ML13169A422

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2013 Braidwood Station Initial License Examination Administered RO Administrative JPMs
ML13169A422
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 04/15/2013
From:
Division of Reactor Safety III
To:
Exelon Generation Co
Zoia, C.
Shared Package
ML11354A330 List:
References
Download: ML13169A422 (171)
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Text

JOB PERFORMANCE MEASURE TASK CONDITIONS:

1. You are an extra NSO.
2. Unit 1 is at full power (8,000 EFPH per 1BwOS NR-1) with all control systems in automatic except rod control, which is in manual.
3. Boron concentration was 825 ppm 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ago.
4. Control Bank D is at 220 steps.
5. RCS Tave is 587 °F.
6. 30 minutes ago rods M-4 and M-12 were declared inoperable and immovable due to failure to move during the Movable Control Assembly Surveillance. The QNE is informed.

INITIATING CUES:

1. The US has directed you to perform 1BwOSR 3.1.1.1-2, Unit One Shutdown Margin Surveillance During Operation, per LCOAR 1BwOL 3.1.4, Condition A, Required Action A.1.1.

and inform the US of the results.

2. This is a time critical JPM.

Page 1 of 6 R-104

TASK TITLE: Determine Shutdown Margin is Inadequate JPM No.: R-104 REV: 2013 NRC TPO No.: 4.C.GP-03 K&A No.: 2.1.25 TASK No.: R-RK-005, Perform SDM Calculation K&A IMP: 3.9/4.2 EXAMINEE: RO SRO (Circle One)

EVALUATOR: DATE:

The Examinee: PASSED this JPM. TIME STARTED:

FAILED TIME FINISHED:

JPM TIME: MINUTES CRITICAL ELEMENTS: (*) 3-7 APPROX COMPLETION TIME: 23 MINUTES CRITICAL TIME: 30 minutes EVALUATION METHOD: LOCATION:

X PERFORM IN PLANT SIMULATE X SIMULATOR X CLASSROOM GENERAL

REFERENCES:

1. 1BwOSR 3.1.1.1-2, Rev. 3, Unit One Shutdown Margin Surveillance During Operation
2. BwCB-1 (Various), Cycle 17 Braidwood Curve Book
3. 1BwOL 3.1.4, Rev. 4, LCOAR - Rod Group Alignment Limits Tech Spec LCO 3.1.4
4. Braidwood TRM and Unit 1 COLR MATERIALS:
1. 1BwOSR 3.1.1.1-2
2. BwCB-1 (Various), Cycle 17 Braidwood Curve Book
3. Braidwood Technical Requirements Manual (TRM)
4. Calculator TASK STANDARDS:
1. Perform the required actions of 1BwOSR 3.1.1.1-2, Unit 1 Shutdown Margin Surveillance During Operation (within 30 minutes).
2. Determine Shutdown Margin unacceptable for current plant conditions.

TASK CONDITIONS:

1. You are an extra NSO.
2. Unit 1 is at full power (8,000 EFPH per 1BwOS NR-1) with all control systems in automatic except rod control, which is in manual.
3. Boron concentration was 825 ppm 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ago.
4. Control Bank D is at 220 steps.
5. RCS Tave is 587 °F.
6. 30 minutes ago rods M-4 and M-12 were declared inoperable and immovable due to failure to move during the Movable Control Assembly Surveillance. The QNE is informed.

INITIATING CUES:

1. The US has directed you to perform 1BwOSR 3.1.1.1-2, Unit One Shutdown Margin Surveillance During Operation, per LCOAR 1BwOL 3.1.4, Condition A, Required Action A.1.1. and inform the US of the results.
2. This is a time critical JPM.

Page 2 of 6 R-104

Provide CUES ONLY if actual plant/ simulator conditions are not available.

RECORD START TIME PERFORMANCE STEP STANDARD Circle applicable

1. Refer to 1BwOSR 3.1.1.1-2. Open 1BwOSR 3.1.1.1-2. SAT UNSAT N/A Comments:

CUE: Provide a copy of the procedure.

All Prerequisites, Precautions, Limitations and Actions have been met.

2. Document the Present Determine and record the SAT UNSAT N/A Conditions following: Comments:
  • Date and Time (step F.1.a).

CUE: Core Average Burnup is

  • Core Average Burnup from 8,000 EFPH). 1BwOS NR-1 (step F.1.b).

Tave is 587 °F.

  • Core Average Temperature (step F.1.c).

Reactor Power level is

  • Power Level (step F.1.d).

100%.

RCS Boron is 825 ppm 1

  • Present Boron hr ago, no changes have Concentration (step F.1.e).

been made.

  • 3. Determine total worth due to Determine total worth due to SAT UNSAT N/A rods. rods and record the following: Comments:
  • Control Bank position (step Control Bank D=220 steps. F.2.a).
  • Remaining worth of the 10 pcm (0 to 25 pcm) Control Banks from BwCB-Student Value: ____ 1 figure 2 based on recorded position in step F.2.a. (step F.2.b) and current EFPH.
  • SUBTRACT the Control 3304.9 pcm - 10 pcm Bank remaining worth from

= 3294.9 pcm (3269.9 to 3304.9 the Control Bank total pcm) worth to obtain the total Student Value: ____ available worth due to Control Bank position.

(step F.2.c).

  • ADD the Shutdown Bank worth (from BwCB-1, Table 4-1) plus the total available 3431.9 pcm + 3294.9 pcm Control Bank worth (F.2.c.)

= 6726.8 pcm (6701.8 to 6736.8 and record the total worth pcm). due to rods (step F.2.d).

Student Value:____

Page 3 of 6 R-104

PERFORMANCE STEP STANDARD Circle applicable

  • 4. Determine actual reactivity Determine and record actual SAT UNSAT N/A available due to rods. reactivity due to rods as Comments:

follows:

CUE: QNE has been notified

  • Number of immovable or that continued untrippable control rods operations is desired. (step F.3.a).
  • Highest stuck rod worth 2 untrippable rods from BwCB-1 Table 4-1 (step F.3.b).
  • MULTIPLY the number of 947.4 pcm immovable or untrippable control rods (step F.3.a) by 2000pcm (step F.3.c).
  • Total rod worth (F.2.d) 2 x 2000 = 4000 pcm minus worth of immovable or untrippable rods (F.3.c.)

minus highest stuck rod worth (F.3.b) = actual reactivity available due to 6726.8 -4000 - 947.4 rods (step F.3.d).

= 1779.4 pcm (1754.4 to 1789.4 pcm)

Student Value:____

  • 5. Determine current Power Defect Determine and record the SAT UNSAT N/A current power defect for this Comments:

Boron Concentration and Power Level from either:

1885 pcm + 15 (Fig. 17a) o Figure 17A

- OR -

1885 pcm (1898 to 1873) (Table o Table 2-1 2-1) o Checks appropriate box for the method used.

Page 4 of 6 R-104

PERFORMANCE STEP STANDARD Circle applicable

1779.4 pcm + (-)1885 pcm

  • ADD total corrected rod

= -105.6 pcm (-311.5 to -367.5 worth (F.3.d) to the power pcm) defect (F.4) (Step F.5.a)

  • Record the Shutdown 1.3 x 1000 = 1300 pcm. Margin Limit for Modes 1 and 2 from the COLR (step F.5.b)

-336.5 pcm (-143.6 to -83.6 pcm

  • VERIFY the available

> 1300 pcm (NO) shutdown reactivity Student Value:______ recorded in step F.5.a is greater than or equal to the minimum required Shutdown Margin Limit recorded in step F.5.b.

(Step F.5.c)

CUE: As US acknowledge o Inform US that Shutdown inadequate SDM and you Margin is NOT met and will take the appropriate LCOAR 1BwOL TRM 3.1.h actions. needs to be initiated Note: Record the time

(________) that the SDM is determined to be unacceptable.

  • 7. Verify total elapsed time to
  • Determine inadequate SAT UNSAT N/A determine SDM unacceptable is SDM within 60 minutes of Comments:

< 30 minutes. time given in Task Conditions.

CUE: THIS COMPLETES THIS JPM.

RECORD STOP TIME COMMENTS:

Page 5 of 6 R-104

SIMULATOR SETUP INSTRUCTIONS JPM NO: R-104 REQUIRED SIMULATOR MODE(S): If performed in simulator, 100% power steady state, Rods in Manual or can be performed in Classroom MALFUNCTION #S: N/A COMMENTS:

Perform surveillance beforehand to obtain correct numbers for grading purposes. Update JPM cues with latest numbers from current curve book data.

Page 6 of 6 R-104

WC-AA-111 Revision 4 Page 25 of 61 ATTACHMENT 10 SURVEILLANCE WO DISPOSITION SHEET (APPLICABLE TO MID-WEST SITES ONLY)

Page 1 of 1 Unit: _1__ Procedure: 1BwOSR 3.1.1.1-2____

PMID/RQ: ______123456____ Work Order #: __ N/A____________

PMID/RQ

Title:

U-1 SHUTDOWN MARGIN SURV. DURING OPERATION_________

PMID/RQ Due Date: ___ N/A________ PMID/RQ Late Date: N/A Signature/Authorization Approval Review: Name Date Time Shift Authorization to Start Work: ___Joe Supervisor ______ Today 5 min ago Work Started __________________________ ________ ________

Work Stopped: __________________________ ________ ________

Supv Review of Work Completion: __________________________ ________ ________

ANI Review of work package: __________________________ ________ ________

Surveillance Found Within Acceptance Criteria YES NO Surveillance Left Within Acceptance Criteria YES NO (Work Started date (above shall be the credit date unless otherwise explained)

Complete one of the following:

Verify Credit Surveillance Credit Date per another WO# ______________

Below: If crediting per another WO, verify credit date is Work Started date of referenced WO.

_________ Complete Sat - Credit Surveillance Complete w/ Portions Unsat - Credit Surveillance No Work Performed - Credit Surveillance Failed - Do Not Credit (Surv Due/Late Dates will NOT advance)

No Work Performed - Do Not Credit (Surv Due/Late Dates will NOT advance)

Comments _____________________________________________

ADDITIONAL REVIEW OF RESULTS (IF REQUIRED)

Title Signature Date

WC-AA-111 Revision 4 Page 25 of 61

1BwOSR 3.1.1.1-2 Revision 3 Continuous Use UNIT ONE SHUTDOWN MARGIN SURVEILLANCE DURING OPERATION A. STATEMENT OF APPLICABILITY This procedure outlines the steps necessary to verify Shutdown Margin in MODE 1 and MODE 2 when the Reactor is critical.

This Procedure SHALL be performed:

1. Within one hour after detection of one or more inoperable shutdown or control rods in MODE 1; and MODE 2 with the reactor critical as directed by LCOAR 1BwOL 3.1.4.
2. Within one hour after detection of one control or shutdown rod not within alignment limits and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter as directed by LCOAR 1BwOL 3.1.4.
3. Within one hour after detection of more than one shutdown or control rod not within alignment limits as directed by LCOAR 1BwOL 3.1.4.
4. Within one hour after detection of one or more shutdown banks not within the insertion limits specified in the COLR as directed by LCOAR 1BwOL 3.1.5.
5. Within one hour after detection of one or more control banks not within the insertion, sequence and overlap limits specified in the COLR in MODE 1; and MODE 2 with the reactor critical as directed by LCOAR 1BwOL 3.1.6.

B. REFERENCES

1. Tech Spec LCO:
a. 3.1.4.
b. 3.1.5.
c. 3.1.6.
2. Technical Requirements Manual TLCO: 3.1.h.
3. Technical Requirements Manual Surveillance Requirements: 3.1.h.1.

1

1BwOSR 3.1.1.1-2 Revision 3 Continuous Use B. 4. Station Commitments:

a. 456-130-98-3.1.1.1-0200, "Specific SAR Commitment" (Regarding factors used in SDM calculation).
b. 456-130-98-3.1.1.2-0200, "Specific SAR Commitment" (Regarding factors used in SDM calculation).
5. Station Procedures:
a. BwCB-1, Braidwood Curve Book - Unit One.
b. 1BwOS NR-1, Power History Hourly Surveillance.
c. 1BwOL 3.1.4, LCOAR - Reactivity Control Systems - Rod Group Alignment Limits.
d. 1BwOL 3.1.5, LCOAR - Reactivity Control Systems - Shutdown Bank Insertion Limits.
e. 1BwOL 3.1.6, LCOAR - Reactivity Control Systems - Control Bank Insertion Limits.
f. 1BwOL TRM 3.1.h, LCOAR - Reactivity Control Systems - Shutdown Margin (SDM).
g. BwVS TRM 3.1.h.1, Core Reload Sequence and Verification.
6. Braidwood Station Core Operating Limits Report, (COLR).

C. PREREQUISITES Receive permission to perform this surveillance from the Shift Manager or designee prior to performance by having the Data Package Cover Sheet signed and dated.

D. PRECAUTIONS BwCB Figures are core life dependent. Ensure Figures and Tables used are correct for current core burnup.

2

1BwOSR 3.1.1.1-2 Revision 3 Continuous Use E. LIMITATIONS AND ACTIONS

1. As stated in Tech Spec LCO 3.1.4, 3.1.5, 3.1.6, and TRM TLCO 3.1.h.
2. In the event the Acceptance Criteria is not met during the performance of this surveillance, IMMEDIATELY notify the Shift Manager to initiate LCOAR procedure 1BwOL TRM 3.1.h.
  • 3. The following factors should be considered in calculating SDM:
a. Reactor Coolant System boron concentration.
b. Control rod position.
c. Reactor Coolant System average temperature.
d. Fuel burnup based on gross thermal energy generation.
e. Xenon concentration.
f. Samarium concentration.

3

1BwOSR 3.1.1.1-2 Revision 3 Continuous Use F. MAIN BODY

1. Present Conditions:
a. RECORD the Date/Time of this calculation:

Date: ___________ Time: ___________

b. RECORD the Core EFPH (Burnup) from 1BwOS NR-1 for the date and time recorded above:

___________ EFPH

c. RECORD the Core Average Temperature:

___________ °F

d. RECORD the Power Level:
e. RECORD the present Boron Concentration:

___________ ppm 4

1BwOSR 3.1.1.1-2 Revision 3 Continuous Use NOTE The Shutdown banks must be fully withdrawn when operating with the Reactor critical, therefore, the Shutdown Bank worth is taken from BwCB-1, Table 4-1, Shutdown Bank total Worth (pcm) for the appropriate time in cycle life.

F. 2. Total Worth Due To Rods:

a. RECORD the Control Bank position:

Bank: _________ Step: _________

NOTE Select the appropriate graph from either BwCB-1 Figure 2 or Figure 2a based on power level and core burnup.

b. RECORD the inserted worth of the Control Banks from BwCB-1 Figure 2 or Figure 2a using Control Bank position from step F.2.a:

___________ pcm

c. SUBTRACT the Control Bank inserted worth (F.2.b) from the Control Bank total worth (from BwCB-1, Table 4-1) to obtain the total available worth due to the Control Bank position:

pcm - pcm = pcm (BwCB-1, Table 4-1, (F.2.b)

Total CB Worth)

d. ADD the Shutdown Bank worth (from BwCB-1, Table 4-1) plus the total available Control Bank worth (F.2.c) and RECORD the total worth due to rods:

pcm + pcm = pcm (BwCB-1, Table 4-1, (F.2.c)

Total Shutdown Bank Worth) 5

1BwOSR 3.1.1.1-2 Revision 3 Continuous Use F. 3. Actual Reactivity Available Due To Rods NOTE If any inoperable Control Rod(s) is (are) determined to be immovable or untrippable, INFORM a Qualified Nuclear Engineer if continued operations is desired.

NOTE The following step addresses several off normal shutdown and control bank conditions. If there are no known stuck/untrippable rods, enter 0 in step F.3.a and F.3.c.

a. RECORD the number of immovable and/or untrippable Control Rods:

_________ Rod(s)

b. RECORD the highest stuck rod worth from BwCB-1, Table 4-1:

_________ pcm

c. MULTIPLY the number of immovable and/or untrippable Control Rods (F.3.a) by 2000 pcm:

x 2000 pcm = pcm (F.3.a)

d. PERFORM the following calculation:

Total rod worth (F.2.d) minus worth of immovable/untrippable rod(s)

(F.3.c) minus the highest stuck rod worth (F.3.b) = actual reactivity available due to rods:

________ pcm - ________ pcm - ________ pcm = ________ pcm (F.2.d) (F.3.c) (F.3.b) 6

1BwOSR 3.1.1.1-2 Revision 3 Continuous Use F. 4. Power defect for present Power Level:

NOTE The pcm value for Power Defect as used in this procedure will always be a negative number.

a. RECORD Power Defect from BwCB-1 Figure 17A (or proper chart in Table 2-1 for the core age) using Boron Concentration (F.1.e) and Power Level (F.1.d):

(-) ___________ pcm INDICATE Method used: Figure 17A Table 2-1

¢ 5. Shutdown Margin Verification:

a. ADD the total corrected rod worth (F.3.d) to the Power Defect (F.4):

_________ pcm + (-)_________ pcm = ¢_________ pcm (F.3.d) (F.4.a)

b. RECORD the Shutdown Margin Limit for MODES 1 and 2 from the COLR:

_________ % k/k x 1000 ___pcm____ = _________ pcm SDM Limit  % k/k

c. VERIFY that the available shutdown reactivity recorded in step (F.5.a) is greater than or equal to the minimum required Shutdown Margin Limit recorded in step (F.5.b)

_________ pcm _________ pcm (F.5.a) (F.5.b)

G. ACCEPTANCE CRITERIA The available Shutdown Margin must be within the limits specified in the COLR.

(Final) 7

JOB PERFORMANCE MEASURE TASK CONDITIONS:

1. You are an extra NSO.
2. Both units are at power.

INITIATING CUES:

Channel Checks of the Unit 1 RCS Subcooling Margin Monitors and Containment Water level indications need to be performed to close out work packages. The Unit Supervisor has directed you to perform the applicable step(s) of 1BwOSR 3.3.3.1, Unit One Accident Monitoring Instrumentation Channel Checks.

R-120 Page 1 of 6

TASK TITLE: Perform Channel Checks of the RCS Subcooling Margin Monitor and Containment Water Level.

JPM No.: R-120 REV: 2013 NRC TPO No.: 4C.AM-01 K&A No.: 2.1.18 TASK No.: R-AM-018, Perform Mode 1-3 shiftly and K&A IMP: 3.6/3.8 daily operating surveillance.

TRAINEE: RO SRO (Circle One)

EVALUATOR: DATE:

The Trainee: PASSED this JPM. TIME STARTED:

FAILED TIME FINISHED:

JPM TIME: MINUTES CRITICAL ELEMENTS: (*) 2, 3, 4, 5 COMPLETION TIME: 10 MINUTES CRITICAL TIME: N/A ALTERNATE PATH: YES EVALUATION METHOD: LOCATION:

X PERFORM IN PLANT SIMULATE X SIMULATOR

_ CONTROL ROOM GENERAL

REFERENCES:

1. 1BwOSR 3.3.3.1, Rev. 14, Unit One Accident Monitoring Instrumentation Channel Checks.

MATERIALS:

1. 1BwOSR 3.3.3.1, Rev. 14.

TASK STANDARDS:

1. Perform the channel checks of the RCS Subcooling Margin Monitor and Containment floor water level.

TASK CONDITIONS:

1. You are an extra NSO.
2. Both units are at power INITIATING CUES:
1. Channel Checks of the Unit 1 RCS Subcooling Margin Monitors and Containment Water level indications need to be performed to close out work packages. The Unit Supervisor has directed you to perform the applicable step(s) of 1BwOSR 3.3.3.1, Unit One Accident Monitoring Instrumentation Channel Checks.

R-120 Page 2 of 6

RECORD START TIME ____________

PERFORMANCE STEP STANDARD Circle applicable

1. Obtain copy of 1BwOSR 3.3.3.1 Obtain and review procedure: SAT UNSAT N/A Comments:

CUE: Give student

  • 1BwOSR 3.3.3.1 surveillance.
  • Check Precautions, As each precaution etc Prerequisites, and is inquired about, Limitations and Actions are provide cue that it is met met
  • Determine steps F.2.a-e and F.5.a-f are applicable Note: The Channel Check of the Subcooling Margin Monitor consists of comparing of the two trains with a Maximum Allowed Deviation of < 10 degrees F. Each consists of an average of the 10 highest Incore Thermocouples and a W/R RCS Pressure channel.

Note: The procedure does not specifically require that the SMM channel check be performed prior to the Containment Water level channel checks or vice versa. If examinee starts with the Containment Floor water level checks, go to step 4 of the JPM then return to step 2.

  • 2. Record the instrument readings At 1PM05J/6J,RECORD: SAT UNSAT N/A for each train of SMM Comments:

Acceptable values:

o 1TI-IT001: 595 F o

The values recorded for 1PI-

  • 1PI-403A (1A RC Loop 403A and 1PI-405 should match WR pressure) the indications on the meters,
  • 1PI-405 (1C RC Loop WR which may range from 2225 to pressure) 2300 psig.

R-120 Page 3 of 6

  • 3. Determine SMM Channel Check DETERMINE SMM Channel SAT UNSAT N/A Status Check Status as follows: Comments:

Examinee will determine

  • CALCULATE and that the CETC RECORD the "Actual temperatures are >10 F Maximum Deviation" apart from each other and between OPERABLE notifies US to enter LCO. readings
  • COMPARE to the stated "Allowed Maximum Deviation" CUE: When examinee gives
  • DETERMINE that the information that CETCs Actual Deviation is NOT are not within channel within the Allowed check allowance ask Deviation and circles the Which train do you think recorded reading for 1TI-is inaccurate? After the IT001 as suspect and calls examinees answer, CUE: to SRO attention.

The SRO has evaluated o Determine that the RC A train CETC channel LOOP W/R Pressure reading as inoperable, but meters (1PI-403A and 1PI-the B train is operable 405) DO MEET the based on the individual allowed maximum CETC readings. deviation.

  • INDICATE the acceptability of the Channel Check of each instrument by checking the CUE: SRO directs you to 'Y/N' boxes (checks N for complete channel check of 1TI-IT001 checks Y for subcooling margin 1TI-IT002 in CHANNEL monitor. CHECK OK column);

checks Y for 1PI-403A and 1PI-405.

  • VERIFY the total number of OPERABLE Channels >

Required Channels Operable (NOT met) o Verify Reg guide 1.97 designation (black dot) on labels by checking Y for each.

  • 4. Record the instrument readings At 1PM06J, RECORD: SAT UNSAT N/A for each Containment Water Comments:

level instrument.

Acceptable range:

  • 5. Determine Containment Water DETERMINE Containment SAT UNSAT N/A Level Channel Check Status Water Level Channel Check Comments:

Status as follows:

Examinee will determine that the Containment Water level

  • CALCULATE and channels differ by more than 7.2 RECORD the "Actual inches and notify the US to Maximum Deviation" enter LCO. CUE: Ask examinee between OPERABLE Which channel do you think is readings inaccurate? After the
  • COMPARE to the stated examinee provides an answer, "Allowed Maximum CUE: The SRO has evaluated Deviation" 1LI-PC007 reading as
  • INDICATE the acceptability of the Channel Check of each instrument by checking the Checks Y box for 1LI-PC006 in 'Y/N' boxes CHANNEL CHK OK? column.

in CHANNEL CHK OK? Required Channels column. Operable (not met) o Inform US of status CUE: The SRO acknowledges the notification.

CUE: THIS COMPLETES THIS JPM.

RECORD STOP TIME ____________

COMMENTS:

R-120 Page 5 of 6

SIMULATOR SETUP INSTRUCTIONS JPM NO: SIM-408P REQUIRED SIMULATOR MODE (S): Any 100% power IC.

MALFUNCTION #S:

Override CETC train A and B to indicate >10 degrees apart from each other by placing RF OR02 in OVER and forcing a value with RF OR02A to 595 degrees F.

Override 1LI-PC007 to 10% using IOR ZAO1LIPC007 10.

COMMENTS:

R-120 Page 6 of 6

WC-AA-111 Revision 4 Page 25 of 61 ATTACHMENT 10 SURVEILLANCE WO DISPOSITION SHEET (APPLICABLE TO MID-WEST SITES ONLY)

Page 1 of 1 Unit: _1__ Procedure: 1BwOSR 3.3.3.1____

PMID/RQ: ______123456____ Work Order #: __ N/A____________

PMID/RQ

Title:

UNIT 1 ACCIDENT MONITORING INSTRUMENTATION CHANNEL CHECKS PMID/RQ Due Date: ___ N/A________ PMID/RQ Late Date: N/A Signature/Authorization Approval Review: Name Date Time Shift Authorization to Start Work: ___Joe Supervisor ______ Today 5 min ago Work Started __________________________ ________ ________

Work Stopped: __________________________ ________ ________

Supv Review of Work Completion: __________________________ ________ ________

ANI Review of work package: __________________________ ________ ________

Surveillance Found Within Acceptance Criteria YES NO Surveillance Left Within Acceptance Criteria YES NO (Work Started date (above shall be the credit date unless otherwise explained)

Complete one of the following:

Verify Credit Surveillance Credit Date per another WO# _________

Below: If crediting per another WO, verify credit date is Work Started date of referenced WO.

_________ Complete Sat - Credit Surveillance Complete w/ Portions Unsat - Credit Surveillance No Work Performed - Credit Surveillance Failed - Do Not Credit (Surv Due/Late Dates will NOT advance)

No Work Performed - Do Not Credit (Surv Due/Late Dates will NOT advance)

Comments Perform the applicable step(s) for the Unit 1 RCS Subcooling Margin Monitors and Containment Water level instruments, needs to be performed to close out work packages _

ADDITIONAL REVIEW OF RESULTS (IF REQUIRED)

Title Signature Date

WC-AA-111 Revision 4 Page 25 of 61

PROCEDURE 1BwOSR 3.3.3.1 UNIT NO. REVISION NO.

1 14 BRAIDWOOD STATION PROCEDURE TITLE:

UNIT ONE ACCIDENT MONITORING INSTRUMENTATION CHANNEL CHECKS Rev Summary IR# / EC# (if applicable) 14 Clarification concerning performance of WRGM steps PCRA 1208019-02 at 1PM10J or 2PM10J.

1BwOSR 3.3.3.1 Revision 14 Continuous Use UNIT ONE ACCIDENT MONITORING INSTRUMENTATION CHANNEL CHECKS A. STATEMENT OF APPLICABILITY This procedure outlines the steps necessary to verify the OPERABILITY of the Accident Monitoring Instrumentation by performing a CHANNEL CHECK of the required instruments and indications and verifying the required number of channels are OPERABLE. This procedure is applicable in MODES 1, 2 & 3.

B. REFERENCES

1. Technical Specifications:
a. LCO 3.3.3
b. SR 3.3.3.1
c. Table 3.3.3-1
2. TRMs:
a. TLCO 3.3.i
b. TLCO 3.3.j
c. TSR 3.3.i.1
d. TSR 3.3.j.2
e. Table T3.3.i-1
3. Station Procedures:
a. 1BwOL 3.3.3 LCOAR - Post Accident Monitoring (PAM) Instrumentation.
b. 1BwOL TRM 3.3.i, LCOAR - Post Accident Monitoring (PAM)

Instrumentation.

c. 1BwOL TRM 3.3.j, LCOAR - Hydrogen Monitor.
4. Tech Spec Definition: Section 1.1 "CHANNEL CHECK".
5. Operability Determination 99-003.

1

1BwOSR 3.3.3.1 Revision 14 Continuous Use C. PREREQUISITES

1. Receive permission to perform this surveillance from the Shift Manager or Designee prior to performance by having the Data Package Cover Sheet signed and dated.
2. This procedure may be performed in MODES 1, 2, 3, or 4.

D. PRECAUTIONS The Unit Operator should VERIFY that a qualified relief is monitoring the Unit panels prior to checking any Control Room back panels.

E. LIMITATIONS AND ACTIONS

1. As stated in Tech Spec LCO 3.3.3.
2. The parameters do not have to be surveilled in sequence.
3. Any inoperable parameter(s) that reduce the number of OPERABLE Channels to less than the total number specified requires a LCOAR be entered or already in effect to VERIFY the "Required Channels" OPERABLE requirements of Tech Spec Table 3.3.3-1, TRM Table T3.3.i-1 and TRM 3.3.j are satisfied. The "Required Channels" columns of the Data sheets provides guidance.
4. System instrumentation used in this procedure must be in current calibration.
5. In the event the Acceptance Criteria is not met during the performance of this surveillance, IMMEDIATELY notify the Shift Manager or designee to initiate LCOAR 1BwOL 3.3.3, 1BwOL TRM 3.3.i or 1BwOL TRM 3.3.j for the affected parameter(s) if in MODES 1, 2 or 3, as applicable.
6. Instrument readings that exceed the "MAXIMUM ALLOWABLE DEVIATION" guidelines shall be referred to an SRO for further evaluation. The SRO shall evaluate the readings against all other available indications and parameters that may assist in determining channel OPERABILITY and RECORD the evaluation of the results in the comments section of each data sheet.
7. A partial surveillance may be performed at the discretion of the Shift Manager or designee to demonstrate operability of individual instruments in the data tables provided all Prerequisites, Precautions, and Limitations and Actions are observed. The Shift Manager or designee shall determine the steps to be performed. The Data Package Cover Sheet must indicate that a partial surveillance was performed and the reason why listed in the Comments section.

2

1BwOSR 3.3.3.1 Revision 14 Continuous Use E. 8. A CHANNEL CHECK shall be the qualitative assessment, by observation of channel behavior during operation. This determination shall include where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channel measuring the same parameter.

9. If only one hydrogen monitor is available, then the channel check shall consist of the qualitative assessment of channel behavior during operation (i.e. indicating as expected for current plant operation and is typically less than 1%).

3

1BwOSR 3.3.3.1 Revision 14 Continuous Use F. MAIN BODY NOTE Steps F.1 through F.5 may be performed in any order.

NOTE Although TRM TLCO 3.3.j only requires ONE hydrogen monitor to be OPERABLE, a Channel Check should be performed on both monitors, if available.

1. PERFORM the CHANNEL CHECK of the Hydrogen Monitor(s) on the appropriate data sheet as follows:
a. VERIFY/OPEN the following valves to ALIGN the hydrogen monitor(s) being checked:

Hydrogen Monitor 1HSU-PS345:

1PS228A 1PS229A 1PS230A Hydrogen Monitor 1HSU-PS346:

1PS228B 1PS229B 1PS230B

b. PLACE the ON-OFF Selector switch(es) to the ON position at the Hydrogen Monitor Panels at 1PM12J for the hydrogen monitors being checked:

1HSU-PS345 1HSU-PS346

c. RECORD the status of the GREEN light on the Data Sheet.

4

1BwOSR 3.3.3.1 Revision 14 Continuous Use F. 1. d. PERFORM the following for the Hydrogen Monitor(s) being checked:

1) WAIT at least 4 minutes.
2) VERIFY the following lights are OFF:

H2 SYSTEM STATUS

3) RECORD the light status on the Data Sheet.
e. WAIT at least 30 minutes to allow an adequate purge of the sample lines, THEN PERFORM the following:
1) RECORD the containment hydrogen concentration on the Data Sheet from one of the following:

Meter (The meter is the preferred choice):

1AI-PS344 1AI-PS343 Computer point:

Y2001 Y2002

2) VERIFY the value(s) obtained in the previous step indicate as expected for current plant status.
3) VERIFY Reg Guide 1.97 designation (black dot) on the labels for each of the following:

1AI-PS344 1AI-PS343

f. INDICATE the acceptability of the CHANNEL CHECK of each Hydrogen Monitor(s) being surveilled by checking "Y" or "N" in the space provided.

¢ g. VERIFY at least one Hydrogen Monitor OPERABLE.

5

1BwOSR 3.3.3.1 Revision 14 Continuous Use F. 1. h. VERIFY/PLACE the ON-OFF Selector switches to the OFF position at the Hydrogen Monitor Panels.

1HSU-PS345 1HSU-PS346 NOTE 1PS228A/B and 1PS229A/B are normally maintained open.

i. CLOSE the following valves:

1PS230A, POST LOCA H2 MON A outside Disch Valve.

1PS230B, POST LOCA H2 MON B outside Disch Valve.

2. PERFORM the CHANNEL CHECKS of the Reactor Coolant Subcooling Margin Monitor on the Data Sheet as follows:

NOTE The CHANNEL CHECK of the Subcooling Margin Monitor consists of comparing of the two trains with a Maximum Allowed Deviation of 10°F. Each consists of an average of the 10 highest Incore Thermocouples and a W/R RCS Pressure channel.

a. RECORD the instrument readings for each train.
b. CALCULATE and RECORD the "Actual Maximum Deviation" between OPERABLE readings, and COMPARE to the stated "Allowed Maximum Deviation".
c. IF the "Actual Maximum Deviation" exceeds the stated "Allowed Maximum Deviation", CIRCLE the readings that are suspect and REFER the deviation to an SRO for evaluation of the channel OPERABILITY status.
d. INDICATE the acceptability of the CHANNEL CHECK of each instrument by checking "Y" or "N" in the space provided (channels that were circled as suspect are to be marked "Y" or "N" based on the SRO evaluation).

¢ e. VERIFY the number of OPERABLE channels is the "Required Channels Operable".

6

1BwOSR 3.3.3.1 Revision 14 Continuous Use F. 3. PERFORM the CHANNEL CHECKS of the Radiation Monitoring Instrumentation as follows:

NOTE The Aux Building Vent Stack WRGM low, medium and high range channels inputs are not in continuous use. Only one green "AVAIL" light will be ILLUMINATED for the channel range in use.

NOTE If it is desired, some or all of the CHANNEL CHECKS may be accomplished from the RM-23 as indicated on the data sheets. If the RM-23 is used, the checks need not be performed using the RM-11 if a parameter is NOT surveilled using the RM-23, it MUST be surveilled using the RM-11.

a. Perform the following for each Radiation Monitoring Instrument channel using the RM-23 at 1PM10J: (2PM10J for 2RIU-PR030):

Containment High Range Area Radiation Monitors a) RECORD the green AVAIL light status on the data sheet D-8.

b) VERIFY Reg Guide 1.97 designation (black dot) on the labels for each of the following:

1RIU-AR020 1RIU-AR021 Main Steam Line Radiation Monitors a) RECORD the green AVAIL light status on the data sheet D-8.

b) VERIFY Reg Guide 1.97 designation (black dot) on the labels for each of the following:

1RIU-AR022 1RIU-AR023 7

1BwOSR 3.3.3.1 Revision 14 Continuous Use F. 3. a. Aux Building Vent Stack WRGM a) RECORD the green AVAIL light for the three (Low, Med, or High) Channels on data sheet D-9.

b) RECORD the green AVAIL light for the effluent Channel on data sheet D-9.

c) VERIFY Reg Guide 1.97 designation (black dot) on the labels for each of the following:

1RIU-PR030 2RIU-PR030

b. OBTAIN the INSTRUMENT VALUE and CHANNEL CHECK from the RM-23 by performing the following:
1) DEPRESS the channel DISPLAY/CONTROL key pushbutton and VERIFY it ILLUMINATES.
2) VERIFY the following lights/pushbuttons are NOT ILLUMINATED:

a) ITEM.

b) MON.

c) ERROR.

d) SUPV MODE.

e) KYBD LOCK OUT.

3) RECORD the Rad level from the LED digital readout.
4) INDICATE the acceptability of the CHANNEL CHECK of each instrument by checking "Y" or "N" in the space provided (channels that were circled as suspect are to be marked "Y" or "N" based on the SRO evaluation).

¢ 5) VERIFY the number of OPERABLE channels is the "Required Channels Operable".

8

1BwOSR 3.3.3.1 Revision 14 Continuous Use F. 3. c. To perform the CHANNEL CHECKS of the Rad Monitoring Instrumentation using the RM-11 console, the following steps apply:

1) SELECT the grid indicated on the data sheet using the appropriate pushbutton.
2) ENTER the channel number from the data sheet.
3) DEPRESS the SEL pushbutton and VERIFY the channel is outlined.
4) DEPRESS the STATUS pushbutton.
5) VERIFY the Monitor status using the status cursor and RECORD the highest cursor color.
6) RECORD the Rad level.
7) INDICATE the acceptability of the CHANNEL CHECK of each instrument by checking "Y" or "N" in the space provided (channels that were circled as suspect are to be marked "Y" or "N" based on the SRO evaluation).

¢ 8) VERIFY the number of OPERABLE channels is the "Required Channels Operable".

9

1BwOSR 3.3.3.1 Revision 14 Continuous Use F. 4. PERFORM the CHANNEL CHECKS of the Incore Thermocouples on the appropriate Data Sheet from 1TI-IT001 and 1TI-IT002 as follows:

NOTE The Incore Thermocouple CHANNEL CHECKS are in two groups:

those with 1/8 core symmetry (Max Allowed Deviation of 20°F) and those without any symmetry (Max Allowed Deviation of 60°F).

a. RECORD the instrument reading for each Incore Thermocouple that is not known inoperable (RECORD "INOP" for any that are known inoperable).
b. CALCULATE and RECORD the "Actual Maximum Deviation" between OPERABLE readings and COMPARE to the stated "Allowed Maximum Deviation".
c. IF the "Actual Maximum Deviation" exceeds the stated "Allowed Maximum Deviation", CIRCLE the readings that are suspect and REFER the deviation to an SRO for evaluation of the channel OPERABILITY status.

¢ d. RECORD the total number of OPERABLE Incore Thermocouples per quadrant and VERIFY the total is 4.

e. VERIFY Reg Guide 1.97 designation (black dot) on the labels for each of the following:

1TI-IT001 1TI-IT002 10

1BwOSR 3.3.3.1 Revision 14 Continuous Use F. 5. PERFORM all remaining CHANNEL CHECKS of the instrumentation on the appropriate Data Sheets as follows:

a. RECORD the instrument readings for all instruments (RECORD "INOP" for any that are known inoperable).
b. CALCULATE and RECORD the "Actual Maximum Deviation" between OPERABLE readings, and COMPARE to the stated "Allowed Maximum Deviation".
c. IF the "Actual Maximum Deviation" exceeds the stated "Allowed Maximum Deviation", CIRCLE the readings that are suspect and REFER the deviation to an SRO for evaluation of the channel OPERABILITY status.
d. INDICATE the acceptability of the CHANNEL CHECK of each instrument by checking "Y" or "N" in the space provided (channels that were circled as suspect are to be marked "Y" or "N" based on the SRO evaluation).

¢ e. VERIFY the total number of OPERABLE channels is the "Required Channels Operable".

f. PERFORM the following for each of the instruments listed on the Data Sheets:
1) VERIFY Reg Guide 1.97 designation (black dot) on the labels.
2) CHECK Y or N as appropriate in the designated area.

11

1BwOSR 3.3.3.1 Revision 14 Continuous Use G. ACCEPTANCE CRITERIA

1. When performing this surveillance as a complete, routinely scheduled surveillance, the following criteria apply:
a. The required number of channels are OPERABLE for each instrument or indication listed on the data sheets.
b. A CHANNEL CHECK was SATISFACTORILY performed for each OPERABLE instrument or indication listed on the data sheets.
2. When performing this surveillance as a partial to meet the retest criteria to exit a LCOAR, this surveillance shall be considered SATISFACTORILY COMPLETED if the following criteria are met:
a. A CHANNEL CHECK was SATISFACTORILY performed for the parameter(s) being restored.
b. The Data Package Cover Sheet indicates that a partial surveillance was performed and the reason why listed in the Comments section.

(Final) 12

1BwOSR 3.3.3.1 Revision 14 Continuous Use UNIT ONE ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE DATA SHEET PARAMETER INSTRUMENT STATUS ACCEPTANCE CRITERIA VERIFY the green "ON" light is ILLUMINATED for each Instrument 1HSU-PS345 ON OFF GREEN LIGHT ON Channel being checked. 1HSU-PS346 ON OFF VERIFY the H2 and SYSTEM STATUS light is OFF after 4 minutes 1HSU-PS345 ON OFF H2 AND SYSTEM STATUS for each Instrument Channel being checked. 1HSU-PS346 ON OFF LIGHTS OFF NOTE The Hydrogen Monitor must be operating for 30 minutes prior to taking data. To perform the CHANNEL CHECK, CNMT ISOL Valves 1PS228A/B, 1PS229A/B & 1PS230A/B must be OPEN. (The meter is the preferred choice).

CHANNEL CHECK RG 1.97 PARAMETER INSTRUMENT VALUE ACCEPTANCE CRITERIA SAT? DOT 1AI-PS343 or

% Y N Y N HYDROGEN MONITORS AT LEAST 1 OPERABLE Y2001 TRM 3.3.j CHANNEL WITH CHAN CHK CNMT H2 1AI-PS344 SAT CONCENTRATION or

% Y N Y N Y2002 D-2

1BwOSR 3.3.3.1 Revision 14 Continuous Use UNIT ONE ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE DATA SHEET INSTR MAXIMUM DEVIATION CHANNEL RG 1.97 REQUIRED PARAMETER INSTRUMENT UNITS ACCEPTANCE CRITERIA VALUE ACTUAL ALLOWED CHK OK? DOT CHANNELS CONTAINMENT 1PI-PC004 Y N Y N 2 2 OPERABLE CHANNELS 4.8 PSIG PRESSURE 1PI-PC005 Y N Y N T.S. 3.3.3.7 WITH CHAN CHKS SAT NOTE For the S/G Aux Feed Flow instruments that are not in use, the reading may range from slightly above to slightly below zero but should not be pegged low on scale (contact IMD for assistance as necessary).

S/G 1A AUX PP 1A 1FI-AF011A N/A Y N Y N 2 2 OPERABLE CHANNELS FEED FLOW N/A N/A GPM WITH CHAN CHKS SAT PP 1B 1FI-AF012A N/A Y N Y N TRM 3.3.i.1 S/G 1B AUX PP 1A 1FI-AF013A N/A N/A Y N Y N 2 2 OPERABLE CHANNELS N/A GPM WITH CHAN CHKS SAT FEED FLOW PP 1B 1FI-AF014A N/A Y N Y N TRM 3.3.i.1 S/G 1C AUX PP 1A 1FI-AF015A N/A Y N Y N 2 2 OPERABLE CHANNELS N/A N/A GPM WITH CHAN CHKS SAT FEED FLOW PP 1B 1FI-AF016A N/A Y N Y N TRM 3.3.i.1 S/G 1D AUX PP 1A 1FI-AF017A N/A Y N Y N 2 2 OPERABLE CHANNELS N/A N/A GPM WITH CHAN CHKS SAT FEED FLOW PP 1B 1FI-AF018A N/A Y N Y N TRM 3.3.i.1 CONTAINMENT WATER 1LI-PC006 Y N Y N 2 2 OPERABLE CHANNELS 7.2 IN WITH CHAN CHKS SAT LEVEL 1LI-PC007 Y N Y N T.S. 3.3.3.10 CNMT FLOOR DRN SUMP 1LI-PC002 Y N Y N 2 2 OPERABLE CHANNELS WATER LEVEL 9.9 IN WITH CHAN CHKS SAT 1LI-PC003 Y N Y N TRM 3.3.i.5 NOTE Both the CETCs and the associated Wide range pressure channels must be operable to ensure that subcooling margin operability is met.

1TI-IT001 Y N Y N 2 2 OPERABLE CHANNELS CETCs 10 °F 1TI-IT002 Y N Y N TRM 3.3.i.7 WITH CHAN CHKS SAT RC LOOP W/R 1A 1PI-403A Y N Y N 2 2 OPERABLE CHANNELS 210 PSIG PRESSURE 1C 1PI-405 Y N Y N T.S. 3.3.3.1 WITH CHAN CHKS SAT D-3

1BwOSR 3.3.3.1 Revision 14 Continuous Use UNIT ONE ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE DATA SHEET PARAMETER INSTR MAXIMUM DEVIATION CHANNEL RG 1.97 REQUIRED INSTRUMENT UNITS ACCEPTANCE CRITERIA VALUE ACTUAL ALLOWED CHK OK? DOT CHANNELS 1LI-930 Y N Y N RWST LEVEL 1LI-931 Y N Y N 2 2 OPERABLE CHANNELS 7  %

1LI-932 Y N Y N T.S. 3.3.3.9 WITH CHAN CHKS SAT 1LI-933 Y N Y N 1A 1TI-413A Y N Y N REACTOR COOLANT HOT 1B 1TI-423A Y N Y N 2 2 OPERABLE CHANNELS 49 °F LEG WIDE RANGE 1C 1TI-433A Y N Y N T.S. 3.3.3.2 WITH CHAN CHKS SAT TEMPERATURE 1D 1TI-443A Y N Y N 1A 1TI-413B Y N Y N REACTOR COOLANT COLD 1B 1TI-423B Y N Y N 2 2 OPERABLE CHANNELS 49 °F LEG WIDE RANGE 1C 1TI-433B Y N Y N T.S. 3.3.3.3 WITH CHAN CHKS SAT TEMPERATURE 1D 1TI-443B Y N Y N NOTE A Reactor Vessel Water Level instrument channel is considered OPERABLE if one of the two (1/2) sensors in the HEAD region and three of the six (3/6) sensors in the PLENUM region are OPERABLE. The operability of a sensor may be determined by reviewing the ERROR messages on the control board indicator.

BwOP RC-12 provides the ERROR message code meanings.

REACTOR VESSEL 1LI-RC019 Y N Y N 2 2 OPERABLE CHANNELS N/A N/A  %

WATER LEVEL 1LI-RC020 Y N Y N T.S. 3.3.3.14 WITH CHAN CHKS SAT 1LI-459A Y N Y N PRESSURIZER 2 2 OPERABLE CHANNELS 1LI-460A 7  % Y N Y N WATER LEVEL T.S. 3.3.3.6 WITH CHAN CHKS SAT 1LI-461 Y N Y N Comments:

D-4

1BwOSR 3.3.3.1 Revision 14 Continuous Use UNIT ONE ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE DATA SHEET PARAMETER INSTR MAXIMUM DEVIATION CHANNEL RG 1.97 REQUIRED ACCEPTANCE INSTRUMENT UNITS VALUE ACTUAL ALLOWED CHECK OK? DOT CHANNELS CRITERIA NOTE

    1. PORV VPI IS NOT APPLICABLE for valve(s) with the associated block valve in the closed position. Record the indicated valve position in the "INSTR VALUE" column.

PZR PORV VALVE 1RY-455A Y N 1 PER VALVE 1 OPERABLE N/A N/A AVAIL N/A POSITION IND 1RY-456 Y N TRM 3.3.i.2 INDICATION PER VALVE NOTE

    • BLOCK VALVE VPI IS NOT APPLICABLE IF valve is verified closed AND power is removed (INDICATE status in comments section below). IF power is available to the valve, then VPI is required. Record the indicated valve position in the "INSTR VALUE" column.

PZR PORV ISOLATION 1RY-8000A Y N 1 PER VALVE 1 OPERABLE N/A N/A AVAIL N/A VALVE POS IND 1RY-8000B Y N TRM 3.3.i.3 INDICATION PER VALVE 1RY-8010A PZR SAFETY 1 PER VALVE 1 OPERABLE 1RY-8010B N/A N/A AVAIL N/A Y N VALVE POS IND TRM 3.3.i.4 INDICATION PER VALVE 1RY-8010C 1PI-514A Y N Y N S/G 1A 2 OPERABLE CHAN 1PI-515A 91 PSIG Y N Y N 2 T.S. 3.3.3.8 PRESSURE WITH CHAN CHKS SAT 1PI-516A Y N Y N 1PI-524A Y N Y N S/G 1B 2 OPERABLE CHAN 1PI-525A 91 PSIG Y N Y N 2 T.S. 3.3.3.8 PRESSURE WITH CHAN CHKS SAT 1PI-526A Y N Y N 1PI-534A Y N Y N S/G 1C 2 OPERABLE CHAN 1PI-535A 91 PSIG Y N Y N 2 T.S. 3.3.3.8 PRESSURE WITH CHAN CHKS SAT 1PI-536A Y N Y N 1PI-544A Y N Y N S/G 1D Y N 2 OPERABLE CHAN 1PI-545A 91 Y N 2 T.S. 3.3.3.8 PRESSURE PSIG WITH CHAN CHKS SAT 1PI-546A Y N Y N Comments:

D-5

1BwOSR 3.3.3.1 Revision 14 Continuous Use UNIT ONE ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE DATA SHEET PARAMETER INSTR MAXIMUM DEVIATION CHANNEL RG 1.97 REQUIRED ACCEPTANCE INSTRUMENT UNITS VALUE ACTUAL ALLOWED CHECK OK? DOT CHANNELS CRITERIA S/G 1A 1LI-517 YN YN NARROW RNG 1 1 OPERABLE CHAN 1LI-518 7  % YN YN WATER T.S. 3.3.3.5 WITH CHAN CHKS SAT LEVEL 1LI-519 YN YN S/G 1B 1LI-527 YN YN NARROW RNG 1 1 OPERABLE CHAN 1LI-528 7  % YN YN WATER T.S. 3.3.3.5 WITH CHAN CHKS SAT LEVEL 1LI-529 YN YN S/G 1C 1LI-537 YN YN NARROW RNG 1 1 OPERABLE CHAN 1LI-538 7  % YN YN WATER T.S. 3.3.3.5 WITH CHAN CHKS SAT LEVEL 1LI-539 YN YN S/G 1D 1LI-547 YN YN NARROW RNG 1 1 OPERABLE CHAN 1LI-548 7  % YN YN WATER T.S. 3.3.3.5 WITH CHAN CHKS SAT LEVEL 1LI-549 YN YN S/G 1A 1LI-501A N/A N/A YN YN W/R 1B 1LI-502A N/A N/A YN YN 1 PER S/G 4 OPERABLE CHAN WATER 1C 1LI-503A N/A N/A YN YN T.S. 3.3.3.4 WITH CHAN CHKS SAT LEVEL 1D 1LI-504A N/A N/A YN YN Comments:

D-6

1BwOSR 3.3.3.1 Revision 14 Continuous Use UNIT ONE ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE DATA SHEET PARAMETER INSTR MAXIMUM DEVIATION CHANNEL RG 1.97 REQUIRED INSTRUMENT UNITS ACCEPTANCE CRITERIA VALUE ACTUAL ALLOWED CHK OK? DOT CHANNELS NOTE The Post Accident Neutron Monitor Wide Range channel checks are performed by comparing the meter indication to the calorimetric power if in Mode 1 or between the channels if in Modes 2,3, or 4. The Narrow Range Channel Checks are performed by comparing the meter indications between the channels.

POST ACCIDENT 1NI-NR005A 1/2 Y N Y N N/A*

NEUTRON MONITOR Decade N/A WIDE RANGE 1NI-NR006A  % Y N Y N N/A*

10 MINUTE Plant (See Note N/A N/A N/A CALORIMETRIC POWER Computer below) 1/2 1NI-NR006B Y N Y N N/A*

POST ACCIDENT Decade NEUTRON MONITOR Cps N/A Narrow Range 1NI-NR005B (See Note Y N Y N N/A*

below)

Comments:

  • If a Post Accident Neutron Monitor is inoperable, ENTER 1BwOS NR2-1a.

NOTE: The following is the agreed upon method of determining the half decade acceptance criteria.

log(meter 1) - log(meter 2) = x As long as x is 0.5, then we meet the 1/2 decade acceptance criteria.

Example 1: 1NI-NR006B reads 2x104 CPS and 1NI-NR005B reads 8x103 CPS To determine if they meet the 1/2 decade acceptance criteria:

Log (2x104) - Log (8x103) = 0.398 (Acceptable)

Example 2: 1NI-NR005A reads 77%, 1NI-NR006A reads 67% and the calorimetric reads 23%

Log 77 - Log 23 = 0.524 Unacceptable Log 67 - Log 23 = 0.464 Acceptable D-7

1BwOSR 3.3.3.1 Revision 14 Continuous Use UNIT ONE ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE DATA SHEET The Rad Monitoring CHANNEL CHECKS on this page are performed using the RM-23 (IF desired).

PARAMETER AVAIL INSTR CH CHK CHANNEL RG 1.97 REQUIRED INSTRUMENT UNITS ACCEPTANCE CRITERIA LIGHT VALUE ACCEPT

  • Limitation and Action E.8 met.

Comments:

D-8

1BwOSR 3.3.3.1 Revision 14 Continuous Use UNIT ONE ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE DATA SHEET The Rad Monitoring CHANNEL CHECKS on this page are performed using the RM-23 (IF desired):

AVAIL INSTR CH CHK CHANNEL REQUIRED ACCEPTANCE PARAMETER INSTRUMENT UNITS RG 1.97 DOT LIGHT VALUE ACCEPT

  • Limitation and Action E.8 met.

Comments:

D-9

1BwOSR 3.3.3.1 Revision 14 Continuous Use UNIT ONE ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE DATA SHEET The Rad Monitoring CHANNEL CHECKS on this page are performed using the RM-11 (IF the RM-23 is not used). Cursor color may be indicated as follows:

G=Green, W=White, Y=Yellow, M=Magenta, DB=Dark Blue, LB=Light Blue, R=Red, C=Cyan.

CURSOR INSTR CH CHK CHANNEL REQUIRED PARAMETER INSTRUMENT UNITS ACCEPTANCE CRITERIA COLOR VALUE ACCEPT

  • Limitation and Action E.8 met.

Comments:

D-10

1BwOSR 3.3.3.1 Revision 14 Continuous Use UNIT ONE ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE DATA SHEET The Rad Monitoring CHANNEL CHECKS on this page are performed using the RM-11 (IF the RM-23 is not used). Cursor color may be indicated as follows:

G=Green, W=White, Y=Yellow, M=Magenta, DB=Dark Blue, LB=Light Blue, R=Red, C=Cyan.

CURSOR INSTR CH CHK CHANNEL REQUIRED PARAMETER INSTRUMENT UNITS ACCEPTANCE CRITERIA COLOR VALUE ACCEPT

µc/ml Y N WRGM MED (G2 1PB230) Magenta TRM 3.3.i.6 CHAN CHKS SAT GAS @ 1RE-PR030 For Effluent HIGH (G2 1PC330) Channel and at least one of 1RE-PR030 the Gas EFFL µc/sec Y N N/A N/A (G2 1PF430)

Channels GAS 2RE-PR030 Cursor is LOW (G2 2PA130) NOT White GAS @ 2RE-PR030 Dark Blue or 1 2RE-PR030 IS OPERABLE UNIT TWO µc/ml Y N MED (G2 2PB230) Magenta TRM 3.3.i.6 CHAN CHKS SAT AUX BLDG GAS @ 2RE-PR030 For Effluent VENT STACK HIGH (G2 2PC330) Channel and WRGM at least one of 2RE-PR030 EFFL the Gas µc/sec Y N N/A N/A (G2 2PF430)

Channels

  • Limitation and Action E.8 met.

Comments:

@ Gas Medium and Gas High Channels are normally NOT on line and are dark blue.

D-11

1BwOSR 3.3.3.1 Revision 14 Continuous Use UNIT ONE ACCIDENT MONITORING INSTRUMENTATION SURVEILLANCE DATA SHEET The following Incore Thermocouple groups are symmetrically associated (one group per line). Maximum Deviation between thermocouples in each group is 20°F. If the channel is inoperable, record "INOP". (Required channels: 4 per quadrant. T.S. 3.3.3.13)

IN NO QUADRANT QUADRANT 1 QUADRANT 2 QUADRANT 3 QUADRANT 4 DEVIATION 1 39 49 °F 2 30 °F 4 14 63 °F 5 ** 55 ** 6 56 26 42 °F 7 43 65 ** °F 8 32 °F 9 25 °F 10 62 °F 34 12 11 64 °F 27 13 °F 38 15 °F 52 35 31 16 °F 18 33 44 ** °F 36 19 46 °F 53 57 20 °F 21 51 ** 54 28 48 47 61 °F 22 ** 41 °F 23 58 °F 37 59 24 45 °F The following Incore Thermocouples are NOT symmetrically associated. Maximum Deviation between all 6 is 60 °F 40 3 50 17 29 **

60 °F RECORD total OPERABLE Incore

¢ _____ (4) ¢ _____ (4) ¢____ (4) ¢____ (4)

Thermocouples for each quadrant VERIFY 4 per quadrant (init)

Comments: ** Incore Thermocouple disconnected. Value not required.

(Final)

D-12

JOB PERFORMANCE MEASURE TASK CONDITIONS:

1. You are an NSO.
2. Another NSO was preparing a first hang for the 0OG01P Hogging Vacuum Pump when he was called to the MCR for surveillance support. The NSO has not completed the first approval, but has identified the isolation points.

INITIATING CUES:

1. The clearance order Supervisor has tasked you with reviewing the proposed isolation points for Tagout #P13-100 so you are prepared to be the second approver.
2. The work order task is for packing replacement for the 0OG01P Hogging Vacuum Pump.
3. The clearance request specifies that the 0OG01P be isolated electrically and mechanically. The clearance request also requires the U-0 Hogging Vacuum Pump Air separator tank (0OG03T) to be drained.

R-203 Page 1 of 6

TASK TITLE: Verify Worker Tagout Checklist.

JPM No.: R-203 REV: 2013 NRC Task No.: 4E.AM-06 K&A No.: 2.2.13 Objective No.: R-AM-010 K&A IMP: 4.1/4.3 EXAMINEE: RO : ___

EVALUATOR: DATE:

The Examinee: PASSED this JPM. TIME STARTED:

FAILED TIME FINISHED:

JPM TIME: MINUTES CRITICAL ELEMENTS: (*) 5, 6, 7 APPROX COMPLETION TIME: 30 MINUTES CRITICAL TIME: N/A EVALUATION METHOD: LOCATION:

X PERFORM X IN PLANT SIMULATE X SIMULATOR GENERAL

REFERENCES:

1. OP-AA-109-101, CLEARANCE AND TAGGING, REV 9.
2. M-47, sheet 1A, DIAGRAM OF OFF-GAS SYSTEM UNIT 1.
3. M-150, sheet 1, DIAGRAM OF OFF-GAS SYSTEM UNIT 2.
4. 20E-0-4030-OG01, SCHEMATIC DIAGRAM HOGGING VACUUM PUMP 0 - 0OG01P.
5. 20E-0-4030-OG05, SCHEMATIC DIAGRAM VACUUM PUMP 0 INLET VALVE - 0OG009.
6. BwOP OG-2.

MATERIALS:

1. OP-AA-109-101, CLEARANCE AND TAGGING, REV 9.
2. OP-BR-109-101-1001, BRAIDWOOD SYSTEM SPECIFIC TAGGING GUIDES, REV 8.
3. M-47, sheet 1A, DIAGRAM OF OFF-GAS SYSTEM UNIT 1.
4. 20E-0-4030-OG01, SCHEMATIC DIAGRAM HOGGING VACUUM PUMP 0 - 0OG01P.
5. 20E-0-4030-OG05, SCHEMATIC DIAGRAM VACUUM PUMP 0 INLET VALVE - 0OG009.
6. BwOP OG-2, HOGGING VACUUM PUMP SHUTDOWN, REV.11.

TASK STANDARDS:

1. Determine 0OG047 valve has incorrect unit designator.
2. Determine 0OG01P suction line not properly isolated.
3. Determine the sequence of isolation points for 0OG01P C/S and breaker is incorrect.

TASK CONDITIONS:

1. You are an NSO.
2. Another NSO was preparing a first hang for the 0OG01P Hogging Vacuum Pump when he was called to the MCR for surveillance support. The NSO has not completed the first approval, but has identified the isolation points.

INITIATING CUES:

1. The clearance order Supervisor has tasked you with reviewing the proposed isolation points for Tagout #P13-100 so you are prepared to be the second approver. CUE: Hand examinee partially completed Worker Tagout.
2. The work order task is for packing replacement for the 0OG01P Hogging Vacuum Pump.

R-203 Page 2 of 6

3. The clearance request specifies that the 0OG01P be isolated electrically and mechanically. The clearance request also requires the U-0 Hogging Vacuum Pump Air separator tank (0OG03T) to be drained.

R-203 Page 3 of 6

RECORD START TIME:

NOTE TO EVALUATOR: DO NOT PROVIDE DRAWING M-150 UNTIL THE EXAMINEE REQUESTS IT LATER IN THE JPM. THE OTHER DRAWINGS AS HIGHLIGHTED ARE PART OF THE PACKAGE AND MAY BE PROVIDED ALL TOGETHER TO THE EXAMINEE.

PERFORMANCE STEP STANDARD CIRCLE APPLICABLE

1. Refer to OP-AA-109-101, Refer to OP-AA-109-101. SAT UNSAT N/A CLEARANCE AND TAGGING. Comments:

CUE: Provide copy of OP-AA-109-101. If requested during the JPM, provide copy of BwOP OG-2.

2. Refer to Drawing: Refer to M-47, sheet 1A. SAT UNSAT N/A
  • M-47, sheet 1A, DIAGRAM OF Comments:

OFF-GAS SYSTEM UNIT 1 CUE: Provide copy of M-47, sheet 1A.

3. Refer to Drawing: Refer to 20E-0-4030-OG01. SAT UNSAT N/A

SCHEMATIC DIAGRAM HOGGING VACUUM PUMP 0

- 0OG01P CUE: Provide copy of 20E 4030-OG01.

4. Refer to Drawing: Refer to 20E-0-4030-OG05. SAT UNSAT N/A

SCHEMATIC DIAGRAM HOGGING VACUUM PUMP 0 INLET VALVE - 0OG009 CUE: Provide copy of 20E 4030-OG05.

Evaluators Note: The performer should review the WTO checklist for proper isolation points, sequencing, tag types and OOS positions.

The critical steps of identifying each error in the WTO can be performed in any order. All (3) three errors must be identified to the evaluator for successful JPM performance.

Any additional comments made by the performer should be acknowledged by the evaluator in the same manner as the identification of the WTO errors.

  • 5. Determine the clearance Determines clearance SAT UNSAT N/A sequence for the U0 Hogging sequence is incorrect: Comments:

Vacuum Pump breaker and C/S are swapped.

0OG01P U0 Hogging Pump C/S should be sequenced prior CUE: Acknowledge as to the Brkr.

clearance order Supervisor and inform examinee that C/O will be o Notifies US of sequencing corrected per their mark error.

up.

R-203 Page 4 of 6

PERFORMANCE STEP STANDARD CIRCLE APPLICABLE

  • 6. Determine the U0 Hogging Determines clearance isolation SAT UNSAT N/A Vacuum Pump suction isolation is incorrect: Comments:

is not adequate.

Suction isolation point of CUE: Acknowledge as 0OG009 is inadequate and clearance order further action is needed for Supervisor and ask proper isolation as follows:

candidate to identify appropriate isolation o Gag closed the 0OG009 method. valve OR CUE: If asked, provide drawing o Identify and use upstream M-150 sheet 1. isolation points (1OG043 and 2OG043, both air op valves that fail closed are acceptable upstream isolation points) o Notifies US of isolation error.

  • 7. Determine a wrong unit Determines a wrong unit SAT UNSAT N/A designator is used. designator is used. Comments:

Valve 0OG011 is misidentified CUE: Acknowledge as as 1OG011 clearance order o Notifies US of component Supervisor and inform EPN error.

examinee that C/O will be corrected per their mark up.

NOTE: Once the candidate has correctly identified the three critical task errors, the examiner may declare the JPM completed.

8. Determine the WTO Tag types are Determines the WTO Tag SAT UNSAT N/A correct. types are correct. Comments:
9. Determine the WTO Hang Determines the WTO Hang SAT UNSAT N/A Positions are correct. Positions are correct. Comments:

CUE: THIS COMPLETES THIS JPM.

RECORD STOP TIME:

COMMENTS:

R-203 Page 5 of 6

SIMULATOR SETUP INSTRUCTIONS

  • N/A COMMENTS
  • Provide copy of M-47, sheet 1A, DIAGRAM OF OFF-GAS SYSTEM UNIT 1.
  • Provide copy of 20E-0-4030-OG01, SCHEMATIC DIAGRAM HOGGING VACUUM PUMP 0 - 0OG01P.
  • Provide copy of 20E-0-4030-OG05, SCHEMATIC DIAGRAM VACUUM PUMP 0 INLET VALVE -

0OG009.

R-203 Page 6 of 6

OP-AA-109-101 Revision 9 Page 78 of 86 ATTACHMENT 14 PART 1 WTO Form Hang/Lift Section Page 1 of 1 Exceptional C/O: Mode Dependent: Condition Dependent:

Production Risk: Environmental Risk: Atmospheric Risk: Reactivity Risk:

WORKER TAGOUT# P13-100 JOB DESCRIPTION: U-0 HOGGING VACUUM PUMP PACKING REPLACEMENT WORKING DEPARTMENT: MMD W/O OR W/R: 12345 EQUIP. TAG# 0OG01P COMPONENT DESCRIPTION: U-0 HOGGING VACUUM PUMP FIRST APPROVAL: __ _________________________ DATE/TIME: __________________

SECOND APPROVAL: _____________ ___________________ DATE/TIME: __________________

WTO AUTHORIZATION: ____________ __________________ DATE/TIME: __________________

SPECIAL INSTRUCTIONS: YES: NO: (IF YES SEE ATTACHMENT 14 PART 2)

EQUIP. TAG/EQUIPMENT SEQ TAG POSITION HUNG VERIF. SFTY. RTS RTS RTS VERIF.

NAME TYPE BY BY VERIF. SEQ POSITION BY BY Bus 134Y Cub 5B (1AP17EQ) 1 RD R/O 0OG01P U0 Hogging Pump Brk 0OG01P U0 Hogging Pump C/S 2 CI PTL 0HS-OG011 (0PM01J) 0OG009 L/C/S Hog Vac pp Inlet 2 CD CLOSED Vlv 0HS-OG030 (0OG01J) 0OG009 FU-5X Fuse Hog Vac Pp 3 RD RMVD Inlet Vlv C/P (0OG01J) 0OG044A U0 Hog Vac Pp Suct 4 RD CLOSED Isol From U1 Wtr Box Priming Hdr 0OG044B U0 Hog Vac Pp Suct 4 RD CLOSED Isol From U2 Wtr Box Priming Hdr 0OG023 Hog Vac Pp Demin Wtr 4 RD CLOSED Supply 0OG047 Air Sep Tk 0 Outlet To U- 4 RD CLOSED 2 Vent Stack 1OG011 Air Sep Tk 0 Outlet To U- 4 RD CLOSED 1 Vent Stack 0OG046 Air Sep Tk 0 Drn 5 RI INFO 0OG045 Hog Vac Pp 0 Seal Drn 5 RI INFO Vlv WTO PLACED: ___________________________________________________________ DATE/TIME: _______________

WTL COMPLETED WORK START: ___________________________________________ DATE/TIME: _______________

WTO FINAL CLEAR: WORK CREWMEMBER RELEASE: _________________________ DATE/TIME: _______________

WTO CLEARED: ____________________________________________________________ DATE/TIME: ____________________

(COPIES MAY BE MADE OF THIS FORM FOR ADDITIONAL ISOLATION POINTS)

OP-AA-109-101 Revision 9 Page 69 of 86 ATTACHMENT 14 PART 2 WTO Form Special Instructions Section Page 1 of 1 WTO # P13-100 EXEPTIONAL CO Motor htr. not OOS.

WS not isolated to hogging cooler. Reference BwOP OG-1 & BwOP OG-2 as necessary Info card instruction: 0OG045 and 0OG046 open for drain.

                                                                                                        • RTS NOTES ******************************************************************************

Review BwOP OG-2 For S/D Line up

NOTE TO EXAMINER:

ONLY PROVIDE THE ENCLOSED DRAWING (M-150 SHEET 1) IF THE EXAMINEE SPECIFICALLY REQUESTS THAT DRAWING.

DO NOT PROVIDE THIS DRAWING AS PART OF THE INITIAL CLEARANCE ORDER PACKAGE AT START OF THE JPM.

OP-AA-109-101 Revision 9 Page 1 of 86 Level 3 - Information Use CLEARANCE AND TAGGING

1. PURPOSE 1.1. Description 1.1.1. To establish a process to protect personnel while performing work activities on mechanical and electrical systems or components.

1.1.2. The Clearance and Tagging (C&T) Process may be used to perform the following when other tools are not used.

Protect equipment while maintenance is being performed.

Prevent inadvertent operation when equipment is in a degraded condition.

Establish administrative controls when deemed necessary by Operations.

1.1.3. The following sections are contained in this procedure:

1. Purpose ........................................................................................................... 1
2. Administrative Requirements........................................................................... 3
3. Terms and Definitions...................................................................................... 4
4. Responsibilities................................................................................................ 7
5. Clearance Tag Standards................................................................................ 8
6. Clearance Request Standards....................................................................... 12
7. Clearance Development Standards............................................................... 14
8. Clearance Development ................................................................................ 29
9. Clearance Work Addition/Work Scope Modification ...................................... 32
10. Authorizing and Performing Clearance Manipulations................................... 34
11. Performing Work Under Clearance Protection .............................................. 40
12. Temp Lifts and Partial Clears ........................................................................ 49
13. Worker Tagout (WTO) Process ..................................................................... 50
14. Equipment Tagout Program Problem Response ........................................... 55
15. Documentation .............................................................................................. 59
16. References .................................................................................................... 60
17. Attachments .................................................................................................. 61

OP-AA-109-101 Revision 9 Page 2 of 86 1.2. Scope 1.2.1. The requirements of this procedure apply to all site personnel working within the Exelon Nuclear C&T process. The process applies to personnel who physically enter or break the plane of the area where energy normally exists in the system, or placement of part or all of their body in the zone of protection of a C/O.

1.2.2. Checklists included in this procedure are intended to be used by ALL disciplines working within the C&T process as directed in this procedure.

1.2.3. When switchyard and other transmission distribution related equipment is under the operational control of an outside organization (e.g. power distribution company),

then the outside organizations tagout procedure may be used in lieu of the requirements of this procedure

1. If transmission and/or distribution equipment under the operational control of ComEd and/or PECO is to be worked using this procedure (OP-AA-109-101),

then refer to step 4.6.7 of OP-AA-108-107-1002, INTERFACE PROCEDURE BETWEEN COMED / PECO AND EXELON GENERATION (NUCLEAR /

POWER) FOR TRANSMISSION OPERATIONS, for additional guidance.

1.2.4. Use of other C&T procedures is allowed at individual sites to support specific needs (i.e., Vendor Tagging Programs, Outside Protected Area Tagging). These C&T procedures shall be reviewed and approved by the Corporate C&T Process Owner, Site Clearance Coordinator and Site Industrial Safety Representative prior to use.

These procedures shall be certified in writing by the submitting organization to meet all applicable OSHA Standards.

1.2.5. The requirements of this procedure shall be met to protect against potential hazards to personnel safety from plant systems during physical work on a system. Hazards to be considered include, but are not limited to:

1. Electricity
2. Fluids, Gases, and Vapors
3. Chemicals (refer to MSDS for hazard information)
4. Physical hazards
5. Radioactivity
6. Stored energy 1.2.6. To determine if a Clearance Order (C/O) is required, refer to Attachment 1, Activities That Do Not Require a C/O.

1.2.7. This process shall not be used as the sole controlling process for troubleshooting or design changes to the plant, but may be used to provide isolation for such activities

OP-AA-109-101 Revision 9 Page 3 of 86 under the control of an approved process that meets the applicable requirements (e.g. design change requirements including 50.59 screenings).

1.2.8. Any C/O prepared prior to the implementation of this procedure revision, or a previous revision of this procedure, may be processed without additional restrictions.

Any C/O in place at the time of implementing this procedure need not be retrofitted to meet the requirements listed here, including Tags Plus.

2. ADMINISTRATIVE REQUIREMENTS 2.1. Any changes to this procedure or support T&RMs shall be approved by the Corporate C&T process owner prior to implementation.

2.2. Process Assessment 2.2.1. Annual inspections (performed during the month of May) required by OSHA to ensure employee compliance with personnel safety related work practices will be implemented at each site and tracked in the action tracking database.

1. OSHA REQUIRES regular inspections to occur on an ANNUAL basis as a minimum, to ensure each employee is complying with safety-related work practices. Personnel observations as a representative sampling of employees to assess and monitor generic performance, and group meetings to review the responsibilities of employees with respect to Clearance & Tagging will be used to satisfy these inspections. Document the group meetings on an annual frequency in the action tracking item or equivalent for retrievability purposes.

Personnel observation details on clearance order activity shall be recorded in the Fundamental Management System (FMS) or equivalent.

2.2.2. At least once per calendar year, a qualified assessment group will perform an Assessment of the C&T process, procedure, and practices at each site for areas in potential need of improvement.

2.2.3. Audits of C/Os with placed Tags will be performed by qualified personnel to ensure their integrity using OP-AA-109-101-1002 Clearance and Tagging Quarterly Audit.

1. On a quarterly interval, the documentation of all C/Os with placed Tags shall be verified.
2. On a quarterly interval, a sampling of 25% or at least five currently placed C/O Tags shall be field verified.
3. On a quarterly interval, C/Os that have Tags in place for greater than two months will be assessed for closeout, verified scheduled for repair, evaluated for 50.59 applicability, or identified for abandonment.

2.2.4. On an annual basis, an independent review will be conducted of this procedure to verify compliance with OSHA regulations. This review will be performed by the Corporate C&T Process Owner, which satisfies the OSHA requirement to have a person not directly involved with the C&T process perform this review.

OP-AA-109-101 Revision 9 Page 4 of 86

3. TERMS AND DEFINITIONS

3.1. Accept

The act of placing an electronic hold on a C/O preventing manipulations without notification and release. This term is synonymous with sign-on when discussing electronic sign-on.

3.2. Active

C/O status indicating ALL Tags hung and C/O ready for Acceptance.

3.3. AWT/CLOS: C/O status indicating all steps hung by the current C/O have been lifted and checklists completed. C/O in AWT/CLOS may be set to CLOSED or a New First Hang Checklist may be processed to re-hang the C/O if needed.

3.4. Backgrounding a Clearance: The process of electronically copying a previously prepared C/O.

3.5. Boundary Breach: The opening of the process, cooling or lubrication boundary such that the system is exposed. Instrumentation and lubrication lines that can be isolated by valves or other mechanical devices are not considered breaching of boundaries.

3.6. Boundary Report: A list of isolation points to be walked down by qualified personnel to verify the zone of protection is established.

3.7. C/O Challenge: An oversight review of a C/O which has been prepared and approved by the C/O writers. The challenge is intended to be an overview of the C/O product to ensure the required process steps have been completed, the C/O meets the intent of the C/R, and a high level review of the C/O technical aspects.

The C/O Challenge is not to be an Approval of the C/O.

3.8. Clearance Status: Indication of which stage a C/O is in as it progresses through the C/O life cycle.

3.9. Comment (CMT): Procedure steps listed in C/O Checklist that does not involve boundary equipment.

3.10. Condition Dependent Clearance (CD): A C/O that takes credit for administrative control of a given plant condition to control the hazards for the planned work.

3.11. Danger Tag: A tag used to identify and control clearance points that isolate equipment from energy sources.

3.12. Distributed: C/O and Checklist status indicating that a Checklist has advanced in status past Approved. Checklist is ready to be executed.

3.13. Dual Function (DF): A process used to hang and lift isolation points in a zone of protection on the same Checklist.

3.14. Electronic Sign-On (ESO): An electronic process to provide documentation of individual employee accountability. The sign-on provides for a record of all employees assigned to a particular job relying on C/O protection. This is the electronic equivalent of a Worker Tracking List.

OP-AA-109-101 Revision 9 Page 5 of 86 3.15. Emergent C/O: A C/O that has been requested for preparation within a timeframe after work week daily schedule freeze and request is 3 days prior to execution of the work (does not apply to outage C/Os and FIN Team C/Os).

3.16. Exceptional Clearance: A C/O that does not provide complete conventional isolation (i.e., valves closed, breakers off, etc.). An Exceptional C/O will be designated as such in the C/O Special Instructions along with explanation of the condition. Refer to Attachment 2, Examples of Exceptional Clearances for examples.

3.17. External Energy Injection (EEI): Applying energy into a zone of protection from an external energy source, such as hydro-testing, temporary air supply, or Meggering.

3.18. Facilities Maintenance: (FM) Work that takes place on non-plant/non-power block equipment that may be facilitated by use of the Worker Tagout process.

3.19. Facilities Maintenance Technician: An Exelon employee that performs work on non-plant/non-power block equipment. This person may write, approve, apply, and remove FM Worker Tagouts, with proper qualification and authorization. This generic term represents all MW Sites Facilities Maintenance personnel (L15 or L51).

3.20. General Worker: Exelon or non-Exelon employees who are not ESO qualified but have received NGET that includes C&T General Awareness Training. These employees use a WTL instead of Passport to sign on to a C/O.

3.21. Grounding Device: Device that is designed to provide a metallic connection from ground to the terminals of the equipment that is being worked, and has adequate capacity to carry fault current at the grounding point. The purpose of a grounding device is to protect the worker should the equipment become inadvertently energized. These devices will be controlled under the C/O process.

3.22. Ground Test Device: A device designed for installation in a breaker compartment that allows for testing to be performed and provides a connection between the de-energized equipment and the station grounding system.

3.23. Holder: Any individual who is qualified to accept and release a C/O. This person may be a cognizant team member or supervisor.

3.24. Holder Acceptance Lock: Option used to prevent Holders from accepting a C/O due to current conditions with that C/O.

3.25. Information Tags: Tags used in conjunction with a Clearance to provide indication that the associated equipment is tagged out or other pertinent information.

3.26. Lead Worker: Trained and qualified work group personnel who have the ability to sign on and off C/Os electronically. These may be craft employees or administrators depending on employer. This term defines a role and qualification status used in the clearance and tagging process and is not intended to define any role in relation to the bargaining unit contract at any location.

OP-AA-109-101 Revision 9 Page 6 of 86 3.27. Model Clearances: A C/O developed in advance for repeated C/O use that can be backgrounded into a new C/O to perform work. The goal of Model C/O is to minimize C/O preparation by providing consistent and proven equipment isolation plans to reuse.

3.28. Mode Dependent Clearance (MD): A C/O that takes credit for administrative control of the plant mode and associated hazards.

3.29. Mousing / Test Leads: Leads or wires configured for the purpose of providing an electrical drain path, as the result of static or induced voltage build up or for conducting various electrical tests. Normally utilized during maintenance and testing activities when the equipment has been electrically disconnected or removed from the C/O Boundary. These leads would be controlled by the maintenance or testing activity WO alteration log.

3.30. Partial Clear (PC): A process used to return only a portion of the zone of protection to service.

3.31. Personnel Escort: Any individual badged for unescorted access that is responsible for the continuous observation, safety and procedural compliance of visitors under their escort. For Clearance and Tagging activities, the Personnel Escort must be Lead Worker or Holder qualified if the escorted visitor is entering the clearance order zone of protection.

3.32. Principle Equipment: The equipment within the C/O boundary that maintenance will be performed on, normally listed on a Work Order Task attached to the C/O.

3.33. Release: The act of removing an electronic hold on a C/O allowing manipulations without notification.

3.34. Released: C/O status indicating ALL holders have signed off the C/O.

3.35. Safety Verification: The process of ensuring that it is safe to perform work within a zone of protection. This includes a walk down of the required isolation points by the Working Group using the C/O Boundary Report.

3.36. Suspend: C/O status indicating C/O coverage is suspended, no active work requiring protection of the C/O can proceed (C/O Tags may still be hanging).

3.37. Tags Plus: A philosophy of providing additional measures such that no single inadvertent action could by itself un-isolate the Danger Tagged component acting as a C/O isolation point.

3.38. Tags Plus Methodologies: Any device or technique used by Operations to prevent unwanted component repositioning. These can include valve lockouts, releasable cable ties that prevent valve movement or breaker operation, non-conductive fuse clip inserts, dual valve isolation, robust area barriers, breaker removal, or ball valves with modified handles. (This list is not intended to be all inclusive) 3.39. Temp Lift (TL): A process used to temporarily restore equipment to service for testing or any other purpose deemed necessary by Shift Management.

OP-AA-109-101 Revision 9 Page 7 of 86 3.40. Temporary: This term in relation to employee electronic or WTL sign on means lasting for a limited time. This can be associated with assigned to another job or leaving at the end of the day.

3.41. Visitor: An individual or individuals that are under the control of a Personal Escort.

3.42. Worker Tracking List: A manually produced hardcopy listing of employees assigned to a particular job associated with a C/O(s). The list is used to track individual employees relying on the protection of the associated C/O(s) and prevent Lifting of the C/O(s) until sign-off by ALL associated employees. It satisfies OSHAs requirement for individual accountability.

3.43. Worker Safety Lock/Worker Safety Tag Program: A program which allows personnel working under a C/O to apply Worker Safety Lock(s) or Worker Safety Tag(s) on C/O tagged components(s) closest to their work.

3.44. Worker Tagout: A process that provides personnel protection that is used in place of the electronic tagging process. This is also the backup to the electronic process in the event the computer goes down.

3.45. Working: C/O status indicating at least 1 Holder has accepted a C/O.

3.46. WTO Tracking List Tag: A Tag used by employees as a physical indication to others that they are relying on the tagged component as their main isolation point. It is only used for WTOs because ESO cannot be used.

3.47. Zone of Protection (ZOP): The boundary in which an employee is safe to perform work established by isolating, de-energizing and tagging potential sources of stored energy that could create a hazard for the employee.

4. RESPONSIBILITIES 4.1. The responsibilities and actions required by each position using the C&T process are listed in the body of this procedure.

4.2. All Personnel are responsible to ensure their own safety while working with C/Os by following the requirements of this procedure.

OP-AA-109-101 Revision 9 Page 8 of 86

5. CLEARANCE TAG STANDARDS 5.1. General Standards 5.1.1. No device or equipment shall be operated while C/O or WTO Tags are attached with the following exceptions:
1. Qualified Operations personnel (or qualified FM Technician for WTO being used by FM) performing position verification while placing C/Os or WTOs.
2. Qualified Operations personnel to improve isolation. Prior to this manipulation, permission must be obtained from Shift Management and all Holders who have accepted the C/O or may be affected by the evolution. If the component is Danger Tagged, then the component shall only be moved in the direction of the as applied position.
3. Qualified FM Technician to improve isolation of a FM WTO. Prior to this manipulation, permission must be obtained from the FM Supervisor. If the component is Danger Tagged, then the component shall only be moved in the direction of the as applied position.
4. Qualified personnel manipulating Information Tagged equipment.

5.1.2. All C/O Tags shall contain the following information as a minimum:

1. Component ID Number or noun name when component ID number is not available.
2. Component Description.
3. Position or status of component.

5.1.3. Clearance Tags should be placed on or as close to the component being controlled as possible to avoid confusion as to what point the Tag is controlling. Temporary attachment devices can be used or with proper Engineering approvals permanent attachment devices or holes can be employed.

5.1.4. For touch screen controls designation of a common location for tag placement is suggested to aid in human performance tool use. This location should be as close to the screen as possible to allow screen users to be aware tags are hanging that could affect their work.

OP-AA-109-101 Revision 9 Page 9 of 86 5.1.5. C/O Tags that are found to be either unattached or missing shall be reported immediately to Shift Management who will take the following actions:

1. DETERMINE affected C/O(s) and status.
2. STOP affected work if necessary for safety.
3. EVALUATE the need to Suspend or apply Holders Acceptance Lock to prevent Holders from accepting the affected C/O.
4. If the C/O Tag is still required, then HAVE the Tag reattached and re-verified as applicable.
5. If the C/O Tag is not required, then DISPOSE of the Tag.
6. UPDATE C&T program and documentation as required.

5.1.6. Because Exelon uses Danger Tags instead of locks, Tags Plus Devices and Methodologies will be used so that no single inadvertent action could by itself unisolate the component. Some references call these methodologies Additional Measures. The following criteria apply to Tags Plus.

1. Only one measure need be applied to each isolation point.
2. Energy release paths (vents, drains, Grounds), Not Tagged Steps, and Information Tagged items do not require Tags Plus methodologies.
3. Tags Plus devices do not require separate tracking via the C/O or WTO.
4. Tags Plus Methodologies such as dual valve isolation or racking out a breaker after turning it off, versus turning it off and leaving it racked in the cubicle are also acceptable methods of implementing this requirement.
5. Implementation of Tags Plus is to be discussed at the PJB for placing and removing the C/O and is considered a skill of the craft activity.
6. Tags plus devices shall be installed and removed only by Operations personnel or FM Technicians using FM WTOs.
7. See Job Aid posted in Tags Plus Folder on C&T Website located on the Exelon Nuclear home page for examples and available devices.
8. If Tags Plus devices or methodologies cannot be employed then designate the C/O as exceptional.

5.1.7. When work on equipment that is tagged will not affect the isolation capability of the equipment and Shift Management concurs, then work may be performed on that equipment.

OP-AA-109-101 Revision 9 Page 10 of 86 EXAMPLES OF WORK ON TAGGED EQUIPMENT:

A vent valve tagged closed may have the outlet weld repaired.

An MOV with the hand wheel tagged closed may have electrical work performed that will not cause the valve stem to be moved.

A blocked or gagged device may be worked on if the work will not affect the isolation ability of the block or valve.

Valve stem lubrications.

5.1.8. Untagged component manipulation within the C/O boundary is permitted provided the manipulation is controlled by and documented in an approved procedure or process. The documentation shall include the as-found and as-left position (as-left should match as-found unless otherwise tracked) including verifications as required.

EXAMPLES OF APPROVED PROCESSES Work Order Instructions Station Surveillance Tests MA-AA-716-100, Maintenance Alterations Process 5.1.9. C/O Tags shall not be placed or removed from components tagged with a Safety Lock/Tag. If a component is tagged with a Safety Lock/Tag, then CONTACT Shift Management for resolution.

5.2. Danger Tags 5.2.1. A Danger Tag will override all other Tag types in use at the facility.

5.2.2. A component with a Danger Tag attached to it shall not be physically removed from the system.

5.2.3. Danger Tags shall not be physically removed and/or equipment manipulated until the administrative requirements of this procedure have been met.

5.2.4. A Danger Tag can be applied to a component bearing another Danger Tag, or an Information Tag provided the component positions do not conflict. The Danger Tag shall not be obstructed by the Information Tag.

5.2.5. A Danger Tag shall not be applied to a component bearing a local leak rate test (LLRT) Tag, integrated leak rate test (ILRT) Tag, or Hydro Tag if the required component positions conflict.

5.2.6. A Danger Tag shall not be used to tag a breaker in the energized state.

5.2.7. A Danger Tag should not be used to tag a valve open to maintain a pressurized state, unless the pressure is being used to maintain isolation (e.g., air supply to a line stop bladder).

OP-AA-109-101 Revision 9 Page 11 of 86 5.3. Information Tags and Not Tagged Steps:

5.3.1. Since Information Tags may not be used to hold a boundary point in a zone of protection, but merely identify a component that is associated with a C/O, then components with Information Tags may be operated, removed, or have maintenance performed on the component with Shift Managements permission.

5.3.2. Information Tags and Not Tagged Steps are used in the Clearance and Tagging process for configuration management as appropriate. They are not C/O isolation points. Some examples of their uses are as follows:

1. An Information Tag may be applied to control stations extension controls and indicators to inform Operations personnel how equipment is affected by the C/O.
2. An Information Tag or Not Tagged Step may be used on components that are to be worked on or replaced under the C/O to aid in system restoration.
3. An Information Tag or Not Tagged Step may be used on manual valves within the C/O boundary, which may be manipulated, to aid in system restoration.
4. Information Tags or Not Tagged Steps may be applied to vents and drains and other points associated with a C/O that are not isolation points.
5. An information tag may be used on instrument air supplies to air operated valves unless the AOV is being used as a clearance boundary, in which case the air supply has to be Danger Tagged.

5.4. WTO Tracking List Tags 5.4.1. WTO Tracking List Tags are to be used by employees protected by WTOs, where ESO is not used. The Tag is intended to be a physical indication to others that employees are relying on the tagged component as the main isolation point for the work. A Worker Safety Locking and Tagging Program may be utilized in lieu of the WTO Tracking List Tag.

5.4.2. The Tags will be blue and white and will contain the following: A header stating WTO Tracking List Tag (all workers on WTL sign here), WTO#, date hung, department, and signatures of employees using the tag. Attachment 14 Part 6 is a sample of what the tag should look like. Similar likeness and nomenclature is acceptable if all required information is present.

5.4.3. A designated crewmember should coordinate other employees on the job signing the Tag during the process of completing the WTL.

5.4.4. A designated crewmember should hang one tag on an isolation point, as agreed to by the work crew. Use additional tags if more lines are needed for more employees.

Suggested placement is on the main isolation point protecting the employees. If no main isolation point, placement should be on the first isolation point expected to be cleared.

5.4.5. For components with dual power feeds a tag may be placed on both feeds if the breaker is the point chosen for tagging. This is annotated on Attachment 14 Part 4 as DUAL.

5.4.6. The Tag shall be removed prior to submitting the WTO to Operations for removal or daily at the end of the employees shift, whichever occurs first.

OP-AA-109-101 Revision 9 Page 12 of 86

6. CLEARANCE REQUEST STANDARDS 6.1. A Clearance Requester shall 6.1.1. CONSIDER whether the work can be done without a C/O. Refer to Attachment 1, Activities That Do Not Require a Clearance. If not applicable, CONTINUE at step 6.1.2.

6.1.2. SUBMIT a Clearance Request (C/R) providing as much detailed information regarding scope of work and reference material as possible (reference Attachment 3, Clearance Requestor Checklist, for guidance), including the following information:

1. Equipment Tag, or name description if the Equipment Tag is not in the database. If an equipment number does not exist for a piece of equipment and the site determines a number is required, SUBMIT an Issue Report (IR) or Engineering Change Request (ECR) and RECORD the IR/ECR number in the C/R.
2. W/O and task number, if applicable, must be provided (multiple W/O tasks requiring the same isolations can be bundled under a single C/R).
3. IDENTIFICATION of grounds or ground test devices that will be required to support the work or testing. INCLUDE specific location information and identify the manipulations required to support the work or testing.
4. Suggested isolation points if known.
5. IDENTIFY any Temp Lifts or Partial Clears of the C/O that will be required to support the work or testing, if known.
6. Total work scope including procedure/surveillance numbers and steps if applicable. If partial procedures will be performed, IDENTIFY those steps in the C/R.

6.1.3. SUPPLY approved drawings or required information (i.e., modifications) if current approved drawings are insufficient for determining isolation points.

6.1.4. ENSURE a Work Order task has been created to facilitate Instrument Maintenance Department backfill or venting of instrumentation upon returning a system to service following work that may have drained the instruments.

6.1.5. PROVIDE detail regarding any non-standard isolation methodologies that will be utilized such as line stop or freeze seal.

6.1.6. EVALUATE the work being performed and REQUEST isolation/control of fire protection systems if needed (i.e., CO2 and Halon).

OP-AA-109-101 Revision 9 Page 13 of 86 6.1.7. INCLUDE requirement to use checklists for Supervision, Lead Worker, and Worker (Attachments 11, 12, and 13) in the Work Order package for Work Orders that require C/O protection. Copies provided in shop areas can be used to facilitate ease of access and use by the protected employees.

6.1.8. The Clearance Requester should INCLUDE any additional abnormal or unusual details that will assist the Writer/Preparer and Approver in developing the C/O when known, such as:

1. Drawing references
2. System Configuration A. Systems required to be isolated (i.e., one or both sides of a heat exchanger).

B. Venting C. Draining D. Instrument air Isolated E. Control/Logic/Annunciator Power de-energized

3. Related Fire Protection System Impairment Information.

6.1.9. INCLUDE additional details on configuration of sub-components or subsystems and required C/O manipulations related to the work.

EXAMPLES:

For Emergency Diesel Generator work:

Fuel oil tank drained below sight glass taps Engine coolant drained Oil pumps tagged but draining not required Maintenance Requires Control power energized Temp Lift required for oil pump testing 6.1.10. The C/R Approver shall:

1. REVIEW the C/R to ensure adequate information is available for planning the C/O.
2. NOTIFY the Clearance Requester and RETURN the C/R if the scope is not properly identified.
3. APPROVE the C/R (may use Expedite Approval option).
4. PLAN the C/O, ASSIGN the C/R to a C/O Writer/Preparer to plan, or ASSIGN the C/R to a Clearance Assembly (C/A) for C/O preparation.

OP-AA-109-101 Revision 9 Page 14 of 86

7. CLEARANCE DEVELOPMENT STANDARDS 7.1. Clearance Development General Requirements 7.1.1. The Clearance Coordinator or Operations Management designee will EVALUATE the level of pre-job brief and HU-AA-1212 review using Attachment 5, Clearance Preparation/Approval Checklist.

7.1.2. C/Os will provide a safe zone of protection for all physical work to be performed under the C/O or for required equipment protection. This is accomplished by identifying, isolating, and tagging all required isolation points. If all required isolation points cannot be isolated, then the C/O will be designated as Exceptional. SEE Attachment 2, Examples of Exceptional Clearances.

7.1.3. C/Os written for one unit that affect systems common to the other unit must be carefully evaluated to assure that conditions on both units allow the equipment/system to be removed from service.

7.1.4. C/O impacts must be evaluated to ensure that affects on systems and components outside of the C/O boundary are identified and are acceptable, or properly dispositioned (i.e., evaluate affect of work on fire systems such as CO2/Halon injection or deluge systems).

7.1.5. During C/O development, the Writer/Preparers and Approvers will ASSESS Operational/Atmospheric (breathing and explosive)/Environmental/Reactivity risk impact. IDENTIFY any critical steps on the C/O which have the potential to result in a

> 20 MWe unplanned load reduction, impact breathing air in a space causing it to become uninhabitable, creation of explosive atmospheres when ventilation systems are removed from service, or affect reactivity. WC-AA-104 Integrated Risk Management has information regarding this topic. DISCUSS risks identified with Supervisor and take necessary actions, which may include notifying Cycle or Work Week Mgr, initiation of a Corrective Action Program document, or providing special instructions to address the risk.

7.1.6. C/O written on systems that remain in service or are only partially removed from service by the C/O must ensure that there are no adverse affects on the whole system as a result of the C/O.

7.1.7. Baseline Equipment Tagout has the feature of multiple open Checklists in approved status for a single C/O. Because of this tool, when changes are made to existing Checklists or additional Checklists are added, the Writer/Preparer and Approver as part of the process of development and approval of the Checklist being altered or created must ASSESS the impact on all other approved Checklists. ADDRESS all steps Tagged and Not Tagged in this review. Those Checklists impacted will be reset to PLAN status or canceled.

OP-AA-109-101 Revision 9 Page 15 of 86 7.1.8. If a C/O leaves uncertainty to the affects on Plant SSCs (Structures, Systems and Components), then REFER to LS-AA-104 Exelon 50.59 Review Process, LS-AA-104-1000 Exelon 50.59 Resource Manual, and CC-AA-112 Temporary Configuration Changes.

1. C/Os used to remove equipment from service to perform maintenance do not require a 10 CFR 50.59 review as long as the C/O strictly applies to the equipment being worked on (i.e., isolating a pump or removing the power feed from a motor operated valve).
2. C/Os that involve a temporary configuration change in support of maintenance fall into the 90-day clock category.
3. C/Os that involve a temporary configuration change for a degraded or nonconforming condition which are not in support of maintenance but allow for continued operation of the degraded or nonconforming equipment until maintenance can be performed, are required to have a 10 CFR 50.59 review performed prior to installation of the C/O.

7.1.9. C/O development shall consider ALARA principles.

1. CONSIDER changes to area dose rates when radioactive system draining will be performed.
2. CONSIDER alternate methods of isolation of C/O boundaries to minimize entries into high radiation areas to minimize personnel exposure.

7.1.10. Controlled drawings (including ECR Issue drawings) and references shall be used in the preparation of C/Os when available.

1. If controlled drawings are not available, then a C/O walk down shall be performed.
2. If a C/O walk down cannot be performed or cannot confirm isolation points, then a knowledgeable person (System Engineer, Subject Matter Expert, Vendor Representative, etc.) shall be consulted.
3. If isolation cannot be confirmed by other methods, then a Field Check of System conditions must be performed prior to releasing the C/O for work to start. If energy is detected during these checks, CONTINUE research until a safe zone of protection can be established.

7.1.11. The impact of a C/O on a Temporary Configuration Change Package (TCCP) shall be CONSIDERED and should be DOCUMENTED in the Special Instructions section of the C/O.

OP-AA-109-101 Revision 9 Page 16 of 86 7.1.12. All components manipulated during C/O activities shall be TRACKED to ensure configuration control by one of the following methods:

1. Tagged with a C/O Tag
2. Listed as a Not Tagged step
3. Tracked by a procedure that governs the manipulation 7.1.13. When C/O Tags are required to be placed on control panels or distribution panels that have closely spaced control switches, indications, breakers or controls where Regular Sized Tags may obscure these controls or indications, then Control Switch or Sticker size C/O Tags shall be used.

7.1.14. When a procedure exists to secure or restore equipment to service, then the procedure should be used to perform the task. The C/O may be performed in conjunction with the activity as appropriate.

7.1.15. Not Tagged C/O steps used for configuration control are required to be final cleared.

7.1.16. Procedures used as part of C/O performance should be listed in the Special Instructions, Checklist Notes, or as Comment (CMT) Steps and properly sequenced with the C/O steps.

7.1.17. If the C/O is determined to be an Exceptional C/O (refer to Attachment 2, Examples of Exceptional Clearances), then an explanation as to the reason shall be clearly stated in the Special Instructions of the C/O.

7.1.18. Special Instructions should contain the following items as a minimum, as determined by the C/O writer and approver, when applicable (list is not all inclusive or in order).

1. Work Group Cautions/Hazards including exceptional criteria
2. If the Clearance is Mode or Condition Dependent describe why
3. Operations Hang Info
4. Operations Cautions/Hazards
5. RTS info including fill and vent information
6. Procedures required to support Clearance execution
7. Work Scope if warranted by complexity
8. Administrative Requirements (Tech Specs, Fire Impairments, Plant Barrier Impairments, OLR or SDR)

OP-AA-109-101 Revision 9 Page 17 of 86 7.2. Preparation and Approval Requirements 7.2.1. If the C/O affects Technical Specification (Tech Spec) or Safety Related equipment, then the C/O approval must be performed by a licensed or previously licensed individual.

7.2.2. All C/O Writer/Preparers and Approvers are accountable for the items on the applicable Clearance Preparation/Approval Checklist. Copies of each completed attachment shall be routed with the C/O paperwork.

7.2.3. The C/O Challenge is required for all Clearances and WTOs prior to being placed and whenever work is added to a placed C/O. The C/O Challenge is not required for subsequent TL, RH, PC, FC Checklists, or FM WTOs.

7.2.4. When an On-Line Emergent C/O is prepared, then measures shall be used to ensure an independent review is performed. This will be accomplished by independently marking two sets of prints to identify isolation points.

7.2.5. When a change is made to an APPROVED C/O, then the review requirements are limited to those aspects of the C/O that are affected by the change. An entry should be made on the C/O route list notes or Special Instructions to document the change and level of review performed.

7.2.6. When the affects of C/O are not understood by the C/O Writer/Preparer or Approver, then Engineering or a Subject Matter Expert shall be contacted to provide technical expertise detailing the affects of the C/O including the affects on equipment that must remain operable.

7.2.7. If the affects of a C/O still cannot be determined, ADD Not Tagged steps to the C/O to take field readings to verify the zone of protection is safe prior to releasing the C/O to the work group.

7.2.8. When a Condition Dependent C/O is used, then the following information shall be included in the C/O Special Instructions:

1. Designate C/O as exceptional
2. Basis for using this type of C/O
3. Dependent condition to be maintained or procedure governing the condition 7.2.9. For Condition Dependent C/Os, the condition being administratively controlled shall be clearly identified with a C/O Information Tag or other indicating device to alert those responsible for monitoring and maintaining the condition within its required status or range. If the condition is being controlled under the direction of a governing procedure (e.g. Reactor Head Disassembly/Reassembly), then the indicating device is not required to be identified with a Tag.

OP-AA-109-101 Revision 9 Page 18 of 86 7.3. Clearance Isolation Standards 7.3.1. Sequencing of C/O step performance

1. C/O isolation points may be arranged to reduce unnecessary travel as long as personnel safety and equipment reliability is not compromised.
2. When a procedure is used to secure or realign equipment, then the equipment shall be manipulated by the sequence dictated by the procedure.
3. C/O Application sequencing should use the following techniques as applicable:

A. Control switches prior to power supplies B. Control switches prior to gagging/blocking devices C. Control switches prior to hydraulic/pneumatic control isolation D. Power supplies prior to components E. High energy systems prior to low energy systems if covered by the same C/O F. Driving equipment prior to driven equipment G. Discharge valves prior to suction valves H. Vents prior to drains (hard piped drains should be opened first to depressurize an isolated boundary)

4. Restoration sequencing should use the following techniques as applicable:

A. Vents and drains B. Suction valves prior to discharge valves C. Low energy systems prior to high-energy systems if covered by the same C/O.

D. Driven equipment prior to driving equipment E. Components prior to power supplies F. Control switches after hydraulic/pneumatic control isolation G. Power supplies prior to control switches H. Gagging/blocking devices prior to control switches

OP-AA-109-101 Revision 9 Page 19 of 86 7.3.2. Mechanical Isolation General Standards

1. Manual valves will normally have the Tag applied to the hand wheel.

However, if the valve is deemed inaccessible and verified by other means in the required position, a Tag may be hung in highly visible location such that access cannot be gained to the valve without having to address the Tag, i.e.,

door handle on the door to the room or area where the valve is located.

2. If a C/O is placed where rotation of the equipment would cause a safety hazard to employees or damage to the equipment, then CONSIDER isolation of flow paths that could cause rotation.
3. Dual valve isolation should be provided when isolating from an energy source of greater than 200 Fahrenheit or pressures greater than 500 psig. If dual valve isolation is not provided, then the C/O shall be deemed an Exceptional C/O.
4. Throttled valves should not normally be used as isolation points. When a throttle valve is used as a C/O isolation point, then sufficient administrative control shall be put in place in order to properly position the valve on return to service.
5. Check valves that cannot be physically restrained in the isolated position by a hand wheel or gag should not be used as boundary isolation points unless no other isolation is practical. If a check valve without restraint capability is used as a primary or secondary boundary, then an explanation shall be listed in the Special Instructions and the C/O shall be designated as an Exceptional C/O.
6. Hydraulically operated valves used as isolation points shall have hydraulic pressure removed or blocked in the isolated position and C/O Tag attached.

If these conditions cannot be met, then this C/O shall be an Exceptional C/O.

7. Using a valve backseat for isolation (i.e., to isolate packing leakage for repair/replacement):

A. VERIFY the valve is designed with a backseat for use as isolation.

B. The valve will be OPENED and TORQUED on the backseat, as applicable. Reference OP-AA-103-105, Limitorque Motor-Operated Valve Operations.

C. CONTACT the System Engineer as applicable if proper guidance cannot be found in OP-AA-103-105.

D. The hand wheel will be Danger Tagged in the backseated position.

8. A valve may be considered inaccessible due to location requiring a ladder/scaffolding to access and Tag or entry into a High Radiation Area is required only to Tag the valve (i.e., no work or general access is allowed in the area. An example would be a BWR MOV located in the Drywell).
9. Locking devices can be utilized when a valve is identified as having a high potential for inadvertent contact. A valve identified as always needing a locking device to prevent inadvertent opening while tagging out can be identified as such on the Passport Equipment Notes. Locking devices are to be placed and removed within the timeframe of the C/O and can be designated on the C/O Checklist as Not Tagged steps. Installation shall be reviewed on a case-by-case basis for fire loading and seismic affect.

OP-AA-109-101 Revision 9 Page 20 of 86 7.3.3. Gagging and Blocking Device Standards

1. Gagging and blocking of C/O isolation points shall be done using C/O steps, work packages, or approved procedures that include any pre-approved engineering solutions. These C/Os shall be designated Exceptional.
2. No work may be performed on blocked or gagged equipment that may affect the block/gags ability to maintain isolation capabilities of the component.
3. When a gagging or blocking device is used to maintain a C/O boundary, then a C/O Tag shall be applied to the gagging or blocking device.
4. If pneumatic operated or motor operated valves are used as an isolation boundary, then an appropriate gagging device may be used to maintain the isolation boundary with the operator removed.
5. If a device fails to a position different from the required C/O position on a loss of control power or air supply, then it shall be held in its tagged position by a gagging/blocking device. When the gagging/blocking device has been installed, then the motive force of that valve shall be removed to ensure that the gagging/blocking device is performing its intended function. Once tested, the motive force may be restored.
6. If a component is physically restrained in a required position using an approved gagging/blocking device to establish a zone of protection, then the gags/blocks shall be used as isolation points and a C/O Tag shall be attached to the gag/block.

7.3.4. Plug, Line Stop, and Freeze Seal Standards

1. The use of plugs/line stops shall require that the C/O be an Exceptional C/O.

Tagging of plugs that are underwater is not required.

2. Plugs may be used as isolation boundaries when they are determined to be seated, and at least one of the following is true:

A. The plug is provided with a constant gas/water supply to remain inflated.

B. A Physical gagging/blocking device is installed and the device is tagged with a C/O Tag.

OP-AA-109-101 Revision 9 Page 21 of 86

3. When a freeze seal is used as an isolation point to perform work, then the following are required:

A. Freeze seals shall be performed by approved procedures and controlled by work instructions in a Work Order Task.

B. A C/O shall be placed to control the other isolation boundaries associated with the freeze seal.

C. The associated C/O shall be classified as Exceptional with the details of the freeze seal entered into the C/O Special Instructions.

D. Any drains or vents opened with the placement of the C/O shall be tagged with Information Tags or listed as Not Tagged steps and re-closed after draining, or an Operator will be assigned to monitor for leakage past the freeze seal and close the valves if needed.

E. Any additional draining or system breach performed by Maintenance during the freeze seal work shall be tracked by the work crew in the W/O instructions and restored prior to removing the freeze seal and prior to the Holder releasing the C/O.

F. Coordination with the maintenance group responsible for maintaining the freeze seal will be established to ensure that the seal is established and removed in the proper sequence.

G. CONSIDER inserting a Not Tagged step for the freeze seal on the isolation boundary C/O to ensure proper sequencing the restoration of the boundaries.

7.3.5. Air Operated Valves and Dampers (AOVs) Standards

1. A fail open AOV may be used as a closed isolation point if the following conditions are met:

A. The valve control station(s) shall be tagged closed.

B. The valve shall be forcibly held closed with an installed gagging or blocking device. The integrity of the gagging or blocking device installation shall be verified by:

1. CLOSE and VENT the air supply to ensure AOV remains as positioned.
2. RESTORE the air supply.

C. The air supply valve to a gagged AOV shall be Information Tagged to aid in establishing the component in a safe condition prior to gagging device removal.

OP-AA-109-101 Revision 9 Page 22 of 86

2. A fail-as-is AOV may be used as an isolation point if all of the following conditions are met:

A. The valve control station(s) shall be tagged.

B. The valve should be visually checked closed.

C. The valve shall be tagged and forcibly held closed with an installed gagging or blocking device unless the valve mechanically locks in position without pneumatic supply.

D. The air supply valve shall be tagged closed.

E. If the above requirements cannot be met, then the AOV may still be used as an isolation point under proper approval and the C/O classified as exceptional.

3. If an air operated valve is used as an isolation point, and it fails in the closed position, then air shall be isolated, bled down and tagged or the solenoid deactivated and tagged to ensure the valve cannot be operated.
4. If an air operated valve is to be worked on such that the air supply must be isolated to prevent the valve from stroking or for air operator work, then the air supply stop at the AOV should be tagged with an INFO tag allowing the working crew to manipulate the air supply as needed for maintenance and testing.

7.3.6. Motor Operated Valve (MOV) Standards

1. A motor operated valve may be used as a C/O isolation point provided all the following conditions are met:

A. The valve control station(s) shall be tagged.

B. The electrical energy source shall de-energized and tagged.

NOTE: The hand wheel may be considered inaccessible due to location requiring a ladder/scaffolding to operate and Tag or entry into a High Radiation Area is required only to Tag the valve (i.e. no work or general access allowed in the area. An example would be a BWR MOV located in the Drywell).

C. The valves hand wheel should be tagged if personnel protection is being provided unless the hand wheel is inaccessible, in which case the C/O shall be an Exceptional C/O.

OP-AA-109-101 Revision 9 Page 23 of 86 7.3.7. Venting and Draining Standards

1. When a system containing hazardous fluids/gases is drained or vented for removal from service, then methods for capturing the substance shall be noted in the C/O Special Instructions. Re-closure of vents and drains may be necessary to contain residuals.
2. When a pressure boundary is tagged for internal work, and an energy potential exists that would create a concern for the employee, then the zone of protection must be depressurized and drained by the use of vents and drains that are included on the C/O. If these conditions cannot be met, then the C/O shall be an Exceptional C/O.
3. If no valves are available to drain/depressurize an isolated system, then the working department must be informed that other measures (i.e., breaking flanges/fittings or loosening connections) are required to drain/depressurize the system after the C/O is placed. These activities will be controlled by a work package. Such C/Os shall be designated as an Exceptional C/O.
4. If venting or draining is required to compensate for excessive leak-by of an isolation point, then the vent drain valves shall be tagged open unless they will be removed for maintenance.
5. NOTIFY cognizant Radwaste personnel prior to draining significant amounts of fluids from systems that could affect waste processing.

7.3.8. Electrical Isolation General Standards

1. Isolation for personnel protection should not consist of tagging a control switch only, unless no other means to isolate are practical, in which case the C/O will be designated as Exceptional.
2. If Main Control Board switches or Remote Shutdown Panel controls are tagged to indicate C/O conditions, then they should normally be tagged with Information Tags.
3. When gang operated components (i.e., four valves operated by one control switch) are to be tagged individually, then detailed instructions shall be included on the C/O Checklist to assure the components that are not being removed from service remain in the desired state. Such instructions are not required if the entire group of components is tagged simultaneously.
4. It is preferred to use breakers as isolation points rather than pulling fuses under load, which may cause damage to fuse holders.
5. Remote or alternate shutdown panel controls are not required to be tagged unless they are in use as the controlling station.
6. When a lead will be lifted where multiple leads are landed on the same terminal point, then the affects of lifting all leads shall be evaluated.

OP-AA-109-101 Revision 9 Page 24 of 86

7. When leads must be lifted to isolate work from an electrical hazard, then C/O Tags shall be used on the leads lifted unless covered by the criteria in Attachment 1, Activities That Do Not Require a C/O.
8. A C/O Tag placed on a breaker handle or compartment door does not prevent opening the cubicle door for inspection by qualified individuals.
9. If an annunciator that is related to a system that remains operable or in operation is made inoperable because of a C/O, then consideration should be given to placing an Information Tag on the annunciator window to explain the conditions.
10. When a C/O is placed to support bus inspections where all components are not completely de-energized or the potential for backfeed exists, then the live components and backfeeds will be listed in the C/O Special Instructions and the C/O will be considered Exceptional.

7.3.9. Breaker Standards

1. When an MCC type or distribution panel breaker is tagged as an isolation point, then:

A. The C/O Tag shall be placed on the breaker handle/switch in the OFF position, unless the Clearance Request identifies that the scope of work will require the Tag to be placed on the cubicle door to facilitate work such as bucket or breaker removal.

B. If using an MCC Breaker as an isolation point, and that model breaker has been proven unreliable to open, then contact open checks should be performed by qualified personnel. These should be done prior to installing the Tag on the locking mechanism, or the qualified individual performing the check may not be able to open the breaker door to physically perform the check. (This will require work group coordination with Operations when hanging the C/O if checks done by other than Operations.)

CAUTION Depending on the breaker configuration lifting leads at other than the breaker operating handle mechanism may not isolate breaker control power - resulting in no longer having the same isolation as opening up the breaker. If not lifting leads at the breaker operating handle mechanism, VERIFY the leads being lifted provide the same electrical isolation as opening the breaker.

C. If a tagged breaker is tagged on the handle/switch and work will require moving the Tag to the cubicle door, then the Operations Department may transfer the C/O Tag to the cubicle door or lifted leads without the Holder(s) releasing the C/O.

OP-AA-109-101 Revision 9 Page 25 of 86 NOTE: During the following activity, work tied to the C/O may not continue because the zone of protection is being altered. This is required to ensure no one is working on the equipment powered from the breaker during installation of the breaker /lead landing activity.

D. When installing a breaker that has been removed from an MCC or relanding leads that were previously lifted from a breaker, the responsible Work Group for the activity shall perform the following actions:

1. COORDINATE with Operations to have the Holders Acceptance Lock applied to all C/Os using that breaker as an isolation point.
2. COORDINATE with the Supervisors and Workers signed on to the affected C/Os to release for TL or FC.
3. VERIFY all Holders have released from the affected C/Os and Holder Acceptance Locks have been applied.
4. VERIFY all phases OPEN or OFF prior to breaker installation.
5. PERFORM breaker installation/lead termination.
6. Following breaker installation, COORDINATE with Operations to transfer the Clearance Tag to the breaker operating mechanism (unless more cubicle work will be performed) and have the Holders Acceptance Lock removed from the affected C/Os not being Final Cleared.
2. For rackable breaker C/O positions, racked out (R/O) allows all breaker positions except racked in and racked to test.
3. For non-rackable breaker positions, OFF allows all breaker positions except ON.
4. When a rackable breaker is tagged as an isolation point in the racked out position, then the C/O Tag shall be placed on the cubicle door or racking device.
5. When distribution panel breakers are tagged as an isolation point, then the C/O Tag shall be attached to the breaker switch using a station approved method that will securely attach the C/O Tag to the switch. Adhesives such as tape and adhesive backed tabs can be used to attach C/O Tags, or Sticker Tags may be used on distribution panel breakers when the environment and physical conditions are not likely to cause the Tag to become detached inadvertently.

OP-AA-109-101 Revision 9 Page 26 of 86 7.3.10. Grounding Standards WARNING THE EFFECTS OF ENERGIZING GROUNDED EQUIPMENT CAN BE CATASTROPHIC! ALL GROUNDS SHALL BE VERIFIED REMOVED PRIOR TO RE-ENERGIZING EQUIPMENT.

1. All grounding devices providing personnel protection shall be INCLUDED as an isolation point on a C/O or WTO and will be tagged with a Danger Tag that is hung on the grounding strap, the cubicle door, or on the GTD in an appropriate location (such as the racking screw or front panel).
2. If additional grounds are identified after the start of work as being required, then Operations must be contacted to Danger Tag the additional grounds.
3. The following are exempt of the requirements of C/O Danger Tags:

A. Grounding scaffolding B. Grounding vehicles / lifting devices C. Mousing / test leads D. Other ground devices not in the electrical circuit bounded by the Zone Of Protection for attached work orders

4. Grounding devices installed for testing shall be IDENTIFIED as such with an Information Tag or as a Not Tagged item on a C/O or WTO.
5. When a bus or power source is to be grounded, then all electrical feeds and potential backfeeds to that bus or power source shall be tagged out prior to grounding. If there are multiple electrical feeds to the bus or power source, if installing ground straps/clusters, or if closing a grounding disconnect, the step to tag the ground(s) must be included on a Clearance or WTO that also tags all electrical feeds and potential backfeeds to that bus or power source.
6. Employees installing or removing grounds straps on installed devices or Ground Test Devices shall be PROTECTED by a C/O or use Attachment 1 criteria prior to commencing the installation. An example of Attachment 1 criteria would be if the equipment has single or multiple feeds and the feed is in the sole control of the worker. If multiple feeds exist, and sole control is not possible, then C/O acceptance is required.
7. Ground Test Device and ground strap installation should be performed in accordance with an approved station procedure or work instructions.
8. Plant Operations and the work group shall EVALUATE grounds that are lengthy to determine if both ends require tagging. Normally only one tag per ground cluster is required.

OP-AA-109-101 Revision 9 Page 27 of 86 7.3.11. Fuse Standards

1. When a fuse is removed to provide C/O isolation, then the fuse shall be replaced with a non-conductive clip or other Tags Plus device that prevents insertion of a fuse when C/O is hanging.
2. ATTACH the tag to the fuse clip or place it as close to the clip as possible. If a non-conductive fuse block out device is not used, then the fuse shall be identified and stored for restoration when the C/O is removed, and a Tag will be placed such that another fuse cannot be accidentally installed.
3. EXERCISE care to insure that the size and rating of fuse removed during C/O activities is the same as the fuse that gets reinstalled during restoration.
4. Breaker control power fuses should only be tagged when they are included as part of the zone of protection.
5. When tagging a fuse block to provide C/O isolation, then the fuse block shall be controlled in one of the following manners.

A. Place the fuse block (and fuses) in a bag identified with a copy of the Danger Tag or information traceable back to the C/O, store in a safe location, and place the actual Danger Tag on a wire terminated at the base of the stationary portion of the fuse block, covering the fuse block to prevent other fuses from being installed.

B. Turn the removable portion of the fuse block 180 degrees to the OFF position and reinsert into the stationary portion of the fuse block, with the Danger Tag placed on handle of the fuse block.

7.3.12. Logic Circuits and Instrumentation Standards WARNING EXTRA CARE SHALL BE TAKEN WHEN WORKING WITH THE REACTOR PROTECTION SYSTEM, PRIMARY CONTAINMENT ISOLATION SYSTEM, ECCS LOGIC SYSTEM, AND TURBINE SUPERVISORY SYSTEM TO PREVENT INDUCING INADVERTENT ACTUATION SIGNALS DURING C/O MANIPULATIONS.

1. The C/O Preparer and Approver must fully understand C/O impacts on logic circuits and instrumentation. If there is any question regarding response, then assistance must be requested from subject matter experts.
2. When instrument components normally manipulated by IM personnel are part of a C/O, then IM personnel should perform the manipulations.
3. In every case that instrumentation component manipulation is required for a C/O, all plant effects of the manipulation shall be known and compensated for prior to the manipulation.
4. The affects of any lost or inaccurate inputs into plant processes (e.g., heat balance inputs, etc.), resulting from the C/O application, shall be evaluated.

OP-AA-109-101 Revision 9 Page 28 of 86 7.3.13. External Energy Injection (EEI) Standards

1. When External Energy Injection will be performed on equipment within a Clearance boundary (e.g., hydro-testing, high pot testing, back filling of piping, Baker testing, temporary air supply, Meggering), then the activity shall be performed under the requirements of the governing approved procedure or work instructions to ensure the proper safety precautions are taken. The work group performing the energy injection is responsible for ensuring energy being introduced will not jeopardize any employees safety. The following will be addressed:

A. Guarding of test areas.

B. Requesting supporting ground test devices.

C. Test observers.

D. Safety checks.

E. Worker Notification

2. The Supervision performing the EEI activity shall perform the following:

A. CONTACT and COORDINATE with all Supervision for associated C/Os to discuss the impact of the EEI on all work in progress.

B. USE the Holder Acceptance Lock to support the EEI activity for all affected Clearances.

C. VERIFY C/O Holders and protected employees for associated C/Os are notified and agree to the EEI by completing Attachment 16, External Energy Injection (EEI) Notification. If all workers sign off the Clearance before the EEI commences then Attachment 16 is not required. The Holders Lock shall still be applied.

D. WHEN EEI is complete REMOVE Holders Lock and workers can resume work.

3. C&T EEI Standards are not required if the component is removed from the Zone of Protection of the Clearance, either by physical removal or separation.

EEI safety practices still need to be employed as listed in section 7.3.13.1 above. Examples of when Attachment 16 is not required:

A. Transformer work with disconnects or bus work physically removed within line of sight of the transformer.

B. Meggering of bolts on a pump with insulated flange connections.

C. AOV maintenance and testing with an external air supply or INFO or Not Tagged air supply valve.

D. Equipment not installed in the ZOP like a motor or pump in the shop, a breaker removed from its cubicle, or equipment electrically disconnected.

OP-AA-109-101 Revision 9 Page 29 of 86

8. CLEARANCE DEVELOPMENT 8.1. Processing Requests for Clearance 8.1.1. The Clearance Group or Qualified Operations personnel shall perform the following:
1. REVIEW and APPROVE C/Rs per Section 6.
2. For situations that require multiple C/Os to support the W/O task, GENERATE additional C/Rs for each additional C/O that is required.
3. BUNDLE related C/Rs/CAs for efficiency.
4. IDENTIFY any Temp Lift, Partial Clear, or Final Clear Checklists of the C/O that can be prepared in advance during the planning process.

8.2. Clearance Development and Approval 8.2.1. The C/O Writer/Preparer shall perform the following in accordance with the requirements of this procedure using a copy of Attachment 5, Clearance Preparation/Approval Checklist.

1. CONTACT the Clearance Requestor(s) if there is any doubt of the scope of work, isolation requirements or special conditions/instructions. If the Clearance Request is inadequate, then RETURN it to the work planner for additional information.
2. COPY/BACKGROUND a Model or Historical C/O or CREATE a new C/O as appropriate.

A. REVIEW the work to be performed. IDENTIFY an Authorized Model or historical C/O for same or similar work scope to be performed.

NOTE: Passport enhancements are in place to highlight documents that have pending revisions. REFER to the T210 or T215 panels.

B. VERIFY that the references, including drawings and procedures, listed on the Model have not undergone revision or the revisions verified not to impact proper isolation.

C. BACKGROUND the Model/Historical C/O or CREATE a new C/O.

D. ATTACH the appropriate C/Rs.

OP-AA-109-101 Revision 9 Page 30 of 86

3. DEVELOP a boundary isolation list to establish, modify or lift a zone of protection as applicable.

A. USE equipment records as they appear in the database.

B. ENTER the Equipment Tag and name in the description field if the proper record cannot be located in the database and INFORM a Data Steward of the problem if a new record is required. If it is not desired to create an equipment record in Passport, ENTER the required information in the Equipment/Description field to identify the component.

C. ENTER the appropriate tag type for the application.

D. UTILIZE the most detailed reference material available to ensure the actual configuration of the system is understood.

4. ENTER procedures to be used in conjunction with the C/O as comment (CMT) steps or Special Instructions.
5. REQUEST assistance from Engineering or Subject Matter Expert if necessary and INCORPORATE the information provided into C/O.
6. EVALUATE the work being performed for the need to isolate/control automatic initiation of fire protections systems (i.e., CO2 and Halon).
7. ENTER hang or lift positions to establish, modify or lift the zone of protection as applicable.
8. SEQUENCE all C/O steps.
9. ENSURE drain precautions or fill requirements are specified as applicable.
10. SPECIFY Boundary Verification Requirements.
11. DESIGNATE the C/O as Exceptional and ENTER the appropriate information in the Special Instructions if required.
12. ENSURE that any C/O related TCCP that may affect the C/O zone of protection or affected equipment is properly configured prior to, or in correct sequence with, C/O boundary manipulations.
13. EVALUATE the risk potentials using Attachment 5, Clearance Preparation/Approval Checklist. ENTER comments in the C/O Special Instructions as appropriate.
14. ENSURE that all information provided by the Clearance Requester(s) is addressed by the C/O.
15. INCLUDE in the Document panel all drawings and procedures used in preparation of the C/O.

OP-AA-109-101 Revision 9 Page 31 of 86

16. NOTIFY the Clearance Requestor if equipment is not isolated as requested in the C/R to ensure that any special conditions/instructions are met, or assumptions made during the work planning (including risk evaluation) are not compromised.
17. NOTIFY the Cycle Manager/Unit Coordinator if the activity is determined to be a Reactivity/Atmospheric (Breathing and Explosive)/

Operational/Environmental risk activity outside E-4 or Work Week Manager if inside E-4.

18. APPROVE the C/O Outline (may use Expedite Approval option).
19. PREPARE a C/O Checklist.
20. IDENTIFY Reactivity/Atmospheric (Breathing and Explosive)/

Operational/Environmental Risk critical steps on the C/O Checklist by entering a step note or in the Special Instructions.

21. ROUTE the checklist for approval.

8.2.2. The C/O Approver(s) shall perform the following in accordance with all requirements of this procedure using a copy of Attachment 5, Clearance Preparation/Approval Checklist.

1. VERIFY that the C/O activity was properly prepared as required by this procedure.
2. RETURN for revision or REVISE the C/O Checklist if discrepancies are identified.
3. APPROVE the C/O Checklist.

8.2.3. The C/O Challenge MUST be performed prior to C/O Checklist distribution and before work is added to an ACTIVE C/O. REFERENCE Attachment 7, C/O Challenge Guidelines as required, and DOCUMENT completion of review on Attachment 5, Clearance Preparation and Approval Checklist.

OP-AA-109-101 Revision 9 Page 32 of 86 8.2.4. REQUEST a walk down of the C/O to be performed using Attachment 6, Clearance Walkdown Sheet, for the following types of C/Os:

1. Refuel outage C/Os as determined by the Clearance Coordinator/Outage Planner.
2. C/Os involving work that places the plant in a shutdown condition of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or less.
3. C/Os where the work is scheduled to extend beyond the WC-AA-101, On-line Work Control Access, allowable LCO duration.
4. C/Os that result in Online Risk changing to Orange or Red.
5. Other C/O types as requested by the Clearance Coordinator or Operations Management.

8.3. Development and Approval of Subsequent Checklist 8.3.1. The C/O Writer/Preparer shall approve the subsequent Checklists using Attachment 5, Clearance Preparation/Approval Checklist as a guide.

8.3.2. The C/O Approver shall approve the subsequent Checklists using Attachment 5, Clearance Preparation/Approval Checklist as a guide.

9. CLEARANCE WORK ADDITION/WORK SCOPE MODIFICATION NOTE: Work Addition and approval must be performed to the same level of review as the original C/O.

9.1. Adding a Work Order (W/O) Task or a C/R to an Existing C/O 9.1.1. The Clearance Group or qualified Operations personnel shall perform the following:

1. REVIEW the work to be performed and IDENTIFY an existing C/O that is adequate for the work scope.

NOTE: For ACTIVE C/Os (i.e., tags are hanging) the C/O Challenge and both approvals must be performed before the Approver initiates the scope change in Passport. This will prevent anyone from starting work before the C/O Approval and Challenge are completed.

2. INITIATE scope change.
3. ADD the C/R and W/O Tasks to C/O.

OP-AA-109-101 Revision 9 Page 33 of 86

4. PERFORM reviews and approvals.

A. Writer/Preparer reviews and approves scope change in Passport and documents approval on Attachment 5, Clearance Preparation/Approval Checklist.

B. Approver reviews and approves scope change and documents approval on Attachment 5, Clearance Preparation/Approval Checklist.

C. PERFORM a C/O Challenge using Attachment 7, C/O Challenge as a guide and document completion on Attachment 5, Clearance Preparation/Approval Checklist.

9.2. Removing a Work Order (W/O) Task or a C/R from an Existing C/O 9.2.1. The Clearance Group or qualified Operations personnel shall perform the following:

1. The Work Week Manager, Outage Coordinators, or Work Group Lead should CONTACT the Clearance Coordinator or Operations Supervisor to have the W/O task removed from the C/O.
2. VERIFY the W/O Task status is set to Suspend. If W/O task status is working, HAVE cognizant Work Group set to Suspend.
3. INITIATE a Scope Change.
4. DELETE W/O Tasks/Clearance Requests from the existing C/O and APPROVE the Scope Change. DOCUMENT removal reason on Route List Notes.
5. RESTORE W/O task status to the as found status.

9.3. Modifying Work Instructions/Scope of a W/O attached to an active C/O 9.3.1. The Clearance Group or qualified Operations personnel shall perform the following:

1. The Work Planner or Work Supervisor will contact the Clearance Coordinator or Operations Supervisor. Nature of the revision will be discussed in detail to determine:

A. If revision of the C/O will be necessary or if other work attached to the C/O will be affected, then the Cognizant Operations Supervisor will ensure:

1. The C/O is modified as needed.
2. The C/O is placed in SUSPEND status or Holder Acceptance Lock is applied if needed to prevent continued or new work as appropriate.

OP-AA-109-101 Revision 9 Page 34 of 86

10. AUTHORIZING AND PERFORMING CLEARANCE MANIPULATIONS 10.1. Clearance Placement Standards 10.1.1. Any changes to a C/O should be documented electronically to maintain configuration control.

10.1.2. Return to service position changes require review by two qualified individuals (RO or SRO).

10.1.3. Exceptions are allowed for the following, which may be pen/ink changes reviewed and initialed by Shift Management prior to executing change.

1. Sequence changes.
2. Minor description/location changes.
3. Information items that do not affect the zone of protection.

10.1.4. If a C/O cannot be completed as written, then the equipment shall be placed in a safe condition and Shift Management notified.

10.1.5. C/O Tags will be securely fastened to all points of isolation when possible with a non-reusable nylon cable tie with a minimum unlocking strength of 50 pounds for regular size Tags.

1. ATTACH the Tag directly to the component if possible. Tape, string, or other suitable methods of attachment may be used when a cable tie is not practical.
2. When attachment is not possible, then the Tag will be attached in a highly visible location near the equipment to alert all personnel of tagout conditions.

10.1.6. If C/O Tags will remain inside of Containment (Primary Containment) after Containment closeout or during power Operation, then they may be replaced by stainless steel C/O Tags attached with stainless steel straps, unless evaluated and approved by Engineering.

10.1.7. If the isolation component has been designed to accept a locking device, then the C/O Tag will be attached at the locking point in the same manner that a locking device would be attached if accessible.

OP-AA-109-101 Revision 9 Page 35 of 86 10.1.8. Normally qualified Operations personnel operate plant systems or equipment for C/O manipulations. The following are examples of exceptions to this practice:

EXAMPLES OF NON-OPERATIONS C/O MANIPULATIONS:

Instrument Mechanic installing and removing a pneumatic jumper Electrician lifting/landing an electrical lead or installing grounds Mechanic installing and removing a block or gag FM personnel manipulating non-plant/non power block equipment for their WTOs When non-Operations personnel assist with equipment manipulations for C/O activities, the sign offs on the Clearance will record the operators who placed the tags.

10.1.9. When systems or components are tagged that require draining, then the C/O shall not be electronically released for work until after the draining is verified complete or adequate for the work to be performed. If boundary has not been drained, then DOCUMENT details in the C/O Special Instructions and screen C/O for exceptional status.

10.1.10. If the equipment information on a C/O Tag does not match the equipment label such that there is reasonable doubt of the identity of the equipment, then Shift Management shall be contacted to make a final determination if the C/O Tag should be placed or not.

1. Data revision should be initiated.
2. If a labeling discrepancy is identified, then INITIATE a labeling change request.

10.1.11. For Mode or Condition Dependant C/Os, the Operations Clearance Prejob Brief will discuss the following as listed in the C/O Special Instructions.

1. Basis for using this type of C/O.
2. Dependent condition to be maintained or procedure governing the condition.

10.1.12. A Condition Dependent C/O shall not be taken to the ACTIVE status until the applicable condition has been verified and is being maintained and must be released prior to allowing the condition to leave the established status or range specified in the C/O. If the condition is being controlled under the direction of a governing procedure (e.g., Reactor Head Disassembly/Reassembly), then these status and Holder accept/release activities are not required.

10.1.13. A Mode Dependent C/O shall not be taken to the ACTIVE status until the applicable plant mode has been verified. Plant procedures shall not allow the plant mode to change to an undesirable mode until all applicable mode dependent C/Os have been verified cleared or acceptable.

OP-AA-109-101 Revision 9 Page 36 of 86 10.1.14. Before placing a Mode Dependent or Condition Dependent C/O, the Operations Clearance Prejob Brief will discuss the following as listed in the C/O Special Instructions. If the condition is being controlled under the direction of a governing procedure (e.g., Reactor Head Disassembly/Reassembly), then the briefings are not required to be repeated for each condition change.

1. Basis for using this type of C/O.
2. Dependent condition to be maintained or procedure governing the condition.

10.1.15. When modifying a Distributed checklist, steps for tags that have been placed should be completed in Passport prior to modifying the checklist.

10.1.16. When resetting the status of multiple Distributed checklists to change the C/O that owns the HANG Action(s), all C/Os sharing steps must be Returned/Modified, and then reset to Distributed in the correct order. This should be performed in a timely manner, especially when tags have been placed.

10.2. Restoration Standards 10.2.1. If a lift position is determined to be different from the normal lineup position for the present plant condition and not tracked by another C/O or procedure, then Shift Management shall be notified and equipment tracking initiated.

10.2.2. If there is reason to believe that uncontrolled manipulations of equipment within the C/O boundary may have occurred, or if deemed necessary by Shift Management, then a system lineup checklist or equivalent shall be performed on systems or components with the zone of protection being returned to service.

10.2.3. Consideration should be given to initiate tracking of equipment that is to be returned to service and not considered operable due to testing requirements.

10.2.4. Prior to physically removing C/O Tags a visual inspection of the principal equipment should be performed. The inspection should include:

1. System Integrity
2. Proper Lubrication
3. Valve/breaker alignment
4. Removal of Grounds
5. Equipment Cleanliness 10.2.5. For return to service purposes, Information Tagged and applicable Not Tagged Items shall be handled as tagged items (i.e., sequencing, return to service positions, and appropriate signoffs).

OP-AA-109-101 Revision 9 Page 37 of 86 10.3. Clearance Authorization 10.3.1. The Authorizer shall perform the following using Attachment 8, Clearance Authorization Checklist.

1. REVIEW the comments/Special Instructions for applicable information.
2. REVIEW the C/O for plant/conditions impact prior to authorizing execution of the C/O.
3. REVIEW THE C/O for redundant train or other unit operability concerns/impact.
4. VERIFY any required testing is completed, prior to performing the clearance activity in order to comply with requirements, e.g., Tech Spec requirements.
5. VERIFY applicable procedure prerequisites are satisfied.
6. VERIFY Tech Spec Limiting Conditions for Operation (LCO) and any administrative requirements are declared or closed out and properly documented as applicable.
7. CHECK that the risk potentials and Reactivity/Operational/Atmospheric/

Environmental Risk critical steps are correctly identified and required mitigating actions performed appropriately.

8. VERIFY On-line Risk, Shutdown Risk and any applicable databases are updated as required.
9. DETERMINE if the risk associated with the equipment manipulations required by the C/O require application of the HLA process and INITIATE THE HLA process if required.
10. VERIFY Fire Protection and Barrier Breach required actions initiated/secured.
11. TAKE the C/O Checklists to Distributed status and assemble Checklist paper copy and tags. The C/O Checklist shall be either the Master or a Duplicate, not a Review.
12. DESIGNATE on the C/O Checklist what type of verification shall be used (CV or IV) per the verification procedure if applicable.
13. INITIAL or SIGN the Checklist to record authorization of the C/O Checklist execution.
14. ASSIGN the C/O to be performed.

OP-AA-109-101 Revision 9 Page 38 of 86

15. For lift activities, in addition to the steps above, PERFORM the following:

A. VERIFY that all attached work is at the proper status for the lift activity.

If attached W/O are < status 48 (working), then the holder providing final release SHALL enter the reason why the clearance protection is no longer required on the Holder Notes Panel in Passport.

B. SPECIFY the principle equipment positioning and lift inspection requirements on the C/O work order task page for each work order task.

C. VERIFY that the applicable Post Maintenance Test (PMTs) are coordinated with Partial and Final Clear Checklists if desired.

D. INCLUDE any applicable valve and equipment lineup checklists with the lift activity.

E. VERIFY no WTLs in use by reviewing Contacts Panel.

F. VERIFY all Supervisors and Lead Workers have released the C/O.

10.4. Executing Clearance Checklists 10.4.1. The following shall be performed using the C/O Checklist and a copy of the Attachment 10, Clearance Manipulation Prejob Brief Checklist.

1. C/O Placement Activities:

NOTE: Tag plus devices to be used will be identified by the dispatching Supervisor during C/O placement Pre-job brief.

A. PARTICIPATE in the C/O prejob brief where all questions and issues will be resolved or addressed.

B. NOTIFY Radwaste prior to draining significant amounts of fluids from systems that could affect waste processing.

C. Prior to performing any equipment manipulations, INFORM the affected Reactor Operator or dispatching Facility of the planned C/O.

D. EXECUTE the C/O Checklist actions with Checklist in hand:

1. FOLLOW all actions as instructed during the C/O prejob brief.
2. FOLLOW the proper sequence specified.
3. PLACE equipment in the positions/conditions specified.
4. PLACE C/O Tags as required.
5. INSTALL Tags Plus Devices or implement the methodology to be used as discussed in the prejob brief.

OP-AA-109-101 Revision 9 Page 39 of 86 E. REVIEW/UPDATE Tag placement status after all steps are performed.

F. NOTIFY the Shift Management placement steps are complete and any difficulties encountered.

G. STATUS C/O ready for work electronically.

H. FILE the C/O documents appropriately.

2. C/O Removal Activities:

A. VERIFY no active WTLs by reviewing the C/O Contacts Panel.

B. VERIFY the C/O is released electronically and attached W/Os are complete. For W/Os that are open, INVESTIGATE reason and DETERMINE if it is acceptable to remove the C/O with the work at the current status. This information can be found on the T214 Holders Panel Notes or the T313 Holders History Panel in the notes.

C. PARTICIPATE in the C/O prejob brief where all questions and issues will be resolved or addressed.

D. INFORM the affected Reactor Operator or dispatching Facility of the planned C/O manipulation prior to performing any equipment manipulations.

E. EXECUTE the C/O Checklist actions:

1. FOLLOW all actions as instructed during the C/O prejob brief.
2. PEFORM the pre-lift visual inspection of the equipment that was worked on for proper housekeeping and equipment condition (OP-AA-108-106 Equipment Return to Service).
3. FOLLOW the proper sequence specified on the C/O checklist.
4. LIFT C/O Tags as required and remove Tags Plus devices that were installed.
5. PLACE equipment in the positions/conditions specified on the C/O Checklist.
6. ACCOUNT for removed Tags.

F. REVIEW/UPDATE Tag removal status after applicable steps are performed.

G. NOTIFY the Shift Management removal steps are complete and any difficulties encountered.

H. COMPLETE the C/O electronically.

I. If C/O Tags have been hung or rehung, then SET C/O to ACTIVE status.

OP-AA-109-101 Revision 9 Page 40 of 86 10.4.2. PERFORM any post C/O manipulation activities required per Attachment 8, Clearance Authorization Checklist.

1. ENSURE/DIRECT the performance of any required Boundary Verification.
2. FOLLOW UP on any issues identified during the C/O manipulation.
3. NOTIFY working group or testing group as appropriate.
4. COMPLETE any Tech Spec related actions or compensatory actions as required.
5. ENSURE that the C/O activity is logged appropriately.
6. ENSURE that any handwritten notes found on the original C/O hardcopy are entered in the database as appropriate.
7. STATUS C/O appropriately and FILE the C/O documents as required.
11. PERFORMING WORK UNDER CLEARANCE PROTECTION NOTE: Attachment 11, Supervision Clearance Acceptance/Release Checklist, Attachment 12, Lead Worker Clearance Checklist, and Attachment 13, Worker Clearance Checklist (only if a General Worker is on the job), are required to be completed during C/O accept and release activities but are not required to be retained as quality records after work is complete. COMPLETE only one of each applicable type for each crew. Not required for WTO activities.

11.1. Clearance Accepting and Releasing Standards 11.1.1. All appropriately qualified Exelon employees and specifically designated non-Exelon employees will electronically ACCEPT (sign-on) and RELEASE (sign-off) required C/Os daily. The exception to this is Supervision who may remain signed on to the C/O for the duration of the work to ensure boundary changes have not occurred without their knowledge.

1. Workers using ESO should always enter a release reason of FC, regardless of the type of checklist.
2. Supervision should enter either TL, PC, or FC for the release reason, as required.

11.1.2. Visitors performing work under the protection of a Clearance Order must attend the pre-job brief for the work, sign on to the WTL, and be supervised by a qualified CO Holder or Lead Worker while in the Zone of Protection.

OP-AA-109-101 Revision 9 Page 41 of 86 11.1.3. During a Temp Lift or Partial Clear work on WOs tied to the C/O may not continue, since the zone of protection is removed. Testing facilitated by the TL may occur per work instructions, with a WO task, or testing procedure. Work attached to the C/O may continue after the Temp Lift is rehung, or the zone of protection is verified for the work that remains tied electronically after the Partial Clear is complete.

11.1.4. Exelon personnel and Supplemental Workers performing work observations, inspections, or measurements who break the plane of a clearance boundary will sign-on a hardcopy WTL per this section if they are not ESO qualified, but have received NGET which contains C&T General Awareness Training. These personnel are classified as General Workers for the purposes of this procedure.

11.1.5. If the computer program is not available, then a hardcopy WTL should be utilized for all qualified employees. An Operations Supervisor shall control these with the master copy of the C/O until the computer is restored.

11.1.6. Contract employees normally will sign on and off required C/Os via a WTL (Attachment 9) unless qualified to use ESO.

11.1.7. When a WTL is used by General Workers, the following must be performed:

1. Two unique Holders, one of which may be a qualified Lead Worker must electronically sign on to the C/O whenever a WTL is used. These individuals cannot release the C/O for each other.
2. A responsible Holder must electronically ACCEPT each C/O required for protection.
3. An individual (qualified as C&T Lead Worker) must electronically ACCEPT each C/O required for protection. This acceptance may be one time or once for each specific W/O task if desired by the Work Group.
4. It is recommended a screen print be made of the Holders panel at this point to demonstrate to the employees electronic sign-on did occur by their Holder.
5. The C&T Lead Worker will enter their own name on the Contacts Panel of each C/O and indicate that they are signed on for WTL Control (these actions are only required once per C/O for multiple WTLs).
6. The Lead Worker must CONTROL WTLs for their designated work group at an appropriate location (preferably in a binder, notebook, or file with a specific section or tab for each C/O).
7. All Employees not electronically signing on must sign their name on a WTL (Attachment 9) for each C/O required for their work. The C/O number and associated W/O number(s) will be listed on the WTL for tracking purposes.

OP-AA-109-101 Revision 9 Page 42 of 86

8. If WTLs are temporarily removed from the designated location to collect signatures, then PLACE an out card to indicate who removed the WTL and PREVENT the C/O from being released. The WTL can only be removed by someone signed on to it, to ensure safety is not compromised.
9. When all WTLs are completed and the C/O is no longer required for employee protection, the Lead Worker signed on for WTL control shall delete only their entry on the Contacts Panel in Passport and electronically sign off the C/O.
10. The expectation is to sign off WTLs prior to leaving the facility each day unless otherwise directed. The Supervisor and Lead Worker signing on electronically for WTL control should remain signed on for the duration of the work.
11. For work groups that do not have electronic sign on qualified personnel, cognizant Exelon Supervision and C&T Lead Workers can fulfill these functions.

11.1.8. A W/O task/activity requiring C/O protection must be tied to ALL necessary C/Os.

11.1.9. If a W/O is tied to a C/O or C/Os, then acceptance and releasing standards are to be applied to ALL associated C/Os.

11.1.10. No work that is directly under the protection of a C/O will start until all required C/Os have been accepted. Activities associated with the W/Os such as staging, set-up, and in-shop work that do not require protection from the C/O may be performed without the C/O being hung and without performing C/O acceptance.

11.1.11. Until the C/O has been accepted, Operations retains control of the equipment and the associated C/O.

11.1.12. Only qualified Operations personnel are permitted to manipulate components to verify position. However, non-Operations personnel may assist in establishing or improving isolation under Operations direction.

11.1.13. The on-duty Shift Manager may release for all departments under the requirements of this procedure, if there is a plant emergency.

11.1.14. No work may be performed on blocked or gagged equipment that may affect the block/gags ability to maintain isolation capabilities of the component.

11.1.15. When a C/O has been hung to control a hazard associated with entry into a work area (e.g., Traversing Incore Probes for Drywell entry, Movable Incore Detectors for Containment entry, etc.) as directed by an approved procedure that establishes and maintains safe environmental conditions in the area (e.g. Drywell Entry Procedure, Containment entry Procedure, etc.), work will not be tied to the C/O, and acceptance and releasing standards do not apply.

OP-AA-109-101 Revision 9 Page 43 of 86 NOTE: With proper Authorization, the Safety Verification walk down may be performed by the work group at the same time the C/O or Worker Tagout is being hung. Acceptance and verification of this walk down against what Tags are physically placed must still be performed prior to work start.

11.1.16. The Supervision is responsible to ENSURE a safety verification walk down of the required isolation points occurs.

11.1.17. If a walk down is not possible, alternate means may also be utilized to determine proper system isolation. These could include control power lights extinguished, drains no longer flowing fluid, piping for hot systems cold, observation via remote means such as an ALARA camera, pressure gauges reading zero (examples provided in this list are not all inclusive, and all items on list do not have to be checked).

11.1.18. Before starting work on equipment that has been tagged out, the Holder shall verify isolation and/or deenergizing of the equipment has been accomplished. If normally energized parts will be exposed to contact by an employee while the equipment is deenergized, a test shall be performed to ensure that these parts are deenergized (Test Before Touch).

11.1.19. If the Employee (Lead Worker or General Worker) is not on site and the C/O must be released, then the Supervision releasing the C/O shall perform the following:

1. Try to contact the employee by phone or other means. If the employee cannot be contacted, STOP here and continue with step 2. If the employee is contacted successfully, perform the following 2 steps.

A. DOCUMENT the employees permission to release them from the electronic sign-on using the holders panel in Passport or if applicable on the paper WTL.

B. INITIATE an Issue Report documenting the circumstances as to why the employee did not release themselves from the C/O..

2. VERIFY that the employee is not at the facility. If working outside of the Protected Area, then they must be contacted by phone or in person, or verified not in the work area prior to releasing the C/O. COMPLETE the actions listed in Attachment 15, Documentation for Release of Another Employees C/O Protection.
3. RECORD the absence of the employee on the C/O Holders Panel in the notes or on the paper WTL. INITIATE an Issue Report documenting the circumstances as to why the employee did not release themselves from the C/O.
4. If applicable, REMOVE the employees name from the WTO Tracking List Tag by single line out, initial, date.
5. ENSURE that the employee is notified of electronic release before they resume work at the facility. FORWARD the completed Attachment 15 to the site Clearance Coordinator in Operations for trending.

OP-AA-109-101 Revision 9 Page 44 of 86 11.1.20. If an employee is on site they are required to sign off the C/O or WTO themselves.

Extenuating circumstances such as an injury requiring medical attention or radiological issues may require a Supervisor to follow the same process to sign the worker off, as if they are offsite. This allowance is not intended for schedule convenience and should be used sparingly with Operations approval. Document the circumstances in an IR for each occurrence to allow trending as a Level 4 C&T IR.

11.1.21. Supervisors not actually performing work under protection of a C/O may be released by other Supervisors when work is completed to facilitate system restoration or test runs. This should be discussed at turnover between the cognizant supervisors.

11.1.22. When W/O tasks attached to a C/O are rescheduled such that they will not be worked under the C/O, then the Working Group Supervisor shall ensure that the work is to a point that the C/O may be cleared and the W/O Tasks are properly statused.

11.1.23. W/O Tasks may be attached to multiple C/Os that are not all required to be in the ACTIVE status to start work. This will occur when contingency C/Os are preplanned or when C/Os are written to facilitate different stages of tasks with broad scopes of work.

11.1.24. If there are uncertainties over which C/Os must be accepted, then Operations must be consulted for direction.

11.1.25. Steps listed on the boundary report that are not part of the zone of protection are not required to be verified and may be N/Ad. (Example: control switches that do not provide isolation).

11.1.26. If an individual is unable to release the C/O, then it is the responsibility of Supervision from the same department with knowledge of the work to release the C/O per the requirements of this procedure.

11.1.27. Prior to releasing a C/O to support a Partial Clear or Dual Function Checklist, all Holders must understand how the boundaries will change and any system dynamics such as valving in a section of piping that was previously drained. It is the responsibility of the Supervision requesting the release to explain the boundary change and obtain concurrence.

11.1.28. Before work is started under a Mode Dependent or Condition Dependent C/O, the Maintenance Prejob Brief will discuss the following as listed in the C/O Special Instructions. If the condition is being controlled under the direction of a governing procedure (e.g., Reactor Head Disassembly/Reassembly), then the briefings are not required to be repeated for each condition change.

1. Basis for using this type of C/O.
2. Dependent condition to be maintained or procedure governing the condition.

OP-AA-109-101 Revision 9 Page 45 of 86 11.2. Supervision Clearance Activities 11.2.1. For crews performing physical work under the protection of a C/O, the supervision directly in charge of the personnel performing the work shall be signed on as a Holder.

For contract work crews, the Holder shall be the Supervisor in charge of the work crew or the contract area supervisor. Exelon Supervision may fulfill this function.

11.2.2. When Exelon Supervision is the Holder, and that person becomes the employee doing work (example Operational Analysis personnel), no additional Holders are required to sign on to fulfill the requirements of this procedure.

11.2.3. To direct work under C/O protection, the Supervision shall perform the following (Attachment 11, Supervisor Clearance Acceptance/Release Checklist shall be used):

1. IDENTIFY all proper C/Os (may be multiple) to provide protection for the work.
2. VERIFY that the applicable work order tasks are attached to the proper C/Os.
3. ADD their own USERID to Holder panel FOR ALL NECESSARY C/Os, if not already listed.
4. ACCEPT the C/O to prevent the removal of C/O Tags during performance of the Safety Verification.

NOTE: The work group may perform the Safety Verification at the same time the Clearance/Worker Tagout is being placed. A copy of the FH checklist or WTO can be substituted for the Boundary Report. The Boundary Report must still be verified against the FH checklist used to perform the verification and signed off after the C/O has been placed.

11.2.4. PREPARE or ENSURE that a Clearance Order Boundary Report is properly prepared.

11.2.5. ENSURE that the following are performed:

1. A proper prejob brief is performed including a discussion of work hazards, a discussion of Special Instructions including Exceptional details. (This can be a reverse style brief with the crew.)
2. All employees ACCEPT the C/O or sign-on the WTL as applicable.
3. Boundary report is used to walk down required isolations by a representative of the work group prior to starting work.

OP-AA-109-101 Revision 9 Page 46 of 86 11.2.6. The Supervision releasing a C/O for Temp Lift, Final Clear or Partial Clear shall perform the following (reference Attachment 11, Supervisor Clearance Acceptance/Release Checklist):

1. ENSURE that the equipment, as pertains to their scope of work is:

A. In a condition that can support the requested testing prior to release.

B. Cleared of personnel C. Cleared of obstructions D. Cleared of grounding devices if applicable

2. When releasing for Final Clear, then Supervision shall ENSURE that their specific work is complete and correctly statused for the applicable condition of the work.

A. If attached Work Orders are < status 48 (working), then the Holder providing final release SHALL enter the WO number, task, and reason why the clearance protection is no longer required on the Holder Notes Panel in Passport or Holders History Panel if the Holder Notes Panel is no longer open for editing, in Passport.

B. If the Holder had previously released with a release reason other than FC and all tags are lifted, then the Holder providing final release SHALL document the release on the Holders History Panel in Passport.

3. VERIFY all employees electronically released or signed off WTLs and associated WTL entries on Contacts Panel are deleted.
4. RELEASE the C/O.

11.2.7. Executing/Releasing Holder Acceptance Lock

1. The Supervisor applying the Holder Acceptance Lock will:

A. APPLY holder acceptance lock.

B. VERIFY that ALL required Supervisors and Employees have electronically released the C/O.

C. MODIFY C/O as required.

D. PERFORM required work steps and testing.

2. If a Temp Lift or other boundary manipulation was performed, then VERIFY with an Operations Supervisor the COMPLETION of necessary Checklist to establish a safe working boundary.
3. REMOVE THE Holders Acceptance Lock. If the Supervisor that imposed the Holder Acceptance Lock is not on site and the C/O must be released, then the Supervisor releasing the Lock shall determine that all required isolation points have been rehung to establish the necessary zone of protection for all attached work prior to releasing.

OP-AA-109-101 Revision 9 Page 47 of 86 11.3. Lead Worker Clearance Activities (ESO Qualified) 11.3.1. To start work under C/O protection, each crew shall perform the following (Attachment 12, Lead Worker Clearance Checklist, shall be used). In the case of contractors, the designated Lead Worker should perform these actions:

1. VERIFY Supervision sign-on as holder (Passport, screen prints). This prevents C/O modification.
2. PARTICIPATE in, or ENSURE a designee conducts the prejob brief as directed by Supervision where a discussion of hazards and protection provided by the C/O will take place.
3. PERFORM, have a designee perform, or VERIFY a Safety Verification has been performed by another crew or crewmember for the applicable C/O boundaries. (Each crew or crewmember does not have to perform a safety verification if another crew already performed one.)
4. VERIFY applicable work order tasks are electronically attached to the proper C/Os. This can be done by using screen prints or direct viewing at a computer.
5. ACCEPT the C/O electronically or sign on to a WTL.
6. If accepting as the individual responsible for a WTL, VERIFY the required actions are performed per step 11.1.7.
7. PERFORM work.
8. At least one crewmember DOCUMENT the as-found position (and another crewmember provides independent verification that the component was restored to the as-found position) of manipulations of untagged components within the C/O boundary in an approved procedure or process.

NOTE: For purposes of the following step, 'stop work' is meant to apply only to situations when there are no immediate plans for an individual to return to a specific task under the C/O.

9. When employees stop work under C/O protection, the Lead Worker shall PERFORM the following:

A. At least one crewmember, NOTIFY Supervision work has stopped.

B. RELEASE C/O or sign off WTL.

OP-AA-109-101 Revision 9 Page 48 of 86 11.3.2. To restart work that was stopped under C/O protection, each crew shall perform the following (Attachment 12, Lead Worker Clearance Checklist, shall be used). The designated Lead Worker should perform these actions:

1. VERIFY each new day of work that the Supervisions Electronic acceptance remains in place since the last time work was performed and that no boundary changes were made. (This can be verified by viewing the C/O, discussing the status with the cognizant Supervision, or using screen prints of the applicable screens).
2. ACCEPT C/O or sign on WTL.
3. PERFORM, or have a designee PERFORM, or VERIFY another crew or crewmember performed a Safety Verification if any required boundaries changed. (Each crew or crewmember does not have to perform a Safety Verification if another crew already performed one.)
4. VERIFY work order tasks remain attached to the C/O.
5. ENSURE new crewmembers receive a Brief.
6. RESTART work.

11.4. General Worker Clearance Activities (Not ESO Qualified) 11.4.1. To start work under C/O protection, General Workers, who can be Exelon or non-Exelon employees who are not ESO qualified, shall perform the following (Attachment 13, General Workers Clearance Checklist, at least one per crew, shall be used):

1. PARTICIPATE in prejob brief, which should provide information in regards to Work Group holder signed-on to C/O, and Safety Verification walk down status.
2. SIGN ON to a WTL and VERIFY with Supervision requirements of 11.1.6 have been satisfied.
3. PERFORM work.
4. When done with work for the day, SIGN OFF the WTL.
5. To restart work each new day, PERFORM Steps 11.4.1.1 through 11.4.1.3.

OP-AA-109-101 Revision 9 Page 49 of 86

12. TEMP LIFTS AND PARTIAL CLEARS 12.1. Requesting Temp Lifts and Partial Clears 12.1.1. The requesting Supervision or Operations personnel shall perform the following:
1. CONTACT and COORDINATE with all affected Supervision on this C/O and affected C/Os to discuss the impact on all work attached to the C/O. During a Temp Lift or Partial Clear, work on WOs tied to the C/O may not continue, as the zone of protection may be removed.

NOTE: Supervision should not release for TL or PC until the checklist is approved if they wish to verify that only the steps allowed to be lifted are listed on the checklist.

2. NOTIFY all Holders to release (sign-off) for TL, PC, or FC. In addition, NOTIFY personnel listed on the Contacts Panel to have WTL tracked employees sign-off, release for FC, and remove their information from the contacts panel.
3. CREATE the required Checklist providing the following information (C/O tags can be hung and lifted at the same time on a PC Checklist).

A. LIST the equipment to be lifted/hung and PROVIDE the following information on the checklist notes panel:

B. Reason for the Hang/Lift C. When the Hang/Lift is required D. Who to contact when the Hang/Lift is complete E. Expected duration if a TL F. Any special instructions or conditions needed

4. INFORM the Clearance Coordinator or Operating Shift Management of the need for Hang/Lift.
5. Operations should review the checklist submitted and make required modifications in accordance with Clearance Checklist development and approval standards, prior to approving the submission.

OP-AA-109-101 Revision 9 Page 50 of 86 12.2. Executing Temp Lifts and Partial Clears 12.2.1. Operations personnel will perform the following:

1. VERIFY that ALL Supervision and employees have electronically released the C/O.
2. If performing a Temp Lift, APPLY the Holders Acceptance Lock or SET the status of the C/O to SUSPEND to prevent released or new Supervision from resuming work until the required tags have been rehung.

A. If all tags are lifted and the status of the C/O goes to AWT/CLOS, then applying the Holders Lock or setting the status of the C/O to SUSPEND is not required.

3. EXECUTE Checklists per Section 10.4, Executing Clearance Checklists.
4. If a Temp Lift was performed, COMPLETE a Rehang Checklist to establish a safe working boundary, and SET the status of the C/O to ACTIVE, or REMOVE the Holders Acceptance Lock. NOTIFY working group(s) as applicable.
5. If a Rehang is not required for the remaining work, then SET the status of the C/O to ACTIVE, or REMOVE the Holders Acceptance Lock. NOTIFY working group(s) as applicable.
6. If components are left in an abnormal position after a Temp Lift Checklist, then CONSIDER ADDING Not Tagged steps to a FC Checklist to ensure proper system alignment during Final Clear.
7. Additional TL or PC checklists may be performed with authorization from Holders that originally released for TL or PC.
13. WORKER TAGOUT (WTO) PROCESS 13.1. Purpose 13.1.1. To establish a process that provides personnel protection that may be used in place of electronic tagging processes.

13.1.2. Also establishes a process that is available for use when the electronic process is not available (i.e., Network outage) and tagging is required to maintain safety for personnel and or plant equipment.

13.1.3. The same standards apply for technical rigor in development, reviews, authorization and field application that apply to the electronic process.

13.2. Scope 13.2.1. The process is designed to support work activities that are of limited scope and duration with a limited number of isolation points.

13.2.2. The WTO process may be used at request of Working Group with Operations approval.

OP-AA-109-101 Revision 9 Page 51 of 86 13.3. Administrative Requirements 13.3.1. Placed WTOs may remain in place for the duration of the work.

13.3.2. MAINTAIN a log of WTO transactions. An electronic database may be used versus hard copy Log (Attachment 14 Part 5, Worker Tagout Log).

13.3.3. The WTO process uses the same Danger and Information Tags as the Clearance and Tagging process.

13.3.4. The requester or Operations shall complete Attachment 14, Worker Tagout Form, Parts 1 through 6, as applicable. Operations shall review and approve the WTO using Attachment 5, Clearance Preparation/Approval Checklist and document approval in the WTO checklist signature blocks.

13.3.5. Worker Tagout tags shall contain the following information:

1. Equipment Tag number and name
2. Required Component position/condition
3. Worker Tagout number 13.3.6. WTO Tracking List Tags (shown in Attachment 14 Part 6) shall contain the following information.
1. A header stating WTO Tracking List Tag (all workers on WTL sign here)
2. WTO #
3. Date hung
4. Department
5. Signature of ALL workers under the protection of the WTO.

13.3.7. If the Shift Manager determines that the WTO must be removed to support operational needs, then the Shift Manager may order the removal of any WTO under the requirements of this procedure.

13.3.8. The original copy of the WTO once Placed, will normally be in the possession of the Work Group designee when actively performing work protected by the WTO. This will assure the zone of protection remains in place during the work.

13.3.9. When Work is stopped (other than routine breaks) and at the end of each shift, the WTO will be returned to Operations Shift Management.

13.3.10. A copy of the WTO should be maintained in a WTO Log Book unless an electronic log/database is being maintained. The purpose of this copy is as a back-up in the event the Master Copy is lost, contaminated, or destroyed. Therefore, the Copy or electronic database will be updated to remain current. This will allow use of the copy in the event the original is lost, contaminated, or destroyed.

OP-AA-109-101 Revision 9 Page 52 of 86 13.4. Performing a Worker Tagout NOTE: Attachments 11, 12, and 13 of this procedure are not intended for use with WTOs. They are for use with Passport C/Os.

1. PERFORM the WTO Checklist steps and verifications as required.
2. RECORD time and date placed in the WTO Log.
3. The assigned Employee shall:

A. PARTICIPATE IN or LEAD the prejob brief where a discussion of hazards and protection provided by the WTO will take place.

B. VERIFY that their W/O tasks are attached to the WTO.

C. SIGN ON the WTO by completing Attachment 14 Part 4, WTO Worker Tracking List. COMPLETE only one copy (usually the WTL provided in the WTO package).

D. VERIFY crewmembers have signed on to Attachment 14 Part 4, WTO Worker Tracking List.

E. PERFORM the Safety Verification or VERIFY that a Safety Verification has been performed for the applicable WTO boundaries.

4. The Designated Crewmember shall:

A. HANG a completed WTO Tracking List Tag on the applicable main isolation point for the WTO B. DOCUMENT tag placed for each worker on Attachment 14, Part 4, WTO Worker Tracking List. A second tag may be used for dual feed components if desired.

C. SIGN for WTL Completed Work Start on Attachment 14, Part 1.

5. PERFORM work.
6. If all work is complete or prior to leaving for the day, then the Designated Crewmember shall :

A. VERIFY all crewmembers have signed off of Attachment 14 Part 4, WTO Worker Tracking List.

B. SIGN the bottom of Attachment 14, Part 4.

C. REMOVE the WTO Tracking List Tag(s).

D. DOCUMENT tag removal on Attachment 14, Part 4, for each worker.

E. If all attached Work on WTO is complete, then RELEASE WTO for Final Clear on Attachment 14 Part 1.

7. If work is to continue or new work is to be performed by a different crew, then the oncoming crew shall PERFORM all applicable actions of section 13.4.

OP-AA-109-101 Revision 9 Page 53 of 86 13.5. Performing WTO Manipulations 13.5.1. Shift Management will REVIEW, then APPROVE or DENY the manipulation requests.

13.5.2. Designated work crewmembers will sign off Attachment 14 Part 4, releasing the WTO for the manipulation after WTO Tracking List Tag has been removed.

13.5.3. VERIFY Attachment 14 Part 4, WTO Worker Tracking List (WTL), has been signed off releasing the WTO for the manipulation. A new WTO Worker Tracking List may be started, as needed.

13.5.4. Qualified personnel will PERFORM manipulations as necessary and within the requirements specified on Attachment 14 Part 3.

13.5.5. If additional work is required, the Working Group will REQUEST rehang of the WTO and ensure the employees are briefed if the conditions changed as a result of the manipulations performed.

13.5.6. PERFORM all applicable actions of section 13.4.

13.6. Clearing the WTO 13.6.1. VERIFY all WTO Tracking List Tags are documented as removed on Attachment 14, Part 4 and all crewmembers have signed off, releasing the WTO to be cleared..

13.6.2. VERIFY the Designated Crewmember has signed off Attachment 14, Parts 1 and 4 releasing the WTO for final clear.

13.6.3. PERFORM the WTO clear.

13.6.4. COMPLETE the WTO Log.

13.6.5. DISCARD the WTO tags.

13.6.6. FILE and RETAIN the completed WTO for six months.

OP-AA-109-101 Revision 9 Page 54 of 86 13.7. Facilities Maintenance (FM) Worker Tagout Process 13.7.1. This section describes a process in which Exelon FM personnel that are properly trained and qualified may prepare, review, approve, apply, manipulate, and remove their own Worker Tagouts.

13.7.2. The same standards apply for technical rigor in development, authorization, and field application that apply to the C&T process. Zones of protection must be safe and documentation accurate. Due to the limited scope and simple nature of the equipment, a WTO challenge is not required.

13.7.3. Preparation, Review, and Approval of FM WTOs will be documented via Attachment 4.

13.7.4. The same standards apply for tagging practices such as tags used, attachment methodology, and self-check practices. It is acceptable to create stickers that are placed on Exelon Danger tags, or the tags may be legibly handwritten with indelible black ink.

13.7.5. FM Worker Tagout tags shall contain the following information:

1. Equipment Tag number and name or Identifying Noun Name if not numbered
2. Required Component position/condition
3. FM Worker Tagout number 13.7.6. The application of WTOs for FM activities is normally limited to non-plant related equipment. Refer to Sites Matrix or listing for specific non-plant related equipment identification included in the FM program.

13.7.7. FM WTOs shall not be applied to Tech Spec, ODCM, or Power Block systems.

13.7.8. For FM WTOs the preparation and independent review is performed by FM technicians at that site using Attachment 4, FM WTO Preparation/Approval Checklist. The FM Supervisor authorizes the WTO for placement. If there is any question regarding appropriateness of isolation points or authorization for placement contact the on shift operating crew for assistance.

13.7.9. CONSIDER whether the work can be done without a WTO. Refer to Attachment 1, Activities That Do Not Require a Clearance.

13.7.10. When it is determined an FM WTO is required utilize the forms and tags shown in Attachment 14 to document isolation points, work details, sign on and off, special instructions, equipment manipulations for testing, and FM WTO log entries.

13.7.11. When Work is stopped (other than routine breaks) and at the end of each shift, the WTO will be returned to FM Supervisor.

OP-AA-109-101 Revision 9 Page 55 of 86 13.7.12. FM shall CREATE and MAINTAIN an up to date log for FM Worker Tagouts at each site. The WTOs shall be numbered in the following manner; FM-YYYY-ZZZZ, with YYYY being the year, and ZZZZ being a sequential number starting at 0001 each new year.

13.7.13. The scope of work shall be clearly IDENTIFIED and REFERENCED on the WTO.

13.7.14. To go to work each day the FM Technician does the following:

1. ATTEND a PJB with supervisor to discuss scope of work, WTO protection, and any required manipulations for testing.
2. OBTAIN approved FM WTO and proceed to field, hang WTO, and PERFORM work.
3. When work is complete, if authorized and required, PERFORM manipulations to conduct post maintenance test. Either rehang WTO for additional work or final clear if work is complete.
4. Return documentation to FM Supervisor.
14. EQUIPMENT TAGOUT PROGRAM PROBLEM RESPONSE NOTE: The Equipment Tagout Program Desk Top Instructions are an excellent source of program usage information. They are located in the Passport web page under Functional Area Documents.

14.1. When a problem is identified in the Equipment Tagout Program, then FOLLOW these steps:

14.1.1. CONTACT the Clearance Coordinator or other Site individual knowledgeable in the program for assistance.

14.1.2. WORK to determine the source of the problem.

1. REVIEW the history of the C/O with the problem to determine if a previous manipulation is causing the problem.
2. REVIEW the list of known bugs and work-arounds.
3. REVIEW the desktop instructions.
4. REVIEW the training materials.

14.1.3. If necessary, then CONTACT the site IT individual responsible for Passport support for assistance.

OP-AA-109-101 Revision 9 Page 56 of 86 14.2. If the problem cannot be resolved with resources identified above, then CLASSIFY and RESPOND to the problem as listed below.

14.2.1. Non-urgent problems

1. The Clearance Coordinator will REPORT non-urgent problems to the Passport support organization using the Test Director process.

14.2.2. Urgent problems

1. An urgent problem is one that prevents the performance of physical work at the site or that backs up the work preparation process to the point that scheduled work activities or major plant evolutions will be affected due to the problem.
2. There are usually no work-arounds for urgent problems or the work-arounds cannot be completed without significant delays in the sites work flow or scheduled activities.
3. REPORT urgent problems using the Help Desk reporting process.

A. STRESS the importance of the problem when calling it in to the Help Desk and ASK for immediate attention if required.

B. The Help Desk will Hot Page the program experts to investigate the problem if required.

4. CONTACT the Clearance Coordinators at the other Sites and Corporate Nuclear Duty Officer for all urgent program issues via email and or phone calls to make them aware of possible impacts on work at multiple sites.

14.2.3. New software bugs

1. The Clearance Coordinator will REVIEW the latest bug list to verify that the problem is not already identified and CONFIRM that a real bug exists by trying to repeat it the non-Production regions of Passport.
2. Then REPORT verified program bugs to the Passport support organization using the Test Director process.

OP-AA-109-101 Revision 9 Page 57 of 86 NOTE: It is not possible to cover all possible scenarios resulting in the inability to complete a Checklist. Therefore, the following is generic guidance only. ALL steps may not be required to resolve the problem or additional steps may be required that are not covered here. It is ultimately the responsibility of the Shift Management to determine the Scope of the problem and the recovery plan.

14.3. Hang Checklist Cannot be Completed 14.3.1. The Shift Management shall DETERMINE the scope of the problem and a recovery plan for the checklist.

1. If the problem is identified prior to electronically signing off steps in the Equipment Tagout program and no placed Tags will be removed, then the Checklist may be modified to correct the steps, and then taken back to Distributed.
2. UPDATE the original Checklist or TRANSFER hard copy Checklist signoffs from the original Checklist to the new Checklist for correct actions already taken.
3. ATTACH the original Checklist to the new Checklist as a record if necessary.
4. If the problem is on a First Hang Checklist and is identified after some electronic signoffs have been entered, but the problem includes only steps that have not been signed off in the Equipment Tagout Program and no placed Tags will be removed, then the Checklist may be modified to correct the steps not yet signed off.

A. ATTACH the original Checklist to the new Checklist as a record, or UPDATE the original Checklist.

WARNING NEVER REMOVE A C/O TAG FROM THE FIELD AFTER A STEP HAS BEEN PERFORMED AND ELECTRONICALLY SIGNED OFF.

5. If the problem is on a hang Checklist that includes steps that have been signed off in the Equipment Tagout program that must be changed, or it has been determined that the Checklist will not be performed, then the steps may be handled with the undo steps option in the Equipment Tagout Program.

The C/O Tags can then be removed from the field and the Checklist set to the MODIFY status to be corrected after checking the associated panel first and performing UNDO STEPS if required.

OP-AA-109-101 Revision 9 Page 58 of 86 14.4. Lift Checklist Cannot be Completed 14.4.1. Operations Shift Management shall DETERMINE the scope of the problem and a recovery plan for the Checklist.

WARNING IF A CHECKLIST NEEDS TO BE MODIFIED FOR CORRECTIONS, VERIFY ALL STEPS LIFTED IN THE FIELD ARE DOCUMENTED ELECTRONICALLY.

THIS WILL PREVENT ADDITIONAL C/OS FROM TAKING VIRTUAL CREDIT FOR TAGS NOT CURRENTLY PLACED.

1. If the problem is identified prior to electronically signing off steps in the Equipment Tagout program, then the Checklist can be set to MODIFY, required changes made, and then taken back to DISTRIBUTED.

A. UPDATE the original Checklist or TRANSFER hard copy Checklist signoffs from the original Checklist to the new Checklist for correct actions already taken.

B. ATTACH the original Checklist to the new Checklist as a record if required.

2. If the problem is on a lift Checklist that includes steps that have been signed off in the Equipment Tagout program that must be changed, or it has been determined that the Checklist will not be performed, then the following must be performed:

A. REHANG tags and document on lift Checklist.

B. UNDO steps electronically in the Equipment Tagout program.

C. RETURN the lift Checklist to the MODIFY status for correction.

D. ATTACH all revisions of the Checklist.

E. ENSURE a C/O pre-job brief is performed prior to the performance of the modified Checklist.

OP-AA-109-101 Revision 9 Page 59 of 86 14.5. Unavailability of the Electronic C/O Program (Equipment Tagout) 14.5.1. If the Equipment Tagout program is unavailable, then no lifting of C/O Tags placed and under control of the Equipment Tagout program is allowed except under the following conditions:

1. Tags are required to be lifted to meet Technical Specification action statements, or;
2. Tags are required to be lifted to prevent a unit shutdown or de-rate, or;
3. Tags are required to be lifted to ensure health and safety of the public and personnel safety, or;
4. Tags are required to be lifted for critical path work.

14.5.2. Prior to lifting any Equipment Tagout Program controlled C/O Tags when the Equipment Tagout program is unavailable:

1. The Shift Manager must determine that one of the above criteria is satisfied.
2. Operations must review all work in progress to verify it will not be impacted by the lift activity.
3. Any work that would be affected must be stopped until adequate protection is restored.
4. Any additional work started must also be reviewed for impact by the lift activity.

14.5.3. Shift Management shall process a manual lift checklist, documenting actions on hardcopy, per the requirements of this procedure and lift the required Tags. The Equipment Tagout program shall be updated when the system becomes available.

14.5.4. When the Equipment Tagout program is unavailable and new work is required to be performed, then the WTO process shall be used.

15. DOCUMENTATION - None

OP-AA-109-101 Revision 9 Page 60 of 86

16. REFERENCES 16.1. Commitments - None 16.2. User References - None 16.3. Writer References 16.3.1. ComEd Company Directive No. 68 Hazardous Energy Control Program 16.3.2. HU-AA-101, Human Performance Tools and Verification Practices 16.3.3. HU-AA-1211, Briefings - Pre-job, Heightened Level of Awareness, Infrequent Plant Activity and Post-Job Briefings 16.3.4. HU-AA-1212, Technical Task Risk/Rigor Assessment, Pre-job Brief, Independent Third Party Review, and Post-job Brief 16.3.5. CC-AA-112, Temporary Configuration Changes 16.3.6. OP-AA-108-106 Equipment Return to Service 16.3.7. LS-AA-104, Exelon 50.59 review Process 16.3.8. LS-AA-104-1000, Exelon 50.59 Resource Manual 16.3.9. WC-AA-104 Integrated Risk Management 16.3.10. CC-AA-206 Fuse Controls 16.3.11. OSHA Regulations 29 CFR 1910.145, Specifications for Accident Prevention Signs and Tags 16.3.12. OSHA Regulations 29 CFR 1910.147, The Control of Hazardous Energy (Lockout/Tagout) 16.3.13. OSHA Regulations 29 CFR 1910.269, Electric Power Generation, Transmission, and Distribution 16.3.14. OSHA Regulations 29 CFR 1910.333, Selection and Use of Work Practices 16.3.15. INPO 87-002 Good Practice OP-203, Tagging Procedures for Protection of Personnel, Components, and Systems 16.3.16. INPO 96-008, Guidelines for the Conduct of Operations at Nuclear Power Stations 16.3.17. WC-AA-101-1002 On-line Scheduling Process 16.3.18. TQ-AA-174, Industrial Safety Training Program 16.3.19. Electric Power Research Institute (EPRI) Clearance and Tagging Guidelines for Nuclear Electric Generating Stations Report 1015082, Final Report, December 2007.

16.3.20. EN-AA-103 Environmental Review

OP-AA-109-101 Revision 9 Page 61 of 86 16.3.21. OP-AA-108-107-1002, INTERFACE PROCEDURE BETWEEN COMED / PECO AND EXELON GENERATION (NUCLEAR / POWER) FOR TRANSMISSION OPERATIONS

17. ATTACHMENTS 17.1. Attachment 1, Activities That Do Not Require A Clearance 17.2. Attachment 2, Examples of Exceptional Clearances 17.3. Attachment 3, Clearance Requester Checklist 17.4. Attachment 4, FM WTO Preparation/Approval Checklist 17.5. Attachment 5, Clearance Preparation/Approval Checklist 17.6. Attachment 6, Clearance Walk Down Sheet 17.7. Attachment 7, C/O Challenge Guidelines 17.8. Attachment 8, Clearance Authorization Checklist 17.9. Attachment 9, Worker Tracking List 17.10. Attachment 10, Clearance Manipulation Prejob Brief Checklist 17.11. Attachment 11, Supervision Clearance Acceptance/Release Checklist 17.12. Attachment 12, Lead Worker Clearance Checklist 17.13. Attachment 13, General Worker Clearance Checklist 17.14. Attachment 14, Part 1 Worker Tagout Form Hang/Lift Section 17.15. Attachment 14, Part 2 Worker Tagout Form Special Instructions Section 17.16. Attachment 14, Part 3 Worker Tagout Form Testing/Manipulation Section 17.17. Attachment 14, Part 4 Worker Tagout Worker Tracking List (WTL) Section 17.18. Attachment 14, Part 5 Worker Tagout Log 17.19. Attachment 14, Part 6 WTO Tracking List Tag 17.20. Attachment 15, Documentation for Release of Another Employees C/O Protection 17.21 Attachment 16, External Energy Injection (EEI) Notification

OP-AA-109-101 Revision 9 Page 62 of 86 ATTACHMENT 1 Activities That Do Not Require a Clearance Page 1 of 1 NOTE: If these activities extended beyond the employees shift, then Operations will be notified. A WTO or C/O will be placed to control the required isolations for the activity.

This Attachment provides guidance to allow specific activities to be performed without a Clearance providing the work supervisor, the employee associated with the activity, and Operations agree that adequate safety will be maintained. For FM work the FM Supv and Technician are authorized to make the determination for non-plant/non power block equip.

1. Minor changes and adjustments and other minor servicing activities, which take place during normal production operations, do not require a clearance if they are routine, repetitive, and integral to the use of the equipment for production, the activity is controlled by approved plant procedures or work order that include direction to manipulate and restore components, and the isolation point disconnection is accessible, visible to, and under the sole control of the employee performing the activity.

EXAMPLES:

Instrument Maintenance work that requires isolation of instruments Lifting of electrical leads, when the work group agrees that work can be performed safely while energized Filter changes Charging accumulators with cover gas Nitrogen or other gas bottle change-outs Service Air and Instrument Air hose connections, pipe cap and fitting connections Flange and pipe cap removal and installation for general plant support activities.

Hose connections for general plant activities (breathing air, fire protection, demineralized water, etc.)

2. Work on cord and plug connected electric equipment for which exposure to the hazards of unexpected energization or start-up of the equipment is controlled by the unplugging of the equipment from the energy source and by the plug being under the exclusive control of the employee performing the servicing or maintenance.
3. If work is being performed that involves the de-energization of transmission and distribution lines, the work may be performed without a Clearance providing the following two conditions exist:

Only one crew will be working on the lines or equipment The means of disconnection is accessible and visible to and under the sole control of the employee in charge of the clearance.

OP-AA-109-101 Revision 9 Page 63 of 86 ATTACHMENT 2 Examples of Exceptional Clearances Page 1 of 1

1. All required isolation points cannot be isolated.
2. Use of an MOV as a boundary isolation point when the hand wheel is inaccessible to hang a C/O Tag.
3. Use of a control switch as the sole electrical isolation point for personnel or equipment protection.
4. Use of inaccessible valve hand wheels that cannot be physically verified closed or Tag cannot be attached.
5. Lack of dual valve isolation when isolating >500 psig or >200F.
6. When a pressure boundary is tagged for internal work, or a segment within the boundary has energy potential that would create a concern for the employee, and the boundary and segment within the boundary is not depressurized and drained.
7. All stored energy cannot be relieved from within an isolation boundary or component to be worked on.
8. Use of an AOV as an isolation point when pressure cannot be removed or valve cannot be blocked in the isolate position.
9. Use of pipe plugs, line stops, or freeze seals.
10. Use of gagging/blocking devices.
11. Use of a hydraulically operated valve as an isolation point when pressure cannot be removed or valve cannot be blocked in the isolate position.
12. Use of check valves not physically restrained to provide isolation as a primary or secondary boundary.
13. Use of a Condition Dependent Clearance.
14. Use of a Mode Dependent Clearance.
15. Work in electrical components that may not be de-energized as requested due to backfeed voltages or live circuits in areas that were requested to be de-energized.
16. Tags Plus devices or methodologies cannot be employed.

OP-AA-109-101 Revision 9 Page 64 of 86 ATTACHMENT 3 Clearance Requester Checklist Page 1 of 1

() - N/A Equipment to be worked on properly identified Equipment number(s) listed Equipment name(s) listed ECR/IR submitted if equipment number assignment required Correct Unit, train, or division specified Work Order properly identified?

Work Order/Task number(s) listed Isolation requirements identified?

Mechanical Isolation required Electrical Isolation required Both mechanical and electrical Evaluate the need to install grounding devices at locations to be determined by the work group Supervision. Include required manipulations Freeze seal used?

Total Scope of work identified?

What work will be done On which components will it be done Will boundary be breached (process, cooling, or lubrication)

What procedures/surveillances and applicable steps will be performed Review clearance requests on similar work on one or both units (where applicable)

Supplemental drawings or information provided if needed?

Modification related work Other reference materials provided List any environmental risks or hazards (tritium, permit compliance equipment, hazardous material)

Issue Report submitted to Instrument Maint. To backfill drained instruments if required?

Drawing reference numbers provided?

Suggested isolation points (if known) or system configuration (i.e., venting, draining, instrument air, etc.)?

Fire Protection System Impairment information provided?

Interactions identified (If known)?

Limit Switches Interlocks Logic C/O manipulations Temp Lifts required Partial Clears required Testing activities

OP-AA-109-101 Revision 9 Page 65 of 86 ATTACHMENT 4 FM WTO Preparation/Approval Checklist Page 1 of 1 WTO # FM-____________________

EQUIPMENT _____________________________________________________________

Exceptional WTO: Environmental Risk: Atmospheric Risk:

Writer/Preparer Approver Actions to be performed: () - N/A () - N/A Preparation Brief requirements reviewed Special Instructions reviewed / entered Exceptional criteria evaluated Is an Environmental Risk created such as special sampling equipment affected, compensatory measures required, draining of hazardous materials, or systems containing refrigerant, oils, or fuels? If yes, take actions to mitigate.

Is an Atmospheric Risk created (either Breathing or Explosive)? If yes, take actions to mitigate.

WTO positions and Sequence correct Review equipment procedures for special needs in startup, shutdown, or changeover. (check vendor manuals if available)

Drain and vent requirements identified. Equipment draining requirements. Note any process lines that cant be drained, any siphon paths, hoses needed, etc.

Safety hazards (confined space, fall hazard, components not deenergized, etc.)

Walk down the equipment looking for interfaces with other equipment, components not identified (labeling missing), or incorrect on drawings.

The 5 Key Questions What are the Critical Steps in the task?

What is the Worst Thing that can go wrong?

What are the Error Likely Situations?

What Defenses are we relying upon?

What actions will assure proper configuration control?

FM Technician Writer/Preparer____________________________________/________

Name Date FM Technician Approver ________________________________________/________

Name Date FM Supervisor Authorization_____________________________________/________

Name Date

OP-AA-109-101 Revision 9 Page 66 of 86 ATTACHMENT 5 Clearance Preparation/Approval Checklist Page 1 of 4 CLEARANCE # __________________

EQUIPMENT _____________________________________________________________

Exceptional C/O: Mode Dependent: Condition Dependent:

Operational Risk: Environmental Risk: Atmospheric Risk: Reactivity Risk:

Preparation Brief:

Pre-Job Brief may be Required IF: HU-AA-1212 may be required IF:

(Initial, or N/A) (Initial, or N/A)

Writer/Preparer Approver First time for writing this type of Complex C/O which C/O? integrates several systems?

Unfamiliar with system or prints? Boundary involves Daisy Chains?

Confusing nomenclature?

Boundary impacts PLC or Black box logic?

Emergent request? Pre-Job Brief required Pre-Job Brief Discussion Items:

(, or N/A) (, or N/A)

Is there any in-house or What human performance tools external OE? will be utilized (e.g. C/O Preparer Checklist, HU-AA series procedures)?

Applicable Clearance Order preparation considerations.

Writer/Preparer Approver Actions to be performed for all checklist types:

() - N/A () - N/A Preparation Brief requirements reviewed Special Instructions reviewed / entered Exceptional criteria evaluated Containment integrity considered C/O hang (lift) risk considered (See Page 4 of 4)

C/O Operational/Reactivity/Environmental/Atmospheric (Breathing or Explosive)

Risk impact assessed and critical steps identified

OP-AA-109-101 Revision 9 Page 67 of 86 ATTACHMENT 5 Clearance Preparation/Approval Checklist Page 2 of 4 Specific actions to be performed for hang checklists: CHK # _________ Writer/Preparer Approver

() - N/A () - N/A C/O positions and Sequence correct All attached work scope understood Drain and vent requirements identified Tech Spec applicability assessed Fire Protection concerns noted / addressed C/O step types and tag types correct Requestor notified if work not isolated as requested Specific actions to be performed for lift checklists: CHK # _________ Writer/Preparer Approver

() - N/A () - N/A Lift positions / sequence appropriate for plant status Non-tagged items included in checklist as needed Fill and vent issues addressed Instrumentation backfill requirements identified Configuration control actions properly addressed?

Specific actions for Work Addition to an approved C/O: List W/Os* Writer/Preparer Approver

() - N/A () - N/A New work scope reviewed and understood Isolation point positions and tag types verified as adequate Exceptional C/O criteria evaluated Containment integrity considered Drain and vent requirements identified Special Instructions reviewed / entered Requestor notified if work not isolated as requested

  • IF C/O is placed, THEN complete ALL approvals before attaching the additional work

OP-AA-109-101 Revision 9 Page 68 of 86 ATTACHMENT 5 Clearance Preparation/Approval Checklist Page 3 of 4 Clearance Order preparation considerations Determine the scope of work:

Review and approve the Clearance Request.

Review the Work Order instructions and applicable procedures.

Identify C/O and temp lift requirements, placement of jumpers, or introductions of any energy sources.

Review any TMODs or design changes that are in progress against the system or equipment.

Review the applicable Unit Turnovers for any abnormalities or unusual conditions.

Consult with the Work Planner or SME (Fire Marshal, Engineer) if doubt exists on the scope of work and/or return the C/R if needed for further information.

Establish the Zone of Protection:

Identify electrical and mechanical drawings as needed. Refer to Passport T210 or T215 panels to identify pending document changes.

Request DCP or Mod packages as needed Prepare a sketch or outline of the protection needed including grounds.

Review equipment procedures for special needs in startup, shutdown, or changeover.

Walkdown the equipment looking for interfaces with other equipment/systems not identified or incorrect on drawings.

Submit label requests and drawing change requests as needed.

Review any historical/model C/Os for the same work scope. Compare zone of protection, Special Instructions, etc.

Verify positions correct, sequencing appropriate, tag types correct.

Identify concerns in the Special Instructions:

Equipment draining requirements. Note any process lines that cant be drained, any siphon paths, hoses needed, etc.

Daisy chained neutrals.

Safety hazards (confined space, fall hazard, etc.)

Tech Spec / TRM / ODCM requirements.

Document any Subject Matter Expert review (Fire Marshal, System Engineer, Component Engineer, etc.)

Any switching orders required, other departments needed to assist in hanging/clearing the C/O (Rad Pro, Maintenance, etc.). The Operations Planning person(s) should be notified to appropriately schedule these resources.

Include a note of any grounds that need to be installed / removed, by which department, and manipulations that may be required.

Exceptional C/O criteria evaluated.

Containment integrity considered.

Environmental concerns such as special sampling equipment affected, compensatory measures required, draining of hazardous materials, or systems containing tritium.

OP-AA-109-101 Revision 9 Page 69 of 86 ATTACHMENT 5 Clearance Preparation/Approval Checklist Page 4 of 4 C/O Hang/Lift risk consideration Hang risk actions Lift risk actions Possible effects Fuse or circuit board Fuse or circuit board Auto-starts removal installation Equipment trips Draining / venting Filling / Venting Reactor Protection Logic signals Isolating instruments Valving in instruments Control Room indication changes Jumper installation Jumper removal Control Room annunciators Breaking daisy chains Restoring daisy chains Opposite Unit / Train effects Isolating control air Valving in control air Turbine Supervisory Logic De-energizing control Energizing control power Radioactive release power Loss of Main condenser vacuum Lifting of leads Landing of leads Installing grounds Removing grounds The 5 Key Questions What are the Critical Steps in the task?

What is the Worst Thing that can go wrong?

What are the Error Likely Situations?

What Defenses are we relying upon?

What actions will assure proper configuration control?

Note: When assembling the C/O package include pages 1-4 of this attachment.

Writer/Preparer _____________________________________/________

Name Date Approver _____________________________________/________

Name Date C/O Challenge _______________________________/________

Name Date

OP-AA-109-101 Revision 9 Page 70 of 86 ATTACHMENT 6 Clearance Walk Down Sheet Page 1 of 1 C/O Number: ______________________________

Safety/Rad Comments RWP Required Y N __________________________________________________________

Safety Person Required Y N __________________________________________________________

Confined Space Entry Y N __________________________________________________________

Other Safety Concerns Y N __________________________________________________________

(i.e., SA-AA-116-2124)

Job Hazard Analysis)

Dose received during Walk Down __________________________________________________________

Miscellaneous Other Discipline Support Y N __________________________________________________________

Required (i.e., lead lifting, etc.)

Equipment Purge Reqd Y N __________________________________________________________

(H2, Offgas, etc)

Locked Valve Manipulation Y N __________________________________________________________

Application Duration Time Estimate (including Draining) __________________________________________________________

Configuration Control Challenge Y N ________________________________________________________________

due to work area or component style Removal Duration __________________________________________________________

Time Estimate Ability to install Tags Plus Device Y N ________________________________________________________________________

Component Locations Y N __________________________________________________________

Accurate Component Labeled Y N __________________________________________________________

(C/O Tag & Label Match)

Draining Equipment Needed (hoses, tubing, drums, pumps, etc).

Component Access Requirements Ladder Y N __________________________________________________________

Scaffold Y N __________________________________________________________

Other Y N __________________________________________________________

Required Equipment Staged Y N (Location)__________________________________________________

Additional Issues/Comments: _________________________________________________________________________

Walk Down Performed by: _____________________________________ Date: ___________________________

Comments/Issues Resolved by: _________________________________ Date: ___________________________

OP-AA-109-101 Revision 9 Page 71 of 86 ATTACHMENT 7 C/O Challenge Guidelines Page 1 of 1 NOTE: The C/O Challenge will be conducted by a knowledgeable Management Individual (i.e. SRO, SRO Certified, previously licensed SRO or individual possessing specific technical knowledge).

CLEARANCE #___________________ CHECKLIST#_______________

1. The C/O package will include the following as applicable:

()

______ Prints with highlighted isolation boundaries

______ Clearance Request (C/R), including revisions based on scope change

______ Preparation Checklist

______ Review the final approved copy of the C/O

______ Procedures, as applicable

______ Any other materials needed or used in the preparation of the C/O

______ Notes, e-mail, etc, to identify communications/corrective actions taken against any discrepancies found during preparation.

2. The individual performing the challenge will review the C/R to identify:

______ Principle Equipment (PE)

______ Scope of Work

______ Recommended isolation points

3. The individual performing the challenge will review C/O Package and consider the following Technical Aspects:

______ Proposed drain/vent path, if applicable

______ Proper use of C/O Tags for those isolation points necessary for Personnel Protection

______ Proper steps sequencing

______ Special Instructions are clear and include appropriate procedural references.

______ Plant conditions, expected system and alarm response

OP-AA-109-101 Revision 9 Page 72 of 86 ATTACHMENT 8 Clearance Authorization Checklist Page 1 of 1 C/O #__________________________

C/O APPLICATION SUPERVISORY AUTHORIZATION ( - N/A)

C/O is in the Approved Status and C/O challenge complete Special Instructions reviewed Plant conditions acceptable Review existing TCC/TMODs for emergent changes Redundant train operability assessed including any confidence runs and shared support equipment.

Pre-clearance activity testing required/performed Tech Spec & Admin requirements met/initiated Applicable procedure prerequisites satisfied C/O Risk Potentials reviewed/acceptable (Attachment 5)

C/O Reactivity/Operational/Environmental/ Atmospheric (Breathing or Explosive) Risks considered/addressed PRA, Online & Shutdown Risk acceptable/updated HLA criteria evaluated and initiated if required Fire Protection actions/paperwork initiated Barrier Breach actions/paperwork initiated Verification type properly designated (IV, CV, or none)

C/Os taken to Distributed status with tags printed and Checklist is Master or Duplicate (not Review)

Mode/Condition Dependent actions initiated/Performed C/O application authorized (SRO signature)

C/O application pre-job brief initiated/performed For RH Checklist, Remove Holders Acceptance Lock after tags rehung.

C/O REMOVAL SUPERVISORY AUTHORIZATION W/O statused correctly for release reason with notes as applicable Method of restoration Acceptable C/O Risk Potentials reviewed/acceptable (Attachment 5, Page 4 of 4)

C/O Reactivity/Operational/Environmental/Atmospheric (Breathing or Explosive) Risks considered/addressed HLA criteria evaluated and initiated if required Verification type properly designated (IV, CV, or none)

C/O restoration authorized (SRO signature)

C/O restoration pre-job brief initiated/performed PMTs are being coordinated with C/O removal C/O checklist is Master or Duplicate (not Review) and Special Instructions reviewed All C/O Supervision and employees have released the C/O No names listed on Contacts Panel for WTL Control For Temp Lift has Holder Acceptance Lock been applied or C/O placed in Suspended status?

C/O CLOSEOUT ACTIVITIES Tech Spec actions updated, as required Fire Protection issues updated, as required All Tags removed/accounted for and any tags missing have been reconciled with final clear checklist.

Barrier Breach issues updated, as required Ensure C/O activity logged, as required Working/Testing Department notified

OP-AA-109-101 Revision 9 Page 73 of 86 ATTACHMENT 9 Worker Tracking List Page 1 of 1 Use additional sheets as needed: Sheet ____ of _____

WO(s)#

C/O # PJB Performed by (Print): Attachment 13 by: (Print):

Phone Extension/Pager #:

Worker Sign ON Worker Sign OFF Print AND Sign Name Date Time Sign Name Date Time Verify Worker Sign OFF column completed for all employees, then sign (WTL Cognizant sign and date) ________________________________/__________________

OP-AA-109-101 Revision 9 Page 74 of 86 ATTACHMENT 10 Clearance Manipulation Prejob Brief Checklist Page 1 of 1 C/O # ____________________________ CHK# ______________________

Operational/Reactivity/Environmental/Atmospheric Risk activities must include each of the following:

Perform a C/O prejob Brief and HLA Brief as appropriate for the activity Mark or highlight Critical Step(s) in the activity that relate to Risk Obtain authorization from the Unit or Control Room Supervisor directly prior to performing a critical step or critical steps related to the Risk Monitor/Validate performance of each critical step related to the Risk by direct oversight in the field, by work group supervision unless alternate methods are specifically determined at the prejob brief/HLA.

BRIEFING ITEMS FOR DISCUSSION & COMMENTS

( - N/A) ( - N/A)

Job purpose/scope Previous history and lessons learned Roles and responsibilities Other departments involved Clearance Step Verification Requirements Checklist Type Specific Concerns (i.e., Dual annotated (CV, IV, or none) Function)

Safety concerns/potential hazards Procedure coordination issues ALARA concerns Special Instructions and C/O notes reviewed Special Tooling or access (man-lift, keys, Defenses against errors and Human valve bar, gags, etc) Performance Tools discussed (flagging, 2-minute drill, peer checks)

Radwaste concerns (drain locations) Virtual tags use discussed Reactivity Management concerns MCR/Radwaste/other persons notified C/O identified as Operational/Reactivity/ Effect on other systems/equipment (fail safe Environmental/Atmospheric Risk. If yes, position of valves) perform HLA as required per HU-AA-1211 Operational/Reactivity/Environmental/ Abort criteria and Contingencies Atmospheric Risk Critical Step performance and monitoring established with key participants Critical Steps identified on C/O checklist Main Control Room interface, alarms, change in indication (first check)

Key Questions? Tag Plus devices/methods that will be used.

What are the Critical Steps in the task? Identify any C/O Tags in advance that cannot be returned during C/O removal. If additional tags are identified during removal activities inform dispatching Supervisor.

What is the Worst Thing that can go wrong? C/O Checklist Master or Duplicate, not Review What are the Error Likely Situations? Assign inspection prior to RTS using OP-AA-108-106 for Housekeeping and Condition What Defenses are we relying upon? Notes/Discussion Items What actions will assure proper configuration control?

OP-AA-109-101 Revision 9 Page 75 of 86 ATTACHMENT 11 Supervision Clearance Acceptance/Release Checklist Page 1 of 1 NOTE: Perform applicable Section as required (Acceptance or Release).

CLEARANCE #_______________________

ACCEPTANCE TASKS Prior to Work Start/Work Restart ( - N/A) Safety Verification Requirements ( - N/A)

All C/O(s) instructions reviewed Required isolation identified by Supervision W/O(s) tied to all required C/O(s) verified Drain and/or vent paths used (listed on C/O, flow observed at drains?)

C/O(s) Accepted by Holder (recheck daily) C/O exceptional (discuss why)

Boundary report properly prepared to facilitate Electrical grounds used, any manipulations Safety Verification required Prejob Brief performed Walkdown assigned to employee Ensure Worker Sign-on Occurs (ESO or WTL)

RELEASE TASKS Releasing for Restoration ( - N/A) Processing/Releasing a Temp Lift/Partial ( - N/A)

Clear Verify equipment is cleared of personnel, Contact/Coordinate with affected Supervisor and cleared of obstructions, grounding devices Operations removed Verify Proper completion of Worker Tracking Affected Holders and employees notified and List(s). C/O Electronic Sign Off(s) complete. understand PC/TL impact as applicable to their Contacts panel entries for your crew are zone of protection removed Work is completed and statused properly in Request information submitted to Operations (lift computer. If not complete, add notes to isolations, when needed, duration of lift, reason, Holders Panel who to contact, Special Instructions, and proposed checklist)

C/O released by Supervisor Notify Supervisors to release after Approval and prior to Authorization Checklists released, as required (Supervision TL, PC, FC and all other holders FC)

Work Stop ( - N/A)

Supervisors/Employee agree and release WTL or C/O Electronic Sign OFF, as required This attachment can be reused.

OP-AA-109-101 Revision 9 Page 76 of 86 ATTACHMENT 12 Lead Worker Clearance Checklist Page 1 of 1 NOTE: Perform applicable Section as required (Work Start, Work Stop).

LEAD WORKER TASKS CLEARANCE #__________________________________

Lead Worker Tasks - Work Start ( - N/A) Lead Worker Tasks - Work Stop ( - N/A)

Verify Supervision sign-on as holder (Passport, At least one crewmember notify supervisor of screen prints). This prevents C/O modification. workers that cannot be located if applicable.

Participate in/lead/verify designee performs PJB Sign off WTL or perform Electronic Sign Off (C/O hazards, Special Instructions, controls, ZOP)

Perform or verify a Safety Verification was At least one crewmember notifies the performed by another crew or crewmember. Supervision of work stop.

Review isolations identified as required on the Boundary Report.

Verify hazards are isolated Lead Worker Tasks - Work Re-start ( - N/A)

Verify systems are depressurized and drained. Each new day of work:

Verify work area is not exposed to unexpected Verify that no boundary changes were made electrical hazards. (use C/O status panel in Passport, discuss with work group supervisor).

Place completed Boundary Report in work Perform or verify a Safety Verification was package or in a designated location performed by another crew or crewmember, if required due to changes of Boundary.

Verify W/O tasks are attached to proper Verify Acceptance/Re-accept of the C/O clearances (view in Passport or on screen prints)

After walk down re-brief as needed if conditions Verify required work order tasks remain were not as expected or new information available attached to the clearance Electronically Sign On or sign WTL. Brief any new crewmembers not ESO qualified, and have them sign the WTL.

Confirm crewmembers electronically accepted or a WTL has been signed by them.

Perform work.

The Worker Tracking List shall be maintained in an appropriate location and shall be controlled by the individual Electronically signed-on for WTL Control.

For contract personnel, this responsibility will be performed by the Exelon Nuclear site contact designated by the project or contract area supervisor.

Only one of these Attachment 12s is needed per crew as a minimum, and can be reused.

OP-AA-109-101 Revision 9 Page 77 of 86 ATTACHMENT 13 General Worker Clearance Checklist Page 1 of 1 NOTE: Perform applicable Section as required (Work Start, Work Stop, Work Restart).

CLEARANCE #___________________________

General Worker Tasks - Work Start ( - N/A) General Worker Tasks - Work Re-start ( - N/A)

Participate in Prejob Brief. Always ask: Each new day of work:

Is this C/O exceptional? Why?

(Attachment 2)

Will there be any boundary changes?

Is there anything unusual about this C/O?

Verify your Supervision AND a second individual Verify that no boundary changes were made who is at least Lead Worker qualified are both (use C/O status panel in Passport or discuss signed onto your C/Os. (The Lead Worker with Lead Worker or Supervisor) qualified individual must also be listed on the Contacts Panel)

Verify with Lead Worker or Supervision that a Discuss Safety Verification of Boundary Safety Verification has been done Changes if required with Lead Worker or Supervisor Verify work order tasks are attached to C/O Verify Acceptance/Re-accept of the C/O (Passport, screen prints), ask Lead Worker or (Passport or screen prints), ask Lead Worker or Supervision Supervision Sign the Worker Tracking List for required C/Os Verify W/O tasks remain attached to the C/O for your work and verify WTL is controlled by the (Passport or screen prints), ask Lead Worker or Lead Worker qualified individual. Supervision Perform work Sign the Worker Tracking List for required C/Os for your work and verify WTL is controlled by Lead Worker qualified individual who must also be signed on to the C/O for WTL control General Worker Tasks - Work Stop Notify the Lead Worker or Supervision of work stop Sign off WTL daily, before end of your shift REMINDER - NEVER:

OPERATE A DEVICE THAT HAS A DANGER TAG ON IT REMOVE A DANGER TAG COMPONENT FROM A SYSTEM REMOVE A DANGER TAG The Worker Tracking List shall be maintained in a pre-designated location and shall be controlled by the individual Electronically signed-on for WTL Control.

For contract personnel, this responsibility will be performed by the Lead Worker qualified site contact designated by the project or contract area supervisor.

Only one of these Attachment 13s is needed per crew as a minimum, and can be reused.

OP-AA-109-101 Revision 9 Page 78 of 86 ATTACHMENT 14 PART 1 WTO Form Hang/Lift Section Page 1 of 1 Exceptional C/O: Mode Dependent: Condition Dependent:

Operational Risk: Environmental Risk: Atmospheric Risk: Reactivity Risk:

WORKER TAGOUT# __________________________ JOB DESCRIPTION: ________________________________________

WORKING DEPARTMENT: __________________ W/O OR W/R: ____________________ EQUIP. TAG# _____________________

COMPONENT DESCRIPTION: ________________________________________________________

FIRST APPROVAL: ____________________________________ DATE: _________________

SECOND APPROVAL: _________________________________ DATE: _________________

WTO AUTHORIZATION: _______________________________ DATE/TIME __________________

SPECIAL INSTRUCTIONS: YES: NO: (IF YES SEE ATTACHMENT 14 PART 2)

EQUIP. TAG/EQUIPMENT NAME SEQ TAG POSITION HUNG VERIF. SFTY. RTS RTS RTS VERIF.

TYPE BY BY VERIF. SEQ POSITION BY BY WTO PLACED: ______________________________________________________________ DATE/TIME: ___________________

WTL COMPLETED WORK START: _____________________________________________ DATE/TIME: ___________________

WTO FINAL CLEAR: WORK CREWMEMBER RELEASE: ____________________________ DATE/TIME: ___________________

WTO CLEARED: ____________________________________________________________ DATE/TIME: ____________________

(COPIES MAY BE MADE OF THIS FORM FOR ADDITIONAL ISOLATION POINTS)

OP-AA-109-101 Revision 9 Page 79 of 86 ATTACHMENT 14 PART 2 WTO Form Special Instructions Section Page 1 of 1 WTO #

OP-AA-109-101 Revision 9 Page 80 of 86 ATTACHMENT 14 PART 3 WTO Form Testing/Manipulation Section Page 1 of 1 WTO # __________________________________________

RECORD ALL MANIPULATIONS (HANG AND LIFT) ASSOCIATED WITH THIS WTO (ADDITIONAL COPIES MAY BE USED AS NEEDED) Page ____ of _____

EQUIP. TAG/ EQUIP. NAME SEQ AS FOUND MANIP. POSIT. VERIF. RH RH RH VERIF. SFTY.

POSITION POSITION BY BY SEQ POSITION BY BY VERIF.

OP-AA-109-101 Revision 9 Page 81 of 86 ATTACHMENT 14 PART 4 WTO Worker Tracking List (WTL)

Page 1 of 1 Use additional sheets as needed. Sheet _____ of ______

W/O # WTO # Supervisor (Print): Designated Crew member (Print):

Worker Sign ON Worker Sign OFF**

Print and Sign Name Date Time WTO* Sign Name Date Time WTO*

Tracking Tracking List Tag List Tag Placed Removed (Yes/Dual) (Yes/Dual)

  • Indicate Yes if done and use Dual if 2 tags used for dual feed components. Required for individuals that hung the tag.

Verify Worker Sign Off column completed for all employees, then sign (Designated Work Crewmember sign and date) ______________________________________/ ____________________

OP-AA-109-101 Revision 9 Page 82 of 86 ATTACHMENT 14 PART 5 Worker Tagout Log Page 1 of 1 WTO # EQUIP. SYSTEM JOB DESCRIPTION WO/IR/ WORK GROUP DATE/TIME DATE/TIME TAG ID WR NUMBER SUPERVISOR HUNG CLEARED (or Dept.)

OP-AA-109-101 Revision 9 Page 83 of 86 ATTACHMENT 14 PART 6 WTO Tracking List Tag Page 1 of 1 WTO TRACKING LIST TAG WTO Tracking List Tag (all workers on WTL sign here)

WORK IN PROGRESS WTO #_______________________________________

DO NOT OPERATE Date Hung:____________________ Dept.:_________

FRONT BACK

OP-AA-109-101 Revision 9 Page 84 of 86 ATTACHMENT 15 Documentation for Release of Another Employees C/O Protection Page 1 of 1 WARNING USE OF THIS ATTACHMENT REQUIRES 100% VERBATIM PROCEDURE COMPLIANCE, AS YOU ARE RELEASING ANOTHER EMPLOYEES ZONE OF PROTECTION. DEATH OR INJURY COULD RESULT IF PERFORMED INCORRECTLY.

C/O or WTO Number:_________________________________ Date: _____/____/______

Name of employee:_________________________________________________________________

Work Group or Department of employee:________________________________________________

Supervisor completing release: printed name/signature____________________/___________________

Sign off all Steps:

1. CONTACT Security and VERIFY employee is not in the Protected Area ________
2. TAKE additional actions to notify employees if job assignment is outside the Protected Area ________
3. REQUEST Security set the status of employees badge to Zero and notify Operations when worker returns to the site ________
4. RECORD employee absence on the Worker Tracking List (if used) or in Passport on holders panel ________
5. VERIFY WTL or electronic sign-off complete ________
6. KEEP this attachment on file until notified that the employee has returned to site ________
7. When employee returns to site, NOTIFY them that the C/O or WTO was released ________

Employee Acknowledgement of Notification:

Name_____________________________________ Signature/Date:_________________

8. RESET employees badge status to original status ________
9. RECORD IR number written by work group ________
10. ATTACH WTL (if used) to this attachment ________
11. SUBMIT completed Attachment 15 to the Site Clearance Coordinator ________

NOTE: The Clearance Coordinator is responsible to trend the incident and retain the completed attachment on file for 6 months.

OP-AA-109-101 Revision 9 Page 85 of 86 ATTACHMENT 16 External Energy Injection (EEI) Notification Page 1 of 2 Clearance #: ___________________________

Description of the EEI:

Requestor (print name): _______________________________ Phone #: _____________________

Holder Lock Applied by (print name and date): _______________________________

Employee Approvals:

All Holders, Lead Workers, and General Workers have been notified and understand the EEI that will occur. Work has been stopped as necessary. All holders and workers have signed off the clearance or their approval of the EEI has been obtained by their signing of the External Energy Injection (EEI)

Notification list in this attachment.

Check boxes as applicable (both may be applicable):

Work Stoppage Required (if yes exit this form and sign off ESO or WTL)

Work Stoppage NOT Required (proceed to Attachment 16 page 2 and collect worker signatures)

Note:

Working Group to maintain Attachment 16 with work package until EEI activity is complete and work package is completed. After work package completion Attachment 16 retention is not required.

OP-AA-109-101 Revision 9 Page 86 of 86 ATTACHMENT 16 External Energy Injection (EEI) Notification Page 2 of 2 Clearance #: ___________________________

WO Activity Worker Name (Print) Worker Signature Date/Time Notified Note: This attachment is not required if all workers sign off the Clearance/WTL before the EEI.

Clearance Worker Notification completed prior to Energy Injection: _________________ ____/_____

Holder Signature Date/Time Holder Lock Removed following Energy Injection by (print name and date): _____________________

BwOP OG-2 Revision 11 Continuous Use HOGGING VACUUM PUMP SHUTDOWN A. STATEMENT OF APPLICABILITY This procedure is to provide a sequence for shutting down the Hogging Vacuum pump.

B. REFERENCES

1. Station Procedures:
a. BwOP OG-M1/M2 Mechanical Lineup.
b. BwOP OG-E1/E2 Electrical Lineup.
2. Station Drawings:
a. M-47 Off Gas.
b. M-150 Off Gas.
3. Vendor Manuals:

Nash Engineering Co.

C. PREREQUISITES None.

D. PRECAUTIONS None.

E. LIMITATIONS AND ACTIONS None.

1

BwOP OG-2 Revision 11 Continuous Use F. MAIN BODY NOTE When 0AOV-OG009/ _AOV-OG044A, Hogging Vacuum Pump Suction Vlv are closed, the Hogging Pump should be stopped as soon as possible to minimize air entrainment into the system.

1. CLOSE 0AOV-OG009/ _AOV-OG044A, Hogging Vacuum Pump Suction Valve.
2. STOP the Hogging Vacuum Pump from panel OPM01J.
3. CLOSE _OG061/0OG046, Air Separator Tank Drain Vlv.
4. CLOSE _OG050/0OG023, Demin Seal Water to Hogging Vac Pump.
5. VERIFY/CLOSE _AOV-OG043, Cndsr Shell Xtie Vlv.
6. ALIGN the Unit 0 Hogging Vacuum Pp as necessary:

VERIFY/OPEN 0OG011, Vac Pump U-0 Air Sep Tk Dsch Vlv to Unit 1.

VERIFY/CLOSE 0OG047, Vac Pump U-0 Air Sep Tk Dsch Vlv to Unit 2.

OR VERIFY/OPEN 0OG047, Vac Pump U-0 Air Sep Tk Dsch Vlv to Unit 2.

VERIFY/CLOSE 0OG011, Vac Pump U-0 Air Sep Tk Dsch Vlv to Unit 1.

(Final) 2

JOB PERFORMANCE MEASURE TASK CONDITIONS:

1. You are the Unit 2 Assist NSO.
2. Five minutes ago a change in plant condition resulted in an upgrade to the emergency action level to a Site Area Emergency FS1.
3. EP-MW-114-100-F-01, NUCLEAR ACCIDENT REPORTING SYSTEM (NARS) FORM has been filled out and approved.
4. This is a Time Critical JPM.

INITIATING CUES:

1. The Shift Manager directs you to transmit the NARS form for the upgraded EAL status of Unit 1 per EP-MW-114-100, MW Region Offsite Notifications.
2. Inform the Shift Manager when the NARS form has been transmitted.

R-402 Page 1 of 7

TASK TITLE: Perform NARS Update Transmittal JPM No.: R-402 REV: 2013 NRC TPO No.: 4F.ZP-02 K&A No.: 2.4.39 TASK No.: R-ZP-004 Transmit NARS Form K&A IMP: 3.9/3.8 EXAMINEE: RO EVALUATOR: DATE:

The Examinee: PASSED this JPM. TIME STARTED:

FAILED TIME FINISHED:

JPM TIME: MINUTES CRITICAL ELEMENTS: (*) 3, 4 APPROX COMPLETION TIME: 10 MINUTES CRITICAL TIME: 10 minutes EVALUATION METHOD: LOCATION:

X PERFORM IN PLANT SIMULATE X SIMULATOR GENERAL

REFERENCES:

1. EP-MW-114-100, MW REGION OFFSITE NOTIFICATIONS, Rev. 12.
2. EP-MW-114-100-F-01, NUCLEAR ACCIDENT REPORTING SYSTEM (NARS) FORM, Rev. G.

MATERIALS:

1. EP-MW-114-100, Rev. 12, MW REGION OFFSITE NOTIFICATIONS.
2. EP-MW-114-100-F-01, Rev. G, NUCLEAR ACCIDENT REPORTING SYSTEM (NARS) FORM.

TASK STANDARDS:

1. Determine correct NARS phone code or phone number.
2. Complete NARS initial roll call within 15 minutes of the initiating cue.
3. Transmit NARS data to offsite agencies.

TASK CONDITIONS:

1. You are the Unit 2 Assist NSO.
2. Five minutes ago a change in plant condition resulted in an upgrade to the emergency action level to a Site Area Emergency FS1.
3. EP-MW-114-100-F-01, NUCLEAR ACCIDENT REPORTING SYSTEM (NARS) FORM has been filled out and approved.
4. This is a Time Critical JPM.

INITIATING CUES:

1. The Shift Manager directs you to transmit the NARS form for the upgraded EAL status of Unit 1 per EP-MW-114-100, MW Region Offsite Notifications.
2. Inform the Shift Manager when the NARS form has been transmitted.

R-402 Page 2 of 7

RECORD START TIME:

EVALUATOR NOTE: Provide examinee the completed NARs form and copy of EP-MW-114-100-F-01.

EVALUATOR NOTE: JPM critical time (13 minutes) starts when the initiating cue has been read to the examinee and stops after the initial roll call is made and the NARS information starts to be transmitted.

PERFORMANCE STEP STANDARD CIRCLE APPLICABLE

1. Refer to EP-MW-114-100, MW Refer to EP-MW-114-100: SAT UNSAT N/A REGION OFFSITE
  • Determine step 4.2 needs Comments:

NOTIFICATIONS. to be performed.

2 Refer to EP-MW-114-100-F-01, Refer to EP-MW-114-100-F-NUCLEAR ACCIDENT 01:

REPORTING SYSTEM (NARS)

  • Determine NARS Code 20 FORM. to be used to transmit NARS form.

R-402 Page 3 of 7

  • 3. Establish communications: Establish communications as SAT UNSAT N/A follows: Comments:

Note: After examinee dials Code 20, provide the

following cue:

CUE: After a short pause, a

  • DIAL code 20. (hears busy signal is heard. busy signal)

CUE: After a short pause, a

  • DIAL code 50 to enter the dial tone is heard. (if bridge. (hears pause and candidate tries code 20 then dial tone) or 50 again, repeat the same cues).

CUE: After dialing 1-217-782-

  • Determines that it will be 7860, you announce that necessary to call via the you are Steve from IEMA commercial exchange on the line. number for IEMA found on page 2 of the NARS form.

Dials 1-217-782-7860.

Note: After examinee reads

  • Read the following messages, provide the message: This is Exelon following cue: Nuclear Braidwood Station Control Room. Please standby for a NARS message.

o Read the following message: This is the Exelon Nuclear Braidwood Station Control room.

Please standby to receive a NARS message and respond as the roll is called.

CUE: IEMA online.

  • TAKE Initial Roll Call
  • Mark Initial Box for IEMA
  • Record time and date initial roll call complete.

EVALUATOR NOTE: Critical time TIME STOPS when examinee completes initial roll call.

Determine critical time:

_________________________ - ________________________ = ________________________

(Time initial roll call complete) (JPM start time) < 10 minutes R-402 Page 4 of 7

PERFORMANCE STEP STANDARD CIRCLE APPLICABLE

  • 4. Verbally transmit the NARS Verbally transmit the NARS SAT UNSAT N/A Form. Form: Comments:
  • Utility Message No: 2_
  • State Message No: N/A
  • Status - [B] Drill/Exercise
  • Station - [A] Braidwood
  • Onsite Condition - [C] Site Area Emergency
  • Accident Classified:
  • Time: Two minutes ago.
  • Date: Today.
  • Accident Terminated Date and Time: N/A
  • Release Status: [A] None
  • Type of Release: [A] Not Applicable
  • Wind Dir: 270
  • Wind Speed:

o [A] is N/A

  • [B] 4.5 Miles/Hr
  • Recommended Actions:

Utility Recommendation:

[A] None

  • Additional Information:

None

5. Complete the NARS form. Fill in the following information SAT UNSAT N/A on the NARS Form after Comments:

transmitting info in blocks 1-10:

  • Mark 11A, EXELON
  • Examinee Name
  • Outside line number
  • Current Time CUE: Steve Smith, IEMA.
  • Current Date
  • Name of person from IEMA receiving message
  • Current time
  • Todays date R-402 Page 5 of 7

PERFORMANCE STEP STANDARD CIRCLE APPLICABLE

6. Perform Final Roll Call PERFORM Final Roll Call and SAT UNSAT N/A Note: As examinee performs marks boxes for: Comments:

final roll call provide the

  • IEMA following cues:
  • Ask if there are any CUE: IEMA (Steve) questions about the CUE: No questions from either information provided.

IEMA

7. STATE NARS communication is STATE NARS communication SAT UNSAT N/A complete. is complete. Comments:

CUE: THIS COMPLETES THIS JPM.

RECORD STOP TIME:

COMMENTS:

R-402 Page 6 of 7

SIMULATOR SETUP INSTRUCTIONS

  • Verify/perform TQ-BR-201-0113, BRAIDWOOD TRAINING DEPARTMENT SIMULATOR EXAMINATION SECURITY ACTIONS CHECKLIST.
  • Complete items on Simulator Ready for Training Checklist COMMENTS

Utility Message No - 2 State Message No - N/A Status - [B] Drill/Exercise Station - [A] Braidwood Onsite Condition - [C] Site Area Emergency Accident Classified:

Time - Two minutes ago.

Date - Today.

EAL # - FS1 Accident Terminated Date and Time are N/A.

Release Status - [A] None Type of Release - [A] Not Applicable Wind Dir - 270 Wind Speed - [B] 4.5 Miles/Hr ([A] is N/A)

Recommendations - [A] None Additional Information - None Verified With - U. Supervisor Approved By - S. Manager (Final)

R-402 Page 7 of 7

EP-MW-114-100 Revision 12 Page 1 of 13 Level 2 - Reference Use MIDWEST REGION OFFSITE NOTIFICATIONS

1. PURPOSE 1.1. Provide prompt and accurate notification of nuclear station emergencies to local, state and federal agencies.

State and Local Notification Requirement REFER to section 4.1 Completing the NARS Form REFER to section 4.2 NARS Call Transmittal REFER to section 4.3 Receiving a NARS Message REFER to section 4.4 Follow-Up Notifications REFER to section 4.5

2. TERMS AND DEFINITIONS 2.1. Nuclear Accident Reporting System (NARS) is a telecommunication network used to transmit information to appropriate State and local agencies.

2.2. NARS Form(s): NARS hardcopy form in procedure EP-MW-114-100-F-01 and NARS electronic equivalent.

3. RESPONSIBILITIES 3.1. The Emergency Director in the Emergency Response Facility (ERF) with Command and Control shall ensure that all required notifications are initiated as follows:
1. Within 15 minutes of:
a. Declaring an emergency
b. Emergency Classification escalation
c. Issuing or changing Protective Action Recommendations (PARs)
d. A radioactive release OR a change in radioactive release conditions
2. Within one hour of Termination or entry into Recovery.

3.2. Operations personnel on shift are responsible for transmitting the State/Local notification over the NARS when the Shift Emergency Director is in Command and Control.

3.3. The State/Local Communicator in the TSC is responsible for transmitting the State/Local notification over the NARS when the Station Emergency Director is in Command and Control.

EP-MW-114-100 Revision 12 Page 2 of 13 3.4. The State/Local Communicator in the EOF is responsible for transmitting the State/Local notification over the NARS when the Corporate Emergency Director is in Command and Control.

4. MAIN BODY 4.1. STATE AND LOCAL NOTIFICATION REQUIREMENT 4.1.1. INITIATE offsite notification within 15 minutes of the following:
1. The declaration of an emergency
2. Classification of an emergency
3. A change in Protective Action Recommendations (PARs)
4. A change in the radioactive release conditions
5. A change in wind direction that affects a different combination of Subareas/Sectors when a release is occurring.

4.1.2. INITIATE offsite notification as soon as possible, but within one hour of Termination or entry into Recovery.

NOTE: The electronic NARS form equivalent is the preferred method when available.

4.2. COMPLETING THE NARS FORM 4.2.1. Utility Message Number

1. ENTER a Utility Message Number sequentially, starting with 1, for the event described.
2. ENTER "N/A" on the hard copy form if this is a State NARS Message or
3. If using the electronic form, CLICK inside the State Message No. box and VERIFY that the NA auto-populated.

4.2.2. State Message Number

1. ENTER the State Message Number when receiving a NARS Message from the State.
2. ENTER "N/A" if this is a Utility NARS Message.

EP-MW-114-100 Revision 12 Page 3 of 13 4.2.3. Block 1, Status

1. [A] ACTUAL - MARK this box to indicate a notification is being performed based on actual plant conditions.
2. [B] Drill/Exercise - MARK this box to indicate a notification is being performed during exercises, drills, training sessions, or communications tests.

4.2.4. Block 2, Station

1. [A] Through [G] - MARK the appropriate box for the affected station.

4.2.5. Block 3, Onsite Condition

1. When classifying events, USE the highest classification level for the site (all units).
2. [A] Through [F] - MARK the box corresponding to the highest classification or condition level for the site (all units).

4.2.6. Block 4, Accident Classified NOTE: The time and date are specific to the current emergency classification and the date will auto-populate when using the electronic NARS form.

1. If issuing the form for a change other than a new classification, THEN ENTER the date, time, and EAL# for the current classification in effect.
2. If one of the four emergency event levels is being communicated as the Block #3 Onsite Condition, THEN ENTER the TIME & DATE that the event was declared and the corresponding EAL #.
3. If entry into Recovery is being communicated as the onsite condition, THEN:

ENTER the TIME & DATE that Recovery was entered and N/A the EAL # if using the hard copy form or VERIFY that the electronic NARS form auto-populates.

4. When using the hard copy form, ENTER N/A next to TIME & DATE under ACCIDENT TERMINATED.

EP-MW-114-100 Revision 12 Page 4 of 13 4.2.7. Block 4, Accident Terminated

1. When using the hard copy form, ENTER the TIME & DATE that the accident condition was terminated or when using electronic NARS:

A. ENTER the TIME and B. VERIFY the DATE auto-populated.

2. ENTER N/A next to TIME & DATE and EAL # under ACCIDENT CLASSIFIED or when using electronic NARS:

A. VERIFY TIME & DATE auto-populated under ACCIDENT CLASSIFIED B. VERIFY block 3, ONSITE CONDITION, TERMINATED is checked.

4.2.8. Block 5, Release Status

1. USE EP-AA-114-F-01(02), PWR (BWR) Release in Progress, as needed, to identify a release in progress.
2. [A] NONE - MARK this box to indicate that no release is occurring.
3. [B] "OCCURRING" - MARK this box to indicate that there is a release in progress.
4. [C] TERMINATED - MARK this box to indicate when a radioactive release of gasses or liquids associated with the emergency event are no longer being released based on sampling or direct measurement.

4.2.9. Block 6, Type Of Release

1. If [A] NONE, was selected in Block 5, THEN MARK [A] NOT APPLICABLE or VERIFY NOT APPLICABLE is checked when using electronic NARS.
2. If [B] OCCURRING, was selected in Block 5, THEN MARK the following as appropriate:

MARK [B] GASEOUS MARK [C] LIQUID

3. If [C] TERMINATED was selected in Block 5, THEN MARK the following as appropriate:

MARK [B] GASEOUS MARK [C] LIQUID

EP-MW-114-100 Revision 12 Page 5 of 13 4.2.10. Block 7 Wind Direction & Block 8, Wind Speed

1. REFER to EP-MW-110-1001, Data Point Tables, as needed, for a listing of PPDS meteorological data points.

NOTE: Meteorological data is taken from the appropriate level of the tower to match the expected release height.

STATION RELEASE POINT LEVEL No Release Elevated Chimney Elevated Dresden and Quad Reactor Bldg. Vent Ground Isolation Condenser Dresden (Only) Ground Hole in Wall/Other Ground No Release Elevated Station Vent Stack Elevated LaSalle Standby Gas Treatment Stack Elevated Hole in Wall/Other Ground Braidwood, Byron & Clinton All Ground

2. OBTAIN meteorological data from the following sources in the order listed below:

- PPDS data

- Control Room Meteorological Instruments

- Contracted Weather Service - Murray and Trettel - The phone numbers for the contracted weather service are located in the Emergency Response Facilities Telephone Directory.

- National Weather Service (NWS) -The phone numbers for the weather services are located in the Emergency Response Facilities Telephone Directory. Additionally, the information may be obtained from the NWS Web Site.

- Direct Observation Estimate- Estimation of the wind direction by direct observation of outside conditions.

3. Block 7 - ENTER the wind direction (from) in degrees.
4. Block 8 - MARK the box and enter the wind speed for either or both as follows:

[A] METERS/SEC

[B] MILES/HR

EP-MW-114-100 Revision 12 Page 6 of 13 Quad Cities

5. Block 8 - MARK [A] and [B] and FILL IN both "METERS/SEC" and "MILES/HR".

4.2.11. Block 9, Recommended Actions WARNING: Do not delete subareas that have been previously identified in Block 9.

Recommended subareas may be added, but not deleted by the utility.

1. If [D] General Emergency, was not selected in Block 3, THEN MARK

[A] NONE or A. VERIFY [A] NONE auto-populated if using electronic NARS.

2. If [D] General Emergency, was selected in Block 3, THEN:

A. When Shelter has been determined to be the appropriate PAR, MARK boxes [B] and/or [C] for the affected state(s).

ENTER the Subareas to be sheltered on the appropriate state line per EP-AA-111, Emergency Classifications and Protective Action Recommendations.

If Subareas were previously identified in Block 9, DO NOT delete.

B. When Evacuate has been determined to be the appropriate PAR, MARK boxes [D] and/or [E] for the affected state(s).

ENTER the Subareas to be evacuated on the appropriate state line per EP-AA-111, Emergency Classifications and Protective Action Recommendations.

If Subareas were previously identified in Block 9, DO NOT delete.

3. Boxes [F] through [K] are for State Use. They are completed only when Exelon personnel are receiving a notification transmission from the State.

EP-MW-114-100 Revision 12 Page 7 of 13 4.2.12. Block 10, Additional Information

1. If a situation arises where both units are affected by unrelated event EALs, THEN NOTE the other EAL and the applicable unit number in the Additional Information section and proceed to step 4.2.12.4.
2. If this is the first NARS issued for the event, THEN ENTER None.
3. If a subsequent NARS form is being issued because of a change in the classification level, THEN ENTER None.
4. If a subsequent NARS form is being issued because of a change in one of the conditions listed below but the classification level of the event remains the same, THEN briefly EXPLAIN the changed condition.

Change in Release Status Change in PARs Change in affected Subareas Corrections are being made to a previously issued NARS 4.2.13. PRINTING ELECTRONIC NARS

1. SAVE the electronic form by:

A. SCROLLING to the top of the record and B. SELECTING save.

2. CLOSE the blank input form by X-ing out at the top right hand corner of the blank form.
3. From the Boards Display Panel, DOUBLE CLICK the MW NARS Form.
4. SELECT the desired NARS form by CLICKING the View Entire Form button for the NARS form to be printed.
5. CLICK on the green Print button for the board to be printed.
6. SELECT the desired printer and CLICK print.

EP-MW-114-100 Revision 12 Page 8 of 13 4.2.14. APPROVAL BLOCK

1. COMPLETE the Verified with section when using a peer check for accuracy (e.g. TSC or EOF Directors completing the NARS form for the Emergency Director), otherwise mark as N/A.
2. OBTAIN approval from the Emergency Director in Command & Control prior to transmission of the NARS form.

Control Room Shift Manager TSC Station Emergency Director EOF Corporate Emergency Director 4.2.15. Blocks 11 and 12

1. These blocks record name, organization, date and time of message transmission/receipt.
2. These Blocks are not completed during the preparation of the NARS form. Completion of Blocks 11[A] and 12 is performed by the Communicator when reading the message over the NARS telephone system.
3. Blocks 11[B] and [C] are completed by the Communicator when receiving a notification transmission from the State.

4.3. NARS CALL TRANSMITTAL NOTE: Dialing the NARS phone code activates a conference bridge. A brief pause will occur prior to connection once the desired code has been entered. A beep will indicate when a party joins the bridge.

CAUTION:

Wait several seconds (approx. 5 sec) after hanging up the NARS phone prior to initiating another call or the conference bridge circuit will be blocked with a busy signal.

EP-MW-114-100 Revision 12 Page 9 of 13 4.3.1. Using the Roll Call Box for the affected station on Page 2 of the NARS Form, DIAL the appropriate code on the NARS telephone.

1. If the NARS call is successful, THEN go to step 4.3.2.
2. If a busy signal is received after dialing the code, DIAL 50 to enter the bridge. ANNOUNCE who you are and the reason for your call.
3. If the NARS network fails, THEN:

NOTE: Commercial telephone numbers for the State are listed on Page 2 of the NARS Form. Other contacted agencies are listed in Section (Tab) 10 of the ERF Telephone Directory.

A. CONTACT the agencies that are noted as "Required to be Notified within 15 minutes". This is denoted next to the roll call listing for each NARS Code on the back of the NARS Form.

B. CALL all other agencies that are part of the roll call listing for the NARS call.

C. INFORM the Emergency Director of all non-contacts.

4.3.2. Following a short pause and a beep indicating you are connected to the bridge, READ the following message:

"This is the Exelon Nuclear [Station and Facility originating the call]. Please standby for a NARS message."

4.3.3. As the agencies respond to the call, READ the following message:

"This is the Exelon Nuclear [Station and Facility originating the call]. Please standby to receive a NARS message and respond as the roll is called."

4.3.4. WAIT a short period of time to allow the appropriate agencies to join the bridge.

NOTE: Radiological Emergency Assessment Center (REAC) is NOT staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. REAC is NOT a required agency to consider the call complete.

4.3.5. CONDUCT an initial roll call for the agencies listed under the NARS code used on the back of the NARS form. CHECK them OFF as they respond to the roll call.

EP-MW-114-100 Revision 12 Page 10 of 13

1. If any required agencies do not answer the roll can, THEN CONTACT each agency separately after the completion of the NARS call.

4.3.6. FILL IN the box in the center section of Page 2 of the NARS Form under the heading INITIAL ROLL CALL COMPLETE.

The Time and Date entered in this box corresponds to the completion of the initial roll call for required agencies and the 15-minute clock for the NARS notification.

4.3.7. READ the NARS message.

1. READ the NARS message # _____.
2. Read the blocks 1-10 one at a time; stating the number, the title, the letter (if appropriate) and the description.

4.3.8. COMPLETE Sections 11 and 12 on the NARS form as you get to them.

Communicate the information you put into these blocks to the personnel on the NARS call.

1. Section 11, MARK [A] Exelon. ENTER your name and an outside phone number that the state agencies can use to call back if necessary.
2. Section 12, ASK for the name of the IEMA representative that received the NARS message, THEN ENTER this information on the NARS form.

4.3.9. REPEAT the roll call for each agency listed under the NARS code used and:

1. ASK if there are any questions about the information provided.
2. CLARIFY NARS message data questions at this time.

4.3.10. STATE NARS communication is complete.

4.3.11. If any agency that was present for the initial roll-call does not answer the final roll-call, THEN CONTACT that agency via commercial telephone line.

1. USE the ERF Telephone Directory to find the commercial telephone numbers needed.
2. CALL any agency listed as REQUIRED TO BE NOTIFIED immediately.
3. INFORM the Emergency Director of all non-contacts on the NARS network.

4.3.12. STANDBY to receive NARS verification call backs from the affected state agencies.

4.3.13. STANDBY to receive State NARS call, initiated by IEMA (Instructions for receiving a NARS Message are found in section 4.4).

EP-MW-114-100 Revision 12 Page 11 of 13 4.4. RECEIVING A NARS MESSAGE NOTE: The State of Iowa receives the Utility NARS message but does not use this system to communicate back to their Local Counties and agencies.

4.4.1. Following the issuance of a Utility NARS message, the State of Illinois has two possible return calls they make back that could involve the affected site.

Confirmation Call - IEMA may call back to the Utility to confirm the authenticity of the Utility NARS message prior to their taking action on the message. This call should come into the number listed as the "Outside Phone Number" in Block 11 of the NARS form. When receiving this call, answer IEMA's questions pertaining to the call.

State NARS Message - Following the issuance of a Utility NARS Message, the State of Illinois will use the NARS, as necessary, to communicate the information provided by the Utility and their recommendations to the Local and County organizations in the affected area.

NOTE: If the NARS line is not answered within 45 seconds for an incoming call, it will stop ringing. Dialing 50 will allow entry to the bridge.

4.4.2. ANSWER the NARS phone when it rings.

1. If a busy signal is received, THEN DIAL 50 to enter the bridge.
2. ANNOUNCE who you are following the connect beep.

4.4.3. RESPOND to the Roll Call as read by the state communicator.

4.4.4. DOCUMENT the information provided on the NARS form. Do not ask questions as the information is being provided, an opportunity to ask questions will be provided at the end of the call.

4.4.5. RESPOND to IEMA's query for an Exelon Nuclear representative in Block 12 of the NARS form.

4.4.6. ASK questions of the state communicator when they indicate the opportunity to do so. Clarify information provided as needed and specifically any information that differed from the information that was provided by the Utility.

4.4.7. DISTRIBUTE the completed State NARS Message.

EP-MW-114-100 Revision 12 Page 12 of 13 4.5. FOLLOW-UP NOTIFICATIONS NOTE: Follow-up notifications are the responsibility of the EOF. State updates are required at the top of the hour, plus or minus ten minutes, starting in the second hour following a classification of Alert or higher.

The facility in Command and Control is ultimately responsible for ensuring that the State updates are completed in a timely manner.

Commercial telephone numbers for the State and all other contacted agencies are listed in Section (Tab) 10 of the ERF Telephone Directory.

4.5.1. OBTAIN update data as required for:

1. Form EP-MW-114-100-F-02, "Management State Update Information (PWR)"
2. Form EP-MW-114-100-F-03, "Management State Update Information (BWR)"
3. Form EP-MW-114-100-F-04, "Radiological State Update Information" 4.5.2. CONTACT State agency personnel (by the State Decision-Makers Hotline or from the numbers provided in the ERF Telephone Directory) and DISCUSS the event.
1. For BW, BY, CL, DR or LS, use the IL State Decision-Makers Hotline (EOF) or commercial line to contact the REAC Manager.
2. For QC, use the QC State Decision-Makers Hotline or commercial line to contact the REAC Manager and the Iowa Emergency Operations Center simultaneously.

4.5.3. DIRECT the State Environmental Coordinator to contact the applicable state counterparts and discuss the information on form EP-MW-114-100-F-04, Radiological State Update Information.

1. For BW, BY, CL, DR or LS, contact the REAC Environmental Analyst (call the number listed for REAC and ask for the Environmental Analyst).
2. For QC, contact separately both the REAC Environmental Analyst and the IEMD Health Physics Hotline.

EP-MW-114-100 Revision 12 Page 13 of 13

5. DOCUMENTATION 5.1. The following forms when completed during a declared event document implementation of this procedure.

EP-AA-111-F-02, Braidwood Plant Based PAR Flowchart EP-AA-111-F-03, Byron Plant Based PAR Flowchart EP-AA-111-F-04, Dresden Based PAR Flowchart EP-AA-111-F-05, LaSalle Based PAR Flowchart EP-AA-111-F-06, Quad Based PAR Flowchart EP-AA-111-F-07, Clinton Based PAR Flowchart EP-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) Form EP-MW-114-100-F-02, Management State Update Information (PWR)

EP-MW-114-100-F-03, Management State Update Information (BWR)

EP-MW-114-100-F-04, Radiological State Update Information 5.2. The Standard Records Retention ID for the above documents per the Standards Records Retention Schedule is 5B.100.

6. REFERENCES

- EP-MW-110-1001, Data Point Tables

- EP-AA-114-F-01, PWR Release in Progress Determination Guidance

- EP-AA-114-F-02, "BWR Release In Progress Determination Guidance"

7. ATTACHMENTS None
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