ML20323A407

NRR E-mail Capture - Request for Additional Information - Brunswick License Exemption Request from 10CFR73 Annual Force on Force Exercise Requirements (EPIC L-2020-LLE-0180)

ML20323A407
Person / Time
Site:	Oconee, Mcguire, Catawba, Harris, Brunswick, Robinson, McGuire
Issue date:	11/18/2020
From:	Andrew Hon NRC/NRR/DORL/LPL2-2
To:	Grzeck L, Zaremba A Duke Energy Carolinas
References
L-2020-LLE-0180
Download: ML20323A407 (4)

Text

From: Hon, Andrew Sent: Wednesday, November 18, 2020 11:58 AM To: Grzeck, Lee; Zaremba, Arthur H.

Subject:

Request for additional information - Brunswick License Exemption Request from 10CFR73 Annual Force on Force Exercise Requirements (EPIC L-2020-LLE-0180)

By letter dated November 4, 2020 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML20310A032), Duke Energy Carolinas, LLC, and Duke Energy Progress, LLC (collectively referred to as Duke Energy), 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 Brunswick Steam Electric Plant, Units. 1 and 2, Catawba Nuclear Station, Units. 1 and 2, Shearon Harris Nuclear Power Plant, Unit 1, McGuire Nuclear Station, Units 1 and 2, Oconee Nuclear Station, Units 1, 2, and 3, and H. B. Robinson Steam Electric Plant, Unit 2. The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The proposed questions below were discussed by email with your team on November 17, 2020. Your team confirmed that the request for additional information (RAI) was understood, it does not contain sensitive information, and agreed to provide a response by November 20, 2020.

The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. Please note that if you do not respond to this request by the agreed-upon date or provide an acceptable alternate date, we may deny your application for amendment under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108. If circumstances result in the need to revise the agreed upon response date, please contact me.

Andy Hon, PE Project Manager (Brunswick Nuclear Plant 1 & 2, Duke Energy Progress Fleet)

Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301-415-8480 OWFN O8E06 Mail Stop O8B1A andrew.hon@nrc.gov

Background

By letter dated November 4, 2020 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML20310A032), Duke Energy Carolinas, LLC, and Duke Energy Progress, LLC (collectively referred to as Duke Energy), 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 Brunswick Steam Electric Plant (BNP), Units. 1 and 2, Catawba Nuclear Station (CNS), Units. 1 and 2, Shearon Harris Nuclear Power Plant (HNP), Unit 1, McGuire Nuclear Station (MNS), Units 1 and 2, Oconee Nuclear Station (ONS), Units 1, 2, and 3, and H. B. Robinson Steam Electric Plant (RNP), Unit 2.

Subsection C.3.(l)(1) requires that:

Each member of each shift who is assigned duties and responsibilities required to implement the safeguards contingency plan and licensee protective strategy participates in at least one (1) tactical response drill on a quarterly basis and one (1) force-on-force exercise on an annual basis.

Duke Energy stated that BNP, CNS, HNP, MNS, ONS and RNP will no longer be able to comply with the annual FOF exercise requirement of the specified regulation for calendar year (CY) 2020 due to the continued implementation of coronavirus 2019 (COVID-19) public health emergency (PHE) training requalification controls consistent with those recommended by the U.S. Centers for Disease Control and Prevention (CDC) and the States of North and South Carolina.

In the request, Duke Energy stated that the grace period for conducting the CY 2020 FOF exercise at all six sites expires on December 31, 2020. Duke Energy also stated that because of company pandemic response plan, some activities at all six of its nuclear sites were postponed due to proactive measures and isolation restrictions (e.g., social distancing, group size limitations, self-quarantining, etc.). Duke Energy asserted that holding FOF exercises will locate drill participants and drill controllers in close quarters (e.g., bullet resistant enclosures, defensive fighting positions, etc.), making it impractical to meet the CDC recommendations for social distancing and group-size limitations. Therefore, the isolation restrictions prevent FOF activities from being performed at all six Duke Energy stations (i.e., BNP, CNS, HNP, MNS, ONS, and RNP).

Regulatory Basis 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 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. They may also prevent licensees that did not previously request an exemption from the annual FOF exercise requirements and, therefore, are still required to complete an FOF exercise before the end of the CY, from being able to complete that exercise 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. The NRC is also prepared to expedite consideration of exemption requests from the requirement to conduct an annual FOF exercise in CY 2020 for those licensees who were not previously granted such an exemption.

This updated guidance also requests that licensees should, in addition to describing how they intend to maintain contingency response readiness, submit the following information:

• 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

• For licensees that have not previously been granted a temporary exemption from the annual FOF exercise requirement, a discussion as to why the licensee is unable to perform a CY 2020 FOF exercise before December 31, 2020, due to continuing COVID-19 PHE impacts. In support of the new exemption request, these licensees should include the information requested in Enclosure C to the April 20, 2020, letter; Issue However, in the November 4, 2020, request, Duke Energy did not provide site-specific condition(s) to justify the exemptions for each of the BNP, CNS, HNP, MNS, ONS, and RNP sites.

Request Provide information on the site-specific condition(s), including site-specific COVID-19-related impacts, that will prevent each of Duke Energys sites from completing its CY 2020 annual FOF exercise prior to December 31, 2020.

Hearing Identifier: NRR_DRMA Email Number: 898 Mail Envelope Properties (SA0PR09MB677988BE592C041742A85ABC99E10)

Subject:

Request for additional information - Brunswick License Exemption Request from 10CFR73 Annual Force on Force Exercise Requirements (EPIC L-2020-LLE-0180)

Sent Date: 11/18/2020 11:57:36 AM Received Date: 11/18/2020 11:57:36 AM From: Hon, Andrew Created By: Andrew.Hon@nrc.gov Recipients:

"Grzeck, Lee" <Lee.Grzeck@duke-energy.com>

Tracking Status: None "Zaremba, Arthur H." <Arthur.Zaremba@duke-energy.com>

Tracking Status: None Post Office: SA0PR09MB6779.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 7748 11/18/2020 11:57:36 AM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: