Text

Initial Exam 2010-302 Final Administrative JPMs
	ML111020339
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: ML111020339 (182)
	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 3.75 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 14.1 K

2. Grounded Bus P

3. Required Actions (SRO Only) 2OP-51 Action Steps

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 2 (ground resistance 15k) Actions:

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

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

0AI-115 Action Steps 6.3 Action Level 2 ( 15k) 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.

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.

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*

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 = 14.1 K ohms 0.46 mA +3.75 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.

14.1 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 2.

- CRITICAL STEP ** SAT/UNSAT*

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

DC Ground Calculation Step 8a - Documents Action Level 2 Actions on cue sheet.

Determines 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.

- CRITICAL STEP ** SAT/UNSAT*

Step 8b - Documents Action Level 2 Actions on cue sheet.

Determines ground hunting / isolation activities are required with continuous Maintenance support IAW ADM-NGGC-0104, Attachment 4, with an assigned priority of 1.

- CRITICAL STEP ** SAT/UNSAT*

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

Step 8c - Documents Action Level 2 Actions on cue sheet.

Identifies review of ongoing and scheduled work should be considered and if necessary delayed / rescheduled base upon impact.

SAT/UNSAT*

Step 8d - Documents Action Level 2 Actions on cue sheet.

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 3.75 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. 69 Page 51 of 235

8.1.2 Procedural Steps

8. IF SCR lights do NOT oscillate after the RESET is N/A 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. 69 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. 69 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. 69 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: 3.75 mA Voltage 2B-1: 135 VDC 135 Voltage 2B-2: VDC 2B Resistance = VDC + VDC - 50 = K P (mA) + N (mA) 2OP-51 Rev. 69 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. 69 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 Sunday and are scheduled three days off following Wednesday.

DAY Sun Mon Tue Wed Thur Fri Sat Sun Mon Tue Wed Thur Operator 0600 0600 0600 0600 0600 0500 0600 0600 0600

1 to to to to to Off to to to to Off 1830 1830 1830 1630 2230 1530 1830 1830 1830 Operator 0600 0600 0600 0600 0600 0600 0600 0600

2 to to to to to to Off Off Off to to 1830 1830 1830 1830 1830 2030 1830 1830 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 Sun Mon Tue Wed Thur Fri Sat Sun Mon Tue Wed Thur Operator

1 12.5 12.5 12.5 10.5 16.5 Off 10.5 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 period on Day #9 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 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 Sunday and are scheduled three days off following Wednesday.

DAY Sun Mon Tue Wed Thur Fri Sat Sun Mon Tue Wed Thur Operator 0600 0600 0600 0600 0600 0500 0600 0600 0600

1 to to to to to Off to to to to Off 1830 1830 1830 1630 2230 1530 1830 1830 1830 Operator 0600 0600 0600 0600 0600 0600 0600 0600

2 to to to to to to Off Off Off to to 1830 1830 1830 1830 1830 2030 1830 1830 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.

ADM-NGGC-0206 Rev. 6 Page 16 of 89

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

9.2.2 Outage Work Hour Limits (continued)

5. The MDO requirements associated with the 60-day outage may be extended for each worker in 7-day increments for each non-overlapping 7-day period in which the worker has not worked more than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months during the unit outage during the first 60 days following breaker opening.

6. For security personnel, during the first 60 days of an unplanned security system outage or increased threat condition, no MDO requirements apply.

7. Workers eligible to work outage hours shall meet at least one of the following criteria:

Covered workers at single sites working on outage activities

Covered workers at multi unit sites with one or more units in an outage that are working on outage activities

Covered workers, due to Emergency Response Organization, Fire Brigade, or Security duties, at a multi unit sites with a unit in an outage

Covered workers at multi unit sites that work on both outage activities and operating unit activities are eligible, with the exception described in the following step for licensed operators.

8. Workers Not Eligible to Work Outage Hours

At multi-unit sites when one unit is in an outage, those licensed operators composing the minimum shift complement of operators required under 10 CFR 50.54(m) for the operating unit, including the operator at the controls specified in 10 CFR 50.54(k) and the senior operator in the control room required under 10 CFR 50.54(m)(2)(iii),

are not eligible for the relaxed outage MDO requirements permitted by Section 9.2.2. For a dual unit with one control room, (BNP), this will require 2 reactor operators and 2 senior reactor operators per shift to remain on on-line work hour requirements. These individuals may perform outage activities.

An operator who has been working outage work hours AND has had 2 days off in the previous 7-day period may provide relief to the operator at the controls or the senior operator in the control room, if an appropriately qualified operator who has been working on-line work hours is not immediately available to provide relief. If an operator who has been working outage work hours and has had 2 days off in the previous 7-day period is not immediately available, an operator who has been working outage hours may provide (1) short-term relief (up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ) for the operator at the controls or the senior operator in the control room without a waiver or (2) longer term relief (more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ) under a waiver of the MDO requirement that is applicable to the shift schedule (i.e., 8-, 10-, or 12-hour shifts) for personnel assigned to the operating unit.

ADM-NGGC-0206 Rev. 6 Page 29 of 89

9.2.3 Transitioning Between On-line and Outage

1. When entering an unplanned outage, unplanned security system outage, or increased threat condition, PGN shall be considered to be in compliance with the rule if the schedule for the shift cycle would have provided for the required minimum days off.

2. The following options for managing the transition into or out of an outage can be used:

(1) Using shift cycles or period lengths of less than six weeks in length; (2) Changing shift duration; (3) Using a rolling 6-week average; (4) A new shift cycle or period can be used at the completion of an outage.

9.3 Establishing and Maintaining Covered Worker Status 9.3.1 SSIS

1. During an initial plant unescorted access request (ARF), a supervisor will determine if the individual will be classified as a covered worker by checking the NFR (Nuclear Fatigue Rule) block on the ARF.

2. If classified as a covered worker, information from PeopleSoft will populate the EmpCenter database with name and other required information to determine the appropriate rules to apply to work hour controls. (Operations, Maintenance, Security, etc).

3. When unescorted access is granted, SSIS will send a record to the NFR database indicating the worker has unescorted access. When unescorted access is terminated, SSIS will send a record back to the NFR database indicating the worker no long has unescorted access at that site.

ADM-NGGC-0206 Rev. 6 Page 30 of 89

9.3.2 Covered Worker Administration Tool

1. If a workers covered/non-covered status needs to be changed after initial plant access is requested, the workers supervisor or time coordinator can make the desired change using the Covered Worker Administration Tool.

2. Before a workers status is changed from covered to non-covered, the workers scheduled time in EmpCenter must be cleared. This can be accomplished by assigning a schedule of none using the steps in Section 9.5. For PGN employees this is required to remove any future hours from the L01Z NFR screen in Passport. Failure to do so will result in difficulties approving future payroll timesheets.

3. If a workers category strictness needs to be changed after initial plant access is requested, (i.e. maintenance to operations), the workers supervisor or time coordinator can make the desired change using the Covered Worker Administration Tool.

9.4 Creating/Adding Schedule Templates and Shift Cycles NOTE: EmpCenter software has preloaded schedules/templates with commonly worked schedules. EmpCenter performs all necessary calculations to ensure scheduled work meets all NRC work hour requirements.

1. If no existing schedule meets the requestors needs, refer to the NGG website for Fatigue Management to find the appropriate contact for building the schedule.

2. If needed, the EmpCenter Scheduler will create new schedule cycles.

ADM-NGGC-0206 Rev. 6 Page 31 of 89

9.4 Creating/Adding Schedule Templates and Shift Cycles (continued)

3. In addition to the considerations in Attachment 3 for Fatigue Management, the following should be considered when developing and assigning schedules:

Duration of scheduled work period (not to exceed 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months )

Duration of break period

Consistent start times for work periods (e.g. 6 or 7 a.m.)

Considerations of start times that is consistent with circadian factors

Consistent stop times for work periods

Consistent rotation (e.g., if working a 5-week shift rotation, the scheduled work days and days off are repeated every five weeks)

Stable 24-hour shift rotation (e.g., 3 X 8s, 2 X 12s, 2 X 10s with four hours un-staffed)

The impact of backward shift rotation (rotation of the start of the shift from days to night to swings)

Rotating schedules provide suitable transition between shifts (days/nights, days/swings/nights), 8-hour shift rotations rotate forward or provide more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months between work periods to adjust circadian rhythm; 12-hour shift rotations provide 34 hours3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months off during day/night transitions.

Long range predictability is a key aspect of fatigue mitigation

Circadian factors - fixed vs. rotating shifts

Training requirements

Vacation scheduling

Consideration of the impact of unscheduled overtime ADM-NGGC-0206 Rev. 6 Page 32 of 89

9.5 Scheduling Work Hours NOTE: Additional information for schedule descriptions can be found on the NGG Fatigue Management web site.

9.5.1 Assigning Schedule Cycles

1. Sign in to EmpCenter

2. From the Dashboard, select Schedules > Assign Schedules under Permanent Changes

3. Click Assign Schedule Cycles

4. Select assignment group for worker from the assignment tree on the left

5. Check Manager Override Box target worker

6. Use drop down menu to select desired Schedule Cycle and Cycle Phase for worker NOTE: The Effective Date must be within the Valid Date Range in the next step.

7. Enter effective date for worker

8. Once data has been entered for all desired workers, save data

9. To assign multiple employees in the assignment group the same schedule, use the Mass Edit function:

Enter desired schedule data in Mass Edit row

Select workers to update

Click the box to the left of each workers name or click the box to the left of the header for the Name field to select all

Select Apply to All Checked Rows

Press Save to finalize updates ADM-NGGC-0206 Rev. 6 Page 33 of 89

9.5.2 Changing Assigned Schedules Assigned schedules for workers may change during the shift cycle. The following guidance applies:

For shift schedule transitions, personnel should calculate the average duration of the shifts worked and to be worked during a period of not more than six weeks that encompasses the schedule transition to determine the applicable NOTE: day off requirement. If the average shift duration is not more than 9 hours1.041667e-4 days 0.0025 hours 1.488095e-5 weeks 3.4245e-6 months , then the MDO requirements for 8-hour shift schedules would apply. If the average shift duration is 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 then the MDO requirements for a 10-hour shift would apply. If the average shift duration is more than 11 hours1.273148e-4 days 0.00306 hours 1.818783e-5 weeks 4.1855e-6 months then the MDO requirements for a 12-hour shift apply.

EmpCenter automatically analyzes shift schedules to determine shift lengths and MDO requirements.

1. To change a workers schedule for current date or future date:

a. Sign in to EmpCenter

b. From the Dashboard, select Schedules > Assign Schedules under Permanent Changes

c. Click Assign Schedule Cycles.

d. Select assignment group for worker from the assignment tree on the left

e. Check box beside Today to open calendar.

f. Use pop-up calendar to navigate to desired date.

g. Using drop down menu, change Schedule Cycle, and Cycle Phase as desired NOTE: Changing the effective date in the next step will be the workers schedule from that date forward. If the schedule is temporary, then another schedule can be added with a later start date.

h. Enter effective date (within valid date range) for new schedule to start ADM-NGGC-0206 Rev. 6 Page 34 of 89

9.5.2 Changing Assigned Schedules (continued)

i. Once data has been entered for all desired workers, save data and review any exception messages.

j. If pending deviations exist, modify schedule to eliminate deviation.

9.5.3 Entering Schedule Changes NOTE: Work hours shall be scheduled in a manner that is consistent with the objective of preventing impairment from fatigue due to the duration, frequency, or sequencing of successive shifts. Human alertness and the propensity to sleep vary markedly through the course of a 24-hour period. These results are referred to as circadian rhythms. See Attachment 3 for important information to consider regarding fatigue management.

1. To change a workers schedule for current date or future date:

a. Sign in to EmpCenter

b. Select Time Entry >Edit Employee Time for a single employee or Time Entry >Edit Time for Groups to edit multiple personnels schedule

c. For individual time editing, from the assignments tree on left, click on the group to which the worker belongs and select worker

d. For group time edit, use pull down menu to select desired group.

e. To create or edit the worker timesheet for a different work period, do one of the following:

(1) Click the backward or forward button on the Work Period field, to select a past or future work period from the current work period.

(2) Click the pop-up calendar on the Work Period field to select a day in the desired work period. Fatigue Management opens the work period in which that date appears.

f. The view may be changed to Table View or List View using the drop-down menu for individual time edit.

ADM-NGGC-0206 Rev. 6 Page 35 of 89

9.5.3 Entering Schedule Changes (continued)

g. If the schedule change is simply a shift in work hours, a shorter work period or a longer work period for an existing time slice:

(1) Change desired in/out for current time slice.

(2) Select the Click to Reload icon under the Exceptions tab at the bottom of screen to recalculate work hours for individual time edit or Save for group time edit.

(3) Review exception list for potential warnings and deviations.

(4) If notification message is for AVG54 limit and no changes can be made to prevent exceeding the cycle average 54 hour/week limit, then the schedule change may be made and an NCR generated for trending/tracking purposes.

(5) If no deviations exist, then SAVE the data and return home OR Logoff if no additional changes are needed.

h. If the schedule change requires additional time record types or time codes:

(1) Select the green + icon for the day that the changes are needed to add the additional time slice with the start/stop times.

(2) Fill in/edit the various fields of the timesheet, using the following table as a guideline.

The type of hours being entered: Scheduled, Actual Replace, Admin and Test Test will allow the schedule change to be tested for rule deviations but must be replaced with Scheduled before saving. If Test is used to model scenarios, every time slice for the day must be changed to Test, otherwise, only that time slice coded Time as Test will be used in the calculations. Once the schedule change is confirmed, Record delete the Test rows and add the time slices back as Scheduled.

Type Except as discussed in Section 9.9.2, Actual Replace must not be used in EmpCenter on open timesheets. Once any Actual Replace time segment is present on a day, all Scheduled time for that day is ignored by compliance calculations. If Actual Replace time is loaded for a day, EmpCenter will use only the hours loaded under Actual Replace for all fatigue rule calculations.

Actual Replace times are transferred from the Passport L01Z NFR Panel Worked Hours.

ADM-NGGC-0206 Rev. 6 Page 36 of 89

The category to which the hours belong: BREAK, COVERED, NON-COVERED, SICK, VAC, CALL-IN INTERVENING, etc. Note these codes determine how the associated hours are counted toward the different elements of the rule. It is extremely important that the correct codes be selected to ensure regulatory Time compliance. If time code for field work is to be changed to NON-COVERED, see Code section 9.5.4 below.

The time the worker will begin work and the time they will end work. If the Out time occurs the following day from the In time (for example, an 11p.m. to 7a.m. shift), click

+ on the keyboard, after entering the Out time, to specify this. Fatigue Management In/Out inserts a + beside the Out time.

(Time) Note: In Table View, enter In/Out time in the column that signifies a particular day of the week on the timesheet, rather than in the In/Out column.

Unit Plant assignment Note these codes will only be used if the Time Record Type is Admin These codes take precedent over the schedule cycle defined parameters and can be used in lieu of changing the schedule or employee record for short periods or future dates.

The need to use admin codes to override schedule cycle parameters should be infrequent and should be used with caution. The admin codes expected to be used most often are OSTAT with a value of OUT-UPL-UN for short unplanned unit outages and OUT-UPL-SS for unplanned security outages. OSTATX is used to end both of these unexpected outages.

Other uses of admin codes include manually changing the length of evaluation periods, changing MDO evaluation from rolling to fixed, or fixed to rolling, etc.

Admin When an administrative code is entered for a particular date, the corresponding Code setting goes into effect on that date. Some administrative code settings remain in effect only for that date. Other administrative code settings are "persistent", which means they remain in effect on subsequent dates until they are overridden by another administrative code or are turned off by an administrative "end" code that is entered on the last effective date.

To enter an admin code for a particular day, add a time slice and select Admin as the time record type. Use a value of 1 in the time field to turn on the feature. When using DEVOVR or MBBS8 the exact military time of day for the beginning of the deviation period is entered in the time field. Select the admin code and admin code value. Enter comments if required or desired.

More information about Admin Codes is available on the web site.

Admin Note these codes will only be used if the Time Record Type is Equal to Admin Code Select desired value. See above and or guide available on website for additional Values information regarding admin codes and values.

ADM-NGGC-0206 Rev. 6 Page 37 of 89

9.5.3 Entering Schedule Changes (continued)

(3) Select the Click to Reload icon under the Exceptions tab to recalculate work hours.

(4) Review exception list for potential warnings and deviations.

(5) If notification message is for AVG54 limit and no changes can be made to prevent exceeding the cycle average 54 hour/week limit, then the schedule change may be made and an NCR generated for trending/tracking purposes.

(6) If no deviations exist, then SAVE the data and return home or Logoff if no additional changes are needed.

(7) If deviations exist, evaluate the following options:

(a) Can work be deferred? If so, make necessary changes to eliminate the violation.

(b) Can work be assigned to different worker? If so, make necessary changes to eliminate the violation.

(c) Can future schedule hours be changed to eliminate violation? If so, make necessary changes to eliminate the violation.

(d) Can current or future work be classified as non-covered work? If so, see section 9.5.4 for re-classifying work hours.

(e) Can current or future work be classified as one of the special covered work categories? (for example, FOF Drill, Unannounced Emergency Drills, Security threat).

If so, see section 9.5.4 for re-classifying work hours.

(8) If the work is covered and no other options are viable, then process a wavier per Section 9.6.

ADM-NGGC-0206 Rev. 6 Page 38 of 89

9.5.4 Re-Classifying Field Work Hours CAUTION Re-classifying past work hours from covered to non-covered, will not eliminate current or future deviations. All non-covered work hours count towards fatigue and allowed work hours when calculating work hours. MDO violations may occur in EmpCenter regardless of whether the work is covered or non-covered. See Acceptance Criteria in Section 8.0 regarding potentially false positives.

CAUTION Reclassifying work from covered to non-covered does not eliminate the effect of fatigue on personnel safety or plant equipment. Care should be taken before assigning work exceeding the work hour rules even if the work is non-covered work.

1. Review specific work assigned to worker using Attachment 4 as a guide for covered systems.

2. If work hours for the pending deviation period can be re-classified to Non-Covered hours:

a. Change Time Code from Covered Work to Non-Covered Work for applicable time slice. Comments describing the activities to be completed should be entered.

b. Change desired in/out for current time slice if necessary

c. Select the Click to Reload icon under the Exceptions tab at the bottom of screen to recalculate work hours.

d. Review exception list at bottom of screen for potential warnings and deviations.

e. Change any necessary subsequent scheduled time to ensure worker does not violate MWH, break or MDO rules

f. Inform worker of schedule changes, specifically stating that only non-covered work can be performed during this period.

g. If notification message is for AVG54 limit and no changes can be made to prevent exceeding the cycle average 54 hour/week limit, then the schedule change may be made and an NCR generated for trending/tracking purposes.

h. If no deviations exist, then SAVE the data and return home or Logoff if no additional changes are needed.

ADM-NGGC-0206 Rev. 6 Page 39 of 89

9.5.5 Amending Closed Timesheets in EmpCenter NOTE: A closed timesheet in EmpCenter should be amended anytime a corrected timesheet is entered in Corporate Time Entry (CTE) for a covered worker.

1. Log in to EmpCenter

2. Select Edit Employee Time

3. Click on the calendar and select a day in the closed week to be corrected.

4. Select the group containing the individual in need of a timesheet correction.

5. Click on the individual from the group to open the timesheet

6. Click the Amend button at the top of the timesheet

7. The timesheet will open up and allow changes to be made.

8. Save the timesheet after all changes are made.

9. If changes impact CTE, click the Other Versions button at the top of the timesheet

a. Click the Compare To Open Version button

b. Click the Print option within the comparison

c. Place this document with the CTE Time Audit Report. Have the documents signed and retain per current timesheet correction guidelines.

10. After the amended timesheet is saved, it must be approved.

a. From the Dashboard, select Approve Hours under Time Entry

b. Select desired assignment group from list

c. Amended timesheets are grouped by week. Select one or more workers timesheet(s) in the week to be approved by clicking in the open box under manager approval. (A green check mark will appear in the box)

d. In the upper left portion of the screen, click Save Approvals ADM-NGGC-0206 Rev. 6 Page 40 of 89

9.6 Waivers CAUTION The waiver must be approved before workers exceed work hour limits. A waiver requires a face to face fatigue assessment, which can be performed no more than four hours prior to a worker beginning work under a waiver.

1. Discuss need for waiver with following Approval Authority as appropriate.

The Shift Manager determines that the waiver is necessary to mitigate or prevent a condition adverse to safety, or

The Manager - Nuclear Plant Security (or designee) determines that the waiver is necessary to maintain the security of the facility, or

The PGM (or designee) determines that a waiver is necessary based on either of the above conditions.

2. If the approval authority verbally authorizes a waiver, then complete the following steps:

NOTE: Attachment 1 can be used to document authorization for waiver. If Attachment 1 is used, the information must be entered into EmpCenter using the manual method when the program is available for tracking and reporting requirements. The manual waiver method in EmpCenter requires the waiver status to be manually changed. This must be entered in EmpCenter before the week is closed.

Multiple waivers may be required to authorize workers exceeding the work hour NOTE: limits. A waiver period cannot exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

a. Workers Supervisor initiates a waiver as follows:

(1) If desired, review training material on Fatigue Management Portal website for refresher on processing waivers.

http://nggweb/nggngg/part%2026%20work%20hour%20contr ols/EmpCenter%20Information/lesson%205%20processing%

20waivers.pdf (Lesson 5 under Training Guides)

(2) Sign in to EmpCenter.

(3) Navigate to the timesheet with the pending deviation (4) Select Create Waiver in the Exception Message ADM-NGGC-0206 Rev. 6 Page 41 of 89

9.6 Waivers (continued)

(5) Review the waiver period and make changes if desired (6) Review the identified pending deviations in the Declarations field.

(7) Enter the allowed excess to be waived in the Declarations field. This must be at least enough to cover the excess or shortfall.

(8) Click Refresh Deviations and Save (9) Complete required fields in Initiation tab.

(10) Assign and submit waiver to approval authority.

(11) Approval Authority completes required fields in Review tab including assigning to supervisor for fatigue assessment.

(12) Approval Authority assigns and submits waiver to supervisor for completion of a fatigue assessment.

b. A fatigue assessment shall be performed for the worker who will be working using a waiver. (refer to Section 9.7 for general information on fatigue)

(1) The supervisor performing the assessment enters the automatically generated Waiver ID number on Attachment 2, Fatigue Assessment.

(2) The worker who will work extended hours shall complete Attachment 2, Fatigue Assessment, Section A.

NOTE: If a supervisor qualified to direct the work is not on site, the assessment may be performed by a supervisor who qualified to provide oversight of the work to be performed by the worker, e.g. Shift Mangers and Control Room Supervisors.

NOTE: A supervisory assessment cannot be delegated to a non-supervisory worker.

ADM-NGGC-0206 Rev. 6 Page 42 of 89

9.6 Waivers (continued)

(3) A supervisor, with the following qualifications, shall perform a face-to-face assessment for the worker by completing Attachment 2, Fatigue Assessment, Section B:

Qualified to direct the work to be performed by the worker, and

Trained in accordance with the requirements of the Fitness for Duty program (Plant Access Training GNR01N)

(4) The supervisory face-to-face assessment shall be performed no more than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months before the worker begins performing any work under the waiver.

(5) If the assessment is APPROVED:

The worker may perform work as described in waiver WITHOUT additional controls and conditions.

(6) If the assessment is APPROVED W/RESTRICTIONS:

The worker may perform work described in waiver WITH controls and conditions identified.

(7) If the assessment is NOT APPROVED:

(a) Relieve worker from work duties.

(b) Arrange transportation assistance or provide rest accommodations.

(c) Review work performed by individual.

(d) Initiate a NCR for the NOT APPROVED Fatigue Assessment.

(8) The supervisor completes the waiver Assessment tab in the EmpCenter.

(9) The supervisor saves the assessment.

(10) The supervisor submits the assessment for close out and the waiver changes to PENDING CLOSE-OUT status.

(11) If the Worker is APPROVED or is APPROVED W/RESTRICTIONS, the work is authorized to begin.

ADM-NGGC-0206 Rev. 6 Page 43 of 89

9.6 Waivers (continued)

3. If no work is done under an APPROVED or an APPROVED W/RESTRICTIONS waiver, then the waiver should be cancelled using the CANCEL WAIVER selection.

4. When work under a waiver has been completed,

a. The supervisor of the worker shall ensure an NCR is written to document that work was performed under a waiver. The NCR description should include the work hour rule(s) waived and the condition which caused the waiver to be issued.

b. Enter NCR number in the CA ID field of the waiver.

c. The supervisor completes the required fields of the Wavier Close-out tab

d. The supervisor submits the waiver for closure. The waiver status will change to CLOSED OUT.

5. The supervisor prints the Waiver from EmpCenter, combines it with the completed Attachment 2 and submits as a completed plant document (Vital Record).

9.7 Fatigue Assessments 9.7.1 Fatigue Assessment Guidelines

1. The ability to perform a supervisory assessment cannot be delegated to a non-supervisory worker.

2. All fatigue assessments shall be performed face-to-face by a supervisor with the following qualifications:

a. Trained in accordance with the requirements of the Fitness for Duty program (Plant Access Training GNR01N) AND

b. For a waiver, qualified to direct or oversee the work to be performed by the worker.

3. Fatigue assessments are performed and documented per Attachment 2 and recorded in EmpCenter.

ADM-NGGC-0206 Rev. 6 Page 44 of 89

9.7.1 Fatigue Assessment Guidelines (continued)

4. The fatigue assessment shall address the following factors:

Acute fatigue;

Cumulative fatigue;

Circadian variations in alertness and performance;

The circumstances that necessitated the fatigue assessment;

Implementation of controls and conditions, if any, that is necessary to permit the worker to resume performing work duties. This might include requiring the worker to take a rest break.

5. If the assessed worker disagrees with the results, the worker may:

Discuss with next level of management

Initiate the dispute resolution process per HRI-SUBS-00370 (Non-Bargaining Unit).

Initiate grievance per Memorandum of Agreement (Bargaining Unit)

Contact Employee Concerns representative,

Contact the NRC resident inspector, or

Submit an allegation to the NRC for investigation 9.7.2 Self-Declaration

1. It is the responsibility of the worker to communicate a clear self-declaration of fatigue to their supervisor. This may be verbally initiated, when necessary, by using the statement below. A casual statement to a supervisor or fellow worker that an individual is tired is NOT a self-declaration. Any individual covered by the FFD program can self-declare by stating the following:

"By the requirements of 10 CFR 26, I believe I am too fatigued to perform the duties assigned to me and would like to make a self-declaration of fatigue."

2. Information provided by the worker regarding the reasons for self-declaration shall remain confidential to the extent allowed by other regulations.

ADM-NGGC-0206 Rev. 6 Page 45 of 89

9.7.2 Self-Declaration (continued)

3. If a covered worker is working under a waiver and self declares, then the following actions shall be taken:

a. The supervisor shall immediately stop the worker from performing their duties unless the worker is required to continue those duties for other reasons (e.g., Operations shift complement required by 10 CFR 50.54(m) or worker is required to fill Emergency Response Organization (ERO) role).

b. The supervisor shall take immediate actions to relieve the worker.

c. The supervisor shall initiate an NCR.

d. Following self-declaration or relief from performing the duties, the worker:

(1) May be reassigned to duties other than covered work if the fatigue assessment indicates the worker is fit to safely and competently perform the other duties, and (2) Shall be permitted or required to take a break of at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months before resuming covered work.

4. If a worker makes a self-declaration and the supervisor CAN provide the minimum 10-hour break, then a fatigue assessment is not necessary. The supervisor shall:

a. Arrange transportation assistance or provide rest accommodations.

b. Review work performed by individual.

c. Revise EmpCenter hours if individual is a covered worker.

d. Initiate an NCR for trending purposes.

5. If a worker makes a self-declaration and the supervisor CANNOT provide the minimum 10-hour break:

a. The individual must be removed from duty as soon as possible AND an appropriate supervisor must perform a Fatigue Assessment per 9.7.2.5b or 9.7.2.5c below.

b. If the worker is loaded in EmpCenter:

(1) Sign in to EmpCenter.

(2) Select Fatigue Assessments and Waivers.

ADM-NGGC-0206 Rev. 6 Page 46 of 89

9.7.2 Self-Declaration (continued)

(3) Select Add New Fatigue Assessment.

(4) Add employee name or ID number and select search.

(5) Select Employee name.

(6) The supervisor enters the automatically generated Fatigue ID number on Attachment 2, Fatigue Assessment.

(7) The individual who is subject to the assessment shall complete Attachment 2, Fatigue Assessment, Section A.

(8) The supervisor shall perform a face-to-face assessment and complete Attachment 2, Fatigue Assessment, Section B.

(9) The supervisor enters the assessment type as Self Declaration in EmpCenter.

(10) The supervisor completes the required fields for the Fatigue Assessment tab in EmpCenter.

(11) If the assessment is APPROVED:

(a) The individual may continue to perform covered or uncovered work WITHOUT additional controls and conditions UNLESS the individual was working under a waiver when the self-declaration was made.

(b) If the individual was working under a waiver, the individual can ONLY perform uncovered activities until a break of at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months is provided (c) Initiate an NCR and record NCR number in CA field (12) If the assessment is APPROVED w/ RESTRICTIONS:

(a) The individual may continue to perform covered or uncovered work WITH the additional controls and conditions UNLESS the individual was working under a waiver when the self- declaration was made.

(b) If the individual was working under a waiver, the individual can ONLY perform uncovered activities until a break of at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months is provided (c) Initiate an NCR and record NCR number in CA field.

ADM-NGGC-0206 Rev. 6 Page 47 of 89

9.7.2 Self-Declaration (continued)

(13) If the assessment is NOT APPROVED:

(a) Relieve individual from work duties.

(b) Arrange transportation assistance or provide rest accommodations.

(c) Review work performed by individual.

(d) Revise EmpCenter hours.

(e) Initiate a NCR and record NCR number in CA field.

(14) The supervisor saves the Fatigue Assessment in EmpCenter.

(15) The supervisor submits Attachment 2 as a completed plant document (Vital Record).

(16) If the individual is provided a break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months before resuming work, than a FOLLOW-UP Fatigue Assessment must be done before the individual can return to work.

c. If the individual is not a covered worker in EmpCenter:

(1) The individual who is subject to the assessment shall complete Attachment 2, Fatigue Assessment, Section A.

(2) The supervisor shall perform a face-to-face assessment and complete Attachment 2, Fatigue Assessment, Section B.

(3) If the assessment is APPROVED:

(a) The individual may continue to work WITHOUT additional controls and conditions.

(b) Initiate an NCR and record NCR number in CA field.

(4) If the assessment is APPROVED w/ RESTRICTIONS:

(a) The individual may continue working WITH the controls and conditions identified.

(b) Initiate an NCR and record NCR number in CA field ADM-NGGC-0206 Rev. 6 Page 48 of 89

9.7.2 Self-Declaration (continued)

(5) If the assessment is NOT APPROVED:

(a) Relieve individual from work duties (b) Arrange transportation assistance or provide rest accommodations.

(c) Review work performed by individual.

(d) Initiate a NCR and record NCR number in CA field.

NOTE: Fatigue assessment must be loaded in EmpCenter regardless of the results.

(6) The supervisor will use the Covered Worker Administration Tool to change the individual NFR indicator to covered worker. This will temporarily activate the individual in EmpCenter.

(7) Sign in to EmpCenter.

(8) Select Fatigue Assessments and Waivers.

(9) Select Add New Fatigue Assessment.

(10) Add employee name or ID number and select search.

(11) Select Employee name.

(12) The supervisor performing the assessment enters the automatically generated Fatigue ID number on Attachment 2, Fatigue Assessment.

(13) The supervisor enters the assessment type as Self Declaration in EmpCenter.

(14) The supervisor completes the required fields for the Assessment tab in EmpCenter.

ADM-NGGC-0206 Rev. 6 Page 49 of 89

9.7.2 Self-Declaration (continued)

(15) The supervisor saves the Fatigue Assessment.

(16) Exit EmpCenter.

(17) The supervisor will use the Covered Worker Administration Tool to change the individual NFR indicator to non-covered worker. This will deactivate the individual in EmpCenter.

(18) The supervisor submits Attachment 2 as a completed plant document (Vital Record).

9.7.3 For Cause

1. A fatigue assessment shall be conducted in response to an observed condition of impaired worker alertness creating a reasonable suspicion that a worker is not fit to safely and competently perform their duties, except if the condition is observed during a workers break period.

2. The worker who observed the condition shall notify a supervisor of the observed impairment.

3. The worker who observed the impairment shall not be the person who conducts the fatigue assessment.

4. The supervisor determines what actions are required.

a. If the observed condition is impaired alertness with no other behaviors or physical conditions creating a reasonable suspicion of possible substance abuse, then only a fatigue assessment is required and is completed per steps 9.7.3.5 or 9.7.3.6 below.

b. If there is a reasonable assurance that the observed condition is not due to fatigue, then a fatigue assessment is not required. The supervisor should consider documenting the observation in PDP logs.

c. If drug or alcohol impairment is suspected, then refer to SEC-NGGC-2130 and SEC-NGGC-2140.

5. If the worker is loaded in EmpCenter, then:

a. Sign in to EmpCenter.

b. Select Fatigue Assessments and Waivers.

c. Select Add New Fatigue Assessment.

ADM-NGGC-0206 Rev. 6 Page 50 of 89

9.7.3 For Cause (continued)

d. Add employee name or ID number and select search.

e. Select Employee name.

f. The supervisor performing the assessment enters the automatically generated Fatigue ID number on Attachment 2, Fatigue Assessment.

g. The worker who is subject to the assessment shall complete Attachment 2, Fatigue Assessment, Section A.

h. The supervisor shall complete a face-to-face assessment (Attachment 2, Fatigue Assessment, Section B).

i. The supervisor enters the assessment type as For Cause in EmpCenter.

j. The supervisor completes the required fields for the Assessment tab in EmpCenter.

k. If the assessment is APPROVED:

(1) The individual may continue to work WITHOUT additional controls and conditions.

(2) Initiate an NCR and record NCR number in CA field.

l. If the assessment is APPROVED W/RESTRICTIONS:

(1) The individual may continue to work WITH additional controls and conditions.

(2) Initiate an NCR and record NCR number in CA field.

m. If the assessment is NOT APPROVED:

(1) Relieve worker from work duties (2) Arrange transportation assistance or provide rest accommodations.

(3) Review work performed by individual.

(4) Initiate a NCR and record NCR number in CA field.

ADM-NGGC-0206 Rev. 6 Page 51 of 89

9.7.3 For Cause (continued)

(5) Revise EmpCenter hours.

(6) If fatigued worker was a Security worker, document the actions in the appropriate Shift Activity Log and initiate other reports as required; i.e., Safeguard Event Report or Security Incident report.

n. The supervisor saves the fatigue assessment.

o. The supervisor submits Attachment 2 as a completed plant document (Vital Record).

6. If the individual is not loaded in EmpCenter,

a. The individual who is subject to the fatigue assessment shall complete Attachment 2, Fatigue Assessment, Section A.

b. The supervisor shall perform a face-to-face assessment and complete Attachment 2, Fatigue Assessment, Section B.

NOTE: Fatigue assessments performed must be loaded in EmpCenter regardless of the results.

c. If the assessment is APPROVED:

(1) The individual may continue to work WITHOUT additional controls and conditions.

(2) Initiate an NCR and record NCR number in CA field.

d. If the assessment is APPROVED W/RESTRICTIONS:

(1) The individual may continue to work WITH additional controls and conditions.

(2) Initiate an NCR and record NCR number in CA field.

e. If the assessment is NOT APPROVED:

(1) Relieve individual from work duties (2) Arrange transportation assistance or provide rest accommodations.

ADM-NGGC-0206 Rev. 6 Page 52 of 89

9.7.3 For Cause (continued)

(3) Review work performed by individual.

(4) Initiate a NCR and record NCR number in CA field.

(5) If the individual is provided a break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months before resuming work, then a FOLLOW-UP Fatigue Assessment must be done before the individual can return to work.

f. The supervisor will use the Covered Worker Administration Tool to change the individual NFR indicator to covered worker. This will temporarily activate the individual in EmpCenter.

g. Sign in to EmpCenter.

h. Select Fatigue Assessments and Waivers.

i. Select Add New Fatigue Assessment.

j. Add employee name or ID number and select search.

k. Select Employee name.

l. The supervisor performing the assessment enters the automatically generated Fatigue ID number on Attachment 2, Fatigue Assessment.

m. The supervisor enters the assessment type as For Cause in EmpCenter.

n. The supervisor completes the required fields for the Assessment tab in EmpCenter.

o. The supervisor saves the fatigue assessment.

p. Exit EmpCenter.

q. The supervisor will use the Covered Worker Administration Tool to change the individual NFR indicator to non-covered worker. This will deactivate the individual in EmpCenter.

r. The supervisor submits Attachment 2 as a completed plant document (Vital Record).

ADM-NGGC-0206 Rev. 6 Page 53 of 89

9.7.4 Post Event Necessary medical treatment should not be delayed to conduct the fatigue NOTE:

assessment.

1. A fatigue assessment must be completed in response to events requiring post-event drug and alcohol testing as specified in SEC-NGGC-2140 Section 9.13.3 Items 1-3. The fatigue assessment is completed per steps 9.7.4.3 or 9.7.4.4 below.

Normally, the workers direct supervisor will not be able to perform the post NOTE: event fatigue assessment.

2. The supervisor who performs the fatigue assessment shall not have:

a. Performed or directed (on-site) the work activities during which the event occurred;

b. Performed within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before the event occurred, a fatigue assessment of the workers who were performing or directing (on-site) the work activities during which the event occurred; and

c. Evaluated or approved a waiver for any of the workers who were performing or directing (on-site) the work activities during which the event occurred, if the event occurred while the workers were performing work under that waiver.

3. If the worker is loaded in EmpCenter:

a. Sign in to EmpCenter.

b. Select Fatigue Assessments and Waivers.

c. Select Add New Fatigue Assessment.

d. Add employee name or ID number and select search.

e. Select Employee name.

f. The supervisor performing the assessment enters the automatically generated Fatigue ID number on Attachment 2, Fatigue Assessment.

ADM-NGGC-0206 Rev. 6 Page 54 of 89

9.7.4 Post Event (continued)

g. The worker who is subject to the assessment shall complete Attachment 2, Fatigue Assessment, Section A.

h. The supervisor shall complete a face-to-face assessment (Attachment 2, Fatigue Assessment, Section B).

i. The supervisor enters the assessment type as Post Event in EmpCenter.

j. The supervisor completes the required fields for the Assessment tab in EmpCenter

k. If the assessment is APPROVED:

(1) The worker and may continue to work WITHOUT additional controls and conditions.

(2) Initiate an NCR and record NCR number in CA field.

l. If the assessment is APPROVED W/RESTRICTIONS:

(1) The worker may continue working WITH controls and conditions identified.

(2) Initiate an NCR and record NCR number in CA field.

m. If the assessment is NOT APPROVED :

(1) Relieve worker from work duties (2) Arrange transportation assistance or provide rest accommodations.

(3) Review work performed by the individual.

(4) Initiate a NCR and record NCR number in CA field.

(5) If fatigued worker was a Security worker, document the actions in the appropriate Shift Activity Log and initiate other reports as required; i.e., Safeguard Event Report or Security Incident report.

(6) Revise EmpCenter hours.

(7) If the individual is provided a break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months before resuming work, then a FOLLOW-UP Fatigue Assessment must be done before the individual can return to work.

ADM-NGGC-0206 Rev. 6 Page 55 of 89

9.7.4 Post Event (continued)

n. The supervisor saves the fatigue assessment.

o. The supervisor submits Attachment 2 as a completed plant document (Vital Record).

4. If the individual is not loaded in EmpCenter:

a. The individual who is subject to the fatigue assessment shall complete Attachment 2, Fatigue Assessment, Section A.

b. The supervisor shall perform a face-to-face assessment and complete Attachment 2, Fatigue Assessment, Section B.

c. If the assessment is APPROVED:

(1) The individual and may continue to work WITHOUT additional controls and conditions.

(2) Initiate an NCR and record NCR number in CA field.

d. If the assessment is APPROVED W/RESTRICTIONS:

(1) The individual may continue working WITH controls and conditions identified.

(2) Initiate an NCR and record NCR number in CA field.

e. If the assessment is NOT APPROVED:

(1) Relieve individual from work duties (2) Arrange transportation assistance or provide rest accommodations.

(3) Review work that individual performed.

(4) Initiate a NCR and record NCR number in CA field.

ADM-NGGC-0206 Rev. 6 Page 56 of 89

9.7.4 Post Event (continued)

NOTE: If a fatigue assessment is performed, then assessment must be loaded in EmpCenter regardless of the results.

f. The supervisor will use the Covered Worker Administration Tool to change the individual NFR indicator to covered worker. This will temporarily activate the individual in EmpCenter as a Maintenance worker. The supervisor will change the worker category to OTHER

g. Sign in to EmpCenter.

h. Select Fatigue Assessments and Waivers.

i. Select Add New Fatigue Assessment.

j. Add employee name or ID number and select search.

k. Select Employee name.

l. The supervisor performing the assessment enters the automatically generated Fatigue ID number on Attachment 2, Fatigue Assessment.

m. The supervisor enters the assessment type as Post Event in EmpCenter.

n. The supervisor completes the required fields for the Assessment tab in EmpCenter.

o. The supervisor saves the fatigue assessment.

p. The supervisor submits Attachment 2 as a completed plant document (Vital Record).

q. Exit EmpCenter.

r. The supervisor will use the Covered Worker Administration Tool to change the individual NFR indicator to non-covered worker. This will deactivate the individual in EmpCenter.

5. Provide results of fatigue assessment for the event NCR investigation.

ADM-NGGC-0206 Rev. 6 Page 57 of 89

9.7.5 Follow-up

1. If an individual was subject to a fatigue assessment for cause or in response to a self-declaration, AND the individual returns to duty following a break of less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , the supervisor shall reassess the individual for fatigue as well as the need to implement controls and conditions before permitting the individual to resume work.

2. Instructions for completing Follow-Up assessments are identical to the original assessment except the assessment is classified as FOLLOW-UP in EmpCenter and on Attachment 2.

9.8 Managing Delegations 9.8.1 A supervisor can delegate authority to another supervisor or worker as follows:

(1) To add a delegation (a) Select Manage Delegations (b) Select Delegate Authority (c) Search for desired group or person to be delegated (d) Verify proper role is selected (e) Select effective dates (if the person is going to be given long term delegation , then select 12/31/3000 as end effective date)

(f) Click checkbox to Allow Re-Delegation if desired (g) Click Next (h) Search for appropriate person by name or ID number and select (i) Click Continue (2) To remove/revoke the delegations, (a) Sign in EmpCenter (b) Select Manage Delegations (c) Select View/revoke delegations (d) Select Group to revoke (e) Select Revoke (f) Enter Effective date (g) Confirm Action ADM-NGGC-0206 Rev. 6 Page 58 of 89

9.9 Documenting PGN Employees Hours Worked

Each PGN employee is responsible for ensuring his or her working hours are accurately documented in EmpCenter.

Time worked for shift turnover shall be documented using a separate time code in Passport.

9.9.1 Passport Labor Entry and Reporting

1. Employee signs into time entry panel in Passport.

2. In top right corner of the TIML010 panel, employee selects the NFR Hours button.

NOTE: Pay time in Passport will not normally match time from EmpCenter. EmpCenter counts break times as work times and ignores count times such as holiday or vacation.

NOTE: 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.

3. Employee must review scheduled times to verify it is accurate with respect to time worked.

4. If work times are different than scheduled times:

a. Add new row

b. Select key WORKED

c. Select appropriate type time code. See Fatigue Management Website for description of appropriate codes.

d. Select Unit ID.

e. Enter new start/stop times. Note that the new start/stop time should encompass the entire work day including time away from the plant if the break is less than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months . If break is greater than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , then a new row should be added with different start/stop times.

f. Save data using the diskette icon. This will transfer the WORKED hours to EmpCenter as Actual Replace. EmpCenter compliance calculations ignore all SCHEDULED time if any Actual Replace is present for a day.

ADM-NGGC-0206 Rev. 6 Page 59 of 89

9.9 Documenting PGN Employees Hours Worked (continued)

5. When the start/stop times are accurate for the week, select Accept Work Hours button in top right hand corner.

6. Enter normal pay time in Passport.

7. Submit timesheet for approval.

8. Once the timesheet is approved, all unmodified SCHEDULED hours are converted to WORKED hours and transferred back to EmpCenter as Actual Replace. Once any Actual Replace time segment is present on a day, all Scheduled time for that day is ignored by compliance calculations.

If Actual Replace time is loaded for a day, EmpCenter will use only the hours loaded under Actual Replace for all fatigue rule calculations.

9.9.2 EmpCenter NOTE: For transmission employees not using Passport Labor Entry and Reporting, the employee is responsible for entering actual work hours in EmpCenter.

1. Sign in to EmpCenter

2. From the Dashboard, Select Enter My Hours under Time Entry. The current time period should open up displaying the schedule.

3. Enter time in Actual Replace lines using appropriate Time Codes.

4. Add additional Actual Replace rows if necessary.

5. Save.

6. Review Exceptions tab. If no violations or pending deviations exist, log off system. If violations or pending deviations exist, discuss with supervisor prior to proceeding.

ADM-NGGC-0206 Rev. 6 Page 60 of 89

9.10 Documenting Contract Worker Hours Worked NOTE: Contract workers are responsible for updating work hours 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.

1. Each site contract worker is responsible for documenting/validating his or her working hours regardless of whether payment is received for the hours worked.

2. Time worked to accommodate shift turnover shall be documented using a separate time code from normal time or overtime worked or be set to a nominal time in contractor schedules.

3. Contract workers may use EmpCenter to record schedules and actual work hours if agreed upon by the designated representative.

4. If contract personnel choose to provide an alternate method of record keeping, the records must indicate scheduled and actual work hours including start and stop times for each work period.

5. Such records must be provided to PGN designated representative at a mutually agreed upon frequency.

6. Records of contractor work hours and schedules maintained outside of EmpCenter should be forwarded to the Director - Nuclear Fleet Operations by the Designated Representative on a quarterly basis or at the completion of the work period. These records can be sent electronically, preferably in

.pdf format.

7. All other requirements of this procedure apply to contractors.

ADM-NGGC-0206 Rev. 6 Page 61 of 89

9.11 Annual Review

1. An annual program review is required to meet the requirements of 10 CFR 26. This review should be done concurrently with data gathering for the annual FFD report. The review shall be completed within 30 days of the end of the review period. (NTM 342373)

2. This review must be completed by January 30 of each year to support inclusion in the annual NRC FFD report required by 10 CFR 26.717 which is due before March 1 of each year.

3. The annual program review should be completed using the self assessment process outlined in CAP-NGGC-0201 and must, minimally, contain the following activities:

a) From the EmpCenter Dashboard Select View Group Reports and run the following reports for applicable assignment groups:

Fatigue Management Reports

Program Review Detail

Program Review Summary

Fatigue Management Deviations

Fatigue Assessment Summary b) From the Passport Information Web Portal using the Fatigue Mgmt database, run the Prompted Reports for Fatigue Management Exceptions by Date Range.

c) Contact the System Administrator to obtain a list of all Waivers and Fatigue Assessments and a list of all Deviation Overrides completed for the year.

d) Review NCRs with the keyword PART26.

e) Review covered worker contractor work hours and schedules for those contractors not using Progress Energys EmpCenter for documentation.

f) Using the above reports and information, review the actual work hours and worker performance of covered individuals during the entire review period, including any plant or security system outages or increased threat conditions, for consistency with the work hours scheduling requirement objective of preventing impairment from fatigue due to the duration, frequency, and sequencing of hours worked. The review should be based on information associated with fatigue, including but not limited to the corrective action program. At a minimum, this review should address the following:

ADM-NGGC-0206 Rev. 6 Page 62 of 89

9.11 Annual Review (continued)

1) Workers whose actual hours worked during the review period exceeded an average of 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months per week in any shift cycle while the workers work hours are subject to the on-line day- off requirements.

2) Workers who were granted more than one waiver during the review period.

3) Workers who were assessed for fatigue for reasons other than waivers during the review period.

g) Review workers hours worked and the waivers under which work was performed to evaluate staffing adequacy for all jobs subject to the work hour controls.

h) Review performance of the station in adhering to work schedules for covered work groups. Evaluate whether or not the schedule is effectively being implemented.

1) Is the schedule being adhered to?

2) Are the changes understood and reasonably consistent with a properly managed schedule?

3) Does the overtime utilized support efficient utilization of resources?

4) Are the available resources properly aligned with the scheduled work load?

5) Is unplanned work or outages indicative that other corrective actions are necessary?

6) Does the level and pattern of overtime support a determination that staff size is appropriate for the schedule and work?

i) Summarize fatigue assessments that were conducted during the calendar year. The summary should include:

1) Conditions under which the fatigue assessment was conducted (for cause, self-declaration, post event and follow-up).

2) Statement of whether or not the worker was working on outage activities at the time of the self- declaration or condition resulting in the fatigue assessment.

ADM-NGGC-0206 Rev. 6 Page 63 of 89

9.11 Annual Review (continued)

3) The categories of duties that the individual was performing at the time of the self-declaration. (e.g.

Operations, Maintenance, Security.)

4) Management actions, if any, resulting from the fatigue assessment.

4. Record, trend, and correct any problems identified in maintaining control of work hours consistent with the specific requirements and performance objectives of the rule in the corrective action program.

5. Document the methods used to conduct these reviews and the results of the reviews.

6. Ensure the annual review and necessary supporting information is transmitted to Records Management.

9.12 Annual FFD Program Performance Report

1. An annual FFD program performance report shall be submitted to the NRC.

2. PGN shall include the following information in a standard format in the annual FFD program performance report as required by 10CFR 26.717:

a) A summary for each nuclear power plant site of all instances during the previous calendar year in which PGN waived the work hour controls specified in this procedure for covered workers. The summary shall include only those waivers under which work was performed. If it was necessary to waive more than one work hour control during any single extended work period, the summary of instances shall include each of the work hour controls that were waived during the period. For each category of workers, PGN shall report:

i. The number of instances in which each work hour control specified in § 26.205(d)(1)(i) through (d)(1)(iii), (d)(2)(i) and (d)(2)(ii), and (d)(3)(i) through (d)(3)(v) was waived for workers not working on outage activities.

ii. The number of instances in which each work hour control was waived for workers working on outage activities.

ADM-NGGC-0206 Rev. 6 Page 64 of 89

9.12 Annual FFD Program Performance Report (continued) iii. A summary that shows the distribution of waiver use among the workers within each category of workers (e.g., a table that shows the number of workers that received only one waiver during the reporting period, the number of workers that received a total of two waivers during the reporting period, etc.).

iv. A summary of corrective actions, if any, resulting from the analyses of these data, including fatigue assessments.

3. Reports related to fatigue management can be integrated into the overall FFD report and can be submitted electronically.

9.13 Disciplinary Actions

1. Self-declaration of fatigue is encouraged to maintain the safety of personnel, co-workers, and the public. Time off following a self-declaration will be considered sick time, rest time or vacation time as negotiated with the supervisor. PGN has the responsibility to schedule work to minimize the impact of both acute and chronic fatigue. Besides scheduled work, there are both employee controllable and employee non-controllable contributors to fatigue. The Employee Assistance Program will be available to employees for help in dealing with these circumstances if fatigue is chronically impacting their ability to perform their job.

2. Workers refusing a fatigue assessment shall be considered fatigued and unable to perform their duties. This act will be considered a program violation which may result in termination.

3. Workers that exhibit chronic self-declarations of not being fit-for-duty as a result of fatigue, with no reasonable basis, may be subject to disciplinary action.

4. Disciplinary actions will be taken in accordance with the companys disciplinary policy. This disciplinary action could include suspension of unescorted access, unfavorable termination of unescorted access, and/or denial of unescorted access depending on the circumstances. Items considered for determining appropriate disciplinary action include but are not limited to workers performance history, current work schedule, health concerns reported by the individual, workers participation in recommended treatments for sleep disorders, job task requirements, etc.

ADM-NGGC-0206 Rev. 6 Page 65 of 89

10.0 RECORDS

1. Completed copies of the following shall be transmitted to Records Management and retained for at least three years as vital records :

a) Form ADM-NGGC-0206-1-5, Authorization to Waive Worker Work Hour Limits b) Form ADM-NGGC-0206-2-5, Fatigue Assessment

2. Completed copies of the following shall be transmitted to Records Management and retained for at least three years as vital records:

a) Records of worker work hours for those who are subject to work hour controls b) Records of the shift schedules and shift cycles for those who are subject to work hour controls c) Items a and b above will be generated on a quarterly basis from EmpCenter. (NTM 378008) d) Contractor work records not in EmpCenter will be transmitted to Records Management as received from the designated representatives.

3. Completed annual reviews per Section 9.11 shall be transmitted to Records Management and retained for at least three years as vital records.

4. The completed Annual Report per Section 9.12 shall be transmitted to Records Management and retained for at least three years as vital records.

11.0 ATTACHMENTS Attachment 1 - Authorization to Waive Work Hour Limits Attachment 2 - Fatigue Assessment Form Attachment 3 - Worker Fatigue Information and Countermeasures Attachment 4 - Risk Based Systems/Components ADM-NGGC-0206 Rev. 6 Page 66 of 89

ATTACHMENT 1 Authorization to Waive Work Hour Limits Sheet 1 of 2 Form ADM-NGGC-0206-1-5 Plant (circle one) Unit Status (check one)

Date NCR # BNP CR3 HNP RNP Outage On-line Waiver Period*: Waiver Start: __________/__________ Waiver End: ___________/____________

Date / Time Date / Time

Cannot exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months The following person is authorized to exceed the limits of 10 CFR 26 Additional Time Work Activity Full Payroll Name (Print) Limits Authorized or Actual Break OPS HP/CHEM MNT SEC SIC Enter the letter code(s) for each of the applicable limits being exceeded under "Limits".

A. More than 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months in any 24-hour period (MWH16/24)

B. More than 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months in any 48-hour period (MWH26/48)

C. More than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months in any 7 day period (MWH72/168)

D. Fewer than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months between work periods (MBBS10)

E. Fewer than 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months between work periods (MBBS8)

F. Less than 34 hour3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months break in the last 9 days (MBBS34/9)

G. Minimum days off for on-line requirements not met (MDO-ONL)

H. Minimum days off for outage requirements not met (MDO-OUT)

Enter the hours/day in excess of the appropriate limit in the Additional Time Authorized/Actual Break column.

Justification for exceeding work hour limits:

Description of work to be performed:

Circumstances that caused work hour extensions:

ERO Minimum Shift Staffing Condition Adverse to Safety Work Order Number: __________________ Work Order Priority:_______

Security Threat or Security Outage:

ADM-NGGC-0206 Rev. 6 Page 67 of 89

ATTACHMENT 1 Authorization to Waive Work Hour Limits Sheet 2 of 2 If the worker will not be in compliance with the work hour limits when they return to work on their next scheduled day of work, then a new authorization to waive the worker work hours, including a new fatigue assessment, must be completed prior to allowing the worker to return to work.

Workers work schedule has been checked and worker YES NO Comments:

has been notified when he can return to work:

Waiver Requested by: (Supervisor, Security Shift Supervisor, USCO)

____________________________/________________________________________/________________

Print Name Signature Date/Time Waiver Approved by: (Shift Manager, Security Manager, PGM)

____________________________/________________________________________/________________

Print Name Signature Date/Time The workers supervisor will complete Fatigue Assessment per Attachment 2 prior to work beginning.

Fatigue assessment completed: YES NO Comments If this waiver was not used, then this attachment should be voided. The voided attachment will not be a Vital Record and the EmpCenter schedule should be updated with actual hours worked.

CLOSE-OUT Full Payroll Name (Print) Hours Worked Was work under this performed EmpCenter waiver satisfactorily? Updated?

YES NO YES NO Comments:

Closed By: ___________________________________/_______________________________/___________

Job Supervisor Signature Date/Time Waiver Entered in Empcenter by: EmpCenter Waiver #

VITAL RECORD Form ADM-NGGC-0206-1-5 ADM-NGGC-0206 Rev. 6 Page 68 of 89

Attachment 2 Fatigue Assessment Form Sheet 1 of 4 Form ADM-NGGC-0206-2-5 Name:

Facility: BNP CR3 HNP RNP Corporate ID or Fatigue Assessment or Waiver Outage: YES NO Badge Number ID Number from EmpCenter This assessment is intended to determine whether a degradation in a workers cognitive and motor functioning have occurred due to the lack of rest and where fatigue is identified, establish appropriate controls and conditions ensuring the worker can safely and competently perform assigned duties. Completed assessment shall be maintained as confidential. As requested, workers shall provide complete and accurate information, to the best of their recollection, necessary to address acute and cumulative fatigue and circadian variations in alertness and performance.

SECTION A Assessment of Fatigue and Work Hours To be completed by worker being assessed.

Work history of the last 14 days to assess acute and cumulative fatigue and circadian variation in alertness and performance. This information is available from Passport or EmpCenter on the waiver tab or can be obtained from worker verbally.

Past 14 day work history (Day 14 is T-14.) 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Shift Schedule Record D for days, N for nights or S for swing Hours Worked Excluding turnovers Check the boxes of those days youve had a 34-hour break break of at least 34 hours3.935185e-4 days 0.00944 hours 5.621693e-5 weeks 1.2937e-5 months before shift.

Have you had a break of at least 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months between successive work periods in the last 14 days (or at least 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months if you were transitioning between shifts)? YES NO Have all duties youve performed off-site, if applicable met the definition of incidental?

(e.g., technical assistance provided by telephone from a workers home) YES NO How many hours of sleep have you had in the past 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ?

How many hours have you been awake?

How many hours of sleep have you averaged each day in the last 9 days?

Describe the work activity you are performing Do you feel you can perform this work activity without additional oversight? YES NO Comments:

Are you mentally alert? If no, at what point did you begin to feel fatigued? YES NO Comments:

Did factors outside of work keep you from obtaining adequate and regular rest (e.g., illness, family personal obligations) YES NO Comments:

Completed by: ____________________________/___________________________________/___________________

Print Name Signature Date/Time Continued on page 2 ADM-NGGC-0206 Rev. 6 Page 69 of 89

Attachment 2 Fatigue Assessment Form Sheet 2 of 4 SECTION B Supervisor Face-to Face Fatigue Assessment Supervisor directing or overseeing assessed worker: (Print Name)

As applicable, worker observing the condition of impaired alertness: (Print Name)

Supervisor performing fatigue assessment: (Print Name)

Assessment Type (check one)

WAIVER FOR CAUSE POST-EVENT FOLLOW-UP SELF-Assessment Include description Include description Required when a DECLARATION cannot be of observed NCR number of worker is returned Required if conducted more behavior and name event and workers to work after a individual makes a than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of worker who involvement in break of less than self- declaration before the worker observed condition comments 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months following and a 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months begins performing in comments a for cause or self- break is not given.

any work under the declaration fatigue waiver assessment.

Assessment Guidelines:

Only supervisors with current Plant Access Training may conduct fatigue assessments.

If this assessment is for a waiver, it shall not be performed more than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months before the start of the extended work period.

When a fatigue assessment is conducted For Cause, the person who observed the condition of impaired alertness cannot conduct the fatigue assessment.

In the case of a post-event fatigue assessment, the worker who conducts the fatigue assessment may not have:

o Performed or directed (on site) the work activities during which the event occurred.

o Performed, within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before the event occurred, a fatigue assessment of the workers who were performing or directing (on site) the work activities during which the event occurred, or o Evaluated or approved a waiver for any of the workers who were performing or directing (on site) the work activities during which the event occurred, if the event occurred while such workers were performing work under that waiver.

For items below as appropriate, interview/observe worker and review workers assessment/documents to determine whether additional controls and conditions are necessary to address fatigue.

Fatigue Assessment Basis: Describe observed behavior and or self-declared conditions leading to assessment.

Minimally state the category of duties (Ops, Maintenance, HP, Chemistry, Security or other) the worker was performing and whether the worker was performing outage activities.

Comments:

Continued on Page 3 ADM-NGGC-0206 Rev. 6 Page 70 of 89

Attachment 2 Fatigue Assessment Form Sheet 3 of 4 SECTION B (continued)

Acute Fatigue Indicators: (Fatigue occurring within last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or since last 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months break)

Was sleep restricted within last 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ? YES NO Comments:

Has worker been awake> 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months ? YES NO Comments:

Did tasks at or away from work require physical exertion? YES NO Comments:

Does worker appear intoxicated? YES NO Comments:

Sleepiness-yawning, tired eyes, legs? YES NO Comments:

Rubs face with hands often? YES NO Comments:

Poor communication/decisions? YES NO Comments:

Bad mood, apathetic, fixated? YES NO Comments:

Observe worker and review Section A completed by the worker: Comments:

Cumulative Fatigue Indicators (Increases in fatigue over consecutive sleep-wake periods resulting from inadequate rest)

Was sleep restricted between any changes in shift schedules within the last 14 days? YES NO Did worker experience sustained wakefulness within last 14 days (were length of sleep periods YES NO reduced as work week progressed)?

If worker has sleep debt, has worker been able to catch-up depleted sleep between shifts or on YES NO off-periods?

Has worker experienced any personal issues or other factors that may impact his/her ability to YES NO obtain adequate sleep within last month? If so, when? Describe impact.

Has worker lacked initiative and/or creativity? YES NO Has workers work schedule during past 14 days allowed adequate opportunity to obtain sufficient YES NO rest?

Comments:

Continued on Page 4 ADM-NGGC-0206 Rev. 6 Page 71 of 89

Attachment 2 Fatigue Assessment Form Sheet 4 of 4 SECTION B (continued)

Circadian Rhythm Considerations (changes in alertness and cognitive/motor functioning related to approximate 24-hour cycle)

Is worker on day, afternoon or evening shifts? Day Afternoon Shift Evening Shift Is worker experiencing or exhibiting fatigue symptoms YES NO during possible physiological alertness low points, 03:00 - 05:00 or 15:00 - 17:00?

Is workers rest/sleep being interrupted by external time YES NO cues such as light and social activity?

Potential Effect of Fatigue on Work Quality (What risk significant function could be impacted during this activity, i.e.,

reactivity management, radioactive release, pressure boundary, containment isolation/integrity, off site power, core cooling, decay heat removal? Consider quality barriers such as post maintenance testing, independent verifications, hold points, and/or surveillance testing.)

Nature of Work to be Performed (What environmental conditions exist that could increase fatigue? Is task repetitive?

Does task have high mental focus or attention demands? Will there be social interaction?)

Assessment Results APPROVED Worker does not exhibit impairment due to fatigue and may continue to work with no addition controls or conditions.

APPROVED Worker may continue working under the controls and conditions identified in next block.

W/RESTRICTIONS Worker is exhibiting impairment due to fatigue and must be provided a break of at least 10 NOT APPROVED hours.

Fatigue Controls and Conditions (to address fatigue concerns identified above)

Additional Breaks Required:

Additional Oversight/Verifications/Peer Checks required:

Additional Environmental Controls required:

NCR Initiated/Number:

Worker signature below indicates worker has read and agrees if assessment results:

_________________________________/__________________________________________________/__________

Print Name Signature Date/Time Supervisor Performing Assessment:

_________________________________/__________________________________________________/__________

Print Name Signature Date/Time Vital Record Form ADM-NGGC-0206-2-5 ADM-NGGC-0206 Rev. 6 Page 72 of 89

Attachment 3 Worker Fatigue Information and Countermeasures Sheet 1 of 3 Fatigue and Decreased Alertness Risk Factors and Symptoms Risk factors for fatigue include:

extended work and/or commuting periods;

split-shift work schedules;

sleep/work periods conflicting with circadian rhythms;

changing or rotating work schedules;

unpredictable work schedule

lack of rest or nap periods during work;

sleep disruption;

inadequate exercise opportunities;

poor diet;

environmental stressors Behavioral symptoms including:

yawning, red eyes;

prolonged or excessive blinking;

irritability;

sleepiness;

difficulty concentrating;

apathy;

feeling of isolation;

annoyance;

increased reaction time to stimulus;

slowing of higher-level mental functioning;

decreased vigilance;

memory problems;

task fixation;

increased errors while performing tasks.

ADM-NGGC-0206 Rev. 6 Page 73 of 89

Attachment 3 Worker Fatigue Information and Countermeasures Sheet 2 of 3 Contributors to Worker Fatigue Task conditions including:

repetitive tasks, tasks with high mental focus or attention demands;

tasks that require the individual to be sedentary;

tasks that limit social interaction;

in studies fatigued individuals consistently underreported how tired they really were;

a tired individual truly does not realize the extent of actual impairment.

Environmental conditions including:

high heat and humidity;

low lighting;

low frequency noise/white noise.

Circadian Variations in Alertness An individuals ability to perform and remain alert is influenced by physiological changes that follow a daily pattern.

Humans are hard-wired with a genetically-determined biological need for sleep and with a circadian pacemaker that programs us to sleep at night and to be awake during the day, on a 24-hour schedule.

Twenty-four hour operations challenge these basic physiological principles.

Individuals may be trying to work when the brain is programmed to be asleep, during the circadian low-point in alertness and performance capacity.

Conversely, individuals may be trying to sleep when the brain is programmed to be awake; leading to sleep loss and poor sleep quality, which further degrades alertness and performance capacity.

Shift work, altered and changing work schedules, crossing time zones, long hours of continuous wakefulness, and sleep loss can create sleep and circadian disruptions that degrade waking function.

This results in:

fatigue and sleepiness while driving;

monitoring equipment, into degraded vigilance and decision-making;

a wide range of other performance effects that can erode the safety margin in operational settings.

ADM-NGGC-0206 Rev. 6 Page 74 of 89

Attachment 3 Worker Fatigue Information and Countermeasures Sheet 3 of 3 Indications and Risk Factors for Common Sleep Disorders Sleep is a complex, active physiological state that is vital to human survival.

When an individual is deprived of sleep, the response is sleepiness, which is the brains signal to prompt an individual to obtain sleep.

When deprived of sleep (acutely or chronically), the human brain can spontaneously, in an uncontrolled fashion, shift from wakefulness to sleep in order to meet its physiological need for sleep.

Sleep apnea and insomnia are conditions that can result from prolonged sleep deprivation.

Shift work strategies for obtaining adequate rest The following are strategies for obtaining adequate rest

Minimize sleep loss;

Take naps;

Develop good sleep habits;

Understand affects of food, alcohol and exercise.

Fatigue Countermeasures The following countermeasures have been determined to be the most effective in countering fatigue:

Adequate Sleep (get in habit of sleeping 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months each night);

Napping (should be less than 30 minutes) ;

Anchor Sleep (deliberate napping prior to shift change e.g. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of sleep at the same time each day when a normal 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months sleep cannot be achieved);

Trip Planning;

Good Sleeping Environment (comfortable mattress, adjust heating and cooling as needed).

ADM-NGGC-0206 Rev. 6 Page 75 of 89

Attachment 4 Risk Based Systems/Components Sheet 1 of 10 BNP Sheet 1 of 1 System System Number System Name Number System Name 1000 Primary Containment Isolation Valves 5110 Diesel Jacket Water & DG Demin Water 1001 ECCS Suction Strainer Debris Monitoring 5111 DG Service Water 1005 Nuclear Boiler 5112 Diesel Generator Starting Air 1011 Primary Containment Isolation 5113 Diesel Generator Intake/Exhaust 1050 Neutron Monitoring 5135 230 KV Switchyard 1065 Rod Control / Rod Worth Minimizer 5145 Start-Up Auxiliary & Unit Auxiliary Transformer 1070 Control Rod Drive Hydraulic 5170 4KV AC Distribution 1080 Reactor Protection 5175 480V AC Distribution 2010 Reactor Water Cleanup 5185 208/120V AC Distribution 2020 Reactor Recirculation 5195 UPS- Uninterruptible AC 2035 Core Spray 5230 250V DC Distribution 2040 Standby Liquid Control 5240 125V Battery Chargers 2045 Residual Heat Removal 5245 125V Dc Battery & Distribution Site Cables (Including Wiring, Trays, and LSSY 2055 Automatic Depressurization 5259 Conduit) 2070 Containment Atmospheric Control 6010 Main Control Board (RTGB) 2095 High Pressure Coolant Injection 6020 Aux Control Board 2100 Reactor Core Isol. Cooling 6135 Instrument Air (IAI, IAN, RNA & RIP)

Post Accident Sampling (Containment Isolation 2117 Function Only) 6152 Pneumatic Nitrogen Torus Drain (Containment Isolation Function 2190 Only) 6175 Fire Protection (Including Fire Stops) 3050 Feedwater 6180 Fire Detection 3060 Heater Drains And Misc. Vents & Drains 6195 Fire Protection Co2 3070 Condensate 6205 Halon Supply Radioactive Floor Drains (Containment 3080 Condensate Makeup And Demin 6235 Isolation Function Only)

Radioactive Equipment Drains (Containment 4005 Condenser 6240 Isolation Function Only) 4010 Off-Gas & Condenser Vacuum 7095 Refueling 4015 Circulating Water 7105 Spent Fuel Storage System Fuel Pool Cooling & Supplemental Fuel Pool 4040 Screen Wash Water 7110 Cooling Intake, Discharge Canal (see NCR 380631 for 4045 activities that are excluded from covered work) 7111 Nuclear Fuels Primary Containment (Incl. Liner &

4060 Service Water 8020 Penetrations) 4070 Rx Bldg. Closed Cooling Water 8065 Bridge Crane 4075 Turbine Building Closed Cooling Water 8075 HVAC Diesel Generator Bldg.

5010 Turbine Controls (EHC) 8185 HVAC Reactor Building 5065 Generator Isolated Phase Bus 8220 HVAC Control Building 5095 Diesel Generator 8232 HVAC Service Water Building 5098 SAMG Diesel Generator 8240 Reactor Building 5100 Diesel Fuel Oil 9300 Alternate Safe Shutdown And SBO 5105 Diesel Lube Oil ADM-NGGC-0206 Rev. 6 Page 76 of 89

Attachment 4 Risk Based Systems/Components Sheet 2 of 10 CR3 Sheet 1 of 2 System System Number System Name Number System Name AC Miscellaneous AC Distribution EF Emergency Feedwater AH-XA Reactor Building Recirculation EG Emergency Diesel Generator AH-XB Misc. Reactor Building Ventilation ES Engineered Safeguards AH-XC Reactor Building Purge FH Fuel Handling AH-XF Decay Heat Closed Cycle Cooling Pump Cooling FS Fire Service Feedwater * (see next page for covered AH-XG Spent Fuel Coolant Pump Cooling FW components)

AH-XK Control Complex HVAC FWP-7 Auxiliary Feedwater AH-XL Emergency Diesel Ventilation IA Instrument Air AH-XS Control Complex EFIC Room HVAC IC Integrated Control System (ICS)

AH-XU EFP-3 Building Ventilation IM Incore Monitoring AR Condenser Air Removal ME Miscellaneous Electric Main Steam * (see next page for covered AS Auxiliary Steam MS components)

AT Anticipated Transient Without Scram MT Auxiliary Electric Power BS Building Spray MU Make Up, Purification, and Letdown CA Chemical Addition MX Miscellaneous Mechanical (includes RB)

CA-LS Liquid Sampling (Containment Isolation) NI Nuclear Instrumentation CA-PA Post Accident Sampling (Containment Isolation) NN Non-Nuclear Instrumentation CB Control Board Components PE Penetrations CD Condensate (CDT-1 and CDV-102 only) RA Reactor Building Airlocks CF Core Flood RC Reactor Coolant CH Chilled Water RCITS Reactor Coolant Inventory Tracking CI Industrial Cooling Water (Containment Isolation) RP Reactor Protection CW Circulating Water RS Remote Shutdown CW- Nuclear Service and Decay Heat Seawater WW Screen Wash Water System RW Cooling CX Condensate Demineralizers SA Station Air DC Decay Heat Closed Cycle Cooling SB Substation DF Diesel Fuel SF Spent Fuel DH Decay Heat Removal SW Nuclear Service Closed Cycle Cooling DJ Diesel Generator Coolant VB AC Vital Bus WD-DL Diesel Lube Oil GW Gas Waste Disposal System (RN Isolation)

DP DC Electrical System WD-LW Liquid Waste Disposal System (RB Isolation)

DR Control Rod Drive WS-CM Containment Monitoring (RB Isolation)

DW Demineralized Water (Containment Isolation) Nuclear Fuel Emergency Feedwater Initiation And Control EC (EFIC)

ADM-NGGC-0206 Rev. 6 Page 77 of 89

Attachment 4 Risk Based Systems/Components Sheet 3 of 10 CR3 Sheet 2 of 2 Covered Components in Main Feedwater System Covered Components in Main Steam System Penetration 108 - MFW to SG3B Penetration 105 - Main Steam Line A-2 FWV-46 Outside Reactor Building MSV-411 Outside Reactor Building FWV-86 Inside Reactor Building MSV-503 Outside Reactor Building FWV-111 Outside Reactor Building MSV-33 Outside Reactor Building FWV-170 Inside Reactor Building MSV-37 Outside Reactor Building MSV-42 Outside Reactor Building MSV-46 Outside Reactor Building MSV-447 Inside Reactor Building Penetration 423 - MFW to SG3A Penetration 106 - Main Steam Line A-1 FWV-45 Outside Reactor Building MSV-412 Outside Reactor Building FWV-85 Inside Reactor Building MSV-505 Outside Reactor Building FWV-171 Outside Reactor Building MSV-25 Outside Reactor Building FWV-169 Inside Reactor Building MSV-34 Outside Reactor Building MSV-38 Outside Reactor Building MSV-40 Outside Reactor Building MSV-43 Outside Reactor Building MSV-55 Outside Reactor Building Penetration 424 - Emergency FW to SG# 3A Penetration 201 - Main Steam Line B-1 FWV-44 Outside Reactor Building MSV-413 Outside Reactor Building FWV-132 Inside Reactor Building MSV-507 Outside Reactor Building FWV-205 Outside Reactor Building MSV-35 Outside Reactor Building FWV-206 Inside Reactor Building MSV-39 Outside Reactor Building FWV-134 Inside Reactor Building MSV-44 Outside Reactor Building FWV-135 Inside Reactor Building MSV-47 Outside Reactor Building MSV-449 Inside Reactor Building Penetration 109 - Emergency FW to SG# 3B Penetration 107 - Main Steam Line B-2 FWV-43 Outside Reactor Building MSV-414 Outside Reactor Building FWV-203 Inside Reactor Building MSV-509 Outside Reactor Building FWV-204 Outside Reactor Building MSV-26 Outside Reactor Building FWV-138 Inside Reactor Building MSV-36 Outside Reactor Building FWV-136 Inside Reactor Building MSV-41 Outside Reactor Building FWV-137 Inside Reactor Building MSV-45 Outside Reactor Building MSV-48 Outside Reactor Building MSV-56 Outside Reactor Building MSV-45 0 Inside Reactor Building MSV-552 Outside Reactor Building FWC-1 Ultrasonic Feedwater Flow Measuring Main Turbine Bypass to Condenser 3B System Cabinet MSV-10 Outside Reactor Building MSV-9 Outside Reactor Building Main Turbine Bypass to Condenser 3A MSV-11 Outside Reactor Building MSV-14 Outside Reactor Building ADM-NGGC-0206 Rev. 6 Page 78 of 89

Attachment 4 Risk Based Systems/Components Sheet 4 of 10 HNP Sheet 1 of 2 System System Number System Name Number System Name 1005 Reactor Vessel and Internals 4060 Normal Service Water 1045 Excore Nuclear Instrumentation 4065 Emergency Service Water Incore Nuclear Instrumentation (RCS pressure 1050 boundary only) 4080 Component Cooling Water 1065 Rod Control 4085 Essential Service Chilled Water 1080 Reactor Protection(ESFAS) 4115 Emergency Screen Wash 1900 NSSS Process Instrumentation 5065 Isolated Phase Bus 2 Offsite AC Power(Switchyard) 5095 Emergency Diesel Generator 2005 Reactor Coolant 5096 Sequencer 2025 Reactor Coolant Pumps And Motors 5100 Diesel Generator Fuel Oil Supply 2050 Pressurizer 5105 Emergency Diesel Generator Lube Oil 2060 Chemical & Volume Control 5110 Emergency Diesel Generator Jacket Water 2070 Containment Spray 5112 Emergency Diesel Generator Starting Air Post-Accident Hydrogen (containment isolation 2075 function only) 5132 Main Transformer 2080 High Head Safety Injection 5145 Startup and Auxiliary Transformers 2085 Low Head Safety 5165 6.9 KV AC Distribution 2090 Passive Safety Injection 5175 480 VAC Distribution 2110 Primary Makeup Water 5185 208/120 VAC Distribution Reactor Coolant Sampling (containment 2115 isolation function only) 5195 Uninterruptable AC (NNS)

Post Accident Sampling (containment isolation 2117 function only) 5196 Class IE Uninterruptable AC 3 Nuclear Fuel 5230 250 VDC Distribution 3005 Steam Generators 5232 125 VDC Electrical Distribution 3010 Steam Generator Blowdown 5245 125 VDC Elect Distribution (NonClass 1E) 3020 Main Steam 6010 Main Control Board 3035 Steam Dump 6012 Main Termination Cabinets 3040 Auxiliary Steam 6013 MCB-ACP Transfer Panels 3050 Main Feedwater 6016 Isolation Cabinets 3065 Auxiliary Feedwater 6018 Auxiliary Relay Cabinets 3070 Condensate 6020 Auxiliary Control Panel 3075 Condensate Polishing 6135 Instrument Air 3080 Condensate Makeup 6140 Service Air(containment isolation function only)

Steam Cycle Sampling (containment isolation 3100 function only) 6150 Nitrogen Supply 4005 Main Condenser 6175 Fire Protection 4010 Condenser Vacuum 6180 Site Fire Detection 4015 Circulating Water 6190 Compressed Air ADM-NGGC-0206 Rev. 6 Page 79 of 89

Attachment 4 Risk Based Systems/Components Sheet 5 of 10 HNP Sheet 2 of 2 System System Number System Name Number System Name Radioactive Equipment Drains (containment 6240 isolation function only) 8200 Spent Fuel Cask Handling Crane Demineralized Water Support (containment 6270 isolation function only) 8210 HVAC Auxiliary Building Radiation Monitoring (containment isolation 7005 function only) 8220 HVAC Control Room Area Waste Gas Processing (containment isolation 7070 function only) 8231 HVAC ESW Intake Structure 7095 Refueling 8320 Auxiliary Building 7105 Spent Fuel Handling 8340 Diesel Generator Building 7110 Spent Fuel Pool Cooling 8342 HVAC Diesel Generator Building Spent Fuel Pool Cleanup (containment 7115 isolation function only) 8350 Fuel Handling Building 8010 Containment Building 8352 HVAC Fuel Handling Building 8020 Cont Liner & Penetrations 8450 Polar Crane 8060 Containment Vacuum Breakers 9001 Containment Isolation Valves 8065 Bridge Crane 8070 Containment Pressurization 8152 Containment Cooling 8170 Containment Purge ADM-NGGC-0206 Rev. 6 Page 80 of 89

Attachment 4 Risk Based Systems/Components Sheet 6 of 10 RNP Sheet 1 of 5 System System Number System Name Number System Name 1005 Reactor Vessel and Internals System 5175 480V AC Distribution System (480 VAC) 1045 Excore Nuclear Instrument System 5185 208-120 VAC Distribution System 1055 RX Vessel Level Instrumentation/ICCM System 5235 125V DC Battery/Charger/Distribution System 1065 Rod Control System 6010 Main Control Board (RTGB) 1075 Rod Position Indication System 6082 EOF/TSC/ Security Diesel 1080 Reactor Protection And Safeguards System 6125 Instrument Air System (IA) 2005 Reactor Coolant System (RC) 6150 Nitrogen Supply/Blanketing System (N2 SUO) 2045 Residual Heat Removal System (RHR) 6175 Site Fire Protection System (SFPS) 2060 Chemical and Volume Control System 6180 Site Fire Detection System (SFDS) 2080 Safety Injection System 6181 Fire Alarm Computer Primary Sampling System (PS) (containment 2115 isolation only) 6185 Emergency Diesel Generator Cardox System 2116 Post Accident Monitoring System 6195 Fire Protection CO2 System Primary and Demineralized Water Makeup 3005 Steam Generator 6270 System Steam Generator Blowdown System Liquid Waste Processing System (containment 3010 (containment isolation function only) 7060 isolation function only)

Main Steam (MS) *(see following pages for Gaseous Waste Processing System 3020 covered components) 7070 (GWPS)(containment isolation function only) 3025 Extraction Steam System (ES) 7095 Refueling System (REFUEL) 3040 Auxiliary Boiler/Steam System (AS) 7105 Spent Fuel System (SFS)

Feedwater System (FW) *(see following pages for 3050 covered components) 8010 Containment System (CV) 3065 Auxiliary Feedwater (AFW) 8050 Containment Pressure Relief System (CVPRS)

Condensate System (C) *(see following pages for Containment Vacuum Breaker System (CV 3070 covered components) 8060 VBS) 3075 Condensate Polishing Demineralizer System 8100 Penetration Pressurization System 4010 Condenser Vacuum System 8150 HVAC Containment Building System (HVAC) 4015 Circulating Water System 8170 Containment Purge System (CV PIR) 4060 Service Water System (SW) 8175 Isolation Valve Seal Water System (IVSW) 4080 Component/Cooling Water System 8200 Spent Fuel Cask Handling Crane (SF CRAN) 5095 Emergency Diesel Generator System 8210 HVAC Auxiliary Building (HVAC) 5098 Dedicated Shutdown Diesel Generator (DSD) 8220 HVAC Control Room Area (HVAC) 5100 Fuel Oil System (FO) 8320 Auxiliary Building (AUX BD) 5114 Dedicated Shutdown System (DSS) 8350 Fuel Handling Building (FUEL BD)

Switchyard and Transformer System (SWTR) 5120 (see following pages for covered components) 8450 Polar Crane 5170 4 KV AC Distribution System (4KV)

ADM-NGGC-0206 Rev. 6 Page 81 of 89

Attachment 4 Risk Based Systems/Components Sheet 7 of 9 RNP Sheet 2 of 5 Covered Components in Main Steam System (3020)*

Main Steam from A SG to Main Steam A Check Valve Main Steam from B SG to Main Steam B Check Valve

1. FT-474: Flow Transmitter and Isolation Valves MS- 1. FT-484: Flow Transmitter and Isolation Valves MS-6A 4A and MS-4B and MS-6B

2. FT-475: Flow Transmitter and Isolation Valves MS- 2. FT-485: Flow Transmitter and Isolation Valves MS-7A 5A and MS-5B and MS-7B

3. FE-474: Venturi Flow Element 3. FE-484: Venturi Flow Element

4. P-7: Containment Vessel Penetration 4. P-8: Containment Vessel Penetration

5. PIC-477: Pressure Indicator/Controller for RV1-1 5. PIC-487: Pressure Indicator/Controller for RV1-2

6. MS-13: Isolation Valve for PIC-477 6. MS-23: Isolation Valve for PIC-487

7. MS-13A: Vent Valve for PIC-477 7. MS-23A: Vent Valve for PIC-487

8. MS-13B: Isolation Valve for PIC-477 8. MS-23B: Isolation Valve for PIC-487

9. MS-13C: Drain Valve for PIC-477 9. MS-23C: Drain Valve for PIC-487

10. PT-474: Steam Generator A Pressure Transmitter 10. PT-484: Steam Generator B Pressure Transmitter and Isolation Valves MS-14, MS-14B, and MS-14D and Isolation Valves MS-22, MS-22B, and MS-22D

11. RV1-1: Steam Generator A Pressure Operated 11. RV1-2: Steam Generator B Pressure Operated Relief Relief Valve (PORV) Valve (PORV)

12. SV1-1A: Steam Generator A Safety Valve 12. SV1-1B: Steam Generator B Safety Valve

13. PT-476: Steam Generator A Pressure Transmitter 13. PT-486: Steam Generator B Pressure Transmitter and Isolation Valves MS-17, MS-17B, and MS-17D and Isolation Valves MS-26, MS-26B, and MS-26D

14. SV1-2A: Steam Generator A Safety Valve 14. SV1-2B: Steam Generator B Safety Valve

15. SV1-3A: Steam Generator A Safety Valve 15. SV1-3B: Steam Generator B Safety Valve

16. PT-475: Steam Generator A Pressure Transmitter 16. PT-485: Steam Generator B Pressure Transmitter and Isolation Valves MS-16, MS-16B, and MS-16D and Isolation Valves MS-25, MS-25B, and MS-25D

17. SV1-4A: Steam Generator A Safety Valve 17. SV1-4B: Steam Generator B Safety Valve

18. MS-19: Steam Generator A Steam Line Before 18. MS-28: Steam Generator B Steam Line Before Seat Seat Root Isolation Valve Root Isolation Valve

19. MS-21: Steam Generator A Steam Line After 19. MS-30: Steam Generator B Steam Line After Seat Seat Root Isolation Valve Root Isolation Valve

20. MS-V1-3A: Steam Generator A Main Steam 20. MS-V1-3B: Steam Generator B Main Steam Isolation Isolation Valve (MSIV) Valve (MSIV)

21. MS-353A: A MSIV Bypass 21. MS-353B: B MSIV Bypass

22. MS-261A: Check Valve Downstream of MS-V1-3A 22. MS-261B: Check Valve Downstream of MS-V1-3B

Note: The electromechanical components listed include all necessary attendant instrumentation, controls, and normal/emergency electrical feeds.

ADM-NGGC-0206 Rev. 6 Page 82 of 89

Attachment 4 Risk Based Systems/Components Sheet 8 of 10 RNP Sheet 3 of 5 Covered Components in Main Steam System (3020)*

Main Steam from C SG to Main Steam C Check Main Steam to Auxiliary Feed Water Pump Valve

1. MS-262A: Isolation Valve for MS-V1-8A

1. FT-494: Flow Transmitter and Isolation Valves 2. MS-263A: Check Valve from Steam Generator A to MS-8A and MS-8B Steam Driven AFW Pump

2. FT-495: Flow Transmitter and Isolation Valves 3. MS-V1-8A: Steam Generator A Supply to Steam MS-9A and MS-9B Driven AFW Pump

3. FE-494: Venturi Flow Element 4. MS-20: Steam Generator A Bypass Valve for Drain

4. P-9: Containment Vessel Penetration and Warm-up Line to AFW Pump

5. PIC-497: Pressure Indicator/Controller for RV1-3 5. MS-262B: Isolation Valve for MS-V1-8B

6. MS-31: Isolation Valve for PIC-487 6. MS-263B: Check Valve from Steam Generator B to

7. MS-31A: Vent Valve for PIC-487 Steam Driven AFW Pump

8. MS-31B: Isolation Valve for PIC-487 7. MS-V1-8B: Steam Generator B Supply to Steam

9. MS-31C: Drain Valve for PIC-487 Driven AFW Pump

10. PT-494: Steam Generator C Pressure 8. MS-29: Steam Generator B Bypass Valve for Drain Transmitter and Isolation Valves MS-32, MS-32B, and Warm-up Line to AFW Pump and MS-32D 9. MS-262C: Isolation Valve for MS-V1-8C

11. RV1-3: Steam Generator C Pressure Operated 10. MS-263C: Check Valve from Steam Generator C to Relief Valve (PORV) Steam Driven AFW Pump

12. SV1-1C: Steam Generator C Safety Valve 11. MS-V1-8C: Steam Generator C Supply to Steam

13. PT-496: Steam Generator C Pressure Driven AFW Pump Transmitter and Isolation Valves MS-35, MS-35B, 12. MS-38: Steam Generator C Bypass Valve for Drain and MS-35D and Warm-up Line to AFW Pump

14. SV1-2C: Steam Generator C Safety Valve 13. MS-161: Steam Feed Water Pump Line Drain Trap

15. SV1-3C: Steam Generator C Safety Valve Isolation Valve

16. PT-495: Steam Generator C Pressure 14. MS-155: Auxiliary Feed Water Pump Steam Supply Transmitter and Isolation Valves MS-34, MS-34B, Line Drain Root Isolation Valve and MS-34D 15. MS-156: Auxiliary Feed Water Pump Steam Supply

17. SV1-4C: Steam Generator C Safety Valve Line Drain Trap Inlet Isolation Valve

18. MS-37: Steam Generator C Steam Line Before 16. MS-158: Auxiliary Feed Water Pump Steam Supply Seat Root Isolation Valve Line Drain Trap Bypass Valve

19. MS-39: Steam Generator C Steam Line After 17. MS-159: Auxiliary Feed Water Pump Steam Supply Seat Root Isolation Valve Line Drain Vent to Atmosphere Isolation Valve

20. MS-V1-3C: Steam Generator C Main Steam 18. MS-154: Main Steam to AFW Pump Isolation Valve Isolation Valve (MSIV) 19. PI-1357-2: Main Steam SDAFW Pump Supply

21. MS-353C: C MSIV Bypass Pressure Indicator and Isolation Valve MS-162

22. MS-261C: Check Valve Downstream of MS-V1- 20. MS-322: Steam Driven AFW Pump Turbine Casing 3C Drain Main Steam Header

1. PT-464: Main Steam Header Pressure Transmitter

2. PT-466: Main Steam Header Pressure Transmitter

3. PT-468: Main Steam Header Pressure Transmitter

Note: The electromechanical components listed include all necessary attendant instrumentation, controls, and normal/emergency electrical feeds.

ADM-NGGC-0206 Rev. 6 Page 83 of 89

Attachment 4 Risk Based Systems/Components Sheet 9 of 10 RNP Sheet 4 of 5 Covered Components in Feed Water System (3050)* Covered Components in Condensate System (3070)*

1. FW-V2-6A - SG A Feed Reg Bypass Outlet 1. Condensate Storage Tank

2. FW-V2-6B - SG B Feed Reg Bypass Outlet 2. LT-1454A - CST Level Transmitter A

3. FW-V2-6C - SG B Feed Reg Bypass Outlet 3. LT-1454B - CST Level Transmitter A

4. FCV-478 - Feed Reg Valve A 4. C Condensate Storage Tank Drain

5. FCV-479 - Feed Reg ByPass Valve A 5. LI-1454A - CST Level Indicator B

6. FCV-488 - Feed Reg Valve B 6. LI-1454B - CST Level Indicator B

7. FCV-489 - Feed Reg ByPass Valve A

8. FCV-498 - Feed Reg Valve C

9. FCV-499 - Feed Reg ByPass Valve C

10. FW-8A - SG A Inlet Stop Check Valve

11. FW-8B - SG B Inlet Stop Check Valve

12. FW-8C - SG C Inlet Stop Check Valve

13. FE-11074A (Pressure Boundary)

14. FE-11074B (Pressure Boundary)

15. FE-11074C (Pressure Boundary)

16. FE-476

17. FE-486

18. FE-496

19. FT-476

20. FT-477

21. FT-486

22. FT-487

23. FT-496

24. FT-497

Note: The electromechanical components listed include all necessary attendant instrumentation, controls, and normal/emergency electrical feeds.

ADM-NGGC-0206 Rev. 6 Page 84 of 89

Attachment 4 Risk Based Systems/Components Sheet 10 of 10 RNP Sheet 5 of 5 Covered Components in Switchyard and Transformer System (5120)

Covered components in this system include all portions of the system inside the plant protected area ,

all components inside the Switchyard Relay Building and only the following four breakers in the switchyard including all associated controls, relays and disconnect switches:

1. 52-8 (Transmission Tag: 230CB28) (Equipment name: Generator Output Ckt Bkr to 230kV Darlington Line)(Transmission Name: 52-8 #2 Unit Darlington SCPSA Tie 230kV CB)

2. 52-9 (Transmission Tag: 230CB29) (Equipment name: Generator Output Ckt Bkr to 230kV North Bus)(Transmission Name: 52-9 #2 Unit 230kV CB)

The following two breakers do not have component tag at this time.

3. West Span Bus Breaker (Transmission name: #2 Start-up XMF-West Bus 115kV CB)

4. East Span Bus Breaker (Transmission name: #2 Start-up XMF-East Bus 115kV CB)

ADM-NGGC-0206 Rev. 6 Page 85 of 89

REVISION

SUMMARY

Processed under PRR 392070 - incorporates PRRs 406967 and 387276 Incorporates corrective actions from NCR 404637 and NCR 40551 Page Section Changes All na Changed to Rev. 6 2 Table of Changed page numbers are needed Contents 4 Purpose Modified 6 a) to read as follows per NCR 404637:

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.

6 References Added reference 22 - NCR 404637 Added reference 23 - NCR 400551 Added reference 24 - CSP-NGGC-2505 - Software Quality Assurance and Configuration Control of Business Computer Systems 14 Definitions Removed work hours performed during an actual emergency from the list of excluded items in definition 46 (See NCR 404637) 15 Responsibilities Added the following responsibility to the PGM Site ownership of the Part 26 program.

Ensuring a Part 26 Program Coordinator is designated for each of the following organizations: Operations, Maintenance, Health Physics, Chemistry, and Security Per comment resolution, modified the responsibility in 4.1.b to Communicate and ensure compliance with. instead of just Communicate 15 Responsibilities Modified the responsibilities of Director Fleet Operations to be as follows:

Fleet ownership of the Part 26 program.

Designating a NGG Fleet Part 26 Program Coordinator.

ADM-NGGC-0206 Rev. 6 Page 86 of 89

18 Responsibilities Added Item 10 for the Part 26 Program Coordinator as follows:

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 these 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 19 Responsibilities Added Item 11 for the Part 26 Program Coordinator as follows:

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 these 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 ADM-NGGC-0206 Rev. 6 Page 87 of 89

procedure.

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

j) Supporting NIT in testing and implementing EmpCenter program changes.

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.

18 Responsibilities Added Project Managers to the Contract Designated Representatives and added the following responsibility for this position:

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

21 Responsibilities Changed item to reflect revised internal reference to 4.13 Covered Workers are responsible for the following in addition to items in Section 4.13:

22 8 - Acceptance Modified 8.3.4 to read as follows:

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

This change will allow the same criteria to be applied during outages as on-line for rolling periods.

23 Section 9.1 Removed Work performed during an actual plant emergency from the list of items in 9.1.2 of items to be excluded from the work hour calculations and renumbered remaining items (See NCR 404637) 28 9.2.2 Changed title to be consistent with 9.2.1 30 Section 9.2 Corrected numbering error for Section 9.2.3 per PRR 406967 36 9.5.3 Modified language in table discussing Time Record Type of Actual Replace due to the addition of section 9.9.2 59 9.9 Renumbered items to create a 9.9.1 and 9.9.2 ADM-NGGC-0206 Rev. 6 Page 88 of 89

60 9.9.2 Added entire section 9.9.2 to provide instructions for employee time entry into EmpCenter for transmission per PRR 392070 62 9.11 Modified item c) to include a list of all deviation overrides c) Contact the System Administrator to obtain a list of all Waivers and Fatigue Assessments and a list of all Deviation Overrides completed for the year.

76 - 85 Attachment 4 Added information on page 5 of 5 for RNP System 5120 regarding scope of covered components in system per PRR 387276.

Renumbered pages to reflect 10 total for Attachment 4 and 5 total for RNP.

ADM-NGGC-0206 Rev. 6 Page 89 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 48 gpm X 1000 Recirc Pump B Flow 43 gpm X 1000 Jet Pump Loop A 30 mlbm/hr Jet Pump Loop B 35 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 complete 0PT-13.1 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(HIGH).

- 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(LOW).

- 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*

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

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

SAT/UNSAT*

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

Evaluate Jet Pump Performance Per PT-13.1.

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

Step 8 - Informs Unit CRS of 0PT-13.1 results.

Unit CRS informed of the following NOT meeting PT acceptance criteria.

A recirculation pump flows is NOT within the region bounded by the established speed-flow characteristic curves A jet pump loop flow is NOT within the region bounded by the established speed-flow characteristic curves.

The diffuser-to-lower plenum % psid reading jet pump #3 is NOT within the region bounded by the established curves.

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 Copy of Unit 2 Tech Specs (SRO)

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 complete 0PT-13.1 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 2B 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.

2B 7.3 Jet Pump Operability Test 2B 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 48 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 35 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.

2B 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: 2B N/A 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 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.2

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 B 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.2

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.2

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 B 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.2

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.2

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 for different HRA with different worker dose and area dose rates.

LOT-ADM-JP-102-A03 Page 6 of 9 Rev.2

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.2

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 B 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.

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

ML111020339

Text

REFERENCES:

7.0 REFERENCES

SUMMARY

REFERENCES:

2.0 REFERENCES

2.0 REFERENCES

2.0 REFERENCES

SUMMARY

REFERENCES:

2.0 REFERENCES

SUMMARY

REFERENCES:

REFERENCES:

Navigation menu

Search