EXHIBIT San Onofre Nuclear Generating Station (SONGS) Requirements For Site Access And Access To Protected/Restricted Radiologically Controlled Areas

Transcription

1 EXHIBIT San Onofre Nuclear Generating Station (SONGS) Requirements For Site Access And Access To Protected/Restricted Radiologically Controlled Areas Contents I. REQUIREMENTS FOR SITE ACCESS... 2 II. GENERAL... 2 A. Searches... 2 B. Fitness for Duty... 3 C. Continual Behavior Observation... 3 D. Work Hour Fatigue Guidelines... 3 III. INCOMING REQUIREMENTS FOR SITE ACCESS (OWNER CONTROLLED AREA)... 3 A. Criminal Activity... 5 B. Processing Requirements... 3 IV. INCOMING REQUIREMENTS FOR UNESCORTED ACCESS TO SONGS PROTECTED/RESTRICTED AREAS AND RADIOLOGICALLY CONTROLLED AREAS... 4 A. Central Processing Facility... 4 B. Validation of Employee Status... 4 V. SITE TERMINATION REQUIREMENTS... 5 A. Notification... 5 B. Processing Out Requirements... 6 VI. TRAINING REQUIREMENTS... 6 A. Radiological Training... 6 VII. HEALTH PHYSICS REQUIREMENTS... 6 A. Personnel Monitoring Records... 6 B. Administrative Dose Controls... 6 C. Bioassay Requirements... 7 D. Respiratory Requirements... 7 E. Expedited Dosimetry Processing... 7 VIII. CONTROL OF CHEMICALS AND CONSUMABLE MATERIALS... 7 IX. SAFETY CONCERNS... 8 A. Contractor Responsibilities Associated With the Establishment and Maintenance of the SONGS Safety Conscious Work Environment... 8 B. Contractor Knowledge of Employee Protection Requirements and Expectations... 9 X. SONGS PHOTO/VIDEO POLICY Exhibit A SITE ACCESS Page 1 of 11 CPF Eff. 7/12, SONGS Rev 2/12/13

2 I. REQUIREMENTS FOR SITE ACCESS Contractor and its Subcontractor must comply with the incoming, periodic and termination Access Control Requirements set forth herein. Failure to comply with these requirements may result in the withholding of payment of invoices until such requirements are satisfied. In addition, Contractor and its Subcontractors may be liable for the additional expenses incurred by Edison, including such expenses related to special processing, investigations and badging which result from Contractor s or its Subcontractor s non compliance with these requirements. II. GENERAL THE FOLLOWING REQUIREMENTS APPLY TO ALL PERSONNEL ENTERING THE SONGS OWNER CONTROLLED PROTECTED/RESTRICTED RADIOLOGICALLY CONTROLLED AREA AS SHOWN ON THE ATTACHED MAP. It is the Contractor s and its Subcontractor s responsibility to obtain copies and maintain familiarity with the key Site programs. A. Searches Nuclear Organization Directive D 028 Searches states that all personnel authorized Site access, including contract and sub contractor personnel may be subject to search when entering, while on, or exiting the Site. Searches are designed to discover the presence of contraband, prohibited items and Edison owned or leased property in the unauthorized possession of an individual. Prohibited items include, but are not limited to: Alcoholic and Non alcoholic beverages Any incapacitating agent (tear gas/pepper spray) Marijuana and any derivatives Controlled substances Narcotic (drug) Paraphernalia Any non related work knife or blade longer than 4" Metallic balloons Contraband items include, but are not limited to: Contraband items are item such as Firearms Explosives Incendiary devices Items that have an apparent primary use as a weapon. Items that could be used to commit radiological sabotage. The Items listed above are neither exhaustive nor controlling and are not permitted on site. Exceptions for firearms will only be made under urgent circumstances by Security Manager or designee in concurrence with the Shift Manager. If the delivery is urgent, the driver will be informed that SONGS Security may take the firearm into custody but, it will be turned over to Local Law Enforcement (LLEA). In these instances the driver will have to retrieve his/her firearm from the responding Local Law Enforcement station. Exhibit A SITE ACCESS Page 2 of 11 CPF Eff. 7/12, SONGS Rev 2/12/13

3 B. Fitness for Duty Nuclear Organization Directive D 006 Fitness for Duty establishes the Fitness for Duty policy applicable to all individuals (SCE employees and non SCE workers) who have access to San Onofre regardless of department or company affiliation. Contact your Site representative for additional information. C. Continual Behavior Observation Contractors are responsible to routinely observe personnel under their cognizance for behavioral traits and patterns that may reflect adversely on their trustworthiness or reliability. Observations of aberrant behavior (deviating from the norm) shall be reported to SCE s Fitness for Duty management at or Site Security. D. Work Hour Fatigue Guidelines In order to comply with 10CFR26 Subpart I, Managing Fatigue and SONGS Procedure SO123 XV 6.2 Work Hour controls, under the NRC Work Hour Restrictions, any individual on site with unescorted access who performs work activities on Maintenance Rule Structures, Systems and Components (SSCs) are considered a covered individual and is subject to the work hour controls. Covered workers include: Operating or on site directs the operation of systems and components that a risk informed evaluation process has shown to be significant to public health and safety: performs on site maintenance or directs maintenance of SSCs that a risk informed evaluation process has shown to be significant to public health and safety: Performs Health Physics or Chemistry duties: performs oversight of Fire Brigade members who respond to fire and provide fire suppressants on safe shutdown systems (for SONGS this is an Operations responder): and security personnel duties (i.e. armed security force officer, alarm station operator, watchperson). Contingent Workers (Vendors) with access to Cross application Timekeeping System (CATS) are responsible for their own daily time entries. III. INCOMING REQUIREMENTS FOR SITE ACCESS (OWNER CONTROLLED AREA) A. Processing Requirements 1. All persons requiring SONGS site access shall be processed for a SONGS Site Access Badge or Visitor Badge at the Central Processing Facility (CPF) located in Building G50 at the SONGS Mesa. a) All persons requesting SONGS Site Access at least (3) times a week for a period of (30) days or more shall be processed for a SONGS Site Access Badge prior to starting the Work. 2. To obtain a SONGS Site Access Badge, each person must be processed at the CPF and must submit the following: a) A completed Edison form, Temporary Access Authorization for Contingent Workforce, and related documents which have been approved by an authorized Edison or manager. b) SCE Form AD (123) 3, Access Clearance Request or SONGS Visitor Access Request Form, approved by an authorized supervisor. c) Verification of Social Security registration. Exhibit A SITE ACCESS Page 3 of 11 CPF Eff. 7/12, SONGS Rev 2/12/13

4 d) Photo identification (driver s license, etc.) All persons issued a SONGS Site Access Badge will undergo a security background check, including a criminal history check. Edison s corporate security and/or a Central Processing Facility Reviewing Official shall determine if access to SONGS should be granted, not granted, or revoked. The CPF should be contacted at if there are any questions regarding processing. To obtain a SONGS Visitor Badge, each person much be processed at the CPF and must submit the following: a) SCE Form AD (123) 3, Access Clearance Request or SONGS Visitor Access Request Form, approved by an authorized supervisor. b) Verification of Social Security registration. c) Photo identification (driver s license, etc.) IV. INCOMING REQUIREMENTS FOR UNESCORTED ACCESS TO SONGS PROTECTED/RESTRICTED AREAS AND RADIOLOGICALLY CONTROLLED AREAS Contractor s and its subcontractor s employees who require unescorted access to the SONGS Protected/Restricted or Radiologically Controlled Areas must complete the following requirements. These requirements are in addition to the requirements listed under Sections I and II, General and Incoming Requirements for Site Access. Such employees require a Security photo identification badge. Applicants processing for a security photo identification badge will be screened in accordance with the Code of Federal Regulations Title 10 (Energy) Personnel Access Authorization Requirements for Nuclear Power Plant, 10 CFR A. Central Processing Facility After the award of a contract, the Contractor s representative shall contact the Supervisor, CPF at to discuss onsite dates and obtain Personal History Questionnaires from each employee. To expedite background investigation processing Contractors are requested to send in the completed Personal History Questionnaire to the address below four weeks prior to their arrival at SONGS. Supervisor, Central Processing Facility Southern California Edison Company P.O. Box 128 G50 San Clemente, CA B. Validation of Employee Status The Nuclear Regulatory Commission has requested that all contractors and its subcontractors working at nuclear plants verify the identity and resident status of their employees. San Onofre Nuclear Generating Station (SONGS) is requiring you to identify and verify the resident status of each of your employees that will be badged for work at SONGS. Exhibit A SITE ACCESS Page 4 of 11 CPF Eff. 7/12, SONGS Rev 2/12/13

5 Your form should include the following information along with the statement that will need to be completed for the employee(s) prior to the issuance of a site/security badge. I have verified the identity and resident status of each employee from the attached list and have validated that all meet the criteria as stated on Form I 9 of the United States Department of Justice. Date: Company Name: Your Name and Title: Signature (Required): Employee(s) Name(s): C. Criminal Activity Contractors are responsible to immediately notify the Supervisor, Central Processing Facility ( ), whenever they become aware that an individual who has applied for or been granted unescorted access at San Onofre has been subject to legal action(s). Legal action is a matter of state law but, in general, the term legal action means: A formal action taken by a law enforcement authority or court of law, including being held, detained, taken into custody, charged, arrested, indicted, fined, forfeited bond, cited, or convicted for a violation of any law, regulation or ordinance. This includes felony, misdemeanor, serious traffic offenses, serious civil or military charges (including non judicial punishment); and the mandated implementation of a plan for treatment or litigation in order to avoid a permanent record of an arrest or conviction in response to the following activities: (1) the use, sale, or possession of illegal drugs; (2) the abuse of legal drugs or alcohol; or the refusal to take a drug or alcohol test. It does not include minor misdemeanors such as parking tickets or minor civil actions such as zoning violations or minor traffic violations such as moving violations when the individual was not physically taken into custody. V. SITE TERMINATION REQUIREMENTS A. Notification Contractors are required to notify the CPF of employee terminations/transfers within 24 hours by telephone to or by submittal of Termination Form SCE AD (123) 10. Telephone notification must be followed by written notification within five working days. Notification is required under the following conditions: 1. Employee no longer requires unescorted access to the Protected and Vital Areas. 2. Employee leaves SONGS (job assignment completed or leaves for 30 or more days). 3. Employee terminates or changes employment. Questions concerning termination may be directed to the Central Processing Facility at or Exhibit A SITE ACCESS Page 5 of 11 CPF Eff. 7/12, SONGS Rev 2/12/13

6 B. Processing Out Requirements 4. Return of the SONGS site badge or visitor badge. 5. Computer clearance for outstanding actions, such as the return of loaned Edison property. 6. A Whole Body Count, if required. 7. Submittal of Termination Form SCE AD (123) 10 to the CPF by the responsible contractor or onsite supervision. VI. TRAINING REQUIREMENTS A. Radiological Training Radiological training is required prior to Restricted Area (RA), Low Hazard Radiologically Controlled Area (LHRCA), or Radiological Controlled Area (RCA) entry. Training requirements vary depending on the access area, access duration, and whether escorted or unescorted access is needed. Training qualifications may range from just the Restricted Area Handout through Radiation Worker Training as determined by the Cognizant Training Supervisor/Designee. VII. HEALTH PHYSICS REQUIREMENTS A. Personnel Monitoring Records Each individual who expects to enter the Restricted Area should present records of dose received during the current year. Each individual should know their lifetime does received. The following documentation may be provided to satisfy those dose reporting requirements. Current year a) NRC Form 5 signed by a licensee; or b) NRC Form 4 signed by a licensee/employer; or c) NRC Form 4 signed by the individual stating no current year dose. Note: Due to differences between European and United States radioactive material release limits and equipment calibration methods, some workers from European plants have been released according to the European standard and have been found contaminated when they enter a U.S. plant where they are monitored using the U.S. standard. San Onofre monitors to 5000 dpm/100cm2 and expects that incoming workers and their personal items (e.g. clothing, shoes, lanyards, glasses), and all clean tools and equipment will meet this standard. B. Administrative Dose Controls 1. San Onofre imposes annual administrative dose controls of 1000 mrem received at SONGS and 2000 mrem SONGS plus offsite total effective dose equivalent (TEDE). Lifetime dose is administratively controlled to one (1) rem for each year of age. 2. Contractor personnel should have sufficient dose remaining to complete their assigned task. Workers who will require an extension beyond the administrative dose control shall not be sent to San Onofre unless approval is granted by both the authorized Edison representative and the Health Physics ALARA Supervisor. Exhibit A SITE ACCESS Page 6 of 11 CPF Eff. 7/12, SONGS Rev 2/12/13

7 C. Bioassay Requirements 1. Upon termination of work assignment and before leaving site, all contract employees who entered the RCA shall receive an exit whole body count at the Health Physics, D 1G (bottom floor of the AWS Building). If the employee made entry into the RCA the day the exit whole body count is requested, the employee will be required to be whole body counted in a paper suit and socks, no undergarments. After hours processing may be arranged by contacting the Health Physics Supervisor two (2) days before scheduled departure at PAX or If an employee leaves the site without receiving an exit whole body count, the Contractor shall have the employee return to SONGS or other mutually agreeable location to receive the whole body count. All costs associated with having an employee return to San Onofre for the whole body count or performing a whole body count at another location shall be borne by the contractor. D. Respiratory Requirements 1. Contractor employees requiring respiratory protection equipment shall provide a medical certification signed by a licensed physician within the past twelve (12) months stating that the employee is medically capable of wearing a respirator in accordance with NUREG Edison has an onsite contract physician and the contractor and its subcontractors may utilize this service. The cost of the medical service shall be borne by Edison. 3. Edison is not responsible for providing safety eyewear for contract employees who require eyeglasses or corrective lenses. E. Expedited Dosimetry Processing (for contractor employees traveling immediately to another plant for a work assignment, contact Health Physics Dosimetry at PAX or and provide the following): 1. Individual s name 2. Social Security Number 3. Badge Storage Slot Number and 4. Time and date of last shift to be worked VIII. CONTROL OF CHEMICALS AND CONSUMABLE MATERIALS All consumable materials used at SONGS shall be evaluated, labeled and used in accordance with San Onofre Procedure SO123 XV 42, Control and Use of Consumable Materials. This procedure governs the use of products such as absorbents, adhesives, caulks, coatings, cleaning solution detergents, dye penetrants, glues, inks, lubricants, sealants, solvents, tapes, etc. Items previously evaluated and approved for use are listed on the Station s Approved Products List (APL) previously approved products. A list of all consumables being brought onsite should be submitted to the Authorized Edison Representative (AER) at Exhibit A SITE ACCESS Page 7 of 11 CPF Eff. 7/12, SONGS Rev 2/12/13

8 least two weeks prior to contractor arrival on Site. The AER will coordinate obtaining labels and, if necessary, adding new products to the APL. Contractors may be required to provide chemical analyses of products. Additional information and copies of SO123 XV 42 can also be obtained contacting the San Onofre consumable Materials Control Coordinator at IX. SAFETY CONCERNS A. Contractor Responsibilities Associated With the Establishment and Maintenance of the SONGS Safety Conscious Work Environment 1. Safety Conscious Work Environment Southern California Edison Company (SCE) is committed to the safe operation of the San Onofre Nuclear Generating Station (SONGS) and to maintaining a Safety Conscious Work Environment (SCWE) in which SONGS workers identify safety concerns, and communicate those concerns to their supervision, the SONGS Employee Concerns Program (ECP) employer, or to the Nuclear Regulatory Commission (NRC) without fear of retaliation of any type for doing so. a) Contractor shall establish and maintain a similar SCWE within its organization, in particular, an environment in which Contractor personnel working at SONGS (or on SONGS related work) have the right, and are encouraged to identify safety concerns and communicate those concerns to Contractor or SCE supervision (either their employer or SCE), Contractor or SCE ECP, or the NRC. b) Contractor shall afford its personnel working at SONGS (or on SONGS related work) the right to communicate safety concerns to the entities identified in 1.b. on paid time consistent with requirements for coordination of absence from work locations with supervision. 2. Employee Concerns Program The SONGS ECP is an alternative means for SONGS workers (SCE, contractor, and subcontractor) to report safety concerns openly, confidentially, or anonymously, and have appropriately addressed. a) Because the SONGS ECP is open and available to both SCE employees as well as contractor and subcontractor employees, SCE encourages, but normally does not require it contractors to establish their own ECP. b) If SCE requires Contractor to establish its own ECP, this requirement shall be specifically identified in the contract between SCE and Contractor. c) If Contractor has its own an ECP (whether or not required by SCE), Contractor shall permit SCE ECP Manager or designee access to the contractors ECP files for the purposes of periodically assessing whether Contractor ECP satisfies generally accepted regulatory and/or industry standards. Exhibit A SITE ACCESS Page 8 of 11 CPF Eff. 7/12, SONGS Rev 2/12/13

9 3. Harassment, Intimidation, Retaliation or Discrimination Strictly Prohibited SCE strictly prohibits harassment, intimidation, retaliation or discrimination (collectively retaliation ) of SONGS personnel (SCE, contractor, and subcontractor) for communicating safety concerns. In other words, an individual s communication of a safety concern shall not be a motivating or contributing factor in subjecting the worker to an adverse employment action. a) Contractor is strictly prohibited from retaliating against personnel working at SONGS (or on SONGS related work) for reporting safety concerns. b) Contractor shall cooperate fully with any SCE investigation into complaints and/or allegations of retaliation raised by or involving Contractor (or subcontractors ) personnel working at SONGS (or on SONGS related work). c) Contractor shall promptly notify SCE of all claims and allegations of retaliation raised by or involving its (or its subcontractors ) personnel working at SONGS (or on SONGSrelated work) irrespective of the forum in which the claim or allegation was brought, including, but not limited to the NRC, the U.S. Department of Labor, other Federal and State government agencies and courts, and the Contractor ECP or similar program. B. Contractor Knowledge of Employee Protection Requirements and Expectations a) Prior to the start of work, the Contractor Site Manager shall meet with the SONGS [TITLE] or their designee, as applicable, to be apprised of: i. Contractor obligations and requirements regarding SCE s commitment to a SCWE and its strict adherence to applicable laws and regulations prohibiting retaliation for raising safety concerns, including, but not limited to the Section 211 of the Energy Reorganization Act, and 10 C.F.R. 50.7; ii. The SONGS locations posting NRC Form 3. The Contractor may be requested to post NRC Form 3 at additional locations. b) Contractor shall assure that its site employees and subcontractors have been informed of the locations where NRC Form 3 has been posited. c) Contractor shall assure that Contractor supervision and subcontractors have been acquainted with the proper conduct for managing safety concerns raised by its employees. d) Contractor shall ensure that Contractor and subcontractor personnel understand their rights and obligations as defined by SCE s policies and NRC s policies and regulations regarding: i. Creating and maintaining a SCWE; Exhibit A SITE ACCESS Page 9 of 11 CPF Eff. 7/12, SONGS Rev 2/12/13

10 X. SONGS PHOTO/VIDEO POLICY ii. The responsibility to identify and report safety concerns; iii. The available mechanisms for reporting safety concerns; iv. Prohibiting retaliation for raising safety concerns The use of cameras and video equipment at SONGS (anywhere on site) must be approved by an authorized Edison representative. No cell phone pictures are permitted. Any exceptions to this policy must be approved by the Plant Manager or Station Manager. It is each employee s responsibility to assure that all photographs and videos of SONGS property or personnel are taken and used for valid business purposes. A. The taking of photos or video (photographic or digital images) of SONGS property or personnel may be done by: 1. Personnel with unescorted access, and 2. For valid business purposes, and 3. Using SCE equipment. B. Visitors may only take photos or video for: 1. Valid business purposes, and 2. When under the supervision of an SCE employee. C. The resulting photos or video are company property and, unless approved for release to the public, are to be protected in accordance with existing Corporate Policy (ESM: ). D. The above rules apply to all SONGS properties: i.e. the SONGS Mesa, Owner Controlled Area and Units 2/3 and ISFSI Protected Areas. E. Taking or using photos or videos of the site for activities that are NOT work related is prohibited. F. In implementing the above policy, employees are advised of the following: 1. Employees should be prepared to be questioned on any pictures being taken on SONGS property. In particular, employees should expect Security to question any photos or video of defensive security equipment or security personnel performing their duties. 2. The use of wireless image making equipment onsite is prohibited. This includes making pictures or videos using cell phones or Personal Digital Assistants (PDAs) with photo/video capability. (Cell phones may be used for oral communication only.) 3. Failure to comply with the SONGS camera/video policy may result in disciplinary action, up to and including termination. 4. Finally, all employees are reminded to report any unusual or suspicious activity to Security at PAX Exhibit A SITE ACCESS Page 10 of 11 CPF Eff. 7/12, SONGS Rev 2/12/13

11 Exhibit A SITE ACCESS Page 11 of 11 CPF Eff. 7/12, SONGS Rev 2/12/13