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Category:Letter
MONTHYEARIR 05000498/20240022024-08-0909 August 2024 Integrated Inspection Report 05000498/2024002 and 05000499/2024002 IR 05000498/20240102024-08-0808 August 2024 Biennial Problem Identification and Resolution Inspection Report 05000498/2024010 and 05000499/2024010 NOC-AE-240040, Application for Order Consenting to Direct Transfer of Licenses2024-07-31031 July 2024 Application for Order Consenting to Direct Transfer of Licenses ML24218A1462024-07-26026 July 2024 2. EPA Comments on South Texas Project Exemption Ea/Fonsi ML24207A1782024-07-25025 July 2024 Licensed Operator Positive Fitness-For-Duty Test IR 05000498/20244042024-06-0303 June 2024 Cyber Security Inspection Report 05000498/2024404 (Cover Letter) ML24141A0482024-05-17017 May 2024 EN 56958_1 Ametek Solidstate Controls, Inc ML24136A2842024-05-15015 May 2024 Independent Spent Fuel Storage Installation Supplement to Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance ML24136A2872024-05-15015 May 2024 Submittal of 2024 Nrc/Fema Evaluated Exercise Scenario Manual NOC-AE-240040, Operator Licensinq Examination Schedule Revision 32024-05-15015 May 2024 Operator Licensinq Examination Schedule Revision 3 ML24128A1572024-05-0707 May 2024 Independent Spent Fuel Storage Installation Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance IR 05000498/20240012024-05-0606 May 2024 Integrated Inspection Report 05000498/2024001 & 05000499/2024001 ML24116A3032024-04-25025 April 2024 Operations Quality Assurance Plan Condition Adverse to Quality Definition Change Resulting in a Reduction in Commitment ML24116A2282024-04-25025 April 2024 Annual Environmental Operating Report ML24117A1602024-04-24024 April 2024 2023 Radioactive Effluent Release Report ML24102A2452024-04-23023 April 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0046 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML24113A3122024-04-22022 April 2024 Cycle 24 Core Operating Limits Report NOC-AE-240040, Relief Request Number RR-ENG-4-07 – Request for an Alternative to ASME Code Case N-729-6 for Reactor Vessel Head Penetration 752024-04-0606 April 2024 Relief Request Number RR-ENG-4-07 – Request for an Alternative to ASME Code Case N-729-6 for Reactor Vessel Head Penetration 75 NOC-AE-240040, Financial Assurance for Decommissioning - 2024 Update2024-03-28028 March 2024 Financial Assurance for Decommissioning - 2024 Update ML24081A3972024-03-21021 March 2024 Response to Request for Additional Information for Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML24080A2902024-03-19019 March 2024 Nuclear Liability Certificates of Insurance ML24079A1312024-03-0505 March 2024 Nuclear Insurance Protection ML24060A1742024-02-28028 February 2024 Submittal of Annual Fitness for Duty Performance Report for 2023 IR 05000498/20230062024-02-28028 February 2024 Annual Assessment Letter for South Texas Project Electric Generating Station, Units 1 and 2 (Report 05000498/2023006 and 05000499/2023006) IR 05000498/20240132024-02-27027 February 2024 Design Basis Assurance Inspection (Programs) Commercial Grade Dedication IR 05000498/2024013 and 05000499/2024013 ML24050A0082024-02-19019 February 2024 Evidence of Financial Protection ML24045A0922024-02-16016 February 2024 Response to STP FOF Move Letter (2024) NOC-AE-240040, Unit L & 2, Supplement to Modify the Implementation Date for License Amendment Request to Revise Alternate Source Term Dose Calculation2024-02-0808 February 2024 Unit L & 2, Supplement to Modify the Implementation Date for License Amendment Request to Revise Alternate Source Term Dose Calculation ML24039A1112024-02-0808 February 2024 Operator Licensing Examination Schedule Revision 2 ML24038A3342024-02-0707 February 2024 Change to South Texas Project Electric Generating Station (Stepgs) Emergency Plan ML24033A3002024-02-0707 February 2024 Summary of Regulatory Audit Regarding a Proposed Alternative to ASME Code, Section XI Requirements for Containment Building Inspections ML24029A2752024-01-29029 January 2024 Request to Reschedule Evaluated Force-on-Force Drill IR 05000498/20230042024-01-29029 January 2024 Integrated Inspection Report 05000498/2023004 and 05000499/2023004 ML24024A1162024-01-24024 January 2024 STP Unit 2 Request for Information IR 05000498/20230032023-12-28028 December 2023 Acknowledgment of Reply to a Notice of Violation (NRC Inspection Report 05000498/2023003 and 05000499/2023003) ML23360A1692023-12-26026 December 2023 FEMA, Submittal of Radiological Emergency Preparedness Final Report for the South Texas Project Medical Services Drill Evaluated on August 31, 2023 NOC-AE-230040, Supplement to Proposed Alternate Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (Relief Request RR-ENG-4-06)2023-12-14014 December 2023 Supplement to Proposed Alternate Frequency to Containment Unbonded Post-Tensioning System Inservice Inspection (Relief Request RR-ENG-4-06) NOC-AE-230039, Docket Nos. Stn 50-498, Stn 50-499 - Reply to a Notice of Violation, NRC Inspection Report 05000498/2023003 and 05000499/20230032023-12-12012 December 2023 Docket Nos. Stn 50-498, Stn 50-499 - Reply to a Notice of Violation, NRC Inspection Report 05000498/2023003 and 05000499/2023003 ML23339A1902023-12-0505 December 2023 Update Foreign Ownership, Control, or Influence (FOCI) ML23326A2592023-12-0505 December 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report IR 05000498/20234012023-12-0404 December 2023 Security Baseline Inspection Report 05000498/2023401 and 05000499/2023401 ML23324A0102023-11-16016 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23310A2282023-11-13013 November 2023 Integrated Inspection Report 05000498/2023003 and 05000499/2023003, and Notice of Violation ML23311A2082023-11-0909 November 2023 Reassignment of U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch IV ML23298A0002023-11-0101 November 2023 the Associated Independent Spent Fuel Storage Installation - Issuance of Amendment Nos. 226 and 211 Related to Order Approving Indirect Transfer of Licenses and Conforming License Amendments ML23279A0342023-10-30030 October 2023 Associated Independent Spent Fuel Storage Installation - Order Approving Indirect Transfer of Licenses and Draft Conforming License Amendments (EPID L-2023-LLM-0004) (Letter) ML23303A0782023-10-30030 October 2023 Submittal of Supplemental Information in Response to Order Consenting to License Transfers and Approval of Draft Conforming License Amendments IR 05000498/20234032023-10-26026 October 2023 Material Control and Accounting Program Inspection Report 05000498/2023403 and 05000499/2023403 (Cover Letter) ML23317A1262023-10-12012 October 2023 South. Texas Project Physical Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program Revision 26 ML23279A1382023-10-0505 October 2023 Responses to Requests for Additional Information Related to Application for Order Approving Indirect Transfer of Control of Licenses 2024-08-09
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December 10, 2020 NOC-AE-20003777 STI: 35106173 Brian Holian Director, Office of Nuclear Security and Incident Response U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 STPNOC Concerns Regarding the Proposed Change to the Evaluated Force-on-Force Inspection Guidance during the COVID-19 Public Health Emergency
References:
- 1. Letter from Douglas E. True, Nuclear Energy Institute (NEI) to Brian Holian, NRC; NRC Evaluated Force-on-Force (FOF) Program during the Public Health Emergency; December 1, 2020
- 2. Draft Temporary Instruction (TI) 2201/006; Modified Contingency Response -
Force-On-Force Testing of Facilities Under a Local, State, or Federal Emergency Condition that Impacts Normal Site Access
- 3. Inspection Procedure (IP) 92707; Security Inspection of Facilities Impacted by a Local, State, or Federal Emergency where the NRCs Ability to Conduct Triennial Force-on-Force Exercises is Limited; effective date August 7, 2020 As stated in Reference 1, the industry was informed that the NRC Nuclear Security and Incident Response (NSIR) staff intends to implement a new Force-on-Force (FOF) Temporary Instruction (TI) 2201/006 (Reference 2) at the beginning of 2021 to replace the current Inspection Procedure (IP) 92707 (Reference 3). STP Nuclear Operating Company (STPNOC) has a scheduled FOF inspection early next year and has several concerns with the planned TI implementation timeframe due to the ongoing Public Health Emergency (PHE).
STPNOC has implemented a comprehensive pandemic response plan that has proven to be effective in minimizing the potential for infection of essential nuclear workers onsite. STPNOCs protective measures include minimizing site access to avoid the introduction of COVID-19 from outside. In response to the COVID-19 PHE, the nuclear industry worked with the NRC to devise interim inspection procedure IP 92707 (Reference 3). IP 92707 has been performed 17 times in 2020 to demonstrate site security capabilities while minimizing additional COVID-19 risk to the site.
IP 92707 has been proven to meet the FOF inspection objectives while helping to prevent the spread of the COVID-19 virus.
Implementation of the draft TI 2201/006 guidance would require additional personnel onsite and in close proximity to each other, placing the participating onsite personnel from both STP and NRC at a higher risk of COVID-19 transmission and potentially causing STPNOC to alter and diminish our existing and effective site rules to continue to prevent the spread of the virus.
NOG-AE-20003777 Page 2 of2 STPNOG has been preparing for the upcoming inspection using IP 92707 in our pre-inspection preparations and planning activities. Based on discussions at previous NRG public meetings, STPNOG understood that the IP 92707 process would be used until at least the end of the first quarter of 2021, and possibly until the end of the declared PHE. NRG's current approach of implementing the draft Tl 2201/006 at the beginning of 2021 would subject STPNOG to a new industry inspection standard that, as of the date of this letter, is not yet finalized. Such a plan appears contrary to several of NRG's stated values and principles of good regulation by implementing such an urgent change to existing, effective and understood inspection guidance without allowing sufficient time for inspection preparations or for making changes to our pandemic response plan due to the additional personnel Tl 2201/006 requires.
STPNOG requests that the NRG maintain the current planned FOF inspection schedule for our station using the guidance in IP 92707. The STPNOG inspection schedule and key events calendar are already backlogged from prior 2020 PHE related schedule changes in addition to our pre-existing 2021 commitments. Rescheduling the STPNOG FOF inspection later in 2021 is not preferred as it will likely cause conflict with our existing long list of scheduled activities.
STPNOG fully agrees and supports the recommendations of the referenced Nuclear Energy Institute (NEI) letter (Reference 1) and strongly recommends that the NRG continue the use of the current inspection procedure, IP 92707, for the foreseeable future as the PHE continues to pose challenges to our normal conduct of business.
STP respectfully requests clarity and a final decision on our inspection standard as soon as possible so we can properly prepare our site and Security force appropriately.
There are no commitments in this letter.
If there are any questions regarding this matter, please contact Wendy Brost at (361) 972-8516 or me at (361) 972-7697.
Aldo Capristo Executive Vice President and Chief Administrative Officer web cc:
Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlington , TX 76011-4511 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001