ML20329A069

NRR E-mail Capture - Request for Additional Information: Diablo Canyon COVID-19 Exemption Request to Extend force-on-force Exercise

ML20329A069
Person / Time
Site:	Diablo Canyon
Issue date:	11/23/2020
From:	Samson Lee NRC/NRR/DORL/LPL4
To:	Richardson M Pacific Gas & Electric Co
References
L-2020-LLE-0166
Download: ML20329A069 (3)

Text

From: Lee, Samson Sent: Monday, November 23, 2020 5:13 PM To: Richardson, Michael; ARMb@pge.com

Subject:

Request for additional information: Diablo Canyon COVID-19 exemption request to extend force-on-force exercise (EPID: L-2020-LLE-0166)

Background

By letter dated October 14, 2020 (Agencywide Documents and Access Management System (ADAMS)

Accession No. ML20288A256), Pacific Gas and Electric Company (PG&E) 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 Diablo Canyon Power Plant (DCPP), Units 1 and 2.

This exemption would supersede the previously approved exemption dated June 24, 2020 (ADAMS Accession No. ML20170A319) to restore compliance with 10 CFR Part 73, Appendix B and the DCPP Training and Qualification Plan, 90 days after the end of the public health emergency (PHE), or December 31, 2020, whichever occurs first.

The NRC staff has reviewed the exemption request and determined that additional information is required to complete the review. The NRC staffs request for additional information (RAI) is listed below.

The staff may have additional RAIs. The staff sent the draft RAI to the PG&E staff and the PG&E staff indicated that they did not need a clarification call. The PG&E staff requested, and NRC agreed, to a RAI response by December 8, 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 The regulation in 10 CFR Part 73, Appendix B, Section VI, 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.

PG&E stated that DCPP will no longer be able to comply with the annual FOF exercise requirements of the specified regulation, and will implement site-specific coronavirus disease 2019 (COVID-19) PHE training requalification controls consistent with those conditions outlined in the NRC Letter from H. Nieh and J. Lubinski to NEI, U.S. Nuclear Regulatory Commission Planned Actions Related to the Requirements for Part 73, Appendix B,Section VI During the Coronavirus Disease 2019 Public Health Emergency, dated April 20, 2020 (ADAMS Accession No. ML20105A483). PG&E stated that the PHE has not ended and continues to impact DCPPs ability to conduct annual FOF exercises and to comply with the requirements of 10 CFR 73, Appendix B, Section VI, subsection C.3.(I)(1), outlined in the NRCs June 24, 2020, temporary exemption approval letter.

PG&E stated that the exemption was in response to the COVID-19 PHE and was necessary because isolation protocols (e.g., social distancing, group size limitations, self-quarantining, etc.) restrict activities associated with conducting annual FOF exercises and to maintain a healthy workforce during the pandemic. The approved temporary exemption expires December 31, 2020.

Issue 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-19-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;

• In addition to the information above, licensees requesting an exemption from the CY 2020 annual FOF exercise requirement, whether previously granted an exemption for the annual FOF exercise requirement or not, should provide a description of how they intend to maintain contingency response readiness.

Request Provide information on the site-specific condition(s), including site-specific COVID-19-related impacts, that will prevent DCPP from completing its CY 2020 annual FOF exercise prior to December 31, 2020.

Hearing Identifier: NRR_DRMA Email Number: 906 Mail Envelope Properties (DM8PR09MB6183D064ABDE54D86C62D8899AFC0)

Subject:

Request for additional information: Diablo Canyon COVID-19 exemption request to extend force-on-force exercise (EPID: L-2020-LLE-0166)

Sent Date: 11/23/2020 5:13:23 PM Received Date: 11/23/2020 5:13:23 PM From: Lee, Samson Created By: Samson.Lee@nrc.gov Recipients:

"Richardson, Michael" <MJRm@pge.com>

Tracking Status: None "ARMb@pge.com" <ARMb@pge.com>

Tracking Status: None Post Office: DM8PR09MB6183.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 6122 11/23/2020 5:13:23 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: