ML20345A146

E-mail - Response to Request for Additional Information: HDI Request for One-Time Exemption from Part 73, Appendix B FOF Requirements

ML20345A146
Person / Time
Site:	Oyster Creek
Issue date:	12/09/2020
From:	Sterdis A Holtec Decommissioning International
To:	Cruz-Perez Z Office of Nuclear Material Safety and Safeguards
Cruz Z, NMSS/DUWP
References
HDI-OC-20-096
Download: ML20345A146 (3)

Text

From: Andrea Sterdis To: Cruz Perez, Zahira Cc: James Frank

Subject:

[External_Sender] Response to Request for Additional Information on HDI Request for Exemption due to COVID 19 Restrictions Date: Wednesday, December 09, 2020 3:12:16 PM December 9, 2020 HDI-OC-20-096 10 CFR 73.5 U.S. Nuclear Regulatory Commission, Project Manager, NMSS - Oyster Creek Nuclear Generating Station Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 Docket No. 50-219 and 72-15

Subject:

Response to Request for Additional Information on Request for a One-Time Exemption from 10 CFR 73, Appendix B, Section VI, Subsection C.3.(I)(1)

Regarding Annual Force-on-Force (FOF) Exercises, Due to COVID 19 Pandemic

Reference:

1. NRC Letter to Holtec Decommissioning International, "Request for Additional Information - Request for a One Time Exemption from 10 CFR Part 73, Appendix B, Section VI, Regarding Annual Force-on-Force Exercises, Due to COVID-19 Pandemic, dated November 30, 2020 By letter dated November 20, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20325A235), 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 Oyster Creek Nuclear Generating Station (OCNGS).

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the request and has determined that a response to the following request for additional information (RAI) is needed to complete its review (Reference 1).

Requested Information:

RAI:

The NRC staff requests that HDI provide additional site-specific information as to why the licensee is unable to conduct make-up FOF exercises due to continuing COVID-19 PHE and New Jersey state of emergency declaration. Certain considerations for site impacts were previously outlined in Enclosure C to the NRC letter to NEI dated April 20, 2020 (ADAMS Accession No. ML20105A483).

HDI Response to RAI Oyster Creek Generating Station is unable to conduct the 2020 CY FOF exercises due to:

Holtec infectious disease transmission prevention strategies, State of New Jersey 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 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

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