ML21265A159

COVID-19 Related Request for Exemption from Part 26 Work Hours Requirements

ML21265A159
Person / Time
Site:	Ginna
Issue date:	09/21/2021
From:	David Helker Exelon Generation Co
To:	V Sreenivas Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML21265A159 (5)

Text

COVID-19 Related Request for Exemption from Part 26 Work Hours Requirements Submitted: Sep 21, 2021

1. Submitter Name/Title:

David P. Helker, Senior Manager Licensing

2. Email Address Please enter the email address for which you would like to receive communications regarding this request.

David.Helker@exeloncorp.com

3. Organization Exelon Generation Co., LLC

4. Plant Name Ginna

5. Plant Unit(s): [Plant Units]

6. Need By Date 2021-10-04

7. Docket Number(s)

Example: 05000313 05000244

8. License Number(s)

Example: DPR-51 DPR-18

9. NRC Licensing Project Manager V. SREENIVAS

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 3/28/20 letter (ML20087P237) and 11/10/20 letter (ML20261H515) for the R. E. Ginna Nuclear Power Plant (Ginna) for the covered workers noted below.

EGC is requesting NRC approval to proactively enter the alternative work hour controls, as necessary, for the covered workers noted below. The basis for the request is that EGC is anticipating conditions where the station would no longer be able to meet the work-hour controls of 10 CFR 26.205(d)(1) through (d)(7) to support plant operational safety and security. The CDC has determined that the community transmission rate is now HIGH in Wayne County (where Ginna is located) and surrounding counties in New York. The number of cases per 100,000 people in Wayne County has increased approximately 43% in the last 7 days (through 9/19/21) and similar increases have been seen in neighboring counties (e.g., Monroe 28%, Ontario 12%, Cayuga 9%). The increase in COVID-19 cases in the State of New York and communities surrounding Ginna could impact the station's ability to meet the workhour controls of 10 CFR 26.205(d) in maintaining minimum staffing and ensuring that 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. EGC has determined that implementing the alternative work hour controls, for the covered workers noted below would allow Ginna to proactively ensure added flexibility facilitating worker and community protection while ensuring safe operation during the exemption period.

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 Ginna staffing be significantly impacted. Ginna 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 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 Ginnas 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 DHS and DOE 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. Ginnas operation must be conducted such that the refueling outage can be completed safely and efficiently such that the plant is available when needed to support the critical infrastructure.

In accordance with the NRC letter from H. Nieh to NEI, U.S. NRC Planned Actions Related to the Requirements for Work Hour Controls During the Coronavirus Disease 2019 Public Health Emergency, dated 3/28/20 (ML20087P237) and NRC letter from H.

Nieh to NEI, "U.S. NRC Updated Planned Actions Related to Certain Requirements for Operating and Decommissioning Reactor Licensees During the Coronavirus Disease 2019 Public Health Emergency," dated 11/10/20 (ML20261H515), the following work groups would begin phasing in on 10/04/21 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.

Ginnas site-specific COVID-19 PHE fatigue-management controls are consistent with the constraints outlined in the cited NRC letters in Item 10 above and their attachments and enclosures. Ginna will continue to follow the fatigue management controls, behavioral observation requirements, and self-declaration allowances currently delineated within the EGC workhour 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) 2021-10-04

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).

0000

15. Statement that the licensees site specific alternative controls for the management of fatigue are consistent with the minimum alternative controls listed below.

Ginna's site-specific COVID-19 PHE fatigue-management controls are consistent with the constraints outlined in the cited 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, Ginna would implement the alternative controls described in the cited NRC letters for the management of fatigue on 10/04/21 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 the COVID-19 challenge in the immediate community of Ginna, an additional email supplement request may be submitted to extend the 60-day exemption period implementation.

A previous Ginna exemption from select requirements of 10 CFR Part 26 due to the potential impact of COVID-19 was approved by the NRC and in effect between April 6, 2020 and June 5, 2020 (ML20095H256).