ULNRC-06629, Response to Request for Additional Information Pertaining to Additional Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs

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

ML21007A374
Person / Time
Site:	Callaway
Issue date:	01/07/2021
From:	Mclachlan M Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ULNRC-06629
Download: ML21007A374 (8)

Text

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Callaway Plant MISSOURI January 7, 2021 ULNRC-06629 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10CFR26 Ladies and Gentlemen:

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

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

References:

1 . Ameren Missouri letter ULNRC-06625, Additional Request for Exemption from Specific Requirements of 1 0 CFR Part 26, Fitness for Duty Programs, dated December 3 1 2020 ,

(ADAMS Accession Number ML20366A062)

2. NRC electronic correspondence, Request for Additional Information (COVID-19) Callaway Plant, Unit 1 Additional Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness For Duty Programs EPID L-2021-LLE-0242.

In the letter identified as Reference 1 Union Electric Company (Ameren Missouri) submitted an additional request for exemption from specific requirements of 1 0 CFR Part 26, Fitness for Duty Programs. From review of the Reference 1 submittal, the NRC staff electronically transmitted per Reference 2 a request for additional information (RAT) on January 6, 2021 This letter provides Ameren Missouris response to the RAT. Specifically, Ameren Missouris responses to the RAT questions/requests are provided in the enclosure to this letter.

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ULNRC-06629 January 7, 2021 Page2of4 Consistent with Reference 1 Ameren Missouri respectfully requests NRC approval of the requested exemption by no later than January 1 6, 2021 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, M. A. McLachlan Senior Director, Nuclear Plant Support

Enclosure:

Ameren Missouri Response to NRC RAT 1

ULNRC-06629 January 7, 2021 Page3of4 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 of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O8B1A Washington, DC 20555-0001

ULNRC-06629 January 7, 2021 Page4of4 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 Distribution:

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

Enclosure to ULNRC-06629 Ameren Missouri Response to NRC RAI 3 pages

Enclosure to ULNRC-06629 Page 1 of3 Ameren Missouri Response to NRC RAI On January 6, 202 1 the NRC electronically transmitted a Request for Additional Information (RAI) in regard to the Part 26 exemption request submitted for the Callaway plant by Ameren Missouri per Letter ULNRC-06625, Additional Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs, dated December 3 1, 2020 (ADAMS Accession Number ML20366A062). The following provides Ameren Missouris responses to the RAT questions/requests.

1. The guidance contained in the NRCs November 10, 2020 letter (ADAMS Accession No. ML20261H515) states, in part, that licensees requesting approval for a subsequent exemption should provide the following information:

. actual hours worked during the initial exemption period of each work group for which the licensee is requesting an exemption from the work hour controls

. the site-specific administrative controls that will be used to manage worker fatigue during the subsequent exemption period With regards to the eight (8) security officers for whom alternate work hour controls were utilized during the initial exemption period that commenced on November 17, 2020, please provide the following information:

. During which dates were the security officers working under alternative work hour controls?

Response

The table below documents the dates when the security officers were working under the alternative work hour controls. For each instance of when alternative work hours were utilized by an individual, a Condition Report was generated under the plants corrective action program. Note that while there were eight (8) cases documented, there were only six (6) security officers impacted.

Condition Report for use of Dates working under alternative work hour alternative work hour controls controls Condition Report 202006997 December 4, 2020 Condition Report 202007109 December 10, 2020 Condition Report 202007109 December 10, 2020 Condition Report 202007153 December 13, 2020 Condition Report 202007242 December 17, 2020 Condition Report 202007434 December 26, 2020 Condition Report 202007434 December 27, 2020 Condition Report 202007469 December 3 1, 2020

Enclosure to ULNRC-06629 Page 2 of 3

. Does the station expect to have utilized the alternative work hour controls during the fourteen (14) days prior to the requested January 16, 2021, implementation date of the subsequent exemption period? (In other words, does the station expect that they will need to utilize alternate work hours anytime between January 2 and January 15, 2021?)

Response

No, the station does not expect to utilize alternate work hours between January 2 and January 15, 2021 The shift cycle changed on January 3 which makes more days available for security personnel to work without having to utilize the alternate work hours. However, with the COVID-l9 cases increasing in the area, conditions may change such that the alternate work hours controls are utilized.

0 If so, what measures have been or will be taken to address the potential for cumulative fatigue among individuals for whom alternate controls will have been utilized during that 14-day period?

Response

In the event that the alternate work-hour controls are utilized during that 14-day period, the following administrative tools are available to address the potential for cumulative fatigue:

I During each shift brief, every security force member (SFM) is briefed to report fatigue.

. $EC-DIR-003, Security Operational Expectations Directive, has a stand-and-call policy to inform a supervisor if the SFM begins to feel fatigued.

. APA-ZZ-009l 1 Fatigue Management, describes the process for the management of fatigue, including provisions for self-declarations and fatigue assessments.

2. The second bullet on Page 3 ofthe submittal which states that no exceedances ofthe work hour controls listed in 10 CFR 26.205(d)(1)-(d)(7) have occurred appears to contradict the first bullet, which states that alternative controls were utilized for eight security officers.

Please clarify whether the alternative controls utilized for the eight officers consisted of an exceedance ofthe usual work hour controls outlined in 10 CfR 26.205(d)(l)-(d)(7).

Enclosure to ULNRC-06629 Page 3 of 3

Response

Yes, as clarification, the alternative controls utilized in the eight instances did consist of an exceedance ofthe usual work hour controls outlined in 10 CFR 26.205(d)(l)-(d)(7).

3 . The guidance contained in the November 10, 2020, letter states that licensees requesting approval for a subsequent exemption should provide the following:

. the scheduled modes ofoperation for the reactor unit(s) during the subsequent exemption period.

Please provide this information.

Response

The station is currently in a forced outage (i.e., in hot standby/Mode 3 at present). Ameren Missouri is still determining the extent of damage that caused the forced outage, as well as the repairs required, so a complete schedule for the outage is still to be developed. The intent is to return the plant to power operation (Mode 1) as soon as possible from the current forced outage, but there is no current projection ofwhen that will occur (and therefore, it is not known whether the plants return to power operation will occur during the requested exemption period). Another unknown is whether the plant will be taken to cold shutdown (Mode 4) for an extended period of time. In that case, the plant would be started up and returned to power through the typical Mode sequence. No additional outages are planned for the unit.

4. The guidance contained in the November 10, 2020, letter states in part that alternate work hours controls should ensure the following:

. 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.

Response

The controls implemented at Callaway will ensure that 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 offpreceding initiation ofthe exemption period.

Access Authorization personnel are working with the corporate Digital Team on updating software to track work hours consistent with the work hour controls. They are currently running an evaluation in a test environment until the changes get pushed into production. In addition, Security personnel are manually tracking the hours.