ULNRC-06582, Security Training Exemption Request Due to COVID-19

Security Training Exemption Request Due to COVID-19

ML20156A192
Person / Time
Site:	Callaway
Issue date:	06/04/2020
From:	Mclachlan M Ameren Missouri, Union Electric Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML20156A191	List: ULNRC-06582, Security Training Exemption Request Due to COVID-19
References
ULNRC-06582
Download: ML20156A192 (4)

Text

Aiiiere MISSOURI n Callaway Plant SENSITIVE INFORMATION WITHHOLD UNDER 10 CFR 2.390(a)(4)

June 4, 2020 ULNRC-06582 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-000 1 10 CFR 73, Appendix B, Section VI 10 CFR 73.5 Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

RENEWED FACILITY OPERATING LICENSE NPF-30 SECURITY TRAINING EXEMPTION REQUEST DUE TO COVID-19

Reference:

EGM 20-002, Enforcement Guidance Memorandum Dispositioning Violations of NRC Requirements during Coronavirus Disease 2019 (COVID-19), April 15, 2020 On January 3 1 2020, the U.S. Department of Health and Human Services declared a public health emergency (PHE) for the United States to aid the nations healthcare community in responding to the Coronavirus Disease 2019 (COVID-19). On March 13, 2020, the Governor ofthe State of Missouri declared a state of emergency. In addition, on March 1 1, 2020, the COVID-19 outbreak was characterized as a pandemic by the World Health Organization, and on March 13, 2020, the President of the United States of America declared the Coronavirus (COVID-19) pandemic a national emergency. In response to these declarations and in accordance with Ameren Missouris pandemic response plan, some Callaway Plant (Callaway) activities have been postponed due to isolation actions and activities (for example, social distancing, group size limitations, self-quarantining, and the possibility of isolating required station personnel to protect and maintain necessary staffing levels).

Consequently, it is necessary for Ameren Missouri to request a certain temporary exemption to the Code of Federal Regulations (CFR), for Callaway, as described in the enclosure to this letter.

Specifically, as a result of the Coronavirus Disease 2019 (COVID-19) public health emergency (PHE),

Callaway expects that it will no longer be able to comply with the requirements of 10 CFR Part 73, Appendix B, Section VI Subsection E. 1 .(f) Weapons range activities on a nominal 4-month Enclosure to this letter contains sensitive information.

Withhold from public disclosure under 10 CFR 2.390(a)(4).

Upon removal of Enclosure, this letter is uncontrolled.

SENSITIVE INFORMATION - WITHHOLD UNDER 10 CFR 2.390(a)(4)

::  : E :;::::.:..

$315 County Road 459

.-,,  ::.::::::::::::.: Steedman, MO 65077 AmerenMissouri.com

ULNRC-06582 June 4, 2020 Page 2 of 4 periodicity. Callaway will implement site specific COVID- 1 9 P1-fE training requalification controls consistent with those outlined in the Reference letter (identified above) and its enclosures.

The enclosure provides details on the required security exemption request for Callaway. Ameren Missouri requests a temporary exemption from the security training requalification requirement identified in the enclosure. No exemption is requested for initial training. Granting of the requested exemption will allow deviation from the associated items in the Callaway Training and Qualification Plan. This temporary exemption supports the isolation restrictions (e.g., social distancing, group size limitations, self-quarantining, etc.) necessary to protect required site personnel in response to the 2020 COVID- 19 virus. These restrictions are needed to ensure personnel are isolated from the COVID- 19 virus and remain capable of maintaining plant security. Callaway implemented isolation restrictions for site personnel on March 17, 2020.

In accordance with the provisions of 10 CFR 73.5, and consistent with the conditions specified in the EGM-20-002 (Reference), Callaway is requesting exemption from the requirements of Appendix B to Part 73 as identified in the enclosure, along with the associated items in the Callaway Training and Qualification Plan. Callaway will begin implementing its site-specific COVID- 19 PHE controls for managing personnel performing Security Program duties on June 22, 2020, or upon NRC approval.

The enclosure provides justification.

This letter does not contain new commitments.

If there are any questions, please contact Billy Brown at (3 14) 203-3629.

Sincerely,

/)41A Mark McLachlan Senior Director, Plant Support Enclosure Security Training Requalification Exemption Request Justification

ULNRC-06582 June 4, 2020 Page 3 of 4 cc: Mr. Scott A. Morris Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. L. John Kios Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 09E3 Washington, DC 20555-0001

ULNRC-06582 June 4, 2020 Page 4 of 4 Index and send hardcopy to QA File A160.0761 Hardcopy:

Certrec Corporation 6100 Western Place, Suite 1050 FortWorth,TX 76107 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Other Situations ULNRC Distribution:

F. M. Diya M. A. McLachlan B. L. Cox F. J. Bianco S. P. Banker R. C. Wink T. B. Elwood B. Brown NSRB Secretary STARS Regulatory Affairs Mr. Jay Silberg (Pillsbury Winthrop Shaw Pittman LLP)

Missouri Public Service Commission