ML20335A310

RAI November 2020 Part 73 FOF Exemption Request

ML20335A310
Person / Time
Site:	Oyster Creek
Issue date:	11/30/2020
From:	Cruz-Perez Z Division of Fuel Management
To:
Cruz-Perez Z, NMSS/DUWP
Shared Package
ML20335A303	List: ML20335A310 ML20335A311
References
Download: ML20335A310 (2)

Text

REQUEST FOR ADDITIONAL INFORMATION REQUEST FOR A ONE-TIME EXEMPTION FROM 10 CFR PART 73, APPENDIX B, SECTION VI, REGARDING ANNUAL FORCE-ON-FORCE EXERCISES, DUE TO COVID-19 PANDEMIC HOLTEC DECOMMISSIONING INTERNATIONAL, LLC OYSTER CREEK ENVIRONAMENTAL PROTECTION, LLC OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219, 72-15 By letter dated November 20, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20325A235), Holtec Decommissioning International, LLC (HDI, the licensee) requested an exemption from Title 10 of the Code of Federal Regulations (10 CFR) Part 73, Appendix B,Section VI, subsection C.3.(l)(1), regarding the annual force-on-force (FOF) exercises for calendar year 2020 at Oyster Creek Nuclear Generating Station (OCNGS).

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the request and has determined that additional information is needed to complete its review.

Request for Additional Information:

In the November 20, 2020 request HDI stated that OCNGS pandemic response plan is based on NEI 06-03, Pandemic Threat Planning, Preparation, and Response Reference Guide, (Reference 3) which recommends isolation strategies such as sequestering, use of super crews or minimum staffing as applicable as well as social distancing, group size limitations and self-quarantining, in an event of a pandemic, to prevent the spread of the virus to the plant. NEI 06-03 provides other mitigation strategies that serve the public interest during a pandemic by ensuring adequate staff is isolated from the pandemic and remains healthy to perform their job function.

In NRC letter to NEI dated October 13, 2020 (ADAMS Accession No. ML20273A117), NRC provided guidance that licensees may consider when requesting exemptions from the annual licensee-conducted FOF exercise requirement in 10 CFR Part 73, Appendix B, Section VI, Nuclear Power Reactor Training and Qualification Plan for Personnel Performing Security Program Duties, paragraph C.3(l)(1).

The October 13, 2020 letter to NEI states, in part, that:

To receive an expedited review of an exemption request from the Part 73, Appendix B,Section VI, paragraph C.3(l)(1) requirement that licensees conduct an annual FOF exercise in CY 2020, a licensee 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 The letter also stated that: This letter does not preclude requests for exemptions that take a different approach or present different rationales or proposed end dates. The NRC cannot guarantee expedited consideration of such requests.

The NRC staff requests that HDI provide additional site-specific information as to why the licensee is unable to conduct make-up FOF exercises due to continuing COVID-19 PHE and New Jersey state of emergency declaration. Certain considerations for site impacts were previously outlined in Enclosure C to the NRC letter to NEI dated April 20, 2020 (ADAMS Accession No. ML20105A483).