RS-20-147, Response to Request for Additional Information Related to Exemption from Part 26 Requirements
| ML20328A215 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 11/23/2020 |
| From: | Demetrius Murray Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RS-20-147 | |
| Download: ML20328A215 (4) | |
Text
4300 Winfield Road Warrenville, IL 60555 Exelon Generation 630 657 2000 Office RS-20-147 10 CFR 26.9 November 23, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. 50-456 and 50-457
Subject:
Response to Request for Additional Information Related to Exemption from Part 26 Requirements
References:
- 1. 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," dated March 28, 2020 (ML20087P237).
- 2. NRC Letter from H. Nieh to NEI, "U.S. Nuclear Regulatory Commission Updated Planned Actions Related to Certain Requirements for Operating and Decommissioning Reactor Licensees During the Coronavirus Disease 2019 Public Health Emergency," dated November 10, 2020 (ML20261H515).
- 3. Exelon Generation Company, LLC application via the online portal for COVID-19 Related Request for Exemption from Part 26 Work Hours Requirements on November 17, 2020 (ML20323A008),
- 4. Email from J. Wiebe (U.S. Nuclear Regulatory Commission) to P.A.
Henderson (Exelon Generation Company, LLC), RAls for Request for Part 26 Exemption," dated November 20, 2020 In Reference 3, Exelon Generation Company, LLC (EGC) requested exemption from Part 26 requirements as a result of the Coronavirus Disease 2019 (COVID-19) public health emergency (PHE) to utilize the alternative work hour controls delineated in Reference 1 for Braidwood Station, Units 1 and 2 (Braidwood).
In Reference 4, the NRC determined that additional information is required to complete its review. The attachment to this letter provides the response to the requested information.
There are no regulatory commitments contained within this letter.
November 23, 2020 U.S. Nuclear Regulatory Commission Page 2 Should you have any questions concerning this letter, please contact Mr. Phillip A. Henderson at (630) 657-4727.
Respectfully, Dwi Murray Sr. Manager Licensing Exelon Generation Company, LLC
Attachment:
Response to Request for Additional Information cc:
NRC Regional Administrator, Region Ill NRC Senior Resident Inspector - Braidwood Station Illinois Emergency Management Agency - Division of Nuclear Safety
ATTACHMENT Response to Request for Additional Information NRC Request for Additional Information By application via the online portal on November 17, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20323A008), Exelon Generation Company, LLC (the Licensee) requested an Exemption from Part 26 requirements. The NRC staff requires additional information to review this request.
By letter dated November 10, 2020 (ADAMS Accession No. ML20261H515), the NRC staff provided guidance on the continued use of expedited processes beyond December 31,
2020. In Enclosure 1 to its November 10, 2020, letter the NRC staff stated, in part, that all requests for expedited review should include the following information:
a statement that explains how, and for which covered groups [Note: the identification of the covered groups was adequately addressed in the licensee's application], the COVID-19 public health emergency (PHE) impacts the licensee's ability to meet the work hour control requirements of 10 CFR 26.205(d)(1 )-(d)(?);
a statement that describes how an exemption from the 10 CFR 26.205 (d)(1 )-(d)(?) work hour control requirements would be used to manage the impact of the COVID-19 PHE on maintaining plant operational safety and security; In addition, the November 10, 2020, letter clarifies the appropriate application of the requirement for 6 days off in any 30 days by adding a item to the minimum criteria for alternative controls, as follows:
The calculation of work hours and days off includes all work hours and days off during the applicable calculation periods, including those work hours and days off preceding initiation of the exemption period; The Braidwood application does not sufficiently address the above items.
Accordingly, the NRC staff requests the licensee provide the above information in accordance with the November 10, 2020, guidance.
EGC Response The alternative controls will support maintaining staffing requirements as a result of recent increase in personnel absence due to COVID-19 positive test results or contact tracing quarantines that cannot be accommodated by the current work hour control requirements of 10 CFR 26.205(d)(1) through (d)(?) to support plant operational safety and security. The increase in COVID-19 cases in the state of lllinois1 and the communities surrounding Braidwood could impact the station's ability to meet work hour control requirements of 10 CFR 26.205(d)(1) through (d)(?) in maintaining minimum staffing and ensuring adequate qualified individuals of personnel specified in 10 CFR 26.4(a)(1) through (a)(5) are available to complete necessary 1Effective November 20, 2020, Illinois has elevated to Tier 3 of its COVID-19 Resurgence Mitigation Plan to combat the surge of COV/0-19 across all regions of Illinois. Recently, the state has experienced exponential spread of COV/0-19 in every region, statewide positivity rate at record highs, and hospitalizations surpassing the Spring 2020 peak (https:I /covid 19-illinoisqov. cs32. force. com/coronavirus/slrestore-illi nois-mitiqation-plan J.
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ATTACHMENT Response to Request for Additional Information operations, tests, inspections, and maintenance in a manner that supports nuclear safety and security.
Exemption from the 10 CFR 26.205(d)(1) through (d)(?) requirements is intended to prevent and limit the spread of COVID-19 and to mitigate its effect should Braidwood staffing be significantly impacted. Braidwood intends to use the alternative controls, where necessary, to efficiently perform operation, inspection, maintenance and testing activities that cannot be performed in accordance with the Centers for Disease Control and Prevention (CDC) recommendations related to social distancing, mask usage, and limiting close proximity work. This practice will reduce the number of people involved in specific activities to limit the potential spread of COVID-19.
In addition to the site-specific alternative controls delineated in Reference 1 for the management of fatigue during the requested exemption period for individuals subject to the controls, Braidwood will add the following item to the minimum criteria for alternative controls:
The calculation of work hours and days off includes all work hours and days off during the applicable calculation periods, including those work hours and days off preceding initiation of the exemption period; Therefore, the above information provides the requested information for expedited review in accordance with Reference 2.
References:
- 1. Exelon Generation Company, LLC application via the online portal for COVID-19 Related Request for Exemption from Part 26 Work Hours Requirements on November 17, 2020 (ML20323A008).
- 2. NRC Letter from H. Nieh to NEI, "U.S. Nuclear Regulatory Commission Updated Planned Actions Related to Certain Requirements for Operating and Decommissioning Reactor Licensees During the Coronavirus Disease 2019 Public Health Emergency," dated November 10, 2020 (ML20261H515).
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