ML20101M597
| ML20101M597 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/10/2020 |
| From: | Browne K NextEra Energy Seabrook |
| To: | Justin Poole Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML20101M597 (3) | |
Text
April 10, 2020 To:
Mr. Justin Poole, Project Manager, NRC Region 1 cc:
NRC Senior Resident Inspector Document Control Desk RE:
Seabrook Station Docket No. 50-443
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), NextEra Energy Seabrook, LLC (NextEra) is requesting NRC approval to proactively enter into the alternative work hour controls delineated in the referenced letter for the Seabrook Station (Seabrook) covered workers described below. The bases for the request is that NextEra is anticipating conditions where the station would no longer meet the work-hour controls of 10 CFR 26.205(d) for certain positions at Seabrook. By implementing alternative work hour controls, NextEra is proactively taking steps to complete necessary work, testing, and inspections in a manner that supports both worker and neighboring community safety to limit the spread of the COVID-19 virus. This request is being made to support NextEra's efforts to maintain Centers for Disease Control and Prevention recommendations related to social distancing, worker screening, and limiting close-proximity work. Particularly given the COVID-19 challenge in the immediate community of Seabrook, leveraging the alternative work hour controls will facilitate further worker and community protection as we perform the refueling outage and subsequent plant operation safely and efficiently.
As the U.S. Departments of Homeland Security and Energy have stated in their guidance, the electric grid and nuclear plant operation make up the nation's critical infrastructure, similar to medical, food, communications, and other critical industries. Seabrook station operations and refueling outages must be conducted such that the plant is available when needed, including during the critical peak summer loads.
In accordance with the referenced letter, the table below lists the individual categories as described in 10 CFR 26.4(a)(1)-(5), for which the proposed alternative work-hour controls will be implemented as a preventive measure to reduce the spread of the COVID-19 virus, and the date and time the alternative controls will become effective.
Applicability Position I Duties Compliance Begin Implementation Will apply alternative work hour 26.4(a)(1)
Operators controls defined in referenced Upon NRC approval]
letter as necessary to minimize covered work transition issues.
Will apply alternative work hour 26.4(a)(2)
Health Physics and controls defined in referenced Upon NRC approval Chemistry letter as necessary to minimize covered work transition issues.
Will apply alternative work hour 26.4(a)(3)
Fire Brigade controls defined in referenced Upon NRG approval letter as necessary to minimize covered work transition issues.
Will apply alternative work hour 26.4(a)(4)
Maintenance controls defined in referenced Upon NRG approval letter as necessary to minimize covered work transition issues.
Will apply alternative work hour 26.4(a)(5)
Security controls defined in referenced Upon NRG approval letter as necessary to minimize covered work transition issues.
Consistent with the COVID-19 PHE fatigue-management controls specified in the referenced letter, NextEra proposes the following alternative controls for the management of fatigue at Seabrook during the period of exemption. At a minimum, these alternative controls assure adequate rest for covered workers between periods of 10 CFR 26.4(a)(1 )-(5) related performance:
- 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 between successive work periods;
- 3) 12-hour shifts are limited to not more than 14 consecutive days;
- 4)
A minimum of 6 days off in any 30-day period;
- 5)
The behavioral observation and self-declaration allowance requirements specified in NextEra Nuclear Fleet administrative procedures AD-AA-101-1004, Work Hour Controls, and SY-AA-100-1012, Behavior Observation, will remain in effect.
NextEra's Nuclear Fleet administrative procedures AD-AA-101-1004 and SY-AA-100-1012, implement the requirements of 10 CFR 26.33, "Behavioral observation"; 10 CFR 26.209, "Self-declarations"; and 26.211, "Fatigue assessments". The regulations establish that procedures and processes shall be in place to address personnel impairment due to fatigue through observation by plant staff and by worker self-declaration, and to address instances of impairment by means of fatigue assessments. NextEra will continue to follow these requirements during the period of exemption to assure site-specific COVID-19 PHE fatigue-management controls at Seabrook are consistent with the constraints outlined in the referenced letter.
In order to expedite implementation of the safety benefits of the alternate work hour controls, NextEra requests approval of this request for Seabrook by April 14, 2020. We understand the authorization will be followed by a written confirmation and shall expire upon sixty (60) days of NRG approval.
Should you have any questions, please contact Ms. Christine Thomas, Senior Licensing Engineer, at 603-773-7589.
enn own Nuclear Safety Assurance and Learning Site Director NextEra Energy Seabrook, LLC