Time and Date with RCM to verify correct dose projection data has been entered. Correct if necessary.

Record the Projection Period block (in hours) and Estimated Release Duration block from RASCAL (in hours).

NOTE: Estimated Release Duration default is six (6) hours.

Record time / date dose projection data was collected in space marked Projection performed, time / date from RASCAL.

0PEP-02.6.21 Rev. 55 Page 32 of 54

ATTACHMENT 2 Page 7 of 7 Guidance for Completion of Emergency Notification Form LINE NO. INSTRUCTIONS 16 PROJECTED DOSE - record results in columns, ensuring units are in mrem.

If using WebEOC, and importing dose projection data, columns will auto populate.

PERFORM LINE-BY-LINE REVIEW / VALIDATION 17 APPROVED BY

Obtain signature/approval of SEC (if notification from the Control Room) or ERM (if notification from the EOF) prior to transmittal of the form. Ensure title, time, and date of approval is completed.

If using WebEOC:

Name is entered and the title is selected from the drop down menu. If in the Control Room, the initials of the individual who performed the independent verification will be entered next to the name of the individual who approves the form

Once form has been approved changes cannot be made.

o If the form has already been transmitted a follow-up message would have to be sent identifying the incorrect information.

o If the form has not been transmitted another form can be developed, but because the message number auto populates a statement in the Remarks section would have to be made identifying that the previous message will not be sent.

Verify the time and date is correct, correct if necessary.

Any change made or information added between approval of the form and transmittal must be initialed/approved by the SEC or ERM.

Print the name of the person who will be notifying the State / Counties in the NOTIFIED BY space.

Disregard the RECEIVED BY and time/date information. This will be completed by the offsite agency upon receipt of the message.

0PEP-02.6.21 Rev. 55 Page 33 of 54

ATTACHMENT 1 Page 1 0f 1 PAR Flowchart NOTES:

1. Shelter remaining zones to have population 4. A protective action recommendation should not be indoors to monitor EAS broadcasts. reduced from the initial recommendation for any

2. Shelter may be the appropriate action for zone until the release is terminated, and the controlled releases of radioactive material from decision is coordinated with the state and counties.

containment if there is assurance that the The following guides should be considered prior to release is short term (puff release) and the area reducing a protective action recommendation:

near the plant cannot be evacuated before the a. Long term weather forecast conditions are plume arrives. obtained with a high degree of confidence in

3. For actual or projected doses > 1 Rem TEDE or the forecast. No sea-breeze in effect.

> 5 Rem CEDE (Thyroid), declare a General b. Radiological environmental conditions are Emergency and recommend evacuation of the defined.

general population from the affected areas. c. Plant conditions are stabilized.

Recommend use of KI if projected or actual d. Population dose savings are quantifiable as a dose is > 5 Rem CEDE (Thyroid). result of the protective action recommendation change, and the decision is ALARA.

0PEP-02.6.28 Rev. 10 Page 10 of 15

ATTACHMENT 2 Page 1 of 2 Evacuation Zones/Time Estimates/10 Mile EPZ Map WIND FROM EVACUATE ZONES SHELTER MAXIMUM ZONES EVACUATION TIMES (hours)

SUMMER/WINTER 180° - 195° A,B,G,H,J,K C,D,E,F,L,M,N 8:40 4:00 196° - 236° A,B,H,J,K,L C,D,E,F,G,M,N 10:00 4:00 237° - 271° A,B,J,K,L,M C,D,E,F,G,H,N 10:00 4:00 272° - 288° A,B,J,L,M C,D,E,F,G,H,K,N 8:40 4:00 289° - 316° A,B,L,M,N C,D,E,F,G,H,J,K 8:40 3:50 317° - 327° A,B,M,N C,D,E,F,G,H,J,K,L 8:40 3:50 328° - 009° A,B,C,M,N D,E,F,G,H,J,K,L 16:30 4:30 010° - 021° A,B,C,D,M,N E,F,G,H,J,K,L 17:00 7:20 022° - 038° A,B,C,D,E,M,N F,G,H,J,K,L 17:30 7:40 039° - 051° A,B,C,D,E F,G,H,J,K,L,M,N 17:30 7:40 052° - 090° A,B,C,D,E,F G,H,J,K,L,M,N 17:30 7:40 091° - 112° A,B,D,E,F C,G,H,J,K,L,M,N 17:20 7:30 113° - 179° A,B,E,F,G,H,J C,D,K,L,M,N 9:50 6:30 ALL ZONES IN A,B,C,D,E,F,G,H,J,K,L,M,N 17:30 7:40 10 MILE EPZ If projected or actual dose is > 5 Rem CDE (thyroid), recommend use of KI.

0PEP-02.6.28 Rev. 10 Page 11 of 15

PROGRESS ENERGY CAROLINAS BRUNSWICK TRAINING SECTION JOB PERFORMANCE MEASURE ADMIN NRC ADMIN RCOO1 (RO/SRO)

LESSON TITLE: Determine Stay Time Limitations in High Radiation Area REVISION NO: 2 LOT-ADM-JP-102-A03 Page 1 of 9 Rev.0

SAFETY CONSIDERATIONS:

None.

EVALUATOR NOTES: (Do not read to performer)

1. The attached Radiological Survey WILL be provided to the candidate.

2. If this is the first JPM of the JPM set, read the JPM briefing contained in NUREG 1021, Appendix E, or similar to the performer.

3. Task standards (i.e. pass/fail criteria) for each JPM step are ITALICIZED below each step.

Read the following to the JPM performer.

TASK CONDITIONS:

Two PGN workers will be performing a coupling alignment on the Unit One RWCU Pump 1B.

Worker #1 has accumulated 1535 mrem this year.

Worker #2 has accumulated 1475 mrem this year.

The following times for each worker have been estimated for performance of the job.

1. Staging time in access area directly outside the RWCU room 30 minutes

2. Staging time in area directly inside room access door 30 minutes

3. Work time at the A RWCU pump 2.0 hours0 days 0 hours 0 weeks 0 months

4. Following completion of the job, an additional 40 mrem per worker will be received during de-staging activities and transit back to the maintenance shop.

INITIATING CUE:

Using the information above and the provided radiological survey using best ALARA practices:

1. Determine the projected total accumulated dose for both workers. (Assume the same task times for both workers)

2. Determine if any Brunswick administrative dose limitations will be exceeded if the workers were to receive the projected dose.

LOT-ADM-JP-102-A03 Page 2 of 9 Rev.0

ANSWER KEY WORKER #1 WORKER #2 INITIAL DOSE 1535 mrem 1475 mrem PROJECTED DOSE 575 575 PROJECTED TOTAL DOSE 2110 2050 PGN ADMIN DOSE LIMIT EXCEEDED YES NO YES NO (Circle Yes or No)

LOT-ADM-JP-102-A03 Page 3 of 9 Rev.0

PERFORMANCE CHECKLIST NOTE: Sequence is assumed unless denoted in the Comments.

NOTE: Provide the candidate the attached survey map TIME START ___________

Step 1 - Determines dose for each worker as follows:

a. Staging time in access area directly outside the RWCU room (30 min) 0.5 Hr X 20 mr/hr = 10 mrem Estimate 10 mrem dose accumulation.

- CRITICAL STEP** SAT/UNSAT

b. Staging time in area directly inside room access door (30 min) 0.5 Hr X 50 mr/hr = 25 mrem Estimate 25 mrem dose accumulation.

- CRITICAL STEP** SAT/UNSAT

c. Work time at the A RWCU pump 2.0 Hrs X 250 mr/hr = 500 mrem Estimate 500 millirem dose accumulation.

- CRITICAL STEP** SAT/UNSAT LOT-ADM-JP-102-A03 Page 4 of 9 Rev.0

d. An additional 40 mr will be accumulated once the job is done for de-staging activities.

Total = 10 + 25 + 500 + 40 = 575 mrem

- CRITICAL STEP** SAT/UNSAT Step 2 - Determines that BOTH workers would exceed the Brunswick administrative limit of 2 REM per calendar year if the estimated dose were accumulated.

Worker #1 1535 mr + 575 mr = 2110 mr (> 2R limit)

Worker #2 1475 mr + 575 mr = 2050 mr (> 2R limit)

- CRITICAL STEP** SAT/UNSAT TERMINATING CUE: When the total dose for each worker has been determined and the administrative limits addressed, the JPM is complete.

TIME COMPLETED _____________

NOTE: Comments required for any step evaluated as UNSAT.

LOT-ADM-JP-102-A03 Page 5 of 9 Rev.0

RELATED TASKS:

CLS-LP-102-A 7. Given a persons exposure history, determine any administrative or general limits which have been violated.

K/A REFERENCE AND IMPORTANCE RATING:

GEN 2.3.7 3.5/3.6 Ability to comply with radiation work permit requirements during normal and abnormal conditions

REFERENCES:

HPS-NGGC-0003 DOS-NGGC-0004 TOOLS AND EQUIPMENT:

Survey Map Calculator SAFETY FUNCTION (from NUREG 1123):

Admin - Radiation Control REASON FOR REVISION:

Modified for 2010-2 NRC License Exam LOT-ADM-JP-102-A03 Page 6 of 9 Rev.0

Validation Time: 15 Minutes (approximate).

Time Taken:

APPLICABLE METHOD OF TESTING Performance: Simulate Actual Unit: 1 Setting: In-Plant Simulator Admin X Time Critical: Yes No X Time Limit N/A Alternate Path: Yes No X EVALUATION Performer:

JPM: Pass Fail Remedial Training Required: Yes No (Reference TAP-411 for evaluation guidance)

Comments:

Comments reviewed with Performer Evaluator Signature: Date:

LOT-ADM-JP-102-A03 Page 7 of 9 Rev.0

TASK CONDITIONS:

Two PGN workers will be performing a coupling alignment on the Unit One RWCU Pump 1B.

Worker #1 has accumulated 1535 mrem this year.

Worker #2 has accumulated 1475 mrem this year.

The elevator is out of service.

The following times for each worker have been estimated for performance of the job.

1. Staging time in access area directly outside the RWCU room 30 minutes

2. Staging time in area directly inside room access door 30 minutes

3. Work time at the A RWCU pump 2.0 hours0 days 0 hours 0 weeks 0 months

4. Following completion of the job, an additional 40 mrem per worker will be received during de-staging activities and transit back to the maintenance shop.

INITIATING CUE:

Using the information above and the provided radiological survey using best ALARA practices:

1. Determine the projected total accumulated dose for both workers. (Assume the same task times for both workers)

2. Determine if any Brunswick administrative dose limitations will be exceeded if the workers were to receive the projected dose.

ML111020330

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