ML20325A278
| ML20325A278 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 11/20/2020 |
| From: | Scott Wall NRC/NRR/DORL/LPL3 |
| To: | Lashley P Energy Harbor Nuclear Corp |
| Wall S | |
| References | |
| L-2020-LLE-0176 | |
| Download: ML20325A278 (4) | |
Text
From:
Wall, Scott Sent:
Friday, November 20, 2020 11:17 AM To:
Lashley, Phil H (EH)
Cc:
Morgan, Jeffrey D.
Subject:
Final RAI - Perry - Part 73 Force-on-Force Exemption (EPID: L-2020-LLE-0176)
Dear Mr. Lashley,
By letter dated October 29, 2020 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML20304A191), Energy Harbor Nuclear Corp (EHNC or the licensee) requested an exemption from the annual force-on-force (FOF) requirement of Title 10 of the Code of Federal Regulations (CFR) Part 73, Appendix B,Section VI, subsection C.3.(l)(1) for the Perry Nuclear Power Plant, Unit No. 1 (PNPP).
The NRC staff has reviewed the submittals and determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). During a telephone calls on November 20, 2020, the EHNC staff indicated that a response to the RAIs would be provided by December 4, 2020.
If you have questions, please contact me at 301-415-2855 or via e-mail at Scott.Wall@nrc.gov.
Scott P. Wall, LSS BB, BSP Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301.415.2855 Scott.Wall@nrc.gov Docket No. 50-440
Enclosure:
Request for Additional Information cc: Listserv RAI-NSIR (Part 73: Force-on-Force)
REQUEST FOR ADDITIONAL INFORMATION EXCEPTION FROM ANNUAL FORCE-ON-FORCE REQUIREMENT ENERGY HARBOR NUCLEAR CORP PERRY NUCLEAR POWER PLANT, UNIT NO. 1
NRC DOCKET No. 50-440 INTRODUCTION By letter dated October 29, 2020 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML20304A191), Energy Harbor Nuclear Corp (EHNC or the licensee) requested an exemption from the annual force-on-force (FOF) requirement of Title 10 of the Code of Federal Regulations (CFR) Part 73, Appendix B,Section VI, subsection C.3.(l)(1) for the Perry Nuclear Power Plant, Unit No. 1 (PNPP).
The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the application and has determined that the following additional information is required in order to complete the review.
APPLICABLE REGULATION AND GUIDANCE Subsection C.3.(l)(1) requires that:
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) tactical response drill on a quarterly basis and one (1) force-on-force exercise on an annual basis.
In the request, EHNC indicated that the NRC approved temporary exemption dated: May 11, 2020 (ADAMS Accession No. ML20119A051) for conducting the CY 2020 FOF exercise at PNPP expires on December 31, 2020. The exemption was in response to the COVID-19 public health emergency (PHE) and was necessary because isolation protocols (for example, social distancing, group size limitations, self-quarantining, and so on) restrict activities associated with conducting annual FOF exercises and was necessary to maintain a healthy workforce.
EHNC indicated that the PHE has not ended and continues to impact the ability of EHNC to conduct annual FOF exercises at PNPP. EHNC states that approval of this exemption [one-time exemption of CY 2020 FOF exercise] will continue to support the isolation protocols necessary to protect essential site personnel. These restrictions are needed to ensure personnel are isolated from COVID-19 and remain capable of maintaining plant security.
Additionally, the October 29, 2020, request identified site-specific actions that will be implemented at PNPP to maintain contingency response readiness.
RAI-NSIR-01 On October 13, 2020, the NRC issued updated guidance for licensees that require exemptions from CY 2020 annual FOF exercises during the COVID-19 PHE (ADAMS Accession No. ML20273A058). The guidance states, in part:
... Since the NRC issued the April 2020 letter, some licensees have taken measures recommended by Federal, State, and local authorities to help protect their personnel, including security personnel, from exposure to COVID-19. These measures include the implementation of COVID related controls such as the widespread use of face coverings for site personnel, frequent surface sanitization and handwashing, and social distancing (i.e., maintaining 6 feet of separation between individuals where
practical). Accordingly, some of these licensees have been able to resume many routine activities with little or no disruption or with the use of other controls, to accomplish the same tasks safely. In addition, due to site-specific configurations and implementation of certain safety measures, some commercial power reactor and fuel cycle facility licensees have successfully conducted their required annual FOF exercises during the PHE without adversely impacting the sites security staffing or operations.
Nevertheless, the impacts of COVID-19 are still ongoing for some licensees and will likely extend beyond December 31, 2020. These circumstances may prevent licensees from completing their missed CY 2020 FOF exercises by December 31, 2020. To address this situation, the NRC is prepared to expedite consideration of requests for an exemption that would relieve licensees from making up any missed CY 2020 annual FOF exercises.
This updated guidance also requests that licensees that have previously been granted a temporary exemption from the annual FOF exercise requirement should submit the following information:
For licensees that have previously been granted a temporary exemption from the annual FOF exercise requirement, a discussion as to why the licensee is unable to conduct make-up exercises due to continuing COVID-19 PHE impacts as committed to in their initial exemption request submission; or Request Describe the site-specific condition(s), including site-specific COVID-19-related impacts, that will prevent the EHNC and PNPP from completing its CY 2020 annual FOF exercise prior to December 31, 2020.
Hearing Identifier:
NRR_DRMA Email Number:
904 Mail Envelope Properties (MN2PR09MB5019DCB8D95CECBC6E233A1292FF0)
Subject:
Final RAI - Perry - Part 73 Force-on-Force Exemption (EPID: L-2020-LLE-0176)
Sent Date:
11/20/2020 11:16:31 AM Received Date:
11/20/2020 11:16:32 AM From:
Wall, Scott Created By:
Scott.Wall@nrc.gov Recipients:
"Morgan, Jeffrey D." <jdmorgan@energyharbor.com>
Tracking Status: None "Lashley, Phil H (EH)" <phlashley@energyharbor.com>
Tracking Status: None Post Office:
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