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EPID:L-2020-LLE-0179, Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-on-Force Exercises, Due to COVID-19 Pandemic (Approved, Closed) |
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MONTHYEARCNL-20-069, Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-on-Force Exercises, Due to COVID-19 Pandemic2020-10-14014 October 2020 Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-on-Force Exercises, Due to COVID-19 Pandemic Project stage: Request ML20308A3602020-11-0202 November 2020 Request for Additional Information on WBN Request for Exemption from 10 CFR Part 73, Appendix B, Section VI for the Conduct of an Annual Force-on-Force Exercise (EPID L-2020-LLE-0165 (COVID-19)) Project stage: Request CNL-20-092, Request for an Exemption Regarding Calendar Year 2020 Force-on-Force Exercise2020-11-0404 November 2020 Request for an Exemption Regarding Calendar Year 2020 Force-on-Force Exercise Project stage: Request ML20316A0172020-11-0909 November 2020 NRR E-mail Capture - Acceptance for Review of Exemption Request from Requirements of 10 CFR Part 73, Appendix B, Section VI, Subsection C.3.(l)(1) for Watts Bar Nuclear Plant, Units 1 and 2 Project stage: Acceptance Review ML20318A0362020-12-0808 December 2020 Exemption from Annual Force-on-Force Exercise Requirement of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel Subsection VI C.3(l)(1) (EPID L-2020-LLE-0179 (COVID-19)) Project stage: Approval 2020-11-04
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Category:Exemption from NRC Requirements
MONTHYEARML24199A0012024-07-22022 July 2024 Clarification and Correction to Exemption from Requirement of 10 CFR 37.11(c)(2) ML24172A1382024-07-16016 July 2024 Exemption from 10 CFR 37.11(C)(2) (EPID L-2023-LLE-0024) - FRN ML24172A1402024-07-16016 July 2024 Exemption from 10 CFR 37.11(C)(2) (EPID L-2023-LLE-0024) - FRN ML24172A1352024-07-15015 July 2024 Exemption ML24172A1342024-07-15015 July 2024 Exemptions from 10 CFR 37.11(C)(2) (EPID L-2023-LLE-0024) - Letter ML24172A1372024-07-15015 July 2024 Exemption ML24082A0692024-04-19019 April 2024 FRN for CBS Exemption Decision Watts Bar ML24087A1912024-04-18018 April 2024 Exemption from Select Requirements of 10 CFR Part 73, Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting ML24082A0602024-04-17017 April 2024 CBS Exemption Decision Watts Bar CNL-24-031, Supplement to Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance2024-03-18018 March 2024 Supplement to Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance CNL-24-012, Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance2024-02-28028 February 2024 Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance CNL-23-069, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-21021 December 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML22117A1852022-04-29029 April 2022 Exemptions from the Requirements of 10 CFR Part 26, Section 26.205(d)(7) (EPID L-2022-LLE-0017) (Letter) ML22117A1862022-04-29029 April 2022 Exemptions from the Requirements of 10 CFR Part 26, Section 26.205(d)(7) (EPID L-2022-LLE-0017) (Exemption) CNL-22-054, Request for Exemption from Requirements of 10 CFR 26.205(d)(4), 26.205(d)(6) and 26.205(d)(7), Fitness for Duty Programs - Work Hours2022-04-15015 April 2022 Request for Exemption from Requirements of 10 CFR 26.205(d)(4), 26.205(d)(6) and 26.205(d)(7), Fitness for Duty Programs - Work Hours ML20318A0362020-12-0808 December 2020 Exemption from Annual Force-on-Force Exercise Requirement of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel Subsection VI C.3(l)(1) (EPID L-2020-LLE-0179 (COVID-19)) CNL-20-092, Request for an Exemption Regarding Calendar Year 2020 Force-on-Force Exercise2020-11-0404 November 2020 Request for an Exemption Regarding Calendar Year 2020 Force-on-Force Exercise CNL-20-069, Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-on-Force Exercises, Due to COVID-19 Pandemic2020-10-14014 October 2020 Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-on-Force Exercises, Due to COVID-19 Pandemic ML19112A0522019-07-25025 July 2019 Federal Register Notice: Watts Bar Nuclear Plant, Units 1 and 2 - Exemption from the Requirements of 10 CFR Section 50.46 and Appendix K to 10 CFR Part 50 NRC-2010-0019, FRN: General Notice. Watts Bar Nuclear Plant, Units 1 and 2 - Exemption from the Requirements of 10 CFR Part 73, Section 73.55 (TAC Nos. ME2601 and ME2602)2010-03-0808 March 2010 FRN: General Notice. Watts Bar Nuclear Plant, Units 1 and 2 - Exemption from the Requirements of 10 CFR Part 73, Section 73.55 (TAC Nos. ME2601 and ME2602) ML1000604112010-03-0808 March 2010 FRN: General Notice. Watts Bar Nuclear Plant, Units 1 and 2 - Exemption from the Requirements of 10 CFR Part 73, Section 73.55 ML0531802632005-12-20020 December 2005 One-Time Exemption from NRC Requirements, EP Scheduler Exemption 2024-07-22
[Table view] Category:Letter type:CNL
MONTHYEARCNL-24-047, Decommitment of Flood Mode Mitigation Improvement Systems2024-09-24024 September 2024 Decommitment of Flood Mode Mitigation Improvement Systems CNL-24-060, Supplement to Request for Approval of the Tennessee Valley Authority Nuclear Quality Assurance Program Description2024-09-24024 September 2024 Supplement to Request for Approval of the Tennessee Valley Authority Nuclear Quality Assurance Program Description CNL-24-065, Tennessee Valley Authority – Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2024-09-18018 September 2024 Tennessee Valley Authority – Central Emergency Control Center Emergency Plan Implementing Procedure Revisions CNL-24-061, Supplement to Application to Revise Function 5 of Technical Specification Table 3.3.2-1, ‘Engineered Safety Feature Actuation System Instrumentation,’ for the Sequoyah and Watts Bar (SQN-TS-23-02 and WBN-TS-23-08),2024-08-19019 August 2024 Supplement to Application to Revise Function 5 of Technical Specification Table 3.3.2-1, ‘Engineered Safety Feature Actuation System Instrumentation,’ for the Sequoyah and Watts Bar (SQN-TS-23-02 and WBN-TS-23-08), CNL-24-052, Response to Request for Additional Information Regarding Application to Modify the Technical Specification Surveillance Requirement 3.9.5.1 (WBN-TS-21-14)2024-06-27027 June 2024 Response to Request for Additional Information Regarding Application to Modify the Technical Specification Surveillance Requirement 3.9.5.1 (WBN-TS-21-14) CNL-24-018, License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-276-A, Revision 2, Regarding TS 3.8.1 AC Sources – Operating to Clarify Requirements for Diesel Generator Testing (WBN-TS2024-06-25025 June 2024 License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-276-A, Revision 2, Regarding TS 3.8.1 AC Sources – Operating to Clarify Requirements for Diesel Generator Testing (WBN-TS CNL-24-040, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2024-05-0808 May 2024 Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revisions CNL-24-037, Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Unit 1 and 2, Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 422024-04-22022 April 2024 Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Unit 1 and 2, Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 42 CNL-24-033, Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2024-04-17017 April 2024 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions CNL-24-024, Hydrologic Engineering Center River Analysis System Project Milestone Status Update2024-04-17017 April 2024 Hydrologic Engineering Center River Analysis System Project Milestone Status Update CNL-24-010, License Amendment Request to Recapture Low-Power Testing Time (WBN-TS-23-19)2024-04-17017 April 2024 License Amendment Request to Recapture Low-Power Testing Time (WBN-TS-23-19) CNL-24-004, Application to Modify the Watts Bar Nuclear Plant, Unit 1 and Unit 2 Technical Specifications for Main Control Room Chiller Completion Time Extension (WBN-TS-23-13)2024-04-0404 April 2024 Application to Modify the Watts Bar Nuclear Plant, Unit 1 and Unit 2 Technical Specifications for Main Control Room Chiller Completion Time Extension (WBN-TS-23-13) CNL-24-020, Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Units 1 and 2, Request for Approval of Quality Assurance Program Description and Application to Revise the Technical Specifications Associated with QAPD Requirements2024-04-0101 April 2024 Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Units 1 and 2, Request for Approval of Quality Assurance Program Description and Application to Revise the Technical Specifications Associated with QAPD Requirements CNL-24-008, Guarantee of Payment of Deferred Premiums - 2023 Annual Report2024-03-27027 March 2024 Guarantee of Payment of Deferred Premiums - 2023 Annual Report CNL-24-007, Annual Insurance Status Report2024-03-27027 March 2024 Annual Insurance Status Report CNL-24-025, Notice of Intent to Pursue License Renewal for Watts Bar Nuclear Plant, Unit 1 - Submittal Schedule2024-03-25025 March 2024 Notice of Intent to Pursue License Renewal for Watts Bar Nuclear Plant, Unit 1 - Submittal Schedule CNL-24-031, Supplement to Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance2024-03-18018 March 2024 Supplement to Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance CNL-24-029, Response to Request for Additional Information Regarding Tennessee Valley Authority - Request for Exemption from Specific Requirements of 10 CFR Part 372024-03-14014 March 2024 Response to Request for Additional Information Regarding Tennessee Valley Authority - Request for Exemption from Specific Requirements of 10 CFR Part 37 CNL-24-028, Response to Request for Additional Information Regarding Watts Bar Nuclear Plant, Units 1 and 2, Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2024-03-14014 March 2024 Response to Request for Additional Information Regarding Watts Bar Nuclear Plant, Units 1 and 2, Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation CNL-24-012, Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance2024-02-28028 February 2024 Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance CNL-24-023, Central Emergency Control Center Emergency Plan Implementing Procedure Revision. Includes CECC EPIP-17, Revision 252024-02-20020 February 2024 Central Emergency Control Center Emergency Plan Implementing Procedure Revision. Includes CECC EPIP-17, Revision 25 CNL-24-017, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure and Emergency Preparedness Department Procedure Revisions2024-01-17017 January 2024 Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure and Emergency Preparedness Department Procedure Revisions CNL-24-016, Supplement to Application to Modify the Technical Specification Surveillance Requirement 3.9.5.1 (WBN-TS-21-14)2024-01-10010 January 2024 Supplement to Application to Modify the Technical Specification Surveillance Requirement 3.9.5.1 (WBN-TS-21-14) CNL-23-052, Application to Adopt TSTF-427-A, Revision 2, Allowance for Non-Technical Specification Barrier Degradation on Supported System Operability2024-01-0909 January 2024 Application to Adopt TSTF-427-A, Revision 2, Allowance for Non-Technical Specification Barrier Degradation on Supported System Operability CNL-23-062, Application to Revise the Technical Specifications Section 3.8.2, AC Sources-Shutdown, to Remove Reference to the C-S Diesel Generator (WBN-TS-23-018)2024-01-0808 January 2024 Application to Revise the Technical Specifications Section 3.8.2, AC Sources-Shutdown, to Remove Reference to the C-S Diesel Generator (WBN-TS-23-018) CNL-23-005, Application to Revise Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis (WBN-19-011)2023-12-26026 December 2023 Application to Revise Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis (WBN-19-011) CNL-23-069, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-21021 December 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation CNL-23-036, Application to Revise Function 5 of Technical Specification Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, for the Sequoyah Nuclear Plant and Watts Bar Nuclear Plant (SQN-TS-23-02 and WBN-TS-23-08)2023-12-18018 December 2023 Application to Revise Function 5 of Technical Specification Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, for the Sequoyah Nuclear Plant and Watts Bar Nuclear Plant (SQN-TS-23-02 and WBN-TS-23-08) CNL-23-001, Rebaseline of Sections 3.1 and 3.2 of the Technical Specifications (WBN-TS-23-01)2023-12-13013 December 2023 Rebaseline of Sections 3.1 and 3.2 of the Technical Specifications (WBN-TS-23-01) CNL-23-067, Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-11-27027 November 2023 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions CNL-23-059, Supplement to Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2, Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-2023-09-20020 September 2023 Supplement to Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2, Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-03 CNL-23-061, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revision2023-09-20020 September 2023 Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revision CNL-23-057, Central Emergency Control Center Emergency Plan Implementing Procedure Revisions. Includes CECC-EPIP-1, Revision 76 and CECC-EPIP-9, Revision 642023-09-0505 September 2023 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions. Includes CECC-EPIP-1, Revision 76 and CECC-EPIP-9, Revision 64 CNL-23-045, License Amendment Request to Revise Technical Specification Table 1.1-1 Regarding the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Bolts (WBN-TS-23-010)2023-08-0707 August 2023 License Amendment Request to Revise Technical Specification Table 1.1-1 Regarding the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Bolts (WBN-TS-23-010) CNL-23-028, Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-03 and WBN-TS-23-06)2023-08-0202 August 2023 Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-03 and WBN-TS-23-06) CNL-23-055, Tennessee Valley Authority - Emergency Preparedness Department Procedure Revision. Includes EPDP-3, Revision 3, Emergency Plan Exercises and Preparedness Drills2023-07-25025 July 2023 Tennessee Valley Authority - Emergency Preparedness Department Procedure Revision. Includes EPDP-3, Revision 3, Emergency Plan Exercises and Preparedness Drills CNL-23-053, Tennessee Valley Authority - Radiological Emergency Plan Revisions2023-07-18018 July 2023 Tennessee Valley Authority - Radiological Emergency Plan Revisions CNL-23-020, Application to Revise Technical Specifications to Adopt TSTF-501-A, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control (WBN-TS-22-06)2023-06-28028 June 2023 Application to Revise Technical Specifications to Adopt TSTF-501-A, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control (WBN-TS-22-06) CNL-23-049, Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan .2023-06-26026 June 2023 Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan . CNL-23-044, Transmittal of Revision 3 to WCAP-18774-P and WCAP-18774-NP, Addendum to the Rotterdam Dockyard Company Final Stress Report for 173 P.W.R. Vessels TVA III & IV (Report No. 30749-B-030, Rev. 3) - Evaluation of One Closure Stud Out2023-06-0101 June 2023 Transmittal of Revision 3 to WCAP-18774-P and WCAP-18774-NP, Addendum to the Rotterdam Dockyard Company Final Stress Report for 173 P.W.R. Vessels TVA III & IV (Report No. 30749-B-030, Rev. 3) - Evaluation of One Closure Stud Out CNL-23-042, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-05-16016 May 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions CNL-23-043, Emergency License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 1.1-1, Modes (WBN-TS-23-09)2023-05-0404 May 2023 Emergency License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 1.1-1, Modes (WBN-TS-23-09) CNL-23-030, Tennessee Valley Authority - Hydrologic Engineering Center River Analysis System Project Milestone Status Update2023-04-27027 April 2023 Tennessee Valley Authority - Hydrologic Engineering Center River Analysis System Project Milestone Status Update CNL-23-032, Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Unit 1 and 2, Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 412023-04-27027 April 2023 Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Unit 1 and 2, Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 41 CNL-23-033, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revision2023-04-24024 April 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revision CNL-23-029, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-04-11011 April 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions CNL-23-023, Annual Insurance Status Report2023-03-30030 March 2023 Annual Insurance Status Report CNL-23-024, TVA Guarantee of Payment of Deferred Premiums - 2022 Annual Report2023-03-29029 March 2023 TVA Guarantee of Payment of Deferred Premiums - 2022 Annual Report CNL-23-022, Decommissioning Funding Status Report2023-03-29029 March 2023 Decommissioning Funding Status Report CNL-23-021, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-03-0808 March 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions 2024-09-24
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Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-20-092 November 4, 2020 10 CFR 73.5 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License Nos. NPF-90 and NPF-96 NRC Docket Nos. 50-390 and 50-391
Subject:
Request for an Exemption Regarding Calendar Year 2020 Force-on-Force Exercise
References:
- 1. TVA Letter to NRC, CNL-20-069, Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-on-Force Exercises, Due to COVID-19 Pandemic, dated October 14, 2020 (ML20288A432)
- 2. NRC Letter from H. Nieh and J. Lubinski to NEI, U.S. Nuclear Regulatory Commission Planned Actions Related to the Requirements for Part 73, Appendix B,Section VI During the Coronavirus Disease 2019 Public Health Emergency, dated April 20, 2020 (ML20105A483)
- 3. NRC Letter from H. Nieh to NEI, Updated Guidance for Licensees that Request Exemptions from the Calendar Year 2020 Annual Licensee-Conducted Force On Force Requirement in Part 73, Appendix B,Section VI During the Coronavirus Disease 2019 Public Health Emergency, dated October 13, 2020 (ML20273A058)
- 4. NRC Electronic Mail to TVA, Request for Additional Information on WBN Request for Exemption from 10 CFR Part 73, Appendix B, Section VI for the Conduct of an Annual Force-on-Force Exercise (L-2020-LLE-0165),
dated November 2, 2020 (ML20308A360)
In Reference 1, Tennessee Valley Authority (TVA) submitted a request for a one-time exemption to 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) regarding conducting an annual force-on-force (FOF) exercise in calendar year (CY) 2020 due to the Coronavirus Disease 2019 (COVID-19) pandemic. This was characterized as a temporary exemption, and was consistent with the information content specified in Reference 2. In Reference 3, the Nuclear Regulatory Commission (NRC) provided additional guidance for
U.S. Nuclear Regulatory Commission CNL-20-092 Page 2 November 4, 2020 licensees requesting COVID-19-related CY 2020 FOF exercise exemption requests. In Reference 4, the NRC issued a Request for Additional Information (RAI) regarding Reference 1, and requested that TVA respond by November 5, 2020. In response, TVA is hereby withdrawing the Reference 1 one-time exemption request and submitting the enclosed updated exemption request for this FOF exemption for CY 2020, based on the guidance of Reference 3. Because this exemption request incorporates the additional information requested in the Reference 4 RAI, TVA is not providing a formal response to Reference 4. TVA requests expedited approval of this exemption request by December 31, 2020.
There are no new regulatory commitments associated with this submittal. If you should have any questions regarding this submittal, please contact Gordon Williams, Senior Manager, Fleet Licensing (Acting), at 423-751-2687.
Respectfully, James T. Polickoski Director, Nuclear Regulatory Affairs
Enclosure:
Request for an Exemption Regarding Calendar Year 2020 Force-on-Force Exercise cc: (Enclosure)
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRC Project Manager - Watts Bar Nuclear Plant Division of Radiological Health - Tennessee State Department of Environment and Conservation
Enclosure Request for an Exemption Regarding Calendar Year 2020 Force-on-Force Exercise 1.0
SUMMARY
DESCRIPTION Tennessee Valley Authority (TVA) requests an exemption from conducting the calendar year (CY) 2020 annual force-on-force (FOF) exercises as required by 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) for the Watts Bar Nuclear Plant (WBN), Units 1 and 2.
Approval of this exemption will continue to support the isolation protocols necessary to protect essential site personnel. These restrictions are needed to ensure personnel are isolated from the Coronavirus Disease 2019 (COVID-19) and remain capable of maintaining plant security.
2.0 BACKGROUND
On January 31, 2020, the U.S. Department of Health and Human Services declared a public health emergency (PHE) for the United States to aid the nations healthcare community in responding to the COVID-19. On March 12, 2020, the Governor of the State of Tennessee declared a state of emergency. In addition, on March 11, 2020, the World Health Organization characterized the COVID-19 outbreak as a pandemic and, on March 13, 2020, the President of the United States of America declared the COVID-19 pandemic a national emergency. In response to these declarations and in accordance with the corporate pandemic response plan, TVA has postponed some site activities due to isolation activities (e.g., social distancing, group size limitations, maximum telework, and self-quarantining), and also has considered the possibility of isolation of required station personnel to maintain necessary staffing levels.
3.0 EXEMPTION DETAILS In accordance with the provisions of 10 CFR 73.5, and consistent with the conditions specified in the Enforcement Guidance Memorandum 20-002 and References 1 and 2, TVA is requesting an exemption from the requirements of Appendix B to Part 73,Section VI, C.3.(l)(1) for WBN Units 1 and 2, regarding the conduct of a force-on-force (FOF) exercise during CY 2020.
As a result of the COVID-19 PHE, TVAs assessment is that WBN will not be able to comply with the requirements of the specified regulation, and will implement site-specific COVID-19 PHE training requalification controls consistent with those conditions outlined in References 1 and 2. Specifically, TVA has evaluated each WBN security position to identify appropriate COVID-19 personnel protection measures to maximize the controls necessary to minimize the potential spread of the virus. These evaluations determined that annual exercises cannot be conducted due to the limited space available in most security positions to allow for appropriate social distancing while taking into consideration maintaining safety and site security requirements, and then introducing necessary exercise control measures. This also supports the requirement of Appendix B to Part 73,Section VI, C.3.(l)(5); Tactical response drills and force-on-force exercises are conducted safely and in accordance with site safety plans. To date, five WBN Security personnel have tested positive for COVID-19, with approximately 19 others who have been quarantined for some period of time. Current data shows an increasing trend in COVID-19 positives in the county where WBN is located.
This exemption supports the isolation restrictions (e.g., social distancing, group size limitations, self-quarantining, etc.) necessary to protect required site personnel in response to the COVID-19 virus. These restrictions are needed to ensure personnel are isolated from the COVID-19 virus and remain capable of maintaining plant security. WBN implemented proactive isolation restrictions for site personnel on March 23, 2020.
CNL-20-092 E-1 of 4
Enclosure This exemption is specific to security personnel who have previously demonstrated proficiency and are currently qualified in accordance with 10 CFR Part 73, Appendix B, Section VI, Nuclear Power Reactor Training and Qualification Plan for Personnel Performing Security Program Duties. Additionally, because of the rigorous nature of WBN security personnel training programs, which consist of regularly scheduled training activities to include weapons training, contingency response drills and exercises, and demonstrated acceptable performance of day-to-day job activities (e.g., detection and assessment, patrols, searches, and defensive operations), it is reasonable to conclude that WBN security personnel will continue to maintain their proficiency, even though the requalification periodicity is exceeded for CY 2020.
WBN requests an exemption from the following specific CY 2020 FOF exercise requirements of 10 CFR 73, Appendix B, VI.C.3.(l)(1).
Each member of each shift who is assigned duties and responsibilities required to implement the safeguards contingency plan and licensee protective strategy participates in at least one (1) tactical response drill on a quarterly basis and one (1) force-on-force exercise on an annual basis.
The FOF exercise grace period expires on November 5, 2020. TVA has extended its maximum telework/reintegration Phase 1 posture until, at least January 1, 2021. Because of these company guidelines and social distancing expectations, WBN will not be able to complete the CY 2020 FOF annual exercises. These restrictions are needed to ensure WBN essential personnel are isolated from the COVID-19 disease and remain capable of maintaining plant security.
4.0 TECHNICAL JUSTIFICATION OF ACCEPTABILITY WBN will implement the following controls to ensure impacted security personnel maintain the knowledge, skills, and abilities required to effectively perform assigned duties and responsibilities.
- WBN will maintain a list of the names of the individuals who will not meet the requalification requirements and will include the dates of their last qualification.
- WBN will ensure contingency response readiness of security personnel not participating in an annual FOF exercise, by conducting the following scenario-based evolution.
o Continue to conduct quarterly tactical response drills, including tabletop exercises, to ensure the security force maintains response readiness.
Additionally, impacted security personnel continue to maintain contingency response readiness and proficiency with the knowledge, skills, and abilities required to effectively implement the protective strategy to protect the station against the design basis threat as described in 10 CFR 73.1, Purpose and Scope, because WBN continues to conduct the following training requalification requirements of Section VI of Appendix B to Part 73 that reinforce FOF exercise skills.
- Annual firearms familiarization
- Annual daylight qualification course
- Annual night fire qualification course
- Annual tactical qualification course CNL-20-092 E-2 of 4
Enclosure
- Annual physical examination
- Annual physical fitness test
- Weapons range activity (4-month periodicity)
- Annual written exam Therefore, WBN continues to maintain a physical protection program that provides high assurance that the health and safety of the public will not be inimical to the common defense and security and does not constitute an unreasonable risk to the public health and safety.
WBN is scheduled to conduct CY 2021 FOF annual exercises beginning in August of 2021, and completing no later than October 31, 2021, provided the PHE has ended. However, should unforeseen circumstances arise that would inhibit resuming these activities, TVA will provide an updated request for exemption with as much advance notice as practicable.
5.0 REGULATORY JUSTIFICATION OF ACCEPTABILITY Part 73.5 of 10 CFR, Specific exemptions, states that the NRC may grant exemptions from the requirements of the regulations of this part provided three conditions are met. They are as follows:
(1) The exemptions are authorized by law.
(2) The exemptions will not endanger life or property or the common defense and security.
(3) The exemptions are otherwise in the public interest.
TVA has evaluated the requested exemption against the criteria of 10 CFR 73.5 and determined the criteria are satisfied as described below.
- 1. This exemption is authorized by law.
The requested exemption is authorized by law in that no law precludes the activities covered by this exemption request. Granting of the request does not result in a violation of the Atomic Energy Act of 1954, as amended.
- 2. This exemption will not endanger life or property or the common defense and security.
The requested exemption will not endanger life or property or the common defense and security. The requested exemption allows the cancellation of certain security training requalification requirements during calendar year (CY) 2020. TVA had scheduled these requalification activities to comply with the regulation. However, these activities must be cancelled for CY 2020 to allow implementation of the TVA pandemic plan mitigation strategies. These strategies serve the public interest by ensuring adequate staff isolation and maintaining staff health to perform their job function actions during the COVID-19 pandemic.
The proposed exemption is related to training requalification and does not change physical security plans or the defensive strategy. Security personnel impacted by this exemption are currently satisfactorily qualified on all required tasks. In addition, security personnel are monitored regularly by supervisory personnel and have implemented controls and conducted the other training requalification requirements as identified above. Therefore, granting the requested exemption will not endanger or compromise the common defense or security, or safeguarding of WBN.
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Enclosure
- 3. This exemption is otherwise in the public interest.
The TVA pandemic response plan is based on NEI 06-03, Nuclear Sector Coordination Council, Influenza Pandemic Threat Summary and Planning, Preparation, and Response Reference Guide, which recommends isolation strategies such as sequestering, use of super crews or minimum staffing as well as social distancing, group size limitations and self-quarantining, in the event of a pandemic, to prevent the spread of the virus to the plant.
NEI 06-03 provides other mitigation strategies that serve the public interest during a pandemic by ensuring adequate staff is isolated from the pandemic and remains healthy to perform their job function.
Keeping WBN in operation during the pandemic will help to support the public need for reliable electricity supply to cope with the pandemic. 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. If the plant operation is impacted because it cannot comply with the security training requalification requirements while isolation activities are in effect for essential crew members, the area electrical grid would lose this reliable source of baseload power. In addition, WBN personnel could face the added transient challenge of shutting down their respective plant and possibly not restarting it until the pandemic passes. This does not serve the public interest in maintaining a safe and reliable supply of electricity.
TVA has determined that the exemption involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite; that there is no significant increase in individual or cumulative public or occupational radiation exposure; that there is no construction impact; and there is no significant increase in the potential for or consequences from a radiological accident. Furthermore, the requirements for which an exemption is being requested involve security training requalification requirements.
Accordingly, the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(25). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this proposed exemption request.
The period during which the exemption is necessary will be in effect until the end of CY 2020.
6.0 REFERENCES
- 1. NRC Letter from H. Nieh and J. Lubinski to NEI, U.S. Nuclear Regulatory Commission Planned Actions Related to the Requirements for Part 73, Appendix B,Section VI During the Coronavirus Disease 2019 Public Health Emergency, dated April 20, 2020 (ML20105A483)
- 2. NRC Letter from H. Nieh to NEI, Electronic Mail to TVA, Updated Guidance for Licensees that Request Exemptions from the Calendar Year 2020 Annual Licensee-Conducted Force On Force Requirement in Part 73, Appendix B,Section VI During the Coronavirus Disease 2019 Public Health Emergency, dated October 13, 2020 (ML20273A058)
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