ML20339A003
| ML20339A003 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/03/2020 |
| From: | Booma Venkataraman Plant Licensing Branch III |
| To: | Schneider T, Schultz E Point Beach |
| Venkataraman B, NRR/DORL/LPL3, 415-2934 | |
| References | |
| EPID L-2020-LLE-0210 | |
| Download: ML20339A003 (3) | |
Text
From:
Venkataraman, Booma To:
Schneider, Thomas; Schultz, Eric Cc:
Salgado, Nancy; Locke, Kim
Subject:
REQUEST FOR ADDITIONAL INFORMATION: Point Beach Units 1 and 2: Part 73 Request for Exemption/ Re:
Annual FOF Exercises (EPID: L-2020-LLE-0210)
Date:
Thursday, December 03, 2020 3:40:00 PM Attachments:
Point Beach _Part 73 Exemption_Final RAI.pdf Mr. Schneider and Mr. Schultz,
By letter dated November 19, 2020 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML20324A693, non-public), NextEra Energy Point Beach, LLC. (NextEra) submitted an one-time exemption request to the U.S. Nuclear Regulatory Commission (NRC),
regarding the 2020 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 Point Beach Nuclear Plant, Units 1 and 2. This exemption would supersede the previously approved exemption dated June 15, 2020 (ADAMS Accession No. ML20153A011) requirement to complete the 2020 annual FOF exercises, as required by 10 CFR Part 73, Appendix B, Section VI, Subsection C.3.(I)(1), within 90 days after the Coronavirus Disease 2019 (COVID-19) public health emergency has ended, or by December 31, 2020, whichever occurred first.
A draft request for information (RAI) was sent to you on December 2, 2020. A clarification call was conducted on December 3, 2020, between NRC staff and NextEra. The final RAI version is attached to this e-mail. In the clarification call, NextEra agreed to respond to the attached RAI with a supplement by December 9, 2020.
Please treat this e-mail as transmittal of formal RAIs. If circumstances result in the need to revise the requested response date, please contact me.
Sincerely, Booma Booma Venkataraman Project Manager, NRR/DORL/LPL3 Office of Nuclear Reactor Regulation Booma.Venkataraman@nrc.gov 301.415.2934
REQUEST FOR ADDITIONAL INFORMATION EXEMPTION FROM 10 CFR 73, APPENDIX B, SECTION VI, SUBSECTION C.3.(I)(1) REGARDING ANNUAL FORCE-ON-FORCE EXERCISE NEXTERA ENERGY POINT BEACH, LLC.
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NO. 50-266 AND 50-301 By letter dated November 19, 2020 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML20324A693, non-public), NextEra Energy Point Beach, LLC. (NextEra) submitted an one-time exemption request to the Nuclear Regulatory Commission (NRC), regarding the 2020 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 Point Beach Nuclear Plant, Units 1 and 2 (Point Beach). This exemption would supersede the previously approved exemption dated June 15, 2020 (ADAMS Accession No. ML20153A011) requirement to complete the 2020 annual FOF exercises, as required by 10 CFR Part 73, Appendix B, Section VI, Subsection C.3.(I)(1), within 90 days after the Coronavirus Disease 2019 (COVID-19) public health emergency (PHE) has ended, or by December 31, 2020, whichever occurred first.
The NRC staff has reviewed the submittal and determined that additional information is needed to complete its review.
Regulatory Basis 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.
In its November 19, 2020 application, NextEra stated that the PHE has not ended and continues to impact Point Beach's ability to conduct annual FOF exercises. 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.
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. ML20273A126). 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, in part, that licensees should, in addition to describing how they intend to maintain contingency response readiness, 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 Request for Additional Information (RAI)