ML20352A166

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Response to STPNOC Concerns Regarding the Proposed Change to the Evaluated Force-on-Force Inspection Guidance During the COVID-19
ML20352A166
Person / Time
Issue date: 12/18/2020
From: Brian Holian
Office of Nuclear Security and Incident Response
To: Capristo A
South Texas
Ruffin S
References
Download: ML20352A166 (3)


Text

December 18, 2020 Mr. Aldo Capristo Executive Vice President and CAO South Texas Project Nuclear Operating Company P.O. Box 289 Wadsworth, TX 77483

SUBJECT:

RESPONSE TO SOUTH TEXAS PROJECT NUCLEAR OPERATING COMPANY CONCERNS REGARDING THE PROPOSED CHANGE TO THE EVALUATED FORCE-ON-FORCE INSPECTION GUIDANCE DURING THE COVID-19 PUBLIC HEALTH EMERGENCY Thank you for your December 10, 2020, letter (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20345A354) and your continued engagement regarding the U.S. Nuclear Regulatory Commissions (NRC) plans for force-on-force (FOF) oversight in 2021 and the use of Temporary Instruction 2201/006, Modified Contingency Response Force-On-Force Testing of Facilities under a Local, State, or Federal Emergency Condition that Impacts Normal Site Access (TI 2201). The NRC continues to take a measured approach to ensure that we prudently carry out our oversight activities in a safe manner. As noted in my response to the Nuclear Energy Institute (NEI) dated December 11, 2020 (ADAMS Accession No. ML20339A666), given the limitations associated with assessment under inspection procedure (IP) 92707 and the lessons learned from its implementation, we believe the most appropriate path forward is to implement TI 2201 or return to the IP 71130.03 framework at an appropriate time. It is important to conduct FOF exercises that are as realistic and risk-informed as conditions permit.

The NRC does not plan to schedule TI 2201 inspections in the first quarter of calendar year (CY) 2021 unless specifically requested by a licensee. This practice will not only provide time for surge conditions associated with COVID-19 to be further assessed, but will also allow additional time for the NEI-provided mock adversary force to conduct preparatory activities to resume inspections. Conditions permitting, NRC will conduct planning week activities (i.e., A week activities) for TI 2201 beginning in the second quarter of CY 2021. These activities have a similar footprint to the IP 92707 activities. The NRC will tentatively schedule exercise week activities (i.e., B week activities) for TI 2201 beginning in summer 2021. We recognize that sites have many priorities to manage in CY 2021, and we will use the information contained in the reactor program system, along with feedback obtained through frequent communications with each site to identify inspection dates. The team lead for South Texas Projects 2021 inspection has conducted outreach to reschedule your inspection activities consistent with this framework.

A. Capristo 2

Please feel free to contact me or have your staff contact David Bradfield, Team Lead, Security Performance Evaluation Branch, Division of Security Operations, David.Bradfield@nrc.gov, or 301-287-3732, if you have any questions or need additional information.

Sincerely,

/RA Brian E. Holian, Director Office of Nuclear Security and Incident Response

A. Capristo 3

SUBJECT:

RESPONSE TO SOUTH TEXAS PROJECT NUCLEAR OPERATING COMPANY CONCERNS REGARDING THE PROPOSED CHANGE TO THE EVALUATED FORCE-ON-FORCE INSPECTION GUIDANCE DURING THE COVID-19 PUBLIC HEALTH EMERGENCY DATE:

December 18, 2020 DISTRIBUTION:

PUBLIC M. Doane, OEDO D. Dorman, OEDO M. Lombard, NSIR S. Lee, NSIR H. Nieh, NRR S. Morris, RIV J. Monninger, RIV R. Lantz, RIV ADAMS Accession No. ML20352A166 OFFICE NSIR/DSO NSIR/DSO NSIR NAME S Ruffin S. Atack B. Holian DATE 12/17/2020 12/17/2020 12/18/2020