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MONTHYEARML20216A2602020-08-27027 August 2020 Exemption Request from Certain Requirements of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel (COVID-19) Project stage: Other 2020-08-27
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Category:Exemption from NRC Requirements
MONTHYEARML23354A2812024-01-0404 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0031 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML23328A0092023-11-22022 November 2023 Supplement - Dresden Security Rule Exemption Request ISFSI Docket No. Reference (EPID L-2023-LLE-0031) (Email) RS-23-102, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-10-16016 October 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML21305A0192022-03-16016 March 2022 Exemption from the Requirements of 10 CFR Part 2, Section 2.109(b) Related to Submission of Subsequent License Renewal Application (EPID L-2021-LLE-0048) (FRN) ML21305A0162022-03-15015 March 2022 Exemption from the Requirements of 10 CFR Part 2, Section 2.109(b) Related to Submission of Subsequent License Renewal Application (EPID L-2021-LLE-0048) (Letter) ML21305A0182022-03-15015 March 2022 Exemption from the Requirements of 10 CFR Part 2, Section 2.109(b) Related to Submission of Subsequent License Renewal Application (EPID L-2021-LLE-0048) (Exemption) RS-21-114, Request for Exemption from 10 CFR 2.109(b)2021-10-28028 October 2021 Request for Exemption from 10 CFR 2.109(b) ML21204A1242021-08-23023 August 2021 Exemption Related to the Approval Authority for Suspension of Security Measures in an Emergency or During Severe Weather ML21103A0082021-04-12012 April 2021 Acceptance Review (Exemption Request): Dresden Nuclear Power Station, Units 1, 2, and 3-Request for Exemption from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E ML21076A4392021-03-17017 March 2021 Attachment 1 - Requests for Exemptions from Portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and 10 CFR 50, Appendix E ML21076A4382021-03-17017 March 2021 Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E ML20322A3032020-12-14014 December 2020 Exemption from Annual Force-On-Force Exercise Requirements of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel, Subsection VI.C.3(I)(1) (EPID L-2020-LLE-0203 (COVID-19)) NMP1L3362, Request for an Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding 2020 Annual Force-on-Force (FOF) Exercises Due to COVID- 19 Public Health Emergency2020-11-13013 November 2020 Request for an Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding 2020 Annual Force-on-Force (FOF) Exercises Due to COVID- 19 Public Health Emergency ML20271A0002020-10-13013 October 2020 FRN - Notice of Issuance of Multiple Exemptions Regarding Various Parts of 10 CFR Due to COVID-19 Impacts for September 2020 ML20248H5652020-10-0505 October 2020 Letter, Exemption from the Requirements of Title 10 of the Code of Federal Regulations Part 50, Appendix J ML20248H5662020-10-0505 October 2020 Exemption from the Requirements of Title 10 of the Code of Federal Regulations Part 50, Appendix J RS-20-124, Request for Exemption from Certain Record Retention Requirements2020-09-30030 September 2020 Request for Exemption from Certain Record Retention Requirements RS-20-113, Request for Exemption from Specific Provisions in 10 CFR 73.55(p)(1)(i) and (p)(1)(ii) Related to the Suspension of Security Measures in an Emergency or During Severe Weather2020-09-28028 September 2020 Request for Exemption from Specific Provisions in 10 CFR 73.55(p)(1)(i) and (p)(1)(ii) Related to the Suspension of Security Measures in an Emergency or During Severe Weather ML20259A4922020-09-28028 September 2020 Exemption from Select Requirements of 10 CFR Part 26 (EPID L-2020-LLE-0143 (COVID-19)) ML20243A0002020-09-23023 September 2020 FRN - Notice of Issuance of Multiple Exemptions Regarding Various Parts of 10 CFR Due to COVID-19 Impacts for August 2020 ML20259A1162020-09-14014 September 2020 Incoming Request-Dresden-Exelon Generation Co., LLC ML20216A2602020-08-27027 August 2020 Exemption Request from Certain Requirements of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel (COVID-19) ML0614302462006-06-27027 June 2006 TMI and Zion - Exemption from the Requirements of 10 CFR 50.54(a)(3) Re Submittal of Changes to Quality Assurance Topical Report ML0233805992002-11-25025 November 2002 Exemption Request from the Requirements of 10 CFR 50.36(c)(1) ML0223502112002-10-0202 October 2002 Exemption from the Requirements of 10 CFR 50.719(e)(4) ML0218603302002-07-12012 July 2002 Exemption, Reschedule Requalification Examination 2024-01-04
[Table view] Category:Letter
MONTHYEARIR 05000237/20230042024-02-0202 February 2024 Integrated Inspection Report 05000237/2023004 and 05000249/2023004 IR 05000010/20230012024-01-17017 January 2024 NRC Inspection Report 05000010/2023001 (Drss) ML23354A2812024-01-0404 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0031 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML23305A1402023-12-13013 December 2023 Units 1 & 2; Nine Mile Point, Unit 2; Peach Bottom, Units 2 & 3; and Quad Cities, Units 1 and 2 - Issuance of Amendments to Adopt Traveler TSTF-580 RS-23-121, Sixth Ten-Year Interval Inservice Testing Program2023-11-30030 November 2023 Sixth Ten-Year Interval Inservice Testing Program SVPLTR 23-0037, Core Operating Limits Report for Cycle 292023-11-29029 November 2023 Core Operating Limits Report for Cycle 29 RS-23-119, Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information2023-11-10010 November 2023 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums RS-23-107, Relief Request I5R-22, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fifth Inservice Inspection Interval2023-11-0808 November 2023 Relief Request I5R-22, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fifth Inservice Inspection Interval RS-23-102, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-10-16016 October 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23285A2342023-10-13013 October 2023 Confirmation of Initial License Examination RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans ML23279A0712023-10-0606 October 2023 Response to NRC Dresden Nuclear Power Station, Units 2 and 3 - Comprehensive Engineering Team Inspection Report 05000237/2023011 and 05000249/2023011 ML23269A0662023-09-28028 September 2023 Proposed Alternative Request RV-23H Associated with the Sixth 10-Year Inservice Testing Interval ML23265A1322023-09-27027 September 2023 Proposed Alternative Request RV-03 Associated with the Sixth 10-Year Inservice Testing Interval ML23205A1362023-09-20020 September 2023 Proposed Alternative Request RV-02D Associated with the Sixth IST Interval IR 05000237/20230112023-09-0606 September 2023 Comprehensive Engineering Team Inspection Report 05000237/2023011 and 05000249/2023011 RS-23-071, Application to Adopt TSTF-564, Safety Limit MCPR2023-08-30030 August 2023 Application to Adopt TSTF-564, Safety Limit MCPR RS-23-080, Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2023-08-30030 August 2023 Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs IR 05000237/20234022023-08-29029 August 2023 Security Baseline Inspection Report 05000237/2023402 and 05000249/2023402 IR 05000237/20230022023-08-0808 August 2023 Integrated Inspection Report 05000237/2023002 and 05000249/2023002 ML23212A9892023-08-0303 August 2023 Subsequent License Renewal Application Public Meeting Summary of Pre-Submittal Meeting ML23174A1502023-08-0303 August 2023 Issuance of Amendment Nos. 282 and 275 Control Rod Scram Times ML23193A0052023-07-28028 July 2023 Subsequent License Renewal Application Public Meeting Summary of Pre-Submittal Meeting ML23192A6292023-07-11011 July 2023 Correction Letter - Issuance of Amendment Nos. 281 and 274 Regarding Transition to GNF3 Fuel (EPID L-2022-LLA-0121) (Non-Proprietary) ML23144A3142023-07-0606 July 2023 Issuance of Amendment Nos. 281 and 274 Transition to GNF3 Fuel (EPID L-2022-LLA-0121) - Nonproprietary ML23187A0462023-07-0606 July 2023 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000237/2023004 ML23178A2422023-06-28028 June 2023 Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch III SVPLTR 23-0021, Registration of Use of Casks to Store Spent Fuel2023-06-20020 June 2023 Registration of Use of Casks to Store Spent Fuel RS-23-078, Supplement to License Amendment Request to Revise Technical Specification 3.1.4, Control Rod Scram Times2023-06-16016 June 2023 Supplement to License Amendment Request to Revise Technical Specification 3.1.4, Control Rod Scram Times RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations IR 05000237/20233012023-05-30030 May 2023 NRC Initial License Examination Report 05000237/2023301; 05000249/2023301 RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling ML23132A0932023-05-17017 May 2023 Information Meeting (Public Open House) with a Question and Answer Session to Discuss NRC 2022 End-Of-Cycle Plant Performance Assessment of Dresden Power Station, Units 2 and 3 RS-23-070, Supplement to License Amendment Request Regarding Transition to GNF3 Fuel2023-05-16016 May 2023 Supplement to License Amendment Request Regarding Transition to GNF3 Fuel SVPLTR 23-0018, Submittal of 2022 Annual Radiological Environmental Operating Report2023-05-15015 May 2023 Submittal of 2022 Annual Radiological Environmental Operating Report IR 05000237/20230012023-05-0404 May 2023 Integrated Inspection Report 05000237/2023001 and 05000249/2023001 SVPLTR 23-0019, ILT 22-1 (2023-301) Svpltr 23-0019 Post-Exam Submittal Letter (1)2023-05-0101 May 2023 ILT 22-1 (2023-301) Svpltr 23-0019 Post-Exam Submittal Letter (1) ML23118A3472023-05-0101 May 2023 County, 1 & 2; Nine Mile Point, 2; and Quad Cities, 1 & 2 - Correction of Amendment No. 193 Adoption of TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration EPID L-2022-LLA-0143 ML23114A2522023-04-28028 April 2023 Request to Use a Provision of a Later Edition of the ASME Boiler & Pressure Vessel Code, Section XI IR 05000237/20234012023-04-26026 April 2023 Cyber Security Inspection Report 05000237/2023401 and 05000249/2023401 ML23081A0382023-04-25025 April 2023 County, 1 & 2; Nine Mile Point, 2; and Quad Cities, 1 & 2 - Issuance of Amendments to Adopt TSTF-306, Rev. 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration IR 05000237/20235012023-04-21021 April 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000237/2023501 and 05000249/2023501 ML23110A3202023-04-21021 April 2023 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection RS-23-057, Supplement to License Amendment Request Regarding Transition to GNF3 Fuel2023-04-17017 April 2023 Supplement to License Amendment Request Regarding Transition to GNF3 Fuel SVPLTR 23-0014, Annual Dose Report for 20222023-04-15015 April 2023 Annual Dose Report for 2022 ML23088A2242023-04-0505 April 2023 Regulatory Audit Report Regarding License Amendment Request to Transition to GNF3 Fuel ML23087A0482023-03-28028 March 2023 Operator Licensing Examination Approval - Dresden Nuclear Power Station, April 2023 2024-02-02
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August 27, 2020 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)
Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - EXEMPTION REQUEST FROM CERTAIN REQUIREMENTS OF TITLE 10 OF THE CODE OF FEDERAL REGULATIONS, PART 73, APPENDIX B, GENERAL CRITERIA FOR SECURITY PERSONNEL, SECTION VI (EPID L-2020-LLE-0123
[COVID-19])
Dear Mr. Hanson:
The U.S. Nuclear Regulatory Commission (NRC or the Commission) has approved the temporary exemption from specific requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 73, Appendix B,Section VI, Nuclear Power Reactor Training and Qualification Plan for Personnel Performing Security Program Duties, for the Dresden Nuclear Power Station, Units 2 and 3 (Dresden). This action is in response to the Exelon Generation Company, LLCs (Exelon or the licensee) application dated July 28, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20210M410 (non-public, withheld under 10 CFR 2.390)), that requested a temporary exemption from 10 CFR Part 73, Appendix B, Section VI, subsection C.3.(l)(1), regarding the annual force-on-force (FOF) exercise at Dresden.
The requirements in 10 CFR Part 73, Appendix B, Section VI, subsection C.3.(l)(1), state, in part:
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) force-on-force exercise on an annual basis.
Force-on-force exercises conducted to satisfy the NRC triennial evaluation requirement can be used to satisfy the annual force-on-force requirement for the personnel that participate in the capacity of the security response organization.
The purpose of the annual licensee-conducted FOF exercise is to ensure that the site security force maintains its contingency response readiness. Participation in these exercises also supports the requalification of security force members.
On January 31, 2020, the U.S. Department of Health and Human Services declared a Coronavirus Disease 2019 (COVID-19) public health emergency (PHE) for the United States.
B. Hanson Subsequently, the Centers for Disease Control and Prevention issued recommendations (e.g., social distancing, limiting assemblies) to limit the spread of COVID-19.
Exelons application dated July 28, 2020, stated the following:
On March 9, 2020, the Governor of the State of Illinois issued a disaster proclamation in response to the spread of COVID-19 and imposed isolation and other restrictions throughout the State. Since that time, Exelon has implemented isolation restrictions and other precautions for the protection of Dresden site personnel.
This temporary exemption supports the isolation restrictions (e.g., social distancing, group size limitations, self-quarantining, use of personal protective equipment, 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 Exelon will maintain a list of the names of individuals who will not meet the requalification requirements and will include the dates of the last qualification.
Exelon will ensure contingency response readiness of security personnel not participating in an annual FOF exercise by conducting scenario-based evolutions that include a lessons-learned review of past exercises.
Exelon will schedule and complete any missed FOF exercise within the time period in this request (i.e., 90 days after the PHE is ended or December 31, 2020, whichever occurs first) when isolation restrictions are ended.
Exelon will begin implementing COVID-19 PHE controls for managing personnel performing Security Program duties upon NRC approval of its July 28, 2020, exemption request.
This temporary exemption is specific to Dresden security personnel who have previously demonstrated proficiency and are currently qualified in accordance with the requirements in 10 CFR Part 73, Appendix B, Section VI. Exelon stated that because of the rigorous nature of the Dresden nuclear 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 security personnel will continue to maintain their proficiency even though the requalification periodicity is temporarily exceeded. Additionally, Exelon identified site-specific COVID-19 PHE controls listed above that will be implemented at Dresden, consistent with those outlined in the NRC staffs April 20, 2020, letter discussing planned activities related to the requirements for 10 CFR Part 73, Appendix B, Section VI, during the PHE (ADAMS Accession No. ML20105A483). Exelon requested that the duration of the exemption be for 90 days after the PHE is ended, or until December 31, 2020, whichever occurs first, consistent with the NRC staffs letter dated April 20, 2020.
Pursuant to 10 CFR 73.5, Specific exemptions, the Commission may, upon application of any interested person or upon its own initiative, grant exemptions from the requirements of 10 CFR
B. Hanson Part 73 that are authorized by law and will not endanger life or property or the common defense and security, and are otherwise in the public interest.
In accordance with 10 CFR 73.5, the Commission may grant an exemption from the regulations in 10 CFR Part 73 that is authorized by law. The NRC staff has reviewed the exemption request and finds that granting the proposed exemption will not result in a violation of the Atomic Energy Act of 1954, as amended, or other laws. Therefore, the NRC staff finds that the exemption is authorized by law.
In accordance with 10 CFR 73.5, the Commission may grant an exemption from the regulations in 10 CFR Part 73 when the exemption will not endanger life or property or the common defense and security. This exemption will only apply to Dresden security personnel who are already satisfactorily qualified on the security requirements in 10 CFR Part 73, Appendix B, Section VI.
Based on the limited scope of this exemption and the controls Exelon will implement for the duration of the exemption, including conducting a lessons-learned review of past exercises, continuing to conduct required quarterly tactical response drills, and completing any missed annual FOF exercises within the time period for this exemption, the NRC staff has reasonable assurance that the security force at Dresden will maintain its proficiency and readiness to implement the licensees protective strategy and adequately protect the site. Therefore, the NRC staff concludes that the proposed exemption would not endanger life or property or the common defense and security.
In accordance with 10 CFR 73.5, the Commission may grant an exemption from the regulations in 10 CFR Part 73 when the exemption is in the public interest. Participation in FOF exercises requires significant staff support and places site security personnel in close proximity to one another. Such proximity has the potential to increase the likelihood of security personnel being exposed to the COVID-19 virus. The NRC staff finds that the temporary exemption from the annual FOF requirement in 10 CFR Part 73, Appendix B, Section VI, subsection C.3.(l)(1),
would facilitate the licensees efforts to maintain a healthy workforce capable of operating the plant safely and implementing the sites protective strategy by isolating security personnel from potential exposure to the COVID-19 virus. The NRC staff concludes that granting the temporary exemption is in the public interest because it allows the licensee to maintain the required security posture at Dresden, while enabling the facility to continue to provide electrical power to the Nation.
Environmental Considerations NRC approval of this exemption request is categorically excluded under 10 CFR 51.22(c)(25),
and there are no special circumstances present that would preclude reliance on this exclusion.
The NRC staff determined, per 10 CFR 51.22(c)(25)(vi)(E), that the requirements from which the exemption is sought involve education, training, experience, qualification, requalification, or other employment suitability requirements. The NRC staff also determined that approval of this exemption request involves no significant hazards consideration because it does not authorize any physical changes to the facility or any of its safety systems, nor does it change any of the assumptions or limits used in the facility licensees safety analyses or introduce any new failure modes. There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite because this exemption does not affect any effluent release limits as provided in the facility licensees technical specifications or by the regulations in 10 CFR Part 20, Standards for Protection Against Radiation. There is no significant increase in individual or cumulative public or occupational radiation exposure because this exemption does not affect limits on the release of any radioactive material or the limits provided
B. Hanson in 10 CFR Part 20 for radiation exposure to workers or members of the public. There is no significant construction impact because this exemption does not involve any changes to a construction permit and no significant increase in the potential for or consequences from radiological accidents because this exemption does not alter any of the assumptions or limits in the facility licensees safety analysis. In addition, the NRC staff determined that there would be no significant impacts to biota, water resources, historic properties, cultural resources, or socioeconomic conditions in the region. Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the approval of this exemption request.
Conclusions Accordingly, the NRC has determined that pursuant to 10 CFR 73.5, this exemption is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest. Therefore, the Commission hereby grants the licensees request to temporarily exempt Dresden from the annual FOF exercise requalification requirement of security personnel in subsection C.3.(l)(1) of 10 CFR Part 73, Appendix B, Section VI. This exemption expires 90 days after the end of the PHE, or December 31, 2020, whichever occurs first.
If you have any questions, please contact the Dresden project manager, Russell Haskell, at 301-415-1129 or e-mail at Russell.Haskell@nrc.gov.
Sincerely, Digitally signed by Craig Craig G. G. Erlanger Date: 2020.08.27 Erlanger 14:48:17 -04'00' Craig G. Erlanger, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237 and 50-249 cc: Listserv
ML20216A260 *email concurrence OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA* NSIR/DPCP/RSB/BC*
NAME RHaskell (BPurnell for) SRohrer (JBurkhardt for) ABowers DATE 8/27/2020 8/4/2020 8/14/2020 OFFICE OGC - NLO* NRR/DORL/LPL3/BC* NRR/DORL/D*
NAME JMaltese NSalgado CErlanger DATE 8/20/2020 8/26/2020 8/27/2020