L-20-092, Email Pilgrim Nuclear Power Station-Exemption from Annual Force-On-Force Exercise Requirements of 10 CFR Part 73, Appendix B,

Email Pilgrim Nuclear Power Station-Exemption from Annual Force-On-Force Exercise Requirements of 10 CFR Part 73, Appendix B,

ML20345A199
Person / Time
Site:	Pilgrim
Issue date:	12/10/2020
From:	Sterdis A Holtec Decommissioning International
To:	Amy Snyder Office of Nuclear Material Safety and Safeguards
A Snyder, NMSS/DUWP
Shared Package
ML20345A329	List: L-20-092, Email Pilgrim Nuclear Power Station-Exemption from Annual Force-On-Force Exercise Requirements of 10 CFR Part 73, Appendix B,
References
HDI-PIL-20-092
Download: ML20345A199 (2)

Text

From: Andrea Sterdis To: Snyder, Amy Cc: Dave Noyes

Subject:

[External_Sender] Supplemental Information to Support Request for a One Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3, (l)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to COVID 19 Pandemic Date: Thursday, December 10, 2020 11:17:08 AM December 10, 2020 HDI-PIL-20-092 10 CFR 73.5 Attn: U.S. Nuclear Regulatory Commission, Project Manager, NMSS - Pilgrim Nuclear Power Station Pilgrim Nuclear Power Station Renewed Facility License No. DPR-35 NRC Docket No. 50-293 and 72-1044

Subject:

Supplemental Information to Support Request for a One Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3,(l)(1) Regarding Annual Force-on-Force (FOF) Exercises, Due to COVID 19 Pandemic

Reference:

1. Letter from Andrea L. Sterdis (Holtec Decommissioning International) to U.S. Nuclear Regulatory Commission, Request for a One-Time Exemption from 10 CFR 73,Appendix B,Section VI, Subsection C.3(l)(1)

Regarding Annual Force-on-Force (FOF) Exercises Due to COVID 19 Pandemic, November 20, 2020 (ML20325A342)

By letter dated November 20, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20325A342), Holtec Decommissioning International, LLC (HDI) requested an exemption from Title 10 of the Code of Federal Regulations (10 CFR) Part 73, Appendix B,Section VI, subsection C.3.(l)(1), regarding the annual force-on-force (FOF) exercises for calendar year 2020 at Pilgrim Nuclear Power Station (PNPS).

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the request and has determined that additional information is needed to complete its review.

This letter provides the additional information to support why Pilgrim Nuclear Power Station (PNPS) is unable to conduct the calendar year 2020 FOF exercises due to the continuing COVID-19 Public Health Emergency (PHE) and Commonwealth of Massachusetts emergency declaration.

PNPS is unable to conduct the 2020 CY FOF exercises due to: Holtec infectious disease transmission prevention strategies, Commonwealth of Massachusetts restrictions, and CDC recommendations. Specifically, drill and exercise evolutions require three teams, along with personnel from other sites, to be onsite and within close proximity during briefings, conduct of the drills, and critiques. Examples of individuals in close proximity are personnel collocated in Bullet Resistant Enclosures (BREs) and Alarm Stations that do not lend themselves to adequate social distancing for the on-duty officer, drill play officer, and the controller.

This letter contains no new regulatory commitments.

Should you have any questions or require further information, please contact me at (856) 797-0900, x3813.

Respectfully, Andrea L. Sterdis Andrea L. Sterdis Vice President Regulatory and Environmental Affairs Holtec Decommissioning International (HDI)

Krishna P. Singh Campus 1 Holtec Blvd.

Camden, NJ 08104 A.Sterdis@Holtec.com Tel: (856)797-0900, x3813 Mobile: +1 (724)493-1833 Holtec Logo-EmailSignature The information contained herein is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material from Holtec International. If you are not the intended recipient, you must not keep, use, disclose, copy or distribute this email without the author's prior permission. Further, review, retransmission, dissemination, or other use of this information in whole or part for any other purpose by persons outside the recipient's organization is strictly prohibited unless explicit authorization to such effect has been issued by the sender of this message. Holtec International policies expressly prohibit employees from making defamatory or offensive statements and infringing any copyright or any other legal right by Email communication. Holtec International will not accept any liability in respect of such communications. Holtec International has taken precautions to minimize the risk of transmitting software viruses, but we advise you to carry out your own virus checks on any attachment to this message. Holtec International cannot accept liability for any loss or damage caused by software viruses. If you are the intended recipient and you do not wish to receive similar electronic messages from us in the future then please respond to the sender to this effect.