ML20174A283
| ML20174A283 | |
| Person / Time | |
|---|---|
| Issue date: | 06/23/2020 |
| From: | Ed Miller Plant Licensing Branch II |
| To: | |
| Miller E | |
| References | |
| Download: ML20174A283 (13) | |
Text
Public Meeting on the Emergency Preparedness Biennial Exercise Exemption Process During the COVID19 Public Health Emergency June 23, 2020
Background and Purpose
- On January 31, 2020, the U.S. Department of Health and Human Services declared a Public Health Emergency (PHE) for the United States.
- On March 11, 2020, the COVID19 outbreak was characterized as a pandemic by the World Health Organization.
- This meeting will be a discussion among participants regarding the EP biennial exercise requirements and guidance documents related to requesting an exemption from the performance of these exercises.
Biennial Exercise and 8 Year Exercise Cycle Requirements
- Appendix E to 10 CFR 50
- E.IV.F.2.b and 2.c
- 8-calendar-year exercise cycle as established in December 2011 EP rule
- First 8-year exercise cycle for a site began in the calendar year in which the first hostile action based (HAB) exercise was conducted. First HAB must be performed by Dec 2015.
- Biennial exercises shall vary the content of scenarios to provide for the ERO to demonstrate proficiency in the key skills necessary to respond to the following scenario elements over the 8-year cycle:
- hostile action directed at the plant site,
- no radiological release or an unplanned minimal radiological release that does not require public protective actions,
- an initial classification of or rapid escalation to a Site Area Emergency or General Emergency,
- implementation of strategies, procedures, and guidance under § 50.155(b)(2),
- and integration of offsite resources with onsite response.
8 Year Exercise Cycle Requirements
- 8calendaryear exercise cycle as established in 2011 EP rule
- Start a drill or exercise between 6:00 p.m. and 4:00 a.m. Some unannounced.
- All functions in each Emergency Response Facility
- Providing medical care for injured, contaminated personnel (every two years).
- Response to essentially 100 % of initiating conditions for classification of emergencies.
- All licensee ERO teams must be provided the opportunity to demonstrate key skills
- within the scope of their duties.
- Use of procedures developed in response to an aircraft threat
- Use of the strategies to mitigate spent fuel pool damage scenarios
- Use of the to mitigate reactor accidents and maintain containment
8 Year Exercise Cycle 2013 - 2020 7 sites 2014 - 2021 30 sites 2015 - 2022 19 sites
Biennial Exercise Requirements
- Each Biennial exercises shall demonstrate ERO proficiency in key skills:
- Timely classification of events;
- Timely notification of offsite authorities;
- Assessment of radiological releases onsite and offsite;
- Development of protective action recommendations;
- Dissemination of information to the public via media channels;
- Engineering assessment, repair plan development, and repair of critical equipment under emergency conditions;
- Mitigative action implementation;
- Protection of workers during emergency response, including medical care;
- Response to operational transients while implementing the emergency plan; and
- Coordination with Offsite Response Organizations.
2020 / 2021 Biennial Exercises Original Schedule 2020 29 sites 2021 27 sites
Biennial EP Exercises as of June 22, 2020
The Exemption Process
- 10 CFR 50.12 Special Circumstances
- Regulatory Issue Summary (RIS) 2006003
- Exemption Letter, May 14, 2020
Previous Biennial Exercise Exemption
- 2001, Limerick Generating Station
- temporary one time exemption from Appendix E IV.F.2.c, (offsite only) in October 2001 as a result of 9/11 ongoing national security threat
- Additionally, Limerick local and State agencies were directly participating in 9/11 activities
- Commission determined, pursuant to 10 CFR 50.12(a)
- the 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.
- special circumstances are present pursuant to 10 CFR 50.12(a)(2)(v), in that the exemption would only provide temporary relief from the applicable regulations.
Information Exchange NRC is seeking information on the impact of COVID19 on Biennial EP Exercises
- If NRC and/or FEMA grant exemption(s) from 2020 exercise(s), are there impacts to the currently scheduled 2021 exercises?
- Are there resource constraints that the NRC should be aware of?
- Are there new technologies being considered to replace gathering in Emergency Response Facilities or other areas which NRC should review in an expedited manner to support future exercises?
Public Meeting on the Emergency Preparedness Biennial Exercise Exemption Process During the COVID19 Public Health Emergency Questions?