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NEI Slides for June 30, 2020, Public Meeting on COVID-19 Response
	ML20178A420
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Three Mile Island, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle
Issue date:	06/30/2020
From:	Basso T; Nuclear Energy Institute
To:	; Office of Nuclear Reactor Regulation
	Miller G
References
	Download: ML20178A420 (18)
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Fall Outage Preparations and Lessons Learned June 30, 2020 Thomas Basso Sr. Director Regulatory Affairs

Introduction - Tom Basso Spring Exemptions and Relief Requests

Greatly appreciate staff support, web page, electronic submittals, ability to work remotely, plan and conduct meetings NEI/Member Presentations

What was learned

What is being done differently

Why relief is still needed

Overview - Geoge Gellrich VP Regulatory Exelon COVID is significant learning opportunity - making us think differently Paradigm changed - Remote capabilities, what can be done to protect health, use of technology Spring Exemptions supported by safety analysis - Sites used judiciously Industry shared and captured learnings Strong Nuclear Safety and COVID results Industry must plan for worst for Fall Outages - must protect health and safety of employees and public Vaccine likely not available - social distancing and technical lessons learned applied yet some activities still present a challenge Regulatory predictability is important for outage safety Many improved methods will become the new normal ©2020 Nuclear Energy Institute 3

What we learned Exelon Spring Outage Southern Company Fire Protection PSEG Medical Reviews Regulatory Relief Regulatory Oversight

Spring 2020 Outage Lessons Learned Shannon Rafferty-Czincila Director - Licensing

COVID-19 Relief Requested & Benefits Limerick Suppression Pool - ISI Relief Request

Contractors on site, close proximity work under unique/challenging conditions

5000 person hours of close contact work eliminated

Reduced contractors onsite and in community Braidwood Steam Generator - Exigent LAR

Specialty work requiring contractors, close proximity work, no safety impact with significant margin

Eliminated 170 contractors onsite and in community 6

COVID-19 Relief Requested & Benefits Limerick & Quad MSIV - Emergency LAR

No safety impact with significant margin

1600 person hours person hours of close contact work eliminated Limerick MOV - IST Relief Request

Specialty testing

Only requested relief from valves with no safety impact

550 person hours of close contact work eliminated Work Hour Rule Experience

Use in Spring outage resulted in no adverse human performance or industrial safety trends

(+) feedback from work crews, as stability was preferred

Planning on requesting in Fall 7

COVID-19 Relief Requested & Benefits

Allowed increased focus on safety significant outage tasks

Resulted in improved outage risk and personnel safety

Minimized COVID-19 cases and decreased normal outage sick time

Reduced COVID-19 potential exposure to local communities.

Contributed to a safe environment to conduct outage related and post-outage NRC inspections.

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SNC-Fire Protection Lessons Learned Cheryl Gayheart Fleet Regulatory Affairs Director

Fire Protection Lessons Learned COVID Relief Requested and Benefit

Farley (NFPA 805) and Hatch (Appendix R)

Quarterly fire brigade drill exemption

Annual live fire training exemption

Vogtle

Utilized self approval process for quarterly drills and live fire deferral per the Safety Evaluation Report Benefit to Critical staff and Equipment

Critical operations staff (operators, SROs, SM)- Operations staffed Fire Brigade

Facilities used to conduct live fire training with critical positions (ambulance, EMT, adjunct FP instructors)

Gear is shared at most sites 10

Fire Protection Lessons Learned Actions during Exemption period

Training and evaluations of knowledge, skills and abilities

Computer based training for fire fighting fundamentals

Observations and reinforcement of fire protection fundamentals

Table top drills including critiques that are reviewed with entire fire brigade to share learnings

Review of previous drill critiques and training assessments 11

PSEG Nuclear Update June 30, 2020

COVID-19 Relief Requested and Benefits

Salem and Hope Creek Generating Station

Part 55 Licensed Operator medical exemption request

Temporary extension of medical physicals until September, 2020

Part 73 Security medical exemption request

Temporary extension of security personnel medical physicals

Benefits

Strict adherence to federal & state mandates on social distancing

Reduced COVID-19 potential exposure to local communities

Reduce burden on community medical services 13

Regulatory Relief Lessons Learned - Dave Mannai Sr. Director Regulatory PSEG Exemption and Relief timeliness was (+)

Web portal (+), advocate continuing efforts

NRC PMs responsive and supportive (+)

Use of templates for submittals (+)

Determination of Appropriate Regulatory Vehicle

Align on Exemptions, Relief Requests, and EGMs

Assess the regulatory options for optimal efficiency

Encourage proactive development of regulatory options 2006 NEI Pandemic Licensing plan submittal (missed opportunity)

NEI advocate stronger and continued dialogue in 2006

Finish conversation after current PHE

Regulatory Oversight Lessons Learned - Cheryl Gayheart Fleet Regulatory Affairs Director Southern Company Resident Inspectors and ROP Inspections Remote inspections were a positive and should be considered a best practice

Excellent communications between inspectors and stations- Skype and conference calls

Use of component photos when needed

Allowed inspections to be conducted on schedule and within time allotted, with less travel and expenses Excellent response by stations to adapt to needs of residents

Laptops

Plant Computer and Logs Access

Shift Turnover and Station Update calls Unplanned scram response was a positive paradigm shift

Inspectors were effective in monitoring plant events remotely Recovery of initial operator exams was appreciated Region II Weekly Call- NRC and Utility Representatives-Enhanced Communication

What we are doing different - Tom Basso NEI is hosting four Conducting an Outage during a Pandemic Forums

Specialized sessions on: In-processing, Supplier Logistics, Conducting Work Safely, and Positive Case Identification and Response

Industry will share best practices and lessons learned from the Spring outage season in time for Fall

Includes All US Nuclear Power Reactors (including non-NEI members) and Canadian sites NEI has been conducting Industry Coordination calls and will continue to conduct through Fall outage season, with emphasis on outage conduct NEI issued, Preventing and Mitigating the Spread of COVID-19, a Resource Guide

Will be supplemented by an Outage specific lessons learned appendix NEI drafting lessons learned document Stations at different states of completing their lessons learned

What we are doing different (cont.)

Stagger work time for various groups including staggered lunch and breaks times Designate specific turnstiles for critical employees to utilize Video or teleconference for turnovers Increased cleaning in common/high traffic areas Discourage car pooling Prohibit outage workers from sharing accommodations & socializing Isolate online and outage workers Create a team of social distance monitors to conduct observations of personnel and provide coaching on maintaining social distancing.

Installing additional trailers for outage workers Survey workers to determine risk (spouse in medical field, overseas travel)

Fall Exemption Requests - Tom Basso NEI Licensee will seek regulatory relief for Fall outages

Until remedies are available, the risk of an outbreak remains

Stations are critical power grid assets and operational personnel need to be protected

Minimizing potential external exposure has been successful Optimize Approach for Fall and any future situations

Public Meeting before or after issuance of exemption letter Questions about Fall Outage Exemptions

What options are being considered by the NRC regarding the conditions in the exemptions that are tied to the Public Health Emergency?

Licensees are considering identifying specific dates and/or time periods for the exemptions to remain in place in their submittals, particularly outages later in the Fall.

What thoughts or recommendations can the NRC provide licensees if this approach is applied?

How would the NRC address potential conflicts between Federal, State, and Local guidelines and COVID-19 requirements, particularly if the Federal PHE is lifted while State/Local requirements remain in place?

ML20178A420

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