ML20272A311

Memo E-mail to File - Summary of August 19, 2020, Meeting with Dominion to Discuss Proposed Exemption Request Biennial Emergency Preparedness Exercise Date Change

ML20272A311
Person / Time
Site:	Millstone
Issue date:	09/28/2020
From:	Richard Guzman NRC/NRR/DORL/LPL1
To:	James Danna NRC/NRR/DORL/LPL1
Guzman R
References
EPID L-2020-LRM-0073
Download: ML20272A311 (4)

Text

From: Guzman,Richard To: james.danna@nrc.gov Cc: Guzman,Richard

Subject:

Memo E-mail to File - Summary of August 19, 2020, Meeting with Dominion to Discuss Proposed Exemption Request re: Millstone Biennial Emergency Preparedness Exercise Date Change (EPID L-2020-LRM-0073)

Date: Monday, September 28, 2020 11:17:23 PM

Jim, For your information, shown below is a summary of the August 19, 2020, Category 1 public meeting with Dominion Energy Nuclear Connecticut, Inc. to discuss the licensees subject proposed exemption request for Millstone Power Station, Unit Nos. 1, 2, and 3. This e-mail will be added to ADAMS as an official agency record and Listservd. Please contact me if you have any questions regarding this meeting.

Thanks, Rich Guzman Sr. PM, Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Office: O-9C7 l Phone: (301) 415-1030 Richard.Guzman@nrc.gov CATEGORY 1 PUBLIC MEETING WITH DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC),

TO DISCUSS PROPOSED ONE-TIME EXEMPTION REQUEST TO POSTPONE THE BIENNIAL EMERGENCY PREPAREDNESS EXERCISE FOR MILLSTONE POWER STATION, UNIT NOS. 1, 2, AND 3 PRE-APPLICATION MEETING MEETING

SUMMARY

AUGUST 19, 2020 DOCKET NOS. 50-245, 50-336, AND 50-423 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Dominion Energy Nuclear Connecticut, Inc. (DENC, the licensee) held a public meeting on August 19, 2020, to discuss the licensees planned one-time exemption request to postpone the biennial emergency preparedness (EP) exercise for Millstone Power Station, Unit Nos. 1, 2, and 3 (MPS), until June 2021, based on limitations of availability of resources due to the COVID-19 public health emergency. The licensees meeting slides are available in Agencywide Documents Access and Management System (ADAMS) at Accession No. ML20226A411. The licensees presentation is summarized as follows:

Overview and Purpose of Proposed Exemption Request The licensee provided an overview of their proposed exemption request. Specifically, due

to COVID-19 restraints and response activities, DENC will be requesting a one-time schedular exemption for the MPS Biennial EP Exercise originally scheduled for June 23, 2020. The last MPS Biennial EP exercise that was federally evaluated by the NRC and Federal Emergency Management Agency (FEMA) was conducted on March 20, 2018.

Basis and Reason for Request The licensee stated that the applicable requirements in 10 CFR 50 Appendix E IV.F.2.b and IV.F.2.c require the MPS Biennial EP Exercise to be performed in calendar year 2020; however, due to the ongoing response to the COVID-19 public health emergency (PHE) declared on January 31, 2020, MPS and the associated state emergency response organizations are precluded from conducting a full participation exercise in June 2020.

Specifically, the licensee indicated that the resources for exercise preparation and participation in simulated response would compete with resources that are devoted to the PHE. Moreover, the gathering of a large group of people for a simulated emergency would place unnecessary risk on all participants. Therefore, an exemption request is needed for DENC and state responders to reduce the exposure risk to responders and essential workers and to adhere to the recommended guidelines from the Center for Disease Control Prevention (CDC).

Exercise Scheduling Considerations The licensee stated that a good faith effort was made to reschedule and conduct the exercise in 2020, but the COVID-19 PHE precludes MPS and the applicable states from participating until 2021. In addition to the ongoing COVID-19 concerns, DENC is also considering other schedule priorities such as the upcoming fall 2020 Unit 3 refueling outage, and previously scheduled audits, inspections, and evaluations with the NRC and Institute of Nuclear Power Operations. The states of Connecticut, Rhode Island, and New York as well as municipal stakeholders are engaged and have proposed the date of June 8, 2021 for conducting a full participation exercise.

Justification of Proposed Exemption The licensee stated that the exemption request will:

1. be submitted in accordance with 10 CFR 50.12, Specific Exemptions;

2. address the guidance criteria contained in Regulatory Issue Summary (RIS) 2006-03, Guidance on Requesting an Exemption from Biennial Emergency Preparedness Exercise Requirements;

3. include lists of numerous inter-facility drills and exercises integrating on-site and off-site responders; extensive on-site and off-site training; tabletop sessions for local emergency managers; and FEMA-evaluated drills and exercise;

4. validate that DENC has regularly exercised its emergency response strategies and personnel in coordination with offsite authorities.

The licensee indicated that the proposed June 2021 exercise date would be 39 months from the last biennial exercise; this will exceed the 35-month window per Regulatory Information Summary (RIS) 2006-03. The licensee intends to provide the following justifications in their exemption request:

1. The last off-year plume/post-plume phase exercise was conducted in October 2019 with extensive participation by the states;

2. Sufficient training, drills, and exercises have been conducted to ensure that exceeding the 35-month guidance in RIS 2006-03 by four months does not pose a threat to emergency response to protect public health and safety;

3. The remaining guidance provided in RIS 2006-03 will be satisfied;

4. The inspections and evaluations conducted by NRC and FEMA since the last MPS Biennial Exercise in March 2018 MPS did not identify any findings of significance or any programmatic issues.

Therefore, the licensee states the exemption request will demonstrate that the rescheduling of the MPS Biennial EP Exercise will support COVID-19 mitigation and prevention activities and will not present an undue risk to the public health and safety.

Schedule The licensee stated their planned submittal is on track and projected for submission by the end of August 2020. DENC intends to request NRC approval by December 2020, based on the requirements for biennial EP exercise participation expiring at the end of 2020.

No decisions were made regarding the acceptability of the licensees proposed submittal.

Two representatives from the state of Connecticut Department of Energy and Environmental Protection attended by teleconference. One member representing the Federal Emergency Management Agency was also on the call. There were no members of the public in attendance. To date, no public meeting feedback forms have been submitted through the NRC public meeting feedback system.

LIST OF ATTENDEES AUGUST 19, 2020, CATEGORY 1 PUBLIC MEETING WITH DOMINION ENERGY NUCLEAR CONNECTICUT, INC. (DENC),

TO DISCUSS PROPOSED ONE-TIME EXEMPTION REQUEST TO POSTPONE THE BIENNIAL EMERGENCY PREPAREDNESS EXERCISE FOR MILLSTONE POWER STATION, UNIT NOS. 1, 2, AND 3 DOCKET NOS. 50-245, 50-336, AND 50-423 ATTENDEE ORGANIZATION Richard Guzman U.S. Nuclear Regulatory Commission (NRC)

Joe Anderson NRC Rick Kinard NRC Don Johnson NRC Bob Kahler NRC Mike Norris NRC Sally Billings NRC Ray Gibson NRC Charles Murray NRC

Fred Bower NRC Josephine Ambrosini NRC Jeff Rady NRC Doug Tifft NRC Neil Sheehan NRC Justin Fuller NRC Eben Allen NRC Jeffry Langan DENC Marylou Calderone DENC James (Ed) Collins DENC Dean Rowe DENC Craig Sly DENC Shayan Sinha DENC Thomas Rigney DENC Helen LaForge Federal Emergency Management Agency Jeffrey Semancik State of Connecticut Department of Energy and Environmental Protection (CT DEEP)

Mike Firsick (CT DEEP)