ML20323A453
ML20323A453 | |
Person / Time | |
---|---|
Site: | Diablo Canyon ![]() |
Issue date: | 11/18/2020 |
From: | Samson Lee NRC/NRR/DORL/LPL4 |
To: | Richardson M Pacific Gas & Electric Co |
References | |
L-2020-LLE-0167 | |
Download: ML20323A453 (4) | |
Text
From:
Lee, Samson Sent:
Wednesday, November 18, 2020 4:01 PM To:
Richardson, Michael
Subject:
Request for additional information: Diablo Canyon COVID-19 exemption request to extend firearms requalification (EPID: L-2020-LLE-0167)
=
Background===
By letter dated October 14, 2020 (Agencywide Documents and Access Management System (ADAMS)
Accession No. ML20288A253), Pacific Gas and Electric Company (PG&E) requested a one-time exemption from conducting firearms requalifications in calendar year (CY) 2020, as required by 10 CFR 73, Appendix B, Section VI, Subsection F.5.(a). If granted, this one-time exemption would supersede the licensees commitment in the temporary exemption that NRC granted on July 30, 2020 (ADAMS Accession No. ML20209A050), to complete any missed firearms requalifications within 90 days after the end of the Coronavirus Disease 2019 (COVID-19) public health emergency (PHE), or December 31, 2020, whichever occurred first.
The NRC staff has reviewed the exemption request and determined that additional information is required to complete the review. The NRC staffs requests for additional information (RAIs) are listed below. The staff may have additional RAIs. The staff sent the draft RAIs to the PG&E staff and held a clarification call on November 18, 2020. The PG&E staff requested, and NRC agreed, to a RAI response by December 3, 2020.
The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. Please note that if you do not respond to this request by the agreed-upon date or provide an acceptable alternate date, we may deny your application under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108. If circumstances result in the need to revise the agreed upon response date, please contact me at (301) 415-3168 or via e-mail Samson.Lee@nrc.gov.
Regulatory Bases and Guidance 10 CFR 73, Appendix B, Section VI, Subsection F.5.(a) requires that:
Armed members of the security organization shall be re-qualified for each assigned weapon at least annually in accordance with Commission requirements and the Commission-approved training and qualification plan, and the results documented and retained as a record.
The firearms qualification courses required to be complete under subsection F.5.(a) are outlined in Appendix B to Part 73,Section VI., subsection F.3., Firearms qualification courses. The licensee shall conduct the following qualification courses for each weapon used, including:
(a) Annual daylight qualification course. Qualifying score must be an accumulated total of 70 percent with handgun and shotgun, and 80 percent with semiautomatic rifle and/or enhanced weapons, of the maximum obtainable target score.
(b) Annual night fire qualification course. Qualifying score must be an accumulated total of 70 percent with handgun and shotgun, and 80 percent with semiautomatic rifle and/or enhanced weapons, of the maximum obtainable target score.
(c) Annual tactical qualification course. Qualifying score must be an accumulated total of 80 percent of the maximum obtainable score.
On October 13, 2020, NRC issued 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 (ADAMS Accession No. ML20273A058). On October 14, 2020, PG&E also submitted a request for a one-time exemption from conducting annual force-on-force (FOF) exercises in CY 2020 (ADAMS Accession No. ML20288A256), as required by Appendix B to Part 73,Section VI., subsection C.3.(I)(1).
Scope of PG&Es Request Page 2 of the attachment in PG&Es request states, in part, that DCPP has continued to conduct the following training requalification requirements of Section VI. of Appendix VI. to Part 73.
- Annual daylight qualification course
- Annual night fire qualification course Because PG&E indicated some firearms requalifications have continued at Diablo Canyon (e.g., daylight and night fire qualifications), it appears to the NRC staff that PG&Es request covers only the tactical requalification course requirement in subsections F.5.(a) and F.3.(c).
Upon its review, staff determined that PG&Es submittal does not appear to address whether PG&E will be able to requalify all of its security personnel at Diablo Canyon on the daylight and night fire courses in CY 2020, or whether the scope of PG&Es request also applies to these two courses for at least some of the Diablo Canyon security personnel (e.g., due to reduced firing range capacity and throughput).
Additionally, PG&Es submittal does not appear to address why PG&E has been able to complete some firearms requalifications (e.g., daylight and night fire requalifications) and anticipates being unable to fully satisfy the annual firearms requalification requirement in Appendix B to Part 73,Section VI.,
subsection F.5.(a), in CY 2020. The staff understands site-specific circumstances could adversely impact firearms requalifications (e.g., no access to a firing range during the COVID-19 PHE, reduced firing range capacity and throughput), but PG&Es request provided no information on any such site-specific circumstances.
Maintaining Contingency Response Readiness with Multiple One-Time Exemptions PG&E has submitted exemption requests from the requirements to perform firearms requalifications and the licensee conducted annual FOF exercise(s) in CY 2020, together. However, PG&E has not provided information in its submittal to explain how security personnel at Diablo Canyon will continue to maintain their contingency response readiness under the cumulative effect that not performing these training activities may inadvertently create.
Requests
- 1. Clarify whether PG&Es request pertains only to the tactical requalification course requirement in subsections F.5.(a) and F.3.(c) to Appendix B to Part 73,Section VI. If PG&Es request is broader in scope than the tactical requalification course, provide information regarding the firearms requalifications, including daylight and night fire requalifications, that PG&E anticipates not being able to complete by the end of CY 2020.
- 2. Provide information to clarify why PG&E has been able to complete some firearms requalifications (e.g., daylight and night fire) but anticipates being unable to fully satisfy the annual firearms requalification requirement.
- 3. Provide information explaining how security personnel at Diablo Canyon will continue to maintain their contingency response readiness under the cumulative effect of not conducting firearms requalifications and the FOF exercise in CY 2020.
Hearing Identifier:
NRR_DRMA Email Number:
899 Mail Envelope Properties (DM8PR09MB6183992EF32229E3D4761E899AE10)
Subject:
Request for additional information: Diablo Canyon COVID-19 exemption request to extend firearms requalification (EPID: L-2020-LLE-0167)
Sent Date:
11/18/2020 4:01:00 PM Received Date:
11/18/2020 4:01:00 PM From:
Lee, Samson Created By:
Samson.Lee@nrc.gov Recipients:
"Richardson, Michael" <MJRm@pge.com>
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