ML101600134
| ML101600134 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 06/09/2010 |
| From: | Lashley P FirstEnergy Corp |
| To: | Michael Mahoney Plant Licensing Branch III |
| mahoney, m NRR/DORL/LPLIII-2 415-3867 | |
| References | |
| Download: ML101600134 (5) | |
Text
From: phlashley@firstenergycorp.com Sent: Wednesday, June 09, 2010 9:23 AM To:
Mahoney, Michael Cc:
hlhegrat@firstenergycorp.com; jeemley@firstenergycorp.com; rritzman@firstenergycorp.com; rehoward@firstenergycorp.com; kmnesser@firstenergycorp.com
Subject:
Request for Additional Information - Part 26 Exemption 10 CFR 26.205(d)(3)
By letter dated May 28, 2010, FirstEnergy Nuclear Operating Company (FENOC) requested Nuclear Regulatory Commission (NRC) review and approval of an one-time exemption from portions of 10 CFR 26.205(d)(3) for the Davis-Besse Nuclear Power Station (DBNPS). By email dated June 7, 2010, the NRC staff requested additional information relevant to the requested exemption. FENOC responses to the NRC staff's questions are provided below. Each of the NRC staff's questions is provided in bold followed by the FENOC response.
- 1. The exemption request states that approval of the exemption will be necessary by June 14, 2010 in order to support the activities required to complete the current extended DBNPS.
Why specifically is this exemption required for security officers (26.4(5))?
Why specifically is this exemption required for health physics and chemistry (26.4(2))?
Why specifically is this exemption required by fire brigade members (26.4(3))?
Why specifically is this exemption required by maintenance (26.4(4))?
Why specifically is this exemption required by operations (26.4(1))?
FENOC Response: The exemption is requested to allow a one-time relaxation of the MDO requirements to support the increased workdays 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.
Security officer (26.4.a(5)) plant startup support includes the compensatory measures associated with controlling access to equipment in startup testing, in addition to the increased support for required for demobilization of equipment and then removal from the protected area. These activities require an increased level of staffing more so than required for on-line staffing.
Radiation Protection (26.4.a(2)) personnel plant startup activities include supporting operations and maintenance personnel accessing plant areas designated as radiologically controlled areas and providing support to de-mobilize maintenance equipment from containment for off-site shipment and on-site storage.
Chemistry (26.4.a(2)) personnel plant startup activities include
additional chemistry sampling and frequencies that cannot be performed with on-line staffing. Increased staffing levels through relaxation of MDO requirements will support chemistry sampling requirements for startup.
Maintenance (26.4.a(4)) personnel activities that support plant startup include Technical Specification surveillance testing, support valve and instrument lineups, complete post maintenance testing for returned to service equipment, and respond to emergent equipment issues.
Operations (26.4.a(1)) personnel activities include startup and return to service of plant systems, surveillance testing, post maintenance testing, and reactor restart activities. Increased staffing levels allowed by relaxation of the MDO requirements ensure sufficient operations personnel are available to perform the increased activities associated with plant startup.
Fire Brigade members (26.4.a(3)) - All fire brigade members at Davis-Besse are on-shift operations personnel and are impacted by the operations personnel activities listed above.
- 2. The MDO relaxation (26.205(d)(4) states the relaxation is available to those individuals are working on outage activities." The exemption requests states the less restrictive work hour controls are needed to support the activities required to complete the current extended outage.
What are the activities?
How will less restrictive MDO support these activities for each of the job duty groups listed above?
FENOC Response: Startup activities for the applicable groups are described in the response to question 1. The less restrictive MDO allows for each covered worker receiving the exemption to work an additional day each week.
Less restrictive MDO requirements will support the staffing requirements necessary for activities associated with plant startup.
- 3. There is an outage MDO extension available in 26.205(d)(6). The Davis-Besse MDO exemption request falls partially within the allowed 56 day window. Why is this existing exception not used?
FENOC Response: Two to three weeks prior to the scheduled end of the normal outage period, which occurred on April 28, 2010, covered workers in the Operations, Maintenance, Chemistry, and Radiation Protection Departments reduced work hours with the intention of applying the outage MDO extension available in 26.205(d)(6). This was a decision made by FENOC management to ensure proper fatigue management for covered workers in preparation for plant startup activities. Once it became apparent that the 56-day extension, which will conclude on June 25, 2010, would not provide sufficient relaxation time from the MDO to completely support plant startup activities, FENOC applied for the exemption to ensure that MDO relaxation would
be available to support plant startup activities. Since switching back to normal on-line work hours for the above cited work groups on April 29, 2010, overtime has been minimized with most workers in these work groups averaging 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or less per week.
- 4. In the next to last paragraph, prior to the environmental assessment, it is mentioned for the first time that the added flexibility will provide additional safety margin. Please describe the safety margin that is referred to, why there is a need for an additional safety margin, and how relaxing the MDO contributes to the addition.
FENOC Response: The exemption will provide more flexibility for scheduling personnel since covered individuals will be able to work an additional day per week. This increased flexibility will provide additional opportunity to identify and address any issues that may arise. Promptly identifying and correcting issues provides the additional safety margin.
- 5. The exemption request mentions that there will be a benefit to the affected employees.
Please explain this in more detail as the relevance of this statement is not understood by the reviewer.
FENOC Response: The main purpose behind the work hour rule was to improve safety by managing fatigue. One of the underlying goals was to improve worker quality of life. Although not relevant to the main purpose of the rule to improve safety by managing fatigue, FENOC believes that the flexibility contained in this exemption request will not only be helpful in promoting an effective and efficient startup, but the flexibility also will improve covered employee quality of life by providing additional resources while at work and potentially the opportunity to schedule the day off to a more convenient day.
- 6. The environmental analysis #5 states that the proposed exemption may result in individuals being on-site for longer periods of time, hence these individuals have the potential to receive additional dose. Please expand on this including indicating if additional work is planned if the exemption were to be granted, versus doing the same work over a longer calendar day window and the job duty groups involved. It is not expected, by the reviewer, that additional dose is a potential, e.g. doing the same 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> job over 1 day or over three days.
FENOC Response: There is no additional work planned if the exemption is granted. The activities necessary to support the planned startup will be required whether or not the additional relief from the minimum days off requirements is granted; therefore, significant occupational dose increases are not expected. Many workers affected by the exemption, however, perform their duties within the radiologically controlled areas of the plant, resulting in the potential for additional incidental radiological exposure.
- 7. Why is 60 days needed?
FENOC Response: The following clarification to the exemption request is provided.
The requested exemption would allow the less restrictive working hour limitations described in 10 CFR 26.205(d)(4) and (d)(5) to be applied only as necessary to support the activities required to return the DBNPS to service.
The 60-day maximum criterion included in the request provides assurance that any exemption granted would not be open-ended. The 60-day period is consistent with the provisions of 10 CFR 26.205 (d)(4), 10 CFR 26.205 (d)(5), and the cited precedent. FENOC does not anticipate that use of the maximum 60-day period stipulated in the request will be necessary.
For the purpose of this exemption, return to service is defined as achievement of generator synchronization. The current restart schedule indicates generator synchronization will occur on July 2, 2010.
Respectfully, Phil Lashley Fleet Licensing MS A-GO-02 Office 330-384-5353 Cell 330-696-7208 Fax 330-245-5323 The information contained in this message is intended only for the personal and confidential use of the recipient(s) named above. If the reader of this message is not the intended recipient or an agent responsible for delivering it to the intended recipient, you are hereby notified that you have received this document in error and that any review, dissemination, distribution, or copying of this message is strictly prohibited. If you have received this communication in error, please notify us immediately, and delete the original message.
E-mail Properties Mail Envelope Properties (OFB91DFC39.7FA878FD-ON8525773C.006C49B0-8525773D.00497D97)
Subject:
Request for Additional Information - Part 26 Exemption 10 CFR 26.205(d)(3)
Sent Date:
6/9/2010 9:22:47 AM Received Date:
6/9/2010 9:22:47 AM From:
phlashley@firstenergycorp.com Created By: phlashley@firstenergycorp.com Recipients:
Michael.Mahoney@nrc.gov (Mahoney, Michael)
Tracking Status: None hlhegrat@firstenergycorp.com (hlhegrat@firstenergycorp.com)
Tracking Status: None jeemley@firstenergycorp.com (jeemley@firstenergycorp.com)
Tracking Status: None rritzman@firstenergycorp.com (rritzman@firstenergycorp.com)
Tracking Status: None rehoward@firstenergycorp.com (rehoward@firstenergycorp.com)
Tracking Status: None kmnesser@firstenergycorp.com (kmnesser@firstenergycorp.com)
Tracking Status: None Post Office:
FirstEnergyCorp.com Files Size Date & Time MESSAGE 22963 6/9/2010 Options Expiration Date:
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