L-PI-20-050, Request for a One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements, Due to COVID-19 Pandemic

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

ML20281A665
Person / Time
Site:	Prairie Island
Issue date:	10/07/2020
From:	Sharp S Northern States Power Company, Minnesota, Xcel Energy
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
L-PI-20-050
Download: ML20281A665 (17)

Text

fl Xcel Energy 1717 Wakonade Drive Welch, MN 55089 October 7, 2020 L-PI-20-050 10 CFR 50.12 10 CFR 50, Appendix E ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Prairie Island Nuclear Generating Plant, Units 1 and 2 Docket Nos. 50-282 and 50-306 Renewed Facility Operating License Nos. DPR-42 and DPR-60 Prairie Island Independent Spent Fuel Storage Installation Docket No. 72-10 Renewed Materials License No. SNM-2506 Request for a One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements, Due to COVID-19 Pandemic

References:

1) Letter from the NRC to the Nuclear Energy Institute, 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, dated May 14, 2020 (Accession No. ML20120A003)

2) Letter from the NRC to the Nuclear Energy Institute, 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, dated September 2, 2020 (Accession No. ML20223A152)

Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), in accordance with 10 CFR 50.12, Specific Exemptions, requests a one-time exemption for Prairie Island Nuclear Generating Plant Unit 1, Unit 2, and Independent Spent Fuel Storage Installation (hereafter Prairie Island) from the requirements of 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c. Specifically, NSPM requests a one-time exemption to postpone the full-participation biennial emergency preparedness exercise required by Section IV.F.2.b of Appendix E to 10 CFR Part 50, currently scheduled for December 1, 2020, until calendar year (CY) 2021. NSPM also requests a one-time exemption from the conduct of the calendar year (CY) 2020 offsite biennial exercise required by Section IV.F.2.c of Appendix E to 10 CFR Part 50.

Document Control Desk Page 2 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 COVID-19. On March 11, 2020, the COVID-19 outbreak was characterized as a pandemic by the World Health Organization. On March 13, 2020, the President of the United States declared the COVID-19 pandemic a national emergency. On this same date, the Governor of the State of Minnesota also declared a peacetime emergency due to the pandemic. State and local governmental jurisdictions have issued directed health measures, including, but not limited to: stay-at-home orders, social distancing measures and group size limitations. The State of Wisconsin, part of which lies within Prairie Island's 10-mile emergency planning zone, has also issued a recommendation that residents cancel or postpone all travel, including travel within the state.

In response to these declarations, and in accordance with the NSPM pandemic response plan, NSPM has postponed some site activities due to isolation activities (for example, social distancing, group size limitations, self-quarantining, and so on). The Prairie Island biennial emergency preparedness exercise has been postponed from its original scheduled date to December 1, 2020. The threat of COVID-19 spread and the ever-changing nature of the pandemic have resulted in the inability to safely conduct the full-participation biennial emergency exercise scheduled for December 1, 2020. Further, the threat of COVID-19 spread has resulted in the inability to safely conduct the exercise with full ORO participation. The State of Minnesota, Goodhue County (the county in which Prairie Island is located), Dakota County, the State of Wisconsin, and Pierce County have communicated to NSPM that they have concerns with supporting the biennial exercise in 2020 and maintaining protection of their staff during the current COVID-19 pandemic response.

Justification for the issuance of an exemption provided in the Enclosure is based on the guidance provided in Reference 1 and the additional guidance of Reference 2. Attachment 1 to the Enclosure provides the concurrence from the State of Minnesota. Attachment 2 to the Enclosure provides the concurrence from the State of Wisconsin. NSPM requests approval of this request by December 31, 2020.

If there are any questions, or if additional information is required, please contact Mr. Ron Jacobson at 612-330-6542 or ronald.g.jacobson@xcelenergy.com.

Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

Scott Sharp Site Vice President, Prairie Island Nuclear Generating Plant Northern States Power Company - Minnesota

Document Control Desk Page 3 Enclosure cc: Administrator, Region III, USNRC Project Manager, Prairie Island, USNRC Resident Inspector, Prairie Island, USNRC State of Minnesota State of Wisconsin

ENCLOSURE PRAIRIE ISLAND NUCLEAR GENERATING PLANT AND INDEPENDENT SPENT FUEL STORAGE INSTALLATION REQUEST FOR A ONE-TIME EXEMPTION FROM 10 CFR 50, APPENDIX E, BIENNIAL EMERGENCY PREPAREDNESS EXERCISE REQUIREMENTS, DUE TO COVID-19 PANDEMIC (7 pages follow)

L-PI-20-050 NSPM Enclosure REQUEST FOR A ONE-TIME EXEMPTION FROM 10 CFR 50, APPENDIX E, BIENNIAL EMERGENCY PREPAREDNESS EXERCISE REQUIREMENTS, DUE TO COVID-19 PANDEMIC 1.0

SUMMARY

DESCRIPTION Northern States Power Company, a Minnesota corporation, doing business as Xcel Energy (hereafter NSPM), in accordance with 10 CFR 50.12, Specific Exemptions, requests a one-time exemption for Prairie Island Nuclear Generating Plant Unit 1, Unit 2, and Independent Spent Fuel Storage Installation (hereafter, Prairie Island) from the requirements of 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c.

The requested one-time exemption supports the continued implementation of the isolation activities (for example, social distancing, group size limitations, self-quarantining, etc.) taken to protect both onsite and offsite emergency response organization (ERO) personnel in response to the COVID-19 pandemic. These activities are needed to ensure ERO personnel are isolated from the COVID-19 virus and remain capable of executing the functions of the ERO.

2.0 BACKGROUND

10 CFR 50, Appendix E, Section IV.F.2.b states in part:

Each licensee at each site shall conduct a subsequent exercise of its onsite emergency plan every 2 years.

10 CFR 50, Appendix E, Section IV.F.2.c states in part:

Offsite plans for each site shall be exercised biennially with full participation by each offsite authority having a role under the radiological response plan. Where the offsite 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 offsite plan exercises in this period.

On April 14, 2020, NSPM conducted a teleconference regarding the scheduled 2020 Prairie Island biennial exercise with representatives from Minnesota Homeland Security and Emergency Management (HSEM), Wisconsin Emergency Management (WEM), Goodhue County, Dakota County, and Pierce County. During this call, these Offsite Response Organizations (OROs) determined that conduct of this exercise may pose undue risk to public health and safety, specifically, their staff: state and local partners and federal evaluators. In addition, NSPM has implemented isolation activities (e.g., social distancing, group size limitations, self-quarantining, etc.) to protect required ERO personnel in response to COVID-19. For these reasons, the July 21, 2020, exercise was rescheduled to December 1, 2020.

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L-PI-20-050 NSPM Enclosure 3.0 TECHNICAL JUSTIFICATION OF ACCEPTABILITY The U.S. Centers for Disease Control and Prevention (CDC) has issued recommendations advising social distancing to prevent the spread of the COVID-19 virus. NSPM has implemented its pandemic response plan, which includes isolation activities such as mandatory work-from-home, self-quarantining, social distancing, and travel restrictions, in an attempt to limit the spread of the virus among the station staff. Similar isolation activities are being practiced by state, county, and local offsite personnel.

The last Prairie Island emergency preparedness exercise was conducted on July 17, 2018.

Since that time, NSPM has conducted drills and other training activities that exercised Prairie Island emergency response strategies, in coordination with offsite authorities. State officials participated in the following:

(1) April 2019 - Limited state and local participation (2) July 2019 - Limited state and local participation NSPM will continue to conduct drills and other training activities that exercise its emergency response strategies.

Additionally, on March 4, 2020, officials from the Minnesota Planning and Assessment Center, the Wisconsin State Radiological Center, and Prairie Island Radiological Protection staff conducted a planning workshop designed for those personnel to discuss and coordinate the tasks they need to accomplish during a radiological emergency.

NSPM has made a reasonable effort to reschedule the exercise, including having moved the date from July 21, 2020 to December 1, 2020; however, due to the ongoing pandemic and uncertainty of the future in this matter, this date is no longer feasible. NSPM has coordinated with NRC Region III and rescheduled the CY 2020 biennial exercise to June 8, 2021. While this date is within the 35 months since the last Prairie Island biennial exercise, a potential exists that this exercise would need to be rescheduled beyond the 35 months. Therefore, NSPM continues to coordinate with the NRC Region III to ensure the Prairie Island exercise is conducted by December 31, 2021, as well as, other Region III actions being planned in the interim:

(1) NRC Region III is currently scheduled to perform an Emergency Preparedness program inspection the week of April 19, 2021.

(2) NRC Region III is coordinating with NSPM to review performance indicators as part of the Emergency Action Level and Emergency Plan changes inspection (71114.04) in the 4th Quarter of 2020.

Approval of this exemption request to conduct the CY 2020 biennial exercise in CY 2021 will not impact the future biennial exercise schedule. They will continue to be held in even years.

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L-PI-20-050 NSPM Enclosure The State of Minnesota and the State of Wisconsin with the concurrence of Goodhue, Dakota and Pierce counties (Attachments 1 and 2):

(1) Are in agreement with the Prairie Island exercise exemption request, (2) Are committed to maintaining their emergency plans, (3) Have not been impacted in a manner that would adversely affect their ability to maintain response capability to support emergency response activities to an actual nuclear power plant radiological emergency at Prairie Island.

4.0 JUSTIFICATION OF EXEMPTION 10 CFR 50.12, Specific Exemptions, states that the NRC may grant exemptions from the requirements of the regulations of this part provided three conditions are met. They are:

(1) The exemptions are authorized by law, (2) The exemptions will not present an undue risk to the public health and safety, and (3) The exemptions are consistent with the common defense and security.

NSPM has evaluated the requested exemption for Prairie Island against the criteria of 10 CFR 50.12 and determined the criteria are satisfied as described below.

(1) This exemption is authorized by law.

The biennial emergency preparedness exercise for the emergency response organization specified in 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c is not required by any statute. The requested exemption is authorized by law in that no law precludes the activities covered by this exemption request. Granting of the request does not result in a violation of the Atomic Energy Act of 1954, as amended.

(2) This exemption will not present an undue risk to the public health and safety.

The underlying purpose of 10 CFR 50, Appendix E, Section IV.F.2.b requiring licensees to conduct a biennial EP exercise is to ensure that ERO personnel are familiar with their duties and to test the adequacy of the emergency plan. In addition, 10 CFR 50, Appendix E, Section IV.F.2.b also requires licensees to maintain adequate emergency response capabilities during intervals between biennial EP exercises by conducting drills to exercise the principal functional areas of emergency response. Similarly, the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c requiring full participation by each offsite authority having a role under the radiological response plan to be exercised biennially is to ensure that the ORO personnel are familiar with their duties and to test their ability to respond during an emergency at Prairie Island.

NSPM has conducted training drills exercising the principle functional areas of emergency response since the last evaluated biennial EP exercise with no performance Page 3 of 7

L-PI-20-050 NSPM Enclosure issues. Drills are also scheduled for 2021 to ensure continued familiarity with duties and to test the abilities of ERO personnel to respond during an emergency at Prairie Island.

Postponing the biennial exercise from the currently scheduled date of December 1, 2020 but completing this exercise prior to the end of 2021 does not create any new accident precursors. The probability and consequences of postulated accidents are not increased, and an acceptable level of emergency preparedness is maintained.

Therefore, there is no undue risk to public health and safety.

(3) This exemption is consistent with the common defense and security.

The proposed exemption would allow rescheduling of the onsite portion of the biennial EP exercise from the currently scheduled date of December 1, 2020 to CY 2021. The requested exemption also excludes the ORO participation in this emergency preparedness exercise to help reduce the spread of COVID-19. This exemption has no relation to security issues. The common defense and security are not impacted by this exemption.

In addition to the three conditions discussed above, 10 CFR 50.12(a)(2) states that the NRC will not consider granting an exemption unless special circumstances are present.

Special circumstances, per 10 CFR 50.12(a)(2)(ii), are present when [a]pplication of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule. 10 CFR 50, Appendix E, Section, IV.F.2.b and IV.F.2.c require NSPM to conduct an exercise of the Prairie Island Emergency Plan biennially with full participation by each offsite authority having a role under the plan. The underlying purpose of this requirement is to ensure that ERO personnel are familiar with their duties and to test adequacy of emergency plans, and to identify and correct weaknesses. NSPM has conducted training drills exercising the principle functional areas of emergency response since the last evaluated biennial EP exercise and has activated onsite emergency response facilities during those drills with state, county, and local participation.

NSPM considers that these measures maintain an acceptable level of emergency preparedness during the exemption period to satisfy the underlying purpose of the rule.

Under 10 CFR 50.12(a)(2)(v), special circumstances are present whenever the exemption would provide only temporary relief from the applicable regulation and the licensee has made good faith efforts to comply with the regulation. The requested exemption to conduct the biennial emergency preparedness exercise for calendar year 2020 in CY 2021 would grant only temporary relief from the applicable regulations. In addition, coordination of activities with current health restrictions, such as social distancing, is increasingly difficult. Based on discussion with ORO representatives, NSPM has concluded that a good faith effort has been made to comply with the regulations.

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L-PI-20-050 NSPM Enclosure 5.0 ENVIRONMENTAL ASSESSMENT NSPM is requesting an exemption from certain requirements of 10 CFR 50, Appendix E, for Prairie Island Units 1 and 2 and the site-specific licensed Independent Spent Fuel Storage Installation. Specifically, NSPM is requesting a one-time exemption from the requirements of 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c for conducting biennial EP exercises.

The following information is provided in support of a determination that no environmental assessment or an environmental impact statement is required in accordance with 10 CFR 51.22(b) and 10 CFR 51.22(c)(25) to grant the requested exemption.

The exemption does not make any changes to the facility or operating procedures and does not:

a) Involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), in that it does not:

• Alter the design, function or operation of any plant equipment. Therefore, granting this exemption would not increase the probability or consequence of any previously evaluated accident.

• Create any new accident initiators. Therefore, granting this exemption does not create the possibility of a new or different kind of accident from any accident previously evaluated.

• Exceed or alter a design basis or safety limit. Therefore, granting this exemption does not involve a significant reduction in a margin of safety.

Therefore, a finding of no significant hazards considerations is justified.

b) Involve any changes that would introduce any change to effluent types, affect any plant radiological or non-radiological effluent release quantities, or affect any effluent release paths or the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation. Therefore, it is concluded that the proposed exemption does not involve a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite.

c) Affect any plant radiation zones, nor change any controls required under 10 CFR Part 20 that preclude a significant increase in occupational radiation exposure.

Therefore, it is concluded that the proposed exemption does not involve a significant increase in individual or cumulative occupational radiation exposure.

d) Involve any facility changes or change any construction activities. Therefore, there is no significant construction impact.

e) Alter the design, function, or operation of any plant equipment. Therefore, there is no significant increase in the potential for or consequences from radiological accidents.

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L-PI-20-050 NSPM Enclosure Finally, the requirements to which the exemption applies involve biennial EP exercise scheduling and therefore meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(25)(vi)(G).

Accordingly, the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(25). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this exemption.

6.0 CONCLUSION

As demonstrated above, NSPM considers that this exemption request is in accordance with the criteria of 10 CFR 50.12. Specifically, the requested exemption is authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security. A temporary exemption from the biennial emergency preparedness exercise requirements of 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c. is required during the 2020 COVID-19 pandemic.

7.0 PRECEDENTS (1) Letter from the NRC to Nebraska Public Power District, Cooper Nuclear Station -

Temporary Exemption from Biennial Emergency Preparedness Exercise Requirements of 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV.F (EPID L-2020-LLE-0102 [COVID-19]), dated September 3, 2020 (Accession No. ML20203M129)

(2) Letter from the NRC to Energy Harbor Nuclear Corp., Perry Nuclear Power Plant, Unit No. 1 - Temporary Exemption from Biennial Emergency Preparedness Exercise Requirements of 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV.F (EPID L-2020-LLE-0125

[COVID-19]), dated September 11, 2020 (Accession No. ML20246G054)

8.0 REFERENCES

(1) Letter from the NRC to the Nuclear Energy Institute, 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, dated May 14, 2020 (Accession No. ML20120A003)

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L-PI-20-050 NSPM Enclosure (2) Letter from the NRC to the Nuclear Energy Institute, 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, dated September 2, 2020 (Accession No. ML20223A152)

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ATTACHMENT 1 TO L-PI-20-050 ENCLOSURE STATE OF MINNESOTA LETTER (3 pages follow)

Homeland Security and Emergency Management 445 Minnesota StreeL Suite 223

• Saint Paul, Minnesota 55101-6223 Phone: 651.201.7_400

• Fax: 651.296.0459 http:/ /hsem. dps. mn. gov eptember 16th , 2020 Alcohol and Gambling Enforcement Bureau of Criminal Mr. Brian Carberry Apprehension Emergency Preparedness Manager Driver Xcel Energy and Vehicle 414 Nicollet Mall Services Minneapolis, Minnesota 55401 Emergency Communication Networks Dear Mr. Carberry Homeland Security and Emergency Management

Subject:

Exemption Request Minnesota State Patro I Office of The state of Minnesota (with concurrence from Goodhue and Dakota Counties)

Communications agree with the Xcel Energy's request for an exemption for the 2020 Prairie Island Office of Nuclear Generating Plant Exercise. The offsite response organizations are Justice Programs committed to maintaining our radiological emergency plans. This exemption Office of would not impact the offsite organizations in a manner that would adversely affect Pipeline Safety our ability to maintain response capability to support emergency response Office of activities at the Prairie Island Nuclear Generating Plant.

Traffic Safety State Fire The state of Minnesota has been working with FEMA to ensure that all exercise Marshal criterion for the 2020 Prairie Island Exercise have demonstrated either through work done this year on the responses to COVID 19 and the Civil Unrest in the Twin Cities earlier this summer. We have also scheduled a number of table top discussions to demonstrate the remaining criterion. Below is a summary of what we have done and what will be done the remainder of year.

Criterion Completed State of Minnesota- 5.b.l Hotline Operations Goodhue County- l.a.1, 1.c.l, l.d.l, 1.e.l, 2.c.l, 3.c.l, 3.c.2, 3.d.l, 5.b.l (partial)

Dakota County- l.a.l, 1.c.l, l.d.1, l.e.l, 2.c.l, 3.c.l, 3.d.l, 3.d.2 (partial), 5.b.l (partial)

St. Elizabeth's Hospital and Wabasha Ambulance- 1.e. l (partial), 3 .a. l (partial),

6.d. l (partial)

EQUAL OPPORTUNITY EMPLOYER

Regions Hospital and Cottage Grove Ambulance- 1.e.1 (partial), 3 .a.1 (partial),

6.d. l (partial)

Criterion being postponed to next year State of Minnesota - 6.a.1- Reception Center Operations (Wabasha Reception Center to be demonstrated in 2021)

Goodhue County- 6.b.1 Emergency Worker Decon (Cannon Falls EWD to be demonstrated in 2021)

Criterion still needing to be demonstrated State of Minnesota 1.e.1, 3.a.1, 6.d.1- MS-1 St. Elizabeth and Wabasha TTX exercise schedule for September 23 rd . Regions and Cottage Grove TTX is scheduled for September 29 th .

Goodhue County- 2.a.1, 2.b2, 3.a.1, 3.b.1, 3.d.2, 5.a.1, 5.b.1 Dakota County~ 2.a.1, 2.b.2, 3.a.1, 3.b.1, 3.d.2, 5.aJ, 5.b.1 Goodhue County and Dakotas County will be setting up a TTX and interviews to demonstrate this criteria, see below for more information.

2.a.1, 2.b.2, 3.b.1, 5.a.1, and 5.b.1 will be demonstrated during a TTX with the state of Minnesota and Wisconsin, Goodhue, Dakota and Pierce County on October 20th. The states and counties will be given information from Prairie Island Nuclear Generating Plant through the Site Area Emergency. PINGP will declare a General Emergency and provide the two states a Protective Action Recommendation (PAR), the two state assessment centers will work to agree on the PAR, once there is concurrence the state of Minnesota will ask each county if they concur with PAR, once each county concurs the state will work with Wisconsin to ensure that Pierce County also has concurred with the PAR, once everyone has concurred and the two GARs agree and sign off on to make the PAR a Protective Action Decision (PAD). KI will be part of the PAR for both Emergency Workers and General Workers. The state of Minnesota will provide a news release with the information from the PAD, each county will review and let the state know if they concur. Goodhue County will coordinate with Dakota and Pierce County to demonstrate how they would sound the sirens (sirens will not be sounded) 3 .a. l will be demonstrated through an interview with two county deputies. A county rad officer will give the deputies a briefing via video on their dosimeters and KI. FEMA evaluator will then interview deputy on his basic knowledge of their procedure on their dosimetry and KI.

3 .d.2 will be demonstrated via TTX and interview- each county will conduct separate TTX exercise. Maps will be provided to the deputies with the direction of the plume and will also be given a traffic impediment on an evacuation route.

The county will demonstrate how they would re-route traffic and provide a map to the state with re-route directions.

If you have any questions, please contact me at (651)201-7434 or patrick.mclaughlin@state.mn. us .

Sincerely,

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Patritk McLaughlin Radiological Emergency Preparedness Administrator State of Minnesota Division of Homeland Security and Emergency Management.

ATTACHMENT 2 TO L-PI-20-050 ENCLOSURE STATE OF WISCONSIN LETTER (1 page follows)

State Of Wisconsin Department of Military Affairs Division of Emergency Management Darrell L. Williams, Ph.D. Tony Evers Administrator Governor Mr. Brian Carberry Emergency Preparedness Manager Xcel Energy 414 Nicollet Mall Minneapolis, MN. 55401

Subject:

Exemption Request

Dear Mr. Carberry,

The State of Wisconsin, with concurrence from Pierce County Emergency Management, support Xcel Energys request for an exemption for the 2020 Prairie Island Nuclear Generating Plant exercise. The offsite response organizations are committed to maintaining our radiological emergency plans and response capabilities independent from Xcel Energys direct participation for 2020. The Prairie Island Nuclear Generating Plant exercise exemption would not adversely impact the offsite organizations ability to maintain response capabilities to support emergency response operations at the Prairie Island Nuclear Generating Plant.

Radiological emergency preparedness activities such as training, virtual exercising, plan review, and communication drills continue to allow the State of Wisconsin to maintain its response capabilities.

Wisconsin Emergency Management, the Wisconsin Department of Health Services Radiation Protection Section, and Pierce County Emergency Management are committed to maintaining a high level of readiness through continued collaboration and frequent consultation with FEMA.

If you have any questions regarding Wisconsins current level of radiological emergency preparedness or response capabilities, please contact me at (608) 242-3243.

Sincerely, Eric V. Franco Program Manager, Radiological Emergency Preparedness Wisconsin Department of Military Affairs Wisconsin Emergency Management 2400 Wright Street Madison, WI. 53707 eric.franco@wisconsin.gov cc: Greg Engle Darrell Williams, Ph.D.

2400 Wright St. PO Box 7865 Madison, WI 53707-7865 24 Hour Emergency Hotline 1-800-943-0003