NRC-20-0070, Work Hour Limits Exemption Request Due to COVID-19

Work Hour Limits Exemption Request Due to COVID-19

ML20315A373
Person / Time
Site:	Fermi
Issue date:	11/10/2020
From:	Peter Dietrich DTE Electric Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-20-0070
Download: ML20315A373 (3)

Text

Peter Dietrich Senior Vice President and Chief Nuclear Officer DTE Electric Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4153 Fax: 734.586.1431 Email: peter.dietrich@dteenergy.com DTE November 10, 2020 10 CFR 26.205( d)

NRC-20-0070 U.S . Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Fermi 2 Power Plant NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Fermi 2 Work Hour Limits Exemption Request due to COVID-19

Reference:

NRC Letter from H. Nieh to NEI, "US. Nuclear Regulatory Commission Planned Actions Related to the Requirements for Work Hour Controls During the Coronavirus Disease 2019 Public Health Emergency," March 28, 2020 (ML20087P237).

As a result of the Coronavirus Disease 2019 (COVID-19) public health emergency (PHE), DTE Electric Company (DTE) is requesting NRC approval for Fe1mi Unit 2 (Fermi 2) to proactively enter into the alternative work hour controls delineated in the Reference letter. By implementing the alternate work hour controls, DTE is proactively taking steps to maintain staffing levels 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 Fermi 2 efforts to maintain Center for Disease Control recommendations related to social distancing, worker screening, and limiting close-proximity work. Particularly given the COVID-19 challenge in the immediate community of Fe1mi 2, leveraging the alternative work hour controls will facilitate further worker and community protection as we operate the reactor 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 nation's critical infrastructure similar to the medical, food, communications, and other critical industries. The operation ofF~1mi 2 must be conducted such that the plant is available when needed.

DTE previously requested, and received NRC approval for, a work hour limits exemption due to COVID-19 earlier in 2020. That exemption expired on August 11, 2020 and Fermi 2 has been following normal work hour limits since that time. A resurgence in COVID-19 has led to the new exemption request in this letter. This new exemption request is independent from the prior expired exemption and sufficient time has elapsed such that there are no concerns regarding cumulative fatigue from the prior exemption period.

USNRC NRC-20-0070 Page 2 In accordance with the Reference letter, the following information is provided in the table below:

• Positions (as described in§ 26.4(a)(l)- (5)) for which either cu1Tent work-hour controls will be maintained, or for which alternative controls will be required to maintain staffing.

• The date and time for which alternative controls (if necessary) will be implemented for the listed positions.

Positions Compliance Begin Implementation 26.4(a)(l) Operators Will implement the 26.4(a)(2) Health Physics and alternative Will use site-specific alternative Chemistry approach upon controls as defined in the Reference 26.4(a)(3) Fire Brigade NRC approval (as letter 26.4(a)(4) Maintenance wananted by 26.4(a)(5) Security COVID-19 conditions)

Fe1mi 2 site-specific COVID-19 PHE fatigue-management controls are consistent with the constraints outlined in the Reference letter and its attachment. Fermi 2 will continue to follow the fatigue management controls, behavioral observation requir~ments, and self-declaration allowances cunently delineated within the Fermi 2 work hour control program and procedures (MGAl O and MGAl 6).

Upon NRC approval, Fermi 2 will implement the alternative controls described below and discussed in the Reference letter for the management of fatigue during the 60-day period of the exemption. Note that Fe1mi 2 only plans to implement the alternative controls when wananted by the COVID-19 conditions during the 60-day exemption period (i.e., normal work hour controls would be continued or restored if conditions allow). The alternative 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 3 0-day period; (5) requirements are established for behavioral observation and self-declaration during the period of the exemption As described above, 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.

USNRC NRC-20-0070 Page 3 DTE is requesting approval of this request based on an expected need for the exemption given the cunent trend of COVID-19 conditions. As indicated above, the alternative controls would be implemented as warranted by COVID-19 conditions during the 60-day period of the approved exemption. Near the end of the 60-day period, if COVID-19 pandemic conditions persist at the site affecting staffing requirements, a supplemental request may be submitted.

DTE requests approval of this request by no later than November 19, 2020 .

.1 No new commitments are being made in this submittal.

Should you have any questions or require additional information, please contact Ms. Margaret Offerle, Manager - Nuclear Licensing, at (734) 586-5076.

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• Peter Dietri Senior Vice President and Chief Nuclear Officer cc: NRC Project Manager NRC Resident Office NRC Region III Branch Chief Division of Reactor Projects Branch 4 Regional Administrator, Region III