NRC-20-0024, Work Hour Limits Exemption Request Due to COVID-19

Work Hour Limits Exemption Request Due to COVID-19

ML20132A239
Person / Time
Site:	Fermi
Issue date:	05/11/2020
From:	Dietch P DTE Electric Company, DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-20-0024
Download: ML20132A239 (3)

Text

Peter Dietrich Senior Vice President and Chief Nuclear Officer DTE Energy Company 6400 N. Dixie Highway, Newport, MI 48166 Tel: 734.586.4153 Fax: 734.586.1431 Email: peter.dietrich@dteenergy.com May 11, 2020 10 CFR 26.205(d)

NRC-20-0024 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Fermi 2 Power Plant NRC Docket No. 50-341 NRC License No. NPF-43

Subject:

Fermi 2 Work Hour Limits Exemption Request due to COVID-19

Reference:

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, March 28, 2020 (ML20087P237).

As a result of the Coronavirus Disease 2019 (COVID-19) public health emergency (PHE), DTE Electric Company (DTE) is requesting NRC approval for Fermi Unit 2 (Fermi 2) to proactively enter into the alternative work hour controls delineated in the Reference letter. By implementing the alternate work hour controls, DTE is proactively taking steps to complete necessary refueling outage work, testing, and inspections in a manner that supports worker and neighboring community safety to limit the spread of the COVID-19 virus. This request is being made to support Fermi 2 efforts to maintain Center for Disease Control recommendations related to social distancing, worker screening, and limiting close-proximity work. Particularly given the COVID-19 challenge in the immediate community of Fermi 2, leveraging the alternative work hour controls will facilitate further worker and community protection as we perform the current outage and subsequent operation safely and efficiently.

As the US Departments of Homeland Security and Energy have stated in their guidance, the electric grid and nuclear plant operation make up the nation's critical infrastructure similar to the medical, food, communications, and other critical industries. The Fermi 2 outage and subsequent operation must be conducted such that the plant is available when needed, including during the critical peak summer loads.

In accordance with the Reference letter, the following information is provided in the table below:

Positions (as described in § 26.4(a)(1) - (5)) for which either current work-hour controls will be maintained, or for which alternative controls will be required as a preventive measure.

USNRC NRC-20-0024 Page 2 The date and time for which alternative controls (if necessary) will be implemented for the listed positions.

Positions Compliance Begin Implementation 26.4(a)(1) Operators 26.4(a)(2) Health Physics and Will use site-specific alternative Will implement the Chemistry controls as defined in the Reference alternative 26.4(a)(3) Fire Brigade letter approach upon 26.4(a)(4) Maintenance NRC approval 26.4(a)(5) Security Fermi 2 site-specific COVID-19 PHE fatigue-management controls are consistent with the constraints outlined in the Reference letter and its attachment. Fermi 2 will continue to follow the fatigue management controls, behavioral observation requirements, and self-declaration allowances currently delineated within the Fermi 2 work hour control program and procedures (MGA10 and MGA16).

Upon NRC approval, Fermi 2 will implement the alternative controls described below and discussed in the Reference letter for the management of fatigue during the period of the exemption. These controls ensure that covered workers are subjected to the following minimum controls:

(1) not 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; (5) requirements are established for behavioral observation and self-declaration during the period of the exemption As described above, the requirements of 10 CFR 26.33, Behavioral observation; 10 CFR 26.209, Self-declarations; and 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.

Upon NRC approval, Fermi 2 will implement the alternative controls described in the Reference letter for the management of fatigue during the 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, a supplemental email may be submitted to extend alternate work hour controls exemption.

DTE requests approval of this request by no later than May 20, 2020.