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 Emergency
| ML20318A288 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Three Mile Island, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle  |
| Issue date: | 11/13/2020 |
| From: | David Gudger Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20318A287 | List: |
| References | |
| NMP1L3362, RS-20-141, TMI-20-031 | |
| Download: ML20318A288 (6) | |
Text
SECURITY-RELATED INFORMATION - WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Attachments 1 through 13 of this submittal contain security-related information; upon separation this cover letter is decontrolled.
200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 73.5 RS-20-141 NMP1L3362 TMI-20-031 November 13, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. 50-454 and 50-455 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 SECURITY-RELATED INFORMATION - WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Attachments 1 through 13 of this submittal contain security-related information; upon separation this cover letter is decontrolled.
U.S. Nuclear Regulatory Commission 2020 Annual FOF Exemption Request November 13, 2020 Page 2 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220 and 50-410 Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket Nos. 50-244 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289
Subject:
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
Reference:
Letter from Ho K. Nieh, U.S. Nuclear Regulatory Commission, to Jennifer L. Uhle, Nuclear Energy Institute - "Updated Guidance for Licensees that Request Exemptions from the Calendar Year 2020 Annual Licensee-Conducted Force on Force Requirement in Part 73, Appendix B,Section VI During the Coronavirus Disease 2019 Public Health Emergency," dated October 13, 2020 (ML20273A117)
On January 31, 2020, the U.S. Department of Health and Human Services declared a Public Health Emergency (PHE) for the United States to aid the nations healthcare community in responding to the Coronavirus Disease 2019 (COVID-19). On March 11, 2020, the COVID-19 outbreak was characterized as a pandemic by the World Health Organization and, on March 13, 2020, President Donald Trump declared the COVID-19 pandemic a PHE. In addition, the Governors of the following states in which the cited Exelon Generation Company, LLC (Exelon) plants are located have declared a state of emergency in response to the COVID-19 PHE on the dates noted:
State State of Emergency Declaration Date State of Illinois March 9, 2020 State of Maryland March 5, 2020 Commonwealth Pennsylvania March 6, 2020 State of New York March 7, 2020
U.S. Nuclear Regulatory Commission 2020 Annual FOF Exemption Request November 13, 2020 Page 3 In response to these declarations Exelon implemented its pandemic response plan which instituted and supported isolation protocols as recommended by the U.S. Centers for Disease Control and Prevention (CDC) that were necessary to protect public health as well as the health and safety of essential site personnel. As a result of these actions, Exelon submitted temporary exemption requests from certain requirements of 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1),
regarding 2020 annual force-on-force (FOF) for which the Exelon facilities cited and received NRC approval for the requested temporary exemptions. The table below provides information regarding the submittal and approval dates for the temporary exemptions for the Exelon facilities. The temporary exemptions were necessary because isolation protocols (e.g., social distancing, group size limitations, self-quarantining, etc.) restrict activities associated with conducting annual FOF exercises and were necessary to maintain a healthy workforce during the PHE. The approved temporary exemptions expire on December 31, 2020.
Facility Submittal Date NRC Approval Date Braidwood Station June 15, 2020 July 9, 2020 Byron Station July 30, 2020 August 17, 2020 Calvert Cliffs Nuclear Power Plant September 8, 2020 October 9, 2020 Clinton Power Station July 23, 2020 August 13, 2020 Dresden Nuclear Power Station July 28, 2020 August 27, 2020 James A. FitzPatrick Nuclear Plant May 29 and June 4, 2020 June 29, 2020 LaSalle County Station July 16, 2020 August 3, 2020 Limerick Generating Station July 29, 2020 August 19, 2020 Nine Mile Point Nuclear Station July 24, 2020 August 25, 2020 Peach Bottom Atomic Power Station May 8, 2020 May 20, 2020 Quad Cities Nuclear Power Station July 27, 2020 August 27, 2020 R.E. Ginna Nuclear Power Plant June 8, 2020 June 24, 2020 Three Mile Island Nuclear Station June 5, 2020 June 30, 2020 In the submitted requests for the temporary exemptions, Exelon stated that actions would be taken at its sites that included completing any missed 2020 FOF exercises. Specifically, at the time of submittals for the temporary exemption requests the duration of the PHE was discussed as "not currently known" and, therefore, Exelon stated that it would complete the exercises 90 days after the PHE ended, or by December 31, 2020, whichever occurred first. However, the PHE has not ended and continues to impact Exelon's ability to conduct the 2020 annual FOF exercises at the noted facilities. Because the temporary exemption expires December 31, 2020, Exelon requests an exemption from conducting 2020 annual FOF exercises as required by 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) for the Exelon facilities cited. Attachments 1 through 13 are included in this submittal and provide additional information supporting the justification for the requested exemptions for each affected Exelon facility. These exemptions would supersede actions previously described in the temporary exemptions approved by the NRC as further discussed in the supporting attachments for the individual facilities.
Approval of these exemptions will continue to support the isolation protocols necessary to protect essential site personnel. These restrictions are needed to ensure personnel are isolated from the COVID-19 disease and remain capable of maintaining plant security.
The proposed exemptions will apply specifically to those security personnel in which the approved temporary exemptions applied.
U.S. Nuclear Regulatory Commission 2020 Annual FOF Exemption Request November 13, 2020 Page 4 There are no commitments contained in this submittal.
Should you have any questions concerning this submittal, please contact Ron Reynolds at (610) 765-5247.
Exelon requests written approval of the exemptions for the affected Exelon facilities by December 15, 2020.
Respectfully, David T. Gudger Senior Manager, Licensing Exelon Generation Company, LLC Attachments:
- 1. Braidwood Station, Units 1 and 2 - Request for Exemption from Certain 10 CFR 73 Appendix B, Section VI, Subsection C.3.(I)(1), Regarding 2020 Annual Force-on-Force (FOF) Exercises Due to the Continued COVID-19 Public Health Emergency
- 2. Byron Station, Units 1 and 2 - Request for Exemption from Certain 10 CFR 73 Appendix B, Section VI, Subsection C.3.(I)(1), Regarding 2020 Annual Force-on-Force (FOF) Exercises Due to the Continued COVID-19 Public Health Emergency
- 3. Calvert Cliffs Nuclear Power Plant, Units 1 and 2- Request for Exemption from Certain 10 CFR 73 Appendix B, Section VI, Subsection C.3.(I)(1), Regarding 2020 Annual Force-on-Force (FOF) Exercises Due to the Continued COVID-19 Public Health Emergency
- 4. Clinton Power Station, Unit 1 - Request for Exemption from Certain 10 CFR 73 Appendix B, Section VI, Subsection C.3.(I)(1), Regarding 2020 Annual Force-on-Force (FOF) Exercises Due to the Continued COVID-19 Public Health Emergency
- 5. Dresden Nuclear Power Station, Units 2 and 3 - Request for Exemption from Certain 10 CFR 73 Appendix B, Section VI, Subsection C.3.(I)(1), Regarding 2020 Annual Force-on-Force (FOF) Exercises Due to the Continued COVID-19 Public Health Emergency
- 6. James A. FitzPatrick Nuclear Power Plant - Request for Exemption from Certain 10 CFR 73 Appendix B, Section VI, Subsection C.3.(I)(1), Regarding 2020 Annual Force-on-Force (FOF)
Exercises Due to the Continued COVID-19 Public Health Emergency
- 7. LaSalle County Station, Units 1 and 2 - Request for Exemption from Certain 10 CFR 73 Appendix B, Section VI, Subsection C.3.(I)(1), Regarding 2020 Annual Force-on-Force (FOF)
Exercises Due to the Continued COVID-19 Public Health Emergency
U.S. Nuclear Regulatory Commission 2020 Annual FOF Exemption Request November 13, 2020 Page 5
- 8. Limerick Generating Station, Units 1 and 2 - Request for Exemption from Certain 10 CFR 73 Appendix B, Section VI, Subsection C.3.(I)(1), Regarding 2020 Annual Force-on-Force (FOF)
Exercises Due to the Continued COVID-19 Public Health Emergency
- 9. Nine Mile Point Nuclear Station, Units 1 and 2 - Request for Exemption from Certain 10 CFR 73 Appendix B, Section VI, Subsection C.3.(I)(1), Regarding 2020 Annual Force-on-Force (FOF) Exercises Due to the Continued COVID-19 Public Health Emergency
- 10. Peach Bottom Atomic Power Station, Units 2 and 3 - Request for Exemption from Certain 10 CFR 73 Appendix B, Section VI, Subsection C.3.(I)(1), Regarding 2020 Annual Force-on-Force (FOF) Exercises Due to the Continued COVID-19 Public Health Emergency
- 11. Quad Cities Nuclear Power Station, Units 1 and 2 - Request for Exemption from Certain 10 CFR 73 Appendix B, Section VI, Subsection C.3.(I)(1), Regarding 2020 Annual Force-on-Force (FOF) Exercises Due to the Continued COVID-19 Public Health Emergency
- 12. R.E. Ginna Nuclear Power Plant - Request for Exemption from Certain 10 CFR 73 Appendix B, Section VI, Subsection C.3.(I)(1), Regarding 2020 Annual Force-on-Force (FOF) Exercises Due to the Continued COVID-19 Public Health Emergency
- 13. Three Mile Island Nuclear Station, Unit 1 - Request for Exemption from Certain 10 CFR 73 Appendix B, Section VI, Subsection C.3.(I)(1), Regarding 2020 Annual Force-on-Force (FOF)
Exercises Due to the Continued COVID-19 Public Health Emergency
U.S. Nuclear Regulatory Commission 2020 Annual FOF Exemption Request November 13, 2020 Page 6 cc: w/ Attachments Regional Administrator - NRC Region III Regional Administrator - NRC Region I NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - R.E. Ginna Nuclear Power Plant NRC Project Manager, NRR - Braidwood Station NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Calvert Cliffs Nuclear Power Plant NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - James A. FitzPatrick Nuclear Power Plant NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Nine Mile Point Nuclear Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - R.E. Ginna Nuclear Power Plant NRC Project Manager, NRR - Three Mile Island, Unit 1 NRC Project Manager, NMSS/DUWP/RDB - Three Mile Island, Unit 1 Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources W. DeHass - Commonwealth of Pennsylvania Bureau of Radiation Protection S. Seaman - State of Maryland A. L. Peterson - NYSERDA B. Frymire - NYSPSC