RBG-48038, Request for One-Time Exemption from 10 CFR 50, Appendix E Biennial Emergency Preparedness Evaluated Offsite Exercise Requirements Due to Covid 19 Pandemic

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

ML20280A734
Person / Time
Site:	River Bend
Issue date:	10/06/2020
From:	Gaston R Entergy Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RBG-48038
Download: ML20280A734 (28)

Text

Entergy Operations, Inc.

1340 Echelon Parkway Jackson, MS 39213 Tel 601-368-5138 Ron Gaston Director, Nuclear Licensing 10 CFR 50.12 10 CFR 50, Appendix E RBG-48038 October 6, 2020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Request for One-Time Exemption from 10 CFR 50, Appendix E Biennial Emergency Preparedness Evaluated Offsite Exercise Requirements due to COVID 19 Pandemic River Bend Station, Unit 1 NRC Docket No. 50-458 Renewed Facility Operating License No. NPF-47 In accordance with 10 CFR 50.12, Specific exemptions, Entergy Operations, Inc. (Entergy) requests an exemption for River Bend Station, (RBS) from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c. Specifically, Entergy requests a one-time exemption to exclude the participation of the offsite response organizations (ORO) in the biennial emergency preparedness exercise for calendar year (CY) 2020.

On January 31, 2020, the U.S. Department of Health and Human Services declared a public health emergency 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, the State of Louisiana has declared a public health emergency and issued restrictions put in place to prevent the spread of the virus as well as measures to reduce the amount of interaction between personnel.

In response to these declarations, and in accordance with the corporate pandemic response plan, Entergy has modified site activities due to isolation protocols (for example, social distancing, group size limitations, self-quarantining, etc.). While the RBS biennial emergency preparedness exercise will be completed, the threat of COVID-19 spread has resulted in the inability to safely conduct the exercise, scheduled for December 1, 2020, with full ORO participation.

RBG-48038 Page 2 of 4 Entergy and the State of Louisiana have been in discussions on the conduct of the CY 2020 offsite biennial exercise. The State of Louisiana agrees with Entergy that requesting an exemption from the offsite biennial exercise in CY 2020 will support the State and Entergy in maintaining protection of their staffs during the current COVID-19 pandemic response.

Conducting the RBS 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, Entergy requests a one-time exemption to exclude the participation of the ORO in the biennial emergency preparedness exercise in CY 2020.

In accordance with the provisions of 10 CFR 50.12, Entergy is requesting exemption from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c, for RBS. Justification for the issuance of an exemption is provided in Enclosure 1 and is based on the guidance provided in the Nuclear Regulatory Commission (NRC) letter to Entergy dated September 2, 2020, "Addendum to U.S. Nuclear Regulatory Commission Planned Actions Related to Emergency Preparedness Biennial Exercise Requirements for Power Reactor Licensees During the Coronavirus Disease 2019 Public Health Emergency," (Accession No. ML20223A152). Letters from the state of Louisiana and the affected parishes are provided as attachments to the enclosure.

The proposed exemption is requested by December 31, 2020. Entergy requests that the duration of the exemption is until December 31, 2022 or until the ORO biennial exercise is performed, whichever occurs first.

A similar request has been made by Entergy for Palisades Nuclear Plant in Reference 5.

No new regulatory commitments are included in this submittal.

If there are any questions or if additional information is needed, please contact Tim Schenk, Manager, Regulatory Assurance, River Bend Station, at (225) 381-4177.

Respectfully, Ron Gaston RWG/chm

RBG-48038 Page 3 of 4

Enclosure:

Request for One-Time Exemption from 10 CFR 50, Appendix E, Offsite Biennial Emergency Preparation Exercise Requirements Attachments to

Enclosure:

1. Letter to Entergy from Louisiana Governors Office of Homeland Security and Emergency Preparedness, dated September 22, 2020

2. Letter to Entergy from Louisiana Department of Environmental Quality, dated October 1, 2020

3. Letter to Entergy from East Baton Rouge Parish - Mayor's Office of Homeland Security and Emergency Preparedness, dated September 10, 2020

4. Letter to Entergy from West Baton Rouge Parish - Office of Homeland Security / Emergency Preparedness, dated September 16, 2020

5. Letter to Entergy from East Feliciana Parish Police Jury - Office of Homeland Security and Emergency Preparedness, dated September 22, 2020

6. Letter to Entergy from West Feliciana Parish Sheriff and Homeland Security, dated September 4, 2020

7. Letter to Entergy from Pointe Coupee Parish - Office of Homeland Security and Emergency Preparedness, dated September 22, 2020

RBG-48038 Page 4 of 4

References:

1) Regulatory Issue Summary 2006-03, "Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirement," (ML053390039), dated February 25, 2006

2) NRC Letter to Entergy, "Planned Actions Related to Emergency Preparedness Biennial Exercise Requirements for All Licensees During the Coronavirus Disease 2019 Public Health Emergency,"

(ML20120A003), dated May 14, 2020

3) NRC Letter to Entergy, "Addendum to U.S. Nuclear Regulatory Commission Planned Actions Related to Emergency Preparedness Biennial Exercise Requirements for Power Reactor Licensees During the Coronavirus Disease 2019 Public Health Emergency,"

(ML20223A152), dated September 2, 2020

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

5) Entergy Letter (PNP) to NRC, "Request for One-Time Exemption from 10 CFR 50, Appendix E Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic," (ML20275A110), dated September 30, 2020 cc: NRC Regional Administrator - Region IV NRC Project Manager - River Bend Station NRC Senior Resident Inspector - River Bend Station Louisiana Department of Environmental Quality Public Utility Commission of Texas

Enclosure RBG-48038 Request for One-Time Exemption from 10 CFR 50, Appendix E, Offsite Biennial Emergency Preparation Exercise Requirements

RBG-48038 Enclosure Page 1 of 7 REQUEST FOR ONE-TIME EXEMPTION FROM 10 CFR 50, APPENDIX E, OFFSITE BIENNIAL EMERGENCY PREPARATION EXERCISE REQUIREMENTS TABLE OF CONTENT 1.0 Summary Description ......................................................................................................... 2 2.0 Background ........................................................................................................................ 2 3.0 Technical Justification of ACCEPTABILITY ....................................................................... 3 4.0 Regulatory Evaluation ........................................................................................................ 4 5.0 Conclusion ......................................................................................................................... 5 6.0 Environmental Consideration ............................................................................................. 6 7.0 Precedence ........................................................................................................................ 6 8.0 References ......................................................................................................................... 6 9.0 Attachments ....................................................................................................................... 7

RBG-48038 Enclosure Page 2 of 7 REQUEST FOR ONE-TIME EXEMPTION FROM 10 CFR 50, APPENDIX E, OFFSITE BIENNIAL EMERGENCY PREPARATION EXERCISE REQUIREMENTS 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.12, Specific exemptions, Entergy Operations, Inc. (Entergy) requests an exemption for the River Bend Station, (RBS) from the requirements of 10 CFR 50, Appendix E, Section IV.F.2.c. Specifically, Entergy 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 protocols (for example, social distancing, group size limitations, self-quarantining, etc.) 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 RBS 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 RBS CY 2020 biennial emergency preparedness exercise with ORO participation is scheduled for December 1, 2020.

Entergy and the Louisiana Department of Environmental Quality (LDEQ) have been in discussions on the conduct of the CY 2020 offsite biennial exercise. During these discussions, the parties expressed concerns with supporting the biennial exercise and maintaining protection of offsite staff during the current COVID-19 pandemic response. With the scheduled exercise date of December 1, 2020, the parties agreed that rescheduling to later in 2020 was not possible due to the limited time available. The parties agreed that it was not feasible to schedule the exercise in CY 2021 due to uncertainty of COVID-19 isolation actions, the needed response to the pandemic, outage duration uncertainty, and conflicts with other NRC inspections. As such, Entergy has made a reasonable effort to reschedule the exercise at RBS during CY 2020 but has been unsuccessful.

The LDEQ agrees with Entergy that requesting an exemption from the offsite biennial exercise in CY 2020 will support the State and Entergy in maintaining protection of their staffs during the current COVID-19 pandemic response. Based on these discussions, Entergy is submitting an exemption request to exempt the offsite organization from participation in a CY 2020 biennial exercise. This allows LDEQ and the offsite response organizations to continue responding to

RBG-48038 Enclosure Page 3 of 7 the current global health crisis and focus on protecting responders as well as the health and safety of the public.

Entergy attended a Tri-Utility Meeting via teleconference with the Federal Emergency Management Agency (FEMA) and LDEQ on September 3, 2020. This call was used to discuss the need to seek an exemption and the activities planned for the successful completion of the Graded Exercise regardless of it being completed in CY 2020. The LDEQ agrees with Entergy that requesting an exemption from the offsite biennial exercise in CY 2020 will support the State and Entergy in maintaining protection of their staffs during the current COVID-19 pandemic response.

The OROs responsible for supporting the RBS Emergency Plan have indicated in the attached letters that they will not be impacted in a manner that would adversely affect their ability to support emergency response activities in the event of an actual nuclear power plant radiological emergency.

3.0 TECHNICAL JUSTIFICATION OF ACCEPTABILITY The U.S. Centers for Disease Control (CDC) has issued recommendations advising social distancing to prevent the spread of the COVID-19 Virus. Entergy 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 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 RBS Emergency Plan.

The last RBS offsite biennial emergency preparedness exercise was conducted June 27, 2018.

This exercise successfully demonstrated the capability of the OROs to respond to an event at the site.

Entergy has conducted drills, exercises, and other training activities with respect to its emergency response strategies, in coordination with offsite authorities since the last biennial exercise. The following lists the drills, exercises, and other training opportunities that have occurred since June 27, 2018.

July 26, 2018 - Tabletop Drill August 21, 2018 - Full-Scale Drill September 11, 2018 - Tabletop Drill September 18, 2018 - Tabletop Drill September 25, 2018 - Full-Scale Drill February 21, 2019 - Tabletop Drill March 12, 2019 - Full-Scale Drill September 18, 2019 - Tabletop Drill September 19, 2019 - Tabletop Drill October 8, 2019 - Full-Scale Drill October 31, 2019 - Tabletop Drill November 12, 2019 - Full-Scale Drill February 27, 2020 - Tabletop Drill

RBG-48038 Enclosure Page 4 of 7 March 10, 2020 - Full-Scale Drill In addition to the drills identified above, RBS also conducted Medical Drills with its health care partners in Baton Rouge, LA (Our Lady of the Lake Regional Medical Center) and in St.

Francisville, LA (West Feliciana Parish Hospital), in 2018 and 2019. Staffing drills on a quarterly basis, Health Physics , and Sampling Drills as well as fire drills and focused area drills in the RBS Emergency Operations Facility (EOF) have been performed during this time frame as well.

These elements are driven by RBS procedural guidance to ensure RBS and Entergy continue to demonstrate completion of essential elements of the RBS Emergency Plan and applicable regulatory requirements. In addition to the required drills and exercises, RBS continues to seek efforts to build proficiency.

With the other drills and demonstration opportunities discussed above, Entergy has partnered with local agencies to conduct training elements on access controls and radiological concerns at the power plant for workers. These training opportunities largely extend to the public through the LDEQ via the Louisiana Peacetime Radiological Response Plan which is implemented through the LDEQ.

Entergy understands that future biennial exercises will continue to be held in even years. 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 occurs.

4.0 REGULATORY EVALUATION

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.

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

1. This exemption is authorized by law.

The biennial emergency preparedness exercise 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.

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 offsite response organization (ORO) personnel are familiar with their duties and to test the adequacy of the Emergency Plan.

RBG-48038 Enclosure Page 5 of 7 Since the last biennial exercise Entergy has periodically engaged the ORO at RBS in various EP program elements, with no performance issues. Entergy plans to continue to periodically engage the ORO at RBS in various program elements for the remainder of 2020 and throughout 2021. Entergy considers the performance of the ORO to be at an acceptable level to satisfy the underlying purpose of the rule.

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.

Exclusion of the ORO from the December 1, 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 granting 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.

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 addition, coordination of activities with current health restrictions, such as social distancing, is increasingly difficult. Based on discussion with ORO representatives, Entergy has concluded that a good faith effort has been made to comply with the regulation.

5.0 CONCLUSION

As demonstrated above, Entergy 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 emergency preparedness exercise requirements of 10 CFR 50, Appendix E, Section IV.F.2.c is required during the 2020 COVID-19 Pandemic.

RBG-48038 Enclosure Page 6 of 7

6.0 ENVIRONMENTAL CONSIDERATION

Entergy is requesting an exemption from certain requirements of 10 CFR 50, Appendix E, for RBS. Specifically, Entergy 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 calendar year 2020. The following information is provided in support of an environmental assessment and finding of no significant impact for the proposed exemption.

Entergy has determined that the exemption involves 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; and there is no significant increase in the potential for, or consequences from, a radiological accident. 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.

7.0 PRECEDENCE A similar request has been made by Entergy for Palisades Nuclear Plant in Reference 5.

8.0 REFERENCES

1) Regulatory Issue Summary 2006-03, "Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirement,", (ML053390039),

dated February 25, 2006

2) NRC Letter to Entergy, "Planned Actions Related to Emergency Preparedness Biennial Exercise Requirements for All Licensees During the Coronavirus Disease 2019 Public Health Emergency," (ML20120A003), dated May 14, 2020

3) NRC Letter to Entergy, "Addendum to U.S. Nuclear Regulatory Commission Planned Actions Related to Emergency Preparedness Biennial Exercise Requirements for Power Reactor Licensees During the Coronavirus Disease 2019 Public Health Emergency,"

(ML20223A152), dated September 2, 2020

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

5) Entergy Letter (PNP) to NRC, "Request for One-Time Exemption from 10 CFR 50, Appendix E Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic," (ML20275A110), dated September 30, 2020

RBG-48038 Enclosure Page 7 of 7 9.0 ATTACHMENTS

1. Letter to Entergy from Louisiana Governors Office of Homeland Security and Emergency Preparedness, dated September 22, 2020

2. Letter to Entergy from Louisiana Department of Environmental Quality, dated October 1, 2020

3. Letter to Entergy from East Baton Rouge Parish - Mayor's Office of Homeland Security and Emergency Preparedness, dated September 10, 2020

4. Letter to Entergy from West Baton Rouge Parish - Office of Homeland Security /

Emergency Preparedness, dated September 16, 2020

5. Letter to Entergy from East Feliciana Parish Police Jury - Office of Homeland Security and Emergency Preparedness, dated September 22, 2020

6. Letter to Entergy from West Feliciana Parish Sheriff and Homeland Security, dated September 4, 2020

7. Letter to Entergy from Pointe Coupee Parish - Office of Homeland Security and Emergency Preparedness, dated September 22, 2020

Enclosure, Attachment 1 RBG-48038 Letter to Entergy from Louisiana Governors Office of Homeland Security and Emergency Preparedness, dated September 22, 2020 (1 Page to Follow)

TO: Tim Gates, Manager, Emergency Planning, River Bend Station FROM: Todd Hollenbaugh, Radiological Program Manager DATE: 09/22/2020 RE: Offsite Response Exemption In response to River Bend Stations request for exemption from the conduct of the calendar year (CY) 2020 offsite biennial exercise required by Section IV.F.2.c of Appendix E to 10 CFR Part 50, the Governors Office of Homeland Security and Emergency Preparedness issues the following:

1. GOHSEP is in agreement with the licensees exemption request and we are committed to maintaining our radiological emergency plans; and

2. GOHSEP will not be impacted in a manner that would adversely affect our ability to maintain response capability to support emergency response activities to an actual nuclear power plant radiological emergency.

Please contact me at (225) 922-2449 or todd.hollenbaugh@la.gov for further questions.

Sincerely, Todd Hollenbaugh Radiological Program Manager

Enclosure, Attachment 2 RBG-48038 Letter to Entergy from Louisiana Department of Environmental Quality, dated October 1, 2020 (1 Page to Follow)

Enclosure, Attachment 3 RBG-48038 Letter to Entergy from East Baton Rouge Parish - Mayor's Office of Homeland Security and Emergency Preparedness, dated September 10, 2020 (2 Pages to Follow)

SHARON WESTON BROOME CLAY RIVES MAYOR-PRESIDENT DIRECTOR East Baton Rouge Parish Mayors Office of Homeland Security And Emergency Preparedness September 10, 2020 Mr. Tim Gates Emergency Planning Manager ENTERGY Operations, Inc.

5485 U.S. Hwy 61 St. Francisville, La 70775

Dear Mr. Gates,

The Mayors Office of Homeland Security and Emergency Preparedness (MOHSEP), on behalf of East Baton Rouge Parish, respectfully request and supports the postponement of the 2020 Biennial Graded Exercise of River Bend Station, or exemption with the assessment schedule resuming in 2022. Like many other local parishes, counties, municipalities and businesses throughout our Nation, East Baton Rouge Parish is continuing to respond to and recover from many ongoing incidents over the past eight months. While coordinating the local public health emergency related to the COVID-19 Global Pandemic, numerous severe weather events, tropical systems and providing intrastate mutual aid to neighboring parishes responding to and recovering from the aftermath of Hurricane Laura, I feel that this request to postpone the above referenced exercise merits strong consideration with recognition of the following concerns and justification.

The East Baton Rouge Parish Emergency Operations Center (EOC), under the oversight of MOHSEP, is currently assisting in the coordination of two Presidential Major Disaster Declarations. As MOHSEP and our local first responders and essential personnel remain vigilant and continue to provide a safe and secure community for our residents, our EOC is not able to accommodate all exercise participants without some potential or elevated risks for COVID-19 transmission. Following the most current Centers for Disease Control and Prevention guidance and input from our Parish Medical Director, our present policy regarding the resource allocation of personnel currently working ongoing disasters and emergencies, MOHSEP limits the number of stakeholders in our EOC to maintain social distancing and extensive cleaning and disinfection measures. At this time, given that each position within our EOC is directly linked to everyday emergency personnel, the additional risk of potentially exposing staff, for exercise purposes, fails to comply with our personnel prevention practices and ongoing mitigation criteria. The postponing an extensive exercise requiring numerous stakeholders in our EOC does not and will not affect our abilities or existing capabilities to prevent, protect against, mitigate the effects of, respond to and recover from incidents involving any radiological emergency.

After many years of partnering with River Bend Station, Waterford III, the Governors Office of Homeland Security and Emergency Preparedness (GOHSEP), Louisiana Department of Environmental Quality (LDEQ),

FEMA and other local parishes and counties, the staff at MOHSEP and our first responders and key stakeholders whom participate in our planning, training and exercises consistently recognize the critical 3773 Harding Boulevard Baton Rouge, LA 70807 (225) 389-2100 Fax (225) 389-2114 www.brla.gov/MOHSEP www.redstickready.com

nature of radiological emergency testing of procedures. Subsequently, as this year presents unique challenges, the multiple activations of our EOC continuously allows East Baton Rouge Parish to examine and validate capabilities in all preparedness mission areas and I remain confident in my assessment that our local first responders are some of the best in the World.

Rest assured that East Baton Rouge Parish, MOHSEP and our first responders and key stakeholders, as proven in real world disasters, remain proficient and available to respond on a moments notice and shall continue to be proactive to fulfill their duties, responsibilities in support of our mission. As such, MOHSEP continues to maintain interoperable communications, radiological emergency plans, logistical resources and the necessary inventory to deliver support to River Bend Nuclear Station, GOHSEP, LDEQ and other parishes or counties in the event of any radiological emergency.

Based on the above, I maintain that it is in the best interest of all participants that the 2020 Biennial Graded Exercise of River Bend Station be delayed or suspended. Should you have any questions or need additional information, please feel free to contact me directly at 389-2100.

Very Respectfully, Clay Rives, MPA, LEM-P Director 3773 Harding Boulevard Baton Rouge, LA 70807 (225) 389-2100 Fax (225) 389-2114 www.brla.gov/MOHSEP www.redstickready.com

Enclosure, Attachment 4 RBG-48038 Letter to Entergy from West Baton Rouge Parish - Office of Homeland Security /

Emergency Preparedness, dated September 16, 2020 (1 Page to Follow)

I~\ o~ =~ West Baton Rouge Parish O ffice of H omeland Security/ Emergency Preparedness Emergency Preparedness Director Anthony "Dea no" M oran and 9-1*1 September 16, 2020 TO WHOM IT MAY CONCERN Due to COVID 19 our office is still on lockdown with no visitors allowed. We feel that our staff is capable, and seasoned, if the need arises to activate the EOC and bring everyone in.

Due to the cost of this drill, with no people, we are opting out of doing the drill for the remainder of this year. We are in agreement with River Bend Station's exemption request to not perform the Biennial Exercise in 2020. Our office is under no travel advisory by the Parish President and will not be able to send a PIO to the JIC. We maintain the capability to respond to an actual radiological emergency at River Bend Station. We are committed to maintaining our radiological emergency plan and we apologize for any inconvenience this may cause.

Sincerely

~~d~u~o/

EOC Coordinator 24 13 Ernest Wil son Dr Port Allen, LA 70767 Office: (225) 346- 1577 Fax : (225) 346-0284

Enclosure, Attachment 5 RBG-48038 Letter to Entergy from East Feliciana Parish Police Jury - Office of Homeland Security and Emergency Preparedness, dated September 22, 2020 (1 Page to Follow)

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12064 Marston Street I P. 0. Box 427 1Clinton, LA 70722 (225) 683-8577 phone I (225) 683-3100 fax Received by Entergy Louis Kent September 22, 2020 President District 7 To Whom it May Concern, Keith Mills In regards to the upcoming River Bend Nuclear Station evaluated exercise I would like to Vice President address concerns I have with the timing of the event. Due to the ongoing recommended District 4-A COVID-19 precautions I have implemented for East Feliciana Parish during this State of Emergency, I have limited the use of my Emergency Operation Center (EOC) to ONLY LIFE-THREATENING REAL- WORLD EVENTS. Our parish EOC is co-located with our Chrissie O'Quin District I -A Communications/ 911 Dispatch Center in a 500 square foot adjoining room. For this reason, I have since the onset of the pandemic, not allowed meetings, training and/or non- employee Chris Hall admittance into the facility. I have also moved my business office into the Police Jury building Finance Chairman as to not risk exposure to our already under staffed 911 Dispatch Center. We have been in District 1-8 constant contact and communication with our partners at the RBNS to ensure our response Queenola H. Brooks assets are in place and properly functioning during these times. For these reasons I am in District 2 agreement with the licensee's exemption request and we at the East Feliciana Parish Office of Homeland Security and Emergency Preparedness are committed to maintaining our Jason McCray radiological emergency response plans.

Public Works &

Equipment Chairman District 3 Also, due to our limited paid and volunteer staffing for our EOC and their dual roles as key members of our local first response agencies, school administrators, and parish officials it Richard Oliveaux would be a strain on them as well as their individual departments to pull them from these Buildings & Properties Chairman roles for the amount of time needed to facilitate the needs of this full-scale exercise. This in District 4-B no means has impacted us in a manner that would adversely affect our ability to maintain response capability to support emergency response activities to actual nuclear power plant Michael Cheatham Personnel C hairman radiological emergencies.

District 5 It is for the above-mentioned concerns that I would like to postpone the upcoming full-scale exercise until a time that we, as a parish, can be better positioned to demonstrate our Kyle Fleniken abilities to perform to our true potential for a graded exercise.

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District 6 Jody Moreau

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Homeland Security Director Director Parish Manager East Feliciana Parish efe oc@ourlook.com Office of Homeland Security and Emergency Preparedness Yamesha Harris Parish Secretary yames ha. efparish

@gmail.com

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Enclosure, Attachment 6 RBG-48038 Letter to Entergy from West Feliciana Parish Sheriff and Homeland Security, dated September 4, 2020 (1 Page to Follow)

WEST FELICIANA PARISH SHERIFF'S OFFICE

~============-- ---------------_-

BRIAN L. SPILLMAN, SHERIFF 8c EX-OFFICIO TAX COLLECTOR September 4, 2020 Tim Gates Manager-Emergency Planning Entergy- River Bend Station St. Francisville, La. 70775

Dear Tim,

In response to your request, please see the following related to conducting an exercise while under the current COVID19 conditions:

• The West Feliciana Parish Office of Ho~eland Security is in agreement with the licensee's exemption request and that we are committed to maintaining their radiological emergency plans; and

• We are not impacted in a manner that would adversely affect our ability to maintain response capability to support emergency response activities to actual nuclear power plant radiological emergencies.

Please contact me if you have any questions or comments.

Sincerely,

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Brian L. Spillman Sheriff and Homeland Security Director PROTECTING WITH COURAGE, SERVING WITH COMPASSION 4785 Prosperity Street I P.0. Box 1844 I St. Francisville, Louisiana 70775 I Phone 225-635-324 l I Fax 225-635-6947

Enclosure, Attachment 7 RBG-48038 Letter to Entergy from Pointe Coupee Parish - Office of Homeland Security and Emergency Preparedness, dated September 22, 2020 (2 Pages to Follow)

POINTE COUPEE PARISH GOVERNMENT P.O. Box 290 160 East Main Street New Roads, Louisiana 70760 PHONE: 225-638-9556 FAX: 225-638-5555 MAJOR THIBAUT Parish President September 22, 2020 Mr. Tim Gates Emergency Planning Manager ENTERGY Operations, Inc 5485 U.S. Highway 61 N St. Francisville, LA 70775

Dear Mr. Gates,

The Pointe Coupee Parish Office of Homeland Security and Emergency Preparedness (PCOHSEP), on behalf of Pointe Coupee Parish, respectfully request and supports the postponement of the 2020 Biennial Graded Exercise of River Bend Station, or exemption with the assessment schedule resuming in 2022. Like many other local parishes, counties, municipalities and businesses throughout our Nation, Pointe Coupee Parish is continuing to respond to and recover from many ongoing incidents over the past eight months. While coordinating the local public health emergency related to the COVID-19 Global Pandemic, numerous severe weather events, tropical systems and providing intrastate mutual aid to neighboring parishes responding to and recovering from the aftermath of Hurricane Laura, I feel that this request to postpone the above referenced exercise merits strong consideration with recognition of the following concerns and justification.

The Pointe Coupee Parish Emergency Operations Center (EOC), under the oversight of PCOHSEP, is currently assisting in the coordination of two Presidential Major Disaster Declarations. As PCOHSEP and our local first responders and essential personnel remain vigilant and continue to provide a safe and secure community for our residents, our EOC is not able to accommodate all exercise participants without some potential or elevated risks for COVID-19 transmission. Following the most current Centers for Disease Control and Prevention guidance and input from our Parish Medical partners, our present policy regarding the resource allocation of personnel currently working ongoing disasters and emergencies, PCOHSEP limits the number of stakeholders in our EOC to maintain social distancing and extensive cleaning and disinfection measures. At this time, given that each position within our EOC is directly linked to everyday emergency personnel, the additional risk of potentially exposing staff, for exercise purposes, fails to comply with our personnel prevention practices and ongoing mitigation criteria. The postponing an extensive exercise requiring numerous stakeholders in our EOC does not and will not affect our abilities or existing capabilities to prevent, protect against, mitigate the effects of, respond to and recover from incidents involving any radiological emergency.

Administration Finance Public Works Parks & Recreation 225-638-9556 225-638-9556 225-638-5552 225-638-3870 Equal Oooortunitv F.mnlrwor

After many years of partnering with River Bend Station, the Governor's Office of Homeland Security and Emergency Preparedness (GOHSEP}, Louisiana Department of Environmental Quality (LDEQ}, FEMA and other local parishes and counties, the staff at PCOHSEP and our first responders and key stakeholders whom participate in our planning, training and exercises consistently recognize the critical nature of radiological emergency testing of procedures. Subsequently, as this year presents unique challenges, the multiple activations of our EOC continuously allows Pointe Coupee Parish to examine and validate capabilities in all preparedness mission areas and I remain confident in my assessment that our local first responders are ready to respond to a radiological emergency.

Rest assured that Pointe Coupee Parish, PCOHSEP and our first responders and key stakeholders, as proven in real world disasters, remain proficient and available to respond on a moment's notice and shall continue to be proactive to fulfill their duties, responsibilities in support of our mission. As such, PCOHSEP continues to maintain interoperable communications, radiological emergency plans, logistical resources and the necessary inventory to deliver support to River Bend Nuclear Station, GOHSEP, LDEQ and other parishes or counties in the event of any radiological emergency. Based on the above, I maintain that it is in the best interest of all participants that the 2020 Biennial Graded Exercise of River Bend Station be delayed or suspended. Should you have any questions or need additional information, please feel free to contact me directly at 225-638-9556.

Sincerely, Mark Ward Director