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EPID:L-2021-LLE-0027, EP-AA-1003, Addendum 3, Revision 3, Emergency Action Levels for Clinton Station (Approved, Closed) |
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MONTHYEARML20316A0042020-11-10010 November 2020 EP-AA-1003, Addendum 3, Revision 3, Emergency Action Levels for Clinton Station Project stage: Request ML21111A0042021-04-20020 April 2021 Response to Request to Request Clinton, Unit 1, COVID-19 Related Request for Exemption from Part 26 Work Hours Requirements Project stage: Request ML21112A0072021-04-29029 April 2021 Exemption from Specific Requirements of 10 CFR Part 26 (EPID L-2021-LLE-0027 (COVID-19)) Project stage: Approval 2021-04-20
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Category:Response to Request for Additional Information (RAI)
MONTHYEARRS-22-089, Additional Information Supporting Request for License Amendment to Revise the Secondary Containment Design Basis to Credit the Fuel Building Railroad Airlock2022-07-25025 July 2022 Additional Information Supporting Request for License Amendment to Revise the Secondary Containment Design Basis to Credit the Fuel Building Railroad Airlock CNL-22-064, Response to Request for Additional Information Regarding Tennessee Valley Authority License Amendment Request to Revise Emergency Plan Implementing Procedure Regarding Seismic Event Emergency Action Level Change2022-06-0909 June 2022 Response to Request for Additional Information Regarding Tennessee Valley Authority License Amendment Request to Revise Emergency Plan Implementing Procedure Regarding Seismic Event Emergency Action Level Change RS-22-027, Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated2022-02-23023 February 2022 Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated P NMP1L3447, Constellation Energy Generation, LLC - Response to Request for Additional Information - Proposed Relief Request Associated with Reactor Pressure Vessel Water Level Instrumentation Partial Penetration Nozzle Repairs2022-02-0202 February 2022 Constellation Energy Generation, LLC - Response to Request for Additional Information - Proposed Relief Request Associated with Reactor Pressure Vessel Water Level Instrumentation Partial Penetration Nozzle Repairs JAFP-21-0087, Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments2021-09-16016 September 2021 Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments RS-21-087, Additional Information Supporting Request for License Amendment to Revise Degraded Voltage Relay Allowable Values2021-08-31031 August 2021 Additional Information Supporting Request for License Amendment to Revise Degraded Voltage Relay Allowable Values RS-21-078, Response to Request for Additional Information for Application to Revise Technical Specification to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, and TSTF-583-T, TSTF-582 Diesel2021-08-19019 August 2021 Response to Request for Additional Information for Application to Revise Technical Specification to Adopt TSTF-582, Reactor Pressure Vessel Water Inventory Control (RPV WIC) Enhancements, and TSTF-583-T, TSTF-582 Diesel NMP2L2773, Company - Response to Request for Additional Information2021-06-30030 June 2021 Company - Response to Request for Additional Information JAFP-21-0044, Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments2021-06-11011 June 2021 Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments JAFP-21-0032, Response to Request for Additional Information - Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting2021-04-20020 April 2021 Response to Request for Additional Information - Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting ML21111A0042021-04-20020 April 2021 Response to Request to Request Clinton, Unit 1, COVID-19 Related Request for Exemption from Part 26 Work Hours Requirements RS-21-037, Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505, Revision 22021-03-23023 March 2021 Response to Request for Additional Information Regarding License Amendment Request to Adopt TSTF-505, Revision 2 RS-20-139, Response to Request for Additional Information Regarding License Amendment Requests to Adopt TSTF-505, Revision 2, and 10 CFR 50.692020-11-24024 November 2020 Response to Request for Additional Information Regarding License Amendment Requests to Adopt TSTF-505, Revision 2, and 10 CFR 50.69 RS-20-096, Response to Request for Additional Information Related to Relief Request I4R-07 for the Fourth Inservice Inspection Interval2020-08-13013 August 2020 Response to Request for Additional Information Related to Relief Request I4R-07 for the Fourth Inservice Inspection Interval RS-20-095, Response to Request for Additional Information Related to Relief Request I4R-06 for the Fourth Inservice Inspection Interval2020-08-13013 August 2020 Response to Request for Additional Information Related to Relief Request I4R-06 for the Fourth Inservice Inspection Interval ML20188A2642020-07-0606 July 2020 Clinton Power Station, R.E. Ginna Station, Limerick Station, Nine Mile Point Station & Peach Bottom Station - Proposed Alternative to Utilize Code Case OMN-26 - Response to Request for Additional Information RS-20-069, Additional Information Supporting Request for License Amendment Regarding Automatic Operation of Transformer Load Tap Changer2020-06-29029 June 2020 Additional Information Supporting Request for License Amendment Regarding Automatic Operation of Transformer Load Tap Changer RS-20-067, Response to Request for Additional Information Related to Relief Request I4R-01 for the Fourth Inservice Inspection Interval2020-05-13013 May 2020 Response to Request for Additional Information Related to Relief Request I4R-01 for the Fourth Inservice Inspection Interval RS-20-045, Response to Request for Additional Information Related to Relief Request 14R.05 for the Fourth Inservice Inspection Interval2020-04-0101 April 2020 Response to Request for Additional Information Related to Relief Request 14R.05 for the Fourth Inservice Inspection Interval RS-19-112, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Following Adoption of TSTF-542, Reactor Pressure Vessel Water Inventory Control2019-12-0505 December 2019 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications Following Adoption of TSTF-542, Reactor Pressure Vessel Water Inventory Control NMP2L2711, Byron Station; Calvert Cliffs; Clinton Power Station; LaSalle County Station; Limerick Generating Station; and Nine Mile Point Nuclear Station - Proposed Alternative to Utilize Code Case N-8792019-10-16016 October 2019 Byron Station; Calvert Cliffs; Clinton Power Station; LaSalle County Station; Limerick Generating Station; and Nine Mile Point Nuclear Station - Proposed Alternative to Utilize Code Case N-879 JAFP-19-0057, Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-8802019-06-0404 June 2019 Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880 NMP1L3279, Response to Request for Additional Information - Proposed Alternatives to Utilize Code Cases N-878 and N-880 for Plants2019-05-0101 May 2019 Response to Request for Additional Information - Proposed Alternatives to Utilize Code Cases N-878 and N-880 for Plants JAFP-19-0006, Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-8802019-01-0808 January 2019 Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880 RS-18-150, Transmittal of Supplemental Information for Exelon Evaluation of Preliminary White Finding2018-12-20020 December 2018 Transmittal of Supplemental Information for Exelon Evaluation of Preliminary White Finding RS-18-143, Supplemental Information Supporting License Amendment Requests for Approval of Changes to Emergency Plan Staffing Requirements2018-11-29029 November 2018 Supplemental Information Supporting License Amendment Requests for Approval of Changes to Emergency Plan Staffing Requirements RS-18-103, Response to Request for Additional Information Concerning License Amendment Request to Revise Alternate Source Term Dose Calculation2018-08-29029 August 2018 Response to Request for Additional Information Concerning License Amendment Request to Revise Alternate Source Term Dose Calculation RS-18-097, Response to Request for Additional Information and Supplemental Information-License Amendment.2018-07-27027 July 2018 Response to Request for Additional Information and Supplemental Information-License Amendment. RS-18-067, Response to Request for Additional Information Regarding Generic Letter 2016-012018-05-29029 May 2018 Response to Request for Additional Information Regarding Generic Letter 2016-01 RS-18-061, Response to Request for Additional Information Regarding Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (Isfsis)2018-05-0202 May 2018 Response to Request for Additional Information Regarding Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (Isfsis) ML18025A7992018-01-25025 January 2018 Response to Request for Additional Information Regarding Generic Letter 2016-01 RS-17-145, Supplement to Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control2017-11-15015 November 2017 Supplement to Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control RS-17-079, Response to Request for Additional Information Regarding the Permanent Extension of Leak Rate Testing2017-06-0101 June 2017 Response to Request for Additional Information Regarding the Permanent Extension of Leak Rate Testing RS-17-044, Response to Request for Additional Information Regarding Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography2017-03-13013 March 2017 Response to Request for Additional Information Regarding Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography RS-17-020, Response to RAI Concerning License Amendment Request to Revise Technical Specification Section 5.5.13, Primary Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies2017-03-0202 March 2017 Response to RAI Concerning License Amendment Request to Revise Technical Specification Section 5.5.13, Primary Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies RS-16-121, Response to Request for Additional Information Concerning License Amendment Request to Incorporate Revised Alternative Source Term Dose Calculation in USAR2016-06-0202 June 2016 Response to Request for Additional Information Concerning License Amendment Request to Incorporate Revised Alternative Source Term Dose Calculation in USAR RA-16-049, Response to Request for Additional Information Regarding Requests to Withhold Emergency Preparedness Documents from Public Disclosure2016-05-26026 May 2016 Response to Request for Additional Information Regarding Requests to Withhold Emergency Preparedness Documents from Public Disclosure RS-16-077, Response to Request for Additional Information Regarding Request for License Amendment to Reduce the Reactor Steam Dome Pressure Specified in the Technical Specification 2.1.1, Reactor Core Sls.2016-04-14014 April 2016 Response to Request for Additional Information Regarding Request for License Amendment to Reduce the Reactor Steam Dome Pressure Specified in the Technical Specification 2.1.1, Reactor Core Sls. RS-15-278, Supplement to Request for Additional Information Regarding License Amendment Request for a One-Time Extension of the Shutdown Service Water Division 2 Subsystem Completion Time2015-10-20020 October 2015 Supplement to Request for Additional Information Regarding License Amendment Request for a One-Time Extension of the Shutdown Service Water Division 2 Subsystem Completion Time RS-15-260, Response to Request for Additional Information Regarding License Amendment Request for a One-Time Extension of the Shutdown Service Water Division 2 Subsystem Completion Time2015-09-30030 September 2015 Response to Request for Additional Information Regarding License Amendment Request for a One-Time Extension of the Shutdown Service Water Division 2 Subsystem Completion Time RS-15-141, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.2, Primary Coolant Sources Outside Containment.2015-06-24024 June 2015 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.2, Primary Coolant Sources Outside Containment. 2022-07-25
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COVID-19 Related Request for Exemption from Part 26 Work Hours Requirements Submitted: Apr 20, 2021
- 1. Submitter Name/Title:
Patrick R. Simpson, Senior Manager Licensing
- 2. Email Address Please enter the email address for which you would like to receive communications regarding this request.
Patrick.Simpson@exeloncorp.com
- 3. Organization Exelon Generation Co., LLC
- 4. Plant Name Clinton
- 5. Plant Unit(s): 1
- 6. Need By Date 2021-05-04
- 7. Docket Number(s)
Example: 05000313 05000461
- 8. License Number(s)
Example: DPR-51 NPF-62
- 9. NRC Licensing Project Manager J. WIEBE
- 10. Statement that the licensee above can no longer meet the work hour controls of 10 CFR 26.205(d) for certain personnel or groups of personnel specified in 10 CFR 26.4(a) because of site specific issues as a result of the COVID-19 public health emergency (PHE).
As a result of the Coronavirus Disease 2019 (COVID-19) public health emergency (PHE), Exelon Generation Company, LLC (EGC) is requesting NRC approval to utilize the alternative work hour controls delineated in the NRCs March 28, 2020 letter (ML20087P237) and November 10, 2020 letter (ML20261H515) for Clinton Power Station (CPS) for the covered workers noted below.
The alternative controls will support maintaining staffing requirements as a result of the 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)(7) to support plant operational safety and security. The increase in COVID-19 cases in the State of Illinois and communities surrounding CPS could impact the station's ability to meet the work hour controls of 10 CFR 26.205(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 operations, tests, inspections, and maintenance in a manner that supports nuclear safety and security. Therefore, EGC has determined that implementing the alternative work hour controls would allow CPS to proactively take steps to ensure added flexibility is available to facilitate further worker and community protection and ensure safe operation during the period of the exemption.
Exemption from the 10 CFR 26.205(d)(1) through (d)(7) requirements is intended to prevent and limit the spread of COVID-19 and to mitigate its effect should CPS staffing be significantly impacted. CPS 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, worker screening, 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 and supports CPS's continuing efforts to maintain CDC recommendations. In addition, the alternative controls will be used to mitigate the staffing impacts should personnel absences challenge required staffing levels.
As the US Departments of Homeland 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. CPS's
operation must be conducted such that the plant can be maintained on-line safely and is available when needed to support the critical infrastructure.
In accordance with the 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) and 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), the following work groups would begin phasing in on May 4, 2021 the site-specific alternative controls, as necessary, to minimize transition issues:
10 CFR 26.4(a)(1) Operators 10 CFR 26.4(a)(2) Health Physics and Chemistry 10 CFR 26.4(a)(3) Fire Brigade 10 CFR 26.4(a)(4) Maintenance 10 CFR 26.4(a)(5) Security
- 11. List of personnel or groups of personnel specified in 10 CFR 26.4(a) for which the licensee will maintain current work hour controls under 10 CFR 26.205(d)(1)-(d)(7).
N/A
- 12. List and description of alternative controls for the management of fatigue to address site specific issues as a result of the COVID-19 PHE.
CPS's site-specific COVID-19 PHE fatigue-management controls are consistent with the constraints outlined in the referenced NRC letters and their attachments and enclosures.
CPS will continue to follow the fatigue management controls, behavioral observation requirements, and self-declaration allowances currently delineated within the EGC work hour control program and procedures (LS-AA-119, SY-AA-102, SY-AA-103-500).
The requirements of 10 CFR 26.33, Behavioral observation; 10 CFR 26.209, Self-declarations; and 10 CFR 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.
- 13. Date when the licensee will begin implementing its site-specific COVID-19 PHE fatigue-management controls for personnel specified in 10 CFR 26.4(a) 2021-05-04
- 14. The time when the licensee will begin implementing its alternative controls for the management of fatigue for personnel (or group of personnel) specified in 10 CFR 26.4(a).
00:00
- 15. Statement that the licensees site specific alternative controls for the management of fatigue are consistent with the minimum alternative controls listed below.
CPS's site-specific COVID-19 PHE fatigue-management controls are consistent with the constraints outlined in the referenced NRC letters, dated March 28, 2020 and November 10, 2020.
- 16. Does Licensee continue to meet the requirements of 10 CFR 26.33, Behavioral observation; 10 CFR 26.209, Self declarations; and 26.211, Fatigue assessments.
Yes
- 17. The alternative controls include the following, as a minimum:
- 1. Individuals will not work 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 30-day period; and
- 5. Changes in actions to meet requirements for behavioral observation for both acute and cumulative fatigue and self declaration during the period of the exemption as appropriate due to potential for increased worker fatigue.
Yes
- 18. Additional Information:
Use the area below to provide any additional information related to your exemption request.
Upon NRC approval, CPS would implement the alternative controls described in the referenced NRC letters for the management of fatigue on May 4, 2021 for an initial period of 60 days. Near the end of the 60-day period, if COVID-19 pandemic conditions persist at the site 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 of particular concern is the COVID-19 challenge in the immediate community of CPS, an additional email supplement request may be submitted to extend the 60-day exemption period implementation.