CP-202100090, (Cpnpp), Supplement to Subsequent Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs

(Cpnpp), Supplement to Subsequent Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs

ML21040A512
Person / Time
Site:	Comanche Peak
Issue date:	02/09/2021
From:	Thomas McCool Luminant, Vistra Operations Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-202100090, T 254.897.6042, TXX-21055
Download: ML21040A512 (2)

Text

II Thomas P. McCool Site Vice President Comanche Peak Nuclear Power Plant (Vistra Operations Company LLC)

Luminant P.O. Box 1002 6322 North FM 56 Glen Rose. TX 76043 T 254.897.6042 CP-202100090 TXX-21055 February 9, 2021 U. S. Nuclear Regulatory Commission Ref 10 CFR 26.9 ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446 Supplement to Subsequent Request for Exemption from Specific Requirements of 10 CFR Part 26, "Fitness for Duty Programs"

References:

1. Vistra OpCo letter dated February 8, 2021, "Subsequent Request for Exemption from Specific Requirements of 10 CFR Part 26, 'Fitness for Duty Programs"' [ML21039A688]

2. NRC letter from H. Nieh to NEI dated November 10, 2020, "U.S. Nuclear Regulatory Commission Updated Planned Actions Related to Certain Requirements for Operating and Decommissioning Reactor Licensees During the Coronavirus Disease 2019 Public Health Emergency" (ML20261H515)

3. NRC letter from Philip J. McKenna to Vistra OpCo dated December 16, 2020, "Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 - Exemption from Select Requirements of 10 CFR Part 26 (EPID L-2020-LLE-0236 [COVID-19])" [ML20349A038]

Dear Sir or Madam:

In Reference 1, Vistra Operations Company LLC (Vistra OpCo) requested a subsequent exemption from certain 10 CFR Part 26 work hour requirements for Comanche Peak Nuclear Power Plant (CPNPP) as a result of the Coronavirus Disease 2019 (COVID-19) public health emergency (PHE).

The following information supplements the Reference 1 submittal to further address the guidance for subsequent requests detailed in the Reference 2 NRC letter:

• To date, the alternative controls approved with the Reference 3 letter have not been invoked at CPNPP during the period commencing December 16, 2020. Station management continued to control the work hours of the covered personnel in accordance with 10 CFR 26.205(d)(l) - (d)(7).

• To date, no waivers or exceedances of the work-hour controls of 10 CFR 26.205(d)(l) - (d)(7) have occurred during the exemption period commencing December 16, 2020.

TXX-21055 Page 2 of2

• To date, no instances requiring fatigue assessments arising from self-declared or behavioral observations of fatigue have occurred since the beginning of the exemption period commencing December 16, 2020.

• Vistra OpCo plans to operate CPNPP Units 1 and 2 in Mode 1 at full power during the extended exemption period. The next scheduled refueling outage is planned for the Fall of 2021.

• As described in the Reference 1 letter, CPNPP will administer the alternative work-hour controls in accordance with the procedure STA-615, "Fatigue Management and Staff Work Hours."

This communication contains no new commitments regarding CPNPP Units 1 and 2.

Should you have any questions, please contact Jim Barnette at (254) 897-5866 or Tames.bamette@luminant.com.

Thomas P. McCool c (email)- Scott Morris, Region N [Scott.Morris@nrc.gov]

Dennis Galvin, NRR [Dennis.Galvin@nrc.gov]

John Ellegood, Senior Resident Inspector, CPNPP Uohn.Ellegood@nrc.gov]

Neil Day, Resident Inspector, CPNPP [Neil.Day@nrc.gov]