ML20343A129
| ML20343A129 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Prairie Island, San Onofre  |
| Issue date: | 12/08/2020 |
| From: | Robert Kuntz NRC/NRR/DORL/LPL3 |
| To: | Jacobson R, Kivi J Northern States Power Company, Minnesota |
| References | |
| Download: ML20343A129 (4) | |
Text
From:
Kuntz, Robert Sent:
Tuesday, December 8, 2020 6:17 AM To:
Jacobson, Ronald G.; Kivi, Jeffrey L.
Cc:
Scott, Sara
Subject:
Request for Additional Information By letter dated October 30, 2020 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML20304A141) Northern States Power Company, doing business as Xcel Energy (Xcel) submitted an exemption request from the requirements related to annual force on force exercises for the Monticello Nuclear Generating Plant (Monticello) and Prairie Island Nuclear Generating Plant, Units 1 and 2 (Prairie Island). The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the request and determined that additional information is required to complete the review. The following is the NRC staffs request for additional information (RAI). During a clarification call held on December 7, 2020 it was agreed that a response to the RAI would be provided by December 22, 2020.
Robert Kuntz Senior Project Manager (Monticello, Prairie Island, and Quad Cities)
NRC/NRR/DORL/LPL3 (301) 415-3733 REQUEST FOR ADDITIONAL INFORMATION MONTICELLO NUCLEAR GENERATING PLANT DOCKET NO. 50-263 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-282 AND 50-306 EXEMPTION FROM 10 CFR 73, APPENDIX B, SECTION VI, SUBSECTION C.3.(I)(1) REGARDING ANNUAL FORCE-ON-FORCE EXERCISES DUE TO COVID-19 PANDEMIC By letter dated October 30, 2020 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML20304A141), Xcel Energy (Xcel) 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 Monticello Nuclear Generating Plant (Monticello) and the Prairie Island Nuclear Generating Plant, Units 1 and 2 (Prairie Island). This exemption would supersede the previously approved exemptions dated July 22, 2020 (ADAMS Accession No. ML20184A013), to restore compliance with 10 CFR Part 73, Appendix B, and the Monticello and Prairie Island Training and Qualification Plans 90
days after the public health emergency (PHE) has ended or prior to December 31, 2020, whichever occurred first.
Subsection C.3.(l)(1) requires, in part, 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.
Xcel stated that the PHE has not ended and continues to impact its ability to conduct annual FOF exercises at Monticello and Prairie Island; approval of this exemption will continue to support the isolation protocols necessary to protect essential site personnel; and these restrictions are needed to ensure personnel are isolated from the COVID-19 disease and remain capable of maintaining plant security.
Regulatory Basis 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, 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.
Issue In its October 30, 2020, request, Xcel did not provide site-specific condition(s) to justify the exemptions for Monticello and Prairie Island.
Request Provide information on the site-specific condition(s), including site-specific COVID-19-related impacts, that prevent Monticello and Prairie Island from completing their CY 2020 annual FOF exercises prior to December 31, 2020.
Hearing Identifier:
NRR_DRMA Email Number:
920 Mail Envelope Properties (SJ0PR09MB6528AFC022AE161B45EEDEDB99CD0)
Subject:
Request for Additional Information Sent Date:
12/8/2020 6:16:52 AM Received Date:
12/8/2020 6:16:52 AM From:
Kuntz, Robert Created By:
Robert.Kuntz@nrc.gov Recipients:
"Scott, Sara" <sara.scott@xcelenergy.com>
Tracking Status: None "Jacobson, Ronald G." <ronald.g.jacobson@xcelenergy.com>
Tracking Status: None "Kivi, Jeffrey L." <jeffrey.l.kivi@xcelenergy.com>
Tracking Status: None Post Office:
SJ0PR09MB6528.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 5386 12/8/2020 6:16:52 AM Options Priority:
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