PLA-7893, Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic (PLA-7893)

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Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic (PLA-7893)
ML20272A020
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 09/28/2020
From: Cimorelli K
Susquehanna, Talen Energy
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-7893
Download: ML20272A020 (30)
v • d • e


Text

September 28, 2020 Kevin Cimorelli Site Vice President Attn: Document Control Desk U S Nuclear Regulatory Commission Washington, DC 20555-0001 Susquehanna Nuclear, LLC 769 Salem Boulevard Berwick, P A 18603 Tel. 570.542.3795 Fax 570.542.1504 Kevin.Cimorelli@TalenEnergy.com SUSQUEHANNA STEAM ELECTRIC STATION REQUEST FOR ONE-TIME EXEMPTION FROM 10 CFR 50, APPENDIX E, BIENNIAL EMERGENCY PREPAREDNESS EXERCISE REQUIREMENTS DUE TO COVID-19 PANDEMIC PLA-7893 TALEN~

ENERGY 10 CFR 50.12 10 CFR 50, Appendix E Docket Nos. 50-387 50-388 In accordance with 10 CFR 50.12, "Specific exemptions," and "Addendum to U.S. Nuclear Regulatory Commission Planned Actions Related to Emergency Preparedness Biennial Exercise Requirements for Power Reactor Licensees During the Coronavims Disease 2019 Public Health Emergency" (ADAMS Accession No. ML20223A152), Susquehanna Nuclear, LLC (Susquehanna), requests an exemption for Susquehanna Steam Electric Station (SSES) from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c. Specifically, Susquehanna requests a one-time exemption to exclude the participation of the offsite response organization (ORO) in the biennial emergency preparedness exercise for calendar year (CY) 2020.

On January 31, 2020, the U.S. Department ofHealth and Human Services declared a public health emergency for the United States to aid the nation's healthcare community in responding to the Coronavims Disease 2019 (COVID-19) pandemic. On March 6, 2020, the governor of the Commonwealth of Pennsylvania issued a Proclamation of Disaster Emergency pertaining to 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 response to these declarations, Susquehanna has postponed some site activities due to isolation activities (e.g., social distancing, group size limitations, self-quarantining). While the SSES biennial emergency preparedness exercise has not been postponed, the threat of COVID-19 spread has resulted in the inability to safely conduct the October 20, 2020, exercise with full ORO participation. During a public meeting on June 23, 2020, State representatives commented to the Nuclear Regulatory Commission (NRC) that, while they are able to deal with multiple events at the same time, the conduct of drills or exercises under the extraordinary circumstances of the COVID-19 Public Health Emergency would require additional planning to ensure the safety of participants.

Document Control Desk PLA-7893 Conducting the SSES biennial emergency preparedness exercise in CY 2020 without ORO participation places the exercise outside of the requirement of 10 CFR 50, Appendix E, Section IV.F.2.c. Consequently, Susquehanna requests a one-time exemption to exclude the participation of the ORO in the biennial emergency preparedness exercise in CY 2020. An exemption from Section IV.F.2.c would not prevent a State or local authority, at its discretion, from demonstrating key skills in drills and exercises for the 8-year exercise cycle or prevent a State or local authority from conducting the exercise in CY 2020 or CY 2021.

In accordance with the provisions of 10 CFR 50.12, Susquehanna is requesting exemption from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c, for SSES. Justification for the issuance of an exemption is provided in the Attachment and is based on the guidance provided in the NRC letter to the Nuclear Energy Institute (NEI) dated May 14, 2020, "U.S. Nuclear Regulatory Commission Planned Actions Related to Emergency Preparedness Biennial Exercise Requirements for All Licensees During the Coronavirus Disease 20 19 Public Health Emergency" (ADAMS Accession No. ML20120A003) and the addendum to this letter dated September 2, 2020 (ADAMS Accession No. ML20223A152). This request is supported by the OROs and Pennsylvania Emergency Management Agency (PEMA) as evidenced in Enclosure A and Enclosure B, respectively. Because the biennial exercise is scheduled for October 20, 2020, Susquehanna requests the proposed exemption be granted by October 9, 2020.

Should you have any questions regarding this submittal, please contact Ms. Melisa Krick, Manager-Nuclear Regulatory Affairs at ( 570) 542-1818.

ised regulatory commitments identified in this letter.

Kevin Cimorelli

Attachment:

Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirement Enclosure A: Copy ofRequests for Relief from Risk County OROs Enclosure B: Copy ofPEMA Letter to Federal Emergency Management Agency Requesting Relief from Frequency Requirements Radiological Emergency Preparedness Program Exercises (excluding enclosures pertaining solely to BVPS and PBAPS)

Document Control Desk PLA-7893 Copy: NRC Region I Mr. M Rossi, NRC Resident Inspector Ms. S. Goetz, NRC Project Manager Mr. M. Shields, PA DEP/BRP Ms. S. Silva, PEMA (Acting) Nuclear Power Plants Division Chief

Attachment to PLA-7893 Request for One-Time Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirement

Attachment to PLA-7893 Page 1 of 4 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.12, Specific exemptions, Susquehanna Nuclear, LLC (Susquehanna), requests an exemption for Susquehanna Steam Electric Station (SSES) from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c. Specifically, Susquehanna requests a one-time exemption to exclude the participation of the offsite response organization (ORO) in the biennial emergency preparedness exercise for calendar year (CY) 2020.

The requested exemption supports the continued implementation of the isolation activities (e.g., social distancing, group size limitations, self-quarantining) to protect required ORO personnel in response to the Coronavirus Disease 2019 (COVID-19) pandemic. These activities are needed to ensure supporting state and local government personnel are isolated from the COVID-19 virus and remain capable of executing the functions of the emergency response organization, as described in the SSES emergency plan, as well as other non-nuclear health and safety functions for the benefit of the public.

2.0 BACKGROUND

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. 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.

The SSES CY 2020 biennial emergency preparedness exercise with ORO participation is scheduled for October 20, 2020.

In June 2020, the OROs notified PEMA of their concerns with supporting the biennial exercise and maintaining protection of offsite staff during the current COVID-19 pandemic response. Based on these concerns, the needed response to the pandemic, and the uncertainty of the future in this matter, the need to seek a one-time exemption regarding the ORO participation in the CY 2020 exercise was determined to be the most appropriate action.

3.0 TECHNICAL JUSTIFICATION OF ACCEPTABILITY The U.S. Centers for Disease Control has issued recommendations advising social distancing to prevent the spread of the COVID-19 Virus. Susquehanna has implemented isolation activities such as self-quarantining, group size limitations and social distancing to protect required site personnel. Ideally, this will limit the spread of the virus among the

Attachment to PLA-7893 Page 2 of 4 station staff. Similar isolation activities are also needed to limit the spread of COVID-19 among off-site personnel-supporting state and local governments - so they remain capable of executing the functions of the emergency response organization, as described in the SSES emergency plan.

The last SSES biennial emergency preparedness exercise was conducted on October 16, 2018. Since that time, SSES has conducted drills, exercises, and other training activities that exercised its emergency response strategies, in coordination with offsite authorities, including in part, a full participation exercise on August 28, 2019, and limited participation (i.e., taking Emergency Offsite Notification Reports) exercises on June 25, July 9, August 13, September 4, and October 29, 2019 and July 28, 2020.

The current biennial emergency preparedness exercise at SSES is scheduled to be conducted on October 20, 2020. The next biennial exercise is expected to occur in October 2022 and be coordinated with the applicable OROs, the applicable Nuclear Regulatory Commission (NRC) region, and the applicable Federal Emergency Management Agency region. This exemption request will not affect the schedule for the next biennial exercise (i.e. biennial exercises, for both onsite and offsite exercises, will continue to be in even years).

Susquehanna has made a reasonable effort to reschedule the exercise but was unsuccessful. As documented Enclosures A and B, it was agreed upon that it was not feasible to schedule the exercise in 2021 due to uncertainty of COVID-19 isolation actions and conflicts with other NRC inspections. Therefore, an exemption from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c is required to exclude the ORO from the October 20, 2020, biennial emergency preparedness exercise.

The ORO will maintain their current emergency plans and remain able to respond to an emergency during the pandemic. The exemption from participation in the exercise does not obviate the ability to respond should an actual emergency occur.

4.0 JUSTIFICATION OF EXEMPTION 10 CFR 50.12, Specific exemptions, states that the NRC may grant exemptions from the requirements of the regulations of this part provided three conditions are met. They are:

(1) The exemptions are authorized by law.

(2) The exemptions will not present an undue risk to the public health and safety, and (3) The exemptions are consistent with the common defense and security.

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

Attachment to PLA-7893 Page 3 of 4

1. This exemption is authorized by law.

The biennial emergency preparedness exercise for the emergency response organization specified in 10 CFR 50, Appendix E, Section 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, or the Energy Reorganization Act of 1974, as amended.

2. This exemption will not present an undue risk to the public health and safety.

The underlying purpose of 10 CFR 50, Appendix E, Section IV.F.2.c requiring full participation by each offsite authority having a role under the radiological response plan to be exercised biennially is to ensure that ORO personnel are familiar with their duties and to test the adequacy of the emergency plan.

Susquehanna has conducted training drills at SSES with ORO participation since the last biennial exercise with no performance issues. Susquehanna considers the performance of the ORO to be at an acceptable level to satisfy the underlying purpose of the rule. Exclusion of the ORO from the October 20, 2020, emergency preparedness exercise does not create any new accident precursors. The probability and consequences of postulated accidents are not increased, and an acceptable level of emergency preparedness is maintained. Therefore, there is no undue risk to public health and safety.

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

The requested exemption excludes the ORO participation in one emergency preparedness exercise to help protect individuals from the spread of COVID-19.

This exemption has no relation to security issues. The common defense and security are not impacted by this exemption.

In addition to the three conditions discussed above, 10 CFR 50.12(a)(2) states that the NRC will not consider granting an exemption unless special circumstances are present.

Under 10 CFR 50.12(a)(2)(iv), special circumstances are present whenever the exemption would result in benefit to the public health and safety that compensates for any decrease in safety that may result from the grant of the exemption. Offsite organizations are currently dealing with COVID-19 in their daily duties. Participation in the biennial exercise presents a potential health risk for those concerned, who may become exposed to COVID-19. Through this exposure, they could become unable to perform their duties during a real-life emergency.

Attachment to PLA-7893 Page 4 of 4 Under 10 CFR 50.12(a)(2)(v), special circumstances are present whenever the exemption would provide only temporary relief from the applicable regulation and the licensee has made good faith efforts to comply with the regulation. The requested exemption to conduct the biennial emergency preparedness exercise for CY 2020 without ORO participation would grant only temporary relief from the applicable regulation in that all future regularly scheduled biennial exercises would require ORO participation. In addition, coordination of activities with current health restrictions, such as social distancing, is increasingly difficult. Based on discussion with ORO representatives, Susquehanna has concluded that a good faith effort has been made to comply with the regulation.

5.0 CONCLUSION

As demonstrated above, Susquehanna 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. Further, special circumstances as defined in 10 CFR 50.12(a)(2)(iv) and (v) exist. A one-time exemption from the biennial emergency preparedness exercise requirements of 10 CFR 50, Appendix E, Section IV.F.2.c is required during the 2020 COVID-19 pandemic.

6.0 ENVIRONMENTAL ASSESSMENT Susquehanna is requesting an exemption from certain requirements of 10 CFR 50, Appendix E, for SSES. Specifically, Susquehanna is requesting a one-time exemption from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c to exclude the participation of the ORO in the biennial emergency preparedness exercise for CY 2020.

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

Susquehanna has determined that the exemption involves no significant hazards consideration; no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite; that there is no significant increase in individual or cumulative public or occupational radiation exposure; that there is no construction impact; there is no significant increase in the potential for or consequences from a radiological accident; and that an exemption from scheduling requirements is being requested. Accordingly, the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(25). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this proposed exemption request.

Enclosure A to PLA-7893 Copy of Requests for Relief from Risk County OROs

September 14, 2020 Ms. Megean M. Brown, Emergency Preparedness Supervisor Susquehanna Steam Electric Station 769 Salem Blvd.

Berwick, PA 18603

Dear Ms. Brown,

Jennifer L Long Emergency Management Coordinator P 0 Box 380 Bloomsburg, P A 17815 As we continue to respond to the COVID-19 Pandemic, we have significant concerns regarding the upcoming Federal Evaluation Exercise for the Susquehanna Steam Electric Station (SSES) on October 20, 2020. Columbia County is prepared to respond to an actual incident at SSES, but participation in an exercise with the current COVID-19 mitigation measures and anticipation of continuing precautions, puts an undue burden on our staff and volunteers.

While we have made reasonable effort towards rescheduling the exercise during the year 2020, we have been unsuccessful with the continued number of COVID-19 cases remaining steady within our county. Additionally, the Governors restrictions have not yet been lifted. We continue to work with the Pennsylvania Emergency Management Agency to coordinate request for exercise credit with the Federal Emergency Management Agency.

Columbia County is committed to maintaining our radiological emergency plans. To ensure our continued state of readiness, in June of this year, the Radiological Emergency Response Plans for our county, municipalities, and support counties were updated and promulgated. The plans have been submitted to the Pennsylvania Emergency Management Agency and the Federal Emergency Management Agency for review. In addition, SSES has conducted and offered several virtual training sessions for our county and municipalities to continue to keep us informed and ready should a real emergency occur at SSES.

Columbia County continues to support Susquehanna Steam Electric Station and has successfully demonstrated our performance through Practice and Graded Exercises throughout the years. SSES's request for exemption will not adversely affect Columbia County's ability to maintain response capability to support emergency response activities. As stated above, we are fully prepared for and can handle any emergency throughout this pandemic including an actual incident at the Susquehanna Steam Electric Station.

Columbia County agrees with the request for exemption and confirms our continued support of SSES.

Respectfully,

~r/Jr)~

Jennifer L Long EMA Director Columbia County EMA

LUZERNE COUNTY Emergency Management Agency Lucille Morgan, Director September 10, 2020 PENNSYLVANIA E S T A D L I S H ED 1 7 8 6 Ms. Megean M. Brown, Emergency Preparedness Supervisor Susquehanna Steam Electric Station 769 Salem Blvd.

Berwick, PA 18603

Dear Ms. Brown,

LUZERNE COUNTY COUNTY MANAGER C. DAVID PEDRI, ESQUIRE As we continue to respond to the COVID-19 Pandemic, we have significant concerns regarding the upcoming Federal Evaluation Exercise for the Susquehanna Steam Electric Station (SSES) on October 20, 2020. Luzerne County is prepared to respond to an actual incident at SSES, but participation in an exercise with the cunent COVID-19 mitigation measures and anticipation of continuing precautions, puts an undue burden on our staff and volunteers.

While we have made reasonable effort towards rescheduling the exercise during the year 2020, we have been unsuccessful with the continued number of COVID-19 cases remaining steady within our county. Additionally, the Governors restrictions have not yet been lifted. We continue to work with the Pennsylvania Emergency Management Agency to coordinate request for exercise credit with the Federal Emergency Management Agency.

Luzerne County is committed to maintaining our radiological emergency plans. To ensure our continued state of readiness, in June of this year, the Radiological Emergency Response Plans for our county, municipalities, and support counties were updated and promulgated. The plans have been submitted to the Pennsylvania Emergency Management Agency and the Federal Emergency Management Agency for review. In addition, SSES has conducted and offered several virtual training sessions for our county and municipalities to continue to keep us informed and ready should a real emergency occur at SSES.

Luzerne County continues to supp01i Susquehanna Steam Electric Station and has successfully demonstrated our performance through Practice and Graded Exercises throughout the years. S SES 's request for exemption will not adversely affect Luzerne County's ability to maintain response capability to suppoti emergency response activities. As stated above, we are fully prepared for, and can handle, any emergency throughout this pandemic including an actual incident at the Susquehanna Steam Electric Station. Luzerne County agrees with the request for exemption and confirms our continued support of SSES.

Sincerely,

~-~to<'

EMA Building

  • 185 Water Street
  • Wilkes-Barre, PA, 18711 voice 570.820.4400 fax 570.820.4456 tdd 570.825.1860

Enclosure B to PLA-7893 Copy of PEMA Letter to Federal Emergency Management Agency Requesting Relief from Frequency Requirements Radiological Emergency Preparedness Program Exercises (excluding enclosures pertaining solely to BVPS and PBAPS)

pennsylvania EMERGENCY MANAGEMENT AGENCY August 21, 2020 Ms. Lilian Hutchinson Acting Regional Assistance Chair Federal Emergency Management Agency, Region III One Independence Mall, Sixth Floor 615 Chestnut Street Philadelphia, Pennsylvania 19106

Dear Ms. Hutchinson:

The Pennsylvania Emergency Management Agency (PEMA) has received the Federal Emergency Management Agency's (FEMA) Framework for Processing Relief from Frequency Requirements Radiological Emergency Preparedness Program (REPP) Exercises, dated July 23, 2020. After reviewing the fi*amework and available options PEMA would like to request cancellation of the three plume federally-evaluated exercises listed in the table below scheduled for 2020 due to hardships created by the current COVID-19 crisis affecting the nation. This request is based on the specific requirements and definitions contained in the framework memo under section 2.b.

Plant I Date Scheduled I Last Plume Exercise I Last Ingestion I ~xercisc Susquehanna Steam Electric Station Beaver Valley Power Station Peach Bottom Atomic Power Station

  • Rescheduled fi*om 06/09/2020
    • Rescheduled from 04/21/2020 10/20/2020 10/16/2018 11/10/2020*

06/12/2018 12/08/2020**

04/17/2018 We offer the following specific points in support of our request:

N/A 03/12/2019 NIA

1. Ongoi11g Pa11demic - The COVID-19 pandemic remains a significant threat and the nation remains under a Public Health Emergency which was originally declared by the US Secretary of Health and Human Services on January 31 and renewed on April 21 and again on July 25. In the Common~ealth, as of the date of this correspondence we have a total of 126,940 cases of COVID-19 since the crisis began. Pennsylvania currently ranks #12 in the nation in case counts, and we continue to add hundreds of new cases each day despite the mitigation attempts that remain in place and continued public emphasis on universal use of face coverings/masks, hygiene practices, social distancing and other limitations on gathering size and indoor occupancy limits.

We are not confident exercises can be safely conducted in the remaining months of2020 without further spreading the virus or jeopardizing the lives of those involved in response operations from the off-site response organizations (OROs). Based on current trends and the potential for a resurgence this fall along with flu season there remains a strong possibility that this pandemic will continue well into calendar year 2021.

Pennsylvania Emergency Management Agency 1310 Elmerton Avenue I Harrisburg, PA 17110 I 800-Hbg-PEMA I www.pema.pa.gov

Ms. Lilian Hutchinson August 21, 2020 Page2

2. Pandemic Related Impacts Affecting the Ability to Adequately Conduct Exercises -Exercises are designed to practice plans, demonstrate capabilities, and be beneficial for the players, observers, and evaluators alike. Cun-ently, it is a severe hardship for most OROs to adequately demonstrate capabilities through an exercise. Government buildings and municipal emergency operation c.enters (EOCs) are closed or restricted to visitors, and many individuals continue to work from home which has been strongly encouraged by the Governor. Additionally, many emergency workers who support nuclear power plant exel'()ises are volunteers wll.o continue to commit time and resources to current response activities such as feeding programs and protective equipment distribution. Many of the volunteers who assist the REPP are retired emergency services or power plant personnel whose age group and potential pre-existing health issues leaves them more susceptible to developing severe complications if they would acquire COVID-19.

Virtual capabilities are limited in many of the municipalities and in-person training has been at a standstill due to social distancing and gathering restrictions imposed by the Pennsylvania Governor's Office and Department ofHealth (DOH). Conducting an exercise during these cun-ent conditions would not be beneficial to anyone but would likely put people in harm's way unnecessarily. Just one person contracting COVID-19 and possibly dying due to an exercise is something Pe:r;msylvania will not condone.

3. Travel, Gathering and Budget Restrictions Impacting Ability to Adequately Conduct Exercises Various restrictions remain in place to limit the spread of COVID-19 or because of the financial impacts related to the COVID-19 crisis that would limit the ability to conduct exercises. The information below outlines some of those restrictions and impacts.

Travel Restrictions - Per the Governor's Office, Pennsylvania state employees are not permitted to travel tmless it is deemed necessary. PEMA and the Department of Environmental Protection's (DEP) Bmeau of Radiation Protection (BRP) does not know when this restriction will be lifted or if exercise travel requests would be approved. PEMA has concerns with sending staff to multiple locations for an exercise. Some of the exercises involve a significant amount of agency personnel and would potentially unnecessarily risk exposure to COVID-19 since they may be conducting exercises in counties with active COVID-19 outbreaks and community transmission of the virus. Additionally, any FEMA evaluators traveling from outside of the Commonwealth may be subject to a 14-day self-isolation period if travelling from a known hot-spot state. The list of hot-spot states is updated weekly by DOH, so this may adversely impact the ability for evaluators to evaluate specific exercise components on short notice, Budget/Financial Restrictions - Commonwealth employees are not permitted to expend costs at this time unless deemed necessary and pre-approved because of state budget impacts associated with the COVID-19 crisis. Though the REPP is funded by Act 147, requests still need to be approved by the Governor's Office. Without approval, PEMA and BRP employees cannot travel, attend or conduct training, or acquire lodging.

Ms. Lilian Hutchinson August 21, 2020 Page3 Gathering Limitations/Restrictions - Currently event or gathering size is limited. to 25 individuals for indoor environments which would impact the ability to conduct in-person or hands-on training, exercises, or conduct demonstrations of specific response procedures.

4. Previous Exercise History - All three Emergency Planning Zones (EPZs) had successful demonstrations during their last three exercises within the eight-year cycle as per their After-Action Report (AAR) written by FEMA. PBAPS has three risk counties (Chester, Lancaster, and York) who participated during the Three Mile Island (TMI) Generating Station federally-evaluated plume exercise conducted on May 7, 2019, and Limerick Generating Station (LGS) federally-evaluated plume exercise conducted on November 19, 2019. BVPS EPZ, which exercises 100 percent oftheir risk and support counties (Allegheny, Beaver, Butler, Lawrence, and Washington) and municipalities every exercise, last conducted a plume exercise on June 12, 2018. BVPS also participated in an IPX on March 12, 2019, that included not only the risk and support counties but also a total of seven ingestion counties (Armstrong, Clarion, Fayette, Greene, Mercer, Venango, and Westmoreland) along with the state of West Virginia.
5. Recent EOC Activations for Risk and Support Counties-The EOC's for all the risk and support counties for all three EPZs have been activated at some point and to some degree for multiple operational periods since March 2020 in response to one ot more incidents involving the COVID-19 pandemic, civU disturbances associated protests, or demonstrations that turned violent, or severe weather. In addition to activations for COVID-19 pandemic these incidents include the following:

May 31 - Civil disturbance, riots and looting that impacted Philadelphia, Montgomery, Chester, Delaware and Allegheny counties.

June 4 - Severe storms and derecho that affected Philadelphia, Montgomery, Chester, Delaware, Berks and Bucks counties causing significant wind damage and power outages that lasted for numerous days and involved critical infrastructure/facilities.

June 11 - Severe storms which caused significant flooding in Schuylkill County and a tornado in Beaver County.

August 4 - Tropical Storm Isaias which caused flash flooding, power outages and numerous road closures in the southeast counties. Chester County specifically had an evacuation route blocked by wires and trees which resulted in their EOC having to devise an alternate route and communicate that to the municipalities until it was cleared.

As you can see from the above information, all risk and support counties have demonstrated their ability to rapidly implement and adapt their all-hazards Emergency Operations Plans (EOPs), as needed, to respond and recover from multiple impacts within the last six months as well as remain ready and able to respond as needed to any incident at a nuclear power plant in their jurisdiction. Many of these real-world responses have been complicated by the COVID-19 crisis which has created a complex operating environment. Even while responding to the pandemic and other emergencies, the risk and support counties for all five nuclear power plant emergency planning zones have been in constant communication with their respective REP Off-site Planners regarding their ability to respond should a real-world radiological incident occur.

Ms. Lilian Hutchinson August 21,2020 Page4 In closing, the pandemic remains a dynamic, challenging and complex situation that tequit*es eady intervention and strict adherence to mitigation procedures when subtle changes are realized in key metrics.

As we have seen in other states recently, it only takes a shoti time to have exponential growth in case counts when mitigation procedures are not strictly followed, and community transmission of the virus occurs. Any u1111ecessary events that could potentially expose individuals to COVID-19 or propagate further transmission of the virus should be scrutinized and heavily weighed against the need to conduct them, While we have evaluated the potential of requesting relief for exercises up until35 months from the previous evaluated biennial exercise, we feel that approach is not addressing the issue and only serves to delay the exercises further with no guarantee that we will be able to conduct them within the specified time frame. We vety well may be in the same predicament in 2021. Instead of using a wait and see approach, we strongly mge you to let us give om OROs peace of mind to focus on the real-world pandemic at hand and save our energy and resources to support t:hem when needed.

Enclosed you will find supporting documentation received from off-site response organizations. Sl;10uld you have any questions or concerns, please contact Mr. Stephen Bekanich, Deputy Director for Preparedness, at 717-651-2231 or via email at sbekanich@pa.gov.

Sincerely, David R. Padfield Director, P A Emergency Management Agency Enclosures Relief from the Frequency Requirements Letter and Framework BVPS Letters PBAPS Letters SSES Letters cc:

Mr. David Allard, PA Department ofEnvironmental Protection, Bureau of Radiation Protection Mr. Joseph Suders, Federal Emergency Management Agency, Region III

U.S. Department of Homeland Security Washington, DC 204 72 FEMA MEMORANDUM FOR INTERNAL DISTRIBUTION DATE:

FROM:

TO:

SUBJECT:

July 23, 2020

'lfJP }J. Q

...2\\tn Michael S. Casey, PhD, Director, Technological Hazards Divi;i~nxrQ Federal Preparedness Coordinators (FPC) and Regional Assistance Chairpersons (RAC)

Relief from the Frequency Requirements Radiological Emergency Preparedness Program (REPP) Exercises Due to the COVID-19 Pandemic response, several States have postponed their REPP Exercises scheduled for the calendar year (CY) 2020. Given the potential of enduring impacts from the COVID-19 Pandemic, FEMA anticipates situations where States will be unable to reschedule the required biennial exercises within CY 2020 and will need to request relief from FEMA's exercise frequency requirements due to hardships associated with COVID-19 response.

The attached framework identifies guidelines for the FEMA Regional staff and Offsite Response Organizations (OROs) to request relief from this frequency requirement.

Point of contacts for this memorandum are, Craig Fiore, Craig.Fiore@fema.dhs.gov, (202) 280-9303, Bruce Foreman at Bruce.forman@fema.dhs.gov (202) 304-5399.

Encl.

Relief from the Frequency Requirements Radiological Emergency Preparedness Program (REPP)

Exercises Framework www.fema.gov

Framework for Processing Relief from the Frequency Requirements Radiological Emergency Preparedness Program (REPP) Exercises 1.

Purpose:

Provide the framework for FEMA to receive, review, approve, and process requests from States for relieffrom the frequency requirements for Radiological Emergency Preparedness Program (REPP) exercises due to hardships associated with COVID-19 response.

2.

Background:

a.

Due to the COVID-19 Pandemic response, several States have postponed their REPP Exercises scheduled for the calendar year (CY) 2020. Given the potential of enduring impacts from the COVID-19 Pandemic, FEMA anticipates situations where States will be unable to reschedule the required biennial exercises within CY 2020 and will need to request relief from FEMA's exercise frequency requirements.

b.

Definitions:

i.

Hardship means any COVID-19 related impact that constrains or severely restricts the ORO's ability to demonstrate the key skills and capabilities necessary to implement their radiological emergency plan.

ii.

Postponement means OROs will conduct their required biennial REP exercise at a date and time later in CY 2020. Postponed exercises must be rescheduled and completed no later than 31 December 2020 to comply with established frequency requirements.

iii.

Relief (Exemption) means conducting the required biennial exercise no later than 35 months from the previously evaluated biennial exercise.

iv. Cancellation means the OROs will not be required to conduct the exercise in the 2-year cycle. Other REP Assessment methods will be applied by FEMA to maintain its Reasonable Assurance determination.

c.

To ensure fairness and consistency across the Nation, THO has developed this framework that:

i.

Leverages successful prior demonstrations of REPP and all-hazard capabilities of communities that surround nuclear power plants.

ii.

Empowers the FEMA Regions to execute their delegated authorities and responsibilities.

iii. Lessens the burden of planning, budgeting, preparing, executing, and assessing all the postponed REPP Exercises in a condensed CY 2020 timeframe.

iv.

Provides the greatest flexibility while maintaining central tenets of the REPP guidance.

v.

Recognizes the OROs response efforts in accordance with their All-Hazards Plan and mirrors REP plans, policies, procedures, capabilities, and readiness previously approved by THO and documented in ALCs.

1

Framework for Processing Relief from the Frequency Requirements Radiological Emergency Preparedness Program (REPP) Exercises

3.

Proposed Process for Relief:

a.

Upon request for relief from applicable offsite response organizations (OROs), the FEMA Regional Assistance Committee (RAC) Chair engages the State to:

i.

Assess Operational Environment and its impacts upon capabilities, implementing REP plans, and Reasonable Assurance.

ii. Assess the State's option to postpone and reschedule (plan, prepare, budget, execute, assess) the required biennial REP exercises later in Calendar Year 2020.

b.

If option 3.a(ii) above is not viable, then a State should submit a formal request to the FEMA Regional Administrator for relief from the FEMA REP biennial exercise frequency requirements due to hardship caused by the response efforts of COVID-19.

c.

The State's Request for Relief should include at a minimum:

i.

How the response to the ongoing COVID-19 Pandemic precludes the State and OROs from conducting and participating in the required REP Exercises in CY 2020.

ii.

List the affected site (s) and ORO(s).

iii. Date of last evaluated biennial exercise.

iv.

Date of currently scheduled biennial exercise.

v. A statement that rescheduling is to be conducted 35 months from the previous exercise.

vi. A list of activities or assessments conducted since previously evaluated exercise (e.g., drills, training, dress rehearsals, site assistance visits).

vii.

Documentation on actual response activities conducted since previously evaluated exercises.

viii. A statement that rescheduling was coordinated with applicable OROs and the utility.

d. This framework does not preclude requests for relief that take a different approach or present different rationales. FEMA will review such requests on a case-by-case basis. 1
e.

Upon receipt of the State's Request, FEMA RAC Chair informs REP HQ Branch Chief, THD of the Request.

f.

In coordination and collaboration with the State, the Regional Administrator, through the FEMA RAC Chair, will assess the request and make an initial determination based upon the following criteria (this list is illustrative and not exhaustive):

i.

Review of recent assessment activities observed by FEMA (Drills, SAVs, tabletop exercises, facilitated discussions, workshops, ALCs, training, etc.,) that have been demonstrated by the State and OROs since the previous Biennial Exercise ii.

Review of "real-world" all-hazards and/or radiological incidents during the past two years that demonstrate successful State and ORO capabilities and Capability Target Assessment.

1 This framework contains guidance for implementing the voluntary information collections related to requesting relief and an alternative approach from requirements contained in 44 CFR Part 350 that are subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et. seq.). These information collections were approved by the Office of Management and Budget under control number 1660- 0024.

2

Framework for Processing Relief from the Frequency Requirements Radiological Emergency Preparedness Program (REPP) Exercises iii.

Review of Objectives/Capability Targets demonstrated during the COVID-19 response (if known at the time of the request) to determine REP Program Evaluation Credit.

iv.

Review the results of the previous biennial exercise evaluated by FEMA and the conclusions from the Biennial Exercise AAR.

v. Summary of coordination with the licensee to ensure compliance and alignment with relevant NRC regulatory and licensing requirements.

vi. This assessment, along with any findings, observations, and recommendations, should be compiled as part of the State's Request for Relief package to the FEMA Regional Administrator.

g.

If the FEMA Regional Administrator approves the request, the FEMA RAC Chair forwards recommendations to FEMA HQ THD for review and consideration.

h.

After FEMA HQ THD review, THD forwards a recommendation to the Deputy Administrator of Resilience and informs NRC ofthe decision to ensure compliance and alignment with relevant NRC regulatory requirements.

i.

Upon approval by Deputy Administrator of Resilience, FEMA HQ THD informs the FEMA Regional Administrator and FEMA RAC Chair.

j.

The Regional Administrator provides the State with a letter communicating FEMA's decision on the exercise frequency relief request.

3

Chris E. Young Richard Ridgway David M. Kovach Commissioners June 10, 2020 Commissioners of Columbia County ComtHouse, P.O. Box 380, Bloomsburg, Pelll1sylvania 17815 570-389-5600 (TDD: 570-389-5745) Fax: 570-784-0257 David R. Padfield, Director Pennsylvania Emergency Management Agency 131 0 Elmerton A venue Hanisburg, PA 17110

Dear Director Padfield:

David Witchey Chief Clerk Anthony McDonnld Sol!citor This letter is in support of Columbia County EMA regarding the request to be excused from the SSES Federal Exercise Evaluation scheduled for October 20, 2020. The Coronavims COVID-19 Pandemic created the unprecedented times we now face. Columbia County is always prepared to assist with and mitigate any issues/incidents that occur at SSES. All real world events always take precedence and Columbia County stands ready regardless.

We feel that the possibility of putting our Municipal Partners, EOC Staff, RAD Team and 911 Telecommunicators at risk of contracting COVID-19 dming the Federal Exercise Evaluations is too great and request that the Evaluation be cancelled for CY2020. The 911 Center/EMA Office have been locked down since early March as an effort to lessen that possibility. We are not comfortable at this time to change that precaution.

We also request that our past perfmmances be considered to show/prove that Columbia County has always excelled in every Federal Evaluation for SSES to date. Columbia County's dedication to and partnership with SSES remains steadfast.

We look forward to your timely response and thank you for your time in this matter.

2/ifnlly, Richard C. Ridgway/Commissioner

~~

Jru1e 9, 2020 David R. Padfield, Director Pennsylvania Emergency Management Agency 1310 Elmerton A venue Hanisburg, PA 17110

Dear Director Padfield:

Jennifer L Long Emergency Management Coordinator P 0Box380 Bloomsburg, P A 17815 This letter is in reference to the scheduled Federal Exercise Evaluation for The Susquehanna Steam Electric Station (SSES) Power Plant on October 20, 2020. Columbia County is always prepared to assist with and mitigate any issues/incidents that occur at SSES. That being said, due to the Coronavirus/COVID-19 Pandemic and the related response efforts we feel that holding such an activity would not be in the best interest ofthose involved at this time.

Due to the restrictions/precautions, set by the Governor of Pennsylvania, regarding social distancing parameters it would not be feasible to accommodate individuals safely in the Municipal Emergency Operations Centers (EOC) or the County Emergency Operations Center (EOC) due to the limited space at these locations. The Columbia County EOC is located directly next to the East Central Emergency Network (ECEN) 911 Center and it would not be in the best interest of the Telecommunicators to hold this evaluation and jeopardize their health and safety by having numerous individuals in the building.

The EMA Office and the 911 Center have been locked down since early March 2020 due to the COVID-19 Pandemic.

Another concern we have is with the Monitoring and Decontamination Evaluation that is scheduled for October 21 2020 at the Columbia Montour Vo"Tech School. With all ofthe uncertainty surrounding the schools, we are unsure of the capacity in which we would be allowed to utilize the building. Not to mention the cleaning and disinfecting that would be required following the Federal Exercise.

I have been employed by Columbia County since 1988. I have been a part of the EOC even prior to becoming the EMA Director. Columbia County has exhibited excellence and great professionalism with every Federal Exercise Evaluation for as long as I have been employed. We are requesting that PEMA strongly consider our request to be excused from this Federal Exercise Evaluation for not only the EOC portion but the Monitoring and Decontamination p01tion as well. We would greatly

appreciate allowing our past evaluations to speak for themselves and be proof that we are extremely prepared for Any Event at SSES.

We would also stress that we participate in Practice Exercises every year regardless if there is a Federal Exercise Evaluation. We also would like it known that preparing for these Evaluations is very time consuming. Since we have spent the last six months dealing with the COVID-19 Pandemic we have not been able to commit the time needed to prepare for the Federal Exercise. The numerous "behind the scenes" activities/preparations require ample time/dedication to ensme that the Exercise is a Success.

We appreciate yoU1' willingness to work with us as our Partner/Team Member to find common ground and a reasonable solution that will benefit everyone involved making health and safety the top priority.

Thank you for your assistance with this extremely important matter.

Respectfully,

.~yj{*Wy Jennifer L Long EMA Director Columbia County

Lacka~1 Commi.Bsloners Jeny Notarianni

  • Debj Domenick

Dear Director Padfield,

Richard P. Barbolish Emergency Management Agency County Public Safety Center 30 Valley View Drive Jessup, PA 18434-1154 Phone (570)307-7304 fax (570) 307-7324 barbolishr@lackawannacounty.org As Lackawanna continues to respond to the COVID-19 situation, we have momentarily shifted our focus to significant issues regarding the upcoming Federal Evaluation Exercise for the Susquehanna Steam Electric Station (SSES) on October 20, 2020. First and foremost, Lackawanna County is always ready to respond to a real world incident at SSES but, participation in the fall exercise with the current COVID-19 mitigation measures and anticipation of continuing precautions would put extra strain on staff and volunteers and potentially expose all to the virus.

The Lackawanna County Public Safety Center, houses the 9-1-1 Communications Center and the Emergency Operations Center. Our facility is currently closed to all visitors except 9-1-1 and EMA regular staff and will be for the predictable future. To facilitate the EOC portion and evaluation of the exercise would create a situation whereby the full EOC staff would not be able to participate while observing social distancing guidelines. Training at our facility at this time and for some time into the future will be next to impossible.

Note that our EOC is also backup to the SSES EOC in event that it is necessary for them to evacuate.

Our other concern is the conducting of the Mon/Decon/Mass Care portion of the exercise at a school building/property. Hopefully school will be normally resuming with new guidelines and rules for their campus, students and staff. Use of the facility may not be granted without assurance that the property be sanitized after our use adding an additional expense to the process and a delay in returning the school to normal use. Health and safety of our mostly volunteer Mon/Decon team and students may be compromised and will expose the County to potential liability unnecessarily.

During past exercises, Lackawanna County has shown that we are most capable of supporting the activities in relation toSSES. We ask that you take our concerns to the Nuclear Regulatory Commission and the Federal Emergency Management Agency for consideration of a new date for 2021 or credit for our past performance and reschedule for 2022.

Sincerely,

~//?~----

Richard P. Barbolish, Coordinator

LUZERNE COUNTY Emel'gency Management Agency Lucille Morgan, Director Date:

June 91h, 2020 PENNSYLVANIA E S T AD L I S H ED 1 7 8 6 To:

David R Padfield, Director, Pennsylvania Emergency Management Agency From: Lucy Morgan, Director, Luzerne County Emergency Management Agency Re:

2020 Federal Evaluation of the Susquehanna Steam Electric Station

Dear Director Padfield:

LUZERNE COUNTY COUNTY MANAGER C. DAVID PEDRI, ESQUIRE During the last several months, our organizations have endured a disaster the likes most of us have never seen. The unprecedented obstacles alone have stressed us to the limit. As we are nearing our annual practice drill for the biennial federally evaluated drill in October, we at Luzerne County have a few very significant issues and concerns we feel would greatly affect our welfare, and the overall outcome, of the exercise. Having said this, I feel it would not be in the best interest for us and for our municipalities to participate in this year's SSES exercises for the reasons stated here.

First, several municipalities have related multiple concerns to our staff in direct relation to their own EOC activities. EMC's are stating that their EOC's are too small to continue social distancing practices or that they cannot effectively staff an EOC due to having elderly participants worried of exposure, should they attend.

Another concern is whether they will have enough time to receive proper training for those participants willing to replace EOC staff on short notice, while maintaining social distancing and following the state's "Yellow Phase" guidelines. These restrictions and precautions set by the Governor would greatly hinder the municipality's effectiveness to complete all tasks required of them in their own EOC's.

Second, our county building is currently locked down with no scheduled date for the lifting of this restriction.

Once lifted, we would still be very limited to the number of staff allowable due the Governors restrictions and the concerns of several participants. The liability alone of someone contracting the virus while working as an EOC staff member is greatly concerning for the county. The logistical aspect of questioning and screening each participant is just another responsibility, taken on by both the county and each municipality, and added onto the responsibility of continuing our response efforts to COVID-19.

Finally, we have not been able to adequately spend the amount of time needed to properly prepare for the federal evaluated drill. To date we would have had multiple tasks and numerous trainings completed had we not have had to respond to and mitigate the current disaster. The recovery phase, yet to be entered, and the potential of us having to be greatly involved in the vaccine process should this occur, could very well begin during the time of these exercises. Real world events always take precedence and we could very well be in this event for many more months.

EMA Building

  • 185 Water Street
  • Wilkes-Barre, PA, 18711 voice 570.820.4400 fax 570.820.4456 tdd 570.825.1860

Sir, Luzerne County EMA has always been a valued partner with both SSES and Columbia County. Our past successes regarding these exercises is positive proof of our dedication and devotion to the welfare of all whom reside within and around the 1 0-mile EPZ. Our EOC staff, comprised of mostly volunteers from our community, takes pride in their job performance, giving 100 percent every time they fill our seats in real-time events as well as our exercises and drills. Having said this, and due to the above mentioned concerns and the general welfare of our municipality responders and county EOC staff, we at Luzerne County EMA feel would struggle to reach our 100 percent goal. Therefore, we respectfully requests that you please allow our past evaluations be counted as proof of our thorough preparedness to respond to any event that may occur at SSES.

As always, we greatly appreciate all you folks have done for us. Your willingness to work with us through real world events and training opportunities speaks volumes of your dedication to the overall emergency management mission and to the citizens of this fine state.

Thank you for your consideration in this most important issue and matter.

Respectfully,

June 15, 2020 LYCOMING COUNTY DEPARTMENT OF PUBLIC SAFETY 542 County Farm R.oad, Suite 101 Montoursville, Pa 17754~9621 (570) 433-4461 (570) 329-4061 Fax: (570) 433-4435 www.lyco.org Jeffrey L. Hutchins Director Mr. David R. P~dfield, Director Petmsylvania Emergency Management Agency 1310 Elmerton A venue Harrisburg, P A 1 711 0

Dear Director Padfield,

Belh A. Baylor, Manager 9-1-1 Communications Kelle. B. Robinson, Manager Emergency 1'-lanagementAgency Wendy S. Hastings, Program Manager Lycoming, Tioga, & Sullivan Emergency Medical Services Darla G. Krotzer ChiifEmergency Preparedness Planner Lycoming County has substantial concerns related to the upcoming Federal Evaluation Exercise for the Susquehmma Steam Electric Station (SSES) on October 20, 2020 due to the ongoing response to COVID-19.

We are more than ready to respond should a teal time incident take place at SSES. However, involvement in an exercise with the current COVID-19 guidelines and the expected safety measqres for the Fall would put an undue burden on our staff and volunteers.

Our building, which includes the 911 Center, LTS EMS Council, and Emergency Operations Center (EOC),

is operating with restricted access with appointments only for the health and safety of our staff. We would have to move to out back up EOC in otder to complete the EOC evaluation portion of the exercise and to be better socially distanced. However, this County owned building is also operating with restricted access.

The more notable concem is our use of a local Middle School for the Monitoring & Decontamination and Mass Care. The schools are actively applying new COVID-19 health and safety guidelines for the students>

facility, and staff. The Couuty and School District would also need to have procedures prepared for the cleaning and sanitizing before and ~;tfte1' the exercise, The staffing portion of the evaluation would be limited as well due to the majority of our volunteers being in the high-risk age range, Past performance in these exercises has shown, Lycoming County and all the counties that support the Susquehmma SteamElectric Station (SSES) are prepared to respond to an incident We askfor your assistance in making our case to the Nuclear Regulatory Commission and the Federal. Emergency Management Agency to allow for cancellation of this exercise cycle or allowance for the next exercise in 2022 due to these mitigating circumstances in the COVID-19 response and recovery.

Respectfully,

/--\\ ?,

I /;) t1 II

  • '/)

( - -) I r~'(,t.kr_ [), f\\ Ui '--.

  • -~

Kelle B. Robinson Emergency Management Manager

Samuel Schiccatano Commissioner* Chairman samuel.sch icc a tano@ no rrycopa.net Joseph M. Klebon Commissioner *Vice Chairman joseph.klebon@norrycopa.net Kymberley Be$t Commissioner kymberley.best@norrycopa.net June 10, 2020 COUNTY OF NORTHUM DEPARTMENT OF PUBLIC SAFETY 911 Greenough Street. Suite 2, Sunbury PA 17801 Ph. 570.988.4217 I bx. 570.988.4375 I www.norrhuwberlantlco.org Mr. David R. Padfield, Director Pennsylvania Emergency Management Agency

Dear Director Padfield,

Stephen Jeffery Director/OEM Stephen.jeffery@norrycopa.net Rus>ell Fellman 911 Coordinator Russell.fellman@ norrycopa.net Jason Zimmerman Operation & Training Jason.zlmm*erman@norrycopa.net As we continue to respond to the COVID-19 situation, we have significant concerns regarding the upcoming Federal Evaluation Exercise for the Susquehanna Steam Electric Station (SSES) on October 20, 2020. Northumberland County continues to be prepared to respond to an actual incident at SSES.

Participation in an exercise with the current COVID-19 mitigation measures and anticipation of continuing precautions in the Fall would put an undue burden on staff and volunteers as to where the epidemic is expected to continue.

Our building, which includes both the 911 Communications Center and Emergency Operations Center, continues operations with restricted access for the health and safety of staff. In order to accomplish the Emergency Operations Center evaluation, we would have to explore the feasibility of activating with the full staffing compliment for an exercise following the social distancing guidelines as well as all others.

The more significant concern is the utilization of the Shamokin Area High School building for Monitoring and Decontamination and Mass Care, while schools are actively implementing the new COVID-19 health and safety guidelines for students, facility, and staff. The Shamokin Area School Board would also need to approve our use of the building and both Northumberland County and the Shamokin Area School District would need to ensure procedures are in-place to clean and sanitize before and after the exercise. Our staffing of these demonstrations would also be limited to effectively protect the health and safety of emergency responders.

Past performance in these exercises has shown, Northumberland County and all the counties that support the Susquehanna Steam Electric Station (SSES) are prepared to respond to an incident. We ask for your assistance in making our case to the Nuclear Regulatory Commission and the Federal Emergency Management Agency to allow for cancellation of this exercise cycle and allowance for the next exercise in 2022 due to these mitigating circumstances in the COVID-19 response and recovery.

Emergency Management Agency

~Schuylkill County County of Schuylkill John M. Matz Coordinator June 10, 2020 Mr. David R. Padfield, Director Office of Public Safety Building 435 North Centre Street Pottsville, PA 17901 Telephone 570*622*3739 Pennsylvania Emergency Management Agency 1310 Elmerton Avenue Harrisburg, PA 17110

Dear Director Padfield,

Commissioners George F. Halcovage, Jr

  • Chairman Barron L. Hetherington Gary J. Hess As we continue to respond to the COVID-19 situation, we have significant concerns regarding the upcoming Federal Evaluation Exercise for the Susquehanna Steam Electric Station (SSES) on October 20, 2020. Schuylkill County continues to be prepared to respond to an actual incident at SSES. Participation in an exercise with the current COVID-19 mitigation measures and anticipation of continuing precautions in the Fall would put an undue burden on staff and volunteers.

Our building, which includes both the 911 Communications Center and Emergency Operations Center, continues operations with restricted access for the health and safety of staff. In order to accomplish the Emergency Operations Center evaluation, we would have to explore the feasibility of activating with the full staffing compliment for an exercise following the social distancing guidelines.

The more significant concern is the utilization of a school building for Monitoring and Decontamination and Mass Care, while schools are actively implementing the new COVID-19 health and safety guidelines for students, facility, and staff. The School Board would also need to approve our use of the building and both the County and School District would need to ensure procedures are in-place to clean and sanitize before and after the exercise. Our staffing of these demonstrations would also be limited to effectively protect the health and safety of emergency responders.

Past performance in these exercises has shown, Schuylkill County and all the counties that support the Susquehanna Steam Electric Station (SSES) are prepared to respond to an incident. We ask for your assistance in making our case to the Nuclear Regulatory Commission and the Federal Emergency Management Agency to allow for cancellation of this exercise cycle and allowance for the next exercise in 2022 due to these mitigating circumstances in the COVID-19 response and recovery.

Sincerely, ~

John M. Matz, Coordinator Preparedness

Response

Recovery Mitigation

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