Letter Sequence Request |
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EPID:L-2020-LLE-0062, Independent Spent Fuel Storage Installation - Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section Le and 10 CFR 73.55(r) Annual Physical Requalification Requirement (Open) CAC:001028, (Approved, Closed) |
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MONTHYEARML19276D3982019-10-0303 October 2019 Exemption Request to Load and Store Spent Fuel in HI-STORM FW Spent Fuel Casks Utilizing Amendment 1, Revision 1 to CoC No. 1032 Project stage: Other ML20115E3782019-10-0303 October 2019 Independent Spent Fuel Storage Installation Exemption Safety Evaluation Report Project stage: Approval ML20014E6772020-01-0909 January 2020 Fws List of Threatened and Endangered Species That May Occur with Respect to the McGuire Exemption Request Project stage: Other ML20015A3142020-01-14014 January 2020 Package: Exemption Request McGuire Nuclear Facility Project stage: Request ML20049A0812020-01-31031 January 2020 Holtec International - HI-STORM 100 Storage CoC Renewal Application Project stage: Request ML20049A0822020-01-31031 January 2020 Holtec International - HI-STORM 100 Storage CoC Renewal Application Project stage: Other ML20055F3372020-02-20020 February 2020 Conversation Record - Clarification Call (02/20/2020) on RAI 1 for CoC 1040 Umax Amendment 4 Project stage: RAI ML20064F6162020-02-29029 February 2020 January 15, 2020, Summary of Meeting with Holtec International, Inc., to Discuss the Upcoming Submittal of the Application for Renewal of the Storage Certificate of Compliance No. 1014 for the HI-Storm 100 Cask System Project stage: Meeting ML20063M0152020-03-0303 March 2020 HI-STORM 100 Renewal Presubmittal Meeting (Holtec Slides, 1-15-20) Project stage: Meeting ML20064E6222020-03-0303 March 2020 U.S. Nuclear Regulatory Commission Approval of NAC International Request for Withholding Information from Public Disclosure for Coc 1025 Renewal (CAC No. 001028) Project stage: Withholding Request Acceptance ML20071J0552020-03-0505 March 2020 Notice of Cancelled Meeting with the U.S. Department of Energy, Idaho Operations Office to Discuss the Upcoming Submittal of the Application for Renewal of the Idaho Spent Fuel Facility License (SNM-2512) Project stage: Meeting ML20065K2162020-03-0505 March 2020 Notice of Meeting with U.S. Department of Energy, Idaho Operations Office to Discuss the Upcoming Submittal of the Application for Renewal of the Idaho Spent Fuel Facility License (SNM-2512) Project stage: Meeting ML20071F1562020-03-0505 March 2020 Interim Storage Partners, LLC - Affidavit Project stage: Other ML20065J4272020-03-0505 March 2020 Submittal of Renewal Application for the TN-32 Dry Storage Cask - CoC 1021 Project stage: Request ML20071F1532020-03-0505 March 2020 Interim Storage Partners, LLC - Supplemental Information in Support of Nrc'S Environmental Review Project stage: Supplement ML20066K5782020-03-0606 March 2020 Acceptance Review of Request for Amendment No. 7 to Certificate of Compliance No. 1032 for the HI-STORM Flood/Wind Multipurpose Canister Storage System Project stage: Acceptance Review ML20065L3442020-03-0606 March 2020 Amendment No. 15 to Certificate of Compliance No. 1014 for the Hi-Storm 100 Multipurpose Canister Storage System - Request for Additional Information Project stage: RAI ML20065N2852020-03-0909 March 2020 ISFSI Renewed Technical Specifications Project stage: Other ML20065N2772020-03-0909 March 2020 ISFSI Renewal Cover Letter Project stage: Other ML20065N2812020-03-0909 March 2020 ISFSI Preamble-License Renewal Order Project stage: Other ML20076D6962020-03-11011 March 2020 Interim Storage Partners, LLC - Submittal of Clarifications to Support Nrc'S Continued Review of the Safety Case for the WCS CISF Project stage: Other ML20065N2782020-03-11011 March 2020 ISFSI FRN Notice of Issuance for License Renewal Project stage: Other ML20071D9942020-03-11011 March 2020 Submittal of HI-STAR 100 Updated FSAR, Revision 4 Project stage: Request ML20104C0152020-03-30030 March 2020 International - Amendment No. 4 to the HI-STORM Umax Canister Storage System Project stage: Other ML20104C0202020-03-30030 March 2020 International - HI-STORM Umax Amendment 4 Responses to Requests for Additional Information - Supplemental Information Project stage: Supplement ML20104C0192020-03-30030 March 2020 International - Affidavit for Kimberly Manzione Project stage: Other ML20104C0182020-03-30030 March 2020 International - HI-STORM Umax Amendment 4 FSAR - Changed Pages Project stage: Other ML20104C0162020-03-30030 March 2020 International - Proposed HI-STORM Umax CoC Amendment 4 Appendix a - Changed Pages Project stage: Other ML20091L0642020-03-31031 March 2020 Enclosure 1 - Request for Additional Information - Non-Proprietary Project stage: RAI ML20091L0632020-03-31031 March 2020 Transmittal Letter - CoC 1042 Amendment Number 2 Request for Additional Information Project stage: RAI ML20065N2802020-03-31031 March 2020 ISFSI License Renewal SER Project stage: Other ML20104C0482020-03-31031 March 2020 International - HI-STORM Umax Amendment 3 Responses to Requests for Additional Information Project stage: Response to RAI ML20105A1352020-03-31031 March 2020 Enclosure 1 - Affidavits Project stage: Other ML20101P3992020-03-31031 March 2020 Interim Storage Partners, LLC - Submittal of Draft Responses for Several Rals and Associated Document Markups from First Request for Additional Information, Parts 1, 2 and Clarifications Project stage: Draft Request ML20105A1732020-04-0606 April 2020 Interim Storage Partners, LLC - Affidavits Project stage: Other ML20099A1802020-04-0606 April 2020 Application for Renewal of the Certificate of Compliance No. 1014 for the Hi-Storm 100 Storage Cask System Accepted for Review (Cac/Epid Nos. 001028/L-2020-RNW-0007) Project stage: Other ML20105A1392020-04-0707 April 2020 Enclosure 8 - Referenced Documents Project stage: Other ML20105A1342020-04-0707 April 2020 Submission of ISP Responses for RAIs and Associated Document Markups from First Request for Additional Information, Parts 2, 3, and 4 Project stage: Request ML20105A1722020-04-0707 April 2020 Interim Storage Partners, LLC - Submittal of Supplemental Information in Support of RAI, Part 3 Project stage: Supplement ML20105A1382020-04-0707 April 2020 Enclosure 7 - SAR Changed Pages Project stage: Other ML20105A1372020-04-0707 April 2020 Enclosure 5 - La Changed Pages Project stage: Other ML20105A1362020-04-0707 April 2020 Enclosure 3 - RAIs and Responses Project stage: Other ML20100F2952020-04-0909 April 2020 Tn Americas LLC - Submittal of Renewal Application for the TN-68 Dry Storage Cask - CoC 1027 Project stage: Request ML20104A0402020-04-10010 April 2020 Request for Additional Information for HI-STAR 100 CoC Renewal Application Project stage: RAI ML20111A2382020-04-13013 April 2020 International - HI-STORM Umax Amendment 4 Responses to Requests for Additional Information - Supplemental Information Project stage: Supplement ML20111A2392020-04-13013 April 2020 Attachment 1: HI-STORM Umax Amendment 4 RAI Supplemental Response (non-proprietary) Project stage: Supplement ML20111A2402020-04-13013 April 2020 Attachment 2: Proposed HI-STORM Umax CoC Amendment 4 Appendix a - Changed Pages (non-proprietary) Project stage: Other ML20094G4822020-04-15015 April 2020 GEH-Morris QAP Rev 4 Approval Project stage: Other ML20092L1732020-04-17017 April 2020 Safety Evaluation Report for the Pacific Gas and Electric Company Humboldt Bay Independent Spent Fuel Storage Installation Quality Assurance Plan HBI-L6 Revision 0 Project stage: Approval ML20120A2282020-04-29029 April 2020 Tn Americas LLC, Response to the Request for Additional Information to Application for Certificate of Compliance No. 1042, Amendment No. 2, to NUHOMS Eos System, (Docket No. 72-1042, CAC No. 001028 EPID: L-2019-LLA-0078)- Request for Extens Project stage: Request 2020-03-05
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Category:Exemption from NRC Requirements
MONTHYEARML20150A3352020-06-19019 June 2020 COVID-19 Exemption for Haddam Neck CY-20-011, Independent Spent Fuel Storage Installation - Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section Le and 10 CFR 73.55(r) Annual Physical Requalification Requirement2020-05-14014 May 2020 Independent Spent Fuel Storage Installation - Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section Le and 10 CFR 73.55(r) Annual Physical Requalification Requirement ML16055A1652016-02-10010 February 2016 Enclosunotice of Issuance of Exemption (Letter to R. Mitchell Issuance of Exemption from NAC International CoC No. 1025) ML13086A0102013-07-15015 July 2013 Letter to W. Norton Request for Exemption from Title 10 of the Code of Federal Regulations 50.38 Requirements for Main Yankee Atomic Power Company, Connecticut Yankee Atomic Power Company, and Yankee Atomic Electric Company ML0521600882005-09-0909 September 2005 Partial Exemption from Requirements of 10 CFR Part 50 Appendix a Criterion I, 10 CFR Part 50 Appendix B Criterion B Section Xvii, and 10 CFR Part 50.59(d)(3), for the Haddam Neck Plant ML0521403952005-09-0909 September 2005 Letter to W. Norton Request for Exemption from Record Keeping Requirements of 10 CFR 50 Appendix a Criterion, 10 CFR 50 Appendix B Criterion Xvii, and 10 CFR 50.59(d)(3) for the Haddam Neck Plant CY-05-025, Request for Exemption from the Record Keeping Requirements of 10 CFR 50 Appendix a Criterion 1. 10 CFR 50 Appendix B Criterion Xvii and 10 CFR 50.59(d)(3)2005-02-16016 February 2005 Request for Exemption from the Record Keeping Requirements of 10 CFR 50 Appendix a Criterion 1. 10 CFR 50 Appendix B Criterion Xvii and 10 CFR 50.59(d)(3) 2020-06-19
[Table view] Category:Letter type:CY
MONTHYEARCY-23-014, Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI2023-12-0404 December 2023 Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI CY-23-006, Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report2023-03-0606 March 2023 Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report CY-23-007, Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2023-03-0606 March 2023 Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste CY-23-003, Independent Spent Fuel Storage Installation, Nuclear Liability Insurance Coverage2023-01-17017 January 2023 Independent Spent Fuel Storage Installation, Nuclear Liability Insurance Coverage CY-23-004, Independent Spent Fuel Storage Installation, Property Insurance Coverage2023-01-17017 January 2023 Independent Spent Fuel Storage Installation, Property Insurance Coverage CY-23-001, Independent Spent Fuel Storage Installation, Report of 10 CFR 50.59 Changes, Tests, and Experiments2023-01-0505 January 2023 Independent Spent Fuel Storage Installation, Report of 10 CFR 50.59 Changes, Tests, and Experiments CY-23-002, Independent Spent Fuel Storage Installation, Report of 10 CFR 72.48 Changes, Tests, and Experiments2023-01-0505 January 2023 Independent Spent Fuel Storage Installation, Report of 10 CFR 72.48 Changes, Tests, and Experiments CY-22-012, Independent Spent Fuel Storage Installation, Supplemental Information for the Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan2022-08-0303 August 2022 Independent Spent Fuel Storage Installation, Supplemental Information for the Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan CY-22-010, Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation, Formal Announcement of New ISFSI Manager2022-05-25025 May 2022 Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation, Formal Announcement of New ISFSI Manager CY-22-006, Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report, Annual Radiological Environmental Operating Report, and Changes to the Offsite Dose Calculation Manual for 20212022-04-25025 April 2022 Independent Spent Fuel Storage Installation Annual Radioactive Effluent Release Report, Annual Radiological Environmental Operating Report, and Changes to the Offsite Dose Calculation Manual for 2021 CY-22-003, and Independent Spent Fuel Storage Installation, Decommissioning Funding Assurance Status Report2022-03-14014 March 2022 and Independent Spent Fuel Storage Installation, Decommissioning Funding Assurance Status Report CY-22-004, Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2022-03-14014 March 2022 Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste CY-22-002, Independent Spent Fuel Storage Installation - Property Insurance Coverage2022-01-20020 January 2022 Independent Spent Fuel Storage Installation - Property Insurance Coverage CY-22-001, Independent Spent Fuel Storage Installation - Nuclear Liability Insurance Coverage2022-01-20020 January 2022 Independent Spent Fuel Storage Installation - Nuclear Liability Insurance Coverage CY-21-015, Independent Spent Fuel Storage Installation, Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan2021-12-10010 December 2021 Independent Spent Fuel Storage Installation, Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan CY-21-013, Biennial Update to the Haddam Neck Plant License Termination Plan2021-12-0101 December 2021 Biennial Update to the Haddam Neck Plant License Termination Plan CY-21-011, Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI2021-12-0101 December 2021 Biennial Update of the CYAPCO Quality Assurance Program for the Haddam Neck ISFSI CY-21-014, Independent Spent Fuel Storage Installation - Adoption of Amendment 8 of NAC-MPC Certificate of Compliance No. 72-1025 and Canister Registration2021-11-18018 November 2021 Independent Spent Fuel Storage Installation - Adoption of Amendment 8 of NAC-MPC Certificate of Compliance No. 72-1025 and Canister Registration CY-21-005, Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report2021-03-0202 March 2021 Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report CY-21-006, Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2021-03-0202 March 2021 Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste CY-21-004, Independent Spent Fuel Storage Installation - Property Insurance Coverage2021-01-27027 January 2021 Independent Spent Fuel Storage Installation - Property Insurance Coverage CY-21-003, Independent Spent Fuel Storage Installation Nuclear Liability Insurance Coverage2021-01-27027 January 2021 Independent Spent Fuel Storage Installation Nuclear Liability Insurance Coverage CY-20-011, Independent Spent Fuel Storage Installation - Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section Le and 10 CFR 73.55(r) Annual Physical Requalification Requirement2020-05-14014 May 2020 Independent Spent Fuel Storage Installation - Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section Le and 10 CFR 73.55(r) Annual Physical Requalification Requirement CY-20-007, Independent Spent Fuel Storage Installation - Formal Announcement of New Tsfst Manager2020-03-31031 March 2020 Independent Spent Fuel Storage Installation - Formal Announcement of New Tsfst Manager CY-20-004, Independent Spent Fuel Storage Installation - Funding Report for Managing Irradiated Fuel and GTCC Waste2020-03-17017 March 2020 Independent Spent Fuel Storage Installation - Funding Report for Managing Irradiated Fuel and GTCC Waste CY-20-003, Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report2020-03-12012 March 2020 Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report CY-20-002, Independent Spent Fuel Storage Installation, Letter Notifying NRC the Amount of Property Insurance Coverage in Force for 20202020-01-22022 January 2020 Independent Spent Fuel Storage Installation, Letter Notifying NRC the Amount of Property Insurance Coverage in Force for 2020 CY-19-014, Independent Spent Fuel Storage Installation - Formal Announcement of ISFSI Manager'S Return2019-06-0505 June 2019 Independent Spent Fuel Storage Installation - Formal Announcement of ISFSI Manager'S Return CY-19-012, Independent Spent Fuel Storage Installation - 2018 Individual Monitoring NRC Form 5 Report2019-04-23023 April 2019 Independent Spent Fuel Storage Installation - 2018 Individual Monitoring NRC Form 5 Report CY-18-021, Connecticut Yankee Atomic Power Company Haddam Neck Plant Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan2018-12-10010 December 2018 Connecticut Yankee Atomic Power Company Haddam Neck Plant Three-Year Update to the Independent Spent Fuel Storage Installation Decommissioning Funding Plan CY-18-005, Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2018-03-0505 March 2018 Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste CY-18-004, Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report2018-03-0505 March 2018 Independent Spent Fuel Storage Installation - Decommissioning Funding Assurance Status Report CY-17-021, Independent Spent Fuel Storage Installation Formal Announcement of Change in HNP ISFSI Manager2017-09-0505 September 2017 Independent Spent Fuel Storage Installation Formal Announcement of Change in HNP ISFSI Manager CY-17-010, Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2017-03-0909 March 2017 Independent Spent Fuel Storage Installation - Funding Status Report for Managing Irradiated Fuel and GTCC Waste CY-17-005, Independent Spent Fuel Storage Installation - Property Insurance Coverage2017-02-28028 February 2017 Independent Spent Fuel Storage Installation - Property Insurance Coverage CY-17-004, ISFSI - Nuclear Liability Insurance Coverage2017-02-28028 February 2017 ISFSI - Nuclear Liability Insurance Coverage CY-17-007, Independent Spent Fuel Storage Installation - Revision 6 to Haddam Neck Plant Post-Shutdown Decommissioning Activities Report2017-02-22022 February 2017 Independent Spent Fuel Storage Installation - Revision 6 to Haddam Neck Plant Post-Shutdown Decommissioning Activities Report CY-17-001, ISFSI - Notification of Changes to the Decommissioning Schedule, Per 10 CFR 50.82(a)(7)2017-01-0505 January 2017 ISFSI - Notification of Changes to the Decommissioning Schedule, Per 10 CFR 50.82(a)(7) CY-17-002, Independent Spent Fuel Storage Installation2017-01-0505 January 2017 Independent Spent Fuel Storage Installation CY-17-003, ISFSI - Report of 10 CFR 50.59 Changes, Tests, and Experiments for 01/01/1995 - 12/31/20162017-01-0505 January 2017 ISFSI - Report of 10 CFR 50.59 Changes, Tests, and Experiments for 01/01/1995 - 12/31/2016 CY-16-035, Independent Spent Fuel Storage Installation - Formal Announcement of Change in HNP ISFSI Manager2016-12-15015 December 2016 Independent Spent Fuel Storage Installation - Formal Announcement of Change in HNP ISFSI Manager CY-16-012, ISFSI - Funding Status Report for Managing Irradiated Fuel and GTCC Waste2016-03-23023 March 2016 ISFSI - Funding Status Report for Managing Irradiated Fuel and GTCC Waste CY-16-011, ISFSI - Decommissioning Funding Assurance Status Report2016-03-0909 March 2016 ISFSI - Decommissioning Funding Assurance Status Report CY-16-004, Independent Spent Fuel Storage Installation, Submittal of Property Insurance Coverage2016-02-29029 February 2016 Independent Spent Fuel Storage Installation, Submittal of Property Insurance Coverage CY-16-006, ISFSI - Annual Notification of Foreign Ownership, Control, or Influence (FOCI) Status2016-02-0202 February 2016 ISFSI - Annual Notification of Foreign Ownership, Control, or Influence (FOCI) Status CY-16-002, ISFSI - Revision 5 of the Post-Shutdown Decommissioning Activities Report2016-01-14014 January 2016 ISFSI - Revision 5 of the Post-Shutdown Decommissioning Activities Report CY-15-042, ISFSI - Three-Year Update to the Decommissioning Funding Plan2015-12-14014 December 2015 ISFSI - Three-Year Update to the Decommissioning Funding Plan CY-15-035, Redacted Haddam Neck ISFSI - Biennial Update to the Updated Final Safety Analysis Report2015-12-0101 December 2015 Redacted Haddam Neck ISFSI - Biennial Update to the Updated Final Safety Analysis Report CY-15-043, ISFSI - Revision 13 to the Emergency Plan2015-12-0101 December 2015 ISFSI - Revision 13 to the Emergency Plan CY-15-037, ISFSI - Biennial Update of the Quality Assurance Program2015-12-0101 December 2015 ISFSI - Biennial Update of the Quality Assurance Program 2023-03-06
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CONNECTICUT YANKEE ATOMIC POWER COMPANY HADDAM NECK PLANT 362 INJUN HOLLOW ROAD* EAST HAMPTON, CT 06424-3099 May 14, 2020 CY-20-011 10 CFR 73.4 and 10 CFR 73.5 A T1N: Document Control Desk Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Connecticut Yankee Atomic Power Company Haddam Neck Plant Independent Spent Fuel Storage Installation NRCLicenseNo. DPR-61 (NRCDocketNo. 50-213) 1 :z__ (:J!)Cj
Subject:
Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section LE and 10 CFR 73.55(r) Annual Physical Requalification Requirement Pursuant to 10 CFR 73.5, "Specific Exemptions," Connecticut Yankee Atomic Power Company (CYAPCO) requests a temporary exemption from 10 CFR Part 73, Appendix B, Section I.E.,
"Physical and medical requalification," and the 10 CFR 73.55(r) approved alternative measures Hsted in Section 9 .1.2.2 of the Haddam Neck Plant (HNP) Independent Spent Fuel Storage Installation (ISFSI) Physical Security Plan (PSP) regarding the annual physical requalification frequency requirement. Section 9 .1.2.2 has a grace period of three months for annual physicals.
CYAPCO has several security force members in the three-month grace period and anticipates these individuals will go beyond the three-month grace period. The first security force member entered the grace period for annual physical requirements on April 16, 2020; thus, CYAPCO will need the temporary exemption approved prior to July 15, 2020 (when the grace period expires).
If granted, the exemption will permit CYAPCO to extend the schedule define for the performance of requalification physicals in accordance with the training and qualification plan described in Section 9 .1.2.2 of the HNP ISFSI PSP.
CYAPCO is requesting that the duration of the temporary exemption be tied to the end of the pandemic associated with the COVID-19 outbreak. The end of the pandemic would be signified by suspension of the emergency declaration at the local, state and federal level. HNP will complete the physical requalification of the impacted security staff at the first reasonable opportunity, and no later than 12 months following the suspension of the emergency declaration at the local, state, and federal level.
The exemption request is provided in Enclosure 1.
~oo//l-This letter contains a regulatory commitment as described in Enclosure 2.
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Connecticut Yankee Atomic Power Company CY-20-011/May 14, 2020/Page 2 If you have any questions regarding this submittal, please do not hesitate to contact me at (860) 267-6426 ext. 320.
Respectfully,
.~~~
dimLenois ISFSI Manager
Enclosures:
- 1. Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section I.E and 10 CFR 73.55(r), Annual Physical Requalification Requirement
- 2. Haddam Neck Plant ISFSI Regulatory Commitment cc: D. Lew, NRC Region I Administrator A. Dimitriadis, Chief, Decommissioning Branch, NRC, Region 1 J. McKirgan, Chief, Division of Fuel Management, Storage and Transportation Licensing Branch J. Semancik, Director, CT DEEP, Radiation Division
Enclosure 1 CY-20-011 Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section I.E and 10 CFR 73.55(r)
Annual Physical Requalitication Requirement
Enclosure 1 CY 011
- 1. PROPOSED EXEMPTION Pursuant to 10 CFR 73.5, "Specific Exemptions," Connecticut Yankee Atomic Power Company (CYAPCO) requests a temporary exemption from 10 CFR Part 73, Appendix B, Section I.E.,
"Physical and medical requalification," and the 10 CFR 73. 55(r) approved alternative measures listed in Section 9.1.2.2 of the Haddam Neck Plant (HNP) Independent Spent Fuel Storage Installation (ISFSI) Physical Security Plan (PSP) regarding the annual physical requalification frequency requirement. Section 9.1.2.2 has a grace period of three months for annual physicals.
CYAPCO has several security force members in the three-month grace period and anticipates these individuals will go beyond the three-month grace period. The first security force member entered the grace period for annual physical requirements on April 16, 2020 and CYAPCO will need the temporary exemption approved prior to July 15, 2020 when the grace period expires.
CYAPCO maintains a Suitability, Training and Qualification (ST&Q) Plan for the security organization to implement the requirements of 10 CFR Part 73, Appendix B, as applicable and with an approved alternative measure established in accordance with 10 CFR 73.55(r). As a result of the current limitations surrounding the pandemic associated with the Coronavirus Disease 2019 (COVID-19), there is limited access to public facilities, state and federal shelter-in-place orders have been issued, and additional risks associated with social interactions, that challenge CYAPCO' s ability to comply with all requirements included in the ST &Q Plan.
Due to the impacts of the COVID-19 outbreak, requiring HNP ISFSI personnel to enter a medical facility imposes undue pandemic-related health risks for the employee, employee's family, medical staff and coworkers. In order to meet the requalification requirements of the HNP ISFSI ST&Q Plan, face-to-face appointments are necessary. Based on the information above, CYAPCO is requesting a temporary exemption from the requirements of 10 CFR 73, Appendix B, Section I.E., and the 10 CFR Part 73.55(r) approved alternative measure regarding the 12-month physical requalification requirement and three-month grace period in Section 9.1.2.2 of the HNP ISFSI PSP.
CYAPCO is requesting that the duration of the temporary exemption be tied to the end of the pandemic associated with the COVID-19 outbreak. The end of the pandemic would be signified by suspension of the emergency declaration at the local, state and federal level.
Page 1 of 6
Enclosure 1 CY 011 Based on the information above, CYAPCO is requesting the following temporary exemption:
Temporary Exemption Duration 10 CFR Part 73, A:m2endix B,Section I.E. and HNP will complete the physical a1;mroved 10 CFR 73.55(r) Alternative requalification of the impacted security staff Measure as* described in Section 9.1.2.2 of the at the first reasonable opportunity, and no HNP ISFSI PSP. later than 12 months 1 following the suspension of the emergency declaration at the local, state, and federal level.
- 2. 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 nation's healthcare community in responding to the COVID-19. On March 10, 2020, the Governor of the State of Connecticut issued a declaration of public health and civil preparedness emergencies (Executive Order 7),
proclaiming a state of emergency throughout the State of Connecticut as a result of the COVID-19 outbreak in the United States and confirmed spread in the State of Connecticut. On March 11, 2020, the COVID-19 outbreak was characterized as a pandemic by the World Health Organization. Subsequently, on March 13, 2020, the President of the United States of America declared the COVID-19 pandemic a national emergency.
On March 19, 2020, the Department of Homeland Security (DHS) issued Version 1.0 of "Guidance on the Essential Critical Infrastructure Workforce: Ensuring Community and National Resilience in COVID-19 Response." In the guidance, DHS provided a list of sectors and identified essential critical infrastructure workers. The section entitled "Hazardous Materials" included "workers at nuclear facilities." Thus, an ISFSI that stores irradiated nuclear fuel and Greater-than-Class-C (GTCC) waste and its workers are considered essential critical infrastructure and workforce.
As a result of the current limitations surrounding the pandemic associated with the COVID-19 outbreak, there is limited access to public facilities, state and federal shelter in place orders, and additional risks associated with social interactions, that challenge CYAPCO's ability to comply with all requirements included in the HNP ISFSI ST&Q Plan.
Therefore, CYAPCO is requesting a temporary exemption as described in Section 1, for the security organization at the HNP ISFSI, located in Haddam Neck, Connecticut.
1 The extended duration of this temporary exemption is based on a potential inundation on medical facilities following suspension of the emergency declaration in the local area.
Enclosure 1 CY 011
- 3. BASIS FOR EXEMPTION The specific conditions for granting an exemption from regulations in 10 CFR Part 73, are set forth in 10 CFR 73.5, "Specific Exemptions." In accordance with 10 CFR 73.5, the Commission may, upon application of any interested person or upon its own initiative, grant such exemptions from the requirements of the regulations in this part as it determines are authorized by law and will not endanger life or property or the common defense and security,*and are otherwise in the public interest. As discussed below, this temporary exemption.request satisfies the provisions of 10 CFR 73.5.
3.1 The Temporary Exemption Request is Authorized by Law The NRC's authority to grant an exemption from its regulations in 10 CFR Part 73 is
- established by law as discussed in 10 CFR 73.5. Therefore, granting an exemption is explicitly authorized by the NRC's regulations.
3.2 The Temporary Exemption Request Will Not Endanger Life or Property or the Common Defense and Security The temporary exemption to allow an extension of the requalification frequency for medical physicals for security personnel will not endanger life or property or the common defense and security. Individuals within the security organization that require a requalifying physical have undergone the initial physical examination in accordance with the HNP ISFSI ST &Q Plan and requalifying physicals, as applicable, in accordance with Section 9.1.2.2 of the HNP ISFSI PSP. The individuals that this exemption applies to have previously proven their physical ability prior to initial assignment and during any subsequent requalification training. As a compensatory measure, CYAPCO will require each individual, as applicable, within the security organization to be examined by a licensed medical physician through an internet based visual examination (e.g., telemedicine application) prior to the current expiration of their requalifying physical qualification within the grace period allowed in Section 9.1.2.2 of the HNP ISFSI PSP. In addition, in accordance with current procedures, CYAPCO will continue to ensure that any individual within the security organization who self-declares their inability to perform their current assigned tasks, will be removed from duty. This temporary exemption will contribute to the common goal of protecting the HNP ISFSI facility, by preserving the health and safety of the current qualified security force. Therefore, this temporary exemption request will not endanger life or property or the common defense and security.
Page 3 of 6
Enclosure 1 CY 011 3.3 The Temporary Exemption Request is in the Public Interest A temporary exemption to allow an extension of the requalification frequency for medical physicals is in the interest of the public. As described above, the Governor of Connecticut has issued shelter in place orders to protect public health and safety. In
- addition, the CDC recommends avoiding close contact (within about 6 feet) by putting distance between individuals. These orders and recommendations have a common goal of limiting social contact in order to disrupt the spread of the virus.
Requiring HNP ISFSI security personnel to enter any type of public facility or engage in close social interactions under the current conditions, imposes additional health risks for employees, employee's family, public facility staff and coworkers, due to the COVID-19 outbreak. In addition, the Center for Disease Control, states that the best way to prevent illness is to avoid being exposed to the virus. While precautions can be taken, each additional interaction among individuals increases the risk of spreading COVID-19. Therefore, this temporary exemption request is in the interest of the public.
- 4. ENVIRONMENTAL ASSESSMENT Pursuant to 10 CFR 51.22(c)(25), an exemption from NRC regulations is subject to a categorical exclusion from the preparation of an environmental assessment or an environmental impact statement if: (i) there is no significant hazards consideration; (ii) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite; (iii) there is no significant increase in individual or cumulative public or occupational radiation exposure; (iv) there is no significant construction impact; (v) there is no significant increase in the potential for or consequences from radiological accidents; and (vi) the requirements from which an exemption is sought involve: .... (E) Education, training, experience, qualification, requalification or other employment suitability requirements.
As demonstrated below, each of these provisions in 10 CFR 51.22(c)(25) is satisfied by this exemption request. Therefore, pursuant to 10 CFR 5 l .22(b ), no environmental impact statement or environmental assessment need be prepared in connection with the proposed exemptions.
4.1 These temporary exemptions do not involve a significant hazards consideration.
As provided in 10 CFR 50.92, an action involves a significant hazards consideration if it would: (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) Involve a significant reduction in a margin of safety. As demonstrated below, none of these criteria apply to these exemptions. ,
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Enclosure 1 CY 011 The proposed temporary exemption would extend the frequency for the physical requalification for the applicable individuals within the security organization at the HNP ISFSI. The temporary exemption does not involve any physical change in the facility or in the procedures governing operation of the facility, and, does not alter the design basis.
Therefore, the exemption does not involve an increase in the probability or consequences of an accident, create the possibility ofa new or different kind of accident, or a reduction in a margin of s_afety.
4.2 This exemption does not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite.
This temporary exemption does not involve any physical change in the facility or in the procedures governing operation of the facility. Therefore, this temporary exemption does not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite.
4.3 This exemption does not involve a significant increase in individual or cumulative public or occupational radiation exposure.
This temporary exemption does not involve any physical change in the facility or in the procedures governing operation of the facility. Therefore, this temporary exemption does not involve a significant increase in individual or cumulative public or occupational radiation exposure.
4.4 This exemption does not involve a significant construction impact.
This temporary exemption does not involve any physical change in the facility or the manner in which the facility will be constructed. Therefore, this temporary exemption does not involve a significant construction impact.
4.5 This exemption does not involve a significant increase in the potential for or consequences from radiological accidents.
This temporary exemption does not involve any physical change in the facility or in the procedures governing operation of the facility. Therefore, this temporary exemption does not involve a significant increase in the potential for or consequences from radiological accidents.
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Enclosure 1 CY 011 4.6 The requirements from which this exemption is sought involve education, training, experience, qualification, requalification or other employment suitability requirements.
This temporary exemption pertains to extending the frequency of requalification associated with physical requalification required by a 10 CFR 73.55(r) alternative measure in Section 9.1.2.2 of the HNP ISFSI PSP. Therefore, the request involves the activities described in 10 CFR 51.22(c)(25)(vi)(E). *
- 5. CONCLUSION Pursuant to the provisions of 10 CFR 73.5, HNP is requesting a temporary exemption from 10 CFR Part 73, Appendix B, Section I.E. and the 10 CFR 73.55(r) associated approved alternative measure in Section 9.1.2.2 of the HNP ISFSI PSP. Based on the considerations discussed above, the requested temporary exemption is authorized by law and will not endanger life or property or the common defense and security, and, are otherwise in the public interest.
- 6. REFERENCES 6.1 Office of the Governor, State of Connecticut, Ned Lemont, "Executive Order No. 7 Protection of Public Health and Safety during COVID-19 Pandemic and Response," March 10, 2020. https://portal.ct.gov/Office-of-the-Governor/Governors-Actions/Executive-Orders?Page=3#pos=6475.2001953125, date accessed May 1, 2020.
6.2 Centers for Disease Control, Coronavirus Disease 2019 (COVID-19), Protect Yourself, page last reviewed April 4, 2020, https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/prevention.html, date accessed May 1, 2020.
6.3 Proclamations, "Proclamation on Declaring a National Emergency Concerning the Novel Coronavirus Disease (COVID-19) Outbreak, issued on March 13,. 2020 https ://www.whitehouse.gov/presidential-actions/proclamation-declaring-national-emergency-concerning-novel-coronavirus-disease-covid-19-outbreak/, date accessed April 6, 2020.
6.4 World Health Organization, "WHO Director-General's opening remarks at the media briefing on COVID-19-11 March 2020," dated March 11, 2020 https://www.who.int/dg/speeches/detail/who-director-general-s-opening-remarks-at-the-media-briefing-on-covid-19---11-march-2020, date accessed April 6, 2020.
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Enclosure 2 CY-20-011 Haddam Neck Plant iSFSI Regulatory Commitment
Enclosure 2 CY-20-011 Commitment Due Date CYAPCO will require each individual, as applicable, within the Prior to the applicable security organization to be examined by a licensed medical individual's current physician through an internet based visual examination (e.g., expiration of their telemedicine application) prior to the current expiration of their requalifying physical requalifying physical qualification within the grace period qualification within the allowed in Section 9.1.2.2 of the HNP ISFSI PSP. grace period allowed in Section 9.1.2.2 of the HNP ISFSI PSP.
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