CP-202100202, One-Time Request for Exemption from the Biennial Emergency Preparedness Exercise Requirements in 10 CFR 50, Appendix E, IV.F.2.b and IV.F.2.c

One-Time Request for Exemption from the Biennial Emergency Preparedness Exercise Requirements in 10 CFR 50, Appendix E, IV.F.2.b and IV.F.2.c

ML21111A364
Person / Time
Site:	Comanche Peak
Issue date:	04/21/2021
From:	Sewell S Vistra Operations Company
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CP-202100202, TXX-21072
Download: ML21111A364 (13)

Text

CP-202100202 TXX-21072 April 21, 2021 U. S. Nuclear Regulatory Commission Ref 10 CFR 50.12 ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

Comanche Peak Nuclear Power Plant (CPNPP)

Docket Nos. 50-445 and 50-446 One-Time Request for Exemption from the Biennial Emergency Preparedness Exercise Requirements in 10 CFR 50, Appendix E, IV.F.2.b and IV.F.2.c

Reference:

1) NRC letter 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,

[ML20120A003]

2) NRC letter dated November 10, 2020, U. S. Nuclear Regulatory Commission Updated Planned Actions Related to Certain Requirements for Operating and Decommissioning Reactor Licensees During the Coronavirus Disease 2019 Public Health Emergency [ML20261H515]

Dear Sir or Madam:

In accordance with 10 CFR 50.12, Vistra Operations Company LLC (Vistra OpCo) hereby submits the enclosed request for a one-time exemption from certain 10 CFR 50, Appendix E requirements regarding biennial emergency preparedness exercises at Comanche Peak Nuclear Power Plant (CPNPP) due to the Coronavirus Disease 2019 (COVID-19) pandemic.

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 COVID-19 pandemic. 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) pandemic a national emergency.

In response to the declarations, Vistra OpCo, in order to maintain a healthy work force, continues to follow practices recommended by the Centers for Disease Control and Prevention (CDC) to limit the spread of COVID-19 by implementing strict isolation protocols (e.g., social distancing, group size limitations, self-quarantining, etc.) and work-from-home requirements at CPNPP. In addition, on-going efforts to vaccinate the population have further limited the availability of offsite resources needed Steven K. Sewell Senior Director, Engineering & Regulatory Affairs Comanche Peak Nuclear Power Plant (Vistra Operations Company LLC)

P.O. Box 1002 6322 North FM 56 Glen Rose, TX 76043 T

254.897.6113

TXX-21072 Page 2 of 2 to adequately schedule, perform and evaluate the required biennial exercises. Offsite response organizations (ORO) have agreed that Vistra OpCo should submit an exemption request.

In accordance with the provisions of 10 CFR 50.12, Specific exemptions, paragraph (a)(2)(v), Vistra OpCo requests a temporary exemption from the requirements of 10 CFR Appendix E, Sections IV.F.2.b.and IV.F.2.c., as meeting these requirements would conflict with the isolation practices recommended by the CDC and required by the CPNPP pandemic response plan. Specifically, Vistra OpCo requests a one-time schedular exemption to postpone the joint, full participation biennial emergency preparedness exercise until calendar year (CY) 2022.

Vistra OpCo will conduct the CY 2022 exercise within 35 months from the performance of the previous full-participation exercise conducted on November 6, 2019.

If exemptions are granted to allow the CY 2021 exercise to be conducted in 2022, future biennial exercises will continue to be held in odd years, beginning in CY 2023.

The enclosed request provides justification for the one-time schedular exemption.

Vistra OpCo requests approval by June 30, 2021.

This communication contains no new commitments regarding CPNPP Units 1 and 2.

Should you have any questions, please contact Jim Barnette at (254) 897-5866 or James.barnette@luminant.com.

Sincerely, Steven K. Sewell

Enclosure:

CPNPP 2021 Biennial Emergency Preparedness Exercise Exemption Request c (email) -

Scott Morris, Region IV [Scott.Morris@nrc.gov]

Dennis Galvin, NRR [Dennis.Galvin@nrc.gov]

John Ellegood, Senior Resident Inspector, CPNPP [John.Ellegood@nrc.gov]

Neil Day, Resident Inspector, CPNPP [Neil.Day@nrc.gov]

Ryan Alexander, Senior Emergency Preparedness Inspector, Region IV

[Ryan.Alexander@nrc.gov]

Enclosure with TXX-21072 Page 1 of 7 CPNPP 2021 Biennial Emergency Preparedness Exercise Exemption Request 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.12, Specific exemptions, Vistra Operations Company LLC (Vistra OpCo) requests a one-time schedular exemption for Comanche Peak Nuclear Power Plant (CPNPP) from the requirement to conduct onsite and offsite full-participation biennial emergency preparedness (EP) exercises 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 exemption supports the isolation activities (e.g., social distancing, group size limitations, self-quarantining) necessary to protect required CPNPP site personnel in response to the Coronavirus Disease 2019 (COVID-19) pandemic. These restrictions are needed to protect plant personnel responsible for emergency response and safe plant operation.

This one-time exemption also serves to protect supporting state and local government emergency management personnel and federal evaluators from transmission of the COVID-19 virus to ensure they remain capable of executing their emergency response functions in the event of an actual CPNPP emergency or in response to other non-nuclear health and safety functions for the broader benefit of the public, including the current efforts to vaccinate the public against the COVID-19 virus.

As a result of discussions between CPNPP, State and local officials, the NRC and the Federal Emergency Management Agency (FEMA), Vistra OpCo has concluded that scheduling the biennial exercise in calendar year (CY) 2021 would not be reasonable during the current COVID-19 public health emergency (PHE). Upon exemption approval, Vistra OpCo will continue to support the isolation protocols necessary to protect essential site personnel while CPNPP coordinates with responsible organizations to schedule onsite and offsite emergency preparedness exercises during the summer of 2022 - an exercise date has been tentatively proposed for July 27, 2022.

2.0 BACKGROUND

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

Each licensee at each site shall conduct a subsequent exercise of its onsite emergency plan every 2 years.

10 CFR 60, Appendix E, Section IV.F.2.c. states in part:

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 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 COVID-19 pandemic. 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) pandemic a national emergency. CPNPP implemented isolation restrictions for site personnel on March 16, 2020.

In response to the PHE, the NRC issued a letter May 14, 2020, U.S. Nuclear Regulatory Commission Planned Actions Related to Emergency Preparedness Biennial Exercise Requirements for all Licensees During the

Enclosure with TXX-21072 Page 2 of 7 Coronavirus Disease 2019 Public Health Emergency [ML20120A003] (Reference 1). This letter provided information regarding licensee requests for exemptions from certain parts of 10 CFR 50, Appendix E, Section IV requirements during the COVID-19 PHE, and the process that the NRC planned to use when reviewing such requests.

The NRC issued a letter dated November 10, 2020, titled, U.S. Nuclear Regulatory Commission Updated Planned Actions Related to Certain Requirements for Operating and Decommissioning Reactor Licensees During the Coronavirus Disease 2019 Public Health Emergency (Reference 2). This letter provides guidance on the continued use of expedited processes needed for submitting exemption requests beyond December 31, 2020. Enclosure 6 of this letter, titled, Title 10 of the Code of Federal Regulations (10 CFR) Emergency Plan Requirements, further describes the exemption process for licensees with 2021 exercise dates that need to seek exemptions from the biennial exercise requirements in 10 CFR Part 50, Appendix E, Section IV.

Because of the COVID-19 PHE, Vistra OpCo has determined that an exemption is needed from the biennial emergency plan exercise requirements specified in 10 CFR 50, Appendix E, Section IV.F.2.b.

and IV.F.2.c., as meeting these requirements would conflict with practices recommended by the CDC, state and local officials, and CPNPPs pandemic response plan to limit the spread of COVID-19. In order to fulfill the exercise requirements of Section IV.F.2.b., Vistra OpCo would need to staff emergency facilities in a manner that would compromise current social distancing strategies and would be inconsistent with CPNPPs isolation activities necessary to protect personnel responsible for safe plant operation and emergency response (e.g., ongoing limitations on protected area and vital area access).

Additionally, required OROs have determined conducting an exercise during 2021 to fulfill 10 CFR 50, Appendix E, Section IV.F.2.c. would compromise social distancing practices and would be inconsistent with pandemic response protocols for Somervell and Hood Counties and the Texas Department of State Health Services (DSHS). Hood and Somervell County emergency responders are leading COVID-19 vaccination distribution efforts for the area. Redirecting the personnel needed to perform an exercise during this ongoing vaccination effort is not feasible with limited rural county staffing and would jeopardize the prioritization off the health and welfare of their community members.

3.0 TECHNICAL JUSTIFICATION OF ACCEPTABILITY Vistra OpCo along with state and local emergency management organizations have implemented isolation activities recommended by the CDC such as social distancing, group size limitations and self-quarantining to limit the spread of the COVID-19 virus. These restrictions are necessary to protect plant personnel and off-site personnel needed for emergency response.

Vistra OpCo provides the following information in support of an expedited review per the references in Section 7.0:

x Regulatory basis for the exemption; o

Per 10 CFR 50.12(a)(2), the NRC will not consider granting an exemption unless special circumstances are present. Under 10 CFR 50.12(a)(2)(v), special circumstances include when the exemption would provide only temporary relief from the applicable regulation. The requested exemption to not conduct the biennial exercise in CY 2021 would provide only temporary relief from the applicable regulations.

Enclosure with TXX-21072 Page 3 of 7 x

The last biennial exercise date; o

The last CPNPP biennial exercise was conducted on November 6, 2019 x

Current biennial exercise scheduled date; o

June 16, 2021 x

A statement the licensee has made a reasonable effort to reschedule the exercise during CY 2021, but was unsuccessful; o

Vistra OpCo has been in communication with NRC Region IV, FEMA Region VI, the state of Texas and the local offsite organizations concerning availability and exercise preparation. The isolation protocols remain in place at CPNPP and the offsite agencies.

Despite the current vaccination efforts, there is still no definitive date for ending the isolation activities. Additionally, CPNPP has an extended (40+ days) refueling outage scheduled in the fall of 2021, which further hinders the ability to reschedule the exercise within CY 2021.

Letters from offsite agencies in support of rescheduling the biennial exercise to a 2022 date are attached to this request.

FEMA is aware of the requests from the offsite agencies and indicated their understanding of the need for the schedular relief due to the ongoing PHE. FEMA has communicated they will work closely with the OROs to accommodate their request to reschedule the biennial exercise.

x A statement the rescheduled biennial exercise will be conducted within 35 months from the month in which the previously evaluated exercise was conducted in CY 2019; o

The next full participation exercise is tentatively scheduled for July 27, 2022. CPNPP will work with the State, local OROs, FEMA and NRC Region IV to ensure the finalized exercise date is within 35 months of the November 2019 date of the last evaluated exercise.

x A statement that if an exemption is granted to allow CPNPP to conduct the exercise in CY 2022, that future biennial exercises will continue to be held in odd years; o

CPNPP will continue to hold both onsite and offsite exercises in odd years. The 2023 full participation biennial exercise is currently scheduled July 19, 2023.

x A statement that CPNPP has conducted drills, exercises, and other training activities that exercised its emergency response strategies, in coordination with offsite authorities, since the previous biennial exercise; o

Since the last biennial EP exercise on November 6, 2019, CPNPP has conducted numerous drills, exercises, and other training activities that have exercised the emergency response strategies and demonstrated proficiency.

State and local agencies have participated at various levels in these activities, exercising various EP program elements during the following months:

x February 2020 x

June 2020 x

August 2020 x

September 2020 x

October 2020

Enclosure with TXX-21072 Page 4 of 7 x

November 2020 x

December 2020 x

February 2021 x

March 2021 x

April 2021 Activities conducted since June 2020 involved reduced staffing due to COVID-19 protocols.

CPNPP will continue to conduct drills, tabletops, and other training activities that exercise the emergency response plan and demonstrate proficiency to the extent reasonable during the PHE. The associated OROs will 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 limited-scope drills and training activities to the extent practical while also complying with the CDC isolation activity 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.

x A statement that the rescheduled biennial exercise has been, or will be, coordinated with the applicable offsite response organizations, NRC Region, and the applicable FEMA Region; o

The tentative July 27, 2022 date for the next full participation exercise has been discussed with the OROs, NRC and FEMA. Vistra OpCo will continue to coordinate with those organizations concerning the scheduling and logistics of the 2022 biennial exercise.

x A statement from responsible OROs that they agree with the exemption request and they are committed to maintaining their radiological emergency plans; o

The OROs agree with Vistra OpCos exemption request and are committed to maintaining their radiological emergency plans. Attached to this enclosure are letters from Somervell County, Hood County, and the Texas DSHS in support of the exemption.

x A statement from the responsible OROs that they are not impacted in a manner that would adversely affect their ability to maintain response capability to support emergency response activities to actual nuclear power plant radiological emergencies.

o As described in the attached letters, the OROs continue to work closely with CPNPP and the state to maintain response capabilities in the event of an actual emergency at CPNPP.

Enclosure with TXX-21072 Page 5 of 7 4.0 JUSTIFICATION OF EXEMPTION 10 CFR 50.12, Specific exemptions, states that the Nuclear Regulatory Commission may grant exemptions from the requirements of the regulations provided three conditions are met:

(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.

CPNPP has evaluated the requested exemption against the criteria of 10 CFR 50.12 and determined the criteria are satisfied as described below.

1. This exemption is authorized by law The biennial emergency preparedness exercise specified in 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c 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 regulations in 10 CFR Part 50, Appendix E, Section IV.F.2.b and Section IV.F.2.c, concern requirements for licensees to conduct biennial EP exercises at their facilities. No new accident precursors are created by allowing Vistra OpCo to postpone the biennial EP exercise from CY 2021 to CY 2022. Thus, 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 This requested exemption for a one-time change to the biennial EP exercise schedule has no relation to security issues. Therefore, the requested exemption is consistent with the common defense and security.

5.0 CONCLUSION

As demonstrated above, Vistra OpCo considers this exemption request to be 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, Section IV.F.2.b and IV.F.2.c due to the COVID-19 PHE is therefore warranted.

Enclosure with TXX-21072 Page 6 of 7 6.0 ENVIRONMENTAL ASSESSMENT Vistra OpCo 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.

The exemption does not make any changes to the facility or operating procedures and does not:

a) involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), in that it does not:

x alter the design, function or operation of any plant equipment. Therefore, granting this exemption would not increase the probability or consequence of any evaluated accident.

x create any new accident initiators. Therefore, granting this exemption does not create the possibility of a new or different kind of accident from any accident previously evaluated.

x exceed or alter a design basis or safety limit. Therefore, granting this exemption does not involve a significant reduction in a margin of safety.

Therefore, a finding of no significant hazards considerations is justified.

b) involve any changes that would introduce any change to effluent types, affect any plant radiological or non-radiological effluent release quantities, or affect any effluent release paths or the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation. Therefore, it is concluded that the proposed exemption does not involve a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite.

c) affect any plant radiation zones, nor change any controls required under 10 CFR Part 20 that preclude a significant increase in occupational radiation exposure. Therefore, it is concluded that the proposed exemption does not involve a significant increase in individual or cumulative occupational radiation exposure.

d) involve any facility changes or change any construction activities. Therefore, there is no significant construction impact.

e) alter the design, function, or operation of any plant equipment. Therefore, there is no significant increase in the potential for or consequences from radiological accidents.

Finally, the requirements to which the exemption applies involve biennial EP exercise scheduling and therefore meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(25)(vi)(G).

Accordingly, 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.

Enclosure with TXX-21072 Page 7 of 7

7.0 REFERENCES

1. NRC letter, 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, dated May 14, 2020 [ML20120A003]

2. NRC Letter, U.S. Nuclear Regulatory Commission Updated Planned Actions Related to Certain Requirements for Operating and Decommissioning Reactor Licensees During the Coronavirus Disease 2019 Public Health Emergency, dated November 10, 2020

[ML20261H515]

3. Regulatory Issue Summary (RIS) 2006-003, Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements, dated February 24, 2006

[ML053390039]

4. Temporary Staff Guidance TSG-NSIR-2020-01, COVID-19 Related Exemptions from NRC Regulations - Emergency Preparedness Exercises, dated September 11, 2020 [ML20196M030]

5. Interim Guidance for Businesses and Employers, retrieved from https://www.cdc.gov/coronavirus/2019-ncov/community/guidance-business-response.html, on March 17, 2020.

6. NEI 06-03, Pandemic Threat Planning, Preparation, and Response Reference Guide, Revision 2, February 2020.

Attachments

1. Letter from Stephen Pahl, DSHS, to George Robinson, FEMA Region 6, re: Endorsement for CPNPP EP Exemption Request, dated March 21, 2021

2. Letter from Danny L. Chambers, Somervell County Judge, re: Comanche Peak Nuclear Power Plant (CPNPP) 2021 Biennial Exercise Relief, dated March 10, 2021

3. Letter from Ron Massingill, Hood County Judge, re: Comanche Peak Nuclear Power Plant (CPNPP) 2021 Biennial Exercise Relief, dated March 10, 2021

32%R[$XVWLQ7H[DV3KRQH77<dshs.texas.gov

March 29, 2021 George A. Robinson, Regional Administrator FEMA Region 6 800 N. Loop 288 Denton, TX 76209

Dear Mr. Robinson,

During the COVID-19 pandemic, both the state of Texas and the counties around the Comanche Peak Nuclear Power Plant (CP) continue to maintain the capability to protect the health and safety of the public and transient population from a potential radiological release. The continuing uncertainty of the COVID-19 pandemic presents challenges to the Radiological Emergency Preparedness Program exercise scheduled for June 16th, 2021.

For the exercise to be successful, an assembly of 45-60 emergency responders would be required to gather in Hood and Somervell Counties, presenting challenges for response personnel to maintain appropriate physical distancing. As a result of the potential threat to the health of emergency exercise participants, DSHS supports CP and Hood and Somervell Counties' request to move the Plume Phase exercise to a target date of June 2022. The postponement is in line with what other states around the country are doing.

In addition, FEMAs request to evaluate a virtual Plume Phase (PP) exercise would require personnel from Hood and Somervell Counties presently involved in local COVID-19 responses. Hood and Somervell Counties are supporting a designated regional vaccine hub location for the next 24 weeks, which limits the availability of staff to participate in an evaluated exercise in 2021. Further, with the proposed alternative evaluation methods (i.e.,

virtual), an undue hardship would be placed on staff to participate in a multi-day, technology dependent evaluation that the Counties do not have staffing or technology equipment set-up to handle.

To maintain response capabilities for a potential radiological release, the state, Hood and Somervell Counties and CP are preparing plans to continue emergency preparedness, training, plan and procedure updates, and to Enclosure With TXX-21072 Page 1 of 2

Mr. George A. Robinson March 29, 2021 Page 2 equipment maintenance as has been done in the past. Information will be provided separately on radiological emergency preparedness activities since the November 6th, 2019 evaluated Plume Phase exercise at CP, and in the 2021 Annual Letter of Certification (ALC).

The State of Texas has been participating in FEMA evaluated exercises since the CP Licensing exercise in 1989. Our history of successful participation in FEMA evaluated exercises demonstrates our ability to provide reasonable assurance to protect the public in the event of an emergency at CP.

Sincerely, Stephen Pahl Associate Commissioner Consumer Protection Division cc:

W. Nim Kidd, Chief, Texas Division of Emergency Management The Honorable Ron Massingill, Hood County Judge The Honorable Danny Chambers, Somervell County Judge S

ce e y, Stephen Pahl Digitally signed by Stephen Pahl Date: 2021.03.29 10:19:21 -05'00' to Enclosure With TXX-21072 Page 2 of 2 to Enclosure With TXX-21072 Page 1 of 1 P.O. Box 851 Glen Rose, Texas 76043 DANNY L. CHAMBERS Somervell County Judge cojudge@co. somervell. tx. us March 10, 2021 254-897-2322 Fax: 254-897-7314

Subject:

Comanche Peak Nuclear Power Plant (CPNPP) 2021 Biennial Exercise Relief To whom it may concern, Somervell County hereby requests relief from participation in the 2021 CPNPP biennial evaluated exercise due to hardships related to the COVID-19 public health emergency. Somervell County continues to work closely with CPNPP Emergency Planning staff and the Department of State Health Services to ensure we maintain the highest level of preparedness to respond to an emergency at Comanche Peak.

Currently, Somervell County employees are engaged in COVID-19 response and vaccination distribution, which limits the availability of our staff to participate in an evaluated exercise in 2021. With the COVID-19 public health emergency still in full effect, social distancing with the county EOC would not be possible for the duration of the exercise placing our employees at higher risk of transmission. Further, with proposed alternative evaluation methods (i.e. virtual), an undue hardship would be placed on our staff by participating in a multi-day, technology dependent evaluation that the County does not have staffing or time.

In consideration of the aforementioned hardships and safety of our employees, Somervell County believes it best to postpone the evaluated exercise until 2022. In the interim, we will work with CPNPP and the State of Texas to participate in training opportunities and seek credit for our current response efforts, until such time an evaluated exercise can be held.

Respectfully yours, Somervell County Judge to Enclosure With TXX-21072 Page 1 of 1 March 10, 2021 HOOD COUNTY JUDGE RON MASSINGILL 100 E. Pearl Street Granbury, Texas 76048 817-579-3200

• FAX: 817-579-3213

Subject:

Comanche Peak Nuclear Power Plant (CPNPP) 2021 Biennial Exercise Relief To whom it may concern, Hood County hereby requests relief from participation in the 2021 CPNPP biennial evaluated exercise due to hardships related to the COVID-19 public health emergency. Hood County continues to work closely with CPNPP Emergency Planning staff and the Department of State Health Services to ensure we maintain the highest level of preparedness to respond to an emergency at Comanche Peak.

Currently, Hood County employees are engaged in COVID-19 response, as well as running a vaccination distribution center three to four days a week. Since we are a rural county with limited Emergency Management resources, our staff is not able to participate in an evaluated exercise in 2021. With the COVID-19 public health emergency still in full effect, social distancing within the county EOC would also be a concern for the duration of the exercise, placing our employees at a higher risk of transmission. Further, with proposed alternative evaluation methods (i.e. virtual), an undue hardship would be placed on our staff by participating in a multi-day, technology dependent evaluation which the County does not have staffing or technology equipment currently set-up to handle.

In consideration of the aforementioned hardships and safety of our employees, Hood County believes it best to postpone the evaluated exercise until 2022. In the interim, we will work with CPNPP and the State of Texas to participate in training opportunities and seek credit for our current response efforts, until such time an evaluated exercise can be held.