ML22013B175

Response to Request for Additional Information Related to Request for Exemption from Specific Requirements of 10 CFR 26, Fitness for Duty Programs (COVID-19)

ML22013B175
Person / Time
Site:	Davis Besse
Issue date:	01/13/2022
From:	Tony Brown Energy Harbor Nuclear Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-22-022
Download: ML22013B175 (2)

Text

energy harbor Terry J. Brown Site Vice President, Davis-Besse Nuclear January 13, 2022 L-22-022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Davis-Besse Nuclear Power Station Docket No. 50-346, License No. NPF-3 Energy Harbor Nuclear Corp.

Davis-Besse Nuclear Power Station.

5501 N State Route 2 Oak Harbor, Ohio 43449 419-321-7676 10 CFR 26 Response to Request for Additional Information Related to Request for Exemption from Specific Requirements of 10 CFR 26,IIFitness for Duty Programs" [COVID-191 On January 12, 2022, Energy Harbor Nuclear Corp. requested an exemption from certain work-hour controls specified in 10 CFR 26 for the Davis-Besse Nuclear Power Station (DBNPS). Because this request was related to the COVID-19 public health emergency (PHE), the request was made by entering information into the Nuclear Regulatory Commission (NRC) Part 26 Work Hour Exemption Request Form available on-line.

During review of the request, the NRC staff indicated that additional information was needed to complete the review. The requested information follows.

Current increased levels of COVID-19 cases and transmission rates in the state of Ohio and states and communities surrounding the DBNPS 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 number of qualified individuals who perform the duties 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.

The requested exemption would allow Energy Harbor Nuclear Corp. to proactively take steps to ensure added flexibility is available to facilitate further worker and community protection and ensure safe operation during the exemption period.

An 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 DBNPS staffing be significantly impacted. Energy Harbor Nuclear Corp. intends to use the alternative controls, where necessary to efficiently perform operation, inspection,

Davis-Besse Nuclear Power Station L-22-022 Page 2 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 potential spread of COVID-19 and supports Energy Harbor Nuclear Corp.'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 during the continuing COVID-19 PHE.

Upon NRC approval of the exemption, the following alternative control will also be implemented:

The calculation of work hours 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.

There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Manager - Fleet Licensing, at (330) 696-7208.

a ly, erry J wn cc:

NRC Region Ill Administrator NRC Resident Inspector NRC Project Manager Utility Radiological Safety Board