ULNRC-06625, Additional Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs

Additional Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs

ML20366A062
Person / Time
Site:	Callaway
Issue date:	12/31/2020
From:	Mclachlan M Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-06625
Download: ML20366A062 (6)

Text

Aiiie MISSOURI ren Callaway Plant December 31, 2020 ULNRC-06625 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 26 Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

RENEWED FACILITY OPERATING LICENSE NPF-30 ADDITIONAL REQUEST FOR EXEMPTION FROM SPECIFIC REQUIREMENTS OF 10 CFR PART 26, FITNESS FOR DUTY PROGRAMS

References:

1. NRC Letter from H. Nieh and J. Lubinski to NEI, dated November 10, 2020, 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 (ML20261H515)

2. NRC Letter from C. Erlanger to Ameren Missouri, dated November 1 7, 2020, Callaway Plant, Unit No. 1 Exemption from Select Requirements of 1 0 CFR Part 26 tEPID L-2020-LLE-0181 [COVID-19]) (ML20317A153)

As a result of continued challenges related to the ongoing public health emergency (PHE) due to the COVID-1 9 pandemic, Union Electric Company (dba Ameren Missouri) expects that the Callaway plant will be unable to comply with the work-hour controls of Title 10 of the Code of Federal Regulation (10 CFR) Part 26, Fitness for Duty Programs, Section 26.205(d) for the covered workers collectively described in this letter. Ameren Missouri continues to proactively take 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-1 9.

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ULNRC-06625 December 31, 2020 Page2of6 Pursuant to 10 CFR 26.9, this request is being made in support ofthe continued 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. Specifically, Ameren Missouri requests an extension of its currently approved work hour exemption (Reference 2) for an additional 60 days beyond the currently established expiration date of January 1 6, 202 1 Particularly given the challenges that COVID-l 9 continues to present in the immediate community surrounding Callaway, leveraging the alternative work-hour controls will assist in facilitating further Callaway worker and community protection.

As the U.S. Departments ofHomeland Security and Energy have stated in their guidance, the electric grid and nuclear plant operation make up the nations critical infrastructure similar to the medical, food, communications, and other critical industries. In regard to the electrical power support provided by the Callaway plant, it is anticipated that Callaway will return to power operation (from its current outage) during the requested, additional 60-day exemption period.

In accordance with Reference 1 and in support of this request, the following information is provided in the table below:

. Positions [as described in 1 0 CFR 26.4(a)(l)(a)(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.

Position Compliance Begin Implementation 26.4(a)(5) Security Will apply the NRC-approved site-specific January 16, 2021 alternative work-hour controls (as defined in the referenced NRC letter) when identified to be needed to support shifi coverage.

The Callaway site-specific COVID-19 PHE fatigue-management controls are consistent with the constraints outlined in the Reference 1 letter, including Enclosure 1 as further described below.

To the extent possible, Ameren Missouri 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 APA-ZZ-009 1 1 Fatigue Management Program.

Under the requested exemption, if approved, Ameren Missouri will implement the alternative controls described below, as needed, consistent with Reference 1 for the management of fatigue during the period ofthe exemption. These controls ensure that covered workers are subjected to the following minimum controls:

( 1) not more than 1 6 work-hours in any 24-hour period and not more than 86 work-hours in any 7-day period, excluding shifi turnover;

( 2) a minimum 1 0-hour break is provided between successive work periods;

ULNRC-06625 December 3 1 2020 Page3of6 (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; and

( 5) requirements are established for behavioral observation and self-declaration during the period ofthe exemption.

The requirements of 10 CFR 26.33, Behavioral observation; 10 CFR 26.209, Self-declarations; and 10 CFR 26.21 1 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 through worker self-declaration, and to assess and address instances of impairment through fatigue assessments.

In regard to exemption from the work-hour rule controls of 10 CFR 26.205(d)(1)-(d)(7), Ameren Missouri requests extension beyond the current exemption period, which expires January 1 6, 2021, such that an additional 60 days beyond that date (i.e., to March 17, 2021) would be allowed. This extension will reasonably not result in cumulative fatigue of covered staff and will not compromise plant safety or security due to impaired worker fitness for duty. This conclusion is justifiable because:

. To date, the approved alternative controls were utilized for only eight security officers by Ameren Missouri during the period commencing November 1 7, 2020. Otherwise, station management continued to control the work hours of the covered personnel in accordance with 10 CFR 26.205(d)(1)-(d)(7).

. To date, neither waivers nor exceedances ofthe work-hour controls of 10 CFR 26.205(d)(1)-

(d)(7) have occurred during the exemption period commencing November 1 7, 2020.

. For security personnel, the shills are 12-hour, rotating shifis (except for the training/relief week, which are 8-hour day shifts). For security supervisors, the hours are 0500 to 1 700 and 1700 to 0500. For security officers, the hours are 0542 to 1800 and 1742 to 0600. There are 1 8 minutes built into each security officers schedule for shift turnover. The schedule for security personnel is a 5-week schedule which is covered by 5 crews. The pattern of days on and offis as follows:

0 Week 1 : Days Monday, Tuesday, Friday, and Saturday 0 Week 2: Days Sunday, Wednesday and Thursday 0 Week 3 : Days 8-hour training/relief week Monday through Friday 0 Week 4: Nights Monday, Tuesday, Friday and Saturday 0 Week 5 : Nights Sunday, Wednesday, and Thursday The average number ofhours worked per week for security is 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> average over the 5 week schedule.

. To date, there was one self-declaration by a security person for fatigue, which occurred on December 1 3 2020. There were no behavioral observations of fatigue or impaired alertness during the exemption period commencing November 1 7, 2020.

. As described above, Ameren Missouri will administer the alternative work-hour controls in accordance the station s work-hour control program and station procedure APA-ZZ-0091 1, Fatigue Management Program.

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ULNRC-06625 December 31, 2020 Page4of6 Upon NRC approval, Ameren Missouri will implement, when necessary, the alternative controls described in Reference 1 for the management of fatigue during the additional 60-day exemption period requested per this letter. The requested exemption from the 1 0 CFR 26.205(d)(l) through (d)(7) requirements is intended to prevent and limit the spread of COVID-l 9 and to mitigate its effect should staffing be significantly impacted. Ameren Missouri intends to use the alternative controls only when necessary to efficiently perform operation, inspection, maintenance and testing activities that cannot be performed in accordance with the requirements of 10 CFR 26.205.

Near the end ofthe 60-day period for the requested exemption, ifthe COVID-19 conditions persist at the site, thereby 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 continuing to present a COVID-l 9 challenge to the immediate community of Callaway, another request may be submitted to provide for an additional 60-day exemption period in regard to work-hour controls.

Ameren Missouri respectfully requests NRC approval of the requested exemption by no later than January 1 6, 202 1 in order to continue implementation of the safety benefits of the alternative controls.

This letter does not contain new commitments.

Ifthere are any questions, please contact Tom Elwood at 314-225-1905.

Sincerely, I 22/c M. A. McLachlan Senior Director, Nuclear Plant Support

ULNRC-06625 December 31, 2020 Page5of6 cc: Mr. Scott A. Morris Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U. S Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. M. Chawla Project Manager, Callaway Plant Office ofNuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O8B1A Washington, DC 20555-000 1

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ULNRC-06625 December 31, 2020 Page 6 of 6 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6100 Western Place, Suite 1050 FortWorth,TX 76107

( Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Other Situations ULNRC Distrib ution:

F. M. Diya B. L. Cox S. P. Banker F. J. Bianco M. A. McLachlan R. C. Wink B. Brown T. B. Elwood NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission T-

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