View source for L-20-311, Response to Request for Additional Information Regarding Request for Exemption - Part 73 Force-on-Force

{{Adams
| number = ML20335A531
| issue date = 11/25/2020
| title = Response to Request for Additional Information Regarding Request for Exemption - Part 73 Force-on-Force
| author name = Penfield R
| author affiliation = Energy Harbor Nuclear Corp
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000440
| license number = NPF-058
| contact person = 
| case reference number = EPID L-2020-LLE-0176, L-20-311
| document type = Letter type:L, Response to Request for Additional Information (RAI)
| page count = 4
| project = EPID:L-2020-LLE-0176
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Energy Harbor Nuclear Corp.
Perry Nuclear Power Plant 10 Center Road P.O. Box 97 Perry, Ohio 44081 Rod L. Penfield                                                                   440-280-5382 Site Vice President, Perry Nuclear November 25, 2020 L-20-311 10 CFR 73.5 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555

==SUBJECT:==

Perry Nuclear Power Plant, Unit No. 1 Docket No. 50-440, License No. NPF-58 Response to Request for Additional Information Regarding Request for Exemption -
Part 73 Force-on-Force (EPID: L-2020-LLE-0176)
By {{letter dated|date=October 29, 2020|text=letter dated October 29, 2020}} (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20304A191), 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.(l)(1) for the Perry Nuclear Power Plant, Unit No. 1 (PNPP).
By electronic mail dated November 20, 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, Rod L. Penfield

==Attachment:==

Response to Request for Additional Information

Perry Nuclear Power Plant L-20-311 Page 2 cc:   NRC Region III Administrator NRC Resident Inspector NRR Project Manager

Attachment L-20-311 Response to Request for Additional Information Page 1 of 2 By {{letter dated|date=October 29, 2020|text=letter dated October 29, 2020}} (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20304A191), 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.(l)(1) for the Perry Nuclear Power Plant, Unit No. 1 (PNPP).
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.
RAI-NSIR-01 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 that licensees that have previously been granted a temporary exemption from the annual FOF exercise requirement should submit the following information:
x    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; or

Attachment L-20-311 Page 2 of 2 Describe the site-specific condition(s), including site-specific COVID-19-related impacts, that will prevent the EHNC and PNPP from completing its CY 2020 annual FOF exercise prior to December 31, 2020.

===Response===
The PNPP pandemic plan has impacted the stations ability to perform annual FOF exercises safely due to the following:
* Site personnel have tested positive for the virus and additional personnel have been quarantined since inception of the pandemic at various levels within the organization.
* The rate of infection has increased in the state of Ohio as well as in Lake County where PNPP 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.(l)(5); Tactical response drills and force-on-force exercises are conducted safely and in accordance with site safety plans.}}