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Nuclear General Employee Training N-GET - Exelon Corporation

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Revision 35 December 15, 2008 Revision 35 December 15, 2008 Revision 35 December 15, 2008<br />

<strong>Nuclear</strong><br />

<strong>General</strong> <strong>Employee</strong><br />

<strong>Training</strong><br />

N-<strong>GET</strong><br />

STUDY GUIDE<br />

Rev. 35<br />

Effective December 15, 2008


Table of Contents<br />

Fitness For Duty------------------------------------------------------------------------------------------------------ 3<br />

Station Organization & Administration --------------------------------------------------------------------------- 39<br />

<strong>Nuclear</strong> Power Station Overview ---------------------------------------------------------------------------------- 46<br />

<strong>Nuclear</strong> Security------------------------------------------------------------------------------------------------------ 52<br />

Industrial Safety ------------------------------------------------------------------------------------------------------ 62<br />

Fire Protection -------------------------------------------------------------------------------------------------------- 83<br />

E-Plan------------------------------------------------------------------------------------------------------------------ 89<br />

Quality Programs----------------------------------------------------------------------------------------------------- 94<br />

Radiological Orientation -------------------------------------------------------------------------------------------- 104<br />

Radiation Worker <strong>Training</strong> ----------------------------------------------------------------------------------------- 110<br />

Attachments<br />

A – Material Safety Data Sheet --------------------------------------------------------------------------- 160<br />

B – NRC Form 3 -------------------------------------------------------------------------------------------- 163<br />

C –Industry Events------------------------------------------------------------------------------------------ 166<br />

D – Contamination Pitfalls--------------------------------------------------------------------------------- 173<br />

E – NRC Form 4 -------------------------------------------------------------------------------------------- 176<br />

F – The 10 Basic Radiation Protection Rules ----------------------------------------------------------- 178<br />

Page 2 of 178


Course/Program: <strong>General</strong> <strong>Employee</strong> <strong>Training</strong> Module/LP ID:<br />

Title: ! <strong>Exelon</strong> Fitness For Duty Course Code: N-GFFDP<br />

N-N-GRP1I<br />

N-N-GRP2I<br />

N-N-GRP1R<br />

N-N-GRP2R<br />

Author: G. Kiss Revision/Date: 5 12/2008<br />

Prerequisites: None Revision By: G. Kiss/S. Techau<br />

The trainee shall:<br />

Page 3 of 178<br />

Est. Teach Time:<br />

Objective # Objective Description<br />

1 State the company AA & FFD policy<br />

2 State the methods used to implement the basic AA & FFD requirements for all<br />

individuals who have unescorted access to the protected area (or assigned duties at<br />

the TSC or EOF in support of the Emergency Plan)<br />

3 State the licensee policy regarding violations<br />

4 State the NRC-mandated sanctions with regard to FFD program violations<br />

5 State the individual roles and responsibilities under AA & FFD<br />

6 State the role of the MRO, human resources and the FFD staff in the FFD program<br />

7 State the purpose of the <strong>Employee</strong> Assistance Program and services provided<br />

8 Recognize the personal, public health, and safety hazards associated with the<br />

use/abuse of drugs (including prescription, over-the-counter drugs and dietary<br />

conditions) and alcohol, illness, mental stress and fatigue<br />

9 State the effects of prescription drugs, over-the-counter drugs, dietary conditions<br />

(e.g., food products such as poppy seeds or hemp oil, etc.) illness, mental stress and<br />

fatigue may have on job performance and tests results<br />

10 State individual rights regarding AA & FFD<br />

11 State company policy on addressing & documenting suspect behavior<br />

12 Recognize indicators of or potential precursors to aberrant behavior and that<br />

behavior may change quickly<br />

13 Recognize drugs and know indicators of the illegal use or possession of drugs<br />

including the possibility of intent to sell<br />

14 Describe techniques for recognizing behavior, which may result from using/abusing<br />

drugs and/or alcohol, work performance, social interactions, personal health<br />

15 Describe Behavior Observation Techniques for detecting deterioration, impairment,<br />

" Copyright 2008 by <strong>Exelon</strong> <strong>Nuclear</strong>, All Rights Reserved. Permission for reproduction and use is reserved for <strong>Exelon</strong> <strong>Nuclear</strong>.<br />

(Any other use or reproduction is expressly prohibited without the express permission of <strong>Exelon</strong> <strong>Nuclear</strong>.)


Objective # Objective Description<br />

or changes in individual behavior<br />

16 State individual responsibility and process for handling and reporting behavioral<br />

problems and FFD concerns<br />

17 State the individual’s responsibility and process with regards to referral to EAP<br />

18 State the individuals or the person(s) designated by the licensee or<br />

Contractor/Vendor to receive FFD concerns<br />

19 State the symptoms of worker fatigue and decreased alertness in the workplace<br />

20 State the contributors to worker fatigue<br />

21 State the contributors to circadian variations in alertness<br />

22 State the indications and risk factors for common sleep disorders<br />

23 State shift work strategies for obtaining adequate rest<br />

24 State the effective use of fatigue countermeasures<br />

25 Recognize behaviors adverse to the safe operations and security of the facility,<br />

including an unusual interest in or predisposition towards security and/or<br />

involvement in operations activities outside the normal work activities’ scope<br />

26 State the supervisor’s role and responsibilities under the AA & FFD program<br />

27 State the role of others in maintaining the company AA & FFD program<br />

28 Describe the process for the timely removal of a potentially untrustworthy or<br />

unreliable person from the protected area<br />

References:<br />

Code of Federal Regulations – 10CFR26, 10CFR73.56 and 10CFR73.57<br />

NRC EA-02-261, “Order for Compensatory Measures Related to Access Authorization” dated 01/07/03<br />

NEI 03-01, “<strong>Nuclear</strong> Power Plant Access Authorization Program”<br />

NEI 03-04, “PADS Guidelines for Plant Access <strong>Training</strong>”<br />

SY-AA-102, “<strong>Exelon</strong> <strong>Nuclear</strong> Fitness For Duty Program”<br />

SY-AA-102-201, “Call-Outs for Unscheduled Work”<br />

SY-AA-102-202, “Testing For Cause”<br />

SY-AA-102-203, “Follow-Up Testing”<br />

SY-AA-102-204, “Random Selection and Notification Process”<br />

SY-AA-102-205, “Fitness For Duty Appeal”<br />

SY-AA-102-206, “Reporting Use of Medication”<br />

SY-AA-102-227, “Qualification of Emergency Operations Facility Participants”<br />

SY-AA-103-500, “Access Authorization Program”<br />

SY-AA-103-501, “Access Authorization Categories and Requirements”<br />

SY-AA-103-503, “Psychological Assessments”<br />

SY-AA-103-504, “Review of Background Investigation and Unescorted Access Denial Appeal”<br />

Page 4 of 178


SY-AA-103-509, “Protection of Personal Information”<br />

SY-AA-103-510, “Critical Group Requirements”<br />

SY-AA-103-513, “Behavioral Observation Program”<br />

SY-AA-103-518, “Out-Processing of Personnel (<strong>Employee</strong> and Contractor)”<br />

I. Introduction<br />

A. Overview<br />

1. Upon completion, students should be aware of the trustworthiness and reliability requirements for<br />

unescorted access to the protected area, the importance of being fit for duty, understand the<br />

potential consequences of substance abuse, and work in compliance with the station access<br />

authorization and fitness for duty policies. Students should also be familiar with individual rights<br />

and responsibilities regarding the fitness for duty program.<br />

2. Students should be able to recognize and report aberrant individual behavior that could lead to acts<br />

detrimental to public health and safety. The Behavioral Observation Program is the primary means<br />

for determining continued trustworthiness and reliability of covered individuals.<br />

B. Purpose<br />

1. The purpose of this training is to provide information on the company’s access authorization and<br />

fitness for duty (AA & FFD) policy so that nuclear workers can perform their jobs safely and<br />

competently in an environment free of drugs and alcohol.<br />

C. Objectives<br />

D. Statement of Evaluation<br />

1. Students will be evaluated by answering questions given on the examination with an accuracy of<br />

80% or better.<br />

II. Company AA & FFD policy, methods used to implement, and the<br />

consequences of violation<br />

A. Failure to meet the policy requirements listed below could result in violation of the <strong>Exelon</strong> FFD<br />

program and may result in disciplinary action up to and including termination and denial of unescorted<br />

access.<br />

B. Report to work fit for duty unimpaired by alcohol, drugs, improper diet, mental stress, fatigue, or<br />

illness, and the use of prescription and over the counter medications that could cause impairment.<br />

Notify their supervisor if there are any conditions that may affect their ability to safely and competently<br />

perform their duties.<br />

C. Each individual is responsible for evaluating their own personal fitness-for-duty based on impairment<br />

from fatigue, managing their work hours consistent with the objective of preventing impairment from<br />

fatigue, verifying their work hours are correctly documented regardless of whether they are paid for the<br />

hours worked, making a self-declaration of fatigue when fatigue or reduced mental alertness could<br />

negatively affect their job performance and discussing these concerns with supervision, monitoring and<br />

reporting concerns related to individuals' Fitness-For-Duty (FFD) based on impairment from fatigue<br />

Page 5 of 178


(i.e., Behavior Observation Program) and being aware of the total hours worked in the previous 14 days<br />

and notifying management if work hour limits will be exceeded if asked to work additional hours.<br />

D. Individuals are required to be fit-for-duty by getting sufficient rest to ensure they are not subject to<br />

fatigue. Individuals who make choices that result in less than adequate sleep to remain alert and avoid<br />

fatigue are not meeting their obligations to safely and competently perform assigned duties. Methods<br />

used to manage fatigue include training, behavioral observation, fatigue countermeasures and work<br />

hour limitations.<br />

E. Failure to follow <strong>Exelon</strong>’s fatigue management policy, including failure to complete any treatment a<br />

healthcare professional recommended based on a fitness for duty evaluation, may result in discipline up<br />

to an including termination and denial of unescorted access.<br />

F. Federal law, Part 10CFR26, requires each utility licensee operating a nuclear facility to:<br />

1. Provide reasonable assurance that personnel are trustworthy and reliable as demonstrated<br />

by the avoidance of substance abuse and are neither under the influence of any substance<br />

(legal or illegal) or mentally or physically impaired from any cause which in any way<br />

adversely affects their ability to safely and competently perform their duties.<br />

2. Provide reasonable assurance that the work place is free of the presence and effects of illegal drugs<br />

and alcohol.<br />

3. Provide reasonable measures for the early detection of individuals who are not fit to perform the<br />

duties that require them to be subject to the FFD program.<br />

4. Provide reasonable assurance that the effects of fatigue and degraded alertness on individuals’<br />

abilities to safely and competently perform their duties are managed commensurate with<br />

maintaining public health and safety.<br />

5. 10CFR26 mandates individuals who perform activities under this rule participate in drug and<br />

alcohol testing.<br />

6. An individual is fit for duty when he/she is neither mentally nor physically impaired from any<br />

cause that could adversely affect safe, competent job performance.<br />

7. These impairments may be the result of:<br />

a. Physical illness<br />

b. Mental stress/illness<br />

c. Improper diet<br />

d. Substance abuse<br />

Page 6 of 178


e. Fatigue and contributing factors to decreased mental alertness<br />

1) Fatigue affects everybody;<br />

2) Fatigue affects everything we do, physically and cognitively;<br />

3) Often when we are fatigued, we are quite unaware of how badly we are performing.<br />

G. Federal law, 10CFR73.56 Personnel Access Authorization and 10CFR73.57 Criminal History Checks,<br />

requires each licensee operating a nuclear facility to:<br />

1. Provide high assurance that individuals granted unescorted access are trustworthy and reliable and<br />

do not constitute an unreasonable risk to the health and safety of the public including a potential to<br />

commit radiological sabotage.<br />

H. <strong>Exelon</strong>’s Fitness For Duty policy dictates that <strong>Exelon</strong> employees and contractors alike, abide by the<br />

appropriate policy requirements.<br />

I. The primary elements of the station’s AA and FFD Program are:<br />

1. Background Investigation/Reinvestigation<br />

2. Psychological Assessment/Re-Assessment<br />

3. Criminal History Inquiry<br />

4. Chemical Testing<br />

5. Behavior Observation (including fatigue assessments)<br />

6. Reporting of Arrests<br />

7. <strong>Training</strong><br />

8. <strong>Employee</strong> Assistance Program<br />

J. <strong>Exelon</strong> ensures specimen collection, documentation, and testing is conducted in strict compliance with<br />

the Fitness For Duty Program.<br />

K. Chemical testing provides a means of detecting and deterring substance abuse in the work place.<br />

There are 5 test categories in chemical testing:<br />

1. Pre-access: conducted prior to employment or prior to being granted unescorted access or<br />

assignment to any Emergency Operations Facility (EOF) or Technical Support Center (TSC) in<br />

support of the Emergency Plan.<br />

2. For Cause: conducted as soon as practical in response to an individual’s observed behavior or<br />

physical condition indicating possible substance abuse or after receiving credible information that<br />

an individual is engaging in substance abuse, this includes the detection of the odor of alcohol.<br />

Page 7 of 178


3. Post Event: conducted as soon as practical after an event involving human error that may have<br />

caused or contributed to the event if it resulted in:<br />

1) A significant illness or personal injury;<br />

2) A radiation exposure or release of radioactivity in excess of regulatory limits; or<br />

3) An actual or potential substantial degradation of the level of safety of the plant<br />

4. Follow-up: as part of a follow-up plan conducted at unannounced intervals to verify an<br />

individual’s continued abstinence from substance abuse.<br />

5. Random: conducted on a statistically random and unannounced basis, so that all individuals in the<br />

population subject to testing have an equal probability of being selected and tested.<br />

L. If you refuse to participate in the FFD testing process, unescorted access will be immediately<br />

terminated. A refusal is considered a violation of the FFD program.<br />

M. The collection site is staffed with personnel who will provide individuals with detailed instructions on<br />

how the collection process will be handled. Locations of the Station collection sites are in the <strong>Exelon</strong><br />

East/West Specific Study Guides.<br />

N. If you are selected for a random test, you or your supervisor or point of contact will be notified. If your<br />

supervisor or point of contact is notified, they will notify you of the scheduled test time.<br />

NOTE<br />

When you are selected and scheduled for a random or followup<br />

test, you must respond promptly. You may NOT request<br />

time off once notified of a random or follow-up test.<br />

O. The chemical testing process will include validity testing for the following adulterants (substances<br />

added to mask or alter test results):<br />

1. creatinine<br />

2. ph<br />

3. nitrites<br />

P. The chemical testing process screens for the following substances:<br />

1. alcohol<br />

2. cocaine<br />

3. marijuana<br />

4. opiates<br />

5. phencyclidine<br />

Page 8 of 178


6. amphetamines<br />

Q. Urinalysis will be used for all substances except alcohol. A Breathalyzer will be used to read the blood<br />

alcohol concentration in a person’s breath.<br />

R. A confirmed positive test for alcohol must be declared under any of the following conditions:<br />

1. When the result of the confirmatory test for alcohol is 0.04% blood alcohol concentration (BAC) or<br />

higher.<br />

2. When the result of the confirmatory test for alcohol is 0.03% BAC or higher and the donor had<br />

been in a work status for at least 1 hour at the time the initial test was concluded (including any<br />

breaks for rest, lunch, dental/doctor appointments, etc.).<br />

3. When the result of the confirmatory test for alcohol is 0.02% BAC or higher and the donor had<br />

been in a work status for at least 2 hours at the time the initial test was concluded (including any<br />

breaks for rest, lunch, dental/doctor appointments, etc.).<br />

S. When the result of the confirmatory test for alcohol is equal to or greater than 0.01% BAC but less than<br />

0.02% BAC and the donor has been in a work status for 3 hours or more at the time the initial test was<br />

concluded (including any breaks for rest, lunch, dental/doctor appointments, etc.), the collector shall<br />

declare the test result as negative and inform FFD program management. The donor shall be prohibited<br />

from performing any duties that require the individual to be subject to 10 CFR Part 26 and may not<br />

return until the individual to performing such duties until a determination of fitness indicates that the<br />

donor is fit to safely and competently perform his or her duties.<br />

As explained above. The test is still considered negative, but if they are doing work that falls<br />

into the Federal Regulation, a review will be completed to ensure they are fit for duty<br />

T. Individuals should be aware that prescription and over-the-counter medication could impact chemical<br />

test results. All drugs must be in a properly labeled container.<br />

U. If you violate the AA or FFD policy, you can be terminated, have your unescorted access denied, and<br />

<strong>Exelon</strong> Company employees will be referred to <strong>Exelon</strong>’s EAP.<br />

V. FFD Sanctions<br />

1. The following acts will result in an immediate unfavorable termination of the individual’s<br />

authorization and permanent denial of authorization thereafter.<br />

a. Any act or attempted act to subvert the testing process, including but not limited to:<br />

1) Refusing to provide a specimen;<br />

2) Providing or attempting to provide a substituted or adulterated specimen, for any test;<br />

3) Individuals whose authorization was denied for a minimum of five (5) years, any<br />

subsequent violation of <strong>Exelon</strong>’s FFD policy.<br />

Page 9 of 178


. Any employee or contractor involved in the sale, use or possession of narcotics, drugs or<br />

controlled substances while within the protected area will result in an immediate unfavorable<br />

termination of the individual’s authorization and permanent denial of authorization thereafter.<br />

2. Resignation after notification to provide a specimen for testing or resignation or withdrawal of<br />

authorization of your application prior to removal for a program violation shall be considered a<br />

violation of 10 CFR 26 and result in unfavorable termination and denial of authorization for a<br />

minimum of five (5) years.<br />

3. A first confirmed positive drug test will result in an immediate unfavorable termination of the<br />

individual’s authorization and denial of authorization for a minimum of three (3) years for:<br />

a. <strong>Exelon</strong> Management Personnel;<br />

b. All <strong>Exelon</strong> <strong>Nuclear</strong> Security, LLC employees (Management, bargaining unit and craft<br />

personnel);<br />

4. A first confirmed positive drug test will result in an immediate unfavorable termination of the<br />

individual’s authorization for a minimum of 14 days for:<br />

a. An <strong>Exelon</strong> bargaining unit, or non-union craft employee<br />

5. A first confirmed positive alcohol test will result in an immediate unfavorable termination of the<br />

individual’s authorization for a minimum of 14 days for:<br />

a. All <strong>Exelon</strong> Personnel;<br />

b. All <strong>Exelon</strong> <strong>Nuclear</strong> Security, LLC Management, bargaining unit and craft personnel;<br />

6. A first confirmed positive drug or alcohol test for a contractor will result in immediate unfavorable<br />

termination and denial of unescorted access for a minimum of three (3) years.<br />

7. A second confirmed positive drug or alcohol test will result in an immediate unfavorable<br />

termination of the individual’s authorization and permanent denial of authorization thereafter for:<br />

a. All <strong>Exelon</strong> personnel*;<br />

b. All <strong>Exelon</strong> <strong>Nuclear</strong> Security, LLC employees (Management, bargaining unit and craft<br />

personnel);<br />

c. All Contractor personnel<br />

*For <strong>Exelon</strong> bargaining unit employees, please contact your Human Resources department for how<br />

this may effect your employment and/or sanctions at your site or refer to SY-AA-102, <strong>Exelon</strong><br />

<strong>Nuclear</strong> Fitness for Duty Program.<br />

8. Any individual with a positive drug test, preceded or followed by a refusal to test or a positive<br />

alcohol test or another positive drug test will be permanently denied unescorted access and<br />

ineligible for further unescorted access to <strong>Exelon</strong> <strong>Nuclear</strong> Stations.<br />

9. All individuals will be referred for assessment and counseling during the termination period. The<br />

individual’s fitness to perform work activities must be approved by the MRO and <strong>Exelon</strong><br />

Page 10 of 178


management before reinstatement of unescorted access or the ability to perform the duties that<br />

require them to be subject to the FFD program. Individuals, upon initial return following a FFD<br />

violation, shall provide an observed negative drug and alcohol specimen prior to reinstatement of<br />

unescorted access. Follow-up testing in accordance with the Fitness For Duty Follow Up Testing<br />

procedure is required.<br />

10. Individuals who fail to report an arrest as defined by <strong>Exelon</strong> <strong>Nuclear</strong>, or provide deliberate or<br />

willful misleading statements with the intent to gain access is a violation of Federal Regulations<br />

and will result in denial of unescorted access. Any misrepresentation, deliberate misstatement,<br />

falsification or willful omission may constitute cause for denial or revocation of unescorted access<br />

authorization. Failure to report and list reasons for any previous suspension, revocation or denial of<br />

unescorted access to <strong>Exelon</strong> or other entity subject to either the NRC Access Authorization or<br />

Fitness-For-Duty Regulation may be sufficient cause for denial or revocation of unescorted access<br />

authorization or security clearance. If such an instance is detected, <strong>Exelon</strong> is required to advise the<br />

NRC. The NRC may investigate the applicant and, if appropriate, criminal and civil sanctions may<br />

be imposed against the applicant.<br />

III. Timely removal from the Protected Area<br />

A. Action must be taken to remove access to the protected area when a supervisor becomes aware of any<br />

situation that may question an individual’s behavior or trustworthiness and reliability.<br />

B. Notification to Site Security/Badging must be completed immediately:<br />

1. For individuals who have been identified that their unescorted access status needs to be temporarily<br />

suspended, placed on administrative hold, temporary hold or denial for any reason; and<br />

2. Personnel whose fitness for duty is questionable, shall immediately be removed from work<br />

activities. The individual shall be escorted at all times until the person exits the protected area, or<br />

until the completion of a For Cause test is conducted, if deemed necessary.<br />

C. Personnel in a “For Cause” termination situation, who have Unescorted Access and are being<br />

separated from <strong>Exelon</strong> or their contract company “for-cause” shall:<br />

1. Not be notified of termination until Security is notified. After notification to Security, the<br />

individual shall be out-processed immediately by their Supervisor and shall be escorted/observed<br />

at all times until final departure from the site. The Supervisor shall be responsible for outprocessing<br />

all “for-cause” dismissals of employees and contractors.<br />

2. Security must be notified of any CANCELLATION of Unescorted Access and must be<br />

completed utilizing either the required form or an electronic form, telephone notification, or in<br />

person and in accordance with SY-AA-103-518, Out-Processing (<strong>Employee</strong> and Contractors).<br />

IV. Rights, Roles and Responsibilities of the individual<br />

A. <strong>Exelon</strong>’s Fitness For Duty policy dictates that <strong>Exelon</strong> employees and contractors alike, abide by the<br />

appropriate policy requirements.<br />

B. Each employee is responsible to report to work fit for duty, unimpaired by alcohol, drugs, improper<br />

diet, mental stress, fatigue, or illness, and the use of prescription and over the counter medications that<br />

Page 11 of 178


could cause impairment. Notify the supervisor if there are any conditions that may affect their ability<br />

to safely and competently perform their duties.<br />

C. Anyone under the influence of alcohol, or who possesses or consumes alcohol on the job, has the<br />

potential for interfering with their own as well as their co-workers safe and efficient job performance.<br />

Consistent with existing Company policies; such conditions will be proper cause for administrative<br />

action up to and including denial of access.<br />

D. Abstain from alcohol for at least five (5) hours preceding regularly scheduled work and long enough to<br />

ensure blood alcohol content (BAC) is less than 0.04 percent upon arrival on company property. If<br />

alcohol has been consumed, you shall request a test before entering the protected area. Failure to meet<br />

this requirement could result in violation of the FFD program. (Abstinence from alcohol for the 5<br />

hours preceding any schedule tour of duty is considered a minimum that is necessary, but may not be<br />

sufficient, to ensure that the individual is fit for duty.)<br />

E. You may be called in as needed for unscheduled work. You are responsible for informing<br />

the person calling if you have consumed alcohol within the past five (5) hours or are not fit<br />

for duty due to physical illness, mental stress/illness, improper diet, substance abuse or<br />

fatigue.<br />

F. If you are contacted at home to discuss a work related issue, you are responsible to alert the<br />

caller if you are uncomfortable about responding due to alcohol consumption, or you are not fit for<br />

duty due to physical illness, mental stress/illness, improper diet, substance abuse or fatigue.<br />

G. Seek assistance for any problems that may affect your ability to safely and competently perform your<br />

duties. Notify your supervisor of any problems you may have such as physical illness, mental stress or<br />

illness, improper diet, substance abuse or fatigue.<br />

H. Report the use of legitimate prescription or over-the-counter drugs that could impact their ability or<br />

performance.<br />

I. Keep their supervisor informed of any medication or other substances that could affect job<br />

performance. Do not use or possess someone else’s prescription drugs.<br />

J. Individuals undergoing prescribed medical treatment with a prescription and/or over-the-counter<br />

medication shall report this treatment to their supervisor. The prescribed use of prescription medication<br />

as directed by a physician is naturally not grounds for disciplinary action, although it is important for<br />

the company to know such use is occurring. Refer to SY-AA-102-206 “Reporting Use of Medication”<br />

K. Observe behavior; you are responsible to immediately report any observed unusual behavior, suspected<br />

drug use, the detected odor of alcohol, or any conditions adverse to station safety. Notify your<br />

supervisor, department head, and Security immediately. Failure to involve a supervisor after detecting<br />

the odor of alcohol on an individual is a violation of the FFD Program and will result in denial of<br />

unescorted access. Supervisors must verify if behavior is questionable (including<br />

presence of the odor of alcohol). Escort while within the protected area, until the<br />

concern is resolved. Report to Security immediately when a For-Cause test is required.<br />

L. The illegal use, sale or possession of narcotics, drugs, or controlled substances while on the job on<br />

<strong>Exelon</strong> Company property is a violation of the Drug and Alcohol Policy and/or the Fitness for Duty<br />

Program. Station parking lots are <strong>Exelon</strong> property. Any illegal substances will be turned over to the<br />

appropriate law enforcement agency and may result in criminal prosecution.<br />

Page 12 of 178


M. Anyone arrested or that is involved with illegal off-the-job drug or alcohol activity may be considered<br />

to be in violation of the Company Drug & Alcohol Policy or the Fitness for Duty Program. In deciding<br />

what action to take, management will take into consideration the nature of the charges, the employee’s<br />

present job assignment, the employee’s record with the company and other factors relative to the<br />

impact of the employee arrest upon the conduct of company business.<br />

N. Some of the drugs which are illegal under federal, state, or local laws include, among others,<br />

marijuana, heroin, hashish, cocaine and hallucinogens. Depressants, stimulants, and other controlled<br />

substances not prescribed for current personal treatment by an accredited physician also fall under this<br />

rule.<br />

O. Individuals will be subject to drug and alcohol screening test. Refusal to cooperate or submit to any test<br />

is a violation of the <strong>Exelon</strong> Fitness for Duty Program. A positive test result, indicating that an<br />

individual was present on <strong>Exelon</strong> <strong>Nuclear</strong> Station property while under the influence of drugs or<br />

alcohol, is considered a violation of the Fitness for Duty Program.<br />

P. Report any previous denial of unescorted access, positive chemical test, or involuntary participation in<br />

a substance abuse treatment program.<br />

Q. Cooperate fully with the chemical testing program and ensure individuals who are notified that they<br />

have been selected for random testing must report to the collection facility within the time period<br />

specified.<br />

R. Refusal to cooperate, subverting or attempting to subvert or refusal to provide a specimen will result in<br />

a violation of the FFD program.<br />

S. Individuals providing specimens that have been adulterated or substituted will be permanently denied<br />

unescorted access.<br />

T. Personal information collected for the FFD program will be protected and will not be disclosed except<br />

as required by the appropriate procedure.<br />

U. You also have the right to privacy at the collection site unless:<br />

1. There is reason to believe that you will tamper with, alter, or substitute a specimen.<br />

2. The specimen is being collected in a for-cause situation.<br />

3. It is an initial return to work after a FFD violation<br />

V. If you test positive, you have a right to appeal the test result and request a reanalysis of the original<br />

positive specimen.<br />

W. Any <strong>Exelon</strong>, contract or vendor employee upgraded or promoted to a supervisory position<br />

is obligated to carry out the supervisory responsibilities as defined in the <strong>Exelon</strong><br />

Fitness for Duty Program.<br />

X. All individuals, vehicles, property, equipment, and areas on <strong>Exelon</strong> <strong>Nuclear</strong> Station property are<br />

subject to search. This includes all parking areas. Refusal by an individual to permit a search of their<br />

person, property, vehicle or area is a violation of Company Policy.<br />

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Y. Individual must report any legal action which is defined as a formal action taken by a law enforcement<br />

authority or court of law, including an arrest, an indictment, the filing of charges, a conviction, or the<br />

mandated implementation of a plan for substance abuse treatment in order to avoid a permanent record<br />

of an arrest or conviction, in response to any of the following activities; the use sale or possession of<br />

illegal drugs, the abuse of legal drugs or alcohol, or a refusal to take an drug or alcohol test.<br />

Z. Report to their supervisor and security all arrests, charges pending resolution or detentions by<br />

authorities for any violation of law, other than speeding or parking offenses.<br />

AA. Individuals that are governed by 10CFR26, and 10CFR 73.56 who are charged with any incident such<br />

an arrest, criminal charges, convictions or proceedings where an individual was held detained, taken<br />

into custody, indicted, fined, forfeited bond or cited for a violation of any law, regulation or ordinance.<br />

This includes misdemeanors, felonies, summary offenses, military criminal history to include court<br />

martial or non-judicial punishment, guilty pleas, nolle contendere, any suspended sentences, pre-trial<br />

diversions, dismissals, nolle prosse or first offender cases and traffic tickets (excluding speeding tickets<br />

or parking offenses) are required to report this to their immediate supervisor, or department head and<br />

<strong>Exelon</strong> <strong>Nuclear</strong> Security on their first day back to work following any arrests, criminal charges,<br />

convictions or proceedings. ALL drug and alcohol related arrests must be reported.<br />

nolle contendere: a defendant’s pleading that does not admit guilt but subjects him or her to<br />

punishment as though a guilty plea had been entered, the determination of guilt remaining open in<br />

other proceedings.<br />

nolle prosse: an entry made upon the records of a court when the plaintiff or prosecutor will<br />

proceed no further in a suit.<br />

BB. Individuals must report to a supervisor or security if they notice any FFD concerns including unusual<br />

behavior or suspects substance abuse by any other worker. Prompt action is required since there is a<br />

potential for injuries or reduced plant performance.<br />

CC. If you have any concerns or are in doubt about handling a Fitness For Duty concern, call Station<br />

Security.<br />

DD. You must report a leave of absence, or any situation if you are not in a behavior observation program to<br />

your supervisor, Security and Human Resources prior to leaving. Examples include:<br />

1. Extended vacation for more than 30 days<br />

2. Leave of absence for any reason (Medical/Personal/Military)<br />

3. Working remotely<br />

4. <strong>Training</strong> at other work locations (e.g., Supervisory Development Program)<br />

V. Roles and responsibilities of others such as the Medical Review<br />

Officer (MRO), Human Resources, and FFD staff<br />

A. The Medical Review Officer is a licensed physician whose primary role is to review and interpret<br />

positive, adulterated, substituted, invalid, and diluted test results obtained through <strong>Exelon</strong>’s testing<br />

program and to identify any evidence of subversion of the testing process. The MRO also:<br />

Page 14 of 178


1. Interviews donors with laboratory confirmed positive test results to determine if a positive test<br />

could have resulted from over-the-counter and/or legally prescribed medication or dietary<br />

condition.<br />

2. Authorizes re-analysis of the original specimen by a SAMHSA Certified Laboratory.<br />

3. Evaluates the need for testing of individuals as identified in the Testing For Cause procedure.<br />

4. Identifies any issues associated with collecting and testing specimens, and advises and assists the<br />

FFD program management in planning and overseeing the overall FFD program.<br />

5. Recommends individuals to the EAP.<br />

6. Evaluates documentation provided by EAP and Access Authorization group to recommend to<br />

Security if an individual can be considered trustworthy and reliable for the purpose of granting<br />

and/or maintaining unescorted access authorization.<br />

7. Recommends follow-up testing as a result of a positive drug or alcohol test or for any other concern<br />

to verify continued abstinence from the use of substances.<br />

8. Directs the MRO Staff and their activities while they are performing those functions.<br />

B. The role of the AA & FFD Program Staff is:<br />

1. Oversee the AA & FFD programs and ensuring compliance with Federal Rules and Regulations<br />

2. Responsible for the adjudication of [Reviews information received regarding] potentially<br />

disqualifying information to determine if an individual is trustworthy and reliable<br />

3. Oversees and assures satisfactory quality performance of the FFD testing processes and the<br />

laboratory contracted to conduct specimen testing<br />

4. Maintain confidentiality of the AA & FFD Records<br />

5. Assists in coordinating Appeals to the Appeal Reviewer<br />

C. The role of the Human Resource organization is to:<br />

1. Serve as the confidential communication link between <strong>Exelon</strong> <strong>Nuclear</strong> Security and Company<br />

employees for Access and Fitness For Duty issues.<br />

2. Promptly report any Access and Fitness For Duty concerns or program violations to Station<br />

Security and Station Management.<br />

3. Notify Security when an employee has been terminated “For Cause” so Security can make an<br />

evaluation concerning the individual’s trustworthiness and reliability. This includes situations<br />

when an employee is allowed to resign prior to termination.<br />

D. The Role of the EAP Staff is to:<br />

1. <strong>Employee</strong> Assistance Program (EAP) provides confidential assessment, short-term counseling,<br />

referral services and treatment monitoring for FFD related issues.<br />

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2. EAP is designed to provide early intervention for individuals who may have problems that could<br />

adversely affect their ability to safely perform their duties.<br />

3. Only <strong>Exelon</strong> employees are eligible for the EAP. <strong>Employee</strong>s may request assistance from the EAP<br />

(self-referral) or be referred by their Supervisor, Security, the MRO or the company Medical staff.<br />

Contractors can check with their supervision on the availability of an EAP in their company.<br />

4. If the EAP staff determines that your condition constitutes a hazard to yourself or to others, or you<br />

have been impaired from using drugs or alcohol while in a work status and has a continuing<br />

substance abuse disorder, 10CFR26 requires notification of company management even if you are a<br />

self-referral.<br />

VI. EAP Services available<br />

A. What EAP Services are available?<br />

1. When you call for EAP services, you will receive confidential help in dealing with any of the<br />

following concerns or possibly other problems that may be troubling you.<br />

• Dealing with Change/<br />

Transition<br />

• Stress<br />

• Family Relationship<br />

Concerns<br />

• Depression<br />

• Dual Careers<br />

• Anxiety<br />

• Job Burnout<br />

• Workplace Problems<br />

• Marital / Relationship<br />

• Work / Life Balance<br />

B. Only <strong>Exelon</strong> employees are eligible for the EAP. <strong>Employee</strong>s may request assistance from the EAP<br />

(self-referral) or be referred by their Supervisor, Security, the MRO or the company Medical staff.<br />

Contractors can check with their supervision on the availability of an EAP in their company.<br />

C. For additional information on the company’s EAP, see your Supervisor, Human Resources or the<br />

company Medical staff. To obtain information or get help, contact the EAP staff directly.<br />

VII. Personal, public health and safety hazards associated with the use/abuse<br />

of illegal and legal drugs and alcohol<br />

A. Substance abusers have the following impact on business and the public:<br />

1. Have FOUR times as many accidents.<br />

• Fitness For Duty<br />

• Alcohol / Drug Problems<br />

• Compulsive Gambling<br />

• Aging Parents / Elder Care<br />

• Death / Dying<br />

• Financial Concerns<br />

• Sexual Problems<br />

• Retirement Concerns<br />

• Eating Disorder Problems<br />

• Physical Abuse<br />

2. File FIVE times as many worker compensation claims.<br />

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3. Use THREE times the number of sick benefits.<br />

4. Are absent or tardy TWICE as often.<br />

5. Make TWICE as many mistakes as non-abusers.<br />

6. Cause 50% of all vehicular accident deaths and 500,000<br />

serious injuries in vehicular accidents each year.<br />

VIII. Effects of prescription and over the counter drugs, dietary factors, illness,<br />

mental stress and fatigue on job performance & test results<br />

A. Prescription and Over the Counter Drugs<br />

1. Use of prescription medication or commonly purchased over-the-counter drugs, such as sedatives,<br />

appetite suppressants, analgesics, cold or allergy medicines may have an impact on testing. They<br />

may contain alcohol or codeine. In addition certain available food products such as poppy seeds or<br />

hemp oil, energy drinks containing alcohol, etc. may cause positive test results.<br />

2. Because of the possible effects on job performance and/or test results, you must be aware of your<br />

medications and keep your supervisor informed as part of the Fitness For Duty Program.<br />

3. Over-the-counter or prescribed medication brought on company property must be kept in its<br />

original container, do not mix medications in the same container. The name on the bottle must<br />

match the name of the individual possessing it. Refer to SY-AA-102, “<strong>Exelon</strong>’s Fitness for Duty<br />

Program.”<br />

4. If under medication and there are signs of job impairment and the work function may be<br />

endangered by this use, a Supervisor should temporarily reassign an employee to a suitable work<br />

function.<br />

B. Dietary Factors<br />

1. Marijuana-flavored lollipops have such names as Purple Haze, Acapulco Gold and Rasta. They are<br />

legal because they are made with hemp oil, a common ingredient in some health food, beauty<br />

supplies and other household products. The oil imparts marijuana’s grassy taste but not the high.<br />

Merchants are calling them a harmless novelty for adults. Health food stores are also selling more<br />

and more products made from hemp. Though consuming products containing hemp oil create no<br />

psychoactive effect, they will cause a positive urinalysis test for marijuana. The Medical Review<br />

Officer will not accept hemp product ingestion as an alternative medical explanation for a positive<br />

marijuana test.<br />

2. Coca leaf tea contains cocaine in quantities sufficient to cause a positive test for cocaine, and the<br />

MRO will not accept coca leaf product ingestion as an alternative medical explanation for a<br />

positive cocaine test.<br />

3. Energy drinks containing alcohol are prohibited while on company property. Individuals who<br />

consume these drinks are impaired because of the alcohol in their system. These drinks contain<br />

alcohol in quantities sufficient to cause a positive test for alcohol and the MRO will not accept<br />

energy drink product ingestion as an alternative medical explanation for a positive alcohol test.<br />

Page 17 of 178


4. There is an herb named Kava Kava that is found in health food stores and has been used, like<br />

valerian root, as an over the counter “prescription” for stress relief and can make you appear<br />

impaired.<br />

5. It is an employee’s responsibility to maintain fitness for duty and be aware of the effects of each<br />

drink, food, or drug you ingest. Although a substance, food, or health supplement is reported<br />

“safe” for you and is legal, doesn’t mean it is wise or safe to ingest these items because they can<br />

result in a positive alcohol or drug test. Remember to read labels and ask questions before you<br />

purchase and use a new product.<br />

C. Mental Stress<br />

1. Individuals should be knowledgeable of causes of worker stress in the workplace.<br />

a. Daily stress is normal.<br />

b. Stress is derived from events that occur throughout life e.g., marriage and family life, job<br />

changes, job performance, etc.<br />

c. When daily stress turns into chronic stress the worker is at risk for adverse impact on day-today<br />

living, e.g., behavior changes.<br />

d. Contributors to worker stress may include:<br />

1) increased irritability,<br />

2) feelings of depression,<br />

3) chronic fatigue (fatigue that has set in over several weeks or months),<br />

4) overreacting to any single situation,<br />

5) impulsiveness,<br />

6) excessive use of alcohol or drugs, and<br />

7) constant sense of worry<br />

e. Worker fatigue can also have an adverse effect on job performance. The NRC, in a Rulemaking<br />

Issue document states, in part:<br />

“… studies concerning extended work hour (e.g., more than 12 hours) suggest that in a broad<br />

range of industries fatigue-induced impairment can increase human error probabilities by a<br />

factor of more than 2 to 3 times baseline human error probabilities.” (SECY-01-0113)<br />

IX. Illegal drugs and indications of the illegal use, sale, or possession of<br />

drugs<br />

A. Individuals should be sensitive to any attempt to use, sell or distribute illegal drugs on company<br />

property.<br />

1. There is no typical drug dealer;<br />

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2. Drug dealers come from all parts of society;<br />

3. Drug transfer or sale can take place quickly, involving nothing more than a casual personal<br />

exchange.<br />

B. All workers need to be aware of locations where drugs can be concealed:<br />

1. Clothing – pockets, socks, shoes, underwear, hard-hats and caps;<br />

2. Personal containers – brief cases, purses, lunch boxes;<br />

3. Tobacco packages – cigarette and chewing tobacco packs.<br />

C. Drugs can have a significant impact on job performance. Those individuals using drugs or other<br />

chemicals can have:<br />

1. Impaired judgment and vision<br />

2. Changes in reflexes; and<br />

3. Reduced analytical ability<br />

D. Common drugs that may be used are:<br />

1. Cannabis: Cannabis is a plant that grows wild throughout most tropic and temperate regions or the<br />

world. The plant is brilliant green in color with an odd number of saw-tooth edged leaves. Some<br />

examples of cannabis include: hashish, hashish oil, and marijuana. Some signs of Cannabis use<br />

include:<br />

a. Bloodshot eyes, dilated (wide) pupils<br />

b. Appearance of intoxication or disorientation<br />

c. Euphoria<br />

d. Odor of burnt marijuana or hemp<br />

e. Relaxed inhibitions<br />

2. Stimulant: Stimulates the central nervous system. Used medically for the treatment of narcolepsy,<br />

obesity, and hyperactivity in children. Some examples of stimulants include: caffeine, nicotine,<br />

amphetamines, meth-amphetamine, some over-the-counter diet pills, and cocaine.<br />

a. Some signs of Stimulant use include:<br />

1) Increased alertness or excitation<br />

2) Euphoria<br />

3) Irritability<br />

4) Mood swings<br />

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5) Risk taking due to overconfidence<br />

3. Depressant: Depresses the central nervous system. Used medically for the relief of anxiety,<br />

irritability, tension, and insomnia. Some examples of depressants include: barbiturates, Valium,<br />

Quaaludes, and alcohol.<br />

a. Some signs of Depressant use include:<br />

1) Slurred speech<br />

2) Disorientation<br />

3) Lowered inhibitions<br />

4) Bloodshot-watery eyes<br />

5) Odor on breath (alcohol)<br />

4. Narcotic: Used medically to relieve pain and to treat diarrhea. Some examples include: opium,<br />

heroin, codeine, morphine, and paregoric.<br />

a. Some signs of Narcotic use include:<br />

1) Constricted or narrow pupils of the eyes<br />

2) Droopy eyelids<br />

3) Euphoria<br />

4) Drowsiness<br />

5) Nausea<br />

5. Hallucinogen: Synthetic or natural drugs that distort the perception of objective reality. Use may<br />

lead to delusions and visual hallucinations. Some examples of hallucinogens include: psilocybin,<br />

LSD, phencyclidine (PCP) and mescaline.<br />

a. Some signs of Hallucinogen use include:<br />

1) Blank stare or rapid eye movement<br />

2) Delusions and visual hallucinations<br />

3) Poor coordination or perception of time and distance<br />

4) Flashback or ‘trips’<br />

E. If the sale, use, or possession of drugs is observed in station or on company property, report this<br />

IMMEDIATELY to your supervisor or Security.<br />

Page 20 of 178


X. Roles & Responsibilities of Supervisors and others under the AA & FFD<br />

Program<br />

A. All individuals must be sensitive to the escorted individual’s performance for indications of aberrant<br />

behavior that affect the ability to perform assigned tasks. Specific diagnosis of the cause of impairment<br />

is not required before action is taken to prevent acts that could affect the reliability of the plant.<br />

B. Managers and supervisors are in frequent contact with their personnel and are most familiar with their<br />

normal behavior patterns. Therefore, they are in the best position to detect long term changes in an<br />

individuals’ behavior and to initiate appropriate corrective action.<br />

C. Managers and supervisors have the responsibility for the continued observation of assigned individuals<br />

and initiating action for degraded behavior that could affect the safety and reliability of the plant.<br />

D. Managers and Supervisors are responsible for implementing parts of the FFD and Behavioral<br />

Observation Program. This includes:<br />

1. Observing assigned individuals’ behavior patterns over time. Observing other workers and<br />

reporting any aberrant behavior detected.<br />

2. Documenting behavioral problems is an essential element in long-term observation so the cause of<br />

the change can be addressed.<br />

a. It’s important to record facts as they occur.<br />

b. Accurate records become a tool for taking appropriate action and can be of use in the EAP<br />

problem solving process.<br />

c. Records are essential if disciplinary action becomes warranted.<br />

3. Acting proactively to address behavior problems. A supervisor’s responsibility is to recognize<br />

declining job performance, caused by behavioral problems, in its early stages and to respond<br />

promptly and constructively.<br />

a. Conducting and documenting a supervisory review on a nominal annual basis for each<br />

individual with unescorted access authorization/unescorted access, maintained for 365<br />

consecutive days. Refer to SY-AA-103-513, “Behavioral Observation Program” for specific<br />

information on supervisory reviews.<br />

E. The employee has the right to review their personal file. The employee also has the right to provide<br />

additional comments about the information.<br />

F. Supervisors shall not disclose personal information collected and maintained to individuals who do not<br />

have a need to know under the NRC regulation.<br />

G. The EAP provides assessment, short-term counseling, and treatment monitoring for fitness for duty<br />

related issues.<br />

1. Situations may develop where a supervisor has no choice but to take corrective action with<br />

employees under his or her control.<br />

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2. Ideally, supervisors should encourage employees to seek assistance through the EAP BEFORE<br />

problems occur. This may prevent a major deterioration of performance plus it demonstrates the<br />

supervisor’s commitment to the well being of his or her workers.<br />

H. Supervisory Steps for Corrective Action:<br />

1. Supervisors may have to ‘step in’ and correct a situation via an interview, making a referral to<br />

EAP, or taking action on Fitness For Duty concerns.<br />

I. Interview Techniques:<br />

1. The following are some recommended steps to consider when interviewing an employee about<br />

behavior-related performance problems:<br />

a. Pre-plan the interview session with a review of the employee’s records.<br />

b. Review the company policies and procedures concerning your employee’s job performance.<br />

c. Consult with Human Resources and your manager about job performance problems.<br />

d. Make an appointment to discuss your concerns about job performance with the employee.<br />

e. Anticipate defensiveness during the session. Give specific instances of behavior-related job<br />

performance problems.<br />

f. Try to show genuine empathy rather than sympathy.<br />

g. Make specific suggestions about how to change the employee’s<br />

behavior that affects job performance.<br />

J. EAP Referral:<br />

1. If the employee continues to show signs of behavior changes or problems, contact EAP staff to<br />

make a supervisor referral. The supervisor should continue to document changes in the employee’s<br />

current performance.<br />

2. If behavior continues to deteriorate, contact Security and the Medical Review Officer (MRO).<br />

3. Advise your management of the steps you have taken and the documentation collected. With your<br />

management’s support, determine the next course of action regarding further discipline or<br />

assistance for the employee.<br />

K. Handling of Fitness for Duty Concerns:<br />

1. The following steps are guidelines that can be used if supervisors suspect an employee may not be<br />

fit for duty. If supervisors have specific concerns or questions, they should contact the Security<br />

Department, Human Resources, or the Medical Review Officer (MRO).<br />

2. Supervisors should not diagnose the cause of an employee’s problem, but are responsible for timely<br />

action once a problem is detected or reported.<br />

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3. If the individual’s action endangers himself or herself, or is a danger to other people, or risks the<br />

safety of the site, the supervisor should immediately remove the employee from work activities and<br />

assume escort duties.<br />

4. If safety is not threatened, try to have at least one other person, preferably a member of supervision,<br />

observe the individual’s behavior.<br />

5. An employee may become belligerent when confronted. This may lead to personnel injury or<br />

damage to station components. If you feel that the encounter may lead to physical problems,<br />

request assistance from another management person or Security and escort the employee from the<br />

protected area.<br />

6. Notify Human Resources or Security for <strong>Exelon</strong> employees. Refer to the <strong>Exelon</strong> Site Specific<br />

Study Guide(s) for further information.<br />

7. If the individual refuses to submit to a medical evaluation or displays threatening behavior, the<br />

supervisor should escort the employee from the protected area and direct Security to revoke<br />

unescorted access.<br />

8. The supervisor should instruct the individual that he or she is suspended pending further<br />

investigation.<br />

9. If the sale, use, or possession of illegal drugs or alcohol is suspected; or if drugs, drug<br />

paraphernalia, or alcoholic beverages are found on site, immediately confiscate and control the<br />

contraband and notify Security.<br />

10. Following any incident, prepare a detailed record of all actions. This includes documenting<br />

statements, dates, times, witnesses, and all pertinent facts. Management should be notified of the<br />

incident as soon as possible.<br />

11. A For Cause drug and alcohol test is required when the odor of alcohol has been detected on an<br />

individual and confirmed by a supervisor or management employee. Breath alcohol testing is<br />

required to begin within one (1) hour. Security must be notified and will arrange for the For Cause<br />

drug and alcohol test. Unescorted access will be suspended pending test results.<br />

12. The FFD rules apply equally to everyone regardless of their title or position.<br />

13. Management has the responsibility to deal with FFD concerns in a timely manner.<br />

14. Due to the transient nature of contracted work, contracting and vendor firms may not always have a<br />

full complement of management on site. In the absence of on-site company management,<br />

contractor and vendor supervisors shall notify Security, the <strong>Exelon</strong> cognizant contact or other<br />

<strong>Exelon</strong> management following the occurrence of any Fitness For Duty issues or events.<br />

L. Each employee (contractor or <strong>Exelon</strong>) must rely upon some sign or indications to look for that may<br />

indicate their co-workers, employees, or visitors are exhibiting aberrant behavior. Possible signs of<br />

aberrant behavior:<br />

1. The taking of medications/use of drugs, signs of fatigue, mental stress, or illness observed in<br />

themselves or others<br />

Page 23 of 178


2. Unusual interest in or predisposition towards security or operations activities outside the scope of<br />

their normal work assignments<br />

3. Uncharacteristic absences from work<br />

4. Frequent unexplained absence from work assignments<br />

5. Unusual or inadequate response when confronted about being in a plant or office location outside<br />

of the worker’s usual scope of work<br />

6. Unusual views or opinions that might be directly or indirectly threatening to a nuclear facility<br />

7. An employee in an area outside of his usual scope of activities, who can’t provide an appropriate<br />

explanation<br />

8. Abnormalities such as vandalism and/or tampering; Examples include but are not limited to:<br />

#$ Misaligned breakers or valves,<br />

#$ Cut wires or cables,<br />

#$ Foreign objects in machinery, reservoirs or tanks,<br />

#$ Inappropriate holes drilled, punched or cuts in pipes, tubes or hoses, and<br />

#$ Damage to a component such that its safety or security function is impeded.<br />

M. Aberrant behavior is defined as behavior that varies from or deviates from normal behavior.<br />

N. Most people behave in a consistent manner. Changes in this pattern can occur quickly and may result<br />

from many possible causes, including heath, family and work difficulties. Usually short lived, all of us<br />

experience such changes at one time or another. On occasion the difficulties continue and even<br />

intensify<br />

O. We identify changes in behavior by observing, through what we hear, see, smell and touch, around us.<br />

There are general indicators of degraded behavior that must be watched for:<br />

1. PERSONAL HEALTH BEHAVIOR<br />

a. Are you aware of signs of NERVES or EMOTIONAL UPSET (MENTAL STRESS)?<br />

1) Headaches<br />

2) Startles easily<br />

3) Cries easily<br />

4) Shaky voice<br />

b. Does the worker use ALCOHOL or DRUGS differently?<br />

1) Drinks too much<br />

Page 24 of 178


2) Smells of alcohol<br />

3) Preoccupied with drinking or drugs<br />

4) Gulps drinks, especially first couple<br />

5) Encourages others to use<br />

c. Does the worker show or report signs of FATIGUE?<br />

1) Sleepiness – yawning, tired eyes, legs<br />

2) Decreased energy level<br />

3) Feeling of malaise or lack of motivation, verbalizes or shows no desire and/or lack of<br />

interest in activity<br />

4) Restlessness/fidgeting<br />

5) Lethargic, listless or disinterested in surroundings<br />

6) Poor Pallor (color), bluish/gray around mouth and lips<br />

7) Shortness of breath/dizziness/pain/signs of extreme stress with exertion<br />

8) Increased irritability or anxiety or impatience<br />

d. Are you aware of changes in DAILY LIVING ROUTINE?<br />

1) Sleep difficulties<br />

2) Change in amount/pattern of eating<br />

3) Rigidly follows same pattern without reason<br />

e. Changes in worker’s general APPEARANCE?<br />

1) Appear better/more poorly groomed<br />

2) Walks differently (slower/stumble)<br />

3) Change in posture<br />

f. Have you noticed changes in the worker’s BODY or LIMBS?<br />

1) Shaky hands or twitching<br />

2) Weight loss/gain<br />

3) Nail biting<br />

4) Cold, sweaty hands<br />

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5) Sweating, especially non-seasonal<br />

g. Has the worker had any GASTROINTESTINAL changes (ILLNESS)?<br />

1) Nausea/vomiting<br />

2) Stomachaches<br />

3) Frequent trips to bathroom<br />

4) Excessive use of antacids, coffee/tea or other liquids, aspirin, cigarettes<br />

h. Does the worker have any CARDIOVASCULAR difficulties?<br />

1) Dizziness/fainting<br />

2) Breathing irregularities<br />

i. Have you noticed any changes in worker’s THINKING PATTERN?<br />

1) Hallucinations (see things that aren’t there)<br />

2) Delusions (false beliefs)<br />

3) Bizarre or unusual ideas<br />

2. SOCIAL INTERACTION BEHAVIOR<br />

a. Does the worker appear LESS SOCIABLE?<br />

1) Isolated/withdrawn<br />

2) Smiles and talk to self<br />

3) Refuses social contact<br />

4) Lacks a sense of humor<br />

5) Overly suspicious of others<br />

6) Holds grudges/sulks<br />

b. Has the worker become TOO SOCIABLE?<br />

1) Talks too much with co-workers<br />

2) Plays pranks/jokes<br />

3) Monopolizes conversations<br />

4) Inappropriate sex behavior<br />

5) Flashes money<br />

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c. Are there CHANGES IN the worker’s choice of FRIENDS?<br />

1) Especially for breaks/lunch or transportation<br />

2) Only those younger or easily dominated<br />

3) Has separate set of friends just for drinking or gambling<br />

d. Are there changes in the way OTHER WORKERS REACT to the worker?<br />

1) Ignore or avoid<br />

2) Get angry with<br />

3) Become condescending<br />

4) Complain about<br />

5) Mistrust<br />

e. Does the worker show more ANGER?<br />

1) Impatient<br />

2) Overreacts to real/imagined criticism<br />

3) Irritable/argumentative<br />

4) Physical fights<br />

5) Temper outbursts<br />

f. Does the worker try to MANIPULATE OTHERS?<br />

1) Brags/exaggerates/show off<br />

2) Acts naive or innocent<br />

3) Lies<br />

4) Borrows money<br />

g. Have you noticed changes in the worker SPEECH BEHAVIOR & CONTENT?<br />

1) Talks slower/faster<br />

2) Talks more/less<br />

3) Stammers<br />

4) Jumps from topic to topic<br />

5) Talks about hopeless future<br />

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6) Preoccupied with suicide, disasters, destruction<br />

7) Never chats about family/interests<br />

h. Does the WORKER have more COMPLAINTS about:<br />

1) Physical ailments<br />

2) Back pain/muscle aches<br />

3) Co-workers or superiors<br />

4) Being ignored/left out<br />

5) Family/money problems<br />

6) Lack of privileges<br />

7) Filling out required forms<br />

8) Or, has stopped complaining<br />

3. WORK PERFORMANCE BEHAVIOR<br />

a. Work Performance Behavior<br />

1) Is the worker ABSENT from work more than normal?<br />

2) Unexplained or vague reasons given for the absence?<br />

3) Reports absence due to depression, anxiety or psychological treatment.<br />

b. Has work QUALITY or QUANTITY changed?<br />

1) Greatly changed speed of working<br />

2) Changed level of work involvement<br />

c. Has the worker made more MISTAKES or BAD JUDGMENTS?<br />

1) Has numerous accidents<br />

2) Laughs off errors or reprimands<br />

3) Denies mistakes<br />

4) Unnecessarily condemns self for mistakes<br />

d. Does the worker have more difficulty CONCENTRATING or remaining<br />

ATTENTIVE?<br />

1) Forgets important or obvious things<br />

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2) Acts without thinking<br />

3) Daydreams too much<br />

4) Signs of dozing off<br />

5) Difficulty following procedures<br />

6) Startle response when addressed or with sudden noise<br />

7) Slow or confused verbal or behavioral responding<br />

e. Is the worker ABSENT “ON THE JOB”?<br />

1) Wanders around the plant a lot<br />

2) Takes excessively long breaks and lunches<br />

3) Avoids a part of the plant because of fear<br />

4) Gets sick while at work<br />

f. Does the worker adhere to COMPANY POLICY?<br />

1) Steals or damages property<br />

2) Disregards rules<br />

3) Bends rules<br />

g. Have you noticed the worker becoming OVERCAUTIOUS?<br />

1) Overreacts to normal conditions<br />

2) Freezes or disappears in an emergency<br />

3) Overly concerned about details/accuracy<br />

4) Double-checks work too much<br />

h. Has the worker become OVERZEALOUS?<br />

1) Never takes breaks<br />

2) Comes to work early<br />

3) Hangs around after shift<br />

4) Volunteers for excessive amounts of overtime<br />

i. Does the worker engage in a lot of RISK-TAKING?<br />

1) Drives recklessly<br />

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2) Operates equipment carelessly on or off the job<br />

3) Shows poor judgment in dangerous physical activities<br />

4) Gambles a lot<br />

j. Has the worker’s COOPERATION with CO-WORKERS changes?<br />

1) Refuses to share equipment/information<br />

2) Refuses to take directions<br />

3) Refuses to accept help from others<br />

XI. Reporting behavior problems and FFD concerns and the ability to initiate<br />

appropriate actions, including referral to the EAP and persons designated<br />

by the licensee to receive FFD concerns<br />

A. When a behavioral problem is detected immediate reporting to a supervisor and security is required.<br />

The primary concern is to preclude actions that could be detrimental to the individual, other workers, or<br />

plant safety. Refer to SY-AA-103-513, “Behavioral Observation Program.”<br />

B. Individuals are responsible for reporting to their:<br />

1. supervisor and security, any arrests, criminal charges, convictions or proceedings. Individuals are<br />

required to report this on their first day back to work and/or in-processing activities subsequent to<br />

any arrests, criminal charges, convictions or proceedings.<br />

2. supervisor any observed behavior indicating degradation in performance, impairment or change in<br />

behavior. This may include the taking of medication, signs of fatigue, mental stress, illness, or any<br />

other condition.<br />

3. supervisor when an individual is exhibiting unusual or aberrant behavior that may constitute an<br />

unreasonable risk to the health and safety of the public, including a potential threat to commit<br />

radiological sabotage.<br />

4. supervisor when an individual has an unusual interest in or predisposition towards security or<br />

operations activities outside the scope of ones normal work assignments, or frequent unexplained<br />

absences from work assignments.<br />

XII. Contributors to worker fatigue and its symptoms, circadian variations in<br />

alertness and performance, indications and risk factors for common<br />

disorders, shift work strategies for obtaining adequate rest, and the<br />

effective use of fatigue counter measures<br />

A. Principle Factors that Contribute to Worker Fatigue:<br />

1. Individuals should be knowledgeable of causes and the impact of fatigue in the workplace as well<br />

as methods to counter symptoms. Knowledge of these topics is necessary to ensure that individuals<br />

are able to:<br />

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a. Self-manage fatigue that is caused by shift work and factors other than work hours;<br />

b. Take actions to maintain their alertness at work; and<br />

c. Recognize and seek treatment for sleep disorders that might be creating fatigue or making their<br />

own fatigue more severe.<br />

B. Symptoms of fatigue include:<br />

1. Yawning<br />

2. Red eyes<br />

3. Prolonged/excessive blinking<br />

4. Irritability<br />

5. Sleepiness<br />

6. Difficulty concentrating<br />

7. Apathy<br />

8. Increased reaction time to stimulus<br />

9. Slowing of higher level mental functioning<br />

10. Decreased vigilance<br />

11. Memory problems<br />

12. Increased errors while performing tasks<br />

C. Contributors to Decreased Alertness and Increased Worker Fatigue:<br />

1. Task demands such as:<br />

a. Repetitiveness<br />

b. High cognitive demands (high mental focus)<br />

c. Heightened level of required attention<br />

d. Sedentary (sitting or being inactive)<br />

e. Lack of social interaction<br />

2. Environmental conditions such as:<br />

a. High heat and humidity<br />

b. Poor lighting<br />

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c. Low frequency noise<br />

D. Physical Fatigue is present:<br />

1. When an individual’s diminished physical capability is due to overexertion; or<br />

2. A brief physical work load that is excessive and the resulting fatigue degrades physical task<br />

performance.<br />

E. Circadian variations in alertness and performance is:<br />

1. The normal, inherent, unavoidable, 24-hour rhythms in human<br />

information processing and physical performance<br />

2. Most of these circadian rhythms fluctuate between a high point<br />

late in the day to a low point in the pre-dawn hours and are<br />

mostly exemplified by:<br />

a. Night work; and<br />

b. Shift work<br />

F. Acute Fatigue – can either be physical or mental and builds up normally and unavoidably within one<br />

waking period.<br />

G. Cumulative Fatigue – can either be physical or mental and builds up across major waking periods<br />

when there is inadequate recovery (due to inadequate sleep) between the waking periods.<br />

H. Chronic Fatigue – may set in after several weeks or months of cumulative fatigue. Its symptoms are<br />

similar to those of Chronic Fatigue Syndrome (CFS):<br />

1. The desire to sleep;<br />

2. Apathy (apathy: a lack of interest or concern / a lack of feeling or emotion);<br />

3. Substantial impairment in short-term memory or concentration;<br />

4. Muscle pain;<br />

5. Multi-joint pain without swelling or redness;<br />

6. Headaches of a new type, pattern or severity;<br />

7. Un-refreshing sleep; and<br />

8. Post-exertional malaise lasting more than 24 hours. (Post-exertional malaise: A deep fatigue &<br />

exhaustion)<br />

I. Physiological changes that follow a daily pattern<br />

1. An individual’s ability to perform and remain alert is influenced by physiological changes that<br />

follow a daily pattern.<br />

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2. Humans are hard-wired with a genetically-determined biological need for sleep and with a<br />

circadian pacemaker that programs us to sleep at night and to be awake during the day, on a 24hour<br />

schedule.<br />

3. Sleep is a complex, active physiological state that is vital to human survival.<br />

4. When an individual is deprived of sleep, the response is sleepiness, which is the brain’s signal to<br />

prompt an individual to obtain sleep.<br />

5. When deprived of sleep (acutely or chronically), the human brain can spontaneously, in an<br />

uncontrolled fashion, shift from wakefulness to sleep in order to meet its physiological need for<br />

sleep.<br />

6. Twenty-four hour operations challenge these basic physiological principles.<br />

a. Individuals may be trying to work when the brain is programmed to be asleep, during the<br />

circadian low-point in alertness and performance capacity.<br />

b. Conversely, individuals may be trying to sleep when the brain is programmed to be awake;<br />

leading to sleep loss and poor sleep quality, which further degrades alertness and performance<br />

capacity.<br />

7. Shift work, altered and changing work schedules, crossing time zones, long hours of continuous<br />

wakefulness, and sleep loss can create sleep and circadian disruptions that degrade waking<br />

function.<br />

8. This results in fatigue and sleepiness while driving, monitoring equipment; degraded vigilance and<br />

decision making; and a wide range of other performance effects that can erode the safety margin in<br />

operational settings.<br />

J. Two Common Sleep Disorders:<br />

1. Sleep Apnea - A temporary suspension of breathing occurring repeatedly during sleep that often<br />

affects overweight people or those having an obstruction in the breathing tract, an abnormally small<br />

throat opening, or a neurological disorder.<br />

2. Insomnia - Chronic inability to fall asleep or remain asleep for an adequate length of time.<br />

K. Indications and Risk Factors for Common Sleep Disorders:<br />

1. Extended work and/or Commuting Periods;<br />

2. Split-Shift Work Schedules<br />

3. Sleep/Work Periods Conflicting with Circadian Rhythms;<br />

4. Changing or Rotating Work Schedules;<br />

5. Lack of Rest or Nap Periods;<br />

6. Sleep Disruptions;<br />

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7. Inadequate Exercise Opportunities;<br />

8. Poor Diet; and<br />

9. Environmental Stressors<br />

L. Shift-work strategies for obtaining adequate rest:<br />

1. Minimize sleep loss; it is important not to begin a new work schedule with an existing sleep debt<br />

(normally requires 2 nights of unrestricted sleep);<br />

2. Take naps; minimize to 30 minutes (only allowed during non-paid work time in designated areas<br />

when in a work status);<br />

3. Develop good sleep habits; a regular pre-sleep routine can condition relaxation in preparation for<br />

falling asleep (physical and mental relaxation techniques such as meditation, yoga and progressive<br />

muscle relaxation can be used); and<br />

4. Understand the affects of food, alcohol and exercise; being hungry or eating too much may<br />

interfere with falling asleep as well as the use of nicotine or caffeine; alcohol produces easily<br />

disrupted, lighter sleep and suppresses REM (rapid eye movement); regular exercise may enhance<br />

deep sleep but avoid strenuous exercise within 6 hours of going to bed.<br />

M. Countermeasures that can be used at Home:<br />

1. Adequate Sleep is the best way to prevent or resolve fatigue<br />

a. Create a comfortable sleep environment at home; get a comfortable mattress; adjust heating<br />

and cooling as needed and get in habit of sleeping 8 hours per night;<br />

b. Napping (only allowed during non-paid work time in designated areas) and should be less than<br />

30 minutes. Longer naps produce sleep inertia, which is counterproductive.<br />

c. Anchor sleep is 4 hours of sleep at the same time each day used when a normal 8-hour sleep<br />

cannot be achieved (effect when changing from shift to shift)<br />

2. Being mindful of effects of medications<br />

N. Countermeasures that can be used at Work:<br />

1. Strategic caffeine use to help work through decreased alertness<br />

2. Social interaction and active involvement in conversation<br />

3. Physical activity such as stretching and isometric exercises<br />

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4. Consume well-balanced meals and plan ahead for nutritious snack food (simple carbohydrates can<br />

cause “sugar highs” followed by lows that cause decreased alertness)<br />

Samples of simple stretches – don’t do<br />

anything that would hurt you or<br />

nearby equipment!<br />

O. <strong>Exelon</strong> Procedure LS-AA-119, Fatigue Management and Work Hour Limits describes <strong>Exelon</strong>'s<br />

program for preventing and dealing with conditions of worker fatigue. It implements requirements for<br />

managing fatigue and controlling work hours in accordance with 10 CFR 26, Subpart I, "Managing<br />

Fatigue." The requirements of this procedure are intended to provide reasonable assurance that worker<br />

fatigue will be avoided and that all individuals will be able to safely perform their duties and maintain<br />

the health and safety of the public.<br />

1. Specifically, it implements the following:<br />

a. Work hour limits for individuals performing work subject to 10 CFR 26.205, "Work hours,"<br />

b. The process for managing fatigue,<br />

c. The process used to schedule, track, and calculate work hours,<br />

d. The conditions and process used to authorize a waiver of work hour limits, and<br />

e. The training, records, reporting, and review requirements.<br />

2. The fatigue management component of the procedure applies to ALL individuals with unescorted<br />

access to a nuclear Power Reactor site.<br />

a. Key aspects of the procedure include:<br />

1) The ability of an individual to declare fatigue under the requirements of 10CFR26, at which<br />

time the individual will be removed fro m covered duties and be formally assessed for<br />

fatigue.<br />

2) The requirement for individuals to undergo a formal, documented fatigue assessment under<br />

the following conditions:<br />

a) A declaration of fatigue<br />

b) In response to an observed condition of impaired alertness creating a reasonable<br />

suspicion the individual is NOT fit for duty<br />

c) In response to an event requiring post-event drug and alcohol testing<br />

d) To follow-up after a “for cause” assessment or before a worker returns to work after<br />

self-declaration and a break of less than 10 hrs<br />

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3. The work hour limits component of the procedure applies to individuals who operate of work on<br />

equipment that is analyzed as risk significant. Key aspects to this component include:<br />

XIII. Summary<br />

a. Defined maximum working hours<br />

b. Required minimum breaks<br />

c. Required minimum days off<br />

d. Formal process for waiving any of the work hour/break/days off limits<br />

e. A formal process for reviewing working hours actually worked by covered workers for<br />

compliance with the rules.<br />

A. You are expected to be fit for duty by being neither mentally no physically impaired from any cause<br />

that could adversely affect safe, competent job performance.<br />

B. Impairments may be the results of physical illness, mental stress/illness, improper diet, substance<br />

abuse, or fatigue.<br />

C. Workers shall abstain from consuming alcohol for at least five hours before scheduled work and long<br />

enough to ensure blood alcohol content (BAC) is less than 0.04 percent upon arrival on company<br />

property.<br />

D. Keep your supervisor informed of any medication or other substances that could affect job<br />

performance.<br />

E. Do not use or possess someone else’s prescription drugs.<br />

F. Report all arrests, charges pending resolution or detentions by authorities for any violation of law, other<br />

than minor traffic violations.<br />

G. The primary parts of the Company AA & FFD Program are background investigation/reinvestigation,<br />

psychological assessment/reassessment, criminal history inquiry, chemical testing, behavior<br />

observation, reporting of arrests, training, and employee assistance program.<br />

H. Over-the-counter or prescribed medication brought on company property must be kept in its original<br />

container, do not mix medications in the same container. The name on the bottle must match the name<br />

of the individual possessing it.<br />

I. Substance abusers negatively impact both business and the public.<br />

J. Do not sell, use or possess illegal substances on or off company property.<br />

K. Report to a supervisor or security if you notice unusual behavior or suspect substance abuse by another<br />

worker.<br />

L. For Cause chemical testing may be conducted as soon as practical after a behavioral issue is<br />

determined such as possible substance abuse or odor of alcohol; or, after an event involving human<br />

error that may have caused or contributed to the event.<br />

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M. Random chemical testing is conducted at various unannounced times during the day, night, weekends,<br />

and holidays.<br />

N. The chemical testing process screens for the following substances: alcohol, marijuana, cocaine, opiates,<br />

phencyclidine, and amphetamines. Urinalysis will be used for all substances except alcohol. The<br />

company limit is 0.04% blood alcohol concentration (BAC).<br />

O. Use of prescription medication or commonly purchased over-the-counter drugs, such as sedatives,<br />

appetite suppressants, analgesics and cold medicines may have an impact on testing.<br />

P. If you violate the FFD policy, you can be terminated, have your unescorted access denied, and<br />

company employees will be referred to EAP.<br />

Q. Personnel whose fitness for duty is questionable shall be immediately removed from work activities<br />

and escorted at all times. Security is to be notified.<br />

R. The Medical Review Officer is responsible for:<br />

1. reviewing all positive test results and recommending individuals to the EAP.<br />

2. evaluates documentation provided by EAP and Access Authorization group to recommend if an<br />

individual can be considered trustworthy and reliable for the purpose of granting and/or<br />

maintaining unescorted access authorization.<br />

3. recommends follow-up testing as a result of a positive drug or alcohol test or for any other concern<br />

to verify continued abstinence from the use of substances.<br />

S. The FFD Staff oversees the Fitness For Duty Program and ensures compliance with various<br />

regulations.<br />

T. The Human Resource organization serves as the confidential communication link between <strong>Exelon</strong><br />

<strong>Nuclear</strong> Security and Company employees for Access and Fitness For Duty issues.<br />

U. <strong>Employee</strong> Assistance Program provides assessment, short-term counseling, and treatment monitoring<br />

for FFD related issues for <strong>Exelon</strong> employees.<br />

V. For additional information on the company’s EAP, see your supervisor. To obtain information or get<br />

help, contact the EAP staff directly.<br />

W. Individuals should be knowledgeable of causes of worker stress in the workplace.<br />

X. Individuals have many rights, roles and responsibilities under the Fitness For Duty Program.<br />

Y. Managers and supervisors have the responsibility for the continued observation of assigned individuals<br />

and initiating action for degraded behavior that could affect the safety and reliability of the plant.<br />

Z. Narcotics are used medically to relieve pain and to treat diarrhea.<br />

AA. Individuals under the influence of stimulants may experience increased alertness or excitation.<br />

BB. Alcohol is an example of a depressant.<br />

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CC. Cocaine is an example of a stimulant.<br />

DD. Drug sales may take as little time as it takes to shake hands.<br />

EE. Behavior which varies from normal behavior is termed aberrant.<br />

FF. Possible signs of aberrant behavior include unusual interest in or predisposition towards security or<br />

operations activities outside the scope of their normal work assignments; uncharacteristic absences<br />

from work; and unusual views or opinions that might be directly or indirectly threatening to a nuclear<br />

facility.<br />

GG. When a behavioral problem is detected, immediate reporting to a supervisor and security is required.<br />

HH. Supervisors should document any changes in employee behavior-related job performance.<br />

II. Supervisors must conduct and document a supervisory review on an annual basis for each individual<br />

with unescorted access authorization/unescorted access, maintained for 365 consecutive days.<br />

JJ. Fatigue is influenced by task demands and environmental conditions.<br />

KK. Circadian variations in alertness and performance is the normal, inherent, unavoidable, 24-hour<br />

rhythms in human information processing and physical performance.<br />

LL. Acute fatigue can either be physical or mental and builds up normally and unavoidably within one<br />

waking period.<br />

MM. Cumulative fatigue can either be physical or mental and builds up across major waking periods when<br />

there is inadequate recovery (due to inadequate sleep) between waking periods.<br />

NN. Chronic fatigue may set in after several weeks or months of cumulative fatigue.<br />

OO. Shift-work strategies for obtaining adequate rest are naps, good sleeping habits, improve sleeping<br />

environment, and understanding the effects of food and exercise.<br />

PP. Fitness For Duty related questions should be referred to your supervisor, the Medical Review Officer<br />

(MRO), Human Resources, or EAP.<br />

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Course/Program: <strong>General</strong> <strong>Employee</strong> <strong>Training</strong> Module/LP ID: Station Org. &<br />

Administration<br />

Title:<br />

! <strong>Exelon</strong> Station Organization and<br />

Administration<br />

Page 39 of 178<br />

Course Code:<br />

N-N-GRP1I<br />

N-N-GRP1R<br />

N-N-GRP2I<br />

N-N-GRP2R<br />

Author: S. Morse Revision/Date: 3, 07/07<br />

Prerequisites: None Revision By: C. Knox<br />

Est. Teach Time: 30 minutes<br />

From memory and in accordance with this lesson material, the trainee shall be able to:<br />

Objective # Objective Description<br />

1. State the function of the following station departments:<br />

a. Operations<br />

b. Maintenance<br />

c. Radiation Protection<br />

d. <strong>Training</strong><br />

e. Security<br />

f. <strong>Nuclear</strong> Oversight<br />

g. Emergency Preparedness/Emergency Planning<br />

h. Occupational Safety and Health/Safety Committee/Industrial Safety<br />

2.<br />

3.<br />

4.<br />

5.<br />

State individual responsibilities regarding the following policies:<br />

a. operating station equipment<br />

b. working on station equipment without authorization<br />

c. reporting problems for resolution<br />

d. complying with radiation protection and security rules<br />

e. smoking on company property<br />

f. reading materials that are not related to the design, operation, or<br />

maintenance of the station.<br />

State the company policy regarding procedure compliance and use of controlled<br />

documents.<br />

State individual responsibilities regarding station cleanliness and housekeeping.<br />

Identify steps involved with self-checking and conditions that require self-checking.<br />

References:<br />

NEI 03-04, “PADS Guidelines for Plant Access <strong>Training</strong>”<br />

" Copyright 2000 by <strong>Exelon</strong> <strong>Nuclear</strong>, All Rights Reserved. Permission for reproduction and use is reserved for <strong>Exelon</strong> <strong>Nuclear</strong>.<br />

(Any other use or reproduction is expressly prohibited without the express permission of <strong>Exelon</strong> <strong>Nuclear</strong>.)


I. Introduction<br />

A. Overview<br />

1. <strong>Exelon</strong> is committed to assuring the supply of electricity to its customers. To do this, nuclear<br />

generating stations have been established.<br />

2. <strong>Nuclear</strong> generating stations use uranium fuel pellets to produce the steam for generating electricity.<br />

3. Highlighted portions of this lesson plan are <strong>Exelon</strong> specific material not covered in NEI 03-04.<br />

B. Purpose<br />

1. The purpose of this training is to provide station organization and administrative information to<br />

prepare the worker to work in a safe environment.<br />

C. Objectives<br />

D. Statement of Evaluation<br />

1. Students will be evaluated by answering questions given on the examination with an accuracy of<br />

80% or better.<br />

II. Functions<br />

A. Operations<br />

1. The operations department operates the station by performing activities such as:<br />

B. Maintenance<br />

a. Operating station equipment<br />

b. Placing protective tags<br />

c. Approving most types of station work<br />

d. Controlling reactor power<br />

1. The maintenance department keeps the station in good operating condition. It performs activities<br />

such as:<br />

a. Repairing station equipment such as:<br />

1) instruments<br />

2) pumps<br />

3) valves<br />

4) security equipment<br />

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5) motors<br />

b. Performing preventive maintenance on equipment.<br />

C. Radiological Protection<br />

1. The radiation protection department assists workers in minimizing personnel radiological exposure<br />

and the spread of radioactive contamination. It performs activities such as:<br />

D. <strong>Training</strong><br />

a. Monitoring various areas of the station for radiation levels.<br />

b. Controlling access and work in radiation, airborne contamination, and contaminated areas.<br />

c. Preparing Radiation Work Permits.<br />

d. Controlling access to and from the Radiologically Controlled Area (RCA).<br />

1. The training department assists with training and supports the line organization in qualifying<br />

personnel to perform the tasks necessary in their job. <strong>Training</strong> performs activities such as:<br />

E. Security<br />

a. Working with the station departments in setting up training programs for station personnel.<br />

b. Presenting training courses.<br />

c. Maintaining training and qualification records.<br />

1. The security department protects the station from nuclear sabotage. Security performs activities<br />

such as:<br />

a. Controlling access to and from the protected area.<br />

b. Controlling the issue of all badges for site access.<br />

c. Controlling security doors within the station.<br />

F. <strong>Nuclear</strong> Oversight<br />

1. This department spot checks the quality level in the station to ensure it meets certain standards and<br />

codes. It performs activities such as:<br />

a. Monitoring station activities to ensure they are done correctly.<br />

b. Performing program reviews to confirm they are being done according to station procedures.<br />

c. Inspecting safety-related parts and supplies to verify they meet all requirements.<br />

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G. Emergency Preparedness/Emergency Planning<br />

1. This department ensures adequate plans and trained personnel are available to protect the health<br />

and safety of the general population in case of a station emergency.<br />

H. Occupational Safety and Health/Safety Committee/Industrial Safety<br />

1. The function of this department is to provide oversight of the industrial safety program. It performs<br />

activities such as:<br />

a. Checking air quality.<br />

b. Evaluating industrial accidents.<br />

c. Evaluating heat stress concerns.<br />

III. Individual Responsibilities<br />

A. Each individual must comply with company policies such as:<br />

1. Operating station equipment only when qualified, and authorized by the control<br />

room, and specifically by procedure.<br />

2. Getting all work on station equipment authorized prior to starting.<br />

3. Issue Reports, part of the CAP (Corrective Actions Program) are used to report, document and<br />

evaluate problems at the sites.<br />

4. Comply with all Radiation Protection and Security rules established by those groups, whether the<br />

rules are written or verbal (includes postings and signs).<br />

5. Use of all tobacco products is permitted in specifically designated areas only.<br />

6. Only authorized material shall be read during work periods. For the policy on reading personal or<br />

non-technical material, consult your supervisor.<br />

7. Understanding possible consequences of vandalism, tampering or sabotage under Section 2284,<br />

Title 42 USC which makes it illegal to destroy or knowingly cause physical damage to a<br />

commercial nuclear power plant licensed by the NRC. It is also illegal to tamper with or make<br />

unauthorized use of plant equipment in order to intentionally cause an interruption of normal plant<br />

operations. Persons who do so, or who conspire or attempt to do, shall be fined not more than<br />

$10,000 or imprisoned for not more than 20 years, or they may be imprisoned for life if a death<br />

results.<br />

8. Understanding that acts of casual tampering or malicious damage to “send a message” will not be<br />

tolerated within a <strong>Nuclear</strong> Power Plant and can lead to serious consequences for those involved.<br />

Regardless of the motive for such actions, these types of events can result in criminal prosecution,<br />

loss of access to all <strong>Nuclear</strong> Power Plants, and possible imprisonment. Workers need to be aware of<br />

this potential and if any suspicious activity is observed report the activity to security immediately.<br />

Page 42 of 178


IV. Procedure Compliance<br />

A. All work in the station is to be performed in accordance with an approved work document. Approved<br />

documents include procedures, maintenance work packages, station modification packages, radiation<br />

work permits, and others. If a task cannot be performed in accordance with the approved document:<br />

1. Stop the work.<br />

2. Place the job in a safe condition.<br />

3. Contact your supervisor.<br />

4. Resolve the problem.<br />

B. Individuals are responsible for:<br />

1. Verifying only the latest approved revision of the document (procedure, drawing, manual, etc.) is<br />

being used to perform the work.<br />

2. Reviewing the document prior to performing the task.<br />

3. Verifying all necessary tools and parts are available.<br />

V. Housekeeping<br />

A. Each individual is expected to keep his/her own workspace as neat as possible and to clean up after<br />

completing a job in the station. The goal should be to leave an area cleaner than it was found. If a<br />

housekeeping problem is discovered that cannot be resolved, contact your supervisor.<br />

VI. Self-Checking<br />

A. Self-checking is a mental process that is used anytime a task is about to be performed<br />

that could have adverse consequences if done incorrectly. Self-checking ensures the<br />

correct action is being taken on the correct component.<br />

Page 43 of 178


B. The steps involved with this process are as follows:<br />

top Stop - Plan and Prepare<br />

hink Think about what you are supposed to<br />

be performing.<br />

ct Perform the Action<br />

eview Verify the response was correct for the<br />

action taken.<br />

C. Some examples of where self-checking should be used are:<br />

1. Manipulating a valve or component<br />

2. Connecting test equipment<br />

3. Opening panel doors<br />

4. Entering Radiologically Controlled Areas (RCAs).<br />

VII. Summary<br />

A. The operations department operates the station by performing activities such as:<br />

1. Operating station equipment.<br />

2. Placing protective tags.<br />

3. Approving most types of station work.<br />

4. Controlling reactor power.<br />

B. The maintenance department keeps the Station in good operating condition.<br />

C. The Radiation Protection Department assists workers in minimizing personnel radiological exposure<br />

and the spread of radioactive contamination.<br />

D. The training department assists with training and supports the line organization in qualifying personnel<br />

to perform the tasks necessary in their job.<br />

E. The security department protects the station from nuclear sabotage.<br />

Page 44 of 178


F. To ensure quality standards are being met, the following are performed by <strong>Nuclear</strong> Oversight:<br />

1. Monitoring station activities to ensure they are done correctly.<br />

2. Performing program reviews to confirm they are being done according to station procedures.<br />

3. Inspecting safety-related parts and supplies to verify they meet all requirements.<br />

G. Safety activities involve the following:<br />

1. Checking air quality.<br />

2. Evaluating industrial accidents.<br />

3. Evaluating heat stress concerns.<br />

H. Each individual must comply with company policies.<br />

I. All work in the station is to be performed in accordance with an approved work document.<br />

J. Each individual is expected to keep his/her own workspace as neat as possible and to clean up after<br />

completing a job in the station.<br />

K. Self-checking is a mental process that is used anytime a task is about to be performed that could have<br />

adverse consequences if done incorrectly.<br />

Page 45 of 178


Course/Program: <strong>General</strong> <strong>Employee</strong> <strong>Training</strong> Module/LP ID: <strong>Nuclear</strong> Power Station<br />

Overview<br />

Title: ! <strong>Exelon</strong> <strong>Nuclear</strong> Power Station Overview Course Code: N-GRP1I N-GRP2R<br />

N-GRP2I N-GRP2R<br />

Author: Silvia Morse Revision/Date: 3, 07/05<br />

Prerequisites: None Revision By: G. Kiss<br />

The trainee shall be able to:<br />

OBJECTIVES<br />

Page 46 of 178<br />

Est. Teach Time: 30 minutes<br />

Objective # Objective Description<br />

1 Given a drawing of the site, identify locations of major station buildings, including:<br />

#$ Turbine building<br />

#$ Reactor building or Auxiliary<br />

#$ Security access points<br />

#$ Radiologically Controlled Areas<br />

#$ Emergency assembly areas<br />

#$ Drug screening reporting site<br />

2 Describe the basic process used to produce electricity at a nuclear facility.<br />

3<br />

Identify the appropriate communication system to be used for:<br />

#$ Reporting emergencies<br />

#$ Locating an individual in the station<br />

#$ Lengthy discussions<br />

References:<br />

NEI 03-04, “PADS Guidelines for Plant Access <strong>Training</strong>”<br />

I. Introduction<br />

A. Overview<br />

1. A nuclear generation station contains numerous buildings and areas that house the equipment and<br />

personnel necessary to operate the station.<br />

2. Upon completion of this section, you should be able to identify major station buildings and how the<br />

station works.<br />

" Copyright 2000 by <strong>Exelon</strong> <strong>Nuclear</strong>, All Rights Reserved. Permission for reproduction and use is reserved for <strong>Exelon</strong> <strong>Nuclear</strong>.<br />

(Any other use or reproduction is expressly prohibited without the express permission of <strong>Exelon</strong> <strong>Nuclear</strong>.)


3. Highlighted portions of this lesson plan are <strong>Exelon</strong> specific material not covered in NEI 03-04.<br />

B. Purpose<br />

1. The purpose of this training is to provide information on the layout of major station buildings and<br />

how the station works.<br />

C. Objectives<br />

D. Statement of Evaluation<br />

1. Students will be evaluated by answering questions given on the examination with an accuracy of<br />

80% or better. Testing is not required on the first objective.<br />

II. Site Layout<br />

A. A nuclear generating station contains numerous buildings and areas that house equipment and personnel<br />

necessary to operate the station. Some of these buildings and areas are:<br />

1. The Turbine Building<br />

This building houses the main turbine, the generator, and support equipment such as the main<br />

condenser and condensate pumps.<br />

2. The Reactor Building or Auxiliary Building.<br />

Dependent on the type of nuclear reactor (Pressurized Water or Boiling Water) these buildings may<br />

house the nuclear reactor, isolation valves, reactor instrumentation, and safety related equipment.<br />

a. Secondary Containment<br />

The primary purpose of secondary containment is to confine the leakage of airborne radioactive<br />

materials from the primary containment.<br />

In Boiling Water Reactors (BWRs) the reactor building completely encloses the reactor and its<br />

primary containment. The structure is “double” containment during operation, when the primary<br />

containment is closed and in service. It becomes the “single” or “primary” containment in<br />

outages when the primary containment is open.<br />

In Pressurized Water Reactors (PWRs), the containment building completely encloses the<br />

reactor. This structure has airlock doors as described below that are interlocked to prevent both<br />

doors from being open at the same time (during reactor operation.).<br />

In addition, the Auxiliary Building contains all the radioactive and contaminated support<br />

systems.<br />

b. Secondary Containment Access Doors – used in BWRs<br />

The secondary containment access doors are operated like normal doors, except that in order to<br />

open a door, all associated interlocked (or airlock) doors must be closed. The secondary<br />

containment doors are electrically interlocked. When entering or exiting the secondary<br />

containment, personnel need to insure that only one door in the set is open. Warning lights<br />

Page 47 of 178


located by the door indicate the status of the other door. When the light is on, the other door is<br />

open and the door being accessed cannot be opened. Unless directed otherwise, do not attempt<br />

to push or pull doors closed. If the air lock is engaged, this can cause damage to the door.<br />

NOTE: Oyster Creek has windows in the doors. They do not use lights.<br />

c. Secondary Containment Negative Pressure<br />

Under normal and accident conditions, the secondary containment is maintained at a slightly<br />

negative pressure. This minimizes radioactive releases during normal operations and optimizes<br />

dispersal during accident conditions.<br />

The Auxiliary Building at PWRs is maintained at a slightly negative pressure as described<br />

above.<br />

3. Security Access Points<br />

Security Access Points are the only places where you may enter the protected areas of the site. You<br />

must pass through security and comply with proper security requirements at all times. The most<br />

common security access points are located in the security guard house known as the Main Access<br />

Facility (MAF).<br />

4. Radiologically Controlled Areas<br />

The Radiologically Controlled Area (RCA) is the part of the plant that contains radiological areas<br />

and is restricted to those personnel who have completed the Radiation Worker <strong>Training</strong> level of<br />

N<strong>GET</strong>.<br />

5. Drug Screening Reporting Site<br />

All personnel requiring unescorted access to a <strong>Nuclear</strong> facility or certain specified emergency<br />

reporting centers must participate in the Fitness for Duty program. This program requires Pre-<br />

Access, For Cause, and Random Fitness for Duty testing.<br />

*Site maps are located in <strong>Exelon</strong> Site Specific Study Guide(s).<br />

III. Electrical Generating Process<br />

A. Basic Operation<br />

1. The basic operation of the power station involves the<br />

conversion of nuclear energy into electricity. To understand<br />

this process, you need to look at how nuclear energy is<br />

converted to thermal energy, thermal energy to mechanical<br />

energy, mechanical energy to electrical energy.<br />

2. <strong>Nuclear</strong> energy is energy released from the fission process.<br />

Fission occurs when a neutron strikes the nucleus of a uranium<br />

atom. The atom will usually split into two smaller atoms and<br />

release additional neutrons, which continue the chain reaction.<br />

Page 48 of 178


3. When a uranium atom fissions or splits, energy is released in the form of heat and radiation which<br />

heats water to produce steam. The steam causes the main turbine, and the generator attached, to spin<br />

(mechanical energy) producing the electricity the company supplies to customers.<br />

B. Reactor Designs<br />

1. Boiling Water Reactor (BWR)<br />

a. In a Boiling Water Reactor (BWR), the operator uses<br />

control rods which contain boron to interrupt the fission<br />

process.<br />

b. The amount of water flowing through the reactor core<br />

can also be changed to control this fission process.<br />

c. A BWR uses a single loop system in which the water actually boils in the reactor core. The<br />

resulting steam is piped directly to the turbine through main steam pipes. The steam is<br />

radioactive because it actually touches the reactor core.<br />

d. The steam turns the turbine rotors which powers the generator and the generator produces<br />

electricity.<br />

e. The steam is then cooled in a condenser and returned to the reactor core to begin the cycle again.<br />

2. Pressurized Water Reactor (PWR)<br />

a. A Pressurized Water Reactor (PWR) controls the<br />

fission process by using control rods and by<br />

controlling the amount of soluble boron in the primary<br />

water.<br />

b. The water which circulates through the reactor core is<br />

called primary water. It is kept at a high pressure to prevent it from boiling.<br />

c. The heat is transferred through tubes in a steam generator which contains secondary water where<br />

steam is created.<br />

d. Water in the reactor and water in the steam generator that is turned into steam never mix. The<br />

steam is NOT radioactive because it does not directly touch the reactor core.<br />

e. The steam is piped through the turbine where it is condensed and filtered and returned to the heat<br />

exchanger to repeat the cycle.<br />

IV. Communication Systems<br />

A. As with any large industrial complex, there are several types of communication systems.<br />

B. Station emergencies shall be reported to the Control Room.<br />

C. The Public Address (PA) system is for official business only. The PA system provides the capability to<br />

locate individuals and make important announcements from a limited number of locations in the station.<br />

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D. Some stations may use the in-station radio or cellular system as a communication system.<br />

E. The telephone system is provided for lengthy business discussions between employees.<br />

F. Refer to the <strong>Exelon</strong> Site Specific Study Guide(s) for information regarding communication systems.<br />

V. SUMMARY<br />

A. Some of the buildings and areas contained in a nuclear generating station are:<br />

1. The Turbine Building<br />

2. The Reactor Building / Auxiliary Building<br />

a. Secondary Containment<br />

3. Security Access Points<br />

4. Radiologically Controlled Areas<br />

5. Drug Screening Reporting Site<br />

B. <strong>Nuclear</strong> energy is released from the fission process.<br />

C. The Boiling Water Reactor and the Pressurized Water Reactor are two types of nuclear power station<br />

reactors.<br />

D. Examples of communication systems are the Public Address system, in-station radio system and the<br />

telephone system.<br />

Page 50 of 178


<strong>Exelon</strong> West<br />

Braidwood Byron Clinton<br />

Dresden LaSalle Quad Cities<br />

<strong>Exelon</strong> East<br />

Limerick Oyster Creek Peach Bottom<br />

Three Mile Island<br />

Page 51 of 178


Course/Program: <strong>General</strong> <strong>Employee</strong> <strong>Training</strong> Module/LP ID: <strong>Nuclear</strong> Security<br />

Title: ! <strong>Exelon</strong> <strong>Nuclear</strong> Security Course Code: N-N-GRP1I<br />

N-N-GRP2I<br />

N-N-GRP1R<br />

N-N-GRP2R<br />

Author: S. Morse Revision/Date: 6 – 08/08<br />

Prerequisites: None Revision By: C. Knox/J. Hayward<br />

OBJECTIVES<br />

Page 52 of 178<br />

Est. Teach Time: 1 hour<br />

From memory and in accordance with this lesson material, the trainee shall be able to:<br />

Objective # Objective Description<br />

1. State the basic purpose of the Security program.<br />

2. Identify areas of the station that are controlled by Security including the ownercontrolled<br />

area, protected area, and vital areas.<br />

3. Recognize the types and purpose of each type of photo identification badge used at<br />

the station and where it will be worn, and actions taken if lost or found.<br />

4. Identify materials/items that are prohibited and when searches are performed.<br />

5. Describe procedure for entering and exiting the station (protected area and vital<br />

doors).<br />

6. State the policies involved with escorting visitors.<br />

7. Identify possible Security violations and their consequences.<br />

8. State the Security roles and responsibilities for both the Security Guard Force and for<br />

all station workers.<br />

9. Identify and discuss the usage of Safeguards information.<br />

" Copyright 2008 by <strong>Exelon</strong> <strong>Nuclear</strong>, All Rights Reserved. Permission for reproduction and use is reserved for <strong>Exelon</strong> <strong>Nuclear</strong>.<br />

(Any other use or reproduction is expressly prohibited without the express permission of <strong>Exelon</strong> <strong>Nuclear</strong>.)


References:<br />

NEI 03-04, PADS Guidelines for Plant Access <strong>Training</strong><br />

SY-AA-101-130, Security Responsibilities for Station Personnel<br />

SY-AA-101-113, Escorting Personnel and Vehicles<br />

SY-AA-101-106, Control and Classification of Safeguards Information<br />

<strong>Exelon</strong> Security Procedures (SY series)<br />

I. Introduction<br />

A. Overview<br />

1. <strong>Exelon</strong> is committed to ensuring that the health and safety of the public and workers are protected<br />

against acts of radiological sabotage.<br />

2. Upon completion of this section, you should be able to comply with station security program<br />

requirements.<br />

3. Highlighted portions of this lesson plan are <strong>Exelon</strong> specific material not covered in NEI 03-04.<br />

B. Purpose<br />

1. The purpose of this training is to provide information on station security program requirements so<br />

that the health and safety of the worker and public are protected against radiological sabotage.<br />

C. Objectives<br />

D. Statement of Evaluation<br />

1. Students will be evaluated by answering questions given on the examination with an accuracy of<br />

80% or better.<br />

II. PURPOSE<br />

A. The purpose of the security program is to assure the protection of the health and safety of the public.<br />

This is accomplished by:<br />

1. Protection against radiological sabotage.<br />

2. Protection of station personnel.<br />

3. Protection of company assets.<br />

Page 53 of 178


III. THE BASIC SECURITY AREAS<br />

A. The basic security areas are the:<br />

1. OWNER CONTROLLED AREA<br />

a. This is the property associated with the station owned by the company. Access is normally<br />

limited to persons entering for official business.<br />

b. Individuals, property, and vehicles within the owner controlled area are subject to search at<br />

anytime.<br />

2. PROTECTED AREA<br />

a. An enclosed area into which access is controlled. Access requires a badge issued by Security.<br />

3. The VITAL AREA<br />

a. An area that contains equipment essential to the safe operation of the station.<br />

b. Access to a vital area is allowed only if an individual has been authorized access.<br />

c. Entry and exit is controlled by keycard readers.<br />

B. Any activity that will breach the integrity (boundary) of the protected or a vital area must be approved<br />

by Security in advance of performing the work. If an opening in a security boundary (doors, fences,<br />

equipment hatches, penetration of floor, ceiling or wall) is discovered, notify Security immediately.<br />

IV. SECURITY BADGES<br />

A. The station uses security badges for access and identification purposes.<br />

B. A security badge is an electronic key to various areas of the station.<br />

C. You will be responsible for the control and custody of your security badge at all times.<br />

D. Display your security badge on the upper front portion of your body, above the waist and below the<br />

neck, outside of the outermost garment so that the badge is clearly visible at all times.<br />

1. Do not apply/affix stickers or labels of any type to the security badge.<br />

2. In situations where the security badge may be easily lost, contaminated, or become a safety hazard,<br />

use alternate methods of control:<br />

a. When performing activities associated with any of the following situations (including, but not<br />

limited to): contaminated areas, foreign material exclusion (FME), confined spaces, rotating<br />

equipment, exposed electrical currents, or fire brigade duties (one of the following badge<br />

control methods is acceptable):<br />

1) Place the security badge under outermost clothing on a badge neck strap or attached to<br />

personal clothing.<br />

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2) Place the security badge inside the pocket of protective clothing and close the flap.<br />

b. If challenged, then present the security badge to verify authorized access to the area.<br />

c. If the area is posted, then a member of the security organization may be designated to collect<br />

and control security badges during high traffic periods.<br />

d. Showering (one of the following badge control methods is acceptable):<br />

1) Place the security badge on a strap around your neck.<br />

2) Secure (lock) the security badge in a locker while showering.<br />

E. If you lose your security badge, IMMEDIATELY notify Security and wait for Security Officer to<br />

arrive.<br />

F. If you find a security badge, IMMEDIATELY notify Security. Inform the security staff of your<br />

location, and wait for them to arrive.<br />

G. If you notice someone without their security badge, notify the individual and Security. Escort the<br />

individual until Security arrives.<br />

H. Examples of security badges are:<br />

1. A badge that allows unescorted access to the station.<br />

2. A visitor badge.<br />

a. The visitor badge does not require any background investigation or training.<br />

b. Anyone wearing a visitor badge must be escorted by an authorized individual while inside the<br />

Protected Area.<br />

I. For site specific information on security badges, refer to the <strong>Exelon</strong> Site Specific Study Guide(s).<br />

V. PROHIBITED ITEMS AND SEARCHES<br />

A. Contraband is defined as unauthorized items and materials whose normal and customary usage presents<br />

a reasonable likelihood that it will be used to cause significant physical damage or interrupt normal<br />

plant operations. Examples include:<br />

1. Explosives<br />

2. Firearms<br />

3. Incendiary devices<br />

4. Reasonable facsimiles of firearms<br />

Page 55 of 178


B. Examples of items that are prohibited include:<br />

1. Alcoholic, low-alcoholic beverages, and their empty containers<br />

2. Illegal drugs or drug paraphernalia<br />

3. Ammunition<br />

4. Incapacitating agents, such as mace<br />

5. Component parts of weapons<br />

6. Unauthorized bows and arrows<br />

C. Contraband and prohibited materials may NEVER be brought into the OWNER CONTROLLED<br />

AREA.<br />

1. Possession of any of these items on <strong>Exelon</strong> property is grounds for dismissal.<br />

D. Three methods are used to assist in the detection of prohibited items and to help accomplish personnel<br />

searches:<br />

1. Explosive detectors<br />

2. Firearms detectors<br />

a. It is recommended that you do not bring metal items through the firearms<br />

detector (e.g. shoes with metal components, large amounts of keys and coins, cell phones, foil<br />

items such as gum wrappers, pagers, lottery cards, electronic automobile key fobs, cigarettes,<br />

etc.) Containers for these items have been provided at the x-ray machines.<br />

3. Personal searches<br />

a. Anyone alarming the Explosive or Firearms Detectors will be searched by the security force in<br />

accordance with station procedures.<br />

E. Airport style x-ray machine is used to search all hand-carried items passing through the main access<br />

facility.<br />

1. All items passing through the x-ray must be sealed to prevent spilling.<br />

Example items not allowed: open pop cans, travel mugs, cups with or<br />

without lids, etc.<br />

2. It may be necessary to open some items to determine the contents.<br />

3. Individuals with laptop computers are required to remove the laptop from the bag and place it on<br />

the X-ray belt.<br />

4. To facilitate the search process, all hand-carried items containing bottles or cans should be opened<br />

when passing through the x-ray.<br />

Page 56 of 178


5. If it becomes necessary to hand search an item, the security guard will maintain control of the item<br />

until the search is complete.<br />

F. All employees, property, and vehicles on <strong>Exelon</strong> property are subject to search at any time. The<br />

following rules apply:<br />

1. All searches are by implied or expressed consent. Signs are posted at the entrance explaining<br />

Company policy.<br />

2. Any employee who refuses to be searched will not be allowed access to the Protected Area and<br />

shall be directed to leave company property.<br />

3. Random searches may be conducted at any time.<br />

VI. Entering and Exiting Station (Protected Area and Vital Doors)<br />

A. Protected / Vital Areas<br />

1. Personnel requiring unescorted entry to protected / vital areas must possess a security badge and be<br />

properly authorized for that area.<br />

2. If you are not certain if you have authorization for unescorted entry into a protected / vital area,<br />

check with Security before attempting to enter.<br />

3. Visitors entering a protected / vital area must be escorted by an authorized individual.<br />

4. Vital doors are easily recognized since entry/exit is controlled by Security doors equipped with<br />

keycard readers.<br />

a. Access is controlled by means of your Security status level.<br />

b. If a door cannot be secured, notify Security and remain at the door until Security arrives.<br />

c. If it is necessary for a Security door to remain open for a period longer than the time it takes to<br />

pass through the door, contact Security first.<br />

5. Card Reader Use is referenced in SY-AA-101-130, ”Security Responsibilities for Station<br />

Personnel.”<br />

a. Use your security keycard prior to using any door or turnstile equipped with a card reader.<br />

b. Ensure a green light is received on the card reader before proceeding.<br />

c. If a red light is received, contact Security or REMAIN at the door until Security responds.<br />

d. If no light, a flashing red light, or a continuous yellow light, is received then RETRY your card<br />

and CONTACT Security if this condition still exists.<br />

e. Notify Security if your hand geometry has changed such that you are unable to obtain a match<br />

on the Hand Geometry Biometrics System. The Hand Geometry Biometrics System “reads” an<br />

individual’s hand geometry to ensure that the security badge keycard is being used by the<br />

assigned person. EXAMPLES: New jewelry, broken finger, large bandages, etc.<br />

Page 57 of 178


VII. ESCORTING VISITORS<br />

A. If you are escorting a visitor, be sure you observe the following requirements.<br />

1. Ensure the visitor is properly displaying the visitor badge.<br />

2. Maintain control of the visitor at all times. Exceptions are bathrooms with only one ingress/egress<br />

point. The ingress/egress point must be continuously observed.<br />

3. Visitors are not allowed to enter a Radiologically Controlled Area unless authorized. Authorization<br />

is obtained by RP.<br />

4. Ensure the visitor follows all applicable policies and procedures.<br />

5. Enter the protected area prior to the visitor and remain in a security area until the visitor has left the<br />

protected area.<br />

B. Visitors are escorted at all times when within the protected area.<br />

1. However, at times escort responsibilities may be transferred to another badged individual.<br />

2. Ensure the receiving person acknowledges that escort responsibilities have been transferred.<br />

C. If you encounter a visitor without an escort, assume escort responsibilities, and contact Security<br />

IMMEDIATELY.<br />

D. A single escort may control up to 10 visitors in the Protected Area and up to 5 visitors in the Vital<br />

Area. Exceptions are listed in SY-AA-101-113, “Escorting Personnel and Vehicles.”<br />

VIII. SECURITY VIOLATIONS<br />

A. Immediately report any observed or identified security violations (including your own) to the Security<br />

Department.<br />

B. "Tailgating" is when more than one individual attempts to pass through a security door or turnstile<br />

using only one security key card.<br />

1. Tailgating is a security violation.<br />

2. All persons passing through a security door must log into the card reader using their own key card.<br />

C. Other possible security violations include:<br />

1. Attempts to bypass or defeat the ingress search equipment.<br />

2. Holding a vital door open too long.<br />

a. If the door is to be held open for a period of time, contact Security first.<br />

Page 58 of 178


3. Improper closing of doors.<br />

a. Always ensure the door closes completely after passing through, particularly if there is a<br />

pressure difference on the two sides of the door. Challenge the door by pushing or pulling, but<br />

do not turn door knob.<br />

4. Unauthorized or multiple attempts to enter a security area will cause a Security alarm to sound.<br />

a. If access is not granted on the first attempt, call Security personnel and follow their<br />

instructions.<br />

5. Using the card reader to enter, then failing to exit properly.<br />

6. Keys left in an unattended vehicle.<br />

7. Failure to comply with Security requirements may result in the denial of unescorted access and<br />

possible disciplinary action up to, and including, termination of employment.<br />

8. Photographs and video taping of sensitive areas/equipment/documentation (e.g., security cameras,<br />

fencing, officer posts, defensive positions, security procedures, etc.) without the approval of Site<br />

Security Manager or designee.<br />

IX. ROLES AND RESPONSIBILITIES<br />

A. Security personnel have the major responsibility for security at the station.<br />

1. Security guards perform routine patrols and control access of personnel and<br />

vehicles to the protected area.<br />

2. They monitor security computer console activities and respond to security alarms.<br />

B. All station personnel must comply with all security requirements and watch for apparent security<br />

violations or deficiencies.<br />

1. Any observed or known security violation or deficiency must be reported immediately to Security.<br />

2. It is NOT your responsibility to physically restrain security violators.<br />

3. Security must grant permission to bring any vehicle into the Protected Area.<br />

4. If leaving a vehicle unattended in the Protected Area, the authorized operator shall keep the keys<br />

in their possession.<br />

5. Contact Security immediately if it is not possible to remove the ignition key.<br />

6. An unattended vehicle with the ignition key in the vehicle is a serious security violation.<br />

Page 59 of 178


X. SAFEGUARDS INFORMATION<br />

A. Safeguards Information – Information not otherwise classified as National Security Information or<br />

Restricted Data which specifically identifies a licensee’ s or applicant’s detailed, (1) security measures<br />

for the physical protection of special nuclear material, or (2) security measures for the physical<br />

protection and location of certain plant equipment vital to the safety of production or utilization<br />

facilities.<br />

1. Safeguards information is protected on a 'need to know' criterion based on<br />

10CFR73.<br />

2. Safeguards information is clearly marked as such at the top and bottom of<br />

each page and may also have a cover sheet designating the item as<br />

“SAFEGUARDS INFORMATION.”<br />

B. When in use Safeguards Information must be under the direct control of an<br />

authorized individual.<br />

C. While unattended and not in use, Safeguards Information SHALL be stored in an approved locked<br />

security storage container.<br />

1. Desks or toolboxes are NOT adequate.<br />

D. If you find Safeguards Information unattended, take control of it and contact Security<br />

IMMEDIATELY. Do NOT read the information.<br />

E. For further information on Safeguards Information, REFER to SY-AA-101-106, Control and<br />

Classification of Safeguards Information.<br />

XI. SUMMARY<br />

A. he purpose of the Security Program is to protect company assets, protect against radiological sabotage,<br />

and to protect station personnel.<br />

B. The basic security areas are the Owner Controlled Area, Protected Area, and the Vital Area.<br />

C. Photographs and video taping of sensitive areas/ equipment/ documentation (e.g., security cameras,<br />

fencing, officer posts, defensive positions, security procedures, etc.) is not allowed without the<br />

approval of Site Security Manager or designee.<br />

D. Unescorted access to a nuclear power station requires all individuals to obtain security clearance.<br />

E. Security personnel have the major responsibility for security at the station.<br />

F. Display your security badge on the upper front portion of your body, above the waist and below the<br />

neck, outside of the outermost garment so that the badge is clearly visible at all times.<br />

G. Do not apply/affix stickers or labels of any type to the security badge.<br />

H. In situations where the security badge may be easily lost, contaminated, or become a safety hazard, use<br />

alternate methods of control.<br />

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I. Alcohol, firearms, weapons, and explosives are just some of the contraband and prohibited items not<br />

allowed on company property.<br />

J. Signs are posted at the station explaining that employees are subject to search at any time.<br />

K. Use your security keycard prior to using any door or turnstile equipped with a card reader.<br />

L. All visitors must be escorted at all times when within the protected area.<br />

M. Report all security violations to Security.<br />

N. All station personnel must comply with all security requirements.<br />

O. Safeguards Information – Information not otherwise classified as National Security Information or<br />

Restricted Data which specifically identifies a licensee’ s or applicant’s detailed, (1) security measures<br />

for the physical protection of special nuclear material, or (2) security measures for the physical<br />

protection and location of certain plant equipment vital to the safety of production or utilization<br />

facilities.<br />

P. Safeguards Information shall be stored in an approved locked security storage container.<br />

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Course/Program: <strong>General</strong> <strong>Employee</strong> <strong>Training</strong> Module/LP ID: Industrial Safety<br />

Title: ! <strong>Exelon</strong> Industrial Safety Course Code: N-GRP1I N-GRP2I<br />

N-GRP1R N-GRP2R<br />

Author: S. Morse Revision/Date: 7 08/08<br />

Prerequisites: None Revision By: C. Knox<br />

OBJECTIVES<br />

Page 62 of 178<br />

Est. Teach Time: 1 Hour<br />

From memory and in accordance with this lesson material, the trainee shall be able to:<br />

Objective # Objective Description<br />

1. Recall your industrial safety responsibilities regarding:<br />

#$ Reporting of unsafe working conditions<br />

#$ Reporting of industrial safety near-misses<br />

#$ Reporting of work-related injuries/accidents<br />

#$ Administration of first aid (if qualified)<br />

#$ Adherence to safety instructions (procedures and permits)<br />

#$ Observation of safety postings, barriers, tags, and signs<br />

#$ Use of personal protective equipment<br />

#$ <strong>General</strong> use of safety equipment such as eyewash stations, first aid kits, and<br />

safety showers<br />

2. Recognize and discuss methods for reducing risk involved with the following<br />

potential health/industrial hazards:<br />

#$ Use of asbestos on some Station components<br />

#$ Lead<br />

#$ Electrical equipment<br />

#$ Steam leaks<br />

#$ Confined spaces<br />

#$ Trip and fall hazards<br />

#$ Heat stress<br />

#$ Compressed gases<br />

#$ Moving/rotating equipment<br />

High noise areas<br />

#$ Falling objects<br />

#$ Eye hazards<br />

#$ Hazardous chemicals, hazardous waste, universal waste, and other regulated<br />

waste, including where information may be obtained explaining risks, hazards,<br />

and handling associated with a chemical or toxic substance.<br />

! " Copyright 2000 by <strong>Exelon</strong> <strong>Nuclear</strong>, All Rights Reserved. Permission for reproduction and use is reserved for <strong>Exelon</strong> <strong>Nuclear</strong>.<br />

(Any other use or reproduction is expressly prohibited without the express permission of <strong>Exelon</strong> <strong>Nuclear</strong>.)


Objective # Objective Description<br />

3. Recall plant policy regarding the use of the following personal protective equipment<br />

and state how it will be worn.<br />

#$ Hard hats<br />

#$ Safety glasses<br />

#$ Hearing protection<br />

#$ Protective footwear<br />

#$ Hand protection<br />

References:<br />

NEI 03-04, “PADS Guidelines for Plant Access <strong>Training</strong>”<br />

29CFR1910.1200<br />

National Fire Protection Association Code/Standard 704<br />

<strong>Exelon</strong> Safety procedures (SA series)<br />

EN-MA-501, “Controlled Materials and Hazard Communication Program”<br />

EN-MW-501, “Chemical Control”<br />

HU-AA-101, “Human Performance Tools and Verification Practices”<br />

I. Introduction<br />

A. Overview<br />

1. <strong>Exelon</strong> is committed to ensuring personnel safety and expects you to follow all the station’s safety<br />

rules. There are many safety rules in the Station and all of them are intended to assist in making<br />

the Station a safe place to work. Many of these safety rules are covered in this training.<br />

2. Upon completion of this section, you should be able to comply with basic station industrial safety<br />

policies, including identifying and reporting workplace hazards.<br />

3. Highlighted portions of this lesson plan are <strong>Exelon</strong> specific material not covered in NEI 03-04.<br />

B. Purpose<br />

1. The purpose of this training is to provide information on how to remain safe while working in a<br />

nuclear power Station.<br />

C. Objectives<br />

D. Statement of Evaluation<br />

1. Students will be evaluated by answering questions given on the examination with an accuracy of<br />

80% or better.<br />

II. Individual Industrial Safety Responsibilities<br />

A. Industrial safety is comprised of many elements. The most important of these is the individual. Station<br />

management expects each individual to take responsibility for his/her own safety and to help keep<br />

others safe.<br />

1. Never bypass safeguards<br />

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2. Always use a questioning attitude<br />

3. Correct unsafe acts or behaviors<br />

4. Report all injuries<br />

#$ Immediately or as soon as possible, report all events, Industrial Safety Near Miss incidents, and<br />

injuries to their supervisor, regardless of severity.<br />

#$ Immediately or as soon as possible, report all incidents and injuries to Occupational Health<br />

Services, regardless of severity.<br />

5. Promptly report unsafe conditions<br />

6. Perform a 2 Minute Drill @ the Job Site<br />

a. “2 Minute Drill @ the Job Site” is a human performance tool used to ensure employees focus<br />

on the critical aspects of a job and that job site conditions reflect those that are expected or<br />

were discussed during the pre-job brief and that the workers are re-focused on the critical<br />

aspects of the job immediately prior to beginning the task or re-commencing a task after a<br />

break. The 2 Minute Drill @ the Job Site supplements, but does not supersede, pre-job briefs<br />

or other human performance tools applicable to the task.<br />

!" What hazards are in the area?<br />

!" How could I get hurt?<br />

!" Do we have the proper PPE?<br />

!" Are our planned dose reduction techniques appropriate? (Every Millirem Counts)<br />

!" Do we have the necessary FME tools?<br />

!" Are we on the correct Unit/Train/Component?<br />

!" Are the appropriate safety barriers in place/available?<br />

!" Have all positionable components been identified within the 2 Foot Zone?<br />

!" Are the appropriate robust operational barriers / flagging in place/available?<br />

!" What else could go wrong?<br />

!" Do we need to or have we changed our plan?<br />

b. If the review determines that conditions are not what you expected and/or a plan change is<br />

needed, then contact your Supervisor and resolve the situation prior to proceeding with the<br />

task.<br />

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7. Apply 2 Foot Zone Rule<br />

a. Maintain a distance of 2 feet from positionable components in the plant to prevent inadvertent<br />

bumping and mispositioning of components. Entry within this zone is permissible following an<br />

appropriate pre-job brief or completed 2-minute drill at the job site. Exceptions are noted in the<br />

governing document.<br />

Any questions regarding Station policy should be directed to the individual’s supervisor. The<br />

following policies are designed to assist in personnel safety.<br />

B. Reporting Problems<br />

1. You are responsible for recognizing unsafe working conditions in the Station. If you should<br />

discover an unsafe working condition, correct it if you can, or report it to your supervisor. If<br />

necessary, your supervisor will give you the proper form to get the problem resolved. A few<br />

examples of problems that should be reported are a:<br />

a. Missing safety sign<br />

b. Trip or fall hazard<br />

c. Frayed electrical cord<br />

d. Missing guardrail or handrail<br />

2. If you are ever involved in a “near-miss” accident (that is, you almost have an injury), report it to<br />

your supervisor so it can be evaluated and actions taken to prevent recurrence.<br />

3. Personnel Injuries<br />

a. You and your supervisor are expected to work together to prevent injuries and to strive for a<br />

safe work environment free of hazards. However, you must be prepared for the possibility of<br />

an on-the-job injury. If there is a serious injury, your response time must be as short as<br />

possible.<br />

b. If you ever discover someone who is seriously ill or injured, you should immediately:<br />

1) Call the number for reporting serious injuries/illness and inform them of the nature of the<br />

first aid emergency. Be certain to clearly state the victim’s location.<br />

2) Render any immediate lifesaving aid that you are qualified to perform.<br />

3) Do not move an injured person unless under direction of trained personnel.<br />

4) When the medical team arrives, offer assistance and then stay clear of the area.<br />

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C. Adherence to Safety Instructions (procedures and permits)<br />

1. Safety is the responsibility of everyone. It involves the following:<br />

a. Using good housekeeping habits.<br />

b. Keeping tools and other work items off floors and out of aisle ways.<br />

c. Adhering to safety instructions, procedures, and permits.<br />

d. Adhering to requirements for using personal protective equipment.<br />

2. Any violation of <strong>Exelon</strong>’s safety instructions is considered a major violation of company policy<br />

and is subject to disciplinary action up to and including termination. The individual’s supervisor<br />

may also be subject to disciplinary action.<br />

3. Station management expects all employees to use all applicable permits for a required task. This<br />

includes welding, propping a fire door open, or entering a confined space. Always get the<br />

necessary permit and authorization before starting the job. Contact your supervisor for assistance.<br />

D. Observation of Safety Postings, Barriers, Tags and Signs<br />

1. Signs and postings warn workers of hazards such as protected equipment, energized equipment,<br />

confined spaces, flammable materials, and others.<br />

2. All personnel are expected by management to read and obey industrial safety postings.<br />

3. Safety Tags<br />

a. Tags are another way of protecting you from potential danger, communicating special<br />

requirements, tracking discrepancies, or providing other types of information.<br />

b. Only qualified personnel may remove tags and operate components or systems.<br />

c. Never hang, remove, or clear a safety tag unless it is done with the permission of the Control<br />

Room. If a safety tag is found that is not attached to a component, or is attached to the wrong<br />

component, notify the Control Room immediately. This could be a life-threatening situation.<br />

d. Authorization must always be obtained from the Control Room before starting work on<br />

equipment or components having a safety tag attached to them.<br />

e. “Equipment Status” Tags (ESTs)<br />

1) ESTs are used to identify temporary, abnormal equipment status<br />

not governed by another approved status control mechanism to<br />

ensure restoration to normal configuration. When working in the<br />

Station, take care to read and obey any “Equipment Status” tags<br />

you may find in an area before starting work.<br />

2) Equipment Status Tags are NOT used for:<br />

a) equipment or personnel protection.<br />

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) to identify a problem that requires a Work Request.<br />

c) to provide operational instruction in lieu of an approved procedure.<br />

3) Do not confuse Equipment Status Tags as Do Not Operate or Danger tags. The Equipment<br />

Status tags are used by the Operations Department for configuration control. They do NOT<br />

provide for personal safety.<br />

f. Clearance Process Tags (Danger, Special Condition, Information, and WTO Tracking List Tag)<br />

1) <strong>Exelon</strong> <strong>Nuclear</strong> uses a Tagout process (Clearance) instead of a Lockout process as allowed<br />

by the Code of Federal Regulations 29CFR1910.269.<br />

2) Worker personal protection and control are provided by requiring personnel to attend the<br />

pre-job brief, sign onto a Clearance (either electronically or a Worker Tracking List) before<br />

beginning work, and sign off the Clearance (either electronically or using a Worker<br />

Tracking List) when completing work. Workers are expected to sign off the Clearance each<br />

day prior to leaving the facility.<br />

3) Worker Tracking Lists (WTL):<br />

All personnel performing work under the protection of a Clearance are required to sign on<br />

and off of the Clearance. This ensures that the Clearance is not cleared (removed) while<br />

personnel are still working in the zone of protection of the Clearance.<br />

You may receive additional training to use electronic signing; if you do not, your protection<br />

is assured by having you sign on and off of the WTL.<br />

4) The tagout process tags do NOT physically restrain isolation points like locks. Tagout<br />

process tags are essentially warning devices.<br />

a) “Information Tags” are attached to plant equipment to provide clearancerelated<br />

information. Information tags do NOT prevent Operation of<br />

equipment.<br />

b) “Danger Tags” clearly state “DANGER – Do Not Operate” and are used<br />

to ensure personnel safety or to prevent equipment damage by establishing<br />

the position of barrier valves, breakers or switches. Operating<br />

components with “Danger Tags” attached can cause injury, death, or<br />

equipment damage and, therefore, is grounds for disciplinary action up to<br />

and including dismissal.<br />

“Special Condition Tags” (SCTs) are similar to “Danger Tags” in that they<br />

prevent manipulation of equipment while work is being performed.<br />

However, under tightly controlled specific conditions, equipment may be<br />

manipulated while SCTs are attached. (Applies only at <strong>Exelon</strong> East Sites.)<br />

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c) WTO Tracking List Tag: A Tag used by workers as a physical indication to<br />

others that they are relying on the Danger tagged component as their main<br />

isolation point. This tag is used only for Worker Tagouts (a type of<br />

Clearance not tracked electronically).<br />

5) Specific departmental training will be provided to those who interface directly with the<br />

Clearance and Tagging process.<br />

4. Barriers and boundaries are also used in the Station to warn you of potential safety hazards.<br />

Examples of barriers include:<br />

a. Yellow and black or red and white safety rope<br />

b. Railings<br />

c. Flaggings<br />

E. Personal Protection Equipment<br />

1. Industrial safety experience has shown that the individual has the most control over reducing onthe-job<br />

injuries. This experience also shows that most injuries will involve the head, feet, eyes, and<br />

hands. For this reason, the company provides personal safety equipment and it is the expectation<br />

that it is to be worn throughout the Station when required.<br />

F. Safety Equipment<br />

1. The Station contains many types of industrial hazards. In some areas of the Station, you will find<br />

safety equipment installed near specific hazards and other equipment strategically placed for<br />

emergency use. Examples include: first aid kits, emergency showers and eyewash stations. This<br />

equipment should never be tampered with unless there is a real need for it.<br />

2. Emergency showers and eyewash stations are located throughout the Station to wash<br />

spilled chemicals off your skin and out of our eyes. These stations may consist of either<br />

a portable or a permanent eyewash/shower. The eyewash/shower is activated by either a<br />

foot pedal, hand lever or pull chain.<br />

3. If you or a coworker need to use an emergency shower, contact the emergency number,<br />

enter the shower, pull the chain, or push the lever. Stay in the shower for at least 15<br />

minutes if chemicals are involved. If you need to use the eyewash station, place your<br />

face near the water fountains and depress the foot/hand handle for at least 15 minutes.<br />

4. If you are assigned to work in an area with a particular hazard, make sure you know<br />

where the safety equipment is and how to get to it before starting the job.<br />

G. Refer to the <strong>Exelon</strong> Site Specific Study Guide(s) for site specific information regarding<br />

industrial safety responsibilities.<br />

III. Health Hazards<br />

A. Hazard Recognition<br />

1. Understand hazards associated with the work activity.<br />

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2. Look for hazards in the work environment.<br />

3. Communicate hazard information to co-workers.<br />

4. Use Lessons Learned/Operating Experience (OPEX) when performing work.<br />

5. Be aware of changing conditions.<br />

6. Know the appropriate Personal Protective Equipment (PPE).<br />

B. Hazard Mitigation<br />

1. Know installed safety equipment.<br />

2. Use PPE appropriate to the work.<br />

3. Maintain a safe work area.<br />

4. Stop if the work cannot be done safely.<br />

C. Job Hazard Analysis<br />

1. Prior to the start of potentially hazardous work, use the Job Hazard Analysis (JHA) procedure and<br />

process to identify potential safety hazards and establish methods to mitigate the potential hazard.<br />

D. Asbestos<br />

E. Lead<br />

1. Asbestos is a fiber used in the fabrication of lagging, insulation, gaskets, and<br />

other applications.<br />

2. Asbestos exposure can cause serious health problems and is most hazardous when it is friable. The<br />

term “friable” means that the asbestos is easily crumbled by hand, releasing fibers into the air.<br />

Sprayed on asbestos insulation is highly friable, while asbestos floor tile is not.<br />

3. Asbestos-containing ceiling tiles, floor tiles, laboratory cabinet tops, shingles, fire doors, siding<br />

shingles, etc., will not release asbestos fibers unless they are disturbed or damaged in some way. If<br />

an asbestos ceiling tile is drilled or broken, for example, it may release fibers into the air. If it is<br />

left alone and not disturbed, it will not release fibers. If you see damaged material that you suspect<br />

contains asbestos, immediately leave the area and notify your supervisor.<br />

4. Follow the station asbestos work procedures to minimize your exposure when you perform work<br />

with asbestos containing material. Personnel must complete specialized training before being<br />

allowed to work with asbestos containing materials or cross asbestos boundaries.<br />

1. Lead <strong>Training</strong><br />

a. <strong>Employee</strong> <strong>General</strong> Awareness – <strong>Employee</strong>s in the workplace where<br />

there is a potential for an exposure to airborne lead at any level shall<br />

be informed of the content of Appendices A and B of 29 CFR<br />

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1910.1025. Appendices A and B are located in SA-AA-0301, “<strong>Exelon</strong> <strong>Nuclear</strong> Industrial<br />

Safety Pocket Guide.”<br />

b. Lead Worker <strong>Training</strong> – In addition to general awareness training, each worker exposed to an<br />

airborne concentration of lead above the action level will receive information at least annually<br />

concerning:<br />

1) Specific jobs that could result in an exposure above the action level.<br />

2) <strong>General</strong> respiratory protection.<br />

3) Medical surveillance/removal program.<br />

4) Use of chelating agents. (medicines used for lead poisoning)<br />

5) Access to medical/exposure records/training materials.<br />

6) The content of 29 CFR 1910.1025 & 29 CFR 1926.62.<br />

2. Health and Hygiene<br />

a. Acute Effects – Short Term Exposure<br />

Lead is a potent poison. With large enough doses, lead can kill in a matter of days. Lead<br />

adversely affects numerous body systems, and causes forms of impaired healing and disease<br />

which arise after short periods of high exposure levels.<br />

b. Chronic Effects – Long Term Exposure<br />

Long-term exposure to low levels of lead may result in severe damage to the blood forming,<br />

nervous, urinary and reproductive systems.<br />

c. Hygiene<br />

Good personal hygiene is a very significant way to reduce exposure. Lead contamination on<br />

hands and face can pose an exposure threat by inhalation and ingestion. Remember to wash<br />

thoroughly after handling lead.<br />

3. Work Control<br />

a. Lead Work Areas will be clearly identified with appropriate signs. If a material is suspected to<br />

contain lead, do not remove it or disturb the area. Contact a supervisor before continuing work.<br />

b. Unless otherwise determined, all paint is to be assumed lead based.<br />

c. When using Peel-Away or similar products, if the company or lead abatement<br />

contractor shows proof that any product containing lead or any process, operation<br />

or activity involving lead cannot result in an employee exposure to lead at or<br />

above the action level, initial monitoring does not need to be implemented.<br />

d. Before removal activity of lead based paint or lead-containing materials begins, a Lead Work<br />

Exposure Compliance Plan shall be written and implemented.<br />

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e. For long-term projects, the Lead Work Exposure Compliance Plan must be reviewed and<br />

updated every six months to reflect the current status of the plan. The Lead Work Exposure<br />

Compliance Plan must be made available at the work site to employees, their representative and<br />

OSHA.<br />

4. Lead Exposure Control Strategy<br />

a. SA-AA-124, Lead Removal and Exposure Control, breaks tasks down into hazard categories<br />

that will be used to design the protective measures for workers.<br />

1) Category 1: Tasks which have an 8-hour time-weighted average exposure less than the<br />

action level 30 %g/m 3 .<br />

2) Category 2: Tasks which have an 8-hour time-weighted average exposure in excess of the<br />

action level but below the OSHA permissible exposure limit PEL of 50 %g/m 3 .<br />

3) Category 3: Tasks, which have an 8-hour time-weighted average exposure above the PEL<br />

50 %g/m 3 .<br />

b. Remember, if you will be working with lead, you will need additional training.<br />

5. Do not enter Lead Work Areas unless you are assigned to that work and have had Lead Worker<br />

<strong>Training</strong>, in addition to this Awareness Level <strong>Training</strong>.<br />

F. Electrical Hazards<br />

1. Many types of electrical power are used in the Station, and both alternating and direct current can<br />

cause injury. Electrical power used in the Station ranges from a few volts to thousands of volts.<br />

2. Damaged electrical cords, a liquid leaking into electrical cabinets, missing ground plugs, and<br />

exposed wiring are just a few of the potential hazards of working around electrical equipment.<br />

Always use caution when working around any component that uses electricity.<br />

3. If assigned to work on or around any exposed conductors or equipment that uses electricity, make<br />

sure it is safe to do so by ensuring equipment is removed from service and safety tagged prior to<br />

starting work.<br />

4. Consideration should be given to hidden electrical hazards prior to performing activities such as<br />

drilling, nailing, or spraying water on an object (example: embedded in concrete). If you need to<br />

drill, nail, or spray water into one of these structures, make sure there aren’t any electrical<br />

conductors in it before you start.<br />

5. Never touch an individual who is in contact with a live electrical circuit.<br />

6. Work activities that involve work on or in the vicinity of electrically energized gear must be<br />

evaluated for potential hazards using the Job Hazard Analysis (JHA) procedure and process.<br />

G. Steam Leaks<br />

1. Steam is used in a variety of applications and pressures. Occasionally, a steam leak will develop<br />

from a Station component such as a valve or pipe fitting. Some indications of a steam leak are:<br />

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a. Visible vapor coming out of a Station component<br />

b. Whistling noise<br />

c. Increased area temperatures<br />

d. Moisture on walls or ceiling<br />

2. You should always use caution when in an area containing a steam leak. Steam can cause burns if<br />

it comes in contact with your body. If you find a steam leak, report it to the Control Room.<br />

3. Efforts are made to identify steam leaks by performing preventive and corrective maintenance and<br />

by periodic operator inspections. When leaks are identified, they are posted with warning ropes<br />

and signs.<br />

H. Confined Spaces<br />

1. Confined spaces may contain a life-threatening atmosphere. A confined space is defined as:<br />

a. Any space not intended for continuous human occupancy and<br />

b. Having a limited means of entry or exit and<br />

c. Large enough and so configured that an employee can bodily enter and perform assigned work.<br />

d. No part of the body may “break the plane” of the opening as this is considered entry of a<br />

Confined Space<br />

2. Some examples of a potential confined space are:<br />

a. Storage tanks<br />

b. Ventilation or exhaust ducts<br />

c. Manholes<br />

d. Underground utility vaults<br />

e. Tunnels<br />

f. Process vessels<br />

1) Boilers<br />

DANGER<br />

CONFINED SPACE<br />

PERMIT REQUIRED<br />

FOR ENTRY<br />

3. Entry into a confined space is not permitted unless the requirements of the confined space permit<br />

are met and you have completed the confined space training program.<br />

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I. Trip and Fall Hazards<br />

1. When working in the Station, special care must be taken regarding hazards that can cause you to<br />

trip or fall. There are many potential hazards at the station that could cause an individual to trip or<br />

fall. Examples are:<br />

a. Piping, conduits, ropes, cables<br />

b. Work on elevated equipment<br />

c. Unsecured ladders<br />

2. When working in a position where there is more than a 6-foot potential fall, additional fall<br />

protection is required. Workers should check with their supervisor before using specialized<br />

equipment. Some protective measures include:<br />

a. Postings<br />

J. Heat Stress<br />

b. Fall protection equipment<br />

c. Temporary platforms for elevated work<br />

d. Scaffold usage<br />

1. Some station areas can get extremely warm. The stay time, or the length of time permitted at a<br />

work site, may be limited to protect you against heat stress. Special clothing may also be required.<br />

2. Heat stress concerns should be discussed with your supervisor. Station procedures can provide<br />

guidance for stay times in those areas, based upon the temperature and humidity.<br />

3. You can minimize the risk of heat stress illness by:<br />

a. Drinking plenty of fluids<br />

b. Using cooling devices such as fans or ice vests<br />

c. Limiting the amount of time you are exposed to the heat environment.<br />

4. If you are working in a hot and/or humid area and begin to feel overheated or dizzy, inform your<br />

co-workers and move to a cooler area and rest. Notify your supervisor of the situation so that<br />

actions can be taken. Seek medical attention for heat related illness.<br />

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K. Compressed Gases<br />

1. Compressed gas cylinders can also present a safety hazard. These cylinders<br />

may contain compressed gases that may be inert, flammable, or poisonous.<br />

The gas cylinders are stored outside whenever possible but should always be<br />

protected from the weather and direct sunlight. The following precautions<br />

should be observed when working with compressed gases:<br />

a. Stay clear of any relief or blow off valves.<br />

b. Be sure hoses are in good repair, and do not direct compressed air at any part of the body.<br />

c. Store compressed gas cylinders securely in an upright position.<br />

d. All compressed gas cylinders must be secured to prevent them from falling.<br />

e. If you are going to work with compressed gas cylinders, refer to procedure SA-AA-122.<br />

Limerick injury with Drill Press - Dated 2/20/06, IR 245257 worker was brushing away metal filings from the<br />

work surface with his left hand while the drill was rotating. The sleeve became entangled in the drill bit which<br />

pulled his hand into the bit causing portions of 2 fingers on his left hand to be severed.<br />

L. Rotating/Moving Equipment<br />

1. Many types of rotating equipment can be found in the Station such as pumps, motor-operated<br />

valves, lathes, and cranes. Some of this equipment operates intermittently.<br />

2. Your clothing and accessories should always be worn in a manner to promote safety. You should<br />

not wear loose clothing or jewelry that could get caught in moving machinery or equipment. Also<br />

pay attention to postings, and do not tamper with guards or shrouds around moving shafts.<br />

M. High Noise<br />

As discussed earlier, there are some high-noise areas in the Station. In addition to the posted areas,<br />

areas where it is difficult to hear or converse should also be considered high-noise areas. As stated<br />

earlier, when in a high-noise area, ear protection is required. Company-provided ear plugs and ear<br />

muffs are available for use in the Station.<br />

N. Falling Objects<br />

Falling objects are also a potential hazard in the Station. Station equipment, scaffolding, tools, and<br />

other objects are examples of what could fall and cause an injury. In some areas, objects can be 30 or<br />

more feet in the air. These hazards can be minimized through the use of equipment such as scaffold toe<br />

boards, tool lanyards and good housekeeping. Wear proper personal protective equipment such as hard<br />

hats. Also, when you are working in the overhead remember that there may be people passing below<br />

you.<br />

O. Eye Hazards<br />

Some activities in the Station can represent a serious eye hazard. Chipping, grinding, and welding are<br />

only a few examples of activities that require special eye protection. When involved in activities that<br />

Page 74 of 178


may present a hazard to your eyes, wear your safety glasses and goggles or a face shield. If you have a<br />

need for other eye protection, discuss it with your supervisor.<br />

P. Hazardous Chemicals<br />

1. The National Fire Protection Association (NFPA) 704 and the Hazardous Materials Identification<br />

System (HMIS) are readily recognized and easily understood labeling systems for identifying<br />

specific hazards and their severity. They address health, flammability, instability, and related<br />

hazards that may be presented as short-term, acute exposures that are most likely to occur as a<br />

result of fire, spill, or similar emergency.<br />

a. The systems are not applicable to chronic exposures or to nonemergency occupational<br />

exposure.<br />

b. The NFPA hazard severity is indicated by a numerical rating that ranges from zero (0)<br />

indicating a minimal hazard, to four (4) indicating a severe hazard.<br />

c. The Hazardous Materials Identification System (HMIS) was developed by the National Paint<br />

and Coatings Association (NPCA), it also categorized hazards according to health, reactivity,<br />

and flammability. In addition, it also assigns the level of PPE appropriate for the substance.<br />

2. According to the Occupational Safety and Health Administration (OSHA), you have the right to<br />

know the potential hazards of any chemical you use. Chemicals used in the Station include acids,<br />

caustics, cleaners, and petroleum products.<br />

3. Some indications of a potential chemical hazard are:<br />

a. Liquid spills<br />

b. Labeled or unlabeled containers<br />

c. Unusual vapors or odors<br />

d. Posted chemical storage areas<br />

4. When using a chemical, always follow the label’s instructions and be careful not to deface the label<br />

on a chemical container. Never mix chemicals, and do not use a chemical if you’re not sure what it<br />

is.<br />

5. All chemicals used on site must have a Material Safety Data Sheet (MSDS) with the following<br />

information:<br />

a. Physical hazards<br />

b. Protective clothing and equipment needed<br />

c. Storage requirements<br />

d. Spill and leak procedures<br />

e. Respiratory protection<br />

Page 75 of 178<br />

MSDS<br />

Material<br />

Safety<br />

Data<br />

Sheet


6. Prior to using any chemical, the user should be aware of potential hazards. You can obtain<br />

information about MSDS through your supervisor and on the company intranet.<br />

7. Every controlled material needs approval prior to bringing it on site and every controlled material<br />

shall have the <strong>Exelon</strong> Controlled Material Program label on it.<br />

8. Contact the Site Chemical Control Coordinator for questions and approvals.<br />

9. EN-MA-501, “Controlled Materials and Hazard Communication Program,” and EN-MW-501,<br />

“Chemical Control,” provide the requirements and guidance for the program.<br />

10. Some Station areas have large quantities of very dangerous chemicals such as strong acids and<br />

caustics. These areas are posted and should not be entered unless you meet the entry requirements.<br />

If you need to enter a posted chemical area and are not sure if you are authorized, contact your<br />

supervisor.<br />

11. Hazardous materials must be disposed of properly according to applicable regulations. To properly<br />

dispose of chemicals, contact the individual responsible for chemical control.<br />

12. Every drain at the station fills a specific purpose. Never pour anything down a drain without<br />

appropriate permission.<br />

13. The company employs methods such as training, labeling, a chemical control program, and<br />

protective equipment to reduce the risk of chemical injuries.<br />

Q. Transportation/Handling of Hazardous Materials<br />

1. All Hazardous material must be offered for transportation by a trained shipper in<br />

accordance with EN-AA-601.<br />

2. A Hazardous Material is a substance or material that meets two criteria:<br />

a. Poses an unreasonable risk when transported in commerce.<br />

b. The Department of Transportation (DOT) designated it as a hazardous material in 40 CFR 172.<br />

3. Prior to transporting, handling, packaging, storing, loading or off-loading, or driving any hazardous<br />

material (e.g., compressed gas cylinders, radioactive material, asbestos, lead, etc.) over a public<br />

road on behalf of the company, contact your supervisor, as additional training is required.<br />

a. <strong>Training</strong> is required to protect the handler, the transporter, the public, the environment, and<br />

emergency responders, and to avoid delays in transportation.<br />

b. Thousands of hazmat transportation accidents occur every year due to people not knowing their<br />

jobs.<br />

R. Waste Management Activities<br />

1. This section’s purpose is to familiarize employees with the Resource Conservation and Recovery<br />

Act, (RCRA) regulations to ensure proper handing of waste. Reference the MSDS, work package,<br />

manufacturer recommendations, and use the pre-job brief to understand the hazards of the products<br />

you are handling.<br />

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2. As with the Chemical Control Programs, you should know the hazards of the products you are<br />

handling. The general employee must be aware of the site-specific processes for handling wastes.<br />

3. At no time should waste products be placed in drains or thrown into the trash without proper<br />

approval through the Site’s RCRA Coordinator, usually the Site’s Environmental Group.<br />

4. This general training does not qualify you to ship hazardous material, hazardous waste or be the<br />

RCRA Coordinator at your site.<br />

5. Hazardous Wastes are certain wastes listed by the EPA as hazardous based on the toxicity,<br />

corrosivity, ignitability, or reactivity of the product. Examples include, but are not limited to spent<br />

chlorinated solvents, unused laboratory reagents, such as cyanide compounds or hydrazine. When<br />

in doubt contact the Site’s RCRA Coordinator, usually the Environmental Group.<br />

6. Universal Waste includes products such as batteries, fluorescent light bulbs and mercury switches.<br />

All handlers of universal waste must understand the hazards of the products they are transporting<br />

and know the proper storage locations on site.<br />

7. Residual Waste, Special Waste, and Medical Waste all require special handling. Careful<br />

consideration during handling and storage should be practiced just as with hazardous waste.<br />

Common examples are asbestos, PCB wastes, waste oil and oily rags, non-hazardous solvents and<br />

latex paint.<br />

8. Mixed waste is waste that is both hazardous and radiologically contaminated. Only qualified<br />

RCRA and Radiation Protection personnel should handle mixed waste.<br />

9. The use of products often involves the creation of waste materials such as left over products or<br />

cleanup material. For this reason, the use of non-hazardous products is strongly encouraged at all<br />

sites. Using as few hazardous chemicals and absorbent materials as necessary to complete the job<br />

is an important factor in minimizing waste generated.<br />

10. Other factors in waste minimization include proper waste segregation, capture and reuse of<br />

materials, fixing oil leaks, and using collection pans instead of pads or rags. Use material stored in<br />

the site tool rooms prior to ordering new material.<br />

S. Hazardous Waste Operations and Emergency Response<br />

1. Hazardous Waste Operations and Emergency Response (HAZWOPER) regulates the safety and<br />

health of employees involved in any emergency response to incidents involving hazardous<br />

substances.<br />

2. If you believe a spill or release of a hazardous chemical and/or substance has occurred, move a safe<br />

distance away and call the Control Room and identify:<br />

a. Who you are<br />

b. The location of the incident<br />

c. Whether there are any injuries<br />

d. The name and approximate quantity of the hazardous material<br />

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3. Any spills should be immediately reported to the Main Control Room. Each site has its own<br />

Emergency Spill Procedures. You should be aware of these procedures and perform your work in<br />

accordance with these procedures.<br />

4. The Resource Conservation and Recovery Act (RCRA) was established to properly manage,<br />

dispose of and minimize hazardous wastes in the United States. Hazardous waste can be solid,<br />

liquid, or gaseous. Not all wastes are hazardous. Common hazardous wastes are paint solvents,<br />

degreasers, and outdated chemicals. RCRA contains specific waste-handling regulations with<br />

harsh penalties for violators. To avoid any violations and to help keep our environment clean, you<br />

must be aware of the type of wastes that are generated from your work and the rules that regulate<br />

these wastes. To ensure proper disposal of any waste, follow directions given by your Station’s<br />

Environmental group.<br />

T. Bloodborne Pathogen Awareness<br />

1. Hepatitis B (HBV) and Human Immunodeficiency Virus (HIV) may be transmitted when disease<br />

organisms enter the body through mucus membranes or through breaks in the skin. HBV can cause<br />

a potentially fatal liver disease. HIV causes Acquired Immunodeficiency Syndrome (AIDS).<br />

2. Transmission of disease could occur if you are exposed to a co-worker’s open sore or if you have<br />

direct contact with their bodily fluids containing infectious material.<br />

3. Additional training is required for personnel whose job requirements could cause them to come in<br />

contact with bio-hazardous material.<br />

4. If you think you have been exposed to potentially infectious material, use the following guidelines:<br />

a. Don’t panic! Wash the affected area.<br />

b. Inform your supervisor who will inform the medical staff.<br />

c. The medical staff will determine your exposure and advise you of any follow-up measures that<br />

may be required.<br />

IV. Personal Protection Equipment<br />

Some jobs may have a particular hazard associated with the performance of the work. Check with your<br />

supervisor if you are in doubt as to whether or not you need protective equipment. There are many<br />

safety precautions, which are required in the Station including the use of the following equipment:<br />

A. Hard Hats<br />

1. A hard hat should be worn with the sides parallel to the ground and the bill in<br />

front.<br />

2. It should not have holes, cracks, unofficial stickers or markings, or any conductive material on the<br />

outside.<br />

3. The suspension on the inside of the hard hat should be periodically checked for frayings and tears.<br />

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4. Never store items between the shell and suspension on the inside of the hard hat. It can interfere<br />

with the proper operation of the suspension. This includes no wearing baseball caps under the hard<br />

hat. Approved welding hats may be allowed.<br />

5. ANSI Z89.1 approved hard hats must be worn by all personnel in all work areas posted as requiring<br />

hard hat and where ever the possibility of head injuries exist.<br />

6. Hard hats will be provided to company employees.<br />

B. Eye Protection<br />

1. Eye protection must meet ANSI and company requirements to protect from flying particles/debris<br />

and be shatterproof.<br />

2. Safety glasses with side shields, safety goggles, or face shields may be needed to meet these<br />

requirements.<br />

3. Your eye protection should be inspected periodically for scratches and cracks that may obscure<br />

vision or lessen protection. Additionally, you should clean your eye protection to prevent obscured<br />

vision.<br />

C. Hearing Protection<br />

1. Being exposed to excessive noise without protection can result in an immediate or a gradual<br />

hearing loss.<br />

a. Sound waves enter the ear and are channeled to the eardrum.<br />

The eardrum vibrates and transmits these vibrations to rows<br />

of tiny hair cells in the inner ear.<br />

b. The hair cells transform these vibrations into electrical<br />

impulses that are then transmitted to the brain.<br />

c. It is these hair cells that can become damaged after prolonged exposure to loud sound that<br />

results in hearing loss.<br />

d. Other effects associated with exposure to loud sound include: annoyance, distraction,<br />

nervousness, headaches and fatigue.<br />

2. For maximum protection, the hearing protection device must make a tight seal with the ear canal or<br />

side of the head. However, not all hearing protection devices are equally suited for all ear canals<br />

and head shapes.<br />

3. The following are examples of hearing protection devices:<br />

a. Ear plugs<br />

1) To insert:<br />

a) Be sure hands, ears and plugs are clean<br />

b) Roll plug with fingers to reduce diameter or until completely compressed<br />

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c) Pull outwards and upwards on ear<br />

d) Insert plug into ear canal<br />

e) Hold plug till it expands<br />

2) Replace ear plugs if soiled or worn. If ear plugs are reusable, wash with mild soap and<br />

warm water.<br />

3) Ear plugs are easier to wear with hard hats, glasses, and protective equipment.<br />

b. Ear muffs<br />

1) The headband fits over the head with ear cups that are foam<br />

or gel-filled.<br />

2) The hardhat ear muff consists of ear muff units that attach<br />

independently to each side of the hard hat.<br />

3) Ear muffs are easy to adjust and can be put on and taken off quickly.<br />

4) Ear muffs should not be worn over eyeglass frames unless approved for use as such by the<br />

manufacturer.<br />

4. The intensity of a particular sound wave is measured in decibels. Any sound that creates a decibel<br />

level of > 90 decibels can result in permanent hearing loss if hearing protection is not used.<br />

5. You must wear hearing protection when:<br />

a. Working in a designated high-noise area. These areas are posted throughout the Station.<br />

b. It is difficult to hear or converse.<br />

6. The effects of hearing loss may not be immediately noticeable. Thus, audiometric testing may be<br />

performed on some employees.<br />

7. Hearing protection is provided by the company.<br />

D. Gloves<br />

1. When working with your hands, wear gloves if there are rough surfaces, chemicals, possibility of<br />

slivers, or a work activity that could result in a hand/finger injury.<br />

2. Never place your hands into the “Line of Fire”, which are locations where your hand can be<br />

pinched, cut, or crushed. Areas that are considered within the “Line of Fire,” where you should<br />

avoid placing your hands include:<br />

a. The outside of carts, doors, or boxes<br />

b. The inside of hinges, doors, or lids<br />

c. The sides of equipment or boxes<br />

d. The striking area for tools and equipment<br />

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E. Footwear<br />

1. ANSI Z41-1991 approved safety work shoes shall be worn if there is a potential for foot injury.<br />

2. When there is less potential for foot injury, “serviceable” or a sturdy work shoe shall be worn.<br />

3. Serviceable shoes cover the entire foot and have a sole of hard rubber or leather to prevent<br />

penetration of objects. Sandals, spiked heeled, moccasins and athletic shoes are not serviceable.<br />

4. Shoes in good condition should not have any of the following:<br />

F. Clothing<br />

a. Crushed toe guard<br />

b. Cracked, split or cut outer covering<br />

c. Cracks or holes in the soles<br />

d. Slick heels or soles<br />

1. In the plant, full length trousers and a shirt covering the shoulders shall be worn.<br />

2. Wear natural fiber or flame retardant clothing when/if your work exposes you to flames, electric<br />

arcs, welding, cutting, grinding, or energized electrical equipment.<br />

3. Do not wear synthetic fibers because it could increase the severity of burns when exposed to<br />

enhanced heat.<br />

4. Wear long sleeves to protect arms when working near hot pipes or equipment.<br />

5. Do not wear metal objects such as rings, chains, and bracelets when they could be a hazard.<br />

V. Summary<br />

A. You are responsible for your own safety and recognizing and reporting unsafe working conditions in<br />

the Station.<br />

B. “2 Minute Drill @ the Job Site” is a human performance tool used to ensure employees focus on the<br />

critical aspects of a job and job site conditions, including those discussed in the pre-job brief, when<br />

applicable, immediately prior to beginning a task in order to prevent events and injuries.<br />

C. Safety Tags are a way of protecting you from potential danger, communicating special requirements,<br />

tracking discrepancies, or providing other types of information.<br />

D. When working under Clearance Orders, workers are expected to sign off the Clearance each day prior<br />

to leaving the facility.<br />

E. Health Hazards include:<br />

1. Prior to the start of potentially hazardous work, use the Job Hazard Analysis (JHA) procedure and<br />

process to identify potential safety hazards and establish methods to mitigate the potential hazard.<br />

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2. Asbestos is a potential health hazard. Working with asbestos requires special training and permits<br />

prior to starting work.<br />

3. Lead is a potent poison. Additional training is required to work in areas where the airborne<br />

concentration is higher than the action level.<br />

4. Always use caution when working around any component that uses electricity.<br />

5. Indications of steam leaks include, whistling noise, increased area temperatures, or moisture on<br />

walls or ceiling.<br />

6. Confined spaces may contain life-threatening atmospheres.<br />

7. Heat stress is a potential health hazard. If working in a hot area and begin to feel overheated or<br />

dizzy, inform your co-workers; move to a cooler area and rest.<br />

8. Compressed gases must be stored out of weather and direct sunlight. Specific storage rules apply<br />

per procedure SA-AA-122.<br />

9. Do not wear loose-fitting clothing around any moving/rotating equipment.<br />

10. Workers have the right to know the hazards of chemical substances in the work place.<br />

11. MSDSs provide information on the chemical identity and dangers of a material. Contact your<br />

supervisor for this information.<br />

12. All containers of hazardous substances must be properly labeled.<br />

F. Your personal protection equipment (PPE) and clothing should always be worn in a manner to promote<br />

safety. Hard hats, safety glasses, hearing protection, gloves, serviceable shoes, and appropriate<br />

clothing are basic PPE.<br />

G. The NFPA 704 Labeling System is a nationally recognized method of indicating the presence of<br />

hazardous materials at FIXED storage locations.<br />

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Course/Program: <strong>General</strong> <strong>Employee</strong> <strong>Training</strong> Module/LP ID: Fire Protection<br />

Title: ! <strong>Exelon</strong> Fire Protection Course Code: N-N-GRP1I, N-N-GRP2I<br />

N-N-GRP1R, N-N-GRP2R<br />

Author: Silvia Morse Revision/Date: 4, 08/08<br />

Prerequisites: None Revision By: R. Keister<br />

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Est. Teach Time: 30 minutes<br />

From memory and in accordance with this training material, the trainee shall be able to:<br />

Objective # Objective Description<br />

1. State individual responsibilities regarding fire barriers such as fire dampers, doors,<br />

seals and combustible free zones.<br />

2. State actions an individual is required to take upon discovery of a fire.<br />

3. State individual responsibilities regarding the control of fire loading (wood, solvents,<br />

oil) and the disposal of flammable materials.<br />

4. State individual responsibilities regarding staging material near fire protection<br />

equipment.<br />

5. State examples of the types of hot work requiring a permit.<br />

6. Recognize and state the response to a station fire alarm.<br />

References:<br />

NEI 03-04 – “PADS Guidelines for Plant Access <strong>Training</strong>”<br />

NFPA 12, “Standard on Carbon Dioxide Extinguishing Systems”<br />

OP-AA-201-009, Control of Transient Combustible Material<br />

OP-AA-201-004, Fire Prevention for Hot Work<br />

CC-AA-201, Plant Barrier Control Program<br />

I. Introduction<br />

A. Overview<br />

1. <strong>Exelon</strong> is committed to ensuring personnel safety. Stations must meet regulations and rules<br />

regarding employee fire safety. Following regulations and rules will assist in making the station a<br />

safe place to work.<br />

2. Upon completion of this section, you should be able to minimize the potential for causing a fire and<br />

properly responding to a fire should one occur.<br />

" Copyright 2008 by <strong>Exelon</strong> <strong>Nuclear</strong>, All Rights Reserved. Permission for reproduction and use is reserved for <strong>Exelon</strong> <strong>Nuclear</strong>.<br />

(Any other use or reproduction is expressly prohibited without the express permission of <strong>Exelon</strong> <strong>Nuclear</strong>.)


3. Highlighted portions of this lesson plan are <strong>Exelon</strong> specific material not covered in NEI 03-04.<br />

B. Purpose<br />

1. The purpose of this training is to provide information on how to minimize and properly respond to<br />

a fire in order to remain safe while working in a nuclear power station.<br />

C. Objectives<br />

D. Statement of Evaluation<br />

1. Students will be evaluated by answering questions given on the examination with an accuracy of<br />

80% or better.<br />

II. Fire Barriers<br />

A. Fire barriers are required by federal law and have been built into the station to prevent the spread of fire<br />

and to restrict the movement of smoke and gasses. These barriers come in several forms such as doors,<br />

dampers, and seals. They may also be used as security, ventilation, flood, missile, and radiation<br />

protection barriers.<br />

B. A fire barrier penetration is an opening in a fire barrier such as a floor, wall, or ceiling for the passage<br />

of conduit, cables, cable trays, piping, HVAC ducting, dampers, etc., and which has been sealed to<br />

maintain a fire barrier rating.<br />

1. Before beginning a task that will disturb a sealed wall or floor penetration, contact the Control<br />

Room or Operations Management and follow their instructions.<br />

C. When in the station and a fire door is opened, make sure the fire door is firmly closed and latched<br />

before leaving. CHALLENGE the door!<br />

1. Be very careful when using carts to transport material or tools through doorways. Doors or frames<br />

may be damaged from carts and may not close or seal properly making them inoperable as a fire<br />

barrier.<br />

2. Doors SHOULD be placed in their required position after use unless previously authorized by a<br />

Plant Barrier Impairment (PBI) permit.<br />

3. If a door must be blocked or tied open, then a PBI Permit SHALL be required.<br />

D. Any problems with a fire barrier should be reported to the Control Room or Operations Management<br />

and documented in an Issue Report.<br />

E. If you have to leave a fire barrier open for a period of time, take the appropriate actions per plant<br />

procedures.<br />

F. There are some areas in the plant in which a specific zone has been established as a barrier to prevent<br />

the spread of fire. Combustibles shall not be placed in these areas unless approved by Fire Protection.<br />

Permits (i.e., Transient Combustible Permit or Barrier Breach Permit) may also be required for<br />

combustible materials placed in these areas.<br />

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III. Discovery of a Fire<br />

A. If a fire is discovered, take the following actions:<br />

1. Notify the control room using the station page, radio, or telephone.<br />

2. Inform the control room of the location and what is burning. Make sure the control<br />

room acknowledges the report.<br />

3. Stand by in a safe location and warn others until the fire brigade arrives. Provide<br />

additional information as necessary.<br />

4. Do not attempt to fight the fire unless it is small and clearly within your capability and you are<br />

properly trained.<br />

B. The above instruction is for the <strong>General</strong> <strong>Employee</strong>. Personnel trained and assigned Firewatch duties<br />

shall follow firewatch instructions.<br />

C. Refer to the <strong>Exelon</strong> Site Specific Study Guide(s) for site specific information regarding discovery of a<br />

fire.<br />

IV. Fire Loading<br />

A. The station is required to meet specific codes and regulations regarding fire suppression and<br />

prevention, which limit the amount of flammable material that can be stored in an area.<br />

1. A transient fire load is any combustible or flammable material temporarily installed or stored in the<br />

plant.<br />

a. Flammable material, such as oils, fuel, lubricants, aerosol cans, etc., must be stored in special<br />

fire-rated cabinets.<br />

b. Combustible materials such as harnesses, gloves, paper, fabric, tool bags, etc., used to support<br />

work must be minimized and controlled.<br />

c. Use of wood that is not fire retardant is NOT permitted on site without authorization.<br />

1) Fire-retardant wood is usually distinctively marked or stamped, most often with a color<br />

coating such as blue or green.<br />

2) Contact supervision if wood is discovered that does not appear to be fire retardant.<br />

2. Whenever using combustible material on a job, limit the amount to what is needed to get the work<br />

done or the amount allowed in the area, whichever is less.<br />

a. This will not only reduce the fire hazard but will also save on material that needs to be<br />

disposed.<br />

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. Control of combustible material is usually performed using a Transient Combustible Permit.<br />

1) When not in use, transient combustibles necessary for work, should be staged in closed<br />

metal containers (cabinets, tool boxes, gang boxes, metal drums) that are in good repair,<br />

and when practical (i.e., size is such that the item will fit in the drum or box).<br />

2) Combustible and flammable liquids are to be kept in an approved (UL listed, FM<br />

Approved, DOT Specification, etc.) flammable liquid storage cabinets, and the cabinet kept<br />

closed when left unattended.<br />

a) Rags used to clean up flammable or combustible liquid spills should be placed in an<br />

approved container with self-closing lid or removed from the area and disposed of<br />

properly.<br />

3. When the job is done, return any unused combustible material to its proper storage area.<br />

a. If in a safety-related area, return the material to its storage area by the end of the shift unless<br />

approval has been given to temporarily store it elsewhere.<br />

b. Consult with your supervisor and the appropriate plant procedure if you have questions<br />

regarding using, storing, or disposing of flammable or combustible material in any area of the<br />

plant.<br />

4. Refer to the <strong>Exelon</strong> Site Specific Study Guide(s) for site specific information regarding fire<br />

loading.<br />

V. Plant Fire Protection Equipment<br />

A. Fire protection equipment is staged throughout the site for use in case of a fire. Do not<br />

block or impair access to plant fire protection equipment during staging of equipment<br />

and materials or when constructing scaffolds. This equipment may vary from site to<br />

site but consists of Fire exits, Fire hydrants, Hose reels, hand held extinguishers,<br />

wheeled extinguishers, foam carts, fire brigade equipment, breathing air (SCBAs) etc.<br />

If equipment is found blocked contact the Control Room or Operations Management.<br />

VI. Hot Work<br />

A. Any work activity that has the potential of starting a fire or accidentally activating an automatic fire<br />

suppression system, such as welding, burning, brazing or grinding metal (sparks) or generating smoke<br />

or fumes, must be approved before work is started. This type of work requires that a permit and,<br />

potentially, other special requirements be met before the work is started.<br />

B. If involved in a task that could create a fire hazard and approval has not been obtained or if you are not<br />

sure if a job requires a permit, contact supervision for guidance.<br />

C. Personnel may be assigned to firewatch duties whenever work activities present a fire risk or when a<br />

fire protection system is out of service.<br />

D. To be qualified for firewatch duties, further training is required.<br />

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E. When hot work is being performed all flammable and combustible material within 35’ must be<br />

removed, covered or some how protected from spark travel.<br />

VII. Fire Alarm<br />

A. In case of a fire, the station will sound the fire alarm or will provide a station alert<br />

followed by an announcement. Should you hear the station fire alarm, listen to the<br />

instructions and follow them.<br />

B. The fire brigade responds to all fires. All other personnel are expected to cooperate with the<br />

responding personnel, evacuate the area, and follow any instructions on the station announcing system.<br />

C. Do not use any elevator in the same building/area (e.g., Power Block) during a fire.<br />

D. Fire suppression systems are systems intended to inhibit the growth of a fire.<br />

Some areas of the station contain gaseous fire suppression systems such as Halon or Carbon Dioxide<br />

(CO2). These areas and surrounding areas are specifically identified (refer to signs) at each station.<br />

E. Pre-discharge alarms are usually provided on systems that exceed the maximum safe levels for<br />

employee exposure. The purpose of the alarm is to alert personnel and allow safe exit from the area.<br />

Some areas with CO2 and Halon systems use multiple senses to warn you: Sight – flashing light, Smell<br />

– wintergreen scent, and Hearing – loud alarm. When working in areas equipped with CO2/Halon<br />

systems, be aware of the warning system utilized by the plant.<br />

1. If the alarm activates or a wintergreen odor (for CO2 systems) is detected while you are working in<br />

a room, leave immediately. These systems can result in suffocation.<br />

2. CO2 will soon fill the room and displace oxygen.<br />

3. The system discharge will create a great deal of noise and will greatly limit visibility.<br />

4. Avoid passing through nozzle spray paths as they can endanger a person’s safety by causing a<br />

strong chilling effect, eye injury, ear injury, or falls due to loss of balance, loss of consciousness or<br />

death.<br />

Page 87 of 178


F. Special attention to housekeeping and maintaining exit paths are mandatory in CO2/Halon protected<br />

areas. If work activities may cause a delay in leaving the area then the system should be taken out of<br />

service in accordance with station procedures.<br />

G. Refer to the <strong>Exelon</strong> Site Specific Study Guide(s) for site specific information regarding fire alarms.<br />

VIII. Summary<br />

A. Fire barriers are required by law and have been built into the station to prevent the spread of a fire.<br />

B. Doors or frames may be damaged from carts and may not close or seal properly making them<br />

inoperable as a fire barrier.<br />

C. As a <strong>General</strong> <strong>Employee</strong>, if you discover a fire, notify the control room, stand by in a safe location, and<br />

warn others until the fire brigade arrives.<br />

D. The station is required to meet many types of codes and regulations regarding fire suppression and fire<br />

prevention.<br />

E. Whenever using combustible material on a job, limit the amount to just what is needed to get the work<br />

done or to the amount allowed in the area, whichever is less. Also make sure material is properly<br />

stored (i.e., in closed metal containers) when not attended.<br />

F. Do not block or impair access to fire protection equipment.<br />

G. If hot work is being performed all flammable and combustible material within 35' must be removed,<br />

covered or some how protected from spark travel.<br />

H. Any work activity that has the potential of starting a fire must be approved before work is started.<br />

I. In the case of a fire, the station will sound the fire alarm or will provide a station alert followed by an<br />

announcement.<br />

J. Halon and Carbon Dioxide fire suppression systems are specifically identified by signs at the stations.<br />

K. When working in areas equipped with CO2/Halon systems be cognizant of the warning system utilized<br />

by the plant.<br />

1. If the alarm activates or a wintergreen odor (for CO2 systems) is detected while you are working in<br />

a room, leave immediately.<br />

Page 88 of 178


Course/Program: <strong>General</strong> <strong>Employee</strong> <strong>Training</strong> Module/LP ID: Emergency<br />

Response/Preparedness<br />

Title:<br />

! <strong>Exelon</strong> Emergency<br />

Response/Preparedness<br />

Page 89 of 178<br />

Course Code: N-GRP1I N-GRP2I<br />

N-GRP2I N-GRP2R<br />

Author: S. Morse Revision/Date: 2, 12/05<br />

Prerequisites: None Revision By: G. Kiss<br />

OBJECTIVES<br />

Est. Teach Time: 30 minutes<br />

From memory and in accordance with this lesson material, the trainee shall be able to:<br />

Objective # Objective Description<br />

1. State the purpose of the emergency plan.<br />

2. State the classifications of station emergencies.<br />

3. Recognize the emergency alarms, and state the proper response for each.<br />

4. State the actions required during emergency plan implementation.<br />

5. State the purpose of accountability during an emergency.<br />

6. State the location of the employee’s assigned assembly area.<br />

7. Discuss evacuation plans, including identification of evacuation routes.<br />

8. State the company’s policy concerning the release of information to the public and<br />

news media regarding an emergency.<br />

References:<br />

NEI 03-04, “PADS Guidelines for Plant Access <strong>Training</strong>”<br />

NRC Bulletin 2005-02, “Emergency Preparedness (EP) and Response Actions for Security-Based<br />

Events”<br />

<strong>Exelon</strong> Emergency Planning procedures (EP series)<br />

" Copyright 2000 by <strong>Exelon</strong> <strong>Nuclear</strong>, All Rights Reserved. Permission for reproduction and use is reserved for <strong>Exelon</strong> <strong>Nuclear</strong>.<br />

(Any other use or reproduction is expressly prohibited without the express permission of <strong>Exelon</strong> <strong>Nuclear</strong>.)


I. Introduction<br />

A. Overview<br />

1. <strong>Exelon</strong> has a plan to protect the public and station workers in the case of a nuclear emergency.<br />

2. Upon completion of this section, you should be able to respond to an emergency plan activation.<br />

3. Highlighted portions of this lesson plan are <strong>Exelon</strong> specific material not covered in NEI 03-04.<br />

B. Purpose<br />

1. The purpose of this training is to provide information on responding to an emergency plan activation<br />

in order to remain safe in a nuclear power station.<br />

C. Objectives<br />

D. Statement of Evaluation<br />

1. Students will be evaluated by answering questions given on the examination with an accuracy of<br />

80% or better.<br />

II. Purpose of the Emergency Plan<br />

A. The <strong>Exelon</strong> <strong>Nuclear</strong> Emergency Plan (E-Plan) establishes an organization and provides the guidance<br />

needed to protect the public, employees, and nuclear stations.<br />

B. An emergency will be declared based on station conditions and will be escalated, transition to Recovery,<br />

or terminated as station conditions change.<br />

III. Emergency Plan Classifications<br />

A. There are five classifications of emergencies depending on the severity. They are:<br />

1. Unusual Event –events are in process or have occurred which indicate a potential degradation of the<br />

level of safety of the plant or indicate a security threat to facility protection. No releases of<br />

radioactive material requiring off-site response or monitoring are expected unless further<br />

degradation of safety systems occurs. (Least severe)<br />

2. Alert – events are in process or have occurred which involve an actual or potential substantial<br />

degradation of the level of safety of the plant or a security event that involves probable life<br />

threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any<br />

releases are expected to be limited to small fractions of the Environmental Protection Agency (EPA)<br />

Protective Action Guideline exposure levels.<br />

3. Site Area Emergency – events are in process or have occurred which involve an actual or likely<br />

major failures of plant functions needed for protection of the public or HOSTILE ACTION that<br />

results in intentional damage or malicious acts; (1) toward site personnel or equipment that could<br />

lead to the likely failure of or; (2) prevents effective access to equipment needed for the protection<br />

of the public. Any releases are not expected to result in exposure levels, which exceed EPA<br />

Protective Action Guideline exposure levels beyond the site boundary.<br />

Page 90 of 178


4. <strong>General</strong> Emergency – events are in process or have occurred which involve actual or imminent<br />

substantial core degradation or melting with a potential for loss of containment integrity or<br />

HOSTILE ACTION that results in actual loss of physical control of the facility. Releases can be<br />

reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more<br />

than the immediate site area. (Most severe).<br />

5. Recovery is an <strong>Exelon</strong> specific emergency classification; it is a condition of the station that may<br />

require substantial time and resources to exit. The situation has stabilized and no longer presents a<br />

hazard to the public, and requires specific criteria to be met prior to entering.<br />

IV. Emergency Alarms/Actions<br />

A. The response required for emergencies is to:<br />

1. Listen and respond to station alarms and announcements.<br />

2. Exit and/or stay out of affected areas.<br />

3. Proceed to designated assembly areas if required.<br />

4. If the station declares an Unusual Event an announcement will be made informing you of the<br />

circumstances and any required action. State and local governments and the NRC are notified of<br />

the event. It is at the next classification—the Alert—that the station begins to call upon additional<br />

Emergency Response Organization (ERO) members to supplement the station emergency<br />

organization.<br />

5. If station management declares an Alert, or a higher classification, an announcement will be made<br />

informing you of the circumstances and any required action.<br />

6. If a Site Area Emergency is declared, the site emergency alarm will sound and you will be directed<br />

to follow assembly and accountability instructions. You must listen to the announcement to ensure<br />

that you understand your expected actions.<br />

7. If a <strong>General</strong> Emergency is declared, the site emergency alarm will sound. All station personnel who<br />

are not part of the emergency response organization will be directed to evacuate the site and to go to<br />

the remote assembly area.<br />

B. Examples of emergency alarms are the:<br />

1. Reactor Building Evacuation Alarm – TMI \ Oyster Creek<br />

2. Station Emergency Alarm – TMI \ Limerick \ Peach Bottom \ Oyster Creek<br />

3. Assembly Alarm – Byron \ Braidwood \ Quad Cities \ LaSalle \ Dresden<br />

4. <strong>General</strong> Purpose Alarm – Clinton \ Peach Bottom \ Limerick<br />

5. Containment Evacuation Alarm – Clinton<br />

6. <strong>General</strong> Evacuation Alarm – Clinton \ Peach Bottom \ Limerick.<br />

Page 91 of 178


V. Emergency Plan Implementation Actions<br />

A. The response required for emergencies is to:<br />

1. Listen and respond to station alarms and announcements.<br />

2. Exit and/or stay out of affected areas.<br />

3. Proceed as instructed in the PA announcement.<br />

VI. Purpose of Accountability<br />

A. During an emergency, all personnel in the protected area must be accounted for to ensure their well<br />

being and location are known.<br />

B. Security must be able to provide a list of unaccounted personnel within 30<br />

minutes of the assembly accountability announcement. Station personnel need to<br />

use the accountability card readers as directed to help accomplish this.<br />

VII. Assembly Areas<br />

A. For each site’s assembly areas, see <strong>Exelon</strong> Site Specific Study Guide(s).<br />

VIII. Evacuation<br />

A. If an evacuation becomes necessary, all employees who are not part of the emergency response<br />

organization will be told the evacuation route to be taken.<br />

IX. Spokesperson<br />

A. A spokesperson is designated by the company to release information to the public and media. The<br />

Spokesperson will present information to media personnel at the respective site’s Joint Information<br />

Center (JIC). The JIC is normally activated following an Alert or higher emergency declaration. Prior to<br />

activation of the JIC, approved company information will come from Corporate <strong>Nuclear</strong><br />

Communications. If anyone asks for information, refer him/her to the company spokesperson or<br />

Corporate <strong>Nuclear</strong> Communications.<br />

X. Summary<br />

A. The <strong>Exelon</strong> <strong>Nuclear</strong> Emergency Plan (E-Plan) protects the public, employees, and station if an<br />

emergency occurs at the station.<br />

B. The five classifications of emergencies are:<br />

1. Unusual Event<br />

2. Alert<br />

3. Site Area Emergency<br />

4. <strong>General</strong> Emergency<br />

5. Recovery<br />

Page 92 of 178


C. The response required for emergencies is to:<br />

1. Listen and respond to station alarms and announcements.<br />

2. Exit and/or Stay out of affected areas.<br />

3. Proceed as instructed in the PA announcement.<br />

D. During an emergency, all personnel in the protected area must be accounted for to ensure their well<br />

being and location are known.<br />

E. If an evacuation becomes necessary, all employees who are not part of the emergency response<br />

organization will be told the evacuation route to be taken.<br />

F. A spokesperson is designated by the company to release information to the public and media.<br />

Page 93 of 178


Course/Program: <strong>General</strong> <strong>Employee</strong> <strong>Training</strong> Module/LP ID: Quality Programs<br />

Title: ! <strong>Exelon</strong> Quality Programs Course Code: N-N-GRP1I<br />

N-N-GRP2I<br />

N-N-GRP1R<br />

N-N-GRP2R<br />

Author: S. Morse Revision/Date: 5, 07/06<br />

Prerequisites: None Revision By: G. Kiss<br />

Page 94 of 178<br />

Est. Teach Time: 30 minutes<br />

OBJECTIVES<br />

From memory and in accordance with this lesson material, the trainee shall be able to:<br />

Objective # Objective Description<br />

1. Concerning the Quality Assurance Program:<br />

a. State the function of the Quality Assurance Program<br />

b. State the purpose of <strong>Nuclear</strong> Oversight (NOS) assessments<br />

c. State the role and authority of <strong>Nuclear</strong> Oversight<br />

d. Identify individual employee responsibilities with regard to QA<br />

2. Recognize the Defense-in-Depth Quality Model<br />

a. Recall the role of the Assessor and QV Inspector<br />

b. Recall the role of the employee<br />

c. Recall the role of the NRC & INPO<br />

3. Concerning Quality Verification (QV):<br />

a. State the function of QV<br />

b. State basic worker responsibilities regarding QV verification points/QV hold<br />

points<br />

c. State the role and authority of QV inspectors<br />

4. State company policy on harassment of <strong>Nuclear</strong> Oversight personnel<br />

5. Identify potential items of non-compliance<br />

6. State how individual employees identify and report concerns, problems or issues<br />

7. Explain how to report nuclear safety concerns to the <strong>Nuclear</strong> Regulatory Commission<br />

(NRC)<br />

8. Recognize appropriate <strong>Employee</strong> Conduct Expectations<br />

References:<br />

NEI-03-04, “PADS Guidelines for Plant Access <strong>Training</strong>”<br />

<strong>Exelon</strong> <strong>Nuclear</strong> Oversight procedures (NO series)<br />

" Copyright 2000 by <strong>Exelon</strong> <strong>Nuclear</strong>, All Rights Reserved. Permission for reproduction and use is reserved for <strong>Exelon</strong> <strong>Nuclear</strong>.<br />

(Any other use or reproduction is expressly prohibited without the express permission of <strong>Exelon</strong> <strong>Nuclear</strong>.)


I. Introduction<br />

A. Overview<br />

1. Quality work is essential to maintaining the safe operation of <strong>Exelon</strong>'s nuclear power plants. Each<br />

worker is responsible for quality. In turn, the company is committed to providing quality assurance<br />

programs to help keep our nuclear stations safe. Federal law also mandates Quality Assurance<br />

programs for all nuclear power plants.<br />

2. Upon completion of this section, you should be familiar with the purpose of the quality program,<br />

how the program is accomplished, and how to report quality-related problems.<br />

3. Highlighted portions of this lesson plan are <strong>Exelon</strong> specific material not covered in NEI 03-04.<br />

B. Purpose<br />

1. The purpose of this training is to provide information on Quality Program roles and reporting items<br />

of non-compliance. This training will allow workers to understand roles in Quality Programs and<br />

provide knowledge of appropriate reporting items of non-compliance in order to maintain safe<br />

working conditions in the plant.<br />

C. Objectives<br />

D. Statement of Evaluation<br />

1. Students will be evaluated by answering questions given on the examination with an accuracy of<br />

80% or better.<br />

II. Quality Assurance Program (QA)<br />

A. The function of the QA program is to provide adequate confidence that systems, structures and<br />

components will perform satisfactorily while in service. This includes:<br />

1. Examining products, services, activities, programs and processes to find out how effective individual<br />

and team efforts are in achieving and maintaining the level of quality.<br />

2. Using a comprehensive system of <strong>Nuclear</strong> Oversight (NOS) assessments to:<br />

a. Verify regulatory compliance with all aspects of the QA program.<br />

b. Evaluate the effectiveness of programs/processes, people, and<br />

systems/equipment/components<br />

c. Conduct Performance Based Assessments<br />

3. Surveillances to observe activities, hardware and/or review documentation to verify conformance<br />

with specified requirements and to evaluate their adequacy and effectiveness.<br />

4. <strong>Nuclear</strong> Oversight personnel may observe an entire job or individual steps within the job.<br />

Page 95 of 178


B. <strong>Nuclear</strong> Oversight personnel have stop work authority. This means they can stop work for concerns<br />

regarding quality or safety.<br />

C. Defense-in-Depth Quality Model<br />

1. The individual worker is the first “Line of Defense” with respect to ensuring quality work. It<br />

represents the best opportunity that <strong>Exelon</strong> <strong>Nuclear</strong> has to prevent events.<br />

2. Supervision and Management represent the second “Line of Defense” with respect to ensuring<br />

quality work and preventing events. Their opportunity to identify a problem before it causes an<br />

event is not as likely as the individual worker simply because they represent a much smaller<br />

population than the individual workers.<br />

3. <strong>Nuclear</strong> Oversight personnel including QV Inspectors and Assessors make up the third “Line of<br />

Defense” in preventing events at the Sites. They are independent of the work activities being<br />

performed. Their opportunity to identify problems before they cause events is even less than the<br />

individual workers, and Management/Supervision.<br />

4. External Assessment agencies such as the <strong>Nuclear</strong> Regulatory Commission (NRC) and the Institute<br />

of <strong>Nuclear</strong> Power Operations (INPO) represent the last “Line of Defense” to prevent events. If they<br />

identify a problem, then it has managed to avoid detection by the three barriers within <strong>Exelon</strong><br />

<strong>Nuclear</strong>. The identification of problems by the NRC and INPO represent a failure of our Self-<br />

Assessment processes.<br />

4. Finally, if all four barriers fail then an event will occur.<br />

D. Worker Responsibilities<br />

1. Individuals in the various line organizations are responsible for the quality of the work performed<br />

including the documentation.<br />

Page 96 of 178


2. Stop, Think, Act, Review (STAR) is used by the worker to evaluate his or her own work and<br />

actions.<br />

3. Each individual is responsible for performing the job in a quality manner and doing every job right<br />

the first time.<br />

4. Workers should never proceed in the face of uncertainty. If you are not sure of the consequences of<br />

your actions then ask someone before you proceed with the action. Start with your co-workers and<br />

Supervisor.<br />

III. Quality Verification<br />

A. Quality Verification (QV) is responsible for performing physical inspections, examinations, and<br />

measurements to verify that acceptable work has been performed and that pre-established characteristics<br />

of materials, structures, components, or systems have been met.<br />

B. QV personnel may observe an entire job or only a specific step in a job.<br />

C. QV Hold Points<br />

1. When performing a task, one may find a QV Hold Point in the document you are using. If one of<br />

these QV hold points is encountered in a procedure or work package, the individual is required to<br />

document compliance with the requirements prior to continuing with the task.<br />

2. This QV Hold Point requires one to have QV perform a QV independent inspection by observing,<br />

inspecting, or testing that point in the document before proceeding past that point in the document.<br />

3. Willful violation of the verification point or QV Hold Point is a serious action and is subject to<br />

disciplinary action up to and including termination of employment.<br />

D. QV personnel have stop work authority. This means they can stop work for concerns regarding quality<br />

or safety.<br />

IV. Harassment of <strong>Nuclear</strong> Oversight Personnel<br />

A. The quality program is required by federal law. Any threat, assault or interference with an inspector or<br />

assessor while performing his or her job is a federal offense punishable by a fine and/or imprisonment.<br />

V. Identifying Items of Non-compliance<br />

A. During a worker's day-to-day activities, something may be found that does not appear to be correct.<br />

These are potential non-compliance items and represent Conditions Adverse to Quality. Examples<br />

include:<br />

1. A part to be installed on a safety system that is not the correct part.<br />

2. A safety related valve stuck out of position and cannot be moved.<br />

3. Use of an out of date procedure.<br />

Page 97 of 178


The Corrective Action Program (CAP) requires the initiation of an Issue Report (IR) for Conditions<br />

Adverse to Quality. The condition may be significant enough to warrant a Root Cause Investigation and<br />

Corrective Actions to Prevent Recurrence.<br />

VI. Reporting Issues, Concerns, and Problems<br />

A. <strong>General</strong><br />

1. All employees have the duty to raise concerns regarding nuclear safety and quality-related issues<br />

that may affect safe operation of a nuclear plant.<br />

2. All employees have the right to raise concerns without fear of reprisal.<br />

B. Safety Conscious Work Environment (SCWE)<br />

1. A Safety Conscious Work Environment (SCWE) is an environment in which employees feel free to<br />

raise safety concerns without fear of retaliation.<br />

2. An SCWE also requires that concerns be prioritized and promptly resolved with feedback provided<br />

to the concerned employee.<br />

C. Chilling Effect<br />

1. Failure to foster a SCWE discourages employees and contract personnel from reporting safety and<br />

quality concerns or issues and results in a "chilling effect."<br />

2. A work environment in which a "chilling effect" has occurred is said to be a "Chilled Work<br />

Environment."<br />

a. Examples of Chilling Effect<br />

D. Protected Activities<br />

1) <strong>Employee</strong>s are reluctant to voice concerns for fear that they may be identified or retaliated<br />

against.<br />

2) <strong>Employee</strong>s or contractors are discouraged from raising concerns as a result of awareness of<br />

discrimination.<br />

3) Management fails to act promptly to deal with acts of intimidation.<br />

1. Federal laws protect employees who are engaged in protected activities associated with identifying<br />

and reporting safety issues or concerns.<br />

2. Examples of protected activities include:<br />

a. Raising concerns to employer or regulator (e.g., NRC or OSHA).<br />

b. Refusing to violate a NRC requirement.<br />

c. Testifying at a NRC proceeding.<br />

Page 98 of 178


d. Requesting the NRC to take action against an employer for a violation of NRC requirements.<br />

E. <strong>Employee</strong> Protection Regulations - Code of Federal Regulations<br />

1. 10 CFR 50.7, <strong>Employee</strong> Protection - Thou shall NOT discriminate against an employee because the<br />

employee raises a safety concern.<br />

2. Enforcement may be taken for violations committed by:<br />

a. Licensee<br />

b. Contractor / Subcontractor<br />

c. Individuals who participated in the violations<br />

3. NRC penalties may include:<br />

a. Notice of Violation (NOV)<br />

b. Order banning individual from licensed activities<br />

4. Protection is provided against Harassment, Intimidation, Retaliation, and Discrimination (H-I-R-D).<br />

F. <strong>Employee</strong> Protection Regulations - Department of Labor (DOL)<br />

1. Energy Reorganization Act of 1974, Section 211 - protects employees from retaliation and provides<br />

a personal remedy (e.g., restore job, recover lost wages, etc.).<br />

2. DOL investigates complaints, holds hearings, and may order employer to remedy past actions.<br />

3. Elements that must exist in order to warrant a Section 211 complaint:<br />

a. <strong>Employee</strong> was engaged in a protected activity<br />

b. Licensee was aware of the protected activity<br />

c. Licensee took adverse action against the employee<br />

d. There is a causal connection between the action taken and the protected activity<br />

G. Preferred Method for Reporting Concerns<br />

1. First Line Supervisors<br />

2. Other Management - Including Site Senior Management and Corporate Management (i.e., Chain of<br />

Command)<br />

3. Corrective Action Program<br />

4. <strong>Nuclear</strong> Oversight (NOS) / NOS Manager<br />

5. <strong>Employee</strong> Concerns Program<br />

Page 99 of 178


6. <strong>Nuclear</strong> Regulatory Commission (NRC) - <strong>Nuclear</strong> safety or quality concerns may be reported to the<br />

NRC at any time.<br />

H. Purpose of the <strong>Employee</strong> Concerns Program (ECP)<br />

1. Provide an alternate method for personnel to voice issues or concerns in regards to nuclear safety or<br />

quality that may impact the safe operation of the nuclear facilities.<br />

2. ECP investigates reports of concerns that have not been addressed when raised through the<br />

traditional methods such as through the management chain of command or through the Corrective<br />

Actions Program.<br />

3. ECP is not intended to replace the normal methods for reporting concerns or issues, but is provided<br />

for cases in which appropriate actions have not occurred.<br />

4. All other concerns or issues reported to ECP that are not relating to nuclear safety or quality are<br />

referred to the appropriate line organization for disposition.<br />

5. When an employee has a concern that he/she does not feel comfortable with reporting to their<br />

respective supervisor or through the normal management chain due to the sensitivity of the issue, or<br />

the traditional methods have failed, the employee can contact the <strong>Employee</strong> Concerns Program.<br />

I. Confidentiality<br />

1. Confidentiality is a cornerstone of the ECP process and is maintained to the highest degree<br />

achievable in all activities and endeavors of the <strong>Employee</strong> Concerns organization.<br />

2. Extensive measures are employed in ensuring that confidentiality is always maintained.<br />

a. All records are maintained in locked files with specific controls established for handling the<br />

documents.<br />

b. All information relating to reported concerns or issues, and all investigation activities and results<br />

are maintained in strict confidence on a need-to-know basis only.<br />

3. <strong>Employee</strong>s reporting concerns to the ECP may remain anonymous, or sign a confidentiality<br />

understanding that protects their anonymity to the highest degree achievable.<br />

J. How to Report a Concern to ECP<br />

1. Contact an <strong>Employee</strong> Concerns Investigator in person or via telephone.<br />

2. Contact the <strong>Employee</strong> Concerns Hotline<br />

1-877-724-7783 (1-877-72-I-S-S-U-E)<br />

K. Ownership of the <strong>Employee</strong> Concerns Program<br />

1. Overall responsibility for the <strong>Exelon</strong> <strong>Nuclear</strong> <strong>Employee</strong> Concerns Program for the <strong>Exelon</strong> nuclear<br />

fleet resides with the <strong>Nuclear</strong> Oversight Vice President.<br />

Page 100 of 178


2. Responsibility for implementation and administration of the <strong>Employee</strong> Concerns Program has been<br />

delegated to the <strong>Nuclear</strong> Oversight Programs Director. The NOS Programs Director reports directly<br />

to the NOS Vice President, thereby ensuring a totally independent reporting chain of command from<br />

the site line organizations, site management, and corporate line organizations.<br />

VII. <strong>Nuclear</strong> Regulatory Commission (NRC)<br />

A. If you feel that federal regulation violations are not getting adequate resolution, you may contact the<br />

<strong>Nuclear</strong> Regulatory Commission (NRC) directly. Addresses and telephone numbers for the NRC are<br />

posted on bulletin boards around the site.<br />

B. You may request a private interview with NRC inspectors. A worker who requests an interview or<br />

reports defects is protected from discrimination. Information on workers' rights can be found in<br />

10CFR19, which is posted on bulletin boards around the site.<br />

C. If an inspection is requested the NRC will:<br />

1. Keep the requester's identity anonymous.<br />

2. Protect the individual from being discharged by the company for filing the complaint.<br />

3. Notify the individual in writing if the complaint is rejected because no reasonable grounds exist.<br />

D. Plant management expects all employees to be truthful with all NRC requests for information.<br />

<strong>Employee</strong>s should conduct themselves with openness and a cooperative spirit when providing<br />

information to the NRC. The following will not be tolerated at any time:<br />

1. Falsifying records.<br />

2. Recognizing a violation of procedural requirements and not taking corrective action.<br />

3. Willfully providing, or causing someone else to provide the NRC with inaccurate or incomplete<br />

information.<br />

4. Willfully withholding safety-significant information from supervisory personnel.<br />

5. Submitting false information to gain unescorted access to a nuclear station.<br />

E. Willful misconduct by any employee or contractor will not be tolerated and will result in disciplinary<br />

action, fines and/or imprisonment.<br />

VIII. <strong>Employee</strong> Conduct Expectations<br />

A. Each individual must comply with the <strong>Exelon</strong> Code of Conduct or the contract requirements, as<br />

applicable:<br />

<strong>Exelon</strong> Code of Conduct:<br />

“Each of us is accountable for following the law, complying with <strong>Exelon</strong> and business unit policies and<br />

procedures, and striving to live up to our own values as well as those of <strong>Exelon</strong>. Committing an illegal<br />

or unethical act as an <strong>Exelon</strong> employee, agent, or contractor is never justifiable.” Failure to comply with<br />

Page 101 of 178


the <strong>Exelon</strong> Code of Conduct will result in disciplinary action, up to and including termination of<br />

employment.<br />

B. Title Ten to the Code of Federal Regulations Part 50.5 (10CFR50.5), Deliberate Misconduct, further<br />

establishes that if a nuclear worker is found to have intentionally, knowingly and consciously caused a<br />

violation of an NRC regulation or order, the individual may be subject to NRC enforcement. Sanctions<br />

that could be imposed on an individual for deliberate misconduct under 10 CFR 50.5 include revocation<br />

of their NRC license, orders prohibiting them from working in any regulated activity for a period of<br />

time, civil penalties, and/or criminal prosecution under various Federal Laws.<br />

C. Examples of behaviors that could cause individual workers to violate 10 CFR 50.5 include, but are not<br />

limited to:<br />

#$ Recognizing a violation of procedural requirements has taken place, even if it was you and even if it<br />

had no immediate consequence, and not reporting this<br />

#$ Knowingly falsifying any required records<br />

#$ Willfully providing, or causing someone else to provide, the NRC with inaccurate or incomplete<br />

information<br />

#$ Willfully creating, or causing someone else to create, an inaccurate or incomplete record<br />

#$ Willfully withholding safety-significant information from supervisory personnel or NRC inspectors<br />

#$ Consciously submitting false information to gain unescorted access to a nuclear station or avoid any<br />

other NRC requirement<br />

D. Again, willful misconduct by any employee or contractor will not be tolerated and may result in<br />

disciplinary action up to and including termination and/or civil penalties to include fines and/or<br />

imprisonment.<br />

IX. Summary<br />

A. The function of the QA Program is to provide adequate confidence that systems, structures, and<br />

components will perform satisfactorily while in service.<br />

B. QV is responsible for performing physical inspections, examinations, and measurements to verify that<br />

acceptable work has been performed and that pre-established characteristics have been met.<br />

C. Verification points and QV hold points requires one to have QV verify the acceptability of the specified<br />

work before proceeding past that point in the document.<br />

D. We are all responsible for preventing events at our stations. <strong>Nuclear</strong> Oversight is just one of several<br />

barriers to prevent unwanted and consequential events.<br />

E. <strong>Nuclear</strong> Oversight personnel have stop work authority.<br />

F. Harassment of <strong>Nuclear</strong> Oversight personnel will not be tolerated.<br />

G. Potential non-compliance items are items found that do not appear to be correct.<br />

H. The preferred method for reporting non-compliance items is through the management chain.<br />

I. If you feel that federal regulation violations are not getting adequate resolution, you may contact the<br />

NRC.<br />

Page 102 of 178


J. If an inspection is requested, the NRC will:<br />

1. Keep the requester's identity anonymous.<br />

2. Protect the individual from being discharged by the company for filing the complaint.<br />

3. Notify the individual in writing if the complaint is rejected because no reasonable grounds exist.<br />

K. Each individual must comply with the <strong>Exelon</strong> Code of Conduct or the contract requirements, as<br />

applicable.<br />

L. Willful misconduct by any employee or contractor will not be tolerated and will result in disciplinary<br />

action, fines and/or imprisonment.<br />

Page 103 of 178


Course/Program: <strong>General</strong> <strong>Employee</strong> <strong>Training</strong> Module/LP ID: Radiation Orientation<br />

Title: ! <strong>Exelon</strong> Radiological Orientation Course Code: N-N-GRP1I<br />

N-N-GRP2I<br />

N-N-GRP1R<br />

N-N-GRP2R<br />

Author: S. Morse Revision/Date:<br />

Page 104 of 178<br />

4 07/06<br />

Prerequisites: Revision By: G. Kiss<br />

Est. Teach Time: 30 minutes<br />

OBJECTIVES<br />

From memory and in accordance with this lesson material, the trainee shall be able to:<br />

Objective # Objective Description<br />

1. Define the following terms and state their differences:<br />

#$ radiation<br />

#$ radioactive material<br />

#$ contamination<br />

#$ dose<br />

2. Define background radiation and contrast the average amount of radiation received<br />

by radiation workers vs. members of the general public.<br />

3. State the federal limit for the declared pregnant worker.<br />

4. State the purpose of the thermoluminescent dosimeter (TLD) and the whole body<br />

contamination monitor (i.e., the exit portal monitor.)<br />

5. Identify potential long-term effects from exposure to low levels of radiation.<br />

6. Contrast the risk of working in a nuclear facility to the risk in other industries.<br />

7. State the colors and symbols used on radiological postings and identify the methods<br />

used to mark radiological areas, e.g., signs, ropes, tape.<br />

8. State the action(s) to be taken if a radiological area or radioactive material is<br />

encountered.<br />

References:<br />

Regulatory Guide 8.29, "Instruction Concerning Risks from Occupational Radiation Exposure"<br />

NEI 03-04, “PADS Guidelines for Plant Access <strong>Training</strong>”<br />

NRC Document 05-097, “NRC News” dated June 30, 2005<br />

RP-AA-270, “Prenatal Radiation Exposure”<br />

RP-AA-376, “Radiological Postings, Labeling, and Markings”<br />

" Copyright 2000 by <strong>Exelon</strong> <strong>Nuclear</strong>, All Rights Reserved. Permission for reproduction and use is reserved for <strong>Exelon</strong> <strong>Nuclear</strong>.<br />

(Any other use or reproduction is expressly prohibited without the express permission of <strong>Exelon</strong> <strong>Nuclear</strong>.)


I. Introduction<br />

A. Overview<br />

1. <strong>Exelon</strong> is committed to protecting the health and safety of workers, appropriately monitoring<br />

radiation and radioactive materials, and minimizing worker radiation exposure.<br />

2. Upon completion of this section, students should be familiar with the radiological restrictions placed<br />

on non-radiation workers and some of the basic risks associated with radiation.<br />

3. Highlighted portions of this lesson plan are <strong>Exelon</strong> specific material not covered in NEI 03-04.<br />

B. Purpose<br />

1. The purpose of this training is to provide information on radiation terminology, radiation exposure<br />

risks, use of dosimetry, and restrictions in Radiologically Controlled Areas. This training will allow<br />

workers to remain safe while working in a nuclear power station.<br />

C. Objectives<br />

D. Statement of Evaluation<br />

1. Students will be evaluated by answering questions given on the examination with an accuracy of<br />

80% or better.<br />

II. Basic Terminology<br />

A. All matter is composed of atoms. These atoms combine to form the different elements of nature.<br />

Sometimes, however, an atom may become unstable. When this occurs, an atom will emit packets of<br />

energy or particles, called radiation, in an effort to become more stable.<br />

1. Radiation, or radioactive decay, is the term used to describe the emission of energy or particles from<br />

the atom.<br />

2. Radioactive material is any material that emits radiation as it decays.<br />

3. Contamination is radioactive material where it is not wanted.<br />

4. Dose is the term used to describe the amount of radiation absorbed by the body or a particular organ.<br />

The unit of dose is rem or mrem.<br />

III. Background Radiation<br />

A. Background radiation is low-level radiation from natural or man-made sources. Some examples of<br />

background radiation sources are:<br />

1. cosmic radiation including the sun<br />

2. radon gas<br />

Page 105 of 178


3. fallout from weapons testing<br />

4. radioactive materials in the earth’s crust such as granite and coal<br />

B. The amount of background radiation a person receives is dependent upon a variety of factors, such as<br />

geographical location and altitude of the city in which he lives. On average, however, a person living in<br />

the United States receives about 360 mrem per year from exposure to background radiation. In contrast,<br />

the average nuclear power station worker in the United States receives about an additional 160 mrem per<br />

year from occupational exposure to radiation.<br />

IV. Federal Limit for Declared Pregnant Workers<br />

1. A pregnant employee should understand the potential effects of radiation on an embryo/fetus.<br />

10CFR20.1208 establishes a dose limit for the embryo/fetus.<br />

a. The Federal dose limit to the embryo/fetus of a declared pregnant worker is 500 mRem for the<br />

entire term of the pregnancy.<br />

V. Radiation Monitoring Devices<br />

A. An individual's dose from radiation exposure may be determined by using a radiation monitor. Several<br />

types of radiation monitors are used in a nuclear power station, each with its own particular purpose and<br />

application. For the nonradiation worker, there are only a few of these instruments that are of concern.<br />

They are as follows:<br />

1. The thermoluminescent dosimeter (TLD) is a small device that is used to<br />

record the amount of radiation to which an individual is exposed when in a<br />

radiologically controlled area (RCA). The TLD result is used as the<br />

permanent dose record for all radiation workers on site. Unless otherwise<br />

specified, it is worn on the front of the body about chest high.<br />

2. The whole body contamination monitor is used when you exit a<br />

Radiologically Controlled Area. This device checks personnel leaving the<br />

area for radioactive contamination.<br />

3. Portal monitors are used to detect personnel contamination as you exit the protected<br />

area. Report nuclear medicine procedures to Radiation Protection prior to the<br />

treatment. Examples include GI tests, Thyroid tests, or Thallium stress tests.<br />

VI. Health Effects of Low Levels of Radiation<br />

A. Research has shown that there is an increase in the risk of cancer and other potential illnesses due to<br />

exposures to high levels of radiation. Therefore, scientists feel it is prudent to assume that there may be<br />

a risk associated with low levels of radiation. Because of this, the federal government has established<br />

limits that are low enough to minimize this risk.<br />

Page 106 of 178


VII. <strong>Nuclear</strong> Power Station Risks<br />

A. The delayed effects of radiation exposure, such as cancer, are not a certainty but are expressed in terms<br />

of increased risk.<br />

B. Risks can also be expressed in terms of life expectancy. Following is a table from Regulatory Guide<br />

8.29 that compares the risk of working in a nuclear facility to the risk in other industries:<br />

Estimated Loss of Life Expectancy from Industrial/Health Risks<br />

Health and Safety Risk<br />

of Life Expectancy Loss (Average) Estimates of Days<br />

Smoking 20 cigarettes a day 6 years<br />

Overweight (by 20%) 2 years<br />

Alcohol consumption (U.S. average) 1 year<br />

All accidents combined 1 year<br />

Motor vehicle accidents 207 days<br />

Home accidents 74 days<br />

Construction Industry 227 days<br />

Agriculture 320 days<br />

All industrial hazards 60 days<br />

Occupational Radiation Exposure<br />

0.3 rem/y from age 18 to 65 15 days<br />

1 rem/y from age 18 to 65 51 days<br />

All natural hazards (earthquake, flood, etc.) 7 days<br />

Medical radiation 6 days<br />

VIII. Postings<br />

A. A variety of postings are used to identify specific areas. Some areas of the station are designated as<br />

Radiologically Controlled Areas (RCAs). Entering these areas require additional training. These areas<br />

are posted with signs that include the following characteristics:<br />

1. The background of the sign is yellow.<br />

2. The sign will have a trefoil/three bladed radiation symbol on it.<br />

3. The lettering and radiation symbol is magenta, purple or black.<br />

Page 107 of 178


B. The postings are usually in the form of signs but can also be in the form of a yellow and magenta rope or<br />

tape. Ropes will normally have a sign hanging from them providing more information about the specific<br />

requirements for the enclosed area.<br />

C. Personnel entering RCAs are responsible for reading and complying with associated postings and labels.<br />

D. Two common <strong>Exelon</strong> postings are as follows:<br />

1. “Caution – Radiation Area” is an area where an individual can receive a dose equivalent in excess of<br />

5 mrem in one hour at 30cm from the radiation source.<br />

2. “Caution – Contaminated Area” is an area that has smearable contamination present at levels greater<br />

than or equal to 1000dpm/100cm 2 beta/gamma or 20dpm/100cm 2 alpha.<br />

IX. Required Actions<br />

A. Should a radiological posting be encountered, do not enter the area or work on the equipment. The<br />

following are examples of activities that are not allowed unless you are a qualified radiation worker and<br />

are cognizant of radiological conditions prior to work:<br />

1. Removing a manway cover with a radiological posting attached.<br />

2. Working on a pipe that has yellow and magenta tape on it.<br />

3. Entering a radiologically controlled area to pick up trash or to retrieve a tool.<br />

X. Summary<br />

A. Radiation, or radioactive decay, is the term used to describe the emission of energy or particles from the<br />

atom.<br />

B. Radioactive material is any material that emits radiation as it decays.<br />

C. Contamination is radioactive material where it is not wanted.<br />

D. Dose is the term used to describe the amount of radiation absorbed by the body or a particular organ.<br />

The unit of dose is rem or mrem.<br />

E. Background radiation comes from natural or man-made sources.<br />

F. Radiation monitoring devices include:<br />

1. Thermoluminescent dosimeter<br />

2. Whole body contamination monitor<br />

3. Portal monitors<br />

G. Research has shown that there is an increase in the risk of cancer and other potential illnesses due to<br />

exposures to high levels of radiation. Therefore, scientists feel it is prudent to assume that there may be<br />

a risk associated with low levels of radiation. Because of this, the federal government has established<br />

limits that are low enough to minimize this risk.<br />

Page 108 of 178


H. Working in a nuclear power station is safe compared to other industrial/health risks.<br />

I. Radiological signs include the following characteristics:<br />

1. The background of the sign is yellow.<br />

2. The sign will have a trefoil/three bladed radiation symbol on it.<br />

3. The lettering and radiation symbol is magenta, purple or black.<br />

J. Should a radiological posting be encountered, do not enter the area or work on the equipment, unless<br />

you are a qualified radiation worker.<br />

Page 109 of 178


Course/Program: <strong>Nuclear</strong> <strong>General</strong> <strong>Employee</strong> <strong>Training</strong> Module/LP ID: RWT<br />

Title: ! <strong>Exelon</strong> Radiation Worker <strong>Training</strong> Course Code: N-N-GRP2I, N-N-<br />

GRP2R, N-N<strong>GET</strong>-<br />

RWT-I, N-N<strong>GET</strong>-<br />

RWT-R<br />

Author: S. Morse Revision/Date: 09 / 08-08<br />

Prerequisites: Completion of PAT <strong>GET</strong> Revision By: C. Knox<br />

OBJECTIVES<br />

Page 110 of 178<br />

Est. Teach Time: 8 hours<br />

Unless stated otherwise, the trainee shall perform the following from memory and in accordance with this<br />

text:<br />

Objective # Objective Description<br />

1. State the basic structure of an atom.<br />

2. Explain how radiation results from the nuclear process.<br />

3. List the sources of radiation in the station.<br />

4. State the four types of radiation found in a commercial nuclear power station.<br />

5. For each of the four types of radiation, explain the following:<br />

#$ Primary source<br />

#$ Penetrating ability<br />

#$ Methods of shielding<br />

#$ Exposure hazard<br />

6. Define the terms Dose Rate and Total Effective Dose Equivalent (TEDE).<br />

7. Calculate a total dose given a dose rate and a period of time.<br />

8. Perform conversions from Rem to millirem and from millirem to Rem.<br />

9. State the effect of radiation on cells.<br />

10. Define the following terms and explain the risks associated with each:<br />

#$ Chronic radiation exposure<br />

#$ Acute radiation exposure<br />

" Copyright 2003 by <strong>Exelon</strong> <strong>Nuclear</strong>, All Rights Reserved. Permission for reproduction and use is reserved for <strong>Exelon</strong> <strong>Nuclear</strong>.<br />

(Any other use or reproduction is expressly prohibited without the express permission of <strong>Exelon</strong> <strong>Nuclear</strong>.)


Objective # Objective Description<br />

11. Define “somatic” and “genetic” effects of radiation exposure.<br />

12. Explain the possible effects of radiation on an unborn child due to prenatal<br />

exposure.<br />

13. Compare the radiosensitivity of different age groups.<br />

14. State the purposes of the NRC Form-4.<br />

15. State the Federal radiation dose limits for:<br />

#$ Total Effective Dose Equivalent (TEDE)<br />

#$ Shallow Dose Equivalent (SDE)<br />

#$ Lens Dose Equivalent (LDE)<br />

#$ Total Organ Dose Equivalent (TODE)<br />

16. State the possible consequences if any Federal radiation dose limit is exceeded.<br />

17. State the <strong>Exelon</strong> Administrative Dose Control Level for TEDE and the<br />

administrative dose guidelines for LDE, SDE, and TODE.<br />

18. State the actions to be taken if an <strong>Exelon</strong> Administrative Dose Control Level or<br />

administrative guidelines are being approached.<br />

19. State the Federal dose limits for an embryo/fetus and the rights of a declared<br />

pregnant female.<br />

20. Define a Planned Special Exposure (PSE).<br />

21. State the purpose of ALARA.<br />

22. Describe the station ALARA program.<br />

23. Explain how time, distance, and shielding may be used to reduce dose, and state<br />

methods to implement each of these concepts.<br />

24. State the individual responsibilities regarding temporary shielding.<br />

25. Calculate stay time given a dose rate, current exposure, and an exposure<br />

limit.<br />

26. State the purpose of dosimetry.<br />

27. List the types of radiation detected by the following devices:<br />

#$ Thermoluminescent Dosimeters (TLD)<br />

#$ Direct Reading Dosimeter (DRD)<br />

Page 111 of 178


Objective # Objective Description<br />

28. Explain how to wear dosimetry devices properly including placement and<br />

orientation.<br />

29. State the modes, methods and frequency for operating and reading dosimetry.<br />

30. State where and when TLDs and DRDs are issued and returned.<br />

31. State the actions(s) to be taken if dosimetry is lost, damaged, off-scale, or<br />

alarming.<br />

32. State the types of contamination found in nuclear power stations and explain why<br />

contamination is controlled.<br />

33. State contamination units, sources, and indications.<br />

34. Explain methods to prevent the spread of contamination.<br />

35. Explain the individual’s actions for removing material from the RCA or<br />

Contaminated Area.<br />

36. Explain how to monitor personnel and personal items for contamination and<br />

actions to take if contamination is indicated.<br />

37. State the method for control of contaminated tools, equipment and materials.<br />

38. State the methods used to designate contaminated areas including postings and<br />

step-off pads.<br />

39. Explain the hazards associated with discrete radioactive particles including:<br />

#$ Methods to identify discrete radioactive particles<br />

#$ Sources of discrete radioactive particles<br />

#$ Work activities which cause discrete radioactive particles<br />

#$ Precautions to be used regarding discrete radioactive particles<br />

40. Explain situations that require personnel to exit a contaminated area.<br />

41. State four pathways for radioactive material to enter the body.<br />

42. State the methods used to limit the internal deposition of radioactive materials.<br />

43. State the processes by which radioactive material is eliminated from the body.<br />

44. State the methods used to determine the amount of radioactive material deposited<br />

in the body.<br />

45. Define the following:<br />

Page 112 of 178


Objective # Objective Description<br />

#$ Committed Effective Dose Equivalent (CEDE)<br />

#$ Annual limit on Intake (ALI)<br />

#$ Derived Air Concentration (DAC)<br />

46. Explain the relationship between DAC, ALI, CEDE and TEDE.<br />

47. Explain station conditions that may increase the potential for airborne<br />

radioactivity.<br />

48. State the function of a Radiation Work Permit (RWP).<br />

49. State the types of RWPs and the function of each.<br />

50. Extract information from an RWP.<br />

51. State the responsibility for complying with RWP requirements.<br />

52. Extract information from a survey map.<br />

53. State the required action(s) to be taken if the work scope or radiological<br />

conditions change so that they are not within the scope of the RWP.<br />

54. Define and recognize radiological areas and postings.<br />

54a. State the requirements to enter a HRA/LHRA.<br />

54b. Explain the proper response when finding a HRA/LHRA posting, barrier laying<br />

on the floor or access to HRA/LHRA unlocked and unguarded.<br />

55. State the potential consequences of violating, moving or altering a radiological<br />

posting.<br />

56. State the radiological alarms used in the station and explain the proper response to<br />

given radiological alarms.<br />

57. State the potential consequences of ignoring a radiological alarm.<br />

58. Define “radioactive waste”.<br />

59. Contrast the disposal costs of radioactive waste vs. non-radioactive waste.<br />

60. State the methods for reducing radioactive waste generation.<br />

61. Explain the importance of segregating contaminated waste from:<br />

#$ Clean/Non-contaminated waste<br />

#$ Wet waste<br />

Page 113 of 178


Objective # Objective Description<br />

#$ Hazardous waste<br />

62. State the rights and responsibilities of the worker with regard to radiation<br />

protection.<br />

63. State the purpose of protective clothing.<br />

64. Explain the steps for inspecting and donning protective clothing.<br />

65. Explain how to conduct work in contaminated areas.<br />

66. Explain how to read your dosimetry while wearing protective clothing in a<br />

contaminated area.<br />

67. Explain how to remove protective clothing and exit a contaminated area using<br />

step off pads.<br />

68. Explain how to perform whole-body frisk.<br />

69. Demonstrate inspecting and donning protective clothing and entering a simulated<br />

contaminated area using step off pads.<br />

70. Demonstrate removing protective clothing and performing a whole body frisk.<br />

References:<br />

10CFR20 - Code of Federal Regulation “Standards For Protection Against Radiation”<br />

INPO ACAD 00-007<br />

RP-AA-203 Exposure Control and Authorization<br />

RP-AA-210 Dosimetry Issue, Usage, and Control<br />

RP-AA-270 Prenatal Radiation Exposure<br />

RP-AA-350 Personnel Contamination Monitoring, Decontamination and Reporting<br />

RP-AA-376 Radiological Postings, Labeling, and Markings<br />

RP-AA-376-1001 Radiological Posting, Labeling, and Marking Standard<br />

RP-AA-401 Operational ALARA Planning and Controls<br />

RP-AA-403 Administration of the Radiation Work Permit Program<br />

RP-AA-410 Selection, Use and Control of Protective Clothing<br />

RP-AA-460 Unescorted Access To and Conduct In Radiologically Controlled Areas<br />

RP-AA-500 Radioactive Material (RAM) Control<br />

LaSalle Commitment – See ATI # 432081-02 (Item is located in Section XII. Radiation Work Permit,<br />

Items F.1 & 2)<br />

Page 114 of 178


I. Introduction<br />

A. Overview<br />

1. Radiation Worker <strong>Training</strong> (RWT) provides a worker with the knowledge and skills necessary to<br />

enter and work safely within a Radiologically Controlled Area (RCA). RWT contains the<br />

radiological training required for unescorted access to the RCA.<br />

2. Upon completion of this section, the student shall be able to discuss radiation and contamination<br />

principles.<br />

B. Purpose<br />

1. The purpose of this training is to provide information on the structure of an atom and on sources<br />

of radiation so one can remain safe while working in a nuclear power station.<br />

C. Objectives<br />

D. Statement of Evaluation<br />

1. Students will be evaluated by answering questions given on the examination with an accuracy of<br />

80% or better.<br />

2. Initial Radiation Worker <strong>Training</strong> requires satisfactory completion of a Dressout performance<br />

evaluation.<br />

II. Sources of Radiation<br />

A. Atomic Structure<br />

1. All matter is composed of atoms, which are the smallest part of an element that retains the<br />

characteristics of that element. Atoms, in turn, are composed of three primary components:<br />

a. proton - positively charged particle contained in the nucleus of an atom. The number of<br />

protons in the nucleus determine the characteristics of the element.<br />

b. neutron - neutrally charged particle also contained in the nucleus of<br />

an atom. It is approximately the same size as the proton.<br />

c. electron - negatively charged particle forming a cloud around the<br />

nucleus of an atom. The number of electrons in the cloud of an atom<br />

generally equal the number of protons in the nucleus. They have very<br />

little mass in comparison to the other two components of the atom.<br />

Page 115 of 178


B. Radioactive Decay<br />

1. When an atom is unstable due to the number of protons,<br />

neutrons, and electrons not being correctly balanced, it will emit<br />

packets of energy or particles to reach stability. It may require<br />

several emissions before becoming stable. These emissions are<br />

called radiation.<br />

2. Operation of a nuclear reactor creates unstable atoms by forcing<br />

a large, stable atom to accept an energized neutron or energized particle. The fission process, in<br />

which two or more smaller atoms are formed from splitting a larger atom, may also result in the<br />

creation of unstable atoms, the emission of radiation, and heat.<br />

3. Radiation may interact with an atom, causing the loss of an electron or multiple electrons. When<br />

an electron is removed, an ion pair is formed. This ion pair consists of a negatively charged<br />

electron and the remaining atom, which is positively charged since it now has more protons than<br />

electrons. This process is called ionization and can change the properties of the atom.<br />

C. Sources of Radiation<br />

1. The station contains many potential sources of radiation. Several examples are:<br />

a. reactor coolant - water that has been in the reactor.<br />

b. fission and activated corrosion products, e.g., cobalt and iron that have been exposed to<br />

radiation in the reactor and have been deposited on station components.<br />

c. reactor fuel<br />

d. reactor operations causing radiation<br />

e. filters that have had reactor coolant flowing<br />

through them<br />

f. reactor components that have been exposed to<br />

radiation<br />

III. Types and Measurement of Radiation<br />

A. Types of Radiation<br />

Page 116 of 178<br />

Just a little humor...<br />

Two atoms are walking down the street<br />

and they run into each other. One says to<br />

the other, “Are you all right?”<br />

“No, I lost an electron!”<br />

“Are you sure?”<br />

“Yeah, I’m positive!” #<br />

1. There are four basic types of ionizing radiation found in a nuclear power station. Each type has<br />

its own characteristics. The four types of radiation are:<br />

a. alpha<br />

b. beta<br />

c. gamma<br />

d. neutron<br />

...Some more #<br />

A neutron goes into a bar and asks the<br />

bartender, “How much for a beer?”<br />

The bartender replies, “For you, no charge!”


B. Characteristics of Radiation<br />

1. Alpha radiation is a particle. Its characteristics are as follows:<br />

a. Primary source is the reactor fuel.<br />

b. Has the least penetrating power of any of the four types identified above. Travel in air is just<br />

an inch or two.<br />

c. It can be shielded by a sheet of paper, by the dead layer of skin on the surface of the body, or<br />

by clothing.<br />

d. Is primarily an internal hazard. It may result in high dose to a sensitive organ if inhaled or<br />

ingested.<br />

2. Beta radiation is a particle originating from the nucleus of an atom. Its characteristics are as<br />

follows:<br />

a. Primary source is activated corrosion and fission products found in fluid within piping.<br />

b. Has more penetrating power than alpha but is limited to a few feet in air or a few layers of<br />

dead skin. It can be shielded by plastic or aluminum.<br />

c. Is primarily a hazard to the skin or lens of the eye. Personnel must work close to a beta<br />

source to receive a significant dose.<br />

3. Gamma radiation is not a particle; it is pure energy with no mass. Its characteristics are as<br />

follows:<br />

a. Primary sources include fission, fission products, and activation products within piping,<br />

including steam in a BWR.<br />

b. Has great penetrating power. It can penetrate the entire body. It is best shielded by very<br />

dense material like lead, steel and concrete. Water may also be used for shielding.<br />

c. Exposure to gamma radiation results in a whole body dose. The most common dose<br />

received at the station is a result of this type of radiation.<br />

4. Neutron radiation is part of the atomic nucleus that has been freed by decay or fission. Its<br />

characteristics are as follows:<br />

a. Primary source is nuclear fission.<br />

b. Has great penetrating power. It is best shielded by water or concrete.<br />

c. Exposure to neutron radiation results in a whole body dose. Most exposures to neutron<br />

radiation occur when personnel enter the containment or drywell while the reactor is<br />

operating.<br />

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C. Dose Rate and Total Effective Dose Equivalent (TEDE)<br />

1. Previously, dose was defined as "the amount of radiation absorbed by the body or a particular<br />

organ."<br />

2. The unit of dose is "Rem". The Rem estimates personal exposure to radiation. A sub-unit of<br />

dose is the "millirem" which is one one-thousandth (1/1000) of a Rem. This is usually<br />

abbreviated as "mRem."<br />

3. Dose rate is the amount of dose received in a specified period of time.<br />

4. The Total Effective Dose Equivalent (TEDE) is a measure of an individual's total whole body<br />

dose. It is determined by adding the external dose to the internal dose.<br />

a. External Dose – dose from energy emitted by radioactive materials (unstable atoms) that are<br />

outside the body. May be referred to as Deep Dose Equivalent (DDE), which is a whole<br />

body dose primarily from gamma radiation.<br />

b. Internal Dose – dose from energy emitted by radioactive materials (unstable atoms) that are<br />

inside the body (lung, stomach, etc.) referred to as Committed Effective Dose Equivalent<br />

(CEDE), which can be alpha, beta, or gamma.<br />

5. TEDE is expressed in terms of Rem or mRem.<br />

D. Calculate Total Dose<br />

1. The unit of dose rate is typically given in millirem per hour, or mRem/hr. If the dose rate of an<br />

area and the individual's time in this area are known, the total dose to the individual may be<br />

estimated as follows:<br />

a. dose rate x time in area = total dose<br />

b. For example, if an individual spent 4 hours in an area with a dose rate of 15 mRem/hr, the<br />

total dose received should be:<br />

E. Unit Conversion<br />

15 mRem/hr x 4 hours = 60 mRem<br />

1. If dose is given in Rem, this number may be converted to mRem by multiplying by 1,000. For<br />

example, 0.300 Rem is equal to 300 mRem. To convert from mRem to Rem, divide by 1,000.<br />

For example, 2,700 mRem is equal to 2.7 Rem.<br />

IV. Biological Effects<br />

A. Effects on Cells<br />

1. The human body is composed of millions of cells that, through natural processes, are always<br />

dying and being replaced by new cells. Excessive exposure to radiation may cause permanent<br />

damage or destruction of cells.<br />

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2. Radiation causes cell damage by ionizing atoms and molecules in the cell, which disrupts normal<br />

cellular chemistry. This radiation also damages chromosomes in the cell nucleus, which may<br />

impair the cell’s reproduction process.<br />

3. Four things may happen when cells are exposed to excessive amounts of ionizing radiation:<br />

a. Nothing<br />

b. Cell damage<br />

c. Cell death<br />

d. Cell mutation<br />

4. <strong>General</strong>ly speaking, radiosensitivity (cell’s ability to be affected by radiation), increases as the<br />

cell’s division rate and metabolism rate increase. For example, a child is much more sensitive to<br />

radiation dose than an adult.<br />

5. Radiation exposure, both internal and external, can cause adverse effects on the body. The effect<br />

on the body depends on:<br />

a. Area or organ of the body exposed to radiation.<br />

b. Type of radiation exposure.<br />

c. Length and amount of exposure.<br />

B. Chronic vs. Acute Exposure<br />

1. Exposure of an individual to radiation may occur over a short period of time or over months or<br />

years. Chronic exposure usually refers to repeated exposure to low levels of radiation over a<br />

long period of time. Acute exposure usually refers to a large dose of radiation received in a<br />

short period of time, usually less than 24 hours.<br />

2. Scientific studies show that chronic exposure to low levels of radiation may increase the chance<br />

of health problems such as cancer. A member of the general public receives about 360 mRem<br />

per year of chronic radiation, depending on the area of the country and other factors.<br />

3. Assuming whole body exposure, exposure to entire population and no medical treatment, the<br />

risks of health effects depending on the dose is as follows for acute exposure:<br />

a. 0 – 25 Rem No observable effects.<br />

b. 25 – 100 Rem Slight blood changes, no other observable effects.<br />

c. 100 – 200 Rem Vomiting may occur within 3 hours of exposure. Moderate blood changes<br />

are possible. Except for the blood-forming system, recovery will occur in essentially all<br />

cases within a few weeks.<br />

d. 200 – 600 Rem Vomiting for most people occurs within 3 hours. Loss of hair after 2<br />

weeks, severe blood changes, hemorrhaging, and infection. Death may occur. The recovery<br />

period is one month to one year.<br />

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e. 600 –1000 Rem Vomiting occurs within one hour. Other effects include severe blood<br />

changes, hemorrhage, infection, and hair loss. Probability of death is at least 80% within<br />

two months. Survivors convalesce (recover health) over a long period of time.<br />

C. Somatic and Genetic Effects<br />

1. Two classes of effects may occur due to exposure to radiation:<br />

a. Somatic effects<br />

b. Genetic effects<br />

2. Somatic effects occur in the individual that has received the radiation exposure. They are broken<br />

into two groups:<br />

a. Prompt or early effects appear shortly after the exposure (immediately or up to a few months<br />

post exposure). Prompt effects are generally considered the result of a large acute exposure.<br />

Some of the known prompt effects are skin reddening or nausea.<br />

b. Delayed effects occur months or years following an exposure. Since many of the delayed<br />

effects may also be caused by influences other than radiation exposure, it is difficult to<br />

positively assign the cause of the effect to radiation exposure. Delayed effects may result<br />

from acute or chronic exposure. Some of the known delayed effects of radiation are cancer<br />

and cataracts.<br />

3. Genetic effects appear in future generations of an individual who received the radiation dose.<br />

Genetic effects cause damage to genetic material and may appear as birth defects or other<br />

conditions in the future children of an exposed individual and succeeding generations. Studies<br />

have shown that the risk of genetic effects is very small.<br />

D. Effects on an Unborn Child<br />

1. The embryo/fetus is believed to be more sensitive to radiation damage than adults since it is<br />

rapidly developing. If the embryo/fetus is exposed to radiation, teratogenic (abnormal) effects<br />

may be observed in the child after birth. These effects, based on the amount of radiation<br />

received, can range from a slight increase in the chances of mental retardation, abnormal growth,<br />

structural abnormalities, to death.<br />

2. Due to the unborn child’s increased sensitivity to radiation, regulations contained in<br />

10CFR20.1208 impose stricter dose limits on the pregnant female who voluntarily notifies<br />

management of her condition. These limits will be covered in a later section.<br />

E. Effects of Age<br />

1. As discussed earlier in this section, radiation has a greater effect on cells that have a higher rate<br />

of reproduction. As a person ages, most cell reproduction rates slow. Therefore, the effects of<br />

ionizing radiation on the body lessen as an individual grows older.<br />

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F. NRC Form-4<br />

1. Before a station worker is allowed to receive any occupational exposure at the station, all<br />

previous occupational doses of radiation must be recorded on an NRC Form-4. Dose received<br />

during the current year at any other nuclear facility must be recorded and included in the<br />

accumulated dose for the individual and applied toward the exposure limit for the year.<br />

2. Before you will be allowed to work as a radiation worker, you must have a completed and signed<br />

NRC Form-4 on record. It is your responsibility to ensure all exposure is reported to the<br />

company prior to starting work in the station. This form will document all dose you receive for<br />

the entire year.<br />

V. Limits and Guidelines<br />

A. Federal Limits<br />

1. The United States <strong>Nuclear</strong> Regulatory Commission (USNRC) has established Federal dose<br />

limits for radiation workers based on the present understanding of the biological effects of<br />

radiation. The limits are set low enough to prevent prompt effects, to minimize delayed effects,<br />

and to ensure that risks due to radiation exposure are comparable with risks in other industries.<br />

2. Since effects on some parts of the body are greater than those to other parts, the USNRC has<br />

divided the body into different areas and established dose limits for each area. These limits are<br />

specified in Title 10 of the Code of Federal Regulations (CFR), part 20. The regulation states<br />

that no licensee shall allow any individual to receive a total occupational dose in excess of the<br />

following values:<br />

a. 5 Rem/yr. – Total Effective Dose Equivalent (TEDE) the sum of the internal dose and<br />

external dose.<br />

b. 15 Rem/yr. – Lens Dose Equivalent (LDE) dose to the lens of the eye.<br />

c. 50 Rem/yr. – Shallow Dose Equivalent (SDE) external exposure of the skin or extremities<br />

(elbows, lower arms, wrists, hands, knees, lower legs, ankles, and feet).<br />

d. 50 Rem/yr. – Total Organ Dose Equivalent (TODE) the sum of the external exposure and<br />

internal exposure to the organ receiving the highest dose.<br />

3. The regulations also state that the licensee should not allow radiation levels in unrestricted areas<br />

that may result in a member of the general population receiving greater than 100 mRem TEDE<br />

per year.<br />

B. Consequences of Exceeding Limits<br />

1. Exceeding the above Federal limits is a serious violation. Station management must evaluate<br />

any incident and report it to the NRC. Depending on the nature and severity of the event, one or<br />

more of the following consequences may occur:<br />

a. Increased risk of adverse health effects.<br />

b. NRC fine.<br />

c. Other NRC action against the station and/or individual.<br />

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d. Possible disciplinary action for willful violation, e.g., suspension of access to the RCA.<br />

C. <strong>Exelon</strong> Administrative Dose Control Levels (ADCL)<br />

1. The Administrative Dose Control Level (ADCL) for TEDE is 2000 mRem/yr.<br />

2. Administrative dose guidelines have been established to provide an additional measure of<br />

protection for the radiation worker. These guidelines will aid in reducing the potential for a<br />

worker to exceed Federal limits.<br />

3. The following administrative dose guidelines are in effect at all <strong>Exelon</strong> <strong>Nuclear</strong> sites:<br />

a. 12 Rem/yr. – Lens Dose Equivalent (LDE)<br />

b. 40 Rem/yr. – Shallow Dose Equivalent (SDE)<br />

c. 40 Rem/yr. – Total Organ Dose Equivalent (TODE)<br />

D. Approaching the Administrative Dose Control Level or administrative guidelines.<br />

1. It could happen that you find yourself about to reach your Administrative Dose Control Level or<br />

administrative dose guideline. It is possible to increase your allowed dose, but only if this is<br />

authorized prior to your current authorized levels being exceeded.<br />

2. The Radiation Protection Manager must review current dose and approve dose extension.<br />

3. Dose extensions are usually given in 500 mRem increments. If the Administrative Dose Control<br />

Level is being approached, the worker’s supervisor is responsible to take the appropriate actions<br />

to either extend the limits or to limit the exposure.<br />

E. Embryo/Fetus Dose Limit<br />

1. A pregnant employee should understand the potential effects of radiation on an embryo/fetus.<br />

10CFR20.1208 establishes a dose limit for the embryo/fetus.<br />

a. The Federal dose limit to the embryo/fetus of a declared pregnant worker is 500 mRem for<br />

the entire term of the pregnancy.<br />

b. An effort shall be made to avoid substantial variation above a uniform monthly exposure rate<br />

of 50 mRem or less of dose equivalent to the embryo/fetus.<br />

2. The above controls will be applied only to women who voluntarily declare their pregnancy or<br />

their intent to become pregnant. This declaration must be made in writing. It is voluntary and<br />

may be withdrawn at any time for any reason. The withdrawal must also be submitted in<br />

writing.<br />

3. Once a declaration of pregnancy is received, the worker will have the option of working in<br />

radiation areas with her dose restricted, or she may request reassignment to a position that has<br />

little or no radiation exposure.<br />

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F. Planned Special Exposure<br />

1. A planned special exposure is an infrequent exposure to radiation separate from, and in addition<br />

to, the annual federal dose limits.<br />

2. This type of exposure may be used only in an exceptional situation where alternatives that might<br />

avoid the higher exposure are unavailable or impractical.<br />

3. It is not anticipated that this type of exposure will be used; but in the unlikely event that it is,<br />

there are several requirements, including senior management approval.<br />

VI. Interim Summary<br />

A. Sources of Radiation<br />

1. An atom is composed of:<br />

a. protons<br />

b. neutrons<br />

c. electrons<br />

2. When an atom is unstable due to the number of protons, neutrons, and electrons not being<br />

correctly balanced, it will emit packets of energy called radiation.<br />

3. Examples of sources of radiation from a station are:<br />

a. reactor coolant - water that has been in the reactor<br />

b. fission and activated corrosion products<br />

c. reactor fuel<br />

d. reactor operations causing radiation<br />

e. filters that have had reactor coolant flowing through them<br />

f. reactor components that have been exposed to radiation<br />

B. Types and Measurement of Radiation<br />

1. The four types of radiation are:<br />

a. alpha<br />

b. beta<br />

c. gamma<br />

d. neutron<br />

2. Alpha radiation is primarily an internal hazard and can be shielded by a sheet of paper, dead<br />

layer of skin, or by clothing.<br />

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3. Beta radiation is primarily a hazard to the skin or lens of the eye and can be shielded by plastic<br />

or aluminum.<br />

4. Gamma radiation exposure results in whole body dose and is best shielded by lead, steel, and<br />

concrete.<br />

5. Neutron radiation exposure results in whole body dose and is best shielded by water or concrete.<br />

6. Dose rate is the amount of dose received in a specified period of time.<br />

7. The Total Effective Dose Equivalent (TEDE) is a measure of an individual's total whole body<br />

dose. It is determined by adding the external dose to the internal dose.<br />

C. Biological Effects<br />

1. Four things may happen when cells are exposed to excessive radiation:<br />

a. Nothing<br />

b. Cell damage<br />

c. Cell death<br />

d. Cell mutation<br />

2. Chronic exposure refers to repeated exposure to low levels of radiation over a long period of<br />

time.<br />

3. Acute exposure refers to a large dose of radiation received in a short period of time.<br />

4. Somatic effects occur in the individual that has received the radiation exposure.<br />

5. Genetic effects appear in future generations of an individual who received the radiation dose.<br />

6. The embryo/fetus is believed to be more sensitive to radiation damage than adults.<br />

7. The effects of ionizing radiation lessen as an individual grows older.<br />

8. Before being allowed to work as a radiation worker, you must have a completed and signed<br />

NRC Form-4 on record.<br />

D. Limits and Guidelines<br />

1. The USNRC has established and set dose limits low enough to prevent prompt effects and<br />

minimize delayed effects.<br />

2. Exceeding Federal dose limits is a serious violation. It is each individual’s responsibility to keep<br />

radiation exposure as low as reasonably achievable (ALARA).<br />

3. Administrative dose guidelines have been established to provide an additional measure of<br />

protection for the radiation worker.<br />

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4. It is possible to increase your allowed dose if authorized prior to your current authorized levels<br />

being exceeded.<br />

5. Embryo/fetus dose limit control can be applied only to women who voluntarily declare their<br />

pregnancy.<br />

6. A planned special exposure is an infrequent exposure to radiation separate from, and in addition<br />

to annual federal dose limits that may be used only in an exceptional situation where alternatives<br />

to avoid higher exposure are unavailable or impractical.<br />

VII. ALARA<br />

A. Purpose of ALARA<br />

1. ALARA is an acronym, meaning As Low As Reasonably Achievable.<br />

2. The purpose of ALARA is to keep the dose of both the individual and group involved with the<br />

performance of a task as low as reasonably achievable and still get the task accomplished. This<br />

includes internal as well as external dose.<br />

3. Required by 10CFR20 to have a formal ALARA program.<br />

B. Station ALARA Program<br />

1. A formal ALARA program represents a management commitment to minimize personnel dose.<br />

This program will help ensure that ALARA concerns are addressed in a systematic manner and<br />

will help make all employees aware of ALARA in their daily work activities.<br />

2. To make the ALARA program effective, several policies and procedures have been established.<br />

There have also been many methods to help reduce dose identified. These are as follows:<br />

a. Pre-job briefing<br />

1) Pre-job briefings can include active participation by RP personnel who may even<br />

physically provide RP coverage for the job.<br />

2) The pre-job briefing should also address any anticipated problem areas in performance<br />

of the task, available alternatives, and expected radiological protection impact.<br />

3) The purpose of a briefing is to ensure workers are aware of the dose rates and other<br />

conditions in these areas. This requirement will be stated on the posting for each area.<br />

You can obtain a briefing from any of the following sources:<br />

a) RP Desk<br />

b) ALARA pre-job brief<br />

c) Ops shift briefing (RP personnel will provide this information)<br />

b. Job planning including worker experience.<br />

c. <strong>Training</strong> using mockups.<br />

d. Use of radiological practices for dose reduction, such as temporary shielding.<br />

e. Engineering controls.<br />

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3. The individual worker is the most important part of the program. The worker’s actions on the<br />

job determine the dose received and, consequently, the success of the ALARA program.<br />

4. Workers must be alert to changing radiological conditions due to certain station operations such<br />

as:<br />

a. Radiography (testing welds with radioactive sources).<br />

b. Changes in reactor power level.<br />

c. Changes in system lineups.<br />

5. If abnormal radiation levels are noticed, workers should notify their co-workers, leave the area<br />

immediately and notify the RP Department.<br />

C. Time, Distance, and Shielding<br />

1. Time<br />

a. Time is one of the most important tools that you, the worker, can use in keeping dose to a<br />

minimum. Making the most efficient use of time in a radiation field will certainly be<br />

effective in reducing your exposure and, consequently, your dose.<br />

Example:<br />

Assume it takes a worker 20 minutes to adjust a valve using a wrench or 12 minutes using a<br />

ratchet. Using the ratchet will save a considerable amount of dose.<br />

b. Effective planning can also help reduce time. Take the few extra minutes necessary to keep<br />

dose down by:<br />

1) Talking to others about the job and area.<br />

2) Knowing what tools to take.<br />

3) Pre-fabricating where possible.<br />

4) Locating the work area on a map.<br />

5) Minimize crew size.<br />

c. Make sure you understand the job by:<br />

1) Reviewing the radiological survey data.<br />

2) Knowing what areas to avoid.<br />

d. Leaving the area as soon as the work is complete.<br />

2. Distance<br />

a. Distance is also a very effective way of reducing dose. In general, the greater the distance<br />

from a source of radiation, the less the dose received.<br />

b. The dose received may be greatly reduced by:<br />

1) Moving a small distance from the source.<br />

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3. Shielding<br />

2) Example – standing four feet from a valve instead of two feet can reduce your dose by as<br />

much as 75 percent assuming you are not moving closer to another source.<br />

3) Using extension tools.<br />

4) Utilize low-dose areas whenever possible.<br />

5) Stepping away from the radiation source when reading a procedure.<br />

6) Source term reduction – Removal or reduction of area dose rates by actions such as<br />

flushing, hydrolyzing, purging, or removing the component that is the source of<br />

radiation.<br />

a. Permanent and temporary shielding in the station can significantly reduce the dose you<br />

receive by reducing the intensity of a radiation field.<br />

D. Temporary Shielding<br />

1. For temporary shielding to be used, a total dose savings must be realized for the station. That is,<br />

the overall dose for the job, including the dose received during the installation and removal of<br />

the shielding, must be less to make it a sound ALARA decision.<br />

2. Whenever shielding is installed, it is important that workers do not tamper with the shielding, as<br />

this could drastically change the dose rates in the area. Stay clear of temporary shielding<br />

installations (i.e. do not sit, kneel, lay, etc. on shielding).<br />

3. If shielding is blocking the equipment you must work on or your tools, contact RP for resolution.<br />

E. Stay Time Calculation<br />

1. A time limit, called stay time, may also be imposed on an individual because of the amount of<br />

exposure the individual has already received and the dose rate in an area.<br />

2. Stay time is used to ensure an individual does not exceed a limit by restricting the amount of<br />

time allowed in a radiation field.<br />

3. Stay time can be calculated using the following formula:<br />

Stay time = Dose limit – Current dose<br />

Dose rate in the work area<br />

Example:<br />

Assume an employee has received 200 mRem of dose this year and the administrative limit is 1,000<br />

mRem. The employee is assigned to work in an area with a dose rate of 20 mRem per hour. How<br />

long could the individual work on this job before exceeding the limit?<br />

First determine the amount of dose the employee may still receive. Since 1,000 mRem is permitted,<br />

the 200 mRem has been received to date, the employee can receive 800 additional mRem.<br />

(1,000 – 200 = 800)<br />

A total of 800 mRem remains and the dose rate is 20 mRem per hour. Divide the amount allowed<br />

by the rate, or 800/20 = 40 hours. Forty hours is the stay time.<br />

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F. Unplanned Personnel Radiation Exposures<br />

Unanticipated radiological conditions or an individual’s disregard for radiological controls can result<br />

in unplanned and excessive radiation exposures. Very high radiation fields are present in certain<br />

areas of nuclear power plants during some activities. Entry into these high fields, even for a brief<br />

period, could result in the unnecessary exposure of personnel to doses several times greater than<br />

established limits and, in extreme cases, could jeopardize the health and safety of personnel.<br />

A review of industry events indicates a number of common factors that contribute to overexposures.<br />

Addressing these factors can significantly reduce the probability of an overexposure event occurring.<br />

VIII. Radiation Dosimetry<br />

A. Purpose of Radiation Dosimetry<br />

1. Dosimetry is used to determine the amount of external dose received by the worker.<br />

2. Use of dosimetry for personnel monitoring is important to ensure we stay within control levels<br />

for worker protection.<br />

B. Types of Dosimeters<br />

1. Many types of dosimeters are used in the industry. There are two basic types.<br />

a. Thermoluminescent Dosimeter (TLD)<br />

1) Measures external exposure to personnel while in the station.<br />

2) Does not provide real-time dose information. TLDs must be “processed” at a later time<br />

to determine dose to worker (TLDs are typically processed semi-annually).<br />

3) TLD is used for the permanent occupational external dose record. The TLD represents<br />

the radiation workers Dosimeter of Legal Record for external dose.<br />

4) TLD detects and measures dose from beta, gamma and neutron radiation. Skin and lens<br />

of eye dose can also be assessed.<br />

b. Direct-Reading Dosimeters (DRD).<br />

1) Electronic Dosimeters (ED)<br />

a) Worn in close proximity to TLD (i.e. hands width, within 6<br />

inches) and provide a real-time estimate of dose received<br />

while on the job.<br />

(1) When wearing protective clothing, electronic dosimeters are required to be<br />

worn in the external pocket or on an outside loop, such that it is easily read<br />

by the wearer. (FME controls must be implemented to prevent loss).<br />

b) Also provide general area dose rate information.<br />

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c) Have various alarms that activate if some preset conditions are exceeded.<br />

d) Designed to measure gamma radiation.<br />

2) Pocket Ion Chambers<br />

C. Wearing Dosimetry Devices<br />

a) Provides a real-time estimate of dose received while on the job.<br />

b) Designed to measure gamma radiation.<br />

c) Since the introduction of EDs, the use of Pocket Ion Chambers<br />

has dramatically decreased. They may be used in emergency kits or other instances<br />

where an ED reader is not readily available. Pocket Ion Chambers do not have alarm<br />

capabilities.<br />

1. Dosimetry should be worn on the front of the body between the waist and shoulders, (normally<br />

at chest height), unless otherwise specified on the RWP. Wear the primary (TLD) and<br />

secondary (electronic) whole body dosimeters within six inches or less of each other on the chest<br />

region unless otherwise specified by Radiation Protection Supervision or the RWP.<br />

2. The TLD beta window should face away from the body and be located next to the ED or Pocket<br />

Ion Chamber if used.<br />

3. Additional or special dosimeters may be required for certain jobs where the dose rates to areas of<br />

the body may be higher than those to the chest region (i.e., when work is being performed in<br />

non-uniform dose rate fields where worker to source orientation is subject to change). A<br />

Wireless Remote Monitor (WRM) may also be attached to the ED as a dose reduction tool. RP<br />

can remotely monitor an individual’s accumulated exposure and working does rate.<br />

4. For multiple TLD and extremity placements, the most conservative reading will be recorded on<br />

the legal record in the respective category.<br />

D. Use of Dosimeters<br />

NOTE<br />

ED readings have been affected by cell<br />

phones, plant radios, microwaves, and arc<br />

welding.<br />

1. The TLD should be handled with care and not tampered with; note that the only way to obtain<br />

any information from the TLD is through the use of a special TLD reader and associated<br />

software.<br />

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2. The ED has two modes of operation:<br />

a. A button on the ED allows you to change from the dose to the dose rate mode of operation<br />

and vice versa.<br />

b. Each mode has an active preset alarm that will sound when the thresholds have been<br />

exceeded, regardless of the mode you are in.<br />

c. The Accumulated Dose Mode: Provides a readout of estimated dose in units of mRem.<br />

After activating an ED, VERIFY the display indicates 0 mRem. If not, return the ED.<br />

1) Accumulated Dose Alarm: The dose alarm will activate if the preset accumulated dose<br />

threshold has been exceeded. An alternating tone indicates the alarm for accumulated<br />

dose. The Dose Rate Mode: The dose rate mode gives an estimate of the current dose<br />

rate.<br />

d. Dose Rate Alarm: The dose rate alarm is activated when your dose rate is greater than the<br />

preset allowable dose rate.<br />

1) The dose rate alarm will stop if you move to an area that is below the predetermined<br />

dose rate setpoint. An audible steady tone indicates an alarm.<br />

2) The ED should never be used by personnel as a hand held dose rate meter.<br />

3. Remember to review your Radiation Work Permit (RWP) for instructions regarding the dose and<br />

dose rate alarms prior to entering the RCA.<br />

4. Be sure you check your dosimetry frequently, especially when working in areas with high noise<br />

levels. Check with Radiation Protection for the availability of an adaptor, which when attached<br />

to the ED vibrates when alarming.<br />

a. While working in a Radiologically Controlled Area, you are expected to check your<br />

Electronic Dosimeter frequently in Radiation Areas and more frequently in High Radiation<br />

Areas. You are also expected to exit the area prior to receiving your cumulative alarm.<br />

5. The Pocket Ion Chamber is read by looking through the barrel part while pointing the Pocket Ion<br />

Chamber at a light source.<br />

6. The Pocket Ion Chamber scale should be horizontal.<br />

7. The Pocket Ion Chamber should not be subjected to shock or high humidity since these<br />

conditions could affect its accuracy.<br />

E. Obtaining and Returning Dosimetry<br />

1. Electronic Dosimetry<br />

a. EDs are obtained before entering the RCA and are “logged in” and activated by a<br />

computerized access control system that sets the appropriate accumulated dose/dose rate<br />

thresholds designated by the selected RWP.<br />

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. When exiting the RCA, individuals will return their ED to storage after the dosimeter is<br />

“logged out” by the computerized access system. Individuals MUST return EDs that are<br />

“logged out” to storage.<br />

2. TLDs<br />

a. TLDs are obtained through Dosimetry of the Radiation Protection Department.<br />

b. The TLD shall be stored with the security badge or key card when not in use.<br />

c. Return the TLD to Dosimetry upon termination of the badge.<br />

d. Do NOT put the TLD through the x-ray machine.<br />

F. Actions for Abnormal Conditions<br />

1. When working in the RCA, several conditions will require you to take action. Some of these are<br />

as follows:<br />

a. If you should discover any of your dosimetry lost, damaged, or missing, you should place<br />

your job in a safe condition, immediately leave the RCA and report to RP.<br />

b. If while on the job you discover your dosimeter is alarming:<br />

IX. Contamination<br />

1) Dose Rate Alarm: place your job in a safe condition, immediately notify your<br />

coworkers, leave the RCA and notify RP UNLESS directed otherwise by RP.<br />

2) Accumulated Dose Alarm: place your job in a safe condition, immediately notify your<br />

coworkers, leave the RCA and notify RP.<br />

3) If the dosimeter does not appear to be working correctly or damaged, leave the RCA and<br />

return the defective dosimeter to RP.<br />

A. Types of Contamination<br />

1. Contamination is defined as radioactive material where it is not desired. The two major sources<br />

of contamination at a nuclear station are fission products and activated corrosion and wear<br />

products such as rust or metal fragments. In either case, these products are transported<br />

throughout the systems that carry reactor water and steam. Leaks and maintenance activities in<br />

these systems may allow radioactive materials to be released and to accumulate on the walls and<br />

floors. This creates a contamination problem for personnel who have to work in these areas and<br />

may also contribute to a hot particle problem.<br />

2. Fixed contamination<br />

a. Fixed contamination is surface contamination that has become embedded in an object so that<br />

it cannot be removed using normal cleaning methods.<br />

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. Fixed contamination can become airborne or be spread through activities such as grinding or<br />

welding.<br />

c. Fixed contamination can become loose surface contamination through the process of<br />

leaching.<br />

3. Loose surface contamination<br />

a. Loose surface contamination is contamination that is loosely adhered to an object or surface.<br />

b. This type of contamination is sometimes referred to as “smearable” contamination.<br />

c. Two problems associated with loose surface contamination are:<br />

1) It is easily transferred to another area or person.<br />

2) It can become airborne if disturbed.<br />

d. Discrete radioactive particles<br />

1) Discrete radioactive particles are very small radioactive particles that may be too small<br />

to be seen.<br />

2) These particles can be highly radioactive and can cause a high dose to a very small<br />

localized area of the skin.<br />

3) If ingested, a discrete radioactive particle can give a large dose to an internal organ.<br />

B. Contamination Units, Sources, and Indications<br />

Because contamination is radioactive, it is measured by the level of activity. The more<br />

contamination there is, the higher the activity will be.<br />

1. The units for measuring contamination are counts per minute (cpm) or disintegrations per minute<br />

(dpm) per unit area. This is typically dpm/100cm2.<br />

2. Potential sources of contamination include:<br />

#$ spills and leaks from a system carrying reactor water<br />

#$ open contaminated systems<br />

#$ grinding on equipment with fixed contamination<br />

#$ disassembly of a station component with internal contamination<br />

Therefore, when working in an area or on a system that is potentially contaminated, be sensitive to<br />

indications of contamination.<br />

3. The following are examples of potential indications of contamination:<br />

#$ reactor water is leaking from a pipe, pump, or valve<br />

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#$ a pipe is being removed from a potentially contaminated system<br />

#$ maintenance on a potentially contaminated system<br />

#$ water standing on the floor near or under a contaminated system<br />

#$ a rise in frisker counts or a frisker alarm<br />

You should use care around potentially contaminated systems because you may contaminate yourself or<br />

spread contamination around the station.<br />

C. Methods to Prevent the Spread of Contamination<br />

1. It is important not to spread contamination. If contamination were not controlled, it could<br />

eventually be spread to areas where it is not wanted. This could result in unnecessary<br />

radioactive waste, lost time, unmonitored dose, and increased costs associated with subsequent<br />

clean-up efforts.<br />

2. There are several methods that are effective in preventing the spread of contamination. These<br />

include:<br />

#$ Planning a job and use of pre-job briefings<br />

#$ Using protective clothing when working in a contaminated area. Protective clothing<br />

information is discussed later in the Protective Clothing module<br />

#$ Using the nearest contamination monitor when exiting a contaminated area<br />

#$ Avoiding water that is around or under a contaminated system<br />

#$ Securing hoses or cords that extend from a non-contaminated area to a contaminated area<br />

#$ Using catch containments, glove bags, or absorbent material<br />

#$ Using step-off-pads and warning signs<br />

#$ Decontamination of surfaces and components prior to start of work AND after work is<br />

complete<br />

#$ Restricting entrance to contaminated areas or to potentially contaminated areas that are not<br />

routinely monitored for contamination<br />

#$ Using engineering controls such as temporary ventilation with special filters and use of<br />

specially designed enclosures<br />

#$ Keeping the workplace clean.<br />

#$ Use good work practices to prevent the spread of contamination.<br />

D. Removing Material From the Radiologically Controlled Area (RCA) or Contaminated Area<br />

1. All material, including notebooks, tools, parts, flashlights, etc., to be removed from a<br />

Radiologically Controlled Area (RCA), must first be surveyed for contamination.<br />

a. A hand-held frisker and the Small Articles Monitor (SAM) are examples of devices used to<br />

survey items out of the RCA.<br />

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. The hand-held frisker is used by RP only to survey items for release.<br />

c. Personal articles can be surveyed out of the RCA, through the SAM, by a radiation worker<br />

provided they were not used in a contaminated area. Note: Radiation worker authorization<br />

for use of the SAM is dictated by station policy.<br />

d. If material is found not to be radioactive then it may be released from the RCA.<br />

e. If material is found to be radioactive:<br />

1) RP will label material.<br />

#$ Material with dose rates greater than 2 mRem/hr on contact or has smearable<br />

contamination will be tagged with radiological information.<br />

#$ Material with dose rates less than 2 mRem/hr on contact and no smearable<br />

contamination is labeled solely, “Caution – Radioactive Material”.<br />

2) Radioactive material must be escorted by RP if transported or used outside of the RCA.<br />

E. Personnel Contamination Monitoring<br />

1. Primary methods used to monitor personnel contamination are the Frisker and the Personnel<br />

Contamination Monitor. The PCM is the preferred equipment.<br />

2. Frisker:<br />

USE THE CLOSEST CONTAMINATION<br />

MONITOR AVAILABLE WHEN EXITING<br />

A CONTAMINATED AREA.<br />

a. The frisker has a hand-held probe that is slowly passed over the area of interest and a meter<br />

that indicates contamination in units of Counts Per Minute (CPM).<br />

b. To use the frisker, perform the following:<br />

1) Verify the unit is ready for use:<br />

a) The frisker is on<br />

b) Set to the times one (X1) scale<br />

c) Volume is up<br />

d) Calibration sticker and daily source check is current<br />

2) Check background radiation.<br />

a) If greater than the specified background count rate (300 cpm), call RP. RP may ask<br />

you to move to another frisker.<br />

b) A preliminary survey may be performed in an area >300cpm prior to transit to a<br />


3) Frisk hands prior to handling the probe.<br />

a) Survey should be performed at a speed of approximately 2 inches per second at a<br />

maximum distance of ½ inch.<br />

4) Frisk all sides of hand-held items such as dosimetry.<br />

5) Frisk entire body with the probe.<br />

a) It should take approximately 2-5 minutes to frisk entire body.<br />

b) Recommended order:<br />

#$ Head and hardhat (pause at mouth and nose)<br />

#$ Neck and shoulders<br />

#$ Arms (pause at each elbow)<br />

#$ Chest and abdomen<br />

#$ Back, hips, and seat of pants<br />

#$ Legs (pause at each knee)<br />

#$ Shoe bottoms ( pause at sole and heel)<br />

#$ Shoe tops<br />

#$ Dosimetry<br />

c) Carefully return probe (face up or side for next person) and leave area.<br />

d) If the frisker reads greater than 100 counts above background at any time during the<br />

frisk, re-monitor the area. If contamination is verified or suspected, remain in the<br />

area and contact RP for assistance.<br />

3. Personnel Contamination Monitor<br />

Examples of personnel contamination monitors are the Personal Contamination Monitor (PCM), IPM7,<br />

and APTEC.<br />

a. To use a monitor, enter the monitor and follow the directions. Note: Hand held items such<br />

as gloves and paperwork are monitored by use of a SAM.<br />

b. If the monitor does not alarm, exit the monitor and proceed as normal.<br />

c. If the monitor alarms:<br />

1) Re-monitor.<br />

2) If monitor alarms again, STOP, contact RP. Avoid spreading contamination by<br />

controlling your movement, and minimize contact with any other person or items.<br />

USE THE CLOSEST CONTAMINATION<br />

MONITOR AVAILABLE WHEN EXITING A<br />

CONTAMINATED AREA.<br />

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F. Control of Contaminated Materials<br />

1. When working on contaminated systems, it is possible to contaminate tools, equipment or<br />

materials. Company policy is to minimize the contamination of these materials.<br />

2. Some of the things that you can do to help in this effort are:<br />

a. Minimize the amount of material contaminated while on the job. Use only those tools that<br />

are necessary.<br />

b. Do not take packing material into the RCA and minimize the amount of trash generated in<br />

the RCA.<br />

c. When working in a contaminated area, use tools with fixed contamination, when possible.<br />

d. If a contaminated article needs to be taken out of a contaminated area, it should be bagged<br />

and clearly labeled. It is to be surveyed by RP prior to removal.<br />

G. Contamination Area Postings<br />

1. Signs warning of known contaminated areas are used in the station. These areas are:<br />

a. Contamination Area – This is an area that has greater than 1,000 dpm/100 cm 2 of beta plus<br />

gamma. Entering this area requires RWP authorization. The RWP will specify entry<br />

requirements.<br />

b. An area designated as a Contamination Area will be posted. The area is typically roped off<br />

with yellow and magenta rope with signs hanging from the rope with the area designation.<br />

There is an entrance and exit to the area with a step-off pad. These are the only authorized<br />

ways in and out of the area.<br />

c. Do not enter the area or reach over the ropes unless authorized by RP.<br />

Failure to adhere to these requirements can result in the spread of contamination, personnel contamination,<br />

and disciplinary actions.<br />

NOTE<br />

Overhead areas are not routinely surveyed and in many cases are<br />

contaminated. Workers can not access overhead areas without informing<br />

RP so that proper controls can be established.<br />

H. Discrete Radioactive Particles<br />

As mentioned earlier, discrete radioactive particles are very small but can deliver a large localized<br />

dose.<br />

1. There are several ways to identify a discrete radioactive particle:<br />

a. When frisking, a discrete radioactive particle can cause the meter to rapidly rise to a much<br />

higher count rate. The frisker will respond only if it is close enough to the discrete<br />

radioactive particle.<br />

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. The whole body personnel contamination monitor is effective in finding discrete radioactive<br />

particles.<br />

2. Discrete radioactive particles originate in the nuclear fuel or from corrosion products.<br />

Therefore, work that involves systems connected to the reactor or systems with activated<br />

corrosion products may expose workers to discrete radioactive particles.<br />

3. Some precautions that should be used in areas that may contain discrete radioactive particles are<br />

careful review of the RWP survey map for discrete radioactive particle contamination areas, use<br />

of Protective Clothing as required by the RWP, and careful monitoring for discrete radioactive<br />

particles when exiting the area.<br />

I. Conditions Requiring Exiting a Contaminated Area<br />

1. Some unusual situations may require exiting the contaminated area immediately. Insure you<br />

follow the direction of site announcements and Radiation Protection. If any of the following<br />

occur, place the job in a safe condition, immediately leave the area, and contact Radiation<br />

Protection:<br />

a. Cut or torn Protective Clothing<br />

b. Cuts, abrasions, or any other type of open wound<br />

c. Protective Clothing wet from a leak or spill<br />

d. Directed to leave by RP<br />

e. Lost or damaged dosimetry<br />

f. As directed by alarms, sirens, or announcements from the Control Room.<br />

X. Internal Radiation Exposure<br />

A. Methods of Internal Deposition<br />

1. There are four primary methods that will allow radioactive material in the body.<br />

a. Inhalation – breathing it in<br />

b. Ingestion – eating, drinking, chewing or swallowing<br />

c. Absorption – absorbing it through the skin<br />

d. Open wounds – entering through an open wound or sore. Make sure all wounds are<br />

identified to RP prior to entering RCA.<br />

B. Methods to Limit Internal Deposition of Radioactive Materials<br />

1. No eating, drinking, smoking, or chewing within the RCA unless specifically allowed by RP.<br />

2. Use S.T.A.R. when entering an RCA. Check yourself for contraband items (i.e. – cigarettes,<br />

chewing tobacco, gum, candy, lozenges, etc.).<br />

NOTE<br />

Water is provided in clean areas where there are<br />

heat stress concerns. Monitoring for<br />

contamination is required prior to entry into<br />

these areas.<br />

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3. Engineering and workplace controls should be the primary mechanisms for maintaining internal<br />

radiation doses to workers as low as reasonably achievable (ALARA).<br />

a. Engineering controls can limit internal exposure by establishing conditions that improve the<br />

radiological environment for workers:<br />

1) Install ventilation systems with temporary filters, commonly known as HEPA filters<br />

2) Isolate potentially radioactive steam leaks<br />

3) Shifting ventilation flowpaths<br />

4. Use of respirators/other protective equipment<br />

a. TEDE must be considered prior to wearing a respirator.<br />

b. It normally takes longer to accomplish a task wearing a respirator.<br />

5. Keeping track of time limits and the use of monitoring devices while in a contaminated area.<br />

C. Elimination of Internal Depositions<br />

1. There are two basic processes that eliminate internal depositions:<br />

a. Biological Processes- Natural bodily mechanisms will cause many types of internal<br />

deposition to be eliminated from the body.<br />

b. Radioactive Decay--Radiological decay lowers the amount of radioactivity in the body as<br />

time passes. The amount of time required for a radionuclide to decay is dependent on the<br />

isotope and can vary from seconds to many years (this is called radiological half-life).<br />

D. Measuring Internally Deposited Activity<br />

1. There are three primary ways to determine the amount of internal radioactivity.<br />

a. Whole Body Count:<br />

1) A device used to directly measure and identify the radioactivity/contamination deposited<br />

in or on the body.<br />

b. Bioassays:<br />

1) A laboratory evaluation of biological material (usually a urine or fecal sample) for<br />

purposes of estimating the quantity of radioactive material in the body.<br />

2) This technique may be required when the presence of non-gamma emitting radionuclides<br />

is suspected (i.e., whole body counter cannot detect such radionuclides).<br />

c. Whole Body Screen/Passive Monitoring<br />

1) A simple survey of workers to evaluate the presence of significant internal radioactivity.<br />

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E. Internal Dose <strong>General</strong> Concepts & Terminology<br />

1. The mouth and nose are the most common pathways for the intake of radioactive material.<br />

Federal law limits the amount of internal dose.<br />

a. Committed Effective Dose Equivalent (CEDE) - the amount of assigned internal dose that<br />

relates organ dose to the whole body dose.<br />

b. Annual Limit on Intake (ALI) - the amount of airborne radioactive material you would<br />

have to breath in to receive a CEDE of 5 Rem effective dose equivalent or 50 Rem to any<br />

organ. Each individual is limited to one ALI per year.<br />

c. Derived Air Concentration (DAC) - the concentration of radioactive material in air which<br />

would result in a volume (and equivalent dose) of one ALI if breathed for 2000 hours.<br />

1ALI=2000 DAC-hrs<br />

F. Relating CEDE, ALI, DAC and TEDE<br />

1. Since 5 Rem internal exposure is equivalent to 2000 DAC-hrs., 1 DAC-hr. is equivalent to 2.5<br />

mRem (5000 mRem/2000 DAC-hr.=2.5 mRem/DAC-hr.).<br />

2. TEDE (Total Effective Dose Equivalent) is the sum of the external whole body dose (Deep Dose<br />

Equivalent) and the internal whole body dose (Committed Effective Dose Equivalent).<br />

DDE + CEDE = TEDE<br />

Problem: A worker is assigned the task of repairing a door in a radiological area. The area has a<br />

dose rate of 24 mRem/hr and also has some airborne radioactivity. From experience with this door,<br />

the worker knows it will take 2 hours and 20 minutes to make the repair with a respirator or 2 hours<br />

without a respirator. If the job is done without a respirator, he will receive two DAC-hours internal<br />

exposure.<br />

Q: If the worker wears a respirator, what will the total dose be?<br />

A: The total dose will be: 24 mRem/hr x 2.33 hr = 56 mRem.<br />

Q: If the worker does not wear a respirator, what will the total exposure (TEDE) be?<br />

A: The total dose will be: (24 mRem/hr x 2 hr) + (2 DAC x 2.5 mRem/DAC) = 53 mRem.<br />

Q: Which worker received less dose?<br />

A: The worker not wearing the respirator.<br />

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G. Airborne Radioactivity Hazards<br />

1. It is extremely important to remember that there are many types of activities you may become<br />

involved with in the RCA that can increase the amount of airborne radioactivity, and hence your<br />

potential internal exposure:<br />

a. brushing or sweeping<br />

b. fans blowing in dusty areas<br />

c. steam leaks<br />

d. sanding, grinding, or welding on a contaminated pipe<br />

e. A wet contaminated area that is drying out<br />

f. Breaching contaminated systems<br />

2. BE ALERT TO THE TYPES OF CONDITIONS THAT CAN INCREASE THE<br />

AIRBORNE ACTIVITY LEVELS AND YOUR TOTAL DOSE (TEDE).<br />

XI. Interim Summary<br />

A. ALARA<br />

1. The purpose of ALARA is to keep the dose of both the individual and group involved with the<br />

performance of a task as low as reasonable achievable.<br />

2. The individual worker is the most important part of the ALARA program.<br />

3. ALARA concepts include time, distance, and shielding.<br />

4. Stay time is used to ensure an individual does not exceed a limit by restricting the amount of<br />

time allowed in a radiation field.<br />

B. Radiation Dosimetry<br />

1. Dosimetry is used to monitor the amount of external dose received by the worker.<br />

2. The types of dosimetry are the TLD and DRD.<br />

3. Dosimetry should be worn together on the front of the body between the waist and shoulders,<br />

unless otherwise specified on the RWP.<br />

4. The TLD should be handled with care and not tampered with; note that the only way to obtain<br />

any information from the TLD is through the use of a special TLD reader and associated<br />

software.<br />

5. The ED should never be used by personnel as a hand held dose rate meter.<br />

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6. The Pocket Ion Chamber should not be subjected to shock or high humidity since these<br />

conditions could affect its accuracy.<br />

7. EDs are obtained before entering the RCA.<br />

8. If you discover any of your dosimetry is lost, damaged, alarming, or does not appear to be<br />

working correctly, leave the RCA and notify RP.<br />

C. Contamination<br />

1. Types of contamination include fixed, loose surface contamination, and discrete radioactive<br />

particles.<br />

2. The units for contamination are counts per minute (cpm) or disintegrations per minute (dpm) per<br />

unit area.<br />

3. Some potential sources of contamination include spills or leaks from a system carrying reactor<br />

water, open contaminated systems, grinding on equipment with fixed contamination.<br />

4. Some potential indications of contamination include reactor water leaking from a pipe, a rise in<br />

frisker counts, water standing on the floor near or under a contaminated system.<br />

5. Some methods used to prevent the spread of contamination include the use of pre-job briefings,<br />

protective clothing, catch containments and engineering controls.<br />

6. Contaminated areas will be clearly indicated through the use of postings and step-off pads.<br />

7. No material is to be removed from the RCA without first being checked for contamination by<br />

Radiation Protection.<br />

8. Primary methods used to monitor personal contamination are the frisker and the personal<br />

contamination monitor.<br />

9. To minimize contamination of materials, use only tools that are necessary for the job; do not<br />

take packing material into the RCA and use tools with fixed contamination when working in<br />

contaminated areas.<br />

10. Discrete radioactive particles are very small but can deliver a large localized dose.<br />

11. Some conditions that require exiting a contaminated area are cut or torn Protective Clothing,<br />

open wounds, lost or damaged dosimetry, or as directed by alarms, sirens, or announcements<br />

from the Control Room.<br />

D. Internal Radiation Exposure<br />

1. Radioactive material can enter the body through inhalation, ingestion, absorption, and open<br />

wounds.<br />

2. Methods to limit internal deposition of radioactive material include no eating, drinking, smoking<br />

or chewing in the RCA unless authorized by RP and engineering controls.<br />

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3. Internal deposition of radioactive material may be eliminated from the body by urinary<br />

excretion, fecal excretion, perspiration and radioactive decay.<br />

4. The three primary ways to determine the amount of internal radioactivity include the Whole<br />

Body Counter, bioassay, and Whole Body Screening/Passive Monitoring.<br />

5. Inhalation through the nose and mouth is the most common pathway for receiving internal<br />

radiation exposure.<br />

6. TEDE is the sum of external whole body dose (DDE) and the internal whole body dose (CEDE).<br />

7. Many types of activities can increase the amount of airborne radioactivity such as brushing,<br />

sweeping, steam leaks, sanding, breaching of contaminated systems, etc.<br />

XII. Radiation Work Permit<br />

A. Function of RWP<br />

1. A radiation work permit contains details concerning a radiological area that will help you<br />

minimize dose and reduce the likelihood of becoming contaminated or spreading contamination.<br />

As a radiation worker, the RWP is one of the most important tools you have available in<br />

achieving your ALARA goals. The RWP has three major functions:<br />

a. An RWP authorizes individuals to enter radiological areas. There are RWPs for all<br />

radiological areas of the station.<br />

b. An RWP provides you with the radiological requirements necessary for you to work in the<br />

area which may include protective clothing, equipment required, special procedures, and<br />

precautions to be followed.<br />

c. An RWP provides you with information regarding the radiological conditions and hazards in<br />

your work area.<br />

B. Types of RWPs<br />

1. Examples of the different types of RWPs utilized for repetitive, general, or routine work may be<br />

referred to as:<br />

a. Standing RWP<br />

b. <strong>General</strong> RWP<br />

c. Work Group RWP<br />

d. Area Standing RWP<br />

e. Departmental Generic RWP<br />

f. Area Access RWP<br />

2. Types of RWPs utilized for specific tasks which may not be of a routine nature may be referred<br />

to as a Specific RWP or a Job Specific RWP.<br />

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C. RWP Worker Information<br />

1. An RWP also contains information that will help you work in a radiologically safe manner by<br />

providing you with information such as clothing requirements, dosimetry requirements, and any<br />

other special requirements that will help you with your job. The RWP may contain the<br />

following information:<br />

a. RWP NUMBER: Each RWP has its own number for documentation and tracking purposes.<br />

This number will never be reused for another RWP.<br />

b. LOCATION: Gives specific locations that are covered by this RWP. Locations are by Unit,<br />

Building, Elevation, Room/Area.<br />

c. DESCRIPTION OF WORK: Brief description of the work that is approved when working<br />

under this RWP.<br />

d. EXPOSURE MONITORING REQUIRED: Dosimetry needed to safely complete this task<br />

will be stated in this section. (TLD, Extremity dosimetry, Electronic dosimetry, Neutron<br />

dosimetry, Multiple dosimetry, etc.)<br />

e. PROTECTIVE CLOTHING: Clothing needed to perform the task or portions of the task will<br />

be listed in this section.<br />

f. RESPIRATORY PROTECTION REQUIRED: If respiratory protection is needed to<br />

complete any portion of this task it will be stated in this section.<br />

g. SPECIAL INSTRUCTION: Special requirements or hold points will be explained in this<br />

section.<br />

h. ED SETTINGS: The dose you are allowed to receive and the allowed dose rate alarms are<br />

listed in this section. The ED alarm settings are automatically set for you when you process<br />

into the access computer, but it is your responsibility to know them.<br />

D. RWP Compliance<br />

1. All requirements contained in an RWP are there to protect you and your coworkers from<br />

receiving unnecessary dose. Therefore, it is important for you to ensure the requirements and<br />

the intent of the requirements is met. Station management and your supervisor expect you to<br />

always be in full compliance with all RWP requirements. Failure to comply with the RWP<br />

requirements may result in a radiological event, increased dose, the spread of contamination, or<br />

other radiological problems. This could also result in <strong>Exelon</strong> being fined, other regulatory<br />

actions, or disciplinary action up to and including termination.<br />

2. You must read, understand and comply with all aspects of the RWP under which your job is<br />

conducted.<br />

E. Survey Maps<br />

1. Survey maps generally show a drawing of the area covered by the RWP. Survey Maps contain<br />

information such as:<br />

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a. Levels of contamination - Contamination levels are measured in units of disintegrations per<br />

minute/100 centimeter squared (dpm/100cm 2 ).<br />

b. Dose rates - in mRem or Rem per hour, (mRem/hr or Rem/hr) taken at chest level unless<br />

indicated otherwise<br />

c. Low Dose waiting areas (if applicable)<br />

d. Radiological Postings<br />

e. RWP number for which the survey was performed<br />

f. Date that the survey was performed<br />

g. Location of area or component to be worked<br />

Legends (normally provided) distinguish different symbols used on the map<br />

F. Radiation Worker Pocket RWP Data Sheet<br />

1. Each worker will be given a “Radiation Worker Pocket RWP Data Sheet” so they can document<br />

radiological information that is important to their specific job.<br />

2. Workers are required to complete the appropriate information on this sheet prior to entry into the<br />

RCA. This information can be obtained from the RWP, Survey Map, and Pre-job Brief.<br />

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G. Change in Conditions<br />

1. When working in some station areas, the radiological conditions can rapidly change. If the<br />

radiation levels should increase, this will increase the rate at which you are receiving dose.<br />

These changes may not be apparent since the cause of the change may happen in a different area<br />

of the station.<br />

a. Radiological conditions can change with reactor power levels, starting of a pump or heat<br />

exchanger, movement of shielding, or some other reason. Therefore, it is important to<br />

monitor your dose on a frequent basis.<br />

b. If you discover that the radiological conditions are different than expected, or if the<br />

conditions change unexpectedly, inform others that may be affected to exit the area and<br />

contact RP.<br />

c. If, while working on a task in the RCA, the scope of the job changes, contact RP before<br />

proceeding. This could include:<br />

1) Moving of component not originally planned<br />

2) Opening of a contaminated system<br />

3) Movement of shielding<br />

d. At <strong>Exelon</strong> <strong>Nuclear</strong> Plants, Radiation Protection performs surveys of the plant up to 7 feet.<br />

Areas above 7 feet are not normally surveyed, and conditions are not always consistent with<br />

the floor elevation. If for any reason you need to go above 7 feet by climbing on piping,<br />

building scaffold, use of a ladder, etc, you will need to contact Radiation Protection for an<br />

evaluation. At no time should you leave the main floor elevation without consulting<br />

Radiation Protection. The consequence of entering an area that is not surveyed is potential<br />

radiation overexposure or contamination event. You are personally accountable for<br />

requirements in your Radiation Work Permit (RWP), which includes instructions for areas<br />

greater than 7 feet.<br />

Page 145 of 178


EXAMPLE:<br />

#<br />

#<br />

I<br />

N<br />

S<br />

T<br />

R<br />

.<br />

R<br />

A<br />

C<br />

K<br />

10<br />

15<br />

22<br />

V 12 B<br />

200<br />

35<br />

14<br />

21<br />

= Air Sample Location<br />

= Smear Location<br />

= Gamma<br />

1<br />

T 12 A<br />

20<br />

V 12 A<br />

All dose rates are in mRem/hour unless otherwise noted.<br />

All dose rates are at chest level unless otherwise noted.<br />

Smears are NUCON smears ( 100 cm 2 ) in contaminated areas.<br />

Smears are ( L ) in clean areas or to release contaminated areas.<br />

13<br />

70<br />

Dose Rate and Contamination Survey<br />

Date Yesterday<br />

Time 12:00<br />

Inst Used Serial #<br />

CP 23<br />

GM 10<br />

Air Sampler 43<br />

RWP Number 950001 Rev 00<br />

NOTE : All dose rates are in mrem/hr unless<br />

otherwise noted . All dose rates at chest level<br />

unless otherwise noted .<br />

1<br />

2<br />

17<br />

16<br />

23<br />

100<br />

40<br />

= Sign Postings<br />

( L ) = Large Area Smears<br />

= Step Off Pads<br />

Reviewed by : _____________________ Date ; ___________<br />

12<br />

3<br />

Page 146 of 178<br />

H O L D IN G T A N K R O O M<br />

Danger High Radiation Area<br />

Contaminated Area<br />

Authorized Entry Only<br />

LOW DOSE AREA<br />

2<br />

19<br />

15<br />

220/150/10<br />

1<br />

2<br />

3<br />

4<br />

5<br />

6<br />

7<br />

8<br />

9<br />

10<br />

11<br />

12<br />

10<br />

4<br />

P 11 A<br />

NCF<br />

NCF<br />

1K<br />

2K<br />

2K<br />

7K<br />

10K<br />

12K<br />

15K<br />

30K<br />

58K<br />

18K<br />

100<br />

11<br />

100<br />

18<br />

5<br />

HOLDING<br />

TANK<br />

9<br />

MOV 11A<br />

10 70<br />

dpm / 100 cm 2<br />

13<br />

14<br />

15<br />

16<br />

17<br />

18<br />

19<br />

20<br />

21<br />

22<br />

23<br />

100<br />

8<br />

180<br />

18K<br />

15K<br />

17K<br />

21K<br />

20K<br />

15K<br />

12K<br />

10K<br />

8K<br />

7K<br />

10K<br />

7<br />

6<br />

Hot Spot<br />

500 @ 1 cm<br />

200 30 cm


Radiological Survey Map Symbols / Abbreviations<br />

# gamma dose rate (mR / hr) # N neutron dose rates (mrem / hr)<br />

# B beta dose rate (mrad / hour) # / # dose rate (mR / hr) at contact / 30 cm<br />

Hd Head Ch Chest<br />

Kn Knee W Waist<br />

O smear location (number inside of circle) L Large Area Smear<br />

K value times1000 M Value times 1,000,000<br />

dpm disintegrations per minute ccpm corrected counts per minute<br />

R R/hr RAD RAD/hr<br />

DF Direct Frisk (# K) smearable contamination (dpm / area )<br />

NBD or NDB No Detectable Beta DAC Derived Air Concentration<br />

Air sample location DRP Discrete Radioactive Particle<br />

x-x-x or ---- radiological boundary SOP step off pad<br />

RA Radiation Area HRA High Radiation Area<br />

RAM Radioactive Materials CA Contaminated Area<br />

AB Airborne Radioactivity Area VHRA Very High Radiation Area<br />

LHRA Locked High Rad Area LDA Low Dose Area<br />

RCA Radiological Controlled Area NRA Neutron Radiation Area<br />

ZI Zone I dress requirement ZII or Z2 Zone II dress requirement<br />

ZIII or Z3 Zone III dress requirement Z Swing Gate/Turnstile<br />

Page 147 of 178


XIII. Radiological Postings<br />

A. Types of Postings<br />

1. Several different types of radiation conditions may exist in the station. Before entering any type of<br />

radiological area, you must meet the requirements of the RWP. The following are common types<br />

of postings that may be encountered and their meanings:<br />

a. Radiologically Controlled Area – This is an area with limited access to protect individuals<br />

from exposure to radiation and/or radioactive material<br />

b. Radiation Area – An area, accessible to individuals, in which radiation levels could result in<br />

an individual receiving a dose equivalent in excess of 5 mRem in one hour at 30 cm from the<br />

source. Typically posted in areas with a dose rate greater than or equal to 5 millirem per hour,<br />

but less than 100 millirem per hour at 30 cm from the source of radiation.<br />

c. High Radiation Area – An area, accessible to individuals,<br />

in which radiation levels from radiation sources external to CAUTION<br />

the body could result in an individual receiving a deep dose<br />

equivalent rate in excess of 100 mRem/hr at 30 cm from the<br />

radiation source. Typically posted in areas with a dose rate<br />

High Radiation Area<br />

greater than or equal to 100 millirem per hour and less than<br />

1000 millirem per hour at 30 cm from the source of<br />

radiation. A physical boundary such as a locked gate is placed at the entrance. A High<br />

Radiation Area briefing and direction for controlling the area is required prior to entering.<br />

As a worker in a nuclear power plant, it is important to understand the requirements for High<br />

Radiation Area entry. You are required to have a brief prior to High Radiation Area entry by<br />

Radiation Protection. This brief is required daily at a minimum. From this brief you must<br />

know:<br />

#$ Dose Rates and Low Dose Area.<br />

#$ Tasks Allowed To Be Performed.<br />

#$ Required Dosimetry, Alarm Set Points, and Maximum Stay-Times.<br />

#$ Proper Control of Barricades and Postings Upon Entering and Exiting. When exiting,<br />

ensure doors, swing gates and locks are returned to their original position.<br />

#$ If you find a HRA posting or Rad Rope lying on the floor, immediately Contact Radiation<br />

Protection, stay in the area and control access until Radiation Protection arrives.<br />

#$ If you find a HRA access unlocked and unguarded, immediately contact Radiation<br />

Protection and control access until Radiation Protection arrives.<br />

Failure to comply with the HRA entry requirements will result in disciplinary action up to and<br />

including termination.<br />

d. Locked High Radiation Area –An area, accessible to individuals, in which radiation levels<br />

from radiation sources external to the body could result in an individual receiving a deep dose<br />

equivalent rate greater than or equal to 1000 mRem/hr at 30 cm from the radiation source. The<br />

access is locked due to the high dose rates. An area that cannot be locked will be identified<br />

with a red flashing or rotating light and signs. To access a Locked High Radiation Area,<br />

special precautions are required. Contact RP for assistance.<br />

Page 148 of 178


As a worker in a nuclear power plant, it is important to understand the requirements for Locked<br />

High Radiation Area entries. You are required to have a brief prior to Locked High Radiation<br />

Area entries by Radiation Protection. From this brief you will be given information that is<br />

required to successfully work in the area such as:<br />

#$ Dose Rates and Low Dose Areas.<br />

&$ These areas will be identified during the briefing through the use of survey or location<br />

maps.<br />

#$ Tasks Allowed To Be Performed.<br />

#$ Required Dosimetry, Alarm Set Points, and Maximum Stay-Times.<br />

#$ Radiation Protection job coverage and technicians assigned the job and controls of<br />

barricades and postings.<br />

#$ Special Precautions and ALARA techniques.<br />

#$ If you find a LHRA posting lying on the floor, immediately Contact Radiation Protection,<br />

stay in the area and control access until Radiation Protection arrives.<br />

#$ If you find the fencing controlling access to a LHRA has fallen down or there is<br />

unguarded access due to a fencing opening, immediately contact Radiation Protection and<br />

control access until Radiation Protection arrives.<br />

#$ If you find a LHRA access unlocked and unguarded, immediately contact Radiation<br />

Protection and control access until Radiation Protection arrives.<br />

You will be asked to acknowledge that you have received this briefing by signing a briefing<br />

acknowledgment form.<br />

Failure to comply with the LHRA entry requirements will result in disciplinary action up to<br />

and including termination.<br />

e. Very High Radiation Area – This is the only posting that uses the words,<br />

“GRAVE DANGER”. This is an area, accessible to individuals, in which<br />

radiation from radiation sources external, to the body could result in an<br />

individual receiving an absorbed does in excess of 500 Rads in one hour at one<br />

meter from a radiation source. Typically posted in areas with dose rates<br />

greater than 500 Rads per hour at 1 meter from the source of radiation.<br />

Note: For this application, Rad is equivalent to Rem.<br />

f. Airborne Radioactivity Area – This is an area containing airborne radioactivity that exceeds<br />

0.30 DAC or 30% of a DAC.<br />

g. Radioactive Materials (RAM) – An area where radioactive material may be<br />

found in excess of 10CFR20 limits.<br />

h. Radioactive Materials (Storage) Area – A room or area used to store<br />

radioactive materials.<br />

i. Hot Spot – This is a localized source that is five times the general background and at least 100<br />

mRem per hour.<br />

j. Low Dose Area – This is the area that has the lowest dose in the general area.<br />

Page 149 of 178<br />

GRAVE DANGER<br />

Very High Radiation Area<br />

CAUTION<br />

vhra.wmf<br />

RADIOACTIVE MATERIALS AREA<br />

Dosimetry Required<br />

Contact Rad Protection Prior To Entry<br />

AUTHORIZED ENTRY ONLY<br />

rma.wmf


k. Discrete Radioactive Particle Areas – Areas that are established to control the spread of<br />

discrete hot particles are posted as:<br />

1) Red Zone – an area where discrete radioactive particles are present<br />

2) Yellow Zone – area that surrounds the Red Zone to control the spread of discrete<br />

radioactive particles.<br />

l. Radiography in Progress – Areas that are established to control access of personnel while<br />

radiography is in progress.<br />

B. Movement of Ropes and Postings<br />

1. The postings listed serve an important purpose: They warn all station personnel of radiological<br />

hazards in the station.<br />

2. If postings are violated, it can affect the well being of you and your co-workers.<br />

3. Any violation, movement, or removal of any radiological posting may result in disciplinary action<br />

up to an including termination.<br />

4. Moving or violating a radiological posting could result in a radiological hazard, increased dose to<br />

personnel, or regulatory non-compliance.<br />

5. If you are working in an area that is roped off, and the rope may need to be moved or adjusted,<br />

contact RP. The RP Department can evaluate the best way to serve your needs and still maintain<br />

regulatory compliance.<br />

6. Follow all the rules, all the time!<br />

XIV. Radiological Alarms<br />

A. Station Radiological Alarms<br />

Reaching, ducking under, or stepping over rad<br />

rope is strictly prohibited unless specifically<br />

authorized by RP or in the event of an<br />

emergency.<br />

1. Many areas of the station are monitored for radiological conditions. Many of these monitors will<br />

alarm if the condition being monitored is not within the normal range. The following are typical<br />

radiological alarms that are used in the station.<br />

a. A Continuous Air Monitor (CAM) or an AMS-3/AMS-4 (Air Monitoring System) samples the<br />

air. If an abnormal amount of airborne radioactivity is detected, the unit will alarm. This alarm<br />

indicates that the air being sampled has exceeded a preset level of radioactivity. The<br />

appropriate response to a CAM alarm is to leave the area immediately and report the situation<br />

to the RP Department.<br />

Page 150 of 178


. An Area Radiation Monitor (ARM) detects radiation. If radiation in an area is above the<br />

normal levels, the ARM will alarm. If you are in an area affected by an ARM alarm, you are to<br />

leave the area and contact RP.<br />

B. Consequences of Ignoring Alarms<br />

1. Radiological alarms can be one of the first indications of a serious radiological problem. Improper<br />

response or ignoring a radiological alarm can increase your radiation dose and consequently, health<br />

risk.<br />

2. Anyone who willfully ignores a radiological alarm will have their unescorted access to the RCA<br />

suspended until a full investigation may be completed, or will be subject to disciplinary action.<br />

XV. Radioactive Waste<br />

A. Definition of “Radioactive Waste”<br />

1. Radioactive waste is defined as any radioactive or contaminated material for which disposal is<br />

required. Some examples of radioactive waste are:<br />

a. Used Protective Clothing that is no longer serviceable<br />

b. Used tape, gloves and plastic bags from a contaminated area<br />

2. Some other terms used to identify radioactive waste are:<br />

a. Radwaste<br />

b. DAW - dry active waste<br />

c. LSA - low specific activity<br />

B. Waste Disposal Costs<br />

1. All waste generated at a nuclear power plant must be classified as either clean or contaminated<br />

trash prior to disposal. The fee for disposing of each type of trash varies dramatically since<br />

contaminated trash is only accepted at a few special burial facilities throughout the country.<br />

Radioactive waste is very expensive.<br />

2. Due to the decreasing number of radwaste burial sites, these costs continue to increase. Therefore,<br />

it is essential to minimize the amount of contaminated waste generated.<br />

C. Waste Reduction Techniques<br />

1. One method for reducing the impact of sky-rocketing burial costs is to reduce the amount of<br />

radioactive waste generated. Following are some methods the worker may use to minimize the<br />

generation of radioactive waste:<br />

a. Recycle. Use items such as cloth bags or nylon bags, protective clothing, and tool bags<br />

whenever possible. Use velcro bands instead of tape.<br />

b. Prevent waste generation by minimizing usage. Bring only those items and quantities into the<br />

RCA that you really need. Remove all packing material prior to entering the plant.<br />

Page 151 of 178


c. Plan ahead. Use good judgment and common sense when planning the job. Return tools and<br />

glass to a survey point to be deconned and reused or disposed of properly.<br />

d. Minimize the spread of contamination. Report spills or leaks to RP so that they may be cleaned<br />

up promptly.<br />

e. Minimize the use of hazardous chemicals in the plant.<br />

f. Segregate waste.<br />

D. Waste Segregation<br />

1. Clean/Non-Contaminated Waste<br />

a. Once radioactive waste is generated, it is important to keep it separate from clean nonradioactive<br />

material or trash.<br />

b. If potentially clean and contaminated trash are mixed together, there may be crosscontamination<br />

which will result in one of the following:<br />

2. Wet Waste<br />

1) Increase in time, manpower, and cost to survey and separate radioactive vs. non-radioactive<br />

waste.<br />

2) Increase in total amount of radwaste generated.<br />

a. Wet and dry contaminated waste should be segregated. If mixed, more waste processing may<br />

be required.<br />

b. The container may leak or corrode and cause a radioactive spill.<br />

c. Most disposal sites refuse to accept mixed dry and wet waste; therefore, it would have to be<br />

separated and dried prior to disposal.<br />

3. Hazardous Waste<br />

a. Radwaste should also be segregated from other hazardous materials in use, e.g., chemicals.<br />

b. If chemicals are placed in the same trash as radwaste this may result in the generation of<br />

“mixed waste.”<br />

c. Disposal of a mixed waste is very difficult and extremely expensive.<br />

XVI. Interim Summary<br />

A. Radiation Work Permit<br />

1. The three major functions of the RWP are:<br />

a. It authorizes individuals to enter Radiologically Controlled Areas.<br />

b. It provides you with radiological requirements.<br />

Page 152 of 178


c. It provides you with information regarding the radiological conditions and hazards in your<br />

work area.<br />

2. Certain types of RWPs may be utilized for repetitive, general, routine work, or a specific task.<br />

3. An RWP may contain information such as clothing requirements and dosimetry requirements to<br />

help an individual work in a radiologically safe manner.<br />

4. You must read, understand, and comply with all aspects of the RWP.<br />

5. The Survey Map generally shows a drawing of the area covered by the RWP.<br />

6. If radiological conditions are different than expected, or if conditions change unexpectedly, inform<br />

others that may be affected to exit the area and contact RP.<br />

B. Radiological Postings<br />

1. Common types of radiological postings that may be encountered:<br />

a. Radiologically Controlled Area (RCA)<br />

b. Radiation Area<br />

c. High Radiation Area<br />

d. Locked High Radiation Area<br />

e. Very High Radiation Area<br />

f. Airborne Radioactivity Area<br />

g. Radioactive Materials<br />

h. Radioactive Materials (Storage) Area<br />

i. Hot Spot<br />

j. Low Dose Area<br />

k. Discrete Radioactive Particle Areas:<br />

1) Red Zone<br />

2) Yellow Zone<br />

l. Radiography in Progress<br />

2. Radiological postings warn all station personnel of radiological hazards in the station.<br />

3. Moving or violating a radiological posting can affect an individual’s well being, resulting in a<br />

radiological hazard, increased dose to personnel, or regulatory non-compliance.<br />

C. Radiological Alarms<br />

1. Some radiological alarms that are used in the station are the:<br />

a. Continuous Air Monitor<br />

b. Area Radiation Monitor<br />

Page 153 of 178


2. Improper response or ignoring a radiological alarm can increase your radiation dose and<br />

consequently, health risk.<br />

3. Anyone who willfully ignores a radiological alarm will be subject to disciplinary action.<br />

D. Radioactive Waste<br />

1. Radioactive waste is defined as any radioactive or contaminated material for which disposal is<br />

required.<br />

2. Due to the decreasing number of radwaste burial sites, costs continue to increase.<br />

3. Some methods for minimizing the generation of radwaste are recycling, planning ahead,<br />

segregating waste, minimizing the spread of contamination and usage of materials brought into the<br />

RCA.<br />

XVII. Rights and Responsibilities<br />

A. Worker Rights and Responsibilities<br />

1. Your rights and responsibilities include:<br />

a. Adhering to instructions provided by RP personnel (including stop work orders), written<br />

policies and procedures, radiation work permits, and posted warnings, signs, and labels.<br />

b. Maintaining awareness of your current accumulated dose for the job, day, and for the year.<br />

c. Keeping your accumulated dose within federal limits and obtaining all required approvals prior<br />

to exceeding site administrative exposure control levels.<br />

d. Maintaining your accumulated dose ALARA.<br />

2. Identifying the actions and reporting responsibilities when abnormal radiological conditions and/or<br />

violations of radiological requirements are encountered.<br />

3. Requesting and reviewing your radiation dose records.<br />

4. Notify RP prior to receiving nuclear medicine testing. RP will take away your TLD, RCA access<br />

will be restricted, and RP will give you a pass to exit the station when the Portal Monitors alarm.<br />

XVIII. Protective Clothing<br />

A. PURPOSE OF PROTECTIVE CLOTHING<br />

1. Most importantly, Protective Clothing prevents workers from becoming contaminated.<br />

2. Used in contaminated areas, per RWP.<br />

3. Used with good work practices and when properly removed, limit the spread of contamination<br />

outside the posted area.<br />

4. Protective Clothing used with modesty garments (i.e. disposables, shorts, t-shirt, etc.) replace a<br />

worker's regular clothing to prevent personal clothing from becoming contaminated.<br />

Page 154 of 178


5. Modesty garments worn under protective clothing shall have no offensive pictures, words, or logos.<br />

6. Required personal protective equipment (PPE – including glasses, hearing protection, etc.) shall be<br />

worn.<br />

7. Protective clothing sets required for entering Contaminated Areas may be designated by pictures on<br />

the posting at the entrance to the Contaminated Area and are indicated as Zone II & III.<br />

a. Zone II – Full set of protective clothing (1,000 –100,000 dpm/100cm 2 )<br />

b. Zone III – Waterproof outer layer (>100,000 dpm/100cm 2 )<br />

8. Taping is only permitted with approval from Radiation Protection.<br />

B. INSPECTION AND PROPER DONNING<br />

1. Inspection<br />

a. If, while inspecting protective clothing, any defects are detected, do not use.<br />

b. Check for rips, tears, and separated seams.<br />

c. Check for any badly worn areas, especially the elbows and knees.<br />

d. Check the operability of zippers, elastic, and Velcro seals.<br />

2. Proper Donning<br />

a. Remove all personal clothing except shoes, socks, undergarments, and/or modesty clothing.<br />

b. Don inner bootie.<br />

c. Don inner cotton glove liners.<br />

d. Don coveralls, making sure you have a comfortable fit.<br />

e. Secure protective ankles and wrist snaps if provided for.<br />

f. Unless specified by Radiation Protection Management, place security badge under/inside of<br />

coveralls.<br />

g. Unless specified by Radiation Protection Management, place/secure Thermoluminescent<br />

Dosimeter (TLD) inside of coveralls.<br />

h. Place/secure Electronic Dosimeter (ED) inside of coveralls pocket. For coveralls with no<br />

pocket, place ED on lanyard outside of coveralls (tape down if applicable).<br />

i. Don rubber shoe covers/boots as required.<br />

j. Don hood/skullcap as required.<br />

k. Don rubber gloves as required.<br />

Page 155 of 178


C. WORKING IN CONTAMINATED AREAS<br />

1. Ensure all work being performed is done under the provisions of the Radiation Work Permit<br />

(RWP.) Perform no work outside the scope of the RWP.<br />

2. Remember to review the RWP survey to determine the low and high dose areas. Stay in the low<br />

dose areas if not needed.<br />

3. Do not cross RP rope (magenta/yellow) at any time. Do not walk next to or lean over Rad rope.<br />

4. If you tear your protective clothing or receive an open wound, immediately leave the area and<br />

contact RP.<br />

5. Avoid walking through puddles so contamination does not get tracked.<br />

6. Do not walk directly on floor drain grates.<br />

7. Never touch your face or any exposed skin surfaces with your outer gloves.<br />

8. Limit contact with all surfaces and items. Hold equipment away from you when carrying.<br />

9. Moisture can allow contaminants to seep through protective clothing. This can be due to sweating<br />

or from liquids on the job.<br />

10. Kneeling or crawling can grind contaminants through protective clothing.<br />

11. Bring tools into a contaminated area in a recyclable container, remove them for use, then return<br />

them to the container.<br />

12. Any exit from the contaminated area must be done through the step-off-pads.<br />

13. If your electronic dosimeter begins to alarm, leave the area immediately and notify RP.<br />

14. If you should lose or damage your dosimetry or if the readings on your secondary dosimetry are not<br />

as expected, leave the area and contact RP. Remember to inform your co-workers of the situation<br />

so they can check their dosimetry.<br />

D. READING DOSIMETRY<br />

1. Dose rates in an area can vary as conditions in the plant change. You need to periodically monitor<br />

your dose by reading your secondary dosimetry.<br />

2. Remember that your outer gloves are probably one of the most contaminated pieces of clothing that<br />

you are wearing. Be very careful if you need to remove your dosimetry, remove your outer gloves<br />

first.<br />

3. If protective clothing has a pocket with a flap, pinch the flap with outer glove to lift flap, then read<br />

the top of the ED or remove ED with other hand in cotton glove.<br />

4. Remember that periodic checks of your secondary dosimetry should be performed during the day to<br />

track your radiation exposure. This is your responsibility.<br />

E. REMOVING PROTECTIVE CLOTHING<br />

1. Removal<br />

a. Remove any securing material from ankles (tape, etc.) and discard in appropriate containers<br />

(clothing, trash receptacle).<br />

Page 156 of 178


. Remove outside rubber shoe covers and place gently in clothing receptacle.<br />

c. Remove any securing material from wrists (tape, etc.) and discard in appropriate receptacle.<br />

d. Remove outer rubber gloves, careful not to cross contaminate inner glove liners and place<br />

gently in clothing receptacle.<br />

e. Remove personal hardhat, if used, and place on step off pad.<br />

f. Remove and read electronic dosimetry, then place on step off pad.<br />

g. Remove hood/skullcap as required.<br />

h. Remove coveralls slowly, careful not to cross contaminate clean glove liners and modesty<br />

garments. Consider pulling PCs over the shoulders and removing by rolling PCs inside out.<br />

i. Remove inner booties at step off pad (SOP), one foot at a time, stepping on the SOP<br />

immediately as the inner bootie is removed. Caution should be used to not cross contaminate<br />

the SOP. Place inner booties gently in appropriate receptacle.<br />

j. Remove inner cotton glove liners and discard in appropriate receptacle.<br />

k. Don hardhat and carry electronic dosimetry to frisking station or nearest Personnel<br />

Contamination Monitor (PCM).<br />

2. Do not shake or toss protective clothing. This maneuver can cause the spread of contamination to<br />

clean areas.<br />

3. Do not step on the outside of coveralls. To prevent contaminating unprotected areas, do not touch<br />

the outside of any protective clothing or equipment.<br />

4. Do not throw or toss Protective Clothing into dirty clothing receptacles or push down or reach into<br />

the clothing receptacles for any items left in Protective Clothing or dropped into receptacle. If this<br />

is necessary, contact RP.<br />

5. You must exit area using the step-off-pad.<br />

F. WHOLE BODY FRISKING<br />

1. Must be done every time you leave the contaminated area.<br />

2. If a Personnel Contamination Monitor (PCM) is not available, a whole body frisker must be used.<br />

3. Prior to performing a whole body frisk you must:<br />

a. Read posted instructions.<br />

b. Determine if the frisker is on lowest scale and operating properly.<br />

c. Determine the background level on the meter.<br />

4. Remember to frisk slowly, approximate speed of 2 inches per second at a distance of about 1/4" to<br />

1/2" from the body. Avoid touching the surface being measured with the probe.<br />

5. An increase in the audible sound of the meter may mean contamination is present so be sure and<br />

watch the meter. Any sustained movement on the meter may also mean the presence of<br />

contamination.<br />

6. If there is an increase in sound or meter deflection, slowly frisk the area again.<br />

Page 157 of 178


7. If contamination is detected (greater than 100 counts over background), notify the RP Dept.<br />

8. Frisking:<br />

XIX. Summary<br />

a. Prior to picking up the probe, frisk hand.<br />

b. If uncontaminated, pick up the probe, frisk your other hand.<br />

c. Frisk personal hard hat, the top of the head and the hair.<br />

d. Frisk your face and neck pausing over the mouth, nose and throat area.<br />

e. Check the chest, stomach, back, buttocks, arms and legs (15 seconds each) paying particular<br />

attention to areas that have been in contact with surfaces or may have gotten damp.<br />

f. Check the bottom of your shoes.<br />

g. Finally, check the top of your feet (5 seconds each.)<br />

h. Frisk dosimetry.<br />

i. After completing, place the probe in a position so the next person can properly check their<br />

hands prior to picking up the probe.<br />

A. Rights and Responsibilities<br />

1. Individual rights and responsibilities include the following:<br />

a. Adhering to instructions.<br />

b. Being aware of your dose.<br />

c. Keeping your dose within limits.<br />

d. Maintaining dose ALARA.<br />

e. Reporting abnormal radiological violations and conditions.<br />

f. Requesting and reviewing your radiation dose records.<br />

g. Report any medical radioactive treatments to RP.<br />

B. Protective Clothing<br />

1. Protective Clothing prevents a worker from becoming contaminated.<br />

2. If, while inspecting protective clothing, any defects are detected, do not use.<br />

3. If you tear your protective clothing or receive an open wound, immediately leave the area, and<br />

contact RP.<br />

Page 158 of 178


4. If you need to remove your dosimetry, remove your outer gloves first.<br />

5. Do not shake or toss protective clothing because this maneuver can spread contamination.<br />

6. Do not step on the outside of coveralls.<br />

Whole body frisking must be done every time you leave the contaminated area.<br />

Page 159 of 178


NUCLEAR - GENERAL EMPLOYEE TRAINING - Attachments<br />

Attachment A<br />

Material Safety Data Sheet<br />

(MSDS)<br />

Page 160 of 178


NUCLEAR - GENERAL EMPLOYEE TRAINING - Attachments<br />

MATERIAL SAFETY DATA SHEET<br />

Page 161 of 178


NUCLEAR - GENERAL EMPLOYEE TRAINING - Attachments<br />

Page 162 of 178


NUCLEAR - GENERAL EMPLOYEE TRAINING - Attachments<br />

Attachment B<br />

NRC FORM 3<br />

Page 163 of 178


NUCLEAR - GENERAL EMPLOYEE TRAINING - Attachments<br />

Page 164 of 178


NUCLEAR - GENERAL EMPLOYEE TRAINING - Attachments<br />

Page 165 of 178


Attachment C<br />

Page 166 of 178


Unplanned Radiation Dose<br />

SER 4-98/SEN 158 – Calvert Cliffs <strong>Nuclear</strong> Power Plant<br />

Date of event – 4/3/97<br />

A diver at Calvert Cliffs <strong>Nuclear</strong> Power Plant nearly received fatal radiation dose while replacing a proximity<br />

switch on the fuel transfer carriage. While waiting for lockwire to secure the switch, the diver decided to perform<br />

another task that had been included in the original work scope. He was unaware that this task had been deleted<br />

because radiation surveys had not been completed in the area where the task was to be performed. The diver left<br />

the approved diving area and traveled about 20 feet to within approximately 5 feet of an area with a 12,000<br />

rem/hr dose rate (a potentially fatal dose in just over three minutes) from a large group of recently discharged<br />

spent fuel assemblies! Fortunately, he avoided significant dose because he was ordered from the spent fuel pool<br />

by a radiation technician responding properly to the diver’s dosimeter alarm.<br />

SER 4-98 – Shearon Harris <strong>Nuclear</strong> Power Plant<br />

Date of Event – 4/12/97<br />

An insulation contract worker and a station radiation protection technician at Shearon Harris <strong>Nuclear</strong> Power Plant<br />

exceeded their RWP – allowed dose while removing and installing insulation on a heat exchanger. When they<br />

started to work, they realized that more insulation than anticipated had to be removed. As work progressed, the<br />

insulation contractor’s electronic dosimeter alarmed; five minutes later, the electronic dosimeter worn by the<br />

radiation protection technician also alarmed. Rather than leave the area, the technician allowed the work to<br />

continue and helped remove insulation in order to complete the task with only one entry. The contractor had<br />

received 495 mrem and the radiation protection technician had received 530 mrem. The radiation protection<br />

technician did not follow station procedures by allowing work to continue after the dosimetry alarmed. Also, the<br />

technician lost focus on his radiation protection responsibilities by helping to finish the insulation work.<br />

OE 9026 – H.B. Robinson Steam Electric Plant<br />

Date of Event – 3/14/98<br />

A worker from another nuclear plant within the H.B. Robinson Steam Electric Plant was repairing a valve<br />

actuator when he received 110 mrem of radiation exposure (the allowed dose was 100 mrem) because he did not<br />

respond to an alarm on his alarming dosimeter. After receiving the continuous dose alarm, ` the worker stayed in<br />

the area, completed torquing four remaining actuator bolts, and picked up the tools to take them to the tool room.<br />

An investigation faulted the worker’s judgment because he did not exit the area immediately upon receiving the<br />

alarm. The worker thought it was more important to complete the job than exit the area as expected.<br />

Page 167 of 178


(NOV) BW 98-54-Braidwood (Unit 1)<br />

RADIOGRAPHY EVENTS AT OPERATING POWER REACTORS<br />

EVENT DESCRIPTION:<br />

At approximately 12:00 on 10/6/98, radiography (RT) was being performed on the hot and cold leg pipe<br />

welds on the “1A” Replacement Steam Generator. Just after the first of two radiography shots was<br />

completed, a Radiation Protection Technician (RPT #2) saw two workers exiting the top of the pressurizer<br />

enclosure. The pressurizer enclosure was within the Radiation Area boundary established by RPT #1 for the<br />

RT work and all personnel were supposed to have been evacuated from this area.<br />

RPT #2 immediately climbed down from the SG enclosure and met the workers at the 426’ elevation. The<br />

RPT checked the workers’ dosimeters and determined that each worker had received only two mrem, which<br />

was consistent with stay times and dose rates in their work area. The two workers were in an area<br />

significantly removed from the RT work. This area was posted not as a result of the potential to receive dose,<br />

but because a possible exit path from the pressurizer enclosure is near the RT work area.<br />

RPT #2 then advised RP Supervision that the RT radiation area had not been properly cleared of personnel.<br />

RP supervision stopped all further RT work and instructed the RPT #2 to secure the RT source. Station<br />

management was advised of the event and a prompt investigation was initiated. The RPT (RPT #1) that had<br />

setup the rad boundaries was temporarily relieved of his normal duties in compliance with RP expectations for<br />

RP event investigations.<br />

The initial investigation of the event determined that the two workers had entered the radiation area boundary<br />

(pressurizer enclosure) prior to the radiation area boundaries being established. The workers were not aware<br />

that RT work was to be performed in the area, and due to the noise level in the area, the workers did not hear<br />

the page announcements conducted prior to the start of the RT work. The first RPT (RPT #1) that had<br />

established the boundary at the pressurizer enclosure relied on input from other RP technicians prior to<br />

establishing postings and did not perform a complete visual inspection of the pressurizer enclosure.<br />

Following an initial investigation of the event, RP management identified the following eight actions that<br />

needed to be performed prior to each Bechtel radiography window. Upon communication of these<br />

requirements and a tailgate of the event, RP management removed the RT work stoppage.<br />

1. The Byron/Braidwood radiography events are to be covered in each briefing.<br />

2. Notification will be made to station Rad Protection X2240 and Numanco BOP RP x2455 along with<br />

maps indicating radiography boundaries.<br />

3. The need to visually verify that no unauthorized personnel are inside the radiography boundaries will<br />

be communicated during the radiography brief.<br />

4. The RP supervisor assigned to cover the radiography will be required to attend the briefing.<br />

5. SGRP RP will be notified of radiography locations 4 hours prior to starting the shot.<br />

6. Bechtel supervision will be notified via radio of RT information following the briefing. Bechtel<br />

workers will be reminded to leave the area as requested by RP when setting up for radiography.<br />

7. The project will establish the minimum number of technicians required to cover each radiography<br />

situation.<br />

8. Include in the PreJob briefing the proper method and personnel assignments for clearing the areas<br />

affected by radiography.<br />

Page 168 of 178


PS 3409 I NEWTON 18-JAN-95 13:01 EST<br />

INPO (INP)<br />

Subject: PLANT EVENT - FITZPATRICK: 18-JAN-95<br />

This report is generated from information supplied by the four NRC regional offices. The report includes highlights from<br />

the NRC Daily Plant Status Report and from NRC Preliminary Notifications (PNOs) received during the past 24 hours. The<br />

information is designed for NRC personnel, but INPO has been provided access to the information. INPO includes in this<br />

report only information that pertains to plant operational safety or reliability. Please Note that generally these highlights are<br />

taken verbatim from the NRC reports and INPO has not verified the accuracy of this information.<br />

II. Significant Events (as defined in 10CFR50.72)<br />

Reports Filed in the Past 24 Hours<br />

FACILITY FITZPATRICK<br />

UNIT (1) ( ) ( )<br />

RX TYPE 1 GE-4<br />

EVENT DATE 12/08/94<br />

EVENT TIME 00:00 EST<br />

EMERGENCY CLASS NOT APPLICABLE<br />

SCRAM CODE N<br />

RX CRIT N<br />

INIT PWR 0<br />

INIT RX MODE REFUELING<br />

CURR PWR 0<br />

CURR RX MODE REFUELING<br />

Contract Supervisor and Contract worker falsified dosimetry information to improperly gain access to radiologically<br />

controlled area.<br />

The Licensee notified the NRC Operations Center of a potential 10CFR50.9 violation by two contract individuals. The<br />

licensee has discovered that two contract individuals (a supervisor and a worker) violated plant radiation protection<br />

procedures and made several entries into the plant radiologically controlled area (RCA) during 12/8/94- 12/9/94 without<br />

following plant procedures for dosimetry issuance and check in with Radiation Protection Staff..<br />

Earlier in December, the Contract Supervisor had escorted a Contract worker in the RCA, but had retained the worker’s<br />

thermoluminescent dosimeter (TLD) upon his departure from the site. When a second supervisor provided him with the<br />

previous worker’s TLD, and instructed him to sign in as the previous individual. The Licensee has interviewed the<br />

Supervisor, who has admitted to providing the TLD to the visitor, and instructing him to sign in under a different name.<br />

The Contract Supervisor was escorted offsite, and his site access has been revoked.<br />

The Licensee has processed the TLD, and determined that neither contract worker had received a measurable dose. The<br />

Licensee is currently reviewing all records of visitors’ onsite who have been issued TLDs in order to assure that this was an<br />

isolated instance. This information was provided to the NRC Region 1 acting Regional Administrator today (1/17/95).<br />

Page 169 of 178


EXCESSIVE PERSONNEL RADIATION EXPOSURES<br />

85-3<br />

Unanticipated radiological conditions or an individual's disregard for radiological controls. Very high radiation<br />

fields are present in certain areas of nuclear power plants during some activities. Entry into these high fields,<br />

even for a brief period, could result in the unnecessary exposure of personnel to doses several times greater than<br />

established limits and, in extreme cases, could jeopardize the health and safety of personnel. A review of industry<br />

events indicates a number of common factors that contribute to overexposures. Addressing these factors can<br />

significantly reduce the probability of an overexposure event occurring.<br />

DESCRIPTION OF EVENTS:<br />

ZION 1<br />

During refueling cavity flooding with the incore instrument thimbles withdrawn, a shift engineer entered the<br />

reactor cavity area to investigate water leakage.<br />

The Shift Engineer received authorization from the Duty Health Physicist for an exposure limit of 500 mrem for<br />

this entry ( his accumulated quarterly dose was 180 mrem). There was no Radiation Work Permit governing this<br />

entry. Two Radiation Technicians were assigned to assist the Shift Engineer, one to survey and the second to act<br />

as timekeeper. Upon arriving at the entrance to the reactor cavity area, the first Radiation Technician proceeded<br />

down the ladder to perform a survey. The dose rate measured at the bottom of the ladder was 50 rem/hr. The<br />

Radiation Technician did not survey beyond the bottom of the ladder because there was about six inches of water<br />

at the bottom of the ladder and he assumed the Shift Engineer would not leave the ladder. The second Radiation<br />

Technician stayed at the top of the ladder to keep time in order to indicate when the Shift Engineer should start<br />

back up to stay within his approved 500 mrem dose.<br />

The Shift Engineer proceeded down the ladder followed by the first Radiation Technician. The Shift Engineer<br />

left the base of the ladder and proceeded approximately six to eight feet toward the bottom head of the reactor.<br />

The first Radiation Technician did not advise the Shift Engineer that he was entering an unsurveyed area.<br />

Unaware that the Shift Engineer had left the ladder, the timekeeper calculated the exposure based on the 50<br />

rem/hr dose rate and after approximately 30 seconds signaled the first Radiation Technician to call the Shift<br />

Engineer back. The second Radiation Technician terminated timekeeping when he saw the Shift Engineer on the<br />

ladder.<br />

The Shift Engineer’s total exposure was calculated to be 931 mrem. Since the Shift Engineer left the bottom of<br />

the ladder and proceeded into an unsurveyed area, his film badge was sent offsite for emergency processing on<br />

the following day. The plant was informed that the film badge indicated a dose of 3.7 rem; the badge was reread<br />

and that reading was confirmed. Further evaluation, using calculated radiation levels to account for streaming<br />

conditions in the area, indicated that the true dose received was 4.72 rem.<br />

Contributing factors to this event include Radiation Technicians that were not fully aware of the scope of the<br />

inspection to be conducted and the lack of work controls (permits or procedures) for entry into the area.<br />

A previous event at Zion, under similar circumstances, occurred in 1976 when a Station Engineer received a<br />

whole-body dose of 8.05 rem in the reactor cavity area. A survey was not performed prior to the entry nor was a<br />

Radiation Protection Technician present.<br />

Page 170 of 178


QUAD CITIES<br />

Tampering with radioactive sources or horseplay of any kind will not be tolerated. Tampering with sources is not<br />

consistent with ALARA and can result in significant worker exposure. On August 9, 1994, a contract laborer<br />

attempted to exit the RPA at Trackway 2. The contract laborer alarmed the personnel radiation monitor. The<br />

worker immediately contacted the RP technician. The worker was taken to Trackway 1 where the personnel<br />

radiation monitor indicated a local alarm for the back of the leg. A GM was used and pegged off-scale over the<br />

back pocket. The RPT attempted twice to remove the suspected hot particle with masking tape and then escorted<br />

the worker to the personnel decontamination room where the worker’s personal clothing was removed. While<br />

checking the blue jeans, a dime-shaped source fell out of the right pocket. This dime-shaped object was<br />

identified as a Sr-90 calibration source from a Plexiglas fan source. (Fan sources were located in various<br />

locations throughout the plant to response check dose rate instruments). The exposure time was 12 minutes with<br />

a 22 REM SDE exposure.<br />

Page 171 of 178


Unplanned Personnel Radiation Exposures<br />

SOER 01-01<br />

Unanticipated radiological conditions or an individual’s disregard for radiological controls can result in<br />

unplanned and excessive radiation exposures. Very high radiation fields are present in certain areas of nuclear<br />

power plants during some activities. Entry into these high fields, even for a brief period, could result in the<br />

unnecessary exposure of personnel to doses several times greater than established limits and, in extreme cases,<br />

could jeopardize the health and safety of personnel.<br />

A review of industry events indicates a number of common factors that contribute to overexposures.<br />

Addressing these factors can significantly reduce the probability of an overexposure event occurring. The<br />

following are examples of such events.<br />

# Koeberg Unit 2 (PWR – South Africa) March 1997 EAR PAR 97-005<br />

A quality control inspector unintentionally entered the in-core detector penetration room to perform an<br />

inspection on the detectors. He used two maintenance personnel to assist him in opening the door leading<br />

to the room, as he assumed that this was the in-core detector storage room. Once inside the room, he<br />

realized that he was in fact in the wrong room. He then left the room, closed the room door, and noted<br />

that his dosimeter was off-scale high. The inspector and maintenance personnel received an unplanned<br />

exposure of 3.2 rem, 1.76 rem, and 260 mrem, respectively, due to this mistake.<br />

# Calvert Cliffs Unit 2 (PWR – United States) April 1997 EAR ATL 97-018<br />

On April 3, 1997, with Calvert Cliffs Unit 2 in a refueling outage, spent fuel pool diving operations were<br />

performed to replace a magnetic proximity switch on the fuel transfer carriage. The diver left the<br />

approved diving area, traveled about 20 feet to within approximately 5 feet of an area reading 12,000 rpm<br />

per hour as a result of a large group of recently discharged spent fuel assemblies, and received an<br />

unplanned whole body exposure of 270 mrem.<br />

Breakdown of multiple barriers resulted in the diver attempting to perform a canceled item in the work<br />

scope that was outside the surveyed, approved work area. Taking prompt action in response to an alarm<br />

on one of the multiple remote reading dosimeters attached to the diver, a radiation protection technician<br />

directed the diver to leave the pool immediately. This final barrier prevented a significant radiation<br />

exposure to the diver.<br />

# Narora (India) EAR TYO 99-011<br />

Unit 2 was in an annual shutdown. A radiological work permit was issued to carry out preventive<br />

maintenance of leak detectors (beetles) in the pump room, delayed neutron monitoring rooms, and fuel<br />

transfer rooms (north and south). Health Physics cleared the radiation work permit in all areas except the<br />

fuel transfer rooms, where radiation fields and contamination levels were high. Two contractor workers<br />

with elementary radiation protection qualification, needing to be supervised for radiation work, went<br />

ahead with the above work without the knowledge of the supervisor who issued the radiation work<br />

permit. After completing the job in the north fuel transfer room and confirming the dose received as<br />

expected, they proceeded to the south fuel transfer room unaware of the high radiation field in the area.<br />

They started work in the room. After working in the room about 15 minutes, they checked their pocket<br />

dosimeters and found they were off-scale high. Subsequent reading of their TLDs indicated they had<br />

received doses of 12.48 rem and 7.6 rem, respectively.<br />

Page 172 of 178


Attachment D<br />

CONTAMINATION PITFALLS<br />

The following items are examples of some poor work practices which each worker at the station must avoid.<br />

$ FAILURE TO PERFORM WORK WITHIN THE SCOPE OF THE RADIATION WORK PERMIT<br />

(RWP): Radiation work at all <strong>Exelon</strong> stations is controlled by the use of an RWP. The protective<br />

clothing requirements and instructions to individuals who must work in the Radiologically Posted Areas<br />

(RPA) of the station are specified on an RWP, based on the Work Description indicated in the heading of<br />

the RWP. If work is to be performed which is not encompassed by the existing Work Description of the<br />

RWP or is outside the work scope of the RWP, then the Radiation Protection Department (RP) must be<br />

contacted before that work is performed. In this way, the additional work can be evaluated by RP, and<br />

potential radiation and contamination exposures maintained ALARA.<br />

% FAILURE TO COMPLY WITH THE REQUIREMENTS OF THE RWP: The protective clothing<br />

requirements and instructions on the RWP are designed to maintain radiation and contamination<br />

exposures ALARA. If workers fail to comply with the requirements of the RWP, it may result in serious<br />

radiological consequences.<br />

& FAILURE TO PROPERLY TRANSFER ITEMS FROM A CONTAMINATED AREA: When<br />

contaminated items are improperly removed from a contaminated area, contamination could be spread<br />

beyond contamination barriers to the worker, the clean area, and hence, to other workers. Contact RP<br />

with questions concerning the proper method for removing contaminated items when you are not sure<br />

how control of these items can best be maintained. Either re-bag radioactive material containers at the<br />

step-off pad, or have an RP Technician release the container by performing a smear survey. All materials<br />

being transferred must be packaged or contained to the extent that there is no possibility of spreading<br />

contamination. If a spill or accident occurs while transferring items, the area should not be left<br />

unattended until it has been properly controlled. RP shall be notified of the occurrence as soon as<br />

possible.<br />

' FAILURE TO INSPECT PROTECTIVE CLOTHING BEFORE DONNING: Inspect all protective<br />

clothing for holes, tears, or other defects. Torn clothing provides no protection against contamination<br />

exposure.<br />

( FAILURE TO ASSOCIATE DUST, DIRT, OR WHITE POWDER (boric acid at PWRs) WITH<br />

CONTAMINATION: RP frequently performs routine surveys of normally accessible areas, and cleaning<br />

of the plant is performed continually. Therefore, any accumulation of dust, dirt, or powder should be<br />

associated with contamination. Before workers come in contact with potentially contaminated dust or<br />

dirt, RP should be contacted for guidance or possible surveys.<br />

) FAILURE TO BE AWARE OF CONTAMINATION LEVELS: It is the responsibility of each worker to<br />

be aware of the radiation and contamination levels of the areas he will be entering. This is accomplished<br />

by checking the surveys attached to each RP office. You may not enter the areas until the radiation and<br />

contamination hazards are known by you. This also applied to areas higher than seven feet above the<br />

floor. Contact RP to perform additional surveys, if needed.<br />

Page 173 of 178


* FAILURE TO RECOGNIZE THE SIGNIFICANCE OF A POSTED CONTAMINATION AREA: A<br />

yellow and magenta rad-rope is merely an extension of the meaning of the sign which is placed on it. The<br />

rad-rope itself does not stop the spread of contamination. Only the good work practices of each worker in<br />

the plant stop the spread of contamination. If practical, don't walk or stand along the side of a rad-rope<br />

barrier. Don't rub up against equipment which is inside and touching the rad-rope, such as fence or a<br />

garbage can, as they are considered to be a part of the contaminated area. Only RP is allowed to move<br />

rad-rope barriers.<br />

+ FAILURE TO PERFORM A TWO-MINUTE WHOLE BODY FRISK: A two minute whole body frisk<br />

(or use of a Whole Body Personnel Contamination Monitor) is required upon exiting a contaminated area<br />

and before dressing in street clothes. Donning personal clothing prior to monitoring for contamination<br />

would provide sufficient shielding to contamination and allow the contamination to be undetected. The<br />

purpose of the frisk (or monitor) is to detect contamination on the body as soon as possible to reduce the<br />

amount of time it is on the skin and thereby reduce personnel exposure to contamination. The frisk (or<br />

use of the monitor) is required by station procedures, and should be performed per the instructions posted<br />

by each frisker (or monitor). Contact RP if contamination is found and minimize the spread of<br />

contamination by not touching anything before RP personnel arrive. If you are working in an area and<br />

suspect you have become contaminated, leave the area immediately, perform a whole body frisk (or use a<br />

Whole Body Monitor), and contact RP and your supervisor if you are contaminated.<br />

, FAILURE TO RECOGNIZE CHANGED RADIOLOGICAL CONDITIONS: There are many times<br />

when radiological conditions in an area may be different than those indicated on your RWP. It is<br />

important that a worker be able to recognize the significance of changed radiological conditions, since the<br />

protective clothing requirements and special instructions on an RWP may no longer apply for the work to<br />

be performed. It is the responsibility of the worker to recognize the significance of changing radiological<br />

conditions. Notify RP if there is any doubt about the status of radiological conditions in your work area.<br />

For example, faster dose accumulation of radiation dose by the ED.<br />

$- FAILURE TO REMOVE PROTECTIVE CLOTHING PROPERLY: Step-off pads provide multiple<br />

buffer zones between contaminated areas and clean area for the removal of protective clothing and the<br />

transfer of contaminated items. Improper use of the step-off pads will result in the spread of<br />

contamination to clean areas. Also, improper handling of contaminated clothing will deposit<br />

contamination in the buffer zone between pads. This may not contaminate you, but it may contaminate<br />

the next person who uses that step-off pad while undressing. Make every attempt not to contaminate the<br />

outside of clothing hampers, trash cans, or yourself and others. Do not overfill trash cans or hampers and<br />

do not push clothing or trash down into containers; this may allow contamination to spread. If they are<br />

full, contact the Station Labor Supervisor to get them emptied.<br />

$$ FAILURE TO CONTAIN CONTAMINATED ITEMS WITHIN RAD-ROPE BARRIERS: Hoses or<br />

cables extending out of the contaminated area should be taped or otherwise secured at the rad-rope<br />

boundary to prevent their movement into clean area. Equipment stored in a contaminated area should be<br />

entirely contained within the rad-rope boundary.<br />

$% FAILURE TO REPORT RADIOLOGICAL EVENTS: Each worker should report unusual<br />

circumstances dealing with radiological events to RP. This would include steam leaks, puddles of water,<br />

dripping water from valves/equipment, obvious violations of radiation safety practices, and any events<br />

occurring in the plant which may have radiological implications. It is important that a worker who<br />

discovers any radiological control deficiencies bring them to the attention of RP.<br />

Remember that personnel contaminations can best be reduced by following the RWP, planning, good<br />

judgment, and common sense. Everyone at the station has a role to play in keeping contamination<br />

exposures ALARA.<br />

Page 174 of 178


CONTAMINATED AREA WORK PRACTICES<br />

When you sign an RWP, it means you agree to abide by the requirements of the RWP. Don't take it upon<br />

yourself to vary from the RWP. Call your supervisor if you have problems. The RWP can be changed and we<br />

will resolve the differences. When we change an RWP or when conditions change, your Supervisor and Rad<br />

Protection must make the changes. Your Supervisor must inform you so you are aware of any changes. We need<br />

to plan ahead to avoid this type of situation as much as possible.<br />

Step off pads act as buffer areas to contain contamination inside the RPAs. The theory of multiple pads is to keep<br />

the next pad as clean as possible when you exit an SOP. To do this, you must have an adequate SOP area to begin<br />

with. The rest is up to the people using the SOP to undress carefully. Stay back as far as possible from the pad<br />

you are approaching when undressing. This will prevent contamination from dropping on to the next pad. When<br />

you need to remove your footwear, back up to the pad and carefully pull off your footwear and deposit it inside<br />

the hamper. Take care so you don't flip your footwear over the clean pad.<br />

Put all trash "inside" the trash can and all RWP clothing "inside" the hampers. The goal is to keep the outside<br />

surfaces of the laundry hamper and trash can clean. This reduces the chance of spreading contamination when<br />

handling the trash and laundry bags. It also keeps the SOP area looking neat and clean.<br />

Secure hoses, cables, etc. that run across an SOP or rad boundary. Tape them down or tie them off to prevent<br />

shifting in and out of the contaminated area. Also, tag your hose and line so people know who is using it.<br />

If you find your SOP to be inadequate for your work (i.e., too small, needs more hampers, etc.), contact the<br />

station labor supervisor to get it changed. Realize, in some cases, space will be restricted.<br />

If the trash or laundry hampers are full, contact station labor supervisor to get them emptied.<br />

Page 175 of 178


Attachment E<br />

NRC<br />

Form 4<br />

Page 176 of 178


NRC FORM 4 EQUIVALENT CUMULATIVE EXPOSURE HISTORY PREPARATION DATE: ____/____/____<br />

10 CFR Part 20 PAGE _____ of _____<br />

I. NAME: ______________ ID/SS NUMBER: ________ ID TYPE: ____ SEX: ___ DATE OF BIRTH: _____/_____/_____<br />

II. PERMANENT MAILING ADDRESS: _____________________________________<br />

CITY: _____________________________________ STATE: ____ ZIP CODE: _________<br />

III. PERSONNEL CODE: _____DEPARTMENT / POSITION: __________________________________________________<br />

IV. To be completed for non-CECo employees: Employers Name:<br />

______________________________________________<br />

Employers Address: ______________________________________________________<br />

I certify that the name, ID/SS number, and date of birth for this employee have been confirmed through the<br />

examination of personal identification documents which appear to be genuine and relate to the individual.<br />

Signature of Witness: ______________________ Company: ____________________ Date: _____/_____/_____<br />

V. Was all prior occupational exposure from <strong>Exelon</strong> facilities? Yes: ___ No: ___<br />

No exposure received at any facility: ______<br />

VI. I certify that the information entered in sections I, II, V, and X is correct and complete to the best of my<br />

knowledge and belief. I understand that if I change my name or permanent mailing address, or if I am<br />

monitored for radiation at a non-CECo facility, it is my responsibility to notify the Radiation Protection<br />

Department. If I am not a <strong>Exelon</strong> employee, I also authorize <strong>Exelon</strong> to obtain and/or distribute an y and all<br />

information, including related date, regarding my occupational exposure history from and/or to other<br />

interested parties.<br />

Signature of Monitored Individual: _________________________________________ Date: _____/_____/_____<br />

VII. Has the individual consented to be on the INDEX computer system? Yes: ____ No: ____<br />

VIII. CERTIFYING ORGANIZATION: COMMONWEALTH EDISON COMPANY _____________________<br />

Signature of Designee: ___________________________________________________ Date: _____/_____/_____<br />

IX. New or corrected information entered into <strong>Exelon</strong> computer system by: ____________________________<br />

Date: _____/_____/_____<br />

X. All dose equivalents are in units of rem<br />

Monitoring<br />

License Dose Routine LDE SDE,WB SDE,ME CEDE CDE TEDE TODE<br />

Period/Facility Number Type PSE<br />

ND = NOT DETECTABLE NR = NOT REQUIRED TO BE MONITORED NA = NOT APPLICABLE XX = INTENTIONALLY BLANK<br />

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Attachment F<br />

THE 10 BASIC RADIATION PROTECTION RULES<br />

. ALWAYS ensure High Radiation Area barriers are secured or controlled.<br />

/ NEVER move radiation control boundaries (ropes, signs, etc.).<br />

0 TLDs and EDs SHALL be worn on the front part of the body, above the waist,<br />

within a hand’s width unless repositioned by the RWP or RP Technician.<br />

1 ALL RWP requirements SHALL be followed.<br />

2 Posted guidelines SHALL be followed when contamination monitors alarm<br />

(IPM7/8, tool monitors, etc.).<br />

3 Radiation Protection SHALL be contacted if working area conditions are different<br />

than expected, change during the course of the activity (Water, unexpected or<br />

high ED count rate), or when entering areas more than 7 feet above floor level.<br />

4 Unless directed otherwise by RP, personnel SHALL leave the area and contact<br />

Radiation Protection for ANY ED alarm.<br />

5 Equipment SHALL NOT be removed from ANY RCA without proper survey and<br />

release.<br />

6 Personnel SHALL perform whole body surveys upon exiting ANY contaminated<br />

area at the closest contamination monitoring point.<br />

.7 Personnel SHALL adhere to Radiation Protection Posting requirements.<br />

WARNING<br />

VIOLATIONS of these rules WILL result, at a minimum, in restricted<br />

access to RCA.<br />

DEVIATIONS from these rules MUST be approved by Radiation<br />

Protection.<br />

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