ML20105A481

Independent Spent Fuel Storage Installation (ISFSI) - Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs

ML20105A481
Person / Time
Site:	Palo Verde
Issue date:	04/14/2020
From:	Rash B Arizona Public Service Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, NRC Region 4
References
102-08094-BJR/SPD
Download: ML20105A481 (3)

Text

10 CFR 26.9 BRUCE J. RASH Vice President, Nuclear 102-08094-BJR/SPD Engineering/Regulatory April 14, 2020 Palo Verde Nuclear Generating Station P.O. Box 52034 Phoenix, AZ 85072 Mail Station 7602 Tel 623.393.5102 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Reference:

NRC Letter from H. Nieh to NEI dated March 28, 2020, U.S. NUCLEAR REGULATORY COMMISSION PLANNED ACTIONS RELATED TO THE REQUIREMENTS FOR WORK HOUR CONTROLS DURING THE CORONAVIRUS DISEASE 2019 PUBLIC HEALTH EMERGENCY, [Agencywide Document Access and Management System (ADAMS) Accession Number ML20087P237]

Subject:

Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2, and 3 and Independent Spent Fuel Storage Installation (ISFSI)

Docket Nos. STN 50-528/529/530 and 72.44 Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs As a result of the Coronavirus Disease 2019 (COVID-19) public health emergency (PHE)

Arizona Public Service Company (APS) has proactively determined that PVNGS can no longer meet the work-hour controls of 10 CFR 26.205(d) for the covered workers noted below. By implementing the alternative work-hour controls, APS 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 COVID-19.

This request is being made in support of the efforts to maintain the recommendations made by the Centers for Disease Control and Prevention (CDC) related to social distancing, worker screening, and limiting close-proximity work. Particularly given the challenges that COVID-19 could present in the immediate community surrounding PVNGS, leveraging the alternative work-hour controls will assist in facilitating further worker and community protection as APS continues the current Unit 2 refueling outage and daily operation of Units 1 and 3.

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 the medical, food, communications, and other critical industries. The PVNGS daily operation of Units 1 and 3 and the current Unit 2 refueling outage must be conducted such that all three units are available when needed, including during the critical peak summer loads.

A member of the STARS Alliance LLC Callaway

• Diablo Canyon

• Palo Verde

• Wolf Creek

102-08094-BJR/SPD ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Part 26 Exemption Request Page 2 In accordance with the Reference, 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 (if necessary) will be implemented for the listed positions.

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

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

26.4(a)(3) PVNGS Fire Will phase in site-specific Upon NRC Approval Department alternative work-hour controls as defined in the Reference, as necessary, to minimize transition issues.

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

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

The PVNGS site-specific COVID-19 PHE fatigue-management controls are consistent with the constraints outlined in the Reference and its attachment.

APS will continue to follow the fatigue-management controls, behavioral observation requirements, and self-declaration allowances in accordance with the current work-hour control program and station Procedure 01DP-0AP17, Managing Personnel Fatigue.

Upon NRC approval, APS will implement the alternative controls described below, consistent with the Reference 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;

102-08094-BJR/SPD ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Part 26 Exemption Request Page 3 (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 10 CFR 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, APS will implement the alternative controls described in the Reference for the management of fatigue during the initial period of 60 days. Near the end of the 60-day period, if the COVID-19 conditions persist at the site affecting staffing requirements and the efforts to maintain CDC, state, and local recommendations related to social distancing, worker screening, and limiting close-proximity work, as well as the particular concern of the COVID-19 challenge in the immediate community of PVNGS, an additional email supplement request may be submitted to extend the 60-day implementation period exemption.

APS requests NRC approval by no later than April 17, 2020, to expedite implementation of the safety benefits of the alternative controls.

APS makes no commitments in this letter. Should you need further information regarding this exemption request, please contact Matthew Kura, Department Leader, Nuclear Regulatory Affairs, at (623) 393-5379.

Sincerely, Rash, Bruce Digitally signed by Rash, Bruce (Z77439)

(Z77439) DN: cn=Rash, Bruce (Z77439)

Date: 2020.04.14 12:51:44 -07'00' BJR/SPD cc: S. A. Morris NRC Region IV Regional Administrator S. P. Lingam NRC NRR Project Manager for PVNGS J. L. Dixon NRC Branch Chief for PVNGS C. A. Peabody NRC Senior Resident Inspector for PVNGS