ML20266G289
| ML20266G289 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 10/19/2020 |
| From: | Craig Erlanger Division of Operating Reactor Licensing |
| To: | Entergy Operations |
| Lingam S, 301-415-1564 | |
| References | |
| EPID L-2020-LLE-0147 [COVID-19] | |
| Download: ML20266G289 (5) | |
Text
October 19, 2020 Vice President, Operations Entergy Operations, Inc.
Grand Gulf Nuclear Station P.O. Box 756 Port Gibson, MS 39150
SUBJECT:
GRAND GULF NUCLEAR STATION, UNIT 1 - EXEMPTION FROM CERTAIN REQUIREMENTS OF 10 CFR PART 73, APPENDIX B, GENERAL CRITERIA FOR SECURITY PERSONNEL, SECTION VI (EPID L-2020-LLE-0147 [COVID-19])
Dear Sir or Madam:
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 Grand Gulf Nuclear Station, Unit 1 (Grand Gulf). This action is in response to the Entergy Operations, Inc. (Entergy, the licensee) application dated September 17, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20262H201 (not publicly available, withheld under 10 CFR 2.390)), that requested a temporary exemption from 10 CFR Part 73, Appendix B, Section VI, subsection C.3.(I)(1), regarding annual force-on-force (FOF) exercises at Grand Gulf.
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 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.
Subsequently, the Centers for Disease Control and Prevention issued recommendations (e.g.,
social distancing, limiting assemblies) to limit the spread of COVID-19.
Entergys September 17, 2020, application stated the following:
This temporary 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.
Entergy implemented isolation restrictions for Grand Gulf site personnel on April 20, 2020, which are currently in effect until January 4, 2021.
Entergy will maintain a list of the names of the individuals who will not meet the requalification requirements for the annual FOF exercises and will include the dates of the last quarterly drill and annual FOF exercise in which the individual participated.
Entergy will ensure contingency response readiness of security personnel not participating in an annual FOF exercise by conducting one of the following scenario-based evolution[s] during quarterly tactical response drills: a table-top exercise; a communications-based exercise; or a lessons-learned review of past exercise.
Entergy will conduct any missed annual licensee-conducted FOF exercises within 90 days after the PHE ends or by December 31, 2020, whichever occurs first.
Entergy will begin implementing COVID-19 PHE training requalification controls at Grand Gulf for managing personnel performing Security Program duties upon NRC approval [of its exemption request].
This temporary exemption is specific to Grand Gulf security personnel who have previously demonstrated proficiency and are currently qualified in accordance with the requirements of 10 CFR Part 73, Appendix B, Section VI. Entergy also stated that because of the rigorous nature of Entergys 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, the September 17, 2020, request stated that Entergy will implement the site-specific COVID-19 PHE training requalification controls listed above at Grand Gulf, consistent with those outlined in the NRC letter dated April 20, 2020, discussing planned activities related to the requirements for 10 CFR Part 73, Appendix B, Section VI, during the PHE (ADAMS Accession No. ML20105A483).
Entergy requested that the duration of the exemption be in effect for 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 by 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, 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 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 Entergy will implement for the duration of the exemption (including, continuing to perform quarterly tactical response drills; conducting either a tabletop exercise, a communications-based exercise, or a lessons-learned review of past exercise; and completing the annual FOF exercise before the expiration of this exemption), the NRC staff has reasonable assurance that the security force at Grand Gulf 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 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 exercise 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 Grand Gulf, 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 this 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 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 Grand Gulf, 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 on December 31, 2020.
If you have any questions, please contact the Grand Gulf project manager, Siva P. Lingam, at 301-415-1564 or via e-mail at Siva.Lingam@nrc.gov.
Sincerely Digitally signed by Craig G. Craig G. Erlanger Date: 2020.10.19 Erlanger 13:37:31 -04'00' Craig G. Erlanger, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-416 cc: Listserv
ML20266G289 *via e-mail OFFICE NRR/DORL/LPL4/PM* NRR/DORL/LPL4/LA* NSIR/DPCP/RSB/BC*
NAME SLingam PBlechman ABowers DATE 09/23/2020 09/23/2020 09/24/2020 OFFICE OGC - NLO* NRR/DORL/LPL4/BC* NRR/DORL/D*
NAME NMertz JDixon-Herrity (SLee for) CErlanger DATE 10/08/2020 10/08/2020 10/19/2020