NRC-20-0045, Work Hour Limits Exemption Request Due to COVID-19 Supplement

Work Hour Limits Exemption Request Due to COVID-19 Supplement

ML20188A339
Person / Time
Site:	Fermi
Issue date:	07/06/2020
From:	Peter Dietrich DTE Electric Company, DTE Energy
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-20-0045
Download: ML20188A339 (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 DTE July 6, 2020 10 CFR 26.205(d)

NRC-20-0045 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 Supplement

References:

1. 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).

2. DTE Electric letter to NRC Fermi 2 Work Hour Limits Exemption Request Due to COVID-19 NRC-19-0024, dated May 11, 2020 (ML20132A239)

3. NRC Letter to DTE, Fermi Exemption from Select Requirements Of 10 CFR PART 26 (EPID L-2020-LLE-0056 [COVID-19]), dated May 14, 2020 (ML20133K055)

As a result of the Coronavirus Disease 2019 (COVID-19) public health emergency (PHE), DTE Electric Company (DTE) requested NRC approval for Fermi Unit 2 (Fermi 2) to proactively enter into the alternative work hour controls in Reference 2. 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. Due to a COVID-19 outbreak affecting the Torus recoating effort, the Fermi 2 refueling outage has extended to over 100 days. Additional alternative work hour controls are needed to support completion of the Torus recoating effort and refueling outage. The 60 days of alternate control exemptions requested in Reference 2 will expire prior to completion of the refueling outage. This request is for an extension to the alternate work hour controls until August 10, 2020 so Fermi 2 can effectively support efforts to maintain Center for Disease Control recommendations related to social distancing, worker screening, and limiting close-proximity work. Extension of the alternative work hour controls

USNRC NRC-20-0045 Page 2 will facilitate worker and community protection as we complete 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.

In accordance with Reference 1, 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.

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 implement the Chemistry Will use site-specific alternative alternative 26.4(a)(3) Fire Brigade controls as defined in Reference 1 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 Reference 1 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 Reference 1 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

USNRC NRC-20-0045 Page 3 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 continue to implement the alternative controls described in Reference 1 for the management of fatigue until August 10, 2020. The extension beyond the initial period of 60 days will provide Fermi 2 time needed to complete the refueling outage and transition back to online rules for covered workers.

DTE requests approval of this request by no later than July 10, 2020.

No new commitments are being made in this submittal.

Should you have any questions or require additional information, please contact Ms. Margaret Offerle, Manager - Nuclear Licensing, at (734) 586-5076.

Senior Vice President and Chief Nuclear Officer cc: NRC Project Manager NRC Resident Office NRC Region III Branch Chief Division of Reactor Projects Branch 4 Regional Administrator, Region III