L-20-257, Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic

Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic

ML20266G336
Person / Time
Site:	Beaver Valley
Issue date:	09/22/2020
From:	Penfield R Energy Harbor Nuclear Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-20-257
Download: ML20266G336 (29)

Text

energy Energy Harbor Nuclear Corp.

harbor Beaver Valley Power Station P. 0. Box4 Shippingport, PA 15077 Rod L. Penfield 724-682-5234 Site Vice President, Beaver Valley Nuclear September 22, 2020 L-20-257 10 CFR 50.12 10 CFR 50, Appendix E ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic In accordance with 10 CFR 50.12, "Specific exemptions," Energy Harbor Nuclear Corp.

requests an exemption for Beaver Valley Power Station, Unit Nos. 1 and 2 (BVPS), from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c. Specifically, Energy Harbor Nuclear Corp. requests a one-time exemption to exclude the participation of the offsite response organization (ORO) in the biennial emergency preparedness exercise for calendar year (CY) 2020.

On January 31, 2020, the U.S. Department of Health and Human Services declared a public health emergency for the United States to aid the nation's healthcare community in responding to the Coronavirus Disease 2019 (COVID-19). On March 11, 2020, the COVID-19 outbreak was characterized as a pandemic by the World Health Organization and, on March 13, 2020, the President of the United States of America declared the COVID-19 pandemic a national emergency. In addition, the Commonwealth of Pennsylvania, State of Ohio, State of West Virginia and local governmental jurisdictions have issued directed health measures.

In response to these declarations, and in accordance with the corporate pandemic response plan, Energy Harbor Nuclear Corp. has postponed some site activities due to isolation activities (for example, social distancing, group size limitations, self-quarantining, and so on). The BVPS biennial emergency preparedness exercise, previously scheduled to be conducted on June 9, 2020, was postponed until November 10, 2020 due to the COVID-19 public health emergency.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-20-257 Page 2 The ongoing threat of COVID-19 spread has resulted in the inability to safely conduct the November 10, 2020 exercise with full ORO participation. The Commonwealth of Pennsylvania, on behalf of Beaver County (the county in which BVPS is located) and support counties; the State of Ohio; Columbiana County (Ohio); the State of West Virginia; and Hancock County (West Virginia) have communicated to Energy Harbor Nuclear Corp. that they have concerns with supporting the biennial exercise and maintaining protection of their staff during the current COVID-19 pandemic response.

Conducting the BVPS biennial emergency preparedness exercise in CY 2020 without ORO participation places the exercise outside of the requirement of 10 CFR 50, Appendix E, Section IV.F.2.c. Consequently, Energy Harbor Nuclear Corp. requests a one-time exemption to exclude the participation of the ORO in the biennial emergency preparedness exercise in CY 2020.

In accordance with the provisions of 10 CFR 50.12, Energy Harbor Nuclear Corp. is requesting exemption from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c, for BVPS. Justification for the issuance of an exemption is provided in Enclosure A and is based on the guidance provided in the Nuclear Regulatory Commission (NRC) letter to the Nuclear Energy Institute (NEI) dated May 14, 2020, "U.S. Nuclear Regulatory Commission Planned Actions Related to Emergency Preparedness Biennial Exercise Requirements for All Licensees During the Coronavirus Disease 2019 Public Health Emergency" (Accession No. ML20120A003) and the addendum dated September 2, 2020, "Addendum to U.S. Nuclear Regulatory Commission Planned Actions Related to Emergency Preparedness Biennial Exercise Requirements for Power Reactor Licensees During the Coronavirus Disease 2019 Public Health Emergency" (Accession No. ML20223A152). A letter of support from the Commonwealth of Pennsylvania, on behalf of Beaver County and support counties, is provided in Enclosure B. Letters of support from the State of Ohio, Columbiana County (Ohio), the State of West Virginia, and County of Hancock (West Virginia) are provided in Enclosures C, D, E, and F, respectively. Because the dry-run of the biennial exercise is scheduled for October 15, 2020, approval of the proposed exemption is requested by October 13, 2020.

There are no regulatory commitments contained in this submittal. If there are any questions, or if additional information is required, please contact Mr. Phil H. Lashley, Manager - Fleet Licensing, at (330) 696-7208.

Beaver Valley Power Station , Unit Nos. 1 and 2 L-20-257 Page 3

Enclosures:

A. Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirement B. Letter of Support from Commonwealth of Pennsylvania C. Letter of Support from State of Ohio D. Letter of Support from Columbiana County E. Letter of Support from State of West Virginia F. Letter of Support from Hancock County cc: NRC Region I Administrator NRC Resident Inspector NRR Project Manager Director BRP/DEP Site BRP/DEP Representative

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pennsylvania EMERGENCY MANAGEMENT AGENCY August 26, 2020 Mr. Steve Sawtschenko Manager, Emergency Response and Regulatory Compliance Energy Harbor - Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, Pennsylvania 15077

Dear Mr. Sawtschenko:

The Pennsylvania Emergency Management Agency (PEMA) has received letters from the Beaver Valley Power Station (BVPS) risk and support counties regarding their federally-evaluated Plume Exercise scheduled for Tuesday, November 10, 2020. Their letters express concerns on conducting an exercise during the COVID-19 pandemic. PEMA would like to request a waiver from the Nuclear Regulatory Commission (NRC), on behalf of the risk and support counties and offsite response organizations from the BVPS Plume Exercise in accordance with 10 CFR 50, Appendix E, Paragraph F.2.c, "ojfsite plans for each site shall be exercised biennially with full participation by each ojfsite authority having a role under the radiological response plan. Where the ojfsite authority has a role under a radiological response plan for more than one site, it shall fully participate in one exercise every two years and shall at least, partially participate in other ojfsite plan exercises in this period. If two different licensees each have licensed facilities located either on the same site or on adjacent, contiguous sites, and share most of the elements defining co-located licensees, then each licensee shall ... '

Beaver Valle Power Station

• Rescheduled from 06/09/2020 We offer the following specific points in support of our waiver request:

1. Ongoing Pandemic - The COVID-19 pandemic remains a significant threat and the nation remains under a Public Health Emergency which was originally declared by the US Secretary of Health and Human Services on January 31 and renewed on April 21 and again on July 25. In the Commonwealth, as of the date of this correspondence we have a total of 129,048 cases of COVID-19 since the crisis began. Pennsylvania currently ranks #12 in the nation in case counts, and we continue to add hundreds of new cases each day despite the mitigation attempts that remain in place and continued public emphasis on universal use of face coverings/masks, hygiene practices, social distancing and other limitations on gathering size and indoor occupancy limits.

We are not confident exercises can be safely conducted in the remaining months of 2020 without further spreading the virus or jeopardizing the lives of those involved in response operations from the off-site response organizations (OROs). Based on current trends and the potential for a resurgence this fall along with flu season there remains a strong possibility that this pandemic will continue well into calendar year 2021.

Pennsylvania Emergency Ma nagement Agency 1310 Elmerton Avenue I Harri sburg, PA 17 110 I 800-Hbg-PEMA I www .pema.pa .gov

Mr. Steve Sawtschenko August 26, 2020 Page 2

2. Pandemic Related Impacts Affecting the Ability to Adequately Conduct Exercises - Exercises are designed to practice plans, demonstrate capabilities, and be beneficial for the players, observers, and evaluators alike. Currently, it is a severe hardship for most OROs to adequately demonstrate capabilities through an exercise. Government buildings and municipal emergency operation centers (EOCs) are closed or restricted to visitors, and many individuals continue to work from home which has been strongly encouraged by the Governor. Additionally, many emergency workers who support nuclear power plant exercises are volunteers who continue to commit time and resources to current response activities such as feeding programs and protective equipment distribution. Many of the volunteers who assist the REPP are retired emergency services or power plant personnel whose age group and potential pre-existing health issues leaves them more susceptible to developing severe complications if they would acquire COVID-19.

Virtual capabilities are limited in many of the municipalities and in-person training has been at a standstill due to social distancing and gathering restrictions imposed by the Pennsylvania Governor's Office and Department of Health (DOH). Conducting an exercise during these current conditions would not be beneficial to anyone but would likely put people in harm's way unnecessarily. Just one person contracting COVID-19 and possibly dying due to an exercise is something Pennsylvania will not condone.

3. Travel, Gathering and Budget Restrictions Impacting Ability to Adequately Conduct Exercises - Various restrictions remain in place to limit the spread of COVID-19 or because of the financial impacts related to the COVID-19 crisis that would limit the ability to conduct exercises. The information below outlines some of those restrictions and impacts.

• Travel Restrictions - Per the Governor' s Office, Pennsylvania state employees are not permitted to travel unless it is deemed necessary. PEMA and the Department of Environmental Protection's (DEP) Bureau of Radiation Protection (BRP) does not know when this restriction will be lifted or if exercise travel requests would be approved. PEMA has concerns with sending staff to multiple locations for an exercise. Some of the exercises involve a significant amount of agency personnel and would potentially unnecessarily risk exposure to COVID-19 since they may be conducting exercises in counties with active COVID-19 outbreaks and community transmission of the virus. Additionally, any FEMA evaluators traveling from outside of the Commonwealth may be subject to a 14-day self-isolation period if travelling from a known hot-spot state. The list of hot-spot states is updated weekly by DOH, so this may adversely impact the ability for evaluators to evaluate specific exercise components on sh011 notice.

• Budget/Financial Restrictions - Commonwealth employees are not permitted to expend costs at this time unless deemed necessary and pre-approved because of state budget impacts associated with the COVID-19 crisis. Though the REPP is funded by Act 147, requests still need to be approved by the Governor' s Office. Without approval, PEMA and BRP employees cannot travel, attend or conduct training, or acquire lodging.

Mr. Steve Sawtschenko August 26, 2020 Page 3

• Gathering Limitations/Restrictions - Currently event or gathering size is limited to 25 individuals for indoor environments which would impact the ability to conduct in-person or hands-on training, exercises, or conduct demonstrations of specific response procedures.

4. Previous Exercise History - BVPS Emergency Planning Zone (EPZ) had successful demonstrations during their last three exercises within the eight-year cycle as per their After-Action Report (AAR) written by FEMA. BVPS EPZ, which exercises 100 percent of their risk and support counties (Allegheny, Beaver, Butler, Lawrence, and Washington) and municipalities every exercise, last conducted a plume exercise on June 12, 2018. BVPS also participated in an IPX on March 12, 2019, that included not only the risk and support counties but also a total of seven ingestion counties (Armstrong, Clarion, Fayette, Greene, Mercer, Venango, and Westmoreland) along with the state of West Virginia.

5. Recent EOC Activations for Risk and Support Counties - The EOCs for all the risk and support counties for BVPS EPZ have been activated at some point and to some degree for multiple operational periods since March 2020 in response to one or more incidents involving the COVID-19 pandemic, civil disturbances associated protests, or demonstrations that turned violent, or severe weather. In addition to activations for COVID-19 pandemic these incidents include the following :

• May 31 - Civil disturbance, riots and looting that impacted Philadelphia, Montgomery, Chester, Delaware and Allegheny counties.

• June 11 - Severe stonns which caused significant flooding in Schuylkill County and a tornado in Beaver County.

As you can see from the above information, all risk and support counties have demonstrated their ability to rapidly implement and adapt their all-hazards Emergency Operations Plans (EOPs), as needed, to respond and recover from multiple impacts within the last six months as well as remain ready and able to respond as needed to any incident at a nuclear power plant in their jurisdiction. Many of these real-world responses have been complicated by the COVID-19 crisis which has created a complex operating environment. Even while responding to the pandemic and other emergencies, the risk and support counties have been in constant communication with their REP Off-site Planner regarding their ability to respond should a real-world radiological incident occur.

In closing, the pandemic remains a dynamic, challenging and complex situation that requires early intervention and strict adherence to mitigation procedures when subtle changes are realized in key metrics.

As we have seen in other states recently, it only takes a short time to have exponential growth in case counts when mitigation procedures are not strictly followed, and community transmission of the virus occurs. Any unnecessary events that could potentially expose individuals to COVID-19 or propagate further transmission of the vims should be scrutinized and heavily weighed against the need to conduct them. While we have evaluated the potential of requesting exemption for exercises up until 35 months from the previous evaluated biennial exercise, we feel that approach is not addressing the issue and only serves to delay the exercise further with no guarantee that we will be able to conduct them within the specified time frame . We very well may be in the same predicament in 2021. Instead of using a wait and

Mr. Steve Sawtschen.ko August 26, 2020 Page4 see approach, we strongly urge you to let us give our OROs peace of mind to focus on the real-world pandemic at hand and save our energy and resources to support them when needed.

Enclosed you will find supporting documentation received from off-site response organizations. Should you have any questions or concerns, please contact Mr. Stephen Bekanich, Deputy Director for Preparedness, at 717-651-2231 or via email at sbekanich@pa.gov.

Sincerely,

~6L~

Director, PA Emergency Management Agency NOTE:

Enclosures:

The enclosures titled "BVPS After-Action Report from FEMA" and "Relief BVPS After-Action Report from FEMA from the Frequency Requirements Relief from the Frequency Requirements Letter and Framework Letter and Framework" are not BVPS Letters provided with the BVPS exemption request.

cc: Mr. David Linkimer, Energy Harbor-Beaver Valley Power Station













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• Beaver, PA 15009

• 724-728-3934

• www.beavercountypa.gov

Board of County Commissioners Steven R. Bicehouse, Director Leslie A. Osche, Chairman SBicehou@co.butler.pa.us Kimberly D. Geyer, Vice Chairman Kevin E. Booze!, Secretary DEPARTMENT OF EMERGENCY SERVICES Rob Mclafferty, 9-1-1 Coordinator RMcLaffert@co.butler.pa. us TSutler (!Countp 120 McCune Drive, Butler, PA 16001-3549 Emergency 911 Phone (724) 284-5211 Fax (724) 285-6388 Director Randy Padfield Pennsylvania Emergency Management Agency 1310 Elmerton Avenue Harrisburg, PA 17110 August 12, 2020 REF: BVPS 2020 Evaluated Exercise Concerns Director Padfield, I am writing to express my concerns regarding the Federally Evaluated Exercise for the Beaver Valley Power Station that is tentatively scheduled for November 10, 2020. Due to the current pandemic situation, we feel that holding an exercise of this size is not in the best interest of our participants' health and safety.

To successfully demonstrate the Emergency Operations Center portion of the exercise, County EOC staff would be required to work in close contact. As such, we would be in violation of the social distancing guidelines set by Governor Wolf as well as our building's guidelines. Many of our County EOC staff members are volunteers who also work with local and county response agencies and outside industries, which, at this time, may also limit their ability to participate.

Another concern is the Mass Care/Decon portion of the exercise that is conducted at our local school district. We are not assured access to the building with the current pandemic guidelines they are implementing including restrictions for sanitizing, screening and limited access for non-school staff.

We are confident in our preparedness for a 2020 exercise. We have met and continue to meet all training and exercise requirements and have successfully completed our required activities during past drills. The last six months have been challenging due to the COVID-19 Pandemic, which has shifted our focus from exercise preparation to "real world" planning, coordination and response. We feel that our training record and past exercise accomplishments are proof that we would be able to respond to incidents at the Beaver Valley Power Station, and we respectfully request that the 2020 exercise requirement be waived due to the existing pandemic situation.

We look forward to finding an exercise solution that will allow all parties involved to focus on safety.

Respectfully, Steven Bicehouse Director Butler County Emergency Services

COUITTY COMMISSIONERS MORGAN BOYD CHAIRMAN

-OFFICE OF- DAN VOGLER LAWRENCE COUNTY LORETTA SPIELVOGEL DEPARTMENT OF PUBLIC SAFETY STAFF 1451 COUNTY LINE ROAD CHAD STROBEL EMA DEPUTY DIRECTOR NEW CASTLE, PENNSYLVANIA 16101 csnot:>el@co.1awceoce pa,us 724-658-7485 724-658-5760 (fax) RICH HOOVER E-mail: lcema@co.lawreoce.pa.us 9-1-1 DEPUTY DIRECTOR rhoovec@co lawreoce,pa us TINA MARSHALL EMA PLANNER JEFFREY R. PARISH tmarshal!@co tawceoce.oa us DIRECTOR ioarish't, co 1;,\,TC'JJCiC no,11s FRAN OCCHIBONE ADMINISTRATIVE ASSISTANT foccbibooe@co.1awrence.oa.us August 13, 2020 Mr. David R. Padfield Pennsylvania Emergency Management Agency 1310 Elmerton Avenue Harrisburg, PA 17110 RE: BVPS 2020 Evaluated Exercise Concerns Director Padfield, I am writing to express my concerns regarding the Federally Evaluated Exercise for the Beaver Valley Power Station that is tentatively scheduled for November I 0, 2020. Due to the current pandemic situation, we feel that holding an exercise of this size is not in the best interest of our participants' health and safety.

To successfully demonstrate the Emergency Operations Center portion of the exercise, County EOC staff would be required to work in close contact. As such, we would be in violation of the social distancing guidelines set by Governor Wolfas well as our building's guidelines. Many ofour County EOC staff members are volunteers who also work with local and county response agencies and outside indust1ies, which, at this time, may also limit their ability to participate.

The more notable concern is our use of Mohawk High School for the Monitoring & Decontamination and Mass Care. The school is actively applying new COVID-19 health and safety guidelines for the students, facility, and staff. The County and School District would also need to have procedures prepared for the cleaning and sanitizing before and after the exercise. The staffing portion of the evaluation would be limited as well due to the majority of our volunteers being in the high-risk age range.

We are confident in our preparedness for a 2020 exercise. We have met and continue to meet all training and exercise requirements. However, the last six months have been challenging due to the COVID-19 Pandemic, which has shifted our focus from exercise preparation to "real world" planning, coordination and response. We feel that our training record and past exercise accomplishments are proof that we would be able to respond to incidents at the Beaver Valley Power Station, and we respectfully request that the 2020 exercise requirement be waived due to the existing pandemic situation.

We look forward to finding an exercise solution that will allow all parties involved to focus on safety.

Sine y, Jeffrey . arish Director Lawrence County Department of Public Safety

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Ohio Department of Public Safety Mike DeWlne, Governor Thomas J. Stickrath, Director Jon Husted, Lt. Governor Sima S. Merlck, Executive Director September 4, 2020 Request for cancellation of the scheduled BVPS evaluated exercise on November 10, 2020.

1. The State of Ohio, and Columbiana County is in agreement with the licensee's exemption request and we are committed to maintaining our radiological emergency plans.

2. The State of Ohio and Columbiana County are not impacted in a manner that would adversely affect our ability to maintain response capability to support emergency response activities to actual nuclear power plant radiological emergencies.

3. On June 23, 2020 during an NRC public meeting, I spoke to the fact that we have been in response mode since the initial outbreak of the pandemic and I requested that the NRC cancel all remaining REP exercises.

4. The response continues for all levels of government across the state. Thus diverting attention from this real world hazard at this time when real human life is on the line, this a risk not worth taking.

5. Throughout this pandemic response, we have been in constant communication with all of our state and local partners and most of our federal partners as well as our utility partners.

6. Ohio Governor DeWine has not changed the requirement for indoor gatherings ofless than 10 people thus severely hampering our ability to adequately respond to a training event.

7. Ohio EMA has developed a virtual response capability 'on the fly' although it works great for all state partners it has its limitations with local partners and with our utility partners so this issue is by no means resolved but in progress.

8. Due to risks involved with COVID-19 and our partners, it is not safe at this time to assemble the required personnel to effective stage and show for a training event.

9. We are fully prepared to continue to participate in all available integrated drills as these afford us the opportunity to continue to practice our dose assessment skills, executive coordination and leadership, and communication within the virtual platform.

Chris Salz,

~fyJ Ohio REP Program anager US NRC Liaison Officer Radiological Branch Chief Ohio Emergency Management Agency Department of Public Safety Emergency Management Agency (614) 889-7150 2855 West Dublin-Granville Road www.ema.ohio.gov Columbus, Ohio 43235-2712

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Columbiana C aunty Em~rgffley Manag~m~nt Ag~ncy 2 I 5 South Market Street Lisbon, Ohio 44432 Office: (330) 424-9725 Fax: (330) 424-9267 September 4, 2020 Steve Sawtschenko Manager, Regulatory Compliance and Emergency Preparedness Energy Harbor-Beaver Valley Power Station RE: 2020 Beaver Valley Evaluated Exercise Mr. Sawtschenko-We are writing to express our supp01i for Beaver Valley Power Station's request to exempt the offsite response organizations from the 2020 Federally Evaluated Exercise tentatively scheduled for November 10, 2020. Due to the current COVID-19 Public Health Emergency (PHE), we feel that holding an exercise of this size is not in the best interest of our participants' health and safety and could interfere with ongoing response to the PHE.

Columbiana County was fully trained and prepared for a dress rehearsal for the biennial Beaver Valley Power Station exercise. The dress rehearsal was scheduled for March 19 and was canceled just days before, due to the COVID 19 PHE. Training was initiated for all aspects of the County's response in order to successfully demonstrate our response capability. Since then Columbiana County has made available to our partners dozens of on-line and vii1ual training opp011unities so they can continue to stay proficient in radiological responses. Annual plan updates and revisions have continued, and the County is committed to staying prepared.

The County has continued to work towards being able to participate in the November 10, 2020 exercise. We have trimmed staff numbers to extremes and have discussed safety concerns.

However, it is becoming apparent that in order to successfully demonstrate the Emergency Operations Center response effort for the exercise, it would be nearly impossible to meet Ohio's cunent group size restrictions and distancing requirements, instituted for the COVID-19 PHE.

Columbiana County utilizes many volunteers who would be asked to push the limits or even violate these requirements. We feel that is not a reasonable request to make of our local responders, the ones on the front lines of this PHE daily, to fu1iher risk their health by gathering for an exercise. Additionally, our EOC is being utilized daily to continue to provide personal .

protective equipment to our frontline workers. Obviously, all of our emergency workers continue to work daily in response to the PHE.

Steve Sawtschenko September 4, 2020 Page 2 Due to our continued partnerships and the hard work we witness from our first responders and volunteers, we remain confident in our preparedness for a 2020 exercise and for the unlikely event of a real emergency at Beaver Valley. Obviously, things have been challenging since mid-March due to the COVID-19 Pandemic, which has shifted our focus from exercise preparation to "real world" planning, coordination and response. We can only point to our training record and past exercise accomplishments as proof that we continue to be able to respond to incidents at the Beaver Valley Power Station. Hence, we join Beaver Valley Power Station and respectfully request that the 2020 exercise requirement be waived due to the existing pandemic situation.

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Otpuo U1r.c1or September 10. 2020 Mr. Steve Sawtchenko Manager* Emergency Preparedness and Regulatory Compliance Energy Harbor-Beaver Valley Power Station Route 168 Shippingport, PA 15077

Dear Mr. Sawtchenko:

The West Virginia Emergency Management Division (WV EMD) has received the Federal Emergency Management Agency's (FEMA) Framework for processing Relieffrom Frequency Requirements Radiologlcal Emergency Preparedness Program (REPP} Exercises, dated July 23, 2020, and the guidance addendum released from the Nuclear Regulatory Commission, September 2, 20201 upon reviewing the framework and available options WV EMO would like to request cancellation of the 2020 federally evaluated plume exercise Involving Beaver Valley Power Station currently rescheduled for November 10. 2020 due to hardships created by the current COVID-19 pandemic affecting the nation. The request Is based on specific requirements and definitions contained ln the framework memo under section 2.b.

The reasoning and concerns regarding our request are listed below:

1. Ongoing Pandemic -The COVID-19 pandemic rernafr,s a significant threat and remains a national public health emergency that was originally declared on January 31 by the US Secretary of Health and Human Services then renewed on April 21 and again on July 25. West Virginia currently has 11,808 cases with over a hundred cases added daily despite measures that have been put in place for mitigation such as hygiene practice awareness, facial coverings, social distancing, and gathering limitations. We are not confident an exercise can be implemented and evaluated appropriately given the limitations required to mitigate the pandemic. Off-site Response Organizations (OROs) continue to be prepared for a response to an emergency event and that is apparent with continued response to dally emergencies withln the respective jurisdictions. The pandemic has increased the need for use of personal protective equipment

{PPE) during daily operations which resulted in a PPE shortage and because of that there is a concern regarding using PPE for an exercise that needs to be conserved for emergency use, especially with the possibility of a resurgence of the disease during flu season.

2. Pandemic Impacts Affecting Exercise Operations - Exercises are designed to practice plans, demonstrate capabilities, and be beneficial for pla11ers, observers, and evaluators alike. Currently, It Is a hardship for most ORO's to adequately demonstrate capabilities through an exercise. Government buildings and Emergency Operations Centers (EOC's) are closed and/or restricted to visitors, and many Individuals continue to work from home. The majority of emergency workers that support exercises with BVPS are volunteers who are now committing time. and effort to pandemic operations, additionally

Page 2 of 3 the majority of volunteers that would participate in the exercise are like the majority of the WV population within the age group that is high risk for complications with COVID-19.

3. Administrative Restrictions - Various restrlctfons remain In place to help lfmlt the spread of COVID-19 or related Impacts that may limit the participation or ablllty to conduct an exercise.

a. Travel Restrictions - All employee out-of-state travel is restricted. The out- of-state travel restriction prevents any state employee from attending and participating at any of the BVPS acllities such as the Emergency Operations Faci!Jty (EOF) and the Joint Public Information Center (JPIC), The travel restriction also would prevent any travel to meetings, briefings, after-action meetings, and public meetings related to the exercise as traditionally they are held In Pennsylvania,

b. Budget/Financial Restrictions - Due to the increased expenses related to PPE, COVID-19 testing, and other related operational activities many agencies have had to restrict their budgets and will not be able to send employees to ei<ercise locations even within the State of WV.

c. Gathering Limitations/Restrictions - Currently gathering sizes are limlted to 25 or fewer individuals at indoor locations and that limits that amount of personnel available during a non*

emergent event such as an exercise at exercise facility locations.

4. Exercise History - The State of WV has had multiple successful exercises during this eight- year cycle including Plume exercises on even years, Medical Service - One exercises on odd years, and a Post-Plume/Ingestion exercise In March 2019 all written and documented In their respective after action reports by FEMA.

5. Recent EOC Activities -The state and Hancock County EOC have been activated through most of the pandemic response with multi ple operational periods. The activations have not been limited to COVID-19 but have also included activations during civil unrest and weather events. The EOC's have demonstrated an ability to mobilize and adapt to the progressing pandemic and include those modifications as other real- world events develop.

The pandemic remains a fluid event that requires constant monitoring and adjustments to mitigation procedures as new information arises, The need to do an adequate risk assessment Is of the up most Importance especially since there are still ongoing active outbreaks wi thin multiple states and locales. The biennial exercises are an Important part of preparedness In case of an event at BVPS but we must also realize that given the successful history of the previous exercises and the dynamic nature of the pandemic the risk that may be placed on our response staff may be to high. Cancellation of the plume e)(ercise only seems logical given the uncertainty of the current situation when you look at the overall picture. The other two option though vrable In most situations are not applicable. Credit for real world events Is not viable In this situation due to most of the tasks that could receive credit are tasks that would still need to be demonstrated so that an exercise could progress accordingly. Postponing or delaying the exercise until May 2021 ls not feasible because this is the last exercise under NlJREG-0654 Rev l with the Plume exercise in 2022 being conducted under the new NUREG 0654 Rev 2. The amount of time that would be required to completely revise and update the current state and local REP Plans 10 meet the NUREG 0654 Rev 2. adequately plan an exercise, and participate In a federally evaluated Medical Services one exercise (Early 2021) is too short w ith a May 2021 exercise date especially since we are still not certain that the pandemic activities will not be complete by then.

Hancock County Homeland Security and Emergency Management as well as WV EMO are responslbly preparing for an increase In operational tempo and committing valuable resources to mitigating the risk of a COVID-19 increase once the school year commences and ongoing efforts to ensure the county and schools, once open, mitigate all risk during the fall semester. The effort If coupled with the exercise will be very taxfng with the county's limited resources. The resources that are being used to plan for this exercise, that at this point in time still may or may not happen, could be well spent focusing on the current pandemic and other emergency events related to not just COVI0-19 but the current unrest that is spreading throughout the country.

Page 3 of 3 In closing, the State of West Virginia supports the Beaver Valley Power Station ln their request for exercise exemption. West Virginia Emergency Management Division Is committed to maintaining our Radlologlca l Emergency Preparedness Plans and response capabilities and the current pandemic has in no way affected the ability for a response to an actual emergency event at the Beaver Valley Power Station.

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William A. Minear II CPP PPS CEM Deputy Director WV Department of Homeland Security Emergency Management Oivislon Integrity Investigations Infrastructure Protection

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Hancock County Homeland Security & Emergency Management PO Box 884

• 82 Emergency Drive* New C umberland, WV 26047 Telephone 304-564-4139

• Fax 304-564-3041 Steve Sawtschenko Manager, Emergency Preparedness and Regulatory Compliance Energy Harbor Beaver Valley Power Station Mr. Sawtschenko,

_ Hancock County supports the Beaver Valley Power Station in their request for exercise exemption. Hancock County is committed to maintaining our Radiological Emergency Preparedness Plans and response capabilities and the current pandemic has not impacted us in a manner that would adversely affect our ability to maintain response capability to support emergency response activities to an actual emergency at Beaver Valley Power Station .

Sincerely, Stephanie Fryer, Deputy Director Hancock County Homeland Security and Emergency Management 82 Emergency Drive, PO Box 884 New Cumberland, WV 26047 304-564-4139 ext. 277 sfryer@hanwvoem.org