L-20-313, Response to Request for Additional Information Regarding Request for Exemption -Part 73 Force-on-Force
| ML20342A199 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/07/2020 |
| From: | Tony Brown Energy Harbor Nuclear Corp |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EPID L-2020-LLE-0175, L-20-313 | |
| Download: ML20342A199 (4) | |
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harbor Terry J. Brow11 Site Vice President, Davis-Besse Nuclear December 7, 2020 L-20-313 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555
SUBJECT:
Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License No. NPF-3 Energy Harbor Nuclear Co,p.
Davis-Besse Nuclear Power Station 5501 N State Route 2 Oak Harbor, Ohio 43449 419-321-7676 10 CFR 73.5 Response to Request for Additional Information Regarding Request for Exemption -
Part 73 Force-on-Force (EPID L-2020-LLE-0175)
By letter dated October 29, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20304A046), Energy Harbor Nuclear Corp.
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.(1)(1) for the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS).
By electronic mail dated November 24, 2020, the Nuclear Regulatory Commission (NRC) staff issued a request for additional information (RAI) to complete its review. The Energy Harbor Nuclear Corp. response is attached.
There are no regulatory commitments contained in this submittal. If there are any questions or if additional information is required, please contact Mr. Phil H. Lashley, Manager - Fleet Licensing, at (330) 696-7208.
Sincerely, Terry J. Brown
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Response to Request for Additional Information
Davis-Besse Nuclear Power Station L-20-313 Page 2 of 2 cc:
NRC Region Ill Administrator NRC Resident Inspector NRR Project Manager Utility Radiological Safety Board
Attachment L-20-313 Response to Request for Additional Information Page 1 of 2 By letter dated October 29, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20304A046), Energy Harbor Nuclear Corp. 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.(I)(1) for the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS).
In order to complete the review of the exemption, the Nuclear Regulatory Commission (NRC) staff requested additional information. The requested information is provided below in bold typeface, followed by the Energy Harbor Nuclear Corp. response.
Request for Additional Information On October 13, 2020, the NRC issued updated guidance for licensees to consider when requesting exemptions from the annual FOF exercises for CY 2020 during the COVID-19 PHE (ADAMS Package 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 material 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.
Attachment L-20-313 Page 2 of 2 This updated guidance also states that licensees should submit, in part, the following information to receive an expedited review of an exemption request from the annual FOF exercise requirement for CY 2020:
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[.]
Describe the site-specific conditions, including site-specific impacts related to COVID-19, that will prevent EHNC from completing the annual FOF exercises for CY 2020 at Davis-Besse prior to December 31, 2020.
Response
The ongoing PHE and implementation of the Energy Harbor Nuclear Corp. pandemic plan at DBNPS has impacted the station's ability to perform annual FOF exercises safely due to the following:
Several officers and staff have tested positive for the virus and additional personnel have been quarantined since inception of the pandemic at various levels within the organization. Additionally, three shift supervisors tested positive for the virus. This has reduced the staffing levels which puts the station at higher risk.
The rate of infection has increased in the state of Ohio as well as in Ottawa County where DBNPS is located.
Pandemic protocols impact exercise play. Participants in the exercise must be within six feet of each other for prolonged periods of time. Area monitor and controller personnel have been reduced due to the PHE.
Not conducting annual FOF exercises due to the reasons listed in this request are consistent with the requirement of Appendix B to Part 73,Section VI, C.3.(I)(5); "Tactical response drills and force-on-force exercises are conducted safely and in accordance with site safety plans."