RS-21-011, Subsequent Request for Exemption from Part 26 Work Hours Requirements

Subsequent Request for Exemption from Part 26 Work Hours Requirements

ML21022A372
Person / Time
Site:	LaSalle
Issue date:	01/22/2021
From:	Demetrius Murray Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-21-011
Download: ML21022A372 (7)

Text

4300 Winfield Road Warrenville , IL 60555 Exelon Generation 630 657 2000 Office RS-21-011 10 CFR 26.9 January 22, 2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Subsequent Request for Exemption from Part 26 Work Hours Requirements

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," dated March 28, 2020 (ML20087P237).

2. 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).

3. Exelon Generation Company, LLC application via the online portal for LaSalle County Station COVID-19 Related Request for Exemption from Part 26 Work Hours Requirements on November 24, 2020 (ML20329A301 ).

4. NRC Letter to EGC, "LaSalle County Station, Units 1 and 2 - Exemption from Select Requirements of 10 CFR Part 26 (EPID L-2020-LLE-0217 [COVID-19])", dated December 1, 2020 (ML20330A326).

As a result of the Coronavirus Disease 2019 (COVID-19) public health emergency (PHE),

Exelon Generation Company, LLC (EGC) requested NRC approval for LaSalle County Station ,

Units 1 and 2 (LSCS) in Reference 3 to utilize the alternative work hour controls. In Reference 4, the NRC approved the requested exemption from specific requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 26, "Fitness for Duty Programs," Section 26.205, "Work hours" for LSCS. The exemption is effective from December 7, 2020 through February 4, 2021 .

The alternative controls will support maintaining staffing requirements due to COVID-19 positive test results or contact tracing quarantines that cannot be accommodated by the current work

January 22 , 2021 U.S. Nuclear Regulatory Commission Page 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> control requirements of 10 CFR 26.205(d) to support plant operational safety and security.

The increase in COVID-19 cases in the state of Illinois and communities surrounding LSCS 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 a supplement request to extend the exemption period implementation approved in Reference 4 would allow LSCS to proactively take steps to ensure added flexibility is available to facilitate further worker and community protection and ensure safe operation during the subsequent exemption period.

An additional period of exemption from the 10 CFR 26.205(d)(1) through (d)(?) requirements is intended to prevent and limit the spread of COVID-19 and to mitigate its effect should LSCS staffing be significantly impacted. LSCS 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 LSCS's continuing efforts to maintain CDC recommendations. In addition, the extended alternative controls will be used to mitigate the staffing impacts should personnel absences challenge required staffing levels during the continuing COVID-19 PHE.

As the U.S. 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. LSCS's operation must be conducted such that the operating units can be safely maintained , and 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 References 1 and 2, the following work groups will continue to implement the site-specific alternative work hour controls, as necessary, for the management of fatigue until April 5, 2021:

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 LSCS's site-specific COVID-19 PHE fatigue-management controls are consistent with the constraints outlined in the References 1 and 2. LSCS 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).

January 22 , 2021 U.S. Nuclear Regulatory Commission Page 3 The information in the following table describes how cumulative fatigue has been managed for the various positions included in the initial alternative work hour controls exemption period approved in Reference 4 and how it will be managed during the extended exemption period.

10 CFR Positions Additional Information 26.4(a)(1) Operators During the initial exemption period, Operations has been following the normal online schedule and has not deviated .

Operations has 52 Equipment Operators (EO), 29 Nuclear Station Operators (NSO), 33 Senior Reactor Operators (SRO),

and 8 Shift Managers (SM).

The online shift rotation is a rotating days and nights schedule for twelve (12) hour durations from 0600 - 1800 and 1800 -

0600 spread across five independent crews as follows:

Days Monday -Thursday (4 days)

Nights Tuesday - Thursday (3 nights)

Nights Friday - Monday (4 nights)

Days Friday - Sunday (3 days)

Training Tuesday - Friday (4 days, 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> each)

Operations plan to work the following schedule during the upcoming outage:

A fixed schedule of either days or nights for four (4) twelve (12) hour shifts with one day off out of five (5) calendar days.

26.4(a)(2) Health Physics Chemistry and Chemistry During the initial exemption period, Chemistry has been following the normal online schedule and has not deviated .

Chemistry has 12 technicians.

Chemistry technicians work a fixed days (0630 - 1430),

afternoons (1430 - 2230), and nights (2230 - 0630) shift for online schedule from Monday through Friday and rotate to cover the weekend shift. These shifts are eight (8) hours in length.

For the upcoming outage, two technicians will be loaned to Radiation Protection (RP). The upcoming outage schedule consists of fixed twelve (12) hours day or night shifts of 4 days on followed by 1 day off for the duration of the outage, with 3 technicians each shift as covered workers. Shifts during the outage are from 0630 - 1830 or 1830 - 0630 .

Other than the 6 covered workers, the rest of the crew will be uncovered workers working 7 days of 12-hour shifts with an optional day off.

January 22 , 2021 U.S. Nuclear Regulatory Commission Page4 Radiation Protection (RP)

During the initial exemption period, RP has been following the normal online schedule and has not deviated.

RP currently has 18 qualified technicians and 2 newly hired unqualified technicians. There are 6 permanent backshift technicians for the afternoons and nights shifts with a rotating schedule to accommodate weekends .

RP technicians work a days (0700 - 1500), afternoons (1500 -

2300), and nights (2300 - 0700) shift for online schedule during all days of the week . These shifts are eight (8) hours in length .

The upcoming outage consists of fixed day or night shifts and RP has 18 technicians of which 6 are covered workers. The outage schedule consists of fixed day or night shifts of one week of six (6) twelve ( 12) hour shifts, followed by one day off, then one week of five (5) twelve (12) hour shifts followed by two days off, followed by a subsequent week of six (6) twelve (12) hour shifts followed by one day off. Shifts during the outaqe are from 0630 - 1830 or 1830 - 0630 .

26.4(a)(3) Fire Brigade Operations maintains the required personnel for Fire Brigade.

Assessment for this position are included in the Operators position assessment.

26.4(a)(4) Maintenance Instrument Maintenance Department (IMO)

During the initial exemption period, IMO has been following the normal online schedule and has not deviated.

Instrument Maintenance currently has 26 Technicians . The online schedule has included fixed 8-hour shifts from Monday through Friday. The shifts are from 0700 - 1530, 1500 - 2330, and 2300 - 0730.

During the upcoming outage, IMO will be working fixed 12-hour shifts (0630 - 1830 and 1830 - 0630) 6 days a week in accordance with normal outage rules. The current plan is to have all technicians work six consecutive days followed by one required day off, and then work the remainder of the outage without a required day off and not exceeding 14 consecutive work days.

Electrical Maintenance Department (EMO)

During the initial exemption period , EMO has been following the normal online schedule and has not deviated.

January 22 , 2021 U.S. Nuclear Regulatory Commission Page 5 Electrical Maintenance currently has 26 Technicians. The online schedule has included fixed 8-hour shifts from Monday through Friday. The shifts are from 0700 - 1530, 1500 - 2330, and 2300 - 0730.

During the upcoming outage, EMO will be working fixed 12-hour shifts (0700 - 1900 and 1900 - 0700) 6 days a week with one day off in accordance with normal outage rules.

Mechanical Maintenance Department (MMD)

During the initial exemption period, MMD has been following the normal online schedule and has not deviated.

Mechanical Maintenance currently has 53 Technicians. The online schedule has included fixed 8-hour shifts from Monday through Friday. The shifts are from 0700 to 1530, 1500 to 2330, and 2300 to 0730.

During the upcoming outage, MMD will be working fixed 12-hour shifts (0700 - 1900 and 1900 - 0700) 6 days a week with one day off in accordance with normal outage rules.

Reactor Services During the initial exemption period , Reactor Services has been following the normal online schedule and has not deviated .

Reactor Services currently has 12 Fuel Handlers and 3 First Line Supervisors. The online schedule has one fixed 8-hour shift from Monday through Friday from 0600 - 1430.

During the upcoming outage, Reactor Services is scheduled to work fixed 12-hour shifts (0600 - 1800, 0800 - 2000, 1800 -

0600, and 2000 - 0800) 6 days a week with one day off in accordance with normal outage rules.

26.4(a)(5) Security During the initial exemption period , Security personnel maintained their normal schedule. Security shifts are fixed either from 0600 - 1800 or 1800 - 0600.

For the upcoming outage, Security personnel will maintain their normal schedule of fixed shifts from 0600 - 1800 or 1800 -

0600.

Immediately preceding the initial exemption period, no personnel specified in 10 CFR 26.4(a) were controlled in accordance with neither 10 CFR 26.205(d)(3) nor (d)(7).

January 22 , 2021 U.S. Nuclear Regulatory Commission Page 6 There have been no self-declarations or fatigue assessments during the initial exemption period thus far.

The above information provides the requested information for expedited review of subsequent request in accordance with Reference 2.

Upon NRC approval, LSCS will continue to implement the alternative controls described in References 1 and 2 for the management of fatigue during the extended exemption period.

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; and (5) The calculation 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 ; and (6) requirements are established for behavioral observation and self-declaration during the period of the exemption.

The requirements of 10 CFR 26 .33, "Behavioral observation"; 10 CFR 26.209, "Self-declarations"; and 10 CFR 26.211, "Fatigue assessments" will continue to remain in effect during the extended exemption period. These requirements continue to 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, LSCS will continue to implement the alternative controls described in the References 1 and 2 for the management of fatigue until April 5, 2021. LaSalle County Station, Unit 1 is planned to remain operating in MODE 1 during the requested exemption period .

LaSalle County Station, Unit 2 is planned for a refueling outage during the requested exemption period . The extension beyond the initial exemption period of 60 days will continue to provide LSCS with the ability to proactively take steps to ensure added flexibility is available to complete necessary operations, tests, inspections, and maintenance in a manner that supports nuclear safety and security.

In order to expedite continued implementation of the alternative controls' safety benefits, LSCS requests written approval of this subsequent request no later than February 4, 2021.

There are no regulatory commitments contained in this letter.

January 22, 2021 U.S. Nuclear Regulatory Commission Page 7 Should you have any questions concerning this letter, please contact Mr. Jason Taken at (630) 806 9804.

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Sr. Manager - Licensing Exelon Generation Company, LLC cc: NRC Regional Administrator, Region Ill NRC Senior Resident Inspector - LaSalle County Station Illinois Emergency Management Agency - Division of Nuclear Safety