ML110550698

RAIs for Requested Exemption Regarding Part 26

ML110550698
Person / Time
Site:	Brunswick
Issue date:	02/23/2011
From:	Farideh Saba Plant Licensing Branch II
To:	Turkal M - No Known Affiliation
Saba F, NRR/DORL/LPL2-2, 301-415-1447
References
Download: ML110550698 (2)

Text

From:

Saba, Farideh Sent:

Wednesday, February 23, 2011 8:57 AM To:

Turkal, Mark

Subject:

RE: RAIs for the requested exemption regarding Part 26

Mark, Thanks. Please consider the RAI in my previous email as the official RAI and provide your response by 03/28/11.

Farideh Farideh E. Saba, P.E.

Senior Project Manager NRC/ADRO/NRR/DORL 301-415-1447 Mail Stop O-8G9A Farideh.Saba@NRC.GOV From: Turkal, Mark [1]

Sent: Wednesday, February 23, 2011 8:16 AM To: Saba, Farideh Cc: Murray, William R. (Bill)

Subject:

RE: RAIs for the requested exemption regarding Part 26

Farideh, Sorry this took a couple of days to reply to, I wanted to ensure EP could support reviews with the outage starting next week. The questions look fine, we have no comments or questions. If you plan on sending this in a letter, please give us 30 days from the date of the letter to respond. If we just work off the e-mail, can we make the date 3/28/11?

Thanks, Mark From: Saba, Farideh [2]

Sent: Thursday, February 17, 2011 5:22 PM To: Turkal, Mark Cc: Murray, William R. (Bill)

Subject:

RAIs for the requested exemption regarding Part 26

Mark, Please see the following RAIs from the review. Please let me know if you have any comments or questions. Also, please let me know when you will be able to provide your responses to these RAIs.

Thanks,

Farideh REQUEST FOR ADDITIONAL INFORMATION BRUNSWICK 1 & 2 PROPOSED EXEMPTION FROM THE REQUIREMENTS OF 10 CFR 26.205(c) AND (d)

DOCKET NUMBERS 50-325 AND 50-324; LICENSE NUMBERS DPR-71 AND DPR-62 By letter dated December 16, 2010, Carolina Power & Light, the licensee for Brunswick 1 and 2 requested an exemption from certain requirements of the Fitness for Duty Rule for Managing Fatigue.

Specifically, the letter requested an exemption from the requirements of 10 CFR 26.205 (c) and (d) for meeting work hour controls during declarations of severe weather conditions involving tropical storm or hurricane-force winds.

The purpose of the request is to allow Brunswick 1 and 2 to ensure that the plant reaches and maintains a safe and secure status during severe weather conditions. Adherence to all work hour control requirements could impede the ability to respond to a plant emergency. The sequestering of plant personnel may be necessary at times during declarations of severe weather.

The NRC staff performed a preliminary review of the exemption request and determined the licensees response to the following request for additional information is needed for the NRC staff to complete its review in a timely manner.

1. NRC staff is not only concerned with fatigue management prior to and during the requested exemption, staff is equally concerned with site individuals fatigue when returning to work hour controls such that the resumption of work hour controls is prudently implemented and individuals are not fatigued on the first day on work hour controls. Please indicate what general criteria the Senior Plant Management will consider when making the determination to resume work hour controls.

2. Lessons learned from NUREG-1474 include that as much as possible, site preparation for a hurricane should occur prior to the need to sequester individuals. What is the time period that is allocated for personnel to prepare the site for a storm, prior to the arrival of hurricane force winds on-site? Please be as precise as possible with respect to the number of days or hours prior to the arrival of severe winds.

3. With respect to the applicability of the exemption request, please provide a breakdown of the various job duty groups and numbers of individuals in each group who will be sequestered.

4. Many factors contribute to fatigue; one of these factors is inconsistent start times. In order to manage fatigue during the sequester, will shift start times be pre-planned and consistent? Please explain the rational for organizing current shift start times.

5. Time at work is one of the major contributors to fatigue (another is lack of restorative rest).

What are the expected typical shift durations for the various job duty groups that will be sequestered? Will any individuals be required to work shifts longer than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />?

6. Licensees are expected to provide an opportunity for restorative rest to mitigate the fatigue that is possible under a sequester for hurricane force winds. Please describe the methods to be used and the procedures governing housing and bunking of the sequestered individuals.

Farideh E. Saba, P.E.

Senior Project Manager NRC/ADRO/NRR/DORL 301-415-1447 Mail Stop O-8G9A Farideh.Saba@NRC.GOV