ML12213A616

Draft Request for Additional Information Related to Request for Exemption from Certain Requirements of the Fitness for Duty Rule

ML12213A616
Person / Time
Site:	Salem, Hope Creek
Issue date:	07/30/2012
From:	John Hughey Plant Licensing Branch 1
To:	Duke P Public Service Enterprise Group
Hughey J
Shared Package
ML12213A592	List: ML122130141 ML12213A616
References
TAC ME7651, TAC ME7652, TAC ME7653
Download: ML12213A616 (2)

Text

DRAFT REQUEST FOR ADDITIONAL INFORMATION RELATED TO REQUEST FOR EXEMPTION FROM CERTAIN REQUIREMENTS OF THE FITNESS FOR DUTY RULE HOPE CREEK GENERATING STATION AND SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-354, 50-272, AND 50-311 By letter dated November 30, 2011 (ADAMS Accession No. ML113350245), PSEG Nuclear LLC (PSEG, the licensee) submitted an exemption request for Hope Creek Generating Station (Hope Creek) and Salem Nuclear Generating Station, Unit Nos. 1 and 2 (Salem). Specifically, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 26.9, PSEG requested an exemption from certain requirements of 10 CFR Part 26, Fitness for Duty Programs, Subpart I, Managing Fatigue, related to meeting work hour controls during declarations of severe weather conditions involving tropical storm or hurricane force winds or severe winter precipitation. PSEG provided a supplement on June 4, 2012, (ADAMS Accession No. ML12157A061) in response to an NRC staff request for additional information. The NRC staff has determined that further, additional information, as described below, is needed to complete the review.

RAI-08: Attachment 1 of the submittal dated November 30, 2011, describes the geographical location of Hope Creek and Salem in terms of the potential impact that severe weather can have on the site. Please describe the local history and policies for cleaning the streets/roads accessing the site.

RAI-09: Attachment 1 of the submittal dated November 30, 2011, states the following:

The proposed exemption does not include discretionary maintenance. Work necessary to maintain the plant in a safe and secure condition or to protect equipment required for safety or power generation from potential storm damage may be performed during periods when the proposed exemption would apply.

Because of the importance and high priority assigned to restoration of electrical power to the area affected by the storm, PSEG does not consider work required to allow the plant to restart following a storm to be discretionary.

Please state whether or not actually restarting the units to restore power is considered discretionary.

RAI-10: Attachment 1 of the PSEG letter dated June 4, 2012, provides the response to NRC DRAFT

request for additional information RAI-07 (ADAMS Accession No. ML12157A061).

The response lists the proposed entry conditions for the exemption during severe winter conditions. The forecast for unsafe travel gives an example of wind conditions but not an example for unsafe road conditions due to severe winter weather such as ice accumulations or snow accumulations. Please provide examples for unsafe road conditions.

RAI-11: Does PSEG specifically communicate with the local government regarding how unsafe travel conditions are determined what various levels of travel restrictions are issued?

If so, please state the local government entity (e.g. city, county, or state Department of Transportation). How much lead time would the local government give site personnel when preparing to declare travel restrictions?

RAI-12: Attachment 1 of the submittal dated November 30, 2011, describes the exit condition for the requested exemption as being when enough personnel are available to support meeting full compliance with the work hour rule. Attachment 1 of the PSEG letter dated June 4, 2012, provides responses to the requests for additional information RAI-02 and RAI-07. The responses provided criteria for entry into the requested exemption. Is there a documented method used by the deciding official that describes the criteria for determining when adequate personnel are available to support exiting the exemption period? An example would be the use of staffing rosters that are tied to a departmental or organizational function, in order to monitor compliance with Part 26 Subpart I requirements. If so, please provide the same level of detail as that provided for the entry criteria.