ML20325A236

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Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to COVID-19 Pandemic
ML20325A236
Person / Time
Site: Oyster Creek
Issue date: 11/20/2020
From: Sterdis A
Holtec Decommissioning International
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML20325A235 List:
References
HDI-OC-20-087
Download: ML20325A236 (2)


Text

SECURITY-RELATED INFORMATION - WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 10 CFR 73.5 November 20, 2020 Attn: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 Docket No. 50-219 and 72-15

Subject:

Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to COVID 19 Pandemic

Reference:

1. NRC Letter, "Oyster Creek Nuclear Generating Station - Exemption Request From Certain Requirements Of 10 CFR Part 73, Appendix B, General Criteria For Security Personnel,Section VI (L-2020-LLE-0054), dated May 20, 2020, (ML20140A130)

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 Coronavirus (COVID-19) pandemic a national emergency. In addition, New Jersey Governor Phil Murphy declared a state of emergency on March 09, 2020.

In response to these declarations and in accordance with the Holtec Decommissioning International, LLC (HDI) Pandemic Response plan, by letter dated May 20, 2020, (Reference1),

a temporary exemption from; 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1),

regarding annual force-on-force (FOF) exercises, was approved for the station. The exemption was necessary because isolation protocols (e.g., social distancing, group size limitations, self-quarantining, etc.) restrict activities associated with conducting annual FOF exercises and was necessary to maintain a healthy workforce during the pandemic. The approved temporary exemption expires December 31, 2020.

In the request for exemption HDI committed to complete any missed FOF exercises, within 90 days of when isolation restrictions are ended or by December 31, 2020. At the time of submittal NOTE: THE ATTACHMENT TO THIS LETTER CONTAINS SENSITIVE SECURITY INFORMATION.

WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390. UPON REMOVAL OF THE ATTACHMENT, THIS LETTER IS DECONTROLLED.

HDI-OC-20-087 Page 1 of 2

SECURITY-RELATED INFORMATION - WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390 Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 for the exemption request the duration of the PHE was discussed as not currently known, and therefore a commitment was added to complete the exercises 90 days after the PHE is ended, or by December 31, 2020, whichever occurs first. However, the PHE has not ended and continues to impact the ability of Oyster Creek Nuclear Generating Station (OCNGS) to conduct annual FOF exercises. Because the temporary exemption expires December 31, 2020, HDI requests a one-time exemption for OCNGS from conducting 2020 annual FOF exercises as required by 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1). This one-time exemption would supersede the commitment in the previously approved exemption to complete any missed FOF exercise, within the time period in that request, when isolation restrictions are ended.

Approval of this exemption 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 one-time exemption will apply specifically to security personnel that the temporary approved exemption applied.

This letter contains no new regulatory commitments.

Should you have any questions or require further information, please contact me at (856) 797-0900, x3813.

Respectfully, Digitally signed by Andrea Sterdis Andrea DN: cn=Andrea Sterdis, c=US, o=Holtec Decommissioning International, ou=HDI, Sterdis email=a.sterdis@holtec.com Date: 2020.11.20 12:41:53 -05'00' Andrea L. Sterdis HDI Vice President, Regulatory and Environmental Affairs Holtec Decommissioning International, LLC Attachment - Security 2020 Annual Force-on-Force Exercise One-Time Exemption Request cc:

USNRC Regional Administrator, Region I USNRC Project Manager, NMSS - Oyster Creek Nuclear Generating Station USNRC Region I, Lead Inspector - Oyster Creek Nuclear Generating Station Assistant Commissioner, Air Quality, Energy and Sustainability, NJDEP Assistant Director Radiation Protection Element, NJ Bureau of Nuclear Engineering NOTE: THE ATTACHMENT TO THIS LETTER CONTAINS SENSITIVE SECURITY INFORMATION.

WITHHOLD FROM PUBLIC DISCLOSURE UNDER 10 CFR 2.390. UPON REMOVAL OF THE ATTACHMENT, THIS LETTER IS DECONTROLLED.

HDI-OC-20-087 Page 2 of 2