NL-20-069, One-time Scheduler Exemption Request from 10 CFR 50, Appendix E Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Public Health Emergency

One-time Scheduler Exemption Request from 10 CFR 50, Appendix E Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Public Health Emergency

ML20282A612
Person / Time
Site:	Indian Point
Issue date:	10/08/2020
From:	Gaston R Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-20-069
Download: ML20282A612 (19)

Text

Entergy Nuclear Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.12 10 CFR 50, Appendix E NL-20-069 October 8, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

One-time Schedular Exemption Request from 10 CFR 50, Appendix E Biennial Emergency Preparedness Exercise Requirements due to COVID-19 Public Health Emergency Indian Point Nuclear Generating Unit Nos. 2 and 3 NRC Docket Nos. 50-247 and 50-286 Renewed Facility Operating License Nos. DPR-26 and DPR-64 In accordance with 10 CFR 50.12, "Specific exemptions," paragraph (a)(2)(v), Entergy Nuclear Operations, Inc. (Entergy) requests an exemption from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.b for Indian Point Nuclear Generating Unit Nos. 2 and 3 (IP2 and IP3, collectively referred to as IPEC). Specifically, Entergy requests a one-time schedular exemption to postpone the onsite portion of the full-participation biennial emergency preparedness exercise until calendar year 2021.

On January 31, 2020, the U.S. Department of Health and Human Services declared a public health emergency (PHE) for the United States to aid the nations 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, President Donald Trump declared the Coronavirus (COVID-19) pandemic a national emergency.

In March 7, 2020, the Governor of New York issued Executive Order 202, "Declaring a Disaster Emergency in the State of New York," to combat the spread of the COVID-19 virus.

Specifically, the Governor imposed sweeping measures to protect public health and safety, including restrictions on businesses and gatherings through Executive Orders. These measures, together known as "New York State on PAUSE" directed all non-essential businesses to close their in-person operations and banned all non-essential gatherings of individuals of any size for any reason.

NL-20-069 Page 2 of 3 In response to the COVID-19 public health emergency, as well as the New York Executive Orders, Entergy implemented protective health measures at all its facilities. These measures include social distancing, group size limitations, mandatory use of face masks, pre-entry temperature checks, and various other COVID-19 mitigation strategies. At the present time, these protective health measures significantly impact Entergy's ability to conduct a biennial exercise of its onsite emergency plan.

In response to these declarations, and in accordance with the Entergy Pandemic Response Plan, Entergy initiated isolation activities at IPEC (e.g., social distancing, group size limitations, self-quarantining, etc.) on March 16, 2020. These isolation activities have resulted in the inability to complete the full onsite emergency preparedness biennial exercise that is scheduled for November 17, 2020. In addition, based on the limited amount of available time between the originally scheduled date and the end of 2020, and the continued impact of the COVID-19 PHE, Entergy is unable to reschedule the biennial exercise prior to the end of 2020.

Conducting the IPEC biennial exercise in calendar year (CY) 2021, rather than CY 2020, places the exercise outside the required biennium. Consequently, Entergy requests a one-time schedular exemption to postpone the onsite portion of the biennial emergency preparedness exercise until CY 2021, but prior to expiration of the 35-month interval. This request represents a Special Circumstance, as specified in 10 CFR 50.12(a)(2)(v).

In accordance with the provisions of 10 CFR 50.12, Entergy is submitting a one-time schedular exemption request for 10 CFR 50, Appendix E, Section IV.F.2.b. Justification for the issuance of an exemption is provided in the Enclosure to this letter and is based on guidance provided in References 1 through 4. Entergy requests authorization by December 31, 2020, in order to maintain compliance with 10 CFR 50, Appendix E.

There are no regulatory commitments contained in this request.

Should you have any questions concerning this letter, or require additional information, please contact Mahvash Mirzai at 914-254-7714.

Respectfully, Ron Gaston RWG/trj

NL-20-069 Page 3 of 3

Enclosure:

One-Time Schedular Exemption Request from 10 CFR 50, Appendix E Biennial Emergency Preparedness Exercise Requirements

Attachment:

IPEC Emergency Response Organization Training and Drills Performed and Scheduled

References:

1) NRC Regulatory Issue Summary 2006-03, "Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements," (ADAMS Accession No. ML053390039), dated February 24, 2006

2) U.S. Nuclear Regulatory Commission (NRC) letter to Entergy Nuclear Operations, Inc (Entergy), "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," (ADAMS Accession No. ML20120A003),

dated May 14, 2020

3) NRC letter to Entergy, "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," (ADAMS Accession No. ML20223A152), dated September 2, 2020

4) NRC Office of Nuclear Security and Incident Response (NSIR)

Temporary Staff Guidance (TSG) TSG-NSIR-2020-01, "COVID-19 Related Exemptions from NRC Regulations - Emergency Preparedness Exercises," (ML20196M030), dated September 11, 2020 cc: Regional Administrator, NRC Region I NRC Senior Project Manager, NRC NRR DORL NRC Senior Resident Inspector, Indian Point Energy Center President and CEO, NYSERDA New York State (NYS) Public Service Commission

Enclosure NL-20-069 One-Time Schedular Exemption Request from 10 CFR 50, Appendix E Biennial Emergency Preparedness Exercise Requirements

NL-20-069 Enclosure Page 1 of 5 One-Time Schedular Exemption Request from 10 CFR 50, Appendix E Biennial Emergency Preparedness Exercise Requirements 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.12, "Specific exemptions," Entergy Nuclear Operations, Inc.

(Entergy) requests a one-time schedular exemption for the Indian Point Nuclear Generating Units Nos. 2 and 3 (IP2 and IP3, collectively referred to as IPEC) from the requirement to conduct the onsite portion a full-participation biennial emergency preparedness (EP) exercise specified in 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"Section IV.F.2.b. Justification for the issuance of an exemption is provided below, and is based on guidance provided in References 1 through 5.

This one-time schedular exemption to allow Entergy to conduct the onsite portion of the IPEC full-participation biennial EP exercise in calendar year 2021 supports continued implementation of the isolation activities (e.g., social distancing, group size limitations, self-quarantining, etc.) to protect required emergency response organization personnel in response to the Coronavirus Disease 2019 (COVID-19). These activities are needed to ensure emergency response organization personnel are isolated from the COVID-19 virus and remain capable of executing the functions of the emergency response organization, as described in the IPEC Emergency Plan.

2.0 BACKGROUND

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

"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:

"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 March 7, 2020, the Governor of New York issued Executive Order 202, "Declaring a Disaster Emergency in the State of New York," to combat the spread of the COVID-19 virus.

Specifically, the Governor imposed sweeping measures to protect public health and safety, including restrictions on businesses and gatherings through Executive Orders. These measures, together known as "New York State on PAUSE" directed all non-essential businesses to close their in-person operations and banned all non-essential gatherings of individuals of any size for any reason.

NL-20-069 Enclosure Page 2 of 5 In response to the COVID-19 public health emergency, as well as the New York Executive Orders, Entergy implemented protective health measures at all its facilities. These measures include social distancing, group size limitations, mandatory use of face masks, pre-entry temperature checks, and various other COVID-19 mitigation strategies. At the present time, these protective health measures significantly impact Entergy's ability to conduct a biennial exercise of its onsite emergency plan. In addition, based on the limited amount of available time between the originally scheduled date and the end of 2020, and the continued impact of the COVID-19 PHE, Entergy is unable to reschedule the biennial exercise prior to the end of 2020.

3.0 TECHNICAL JUSTIFICATION OF ACCEPTABILITY The U.S. Centers for Disease Control (CDC) has issued recommendations advising social distancing to prevent the spread of the COVID-19 Virus. Entergy and the State of New York have implemented pandemic plans which include social distancing, group size limitations and self-quarantine. Ideally, this will limit the spread of the virus among the station staff and off-site personnel.

IPEC's last biennial EP exercise was conducted on September 25, 2018. Since that time, Entergy has conducted numerous drills, exercises, and other training activities at IPEC that have exercised its emergency response strategies. These are tabulated and listed in the Attachment to this Enclosure. In addition, New York State officials have participated, or are scheduled to participate in the following:

January 23, 2019 - Limited state and local participation May 22, 2019 - Limited state and local participation September 10, 2019 - Full state and local participation November 20, 2019 - Full state and local participation January 29, 2020 - Limited state and local participation September 23, 2020 - Limited state and local participation November 17, 2020 - Full state and local participation Entergy will continue to conduct drills, exercises, and other training activities at IPEC that exercise its emergency response strategies, as tabulated in the Attachment to this Enclosure.

New York State and local authorities recently participated in a September 23, 2020 limited participation drill, and are expected to participate in a full off-site state and local participation exercise on November 17, 2020. Entergy has shown a good faith effort to comply with the regulation by committing to support the November off-site exercise to ensure that New York State and the surrounding four counties can demonstrate objectives to FEMA for evaluation.

The demonstration criteria that cannot be observed by FEMA during this exercise, due to COVID-19 restrictions, will be demonstrated out of sequence, prior to December 31, 2020.

Upon completion of the November 17th exercise and out-of-sequence FEMA evaluations, all offsite criteria will be satisfactorily demonstrated, thus fulfilling the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c.

Entergy will reschedule the onsite portion of the biennial IPEC EP Exercise to occur prior to August 25, 2021, which is within 35 months from the month of the previously evaluated exercise (i.e., September 25, 2018). If this exemption request is granted to allow Entergy to conduct the

NL-20-069 Enclosure Page 3 of 5 IPEC CY 2020 biennial exercise in CY 2021, future biennial EP exercises will continue to be held in even years.

In addition, NRC Region I has indicated to Entergy that, if IPEC receives approval to reschedule the onsite portion of the currently scheduled biennial exercise until 2021, the scope of the planned EP Program inspection in November 2020, as documented in Reference 5, will be expanded to include the following additional NRC Inspection Procedures. This expanded EP Program Inspection will confirm, with reasonable assurance, Entergy's maintenance of an acceptable level of emergency preparedness during the exemption period.

• IP 71114.02, "Alert and Notification System Testing"

• IP 71114.03, "Emergency Response Organization Staffing and Augmentation System"

• IP 71114.05, "Maintenance of Emergency Preparedness" 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.

The justifications to allow an exemption to the onsite portion of a full-participation biennial EP exercise of 10 CFR 50, Appendix E, Section IV.F.2.b at IPEC are described below.

1. This exemption is authorized by law The biennial EP exercise for the emergency response organization specified in 10 CFR 50, Appendix E, Section IV.F.2.b 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 the Emergency Response Organization (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. Consistent with this requirement, Entergy has conducted numerous drills, exercises, and other training activities since the last evaluated biennial EP exercise, including activation of all onsite emergency response facilities during those drills with State participation. Most recently, these activities included a drill with State participation that was conducted on September 23, 2020, as well as the commitment to support a full off-site state and local participation exercise on November 17, 2020. Entergy has concluded that these measures have adequately exercised the principle functional areas of emergency response

NL-20-069 Enclosure Page 4 of 5 at IPEC, and will maintain an acceptable level of emergency preparedness during the exemption, thus satisfying the underlying purpose of the rule.

In addition, NRC Region I has indicated to Entergy that, if IPEC receives approval to defer the onsite portion of the currently scheduled biennial exercise until 2021, the scope of the planned EP Program inspection in November 2020, as documented in Reference 5, will be expanded to include the following additional NRC Inspection Procedures. This expanded EP Program Inspection will confirm, with reasonable assurance, Entergy's maintenance of an acceptable level of emergency preparedness during the exemption period.

IP 71114.02, "Alert and Notification System Testing" IP 71114.03, "Emergency Response Organization Staffing and Augmentation System" IP 71114.05, "Maintenance of Emergency Preparedness" Postponing the on-site portion of the Exercise from the previously scheduled date of November 17, 2020 to CY 2021 does not create any new accident precursors. The ability to reschedule the exercise in CY 2020 was not feasible due to the Exercise currently being scheduled in the month of November. 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 previously scheduled date of November 17, 2020, to CY 2021. This change to the EP exercise schedule 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, paragraph (a)(2) of the regulation states that the NRC will not consider granting an exemption unless special circumstances are present.

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 onsite EP exercise in CY 2021 instead of CY 2020 would grant only temporary relief from the applicable regulation. Entergy has made good faith efforts to comply with the regulation based on:

The drills, exercises, and training activities conducted at IPEC since the last evaluated biennial EP exercise; Completion of a limited state and local participation training drill on September 23, 2020; Entergy's efforts to coordinate a rescheduled date that is agreeable with FEMA, NRC Region I inspectors, the State of New York, and local counties; Entergy's planned support of the offsite portion (i.e., full state and local participation) of the November 2020 Exercise; and Entergy's planned support of an expanded NRC EP Program Inspection in 2020.

NL-20-069 Enclosure Page 5 of 5

5.0 CONCLUSION

As demonstrated above, Entergy 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 one-time schedular exemption from the biennial EP exercise requirements of 10 CFR 50, Appendix E, Section IV.F.2.b is required during the 2020 COVID-19 Pandemic.

6.0 ENVIRONMENTAL ASSESSMENT Entergy is requesting an exemption from certain requirements of 10 CFR 50, Appendix E, for IPEC. Specifically, Entergy is requesting a one-time schedular exemption from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.b for conducting a biennial EP exercise.

The following information is provided in support of an environmental assessment and finding of no significant impact for the proposed exemption.

Entergy has determined that the exemption involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite; that there is no significant increase in individual or cumulative public or occupational radiation exposure; that there is no construction impact; and there is no significant increase in the potential for or consequences from a radiological accident. 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 proposed exemption request.

7.0 REFERENCES

1. NRC Regulatory Issue Summary 2006-03, "Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements," (ADAMS Accession No. ML053390039), dated February 24, 2006

2. U.S. Nuclear Regulatory Commission (NRC) letter to Entergy Nuclear Operations, Inc (Entergy), "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," (ML20120A003), dated May 14, 2020

3. NRC letter to Entergy, "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,"

(ML20223A152), dated September 2, 2020

4. NRC Office of Nuclear Security and Incident Response (NSIR) Temporary Staff Guidance (TSG) TSG-NSIR-2020-01, " COVID-19 Related Exemptions from NRC Regulations - Emergency Preparedness Exercises," (ML20196M030), dated September 11, 2020

5. NRC letter to Entergy, "Updated Inspection Plan for Indian Point Energy Center, Unit 3 (Inspection Report 05000286/2020005)," (ML20237F429), dated August 31, 2020

Attachment to Enclosure NL-20-069 IPEC Emergency Response Organization Training and Drills Performed and Scheduled

NL-20-069 Attachment to Enclosure Page 1 of 9 IPEC Emergency Response Organization Training and Drills Performed and Scheduled Training or Evaluations IPEC Participation Integrated Capability and Functions Tested during this Drill/Training Offsite Response Organization (ORO)

Participation Radiological Radiological Monitoring Demonstrate the ability of a Field Monitoring Team (FMT) to support emergency N/A Environmental Teams operations through the response to and analysis of simulated elevated Monitoring Program Drill airborne/liquid samples following a simulated emergency event involving the October 17, 2018 release of radioactive material.

Accountability and Full station participation Demonstrate the ability to perform accountability for all individuals in the protected N/A Assembly Drill area within 30 minutes of declaration.

November 5, 2018 Training Drill "C" Team ERO-Full Accident Assessment and Classification No ORO participation December 12, 2018 station participation Command and Control Direction and coordination of the emergency response was received for this including all ERFs Technical Support Center Operations training drill. Entergy Offsite Liaisons Operations Support Center Operations reported to the State Alternate Emergency Operations Facility Operations and County Joint Information Center Operations Emergency Control Room Operations Operations Centers.

Incident Command Post Operation Public Alerting and Notification procedures Radiological Monitoring and Dose Assessment Protective Action Decision Making Demonstrate ability to monitor radiological releases to the environment in the field Demonstrate adequacy of the Offsite Monitoring Teams (OMTs) to support emergency response activities.

SAMG Training Engineering, Operations Implementation of Beyond Design Bases strategies, procedures, and guidance N/A January 2019 personnel; SAMG and integration of offsite resources with onsite response.

decision makers

NL-20-069 Attachment to Enclosure Page 2 of 9 IPEC Emergency Response Organization Training and Drills Performed and Scheduled Training or Evaluations IPEC Participation Integrated Capability and Functions Tested during this Drill/Training ORO Participation Training Drill "B" Team ERO-Full Accident Assessment and Classification State and Local January 23, 2019 station participation Command and Control Direction and coordination of the emergency response Governments for including all ERFs Technical Support Center Operations Communications and Operations Support Center Operations Notifications. Entergy Alternate Emergency Operations Facility Operations Offsite Liaisons Joint Information Center Operations reported to the State Control Room Operations and County Emergency Incident Command Post Operations Operations Centers.

Public Alerting and Notification procedures Radiological Monitoring and Dose Assessment Protective Action Decision Making Demonstrate ability to monitor radiological releases to the environment in the field Demonstrate adequacy of the OMTs to support emergency response activities.

Training Drill "C" Team ERO-Full Accident Assessment and Classification State and Local May 22, 2019 station participation Command and Control Direction and coordination of the emergency response Governments for including all ERFs Technical Support Center Operations Communications and Operations Support Center Operations/ Health Physics Drill (in-plant monitoring) Notifications. Entergy Emergency Operations Facility Operations Offsite Liaisons Joint Information Center Operations reported to the State Control Room Operations and County Emergency Incident Command Post Operations Operations Centers.

Public Alerting and Notification procedures Radiological Monitoring and Dose Assessment Accountability and Assembly Drill SAMG drill (Demonstrated the ability to implement Beyond Design Bases Mitigating Strategies)

Demonstrate ability to monitor radiological releases to the environment in the field Demonstrate adequacy of the OMTs to support emergency response activities.

Offsite Monitoring Team FMTs/Offsite Team Demonstrate ability to monitor radiological releases to the environment in the field N/A Training Coordinators Demonstrate adequacy of the OMTs to support emergency response activities.

July 2019

NL-20-069 Attachment to Enclosure Page 3 of 9 IPEC Emergency Response Organization Training and Drills Performed and Scheduled Training or Evaluations IPEC Participation Integrated Capability and Functions Tested during this Drill/Training ORO Participation Dose Assessment Dose Assessors and Demonstrate the capability to determine the magnitude of radioactive releases or N/A Training Radiological Assessment perform dose assessments based on plant parameters, effluent monitors, field August 2019 Coordinators data and meteorological conditions.

Demonstrate the ability to determine the release rate and projected dose when effluent monitors are off-scale or inoperable.

WANO Drill "D" Team ERO-Full Accident Assessment and Classification No ORO participation August 20, 2019 station participation Command and Control Direction and coordination of the emergency response was received for this including all ERFs Technical Support Center Operations training drill. Entergy Offsite Liaisons Operations Support Center Operations reported to the State Emergency Operations Facility Operations and County Joint Information Center Operations Emergency Control Room Operations Operations Centers.

Incident Command Post Operations Public Alerting and Notification procedures Radiological Monitoring and Dose Assessment Protective Action Decision Making Demonstrate ability to monitor radiological releases to the environment in the field Demonstrate adequacy of the OMTs to support emergency response activities.

Limited Scope Drill "A" Team EOF and JIC REMP Drill (Demonstrate the ability of an FMT to support emergency operations) Full State and Local September 10, 2019 facilities only Accident Assessment and Classification Government Command and Control Direction and coordination of the emergency response participation. This Emergency Operations Facility Operations demonstrated Communication Joint Information Center Operations between the nuclear Incident Command Post Operations facility, state and local Public Alerting and Notification procedures emergency Radiological Monitoring and Dose Assessment operations centers Protective Action Decision Making and field assessment Demonstrate ability to monitor radiological releases to the environment in the field teams. Entergy Demonstrate the adequacy of OMTs to support emergency response activities. Offsite Liaisons reported to the State and County Emergency Operations Centers.

NL-20-069 Attachment to Enclosure Page 4 of 9 IPEC Emergency Response Organization Training and Drills Performed and Scheduled Training or Evaluations IPEC Participation Integrated Capability and Functions Tested during this Drill/Training ORO Participation Training Drill "A" Team ERO-Full Accident Assessment and Classification Full State and Local November 20, 2019 station participation Command and Control Direction and coordination of the emergency response Government including all ERFs Technical Support Center Operations participation. This demonstrated Operations Support Center Operations/ Health Physics Drill (in-plant monitoring)

Communication Emergency Operations Facility Operations between the nuclear Joint Information Center Operations facility, state and local Control Room Operations emergency Incident Command Post Operations operations centers Public Alerting and Notification procedures and field assessment Radiological Monitoring and Dose Assessment teams. Entergy Offsite Liaisons Protective Action Decision Making reported to the State Health Physics In-Plant Monitoring and County Demonstrate ability to monitor radiological releases to the environment in the field Emergency Demonstrate adequacy of the OMTs to support emergency response activities. Operations Centers.

SAMG Training Engineering and Implementation of Beyond Design Bases strategies, procedures, and guidance N/A January 2020 Operations/SAMG and integration of offsite resources with onsite response.

decision makers Training Drill "D" Team ERO-Full Accident Assessment and Classification State and Local January 29, 2020 station participation Command and Control Direction and coordination of the emergency response Governments for including all ERFs Technical Support Center Operations Communications and Notifications. Entergy Operations Support Center Operations/ Health Physics Drill (in-plant monitoring)

Offsite Liaisons Emergency Operations Facility Operations reported to the State Joint Information Center Operations and County Control Room Operations Emergency Incident Command Post Operations Operations Centers.

Public Alerting and Notification procedures Health Physics In-Plant Monitoring Radiological Monitoring and Dose Assessment Demonstrate ability to monitor radiological releases to the environment in the field Demonstrate adequacy of the OMTs to support emergency response activities.

NL-20-069 Attachment to Enclosure Page 5 of 9 IPEC Emergency Response Organization Training and Drills Performed and Scheduled Training or Evaluations IPEC Participation Integrated Capability and Functions Tested during this Drill/Training ORO Participation TSC/OSC Tabletop Drill All TSC/OSC Demonstrate the adequacy of the OSC to support emergency response activities. No ORO participation June 22-25, 2020 Participants Demonstrate the adequacy of the TSC to support emergency response activities. was received for this training drill.

(A)EOF Tabletop Drill All (A)EOF Participants Demonstrate the adequacy of the EOF to support emergency response activities. No ORO participation July 20-24, 2020 Accident Assessment and Classification was received for this Command and Control Direction and Coordination of the Emergency response training drill.

Public Alerting and Notification Procedures Protective Action Decision-making Offsite Monitoring Team FMTs/Offsite Team Demonstrate ability to monitor radiological releases to the environment in the field N/A Training Coordinators Demonstrate adequacy of the OMTs to support emergency response activities.

August 2020 JIC Tabletop Drill All JIC Participants JIC Support of Emergency Operations No ORO participation August 17-21, 2020 Media Briefings was received for this Exchange of Public Information training drill.

Public Inquiry (Rumor Control)

Release of Information Limited Scope Drill "B" Team ERO-minimum Accident Assessment and Classification State & local September 23, 2020 Staffing in all ERFs Command and Control Direction and coordination of the emergency response Governments for (COVID-19 controls) Technical Support Center Operations Communications, PIO and participation in Operations Support Center Operations/ Health Physics Drill (in-plant monitoring)

OMT Teams. This Alternate Emergency Operations Facility Operations demonstrates Joint Information Center Operations Communication Control Room Operations between the nuclear Public Alerting and Notification procedures facility, state & local Radiological Monitoring and Dose Assessment EOCs and OMT Protective Action Decision Making teams. Entergy Offsite Liaisons reported to the State and County Emergency Operations Centers.

Accountability and Full station participation Demonstrate the ability to perform accountability for all individuals in the protected N/A Assembly Drill area within 30 minutes of declaration October 2020

NL-20-069 Attachment to Enclosure Page 6 of 9 IPEC Emergency Response Organization Training and Drills Performed and Scheduled Training or Evaluations IPEC Participation Integrated Capability and Functions Tested during this Drill/Training ORO Participation Training Drill "D" Team ERO-Full Accident Assessment and Classification TBD January 20, 2021 station participation Command and Control Direction and coordination of the emergency response including all ERFs Technical Support Center Operations Post Shut down ERO Operations Support Center Operations/ Health Physics Drill (in-plant monitoring)

Emergency Operations Facility Operations Joint Information Center Operations Control Room Operations Incident Command Post Operations Public Alerting and Notification procedures Radiological Monitoring and Dose Assessment Protective Action Decision Making Health Physics In-Plant Monitoring Demonstrate ability to monitor radiological releases to the environment in the field Demonstrate adequacy of the OMTs to support emergency response activities.

Training Drill "B" Team ERO-Full Accident Assessment and Classification TBD February 3, 2021 station participation Command and Control Direction and coordination of the emergency response including all ERFs Technical Support Center Operations Post Shut down ERO Operations Support Center Operations Emergency Operations Facility Operations Joint Information Center Operations Control Room Operations Incident Command Post Operations Public Alerting and Notification procedures Radiological Monitoring and Dose Assessment Protective Action Decision Making Demonstrate ability to monitor radiological releases to the environment in the field Demonstrate adequacy of the OMTs to support emergency response activities.

NL-20-069 Attachment to Enclosure Page 7 of 9 IPEC Emergency Response Organization Training and Drills Performed and Scheduled Training or Evaluations IPEC Participation Integrated Capability and Functions Tested during this Drill/Training ORO Participation Training Drill "A" Team ERO-Full Accident Assessment and Classification TBD February 24, 2021 station participation Command and Control Direction and coordination of the emergency response including all ERFs Technical Support Center Operations Post Shut down ERO Operations Support Center Operations Emergency Operations Facility Operations Joint Information Center Operations Control Room Operations Incident Command Post Operations Public Alerting and Notification procedures Radiological Monitoring and Dose Assessment Protective Action Decision Making Demonstrate ability to monitor radiological releases to the environment in the field Demonstrate adequacy of the OMTs to support emergency response activities.

Training Drill "C" Team ERO-Full Accident Assessment and Classification TBD March 10, 2021 station participation Command and Control Direction and coordination of the emergency response including all ERFs Technical Support Center Operations Post Shut down ERO Operations Support Center Operations Emergency Operations Facility Operations Joint Information Center Operations Control Room Operations Incident Command Post Operations Public Alerting and Notification procedures Radiological Monitoring and Dose Assessment Protective Action Decision Making Demonstrate ability to monitor radiological releases to the environment in the field Demonstrate adequacy of the OMTs to support emergency response activities.

NL-20-069 Attachment to Enclosure Page 8 of 9 IPEC Emergency Response Organization Training and Drills Performed and Scheduled Training or Evaluations IPEC Participation Integrated Capability and Functions Tested during this Drill/Training ORO Participation NRC Evaluated "D" Team ERO-Full Accident Assessment and Classification TBD Exercise-Reduced station participation Command and Control Direction and coordination of the emergency response Staffing ERO (proposed including all ERFs Technical Support Center Operations dates)

Operations Support Center Operations March 17, 2021 or April 14, 2021 Emergency Operations Facility Operations Joint Information Center Operations Control Room Operations Incident Command Post Operations Public Alerting and Notification procedures Radiological Monitoring and Dose Assessment Protective Action Decision Making Demonstrate ability to monitor radiological releases to the environment in the field Demonstrate adequacy of the OMTs to support emergency response activities.

Training Drill "D" Team ERO-Full Accident Assessment and Classification TBD September 1, 2021 station participation Command and Control Direction and coordination of the emergency response including all ERFs Technical Support Center Operations Post Shut down ERO Operations Support Center Operations Emergency Operations Facility Operations Joint Information Center Operations Control Room Operations Incident Command Post Operations Public Alerting and Notification procedures Radiological Monitoring and Dose Assessment Protective Action Decision Making Demonstrate ability to monitor radiological releases to the environment in the field Demonstrate adequacy of the OMTs to support emergency response activities.

NL-20-069 Attachment to Enclosure Page 9 of 9 IPEC Emergency Response Organization Training and Drills Performed and Scheduled Training or Evaluations IPEC Participation Integrated Capability and Functions Tested during this Drill/Training ORO Participation Training Drill "A" Team ERO-EOF/JIC Accident Assessment and Classification TBD participation only Command and Control Direction and coordination of the emergency response November 3, 2021 Emergency Operations Facility Operations Joint Information Center Operations Post Shut down ERO Control Room Operations Incident Command Post Operations Public Alerting and Notification procedures Radiological Monitoring and Dose Assessment Protective Action Decision Making Demonstrate ability to monitor radiological releases to the environment in the field Demonstrate adequacy of the OMTs to support emergency response activities.

Training Drill "A" Team ERO-EOF/JIC Accident Assessment and Classification TBD participation only Command and Control Direction and coordination of the emergency response December 1, 2021 Technical Support Center Operations Operations Support Center Operations Post Shut down ERO Emergency Operations Facility Operations Joint Information Center Operations Control Room Operations Incident Command Post Operations Public Alerting and Notification procedures Radiological Monitoring and Dose Assessment Protective Action Decision Making Demonstrate ability to monitor radiological releases to the environment in the field Demonstrate adequacy of the OMTs to support emergency response activities.