ML111470265
| ML111470265 | |
| Person / Time | |
|---|---|
| Site: | Surry, North Anna  |
| Issue date: | 05/26/2011 |
| From: | Hartz L Virginia Electric & Power Co (VEPCO) |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| 10-448B | |
| Download: ML111470265 (5) | |
Text
VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 May 26, 2011 10 CFR 26.9 10 CFR 26.205 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Serial No.:
NL&OS/GDM Docket Nos.:
License Nos.:
10-448B R1 50-338/339 50-280/281 NPF-4/7 DPR-32/37 VIRGINIA ELECTRIC AND POWER COMPANY NORTH ANNA AND SURRY POWER STATIONS UNITS 1 AND 2 REQUESTS FOR EXEMPTION FROM CERTAIN REQUIREMENTS OF THE FITNESS FOR DUTY RULE FOR MANAGING FATIGUE RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION By letter dated February 10, 2011, Dominion Nuclear Connecticut, Inc., (DNC) and Virginia Electric and Power Company (Dominion) submitted requests for 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 for Millstone Power Station Units 1, 2 and 3 and North Anna and Surry Power Stations Units 1 and 2, respectively.
By emails dated May 2, 2011, the NRC Project Manager for North Anna Power Station provided requests for additional information for North Anna and Surry associated with assigned work shifts for personnel sequestered during declarations of severe weather conditions involving tropical storm or hurricane force winds.
Dominion's response to the NRC questions is provided in the attachment.
If you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.
Sincerely,
~l?;l1J L. N. Hartz Vice President - Nuclear Support Services Commitment made in this correspondence 1.
Guidance will be incorporated into the HRP-N that: 1) emphasizes the need for pre-planned and consistent work-shift start times to better facilitate fatigue management, and 2) states that the Station Hurricane Response Organization staff will be provided an opportunity for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of restorative rest when off-shift and should not be assigned any duties when off-shift.
Attachment Response to NRC Request for Additional Information
cc:
U.S. Nuclear Regulatory Commission - Region II Marquis One Tower, NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Senior Resident Inspector North Anna Power Station J. S. Wiebe NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Surry Power Station K. R. Cotton NRC Project Manager U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Serial Number 10-4488 Docket Nos. 50-338/339/280/281 Page 2 of 2
Serial No. 10-4488 Docket Nos. 50-338/339/280/281 Attachment Response to NRC Request for Additional Information Virginia Electric and Power Company (Dominion)
North Anna and Surry Power Stations Units 1 and 2
Serial No. 10-4488 Docket Nos. 50-338/339/280/281 Attachment Response to NRC Request for Additional Information North Anna and Surry Power Stations Units 1 and 2 By letter dated February 10, 2011, Virginia Electric and Power Company (Dominion) requested an exemption from certain requirements of the Fitness for Duty Rule for Managing Fatigue for North Anna and Surry Power Stations Units 1 and 2. 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 NRC staff subsequently determined that additional information was necessary to complete their review.
The requested information and Dominion's responses are provided below:
1.
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? Explain the rationale for organizing current shift start times during the sequester.
Dominion Response Dominion's expectation is that shift start times during declarations of severe weather conditions involving tropical storm or hurricane force winds will be pre-planned and consistent.
The Dominion Hurricane Response Plan (Nuclear) [HRP-N] currently includes a 24-hour shift assignment schedule template that includes entries for two 12-hour shifts for the Station Hurricane Response Organization staff positions.
Determination of the initial 12-hour shift schedule and notification of the response staff of their assigned positions and work shifts would be completed prior to the arrival of severe weather onsite as part of the pre-storm activities outlined in the HRP-N.
In addition, the HRP-N is being revised to emphasize the need for pre-planned and consistent work-shift start times to better facilitate fatigue management.
2.
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 />?
Dominion Response It is expected that the Station Hurricane Response Organization staff will work a 12-hour shift followed by a 12-hour break for restorative rest between successive work periods. Regardless, the Station Hurricane Response Organization staff will be provided an opportunity for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of restorative rest when off-shift and should not be assigned any duties when off-shift. This guidance will be incorporated Page 1 of 2
Serial No.1 0-4488 Docket Nos. 50-338/339/280/281 Attachment into the HRP-N. Support staff personnel and contractors who are not assigned to a 12-hour shift would work their regularly scheduled shifts unless directed otherwise by their departmental manager, but in any case would not be expected to work longer than a 12-hour shift.
Once station management has had an opportunity to evaluate the impact of the severe weather on station operations, transition to a work schedule other than 12-hour shifts, i.e., less than 12-hours per shift, would be considered if practical.
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