LIC-13-0007, Response to NRC Request for Additional Information Re Request for Work Hours Exemption

Response to NRC Request for Additional Information Re Request for Work Hours Exemption

ML13101A004
Person / Time
Site:	Fort Calhoun
Issue date:	03/16/2013
From:	Prospero M Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-13-0007
Download: ML13101A004 (10)

Text

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iJppii Omaha Public Power Oislrfcf 444 South 1fin Street Mall Omaha, NE 68102-2247 LI C-13-0007 March 16, 2013 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

References:

1. Docket No. 50-285

2. Letter from Omaha Public Power District (Louis P. Cortopassi) to NRC (Document Control Desk), Request for One-Time Exemption from Requirements of 10 CFR 26.205(d)(7), dated October 10, 2012, (ML12284A344), (LlC-12-0145)

3. Email from NRC (L. E. Wilkins) to OPPD (8. R. Hansher), DRAFT: RAls Fort Calhoun Work Hour Exemption Request (TAC No. ME9770), dated January 8, 2013

SUBJECT:

OPPD Response to NRC RAI Regarding Request for Work Hours Exemption As requested in Reference 3, attached is the Omaha Public Power District's (OPPD) response to the Nuclear Regulatory Commission's (NRC) Request for Additional Information (RAI) concerning OPPD's Reference 2 Exemption Request. To support the restart of Fort Calhoun Station in a safe, effective, and efficient manner, approval of the exemption request is requested by March 31, 2013.

No regulatory commitments are contained in this submittal.

If you should have any questions, please contact Mr. Bill R. Hansher at (402) 533-6894.

Sincerely,

~~p~

Michael J. Prospero Plant Manager MJP/DRT/mle

Attachment:

OPPD Response to NRC RAI E. E. Collins, Jr., NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. M. Sebrosky, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector Employment with Equal Opportunity

LlC-13-0007 Attachment Page 1 REQUEST FOR ADDITIONAL INFORMATION FORT CALHOUN STATION. UNIT 1 EXEMPTION REQUEST DOCKET NUMBER 50-285 By letter dated October 10, 2012 (ADAMS Accession No. ML12284A344) and pursuant to 10 CFR 26.9, Omaha Public Power District (OPPD) requested a one-time exemption for Fort Calhoun Station, Unit 1 (FCS) from specific requirements of 10 CFR 26.205(d)(7). OPPD is requesting to use the less restrictive working hour requirements of 10 CFR 26.205(d)(4) and (d)(5) in lieu of 10 CFR 26.205(d)(7) during the unit restart.

FCS has been in an extended outage since April 9, 2011. The exemption request states that personnel performing the duties defined in 10 CFR 26.4(a)(1) through (a)(5) transitioned to working an on-line schedule that complied with 10 CFR 26.205(d)(3) on August 29,2011. In August 2012 the station processes and procedures were revised to adopt an on-line schedule that complies with the alternative maximum average work hour provisions of 10 CFR 26.205(d)(7).

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the information provided by the licensee and has determined that the following information is needed in order to complete its review.

1. Please provide additional details regarding the activities that are required to restart the plant and how those activities increase the workload for the plant.

Please explain why a relaxation of the work hour controls is needed prior to restarting the plant.

OPPD Response To provide an appreciation for the numerous work activities required to restart Fort Calhoun Station (FCS), it is helpful to discuss the recent history of natural and manmade events that have occurred at FCS since the spring of 2011.

On April 9, 2011, FCS commenced its 2011 Refueling Outage (RFO). On June 6, 2011, a Notification of Unusual Event (NOUE) was declared in anticipation that the level of the Missouri River would reach 1004 feet mean sea level (MSL) (Event Notification 46929). The following day, FCS experienced a fault in an electrical bus, resulting in a fire and damage to the bus (Event Notification 46932). The fire was quickly extinguished; however, FCS remained challenged by the flood throughout the summer of 2011. On August 29, 2011, FCS exited the NOUE as the level of the Missouri River was at 1003.56 feet MSL and receding.

Subsequent to the flood, on December 13,2011, the NRC informed OPPD that FCS had transitioned to Inspection Manual Chapter (IMC) 0350, "Oversight of Reactor Facilities in a Shutdown Condition Due to Significant Performance and/or

LlC-13-0007 Attachment Page 2 Operational Concerns," (Reference 1). The conditions that led to the transition to IMC 0350 included the plant being in an extended shutdown with significant performance problems, and a significant operational event involving a fire in safety-related electrical switchgear, which occurred on June 7, 2011.

OPPD has undertaken comprehensive and aggressive actions to fully scope and correct the impact of the flood and performance problems at FCS. The effort began with a comprehensive assessment of systems, structures, and components (SSC) and continued with detailed plans for repair, restoration, and performance improvement (References 2 and 3).

Because of the events noted above, there is an extremely large workload to accomplish prior to restart. The workload is due in part to the extended outage since as noted in Reference 4, Item 2.b; systems that have been shut down for prolonged periods are subject to different environments than those experienced during power operations.

During the extended shutdown and because of being in IMC 0350, a number of issues have been discovered that must be resolved prior to restart. For example, Reference 5 notes that six (6) reactor containment building electrical penetrations were identified that may not provide an adequate seal following a design basis accident (DBA). These penetrations must be tested and restored to full environmental qualifications prior to plant restart. As noted in Reference 4, a review of high-energy line break (HELB) calculations has identified examples of documentation and calculation inadequacies associated with HELB effects and electrical equipment qualification (EEQ) issues in some areas of the plant.

The resolution of many of the issues that have been discovered will require modifications to plant equipment, which will increase the workload on personnel subject to work hour controls. FCS personnel must also complete actions associated with the NRC's restart checklist that is intended to verify that the Issues that resulted in the prolonged performance decline at Fort Calhoun Station are resolved prior to restart. Although the workload associated with the restart checklist may fall primarily on non-covered workers, there is still a substantial amount of work that covered workers must support as well as it involves additional modifications, walk downs, inspections, etc., that are not associated with a normal refueling outage.

In summary, as a result of the extended outage and being in IMC 0350, FCS personnel including workers governed by 10 CFR 26.205 must put in additional hours beyond that required by a normal refueling outage. To accomplish the tasks listed above safely, efficiently, and effectively requires that OPPD be given the flexibility to schedule workers in accordance with 10 CFR 26.205(d)(4) and (d)(5).

2. Please explain how each of the job duty groups specified in 26.4(a)(1) through (a)(5) are impacted by the restart activities.

LI C-13-0007 Attachment Page 3 OPPD Response A one-time exemption from specific requirements of 10 CFR 26.205(d)(7) is requested to permit the increased work days necessary to effectively support the staffing requirements for activities associated with plant startup. The following provides a sampling of activities required to support plant startup.

Operations personnel (10 CFR 26.4(a)(1>> support plant startup by their involvement in startup and return to service of plant systems, surveillance testing, post maintenance testing, and reactor restart activities. The relaxation of 10 CFR 26.205(d)(7) work hour controls in favor of the less restrictive work hour requirements of 10 CFR 26.205(d)(4) and (d)(5) ensures that sufficient operations personnel are available to perform the increased activities associated with plant startup.

Radiation protection (RP) personnel (10 CFR 26.4(a)(2>> support plant startup by providing RP support to operations and maintenance personnel that have an increased need to access radiologically controlled areas. RP personnel also provide support in de-mobilizing maintenance equipment from containment for off-site shipment and on-site storage. The increased workload for RP personnel associated with plant startup as compared to an on-line schedule requires a temporary relaxation of 10 CFR 26.205(d)(7) work hour controls in favor of the less restrictive work hour requirements of 10 CFR 26.205(d)(4) and (d)(5).

Chemistry personnel (10 CFR 26.4(a)(2>> support plant startup by performing additional chemistry sampling at frequencies that cannot be met by an on-line staffing level. The increased workload for chemistry personnel associated with plant startup as compared to an on-line schedule requires a temporary relaxation of 10 CFR 26.205(d)(7) work hour controls in favor of the less restrictive work hour requirements of 10 CFR 26.205(d)(4) and (d)(5).

Fire brigade members (10 CFR 26.4(a)(3>> - fire brigade members at Fort Calhoun Station are comprised of on-shift operations and security personnel. Thus, in addition to supporting the fire brigade, these individuals also perform operations and security duties as described in this section.

Maintenance personnel (10 CFR 26.4(a)(4>> support plant startup by their involvement in surveillance testing required by Technical SpeCifications (TS).

Maintenance personnel assist with making required valve, system, and instrument lineups and complete post maintenance testing for equipment returned to service.

Maintenance personnel must also respond to emergent equipment issues. The increased workload for maintenance personnel associated with plant startup as compared to an on-line schedule requires a temporary relaxation of 10 CFR 26.205(d)(7) work hour controls in favor of the less restrictive work hour requirements of 10 CFR 26.205(d)(4) and (d)(5).

Security officers (10 CFR 26.4(a)(5>> support plant startup by implementing additional compensatory measures associated with controlling access to equipment

LI C-13-0007 Attachment Page 4 in startup testing. Additional security officer support is also required for demobilizing equipment and removing it from the protected area. The increased workload for security officers that is associated with plant startup as compared to an on-line schedule requires a temporary relaxation of 10 CFR 26.205(d)(7) work hour controls in favor of the less restrictive work hour requirements of 10 CFR 26.205(d)(4) and (d)(5).

3. Please provide additional information on the schedule for restart activities.

Specifically, please explain why 60 days is necessary for the exemption.

OPPD Response The current refueling outage schedule shows fuel loading scheduled for April 12, 2013, with plant heat-up scheduled for May 15, 2013.

Approval of the requested exemption would allow the less restrictive work hour limitations described in 10 CFR 26.205(d)(4) and (d)(5) to be applied to the extent necessary to support those activities required to return FCS to service. The 60-day period specified in the exemption request ensures that the exemption is not open-ended. The requested 60-day period is consistent with the provisions of 10 CFR 26.205(d)(4) and (d)(5). Although OPPD may not utilize the entire 60-day period, the additional time will allow OPPD management and staff to properly plan and execute the complex evolutions required to safely and efficiently return the plant to service. A temporary relaxation in the work hour controls of 10 CFR 26.205(7) also ensures that adequate resources are available to respond to unforeseen events.

4. The letter dated October 10, 2012 originally requested approval for this exemption by November 10,2012 to support the restart of FCS. Please state if there is a projected schedule for when restart activities will commence.

OPPD Response As stated above, the current refueling outage schedule shows fuel loading scheduled for April 12, 2013, with plant heat-up scheduled for May 15, 2013.

Beginning April 1, 2013 through May 30, 2013, FCS would like to go to a "supercrew" outage schedule for Operations personnel. The benefits of such a schedule include:

• Allows crews to acclimatize to their outage shift.

• Allows crew personnel to become more familiar with each other.

• Allows a transition period from normal shift rotation to the outage shift rotation (accommodate transitioning people from days to nights and vice versa).

• Ensures that sufficient personnel are available to pre-stage equipment for the first few days of the outage and to walkdown worker protection clearances for timely turnover to maintenance teams.

LlC-13-0007 Attachment PageS

• Provides better preparation time, including pre-job briefs, to safely accomplish the large number of infrequently performed tasks associated with restarting the plant after an extended plant shutdown.

• Lowers stress levels in the Control Room because personnel are better prepared.

• The additional preparation time reduces the chance for human performance errors and improves overall safety.

• Ensures that sufficient personnel are available to handle emergent issues that can occur after an outage (there are a large number of activities for Operations in the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> centered around unit output breaker closure).

• The better a plant deals with outage recovery (Le., resolves emergent issues) the fewer challenges experienced during the cycle.

5. Please explain why the restart activities cannot be accomplished using the maximum average work hour controls of 26.205(d)(7).

OPPD Response FCS personnel including workers governed by 10 CFR 26.205 must put in additional hours beyond that permitted by 10 CFR 26.205(d)(7) in order to safely, efficiently, and effectively restart the plant. There are an extremely large number of tasks to accomplish in restarting a unit after an extended shutdown following a flood and significant operational event. FCS personnel are also supporting NRC IMC 0350 inspections, which are likely to add additional tasks to accomplish before the plant will be allowed to restart. Personnel whose work hours are subject to control by 10 CFR 26.205 will be key to resolving many of these issues in a timely manner, which is beneficial to public health and safety as well as in minimizing the impact of the shutdown on electric rates.

In addition to considering the potential for cumulative fatigue, the NRC considered current industry data on the duration of unit outages in determining whether the cost to licensees imposed by limiting the exclusion period to 60 days was justified in terms of the benefit. The NRC considered it appropriate to allow flexibility within the work hour requirements to accommodate limited periods of more intensive work schedules, such as unit outages. The NRC limited this flexibility to infrequent circumstances, such as unit outages, to limit the potential for cumulative fatigue.

Further, the NRC considered the substantial cost to licensees for meeting the requirements applicable to periods of plant operation through either increasing staffing (to minimize outage durations) or increasing outage durations to accommodate a less intensive work schedule. Given these considerations, the NRC concluded that a limited period of less restrictive work hour requirements, as included in the final rule, is better justified by the costs and benefits.

6. By letter dated October 10, 2012, Davis Besse was referenced as a precedent.

Davis Besse was granted an exemption for 21 days immediately following the expiration of its window for extending outage hours, as outlined in 26.205(d)(6), because individuals performing covered work during the outage worked no more than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in at least 3 non-overlapping 7 day periods

LlC-13-0007 Attachment Page 6 during the first 60 days of the outage. Please explain the rationale for using Davis Besse as the precedent for this exemption.

OPPD Response Davis-Besse was cited as precedenf because it was also seeking an exemption because of an extended outage. Following the 60 days allowed by the less restrictive work hour limitations of 10 CFR 26.205(d)(4) and (d)(5), Davis-Besse personnel transitioned to an online schedule that complied with 10 CFR 26.205(d)(3) requirements.

In a similar manner, after the NOUE was exited on August 29,2011, FCS personnel performing the duties specified in 10 CFR 26.4(a)(1) through (a)(5) transitioned to an online schedule that complied with 10 CFR 26.205(d)(3) for minimum days off. In August 2012, as permitted by the regulation, FCS transitioned from compliance with 10 CFR 26.205(d)(3) to compliance with the maximum average work hour requirements of 10 CFR 26.205(d)(7).

OPPD considered citing the Crystal River Unit 3 (CR-3) exemption request (ML102000019), because its situation has certain parallels with the situation at FCS.

For example, CR-3 was in an extended outage preparing for an extended power uprate when delamination was discovered in the reactor-building wall. FCS was also in a refueling outage that was subsequently delayed by the onset of flooding and a fire in safety-related switchgear. However, Florida Power Corporation subsequently withdrew (ML11103A077), the CR-3 exemption request and OPPD does not cite unapproved exemption requests as precedent.

7. Page 4 of attachment 1 states that "assurance has been provided that cumulative fatigue will not compromise the ability of these individual to safely and competently perform their duties" because these individuals have been working a "normal on-line schedule" since August 29, 2011. Please explain what a "normal, on-line schedule" is and how it ensures fatigue management.

OPPD Response In August 2012, as permitted by the regulation, FCS transitioned from compliance with 10 CFR 26.205(d)(3) (minimum days off) to compliance with the maximum average work hour requirements of 10 CFR 26.205(d)(7). This regulation states that individuals may not work more than a weekly average of 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> calculated using an averaging period of up to six (6) weeks, which advances by seven (7) consecutive calendar days at the end of each averaging period.

This alternative method for managing cumulative fatigue establishes a requirement to limit actual hours worked instead of mandating the number of days off those individuals must have. A limit on actual hours worked, when applied to schedules that require regular shift coverage, limits the number of work hours that can contribute to cumulative fatigue and, as a practical matter, results in periodic days off for recovery rest. A schedule resulting in a weekly average of 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> worked,

LlC-13-0007 Attachment Page 7 calculated using an averaging period of up to 6 weeks that incrementally advances on a consistent basis is such a schedule.

This alternative approach, together with other aspects of the rule provides reasonable assurance that cumulative fatigue is managed in a manner that contributes to the protection of public health and safety and common defense and security.

Since August 2012, FCS personnel have averaged considerably less than 54-hours per week. FCS's fatigue management program also encompasses more than just work hour controls. Training and behavioral observations also ensure that worker fatigue is appropriately managed. Standing Order (SO) SO-G-52, "Plant Staff Working Hours" addresses worker fatigue at length.

When establishing work schedules, SO-G-52 requires that the following items be considered:

• Duration of scheduled work period,

• Duration of break periods,

• Consistent start times for work periods,

• Start times consistent with circadian factors,

• Consistent stop times for work periods,

• Consistent rotation from days to nights,

• Stable 24-hour rotation,

• Impact of backward shift rotation,

• Rotating schedules provide suitable transition between shifts,

• Circadian factors - fixed versus rotating shifts

• Training requirements,

• Vacation scheduling,

• Impact of unscheduled overtime.

For the period from December 30, 2012 to February 2, 2013, operations, maintenance, chemistry, security, and RP personnel have averaged 38.5, 42.2, 35.5, 40.4, and 39.6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> per week respectively. No waivers have been issued under 10 CFR 26.207 by FCS operations, maintenance, chemistry, security or RP departments since the end of January 2012.

It should be noted that the 2011 RFO has extended past the date when the fall 2012 RFO was scheduled to begin. As a result, FCS covered workers have worked on-line work hours for a longer period in the present extended RFO than they would have had FCS been operating and entered outage hours in the fall of 2012 as originally scheduled. As such, fatigue should be less of an issue for these workers than it would be upon entering a refueling outage after a normal cycle of operation.

Consequently, OPPD is confident that cumulative fatigue will not be an issue going into restart.

LI C-13-0007 Attachment Page 8

8. The Statement of Considerations for 10 CFR Part 26 states that the provisions of 26.205(d) should not be considered guidelines for routine work scheduling because 26.205(d) does not address several elements of work scheduling that can significantly affect worker fatigue, such as shift length, the number of consecutive shifts, the duration of breaks between blocks of shifts, and the direction of shift rotation. Therefore, 26.205(c) requires licensees to schedule personnel consistent with preventing impairment from fatigue. Please state what FCS is doing to ensure fatigue management, other than the work hour controls of 26.205(d).

OPPD Response Since exiting the NOUE on August 29, 2011, FCS has maintained an online work schedule for covered workers in accordance with the applicable regulations of 10 CFR 26.205.

This type of schedule is designed to minimize worker fatigue, as it only requires a standard 40-hour work week when practical. Step 4.2.2 of SO-G-52 states 'When practical, maintain a forty-hour week during normal plant operation. AVOID the use of overtime to meet routine operational requirements. If overtime is necessary, the use of overtime shall be considered on an individual basis and not for the entire work group."

The combination of a 40-hour work week with the scheduling considerations described in the response to question 7 above will ensure that worker fatigue has been minimized prior to approval of this exemption request.

9. On page 4 of attachment 1, the request states that "the benefit to affected employees will result in a positive impact to the public interest." Please explain how this exemption benefits affected employees and result in a positive impact to the public.

OPPD Response The main purpose behind the work hour rule was to improve safety by managing fatigue with one of the underlying goals to improve worker quality of life. The flexibility contained in this exemption request will be helpful in promoting a safe, effective, and efficient startup and will improve covered workers quality of life, as additional resources will be available to handle the increased workload associated with restarting the plant. The exemption will also allow the worker an opportunity to move his or her day off to a more convenient day. The public benefits from the additional resources that will be allowed by the exemption because the availability of these resources ensures that the restart of Fort Calhoun Station is safe, effective, efficient, and minimizes the impact on electric rates.

LlC-13-0007 Attachment Page 9 References

1. NRC Memorandum from Elmo Collins to Martin S. Virgilio, "Notification of Change to Regulatory Oversight of Fort Calhoun Station," dated December 13, 2011 (NRC-11-0136)

2. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), "Fort Calhoun Station Integrated Performance Improvement Plan, Revision 3," dated July 9,2012 (ML12192A204) (LlC-12-0098)

3. Letter from OPPD (T. W. Simpkin) to NRC (Document Control Desk), "Fort Calhoun Station Integrated Performance Improvement Plan, Revision 4," dated November 1, 2012 (ML12311A164) (LlC-12-0165)

4. NRC Memorandum from Tony Vegel to Eric Leeds), "Issuance of U.S. Nuclear Regulatory Commission Manual Chapter 0350 Panel Fort Calhoun Station Restart Basis Document," dated November 13, 2012 (NRC-12-0106)

5. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), "Licensee Event Report 2012-002, Revision 0, for the Fort Calhoun Station," dated May 1, 2012 (ML12208A313) (LlC-12-0043)