ML20134J003
| ML20134J003 | |
| Person / Time | |
|---|---|
| Issue date: | 05/15/2020 |
| From: | Michael Mahoney Plant Licensing Branch II |
| To: | Markley M Plant Licensing Branch II |
| Mahoney M | |
| Shared Package | |
| ML20141L645 | List: |
| References | |
| Download: ML20134J003 (5) | |
Text
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May 15, 2020 MEMORANDUM TO:
Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:
Michael Mahoney, Project Manager /RA/
Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF APRIL 30, 2020, PUBLIC MEETING WITH NUCLEAR INDUSTRY TO DISCUSS COVID-19 REGULATORY IMPACTS RELATED TO POTENTIAL EMERGENCY PREPAREDNESS ENFORCEMENT GUIDANCE AND EXEMPTION REQUESTS On April 30, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff held a public teleconference with representatives from the nuclear industry, including the Nuclear Energy Institute (NEI), NextEra, and Entergy. The purpose of the meeting was to discuss potential emergency preparedness enforcement guidance and exemption requests resulting from the COVID-19 public health emergency (PHE). The meeting notice can be found in Agencywide Documents Access and Management System (ADAMS) at Accession No. ML20115E640.
At the start of the meeting, the NRC staff stated that the meeting was an information gathering dialogue only and as with all NRC public meetings, no regulatory decisions will be made.
Additionally, the NRC stated that none of the information provided in todays meeting should be taken to be a request by any licensee or a decision by the NRC. The meeting was spilt into two separate parts, with a brief break in between, first to discuss emergency preparedness enforcement guidance and second, discuss potential exemption requests related to emergency preparedness exercise biennial scheduling, resulting from the COVID-19 PHE.
After Shana Helton, Acting Deputy Director, Office of Nuclear Security and Incident Response (NSIR), made opening remarks, the meeting was turned over to NEI, Entergy, and NextEra to make opening remarks.
After opening remarks, Don Johnson, a senior emergency preparedness specialist in the Division of Preparedness and Response in NSIR, discussed potential emergency preparedness enforcement guidance. Items discussed included:
It is expected that licensees will take reasonable actions to prepare for, and limit staff exposure, to COVID-19. Performing certain emergency preparedness activities could affect the spread of the COVID-19 virus and ultimately have a negative impact on the
licensees ability to staff mission-critical positions necessary to successfully implement the emergency plan in an actual event at the site.
Licensee must maintain emergency preparedness effectiveness (i.e., the licensee is maintaining a state of readiness to respond to a radiological event) in order for enforcement discretion to be considered.
The COVID-19 PHE may cause licensees to implement temporary compensatory measures or develop contingency plans, in order to maintain an effective emergency plan, while adhering to COVID-19 PHE requirements. Enforcement discretion may be applied for these temporary adjustments to the emergency plan.
Licensees should maintain documentation that provides a summary of compensatory measures or contingency plans and the analyses on how they would be implemented effectively during the COVID-19 PHE.
The NRC encourages licensees to contact their NRC licensing project manager or appropriate point of contact upon identifying any potential compliance issues (with a regulation or site-specific emergency plan) resulting from the COVID-19 PHE.
During the public question and answer session of the meeting related to the potential emergency preparedness enforcement guidance, NRC staff addressed questions on the following topics:
Would the emergency preparedness enforcement guidance be an attachment to the recently issued enforcement guidance memorandum (EGM)20-002?
Discuss NRC and the Federal Emergency Management Agency (FEMA) coordination regarding changes to emergency preparedness plans.
After a brief break, Don Johnson discussed potential exemption requests related to emergency preparedness biennialexercise scheduling. Items discussed included:
Draft criteria for potential exemption requests related to emergency preparedness biennial exercise scheduling:
o the licensees last biennial exercise date; o the licensees current biennial exercise date; o a statement that the licensee has made a reasonable effort to reschedule the exercise during 2020, but was unsuccessful; o a statement that the licensee will reschedule the conduct of the biennial exercise within 35 months from the month in which the previously evaluated exercise was conducted in 2018; o a statement that, if an exemption is granted to allow the licensee to conduct the 2020 biennial exercise in 2021, future biennial exercises will continue to be held in even years; o a statement that the licensee conducted drills, exercises, and other training activities that exercised its emergency response strategies, in coordination with offsite authorities, since the previous biennial exercise; and o a statement that the rescheduled biennial exercise has been, or will be, coordinated with the applicable offsite response organizations (if offsite response organization participation is required), the applicable NRC Region, and the applicable FEMA Region.
During the public question and answer session of the meeting, related to potential exemption requests related to emergency preparedness exercise scheduling, NRC staff addressed questions on the following topics:
Will Regulatory Issue Summary (RIS) 2006-03, Guidance On Requesting an Exemption From Biennial Emergency Preparedness Exercise Requirements be updated?
How would the planned letter on potential exemption requests related to emergency preparedness exercise scheduling relate to RIS 2006-03?
No regulatory decisions were made in the meeting.
Enclosure:
List of Attendees
List of Attendees April 30, 2020, Public Meeting with the Nuclear Industry Potential Emergency Preparedness Enforcement Guidance and Exemption Requests resulting from the COVID-19 PHE Name Organization Shana Helton NRC/NSIR Don Johnson NRC/NSIR Bob Kahler NRC/NSIR Milt Murray NRC/NSIR Justin Poole NRC/NRR Ed Miller NRC/NRR Scott Burnell NRC/OPA Dan Cronin University of Florida Sandi Duffey Grant County Emer. Management David Crozier Arizona DEMA David Young NEI Steven Kraft Kraft-Contente Patricia Milligan NRC/NSIR John Costello Energy Compliance Consultants Thomas Poindexter Morgan, Lewis, & Bockius Mark Reese Oregon DOE John Pelchat NRC/R-II Sandra Silva Pennsylvania EMA Jamie Dismukes Louisiana DEQ Alonzo McSwain FEMA David Lafleur Pennsylvania DEP Brian Carberry Excel Energy Michael Ginn PGE Eric Epstein Three Mile Island Alert
- via e-mail OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DORL/LPL2-1/BC NAME MMahoney KGoldstein MMarkley DATE 05/14/2020 05/14/2020 05/14/2020 OFFICE NRR/DORL/LPL2-1/PM NAME MMahoney DATE 05/15/2020