ML20288A347

(COVID-19) Emergency Preparedness Exemption Pre-Application Meeting

ML20288A347
Person / Time
Site:	North Anna
Issue date:	10/14/2020
From:	Geoffrey Miller Plant Licensing Branch II
To:	Stoddard D Southern Nuclear Operating Co
Miller G
References
Download: ML20288A347 (14)

Text

Purpose

• Dominion Energy Virginia will be requesting a one-time schedular exemption from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c for NAPS because the August 18, 2020 NAPS biennial Emergency Preparedness (EP) exercise was conducted without full ORO participation due to the potential spread of COVID

• During this meeting, Dominion Energy Virginia will:

Brief NRC on the proposed exemption request, supporting information, and proposed timeline Discuss the exemption request prior to formal submittal Provide information to ensure a common understanding of the exemption request, its scope and the regulatory expectations 2 October 13, 2020

Proposed Exemption

• Dominion Energy Virginia is requesting an exemption to postpone the Calendar Year (CY) 2020 offsite biennial EP exercise until CY 2021 The August 18, 2020 NAPS biennial EP exercise was conducted without full ORO participation, placing the exercise outside the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c The last NAPS biennial EP exercise that was federally-evaluated by Federal Emergency Management Agency (FEMA) was held on July 17, 2018 3 October 13, 2020

Regulatory Requirements 10 CFR 50.47 (b)(14) - Conduct periodic exercises 10 CFR 50 Appendix E IV.F.2.c - Offsite Biennial Exercise 4 October 13, 2020

Basis for Request & Precedent

• Meeting the requirements of 10 CFR 50 Appendix E, Section IV.F.2.c requires the NAPS offsite biennial EP exercise to be performed in CY 2020 Exemption Request will be submitted to conduct this exercise in CY 2021, as authorized by 10 CFR 50.12, Specific Exemptions Exemption Request will address the guidance criteria contained in Regulatory Issue Summary (RIS) 2006-03, Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements Exemption Request will address the guidance criteria contained in NRCs 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" 5 October 13, 2020

Reasons for Request

• Ongoing response to the COVID-19 pandemic Public Health Emergency (PHE) declared on January 30, 2020 On March 12, 2020, a State of Emergency was declared in Virginia, and then Nationally on March 13, 2020 The COVID-19 PHE created special circumstances (per 10 CFR 50.12) that precluded NAPS and the Commonwealth of Virginia from conducting a full participation biennial EP exercise in August of 2020 6 October 13, 2020

Reasons for Request

• An exemption is needed for Dominion Energy Virginia to reduce the exposure risk to responders/essential workers and to adhere to Center for Disease Control and Prevention (CDC) recommended guidelines

• Commonwealth of Virginia, as well as municipal stakeholders, are engaged in pandemic response Resources for exercise preparation and participation would compete with resources devoted to pandemic response

• Gathering a large group of people (including players, controllers, evaluators) for an exercise when there is no actual emergency:

Puts all participants at risk Conflicts with practices recommended by the CDC 7 October 13, 2020

Scheduling Considerations

• A good faith effort was made to reschedule and conduct the exercise in 2020, but Dominion Energy Virginia and the Commonwealth of Virginia determined they could not participate until 2021

• In addition to ongoing COVID-19 concerns, Dominion Energy Virginias schedule challenges in 2020 include:

2020 Fall North Anna Unit 2 refueling outage Potential conflicts with FEMA Region 3 participation Conversion of Offsite Notification System from Insta- phone to Electronic Conversion of emergency action levels (EAL) program from previous standards (NEI 99-01, Revision 4) to use NEI 99-01, Rev.6

• A proposed date of February 23, 2021 can be supported by all parties for a full-participation offsite biennial EP exercise

• FEMA in-person evaluation is expected but arrangements will be implemented or a virtual evaluation performed, if necessary 8 October 13, 2020

Justification - RIS 2006-03 Guidance

• RIS 2006-03 states that in most cases, the postponed exercise still falls within the 35-month window The proposed one-time change in the NAPS offsite biennial EP exercise to February 23, 2021 is 31 months from the last biennial exercise which meets the intent of the regulation

• The exemption request will:

Justify that postponing the offsite biennial EP exercise does not pose an undue risk to public health and safety Specify that both Dominion Energy Virginia and the Commonwealth of Virginia understand that if the requested exemption is granted allowing NAPS to conduct the CY 2020 offsite biennial EP exercise in CY 2021, subsequent biennial exercises will be held in even numbered years Conform to the remaining guidance provided in RIS 2006-03 9 October 13, 2020

Justification - Guidance in NRC to NEI Letter, dated May 14, 2020

• The exemption request will:

Provide the last full-participation biennial EP exercise date State that reasonable effort was made to reschedule the offsite biennial EP exercise in CY 2020, but was unsuccessful Provide the proposed rescheduled offsite biennial EP exercise date and indicate that this date has been coordinated with the Commonwealth of Virginia and FEMA Region 3 State that Dominion Energy Virginia has conducted drills, exercises, and other training activities that have exercised the emergency response strategies, in coordination with offsite authorities, since the previous biennial exercise 10 October 13, 2020

Applicability & Inspection History

• FEMA has not conducted any evaluations of the Risk Jurisdictions around NAPS since the July 2018 biennial EP exercise which had zero Findings of Significance and zero Programmatic Issues

• Commonwealth of Virginia was evaluated by FEMA during the 2019 Surry Power Station biennial EP exercise Risk Jurisdictions around NAPS are evaluated every 2 years Commonwealth of Virginia is evaluated annually

• The exemption request will demonstrate that rescheduling of the NAPS offsite biennial EP exercise will support COVID-19 mitigation and prevention activities and will not present an undue risk to the public health and safety 11 October 13, 2020

Precedents

• Impact of COVID-19 has resulted in Exercise Exemption Request submittals (currently under NRC review)

From IV.F.2.c for the following plants:

Beaver Valley, Units 1 & 2 (ML20266G366)

Peach Bottom, Units 1, 2 & 3 (ML20269A267)

Palisades (ML20275A110)

From IV.F.2.b and IV.F.2.c for the following plants:

Joseph M. Farley, Units 1 & 2 (ML20265A353)

Duane Arnold (ML20266G292)

Prairie Island, Units 1 & 2 (ML20281A665) 12 October 13, 2020

Schedule

• Exemption submittal Week of November 16, 2020

• NRC approval Requested by December 21, 2020 Based on the requirements for offsite biennial EP exercise participation expiring at the end of 2020 13 October 13, 2020

Summary

• Subsequent to March 13, 2020, isolation activities (e.g.,

social distancing, group size limitations, self-quarantining, etc.) were implemented to prevent the spread of COVID

• NAPS is requesting a one-time schedular exemption from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c for NAPS because the August 18, 2020 NAPS biennial Emergency Preparedness (EP) exercise was conducted without full ORO participation

• Exemption request IAW requirements of RIS 2006-03 and NEI letter to NRC dated May 14, 2020

• Consistent with Precedent - Submittals approved and under review 14 October 13, 2020