ML20098G313

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Actions Related to the Requirements for Work Hour Controls During the Coronavirus Disease 2019 Public Health Emergency
ML20098G313
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 04/07/2020
From: Simpson P
Exelon Generation Co
To: Robert Kuntz
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML20098G313 (3)


Text

April 7, 2020 To: Robert Kuntz, NRC Project Manager Document Control Desk CC: R. Murray, Quad Cities Senior Resident Inspector Ken Riemer, Div. Reactor Projects Branch Chief

Reference:

NRC Letter from H. Nieh to NEI, U.S. Nuclear Regulatory Commission Planned Actions Related to the Requirements for Work Hour Controls During the Coronavirus Disease 2019 Public Health Emergency, March 28, 2020 As a result of the Coronavirus Disease 2019 (COVID-19) public health emergency (PHE)

Exelon Generation Company, LLC (EGC) has proactively determined that Quad Cities Nuclear Power Station (QCNPS) can no longer meet the work-hour controls of 10 CFR 26.205(d) for the covered workers noted below. By implementing the alternate work hour controls, QCNPS is proactively taking steps to complete necessary work, testing, and inspections in a manner that supports worker and neighboring community safety to limit the spread of the COVID-19 virus.

This request is being made to support the QCNPS efforts to maintain Centers for Disease Control and Prevention (CDC) recommendations related to social distancing, worker screening, and limiting close-proximity work. Particularly given the COVID-19 challenge in the immediate community of QCNPS, leveraging the alternative work hour controls will facilitate further worker and community protection as we perform the current outage and subsequent operation safely and efficiently.

As the US Departments of Homeland Security and Energy have stated in their guidance, the electric grid and nuclear plant operation make up the nations critical infrastructure similar to the medical, food, communications, and other critical industries. QCNPSs operation and outage must be conducted such that the plant is available when needed, including during the critical peak summer loads.

In accordance with the Reference letter, the following information is provided in the table below:

  • Positions (as described in § 26.4(a)(1) - (5)) for which either current work-hour controls will be maintained, or for which alternative controls will be required as a preventive measure.
  • The date and time for which alternative controls will be implemented for the listed positions is identified in the Table below.

Positions Compliance Begin Implementation 26.4(a)(1) Operators Will phase in site-specific Upon NRC Approval alternative controls as defined in the Reference letter, as necessary, to minimize transition issues.

26.4(a)(2) Health Physics and Will phase in site-specific Upon NRC Approval Chemistry alternative controls as defined in the Reference letter, as necessary, to minimize transition issues.

April 7, 2020 Positions Compliance Begin Implementation 26.4(a)(3) Fire Brigade Will phase in site-specific Upon NRC Approval alternative controls as defined in the Reference letter, as necessary, to minimize transition issues.

26.4(a)(4) Maintenance Will phase in site-specific Upon NRC Approval alternative controls as defined in the Reference letter, as necessary, to minimize transition issues.

26.4(a)(5) Security Will phase in site-specific Upon NRC Approval alternative controls as defined in the Reference letter, as necessary, to minimize transition issues.

QCNPSs site-specific COVID-19 PHE fatigue-management controls are consistent with the constraints outlined in the Reference letter and its attachment. QCNPS will continue to follow the fatigue management controls, behavioral observation requirements, and self-declaration allowances currently delineated within the EGC work hour control program and procedures (LS-AA-119, SY-AA-102, SY-AA-103-500).

Upon NRC verbal approval, QCNPS will implement the alternative controls described below and consistent with the Reference letter for the management of fatigue during the period of the exemption. These controls ensure that covered workers are subjected to the following minimum controls:

(1) not more than 16 work-hours in any 24-hour period and not more than 86 work-hours in any 7-day period, excluding shift turnover; (2) a minimum 10-hour break is provided between successive work periods; (3) 12-hour shifts are limited to not more than 14 consecutive days; (4) a minimum of 6-days off are provided in any 30-day period; and (5) requirements are established for behavioral observation and self-declaration during the period of the exemption.

The requirements of 10 CFR 26.33, Behavioral observation; 10 CFR 26.209, Self-declarations; and 26.211, Fatigue assessments remain in effect during the period of the exemption. These requirements provide reasonable assurance that should personnel become impaired due to fatigue, requirements and processes are in place to identify the impairment through observation by plant staff or by worker self-declaration, and to assess and address instances of impairment through fatigue assessments.

Upon NRC approval, QCNPS will implement the alternative controls described in the Reference Letter for the management of fatigue during the initial period of 60 days. Near the end of the 60 day period, if COVID-19 pandemic conditions persist at the site affecting staffing requirements and the efforts to maintain Centers for Disease Control, state and local

April 7, 2020 recommendations related to social distancing, worker screening, and limiting close-proximity work, as well as of particular concern is the COVID-19 challenge in the immediate community of QCNPS, an additional email supplement request may be submitted to extend the 60-day implementation period exemption.

In order to expedite implementation of the safety benefits of the alternate controls, QCNPS requests verbal approval of this request. We understand this will be followed up by a written confirmation.

Respectfully, Patrick R. Simpson Sr. Manager - Licensing Exelon Generation Company, LLC