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MONTHYEARML20112F5232020-04-20020 April 2020 Maryland Department of the Environment Draft EA Review Response for the Exemption Request for the Calvert Cliffs Nuclear Power Plant Project stage: Draft Request ML20264E6892020-10-0909 October 2020 Exemption from Certain Requirements of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel (EPID L-2020-LLE-0141 (COVID-19)) Project stage: Approval 2020-10-09
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Category:Exemption from NRC Requirements
MONTHYEARML24003A8872024-01-19019 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0033 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) RS-23-125, Request for Exemption from 10 CFR 2.109(b)2023-12-0707 December 2023 Request for Exemption from 10 CFR 2.109(b) ML23289A1202023-10-16016 October 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML22060A2622022-03-0808 March 2022 FRN - Notice of Issuance of COVID-19 Exemptions Issued in February 2022 ML22034A8122022-02-0404 February 2022 Exemption from Specific Requirements of 10 CFR Part 26 (EPID L-2022-LLE-0006 (COVID-19)) ML21029A3362021-02-18018 February 2021 Exemption from Select Requirements of 10 CFR Part 26 (EPID L-2021-LLE-0005 (COVID-19)) ML20321A2432020-12-11011 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-0194 (COVID-19)) ML20304A2862020-11-20020 November 2020 Federal Register Notice for COVID-19 October 2020 Group Exemptions 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 ML20264E6892020-10-0909 October 2020 Exemption from Certain Requirements of 10 CFR Part 73, Appendix B, General Criteria for Security Personnel (EPID L-2020-LLE-0141 (COVID-19)) ML16075A4082016-08-22022 August 2016 Exemption Related to the Updated Final Safety Analysis Report 10 CFR 50.71(e)(4) Update Schedule NRC-2016-0181, Exemption Related to the Updated Final Safety Analysis Report 10 CFR 50.71(e)(4) Update Schedule (CAC Nos. MF7340 and MF7341)2016-08-22022 August 2016 Exemption Related to the Updated Final Safety Analysis Report 10 CFR 50.71(e)(4) Update Schedule (CAC Nos. MF7340 and MF7341) ML16075A4062016-08-18018 August 2016 Plants, Units 1 and 2 - Exemption Related to the Updated Final Safety Analysis Report 10 CFR 50.71(e)(4) Update Schedule ML15054A3342015-03-0404 March 2015 Relaxation of the Scheduler Requirements for Order EA-12-049 Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design Basis External Events. ML12198A1232012-07-31031 July 2012 Exemption from Certain Requirements of 10 CFR Part 26, Fitness for Duty Programs ML11203A5132011-07-21021 July 2011 Request for Exemption from Certain Requirements of the Fitness for Duty Rule, Subpart I ML1101906322011-01-19019 January 2011 Correction Letter Regarding Exemption for Use of M5 Cladding-Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (TAC Nos. ME5154 and ME5155) ML0732006942007-12-17017 December 2007 Exemption from the Requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix K ML0622601232006-11-0909 November 2006 Exemption from the Requirements of 10 CFR 50.46 and 10 CFR Part 50, Appendix ML0521405582005-09-0202 September 2005 Exemption from the Requirements of CFR Part 50, Section 50.68 ML0436405412004-12-21021 December 2004 Exemption Requested from the Requirements of 10 CFR Part 50, Paragraph 50.68(b)(1) ML0333200052003-12-22022 December 2003 Exemption, Temporary Exemption from the Requirements of 10 CFR 50, Appendix E, Section IV.F.2.c ML0333606342003-11-24024 November 2003 Schedule Exemption from 10 CFR Part 50, Appendix E, Section IV.F.2.c - Rescheduling of Biennial Full-Participation Emergency Preparedness Exercise ML0306401372003-04-11011 April 2003 Exemption from Requirements of 10 CFR 50.46, 10 CFR 50.44, and 10 CFR Part 50, Appendix K ML0309300552003-03-28028 March 2003 Request for Exemption to 10 CFR 50.44 & 10 CFR Part 50, Appendix E, Section VI & Proposed License Amendments for Relaxation of Post Accident Hydrogen Monitoring & Control Requirements 2024-01-19
[Table view] Category:Letter
MONTHYEARIR 05000317/20230042024-02-0101 February 2024 Integrated Inspection Report 05000317/2023004 and 05000318/2023004 ML24029A0102024-01-29029 January 2024 Request for Information and Notification of Conduct of IP 71111.21.N.04, Age-Related Degradation, Reference Inspection Report 05000317/2024010 and 05000318/2024010 ML24003A8872024-01-19019 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0033 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) 05000318/LER-2023-004, Submittal of LER 2023-004-00 for Calvert Cliffs Nuclear Power Plant, Unit 2, Submittal of Automatic Reactor Trip from Reactor Protection System Actuation Due to Loss of Unit Service Transformer2024-01-16016 January 2024 Submittal of LER 2023-004-00 for Calvert Cliffs Nuclear Power Plant, Unit 2, Submittal of Automatic Reactor Trip from Reactor Protection System Actuation Due to Loss of Unit Service Transformer ML24011A0732024-01-11011 January 2024 Proposed Alternative to the Requirements for Repair/Replacement of Saltwater (SW) System Buried Piping 05000318/LER-2023-002, Forward LER 2023-002-00 for Calvert Cliffs Nuclear Power Plant, Unit 2, Automatic Reactor Trip from Reactor Protection System Actuation Due to Loss of Unit Service Transformer2024-01-0808 January 2024 Forward LER 2023-002-00 for Calvert Cliffs Nuclear Power Plant, Unit 2, Automatic Reactor Trip from Reactor Protection System Actuation Due to Loss of Unit Service Transformer 05000318/LER-2023-003, Forward LER 2023-003-00 for Calvert Cliffs Nuclear Power Plant, Unit 2, Manual Actuation of Auxiliary Feedwater System Due to 22 Steam Generator Feedwater Pump Trip2024-01-0808 January 2024 Forward LER 2023-003-00 for Calvert Cliffs Nuclear Power Plant, Unit 2, Manual Actuation of Auxiliary Feedwater System Due to 22 Steam Generator Feedwater Pump Trip ML24005A0222024-01-0505 January 2024 Revised Steam Generator Tube Inspection Reports ML23304A0642024-01-0202 January 2024 Issuance of Amendment No. 349 to Modify the Long-Term Coupon Surveillance Program RS-23-125, Request for Exemption from 10 CFR 2.109(b)2023-12-0707 December 2023 Request for Exemption from 10 CFR 2.109(b) ML23331A2992023-11-27027 November 2023 Submittal of Condition Prohibited by Technical Specifications Due to Failure to Sample Diesel Generator Fuel Oil Storage Tank IR 05000317/20230102023-11-20020 November 2023 Biennial Problem Identification and Resolution Inspection Report 05000317/2023010 and 05000318/2023010 ML23318A4722023-11-14014 November 2023 Supplement to License Amendment Request to Adopt TSTF-59-A ML23317A1032023-11-10010 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 ML23310A0442023-11-0707 November 2023 Project Manager Assignment IR 05000317/20230402023-11-0202 November 2023 95001 Supplemental Inspection Report 05000317/2023040 and Follow-Up Assessment Letter IR 05000317/20230032023-11-0101 November 2023 Integrated Inspection Report 05000317/2023003 and 05000318/2023003 IR 05000317/20230902023-10-26026 October 2023 Final Significance Determination of a White Finding with Assessment Follow-Up and Notice of Violation; Inspection Report 05000317/2023090 ML23289A1202023-10-16016 October 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation 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 RS-23-108, Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator Pressure Retaining Welds and Full Penetration Welded Nozzles2023-10-11011 October 2023 Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator Pressure Retaining Welds and Full Penetration Welded Nozzles RS-23-105, Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections2023-10-10010 October 2023 Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections ML23279A1202023-10-0606 October 2023 Response to NRC Inspection Report and Preliminary White Finding IR 05000317/20230502023-09-29029 September 2023 Special Inspection Report 05000317/2023050 and Preliminary White Finding and Apparent Violation ML23272A1032023-09-29029 September 2023 Condition Prohibited by Technical Specifications Due to Inoperable Nuclear Instrumentation at Very Low Power IR 05000317/20234012023-09-18018 September 2023 Cyber Security Inspection Report 05000317/2023401 and 05000318/2023401 ML23254A0012023-09-0505 September 2023 Registration of Use of Casks to Store Spent Fuel IR 05000317/20230052023-08-31031 August 2023 Updated Inspection Plan for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Report 05000317/2023005 and 05000318/2023005) ML23158A1952023-08-30030 August 2023 R. E. Ginna - Issuance of Amendments to Adopt TSTF-273-A, Revision 2, Safety Function Determination Program Clarifications ML23241A8412023-08-29029 August 2023 Response to Request for Additional Information - Proposed Alternative to the Requirements for Repair/Replacement of Saltwater (SW) System Buried Piping ML23240A3872023-08-28028 August 2023 Senior Reactor and Reactor Operator Initial License Examinations ML23151A3472023-08-21021 August 2023 Issuance of Amendments to Adopt TSTF-295-A, Modify Note 2 to Actions of PAM Table to Allow Separate Condition Entry for Each Penetration ML23219A1662023-08-16016 August 2023 Request for Additional Information Regarding Proposed Alternative to the Requirements for Repair/Replacement of Saltwater (SW) System Buried Piping (EPID: L-2023-LLR-0006) - Non-proprietary ML23228A1002023-08-15015 August 2023 Notification of Readiness for NRC 95001 Inspection ML23188A0402023-08-0808 August 2023 Issuance of Amendment Nos. 346 and 324 Adoption of TSTF-577, Revised Frequencies for Steam Generator Tube Inspections, Revision 1 ML23214A1572023-08-0707 August 2023 Correction to the Renewed Facility Operating License Page 3 in Amendment No 345 IR 05000317/20230022023-08-0303 August 2023 Integrated Inspection Report 05000317/2023002 ML23188A0512023-07-13013 July 2023 Correction to the Renewed Facility Operating License Pages in Amendment Nos. 336 and 314 ML23186A0372023-07-13013 July 2023 Correction to the Renewed Facility Operating License Pages in Amendment Nos. 340 and 318 IR 05000317/20233012023-07-12012 July 2023 Initial Operator Licensing Examination Report 05000317/2023301 and 05000318/2023301 IR 05000317/20230122023-07-10010 July 2023 Commercial Grade Dedication Report 05000317/2023012 and 05000318/2023012 ML23180A2362023-06-29029 June 2023 Correction of Errors on Technical Specification Pages RS-23-083, Withdrawal - Proposed Alternatives Related to the Steam Generators2023-06-27027 June 2023 Withdrawal - Proposed Alternatives Related to the Steam Generators ML23156A6752023-06-20020 June 2023 Request for Withholding Information from Public Disclosure for Proposed Alternative to the Requirements for Repair/Replacement of Saltwater System Buried Piping 2024-02-01
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October 9, 2020 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2 - EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR PART 73, APPENDIX B, GENERAL CRITERIA FOR SECURITY PERSONNEL (EPID L-2020-LLE-0141
[COVID-19])
Dear Mr. Hanson:
The U.S. Nuclear Regulatory Commission (NRC, the Commission) has approved the below 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 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Calvert Cliffs). This action is in response to Exelon Generation Company, LLCs (Exelon or the licensee) application dated September 8, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20252A154 (non-public, withheld under 10 CFR 2.390)), that requested a temporary exemption from the annual force-on-force (FOF) exercise requirement in 10 CFR Part 73, Appendix B, Section VI, subsection C.3.(l)(1).
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 the annual FOF exercise 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.
Subsequently, the Centers for Disease Control and Prevention issued recommendations (e.g.,
social distancing, limiting assemblies) to limit the spread of COVID-19.
B. Hanson Exelons September 8, 2020, exemption request states the following:
This temporary exemption supports 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 2020 COVID-19 virus.
These restrictions are needed to ensure personnel are isolated from the COVID-19 virus and remain capable of maintaining plant security.
On September 1, 2020, the Governor of the State of Maryland renewed the disaster declaration in response to the COVID-19 PHE, which was first imposed on March 5, 2020. The declaration continued the imposition of isolation and other restrictions throughout the state. Since that time, Calvert Cliffs has implemented isolation restrictions and other precautions for the protection of site personnel.
Exelon 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.
Exelon will ensure contingency response readiness of security personnel not participating in an annual FOF exercise by conducting a lessons-learned review of a past exercise.
Exelon will schedule and complete any missed annual FOF drills 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 September 8, 2020, exemption request.
This temporary exemption is specific to Calvert Cliffs security personnel who have previously demonstrated proficiency and currently are qualified in accordance with the requirements in 10 CFR Part 73, Appendix B, Section VI. Exelon also stated that given the rigorous nature of the Calvert Cliffs 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 Calvert Cliffs, 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 90 days after the PHE is ended, or until December 31, 2020, whichever occurs first, consistent with the NRC staffs April 20, 2020, letter.
Pursuant to 10 CFR 73.5, Specific exemptions, the Commission may, upon application of any interested person or on its own initiative, grant exemptions from the requirements of 10 CFR Part 73 when the exemptions are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest.
B. Hanson 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 licensee security personnel who are already satisfactorily qualified on the security requirements in 10 CFR Part 73, Appendix B, Section VI.
Based on this fact, and its review of the controls Exelon will implement for the duration of the exemption, including continuing to conduct required quarterly tactical response drills, a lessons-learned review of a past exercise, and completing the annual FOF exercise within the time period for this exemption, the NRC staff has reasonable assurance that the security force at Calvert Cliffs will maintain its proficiency and its 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 annual FOF exercises 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 Calvert Cliffs, 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 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
B. Hanson 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, the 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 Calvert Cliffs 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 December 31, 2020.
If you have any questions, please contact the Calvert Cliffs project manager, Michael Marshall, at (301) 415-2871 or Michael.Marshall@nrc.gov.
Sincerely, Digitally signed by Gregory F. Gregory F. Suber Date: 2020.10.09 Suber 14:08:15 -04'00' Gregory F. Suber, Deputy Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-317 and 50-318 cc: Listserv
ML20264E689 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NSIR/DPCP/RSB/BC NAME MMarshall LRonewicz ABowers DATE 09/21/2020 09/21/2020 09/23/2020 OFFICE OGC - NLO NRR/DORL/LPL1/BC NRR/DORL/DD NAME NMertz JDanna GSuber DATE 09/30/2020 10/07/2020 10/09/2020