Text

Summarizes 961028 Meeting in Atlanta,Ga Re Apparent Violation of NRC Requirements Prohibiting Discrimination Against Employees Who Engage in Protected Activities
	ML20134Q276
Person / Time
Site:	Crystal River
Issue date:	11/08/1996
From:	Landis K; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Beard P; FLORIDA POWER CORP.
References
	EA-96-335, NUDOCS 9612020206
	Download: ML20134Q276 (102)
	v • d • e

r November 8, 1996 1

f. EA 96-335 l

Florida Power Corporation Crystal River Energy Complex 4 Mr. P. M. Beard, Jr. (SA2A)

, Sr. VP, Nuclear Operations !

. . ATTN: Mgr., Nuclear Licensing i i 15760 West Power Line Street !'

j Crystal River, FL 34428-6708 E

SUBJECT:

' MEETING SUMMARV: PREDECISIONAL ENFORCEMENT CONFERENCE- !

CRYSTAL RIVER - DOCKET NO. 50-302 !

Dear Mr. Beard:

1 This. refers to the meeting on October 28, 1996, at the Region II office in ;

Atlanta, Georgia. The purpose of the meeting was to discuss an apparent ;

violation of NRC requirements prohibiting discrimination against employees who i engage in protected activities It is our opinion, that this meeting.was beneficial to our understanding of the issue.

i 1 .

L Enclosed is a List of Attendees and Florida Power Corporation's and McEnany l i Roofing, Inc. 's presentation material. -)

3 In accordance with Section 2.790 of NRC's'" Rules of Practice," Part 2, l i Title 10 Code of Federal Regulations, a co)y of this letter and its enclosures

will be placed in the NRC Public Document Room.

Should.you have any questions concerning this letter, please contact us.

Sincerely.

Orig signed by Caudie Julian for Kerry D. Landis, Chief

$612o2o2o69611oe R

Reactor Projects Branch 3 G ADOCK 050003o2 Division of Reactor Projects ;

PM u v .

EA 96-335 Docket No. 50-302 a License Nos. DPR-72 ,

Enclosures:

1. List of Attendees l 2 FPC and McEnany Presentation Material cc w/encls: Gary L. Boldt, Vice President Nuclear Production (SA2C) I {

Florida Power Corporation I Crystal River Energy Complex 15760 West Power Line Street Crystal River, FL 34428-6708 cc w/encls: Continued see page 2 0FFICIAL COPY

_ 28 b <

FPC 2 cc w/encls: Continued B. J. Hickle. Director ibclear Plant Operations (NA2C)

Florida Power Corporation Crystal River Energy Complex 15760 West Power Line Street Crystal River, FL 34428-6708 L. C. Kelley, Director (SA2A)

Nuclear Operations Site Support Florida Power Corporation Crystal River Energy Complex 15760 West Power Line Street Crystal River, FL 34428-6708 R. Alexander Glenn Corporate Counsel Florida Power Corporation MAC - ASA P. O. Box 14042 St. Petersburg, FL 33733 Attorney General

. Department of Legal Affairs The Capitol Tallahassee, FL 32304 Bill Passetti Office of Radiation Control De)artment of Health and Rehabilitative Services 1317 Winewood Boulevard Tallahassee, FL 32399-0700 i

Joe Myers Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, FL 32399-2100 Chairman Board of County Commissioners Citrus County 110 N. Apopka Avenue Inverness FL 34450-4245 Robert B. Borsum B&W Nuclear Technologies 1700 Rockville Pike. Suite 525 Rockville, MD 20852-1631 i

i

FPC 3 Distribution w/ encl:

L. Raghavan. NRR B, Crowley, RII G. Hallstrom, RII J. Lieberman. OE B. Uryc, RII OE EA File (/ittn: B. Summers, DE)

PUBLIC NRC Resident Inspector U.S. Nuclear Regulatory Commission 6745 N. Tallahassee Road

! Crystal River, FL 34428 a

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LIST OF ATTENDEES Florida Power CorDoration G. Boldt. Vice President. Nuclear Production A. Glenn. Corporate Counsel B. Gutherman. Manager. Nuclear Licensing V. Fernandez. Senior Nuclear Quality Assurance Specialist L. Kelly. Director. Nuclear Operations Site Support J. Limper. Nuclear Projects Cost Estimater M. McEnany President. McEnany Roofing. Inc.

C. Tilman. Manager. Nuclear Operations Purchasing and Contracting

%iclear Reculatory Commission 4

J. Johnson. Deputy Director. Division of Reactor Projects K. Landis. Chief. Branch 3. Division of Reactor Projects C. Evans. Regional Counsel. RII M. Stein. Enforcement Specialist. Office of Enforcement B. Uryc. Director. Enforcement and Investigation Coordination Staff. RII L. Watson. Enforcement Specialist. Enforcement and Investigations Coordination Staff A

e Enclosure 1

.._.._ _ .. ... ._.. ... -.. ,__ _ . .-.._.. . - . _ - ._. m.m. - - . _ . - - . _ _ . . . _ - - . ~ _ . _ . . . - - - . . . _ . _ . - _ . . _ . - ~ . . . _

l l

l l Summary Statement

.,n .

,m, i

l e FPC agrees Ms. James j discharge was inappropriate l j e Pre-incident FPC policies 1

1 and actions: l

, established an anti- i discrimination policy provided training on this policy '

j to badged employees and contractors l established an effective employee concerns program l

reacted quickly and decisively l .

to remedy the situation j 1 Enclosure 2 ll

! l

t i

i i

i Prior Established ;

i Policy

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- ' t <; s Yl' ' Efbf - " ._fA <V:t.

l :

l e In contract language l e In Control of Contractor Activities manual i

j e In badge training curriculum l e In site-wide procedures '

I a

i 1

l 1

i i

i

2

r__ _ _ - _ . _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _

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I i

Training I

. -ca auwpemw. ; . .

! e Provided to FPC contract i

! managers o Provided to badged l employees and contractors

! through GET l e Provided in the form of contractual written .

l requirements

}

i

! 3

! 1 i

l Employee Concerns

Program l

l e Effectively communicated l

i and understood l l

Within one hour of the incident Ms. '

James sought remedy through l FPC's employee concerns program ;

i j She had been referred to the

! program by another contractor firm .

who had confidence in the program l-l e Effectively implemented .

! Within two hours of the incident,

FPC had met with Ms. James and i determined her discharge was

{ inappropriate i

i I

i i

l i

l Prompt Remedy j Sought i .

i l e FPC met immediately with Ms. James

~

advised her of FPC's finding l advised her that there would be no l unfavorable termination logged in the badging records j e FPC immediately contacted '

l contractor management j advised Mr. McEnany of FPC's .

l I

finding l arranged for him to speak directly to I Ms. James on the phone i

j Mr. McEnany offered to immediately l remedy the incident i

l I

i 4

4 l Remedy (cont'd)

,,,mm _ _

l l

e FPC hired Ms. James as a l

temporary employee following the incident l

at a higher rate of pay i

l i

i i

t' .

i i

f h

) 6

1 l

l Corrective Action naa m mgk a:n:w + .

l l

l e FPC management met with l Pritts-McEnany management j to discuss expectations l before work could continue i

e Revised the standard i contract language and l require signoff by the -

i contractor site management representative l l

7 1

i l Corrective Action l (cont'd) l i

! 1 l e Implemented a new site-wide computer based training

course on the employee ,

i l concerns program t

i e Senior Nuclear Officer i

l endorsed the new CBT l course and required all .!

i personnel to complete it I

i i

?

I J

4 i

i

l l

i Corrective Action l (cont'd)

__ g--

l

. o Will use this incident as the l

basis for a case study l j the study will be required reading by j contractor management l contractor management will be j given a test on the case study that j must be passed as a condition of l contract approval I o The employee concerns l coordinator will provide

! training on the employee

! concerns program to FPC 4

}

contract managers

! 9 i --l

l I

l i

Corrective Action l

(Cont'd) l e Further revisions to the

! Control of Con;?ractor Acifivi;fies manual are being l

made

! e Additional revisions to FPC's l standard contract language are being made l

l l

A i

i 10 l

i i

l Positive Envirorunent l for Raising Concerns i L _ _ _ _

i

! e Senior management has

) taken this incident very l seriously j e The concerns program is j well advertised i

j e Many contractors (and !

! employees} have sought ~

l remedy through the concerns i

j program i

l e Precursors have increased l nearly ten-fold 11 4

i l Environment for Raising l Concerns (cont'd) s ___

l e The recent NRC inspection l of FPC's employee concerns l program ('96-09} found:

)

the program adequate

! program strengths s

j a generally positive attitude j toward the program among l those randomly interviewed i

j program weaknesses which l FPC is correcting l e FPC agrees with the l inspection results 12 l

Ft.ORIDA POWER CORPORATION Crystal River Energy Complex (SA2E) 15760 West Power Line Street l

Crystal River, FL 34428-6708 1

CONTRACT (Nunber)

(Date)

.; This contract by and between Floride Power Corporation having its principet place of business at 3201 34th Street

south hereinafter catted " Corporation," and i

4 .

l hereinafter called "Cortractor". l WITNESS THAT:

4 In consideration of the sutunt promises, covenants and agreements and other good and valuable considered set forth

! herein, the parties agree that the contractor shalt furnish, perfonn, and deliver to the Corporation the services set forth I

in the attached schedule. The Rights and obligettons of thle parties to this contract shall be adject to and governed by the following provisions hereby made a part hereof as if futty set forth herein:

APPENDICES "A" THROUGH " ", ALSO REFERRED TO ON THE ATTACHED INDEX TO APPENDICES. ]

I THE TERM OF THIS CONTRACT IS FROM THROUGH .

. TOTAL PAYMENTS UNDER THIS CONTRACT SHALL NOT EXCEED AND 00/100 DOLLARS ($ ), AND THIS AMOUNT SHALL NOT BE CHANGED EXCEPT BY A WRITTEN ;

AMENDMENT TO THIS CONTRACT. !

IN WITNESS WHEREOF, the parties hereto have entered into this contract on the day and year herein above written.

I CONTRACTOR FLORIDA POWER CORPORATION 1

l By Gary Hill

} Title -

Senior Contract Administrator i

FFD l Rev. 09/23/96 l

900 758 a - -------------_-2.-_.----- t ~ r e c > % e e o a

l l

INDEX TO APPENDICES APPENDIX "A" -

Schedule ( pages) l l

APPENDIX "B" -

Professional Services General Terms and Conditions I 902 113 which is incorporated as if fully set forth herein. l (8 pages) {

1 APPENDIX "B" -

Construction General Terms and Conditions 900 355 which is . incorporated as if fully set forth herein.

(8 pages)

APPENDIX "B" -

Services General Terms and Conditions S902 114 which is incorporated as if fully set forth herein. (4 pages)

APPENDIX " " -

Scope of Work and Specifications

( pages)

APPENDIX " " -

Price Schedule / Rate ( page) i l

APPENDIX " " -

Control of Contractor Activities Manual l (68 pages) -

APPENDIX " " -

Nuclear Operations Access Control Procedure ACP-102 or ACP-103 and ACP-104 latest Revision as appropriate, for Contractor Access Authorization Screening Program which is incorporated as if fully set forth herein. -

APPENDIX " " -

Nuclear Operations Work Authorization (N0WA)

(1 page)

APPENDIX " " -

Attachment Q (2 pages)

APPENDIX " " -

Contractor's Affidavit (2 pages) i APPENDIX " " -

Software General Terms and Conditions (4 pages) l

APPENDIX " " -

Terms and Conditions for Hardware (1 page) i APPENDIX " " -

Florida Power Corporation Contractor Hazard Communication Notification (9 pages) l l

.m

APPENDIX "A" SCHEDULE ARTICLE I SCOPE OF WORK CONTRACTOR, as an independent CONTRACTOR and not as an agent of the CORPORATION shall, in conformance with the Terms and Conditions more particularly set forth herein, provide the necessary personnel, material and facilities (except as specified herein to be furnished by CORPORATION) and do all things necessary or incidental to the furnishing and delivery to CORPORATION of the following:

WHEN APPROPRIATE: The written authorizations required to perform work under this contract shall be accomplished by use of a Nuclear Operations Work Authorization (N0WA) in accordance with Article IX.F.

ARTICLE II PERFORMANCE AND DELIVERY SCHEDULE CONTRACTOR shall complete the performance of this contract before and deliver the supplies and services required herein to CORPORATION in accordance with the following delivery schedule:

Work shall commence and TIME IS Cc THE ESSENCE FOR THIS CONTRACT 2r TIME 1 IS OF THE ESSENCE for the NOWA's issued under this :ontract based on the schedules stated therein and shall be completed by ARTICLE III PLACE OF INSPECTION AND ACCEPTANCE Final inspection and acceptance of all services shall be made at:

FLORIDA POWER CORPORATION Crystal River Unit 3 15760 West Power Line Street Crystal River, FL 34428 ARTICLE IV SUBMISSION OF INVOICES A. Invoices or vouchers for payment, with supporting information acceptable to CORPORATION shall be submitted, in duplicate, to the address below. Timesheets for work done on a time and materials basis must be provided to the Contract Manager or his designee for approval and retention.

FLORIDA POWER CORPORATION Nuclear Operations Controls (SA2I) 15760 West Power Line Street Crystal River, FL 34428-6708 Ref: Contract #

l INTERNAL ACCmJNTING DATA REERSITICW No. RA EAC ACTIVITY (FERC) & TASK SALES TAXABLE VEISOR NO.

Yam No l

_ _ . . _ _ . _ _ _ _ . _ _ _ _ _ _ __ _ _..__. ___ _ _____m ._

l l '

Each NOWA must be invoiced separately. The seventh character. of the referenced' !

l contract number can vary due to this contract having sections. The seventh character l must be that character which appears on the NOWA.

5 B. The final invoice or voucher shall be clearly designated as' the " Completion Invoice" or 1

4 1

} . " Completion Voucher".

ARTICLE V PACKAGING AND DELIVERY Unless otherwise specified in the applicable Specification (s) or Drawings, packaging and packing of all items for delivery shall be in accordance with good commercial practice and

adequate to assure safe arrival at destination.

! The delivery point of all items to be delivered by CONTRACTOR hereunder shall be F.0.B.,

i FLORIDA POWER CORPORATION, Crystal River, Florida, and unless the CONTRACTOR is notified to the contrary, shall be marked for delivery to:

3 FLORIDA POWER CORPORATION Crystal River Energy Complex

~

Crystal River Unit 3 i I

~

15760 West Power Line Street Crystal River, FL 34428-6708 i

ARTICLE VI PRICE AND PAYNENT (NOTE: INCLUDE A STATENENT TO INSURE BADGING AND TRAINING TINE l ARE IN RATES / PRICES)

A. Pricing - As compensation in full for the foregoing work and services, CORPORATION shall pay CONTRACTOR as follows:

l B. Payment I

1. CONTRACTOR agrees to accept the compensation as specified herein as full compensation i for performing all work and services and furnishing all materials, supplies and equipment necessary for satisfactorily performing this contract; and for all loss or i damage arising out of the nature of the work or from the action of the elements which

, may arise or be encountered in the prosecution of the work.

! 2. CONTRACTOR shall not be compensated for delays in the Work caused by CONTRACTOR inefficiencies, correction or rework made necessary by CONTRACTOR error, or any other corrective or productivity measures made necessary by errors, omissions or failures to properly perform the Work.

3. Payment will be made, Net 30. Retainage shall be paid only upon final acceptance of the project. CONTRACTOR'S Affidavit (Appendix " ") must accompany final invoice.

NOTE: On construction contracts, specify progress payments, the amount of each to be withheld ,

until substantial completion and a final payment upon completion. l C. CORPORATION specifically reserves the right to retention in an amount equal to all claims arising out of this contract.

i a

I Page 2 e

i D. CORPORATION shall pay only for hours worked. Lunch periods shall not be billed to CORPORATION unless previously authorized and noted on the CORPORATION'S approved time sheet.

ARTICLE VII ORDER 0F PRECEDENCE To the extent of any inconsistency between the Schedule (Appendix "A"), the General Terms and Conditions (Appendix "B"), which is incorporated as if fully set forth herein, and any specifications, or other documents, including CONTRACTOR'S proposal, which are made a part hereof either as an attachment, by reference or otherwise, the Schedule and the General Terms and Conditions shall govern. To the extent of any inconsistency between the Schedule and the General Terms and Conditions, the Schedule shall govern.

ARTICLE VIII ADDITIONAL REQUIRENENTS FOR WORK DONE AT THE CRYSTAL RIVER UNIT #3 SITE j A. CONPLIANCE WITH LAW /0RDINANCES. The CONTRACTOR is responsible for compliance with all applicable Federal and State laws and Regulations and Local Ordinances incidental to the

performance of the work contemplated herein.

Temocrary Automobile Reaistration: Section 320.1325, Florida Statutes requires automobile registration for the temporar.ily employed who are not Florida residents. A 90 day temporary plate is required and may be renewed for an additional 90 days. The fee is approximately

$40.00 plus service charges. -

Sex Discrimination: The Civil Rights Act.of 1964 prohibits sex discrimination 'in the work-place. In 1980, the Equal Employment Opportunity Commission amended the sex discrimination a guidelines and included sexual harassment as a separate form of discrimination. Any form 2 of sexual harassment, whether verbal or physical, by a CONTRACTOR employee has no place in a business environment and is a violation of law. It will not be condoned by the CORPORATION.

+

Preservina the Free Flow of Information: In accordance with 10CFR30, 40, 50, 60, 61, 70,

', and 72, CONTRACTOR is hereby advised that:

l Nothing in this contract shall be construed to prevent CONTRACTOR or CONTRACTOR emgloyees l' from communicating with CORPORATION, the NRC or other governmental agencies regarding concerns, including, but not limited to, safety, quality and radiation exposure.

CONTRACTOR shall take no action adversely affecting the compensation, terms, conditions and privileges of CONTRACTOR employees or subcontract' ors which may prohibit, restrict or

otherwise discourage any such CONTRACTOR employees or subcontractor from filing a complaint with the Department of Labor pursuant to Section 211 of the Energy Reorganization Act of

. 1984 or from engaging in any protected activity as defined in 10 CFR 50 or in paragraph

(a)(1) of 10 CFR 30, 40, 60, 61, 70 and 72.

No agreement affecting the compensation, terms, conditions and privileges of employment of CONTRACTOR'S employees or subcontractors, including an agreement to settle a complaint filed by an employee with the Department of Labor pursuant to Section 211 of the Energy Reorganization Act, may contain any provision which would prohibit, restrict, or otherwise

- discourage an employee from participating in protected activities as defined in 10 CFR 50 j or in paragraph (a)(1) of 10 CFR 30, 40, 60, 61, 70, 72, and including, but not limited to f providing information to the NRC on potential violations or other matters within the NRC's regulatory responsibilities.

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CONTRACTOR shall take no action adversely affecting the compensation, terms, conditions and privileges of employment of CONTRACTOR'S employees or subcontractors in retaliation for or as a result of any CONTRACTOR employee or subcontractor following a complaint pursuant to Section 211'of the Energy Reorganization Act of 1984 while participating in any protected activity as defined in 10 CFR 50 or in paragraph (a)(1) of 10 CFR 30, 40, 60, 61, 70 and 72.

B. CONTROL 0F CONTRACTOR ACTIVITIES AND AFFIRNATIONS.- All work conducted on this contract within the Crystal River Unit 3 Protected area shall be conducted in accordance with the .

Crystal River Unit 3 Control of Contractor Activities Manual. However, nothing in the '

Manual shall relieve the CONTRACTOR of responsibility for conducting the work in accordance with applicable governmental regulations and the term of this contract.

Personnel coming to the site are required to have read the Centrol of Contractor Activities Manual and will be required to sign that they have read and understand 'it.

Personnel coming to the site will be required to sign that they have been briefed on safety, site policies and other site requirements.

C. RADIATION EXPOSURE FOR PERSONNEL. CONTRACTOR shall adhere to the requirements of the Florida Power Corooration (FPC) Radioloaical Protection Standard Manual and its implementing procedures, a copy of which will be furnished to the CONTRACTOR upon request.

RADIOLOGICAL RESPONSIBILITIES. The CONTRACTOR shall be responsible ~ for any necessary decontamination of facilities, materials or equipment used in the performance of work at CONTRACTOR'S facilities under this contract. In the event that any such facilities, materials or equipment cannot be decontaminated in accordance with generally accepted standards, CONTRACTOR shall be responsible for any damages due to contamination of said facilities, materials or equipment.

The CONTRACTOR shall be responsible for the radiological safety of personnel at its facilities.

D. SAFETY. When the following activities are required by this contract, the following special provisions relating to safety are incorporated into this contract. The inclusion of the specific references shall not operate to relieve the CONTRACTOR from the responsibilities set forth and are not intended to be exclusive. The CONTRACTOR is responsible for the performance of the work in accordance with all applicable laws, regulations, codes and standards regarding the health and safety of employees, CORPORATION'S employees or third parties which are affected by the CONTRACTOR'S work activities.

For the specific work activities shown below, the following express references are hereby made a part hereof as if fully set forth herein.

Sandblastina: The CORPORATION does not guarantee the air quality and disclaims all

~ liability for any impact or effect of this air in conjunction with the operation of CONTRACTOR'S equipment or work activities of CONTRACTOR'S personnel. The CONTRACTOR must be capable of providing all point of use conditioning to meet any necessary air quality requirements. CONTRACTOR shall supply grade "D" breathing air for his personnel and comply with OSHA Title 29, Subpart I Personal Protective Equipment 1910.34, (d) Air Quality.

Divina Services: In the performance of diving services, the CONTRACTOR shall conduct operations to comply with CORPORATION'S Compliance Procedure CP-139 and all applicable laws, regulations, codes and accepted industry standard practices including, but not limited to, OSHA Title 29, 1910.401 through 1910.441, Subpart - T Commercial Diving Operations.

Page 4

4 Personnel employed or utilized by the CONTRACTOR to perform diving services for the i CORPORATION will be competent, certified, licensed and suitably equipped to perform the j services required herein.

! Asbestos Abatement: The CONTRACTOR is responsible for the provision of services which

! comply with the provision of Section 112 of the clean Air Act, Environmental Protection j Agency, Title 40, CFR Part 61, Subpart M and Part 763, Subpart G; OSHA Title 29, CFR Part l

1910.1001 - Asbestos, Tremolite, Anthophyllite, and Actinolite, CFR Part 1926, Subpart C -

General Safety and Health. Provisions, and CFR Part 1926.58 -

Asbestos, Tremolite,

Anthophyllite and Actinolite, as well as the .most current published " EPA Guidance for Controlling Asbestos Containing Materials in Buildings," and other applicable laws, I regulations, codes and acceptable industry standard practices.

1 The CONTRACTOR must provide a supervisor who is certified in asbestos abatement signified

! by baing a graduate of the program offered by Georgia Institute of Technology, University of Kansas, Tufts University, the University of Florida, or anj other EPA recognized 1.'urse i not listed above, if the company specifically reviews and authorizes the course anc so l informs the CONTRACTOR.

i i The CONTRACTOR'S trained supervisor must remain on the company work site at all times while

asbestos abatement services are being performed. Asbestos abatement may not be i subcontracted except to wholly owned subsidiaries or affiliate companies owned by the same parent company.

l j E. INSTALLATION OF ASBESTOS MATERIALS. While the CORPORATION does not exclusively prohibit the

use of asbestos, the use of non-asbestos substitutes and/or the development of alternative j designs to avoid the use of products containing asbestos is strongly recommended. Only if j no other alternatives are possible, should asbestos containing products be used and, even i then, such use must be justified.

i l All asbestos containing materials must be clearly marked as "CONTAINING ASBESTOS".

4

F. SAFEGUARDS INFORNATION. The provisions of 10CFR73.57 relating to CONTRACTOR employees j having access to Safeguards Information are incorporated into this contract as stated below.

i

1. Employees may have access to Safeguards Information if they are badged if appropriate, l trained and fingerprinted.

i 2. CONTRACTOR shall indemnify and hold harmless CORPORATION and its officers, employees

! and agents against any liability, including costs and attorney's fees, for failure to comply with the requirements of 10CFR73.57.

]

! -G. EMPLOYEE CONCERNS PROGRAM. The Florida Power Corporation (CORPORATION) Employee Concerns i Program applias to all personnel, including contractors and their subcontractor personnel, 4

providing services for CORPORATION. CONTRACTORS and their subcontractors are to conform to i all governmental regulations, specifically,10CFR50 Section 7 " Employee Protection",10CFR19 i " Notices, Instructions and Reports to Workers; Inspections" and to the CORPORATION'S Employee Concerns Program. All work is to be performed in strict compliance to 1 CORPORATION'S Nuclear Safety Policies and Procedures. CONTRACTOR is obligated to promptly

! advise CORPORATION of any individual's concern brought to you or filed with a governmental

agency or court in connection with work performed at CORPORATION licensed facilities. If j

CONTRACTOR requires additional information, contact the Contract Manager.

i H. CORPORATE COMPLIANCE ETHICS LINE PROGRAM. The CORPORATION has initiated a Corporate Compliance Ethics Line Program to ensure that business activities are conducted in an ethical manner. A CONTRACTOR who encounters unethical behavior or a violation of federal, l

) Page 5

,. --. . ~ . - . - . -- _ - . . . - - - - ___ .- - _ _ . -

A

$ state, local law, or regulation by a CORPORATION employee, may anonymously report such actions by dialing 1-800-683-2301, 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day, seven days per week. A number will be assigned to the allegation which includes the date, time and location of the occurrence.

The CONTRACTOR can make a follow-up call to determine the Corporate response to the allegation. The ETHICS line service is provided by Pinkerton Services Group in Charlotte,

NC. If CONTRACTOR requires additional information, contact the Contract Administrator.

4 ARTICLE IX SPECIAL PROVISIONS I The following special provisions apply to this contract.

. A. The Contract Manager is . The Contract Manager will provide scheduling

information, direction of activities within the scope of this contract, Fitness for Duty observations and acceptance of the work.

B. Any work performed outside the scope of this contract or cost incurred beyond the "Not To Exceed" amount is at CONTRACTOR'S risk, and CORPORATION will not be liable for such costs.

No work shall be performed outside the scope of this contract without the express written

! approval from the Contract Administration Department. The Contract Administrator for this

! contract is Gary Hill.

C. Evidence of insurance required by Appendix "B" must be supplied by the CONTRACTOR'S insurance carrier, marked with this contract number and returned to Mrs, J. M. Petrilli (SA2E), Florida Power Corporation, Crystal River Unit #3,15760 West Power Line St., Crystal River, FL 34428-6708.

D. CONTRACT MATERIALS (NSR Contracts 1. All materials, including spare parts and expendable materials exctpt "B" and "X" (chemicals, welding materials, fittings, cleaners, etc.) which and SR Contracts). are to be utilized in performing work in the Protected Area must be submitted to the " Contract Manager" for acceptance and release.

NOTE: If SR And QPD provides a statement regarding material control, delete this and use the QPD statement.

9E "B" and "X"

1. Any materials, including parts and consumables (e.g., weld material, fasteners, etc.)

shall require FPC Receipt Inspection, acceptance and release. For these materials the CONTRACTOR must provide, in advance of material shipment, a detailed " Bill of Materials" to the CORPORATION'S Contract Administrator for initiation of a "no charge" purchase order. -

2. Hazard Communication as required by Appendix "B", Article XXXIII and further described by the Control of contractor Activities Manual (Appendix " ") is required.

3. Unless the Contract Manager provides an exemption, all chemicals must be labeled by CORPORATION upon receipt in accordance with the Control of Contractor Mtivities Manual.

In addition, unless the chemicals provided are specified as a deliverable item, and a separate purchase order number is assigned to the chemicals, the unused quantities of Pac 2 6

+ % .-g -

.s. n.@t - a. A n g 9

. _ . _ _ _ . _ _ _ . . _ _ _ . _ _ _ _ _ . . _ _ . . ~ _ _ . . - _ . _ _ _ . _ _ _

h I these . chemicals are to be removed from the site upon contract completion. .If l 1 CONTRACTOR does not remove the aforementioned unused chemicals, CONTRACTOR agrees that

! ' CORPORATION may dispose of such chemicals at CONTRACTOR'S expense. This requirement-to remove unused chemicals only applies to materials which have not been used inside

Radiation Controlled Areas (RCA's).. For CONTRACTOR materials used inside RCA's, the

material must meet the radiological release criteria applicable to that specific type

material RCiQ.t to being returned to and removed by the contractor.

l Notice - Page 59 of the Control of Contractor Activities Manual .is a Hazard

! Communication Checklist which must be completed, marked with this contract i number, and returned to Mrs. J. M. Petrilli (SA2E), Florida Power

! , Corporation,15760 West Power Line Street, Crystal River, FL 34428-6708.

i

'4 . Control of these materials is required by regulations and/or laws. CORPORATION will i

not be held liable for delays resulting from a failure of CONTRACTOR to obtain approval for the use of materials.

1 i

! E. The materials for this work are to be delivered at no cost under separate Purchase Order. I

! A Bill of Materials must be forwarded to Gary Hill two (2) weeks prior to shipment to allow I

time for the aforementioned purchase order preparation.

l l F. The Nuclear' Operations Work Authorization (N0WA), Appendix " ", will provide the scope,

schedule and "Not To Exceed" price authorized for work. ' Any work done outside the sccpe of i the NOWA or cost incurred beyond the "Not To Exceed" price is at. CONTRACTOR'S risk, and

i. CORPORATION will not be liable for such costs. Work performed in advance of NOWA approval

by CORPORATION'S Contract Administrator or his designee is at CONTRACTOR'S risk and j CORPORATION will not be held liable for such cost.

i G. CORPORATION'S Contract Manager shall submit a punch list to CONTRACTOR within 30 days after

CONTRACTOR provides written notification of substantial completion. ,

! H. SCREENING OF PERSONNEL FOR BADGING AND ACCESS TO SECURITY SAFEGUARDS INFORMATION I i

j 1. CONTRACTOR employees shall be escorted in all Vital and Protected areas.

I OR i

i 1. CONTRACTOR compliance with Nuclear Operations Access Control Procedure ACP-102 or ACP-

103, as appropriate, and ACP-104 Revision 0 all dated 11/14/95 for Contractor Access l Authorization Screening Program (CAASP), Appendix " ", is required for unescorted access of CONTRACTOR personnel to protected and vital areas of Crystal River Unit #3.

j 'Use if they use their own oroaram 4

j 2. CONTRACTOR will badge employees under their own approved program.

3. CORPORATION will provide Continual Behavior Observation of CONTRACTOR supervisors.

4. As provided for in Article 6.15.2 of CAASP, CONTRACTOR shall transfer employee records

< to a contractor designated by CORPORATION upon request.

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.__. . .- . .- _ m . . . . . , _ .. .. . _ .-

Use if they subcontract their orocram

2. In accordance with Article 6.15.3 of CAASP, CORPORATION will badge personnel for unescorted access to Crystal River Unit #3.

3. CORPORATION will observe employees in accordance with Article 6.13.2 of CAASP.

OR

3. CORPORATION will provide Continual Behavior Observation of CONTRACTOR supervisor.

4. CORPORATION will not be held liable for delays due to badging if badge training is not scheduled through the Contract Manager.

5. As provided for in Article 6.15.2 of CAASP, CONTRACTOR shall transfer employee records to a contractor designated by CORPORATION upon request.

I. All software must be Year 2000 compliant and documentation stating that the product is Year 2000 compliant, must be provided to the Contract Administrator.

ARTICLE X PERFORMANCE AND PAYMENT BOND (use where appropriate)

The CONTRACTOR will provide a performance and--f ayment bond in the face amount of the contract at a cost of .

Page 8

9M M f' CORP 0Ratt0N

Subject:

Transmittal of Contract To:

Contract Manager

/ Mail Code

)

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Consultant Contract Number The following management reqcirements and Special Provisions are applicable to this contract:

This contract is for on-site services, the attached "On Site l Contractor / Contract Manager Responsibility Index" MUST be completed by you and returned to the undersigned.at (SA2E) for placement in the Contract File before work commences.

Nuclear Operations Work Authorizations (N0WAs) are required to be approved before any work commences. (See contract for details)

Resumes for all personnel proposed under this contract are evidence that the contractual education and experience requirements are met and must be sent to the contract file for permanent retention.

Contractor / Consultant ( ) will badge personnel via a subcontractor;

( ) will be escorted; ( ) will badge personnel under their own program.

X FPC wishes to identify satisfactory and unsatisfactory suppliers of services. When the contract is completed, it is requested that you complete the attached Contractor Survey / Rating Form and return it to my attention at SA2E.

In reviewing invoices, ensure badging and training time for unescorted access are not billed, but are included in rates and prices.

Due to special terms, a conference with me is recommended before contract commencement.

Contract Manager has attendeo Contract Manager Training.

If you have any questions, please contact me at extension 240-4331.

Gary Gary Hill Senior Contract Administrator cc: Contract File Page 9

ON SITE CONTRACTOR / CONTRACT MANAGER

RESPONSIBILITY INDEX This is a contract for "On-Site" activity by a Contractor. As assigned " Contract Manager" you are responsible to i assure that the Contractor works safely and follows all Florida Power Corporation (FPC) requirements and work

{ rules. The following index is provided to highlight important functions. Acknowledge and return this form to j Purchasing & Contract Administration (SA2E) PRIOR TO COMMENCEMENT OF WORK ON SITE.

> sCONTRACT MANAGER RESPON518tuTIES?

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?OKi 0N/AY l

Rrad/ Accept contract l

Conduct pre-job indoctrination l

Agree to monitor performance Assure that supplied personnel are qualified per contract f

l Obtain "no cost" Purchase Order for safety related/special requirement materials

! Assure Work Requests are in place prior to start of work Notify "NQC" on safety related efforts Obtain FPC approval for contractor procedures Assure use of only approved and labeled chemicals Receive Contractor Confirmation Form to ensure on-site contractor personnel are briefed on safety, etc.

Agree to monitor personnel safety Assure personnel are escorted / badged Send names of temporary contractors to S. Metzler via CCmail or interoffice correspondence Assure that work is within the contract scope Assure adherence to work procedures Assure " Work Authorization" is approved (when applicable)

Close out job

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. Mr ' 1 CONTRACTOR RESPONSIBILITIESs 1 - +

EOKi EN/AW Read / acknowledge contract i Read / acknowledge Control of Contractor Actmties Manual I

Require on-site contractor personnel to sign Contractor Confirmation Form Provide qualified personnel .

Provide Bill of Materials for any Safety Related material to be provided ("No Cost" PO is needed) ]

Submit work procedures for FPC approval prior to use on site (15 days prior to arrival)

Provide certifications for personnel and instrumentation Provide list of chemicals to be used on site (15 days prior to arrival)

Report to Contract manager prior to start of any work on site Work to be performed in accordance with FPC Work Request Comply with Work Request " Hold Point" inspections Route chemicals through FPC warehouse for chemical labeling Route all safety related/special requirement materials through FPC warehouse Keep Contract Manager informed of work progress j Submit "Out of Scope" work for FPC approval, prior to performing work i

CONTRACT MANAGER CONTRACTOR / CONTRACT NUMBER / SITE REPRESENTATIVE ,

04/26/ %

3 FLORIDA POWER CORPORATION Crystal River Energy Complex 15760 West Power Line Street ;

Crystal River, FL 34428-6708 l

\ CONTRACT l

N00904AX l i

(Number)

(Date)

September 16,1994 ;

This Contract by and between Florida Power Corporation having its principal place of business at 3201 34th Street i South hereinafter catted " Corporation," and

j. Pritts-McEnany, Inc.

8803 Industrial Drive Tampa, FL 33637 Attention: Bill Bell hereinafter catted " Contractor".

WITNESS THAT:

In consideration of the autual promises, covenants and agreements and other good and vetumble considered set forth

, herein, the parties agree that the contractor shall furnish, perform, and deliver to the Corporation the services set forth I

in the attached schedate. The Rights and obligations of the parties to this contract shall be st&Joct to and governed ty l the following provisions hereby made a part hereof as if futty set forth herein

l.

APPENDICES "A" THROUGH 'I", ALSO REFERRED TO ON THE ATTACHED INDEX TO APPENDICES.

l THE TERM 0F THIS CONTRACT IS FROM SeDtember 30. 1994 THROUGH December 31. 1995. '

I

TOTAL PAYMENTS UNDER THIS CONTRACT SHALL NOT EXCEED FIVE-HUNDRED THOUSAND AND 00/100 DOLLARS ($500.000.00), AND THIS AMOUNT SHALL NOT BE CHANGED EXCEPT BY A WRITTEN AMENDMENT TO THIS CONTRACT.

IN WITNESS WHEREOF, the parties hereto have entered into this contract on the day and year herein above written.

PRITTS-McE , INC. FLORIDA PO R CORPpRATION By f/ 15 N //>

W. L. CorIklin

%, Director, Nuclear Operations Title M. Materials and Controls l Rev. 09/01/94 FFDS NM

. 900 758

INDEX TO APPENDICES APPENDIX "A" -

Schedule (7 pages)

APPENDIX "B" -

Construction General Terms and Conditions !

900 355 (8 pages)

APPENDIX "C" -

Scope of Work and Specifications (42 pages) and Drawings 1 #101-112, #101-113, #101-114, #101-115, #101-117, #101-118,

101-119 l

APPENDIX "D" -

Price Schedule / Rate (1 page) l

APPENDIX "E" -

Control of Contractor Activities Manual l (68 pages) l l APPENDIX "F" -

Contractor Access Authorization Screening Procedure (CAASP) i to Crystal River Unit Three Nuclear Plant, Revision 1

(22 pages)

APPENDIX "G" -

Contractor's Affidavit (2 pages)

APPENDIX "H" - Notice of Commencement (1 page) j APPENDIX "I" - Geoflex PIB Warranty and Soprema Limited Warranty i (3 pages)

APPENDIX "J" - Nuclear Operations Work Authorization (N0WA) 1 (1 page) )

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2. CONTRACTOR shall not be compensated for delaye in the Work caused by CONTRACTOR inefficiencies, correction or rework made necessary by CONTRACTOR error, or any other ,

corrective or productivity measures made necessary by errors, omissions or failures to l properly perform the Work. l

$ 3. Payment will be made, Net 30. CONTRACTOR'S Affidavit (Appendix "G") must accompany each invoice, along with Releases of Lien with each invoice.

C. CORPORATION specifically reserves the right to retention in an amount equal to all claims ;

arising out of this contract, i a

ARTICLE VII ORDER OF PRECEDENCE )

To the extent of any inconsistency between the Schedule (Appendix "A"), the General Terms and i CCnditions (Appendix "B"), which is incorporated as if fully set forth herein, and any l spGcifications, or other documents, including CONTRACTOR'S proposal, which are made a part hereof either as an attachment, by reference or otherwise, the Schedule and the General Terms and Conditions shall govern. To the extent of any inconsistency between the Schedule and the General Terms and Conditions, the Schedule shall govern. j l

ARTICLE VIII ADDITIONAL REQUIRENENTS FOR WORK DONE AT THE CRYSTAL RIVER UNIT #3 SITE

! l A. CONPLIANCE WITH LAW /0RDINANCES The CONTRACTOR is responsible for compliance with all applicable Federal and State laws and Regulations and Local Ordinances incidental to the performance of the work contemplated

herein.

Temporary Automobile Reaistration: Section 320.1325, Florida Statutes requires automobile registration for the temporarily employed who are not Florida residents. A 90 day temporary plate is required and may be renewed for an additional 90 days. The fee is approximately

$40.00 plus service charges.

Sex Discrimination: The Civil Rights Aci. of 1964 prohibits sex discrimination in the work-place. In 1980, the Equal Employment Opportuaity Commission an. ended the sex discrimination guidelines and included sexual harassment as a separate form of discrimination. Any form of sexual harassment, whether verbal or physical, by a CONTRACTOR employee has no place in a business environment and is a violation of law. It will not be condoned by the CORPORATION.

Preservina the Free Flow of Information: In accordance with 10CFR30, 40, 50, 60, 61, 70, and 72, CONTRACTOR is hereby advised that:

)h Nothing in this contract shall be construed to prevent CONTRACTOR or CONTRACTOR employees from communicating with CORPORATION, the NRC or other governmental agencies regarding concerns, including, but not limited to, safety, quality and radiation exposure.

Page 3 i

CONTRACTOR shall take '1o action adversely affecting the compensation, terms, conditions and privileges of CONTRACTOR employees or subcontractors which may prohibit, restrict or otherwise discourage any such CONTRACTOR employees or subcontractor from filing a complaint O2, with the or 1984 Department of Labor from engaging pursuant in any to Section protected 211 activity as of the in defined Energy Reorganization 10 CFR Act of 50 or in paragraph (a)(1) of 10 CFR 30, 40, 60, 61, 70 and 72.

No agreement affecting the compensation, terms, conditions and privileges of employment of CONTRACTOR'S employees or subcontractors, including an agreement to settle a complaint filed by an employee with the Department of Labor pursuant to Section 211 of the Energy Reorganization Act, may contain any provision which would prohibit, restrict, or otherwise discourage an employee from participating in protected activities as defined in 10 CFR 50 l cr in paragraph (a)(1) of 10 CFR 30, 40, 60, 61, 70, 72, and including, but not limited to providing information to the NRC on potential violations or other matters within the NRC's regulatory responsibilities.

CONTRACTOR shall take no action adversely affecting the compensation, terms, conditions and l privileges of employment of CONTRACTOR'S employees or subcontractors in retaliation for or f as a result of any CONTRACTOR employee or subcontractor following a complaint pursuant to I Section 211 of the Energy Reorganization Act of 1984 while participating in any protected activity as defined in 10 CFR 50 or in paragraph (a)(1) of 10 CFR 30, 40, 60, 61, 70 and 72.

B. CONTROL OF CONTRACTOR ACTIVITIES All work conducted on this contract within the Crystal River Unit 3 Protected area shall be conducted in accordance with the Crystal River Unit 3 Control of Contractor Activities Manual, a copy of which has been furnished to the CONTRACTOR. However, nothing in the Manual shall relieve the CONTRACTOR of responsibility for conducting the work in accordance with applicable governmental regulations and the term of this contract.

C. RADIATION EXPOSURE FOR PERSONNEL CONTRACTOR shall adhere to the requirements of the Florida Power Corocration (FPC)

Radioloaical Protection Standard Manual and its implementing procedures, a copy of which will be furnished to the CONTRACTOR upon request.

D. SAFETY When the following activities are required by this contract, the following special provisions relating to safety are incorporated into this contract. The inclusion of the specific references shall not operate to relieve the CONTRACTOR from the responsibilities set forth and are not intended to be exclusive. The CONTRACTOR is responsible for the performance of the work in accordance with all applicable laws, regulations, codes and standards regarding the health and safety of employees, CORPORATION'S employees or third parties which are affected by the CONTRACTOR'S work activities.

For the specific work activities shown below, the following express references are hereby made a part hereof as if fully set forth herein.

Sandblastina: The CORPORATION does not guarantee the air quality and disclaims all liability for any impact or effect of this air in conjunction with the operation of CONTRACTOR'S equipment or work activities of CONTRACTOR'S personnel. The CONTRACTOR must be capable of providing all point of use conditioning to meet any necessary air quality requirements. CONTRACTOR shall supply grade "D" breathing air for his personnel and comply with OSHA Title 29, Subpart I Personal Protective Equipment 1910.34, (d) Air Quality.

Page 4

c McENAXY ROOFIXG, IXC. 813 988-1609 FAX 813 988-1855 3

STATE CERT. # CCC-037013 I

l IMPORTANT NOTICE TO ALL EMPLOYEES I WORKING AT A NUCLEAR POWER PLANT i ABOUT YOUR RIGHTS McENANY ROOFING BELIEVES IN PRESERVING THE FREE FLOW

OF INFORMATION BETWEEN MANAGEMENT AND OUR

{ EMPLOYEES

YOU ARE PROTECTED FROM DISCRIMINATION FOR ENGAGING IN PROTECTED ACTIVITIES

McEnany Roofing encourages all employees to notify their supervisors of any concerns they have j about any problem related to safety, quality or radiation exposure in the nuclear power plant or any possible violations of regulatory requirements. No one who has a concem about safety, quality or radiation exposure will be discriminated against in any way for raising that concern.

Your concern will be kept confidential at your request. WE WANT YOU TO TELL US ,

IF YOU SEE SOMETHING THAT CONCERNS YOU.

It is a violation of federal law to discharge or otherwise discriminate against any employee with ;

respect to his or her compensation, terms, conditions or privileges of employment because the employee provided information about possible violations of regulatory requirements or other nuclear safety concems requested the Nuclear Regulatory Commission (NRC) to take action against one's employer or testified in any NRC proceeding.

McEnany Roofing will take no action that would adversely affect the compensation, terms, conditions and privileges of an employee which would prohibit, restrict or otherwise discourage any empicyee from filing a complaint with the Department of Labor pursuant to Section 210 of the Energy Reorganization Act of 1974 or from engaging in any protected activity as defined in 10 CFR 50 or in paragraph (a)(1) of 10 CFR 30,40,60,61,70 and 72.

If you do not feel comfortable in telling your supervisor about your safety concerns or if you have told your supervisor but are not satisfied with his or her response to your safety concerns, you may ALWAYS speak to Mike McEnany directly about your concerns.

8803 Industrial Drive Tampa, Florida 33637

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e McEXAXY ROOFIVG, IXC. 813 988-1669 FAX 813-988-1855 3 ,

i STATE CERT. # CCC 037013 I i

You have the right to contact the NRC about your concerns.

U.S. Nuclear Regulatory Commission i

101 Marietta Street, Suite 3100 or Atlanta, GA 30323 i

j You also have the right to contact the Employee Liaison at the nuclear power plant at any time

to discuss any concerns you may have about your work at the nuclear power plant. )

The Employee Liaison at Florida Power Corp. Crystal River is Victor Hemandez f Phone: 352-563-2943 ext. 3762

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l 8803 Industrial Drive Tampa, Florida 33637

J

c McEXAXY ROOFIXG, IXC. 813-988-1669 FAX 813-988-1855 3

STATE CERT. # CCC-037013

! POIJCY AND PROCEDURES

! FOR INSURING COMPIJANCE WITH RULES REIATED TO j NUCLEAR PLANT ACCESS, EMPLOYEE CONCERNS AND THE FREE 1

! FLOW OF INFORMATION.

1. Mike McEnany, in his capacity as President of McEnany Roofing, Inc., will have a one on one personal meeting with each employee who is scheduled to work at a nuclear facility to review the special concerns that are present on a nuclear j power site. This meeting may be in conjunction with but must be in addition to I the General Employee Training process relating to the policies and procedures for i

plant access and in particular, the escort rules. The goal of this meeting will be to place special emphasis on the following concerns:

The differences in work performed in the environment of a nuclear power plant.

The importance of each employee having an appreciation for the responsibilities of the other employees. In particular, the importance of the role of the escort should be explained.

The importance of raising any safety concerns.

The assurance that the employee will never be penalized for raising any concern he or she has about the procedures followed by our company or the nuclear power plant that are or could be a violation of nuclear safety regulations.

8803 Industrial Drive Tampa, Florida 33637

e McESASY ROOFING, IXC.

813 988-1609 FAX 813-988-1855 3

$7 ATE CERT. # CCC-037013 -

2. Each employee will be provided with a copy of the "Important Notice to All Employees Working at a Nuclear Power Plant About Your Rights." This Notice will be posted on the company bulletin board. (The Notice will be available in Spanish for employees whose first language is i

Spanish).

3. At the beginning of each job on a nuclear power site, this policy will be reviewed with the applicable project foreman

who will have the responsibility of holding periodic meetings with the employees he or she supervised to insure

that the employees are reminded of our commitment to the free flow ofinformation. Any employee conce'. will be promptly brought to the attention of Mike McEnany.

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4 8803 Industrial Drive Tampa, Florida 33637

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l l Florida ;

Power j C O R P O R ATIO N i

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l CO NTROL OF I CONTRACTOR ACTIVITIES l

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b Y{4 Vf v b Approved / ///23/1p' G. L. Bolgt (fate Interpretation

Contact:

Manager, Purchasing and Contract Administration FILE: Cont-Act. Man Rev. 4

CONTENTS

! TOPIC PAGE J

1 Foreword i

Conduct of Contractor Employees 2 General Information 4 5

Sexual Harassment 1 , .:

4

, Contract Administration Practices 6 Company Contractor Interface 8 Contractor Access to FPC Property 9 CR-3 Parking 10 12 Security 14

Escorts 15 Tailgating 16 l Drugs, Alcohol, and Contraband 17 Regulatory Agencies 17 Solicitation 18 Safety Manual - Section - Contractors 19 Personnel Safety

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21 Medical (Health Services) 5 i

O CONTENTS TOPIC PAGE Quality Assurance 22 Compliance with Procedures 24 Health Physics 25 Hazardous Waste Volume Reduction Program 31 ALARA Program 32 Control of Plant Equipment 34 Housekeeping 35 Fire Protection 36 !

Equipment, Tools, and Personal Property 43 Use'of Communication Equipment 44 1 311 Emergency Phone System 46 l Radiological Emergency Response Plan 47 Control of Consumable Chemicals 49 ,

l Employee Concerns Program 51 Preserving the Free Flow of Information 56 Contractor Hazard Communication Notification 57 l

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l FOREWORD i Welcome to Crystal River Unit 3. We trust that your experience at our plant j will be productive and rewarding. This manual will provide to you a ,

j compilation of the requirements governing your conduct at our facility. Please l take the time to carefully read and study its contents.

Every contractor that enters our gate becomes an integral part of our team. As l a team member, you are expected to perform your work safely, follow our work

rules to the letter, and question anything that does not look right until a j satisfactory response is received. Industry experience shows that teams that i l ,

l follow their work rules and maintain a questioning attitude have the best and i safest operating . records. l l After reviewing this manual, please seek help if you require further information.

Any one of our staff would be obliged to assist you at any time. We wish you success in accomplishing your work and look forward to your help in improving f

! our plant operations.

I

, P' I 1

Bruce J. Hickle Director Nuclear Plant Operations

! September 7,1994 i

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l CONDUCT OF CONTRACTOR EMPLOYEES

.l The professional conduct of contractor employees and a strong customer service l orientation is paramount to maintai sg a successful business relationship with l Florida Power Corporation. This regt u the presence of contractor management l at the site that is as experienced in customer and employee relations (whistleblower l protection, discrimination, and harassment issues), as it is'in labor relations and the ,

l technical aspects of the service specialty being provided.

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l A number of problems occurring with supplemental labor have continued to l exacerbate the relationship FPC has had with certain contractors over the years.

l The following are some examples of this unacceptable conduct we expect to avoid .

l repeating:

I l o Defacing company property (including graffiti of any type)

I l o Willful damage to company property

~

I l o Damage to vehicles in the parking facilities l

l o Unprofessional / offensive tee-shirts (including any tending to defame the l company, its employees, or its agents)

I l o Airing grievances in the media before addressing, or attempting to l resolve them with company management, contractor management, or l union representatives l l

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l o Walkouts, sickouts, or other efforts to intentionally delay work progress I

l o Practical jokes or horseplay i

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. . . - . . . ._ -. - - - . - . - _ -.- - _----. - -. . . ~ ---

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.l CONDUCT OF CONTRACTOR EMPLOYEES (CONTINUED) l l o Other forms of belligerent behavior (e.g. urinating on walls, threats, or i

l acts of racial, sexual, ethic, or religious harassment) l l It is important that contractor management work closely with their employees to i

l clearly define and enforet their own expectations regarding employee conduct and ;

l . maintenance of a constructive contractor-customer relationship. Failure to do so l l may result in contract termination.

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GENERAL INFORMATION 1.- All work at Crystal River Unit #3 shall be done in a safe and legal manner.

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2. Normal working hours for the day shift are from 7 a.m. to 3:30 p.m. The Maintenance, Operations, and Chem-Rad Departments usuallyhave persodnel l l l

on site 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day during the week.

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3. There are no lunch facilities at CR-3. Snack machines are located-at vaHous )

locations throughout the site for your convenience. These items are to be I consumed at designated break areas. Please do not abuse these machines.

l When they do not work, leave a note and the vendor willcontact you with a ,

j refund.

4. Employees within the plant complex willbe fully clothed at all times. Fully I

I clothed means the wearing appropriate apparel for the work being performed i

which completely covers the back, chest, and shoulders and suitable shoes.

+ Hard hats, safety glasses, and hearing protection are required in plant work l areas. Foot protection shall be appropriate for work environment. Leather shoes are required. Athletic type shoes are not allowed.

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t j 5. Your identification badge shall be visible at all times, attached to the upper

chest area.

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6. Care and courtesy is required of all drivers. Safety is paramount, and speed

! limits shall be observed.

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? SEXUAL HARASSMENT The Civil Rights Act of 1964 prohibits sex discrimination in the work place.

In 1980, the Equal Employment Opportunity Commission amended the sex discrimination guidelines and include sexual harassment as a separate form of f

i discrimination. Sexual harassment is any unwelcome. sexual advance, request j for sexual favors, or other verbal or physical encounters of a sexual nature jI which affect or interfere with an individual's work performance or create an i intimidating, hostile, or offensive work environment.

! This policy applies to all employees as well as contractors, consultants, and f others who perform work for the Company.

i Florida Power Corporation's long standing practice has been to make this l Company a good place to work for all employees. Employees are expected to conduct themselves in a business-like and pleasant manner as they interact with fellow employees, as well as with the public. Each employee and supervisor has a responsibility to interact with fellow employees in a professional manner befitting a member of the Florida Power team.

Any form of sexual harassment, whether verbal or physical, by an. employee has no place in a business environment and is a violation of law. It will not be condoned by the Company. Any employee who is found to be guilty of sexual harassment can expect to be disciplined up to and including discharge.

If an employee is subjected to such unwelcome behavior, he/she should let the other party know clearly that he/she objects. If the behavior continues, the matter should be reported by the individual being harassed to his/her immediate supervisor. If the problem persists, the appropriate local Human Resources Office or Affirmative Action Systems should be contacted.

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t 1-t I CONTRACT ADMINISTRATIVE PRACTICES i

1. It is the responsibility of the Contractor to keep track of dollars (man-hours) !

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expended under an agreement to insure that the amount of the contract or Nuclear Operations Work Authorization (WA) is not exceeded. The l

! l Contractor should notify the Contract Manager wellin advance of expenditure l l

of all the authorized monies, usually at least ten (10) working days, reaching i l an authorized limit.

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2. Work should not start until a properly approved contract between the I Contractor and FPC is in place.

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3. If a Contractor performs services outside the terms of his contract, FPC f

l will/may not pay for these services. Verbal changes to contracts are not

! acceotable. All channes shall be in writing via a contract amendment.

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4. For certain contracts, FPC willexpect periodic written and/or verbal progress l reports usually on a weekly basis per contractual requirements. The content of these reports shall be agreed upon in advance by the FPC Contract /WA Manager and a Contractor Representative.

5. If a previously approved work schedule cannot be met, the FPC Contract /WA Manager should be notified as soon as possible z.fter this possibility is !

identified.

6. A Time and Materials contract reauires weekly time sheets signed by both the l Contractor and FPC Mananer to verify work performed and for use as f sunoortine detail to contractor invoices billed _against the contract.

7. Normally all material, equipment, and labor should be supplied by the Contractor. If the workscope requires FPC to support the Contractor with any of the above it should be specifically identified. 1 6

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i 1 CONTRACT ADMINISTRATIVE PRACTICES (CONTINUED)

8. Any new work not covered within the contract or WA scope of work must be

identified by a written proposal from the contractor.

l 9. In order to properly close a contract or WA the Contractor must state on his last invoice that the subject billis the final charge associated with the contract

or work authorization.

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j -l10. All work done by Contractors on CR-3 Plant Systems and Equipment must -

l have a Work Request in place. This includes work performed using PRC l approved vendor / contractor procedures.

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l 11. For certain contracts involving use of vendor supplied equipment, contractors

! l are responsible for supplying equipment, calibration certification and/or '

l l personnel certifications prior to beginning work.

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i l COMPANY-CONTRACTOR INTERFACE 4

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1. The Contractor should consult the Contract Manager listed in the contract to determine before the start of work who the FPC point of contact for direction ;

1 i and information willbe.

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. 2. Contract employees having some point of disagreement with FPC employees or other contract . personnel should address this disagreement to their l supervisor who willcontact the FPC Contract Manager to resolve the matter. ,

3. For questions about priority and schedule of work the Contract Manager is l normally the point of contact. The Nuclear Shift Supervisor (Ext. 3133) is the l

point of contact concerning operation of or changing the operational status l

j of plant equipment.

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! 4. The Shift Supervisor On Duty shall be notified of any personnel injuries that require transporting of the injured person to a medical facility. This contact f

j is necessary so that the Shift Supervisor can make the required reports to the

! NRC.

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CONTRACTOR ACCESS TO FPC PROPERTY l i l

There are three types of access control at the Crystal River Site. The first is by ,

means of security officers, barriers, and detection devices. These willbe explained l during your General Employee Training. The second is by means of fences and postings. You should not enter these areas except at proper access points and in ,

compliance with the notices posted at the areas. The third means of access control I is by principle of the need to be in an area to accomplish the job you are there to do.

The job you are contracted to do is at CR-3. Therefore, you are not to enter the CR-1 & 2 or CR-4 & 5 job sites, the CR-3 warehouse area, the CR-3 intake / waterfront area, and office areas unless your duties require you to enter.

You are permitted to park in the CR-3 main parking lot. Other areas are prohibited to contractor parking.

Inside the protected area you willbe authorized by security badge to enter those security areas necessary to perform your duties. This does not mean that you have access to all other plant areas. You will have an assigned area adjacent to your work for tool storage and breaks. You are not to go to other areas of the plant site except for the purpose of passing through as you arrive and leave the plant site.

Other areas that are off limits to contractors are FPC material storage areas and staging areas for other contract organizations. You should not congregate in areas of high traffic such as the Control Room,95' Control Complex RCA Control Point, or the Security Checkpoint at the entrance to the plant. 1 The general rule for access is simply stated. If the job you were hired to do does not require you to be in an area you do not have" access to that area.

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A CR-3 PARKING -

Allpersonnel utilizing Crystal River Unit 3 parking facilities are expected to adhere to the following policies. .

1. The main paved parking lot is on a "first come - first served" basis. When filled to capacity, additional parking is provided on the graded overflow areas.

Reserved posted spaces in the front row will only be utilized by tifose authorized individuals who have been issued special parking permits, which willbe displayed in the vehicle windshield area.

2. . Additional parking in the paved lot adjacent to the roadway and gravel areas cast of the CR-3 Security Building is available on a "first come, first served" basis.

3. . Parking in the areas specified above is restricted to within the yellow lines and roped off areas. You must have one yellow line on each side of your vehicle and be parked within the confines-of the roped boundaries.

l4. Possession or use of alcoholic beverages, non alcoholic beer, or controlled substances is strictly prohibited within the parking areas.

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5. Loitering within the parking areas is prohibited. Personnel should only be in the parking areas when traveling to or f- m his/her work station.

6. Due to explicit safety concerns, speeding will not be tolerated. Speeds in excess of 5 MPH are prohibited while in the parking areas.

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7. Company work vehicles are not allowed within the parking lot except when an l identified work need necessitates the vehicle being in the area. If a need arises to take a work vehicle into the parking area, the Security Shift Supervisor is to be notified of the reason and time it will be there.

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CR-3 PARKING (CONTINUED) 1 .

! 8. Fence line parking East of the Security Building is limited to designated ,.

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l individuals with special parking permits. j 4

Violations of the above polices willbe recorded by Security personnel. Copies will be sent to the employees respective work supervisor for actions to include appropriate disciplinary action.

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SECURITY i The purpose of having a security organization at Crystal River Unit 3 is three- fold:

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1. To- provide a high assurance against radiological sabotage which could constitute a risk to the public health and safety.

2. To protect corporate assets.

3. To help provide for a safe and productive work environment for our most valuable asset - YOU, THE EMPLOYEE.

General Employee Training is an initial requirement, the purpose of which is to acquaint you with the policies and procedures here at CR-3. The Security portion of this training session provides an overview of site security which includes personnel / equipment entry, control procedures, physical security protection systems, and the proper use of your identification badge (key card).

Picture identification is required for identification purposes in training and for initial badging, random drug testing, and if you are being red badged.

Upon arriving at the Security Building Access Control Point, all personnel and packages are subjected to search requirements. Normally, the search function is performed by means of electronic equipment, x-ray, and metal and explosive detectors. The electronic searches willat times be augmented by physical searches, pat down of personnel, and visual inspection of packages.

While the search requirements willcause some inconvenience, it should be noted

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that the goal is to prevent contraband from entering the plant area. Again, this protects YOU, THE EMPLOYEE.

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d J SECURITY (C D) 1 It is your responsibility to ensure that you follow posted and verbal instructions in the Search Area; ensure that you are issued thescorrect badge; display your badge l in the proper manner; ensure your vehicle is closed?after entering or exiting a Vital

, l Area door, ensure that it is properly secured; and, if you see something that may l or could be a problem area, report it to Security (Ext. 3199). Florida Power

! Corporation's goal is to operate in a Safe, Legal, and Efficient manner. This can

only be accomplished with your help.

Remember - SECURITY IS AN INDIVIDUAL RESPONSIBILITY! YOUR

! RESPONSIBILITY!

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1 ESCORTS ,

4 You may be requested or find it necessary to escort another individual (s) who cannot be granted unescorted access. This is an extremely important function as ysu are responsible for the safety, welfare, and conduct of your visitor (s). The

! following rules apply when escorting a visitor:

o No more than ten visitors shall be assigned to one escort, and access is i limited to those areas not locked or card key controlled. For groups up j to 10 visitors, the purpose is limited to tour or familiarization of plant, '

! not to accomplish work.

4 o No more than five visitors shall be assigned to one escort for work related purposes and/or vital area access. .

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! o Escorts will check in with the Health Physics Department prior to l escorting visitors into the Radiation Controlled Areas.

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i o Escort shall maintain both visur .ad conversational voice control over i visitor (s).

! o Escorts will not perform any work functions or other duties which l interfere with their ability to control their visitor (s).

f l- o Visitors escorted into card reader controlled areas shall be instructed to

insert their card key into the card reader (this willnot open the door but l will allow for accountability). The escort shallinsert their card key and I access willbe granted if authorized.

o Escorts will ensure the proper evacuation of their visitor (s) whenever a j

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! Site Area Emergency or General Emergency is declared.

i Escort duties can be transferred to other qualified individuals. Contact the Security

} Department to initiate a proper transfer of escort responsibilities. i i

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TAILGATING s

l Personnel are reminded that tailgating is a violation of both Federal Regulations I

and Plant Procedures.

l Tailgating is defined as the entry through a card reader controlled door behind

! another's card access initiation. -

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Your card key is required to be used each and every time you enter / exit a card I 1

reader controlled door, and then only with a green or white light indicator being l received on the card reader. A red light or door remaining locked is an indication l that you are not authorized to enter. .

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! To ignore this requirement and enter or exit under another's card entry transaction

! is tailgating and a violation of plant rules. It could also impact your safe recovery in the event of an accident if the security system cannot provide your actual 3 location.

l You may escort an individual to the plant but not to the space controlled by a

specific card reader. In this situation, it is acceptable for that person to be escorted l and providing that all requirements regarding escorts and escorted personnel are maintained.

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DRUGS, ALCOHOL, AND CONTRABAND The intent of this section is to reaffirm FPC policies dealing with drugs, controlled l

l substances and contraband as they apply to all contractors, consultants or others l who perform work for the Company on Company Premises and/or in the immediate proximity of Company employees.

s j 1. Any contract employee found selling, delivering, using, possessing, soliciting or under the influence of illegal drugs / controlled substances or alcohol willbe i directed to stop working immediately and leave company Premises. Illegal i i drugs and substances seized will be turned over to the appropriate legal

authorities. The individual's employer will be notified of the event and an -

I acceptable replacement willbe requested.

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i 2. Any contractor employee who inadvertently or intentionally attempts to introduce contraband in the Protected Area of CR-3 willbe removed from the I site and his badge pulled.

I For purpose of clarification, illegal drugs and controlled substances are defined as-but not limited to: Marijuana, Heroin, Hashish, Cocaine, Hallucinogens, l

i Depressants, Narcotics, Stimulants, or any drugs or controlled substances which are not prescribed by a licensed medical physician, or prescription drugs used in a f

manner not consistent with recognized medical procedures.

Contraband is dermed as unauthorized items, material, or substances which are j commonly prohibited at industrial sites for security, legal, or safety reasons.

Examples of such contraband would be firearms, ammunition, explosives, alcoholic l

j beverages, and controlled substances. ,

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REGULATORY AGENCIES i

l The operation of Crystal River Unit 3 is regulated by federal law through federal

agencies such as the Nuclear Regulatory Commission (NRC), Federal Emergency 2

Management Agency (FEMA), and Environmental Protection Agency (EPA). The j principal regulator is the NRC, and resident inspectors are assigned to the plant on l a full-time basis. The continued compliance with NRC requirements in day to day activities at the plant is assured by procedures, policies, and programs which must be followed. It is FPC policy that all official contact with regulatory agencies

! regarding CR-3 operation is conducted through, or under the guidance of, the Nuclear Licensing Department.

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4 SOLICITATION Florida Power Corporation expects that all employees including contractors should only be involved with work as identified by contract provisions and should not be involved with Solicitation, Selling, or Promoting products or services outside such contract provisions, either during working hours or on Florida Power Corporation property.

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I SAFETY MANUAL - SECTION - CONTRACTORS '

i It is the desire of Florida Power Corporation to have a safe work place for all 1

l personnel assigned to Crystal River Unit 3. It is our theme, as indicated by the

" SAFE, LEGAL, EFFICIENT" motto. It is the responsibility of each person

] working at Crystal River Unit 3 to perform all tasks in a safe manner to prevent injuries to themselves and fellow workers. The responsibility of the Crystal River l

! I Unit 3 Contractors safety program lies within the contractors own management and l supervision. If you observe any unsafe acts or conditions, correct any such acts .or I conditions which are within your scope of knowledge and authority. ~ Also, bring .

2 these unsafe acts to the attention of your Supervisor. Safety training for the site specific tasks, and compliance to the Code of Federal Regulation 29, Parts 1900 to ;

1910 (normally called OSHA 1910), is the responsibility of your supervision, j i

Florida Power Corporation will,at times, through the prudent person approach, bring unsafe acts and conditions to you and/or your Supervisor's attention for any l necessary correction. Repeated, documented cases of willful violation of OSHA !

1910, willbe grounds for the Security Force to remove your badge and for you to :

be escorted from the Site. Florida Power Corporation Safety l (7-240-4520) will assist in safety matters from time to time, when called upon by j your Management. This may include, but not be limited to, investigations of serious injuries and conducting safety meetings, or supplying information for these safety meetings. Working at a nuclear facility always requires a high level of awareness in order to prevent accidents and injuries. Your work could produce a " ripple effect" and cause an accident that you may not even realize. Know your limits and work boundaries and do not exceed them. When in doubt, do not proceed; ask your Supervisor. Carrying through with these thoughts and ideas will provide a safer place to work for all employees. Information to help you carry out the above safety objectives can be found in the AI-1800 series procedures with AI-1800

" Safety Management / Loss Control Policy" being the overall safety guide.

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/ERSONNEL SAFETY

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The following administrative procedures provide mandatory requirements for personnel safety control at Crystal River Unit #3.

AI-1800 - Safety Management / Loss Control Policy - Outlines the basic philosophy and assignments of responsibility necessary for a safe and healthful work environment.

AI-1801 -Heat Stress Guidelinn -Provides guidance in recognizing potential heat stress situations.

l AI-1802 - Personal Protective Eauioment Policy - Defines policy on the wearing of personal protective equipment. q AI-1803 - Safety Standards - for T ndders. Scaffolds. and Ancillarv Eouloment - Sets minimum acceptable safety standards for use of ladders and scaffold.

AI-1805 - Safe Working Practices for Confined Spaces - Describes proper work practices to be taken when opening, entering, and working in confined spaces. ,

l AI-1806 - CR-3 Safety Committee - Provides for a joint Labor / Management Committee to assist in maintaining a safe and healthful work place.

1 l AI-1808 - Near Miss - Accident and Safety Concerns Report - Establishes l guidelines and instructions for reporting potential c.ucidents and safety concerns.

AI-1809 - Use of Personnel Platforms (Man Baskets) - Provides information on use

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of personnel platform (man baskets).

i AI-1810 - Asbestos Management and Exposure Control - Provides guidelines-and controls for any asbestos activities.

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PERSONNEL SAFETY (CONTINUED)

I AI-1811 - Safety at Heights Program - Provide guidelines for safety requirements when working at heights, including controls for free climbing. ..

i i The above procedures and controls are provided for your protection and must be complied with when working at CR-3. If you have a problem in complying with any 3

of the listed safety instructions, contact your Contract Manager so he may assist

! you in complying.

j " Noncompliance is not acceptable."

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! MEDICAL (HEALTH SERVICES) ,

l Employees working on site at Crystal River for a contractor can expect to be seen

and receive initial first aid treatment for injuries incurred while working at this i plant site.

y i When the injuries are such of a serious nature, transportation willbe provided by j

l the EMT vehicle, or by a Paramedic-Rescue unit of Citrus County, when it is deemed necessary that this service is needed. This willbe to transport the injured to the nearest medical treatment facility - Seven Rivers Hospital.

I Illnesses that occur while at the plant site, not due to a work hazard, would be the !

responsibility of the employee to seek medical attention from their own physician. .

Should any illness that occurs on plant site be of such a serious nature that it would !

be prudent to have medical attention immediately, then Health Services, Crystal River will respond to that need.

Health Services, Crystal River, will not be able 'to offer " walk-in medical clinic" services to contractor employees for non-work related injuries or illnesses. l If a contractor employee is under the care and treatment of their physician and required to be on prescribed medication, this information should be given to their supervisors. Each employee should be aware that some medications have an adverse affect on the person taking it in certain instances ofjob performance - such as working in high temperature areas, on scaffolding, ladders, and around moving machinery, high voltage, etc. If there is any question, then their own physician j i

should provide a medical opinion as to their ability to perform in that job

- description.

Persons that are on medication for seizure disorders, of any type, must have a restriction placed permanently in their record, in regard to their activity. Persons that are deoendent on insulin for diabetes control, must likewise have permanent restrictions placed in their records. There are no exceptions to these two instances of medical conditions.

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QUALITY ASSURANCE Crystal River's Nuclear Power Plant design includes structures, systems and ;

components that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the safety of the public. We (FPC) are required, as a matter of law through the Code of Federal Regulations, to have contained in our Final Safety Analysis Report (FSAR), a description of the managerial and i

administrative controls that assure the safe operation of this design. These

" controls" are the requirements of the Quality Assurance Program and are the responsibility of every oerson working at Crystal River to implement. It is the successful implementation of the procedures, policies, etc., that provide FPC management with the assurance that the design p:rforms satisfactorily in service.

Section 1.7 of our FSAR establishes the Quality Assurance ' requirements for activities performed at Crystal River including those areas governing design, purchasing, document control, material handling, shipping and storage, cleaning, component installation, inspection, testing, maintenance, modification and refueling.

Quality Assurance is a systematic way of assuring that organized activities happen the way they are planned. It is a management discipline concerned with preventing problems from occurring by creating the attitudes and controls that make prevention possible.

In a more fundamental sense, the individual's responsibility for the implementation l of Crystal River's Quality Assurance Program can be summarized into the following general guidelines:

1. The quality requirements are contained in the process and procedures that establish the way we do things. They are specific, exacting, and express the intent of FPC management ~ direction for the conduct of nuclear operations. The requirements must be clearly stated so that they cannot be misunderstood.

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i i I i QUALITY ASSURANCE (CONTINUED) )

l 2. It is the responsibility of all persons at Crystal River to perform their j

tasks in a manner which yield the highest workmanship and professional

! standards possible.

l l 3. In order to achieve such results, all specifications, procedures, and

instructions are to be followed as written. If any individual finds that l

he/she cannot use a procedure as'it is written, immediately notify your I

supervisor who will obtain the required changes and approvals prior to i continuing the task. Deviation from requirements is a nonconformance

representing an absence of quality. Such deviations are documented i within FPC as Problem Reports. Contact your supervisor for direction

on initiating Problem Reports.

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! 4. The most productive method of performing work is to perform it correctly, as specified and planned - the first time. Errors resulting from l'

! poor planning or poor workmanship are required to be corrected. The t

i actions (and their associated costs) necessary to correct these errors are l preventable if the work is correctly performed. By doing your work j properly, you assure that we meet our goals and objectives of providing I safe, legal, and efficient energy at the lowest possible cost.

5. Logging of data required by procedures shall be as the work is accomplished, on the field work document, and signed by the individual j accomplishing the work and/or logging data.

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! COMPLIANCE WITH PROCEDURES a :

! Florida Power Corporation requires adherence to procedure requirements without l exception. This policy starts with the highest levels of management and continues i down through all levels of employees and contractors. Failure to comply with

! procedural requirements willsubject the offender to disciplinary action, which may l possibly include exclusion from the Protected Area.

! It is the responsibility of the Contract Manager to insure that contractor personnel l are familiar with Florida Power Corporation's procedures being , utilized.

j Contractor's procedures must be soproved by the Plant Review Committee prior

! to use in the olant. ~

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!' It is the duty of all persons (both FPC personnel and contractors) to strictly adhere to all written policies and procedures concerned with operation and support of the CR-3 Nuclear Plant. This does not mean that you should blindly follow a procedure that you know, or even suspect, to be wrong. When following a procedure and you discover the procedure is wrong, or that you cannot proceed as instructed by the procedure, STOP WORK IMMEDIATELYl!

and notify your supervisor.

The following is taken from NRC INFORMATION NOTICE NO. 87-64:

Licensees have the responsibility for ensuring the safe performance of licensed activities. In so doing, licensees must not only use trained individuals, provide adequate procedures, and maintain accurate records, but must also exercise supervision over their employees and their contractors' employees to ensure that procedures are followed and NRC requirements are met. While violations of NRC ;

requirements caused by inattention to detail and human error are unacceptable to ,

the NRC and may result in civilenforcement action, they do not subject individuals to criminal prosecution. However, violations caused by intentional acts may subject corporations, the individual wrongdoer, and others who knew and condoned such acts to criminal prosecution.

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i HEALTH PHYSICS 4

IT IS THE RESPONSIBILITY OF EVERY INDIVIDUAL ON THE SITE TO I KNOW AND TO OBSERVE PROPER RADIOLOGICAL CONTROL

PROCEDURES, PRACTICES AND POLICIES.

l Radiological Safety Policy

! Plant Management strongly supports and expects involvement in Radiological l Safety by all personnel classified as Radiation Workers while at CR-3. It is

! Management's intent that personnel exposure to Radiation and/or Radioactive i Material (s) be maintained "As Low As Reasonable- Achievable" (ALARA).

1 Enforcement Policy l

i f Any Radiation Worker who compromises Radiological Safety may be denied

! Radiation Control Area access until the Director Nuclear Plant Operations ;

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authorizes re-entry.

General Guidelines j Personnel trained in radiological control practices are available for assistance and

their instructions must be followed completely. Ask for assistance if you are l uncertain of any requirements or procedures.

L l 1. The Radiation Work Permit (RWP) is used to control all radiological l activities in the Radiation Controlled Area. Every worker must sign in l

l on an RWP prior to entry to the RCA.

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HEALTH PHYSICS (CONTINUED) l 2. CR-3 uses a " total risk assessment" approach to minimize the " total risk" l from all activities. This means that HP staff and workers willconsider l both radiological and non-radiological risks,and that the jobs willbe set l up to minimize the total risk. For example, workers will not necessarily l be required to wear respirators because of a small chance of an intake if l

their total dose can be reduced by not wearing respirators.

l Similarly, workers may not be required to wear plastics to prevent a small chance l of skin contamination when working in a heat stress environment. CR-3 is l interested in the best protection of the worker considering allthe risks,not just the l radiological risk.

Report any unsafe, hazardous, or unusual condition or practices immediately to l your foreman, supervisor, or the Florida Power Corporation Health Physics Staff so that corrective and preventive action can be taken.

Falsification of Dosimetry or other records is prohibited. .

There 'will be no eating, drinking, smoking, or chewing of tobacco or gum in any ,

area controlled for purposes of radiological protection.

l The TLD and Pocket Ion Chamber are used to determine the amount of radiation j exposure and willbe worn between the neck and waist next to each other on the l front of the body.

Any condition that could cause an unnecessary exposure to radiation must be reported immediately to FPC Health Physics. ,

Except for personal items (e.g., pens, pencils, notepads, hard hats, etc.) no material, l tools, or equipment may be removed from an RCA prior to Health Physics l performing a contamination survey.

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HEALTH PHYSICS (CONTINUED)

Tools and materials to be taken from any contaminated area must be surveyed by l Health Physics Personnel prior to removing them from the contaminated area. '

Report immediately to Health Physics any lost or damaged Dosimetry devices (TLD, PIC, etc).

I If you are uncertain of a radiation or security requirement, contact a supervisor j before proceeding any further.

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Protective clothing, dosimetry, respirators, radiation shielding, etc, are supplied ;

I when needed and shall be used as directed by Health Physics. A whole body frisk is required after removing protective clothing, prior to donning " street" clothing.

A PCM-1B whole body frisk is required when exiting the RCA.

CR-3 maintains a policy that skin and clothing contamination events are avoidable and unacceptable. Personnel are required to support this policy toward achieving the elimination of these events and reaching a goal of zero events.

In short, DON'T GET CONTAMINATED!

In the event an employee is required to work in a respirator or qualify to work in a respirator, as a part of his work,it willbe mandatory that the employee be clean shaven.

Total nudity in the dress out area is not acceptable.

These guidelines are not intended nor are they to be used as a substitute for approved procedures (See RSP-101).

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HEALTH PHYSICS (CONTINUED)

' l Prenatal Radiation Exposure Policy l

1. Emolovment l

i The FPC employment policy is:

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.l a. Hire qualified workers without any restriction on. employability related to l

their maternal or potential maternal state; l b. Provide declared pregnant. workers or workers intending to become l

pregnant with temporary employment opportunities equivalent to their '

l existing job classifications without further radiation exposure (i.e. ,

l assignment outside the RCA); and l c. Limit declared pregnant workers who do not choose the "no expo' tre" l

option to <400_ mrem during the gestation _ period, and to avoid substantial variation in monthly doses.

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. 2. Trainine In accordance with 10 CFR 19 and NRC Regulatory Guide 8.13, all individuals shall be instructed in the health protection problems associated with exposure to radioactive materials or radiation, in precautions or procedures to minimize exposure, and in the regulations that they are !

expected to observe. This includes " instructions an employer should provide j to workers and supervisors concerning radiological risks to the embryo / fetus exposed to radiation."

Training is provided such that the declared tregnant worker can make an informed decision on the relative risks and benefits of the employment.

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HEALTH PHYSICS (COhTINUED)

) 3. Declaration of Pregnancy 4

i l' Pregnant workers must be provided the opportunity, without harassment, to i voluntarily elect to utilize the additional protection provided by this policy.

This has the effect of reducing the occupational dose limits for the pregnant l

l worker and the embryo / fetus to 400 mrem for the term of the pregnancy and l-l avoiding substantial variation in the monthly dose.

Florida Power Corporation recognizes that it is the fundamental privilege and l

responsibility of the pregnant worker to decide when or whether she will I formally declare her condition to her employer. Therefore, in accordance with i Federal Radiation Protection Guidance for Occupational Exposure, pregnant l workers who desire increased protection of their embryo / fetus have the option of declaring their pregnancy or intention to become pregnant and, thereby, i' obtain increased protection for their embryo / fetus.

This declaration must be a written declaration, with the estimated date of conception, made to the Health Services (medical) staff at FPC's Safety and

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j Occupational Health Department, Health Services Section. Health Services i will provide a " Declaration of Pregnancy Form," will maintain the written l

! record of the pregnancy declaration,- and will notify the pregnant worker's appropriate supervisor or manager and the Health Physics Dosimetry Section.

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. If a pregnant worker chooses not to make this declaration, the worker's j radiological exposure will be limited to as low as reasonably achievable and within normal administrative and Federal dose limits. Under no circumstances i will an employee be harassed or coerced into declaring her pregnancy.

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! HEALTH PHYSICS (CONTINUED)

4. Acknowledgement ]

l Pregnant workers willbe provided with their own copy of Regulatory Guide j 8.13 and have access to copies of NCRP Report No. 91,Section 11,and ICRP ;

Report No. 60, paragraphs B160 thru B173. Prior to issuance of a thermoluminescent dosimeter (TLD), female workers shall acknowledge that they have been provided with the appropriate information on radiological risks to the embryo / fetus, that they understand they have the option of declaring j their pregnancy and, if declared pregnant, will be provided with temporary j employment opportunities equivalent to their existingjob classifications which limit their radiation exposure to within 500 mrem during the gestation period and which avoid substantial variation in monthly doses.

5. Additional Information/ Reminders It is deemed prudent for an obviously pregnant worker's supervisor to remind a pregnant but undeclared worker of the special provisions for protection of the embryo / fetus and to provide another copy of Regulatory Guide 8.13 to her. .This should be done in a tactful manner which does not infringe on

-personal privacy.

6. Imolementation CR-3 management and supervision are responsible for providing meaningful, equivalent employment opportunities in accordance with this policy.

. Contract workers are also covered under this policy and willbe employed for the normal duration of the contract job; i.e., pregnant workers will not be terminated earlier than what would have resulted under normal contract conditions. .

The temporary employment opportunities will be in work areas where responsibilities are similar to previous job responsibilities, such that experience and progress in careers can be maintained through the pregnancy.

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I HAZARDOUS WASTE i ,

VOLUME REDUCTION PROGRAM It is the responsibility of all personnel to keep the generation of hazardous waste l to a minimum.

f The following guidelines are to be utilized to effectively reduce the generation of ;

1 hazardous waste within the company.

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1. Do not mix solvents or solvent contaminated oil with used oil.

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4 2. Do not mix unknown liquids together. Do not mix hazardous waste and radioactive waste.

3. Prior to use, products must be carefully reviewed to minimize the use of those products which are potential hazardous waste.

4. When possible, prior to disposing, use the entire contents of containers such as grease, epoxy, spray solvents, paints, sealers, etc.

5. If a listed hazardous waste is mixed with other non-hazardous material, the resulting mixture must be handled as hazardous waste. Therefore, care should be taken to segregate hazardous, waste from non-hazardous waste to reduce the amount of hazardous waste handled.

6. Reclaim and recycle wastes where possible to minimize the disposal of hazardous waste. For example, lead-acid batteries are exempt from hazardous waste regulation if they are recycled. They must be given/ sold to a legitimate recycler, intact, and non-leaking.

7. Prior to disposing of unwanted, off-specification, or outdated products, attempt to find if the material can be utilized legitimately by another department or facility.

3. If a product is known to be a potential hazardous waste, such as a chlorinated solvent, determine if a non-hazardous substitute can be utilized.

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l ALARA PROGRAM_ uu .a . . ..

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Florida Power Corporation (FPC) is committed to the philosophy for maintaining l

occupational radiation exposure as low as reasonably achievable (ALARA) in the operation of Crystal River Unit 3 (CR-3). ..

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' The ALARA Program was designed to enhance radiation protection efforts at ,

! CR-3. Through ALARA reviews of potentially high exposure jobs and, t50s,' l utilization of ALARA techniques, we willmaintain occupational radiation exposure ,,

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as low as reasonably achievable.

The three key elements in radiation exposure reduction are time, distance, and ,

a shielding. These key elements are discussed in more detail as follows:

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In order to reduce stay time in a radiation area, the following considerations willbe made:

1. Utilization of experienced personnel.

2. Feasibility of mock-up work for familiarization of worker.

3. Pre-planning of jobs prior to beginning work.

4. Reading and understanding applicable procedures and work instructions.

5. Working efficiently by making sure all necessary equipment is available prior to starting work, performing as much of a job as possible outside radiation areas, and being aware of radiological conditions at the job site l prior to entering the RCA.

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i ALARA PROGRAM (CONTINUED) 3

b. Distance

! In order to increase the distance from the source of radiation, the following considerations willbe made:

n i 1. Utilization of long-handled tools where possible.

2. Access restriction to High Radiation Areas through the use of postings, ,

I i barriers, etc.

3. Familiarization of workers with radiation exposure rates in the work area. . j i .I

4. Staying away from known hot spots.

, l S. Moving to low dose rate areas when there are short waiting periods i during work.

i-i l 6. Keeping away from bagged or drums of Radioactive Waste. ,

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c. Shielding i

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1. Shielding of radiation sources will be evaluated by the ALARA

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Specialist / Health Physics Section of the Chem-Rad Department, utilizing j

lead blankets, lead sheets, water shielding, concrete shielding, or other l type of shielding material. <

. 2. DO NOT install or remove temporary shielding without Heath Physics,

! ALARA, and Engineering (when necessary) approval. :

! All personnel at CR-3 are ultimately responsible to make every effort to keep their exposure as low as reasonably achievable.

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! CONTROL OF PLANT EQUIPMENT f

I It is essential that all equipment in the CR-3 plant be operated only by qualified l personnel. It is the responsibility of the work supervisor to insure that those operating plant equipment are qualified. Due to our concern for loads moving over l Safety Related Equipment, you must complete our Crane Training program and be

! placed on the approved Qualifications List before operating any plant crane.

t It is equally important that you receive authorization to operate specific equipment.

This authorization requires that you contact the Nuclear Shift Supervisor (NSS) on duty and explain what you need to operate, when you plan to start and when you l

are expected to complete your task. The Nuclear Shift Supervisor will then authorize you to proceed.

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i When you have completed your job task and will no longer need to operate the

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equipment, it is important that you notify the NSS that you have completed your

task.

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! To remain qualified requires that you periodically complete a "Requalification" I training program.

! If you have any doubt as to your qualification status, contact your immediate l' supervisor. In any case, do not operate any equipment until you are sure you are i l currently qualified and have received authorization to do so.

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! Any individual who operates equipment without authorization could result in having

! the individuals badge pulled. This would prevent access into the plant. !

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HOUSEKEEPING Maintaining an acceptable level of facility and equipment safety, cleanliness, orderliness, and appearance is-the objective of our housekeeping program. Good housekeeping is essential to safe and efficient work and is your responsibility.

1. All areas, stairways, walkways, lavatories, and change rooms shall be kept clean, orderly, and clear of obstructions and debris at all times. ,

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2. You must actively do your part to minimize the generation of any waste, i particularly radiological waste. :

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a. Any disposal of liquid waste including cleaning solvents, oil, chemicals, 1

decontamination agents,- and other liquids shall be performed under the :

direction of the Nuclear Waste Supervisor.

b. Methods of decontaminating equipment and tools willbe specified by the Nuclear Waste Supervisor.

c. Prior to starting any project that will generate a large volume of Rad Waste (core drilling, removal of concrete, etc.) contact the Nuclear Waste Supervisor.

3. Proper control and disposal of combustibles is necessary for the safety of the plant., you and others.

4. The policy at CR-3 is "If you mess it up you clean it up."

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FIRE PROTECTICN.c _ ,. .

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1.0 GENERAL s -

i 1.1 A Fire Protection Program at CR-3 has been established to comply with thef' requirements set by the Nuclear Regulatory Commission. Elements of tiie f

i program are described by the CR-3 Fire Protection Plan. This is a controlled

document which may be made available through Document Control.

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1.2 These statements regarding fire protection practices do not define all aspects l of the Fire Protection Program; which are too lengthy to be included in this l

l document. Contractor managers, however, should become aware of'the .

] technical aspects of the program through familiarization with the Fire.

! Protection Plan.

1.3 Fire is an ever present threat and should be of major concern at CR-3. Bring l l

l to your supervisor's attention any condition you observe that could initiate a i fire or contribute to its propagation. Awareness of the following items should be acknowledged by every contract employee:

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i i 2.0 FIRE EMERGENCIES AND DRILLS i

1 2.1 All fires at CR-3, no matter how minor, must be reported. Contractor )

l employees must become familiar with plant procedure EM-201, Duties of an Individual Who Discovers an Emergency. This procedure directs the individual to: 4

a. Report the fire (emergency) to the Control Room.

b. Take any action she/he is qualified to perform that willaid in controlling and minimizing the effects of the emergency.

36

FIRE PROTECTION (CONTINUED)

c. Withdraw to a safe area and follow instructions issued by the Control Room. .

2.2 Florida Power Corporation endorses an orderly response to emergencies, including fire,byindividuals working at CR-3. Allcontractor personnel should be familiar with procedure .EM-205, " Assembly, Evacuation, and Personnel Accountability of CR-3 Personnel During Emergencies." Important key statements of EM-205 include:

2.2.1 During fire emergencies, all available supervisors report to their assembly area and assist in accounting for all personnel under their supervision.

l (EM-205).

2.2.2 Visitor escorts shall be responsible for providing the visitor with a brief explanation of what is occurring and escorting the visitor off-site.

l (EM-205).

2.2.3 During actual emergencies, various levels of assembly, evacuation, and l accountability may be required. EM-205 will be implemented.

Familiarity with the procedure will enhance safe and effective response to emergency conditions.

2.2.4 During a fire emergency, all contractor personnel willstay out of the fire area and other areas being used for fire brigade operations. :

2.3 Fire drills are held periodically at CR-3 to train and maintain proficiency of the CR-3 Fire Brigade. Contractor work should continue uninterrupted unless the drill is in a work area occupied by contractor employees. During such drills or during actual emergencies, do not interfere with fire brigade activities.

i Follow instructions of the Fire Team Leader.

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FIRE PROTECTION (CONTINUED) l l

l 3.0 FIRE EMERGENCY SIGNALS l

.i 3.1 The alarm for a fire is a siren sounded over the .PA system followed by an announcement of the emergency condition. "This sequence is repeated twice.

f

! l Plant procedure SP-323, Evacuation, Fire, and Security Alarm Demonstration,

! and General Employee Training, TDP-301, detail the emergency alarms used

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at CR-3. ;

i i l 4.0 SMOKING .

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.'1 4.1 Tobacco can be used in areas posted for such use. Tobacco may not be used in the berm area or en the paved entranceway within the secured area of the.

j plant. - Tobacco may not be used when traveling from one work area to l

! another through a no-smoking zone. Observe smoking restrictions and be thoughtful in disposal of smoking materials. Smoking is not permitted inside any building at CR-3.

5.0 USE OF COMBUSTIBLES i

1 5.1 CR-3 has a combustibles program to minimize the possibility and consequences of fire. AI-2200, Guidelines for Use of Combustibles, establishes the control of combustible materials, liquids and gases at CR-3. All supervisors must become familiar with this procedure. Key features of AI-2200 include:

a. No combustible materials, liquids, or gases shall be allowed in areas where safety related system or equipment would be exposed except as allowed by AI-2200 or the Senior Nuclear Fire Protection Specialist.

b. Plastic sheeting material used at CR-3 must be flame retardant.

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i e i FIRE PROTECTION (CONTINUED) !

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c. Wood used in plant must be flame retardant; treated with chemicals

approved by the plant fire protection staff.

! d. No explosive material is allowed in safety related areas of the plant without the approval of the Senior Nuclear Fire Protection Specialist.

i l e. Placement of all temporary structures and trailers must be approved by l the Senior Nuclear Fire Protection Specialist. i

) f. Cabinets, tanks, drums, and safety cans used for storage of flammable j and combustible liquids and aerosols must be UL Listed or FM approved.. i l g. Gas cylinders must be legibly labeled or coded and correctly handled, l stored and secured (tied off).

l

h. Upon completion of the work, portable compressed gas containers or l

aerosol cans must be removed from all plant areas as soon as possible.

l 6.0 BREACHING FIRE BARRIERS

! 6.1 During the course of work, fire barriers may be required to be breached or i may be found to be broken. It is the responsibility of any individual to report

! l to the Nuclear Shift Supervisor broken / damaged fire doors, fire dampers; open i fire barrier penetration seals; broken or penetrated fire barrier material on 4

! ducts, raceways, conduits and supports. CP-137, Fire Barrier Breach Report, shall be implemented if any of the above conditions are found to exist and a

. fire watch shall be established. No breach of any fire barrier shall be left unattended.

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j FIRE PROTECTION (CONTINUED)

'7.0 FIRE PREVENTION WORK PERMITS l 7.1 Plant procedures involving cutting, grinding, and welding work must be -

adhered to. These activities require that a fire watch be posted in accordance with CP-118, Fire Prevention Work Permit. If you are uncertain or have

[ questions regarding these activities or the interpretation of CP-118, consult

! your supervisor.

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8.0 FIRE EOUIPMENT 2

including Self Contained Breathing 8.1 Station fire protection equipment, i

i Apparatus (SCBAs) and turn out gear, are located at strategic locations in the

, plant and shall not be used for any purpose other than fire fighting. Access to this equipment shall not be restricted. Portable fire fighting equipment-

! shall not be removed from its assigned location except to fight fires. Mounted

! fire extinguishers are to be used only to fight fires and may be utilized by -

i 4

anyone who has been instructed in their use. All other equioment is for use !

by the olant fire briende only! Fire extinguishers used by fire watches willbe J f checked out from Building Services. ~

1 i 8.2 Fire Service systems willnot be taken out of operation without first notifying the Nuclear Shift Supervisor and obtaining the proper clearance.

8.3 Individuals found tampering with fire protection equipment willbe subject to i disciplinary action. ,

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4 1

! l FIRE PROTECTION (CONTINUED) i.

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9.0 HOUSEKEEPING ACTIVITIES i

9.1 Plant standards for housekeeping activities are contained in AI-1000, Good Housekeeping. The fire protection department supports good housekeeping l

as a deterrent to fire by controlling the conditions which contribute to its

cause.

1 9.2 As expressed in AI-1000, activities relating to cleanliness of facilities, material I and equipment; storage of tools, materials, and combustible items; and g disposal of debris, apply to all plant conditions whether shutdown or at power.

! 9.3 Accumulation of combustible debris is of major concern to the fire protection

{ department. Waste receptacles are located at central locations throughout the i l plant and it is the responsibility of the Nuclear Facility Service Supervisor to ensure that the receptacles do not contain excessive amounts of refuse.

9.4 Debris such as accumulation of rags, wood products, cardboard and other transient combustible materials must be removed within the time interval allowable by AI-2200 or before they present an unacceptable fire hazard. Oily rags and rags which contain other flammable or combustible liquids will be stored only in approved containers and will be properly labeled. These 1 1

containers must be emptied at the end of each shift.

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FIRE PROTECTION (CONTINUED)

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, 10.0 FIRE INSPECTIONS

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-10.1 Periodic inspection of fire protection related concerns are conducted as follows: ,

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a. A weekly - plant .walkthrough inspection is conducted by the fire I protection staff in accordance with plant procedure SP-809, Fire i

Protection Weekly Inspection. ,

1

b. . The inspector will be checking for violations of operating conditions j which could create or propagate fire.

c. .If hazards or conditions are found which could create or propagate ' fire, the inspector may recommend _ to plant management to stop work until the situation is rectified.

d. At a bi-weekly interval, the Area Owners will conduct a routine l inspection of their areas to verify conditions comply with plant procedures AI-1000 and AI-2200. Corrective action for any violation of the CR-3 Fire Protection Plan or personnel safety hazard willbe handled in accordance with AI-1000.

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EQUIPMENT, TOOLS, AND PERSONAL PROPERTY l 1. Tools and equipment brought into the " Protected Area" shall be clearly inventoried through Receiving Warehouse prior to use.

2. Tool usage and the bringing of un-contaminated tools into the hot-side of the f

plant should be discussed with your Contract Manager if you are working in

contaminated areas.

3. It is in your best interest not to bring valuables to the site. Lockers are not i.

available to secure these items and Florida Power willnot accept responsibility l

for any lost or stolen items.

! 4. Tools, equipment, and materials willnot be allowed to be removed from the i

! l site unless accompanied by a properly completed Material and Package Pass.

l 5. Vehicles and lunch pails willbe inspected, at exit from the site, for tools and material.

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! 6. All chemicals must be approved for use on site and shall be brought on site l through the FPC Materials Receiving Warehouse.

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i USE OF COMMUNICATION EQUIPMENT Crystal River Unit 3 has (3) basic communications systems for general use. These are the Florida Telephone Company (F.T.C.),Public Address Exchange-(PAX), and hand held radios.

F.T.C. phones are normally located in Administrative offices and shop areas. These all have four digit numbers and have a wide range of capabilities as described in the " Harris Telephone User's Handbook."

The PAX phones are found in practically all areas in the plant and is probably the system most employees should become very familiar with. These are normally gray in color and have three digit numbers. This is an extremely important and useful system because it offers the capability of making emergency announcements and paging others throughout the plant as well as two separate lines for station to station calls. PAX phones are convenient to virtually all work areas (including elevators) and for this reason should be treated with care as they could become your primary source of help in an emergency situation. The PAX PA system shall be used for EMERGENCIES ONLY.

Hand held radios are issued on an "as needed" basis and are equipped with either two or three channels. Channels generally are designated as follows:

Chn 1.- Operations Activities Chn 2 - Maintenance Activities Chn 3 - Security Activities These are to be used only for brief messages conducted in a professional manner.

(C.B. jargon is not considered acceptable.) Remember that your transmissions are monitored by everyone on the same channel.

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_ . _ _ _ - . . . . . _ . _ . _ ~ . _ . . _ . _ _ . _ . . . . _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _

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l USE OF COMMUNICATION EQUIPMENT (CONTINUED) 4 It is recognized that occasionally circumstances will require that outside or long distance personal calls be made. You are expected to reimburse FPC for all calls of this type. A monthly report is available which lists all calls in and out of the

! plant, much like your own home phone bill. This is used to accurately determine

who is responsible for cost.

L 1

Effective communication systems are vital to the safe, legal, and efficient operation of the plant. Therefore, it is expected that their use be limited to conversations of a business nature. Misuse or abuse of these systems willbe considered grounds for disciplinary action. Bird calls, wolf howls, and assorted animal noises are considered as misuse due to the fact that they may prevent someone from receiving essential information and besides that, is just plain childish behavior in a professional environment.

This information is intended to be general in nature. Specific information for normal and emergency situations should be obtained through your supervisor.

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311 EMERGENCY PHONE SYSTEM This system will enable you to report an emergency by dialing 311 on any phone located on the complex. This will activate a dedicated emergency phone located in the Control Room.

The Gontrol Room personnel will,in turn, follow an established procedure.

l When reporting an emergency, calmly and clearly state the following information:

Your name Location of the emergency Type of emergency (fire, medical, security)

If any injuries involved What action (if any) you have already taken 1

The 311 number is to be used for emergencies only. :

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RADIOLOGICAL EMERGENCY RESPONSE PLAN Florida Power Corporation possesses a Radiological Emergency Response Plan P i (RERP) that describes its response to potential radiological emergencies at the t

j Crystal River Nuclear Power Plant. In the event of an emergency this plan willbe

implemented to assure that prompt actions are taken to identify and assess the

! . nature of the emergency, and to bring it under , control in a manner that minimizes the effects on the health and safety of the public and plant personnel.

Proper action by any individual who discovers an emergency is imperative so that the RERP can be implemented as rapidly as possible. The proper actions to be .

l taken are described in EM-201, " Duties of an Individual Discovering an Emergency." Briefly, these actions include the following:

l

- Notification to the CR-3 Control Room (Ext. 3133) of the type and location of the emergency condition. ;

- Initiation of any immediate action the individual is qualified to perform j that will aid in controlling and minimizing the effect of the emergency.

- Relocation of self and nearby individuals to a safe area.

- Implementation of additional instructions issued by the Control Room.

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RADIOLOGICAL EMERGENCY RESPONSE PLAN (CONTINUED)

Some emergency conditions may be sufficiently severe to require that measures be taken to protect individuals on site. These measures may range from securing the immediate vicinity of the emergency to evacuation of the Generating Complex. All individuals on site willbe informed of any necessary protective measures by public address announcement and/or audible sirens. These methods willbe supplemented by strobe lights in high noise areas. The audible sirens that may be used to evacuate specific areas are described below:

- Steady tone: Reactor Building evacuation Pulsed tone: Site evacuation

- Pulsed tone (rapid): Auxiliary Building evacuation Upon hearing a signal to evacuate, individuals in the affected area must secure energized equipment and report to their shop for accountability. Personnel will receive additional instructions to remain assembled in the shops, report to an l assigned assembly area outside the Protected Area, or to prepare for generating l complex evacuation. Detailed instructions are contained in EM-205, " Emergency l Assembly, Evacuation, and Accountability of Personnel Within the Protected Area".

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CONTROL OF CHEMICALS AI-2001 is the CR3 Administrative Instruction that provides guidance for the control of consumable chemicals brought on-site. Please refer to this procedure for the basic philosophy and assignments of responsibilities relating to this important program.

Consumable chemical definition per AI-2001: Chemical items or chemical base products that are used in and around all areas of the plant. These products often have properties which can promote corrosion damage to plant equipment, degrade plant systems, and create health and safety hazards under certain environmental conditions. Some examples are: adhesives, abrasives, scalants, lubricants, cleaner, solvents, lab reagents, paint markers, welding and cutting chemicals, and non-destructive examination chemicals.

Programmatic highlights include the following:

1. All materials, chemicals, and other products containing chemicals shall be approved and labeled prior to entering into the CR3 protected area, unless the item is exempted as listed ia. AI-2001.

Exempted items include: Gasoline, diesci fuel, compressed gases, bulk tanker deliveries (hydrogen, nitrogen, carbon dioxide), radiochemistry standards, personal hygiene items (soap, shaving cream, lotions, etc.), office supplies, fire extinguishers, paving materials, concrete (bulk and bag mixed), pesticides being l used by the site contractor, sandblasting grits, and batteries (sealed and dry l cell).

NOTE: For items that are exempted from the labeling requirements, it is understood that these items may already have restrictions placed on them.

These restrictions include, but are not limited to, specific or designated use only areas, specific storage areas, designated exclusion areas, additional or special handling requirements, orin place contractual-adherence requirements.

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CONTROL OF CHEMICALS (CONTINUED)

! 2. Contractors who require the use of chemicals on-site shall provide the FPC Contract Manager, a minimum of 15 days prior to arrival on site, a list of the

chemicals or products along with an individual MSDS sheet and chemical '

evaluation listing the chemical constituents for each item. .

f 2 FPC shall not be responsible for any holdups if proper lead time is not ,

l provided for evaluation and labeling requirements ofitems to be used on site. ;

3. Contractors shall bring their chemical items and other products to the CR3 warehouse for labeling prior to bringing them inside the CR3 protected area.

Considerations should be given to the amount of materials being brought on site and the time involved with labeling these items. Contractors should l consider sending these items in advance to allow enough time for proper labeling.

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4. Contractors shall insure that containers are labeled properly when they l l subdivide chemical products, in accordance with the Florida Power l Corporation Hazard Communication Program.

5. Administrative persons outside FPC in charge of contract shall ensure that all persons working under the contract are aware of this CR3 policy, and that all persons shall adhere to guidelines and requirements of AI-2001.

6. Chemistry supervision, or designee, is authorized to label minute quantities of chemicals; i.e.,can of cleaning spray solvent in a tech. rep's. tool box.

7. If in doubt as to whether a product falls under the CR3 Chemical Control Program - contact your Contract Manager.

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EMPLOYEE CONCERNS PROGRAM 4 Florida Power Corporation has an Employee Concerns Program in place which !

l allows all personnel to share employee concerns with management in a confidential !

I manner, in accordance with NOD-36. ,

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{ A. Protection from Discrimination for Enganing in Protected Activities l FPC encourages personnel to notify their supervisors of concerns including matters defined in, but not limited to, items in Section B.1. Any individual

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[ may do so without fear of retribution or discrimination. In the case of i concerns involving nuclear safety, the individual is protected from retribution l

i or discrimination by the Code of Federal Regulations which defines the i concept of protected activities. If the individual feels the need to address the .

j concerns to the NRC directly, the protection of 10 CFR 50.7 also applies.

1 !

NRC Form 3 provides information on protected activities, including the

! addresses and telephone numbers of NRC Region Offices. This form is l l posted at Crystal. River Unit 3 (CR-3). Protected activides include, but are j not limited to, i

o providing information about possible violations of regulatory l

requirements or other nuclear safety concerns, l

o requesting the NRC to take action against one's employer, or

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i l o testifying in any NRC proceeding.

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EMPLOYEE CONCERNS (CONTINUED)

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. B. Employee Concerns ,

i 1. Employee concerns include, but are not limited to, any of the following: ,.

o Perception by an employee that an unidentified or unaddressed problem with equipment exists or has occurred.

o Perception by an employee that an error in design, construction, analysis, f

or fabrication exists or has occurred.

o Perception by an employee that a personnel error or procedural problem, i

related to safety, exists or has occurred.

o Perception by an employee that a problem islacking or deficient and may result in a problem.

o Perception by an employee that a policy exists which may result in a problem.

o Belief of an employee that the actions of another individual may have resulted or may result in a problem. l Perception by an employee that a deficiency related to industrial c-o 1 radiatica safety exists. i i

l Employee concerns willbe investigated and resolved to the satisfaction of FPC management.

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EMPLOYEE CONCERNS (CONTINUED)

2. Confidentiality Policy The information provided in the Employee Concerns Program form is done with the understanding that the identity of the person providing the !

information willbe kept confidential within the guidelines set forth below.

a. An individual willnot be identified by name or personal identifier in any document, conversation, or communication released to the public which relates to the information provided. It is understood that the term i "public release" encompasses any distribution outside of FPC with the

- exception of public agencies which may require this information in j furtherance of their responsibilities under law or public trust.

b. An individual's identity will be disclosed internally only to the extent required for the conduct of the investigation into the concern raised on the Employee Concerns Program form.

C. Exiting Personnel Program ,

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1. Nuclear Operations Supervisory Staff The Nuclear Operations supervisory staff has the responsibility to assure that all exiting personnel have the opportunity to identify concerns. This should be accomplished by conducting an interview between the exiting ;

individual and his/her direct supervisor. The scope of the interview should specifically address concerns. j 53

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', EMPLOYEE CONCERNS (CONTINUED)

' At a minimum, all exiting employees within the scope of NOD-36 must q complete Part 1 of an Employee Concerns Program form. Exiting employees may request a gagy of the form as completed or additional 1.

blank forms. The signed form must be submitted to the Employee L

Concerns Representative. If an exiting employee refuses to complete the .

i form, the supervisor must note the refusal on the form, sign it, and

! submit it to the Employee Concerns Representative.

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Nuclear Operations supervisors responsible for permanent, temporary, or casual FPC employees must directly implement this procedure for exiting l

i personnel. For contract personnel, see paragraph 2 below. j

2. FPC Managers of Contractors FPC atilizes contractor support in a variety of ways (e.g., direct contracts, contracts with subsections, WA contracts, contracts for general services, j turnkey contracts, etc.). In all cases, an FPC individual (contract !

manager, W.A manager, etc.) is responsible for terminating the services ;

of each contractor. The FPC person responsible for terminating )

contractor services is responsible for implementing this procedure for exiting contractor personnel. !

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i EMPLOYEE CONCERNS (CONTINUED) 2 3. Exiting Personnel i Nuclear Operations employees include employees of other FPC l.

departments that perform work for Nuclear Operations and non-FPC j personnel who perform work for Nuclear Operations at FPC. Nuclear

Operations employees are encouraged to freely voice to FPC l Management any concern or suggestion relating to Crystal River Unit 3.

I Alternatively, the concern / suggestion may be brought to the attention of the Employee Cocc:rns Representative or directly to the NRC.

When an individual has completed service for Nuclear Operations, he/she l

i is required to complete and submit Part 1 of an Employee Concerns form j to acknowledge the opportunity to document any concern not already I

being addressed. If desired, the individual may request a copy of the completed form (or blank forms). This willallow submittal of concerns on a confidential or anonymous basis.

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) RESERVING THE FREE FLOW O ORMATION The C tractor and/or its employees or subcontractors ay communicate their concerns lated to safety, uality or radiation expo re at Florida Power Corporation, .,21 Ri - it 3 Nuclear Plant to Flo ~ a Power Corporation, the NRC or other govern ntal a ncy.

If the Contractor's employees cr a subcontractor communicates a concern, the contractor may not take re aliatory actions which adversely affect their compensation, terms and cond tions (of contract or employment) or privileges.

Nor, may Contractors prohibit restrict or otherwise discourage an employee or ,

subcontractor, by contract otherwise, from filing a complaint with the l' Department of Labor.

The rights above are assure by Section 211 of the Energy Reorganization Act of 1984 and 10 CFR 30,40,5 ,60,61,70, and 72. Contractor shall assure that its Managers, Supervisors a employees are aware of their rights under these provisions.

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S FLORIDA POWER CORPORATION I i CONTRACTOR HAZARD COMMUNICATION NOTIFICATION i l

The Occupational Safety and Health Administration's (OSHA) Hazard Communication (hereinafter referred to as HAZCOM) Standard, 29 CFR 1910.1200, requires that Florida Power Corporation (hereinafter referred to as the Company) provide Contractors with certain information regarding chemical hazards present at its facilities. Prior to the start of work, the Contractor shall contact the Company representative, who will inform the Contractor as to the location .and availability of the Company's written HAZCOM Program and collection of Material Safety Data Sheets (MSDS's) for chemicals present at the facility or work location.

The Company representative will normally be the Outage or Project Manager or a designee. Copies of the written HAZCOM Program or any MSDS will be available upon request.

Similarly,the HAZCOM Standard requires that the Contractor shall,upon request, provide the Company representative with copies of MSDS's for all products or '

chemicals the Contractor uses at the job site. The Contractor is responsible for compliance with all applicable provisions of the HAZCOM Standard, including, but not limited to, the training of its employees and the establishment of a HAZCOM Program that may be required for completion of the scope of work. The Contractor shall notify all subcontractors of the availability of the Company's written HAZCOM Program and collection of MSDS's and shall be responsible for subcontractors' compliance with the HAZCOM Standard.

Chemical hazard information specific to the facility or facilities covered by the scope of work is included in Appendix A of this document.

The Contractor shall complete and sign the Hazard Communication Checklist for Contractors, included as Appendix B of this Notification. Copies of the signed Checklist willbecome part of the work contract, with the Company to retain a copy at the job site for the duration of the work performed by the contractor.

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APPENDIX A CRYSTAL RIVER NUCLEAR PLANT (UNIT 3) i PLANT-SPECIFIC CHEMICAL HAZARD INFORMATION

Material SafetV Data Sheets i

A collection of Material Safety Data Sheets (MSDS's) is available in the plant Control Room. An effort has been made to have an MSDS for all of the chemicals j - and products used on the plant site. The collection of MSDS's is broken down into 3

sections, as follows:

l Section 1 Policy and Procedures ,

! Section 2 Adhesives, Sealants l l Section 3 Chemical Agents

. Section 4 Cleaners: Environmental Surfaces

Section 5 Cleaners: Personal Section 6 Cleaners: Electronic / Electrical Equipment

, Section 7 Compounds i Section 8 Insulating Materials

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Section 9 Biocides / Herbicides / Insecticides

! Section 10 Lubricants, Penetrants, Fuels Section 11 Paints, Coatings, Surface Treating Materials l j Section 12 Solvents i i Section 13 Metals, Alloys and Related If an MSDS is not available for a chemical or product of interest, call the Safety l;

Department, Industrial Hygiene at:

. 7-231-4230 (Microwave Line) 813-866-4230 (Outside Line).

Interim safe use instructions w ill b e provided pending the receipt of a manufacturer's MSDS.

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Written Hazard Communication Program A copy of the Company's Hazard Communication (HAZCOM) Program is also available in the plant Control Room. This document describes the Company's HAZCOM labeling, training and MSDS programs and outlines the responsibilities for those programs.

Confined Spaces l Various confined spaces (e.g., tanks, pits, flumes, etc.) are present in and around the plant. A listing of confined spaces is incorporated into Plant Procedure AI-1805 and is available in the plant control room. One or more of the following conditions may exist in the confined spaces:

1. Oxygen deficiency;

2. Combustible atmospheres;

3. Toxic atmospheres (e.g., carbon monoxide, hydrogen sulfide, hydrazine, etc.).

Prior to entering any area designed as a confined space, instrumental tests of the atmosphere therein must be made. Once work has begun in a confined space, periodic testing of the atmosphere is necessary in order to determine whether safe conditions are being maintained. This is particularly important when work in confined spaces involves the use of chemicals, such as paints, solvents, adhesives and other chemicals. Welding also may cause the accumulation of toxic fumes and vapors if adequate ventilation is not maintained.

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Hn7mrdous Chemicals Hazardous chemicals or products belonging to all the categories listed on Page 1 of this Appendix may be used in and around the plant. Most of the chemicals or products are present in small quantities, such as gallon or smaller cans and bottles, aerosol containers, tubes and the like. A number of hazardous chemicals or products are present in bulk quantities (30 gallons or more for liquids, standard gas cylinders for compressed gases and 25 pounds or mort, for solids); they include, but are not limited to, the following:

Asbestos-containing materials !

I Fire barriers; Gaskets; Thermal systems insulation; Transite panels; Valve packing.

[ Note: Asbestos is a known human carcinogen (cancer-causing agent). Extreme l care must be exercised around asbestos-containing materials. If the composition of a material is in doubt, it must either be considered to l contain asbestos or a sample must be analyzed for asbestos content. l Work with asbestos must comply with all applicable federal, state and local regulations.] l l

Ammonium hydroxide - corrosive liquid, highly irritating to the skin and eyes.

Vapors are extremely irritating to the respiratory system.

Carbon dioxide - contained in the Cardox system (in the generator enclosure); !

an asphyxiant. ,

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Compressed gases - cylinders of: ,

i. Acetylene - flammable, an asphyxiant;

) Argon - inert gas, an asphyxiant; ;

Hydrogen - extremely flammable, burns with an invisible flame, explosive; l i Nitrogen - an asphyxiant; )

Nitrous oxide - an asphyxiant; when inhaled in high concentrations, produces ]

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! an anesthetic effect (" laughing gas").

Oxygen - flammable; oxygen-enriched atmospheres pose an extremely dangerous fire hazard by facilitating rapid combustion.

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Fuel oil #2 (diesel) - flammable.

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Gasoline -located east of the main plant entrance; extremely flammable, contains trace quantities of benzene, a known human carcinogen.

Halon - a chlorofluorocarbon compound utilized in the fire suppression system,it replaces oxygen in air and acts as an asphyxiant.

Hydrazine - 35% solution. Vapors may be present in the hot well. Hydrazine may cause skin sensitization as well as systemic poisoning, liver damage and red blood cell destruction. Hydrazine is a suspect carcinogen; appropriate respiratory and skin protection is necessary when working around hydrazine. ;

l Janitorial products - bleach, various cleaners, detergents, -waxes and related products; . most are skin, eye and respiratory irritants. .

Liquid nitrogen - evolved gas is an asphyxiant; contact with liquid nitrogen can cause cryogenic-type burns and freeze tissue.

Lithium hydroxide - crystalline or granular; skin and eye irritant; powder is a respiratory hazard.

4 61

V - ,

1 i

! Petroleum-based lubricants (greases, oils) - flammable, skin and eye irritants 3 j

! Sodium hydroxide (caustic soda) - causes severe chemical burns. Reacts violently

[ with-acids, acidic compounds, water and some metals. l 1

f Solvent - 1,1,1-trichloromethane; skin and eye irritant; vapors are harmful.

Additional-information regarding these materials and their location is available from h

the Company representative.

[

4 I Havardous Areas

[ Note: This section does not address radiation hazards].

Chemistry Lah Various chemical compounds are routinely handled in conjunction with plant chemistry operations. Since accurate chemical testing is vital to the safe, efficient operation of the plant, contractors must avoid the lab unless their work specifically requires them to be there.

Cooling Water Intake Fiumes When drained for maintenance, the cooling water intake fiumes represent several ;

hazards. First, the fiumes are confined spaces. Secondly, the biological growth (barnacles, mussels, etc.) in the flumes is subject to microbial decomposition and as a consequence, various gases such as ammonia, hydrogen sulfide, carbon dioxide and carbon monoxide may be present in harmful concentrations. It is imperative that atmospheric testing and ventilation be carried out prior to entry.

j 62

j l

APPENDDC B I FLORIDA POWER CORPORATION HAZARD COMMUNICATION CHECKLIST FOR CONTRACTORS ;

l

[Each item must be checked or initialed.] 1 i

Florida Power Corporation (hereinafter referred to as the " Company") has i advised the Contractor of hazardous substances in the Contractor's work area. I The Company has advised the Contractor of the location of Material Safety .

Data Sheets (MSDS's) for chemicals present in the area included in the !

Contractor's scope of work. i The Company has advised the Contractor of the location of the Company's l written Hazard Communication Program.

The Company has advised the Contractor that MSDS's are to be made j available for all chemical substances brought to the work site 'by the l Contractor. !

The Contractor's employees and the employees of any subcontractors, if l applicable, have been provided with the site-specific hazard communication l information contained in the Florida Power Corporation Contractor Hazard Communication Notification. j

have read and understand the Florida Power Corporation Contractor Hazard Communication Notification and all Appendices and agree to abide by its j provisions and provide any information requested to support the Company's Hazard Communication Program.

l H

Signature of Contractor's Authorized Representative Title Company Name' l

Date 63 l

ML20134Q276

Contents

Text

SUBJECT:

Dear Mr. Beard:

Enclosures:

Subject:

Contact:

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ML20134Q276

Text

SUBJECT:

Dear Mr. Beard:

Enclosures:

Subject:

Contact:

Navigation menu

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