NL-20-0713, Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic

Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic

ML20265A353
Person / Time
Site:	Farley
Issue date:	09/21/2020
From:	Gayheart C Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-20-0713
Download: ML20265A353 (20)

Text

A Southern Nuclear Cheryl A. Gayheart Regulatory Affairs Director 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5316 cagayhea@southernco.com September 21, 2020 10 CFR 50.12 10 CFR 50, Appendix E Docket Nos.: 50-348 NL-20-0713 50-364 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Joseph M. Farley Nuclear Plant - Units 1 and 2 Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements due to COVID-19 Pandemic Ladies and Gentlemen:

In accordance with 10 CFR 50.12, Specific exemptions, Southern Nuclear Operating Company (SNC) requests an exemption for Joseph M. Farley Nuclear Plant (FNP) Units 1 and 2 from the requirements of 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c. Specifically, SNC requests a one-time schedular exemption to postpone the calendar year (CY) 2020 onsite biennial emergency preparedness (EP) exercise (Appendix E,Section IV.F.2.b) and the CY 2020 full-participation biennial EP exercise (Appendix E,Section IV.F.2.c) until CY 2021.

Special circumstances 10 CFR 50.12(a)(2)(ii) and 10 CFR 50.12(a)(2)(v) are applicable to this request.

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, the President of the United States of America declared the COVID-19 pandemic a national emergency. In addition, on March 13, 2020, Kay Ivey, Governor of the State of Alabama, declared a state PHE. In response to these declarations, on March 18, 2020 SNC initiated its pandemic response plan, which includes protective health measures such as social distancing, group size limitations, and self-quarantine.

On April 30, 2020, SNC submitted the scenario for the FNP biennial EP exercise originally scheduled for June 30, 2020. On June 29, 2020, due to the COVID-19 PHE, SNC notified the NRC that the exercise would be postponed to a date yet to be determined and requested that the scenario continue to be retained as a non-public document to ensure confidentiality until the exercise was conducted. Because the threat of spreading COVID-19 has resulted in continued uncertainty to safely conduct FNPs biennial EP exercise in CY 2020 and because conducting the exercise in CY 2021 places the exercise outside of the required biennium, SNC requests a one-time schedular exemption to postpone the biennial EP exercise until CY 2021. The rescheduled biennial exercise will be coordinated with the applicable offsite response organizations, the U.S. Nuclear Regulatory Commission Region II, and the Federal Emergency Management Agency Region IV.

NL-20-0713 Page 2 The enclosure to this letter contains the exemption request and justification for the issuance of an exemption. The proposed exemption is needed by December 31, 2020.

This letter contains no NRC commitments. If you have any questions, please contact Jamie Coleman at 205.992.6611.

Respectfully submitted, Cheryl A. Gayheart Regulatory Affairs Director Southern Nuclear Operating Company CAG/wag/scm

Enclosure:

Request for Exemption from 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c

Attachment:

Collection of Communications Supporting the Exemption Request cc: NRC Regional Administrator, Region II NRC Senior Resident Inspector - Farley 1 & 2 NRR Project Manager - John Lamb NRR Project Manager - Shawn Williams Licensing Project Manager, In-Training - Stephanie Devlin-Gill Federal Emergency Management Agency - Region IV Administrator Alabama State Board of Health - Director of Radiation Control Alabama Emergency Management Agency - Office of Radiation Control Georgia Emergency Management Agency - REP Manager Program Manager - AEMA/HS Radiological Emergency Preparedness SNC Document Control R-Type: CFA04.054

Joseph M. Farley Nuclear Plant - Units 1 and 2 Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic Enclosure Request for Exemption from 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c

Enclosure to NL-20-0713 Request for Exemption from 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.12, Specific exemptions, Southern Nuclear Operating Company (SNC) requests a one-time schedular exemption for Joseph M. Farley Nuclear Plant (FNP)

Units 1 and 2 from the requirements of 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c.

The proposed exemption would allow FNPs calendar year (CY) 2020 onsite biennial emergency preparedness (EP) exercise and CY 2020 full-participation biennial EP exercise to be postponed until CY 2021.

This one-time schedular exemption to allow FNP to conduct the biennial EP exercise in CY 2021 supports continued implementation of isolation activities (e.g., social distancing, group size limitations, self-quarantining) to protect required emergency response organization (ERO) personnel in response to the ongoing Coronavirus Disease 2019 (COVID-19) public health emergency (PHE). These activities are needed 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 SNC Standard Emergency Plan and the Standard Emergency Plan Annex for FNP.

Additionally, these isolation activities help ensure supporting state and local government personnel are protected from transmission of the COVID-19 virus and remain capable of executing the functions of the FNP emergency response organization as well as non-nuclear health and safety functions for the benefit of the public.

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. The exercise may be included in the full participation biennial exercise required by paragraph 2.c. of this section.

10 CFR 50, 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.

SNC has implemented isolation activities (e.g., social distancing, group size limitations, self-quarantining) to protect required ERO personnel in response to the COVID-19 PHE. Based on the widespread existence of the virus in the local communities, the uncertainty associated with the ease of its transmission, the need to maintain the health of the emergency response organization, and the desire to not detract from ongoing efforts by state and local agencies responding to the existing pandemic, the June 30, 2020 exercise was postponed. While performance of this exercise at any time during CY 2020 would satisfy the biennial calendar, due to the ongoing threat posed by the COVID-19 pandemic, SNC has determined that it is no longer feasible to schedule the biennial EP exercise before the end of the CY 2020. Therefore, FNP is requesting an exemption from the biennial EP exercise requirements contained in 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c.

A recent biennial EP exercise schedular exemption application, addressing the same NRC requirements and guidance documents as SNCs request, and the exemptions approval are stated here for reference. Cooper Nuclear Stations application for exemption from the requirements of Sections IV.F.2.b and IV.F.2.c of 10 CFR 50, Appendix E, was submitted to the NRC on June 16, 2020 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML20191A276), and the temporary exemption was approved by the NRC on September 03, 2020 (ADAMS Accession No. ML20203M129).

E-1

Enclosure to NL-20-0713 Request for Exemption from 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c 3.0 TECHNICAL JUSTIFICATION OF ACCEPTABILITY The Centers for Disease Control and Prevention (CDC) has issued recommendations advising social distancing to prevent the spread of the COVID-19 virus. To limit the spread of the virus among the station staff and offsite personnel, SNC and the State of Alabama have implemented pandemic response plans that include social distancing, group size limitations, and self-quarantine.

FNPs last biennial EP exercise was an ingestion pathway exercise, and it was conducted on October 30, 2018 and October 31, 2018. Since that time, in coordination with offsite authorities, FNP has conducted other EP drills, exercises, and training activities that exercised its emergency response strategies as follows.

June 25, 2019: Training drill with participation including: Control Room (Simulator);

Technical Support Center (TSC); Emergency Operations Facility (EOF); Operations Support Center (OSC); Field Monitor Teams; Emergency Response Teams; Joint Information Center (JIC) - in a limited role; and offsite agencies participating in communications roles: Georgia Emergency Management Agency, Dothan/Houston County Emergency Management Agency, Blakely/Early County Emergency Management Agency, Florida Division of Emergency Management, and Florida Bureau of Radiation Control August 13, 2019: Off-Year exercise with participation including: Control Room (Simulator); TSC; EOF; OSC; Field Monitor Teams; Emergency Response Teams; JIC; offsite agencies participating in full roles: Georgia Emergency Management Agency, Georgia Department of Natural Resources, Alabama Department of Public Health Office of Radiation Control, Dothan/Houston County Emergency Management Agency, Blakely/Early County Emergency Management Agency, and Henry County Emergency Management Agency; and an offsite agency participating in communications role:

Florida Division of Emergency Management November 05, 2019: Training drill with participation including: Control Room (Simulator); TSC; EOF; OSC; Field Monitor Teams; Emergency Response Teams; and offsite agencies participating in communications roles: Georgia Emergency Management Agency, Alabama Emergency Management Agency, Dothan/Houston County Emergency Management Agency, and Blakely/Early County Emergency Management Agency Further, FNP has scheduled EP 101 training scenarios with all ERO positions through the remainder of CY 2020. This training covers position-specific material, including fleet learnings and operating experience gained in previous drills. In December 2020, FNP has a tabletop exercise scheduled for select ERO positions to support maintaining drill proficiency. Although not yet scheduled, FNP is planning to conduct similar tabletop exercises with other ERO team members during the first quarter of CY 2021.

FNP has made a reasonable effort to reschedule the biennial EP exercise during CY 2020 but has been unsuccessful. The uncertainties associated with COVID-19 transmission, number of new cases, hospitalizations, and deaths caused by COVID-19 have made it impractical to reschedule the onsite biennial EP exercise in CY 2020. FNP and the associated Offsite Response Organizations (OROs) have similarly concluded that the PHE conditions prevent the safe conduct of the offsite exercise prior to the end of CY 2020. On August 26, 2020, after reviewing the site, the Nuclear Regulatory Commission Region II (NRC), and the Federal Emergency Management Agency Region IV (FEMA) schedules, FNP proposed the following exercise dates to the applicable OROs, the NRC, and FEMA: June 08, 2021 (practice FNP E-2

Enclosure to NL-20-0713 Request for Exemption from 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c only), July 27, 2021 (practice evaluated exercise), and September 21, 2021 (evaluated biennial EP exercise). September 21, 2021 was determined to be acceptable by the following: FEMA Region IV, Alabama Emergency Management Agency, Georgia Emergency Management Agency, Alabama Radiation Control, Early County Emergency Management Agency, Henry County Emergency Management Agency, and Houston County Emergency Management Agency.

The attachment to this exemption request provides a copy of a September 10, 2020 letter from State of Alabama Emergency Management Agency to FEMA requesting that the FNP June 30, 2020 biennial EP exercise be rescheduled to September 21, 2021. Further, the letter states that Alabama EMA, applicable OROs, Southern Company, and the NRC have concurred. The attachment also provides documentation of statements, in email or letter format, from the applicable OROs affirming that they continue to maintain their radiological emergency plans, and they are not impacted in a manner that would adversely affect their abilities to maintain response capabilities that would support emergency response activities for actual nuclear power plant radiological emergencies. Also included is a copy of an email to FEMA requesting scheduling the following dates: July 27, 2021 (conduct of FNPs Practice for Graded Exercise) and September 21, 2021 (conduct of FNPs Graded Exercise), and this email string documents FEMAs acknowledgment.

FNP has determined that the proposed exemption will not adversely impact the 8-year exercise cycle plan. As originally scheduled, the CY 2020 exercise would have been the last evaluated exercise of the 8-year exercise cycle; however, rescheduling this exercise into CY 2021 will not result in exceeding the 8-year exercise cycle for exercises required to be demonstrated. FNPs 8-year exercise cycle concludes at the end of CY 2021.

The proposed date, September 21, 2021, falls within the 35-month window, ending in September 2021, for conducting FNPs biennial EP exercise from the time the previously evaluated exercise was conducted in CY 2018. Conducting an evaluated biennial exercise within a 35-month window, as described in NRC Regulatory Issue Summary 2006-03, Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements, from the time of the previously evaluated biennial exercise meets the intent of the regulation. FNP will continue to hold future biennial exercises in even years, with the subsequent biennial EP exercise to be conducted in CY 2022.

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 Part 50, 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 biennial EP exercises of 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c at FNP 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, 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.

E-3

Enclosure to NL-20-0713 Request for Exemption from 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c

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 the ERO personnel (onsite and offsite, respectively) are familiar with their duties, to test the adequacy of the emergency plans, and to identify and correct weaknesses. Additionally, 10 CFR 50, Appendix E, Section IV.F.2.b 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 since the last evaluated biennial EP exercise and have activated onsite emergency response facilities during those drills with state, county, and local participation. SNC maintains adequate emergency response capabilities during intervals between biennial EP exercises by conducting drills to exercise the principal functional areas of emergency response since the last evaluated biennial exercise, and SNC identifies and documents weaknesses and areas for improvement using the Corrective Action Program, as necessary. SNC has activated onsite emergency response facilities during those drills with state, county, and local participation. SNC considers that these measures maintain an acceptable level of emergency preparedness during the one-time schedular exemption period 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.

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 June 30, 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.

4. Special Circumstances are present.

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. 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 SNC to conduct an exercise of the FNP emergency plan biennially with full participation by each offsite authority having a role under the plan. The underlying purpose of this requirement is to ensure that ERO personnel are familiar with their duties, to test adequacy of emergency plans, and to identify and correct weaknesses. FNP has conducted training drills exercising the principal functional areas of emergency response since the last evaluated biennial EP exercise and has activated onsite emergency response facilities during those drills with state, county, and local participation.

SNC considers that these measures maintain an acceptable level of emergency preparedness during the exemption period to satisfy the underlying purpose of the rule.

Special circumstances, per 10 CFR 50.12(a)(2)(v), are also present when, The exemption would provide only temporary relief from the applicable regulation and the licensee or applicant has made good faith efforts to comply with the regulation. Due to uncertainties associated with COVID-19 transmission, number of new cases, hospitalizations, and deaths caused by COVID-19, SNCs efforts to comply with the regulation have been unsuccessful, and it is no longer feasible to reschedule the biennial EP exercise in CY 2020. The requested exemption to conduct FNPs biennial EP exercise in CY 2021 instead of CY 2020 would grant only temporary relief from the applicable regulation.

E-4

Enclosure to NL-20-0713 Request for Exemption from 10 CFR 50, Appendix E, Sections IV.F.2.b and IV.F.2.c

5.0 CONCLUSION

As justified herein, SNC 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 is requested due to the COVID-19 PHE.

6.0 ENVIRONMENTAL ASSESSMENT Southern Nuclear Operating Company (SNC) is requesting an exemption from certain requirements of 10 CFR 50, Appendix E, for Joseph M. Farley Nuclear Plant (FNP) Units 1 and 2. Specifically, SNC 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 an environmental assessment and finding of no significant impact for the proposed exemption.

SNC has determined that the exemption does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, (iii) a significant increase in individual or cumulative public or occupational radiation exposure, (iv) a significant construction impact, and (v) a significant increase in the potential for or consequences from a radiological accident. The requirements for which the exemption is being requested involve biennial EP exercise training and its scheduling.

Accordingly, the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c), specifically 10 CFR 51.22(c)(25)(vi)(E) and (G).

Pursuant to 10 CFR 51.22(b), neither an environmental assessment nor an environmental impact statement need be prepared in connection with the issuance of this proposed request.

7.0 REFERENCES

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

2. Letter from Ho K. Nieh and Robert Lewis, U.S. Nuclear Regulatory Commission, to Dr.

Jennifer L. Uhle, Nuclear Energy Institute, 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 (ADAMS Accession No. ML20120A003)

3. Letter from Dr. Michael S. Casey, Federal Emergency Management Agency, to Ms. Kathryn Brock, U.S. Nuclear Regulatory Agency, COVID-19 Preparedness Assessments for FEMA Region IV Commercial Nuclear Power Plants, dated June 16, 2020 (ADAMS Accession No. ML20170B043)

4. Joint NRC and FEMA Memorandum, Guidance for Postponement of REP Exercises due to the COVID-19 Outbreak, dated March 30, 2020 (ADAMS Accession No. ML20085F705)

E-5

Joseph M. Farley Nuclear Plant - Units 1 and 2 Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic Attachment Collection of Communications Supporting the Exemption Request

Attachment to NL-20-0713 STATE OF ALABAMA EMERGENCY MANAGEMENT AGENCY 5898 COUNTY ROAD 41

• P.O. DRAWER 2160

• CLANTO:--1. ALABAMA 35046-2160 (205) 280*2200 FAX# (%05) 280-2495 KAYIVEY BRIAN E. HASTINGS GOVERNOR DLRECTOR September 10, 2020 W Montague Winfield Acting Regional Advisory Council Chairperson National Preparedness Division U. S. Department of Homeland Security Federal Emergency Management Agency 3005 Chamblee Tucker Road Atlanta, Georgia 30341 RE: Rescheduling Joseph M. Farley Nuclear Power Plant 2021 Evaluated Exercise

Dear Mr. Acting Chairperson:

On January 13, 2020, the U.S. Department of Health and Human Services (HHS) declared a public health emergency for the United States to aid the nation's healthcare community in responding to the Coronavirus Disease (COVID-19). On March 11 , 2020, the COVID-19 outbreak was characterized as a pandemic by the World Health Organiution (WHO).

As a result of closely monitoring the evolving outbreak, the State of Alabama' s Public Health Officer declared a State Public Health Emergency March 13, 2020. This public health emergency directed the appropriate state agencies to exercise their statutory and regulatory authority to assist communities and entities that have been affected by COVID-19. The State of Alabama's Public Health Officer extended the "Safer at Home" public health order August '?,7, 2020 and shall remain in full force and effect until October 2, 2020. This Health Order addressed facial coverings for individuals and suspended certain gathering due to risk of infection by COVID-19.

At this time the State of Alabama Emergency Management Agency is requesting that the FY 2020 Evaluated Joseph M. Farley Nuclear Power Plant exercise be rescheduled from June 30, 2020 to September 21 , 2021 . Due to Alabama~ s response of protecting the health and welfare of the public during this global pandemic, implementing social distancing measures to prevent the spread of COVID-19, and numerous conflicts with the off-site response organizations' calendars, all involved parties believe that rescheduling to September 2 1, 2021 would ensure full participation and an adequate demonstration of off-site procedures and/or response capabilities. The Farley OROs, Southern Company, and the Nuclear Regulatory Commission have concurred, and we propose rescheduling to the 21st of September 2021 .

Page 1 of 11

Attachment to NL-20-0713 STATE OF ALABAMA EMERGENCY MANAGEMENT AGENCY 5898 COUSTY ROAD 41

• P.O. DRAWER 2160

• CLANTON,ALABAMA 35046-2160 (20S) 280-2200 - FAX I (205) 280-2495 KAYIVEY BRIAN E. HASTINGS GOVERNOR DIRECTOR If you have any questions, please contact Quinton Dailey, Technical Hazards Coordinator (205) 280-2406.

ck~d Director of Field Operations RWAfqd cc: John Ackennann, Federal Emergency Management Agency David Tuberville, ADPH/Radiation Control Chris Judah, Houston Co EMA Ronnie Dollar, Henry Co EMA Jeff Morrison, Georgia EMA Tony Gentry, Early Co EMA

. Barty Simonton, Georgia DNR Cherie Cornelius, Southern Nuclear Co John Perkins, Southern Nuclear Co David Simmons, Southern Nuclear Co William Gilbert, Southern Nuclear Co Page 2 of 11

Attachment to NL-20-0713 Garrett, William From: Bryson, Glenda <glenda.bryson@fema.dhs.gov>

Sent: Wednesday, September 2, 2020 8:10 AM To: Perkins, John M.; Taylor, Gene; Dailey, Quinton Cc: Lowery, Deshun; Simmons, David L.

Subject:

RE: Dates for Farley Graded Exercise 2021 EXTERNAL MAIL: Caution Opening Links or Files John, thanks. Well pencil it in on our end.

Quinton, please send us a date change letter from AEMA to FEMA with the new reschedule dates. Please note, we have a new mailing address and Randy Hecht has retired. The letter should be addressed to the acting RAC Chair, but routed first through JT Ackermann as the acting Branch Chief.

New FEMA mailing address:

3005 Chamblee Tucker Road Atlanta, Georgia 30341 John JT Ackermann. Acting Chief Technological Hazards Branch W Montague Q Winfield, Acting RAC Chair National Preparedness Division Glenda M. Bryson Emergency Management Specialist l Technological Hazards l National Preparedness Office: 7702203168 l Mobile: 2027055825 glenda.bryson@fema.dhs.gov Federal Emergency Management Agency www.FEMA.gov [fema.gov]

From: Perkins, John M. <JMPERKIN@southernco.com>

Sent: Wednesday, September 2, 2020 8:53 AM To: Bryson, Glenda <glenda.bryson@fema.dhs.gov>; Taylor, Gene <gene.taylor@fema.dhs.gov>

Cc: Lowery, Deshun <deshun.lowery@fema.dhs.gov>; Simmons, David L. <DAVLSIMM@southernco.com>

Subject:

Dates for Farley Graded Exercise 2021 Glenda/Gene, Not sure what we need to do to get these dates penciled in on the REP Exercise Schedule but we have buy in from all the OROs that these will work so I would like to get them please. Let me know if I need to do anything else. Thank you and I hope you all are having a great week.

Practice for Graded: July 27th Graded: September 21st 1

Page 3 of 11

Attachment to NL-20-0713 Very Respectfully, John Perkins BLEM Emergency Preparedness Specialist SR.

Southern Nuclear Company Plant Farley Jmperkin@southernco.com Office: 3346612796 Cell: 3345508682 Linc: 3345201334 Plant Farley Link 5'illtlwril Core Group 1 Ambam1dor Progmm 2

Page 4 of 11

Attachment to NL-20-0713 STATE OF ALABAMA EMERGENCYMANAGEMENTAGENCY 5898 COUNTY ROAD 41

• P.O. DRAWER 2160

• CLANr<>S, ALABAMA 35046-2160 (205) 280-2200 FAX I (205) 280-2495 KAYIVEY BRIAN E. HASTINGS GOVERNOR DIRECTOR John Perkins Emergency Preparedness* Specialist Southern Nuclear Company - Plant Farley 3535 Colonnade Pkwy Binningham, Al 35243 On January 31 , 2020, the U.S. Department ofHeaJth and Human Services declared a public heaJth emergency (PHE) for the United States to aid the nation's healthcare community in responding to the Coronavirus Disease 2019 (COVID-19). On March 11, 2020, the COVID-19 outbreak was characterized as pandemic by the World Health Organiz.ation. On March 13, 2020, the President of the United States of America declared the COVID-19 pandemic a national emergency. On March 13, 2020, Kay Ivey, Governor of the State of Alabama, declared a state PHE. The PHE directed the appropriate state agencies to exercise their statutory and regulatory authority to assist communities and entities that have been affected by COVID-19.

Due to ongoing response to the COVID-19 PHE at the state and local levels, to protect the health and welfare of the public during this global pandemic, the Alabama Emergency Management Agency supports the exemption request which proposes postponing the Joseph M. Farley Nuclear Plant (FNP) 2020 biennial emergency preparedness exercise to September 21 , 2021 . The exemption request for offsite exercises would allow state and local government resources to continue focusing essentiaJ response efforts on the COVID-19 PHE. The Alabama Emergency Management Agency would not be impacted in a manner that would adversely affect our ability to maintain response capabilities to support emergency response activities to actual nuclear power plant radiological emergencies at FNP. Throughout this pandemic, the Alabama Emergency Management Agency has remained ready to respond to an actual emergency at FNP and we are committed to maintaining the radiological emergency plan.

Sincerely, 1/

Quinton R. Dailey ~

Technical Hazards Coordinator Alabama Emergency Management Agency Page 5 of 11

Attachment to NL-20-0713 To: John Perkins Plant Farley Emergency Preparedness Dept.

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 (COVID19). On March 11, 2020, the COVID19 outbreak was characterized as a pandemic by the World Health Organization. On March 13, 2020, the President of the United States of America declared the COVID19 pandemic a national emergency. On March 13, 2020, Kay Ivey, Governor of the State of Alabama, declared a state PHE. The PHE directed the appropriate state agencies to exercise their statutory and regulatory authority to assist communities and entities that have been affected by COVID19.

Due to ongoing response to the COVID19 PHE, at the state and local levels, to protect the health and welfare of the public during this global pandemic, the Georgia Emergency Management and Homeland Security Agency REP Program supports the exemption request which proposes postponing the Joseph M. Farley Nuclear Plant 2020 biennial emergency preparedness exercise to September 21, 2021. The exemption request for offsite exercises would allow state and local government resources to continue focusing essential response efforts on the COVID19 PHE. The Georgia Emergency Management and Homeland Security Agency REP Program would not be impacted in a manner that would adversely affect our ability to maintain response capabilities to support emergency response activities to actual nuclear power plant radiological emergencies at FNP. Throughout this pandemic, the Georgia Emergency Management and Homeland Security Agency REP Program has remained ready to respond to an actual emergency at FNP, and we are committed to maintaining the radiological emergency plan.

Sincerely, Jeff Morrison REP Program Manager Georgia Emergency Management and Homeland Security Agency Page 6 of 11

Attachment to NL-20-0713 Garrett, William From: Perkins, John M.

Sent: Tuesday, September 15, 2020 12:24 PM To: Garrett, William Cc: Simmons, David L.

Subject:

Fwd: RE Response to COVID-19 Virus - Alabama Radiation Control Alabama Rad Health letter Get Outlook for iOS From: Kevin.Hicks@adph.state.al.us <Kevin.Hicks@adph.state.al.us>

Sent: Tuesday, September 15, 2020 12:18:41 PM To: Perkins, John M. <JMPERKIN@southernco.com>

Subject:

RE Response to COVID19 Virus Alabama Radiation Control EXTERNAL MAIL: Caution Opening Links or Files John Perkins, Emergency Preparedness Specialist, Sr.

Joseph M. Farley Nuclear Plant Emergency Preparedness Department John:

RE: Response to COVID-19 Virus - Alabama Radiation Control 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 Corona virus Disease 2019 (COVID-19).

On March 11, 2020, the COVID-19 outbreak was characterized as pandemic by the World Health Organization. On March 13, 2020, the President of the United States of America declared the COVID-19 pandemic a national emergency. On March 13, 2020, Governor Kay Ivey declared a state PHE for Alabama. The PHE directed the appropriate state agencies to exercise their statutory and regulatory authority to assist communities and entities that have been affected by COVID-19. Due to ongoing response to the COVID-19 PHE, at the state and local levels, to protect the health and welfare of the public during this global pandemic, the Alabama Department of Public Health, Office of Radiation Control supports the exemption request which proposes postponing the Joseph M. Farley Nuclear Plant 2020 biennial emergency preparedness exercise to September 21, 2021. The exemption request for offsite exercises would allow state and local government resources to continue focusing essential response efforts on the COVID-19 PHE. The Alabama Department of Public Health, Office of Radiation Control would not be impacted in a manner that would adversely affect our ability to maintain response capabilities to support emergency response activities to actual nuclear power plant radiological emergencies at Farley Nuclear Plant. Throughout this pandemic, the Alabama Department of Public Health, Office of Radiation Control has remained ready to respond to an actual emergency at Farley Nuclear Plant, and we are committed to maintaining the radiological emergency plan.

We appreciate the continued support and long standing relationship we have with Farley Nuclear Plant. Please let me know if I may be of assistance to you.

Sincerely, Kevin W. Hicks Alabama Department of Public Health Office of Radiation Control 1

Page 7 of 11

Attachment to NL-20-0713 Kevin W. Hicks, M.P.A.

COVID-19 UC Operations Section Chief Director, Emergency Preparedness & Environmental Monitoring Office Of Radiation Control Alabama State Department Of Public Health Confidentiality Notice - This e-Mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential or privileged information. If this message concerns a lawsuit, it may be considered a privileged communication. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message.

2 Page 8 of 11

Attachment to NL-20-0713 To: John Perkins Plant Farley Emergency Preparedness Dept.

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 nation's healthcare community in responding to the Coronavirus Disease 2019 (COVID-19). On March 11, 2020, the OCVID-19 outbreak was characterized as a pandemic by the World Health Organization. On March 13, 2020, the President of the United States of America declared the COVID-19 pandemic a National emergency. On March 13, 2020, Kay Ivey, Governor of the State of Alabama, declared a state PHE. The PHE directed the appropriate state agencies to exercise their statutory and regulatory authority to assist communities and entities that have been affected by COVID 19.

Due to ongoing response to the COVID* 19 PHE, at the state and local levels, to protect the health and welfare of the public during this global pandemic, the Blakely-Early County Emergency Management Agency supports the exemption request which proposes postponing the Joseph M. Farley Nuclear Plant 2020 biennial emergency preparedness exercise to September 21, 2021. The exemption request for offsite exercises would allow state and local government resources to continue focusing exxential response efforts on the COVID-19 PHE. The Blakely-Early County Emergency Management Agency would not be impacted in a manner that would adversely affect our aboility to maintain response capabilities to support emergency response activities to actual nuclear power plant radiological emergencies at FNP.

Throughout this pandemic, the Blakely-Early County Emergency Management Agency has remained ready to respond to an actual emergency at FNP, and we are committed to maintaining the radiological emergency plan.

Sincerely, Anthony Gentry Blakely-Early County Emergency Management Agency Page 9 of 11

Attachment to NL-20-0713 To: John Perkins Plant Farley Emergency Preparedness Dept.

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 (COVID19). On March 11, 2020, the COVID19 outbreak was characterized as pandemic by the World Health Organization. On March 13, 2020, the President of the United States of America declared the COVID19 pandemic a national emergency. On March 13, 2020, Kay Ivey, Governor of the State of Alabama, declared a state PHE. The PHE directed the appropriate state agencies to exercise their statutory and regulatory authority to assist communities and entities that have been affected by COVID19.

Due to ongoing response to the COVID19 PHE, at the state and local levels, to protect the health and welfare of the public during this global pandemic, the Henry County Emergency Management Agency supports the exemption request which proposes postponing the Joseph M. Farley Nuclear Plant 2020 biennial emergency preparedness exercise to September 21, 2021. The exemption request for offsite exercises would allow state and local government resources to continue focusing essential response efforts on the COVID19 PHE. The Henry County Emergency Management Agency would not be impacted in a manner that would adversely affect our ability to maintain response capabilities to support emergency response activities to actual nuclear power plant radiological emergencies at FNP. Throughout this pandemic, the Henry County Emergency Management Agency has remained ready to respond to an actual emergency at FNP, and we are committed to maintaining the radiological emergency plan.

Sincerely, Ronnie Dollar Henry County Emergency Management Agency Page 10 of 11

Attachment to NL-20-0713 To: John Perkins Plant Farley Emergency Preparedness Dept.

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 nation's healthcare community in responding to the Coronavirus Disease 2019 (COVID-19). On March 11, 2020, the COVID-19 outbreak was characterized as pandemic by the World Health Organization. On March 13, 2020, the President of the United States of America declared the COVID-19 pandemic a national emergency. On March 13, 2020, Kay Ivey, Governor of the State of Alabama, declared a state PHE. The PHE directed the appropriate state agencies to exercise their statutory and regulatory authority to assist communities and entities that have been affected by COVID-19.

Due to ongoing response to the COVID-19 PHE, at the state and local levels, to protect the health and welfare of the public during this global pandemic, the Dothan-Houston County Emergency Management Agency supports the exemption request which proposes postponing the Joseph M. Farley Nuclear Plant 2020 biennial emergency preparedness exercise to September 21 , 2021 . The exemption request for offsite exercises would allow state and local government resources to continue focusing essential response efforts on the COVID-19 PHE. The Dothan-Houston County Emergency Management Agency would not be impacted in *a manner that would adversely affect our ability to maintain response capabilities to support emergency response activities to actual nuclear power plant radiological emergencies at FNP.

Throughout this pandemic, the Dothan-Houston County Emergency Management Agency has remained ready to respond to an actual emergency at FNP, and we are committed to maintaining the radiological emergency plan.

Sincerely, Leigh Martin Deputy Director - REP Liaison Emergency Management Agency www.dothanhoustoncountyema.org Dothan - Houston County Telephone: (334) 794-9720 405 East Adams Street Fax: (334) 836-7059 Dothan, AL 36303 Page 11 of 11