Letter Sequence Request |
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EPID:L-2022-LLE-0000, Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs (Approved, Closed) |
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Category:Exemption from NRC Requirements
MONTHYEARML23335A0782023-11-30030 November 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23166B0832023-07-0505 July 2023 Independence Spent Fuel Storage Installation - Issuance of Exemption ML23143A3912023-05-23023 May 2023 Independent Spent Fuel Storage Installation - Request for Exemption from NAC-MAGNASTOR Certificate of Compliance 72-1031 - Cask Lid Batch 3 Design Requirements ML22118B1622022-04-28028 April 2022 Request for Exemption from NAC-MAGNASTOR Certificate of Compliance 72-1031 - Cask Lid Design Requirements - Supplement ML22090A0982022-03-31031 March 2022 Independent Spent Fuel Storage Installation - Request for Exemption from NAC-MAGNASTOR Certificate of Compliance 72-1031 - Cask Lid Design Requirements ML22054A0062022-03-23023 March 2022 Exemption from the Requirements of 10 CFR 50.62 to Delete Diverse Auxiliary Feedwater Actuation System Using Risk-Informed Process for Evaluations (EPID L 2022 Lle 0004) Exemption ML22054A0052022-03-23023 March 2022 Exemption from the Requirements of 10 CFR 50.62 to Delete Diverse Auxiliary Feedwater Actuation System Using Risk-Informed Process for Evaluations (EPID L 2022 Lle 0004) Letter ML22034A9832022-02-15015 February 2022 FRN - Notice of Issuance of COVID-19 Exemptions Issued in January 2022 ML22035A3302022-02-10010 February 2022 Requests for Confirmation of Information for Exemption to Delete Diverse Auxiliary Feedwater Actuation System Based on Risk-Informed Process for Evaluations ML22003A1042022-01-26026 January 2022 the Independent Spent Fuel Storage Installation - Order Approving Indirect Transfer of Control of Licenses (EPID L 2021 LLM 0002) (FRN) ML22020A0402022-01-21021 January 2022 Exemption from Specific Requirements of 10 CFR Part 26 (EPID L 2022 Lle 0005 (Covid 19)) ML22020A0172022-01-19019 January 2022 Incoming Request from Palo Verde-Arizona Public Service Co. Re COVID-19 Related Request for Exemption from Part 26 Work Hours Requirements ML22014A4152022-01-14014 January 2022 Request for Exemption from Certain Requirements in 10 CFR 50.62(c)(1) Using Risk-Informed Process for Evaluations ML21243A5432021-09-0101 September 2021 Request for Partial Exemption from 10 CFR 50.62(c)(1) Risk-Informed Process for Evaluations (RIPE) ML20355A0002021-01-0505 January 2021 Exemption from Annual Force-on-Force Exercise Requirement of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel, Subsection VI.C.3.(I)(1) (EPID L-2020-LLE-0XXX (COVID-19)) ML20357A0552020-12-23023 December 2020 Subsequent Request for Exemption from Select Requirements of 10 CFR Part 26 (EPID L-2020-LLE-0238 (COVID-19)) ML20335A0902020-12-21021 December 2020 Federal Register Notice - November 2020 COVID-19 Exemptions ML20356A2922020-12-21021 December 2020 Independent Spent Fuel Storage Installation (ISFSI) - Subsequent Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs ML20353A3912020-12-18018 December 2020 Independent Spent Fuel Storage Installation (ISFSI) - Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section VI, Subsection A.7 and Subsection C.3(l)(1) ML20303A0152020-11-0202 November 2020 Exemption from Select Requirements of 10 CFR Part 26 (EPID L-2020-LLE-0170 (COVID-19)) ML20302A4172020-10-28028 October 2020 Independent Spent Fuel Storage Installation, Request for Exemption from Specific Requirements of 10 CFR Part 26, Fitness for Duty Programs ML20119A5242020-05-0707 May 2020 FRN: Notice of Issuance of Multiple Exemptions Regarding 10 CFR Part 26 (COVID-19) ML20107F8352020-04-16016 April 2020 Exemption from Select Requirements of 10 CFR Part 26 (EPID L-2020-LLE-0024 (COVID-19)) ML19205A2732019-08-19019 August 2019 Environmental Assessment for the Exemption Request for Arizona Public Service Company'S Palo Verde Nuclear Generating Installation in Wintersburg, Arizona ML19186A4492019-07-0505 July 2019 Request for Exemption from NAC-MAGNASTOR Certificate of Compliance 72-1031 ML0931605962009-11-0202 November 2009 Request for Temporary Exemption from the Provisions of 10 CFR 50.46 and 10 CFR 50, Appendix K for Lead Fuel Assemblies ML0827300062008-10-14014 October 2008 Temporary Exemption from the Requirements of 10 CFR Part 50, Section 50.46 and Appendix K for Lead Fuel Assemblies ML0827300032008-10-14014 October 2008 Transmittal Letter, Temporary Exemption from the Requirements of 10 CFR Part 50, Section 50.46 and Appendix K for Lead Fuel Assemblies 2023-07-05
[Table view] Category:Letter
MONTHYEARML24019A2012024-01-19019 January 2024 Fourth 10-Year Interval, Second Period Owners Activity Report Number 1R24 ML24019A1362024-01-18018 January 2024 Inservice Inspection Request for Information ML24012A2452024-01-12012 January 2024 Response to Request for Additional Information to Proposed Method to Manage Environmentally Assisted Fatigue for the Pressurizer Surge Line ML24010A1532024-01-10010 January 2024 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection ML23341A0062023-12-21021 December 2023 Project Manager Assignment IR 05000528/20230112023-12-18018 December 2023 License Renewal Inspection Report 05000528/2023011 ML23335A0782023-11-30030 November 2023 Independent Spent Fuel Storage Installation - Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23325A1602023-11-17017 November 2023 Supplemental Submittal - Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle IR 05000528/20234032023-11-13013 November 2023 NRC Security Inspection Report 05000528 2023403, 05000529 2023403, 05000530 2023403 (Full Report) ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23299A3052023-10-26026 October 2023 Response to Request for Additional Information Relief Request 70 Proposed Alternatives for Pressurizer Lower Shell Temperature Nozzle IR 05000528/20230032023-10-17017 October 2023 Integrated Inspection Report 05000528 2023003 and 05000529 2023003 and 05000530 2023003 ML23270B9232023-09-28028 September 2023 Notification of Age-Related Degradation Inspection (05000528/2024012, 05000529/2024012, and 05000530/2024012) and Request for Information ML23251A2332023-09-13013 September 2023 Notification of Post Approval Site Inspection for License Renewal and Request for Information Inspection (05000528/2023011) ML23241B0182023-09-13013 September 2023 Use of Honeywell Mururoa V4F1 and MTH2 Supplied Air Suits within Respiratory Protection Program IR 05000528/20243012023-09-0606 September 2023 Notification of NRC Initial Operator Licensing Examination 05000528/2024301; 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COVID-19 Related Request for Exemption from Part 26 Work Hours Requirements Submitted: Jan 19, 2022
- 1. Submitter Name/Title:
Matthew S. Cox, Licensing Section Leader
- 2. Email Address Please enter the email address for which you would like to receive communications regarding this request.
Matthew.Cox@aps.com
- 3. Organization Arizona Public Service Co.
- 4. Plant Name Palo Verde
- 5. Plant Unit(s): 1,2,3
- 6. Need By Date 2022-01-21
- 7. Docket Number(s)
Example: 05000313 05000528, 05000529, and 05000530
- 8. License Number(s)
Example: DPR-51 NPF-41, NPF-51, and NPF-74
- 9. NRC Licensing Project Manager S. LINGAM
- 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), Arizona Public Service Company (APS) is requesting NRC approval to utilize the alternative work hour controls delineated in the NRCs March 28, 2020 letter (ML20087P237) and November 10, 2020 letter (ML20261H515) for Palo Verde Nuclear Generating Station (PVNGS) for the covered workers noted below.
The alternative controls will support maintaining staffing requirements as a result of the recent increase in personnel absence due to COVID-19 positive test results or contact tracing quarantines that cannot be accommodated by the current work hour control requirements of 10 CFR 26.205(d)(1) through (d)(7) to support plant operational safety and security. The Centers for Disease Control (CDC) has determined that the community transmission rate is high in Maricopa County (where PVNGS is located) and all the surrounding counties in Arizona. The number of cases in Maricopa County has increased with a positivity rate of 36.11% in the last 7 days (through January 15, 2022) and similar increases have been seen in neighboring counties. This increase in cases 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 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.
APS has determined that implementing the alternative work hour controls for the covered workers would allow PVNGS to proactively take steps to ensure added flexibility is available to facilitate further worker and community protection and ensure safe operation during the period of the exemption.
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 PVNGS staffing be significantly impacted. PVNGS 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. The alternative controls will be used to mitigate the staffing impacts should personnel absences challenge required staffing levels. As the US Departments of Homeland Security and Energy 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. The PVNGS operation must be
conducted 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. 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) and 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), the following work groups would begin phasing in the site-specific alternative controls, as necessary, to minimize transition issues:
- 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.
PVNGS site-specific COVID-19 PHE fatigue-management controls are consistent with the constraints outlined in the referenced NRC letters and their attachments and enclosures. PVNGS will continue to follow the fatigue management controls, behavioral observation requirements, and self-declaration allowances in accordance with the current work-hour control program and station procedure 01DP-0AP17, Managing Personnel Fatigue. 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) 2022-01-21
- 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).
00:00
- 15. Statement that the licensees site specific alternative controls for the management of fatigue are consistent with the minimum alternative controls listed below.
PVNGS site-specific COVID-19 PHE fatigue-management controls are consistent with the constraints outlined in the referenced 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, PVNGS would implement the alternative controls described in the referenced NRC letters for the management of fatigue on January 21, 2022, 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 response to the COVID-19 challenges in the immediate community of PVNGS, an additional request may be submitted to extend the 60-day implementation period of the exemption.
Three previous PVNGS exemptions from select requirements of 10 CFR Part 26 due to the potential impact of COVID-19 were approved by the NRC and in effect between April 16, 2020, through June 15, 2020 (ML20107F835), November 2, 2020, through January 1, 2021 (ML20303A015), and January 2, 2021, through March 2, 2021 (ML20357A055).