GO2-20-130, Exemption Request from 10 CFR 50 Appendix Due to COVID-19 Pandemic

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Exemption Request from 10 CFR 50 Appendix Due to COVID-19 Pandemic
ML20303A348
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 10/29/2020
From: Schuetz R
Energy Northwest
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-20-130
Download: ML20303A348 (24)
v • d • e


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ENERGY R.E. Schuetz Site Vice President NORTHWEST P.O. Box 968, PE23 Richland, WA 99352-0968 Ph. 509.377.2425 l F. 509.377.4140 reschuetz@energy-northwest.com October 29, 2020 GO2-20-130 10 CFR 50.12 10 CFR 50, Appendix E U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397; EXEMPTION REQUEST FROM 10 CFR 50 APPENDIX E DUE TO COVID-19 PANDEMIC

Dear Sir or Madam:

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 COVID-19 outbreak a national emergency. In addition, Washington State Governor Jay Inslee declared a state of emergency on February 29, 2020.

Because of the COVID-19 PHE, Energy Northwest has determined that an exemption is needed from the biennial emergency plan exercise requirements that are specified in 10 CFR Part 50, Appendix E, Sections IV.F.2.b. and IV.F.2.c., as meeting these requirements would likely conflict with practices recommended by the Centers for Disease Control and Prevention (CDC) to limit the spread of COVID-19. Additionally, required Offsite Response Organizations (ORO) have agreed that Energy Northwest should submit an exemption request to postpone the exercise, most recently scheduled for October 27, 2020.

In accordance with 10 CFR 50.12, "Specific Exemptions," paragraph (a)(2)(v), Energy Northwest requests an exemption for Columbia Generating Station (Columbia) from the requirement to conduct biennial emergency plan exercise requirements specified in 10 CFR 50, Appendix E, Sections IV.F.2.b. and IV.F.2.c. Specifically, Energy Northwest requests a one-time schedular exemption to postpone the joint, full participation biennial emergency preparedness exercise until calendar year (CY) 2021.

 

 



 

  





 







GO2-20-130 Page 2 of 3 Energy Northwest has made a reasonable effort to reschedule and complete the Columbia planned exercise in CY 2020 but has been unsuccessful due to the sustained and continuing impact of the nationwide PHE. Energy Northwest has been unable to find a date in CY 2020 that would factor in a possible reduction of the impact of the PHE on the conduct of the CY 2020 exercise which was originally scheduled for March 24, 2020, and then rescheduled to occur on October 27, 2020 in an effort to allow the COVID-19 PHE to resolve. Energy Northwest and the pertinent OROs have determined that the PHE conditions will not sufficiently improve by the end of CY 2020 to support the safe conduct of a full participation exercise.

Supporting letters from Benton and Franklin counties Emergency Management offices and the States of Washington and Oregon are attached to this letter (Attachments 1 through 4, respectively.)

Benton and Franklin counties (the counties located within the 10-mile emergency planning zone (EPZ); Columbia is located in Benton County) along with the States of Washington and Oregon have communicated to Energy Northwest that the current COVID-19 pandemic response has impacted their ability to prepare for the scheduled exercise. Each of these OROs has also affirmed that supporting the exercise in October 2020 would place undue burden on existing resources that are managing the ongoing PHE. Benton and Franklin counties indicated they would be unable to support the exercise as planned without compromising their current social distancing practice which would be inconsistent with current Benton Franklin Health District and Washington state pandemic response directives, mandates, and protocols. Further, these OROs continue to maintain readiness to respond to an actual radiological emergency at Columbia. This exemption request will allow state and local governments to continue to focus their essential response efforts on the COVID-19 PHE and other actual events that may occur during the COVID-19 PHE.

Energy Northwest similarly concluded that the threat of COVID-19 has resulted in the inability to safely conduct the biennial emergency preparedness (EP) exercise that was scheduled for October 2020 due to the continuing need to implement isolation activities such as social distancing, group size limitations, and, when necessary, self-quarantining.

Since the previous biennial exercise on March 27, 2018, Energy Northwest has successfully conducted drills, exercises, and other training activities that exercised emergency response strategies, in coordination with offsite authorities.

Energy Northwest will coordinate with the State of Washington, Oregon Department of Energy, Benton and Franklin counties, U.S. Nuclear Regulatory Commission (NRC)

Region lV, and Federal Emergency Management Agency (FEMA) Region X to reschedule the biennial exercise for Columbia. A nominal date in October 2021 is currently being coordinated for a joint biennial exercise.

The basis for a fall 2021 exercise date has been discussed with NRC Region IV and is described in the Enclosure, Temporary Exemption Request from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements. In addition, because the

 

 



 

  



 







GO2-20-130 Page 3 of 3 proposed fall 2021 exercise date is more than 35 months from the CY 2018 biennial exercise date (March 27, 2018), a November 2, 2020, date was coordinated with the senior Region IV EP inspector for performance of an EP Baseline Program Inspection.

This exemption, if approved, will be in effect until the performance of the rescheduled biennial exercise in CY 2021, per the specific direction of the NRC's approval of the exemption.

Energy Northwest understands that such approval would not preclude the request and approval of a subsequent additional exemption period should the PHE conditions not resolve sufficiently or should another significant unanticipated circumstance occur before the end of the exemption period. However, Energy Northwest understands that an additional exemption request would be required to be submitted should such unlikely circumstances occur.

Energy Northwest requests expedited approval of this temporary exemption request by no later than December 31, 2020.

There are no new commitments in this letter.

Should you have any questions or desire additional information regarding this matter, please contact Mr. Stephen M. Sullivan, Emergency Preparedness Manager, at (509) 377-8019.



Executed on the _____ day of October, 2020.

Respectfully, R.E. Schuetz Site Vice President

Enclosure:

Temporary Exemption Request from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements Attachment 1: Letter from Benton County Emergency Services to Energy Northwest Attachment 2: Letter from Franklin County Emergency Management to Energy Northwest Attachment 3: Letter from State of Washington to Energy Northwest Attachment 4: Letter from State of Oregon Department of Energy to Energy Northwest cc: NRC Region IV Administrator NRC Sr. Resident Inspector NRC NRR Project Manager CD Sonoda, BPA S. Williams, Washington Emergency Management Division R. Brice, Washington Department of Health

 

 



 

  





 







GO2-20-130 Enclosure Enclosure Temporary Exemption Request from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements

 

 



 

  





 







GO2-20-130 Enclosure Page 1 of 8 Temporary Exemption Request from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements 1.0 Summary Description of Exemption Request In response to the special circumstances resulting from the on-going Coronavirus Disease 2019 (COVID-19) public health emergency (PHE) and in accordance with 10 CFR 50.12, Specific exemptions, Energy Northwest requests a one-time schedular exemption for Columbia Generating Station (Columbia) and associated Offsite Response Organizations (OROs) which would provide temporary relief from the requirements to conduct a joint, full participation biennial emergency preparedness (EP) exercise as specified in 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities sections IV.F.2.b and IV.F.2.c.

This one-time schedular exemption to allow Energy Northwest and relevant OROs to conduct the full participation biennial EP exercise in calendar year (CY) 2021 is needed to support continued implementation of the isolation activities (e.g., social distancing, group size limitations, self-quarantining) currently implemented to protect critical personnel and required emergency response organization (ERO) personnel as a result of the ongoing COVID-19 PHE. These protective strategies are needed now and in the foreseeable future to ensure ERO personnel are isolated from the COVID-19 virus and remain capable of executing the functions of the ERO, as described in the Columbia Emergency Plan.

Additionally, these protective strategy activities are needed to ensure supporting state and local government emergency management personnel and federal evaluators are similarly protected from transmission of the COVID-19 virus and remain capable of executing their emergency response functions in the event of an actual Columbia emergency or in response to other non-nuclear health and safety functions for the broader benefit of the public. As a result of discussions among the licensee, State, local officials, U.S. Nuclear Regulatory Commission (NRC) and Federal Emergency Management Agency (FEMA), Energy Northwest has concluded that scheduling the exercise in CY 2020 would not be reasonable during the current COVID-19 PHE conditions and upon exemption approval will coordinate a date in the fall of CY 2021 for a joint biennial exercise.

2.0 Background

Because of the COVID-19 PHE, Energy Northwest has determined that an exemption is needed from the biennial emergency plan exercise requirements that are specified in 10 CFR Part 50, Appendix E, Sections IV.F.2.b. and IV.F.2.c., as meeting these requirements would likely conflict with practices recommended by the Centers for Disease Control and Prevention (CDC), Washington State, and Columbias Pandemic Plan to limit the spread of COVID-19. In order to fulfill the exercise requirements of Section IV.F.2.b., Energy Northwest would need to staff emergency centers in a manner that would compromise current social distancing strategies and would be

 

 



 

  





 







GO2-20-130 Enclosure Page 2 of 8 inconsistent with current local and state pandemic response guidelines regarding non-essential activities.

Additionally, required OROs have determined conducting an exercise in October 2020, to fulfill Section IV.F.2.c., would compromise current social distancing practices and would be inconsistent with current Benton Franklin Health District and Washington State pandemic response directives, mandates, and protocols.

If this exemption request is approved, the completion of this deferred biennial exercise by the end of calendar 2021 will allow Energy Northwest to complete the exercise requirements associated with the current 8-year exercise inspection cycle - including those associated with 10 CFR Part 50, Appendix E, Sections IV.F.2.d and IV.F.2.j

[including § 50.155(b)(2)] - within the current nominal 8-year cycle. The Columbia 8-year inspection cycle began in 2014 following the August 26, 2014, Hostile Action Based Exercise.

Columbias most recent joint biennial emergency response exercise was conducted on March 27, 2018.

This biennial exercise was originally scheduled for March 24, 2020, but was rescheduled to October 27, 2020, (within calendar 2020) following the declaration of the COVID-19 PHE to allow time for the PHE to resolve and allow the exercise to be performed within the originally scheduled calendar year.

Energy Northwest has implemented isolation activities (e.g., social distancing, group size limitations, self-quarantining) to protect site workers (including emergency response organization personnel) in response to the COVID-19 PHE. In addition, Energy Northwest has received clear statements from OROs supporting the requested exemption from conducting an exercise in CY 2020. ORO support for this position is included in the attached letters. Performance of a full participation biennial exercise during the COVID-19 PHE presents a significant potential health risk for those involved, due to the potential for exposure to COVID-19. Such exposure to COVID-19 could impact participants subsequent ability to perform required duties safely in both dealing with COVID-19 and other actual emergencies that may arise during the PHE.

Conducting an exercise during the COVID-19 PHE presents unnecessary risk of impacting both the licensees and OROs ability to respond to an actual emergency at Columbia. Deferring the exercise to the fall of 2021 has a reasonable likelihood of reducing that risk. Energy Northwest discussed a tentative date of October 26, 2021 with ORO officials in preparation for scheduling a joint biennial exercise in fall 2021.

 

 



 

  





 







GO2-20-130 Enclosure Page 3 of 8 Because the proposed fall 2021 exercise date is more than 35 months from the CY 2018 biennial exercise date (March 27, 2018), a November 2, 2020, date was coordinated with the senior Region IV EP inspector for performance of an EP Baseline Program Inspection.

Energy Northwest has begun and will continue to coordinate with applicable OROs, NRC Region IV, and FEMA Region X to finalize the exercise date in the fall of 2021.

Following the Columbia biennial exercise in the fall of 2021, future Columbia biennial exercises would continue to be held in even years, with the exercise schedule resuming in 2022.

3.0 Technical Justification of Acceptability The CDC has issued recommendations advising social distancing to prevent the spread of the COVID-19 virus. Energy Northwest along with its state and local emergency management organizations, have implemented pandemic plans that include social distancing, group size limitations, and self-quarantine protocols. Ideally, these protocols will limit the spread of the virus among the station staff and off-site personnel.

Since its last biennial EP exercise on March 27, 2018, Energy Northwest has conducted numerous drills, exercises, and other training activities that have exercised its emergency response strategies and demonstrated proficiency. State and local officials participated in these activities exercising various EP program elements during the following months:

  • May 2018
  • July 2018
  • September 2018
  • February 2019
  • July 2019
  • September 2019
  • October 2019
  • February 2020
  • August 2020 (involved reduced center staffing due to COVID-19 protocols).

Energy Northwest will continue to conduct drills, tabletops, and other training activities that exercise its emergency response strategies and demonstrate proficiency to the extent reasonable during the pandemic PHE. The associated OROs have committed to continue to maintain their current emergency plans and ability to respond to an actual emergency during the pandemic. These state and local authorities are expected to participate in drills to the extent practical while also complying with the

 

 



 

  





 







GO2-20-130 Enclosure Page 4 of 8 CDC recommendations to limit the spread of COVID-19. The extension afforded by an exemption would not hinder the ability to respond should an actual emergency occur.

Energy Northwest has made a reasonable effort to reschedule and complete the Columbia planned exercise in CY 2020 but has been unsuccessful due to the sustained and continuing impact of the nationwide PHE. Energy Northwest has been unable to find a date in CY 2020 that would factor in a possible reduction of the impact of the PHE on the conduct of the CY 2020 exercise which was originally scheduled for March 24, 2020, and then rescheduled to occur on October 27, 2020.

Energy Northwest and the pertinent OROs have determined that the PHE conditions will not sufficiently improve by the end of CY 2020 to support the safe conduct of a full participation exercise.

Due to the uncertainty of COVID-19 isolation actions, and scheduling conflicts (described below), it is not feasible to reschedule in the first three quarters of CY 2021.

A date in the fourth calendar quarter of 2021 will allow for a joint exercise to be conducted:

x if the PHE conditions improve sufficiently to hold a joint exercise safely, x after the Columbia refueling outage in second calendar quarter of 2021, and x after the summer fire season can be reasonably expected to end after late September 2021.

As noted previously, Energy Northwest is currently coordinating a tentative for a joint biennial exercise date in the month of October 2021. Rescheduling the biennial exercise from CY 2020 to CY 2021 will require an exemption to biennial EP exercise requirements in 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c.

4.0 Regulatory Justification for Exemption 10 CFR 50.12, Specific exemptions, states that the NRC may grant exemptions from the requirements of the regulations of Part 50 provided:

(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.

 

 



 

  





 







GO2-20-130 Enclosure Page 5 of 8 The basis for an exemption to conducting the full participation biennial EP exercise of 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c at Columbia in calendar 2020 are described below.

1. This exemption is authorized by law.

The requested exemption of the biennial EP exercise for the emergency response organization specified in 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c is authorized by law, and no other prohibition of law exists to preclude the activities that would be authorized by the exemption request. Granting of the request is permissible under 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, Sections IV.F.2.b and IV.F.2.c requiring licensees to conduct a biennial EP exercise is to ensure that emergency response personnel (onsite and offsite, respectively) are familiar with their duties and to test the adequacy of the emergency plan as well as to identify and correct any weaknesses that may exist in the program. The underlying purpose of Section IV.F.2.c is also test and maintain interfaces among affected state and local authorities and the licensee. 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.

Energy Northwest has conducted training drills (see section 3 above) exercising the principal functional areas of emergency response since the last evaluated biennial EP exercise and has activated all onsite emergency response facilities during those drills with state and local participation. Energy Northwest considers that these measures maintain an acceptable level of emergency preparedness during the exemption period sufficient to satisfy the underlying purpose of the rule and provide reasonable assurance this exemption will not present an undue risk to the public health and safety.

Postponing the exercise from the 2020 date does not create any new accident precursors, and the probability and consequences of postulated accidents are not increased. Therefore, the requested exemption will not present an undue risk to the public health and safety.

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

The proposed exemption would allow rescheduling of the joint biennial EP exercise from the scheduled date of October 27, 2020, to the Fall of CY 2021. This change to the EP exercise schedule is not related to security issues. The common defense and security are not impacted by this exemption.

 

 



 

  





 







GO2-20-130 Enclosure Page 6 of 8 In addition to the three conditions discussed above, paragraph (a)(2) of 10 CFR 50.12, Specific exemptions, 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, Application 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, Sections IV.F.2.b and IV.F.2.c require Energy Northwest and responsible OROs to conduct a full participation biennial exercise of the Columbia Emergency Plan biennially. The underlying purpose of this requirement is to ensure that emergency response personnel are familiar with their duties and to test the adequacy of emergency plans as well as to identify and correct any weaknesses that may exist in the program. The underlying purpose of Section IV.F.2.c is also to test and maintain interfaces among affected state and local authorities and the licensee.

Energy Northwest has conducted training drills (see section 3 above) exercising the principal functional areas of emergency response since the last evaluated biennial EP exercise and has activated all onsite emergency response facilities during those drills with state and local participation. Energy Northwest 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 also 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.

Energy Northwest has made a good faith effort to comply with the regulations based on the following:

  • Training and drills have been conducted since the last evaluated biennial EP exercise,
  • Training and drills are scheduled to be conducted between now and the biennial EP exercise that would be conducted in CY 2021, and
  • Efforts were made to schedule a new biennial EP exercise date in CY 2020 with FEMA, NRC Region IV inspectors, state and local emergency management officials.

5.0 Exemption Request Energy Northwest, with support from its associated responsible ORO partners, requests a one-time schedular exemption from 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c to reschedule the joint biennial EP exercise (most recently planned for October 27, 2020) to the fall of 2021 to occur prior to December 31, 2021.

 

 



 

  





 







GO2-20-130 Enclosure Page 7 of 8 The tentative date currently being coordinated for the rescheduled joint biennial exercise is October 26, 2021.

6.0 Conclusion As discussed above, Energy Northwest 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 EP exercise requirements of 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c due to the COVID-19 PHE is therefore warranted.

7.0 Environmental Assessment As previously stated, Energy Northwest is requesting a one-time schedular 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.

Energy Northwest has determined that the exemption would not change requirements with respect to installation or use of a facility component located within Columbia's restricted area, as defined in 10 CFR 20, nor would it change an inspection or surveillance requirement. Energy Northwest has evaluated the proposed exemption and has determined that the exemption does not involve, (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed exemption meets the eligibility criteria for categorical exclusion in accordance with 10 CFR 51.22(c).

The requirements to which the exemption applies involve biennial EP exercise scheduling; therefore, the exemption meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22 sections (c)(25)(vi)(E), Education, training, experience, qualification, requalification, or other employment suitability requirements and (c)(25)(vi)(G), Scheduling requirements.

The proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(25). Therefore, 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.

 

 



 

  





 







GO2-20-130 Enclosure Page 8 of 8 References

1. Letter; H. Nieh and R. Lewis to NEI; 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, May 14, 2020; ML20120A003.
2. Letter; H. Nieh to NEI; 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, September 2, 2020; ML20223A152.
3. NRC Regulatory Issue Summary 2006-03; Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements, February 24, 2006; ML053390039.
4. NSIR Temporary Staff Guidance TSG-NSIR-2020-01; COVID-19 Related Exemptions from NRC Regulations - Emergency Preparedness Exercises, September 11, 2020; ML20196M030.

 

 



 

  





 







GO2-20-130 Attachment 1 Letter from Benton County Emergency Services to Energy Northwest On behalf of Benton County (Columbia Generating Stations host county)

 

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BENTON COUNTY IJJ SECO EMERGENCY SERVICES 651 Truman Avenue

~4-J-c>Nco Richland, Washington 99352 (509) 628-2600 Sept 25, 2020 Stephen M. Sullivan Energy Northwest P.O. Box 968 / MD PE30 Richland, WA, 99352 Re: October 27, 2020 REPP Evaluated Exercise

Dear Mr. Sullivan,

During this worldwide COVID-19 pandemic, Benton County Emergency Management (BCEM) continues to maintain the capability to protect the health and safety of the public in the areas of Benton County surrounding Columbia Generating Station.

We are currently scheduled to support a Radiological Emergency Preparedness Program (REPP) evaluated exercise in conjunction with Energy Northwest and along with other ORO entities on October 27, 2020. The planned exercise was deferred from its original March 24, 2020, date in the hope that COVID-19 would resolve sufficiently to allow the exercise to be performed in October.

However, despite our joint efforts to identify a time in this calendar year when it would be reasonable to plan for and participate in a joint, full-scale exercise, the continuing significant impact of the COVID-19 pandemic has made that outcome unrealistic for the remainder of 2020 and likely into at least the first half of 2021.

The on-going COVID-19 pandemic public health emergency presents significant challenges to ensuring the continued health and safety of those individuals scheduled to participate in that exercise for the following reasons:

  • Most Benton County emergency response personnel are supporting the COVID-19 pandemic in varying capacities and are expected to continue doing so through at least the end of calendar 2020. Participation in preparing for and participating in the scheduled CGS evaluated exercise would create an additional burden on our response personnel.
  • Due to the large number of COVID-19 cases in Benton County the exposure risks to this virus would be significantly increased due to the need to co-locate additional response personnel/workers inside the Benton County EOC and Columbia Generating Station Emergency Operations Facility and Joint Information Center.
  • Physically staffing of the Emergency Operations Center with the necessary emergency response personnel/workers and support staff would compromise our current social distancing practice Page 1 of 2

 

 



 

  





 







and would be inconsistent with current Benton Franklin Health District and WA State pandemic response directives/mandates/protocols.

  • Any COVID-19 cases resulting from a positive test for a participant of this exercise could unnecessarily limit the availability of the staff to support their current emergency response COVID-19 role.

The potential to expose emergency response personnel/workers and support staff participating in an exercise during the COVID-19 pandemic public health emergency is very real, and therefore, not warranted.

As a result of these health and safety impacts from this emergency, Benton County Emergency Management requests the exercise be moved out to the Fall 2021 timeframe and is in agreement with the licensees intent to request an exemption to defer said joint biennial exercise to the Fall of 2021.

In order to maintain the Benton County response capabilities for a potential emergency event emanating from CGS, Benton County Emergency Management is committed to maintaining emergency plans and procedures, coordinating and conducting necessary training, and maintaining necessary emergency response equipment.

Benton County has been participating in training and evaluated exercises in conjunction with and in support of CGS throughout its history. Our track record consistently demonstrates our ability to provide reasonable assurance we can protect the health and safety of the public in the event of a CGS emergency.

Benton County Emergency Management has not been impacted by the COVID-19 pandemic in a manner that would adversely affect our ability to maintain response capability to support emergency response activities for an actual nuclear power plant radiological emergency. We remain prepared to respond to an actual CGS emergency event.

However, the current COVID-19 conditions and response have taken precedence over conducting exercises. We respectfully request delaying the scheduled exercise to Fall, 2021. This delay will be an important contribution to our efforts to focus our resources and maintain readiness for a response to actual events - including a potential actual CGS event.

Should you have any questions, please do not hesitate to contact me.

Regards, Deanna Davis, Emergency Manager Benton County Emergency Management Page 2 of 2

 

 



 

  





 







GO2-20-130 Attachment 2 Letter from Franklin County Emergency Management to Energy Northwest On behalf of Franklin County

 

 



 

  





 







Franklin County Emergency Management XWXXGlUGhGzU Em11rgencyManagem11nt wSG~hGG``ZWX Franklin County O\W`PG\[\TZ\[]GG Sept 23, 2020 Stephen M. Sullivan Energy Northwest P.O. Box 968 / MD PE30 Richland, WA, 99352 Re: October 27, 2020 REPP Evaluated Exercise

Dear Mr. Sullivan,

During this worldwide COVID-19 pandemic, Franklin County Emergency Management (FCEM) continues to maintain the capability to protect the health and safety of the public in the areas of Franklin County surrounding Columbia Generating Station.

We are currently scheduled to support a Radiological Emergency Preparedness Program (REPP) evaluated exercise in conjunction with Energy Northwest and along with other ORO entities on October 27, 2020. The planned exercise was deferred from its original March 24, 2020, date in the hope that COVID-19 would resolve sufficiently to allow the exercise to be performed in October.

However, despite our joint efforts to identify a time in this calendar year when it would be reasonable to plan for and participate in a joint, full-scale exercise, the continuing significant impact of the COVID-19 pandemic has made that outcome unrealistic for the remainder of 2020 and likely into at least the first half of 2021.

The on-going COVID-19 pandemic public health emergency presents significant challenges to ensuring the continued health and safety of those individuals scheduled to participate in that exercise for the following reasons:

  • Most Franklin County emergency response personnel are supporting the COVID-19 pandemic in varying capacities and are expected to continue doing so through at least the end of calendar 2020. Participation in preparing for and participating in the scheduled CGS evaluated exercise would create an additional burden on our response personnel.
  • Due to the large number of COVID-19 cases in Franklin County the exposure risks to this virus would be significantly increased due to the need to co-locate additional response personnel/workers inside the Franklin County Emergency Coordination Center (ECC) and Columbia Generating Station Emergency Operations Facility and Joint Information Center.
  • Physically staffing of the FC-ECC with the necessary emergency response personnel/workers and support staff would compromise our current social distancing practice and would be Page 1 of 2

 

 



 

  





 







inconsistent with current Benton-Franklin Health District and WA State pandemic response directives/mandates/protocols.

  • Any COVID-19 cases resulting from a positive test for a participant of this exercise could unnecessarily limit the availability of the staff to support their current emergency response COVID-19 role.

The potential to expose emergency response personnel/workers and support staff participating in an exercise during the COVID-19 pandemic public health emergency is very real, and therefore, not warranted.

As a result of these health and safety impacts from this emergency, Franklin County Emergency Management requests the exercise be moved out to the Fall 2021 timeframe and is in agreement with the licensees intent to request an exemption to defer said joint biennial exercise to the Fall of 2021.

In order to maintain the Franklin County response capabilities for a potential emergency event emanating from CGS, Franklin County Emergency Management is committed to maintaining emergency plans and procedures, coordinating and conducting necessary training, and maintaining necessary emergency response equipment.

Franklin County has been participating in training and evaluated exercises in conjunction with and in support of CGS throughout its history. Our track record consistently demonstrates our ability to provide reasonable assurance we can protect the health and safety of the public in the event of a CGS emergency.

Franklin County Emergency Management has not been impacted by the COVID-19 pandemic in a manner that would adversely affect our ability to maintain response capability to support emergency response activities for an actual nuclear power plant radiological emergency. We remain prepared to respond to an actual CGS emergency event.

However, the current COVID-19 conditions and response have taken precedence over conducting exercises. We respectfully request delaying the schedule exercise to Fall, 2021. This delay will be an important contribution to our efforts to focus our resources and maintain readiness for a response to actual events - including a potential actual CGS event.

Should you have any questions, please do not hesitate to contact me.

Regards, r- Sean Davis, Director Franklin County Emergency Management Page 2 of 2

 

 



 

  





 







GO2-20-130 Attachment 3 Letter from WA State Emergency Management Division to Energy Northwest On behalf of the State of Washington

 

 



 

  





 







STATE OF WASHINGTON MILITARY DEPARTMENT Camp Murray, Washington 98430-5000 September 30, 2020 Stephen M. Sullivan Energy Northwest P.O. Box968/MDPE30 Richland, WA 99352 Re: October 27, 2020 REPP Evaluated Exercise

Dear Mr. Sullivan:

The State of Washington, which for the purposes of this letter includes the Emergency Management Division, Department of Health, and Department of Agriculture, agrees with Columbia Generating Station's (CGS) request to the Nuclear Regulatory Commission (NRC) to approve an exemption for the scheduled October 27, 2020, joint biennial Radiological Emergency Preparedness Program (REPP) evaluated exercise and reschedule it for a date in the fall of 2021. The State of Washington, in concert with Energy Northwest, has made a reasonable effort to defer the planned exercise from its original March 24, 2020, date to October 27, 2020, in the hope that the COVID-19 pandemic public health emergency would resolve sufficiently to allow the exercise to be performed in October. However, COVID-19 continues to affect the state's population to an extent that it would not be an appropriate public health decision to conduct a REPP exercise during the remainder of 2020 or, based on CUlTent projections, plan to do so in the early months of 2021.

During this national public health emergency, the State of Washington continues to maintain the capability to protect the health and safety of the public. The State of Washington has not been impacted by the COVID-19 pandemic in a manner that would adversely affect our ability to maintain the response capability needed to support emergency response activities for an actual nuclear power plant radiological emergency. Washington remains prepared to respond to an actual CGS emergency

  • event.

To maintain response capabilities for a potential radiological release emergency originating at CGS, the State of Washington is committed to maintaining radiological emergency plans, continue necessary training, and maintain equipment as we have previously done.

The ongoing public health emergency presents challenges to the planning for and execution of the evaluated exercise currently scheduled for October 27, 2020. In addition, the planning and execution of a REPP biennial exercise places an unreasonable and unwarranted burden on the resources that are engaged in response to the continuing public health emergency.

 

 



 

  





 







As a result, the State of Washington agrees with Energy Northwest's proposal to move the scheduled exercise to the fall of 2021 and supports the request to do so. Delaying the exercise into the second half of calendar 2021 will allow the State of Washington to apply vital resources in response to the continuing public health emergency and maintain readiness for a response to other actual events, including a potential actual CGS event.

As you are aware, and as this year has demonstrated, the State of Washington has a need to limit non-emergency events such as drills and exercises that would serve to distract vital emergency response resources from attending to actual emergency events during the state's fire season (nominally July through late September). Therefore, we endorse your stated intent to request to delay the joint exercise to the fall of calendar 2021 (after the nominal fire season window) which would provide the greatest likelihood of resources being available for the non-emergency, joint biennial evaluated exercise event.

The State of Washington has a long history of successful participation in FEMA evaluated exercises, including the most recent evaluated exercise on March 27, 2018, that demonstrated reasonable assurance of our continuing ability to protect the public in the event of an emergency at CGS.

This letter was prepared by EMD, in coordination with the Departments of Health and Agriculture, who are in agreement with EMD signing this letter on their behalf.

Sincerely,

~druJ Sfiaron A. Wallace, Operations Unit Manager Emergency Management Division

 

 



 

  





 







GO2-20-130 Attachment 4 Letter from State of Oregon Department of Energy to Energy Northwest On behalf of the State of Oregon

 

 



 

  





 







Oregon Kate Brown, Governor

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~ENERGY OREGON DEPARTMENT OF 550 Capitol St. NE Salem, OR 97301 Phone: 503-378-4040 Sept 24, 2020 Toll Free: 1-800-221-8035 FAX: 503-373-7806 www.oregon.gov/energy Stephen M. Sullivan Energy Northwest P.O. Box 968 / MD PE30 Richland, WA, 99352 Re: October 27, 2020 REPP Evaluated Exercise

Dear Mr. Sullivan,

Please accept this Oregon Department of Energy (ODOE) letter of support for Columbia Generating Stations (CGS) request to the Nuclear Regulatory Commission (NRC) to approve an exemption for the scheduled October 27, 2020 joint biennial evaluated exercise and reschedule it for a date in the fall of calendar 2021. The planned exercise was deferred from its original March 24, 2020 date in the hope that COVID-19 would resolve sufficiently to allow the exercise to be performed in October. However, COVID-19 continues to impact the region to an extent that makes it inappropriate to conduct a Radiological Emergency Preparedness Program (REPP) exercise during the remainder of 2020 or the early months of calendar 2021.

During this national COVID-19 pandemic public health emergency (PHE), the State of Oregon continues to maintain the capably to protect the health and safety of the public. The emergency management organizations of the State of Oregon have not been impacted by the COVID-19 pandemic in a manner that would adversely affect our ability to maintain the response capability needed to support emergency response activities for an actual nuclear power plant radiological emergency. Oregon remains prepared to respond to an actual CGS emergency event.

To maintain response capabilities for a potential radiological release emergency originating at CGS, the State of Oregon and its emergency management organizations are committed to maintaining radiological emergency plans, continue necessary training, and maintain equipment as we have previously done.

However, the on-going COVID-19 pandemic presents challenges to the planning for and execution of the evaluated exercise scheduled for October 27, 2020. In addition, the planning 1

 

 



 

  





 







and execution of an exercise places an unreasonable burden on the resources that are dealing with the long-duration COVID-19 pandemic public health emergency response.

As a result, ODOE agrees with Energy Northwests proposal to move the scheduled exercise to the fall of 2021 and supports the request to do so. Delaying the exercise to the fall of calendar 2021 will allow the State of Oregon to apply vital resources in response to the continuing COVID-19 pandemic PHE and maintain readiness for a response to other actual events, including a potential actual CGS event.

The State of Oregon has a long history of successful participation in FEMA evaluated exercises, including the most recent evaluated exercise March 27th, 2018 that demonstrated reasonable assurance of our continuing ability to protect the public in the event of an emergency at CGS.

Sincerely, Maxwell Woods Assistant Director for Nuclear Safety and Emergency Preparedness Oregon Department of Energy Mark D. Reese Mark D. Reese, ORCEMS Nuclear Emergency Program Coordinator, Lead REP Planner Oregon Department of Energy 2

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