ML20345A354

STPNOC Concerns Regarding the Proposed Change to the Evaluated Force-on-Force Inspection Guidance During the COVID-19 Public Health Emergency

ML20345A354
Person / Time
Site:	South Texas
Issue date:	12/10/2020
From:	Capristo A South Texas
To:	Brian Holian Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-20003777, STI: 35106173
Download: ML20345A354 (2)

Text

December 10, 2020 NOC-AE-20003777 STI: 35106173 Brian Holian Director, Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 STPNOC Concerns Regarding the Proposed Change to the Evaluated Force-on-Force Inspection Guidance during the COVID-19 Public Health Emergency

References:

1. Letter from Douglas E. True, Nuclear Energy Institute (NEI) to Brian Holian, NRC; NRC Evaluated Force-on-Force (FOF) Program during the Public Health Emergency; December 1, 2020

2. Draft Temporary Instruction (TI) 2201/006; Modified Contingency Response -

Force-On-Force Testing of Facilities Under a Local, State, or Federal Emergency Condition that Impacts Normal Site Access

3. Inspection Procedure (IP) 92707; Security Inspection of Facilities Impacted by a Local, State, or Federal Emergency where the NRCs Ability to Conduct Triennial Force-on-Force Exercises is Limited; effective date August 7, 2020 As stated in Reference 1, the industry was informed that the NRC Nuclear Security and Incident Response (NSIR) staff intends to implement a new Force-on-Force (FOF) Temporary Instruction (TI) 2201/006 (Reference 2) at the beginning of 2021 to replace the current Inspection Procedure (IP) 92707 (Reference 3). STP Nuclear Operating Company (STPNOC) has a scheduled FOF inspection early next year and has several concerns with the planned TI implementation timeframe due to the ongoing Public Health Emergency (PHE).

STPNOC has implemented a comprehensive pandemic response plan that has proven to be effective in minimizing the potential for infection of essential nuclear workers onsite. STPNOCs protective measures include minimizing site access to avoid the introduction of COVID-19 from outside. In response to the COVID-19 PHE, the nuclear industry worked with the NRC to devise interim inspection procedure IP 92707 (Reference 3). IP 92707 has been performed 17 times in 2020 to demonstrate site security capabilities while minimizing additional COVID-19 risk to the site.

IP 92707 has been proven to meet the FOF inspection objectives while helping to prevent the spread of the COVID-19 virus.

Implementation of the draft TI 2201/006 guidance would require additional personnel onsite and in close proximity to each other, placing the participating onsite personnel from both STP and NRC at a higher risk of COVID-19 transmission and potentially causing STPNOC to alter and diminish our existing and effective site rules to continue to prevent the spread of the virus.

NOG-AE-20003777 Page 2 of2 STPNOG has been preparing for the upcoming inspection using IP 92707 in our pre-inspection preparations and planning activities. Based on discussions at previous NRG public meetings, STPNOG understood that the IP 92707 process would be used until at least the end of the first quarter of 2021, and possibly until the end of the declared PHE. NRG's current approach of implementing the draft Tl 2201/006 at the beginning of 2021 would subject STPNOG to a new industry inspection standard that, as of the date of this letter, is not yet finalized. Such a plan appears contrary to several of NRG's stated values and principles of good regulation by implementing such an urgent change to existing, effective and understood inspection guidance without allowing sufficient time for inspection preparations or for making changes to our pandemic response plan due to the additional personnel Tl 2201/006 requires.

STPNOG requests that the NRG maintain the current planned FOF inspection schedule for our station using the guidance in IP 92707. The STPNOG inspection schedule and key events calendar are already backlogged from prior 2020 PHE related schedule changes in addition to our pre-existing 2021 commitments. Rescheduling the STPNOG FOF inspection later in 2021 is not preferred as it will likely cause conflict with our existing long list of scheduled activities.

STPNOG fully agrees and supports the recommendations of the referenced Nuclear Energy Institute (NEI) letter (Reference 1) and strongly recommends that the NRG continue the use of the current inspection procedure, IP 92707, for the foreseeable future as the PHE continues to pose challenges to our normal conduct of business.

STP respectfully requests clarity and a final decision on our inspection standard as soon as possible so we can properly prepare our site and Security force appropriately.

There are no commitments in this letter.

If there are any questions regarding this matter, please contact Wendy Brost at (361) 972-8516 or me at (361) 972-7697.

Aldo Capristo Executive Vice President and Chief Administrative Officer web cc:

Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlington , TX 76011-4511 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001