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0-CNS-02 Physical care and handling of qualitydocumentation shall be conducted to maintain its integrity from the time it isgenerated until it has been either filmed or disposed of, as appropriate.
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Corrections of any magnitude shall be made in accordance with the following:
•Drawa single line through the incorrect information with black, blue, or red ink,being careful not to destroy or obliterate the incorrect information •Writethe correct information as close as possible to the incorrect information. •Initialand date the correction.
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0-CNS-02 Station Fire Marshall is responsible for givingpermission for:
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•Removal of fire‑fighting equipment from itsdesignated storage location.
•Personnel wanting to use fire protectionequipment (including hose, fittings, and fire extinguishers, etc.) from theFire Building or any other approved storage location.
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0-CNS-02 Service/Instrument Air System
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• Service air will not typically be used for other than normalair tools, breathing air equipment, and permanently installed equipmentneeds. Large air needs (i.e.,sandblasting, Intake Structure sparging, etc.) will normally be performed usinga portable unit.
• Notify the Control Room when operating equipment that useslarge amounts of service/instrument air.
•RP approval required prior to using service air forbreathing air.
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0-CNS-17 Nuclear Workers at CNS are responsible for:
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• Knowing, understanding, and complying withregulatory requirements of the functions in which they are engaged.
• Promptly reporting to Station Management anydefects in structures, systems, or components, or any condition which may leadto or cause a violation of regulations and licenses, or unnecessary exposure toradiation or radioactive material.
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0-CNS-17 COMPLIANCE WITH REGULATIONS AND PROCEDURES
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Comply with regulations and approvedprocedures. Compliance first means thatManagers, Supervisors, and nuclear workers know and understand the regulations,licensing bases, and other regulatory requirements applicable to their areas ofresponsibility, and second it means that they take all appropriate actions tocomply with those requirements as they are written.
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0-CNS-52 CONTROL OFSWITCHYARD AND TRANSFORMER YARD ACTIVITIES AT CNS
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All gates for yards outside the Protected Area will be kept closed and locked whennot required to be open for vehicle or personnel passage. •This includes times when personnel are present inside the 345 kV Substation or 161 kV Substation. •The only exception to this requirement is if an individual is posted at the gatewith no other duties than to restrict access by unauthorized personnel.
Gates inside the Protected Area Transformer Yards may be left unlocked when personnelare physically in the yards to facilitate emergency egress, but must remainlocked at all other times.
When more than one group or individual is working in a Substation: 1. Only one key is required to be issued. Additional keys may be available upon request, but each key shall bestrictly controlled. Keys can betransferred to another individual, but the Control Room shall be notified. 2. Each Work Supervisor must obtain permission for access from the Shift Manager. 3. The Work Supervisor for each group is required to sign-in to the Substation AccessLog. The Substation Access Log ismaintained by Operations in the Control Room. Sign-in may be via telecom. 4. The issued key is to be turned over to the Work Group Supervisor that remains whenone group departs. 5. The last Work Group Supervisor to depart will return key from where it was issued.
Vehicle operation in SUBSTATIONS - Permission from the Shift Manager is required prior to taking a vehicle into a Substation.
NOTE – Aerial vehiclesinclude mobile equipment such as cranes, bucket trucks, cherry pickers, diggerderricks, and backhoes. Movement of vehicles without a Work Order is limited to non-aerial vehicles utilizing standarddriving paths depicted in Attachment 3, 345 kV Substation Standard DrivingPath, and Attachment 4, 161 kV Substation Standard Driving Path.Movement of vehicles outside the standard driving paths or use of aerial vehicles mustbe specifically documented in the Work Order controlling the work.Arrangements must be made to have an Aerial Vehicle Observer, with no concurrent duties,assigned continuously while an aerial vehicle is being operated in a Substation.The Shift Manager or WCCA will identify areas that must be avoided and what controlswill be implemented during aerial vehicle work. These identified areas and controls will be documented in the Work Order.A Spotter must be used when backing any vehicle for work performed per this procedure.Large fuel trucks shall not normally be taken into Substations.Individuals operating vehicles outside of a standard driving path will be briefed on their required safe travel path.
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0-CNS-52 CONTROL OFSWITCHYARD AND TRANSFORMER YARD ACTIVITIES AT CNS
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CNSStation Operators may perform the following activities without completing a WorkOrder: - Dailyrounds and routine duties such as changing out nitrogen bottles.
- Investigationand response to Substation alarms.
Forroutine tours, evaluations, and inspections (i.e., system walkdowns,evaluations of relay alarms and annunciation, communications personnelacquiring data from specific test points, thermography data collection,dissolved gas analysis sampling, "hot stick" testing, etc.) of Substationsby NPPD Operations or CNS personnel, the following apply:
NOTE – Steps 2.10.1 through 2.10.4 are N/A for Station Operators daily rounds. - Completionof a Work Order is not required.
- Obtainpermission from on-duty Shift Manager prior to entering Substation.è5
- Personnelor Work Supervisor must log in and out of Substation Access Log. The Substation Access Log is maintained byOperations in the Control Room at CNS. Sign-in may be via telecom.
- Checkout key from Shift Manager or Security.
- Personnelshall inform Doniphan Control Center promptly after entering and prior toexiting the 345 kV or 161 kV Substations.
In CNS Substations, CNS Station Operators willnot perform tasks outside of routine operations unless controlled by Procedure7.0.1.7 with concurrence from both the Shift Manager and Doniphan ControlCenter.
No work may be performed in CNS Substationswithout CNS Shift Manager permission.
TheShift Manager provides final approval for work by issuing key for Substationaccess.è5,7
- The Shift Manager shall inform Access Control if keyis being issued from Security Access.
Itis recognized there will be occasions when emergency Substation work will benecessary. In these instances, and assoon as practical, the Work Supervisor will brief the Shift Manager on the workbeing performed.
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0-EN-HU-106 Procedure and Work lnstruction Use and Adherence
Actions to Take When Editorial Changes are ldentified While Procedure or Work lnstruction is in Progress.
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IF conditionsare discovered where Procedure or Work Instruction steps cannot or should notbe performed, THEN the step may bemarked “N/A” if ALL of the following criteria are satisfied: - The step is not needed or cannot be performeddue to the current mode, condition, or configuration of the plant.
- Marking the step N/A Does Not violate the Limitsor Precautions or initial conditions described in the Procedure or WorkInstruction.
- Marking the step N/A Does Not create an unsafecondition in the Procedure or Work Instruction.
- Marking the step N/A Does Not change the intent(method of operation or the results) of the steps or sections.
If editorial changes (see EN-AD-101 forprocedures and 0-EN-WM-105 for work instructions) are identified while using a Procedure or WorkInstruction, work may continue provided the following actions are taken withconcurrence of the supervisor:
- Line through the error and enter the correctinformation.
- User or supervisor initial and date the changeindicating supervisor concurrence was obtained.
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0-EN-HU-106
Actions To Take lf Steps Cannot Be Performed As Written
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WARNING: The performer must be aware that attempting to undo anunexpected result could worsen the situation. Only when an immediate personnel hazard orrisk of equipment damage exists should attempts be made to change the state ofthe system. For all other situations,the performer involves supervision or the Control Room Supervisorprior to changing the state.
Performance of a Procedure or Work Instruction isto be stopped if the Procedure or Work Instruction :
- Cannot be performed or completed as written.
- Is determined to be inadequate for the intendeduse.
- Conflicts with another Procedure or WorkInstruction in progress or would be in violation of approved controllingdocuments.
- Produces unexpected results.
- Performance would result in an unsafe condition,or stopping is the only way to protect the health and safety of the public orplant personnel.
- Performance would result in violation of alicense condition; plant Technical Specifications, Technical Requirements,LCOs, the ODCM, or Fire Protection requirements.
The Procedure or Work Instruction user shall do thefollowing: - Stop work and, if necessary, take actions toplace equipment in a safe condition.
- Notify the Shift Manager (SM)/Control RoomSupervisor (CRS) for any plant equipment surveillance that cannot be performedas written.
- Consult supervision to evaluate problem causeand determine follow‑up actions.
- Notify other affected workers.
- IF a Procedureor Work Instruction change is required to complete the activity, THEN process the change prior toproceeding.
- Initiate the appropriate corrective actiondocument.
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0-EN-HU-106
Backing out of a Procedure or work instruction
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Should it become necessary to back out of a Procedureor Work Instruction while performing work on equipment that is in service andcontrolled by Operations, a verbal orwritten plan must be developed and be reviewed (e.g., by another Supervisor,Lead, Operations). Appropriateschematics, P&IDs, and logic diagrams should be reviewed. Approval of the SM/CRS should be obtainedbefore proceeding.
The SM/CRS approval is not required to back outof a Procedure or Work Instruction while working on equipment that is out ofservice, equipment that does not change the plant configuration, shop work, orwork that is controlled by another work group other than Operations.
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0.12 WORKING HOUR LIMITATIONS AND PERSONNEL FATIGUEMANAGEMENT
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DISCUSSION
The Fatigue Management Program applies to ALLworkers who are granted unescorted access or who are required to physicallyreport to the Technical Support Center (TSC) or Emergency Operations Facility(EOF) in accordance with Emergency Plans and procedures.
RESPONSIBILITIES Supervisoris responsible for: NOTE – If evaluating for the issuance of a waiver and the worker'sSupervisor or Manager/Superintendent is not on-site, this responsibility may beperformed by any Manager/Superintendent or Supervisor (including the SM) who isqualified to oversee the work to be performed by the worker.
NOTE – For the purpose ofthis procedure, the designated site senior-level with requisite signatureauthority for Security is the Director of Nuclear Safety Assurance.
ShiftManager (SM) or Designated Site Senior-Level Manager is responsible for: NOTE – For the purpose of this procedure, the designated sitesenior-level with requisite signature authority for Operations Department isthe Operations Manager or General Manager of Plant Operations (GMPO).
- Determiningthat a work hour waiver is necessary to mitigate or prevent a condition adverseto safety.
- Approvalof a work hour waiver to mitigate or prevent a condition adverse to safety.
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0.12 WORKING HOUR LIMITATIONS
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Workinghour limitations apply to following: - Anyperson operating or on-site directing the operation of systems and componentsthat are classified as Maintenance Rule Risk Significant (MRRS).
- Anyperson performing maintenance or on-site directing of the maintenance ofsystems and components that are classified as MRRS.
- Performingthe duties of a Radiation Protection or Chemistry Technician required as partof the minimum shift complement for the on-site Emergency ResponseOrganization.
- Performingthe duties of Fire Brigade Leader.
- Allsupplemental employees who meet the definition of one or more of the abovecategories.
Armed members of the Security Force, CAS/SASOperators, Security Shift Supervisors, and Watch Persons (i.e., Watchman).
WORKING HOURS
NOTE – All hours spent performing duties for the Licensee shallbe included in the calculation of working hours, including all within-shiftbreak times and lunch.
- An individual shall not work more than 16 hours straight (excluding shift turnovertime) unless approved per Section 6,Waivers, of this procedure.
- An individual shall not work more than 16 hours in any 24 hour period, nor morethan 26 hours in any 48 hour period, nor more than 72 hours in any 7 day period(all excluding shift turnover time) unless approved per Section 6,Waivers, of this procedure.
- Deviations from the requirements from the rule may occur as the result of administrativeerrors or unforeseen circumstances and may constitute violations of rulerequirements. A person is considered"reset" from a deviation, whether under a waiver or otherwise, whenthey are less than the minimum hour requirements 16/24, 26/48, 72/7, have hadat least 10 hours off since last at work, and actions are in place to ensurethey will meet the maximum average work hour alternative during on-line or workhour/day-off requirements during outage.
RESTBREAKS (between work periods) NOTE 1 – One period of shift turnover, either before or aftershift, may be included in the rest break, but not both. NOTE 2 – Incidental duties are (unscheduled) work activitiesoccasionally performed off-site (including phone calls and work required by Supervisorto complete off-site) that are required by the Licensee but do not exceed anominal, cumulative 30 minutes in a single break period. These occasional 30 minute incidental dutiesshall be excluded from calculation of working hours. If duties performed off-site exceed thenominal, cumulative 30 minutes or are scheduled activities, this time iscounted in the individual's working hours and must be followed by a 10 hourbreak.
- Arest break of at least 10 hours shall be required between work periods unlessapproved per Section 6,Waivers, of this procedure.
- A rest break of at least 34 hours shall be required inany 9 day period.
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0.12 TRANSISITONS BETWEEN EXEMPT AND NON-EXEMPT
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- Cannot work > 16 hours in 24 hour period.
- Cannot work > 26 hours in 48 hour period.
- Cannot work > 72 hours in 7 day period.
- Must have a 10 hour break between successive work periods.
- Must have a 34 hour break in any 9 day period.
- For the five full weeks worked, the hours over those five weeks must average 54hours per week or less and must comply with the above work hour limits
- If CNS shortened the initial averaging period of their own decision, then theworker needs to meet the 54 hour per week limit for the weeks worked.
When entering an unplanned outage, unplanned SecuritySystem outage, or increased threat condition, CNS shall be considered to be incompliance with the rule if the schedule would have met the 54 hour calculatedaveraging period in 10CFR26.205(d)(7).
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0.12 EXCEPTIONS TOWORKING HOUR LIMITATIONS
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- PlantEmergencies - Working Hour Limitations do not apply to CNS personnel duringcall-in and staffing of ERO during declared plant emergencies classified perthe CNS Emergency Plan.
- UnannouncedEmergency Preparedness Exercises and Drills - The time individuals workunscheduled work hours for the purpose of participating in the actual conductof an unannounced emergency preparedness exercise or drill.
- CommonDefense and Security - When informed in writing by the NRC that therequirements of working hours are waived for Security personnel to ensure thecommon defense and security.
- UnplannedSecurity System Outage/Increased Threat - During the first 60 days of anunplanned Security System outage or increased threat condition, Securitypersonnel need not meet the minimum days off requirements.
- Force-on-ForceTactical Exercises - CNS should exclude from calculation of hours worked duringthe actual conduct of NRC-evaluated Force‑On‑Force tactical exercises; onlythose hours worked in excess of 54 hours during the week of the exercise.
- UncoveredWork - During the performance of uncovered work, covered workers may exceed theworking hour limitations; however, prior to resuming covered work, they shallmeet all limitations. All hours worked(covered and uncovered) must be counted.
WAIVERS
- Tothe extent practicable, CNS shall rely on the granting of waivers only toaddress circumstances that could nothave been reasonably controlled.
- Waiversto work hour controls may be granted to an individual (not groups) under thefollowing conditions:
- TheOperations Shift Manager determines that the waiver is necessary to mitigate orprevent a condition adverse to safety, the Security Manager or Security ShiftSupervisor determines that the waiver is necessary to maintain site security,or a Site Senior-Level Manager with requisite signature authority makes eitherdetermination.
- Allowedif compliance with the work hour requirements would cause:
- Aviolation of other NRC requirements, such as minimum staffing.
- Adelay in the recovery of failed plant equipment that is necessary formaintaining plant safety will occur.
- Would cause a forced reactor shutdown, powerreduction, or other similar action, as a result of exceeding a time limit for aTechnical Specification LCO
- Other immediate adverse consequences to the protection of public health and safety or the common defense and security.
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0.26 SURVEILLANCE PROGRAM
MISSED TECHNICAL SPECIFICATION/TECHNICAL REQUIREMENTS MANUAL SURVEILLANCE
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TheMISSED TECHNICAL SPECIFICATION/TECHNICAL REQUIREMENTS MANUAL SURVEILLANCE Sectionapplies to unintentionally missed surveillance tests AND shall NOT be used foroperational convenience to extend surveillance frequencies. The missed surveillance requirements areexpected to be completed at the First Reasonable Opportunity. • TheMISSED TECHNICAL SPECIFICATION/TECHNICAL REQUIREMENTS MANUAL SURVEILLANCE Sectionapplies only to those components or features which have previously had aSatisfactory Completion of Surveillance Test Procedure. Discovery that the applicable Surveillance Procedureis inadequate or has never been successfully performed does notconstitute a missed surveillance and component or feature not demonstrated tomeet applicable Surveillance Requirements is inoperable.
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0.26 SURVEILLANCE PROGRAM
Questionable validity of test data in the surveillance?
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Ifa surveillance was previously completed, reviewed, signed off, and later (e.g.,could be days or weeks), the Control Room is notified of questionable validityof test data in the surveillance: - ContactWork Week Director to ensure appropriate organizational resources dedicated to resolvingthe concern.
- Ifnecessary, re-perform surveillance to determine or establish system functionality/operability.
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0.26 SURVEILLANCE PROGRAM
1O.CFR.72 Surveillance Requirements Applicability for Dry Fuel Storage
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Inaccordance with the Certificate of Compliance (CoC) No. 72-1004, Latest Amendmentfor the NUHOMS® Storage System, only Daily or 24 hour surveillances arecontrolled by this procedure. Periodicities described in Table 1.3.1 of the CoC TechnicalSpecifications as prior to loading (PL), during loading (L), prior to movement(S), or as necessary (AN) are controlled by approved Dry Fuel Storage LoadingProcedures. The surveillance limits andconditions for periodicities PL, L, S, and AN are met and tracked within those DryFuel Loading Procedures.
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0.31EQUIPMENT STATUS CONTROL
PURPOSE
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PURPOSE- Thisprocedure provides instructions for maintaining an Equipment Status Control Program.
- Equipmentstatus control is an essential element of an effective Configuration Control Program. The complexity and wide array of activitiesperformed at CNS creates the need for a formal Equipment Status Control Programto promote safe and efficient operation. CNS Equipment Status Control Program has two goals:
- Maintainsystem and equipment operation within design requirements.
- EnsureOperations personnel are aware of equipment status for use in decision makingfor routine activities and in response to abnormal or emergency conditions.
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0.31 EQUIPMENT STATUS CONTROL
OWNERS
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- The department responsible for maintenance of normal configuration of assignedcomponents.
- IACDepartment has ownership of components listed in Operating Procedure BSystem Component Checklists.
- Thisincludes valves located closest to an instrument which can be used forisolation/equalization of an instrument and is not located in theflow path of system.
- ChemistryDepartment has ownership of components listed in Chemistry Procedure AComponent Checklists.
- Thisincludes components located in sample sinks, sample hoods, sample racks in ChemistryLabs, or components normally used for maintaining radiological equipment,monitoring, sampling, and the collection of samples.
- CNSEngineering Department has ownership of and is authorized to manipulate allmanually adjustable dampers in station ventilation systems.
NOTE – If the dampers intended position is not clear, thencontact H&V Engineer for assistance.
5. Ifthe position is changed by Operations (via procedure or in support of Procedure0.9 activities) and the intended position is clear, then Operations personnelare able to position and verify the damper. 6. OperationsDepartment has ownership of all other plant components.
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0.31 EQUIPMENT STATUS CONTROL
EQUIPMENT STATUS CONTROL
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Duringnormal plant operations, equipment status is controlled per Section 7. If a transient would result in entry intoEmergency, Abnormal, or EOPs, configuration is restored per Section 8. - Deviationsfrom normal position which will last for greater than one shift should be trackedper Section 7.1regardless of the controlling document. This is to help ensure better documentation and tracking of extended offnormal component/system configuration (i.e., some control documents that haveless stringent equipment status tracking than other methods such asSurveillances, Procedure 0.9 activities, etc.)
Examples - Throttlinga downstream valve, that is normally open, greater than one shift, because anautomatic valve is failed.
- Acomponent/portion of system is removed from service per the System OperatingProcedure and will remain out of service greater than one shift.
- A system evolution is carried over from one shift tothe next.
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0.31 EQUIPMENT STATUS CONTROL
SHIFT MANAGER
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Inthe event of a configuration control issue not covered in thisprocedure, the SM shall take those steps necessary to ensure equipment statuscontrol is maintained.
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0.31 EQUIPMENT STATUS CONTROL
PRECAUTIONS AND LIMITATIONS
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Inan emergency, any badged individual may manipulate a component outside the MainControl Room for the purpose of terminating an event which threatens personnelor plant safety. - TheControl Room shall be notified immediately following the manipulation neededfor event termination.
- Componentsmanipulated for the purpose of terminating an event which threatens personnelor plant safety shall be tracked per Section 7.
- TheShift Manager or designee may direct components to be positioned without anapproved document in response to an equipment failure not covered byexisting procedures.
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0.31 EQUIPMENT STATUS CONTROL
INDEPENDENT/CONCURRENT VERIFICATION
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Independent Verification is a series of actionsby two individuals working independently to confirm the condition of acomponent after the original act that placed it in that condition.
Requirementsof Independent Verification are satisfied by Concurrent Verification for thefollowing if improper performance would jeopardize personnel safety, result inunanticipated or adverse plant conditions, or pose an immediate threat to safeand reliable plant operation:è7 - Lifting/landinglead/jumper/boot.
- Removing/installingfuse.
- Positioningcontrol switch.
- Installing/removing4160V breaker test block and extension arm.
- Manipulatingpotential transformer doors.
- Backseating open valves.
IndependentVerification involves the following process: - Determine,prior to verification, who will fulfill the role of the Operator locating andperforming the component manipulations and who will be the Verifier of thecomponent.
- TheOperator performing the component manipulation enters the area, separated fromthe Verifier by time or physical barriers.
- TheOperator then references the procedure or lineup sheet and verifies theproper component using human performance tools such as STAR.
- TheOperator then places (or checks) the component in the intended position.
- TheVerifier enters the area, separated from the Operator performing themanipulation by time or physical barriers.
- TheVerifier references the lineup sheet or procedure and verifies thecorrect component has been identified using human performance tools such asSTAR.
- TheVerifier observes the position of the component and physically verifiescomponent position, when applicable.
- Wheneverpossible, indirect method of verification of the components status should beperformed.
Concurrent Verification - A series of actions bytwo individuals working together at the same time and place to separatelyconfirm the condition before, during, and after an action when the consequencesof an incorrect action would lead to immediate and possibly irreversible harmto the plant or personnel.
Concurrent Verification should be used whereincorrect positioning would jeopardize personnel safety, result inunanticipated or adverse plant conditions, or pose an immediate threat to safeand reliable plant operation.
ConcurrentVerification involves the following process: - Determine,prior to the verification, who will be performing the role of the Operatorlocating and performing the component manipulation and who will be the Verifierof the component.
- TheOperator performing the component manipulation locates the component andidentifies each unique identifier on the component label.è7
- TheVerifier references the lineup sheet or procedure and verifies the correctcomponent has been located. The Verifierensures the correct component has been identified and will be manipulated.
- TheOperator references the lineup sheet or procedure and verbalizes the positionin which he/she intends to place (or check) the component.
- TheOperator places (or checks) the component in the intended position.
- TheVerifier witness the positioning (or check) of the component and physicallyverifies the component position, when applicable.
- Whenever possible, indirect method of verification ofthe components status should be performed.
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0.31 EQUIPMENT STATUS CONTROL
SYSTEM COMPONENT CHECKLIST REQUIREMENTS
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NOTE – Independent/Concurrent Verification requirements may bewaived by the Operations Manager if excessive radiation exposure wouldresult. As a guideline, an exposure inexcess of 5 mrem to Independently/Concurrently Verify the position of a singlecomponent would be excessive.
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0.31 EQUIPMENT STATUS CONTROL
EQUIPMENT STATUS CONTROL DURING NORMAL PLANTOPERATIONS
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NOTE – Caution Orders are not normally used to controlconfiguration but may be required in conjunction with one of the followingmethods to warn Operators of off normal plant configuration such as a pumpdischarge valve closed.
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0.31 EQUIPMENT STATUS CONTROL
EQUIPMENTSTATUS CONTROL OF SERVICE CONNECTIONS
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- Air loads on the Service Air System larger than hand-held portable tools shallrequire authorization from the Control Room prior to use. Service air usage for personnel breathing is notconsidered a large air load and does not require Control Roomauthorization.
- Largeair loads on the Service Air System which are controlled by an approveddocument shall not require Control Room authorization beyond authorizingthe procedure.
- Anticipatedusage of > 50 gallons of demineralized water shall require Control Roomauthorization.
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0.31 EQUIPMENT STATUS CONTROL
MANUALVALVE OPERATIONS
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- Manualvalves shall be operated by hand, applying normal force to the installed valveoperating device (valve handwheel, T-handle, etc.).
- Avalve wrench or any other torque amplifying device should not be usedwhile operating a manual valve except when permission is granted by the SM orCRS on a case-by-case basis.
Checkposition of a manual valve as follows: - Valvesthat are to be verified open shall be operated in the close direction, asnecessary, to remove slack from the valve operator and movement of the valvestem verified. The valve will then beoperated in the open direction until valve is on the backseat. Operate valve in the close direction untilvalve is just off the backseat.
NOTE – A valve on the open backseat can be perceived asclosed. Enough force should be appliedto move a valve off the open backseat.
- Valvesthat are to be verified close shall be operated in the close direction, as necessary,to verify the valve is closed and not binding or difficult tooperate. Excessive force may result indamage to the valve seating surface.
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0.31 EQUIPMENT STATUS CONTROL
ELECTRICAL PROTECTIVE DEVICES
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Lockoutrelays and protective relay targets shall only be reset under followingconditions: - Allrelay targets (indications of undervoltage, grounds, overcurrent, etc.) arerecorded in the Control Room Log.
- Thecondition has been evaluated and there is no reason to expect theresetting will result in damage to the electrical equipment.
- Lockoutrelays and protective relay targets which trip shall not be reset untilinvestigated by the Engineering or Maintenance Department and approval given toreset the trip.
- Exceptionto this requirement is granted on the turbine trip lockout relay action and theReactor Recirculation System when the cause is known not to be of anelectrical failure and the trip condition has been cleared.
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0.31 EQUIPMENT STATUS CONTROL
SYSTEM LINE-UP DEVIATIONS
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Ifwhile performing a Performer Verification or an Independent Verification of aSystem Component Checklist a component is found in other than the normalposition, perform following: - Immediatelynotify the SM.
- Positionthe component as directed by the SM and initial the System Component Checklistfor Performed By.
- TheSM shall ensure an Independent/Concurrent Verification is performed.
- EnsureCondition Report is generated addressing all applicable information available.
- Recordcomponent description, AS FOUND position, and AS LEFT position on a DiscrepancySheet, and ensure it is attached to the System Component Checklist.
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0.37 MEASURING AND TEST EQUIPMENT (M&TE) CALIBRATION PROGRAM GUIDELINES
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CALIBRATION STANDARDS AND ACCURACY LIMITS
In general, calibrating standards that are usedfor calibrating M&TE should have a tolerance no > 1/4 the tolerance ofthe M&TE. An exception to thisrequirement is a limitation restricted by the state-of-the-art. However, when such exceptions are taken, theyshould be documented. The M&TESpecialist or designee should be responsible for granting concurrence to anexception for M&TE that cannot be calibrated to a 4:1 ratio.
CALIBRATIONFREQUENCIES
Theassigned calibration due date may be extended by 25% with the approval of theM&TE Specialist or designee when justified and documented. The following items shall be considered priorto a due date extension and the basis used for the decision recorded onAttachment 3:
- Pastequipment history/reliability.
- Pastequipment usage.
- Intendeduse.
- Designof the equipment.
- Plantimpact if the equipment is found to be in non-conformance during calibration.
- Intermediatetests/checks which can be performed to verify conformity prior to theextension.
- TheM&TE Specialist or designee shall update the electronic database,instrument record, and issue a new calibration sticker.
Underspecial circumstances, M&TE may be used beyond its calibration due date (asnon-calibrated M&TE) to acquire data/information for diagnostic use only.
NOCALIBRATION REQUIRED (NCR) TEST EQUIPMENT USE
Theuser of NCR test equipment (also referred to as "information only")shall ensure the correct classification of test equipment is used. If the process being measured has to meetspecified acceptance criteria, then M&TE must be used. If the work document requiring themeasurement does not specify a quantitative value, then NCR test equipment maybe used.
- Example- A Work Order requires a Craft person to measure a voltage and verify120 VAC. M&TE is required because aquantitative value is specified.
- Example- A procedure requires a Craft person to verify voltage on Terminals 2 and 3 ofTerminal Strip "AA". Noquantitative values are specified. NCRtest equipment may be used.
- Example- A Work Order requires a Craft person to verify continuity between two testpoints. No quantitative values arespecified. NCR test equipment may beused.
- Example- A procedure requires a Craft person to verify continuity between two testpoints and requires the resistance to be between 349 and 351 ohms. M&TE is required.
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0.5.OPS
OPERATIONSREVIEW OF CONDITION REPORTS/OPERABILITY DETERMINATION
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COMPENSATORYMEASURE - An interim action (taken before the final corrective action) thatmay: - Maintainor enhance an OPERABLE but Degraded or Non-Conforming SSCs capability toperform its Specified Safety Functions (RIS 2005-20, Revision 1). This includes any periodic monitoring ortesting to demonstrate continued operability.
- RestoreINOPERABLE SSCs to an OPERABLE - COMP MEAS status (RIS 2005-20, Revision 1).
- Restoreoperating margins (RIS 2005-20, Revision 1).
- Compensatefor a Degraded or Non-Conforming Condition (RIS 2005-20, Revision 1).
- Allowcorrective maintenance to be performed (RIS 2005-20, Revision 1).
- Maintain, enhance, or restore functionality to supportSSCs.
DEGRADEDCONDITION - Condition in which the qualification of a SSC or its functionalcapability is reduced. Examples ofDegraded Conditions are failures, malfunctions, deficiencies, deviations, anddefective material and equipment. Examples of conditions that can reduce the capability of a system areaging, erosion, corrosion, improper operation, and maintenance (RIS 2005-20, Revision1).
ENGINEERINGJUDGMENT - A determination based on Engineering principles, objectiveevidence, or available data that provide Reasonable Expectation the SSC willperform its normal and design function until detailed analysis, testing, andmonitoring can be performed while considering the risk of being wrong. This may include either a documented Engineeringanalysis or a judgment by a technically qualified individual based on the complexity,seriousness, and nature of the event or condition.
FUNCTIONAL/FUNCTIONALITY- An attribute of SSCs that is not controlled by TSs. A SSC is functional or has functionality whenit is capable of performing its Specified Function as set forth in theCLB. Functionality does not apply toSpecified Safety Functions, but does apply to the ability of non-TS SSCs toperform other Specified Functions that have a necessary support function (RIS2005-20, Revision 1).
IMMEDIATEDETERMINATION - The Operability Determination performed immediately afterconfirmation that a Degraded or Non-Conforming Condition exists for a SSCrequired to be operable by Technical Specifications. NON-CONFORMINGCONDITION - A condition of a SSC that involves a failure to meet the CLB ora situation in which quality has been reduced because of factors such asimproper design, testing, construction, or modification. The following are examples of non-conformingconditions (RIS 2005-20, Revision 1):
- ASSC fails to conform to one or more applicable codes or standards (e.g., theCFR, operating license, UFSAR, and/or Licensee commitments).
- AnAs-Built or As-Modified SSC does not meet CLB.
- OperatingExperience or Engineering reviews identify a design inadequacy.
- Documentationrequired by NRC requirements, such as 10CFR50.49 is not available or deficient.
OPERABLE/OPERABILITY- Defined by plant‑specific TS (RIS 2005-20, Revision 1). OperabilityCodes are used to classify Operability in ActionWay. The codes used at CNS include: - ADMIN‑NA- A condition that is an administrative issue such as documentation issues/procedureviolations and does not affect installed plant equipment.
- EQUIPMENTFUNCTIONAL - A condition where a Non-TS SSC is functional.
- INOPERABLE- A condition where a TS SSC is not OPERABLE.
- EQUIPMENTNON‑FUNCTIONAL - A condition where a Non-TS SSC is not functional.
- NOTREQUIRED - An Operability Code used in ActionWay for SSCs that are not in thescope for either Operability Determination or Functionality Assessment.
- OPERABLE- A condition where a TS SSC is OPERABLE.
- OPERABLE-COMPMEAS. - A condition where a TS SSC is OPERABLE but a Degraded or Non-ConformingCondition exists that requires Compensatory Measures based on the definitionsin Step 2.2of this section.
- OPERABLE-OPEVAL is a condition where a TS SSC is OPERABLE and an Operability Evaluation isrequired.
PROMPTDETERMINATION APrompt Determination of SSC Operability is a follow-up to an ImmediateDetermination of SSC Operability. APrompt Determination is warranted when additional information, such assupporting analysis, is needed to confirm the immediate determination. A Prompt Determination, when needed, should bedone without delay. Plant Staff shouldmake continuing progress toward completing the determination. A Reasonable Expectation of Operability mustexist while the Operability Evaluation and the Prompt Determination are beingdone. An Operability Evaluation andPrompt Determination are not always necessary. For example:
- Ifa component is declared INOPERABLE and taken out of service for repairs, aPrompt Determination (to generate additional information about the inoperability)is not necessary.
- Ifsufficient information is available at the time of the Immediate Determinationand new information will not change the outcome, a Prompt Determination is notnecessary.
Thereis no explicit time limit for completing a Prompt Determination. Nevertheless, timeliness is important andshould depend on the safety significance of the issue. For example, it may be appropriate to make aprompt Operability Determination within a few hours for situations involvinghighly safety significant SSCs. PromptDeterminations can often be done within 24 hours of discovery even ifcomplete information is not available. If more time is needed to gather additional information (such as aVendor analyses or calculations), the Licensee can evaluate the risk importanceof the additional information to decide whether to prolong the OperabilityDetermination. TS completion time is onefactor that can be used in determining an appropriate time frame within which aPrompt Determination should be completed. REASONABLEEXPECTATION - The discovery of a Degraded or Non-Conforming Condition maycall the Operability of one or more SSCs into question. A subsequent determination of Operability shouldbe based on the Licensee's "Reasonable Expectation", from theevidence collected, that the SSCs are OPERABLE and that the Operability Determinationwill support the expectation. Reasonableexpectation does not mean absolute assurance that the SSCs are OPERABLE. The SSCs may be considered OPERABLE whenthere is evidence that the possibility of failure of a SSC has increased, butnot to the point of eroding confidence in the Reasonable Expectation that theSSC remains OPERABLE. The supportingbasis for the Reasonable Expectation of SSC Operability should provide a highdegree of confidence that the SSC remains OPERABLE. It should be noted that the standard of"Reasonable Expectation" is a high standard and there is no suchthing as an indeterminate state of Operability; a SSC is either OPERABLE orINOPERABLE (RIS 2005‑20, Revision 1).
TSSUPPORT SSC - Structure, system, or component that is not mentioned in TSor required to be OPERABLE by TS that provides a necessary support function toTS SSC(s) and that support function is required for the TS SSC(s) to be able toperform their specified safety function. The key element here is the assumption that if the SUPPORT SSC was notFUNCTIONAL, the TS SSCs OPERABILITY would be in question. A critical attribute of a TS SUPPORT SSC isthat it should be expected to be FUNCTIONAL in all modes in which the supportedTS SSC is required to be OPERABLE. Thefollowing are examples of TS SUPPORT SSC(s) at CNS (Note: This list is notconsidered all inclusive): - Zsump pumps and associated power supplies.
- RBQuad FCUs and HPCI Room FCU.
- EssentialERP and SGT piping heat trace (only under certain weather conditions).
- Thecheck valves that separate the pressure maintenance portion of the CondensateSystem from the respective ECCS and RCIC Systems.
UNANALYZEDCONDITION - Exist if analyses do not exist to demonstrate that SpecifiedFunctions or Specified Safety Functions would be accomplished as required bythe CLB while the plant is operating within the limitations of the CLB. - Entryinto the Operability Determination Process is required following discovery ofany Unanalyzed Condition or accident that falls within the Current LicensingBasis (CLB) for the facility, andcalls into question the Operability of any SSC described in TSs. Engineering Judgment may be required todetermine if a condition falls within the CLBfor the facility (RIS 2005-20).
- When a potential Unanalyzed Condition is identified,Engineering assistance should be obtained to assist in evaluation of thecondition.
TheOPERATIONS REVIEW of the Condition Report should be performed within one shiftof receipt of the Condition Report. Ifan Operability issue exists, ensure an Operability Determination is performed inActionWay in a timely manner. The OPERABILITY/ FUNCTIONALITY REVIEW of the CR shallbe approved by the Shift Manager as soon as practical after receiving the CR,along with the OPERABILITY DECLARATION, if required, and is expected to becompleted within one shift of receipt of the CR. Receipt of the CR occurs after the CR iscompleted by the Originator or verbal communication of the condition by theOriginator or Supervisor.
IMMEDIATEDETERMINATION/FUNCTIONALITY ASSESSMENT
OPERABILITYASSESSMENTS
Thefollowing are examples of conditions that would typically be consideredADMIN-NA: - TPEfailures.
- Individuallate for training.
- INPOAFI/ Assessment CAP Inputs.
- INPOOE Review Documents.
- CAPPI CRs.
- Failureto meet schedule adherence goals.
- Warehousediscrepancies related to material not installed in the plant.
- SafetyReports/Near Misses.
- SchedulingIssues.
- Work Order Requests related to previously evaluatedequipment deficiencies.
Operability should be determined immediatelyupon discovery (i.e., Immediate Determination) without delay and in acontrolled manner using the best information available.
It is not acceptable to use Probabilistic RiskAssessment for making Operability Determinations.
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0-CNS-61CNS REACTIVITY MANAGEMENT PROGRAM
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OPERATIONS MANAGER - Expectations and thresholds for assigning aSenior Reactor Operator (SRO) as Reactivity Manager to provide oversight andensure formal protocol for reactivity manipulation with control rods set forthin this procedure are carried out by Control Room Operators (CROs).
Expectationsthat Shift Manager should ensure other activities which may affect corereactivity would not be performed while manipulating control rods or changingcore flow. An exception is allowed inthat control rod motion and reactor pressure changes may be performedconcurrently during plant startup, but only if all the following are met: - Approvalobtained from Reactivity Manager.
- DEHpressurization rate is constant.
REACTOR ENGINEER (RE) - Responsible for obtaining approval by ShiftManager prior to implementing any core recommendations.
- Responsible for participating in pre-jobbriefing led by the designated Reactivity Manager prior to performing significantreactivity manipulations or power changes.
- Responsible for providing clear communication ofadvice to Reactivity Manager, CRS, and CROs regarding the reactor core withoutproviding explicit directions for Operator actions.
• Exceptions may include special evolutions thatrequire continuous interaction between RE and CROs. In such situations, RE may provide directionto CROs per approved procedures. 4. Responsible for being present on-site to provideassistance for significant reactivity manipulations or power changes whenrequested.
PROGRAMMATIC CONTROLS RE shall be available to provide technical assistance to Control Room during performance of following activities: a. All deep/shallow exchanges. b. All startups, from initial rod pull to the point of adding heat.
REFUELING ACTIVITIES - Procedures shall be used to control all refueling operations including fuel handling and rod withdrawal. Procedures shall ensure all Technical Specification requirements are met and reflect following key elements:
lf fuel loading error is discovered, core alterations shall be suspended, Management notifications made, plan to correct error developed and approved, and re-commencement criteria established.
- lf fuel bundle was being carried to the core when error discovered, that bundle shall be placed in a designated set down location in fuel pool.
- Reactor Engineering has lead responsibility for resolution of fuel loading error.
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EN-LI-108-01 10 CFR 21 EVALUATIONS AND REPORTING "Reporting of Defects and Noncompliance"
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PURPOSE To identify administrative controls for reviewing, discovering, evaluating, documenting and reporting to the Nuclear Regulatory Commission (NRC) existence of a defect or failure to comply in a facility, activity or basic components of licensed facilities pursuant to 10 CFR 21.
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O-EN-Ll-100 PROCESS APPLICABILITY DETERMINATION
The process for the performance anddocumentation of evaluations pursuant to 10CFR50.59 AND 10CFR72.48
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50.59 Changes, tests and experiments.Change means a modification or addition to, or removal from, the facility or procedures that affects a design function, method of performing or controlling the function, or an evaluation that demonstrates that intended functions will be accomplished.
72.48 Changes, tests, and experiments.Change means a modification or addition to, or removal from, the facility or spent fuel storage cask design or procedures that affects a design function, method of performing or controlling the function, or an evaluation that demonstrates that intended functions will be accomplished.
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0.29. 1 LICENSE BASIS DOCUMENT CHANGES
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PURPOSE The purpose of this procedure is to establish the administrative process and controls necessary to document changes made_to the following Cooper Nuclear Station (CNS) License Basis Documents, including:
- CNS Technical Specifications (TS).
- Quality Assurance Program for Operation - Policy Document (QAPD),
- Emergency Plan (E-Plan).
- Safeguards Plan.
- Technical Specification Bases (TS Bases).
- Technical Requirements Manual (TRM).
- Off-Site Dose Assessment Manual (ODAM).
- Process Control Program (PCP).
- Plant Unique Analysis Report (PUAR).
- 10CFR72.212 Report,
- Cyber Security Plan.
RESPONSIBILITIES Safety Review and Audit Board'(SRAB) is responsible for reviewing the following prior to submittal to the NRC for approval:
NOTE - Revisions to a proposed Technical Specification or Operating License change require SRAB review only when the revision involves a significant change to the technical basis for the proposed change.
Proposed changes to Appendix A Technical Specifications or the CNS Operating License.
License Amendment Requests required per 1OCFR50.59(c)(2) or License Condition 2.C.(4)
License Amendment Requests for changes that constitute a decrease in effectiveness or a reduction in commitment pursuant to 50.54(a), (p), or (q)
LBDCR (ATTACHMENT 1) INITIATION AND PROCESSING
NOTE - lf a TS Bases change is associated with a change to the TS, it must be submitted to the NRC in conjunction with the requested TS change.
PRIOR NRC APPROVAL REQUIRED - LBDCR APPROVAL AND IMPLEMENTATION
NOTE - Per 10CFR50.54(a)(iv), changes to the QA Plan which reduce the level of NPPD commitment are regarded as approved by the NRC upon receipt of formal notification from the NRC or 60 days after submittal, whichever occurs first.
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EN-LI-129, “Notice of Enforcement Discretion”
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PURPOSE The purpose of this procedure is to provide guidance for requesting that the Nuclear Regulatory Commission (NRC) exercise enforcement discretion from Technical Specifications (TS) or operating license conditions.
DEFINITIONS - Compensatory Actions - For the purpose of an NOED request, compensatory actions (or compensatory measures) are those temporary actions taken to provide reasonable assurance the necessary function as detailed in the TS or license condition will be compensated for during the period of the NOED. Compensatory measures include but are not limited to actions such as fire watches, administrative controls, temporary mod ifications, maintenance stoppages, and features of components. Such actions can reduce both the duration and the magnitude of the elevated risk condition, thereby reducing the incremental risk incurred. Compensatory actions eliminate or reduce the additional risk associated with a licensee operating outside of TS or license conditions.
- Enforcement Discretion -An agreement in the form of a Notice of Enforcement Discretion (NOED) from the NRC to NOT enforce TS requirements or other license conditions.
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0-PROTECT-EQP,Protected Equipment Program
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PURPOSE - This procedure provides Protected Equipment Program implementation guidance.
- This procedure defines expectations for identification and control of protected systems and equipment, for both on-line and off-line maintenance, to ensure the availability of systems needed for the reduction of core damage frequency/defense-in-depth risk.
DEFINITIONS Protected Equipment - Plant equipment or systems whose failure couldsignificantly increase core damage risk if redundant or related equipment isout of service or unavailable. Additionally, plant equipment or systems whosefailure would result in a plant shutdown or Technical Specification requiredshutdown. - The On-Line Protected Equipment will normally becomprised of SSCs identified as such by Procedure 0-CNS-WM-104 which if madeunavailable, would result in a step change in overall PRA risk for CDF (i.e.,overall risk for CDF increases from YELLOW to ORANGE or RED).
- When the loss of theredundant component or system would result in a Technical Specification actionstatement that requires an immediate plant shutdown (24 hours or less). Theredundant component or system is required to be protected.
- When the loss of the redundant component orsystem would cause a plant transient resulting in a reduction of > 10% ofthe current plant generation output or a plant trip. The redundant component or system is requiredto be protected.
- Outage Protected Equipment (when reactorpressure < 150 psig) is normally comprised of equipment that if madeunavailable would result in the inability to satisfy the Defense-in-Depthrequirements of Procedure 0.50.5, Outage Shutdown Safety.
- Workor testing on Protected Equipment, or other activities in areas containingProtected Equipment, should be limited to that necessary to address emergentconditions affecting plant or personnel safety. Exceptions tothis will be reviewed and authorized using guidance contained in Section 8.
a. When equipment in both divisions are in samelocal area, placing signs on individual equipment to be protected meets thisintent.
Impact to ProtectedEquipment LOWIMPACT - Entering into an area of posted Protected Equipment but notworking near the posted Protected Equipment. Examples include: - Non-routinerounds by plant personnel.
- Inspectionsby plant personnel.
- RoutineRP surveys.
- Operationof breakers (opening and closing breakers but not opening the cabinet)(Operations Department only).
MEDIUMIMPACT - Working in the area of or next to the posted Protected Equipment. Examples include: - Frequentlyperformed Tech Spec surveillances (that are required to be performed (i.e.,weekly battery checks, required sampling)).
- Workingin a cabinet that contains Protected Equipment.
- Workingon a breaker adjacent to the protected breaker.
- Workingwithin 2' of the posted Protected Equipment.
- Materialsuch as a carts, scaffolding, or tool/gang box will be transported in closeproximity that they could strike Protected Equipment.
HIGHIMPACT - Working on the posted Protected Equipment.
Shift Manager (SM) is responsible for: Approving LOW, MEDIUM, and HIGH IMPACT activities to Protected Equipment.
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0-HOSE-CTRL, Control and Use of Temporary Hoses
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PURPOSE The purpose of this procedure is to provide administrative controls for temporary hose identification, precautions, personnel safety, and storage requirements
PRECAUTIONS AND LIMITATIONS Hoses must be flushed prior to their use for filling systems, operating equipment, performing diagnostics or testing, or for any other use in which contaminates may be introduced. Demineralized water must be used for flushing of hoses that are to be used in water systems requiring Foreign Material Exclusion controls.
HOSE CONTROL INSTRUCTIONS
NOTE 2 - Marking and identification are accomplished with colored tape, hose markers, or other suitable color coding.
Hoses are marked/identified for use per the HOSE COLOR CODING chart when required.
HOSE COLOR CODING Air or Gas - Green Water - Blue Oil - Yellow SLC - Orange DG Jacket Water - Red
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CONDUCT OF OPERATIONS PROCEDURE 2.0.1.2
OPERATIONS PROCEDURE POLICY
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Operators shall ensure automatic safety initiations and actuations. They shall ensure automatic actions take place in response to valid initiation signals per their safety function design. Upon recognition of a failure of automatic safety feature, Operators shall manually perform those actíons necessary to fulfill the safety function.
AUTOMATIC ACTIONS If a valid initiation signal exists, Operators shall ensure the identified automatic actions take place. Upon recognition of a failure of an automatic safety feature, Operators shall manually perform those actions necessary to fulfill the safety function.
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2.0.7 Licensed Operator Active/Reactivation/Medical Status Maintenance Program
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Plant Tour - Tour all safely accessible areas of power block buildings/areas to ensure Licensee is current with plant and equipment status, location of in-plant controlled procedures, changes in posted Radiological Controlled Areas, etc. Tour must be under active SRO direction. Tour shall be completed during the 40 hour reactivation.
Proficiency Time - Performing license authorized (RO, BOP, CRS, or SM) tasks to which Licensee is/will be assigned.
2.8.1 Track time on attachments and sign in Control Room Logs is recommended
2.8.2 Extra fifth license position is not counted towards proficiency time.
2.8.3 Licensee should have no other concurrent duties.
NOTE - SRO is not required to stand panel watches to remain active to assume panel watch. Time spent on panel watch cannot be counted toward maintaining SRO active.
2.8.4 Maintaining Active Status - Licensees perform RO or SRO tasks for minimum of seven 8-hour or five 12-hour shifts per calendar quarter.
2.8.5 Reactivation - Licensee performs RO or SRO tasks for minimum of four 12-hour
shifts (NRC requires 40 hours) under Coach direction.
2.8.6 lnitial Activation - Licensee who has not completed a minimum of five 12-hour shifts under instruction in the quarter of or quarter proceeding receipt of their license shall perform a minimum of four 12-hour shifts under instruction prior to assuming licensed operator duties.
2.8.7 Under instruction and reactivation time satisfies active requirements; additional proficiency time is not required during calendar quarter.
INITIAL ACTIVATION
4.1 Licensee shall: 4.1.1 lf required, complete a minimum of four 12-hour shifts under instruction and document on Attachment 5.
REACTIVATION
7.1 Licensee shall 7.1.1 Ensure compliance with active definition above completed prior to or during reactivation. 7.1.2 Review training/medical examination status. Complete any required items that are not up-to-date. Contact Operations Training, as needed, to complete training requirements. 7.1.3 Document proficiency time on Attachment2 for RO or Attachment 4 for SRO. 7.1.3.1 Sign into eSOMS as an Under lnstruction (U/l) to track proficiency time. 7.1.4 Document required procedure reading performance on attachment. 7.1.5 Document plant tour completion. 7.1.5.1 Plant tour shall be completed with and accompanied by an active SRO (Coach) and shall be performed during the 40 hour reactivation.
NOTIFICATION OF CHANGE IN LICENSED OPERATOR MEDICAL STATUS
8.1 Licensee shall complete Attachment 2 of Procedure NTP8.1 when his/her mental, physical, or medical condition changes.
8.1.1 Examples of medical condition changes that require notification include, but are not limited to, the following:
Diagnosis and treatment of following conditions:
a. Diabetes. b. Asthma. c. Cancer. d. Emphysema or chronic bronchitis. e. High blood pressure or hypertension. f. Heart problems. g. Blackouts, convulsions, or epilepsy.
Stopping treatment for a long term medical condition.
Any hospitalizations.
Major changes in vision since last physical (includes eye or other refractive surgery, or glasses being prescribed for the first time).
Injuries which result in prescriptions for pain medication or limit mobility or dexterity (i.e., hand, fooUleg, back, or neck injuries).
Any newly diagnosed injury or illness which results in work restrictions (i.e., no prolonged standing).
Medication - changes in, new prescriptions, or stopping medication.
Prescribed to use a CPAP machine due to being diagnosed with sleep apnea.
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0-CNS-CASK, Conduct Of Cooper Nuclear StationOn-Site Dry Fuel StorageProgram Operation.
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0.31MOV, “MOTOR OPERATED VALVES”
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2.7 STROKE 2.7.1 Valve movement from closed-to-open or from open-to-closed. One full CYCLE of valve travel would be two strokes.
2.8 STROKE LIMIT 2.8.1 As used in Attachment 1, this is defined as maximum amount of strokes that may be applied to subject functional location before 10 minute cooldown period is required.
PRECAUTIONSAND LIMITATIONS
- Localdial position indicators on motor operated valves are inaccurate and are not tobe used for determining local valve position unless specifically required bystation procedure. Use stem position or,where provided, fixed stem indication
- Donot attempt to place the actuator in manual(declutch) during electrical operation
- Stayclear of motor operator declutch lever when transitioning from manual to electrical mode. Internal recoil may cause lever to snap back suddenly.
- Handwheelis designed so that average man is able to exert sufficient torque to operatevalve. Valve operation with anythingother than two hands is indication of severe mechanical problems with eitheractuator or valve and is, more importantly, potential worker safetyproblem. Instances have occurredresulting in valve or actuator failure due to use of torque amplifying devices.
- Unless coordinated directly with Maintenance, MOVProgram motor operated valves are not to be electrically stroked duringmaintenance activities prior to final diagnostic testing. Manual stroking in order to meet ClearanceOrder steps is allowable with Electrical Maintenance or Valve Team inattendance.
OPERATION OF LIMITORQUE MOTOR OPERATED VALVES
5.1 Following indicated closure of any Limitorque motor operated throttle valve, continue to hold control switch in CLOSE position for an additional 5 seconds. This will ensure open-to-close stroke is terminated by torque switch and not CLOSE LIMIT switch.
5.2 Do not hold control switch for any seal-in Limitorque motor operated valve in CLOSE position any longer than momentarily after green indicating light turns on. Placing or holding control switch in CLOSE position after valve is closed can cause hammering of valve.
NOTE - Some Limitorque motor operated valves throttle in open direction but seal-in, in closed direction. These dual-function valves are identified by words "THROTTLE OPEN ONLY" on CAUTION label near their control switches.
5.3 When operating any dual-function valve in closed direction, operate valve per Step 5.2.
5.4 When operating any Limitorque motor operated valve, wait a minimum of 3 seconds after releasing control switch before reversing its direction of travel.
5.5 To prevent thermal overloads associated with valves that have stroke times > 45 seconds from tripping, a cooldown period of - 1 minute should be observed following a cycle (two strokes) of valve.
MANUAL OPERATIONS
6.1 Use of torque amplifying devices, lever bars, or valve wrenches are prohibited while manually operating motor operated valves.
6.2 Do not use excessive force when manually operating handwheel. Handwheel is designed so that an average man is able to exert sufficient torque with two hands to operate valve. lf greater force is required, contact Valve Team or MOV Engineer for guidance and troubleshooting.
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Procedure1.2, Protection of Unclassified Safeguards Information
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TYPESOF INFORMATION TO BE PROTECTED UnclassifiedSafeguards Information not otherwise classified as National SecurityInformation or Restricted Data, which specifically identifies CNS detailedsecurity measures for the physical protection of the site. Thefollowing are considered examples of SGI:
Informationdesignated SGI by the NRC. EmergencyPlanning scenarios and implementing procedures involving security‑relatedevents which contain SGI. Site-specificdrawings, diagrams, sketches, or maps that substantially represent the finaldesign features of the physical security system not easily discernible bymembers of the public. Alarmsystem layouts showing the location of the intrusion detection devices, alarmstations, alarm assessment equipment, alarm system wiring, emergency powersources for security equipment, and duress alarms not easily discernible bymembers of the public. PhysicalSecurity Orders and Procedures issued by the licensee for members of the Securityorganization detailing duress codes, patrol routes and schedules, or responsesto security contingency events. Site-specificdesign features of plant security communications systems. Lockcombinations and mechanical key design or passwords integral to the physicalsecurity system. Documentsand other matter that contain lists or locations of certain safety‑relatedequipment explicitly identified in the documents or other matter as vital forpurposes of physical protection, as contained in security plans, contingencymeasures, or plant specific safeguards analyses. Thecomposite safeguards contingency plan/measures for the facility or site. Informationrelating to on-site or off-site response forces, including size, armament ofresponse forces, and arrival times of such forces committed to respond tosecurity contingency events. Thecomposite facility guard qualification and training plan/measures disclosingfeatures of the physical security system or response procedures. Theadversary characteristics document and related information, includingimplementing guidance associated with the Design Basis Threat in 73.1 (a)(1) or(a)(2). Engineeringand safety analyses, security-related procedures or scenarios, and otherinformation revealing site-specific details of the facility or materials if theunauthorized disclosure of such analyses, procedures, scenarios, or otherinformation could reasonably be expected to have a significant adverse effecton the health and safety of the public or the common defense and security bysignificantly increasing the likelihood of theft, diversion, or sabotage ofsource, by‑product or special nuclear material. Thoseportions of safeguards inspections, reports, evaluations, audits, orinvestigations that contain details of the site's physical protection system ordisclose uncorrected defects, weaknesses, or vulnerabilities of the physicalprotection system. Thoseportions of correspondence that contain SGI as described in this section. Mediaother than documents and drawings (such as but not limited to alarm systemsoftware programs, data processing storage disks, microfilm, or photographs)that contain SGI as described in this section.
Thefollowing are not considered examples of SGI:
Genericstudies, reports, or analyses conducted by or on behalf of the NRC or NPPDwhich concern the safeguarding of the facility. Documents,drawings, or reports submitted in response to the environmental and safetyrequirements contained in 10CFR Parts 50, 51, 70, and 71. InitialEngineering or construction drawings, diagrams, design sketches, or mapsrequested for bids or proposals (provided that they do not substantiallyrepresent final design features of the physical protection system). Anyinformation already in the public domain, including safeguards equipmentspecifications, catalogues, and equipment buying data. Generalinformation, already in the public domain concerning State or local policeforces, such as total complement, shift size, etc. Portionsof the Training and Qualification Plan that do not disclose facilitysafeguards features or response procedures.
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Procedure 1.3, Non-Vital Door Key Control
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The responsibility for maintenance and issuance of keys to the non-vital doors will be with the Key System Custodian . The position of the Key System Custodian will normally be filled by an individual assigned to CNS Security
The working depositories will normally be located in the Control Room, SecondaryAlarm Station, Access Control, and Work Control Center.
1.1.1.2 Keys located in the working depositories are for temporary issue. Keys will only be issued to badged personnel.
a. Non-vital door keys assigned to the Control Room will be building and grand masters and willbe controlled and issued, as required, by Control Room Supervisory personnel.
b. Non-vital door keys assigned to the Secondary Alarm Station will normally be building mastersand issued to individuals for the performance of routine repairs.
1. Keys to doors located within a vital area will not be issued to an individual whodoes not have approved access to that vital area.
c. Building and grand master keys, located in the main depository, may be issued permanentlyto individuals whose duties/responsibilities require such access on a frequent basis.
d. Building and grand master keys will be assigned to the Work Control Center. The Work Control Center Supervisor or WorkControl Center Administrator shall control and issue these keys.
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Procedure1.15, Visitor/Tour Station Access
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Escortto Visitor/Tour Member Ratio One to <= 10 visitors for the Protected Area or 1 to <= 5 visitors for the Vital Area.
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Procedure1.10, “Control of Documents”
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PURPOSE This procedure establishes requirements for processingcontrolled documents and establishes controls to ensure the latest applicablerevisions of controlled documents are available to minimize the inadvertent useof superseded documents.
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Procedure 2.0.1, Plant OperationsPolicy
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REGULATORYGUIDE 1.97 INSTRUMENTSThe NRC requires that certain Regulatory Guide 1.97 instruments used in ControlRoom be identified to Control Room Operators.
Theseinstruments are identified by a small black diamond in lower left-hand cornerof nameplate for instrument.
Theseinstruments are to be considered more reliable and accurate during accidentconditions because they meet certain criteria for EQ requirements, seismicrequirements, redundancy requirements, power requirements, channelavailability, range, and display requirements.
10CFR50.54(x)OR 10CFR72.32(d) DEVIATION FROM LICENSEè5
NOTE 1 – Only NPPD employees can be considered part of the chain‑of‑command. The normal chain-of-command for anon-shift SRO is the Assistant Operations Manager - Operating Shift, OperationsManager, and GMPO. If an event has beendeclared, the chain-of-command for an on-shift SRO is the Emergency Director.
NOTE 2 – The use of 10CFR50.54(x) and (y) or 10CFR72.32(d) is notoptional. If an emergency exists andprotective action is needed to protect the public health and safety or sitepersonnel, and no action consistent with the operating license or ISFSI generallicense can provide adequate or equivalent protection, then personnel shalltake the protection action under 10CFR50.54(x) and (y) or 10CFR72.32(d).
Inan emergency, an on-shift SRO (or an individual higher in the chain‑of‑command)may authorize deviation from a license condition (e.g., approved procedures) orTechnical Specifications as allowed by 10CFR50.54(x) and (y) or 10CFR72.32(d). Screendeviation for 10CFR50.54(x) or 10CFR72.32(d) applicability by answering thefollowing questions:
Isthe action needed immediately to avert possible adverse consequences to publichealth and safety or site personnel?
Theanswer to this question must be YES. 10CFR50.54(x) or 10CFR72.32(d) is not to be invoked for situations andcircumstances for which adequate time is available to pursue a licenseamendment or procedure change. Note thatthe "action" may include provisions to protect plant equipment orprevent deterioration of plant conditions when those actions are needed toprotect public health and safety or site personnel.
Isadequate or equivalent protective action consistent with current operatinglicense, Technical Specification, ISFSI general license, or ISFSI Technical Specificationrequirements or actions apparent?
Theanswer to this question must be NO. Ifactions allowed or required by the operating license, Technical Specifications,ISFSI general license, or ISFSI Technical Specifications will adequatelyaddress the situation, then the licensee shall implement those actions and notinvoke 10CFR50.54(x) or 10CFR72.32(d).
Doesthe action deviate from the operating license, Technical Specifications, ISFSIgeneral license, or ISFSI Technical Specifications only to the extent necessaryto meet the emergency?
Theanswer to this question must be YES. Theproposed action must be limited to the emergency at hand and not extend intoareas not affected by the situation.
Isthe action reasonable?
Theanswer to this question must be YES. Based on the time available, have sufficient resources been involvedwith planning and approving a course of action that will be successful inproviding protection for public health and safety or site personnel.
10CFR50.54(x)-A licensee may take reasonable action that departs from a license condition or a technical specification (contained in a license issued under this part) in an emergency when this action is immediately needed to protect the public health and safety and no action consistent with license conditions and technical specifications that can provide adequate or equivalent protection is immediately apparent. 10CFR72.32(d)-A licensee with a license issued under this part may take reasonable action that departs from a license condition or a technical specification (contained in a license issued under this part) in an emergency when this action is immediately needed to protect the public health and safety and no action consistent with license conditions and technical specifications that can provide adequate or equivalent protection is immediately apparent.
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Procedure2.0.2, Operations Logs and Reports
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PRIMARY CONTAINMENT MANUAL ISOLATION VALVE ANDPIPE CAPS ADMINISTRATIVE CONTROL
PC SEALED MANUAL ISOLATION VALVES AND PIPE CAPS
Attachment 3, PC Manual Isolation Sealed Valve and Cap Verification, contains a list ofthe normally sealed closed primary containment manual isolation valves andcaps.
Thesevalves shall be sealed in such a manner as to prevent their being manuallyoperated without destroying the seal.
Thevalves are identified by a tag labeled PRIMARY CONTAINMENT BOUNDARY and thecaps are identified by being painted yellow.
Theapplicable operating procedure component checklist lists the valve as a PCisolation valve, lists the normal position as SEALED CLOSED & LINE CAPPEDor SEALED CLOSED & LINE PLUGGED.
ThePC Manual Isolation Valve and Cap Log, Attachment 6, shall document themanipulation of any valves or caps listed in Attachment 3, as required byStep 5.1.5.
TheSM shall maintain the PC Manual Isolation Valve and Cap Log, and ensureappropriate entries are made. TheShift Manager's permission is required to open any of these valves.
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Procedure 2.0.3, Conduct of Operations
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SMgeneral management responsibilities include: TheSM maintains an oversight role cognizant of all plant evolutions occurring onthe shift.
TheSM shall maintain oversight and control of operations, maintenance, andsurveillance activities during all modes of plant operations through the CRS,WCO, STE, WCCA, and other work organization Supervisors. TheCRS and the WCCA can sign for the SM for all scheduled activities (i.e.,surveillances, maintenance procedures, Work Orders, PMs) and for othersignatures requiring the SM signature. Ifthe WCCA is signing for the SM and it is not a scheduled activity, then the SMneeds to be contacted prior to signing and concur with signing the document. The following is a list of exception to thisrule:
Protectedequipment implementation and access authorization. Switchyardaccess. Procedure7.0.1.7 troubleshooting approval. Finalreview of surveillance procedures. ReactivityManeuvering Plan (RMP) approval and terminations.
TheSM shall provide an oversight function to the CRS, WCO, and the STE duringnormal, abnormal, and emergency operations. TheSM should refrain from manipulating equipment. TheSM shall provide guidance and assistance, when necessary, to the CRS inabnormal and emergency conditions. Duringactivities when additional management oversight is required or provided, theSM, as Senior License Operator on-watch, shall retain the overall responsibilityfor all plant operations.è30
TheSM shall ensure conservative operating practices are followed and that safetyand core integrity take precedence over power production. This includes:è4,6,7,31,32,33
EnsuringOperations personnel control reactivity and take conservative action tosafeguard integrity of the reactor fuel. Ensurehasty decisions and hurried actions are avoided, whenever possible, duringreactivity manipulations. Ensureadding positive reactivity during abnormal or transient events as a means tomitigate the event is avoided whenever possible.
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Procedure2.0.4, Relief Personnel and Shift Turnover
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This procedure provides guidance to Operations personnel for relief of personnel and shift turnover.
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Procedure2.3.1, General Alarm Procedure
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PURPOSE This procedure provides instructions for Operations personnel to operate the Annunciator Systems
ALARMACKNOWLEDGMENT
Expectedalarms are those that have been discussed prior to alarming and have been orare obviously attributed to component or equipment status. Whenever alarms are received, they are to berecognized as to their validity. Allalarms are to be treated as valid until proven otherwise.
Expected alarms, such as those associated with aSurveillance Procedure or other maintenance activities, or as determined by theCRS, may be identified with a "flag" to signify an expectedalarm. This will be communicated to theCRS prior to receiving the alarm. Once"flagged" as an expected alarm for a SP or maintenance activity, thecommunication of each time the alarm comes in and resets is not requiredas long as the alarm is received at the appropriate time or is caused byidentified maintenance activity. If the"flagged" annunciator were to come in at a time not specified in theprocedure or alarm was not caused by identified maintenance activity, itis to be treated as an unexpected annunciator.
During a plant transient, multiple annunciatorsmay be coming in rapidly. The panelOperator will acknowledge the annunciators as soon as reasonably possible,commensurate with the importance of the activities that are on-going. It is not necessary to announce allannunciators that come in during a transient, but operationally significant eventsthat are indicated by annunciators should be announced. Announcements that are made shall beprioritized according to their relative merit to other communications that areon-going.
ANNUNCIATOR DTSABLING OR PLACING IN POINT MAINTENANCE MODE
NOTE – Use of Master Silence feature does not requireperformance of this section or Attachment 1. Disablingannunciators using this section applies only to the following: - Pullingalarm cards for non‑Control Room alarms and Control Room Fire Panel alarms.
- DisablingControl Room main panel alarms per Procedure 2.2.64.
- PlacingControl Room main panels alarm in Point Maintenance mode using Procedure 2.2.64.
Annunciatorsshould be considered failed under the following conditions: Annunciatorwill not alarm (e.g., SW strainer DPIS has failed downscale, preventingan alarm on high strainer D/P). Annunciatorsetpoint has drifted beyond the value where Operator or Automatic Action isrequired (e.g., Battery Room low temperature alarm is alarming at 68°Fvice 76°F. Operator is required to declare batteryinoperable at 72.5°F).
Continuouslyalarming annunciators should be evaluated for compensatory actions if all thefollowing conditions are met:
Annunciatormonitors a process parameter (e.g., stator high temperature alarm. A pump trip alarm is an example of anannunciator that does not monitor a process parameter). Annunciatormonitors a system that is in service or in standby. Annunciatoris not expected for existing plant conditions. Annunciatoris expected to remain in continuous alarm for greater than one shift.
Afteralarm evaluation has been approved and compensatory measures established, if necessary,perform following: - Ensuregreen self-adhesive flag is placed on affected annunciator window.
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Procedure 2.0.5, Reports to NRC OperationsCenter
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PURPOSE
Thepurpose of this procedure is to establish immediate notification requirementsand 60 day telephone reporting requirements for reports to the NRC OperationsCenter for non‑emergencies. Immediate notification requirements foremergencies are included in Procedure 5.7.6. Immediate notifications for non-emergencies are categorized into immediate,1 hour, 4 hour, 8 hour, or 24 hour and 30 day reports. Guidance is provided in this procedure ondetermining the appropriate reporting category, confirming the accuracy ofreported information, performing the required notification, and providingsubsequent updates or retracting the report based on evaluations of additionaldata. Additional guidance fordetermining reportability can be found in NUREG 1022, Revision 3, GenericLetter 91-03, or references contained in Section 6. This procedure covers immediate notificationsperformed by Operations or Security, and 30 and 60 day telephone reportsperformed by Licensing. 2. DISCUSSION
- Plantconditions which require declaration of an emergency classification andnotification per Procedure 5.7.6 also require performance of this procedure toensure non-emergency reports continue to be made as required. Control Room Staff continue to identifynon-emergency reportable events, but may direct the Emergency NotificationSystem (ENS) Communicator in the Technical Support Center (TSC) to make theactual phone call and log the notification. During declared emergencies, completion of Attachments 8 and 9 are notrequired.
- Most conditions reported to the NRC per thisprocedure will require a 30 day written report or 60 day follow-up LER perProcedure EN-LI-108. Preparation of thereport or LER is the responsibility of the Licensing Department. The determination of 30 or 60 dayreportability will be made as part of processing the Condition Report (CR) inthe Corrective Action Program.
DETERMINE REPORTABILITY FOR SAFEGUARDS (1 0CFR73.71), FTTNESS-FOR-DUTY EVENTS (10CFR26), OR ACTUAL OR ATTEMPTED THEFT, SABOTAGE, OR DIVERSION OF RADIOACTIVE MATERIAL (10CFR37)
NOTE 1 – Per 10CFR73.22(f)(3), except under emergency orextraordinary conditions, Safeguards information should not be transmitted byunprotected telecommunications circuits (including faxes). Reporting of Safeguards events pursuant to 10CFR73.71 is considered an extraordinary condition.
IMMEDIATE FOLLOW-UP NOTIFICATION OR REVISION TO NOTIFICATION
In addition to the initial notification, during the course of the event,immediately report:
- Anyfurther degradation in level of safety of the plant or other worseningconditions. If plant conditions degradeto require the declaration of an emergency classification, perform the emergencynotifications per Procedure 5.7.6.
- Resultsof ensuing evaluations or assessments of plant conditions.
- Effectivenessof response or protective measures taken; or
- Informationrelated to plant behavior or any condition that is not understood.
- Answersto questions raised by the NRC for which immediate information was notavailable.
RETRACTING(CANCELING) IMMEDIATE NOTIFICATIONS
- Asa result of reviews and analysis, it may be later determined that a conditionor event was not reportable. The ENSnotification should be retracted via a follow-up ENS call. A sound, logical basis (rationale for thedecision) should be communicated with the retraction or cancellation. There is no time limit for when a retractionshould be initiated; however, it should typically occur shortly after reachingthe decision that the initial immediate notification was not required.
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Procedure 2.0.1.2, Operations Procedure Policy
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PURPOSE
Provide Operations procedure usage requirements and Operations Management's
These requirements are in addition to the requirements of Procedure EN-HU-106.
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Procedure 3.4.4, TemporaryConfiguration Change
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PRECAUTIONSAND LIMITATIONS- TCCsare considered a last resort when dealing with plant equipment issues. As such, they are expected to be few innumber and short in duration. They areexpected to be removed during the next applicable system work window and nolater than the next refueling outage.
IMPLEMENTATION
- For any TCC performed on RHR Group 2 low water level isolation logic or RHR System valveinterlocks associated with the shutdown cooling suction valves, as described inStep 3.6, the TCC shall specify that one of the following requirementsmust be met:
- An operable ECCS is available for RPV injection and can supply adequate quantitiesof makeup water at sufficient flow rates to ensure adequate core cooling; or
- Manual valve isolation is established per Procedure 0.9 to prevent inadvertent RPV draining.
TCCSIGNATURE REQUIREMENTS AND DISTRIBUTION
- SHIFTMANAGER - Shift Manager approval as directed by Step 4.10.
- TSCDIRECTOR - TSC Director approval as directed by Step 4.11.
- GENERALMANAGER OF PLANT OPERATIONS (GMPO) - GMPO shall sign indicating TCC approval.
- Vice President-Nuclear (VP-Nuclear) - If TCC durationexceeds the next refuel outage, then VP-Nuclear approval is required.
URGENT TCC'S
NOTE 1 – In the event of an imminent threat to the safety orreliability of the plant due to an unforeseen plant event, the Shift Managermay direct the installation or removal of a Temporary Configuration Changewithout approved controlling documentation where immediate actions are requiredto protect the health and safety of public and plant personnel, protectequipment, or prevent deterioration of plant conditions provided the changedoes not adversely affect nuclear safety. Procedure 0‑CNS‑WM‑102 controlsEmergency Work Order processing.
NOTE 2 – If time permits, a preliminary Urgent TCC should beprepared, but no forms are required to be completed to document the initialpreparation or approval of the Urgent TCC.
NOTE 3 – Verbal approval of the Urgent TCC is acceptable.
- If the TCC is not implementing 10CFR50.54(x) actions, the Shift Managershall approve the Urgent TCC. Thisapproval shall be documented in the Shift Manager's Log.
EMERGENCYPLAN TCC'Sè10
NOTE 1 – This section is to be used only during an emergencysituation as directed by the TSC Director.è4
NOTE 2 – During Emergency Plan conditions, the TSC Director maydirect the installation or removal of a Temporary Configuration Change withoutapproved controlling documentation where immediate actions are required toprotect the health and safety of public and plant personnel, protect equipment,or prevent deterioration of plant conditions. Procedure 0‑CNS‑WM‑102 controls Emergency Work Order processing.
NOTE 3 – If time permits, a preliminary Emergency Plan TCC shouldbe prepared, but no forms are required to be completed to document the initialpreparation or approval of the Emergency Plan TCC.
NOTE 4 – Verbal approval of the Emergency Plan TCC is acceptable.
If the TCC is not implementing10CFR50.54(x) actions, the TSC Director shall approve the Emergency Plan TCC. This approval shall be documented in the TSCDirector's Log.
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Procedure 3.18, Regulatory Guide 1.97Instrumentation
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DISCUSSION
RegGuide1.97 provides for five variable types and three qualification categories. - The RegGuide lists a minimum set of Types B, C, D, and E variables to be measured. Type A variables are plant specific and weredetermined as part of the submittal and review process. An instrument may be used for more than onevariable type.
- Category1 provides the most stringent requirements and is intended for key variables. Category 2 provides less stringentrequirements and generally applies to instrumentation designated for indicatingsystem operating status. Category 3 isintended to provide requirements that will ensure high-quality off‑the‑shelfinstrumentation is obtained and applies to backup and diagnosticinstrumentation. It is also used wherestate of the art will not support requirements for higher qualifiedinstrumentation.
CATEGORY1 - Equipment Qualification - The instrumentation should be qualified per RegGuide 1.89 andthe methodology described in NUREG-0588. The seismic portion should be in accordance with RegGuide 1.100.
- Redundancy- The RegGuide 1.97 instrumentation shall be single failure proof within theaccident monitoring instrumentation, its auxiliary supporting features, or itspower sources concurrent with the failures that are a condition or result of aspecific accident. Redundant channelsshould be electrically independent and physically separated from each other,and from equipment not classified important-to-safety per RegGuide 1.75.
- PowerSource - The instrumentation should be energized from station standby power sources,as provided in RegGuide 1.32, and should be backed up by batteries where momentaryinterruption is not tolerable.
- ChannelAvailability - The instrumentation channel should be available prior to an accident,except as provided in Paragraph 4.11, as defined in IEEE Standard 279 as specifiedin Technical Specifications or the Technical Requirements Manual.
- QualityAssurance - 10CFR50 Appendix B
- EquipmentIdentification - Types A, B, and C instruments should be specificallyidentified on the control panels.
ControlRoom indicators for Categories 1 and 2, Types A, B, and C variables, are markedwith black diamonds on the panels to identify them as RegGuide 1.97instruments.
Reg Guide1.97 instruments are classified per Procedure 3.4. In general, the following rules apply: - Category 1 variables are classified ESSENTIALthroughout the instrumentation channel. Instrumentslocated in harsh environments as defined in Procedure 3.12.7 areclassified EQ.
DEFINITIONS
TypeA - Those variables to be monitored that provide the primary informationrequired to permit the Control Room Operators to take the specified manuallycontrolled actions for which no automatic control is provided and that arerequired for safety systems to accomplish their safety function for designbasis accident events.
TypeB - Those variables to be monitored that provide the Control Room Operator informationto assess the process of accomplishing or maintaining critical safety functions(i.e., reactor control, core cooling, Reactor Coolant System OPERABILITY,primary reactor containment OPERABILITY, and radioactive effluent control).
TypeC - Those variables to be monitored that provide the Control Room Operator informationto monitor (1) the extent to which parameters, which have the potential for causinga breach of the primary reactor containment, have exceeded the design basis values,or (2) that the in-core fuel clad, Reactor Coolant System pressure boundary, orprimary reactor containment may have been breached.
TypeD - Those variables that provide information to indicate the operation ofindividual safety systems and other systems important to safety.
TypeE - Those variables to be monitored, as required, for use in determiningthe magnitude of the release of radioactive materials and in continuallyassessing such releases.
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Procedure 3-EN-DC-186, Fuse Control
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All Plant Personnel assigned the taskof replacing fuses in plant equipment are responsible for ensuring that theproper size and type of replacement fuse is verified before installation, andthat the fuse is suitable for the application. Personnel are also responsible for initiating a Condition Report (CR)when a fuse discrepancy is found. Fuse Replacement NOTE
29 CFR 1910.334(b)(2)states: 'Reclosing circuits after protective device operation." After a circuit is deenergized by a circuit protective device, the circuit may not be manually reenergized until it has been determined that the equipment and circuit can be safely energized. The repetitive rnanual reenergizing of circuits through replaced fuses is prohibited. When it can be determined from the design of the circuit and the overcuffent devices involved that the automatic operation of a device was caused by an overload rather than a fault condition, no examination of the circuit or connected equipment is needed before the circuit is reenergized. NOTE Fusescan blow while performing their design function of overcurrent protection orthey may fail due to degrading over time. Protective devices (fuses andbreakers) that are reset with a continued fault can explode, causing seriousinjury. Personnel with training and experience in electricaltroubleshooting techniques must ensure that a short does not exist and that itis safe to re-energize the circuit. A blown fuse must be replacedto continue normal operation of the circuit it was protecting. IF thecause of the blown fuse cannot be readily identified, then determine if the equipment/circuit can be safelyenergized prior to reenergizing the circuit by fuse replacement. IFit can be verified that an overload condition caused the fuse to blow, thenno examination is needed before the circuit is reenergized. If the replacement fuse blows, theninitiate troubleshooting activities in accordance with CNS Procedure 7.0.1.7 toidentify the cause ANDdetermine whether or not an electrical fault condition exists.
Both fuses in a DC branch circuit (positive and negative),all three fuses in a three-phase circuit, or both fuses in a single phase AC branchcircuit, should be fused with the same fuse, i.e. the same manufacturer,catalog number, type, rating and class. IF the fuses are different, THENcontact Engineering PRIOR toreinstalling the fuses.
NOTE Following a short circuit or overloadcondition, all fuses in a branch circuit are stressed (weakened). Replacement of all fuses will restore theelectrical protection provided by the fuses to their original design configuration.
When replacing a blown fuse, ALL fuses should be replaced, i.e. both the positive and negativefuses in a DC branch circuit, all three fuses in a three-phase AC circuit, orboth fuses in a single phase AC branch circuit.
Circuits with secondary fuses (double fused forcontainment penetration protection or Essential to Non-Essential loadseparation) - replace both the primary and secondary fuses if a fuse blows.
[6] Emergency Situations In the event of an imminent threat to the safety or reliabilityof the plant due to an unforeseen plant event, the Shift Manager, in accordancewith the requirements of CNS Procedure 3.4.4, may direct installation of aTemporary Configuration Change (TCC) to the plant on an “emergency” basis withoutapproved controlling documentation, as long as the TCC does not adverselyaffect nuclear safety, i.e. the SM may direct temporary installation of an alternatefuse as an immediate substitution for a fuse listed on a controlled plantdocument.
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Procedure 3.26.1, Meter Banding Control
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DISCUSSION Meterbanding changes included in a configuration change or a setpoint change arealso controlled by this procedure. Thesechanges are considered to be administrative in nature and should be approvedand implemented as part of configuration change or setpoint change inaccordance with the MBCR Admin Change Process of this procedure. Instrumentmeter banding is a method of enhancing indicators by color banding and markingof indicator scales. Meter bandingidentifies normal operating range, abnormal range, alarm, out-of-toleranceconditions, and entry conditions to the Emergency Operating Procedures (EOPs). Thefollowing color types of meter banding were established by the Detailed ControlRoom Design Review (DCRDR) Program:
GreenBand - Indication of a parameter within the normal operating range. AmberArrow - Indication of an operating limit, caution, or alarm being reached. RedArrow - Indication of an entry condition to the EOPs or a significant systemsetting being reached requiring immediate Operator action. On panels with meters and indicators used tomonitor EOP entry conditions, red arrows should only be used for marking EOPentry conditions. Red arrows may be usedto mark significant system settings on other panels provided that they cannotbe mistaken for EOP entry conditions.
Meter banding is primarily performed for instrumentsinside the Control Room and the Alternate Shutdown Room. Meter banding performed outside the ControlRoom and the Alternate Shutdown Room is limited to instruments used forregulatory compliance, scram frequency reduction, personnel or equipmentsafety, or where an instrument for monitoring important plant parameter is notavailable in the Control Room.
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Procedure 8.3, Control Parameters and Limits
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DISCUSSION Theestablishment of and adherence to appropriate chemistry control parameters andlimits are important factors in the safe and efficient operation of CNS. By maintaining plant systems and effluentswithin these limits, compliance with regulatory requirements is accomplishedand the impact of chemical impurities and chemistry transients is minimized. These limits provide values at whichincreased surveillance may be necessary or required and should alert theChemistry Staff to degrading conditions within plant systems. The return of plant systems or effluents towithin the normal limits in a systemized and timely fashion, which will helpmaintain plant safety, equipment reliability, and regulatory compliance. Limits are divided into four categories; CWL,AL1, AL2, and AL3 are based on plant conditions and chemical significance. With Hydrogen Water Chemistry (HWC), alsoknown as Optimum Water Chemistry (OWC), cycling of this system will causeelevated reactor water conductivity during one hydrogen injection transientsand following noble metals application. This conductivity increase is the result of soluble iron released duringvessel crud restructuring and soluble zinc returning to solution.
When evaluatingconductivity indications that are outside of the limits detailed in theprocedure, ensure elevated conductivity is not the result of impurity ingress.
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Procedure 8.8.11, Liquid Radioactive WasteDischarge Authorization
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- Releasesof radioactive liquid effluents from CNS require authorization by Chemistry,approval by duty Shift Manager, and final review and recording by Chemist.
- ChemistryManager's permission required to discharge with monitor inoperable.
- Circulatingwater pump(s) shall be in operation, as determined by Attachment 1, to supportrequired minimum discharge canal flow rate of 159,000 gpm during discharges.
SAMPLECOLLECTION AND ANALYSIS - Shift Manager determines circulating water pump requirement for proper flow todischarge canal to comply with required dilution flow
- Exact flows cannot be pre-determined for this procedure. They have to be determined dependent on plantoperating condition at time release is affected.
- Shift Manager shall tag running circulating water pumps with DISCHARGE IN PROGRESStags to ensure pumps remain running until completion of discharge
- If dilution flow falls below value specified in Attachment 1, Section 3, dischargeshall be immediately secured.
- Upon completion of discharge, Shift Manager shallsign Attachment 1, Section 5, to provide confirmation that discharge valveis closed, monitor has been flushed, and all data in Attachment 1, Sections 4and 5, is correct.
LIQUID RADWASTE DISCHARGE CALCULATIONS WITH MONITOR INOPERABLE - Shift Manager determines circulating water pump requirement for proper flow todischarge canal to comply with required dilution flow.
- Exact flows cannot be pre-determined for this procedure. They have to be determined dependent on plantoperating condition at time release is effected.
- Shift Manager shall tag running circulating water pumps to remain running untilcompletion of discharge.
- If dilution flow falls below value specified in Attachment 1, Section 3, dischargeshall be immediately secured.
- Upon completion of discharge, Shift Manager shallsign Attachment 1, Section 5, to provide confirmation that discharge valve isclosed, monitor has been flushed, and all data in Attachment 1, Sections 4 and5, is correct.
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Procedure 9.EN-RP-207, Planned Special Exposure
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PRECAUTIONSAND LIMITATIONS- NPPD may authorize an adult worker to receive a planned special exposure only inexceptional situations when alternatives that might avoid the higher exposureare unavailable or impractical.
- Use of a PSE should normally be considered only when a severe handicap to plantoperations could result
- Individual(s) performing PSEs shall have a completed, signed NRC Form 4, CumulativeOccupational Exposure History, on file. If there are any periods of exposure during the life of the individualproposed to receive a PSE that have not been determined and documented,participation in a PSE is not permitted.
- Declared pregnant women shall not be considered for PSEs.
- Doses received during emergency situations that involve immediate measures requiredto save lives or equipment are not considered PSEs.
- A PSE is not required to be a voluntary action on thepart of the individual worker.
GENERAL INSTRUCTIONS
- Radiation Protection Manager, General Manager of Plant Operations, and Vice President-Nuclear,shall specifically authorize a PSE, in writing, before the exposure occurs.
- The applicable department head will identify individual(s) selected to perform theplanned special exposure.
3. If the individual who will receive the PSE is not anemployee of NPPD, then the individual's employer shall also authorize the PSE in writing.
- Individuals may receive dose from PSEs, in addition to the annual limits according to thefollowing:
Annually Lifetime
- Total Effective Dose Equivalent. 5rem 25 rem
- Individual organ or tissue. 50rem 250 rem
- Eye. 15rem 75 rem
- Skin or any extremity. 50rem 250 rem
- ExceptionalSituation - An extraordinary situation, other than a declared emergency, whereexposures above the normal limits of 10CFR20.1201 are allowed if propercontrols are in place and the event is properly documented.
- Planned Special Exposure - An infrequentexposure to radiation, separate from an in addition to, the annual dose limits.
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Procedure 9.ALARA.1, Personnel Dosimetry and Occupational Radiation Exposure Program
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Per 10CFR20.1201, an individual may annuallyreceive up to 5 rem TEDE of occupational dose. To ensure this limit is not exceeded, CNS shall impose a morerestrictive administrative annual TEDE guideline of 4 rem.
DRD SPECIAL PRECAUTIONS At any time an individual loses their DRD whilein the RCA or enters the RCA without a DRD, they shall immediately notifyRadiation Protection.
Anytime an individual does not wear their DRD in the RP prescribed location, thatindividual shall leave the RCA. Radiation Protection shall perform a dose evaluation.
Atany time an individual feels their DRD is not functioning properly, they shallreturn it to Radiation Protection for evaluation and replacement as required. Theexpectation for RCA entry is to monitor exposure so that RCA exit occurs beforethe RWP/SWP accumulated dose alarm setpoint is reached.
Oncehaving reached the 80% dose warning alarm, immediately perform the following:
Stopwork. Placework in a safe condition. Exitthe area. Proceedto the RCA access and log off the RWP/SWP. NotifyRP.
Ifyou receive an unanticipated DRD dose rate alarm, then perform the following:
Backout of the affected area. Notifyothers in the work area. Immediatelycontact RP for direction.
If an individual loses their DRD, they shall contact Radiation Protection andreport to the RCA Access Control Point for further evaluation.
LOST DLR/X-RAYED DLR
externalexposure and the committed dose equivalent for internal exposure.
Atany time an individual loses their DLR, they shall immediately notify theirSupervisor and Radiation Protection. Whenindividuals who have x-rayed their DLR report to Dosimetry, a RP‑17A (X-RayedDLR) will be completed and inserted in the individual's personnel file.
NUCLEAR MEDICINE ADMINISTRATION NOTE – It is preferred that individuals notify Dosimetry and turnin their DLR prior to receiving medical injections; however, in some instancesthis may not be feasible.
Individualsissued a DLR, who are undergoing nuclear medicine treatment, should notifyDosimetry upon return to CNS following the treatment. Uponnotification, Dosimetry shall collect the individual's DLR and restrict theiraccess to RCA and Satellite Areas until such time that the individual cansatisfactorily pass through a PCM and a portal monitor without alarming eithermonitor.
MONITORING VISITORS A NRC Form 5 or equivalent, Occupational Exposure Record for a Monitoring Period, shall be issued if a visitor receives > 100 mrem (1.0 mSv) or issuance of a DLR was required as a result of the visitor access request radiological evaluation.
MONITORING TOUR GROUPS A NRC Form 5 or equivalent, Occupational Exposure Record fora Monitoring Period, shall be issued to a tour member that receives > 100mrem (1.0 mSv) or issuance of a DLR was required as a result of the tour group members'access request radiological evaluation.
MAXIMUMALLOWABLE NON-PSE OCCUPATIONAL DOSE LIMITS (10CFR20.1201)
Anannual limit which is the more limiting of:
5rem TEDE. 50rem TODE to any individual organ or tissue other than the lens of the eye.
Anannual limit of 15 rem LDE to the lens of the eye. Anannual limit of 50 rem SDE to the skin or to any extremity.
ANNUALADMINISTRATIVE GUIDELINES
Totaldose, off-site plus on-site, allowed an individual shall be limited to 4,000 mrem. TEDE, received at CNS (on-site) to anyindividual, shall be controlled in any calendar year as follows:
Authorizationto exceed 1,000 mrem on-site requires written approval of the individual's DepartmentSupervisor, the RP Technical Supervisor, and shall be documented on the CNSRP-9. Prior to authorization, RadiationProtection shall verify the requirements in Step 6.7.2have been met. Non-CNS dose (off-site)determinations shall be based on estimated, recorded, or calculated dose. CNS external dose determinations may be basedon DLR and DRD readings. CNS internaldose determinations may be based on bioassay data, DAC-hour data, and ALI data. Authorizationto exceed 2,000 mrem on-site requires written approval of the individual's DepartmentManager, RP Technical Supervisor, Radiation Protection Manager, and the GeneralManager of Plant Operations (GMPO) shall be documented on the CNS RP-9. Prior to authorization, Radiation Protectionshall verify the requirements in Steps 6.7.2and 6.7.6have been met. Non-CNS dose (off-site)determinations shall be based on estimated, recorded, or calculated dose, ofwhich non-CNS (off-site) estimated dose shall not exceed 1,500 mrem. CNS external dose determinations may be basedon DLR and DRD readings. CNS internaldose determinations may be based on bioassay data, DAC-hour data, and ALI data. Authorizationto exceed 3,000 mrem (on-site) requires written approval of the individual's DepartmentManager, RP Technical Supervisor, Radiation Protection Manager, and the GMPO shallbe documented on CNS RP-9. Non-CNS dose(off-site) determinations shall be based on estimated, recorded, or calculateddose, of which non-CNS (off-site) estimated dose shall not exceed 1,000mrem. CNS external dose (on‑site)determinations may be based on DLR and DRD readings. CNS internal dose determinations may be basedon bioassay data, DAC-hour data, and ALI data. Prior to authorization, Radiation Protection shall verify therequirements in Steps 6.7.2and 6.7.6have been met.
SkinSDE dose, on-site and off-site combined, shall not exceed 45 rem/year. ExtremitiesSDE dose, on-site and off-site combined, shall not exceed 45 rem/year. Lensof the eye LDE dose, on-site and off-site combined, shall not exceed 12.5 rem/year. Dosesreceived in excess of the annual limits, including doses received duringaccidents, emergencies, and PSEs, shall be subtracted from the limits for PSEsthat the individual may receive during the current year and during theindividual's lifetime.
MAXIMUM ALLOWABLE DOSE LIMITS FORINDIVIDUALS IN THE UNRESTRICTED AREA
Per 10CFR20.1301, NPPD shall control thedose from licensed operations to individuals in the unrestricted area by applyingthe following dose and dose-rate limits:
0.1 rem TEDE in 1 year.
2 mrem in 1 hourfrom external sources.
ADMINISTRATIVE DOSE CONTROLS
Per10CFR20.2104, Radiation Protection shall determine occupational dose for each individualwho may enter the Restricted Area and is likely to receive, in a year, an occupationaldose requiring monitoring pursuant to 10CFR20.1502. To accomplish this, Radiation Protectionshall:
Determine the occupational radiation dosereceived during the current year.
To comply with therequirements of Step 6.7.2.1, current year occupational radiation dose, Radiation Protectionmay:
Accept as a record of the occupational dose that theindividual received during the current year, a written signed statement fromthe individual or from the individual's most recent employer for work involvingradiation exposure that discloses the nature and the amount of any occupationaldose that the individual may have received during the current year.
The following documents (or equivalents) can be used toverify the individual's current year occupational dose:
A NRC Form 5 or equivalent for each listed monitoringperiod.
Electronic,telephone, or facsimile transfer of dose data provided by licensees listed onthe written statement. RadiationProtection shall request a written verification of the dose data if theauthenticity of the transmitted report cannot be established. ANRC Form 4, PADS Form 4, or equivalent signed by the individual.
Ifthe record of cumulative radiation dose contains any estimated dose, theindividual shall not participate in a planned special exposure until the dosedetermination requirements of 10CFR20.1206 have been met. Whenpracticable, to help maintain individuals cumulative dose £ 10rem in 5 years, it requires Radiation Protection Manager approval toexceed 2000 mrem CNS dose.
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Procedure 9.ALARA.4, Radiation Work Permits
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PRECAUTIONS AND LIMITATIONS - RWPs shall normally be issued for a time period adequate to cover the expected duration of the job requiring the RWP.
- Radiation Protection job coverage requirements shall be placed in the worker instructions of the RWP/SWP.
- Radiation Protection hold points and stop work criteria shall be placed in the worker instructions of the RWP/SWP.
- SWPs issued for a period > 1 month shall be reviewed each time a routine survey is completed to ensure the requirements are still adequate for the radiological conditions of the area.
- Surveys performed in support of a job shall be reviewed with RWP requirements in mind. IF survey data indicates inadequate or overly restrictive requirements, THEN the RWP/Task requirements shall be revised commensurate with the radiological conditions.
- RWPs fall into two categories, General and Specific. A RWP/SWP can be written for either category.
- General RWPs can be written for areas where radiological conditions are static or the RWP already addresses the situations where changes will occur.
- Area dose rates are < 100 mrem/hr.
- Alpha contamination levels are < 20 dpm/100 cm2.
- General contamination levels are < 50,000 dpm/100 cm2.
- The activity is not expected to create an airborne radioactivity area.
- The estimated cumulative dose for any particular activity is < 1,000 mrem.
- The job is considered to be routine in nature.
- The work does not require entry into areas where the radiation, contamination, or airborne radioactivity levels are unknown or expected to change significantly.
- General SWPs can be written for areas where radiological conditions are static or the SWP already addresses the situations where changes will occur.
- The work does not involve complex radiological conditions.
- The job is considered to be routine in nature.
- The estimated cumulative dose for any particular activity is < 1,000 mrem.
- The estimated effective dose rate for the work is < 1,000 mrem/hr.
- The extremity dose rates are < 5,000 mrem/hr.
- Alpha contamination levels are < 20 dpm/100 cm2.
- General contamination levels are < 100,000 dpm/100 cm2.
- The activity is not expected to create an airborne radioactivity area.
- The work does not require multiple dosimetry to be used.
- The work does not require entry into areas where the radiation, contamination, or airborne radioactivity levels are unknown or expected to change significantly.
- WHEN the criteria listed in Step 6 or 7 for using a General RWP/SWP is not satisfied, or it is desirable to closely track job performance, THEN use a Specific RWP/SWP.
- Radiation Protection personnel shall be exempt from the SWP issuance requirement during the performance of the radiological surveys for SWP evaluation, provided the 12" (30 cm) dose rates are not expected to exceed 1,000 mrem/hr and proper radiation protection measures are taken.
- In an emergency, Radiation Protection Technicians can provide continuous radiological protection coverage for entries into an area that would normally require a SWP. The SWP shall be completed following the entry to document the radiation protection measures taken and the radiation dose incurred. The CNS RP-1B, RWP Time and Dose Log, shall be used during these instances to record personnel time and dose in the SWP Area. Radiation Protection personnel shall ensure this data is entered in the Radiological Data Management System RDMS.
- In the event of RDMS failure, a manual method of RWP log-in/log-out shall be used. This shall consist of a hard copy RWP and the CNS RP-1B, RWP Time and Dose Log.
- Ensure the RWP addresses dosimetry placement. By referring to the Form CNS RP 39, Alarming Dosimeter Setpoint Worksheet, in the job package, determine the dosimetry requirements. Ensure adequate documentation exists prior to requiring additional dosimetry. For extremity monitoring, the extremity monitoring calculation must appear on the survey or an attachment to the survey (CNS-RP-39). For additional whole body monitoring, a calculation and a clear statement supporting the need for additional monitoring must appear on the survey or an attachment to the survey (CNS-RP-39).
- Ensure dosimeter setpoints for low dose tasks are set commensurate with the needs of the job and with consideration of the need to exit the work area when the 80% dose warning alarm sounds.
- Radiological Supervisor approval is required for integrated alarming dosimeter setpoints > 100 mrem.
COMPLIANCE AND USE - Radiological information covered by a RWP shall be provided to the worker by one or more of the following methods:
- Briefing prior to entry into the area.
- Radiological surveys.
- Floor plans or maps with radiological data.
- Continuous RP coverage.
- Computer/electronic or hard copy updates posted conspicuously.
- The Job Supervisor ensures Radiation Protection is notified prior to starting work in any RWP Area. Radiation Protection shall ensure appropriate radiation protection measures are taken.
- It is each individual's responsibility to comply with the RWP requirements.
Two categories ofRadiation Work Permits (RWPs) exist; the General Radiation Work Permit(RWP)/Special Work Permit (SWP) and the Specific RWP/SWP. The RWP providesinstructions for access to the RCA. RWPsmay be written for general access to the RCA or for specific jobs within theRCA. Satellite Areas do not require theissuance and use of a RWP for general access; however, ALARA may determineduring the review of Work Orders or other work documents that a RWP should beissued to control the work. The SWP defines theradiological controls necessary for access to areas where any one or more ofthe following radiological conditions exist or expected to exist during variousevolutions of a specific job: Ahigh radiation area. Ahigh contamination area. Anairborne radioactivity area. Lockedhigh radiation area. Veryhigh radiation area. Discreteradioactive particle area. The SWP satisfies thefollowing requirements: Controlsand establishes radiation protection requirements necessary for entry and workin high radiation areas, high contamination areas, and airborne radioactivityareas. Specifiesthe instructions, protective clothing, personnel dosimetry, notificationrequirements, and respiratory protection requirements. Providesmaximum or expected maximum radiation dose rates and the requirements for entryand/or work in the area.
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Procedure 9.RADOP.1, Radiation Protection at CNS
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Shift Managers, whileon-shift, are responsible for the following: - Implementing and enforcing of the Radiation Protection procedures and requirements with regard to radiation safety in the operation of the station.
- Monitoring station activities to ensure compliance with approved Radiation Protection procedures and requirements specified by Radiation Protection with regard to radiation protection.
- Notifying the Radiation Protection Manager of any exception or violation of Radiation Protection procedures with regard to radiation protection.
- Ensuring all work to be performed, which involves known or potential radiological hazards, has received review by Radiation Protection and requirements specified by Radiation Protection are properly implemented and complied with during the performance of that work.
- Consulting with and requesting the assistance of Radiation Protection, as needed, in any matter concerning radiological safety.
- Additional items listed for Station Supervision in Step 3.6, with regard to radiation protection.
The RadiationProtection Manager has the authority to take the following action without priornotification to the General Manager of Plant Operations: - Restricting further radiation dose to those individuals whose known or estimated dose is approaching the allowable administrative or regulatory limits.
- Terminating any or all operations involving radiological hazards, when considered necessary, to avoid personnel radiation dose beyond allowable administrative and regulatory limits.
- Delegating functional responsibilities and assigning duties within the Radiation Protection Department, as may be elected, regarding performance of radiation safety at CNS.
- Terminating any or all operations involving the release, or potential release, of radioactive materials to the environment whether or not the release is by a monitored pathway.
- Terminating access to the restricted area or RWP areas if an individual or group of individuals fails to demonstrate proper radiological protection practices.
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Procedure 9.RADOP.2, Radiation Safety Standards and Limits
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LEVELS OF RADIOACTIVE CONTAMINATION Permissiblelevels OUTSIDE the RCA, but INSIDE the restricted area: LOOSESMEARABLE CONTAMINATION NODETECTABLE ACTIVITY - Detectable activity is defined as the activity detectable with a frisker or an equivalently sensitive technique. This level of activity applies only to licensed material as defined by 10CFR20, Paragraph 20.1003.
- If no alpha activity, using an instrument with a sensitivity ≤ 20 dpm/100 cm2, is detected on selected routine contamination surveys in the RCA, items being released need not be surveyed for alpha activity unless directed by RP Supervision.
- Loose smearable contamination associated with radioactive shipments shall be in compliance with the requirements of Procedure 9.RW.1.
FIXEDCONTAMINATION - No detectable activity found when using instrumentation with a sensitivity of ≤ 2.2 nCi, as determined by gross gamma analysis with gamma sensitive counter; or
- No detectable activity found when using instrumentation with a sensitivity of ≤ 100 cpm/probe area using a GM detector by direct frisk.
- Fixed contamination associated with radioactive shipments shall be in compliance with the requirements of Procedure 9.RW.1.
Permissiblelevels inside the RCA and satelite areas LOOSESMEARABLE CONTAMINATION - Controlled Clean Areas (CCA) are accessible areas in the RCA and Satellite Areas that shall be maintained at ≤ 1000 dpm/100 cm2 beta gamma and ≤ 20 dpm/100 cm2 alpha.
- Areas > 1000 dpm/100 cm2 beta gamma or > 20 dpm/100 cm2 alpha shall be roped off and posted in compliance with Procedure 9.EN RP 108.
- When general contamination levels exceed 50,000 dpm/100 cm2, a SWP shall be required for entry.
- In areas where general contamination levels are found to be > 50,000 dpm/100 cm2, an initial beta and airborne radioactivity survey shall be conducted. Subsequent beta and airborne radioactivity surveys in these areas shall be performed per RWP requirements and when RP Supervision deems necessary.
FIXEDCONTAMINATION Fixedcontamination shall not exceed RWP, SWP, and area postings. WATERBORNECONTAMINATION Areaswith free standing surface water containing radioactive material inconcentrations > 3E-4 mCi/ml shall be roped off and posted in compliancewith Procedure 9.EN-RP-108. CONTAMINATIONLEVELS OF MATERIALS AND EQUIPMENT Allequipment and materials inside the RCA and RMA, ARA, HCA, and CA SatelliteAreas shall be considered radioactive material unless surveyed and released bya RP. Items, except for containersdescribed in 10CFR20.1904, need not be labeled or posted provided that they donot adversely affect area radiation levels. Contaminated material shall not exceed RWP, SWP, and area postings. Materialsand equipment with loose surface contamination > 1000 dpm/100 cm2 beta-gammaor > 20 dpm/100 cm2 alpha shall be dispositioned in one of the followingways to prevent the unnecessary spread of contamination: - Remain inside contamination areas.
- Decontaminated to levels less than contamination area threshold.
- Contained and labeled properly.
- Remain under direct RP control.
CONTAMINATIONLEVELS OF PROTECTIVE CLOTHING Loose surface contamination on protective clothingshall be ≤ 1000 dpm/100 cm2 beta-gamma and ≤20 dpm/100 cm2 alpha. Fixed contamination on protective clothing shall be ≤5,000 cpm above background by direct frisk with a ratemeter equipped with apancake type GM probe. Protectiveclothing which exceed the limits shall be processed for rewash or dispositionedfor disposal. CONTAMINATIONLEVELS OF RESPIRATORY EQUIPMENT Loose surface contamination on respiratory equipmentshall be ≤ 1000 dpm/100 cm2 beta-gamma and ≤20 dpm/100 cm2 alpha. Fixed contamination on respiratory equipment shall be≤ 1000 cpm/probe area. CONTAMINATIONLEVELS FOR PERSONNEL UNRESTRICTEDCONTAMINATION LIMITS No detectable activity found when using an instrumentwith a sensitivity of ≤100net cpm/probe area using a GM detector with a pancake probe and/or ≤2.2 nCi/detector area using the personnelcontamination monitors. Clearanceof a functioning portal monitor, if available. UNRESTRICTEDCONTAMINATION LEVELS FOR TRASH COLLECTED INSIDE THE RCA OR RMA, ARA, CA, ANDHCA SATELLITE AREAS TRASHRELEASED THROUGH RCA ACCESS Uselevels established in Step 3.1. TRASHRELEASED AT TRASH MONITORING AREA Nodetectable activity found when using an instrument with a sensitivity of £ 100net cpm by direct frisk and one of the following: No detectable activity found when using the NNC ModelWCM-10 bag monitor with a sensitivity of ≤ 10 nCi. Nodetectable activity when using and Integrated Tool Monitor (ITM) or SmallArticles Monitor Airborne Radioactivity Area - An area,accessible to personnel, in which airborne radioactive materials composed oflicensed material exist in concentrations which: - > 3E-9 mCi/ml for unidentified radionuclides per 10CFR20, Appendix B, Table 1.
- Are in excess of amounts specified in 10CFR20, Appendix B, Table 1, Column 3.
- Averaged over the number of hours in any week during which individuals are in the area, exceed 30% of the amounts specified in 10CFR20, Appendix B, Table 1, Column 3.
- > 30% of the DAC values for identified radionuclides.
Derived Air Concentration (DAC) - Theconcentration of a given radionuclide in air which if breathed by the referenceman for a working year of 2,000 hours under conditions of light work results inan intake of one ALI. DAC values aregiven in 10CFR20, Appendix B, Table 1, Column 3. Derived Air Concentration-hour (DAC-hour)- The product of the concentration of radioactive material in air (expressed asa fraction or multiple of the DAC for each radionuclide) and the time ofexposure to that radionuclide in hours. 2,000 DAC-hours is equivalent to one ALI or 5 rem CEDE. Unrestricted Area - The areaaccessible to the general public, access to which is neither limited norcontrolled by NPPD. This area iscomprised of the area outside of the Owner Controlled Area. Controlled Area - The area outside ofthe Restricted Area but inside the NPPD property boundary, access to which canbe limited by NPPD. This area iscomprised of the area outside of the Protected Area fence but within the OwnerControlled Area. Restricted Area - The area at CNS inwhich access is limited by NPPD for the purpose of protecting individualsagainst undue risks from exposure to radiation and radioactive materials. The Restricted Area is comprised of all areaswithin the boundary of the Protected Area fence and the area within the lowlevel radioactive waste storage pad fence when the pad is in use. Satellite RCA (or Satellite Area) -Those areas controlled by Radiological Protection via radiological postingsthat are not defined as part of the RCA. Radioactive Material Area (RMA) - Anarea or room, accessible to personnel, in which licensed materials are used orstored and which contain any radioactive material (other than natural uraniumor thorium) in an amount exceeding ten times the quantity of such materialsspecified in 10CFR20, Appendix C. Neutron Area (NRA) - An area,accessible to personnel, in which neutron radiation levels could result in anindividual receiving a deep-dose equivalent in excess of 5 mrem in 1 hour at12" (30 cm) from the radiation source or from any surface that theradiation penetrates. Contamination - The deposition ofradioactive material in an area where it is not desired. It may exist as either fixed contamination(radioactive material which has been absorbed) or as loose contamination onsurfaces, in liquids, or in a gaseous media. Contamination Area (CA) - An areawhere removable surface contamination is > 1000 dpm/100 cm2 beta gamma or> 20 dpm/100 cm2 alpha, but is < 50,000 dpm/100 cm2 beta-gamma. High Contamination Area (HCA) - Anarea in which loose surface contamination exceeds 50,000 dpm/100 cm2 generalarea. Hot Spot - A localized area such asvalves, bends in pipes, drains, etc., which have radiation levels: >100mrem/hr on contact; and Thecontact radiation levels are greater than four times the 30 cm (about 12")reading. Licensed Material - Any sourcematerial, special nuclear material, or by-product material received, possessed,used, or transferred under a general or specific license by the NRC. Discrete Radioactive Particle -Radioactive contamination that can be identified as a unique fragment, composedof fuel constituents, neutron activated components or corrosion, and wearproducts. It can be differentiated byvarious shielding techniques to show that it is not distributed. Planned Special Exposure (PSE) - Aninfrequent exposure to radiation, separate from and in addition to the annualdose limits.
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Procedure 9.EN-RP-108, Radiation ProtectionPosting
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PRECAUTIONS AND LIMITATIONS - For an area already inside a posted Radiologically Controlled Area (RCA), a RCA insert or text is not required to be on a posting for Radioactive Material Area, Radiation Area, High Radiation Area, Locked High Radiation Area, Very High Radiation Area, Contaminated Area, High Contamination Area, or Airborne Area.
- Contact RP Supervision if questions arise as to the proper method to be used to post or label materials or areas.
- Immediately notify RP Supervision of incorrect postings or a significant change in radiological conditions, unless the change in conditions was discussed and documented (e.g., Log Book or Electronic Log) prior to the evolution.
- When radiological conditions change, postings shall be updated and changes documented as soon as possible.
- When changes in radiological conditions are planned or expected (e.g., power increase, RWCU sludge pumping), postings should be conservatively established in anticipation of the changes rather than after the fact.
- Ensure proper postings exist in areas where dose rates may change due to operation of plant systems. Increase in Optimum Water Chemistry (OWC) hydrogen injection flow rates should be evaluated by RP Supervision/designee for potential impact on radiological postings.
- The requirements of this procedure do not apply to background radiation or naturally occurring radioactive material such as Radon.
- Snow fence cannot be used as a radiological barrier.
- Eating, drinking, and chewing are prohibited in any RCA unless specifically authorized by the Radiation Protection Manager, unless emergency conditions warrant.
- Normal RCA exit points should have signs with the requirements:
- Personnel and personal items shall be monitored.
- Tools and equipment shall be monitored as directed by RP Personnel.
- Posting only the entrance to a large room or building is inappropriate if most of the area is not a Radiation Area and only discrete areas are Radiation Areas. If discrete areas can be reasonably posted, they should be.
- Refer to Attachment 1, Standard Posting Guidelines, for additional posting guidance.
- Installation of radiological protection postings and radiological boundaries shall comply with Procedure 0-BARRIER and its supporting procedures.
- RP postings (rope and signage) is Transient Combustible Evaluation (TCE) exempt (reference Procedure 0.7.1, Section 4.11); however, step-off pads and plastic/tacky cloth used to cover the walls and floors for contamination control purposes require a TCE.
RADIOLOGICAL CONTROLLED AREA POSTING - Normally, RCAs are identified by a posting on a stanchion, wall, or door at each approach to the area. Rope boundaries or barriers may be used when necessary to effectively indicate the extent of area.
- Additionally, post normal RCA access points with:
- Radioactive Materials.
- DLR and SRD required for entry.
- RWP required.
- No eating, drinking, chewing.
- Place signs along the boundary at appropriate intervals to ensure approaching individuals recognize the radiological hazard(s) present.
- For normal plant RCA access points, green RCA boundary tape may be used.
- Ensure postings are visible from all access points.
- For Satellite RCA entrance points, post the following requirements:
- "CAUTION", Radioactive Material or Radioactive Material area.
- RWP required for entry.
- For Satellite RCAs, post the following applicable monitoring requirements:
- If a Contamination Area was entered, then perform Whole Body frisk AND proceed to nearest access WBCM; or
- Perform, as a minimum, a Hand and Foot frisk, and proceed to nearest WBCM.
- For Satellite RCAs during the preparation for loading a trailer for a radioactive shipment, the RPM may deviate from the requirements of frisking each time the individual exits the area; however, when the task is complete, the individual must proceed to the nearest WBCM. This approval should be documented in the RP Log or equivalent.
- POSTING WALK-IN AND SEALAND CONTAINERS IN SATELLITE AREAS
- Walk-in containers housing radioactive material occupied by personnel to perform specific work functions (e.g., Eddy Current Trailer, Snubber Trailer, etc.) should be posted as a RCA and treated as buildings.
- The Radiation Protection Manager may give approval for altering specific posting requirements on a case-by-case basis. This approval should be documented in the RP Log or equivalent.
- Post all non-approved RCA exits as "Caution", "RCA Boundary", "Emergency Exit Only", "Contact Radiological Protection Prior to Breaching This Boundary".
- Post all non-approved RCA entrances as "Caution", "Radioactive Materials", "RCA Boundary", "Emergency Entrance Only".
RADIATION AREA - Normally, Radiation Areas inside the RCAs are identified by a posting on a stanchion, wall, floor, or door at each approach to the area. Rope boundaries or barriers may be used, when necessary, to effectively indicate the extent of area.
- Post each Radiation Area with the words "Caution - Radiation Area". Lettering will normally be white on green background.
- Post each Radiation Area with the words "RWP Required" unless the area is within an area already posted as such.
- Consideration should be given to conspicuously posting does rate ranges at or within the Radiation Area.
- Alternate means of posting dose rate ranges may be approved by the RPM (e.g., RP Status Boards).
- Place signs along the boundary at appropriate intervals to ensure approaching individuals recognize the radiological hazard(s) present.
- Ensure postings are visible from all access points.
HIGH RADIATION AREA - Completely barricade each High Radiation Area with suitable material or perform direct surveillance to prevent inadvertent entry when access to the area is required.
- Post each High Radiation Area with the words "SWP Required" unless the area is within an area already posted as such.
- Post each High Radiation Area with the words "Caution - High Radiation Area" as provided in Attachment 2, "High Radiation Area Signage", or equivalent. Lettering will normally be magenta on a yellow background.
- Access/egress points (as necessary) require a barricade to prevent inadvertent access. The following are acceptable barricades:
- An alarming device.
- Rope with a High Radiation Area posting placed ~ 4' to 6' off the floor.
- The posting of doors/gates hung in a manner as to not interfere with the operation of the door/gate or results in de-posting when the door or gate is opened. A stop sign shall be posted at the access/egress point stating the following: "This High Radiation Area barricade must remain in place at all times. This is a requirement of CNS procedures and Tech. Spec 5.7.1. DO NOT REMOVE THIS BARRICADE".
- Depending upon circumstances involved with various areas of the plant, deviations from these methods of posting may be approved by RP Supervision and documented in a log or equivalent.
LOCKED HIGH RADIATION AREA POSTING - Completely barricade each Locked High Radiation Area utilizing physical barriers at least 6' high (e.g., chain link fence or fabricated walls) with a locked access point to prevent unauthorized entry or perform direct surveillance to prevent unauthorized entry when access to the area is required.
- Post each Locked High Radiation Area that is not a Very High Radiation Area with the words "Caution-Locked High Radiation Area" as provided in Attachment 3, Locked High Radiation Area Signage, or equivalent. Lettering will normally be magenta on a yellow background.
- Post each Locked High Radiation Area with the words "SWP Required" unless the area is within an area already posted as such.
- Post the inside and outside of each Locked High Radiation Area door or gate with the words "This is a Locked High Radiation Area; you must ensure this area is locked or guarded after you enter or exit".
- In case of large areas (e.g., BWR Drywell) where no enclosure exists for the purpose of locking and no enclosure can reasonably be constructed around the individual areas where the Locked High Radiation level exist, then the area shall be barricaded, conspicuously posted, an Area Radiation Monitor established with both visual and audible signals set to alarm if radiation levels rise, and a flashing red light warning device may be utilized to warn plant personnel. Obtain Radiation Protection Supervision/Management's approval to implement the alternate method of controlling a Locked High Radiation Area described in this step.
- No ladders or equipment shall be stored around or used in a manner that would allow access over a LHRA barricade.
VERY HIGH RADIATION AREA POSTING - Completely barricade each Very High Radiation Area such that fencing or walls extend to the overhead to preclude anyone from climbing over and a locked access point to prevent unauthorized entry or perform direct surveillance to prevent unauthorized entry when access to the area is required.
- Post each Very High Radiation Area with the words "Grave Danger, Very High Radiation Area, SWP Required" as provided in Attachment 4, Very High Radiation Area Signage, or equivalent.
- Lettering will normally be magenta on a yellow background.
- Post the inside and outside of each Very High Radiation Area door with the words "This is a Very High Radiation Area; you must ensure this area is locked or guarded after you exit or enter".
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Procedure 9.EN-RP-141-02, Discrete RadioactiveParticle Control
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PRECAUTIONS AND LIMITATIONS - Individual sections of this procedure may be performed independently from other sections. The steps in this procedure do not need to be performed sequentially.
- Discrete Radioactive Particles (DRPs) can be composed of:
- Corrosion/wear products such as cobalt and tin.
- Fuel fragments such as ruthenium, cerium, and plutonium.
- DRPs are classified as either fuel particles or corrosion particles.
- DRPs tend to assume an electrostatic attraction which causes them to physically relocate from surface to surface. Care should be taken while handling DRPs to prevent their loss and possible re-contamination of personnel or areas.
- DRPs can cause high localized dose rates which could result in personnel dose limits being exceeded in a short period of time.
- The dose rate from a DRP may be grossly under estimated when using portable radiation detection instrumentation.
- Whole body Personnel Contamination Monitors (PCMs) should be located at normally established Radiologically Controlled Area (RCA) egress points and set to identify DRP contamination on workers.
- Slow and careful techniques must be used when surveying for DRPs because the dose rate drops off rapidly with distance and readings may be masked with background radiation levels.
- DRP trash may have very high dose rates.
- Due to the rapid accumulation of shallow dose equivalent (skin dose), do not delay in removing DRPs from personnel.
- Isotopic analysis (e.g., gamma spectroscopy) may be performed on captured DRPs to determine the type of particle, the activity of the particle, and for personnel dose assessment.
- DRPs from other nuclear facilities may be introduced to a site via the shipment of material and equipment.
- Prior to loading materials and/or equipment that could contain DRPs, contact the RP Supervisor, Radwaste, or the RP Specialist for instructions on how to best contain/fix the particles to the materials so that during transportation significant changes in dose rates will not occur. Some methods utilized may be the use of strippable coatings or wrapping the material with plastic sheeting prior to loading into a container.
DISCRETE RADIOACTIVE PARTICLE SOURCES - Potential sources of DRPs include:
- Reactor Coolant System and systems/components containing reactor coolant.
- Spent Fuel Pool.
- Refueling Canal/Fuel Transfer Canal.
- Decontamination Facilities.
- Refueling equipment.
- Vendor equipment used in or on radioactive systems at other nuclear facilities (e.g., fuel handling, ISI, steam generator eddy current, diving, underwater cameras, etc.).
- Re-usable radiological protective clothing.
- Activities which could generate DRPs:
- Maintenance involving the opening of radioactive systems or components.
- Spent Fuel Pool activities.
- Refuel Floor activities.
- Radioactive shipments received from other nuclear facilities.
- Decontamination of plant surfaces and equipment.
DRP CONTROLS - The source of DRPs should be identified AND controlled OR eliminated.
- Ensure that the RWP is appropriate for work within a DRP posted area.
- Discuss DRP hazards and controls with all workers prior to their commencing activities within a DRP posted area.
- USE decontamination methods to reduce DRP radiation and contamination levels, as appropriate.
- Consider the use of containments or glove bags to minimize the spread of DRPs.
- Local and plant ventilation should be controlled so as to minimize the spread of DRPs (e.g., establish negative ventilation in the DRP area, use Engineering controls to direct the airflow away from the DRP area, etc.).
- Tools and equipment used in DRP areas should be wiped down or otherwise decontaminated prior to removal from the area.
- Items leaving a DRP area are to be surveyed and tagged as having come from a DRP area.
- Radioactive trash and material generated within a DRP area should be marked or labeled (e.g., Discrete Radioactive Particles, DRP, etc.).
- Double bagging, wrapping, etc., may be used to ensure that the DRPs are adequately contained.
- Ensure that the external surfaces of bags, wrapping materials, etc., are free from DRPs prior to removing from a DRP area.
- Trash known to contain DRPs should be stored in a designated area separate from other radioactive trash.
- SEGREGATE re-usable protective clothing worn in DRP areas from other protective clothing.
- SEGREGATE respiratory protection equipment used in DRP areas from other respiratory protection equipment AND clearly identify the items as having been worn in a DRP area.
- IF a vacuum or HEPA ventilation unit was used in a DRP area, THEN label the equipment as "DRP - Contact RP prior to Opening".
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Procedure9.EN-RP-101, Access Control for Radiologically Controlled Areas
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- RADIATION AREA ACCESS CONTROL
- Specific monitoring and radiological controls for access to "Radiation Areas" shall be listed on the appropriate RWP. As a minimum, each person entering a "Radiation Area" shall have:
- DLR.
- Direct reading dosimeter.
- Approved RWP.
- HIGH RADIATION AREA (HRA) ACCESS CONTROL
- High Radiation Area entry points require a barricade to prevent inadvertent access.
- If barricade for a HRA must be temporarily removed, then a RP Technician may maintain direct "line-of-sight" surveillance of access to HRA until access/barrier is re‑secured and verified.
- Specific monitoring and radiological controls for access to "High Radiation Areas" are listed on appropriate SWP. As a minimum, each person entering a "High Radiation Area" shall have:
- DLR.
- Alarming direct reading dosimeter (electronic dosimeter).
- Stay time (if > 500 mrem per entry is expected).
- Approved SWP.
- Pre-job briefing on radiological conditions in the area.
- LOCKED HIGH RADIATION AREA ACCESS CONTROL
- Specific monitoring and radiological controls for access to "Locked High Radiation Areas" shall be made by RP personnel and listed on the appropriate SWP. As a minimum, each person entering a "Locked High Radiation Area" shall have:
- DLR.
- Alarming direct reading dosimeter (electronic dosimeter).
- Approved SWP.
- RP Shift Technician or Radiation Protection Supervision (RPS) approval.
- If an individual is working in a dose rate of ³ 1000 mR/hr, then continuous RP coverage with the use of CNS RP-56, Radiological Stay Time Verification Sheet, is required.è4
- Radiation Protection Manager or designee approval for entry into LHRAs with general area dose rates > 1.5 rem/hr in the actual work area.è4
- Documented pre-job brief for entry, using CNS RP-800, given by RP personnel. This brief shall cover radiological conditions in the immediate work areas using the most recent survey data available and the scope of the work to be performed. RPS performs pre-job brief for entry into LHRAs with general dose rates > 1.5 rem/hr in actual work area.è4,5,6
NOTE – Decisions regarding operation of plantequipment and systems are the sole responsibility of licensed Operationspersonnel. Due to plant conditions, itmay not be possible or advisable for Operations to implement requests forequipment or system status changes. - VERY HIGH RADIATION AREA ACCESS CONTROL
WARNING – To the extent possible, entry into a VHRA should be forbidden unlessthere is a sound operational or safety reason for entering. Without proper controls and monitoring,personnel entering these areas could receive radiation exposure with severe orlife‑threatening consequences. - Specific monitoring and radiological controls for access to "Very High Radiation Area" shall be listed on the appropriate SWP. As a minimum, each person entering a "Very High Radiation Area" shall have a(n):
- DLR.
- Alarming direct reading dosimeter (electronic dosimeter).
- Continuous RP coverage and stay time tracking per Procedure 9.EN‑RP-141.
- Stay time and dose estimate assigned for each entry.
- Documented pre-job brief for entry given by a RPS. This brief shall cover radiological conditions in the immediate work area using most recent survey data available and the scope of the work to be performed.
- Approved Job Specific SWP.
- Approval of Radiation Protection Manager or designee and on-watch Shift Manager.
- AIRBORNE RADIOACTIVITY AREA < 10 DAC ACCESS CONTROL
- As a minimum, each person entering an "Airborne Radioactivity Area" shall have:
- DLR.
- Direct reading dosimeter.
- Approved SWP.
- AIRBORNE RADIOACTIVITY AREA > 10 DAC ACCESS CONTROL
- As a minimum, each person entering an "Airborne Radioactivity Area > 10 DAC" shall have:
- DLR.
- Direct Reading Dosimeter (DRD).
- Approved SWP.
- Respiratory protection devices for access to "Airborne Radioactivity Areas > 10 DAC" shall be issued in accordance with the Respiratory Protection Program procedures.
- If an individual is working in an airborne radioactivity area > 10 DAC, then continuous RP coverage is required.
- A RP Technician should perform a briefing using CNS RP-800 for guidance.
- UNKNOWN RADIOLOGICAL CONDITION AREA
- As a minimum, each person entering an "Unknown Radiological Condition Area" shall have:
- DLR.
- Direct Reading Dosimeter.
- Approved SWP.
- If an individual is working in an unknown radiological condition area, then continuous RP coverage is required.
- A RP Technician should perform a briefing using CNS RP-800 for guidance.
- MOVEMENT OF RADIOACTIVE MATERIAL (RAM) ³ 100MR/HR @ 30 CENTIMETERS
- As a minimum, each person involved in "Movement of Radioactive Material (RAM) ³ 100 mrem/hr @ 30 centimeters" shall have:
- DLR.
- Direct Reading Dosimeter.
- Approved SWP.
- If movement of RAM ³ 100 mrem/hr @ 30 centimeters is being performed, then continuous RP coverage is required.
- A RP Technician should perform a briefing using CNS RP-800 for guidance.
- LOOSE SURFACE CONTAMINATION LEVEL > 1E6 DPM/100 CM2
- As a minimum, each person involved in "Loose Surface contamination Level > 1E6 dpm/100 cm2" shall have:
- DLR.
- Direct Reading Dosimeter.
- Approved SWP.
- CONTAMINATION/HIGH CONTAMINATION AREA ACCESS CONTROL
- As a minimum, each person entering a "Contamination Area" should have:
- DLR.
- Direct Reading Dosimeter.
- Protective clothing.
- Approved RWP/SWP.
- CONTROL AND INVENTORY OF LHRA KEYS
- The use of LHRA keys not in the possession of the RP Department shall be limited to emergency entries and shall be maintained by the Operations Shift Manager. In the event that use of a LHRA key is needed for access, contact with Shift RPT shall be made as soon as possible following the entry to the area.
- This provision allows for emergency access to LHRA Areas. In the case of emergency, entry being required and at the direction of the Operations Shift Manager, Operations personnel may utilize the emergency key to gain access to the LHRA.
- CONTROL AND INVENTORY OF VERY HIGH RADIATION (VHRA) KEYS
VHRAkeys will be issued to RP personnel only, as outlined in Step 19.5, with RPMapproval for specific use. The RPM and Operations ShiftManager shall approve the issuance of VHRA keys by completing Attachment 3,VHRA Access Approval Form. The issuanceof these keys shall be for specifically briefed activity. - DEFINITIONS
- Contamination Area - An area where removable surface contamination is > 1,000 dpm/100 cm2 beta-gamma or > 20 dpm/100 cm2 alpha but is £ 50,000 dpm/100 cm2 beta-gamma.
- High Contamination Area (HCA) - An area in which loose contamination is > 50,000 dpm/100 cm2 general area.
- High Radiation Area (HRA) - An area accessible to individuals in which radiation levels from surface external to the body could result in an individual receiving a deep dose equivalent > 100 mrem (1 mSv) in 1 hour at 30 cm (~ 12") from the radiation source or from any surface that the radiation penetrates.
- Locked High Radiation Area - An area accessible to individuals in which radiation levels from sources external to the body could result in an individual receiving a deep dose equivalent > 1 rem (10 mSv) in 1 hour at 30 cm (~ 12") from the radiation source or from any surface that the radiation penetrates.
- Radiation Area - An area accessible to individuals in which radiation levels could result in an individual receiving a deep dose equivalent > 5 mrem (0.05 mSv) in 1 hour at 30 cm (~ 12") from the radiation source or from any surface that the radiation penetrates.
- Restricted Area - The area at CNS in which access is limited by NPPD for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials. The Restricted Area is comprised of all areas within the boundary of the Protected Area fence and the area within the low level radioactive waste storage pad fence when the pad is in use.
- Very High Radiation Area (VHRA) - An area, accessible to individuals, in which radiation levels from radiation sources external to the body could result in an individual receiving an adsorbed dose in excess of 500 rads (5 Gy) in 1 hour at 1 meter (~ 3') from a radiation source or 1 meter from any surface that the radiation penetrates.
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Procedure 9.ALARA.13, Radiation Worker and TourGroup Dosimetry Management
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- Verify Tour Groups entering Vital Areas have at most a 5 to 1 ratio of tour members to the individuals escorting them per Procedure 1.15.
- ENTRANCE WHOLE BODY COUNT, DIRECT READING DOSIMETER HEARING TEST, AND DLR ISSUANCE
NOTE – For the purpose of entrance whole bodycounting, the individual is not required to have a DLR and ED for entry intothe RCA Access PM-7/12 as long as they are escorted by RP personnel. - SETTING DOSE LIMITS FOR A DECLARED PREGNANT WORKER
- A monthly dose limit for a declared pregnant woman shall be imposed to ensure a uniform monthly exposure. This limit shall take into account the time remaining in the pregnancy and the dose limit in Procedure 9.EN-RP-205.
- DISCUSSION
- Minors, individuals under 18 years of age, may have access to the RCA with the approval of the Radiation Protection Department for the purpose of a tour or job interview only. No access to the following areas within the RCA shall be allowed:
- Contamination Areas.
- High Contamination Areas.
- High Radiation Areas.
- Locked High Radiation Areas.
- Very High Radiation Areas.
- Airborne Radioactivity Areas.
- Discrete Radioactive Particle Areas.
- REQUIREMENTS
- All visitors entering Radiologically Controlled Area shall be issued a DLR and DRD.
- Visitors requiring access to the RCA shall log in and out of the RCA via the RCAWP login and logout process. Their escort or Radiation Protection may provide assistance.
- Visitors requiring access to SWP Areas shall log in and out of the SWP Area via the SWP login and logout. Their escort or Radiation Protection may provide assistance.
- Visitors shall return DLR to Dosimetry and receive a whole body count prior to departure.
- TOUR GROUP REQUIREMENTS FOR RCA ACCESS
- Approval from the General Manager of Plant Operations to allow a tour group inside the RCA.
- If Tour Group Access to Radiologically Controlled Area is required, complete Attachment 2 and route to Radiation Protection for processing. Contact Dosimetry for guidance.
- All Tour Groups entering the Radiologically Controlled Area shall be issued a DRD or equivalent upon entry.
- Tour Group members requiring access to the Radiologically Controlled Area should not be logged in and out of Radiologically Controlled Area via the RCAWP.
- DRD or equivalent issued to tour members shall be zeroed. These individuals shall be logged in and out of the Radiologically Controlled Area on Attachment 2.
- Tour members shall not enter SWP Areas.
- Tour Group escort shall ensure Tour Group members do not enter posted Contaminated Areas, High Radiation Areas, or Airborne Radioactivity Areas.
- If any Tour Group member receives > 100 mrem (1.0 mSv) by DRD, or equivalent during their visit, Radiation Protection shall be contacted and a CNS‑RP-10, Exposure History Worksheet, shall be completed before allowing the tour member to depart.
- The Tour Guide will be issued a DLR that will monitor the group.
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Procedure 5.7.12, Emergency Radiation ExposureControl
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- PRECAUTIONS AND LIMITATIONS
- Personnel authorized to receive emergency exposures should meet the following criteria:
- Personnel conducting corrective or protective actions or life-saving actions who may receive a TEDE in excess of occupational limits should be selected on a voluntary basis.
- Personnel shall be familiar with the hazards of any exposure received under emergency conditions.
- Declared pregnant woman shall not take part in these actions.
- Personnel should not have received previous emergency exposures. Emergency exposure should be limited to once in a lifetime.
- All occupational doses, including emergency doses, are required to be included as part of a worker's exposure history and hence can affect the worker's future allowable exposure.
- REQUIREMENTS
NOTE 1 – The examples listed below do not representan absolute list. The existing situationmay dictate additional conditions under which exceeding 10CFR20 limits may bewarranted. NOTE 2 – The terms populationand large population are notspecifically defined in regulations; however, the following is listed asguidance in EPA 400: "Risks to populationsin this context "substantial risks" means collective doses that aresignificantly larger than those incurred through the protective activitiesengaged in by the workers. In thecontext of this guidance, exposure of workers that is incurred for theprotection of large populationsmay be considered justified for situations in which the collective dose avoidedby the emergency operation is significantly larger than that incurred by theworkers involved". NOTE 3 – Federal Register/Vol. 47, No. 205/Friday,October 22, 1982/Notices, lists the following guidance: "The ratio oftotal United States population to the maximum number of people in the vicinityof an operating reactor could be erroneously interpreted so that progressivelysmaller populations would be subject to progressively larger individual risks.This is not the intent of the recommendations". Therefore, the members of the public aroundCNS constitute populations or large populations. - The Emergency Director may authorize emergency exposures under the following conditions:
- LIFE-SAVING ACTIONS 25 REM OR MORE
- Rescue and/or treatment of personnel with life threatening injuries.
- Corrective activities to avoid extensive exposures to large populations.
- CORRECTIVE OR PROTECTIVE ACTIONS 25 REM
- Support of life saving activities or protection of large populations when lower dose is not practical.
- CORRECTIVE OR PROTECTIVE ACTIONS 10 REM
- Protecting valuable property when lower dose is not practical.
- ALL OTHER EMERGENCY CONDITIONS 5 REM
- Collection of in-plant airborne and liquid samples.©1
- Performing personnel decontamination.
- Use of the post-accident sampling system.©1
- Radiological monitoring (teams).
- GUIDE ON DOSE LIMITS FOR WORKERS PERFORMING EMERGENCY SERVICES
CONDITION EMERGENCY LIMIT, up to (see NOTE) Sampling, Surveys (on and off-site), Decontamination, PASS System use, etc. 5R Restoration/repair of critical equipment during the emergency phase of a declared emergency. 10R Protection of valuable equipment (ensure lubrication, prevent damage, fire-fighting, etc.). 10R Isolation of a radiological release less than G.E. (as calculated by CNS-Dose). 10R Isolation of a radiological release greater than G.E. (as calculated by CNS-Dose) and off-site protective actions (evacuation) have been completed. 10R Providing first aid to less seriously injured personnel or in support of life-saving activities. 10R Isolation of a radiological release greater than G.E. (as calculated by CNS-Dose) and off-site protective actions (evacuation) have not been completed. 25R Prevent imminent core damage. 25R Life-saving activities or protection of large populations (only on a voluntary basis). > 25R NOTE – Sum of external effective dose equivalent and committed effective doseequivalent to non‑pregnant adults from exposure and intake during anemergency situation. Workers performingservices during emergencies should limit dose to the lens of the eye to 3 timesthe listed value and doses to any other organ (including skin and bodyextremities) to 10 times the listed value. These limits apply to all doses from an incident, except those receivedin unrestricted areas as members of the public during the intermediate phase ofthe incident (refer to Chapters 3 and 4 of EPA 400). - DISCUSSION
- Under emergency conditions, it may become necessary for emergency workers to receive exposures in excess of occupational limits established by 10CFR20. Emergency dose exposure limits (guidance) are defined for emergency workers performing several activities. These exposure limits are listed on Attachment 1.
- Only the Emergency Director has the authority to authorize exposures in excess of occupational limits. These exposures are only justifiable if it is determined that benefits to be achieved are commensurate with the projected dose and every reasonable effort is being made to maintain emergency workers doses As Low As Reasonably Achievable (ALARA).
- Justification of any such exposure must include the presence of conditions that prevent the rotation of workers or other commonly-used dose reduction methods such as protective clothing or respiratory protection. For the risks to be judged "acceptable", the net benefit to society needs to be positive.
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Procedure 10.1, APRMCalibration
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- PRECAUTIONS AND LIMITATIONS
- Prior to performing any adjustments to an APRM channel, it shall be bypassed.
- Any APRM with its setting outside the two loop operation range of ± 2% RTP or corrected single loop operation range as required by LCO 3.4.1, as observed on a Periodic Case or Heat Balance Summary, shall be calibrated per this procedure.
- REQUIREMENTS
- During MODE 1, opening RWCU-MO-74 per Procedure 2.2.66 results in thermal reactor power indicating lower than actual power due to RWCU flow bypassing flow elements.
- VALID CTP AVAILABLE
- For two loop operation, (APRM - %CTP) readings shall be within -2.0 £ APRM - %CTP £ 2.0. Record (APRM - %CTP) readings (from Periodic Case or Heat Balance Summary) and attach Periodic Case or Heat Balance Summary to Attachment 1.
- For SLO, (APRM - %CTP) readings shall be within 6.9 £ APRM - %CTP £ 10.9. Record (APRM - %CTP) readings (from Periodic Case or Heat Balance Summary) and attach Periodic Case or Heat Balance Summary to Attachment 2.
- DISCUSSION
- MODE 1 - The APRM System provides continuous indication of the bulk power level of the reactor during power range operation. The APRM meters read in percent of rated CTP. The APRM System is also used to initiate rod block trips based on power‑to‑flow relationships and to initiate reactor scrams. The flow biased APRM high flux scram will prevent the 1% plastic strain limit from being exceeded with the APRMs reading equal to actual percent CTP. Each APRM channel averages the outputs of selected groups of local power range monitor (LPRM) amplifiers. Half of these channels (A, C, and E) are associated with the Reactor Protection System (RPS) Bus A and the other half (B, D, and F) are associated with RPS Bus B. One APRM channel in each RPS bus may be bypassed at a time.
- Two Loop Operation - The procedure for calibrating the APRM System to CTP consists of adjusting the APRMs to read ± 2% RTP.
- Plant Startup - During plant startup, the APRM AGAFs are not very close to 1.00 because of the significantly different rod pattern from when the last calibration was performed.
- Valid CTP - During reactor startup, a valid CTP (by heat balance) can be obtained when the active feedwater loop(s) flow is ³ 0.9 Mlbm/hr. GARDEL will calculate an inaccurate heat balance if the active loop(s) flow is < 0.9 Mlbm/hr and will be swapped to calculated CTP using the APRMs. This is done for exposure accounting purposes only.
- In the example below, the APRM Data section of the Heat Balance Summary or Periodic Case gives a table that directly calculates the APRM - %CTP. These parameters are determined at slightly different times by GARDEL and are rounded off, so round off differences may exist.
CTP = 99.9% A C E B D F READING 100.4 100.2 98.8 100.3 99.5 99.7 AGAF 0.995 0.997 1.011 0.996 1.003 1.002 APRM - %CTP 0.5 0.3 -1.1 0.4 -0.3 -0.2
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Procedure 10.7, Core Thermal Limits
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- PRECAUTIONS AND LIMITATIONS
- If thermal limits (MAPRAT, MFLCPR, MFLPD) exceed 0.99 or rod line exceeds 118% and equilibrium xenon conditions exists, notify Reactor Engineering.
- OPERATION ABOVE MAPRAT (MAPLHGR) LIMIT
- IF MAPRAT > 1.00, THEN take action per Tech Spec LCO 3.2.1 to reduce MAPRAT to 1.00 or below. Corrective action may consist of:
- Reducing power using recirculation flow and/or control rods. Call Reactor Engineering as soon as possible following power reduction.
- █AC█ Verify corrective action initiated promptly.
- █AC█ Verify MAPRAT returned to £ 1.00 within 2 hours.
- OPERATION ABOVE MFLCPR (MCPR) LIMIT
- IF MFLCPR is > 1.00, THEN take action per Tech Spec LCO 3.2.2 to reduce MFLCPR below limit. Corrective action may consist of:
- Reducing power using control rods. Call Reactor Engineering as soon as possible following power reduction.
- █AC█ Verify corrective action initiated promptly.
- █AC█ Verify MFLCPR returned to £ 1.00 within 2 hours.
- ACCEPTANCE CRITERIA
- MAPRAT, MFLCPR, and MFLPD (MAPLHGR, MCPR, and LHGR)
- [SR 3.2.1.1, SR 3.2.2.1, SR 3.2.3.1] Corrective action was initiated promptly and Core Thermal Limits returned to within limits within 2 hours.
- DISCUSSION
- Specifically, with MAPLHGR less than or equal to its limit (MAPRAT £ 1.00) fuel cladding temperature following the Design Bases Loss of Coolant Accident (LOCA) will remain £ 2200°F.
- At values above these limits the thermal expansion rate of the fuel pellets can exceed that of the zircaloy cladding to the point where there is potential for cladding ruptures. If the MFLPD exceeds the limit (1.00) at any node in the core, power must be reduced in those affected regions. This can be accomplished by decreasing core thermal power with recirculation flow and/or by adjusting the control rod pattern as needed.
- By maintaining MFLCPR £ 1.00, we ensure no fuel pin within a bundle will reach a power level such that the coolant will reach the Onset of Transition Boiling (OTB).
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Procedure 10.13, Control Rod Sequenceand Movement Control
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- PRECAUTIONS AND LIMITATIONS
- The individual scram switches located on the scram time panel shall not be used for control rod insertion unless directed by authorized ITR-RDM procedures.
- Reactor operation within Stability Exclusion Region is prohibited.
- Do not withdraw a control rod without first verifying it is the only control rod selected. A malfunction of the Reactor Manual Control System could cause more than one control rod to be selected.è9
- Whenever plant conditions are stable and control rod movement is not required, deselect ROD SELECT pushbuttons. This will prevent pushbuttons from failing due to thermally induced failure of pushbutton coils.
- If a control rod double-notches during approach to criticality, following steps should be performed:è8
- If double-notch occurs due to fast rod or rod position control problem, contact System Engineer to correct problem.
- Contact Reactor Engineer for guidance on rod position.
- Write Condition Report to trend occurrence.
- If a control rod double-notches past its intended position in either direction, move rod to intended position immediately.
- APPROACH TO CRITICAL
- GENERAL GUIDELINES
- When high xenon conditions exist, extra caution should be taken when withdrawing peripheral control rods. These rods may have higher rod worth than during low or xenon-free startups.
- The first control rods in each Rod Worth Minimizer (RWM) group should be treated with extra caution since they will be the highest worth rods of the rods in that group.
- With reactor power less than the Low Power Setpoint (LPSP) and the Rod Worth Minimizer manually bypassed, control rods shall not be withdrawn outside the restraints of Banked Position Withdrawal Sequence (BPWS). This is required to preclude operation outside the assumptions of the Control Rod Drop Accident (CRDA) analysis.
- Control rod coupling shall be verified and documented each time a control rod is withdrawn to Position 48.
- Criticality should be expected at any time. Notch control is appropriate when SRM period response becomes significant.
- (Checked By) Record initial SRM readings on Attachment 1.è1
- (Checked By) Calculate continuous withdrawal SRM count rate limits (10 times the initial SRM readings) and record on Attachment 1.è1,3
- Proceed with continuous control rod withdrawal using Attachment 4 in the Control Rod Sequence Package until continuous withdrawal limit for any SRM on Attachment 1 is reached.è3
- REACTOR STARTUP FROM CRITICALITY TO LPSP
- GENERAL GUIDELINES
- The first control rods in each RWM group should be treated with extra caution since they will be the highest worth rods of the rods in that group.
- With reactor power less than the LPSP, a control rod which is bypassed shall not be withdrawn outside the restraints of BPWS. This is required to preclude operation outside the assumptions of the CRDA analysis.
- Control rod coupling shall be verified and documented each time a control rod is withdrawn to Position 48.
- INSTRUCTIONS
- Proceed with consecutive step order on Attachment 4 in Control Rod Sequence Package. Continuous rod withdrawal may be used unless otherwise specified by a Reactor Engineer.è3
- The Operator or Concurrent Verifier shall place a check mark in DESIRED ROD SELECTED block for selected rod.è11
- REACTOR STARTUP FROM LPSP TO RWM INTERLOCK
- GENERAL GUIDELINES
- Face adjacent control rod tips should generally not be allowed to pass each other on a control rod withdrawal at power levels above 50% of rated power unless otherwise directed by a Reactor Engineer.
- POWER OPERATION
- GENERAL GUIDELINES
- Face adjacent control rod tips should generally not be allowed to pass each other on a control rod withdrawal at power levels above 50% of rated power unless otherwise directed by a Reactor Engineer.
- Control rod coupling shall be verified and documented each time a control rod is withdrawn to Position 48.
- Operation in asymmetric control rod patterns should be minimized. Contact a Reactor Engineer if a symmetric control rod pattern cannot be maintained.
- If a rod is not at its intended position but is within one notch of intended position in withdrawal direction and reactor is near rated power, move rod to intended position immediately.è14
- If a rod is not at its intended position but is within one notch of its intended position and has not been mispositioned for > 2 hours, move control rod to correct position.
- If a rod is not at its intended position and is greater than one notch from its intended position or has been mispositioned for 2 or more hours, contact Reactor Engineer for movement instructions.
- SHUTDOWN
- GENERAL GUIDELINES
- Face adjacent control rod tips should generally not be allowed to pass each other on a control rod withdrawal at power levels above 50% of rated power unless otherwise directed by a Reactor Engineer.
- EMERGENCY POWER REDUCTION
- Insert rods in the order listed on Attachment 6 from current position to 00 using continuous insert. Do not stop at intermediate positions.
- MISPOSITIONED CONTROL RODè4
- Verify control rod mispositioned as follows:
- A control rod "left" (next control rod to be moved is selected or last control rod to be moved is deselected) at a position other than the intended position per Control Rod Sequence Package; or
- A control rod moved more than one notch beyond its intended position per Control Rod Sequence Package; or
- A control rod moved in wrong direction; or
- Selecting and moving wrong control rod; or
- A drifting control rod; or
- Unexpected single control rod scram.
- If rod can be recovered to intended position in accordance with provisions of Step 6.1, recover rod to intended position.
- If rod cannot be recovered to intended position using provisions of Step 6.1, contact Reactor Engineering for recovery instructions.
- The System Engineering Manager, Operations Manager, and General Manager of Plant Operations shall be notified of mispositioned control rod and recovery actions taken.
- A Condition Report shall be generated.
- DOCUMENTATION
- EMERGENCY POWER REDUCTION
- The rods used for emergency power reduction shall be documented on Attachment 6.
- The rods used should be the control cell rods inserted in reverse order from the target rod pattern.
- Rods that are already at Position 00 should not be included.
- The attachment should contain all the control cell rods used in a given sequence or enough rods to lower reactor power to rod line < 70%.
- DISCUSSION
- A Control Rod Sequence refers to the order in which control rod groups are moved, not the order in which individual control rods are moved within a group or step.
- An asymmetric control rod pattern refers to a control rod pattern that results in an asymmetric power distribution. The power distribution is determined by the placement of shallow control rods (Positions 36 to 48) and to a lesser extent by the position of intermediate control rods (Positions 24 to 34). The power distribution is not significantly affected by the position of deep control rods (Positions 00 to 22). Therefore, deep control rods that are not more than two notches different from the other control rods in that group are considered to be symmetric. Intermediate or shallow control rods within a group shall be at the same notch position in order to be considered symmetric.
- Mispositioned control rods may produce power distributions that can result in fuel failures. Furthermore, recovery of mispositioned control rods may result in large changes in nodal xenon concentration. For these reasons, immediate recovery of mispositioned control rods to their target positions is limited to the first 2 hours following the mispositioning. This time limits the extent of any xenon redistribution transient.
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