SBK-L-20149, Response to Request for Additional Information in Respect to One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to Covid 19 Pandemic
| ML20343A112 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/08/2020 |
| From: | Browne K NextEra Energy Seabrook |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| SBK-L-20149 | |
| Download: ML20343A112 (5) | |
Text
December 08, 2020 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Seabrook Station Docket No. 50-443 Renewed Facility Operating License No. NPF-86 Seabrook Station NEXTera ENERGY~
SEABROOK 10 CFR 73.5 SBK-L-20149 Response to Request for Additional Information in Respect to One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(1)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to COVID 19 Pandemic
References:
- 1.
NextEra Energy Seabrook, LLC letter SBK-L-20144, "Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(1)(1)
Regarding Annual Force-on-Force (FOF) Exercises, Due to COVID 19 Pandemic",
November 23, 2020 (ML20329A205).
- 2.
NRC "Request for Additional Information Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(1)(1) Regarding Annual Force-on-Force (FOF)
Exercises, Due to COVID 19 Pandemic", December 03, 2020 (L-2020-LLE-0219).
In Reference 1, NextEra Energy Seabrook, LLC (NextEra) 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 Seabrook Station, Unit No. 1 (Seabrook). This exemption would supersede the previously approved FOF exemption dated June 8, 2020 (ADAMS Accession No. ML20143A273) to restore compliance with 10 CFR Part 73, Appendix B, and the Seabrook Training and Qualification Plan 90 days after the public health emergency (PHE) has ended or prior to December 31, 2020, whichever occurred first.
NextEra Energy Seabrook, LLC P.O. Box 300, Lafayette Road, Seabrook, NH 03874
SBK-L-20149 Page 2 of 2 In Reference 2, the NRG requested additional information to complete the review of the 10 CFR 73, Appendix B, Section VI, subsection C.3(1)(1) exemption request.
The enclosure provides NextEra's response to the NRC's Request for Additional Information.
No new or revised commitments are included in this letter.
If you have any questions regarding this correspondence, please contact Mr. Kenneth Browne, Safety Assurance and Learning Site Director, at (603) 773-7932.
Executed on December 08, 2020.
Sincerely, Enclosure
Enclosure to SBK-L-20149 Response to Request for Additional Information in Respect to One-Time Exemption from 10 CFR 73, Appendix B.Section VI, Subsection C.3.(1)(1) Regarding Annual Force-on-Force (FOF) Exercises. Due to COVID 19 Pandemic
Enclosure to SBK-L-20149 Pg. 1 of 2 By letter dated November, 23, 2020 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML20329A205), NextEra Energy (NextEra) 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 Seabrook Station, Unit No. 1 (Seabrook). This exemption would supersede the previously approved FOF exemption dated June 8, 2020 (ADAMS Accession No. ML20143A273) to restore compliance with 10 CFR Part 73, Appendix B, and the Seabrook Training and Qualification Plan 90 days after the public health emergency (PHE) has ended or prior to December 31, 2020, whichever occurred first.
The NRC staff has identified the need for additional information to complete their review of the exemption request.
Response to the request for additional information (RAI) is provided below.
NRC RAI #1 Provide information on the site-specific condition(s), including site-specific COVID related impacts, that will prevent Seabrook from completing its CY 2020 annual FOF exercise prior to December 31, 2020.
1.0 NextEra Energy Seabrook Response #1 The threat of the Coronavirus Disease 2019 (COVID-19) spread has resulted in the inability to safely conduct the annual force on force (FOF) exercise at Seabrook Station within calendar year (CY) 2020 as required by Title 10 of the Code of Federal Regulations (CFR) Part 73, Appendix B,Section VI, subsection C.3.(1)(1). As noted by the Centers for Disease Control and Prevention (CDC)(Reference 2.1 ), COVID-19 may spread between people who are in close contact with one another (within 6 feet), through respiratory droplets produced when an infected person coughs, breathes, sings, or talks, by airborne transmission under certain circumstances (e.g. enclosed spaces with poor ventilation) or by individuals who are infected but do not have symptoms.
Performance of FOF exercises requires significant site resources that will result in exposing multiple individuals to conditions of close contact with others. Those scenarios would conflict with CDC guidance and NextEra policy for maintaining separation of 6 feet between personnel, and many of these situations would also be in enclosed areas. Areas where public health measures cannot be followed due to the performance of an FOF exercise would be the inside of bullet resistant enclosures, and alarm stations as they do not provide adequate social distancing capability for the increased FOF staffing.
Enclosure to SBK-L-20149 Pg. 2 of2 The annual FOF exercises require approximately 75% of the security staff to be onsite and within close proximity during the exercise. In addition, there is a potential for interdepartmental exposure risks with the addition of Seabrook Station non-Security support staff that are required to participate in the exercise, briefings, and critiques.
Modifications to the drill and exercise program to accommodate the PHE, State, and NextEra Guidelines would jeopardize the effectiveness of the safety protocols in place to run a full-scale FOF exercise in accordance with station procedures and regulatory guidelines.
Continued implementation of public health measures (for example, social distancing, group size limitations, remote working, etc.) taken at Seabrook Station remain necessary to protect the health and safety of essential site personnel during the COVID-19 public health emergency (PHE). Participation in the annual FOF exercise with the current, rapidly increasing rate of COVID-19 infections in the towns and communities surrounding Seabrook Station in southern New Hampshire, and northern Massachusetts (Reference 2.2 and Reference 2.3), exposes additional COVID-19 risk to Security, as well as site personnel that are necessary to participate in the FOF exercise.
2.0 References 2.1 Centers for Disease Control and Prevention, How to Protect Yourself and Others; retrieved from https://www.cdc.gov/coronavirus/2019-ncov/prevent-getting-sick/prevention.html#:-:text=%2D%20Some%
20people%20without%20symptoms,)%20from%20other%20people, Accessed December 04, 2020.
2.2 State of New Hampshire, COVID-19 Trends Dashboard; retrieved from https://www.nh.gov/covid19/dashboard/trends.htm#dash, Accessed December 03, 2020.
2.3 Commonwealth of Massachusetts, COVID-19 Updates and Information; retrieved from https://www.mass.gov/info-details/covid-19-updates-and-information, Accessed December 03, 2020.