ML20085F705
| ML20085F705 | |
| Person / Time | |
|---|---|
| Issue date: | 03/30/2020 |
| From: | Kathryn Brock, Hart H NRC/NSIR/DPR, US Dept of Homeland Security, Federal Emergency Management Agency |
| To: | |
| Kahler R, | |
| References | |
| Download: ML20085F705 (4) | |
Text
United States United States Nuclear Regulatory Commission Department of Homeland Security
Washington, D.C. 20472 Washington, D.C. 20555-0001
MEMORANDUM FOR DISTRIBUTION Digitally signed by HAMPTON H FROM: Hampton H. Hart, Jr., Deputy Director, Technological Hazards Division HART JR Date: 2020.03.27 National Preparedness Directorate 15:25:21 -04'00' Kathryn M. Brock, Division Director, Division of Preparedness and Response Digitally signed Kathryn byBrockKathryn M.
Office of Nuclear Security and Incident Response M. Brock Date: 2020.03.30 08:31:47 -04'00'
SUBJECT:
GUIDANCE FOR POSTPONEMENT OF REP EXERCISES DUE TO THE COVID-19 OUTBREAK In response to the Presidents National Emergency Declaration, there have been numerous inquiries by both licensees and offsite response organizations (OROs), resulting in several postponements of scheduled REP exercises. In the effort to provide a consistent message, NRC Headquarters/Office of Nuclear Security and Incident Response/Division of Preparedness and Response (NSIR/DPR) and FEMA Resilience/Technological Hazards Division (THD) have decided to provide uniform regulatory and statutory context and recommendations to consider when entering discussions with licensees and OROs on the subject of exercise postponement and rescheduling.
The licensee and the applicable OROs have the lead in scheduling and conducting REP exercises of the onsite and offsite plans. To be effective, the scheduling and/or rescheduling of these exercises must be a coordinated effort among the OROs, licensee, FEMA, and NRC in order to ensure effective onsite/offsite integration and participation. Critical to the success of these exercises is the availability of adequate evaluation resources by both the NRC and FEMA.
If the need arises for either the licensee or an ORO to postpone and/or reschedule an exercise, it is within their authority to do so; and, prior approval is not required from either NRC or FEMA.
However, when licensees and OROs are considering the postponement of exercises, it is requested that they engage the respective NRC and FEMA Regional staff, as soon as reasonably possible, to ensure that appropriate coordination is maintained when rescheduling the exercises.
As the National public health emergency continues, it would be prudent to assume that the number of postponed REP exercises will rise. While this may result in taxing the capacity of NRC and FEMA inspection/evaluation resources towards the end of CY 2020, this specific issue should not be a contributing factor as OROs and licensees are negotiating mutually agreeable dates to reschedule exercises. It may become necessary for licensees and OROs to seek exemptions from conducting their exercises prior to the end of CY2020. NRC (NSIR/DPR) and
FEMA (THD) will consider these requests on a case-by-case basis and are also in discussions to seek possible regulatory solutions.
FEMA and NRC should be mindful that the States, their respective OROs, and the licensees are currently focusing their time and resources on responding to this crisis and protecting the health and safety of the public, including their respective staff. Any decisions made by NRC and FEMA should be supportive and flexible enough to not create undue burden or hardship on the effected communities, and should be mindful of the Federal, state, and local public health directives that have been issued in response to the National Emergency.
NSIR/DPR and THD greatly appreciate your efforts and maintaining open lines of communication. The bottom line is that both the NRC and FEMA will be supportive as our stakeholders are making critical and difficult decisions about how to prioritize their time and resources during this National public health emergency.
ML20085F705 OFFICE NSIR/DPR/POB/BC NSIR/FO/DD (A) NSIR/DPR/D FEMA/THD/BC FEMA/THD/DD NAME RKahler SHelton KBrock VQuinn HHart DATE 3/27/20 3/27/20 3/30/20 3/27/20 3/27/20 REFERENCES PROCLAMATION ON DECLARING A NATIONAL EMERGENCY CONCERNING THE NOVEL CORONAVIRUS DISEASE (COVID-19) OUTBREAK, Issued on: March 13, 2020 IMC 2515, LIGHT-WATER REACTOR INSPECTION PROGRAMOPERATIONS PHASE IMC 2515 Appendix E, INSPECTION PROGRAM MODIFICATIONS DURING A PANDEMIC RIS 06-03, GUIDANCE ON REQUESTING AN EXEMPTION FROM BIENNIAL EMERGENCY PREPAREDNESS EXERCISE REQUIREMENTS RIS 10-04, MONITORING THE STATUS OF REGULATED ACTIVITIES DURING A PANDEMIC 10 CFR 50.47(b)(14) states:
(14) Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skills, and deficiencies identified as a result of exercises or drills are (will be) corrected.
Appendix E.IV.F.2.b of 10 CFR Part 50 states, in part:
- b. Each licensee at each site shall conduct a subsequent exercise of its onsite emergency plan every 2 years. Nuclear power reactor licensees shall submit exercise scenarios under § 50.4 at least 60 days before use in an exercise required by this paragraph 2.b. The exercise may be included in the full participation biennial exercise required by paragraph 2.c. of this section.
Appendix E.IV.F.2.c of 10 CFR Part 50 states, in part:
- c. Offsite plans for each site shall be exercised biennially with full participation by each offsite authority having a role under the radiological response plan.
44 CFR 350.9(c)(1) states, in part:
(1) Each State which has a commercial nuclear power site within its boundaries or is within the 10-mile plume exposure pathway Emergency Planning Zone of such site shall fully participate in an exercise jointly with the nuclear power plant licensee and appropriate local governments at least every two years.
RIS 2006-03 (ADAMS ML053390039) states:
Rescheduling an exercise within the same calendar year does not require an exemption from regulatory requirements.