ML022420106

FEMA Final Exercise Report - Millstone May 1, 2002 Exercise

ML022420106
Person / Time
Site:	Millstone
Issue date:	07/31/2002
From:	Federal Emergency Management Agency
To:	Office of Nuclear Reactor Regulation
References
Download: ML022420106 (115)

Text

Exercise ReportATO MILLST-ON-E PO.WER STATION

• . Licensee: Dominion Nuclear Connecticut, Inc.

Exercise Date: May1, 2002

• Repr Date:. July 31, 2002

-" "* *".' -4*,-*. . ?' .* :".*Z4" * . . .... ,:. U, FEDERAL EMERGENCY:MANAGEMENT AGENCY REGION I J.W. McCormack Post:Office and Courthouse Boston, Massachusetts 02109

TABLE OF CONTENTS EXECUTIVE

SUMMARY

1. Page EEU....

II. INTRODUCTION ..................................................

Ill. EX ER C ISE O V ER V IE W ......................................................................................................

4 A. Plume Emergency Planning Zone Description ......................................................

4 B. Exercise Participants (M illstone) ..............................................................................

5 C. Exercise Participants (Support Jurisdictions) ............................................................

11 D. Exercise Timeline .............................................

11 IV. EXERCISE EVALUATION AND RESULTS .................................................................

14 A. Summary Results of Exercise Evaluation .......................... ... 14 B. Status of Jurisdiction Evaluations ........................................................................

17

1. STATE OF CONNECTICUT ................................................................... 19 1.1 State Emergency Operations Center ............................................. 19 1.2 Department of Environmental Protection ....................... 22 1.3 Emergency Operations Facility ......................... 22 1.4 State Field Monitoring Teams (A & B) ........................................ 23 1.5 Joint M edia Center ...................................................................... .2 3 1.6 State Department of Public Health ............................................... 25 1.7 OEM Area IV, Colchester ............................. 26 1.8 State Police Access Control Points/Traffic Control Points ....... 27 1.9 Connecticut Department of Transportation ................................... 27 1.10 State Transportation Staging Area ....................... 8

2. ...................................................................... . . . 29 2.1 .................................... ................................ . . . 29 2.2 Hamlet of Fishers Island, NY, EOC ............................................ 30 2.3 City of Groton EOC ................................. 31 2.4 Town ofGroton EOC .................................................................. 32 2.5 Ledyard EO C ................................................................................. 32 2.6 Lym e E O C ................................................................................... 33 2.7 M ontville EO C ............................................................................ 34 2.8 City of New London EOC ............................................................ 35 2.9 O ld Lvm e EO C ............................................................................. 36 2.10 Waterford EOC ............................................ 37 2.11 Schools/Bus Evacuation ............................................................... 37 2.12 Special Populations - Nursing Homes .......................................... 38

3. S..................................... ........................... . . 38 3.1 N ew H aven EO C .......................................................................... 38 3.2 New Haven Host Community Reception Center .......................... 39 3.3 New Haven Congregate Care Facilities ....................................... 41 i

List of Appendices Appendix 1 - Acronym s and A bbreviations ............................................................................ 42 Appendix 2 - Exercise Evaluators and Team Leaders ............................................................ 45 Appendix 3 - Exercise Criteria and Extent-of-Play Agreement ............................................... 48 Appendix 4 - Millstone Plume Exposure Pathway Exercise Scenario ....................................... 109 Appendix 5 - Host Community Exercise Scenario ................................................................. llI List of Tables T able 1 - E xercise T im eline .................................................................................................... 12 Table 2 - Summary Results of Exercise Evaluation ................................................................. 15 ii

I. EXECUTIVE

SUMMARY

On Ma\ 1. 2002, an exercise was conducted in the Plume Exposure Pathway emergency planning zone (EPZ) around the Millstone Power Station by Management Agency (FEMA), Region I. The purpose of thethe Federal Emergency exercise was to assess the level of State and local preparedness in responding to a radiological emergency. The exercise was held in accordance with FEMA's policies and guidance concerning the exercise of State and local radiological emergency response plans (RERP) and procedures.

The most recent exercises at this site were conducted on March

15. 2000 (plume exposure pathway), and October 8-10. 1997 (ingestion exposure pathway).

The qualifying emergency preparedness exercise was conducted in 1982.

FEMA wvishes to acknowledge the efforts of the many individuals who participated in this exercise. The various agencies, organizations, and units of government from the State and local jurisdictions within the States of Connecticut and New York who participated in this exercise are listed in Section 1II.B of this report.

Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities.

Cooperation and teamwork of all the participants were evident during this exercise.

This report contains the final evaluation of the biennial exercise and the evaluation of the following out-of-sequence activities:

"* School demonstrations in the Town of Groton, City of Groton.

and Montville on May 2.

2002:

" Nursing homes including Mariner (East Lyme), Camelot (New London). and Mystic Manor (Groton) on May 2. 2002; New Haven Congregate Care Centers on May 31. 2002; and

" New Haven Emergency Operations Center (EOC) and Host Community Drill on June 1.

2002.

The State and local organizations, except where noted in this report. demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Deficiencies and seven Areas Requiring Corrective Action (ARCA) identified as a result of this exercise. Two of these seven ARCAs were successfully redemonstrated.

I

II. INTRODUCTION On December 7, 1979, the President directed FEMA to assume the lead off-site nuclear planning and response. FEMA's activities responsibility for all are conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350. 351, and 352.

These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island Nuclear Station accident in March 1979.

FEMA Rule 44 CFR 350 establishes the policies and procedures for FEMA's initial and continued approval of State and local government radiological preparedness for commercial nuclear power plants. emergency planning and This approval is contingent, in part, on State and local government participation in joint exercises with licensees.

FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities include the following:

" Taking the lead in off-site emergency planning and in the review and evaluation of RERPs and procedures developed by State and local governments;

" Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by State and local governments;

" Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17, 1993 (FederalRegister, Vol. 58, No. 176. September 14, 1993); and

"* Coordinating the activities of the following Federal agencies with responsibilities in the radiological emergency planning process:

U.S. Department of Commerce U.S. Nuclear Regulatory Commission U.S. Environmental Protection Agency U.S. Department of Energy U.S. Department of Health and Human Services U.S. Department of Transportation U.S. Department of Agriculture U.S. Department of the Interior U.S. Food and Drug Administration Representatives of these agencies serve on the FEMA Region I Regional Assistance Committee (RAC) that is chaired by FEMA.

The State of Connecticut and affected local jurisdictions formally submitted their RERPs for the Millstone Power Station to FEMA Region I in 1982.

Formal approval of the RERP was granted by FEMA in October 1984, under 44 CFR 350.

1

A REP exercise was conducted on May 1. 2002. by FEMA Region I to assess the capabilities of State and local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving the Millstone Power Station. The purpose of this exercise report is to present the exercise results and findings on the performance of the off-site response organizations (ORO) during a

simulated radiological emergency.

The findings presented in this report are based on the evaluations of the Federal evaluator team, with final determinations made by the FEMA Region I RAC Chairperson, and approved by the Regional Director.

The criteria utilized in the FEMA evaluation process are contained in:

" NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980; and

" "Radiological Emergency Preparedness: Exercise Evaluation Methodology," published in the FederalRegister on September 12, 2001, and revised April 25. 2002.

Section III of this report, entitled "Exercise Overview," presents basic information and data relevant to the exercise. This section of the report contains a description of the plume pathway EPZ, a listing of all participating jurisdictions and functional entities that were evaluated, and a tabular presentation of the time of key exercise events and activities.

Section IV of this report, entitled "Exercise Evaluation and Results, presents detailed information on the demonstration of applicable exercise criteria at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format. This section also contains:

(1) descriptions of all Deficiencies and ARCAs assessed during this exercise, recommended corrective actions, and the State and local govermments' schedule of corrective actions for each identified exercise issue, and (2) descriptions of unresolved ARCAs assessed during previous exercises and the status of the OROs' efforts to resolve them.

3

III. EXERCISE OVERVIEW Contained in this section are data and basic information relevant to the May 1, 2002. Plume Exposure Pathway exercise to test the off-site emergency response capabilities in the area surrounding the Millstone Power Station. This section of the exercise report includes a description of the plume pathway EPZ, a listing of all participating jurisdictions and functional entities that were evaluated, and a tabular presentation of the time of key exercise events and activities.

A. Plume Emergency Planning Zone Description The area within 10 miles of the Millstone Power Station is located in the States of Connecticut and New York. The nine Connecticut communities within the Millstone EPZ are entirely located in New London County. The one New York community and the Plum Island Animal Disease Center (PIADC), a United States Department of Agriculture (USDA) research facility, are located in Suffolk County. Millstone Power Station is located on the coast of Connecticut, in the Town of Waterford. and is adjacent to Long Island Sound.

Based on the 2002 census, the total population of the EPZ is 122,100. with the permanent population of those New York portions of the EPZ being approximately 300.

Two parallel Amtrak freight and passenger lines run east-west along the coast through the Connecticut portion of the EPZ. passing across the Utility owner-controlled property. Major highways within the EPZ include Interstate 95, running east-west approximately four miles north of the site. and Interstate 395 running approximately north beginning about four miles north of the site.

Public institutions, aside from schools and churches, within the EPZ include the PIADC, the Niantic Correctional Facility. Lawrence & Memorial (L&M) Hospital, the United States Coast Guard Academy, the United States Naval Submarine Base at New London (Groton), the Naval Undersea Warfare Center. and the Rocky Neck State Park.

The EPZ is divided into six zones for the purpose of emergency response planning and implementation of protective actions.

4

B. Exercise Participants (Millstone) government participated in the The following agencies, organizations, and units of exercise on May 1,2002.

Millstone Power Station Plume Exposure Pathway STATE OF CONNECTICUT (EOC)

STATE EMERGENCY OPERATIONS CENTER Governor's Office Connecticut National Guard Connecticut Office of Emergency Management Connecticut Department of Environmental Protection Division of Radiation Connecticut Department of Environmental Protection, Division of Parks Connecticut Department of Environmental Protection, Connecticut Department of Public Health Connecticut Department of Transportation Connecticut Department of Agriculture Connecticut Department of Consumer Protection Connecticut State Police Connecticut Department of Corrections Connecticut Commission on the Deaf and Hearing Impaired New York State - Emergency Management Office U.S. Coast Guard Dominion Nuclear Connecticut, Inc.

American Red Cross (DEP)

DEPARTMENT OF ENVIRONMENTAL PROTECTION Division of Radiation Connecticut Department of Environmental Protection, Millstone Power Station EMERGENCY OPERATIONS FACILITY (EOF)

Connecticut Department of Environmental Protection 5

STATE FIELD MONITORING TEAMS Connecticut Department of Environmental Protection. Oil Spill Group Connecticut Department of Environmental Protection. Division of Radiation Connecticut Department of Health, Radiological Control Officer Dominion Nuclear Connecticut. Inc.

JOINT MEDIA CENTER Connecticut Office of Emergency Management Connecticut Governor's Press Secretary Connecticut Department of Environmental Protection Connecticut Department of Public Health Connecticut Department of Transportation Connecticut Department of Agriculture Connecticut State Police Dominion Nuclear Connecticut. Inc.

U.S. Coast Guard STATE DEPARTMENT OF PUBLIC HEALTH (DPH) EOC Department of Public Health OFFICE OF EMERGENCY MANAGEMENT (OEM) AREA IV, COLCHESTER Connecticut Office of Emergency Management Local civilian volunteers STATE POLICE ACCESS CONTROL POINTS/TRAFFIC CONTROL POINTS Connecticut State Police, Troops E and F CONNECTICUT DEPARTMENT OF TRANSPORTATION Connecticut State Department of Transportation. District II Office STATE TRANSPORTATION STAGING AREA (STSA)

Connecticut Department of Veterans Affairs, Fire Brigade Connecticut Department of Veterans Affairs. Security Department Connecticut Office of Emergency Management, Area III Office Connecticut Office of Emergency Management, Headquarters Connecticut State Veterans Home and Hospital 6

RISK JURISDICTIONS EAST LYME EOC Connecticut State Police East Lyme Municipal Chief Executive Officer (CEO)

East Lyme Fire Department East Lyme Emergency Management Agency East Lyme Public Works East Lyme Public Health HAMLET OF FISHERS ISLAND, NY. EOC Fishers Island Emergency Management Fishers Island Volunteer Fire Department Town of Southold, New York New York State Police CITY OF GROTON EOC City of Groton Mayor's Office City of Groton Office of Civil Preparedness City of Groton Fire Department City of Groton Police Department City of Groton Utilities Department City of Groton Highway Department City of Groton Parks and Recreation Department City of Groton Water Treatment Plant TOWN OF GROTON EOC Town of Groton Manager Town of Groton Civil Preparedness Director Town of Groton Fire/Emergency Medical Service (EMS)

Town of Groton Police Town of Groton Public Works Town of Groton Health Department Town of Groton Communications Office Town of Groton Board of Education Town of Groton Human Services Town of Groton Parks and Recreation 7

LEDYARD EOC Ledyard Town Council Ledyard Emergency Management Agency Ledyard Fire Department Connecticut State Police Ledyard Police Ledyard 911 Dispatch Office Ledyard Health Department Ledyard School Department Dow Chemical (Observer)

LYMIE EOC Lyme Selectman Lyme Emergency Management Agency Lyme Fire Department Lyme EMS/Ambulance Connecticut State Police Lyme Fire/Police Lyme Department of Public Works Lyme Marina Operators Lyme Parks Department Lyme School Department Connecticut State Department of Environmental Protection MONTVILLE EOC Mayor, as the Town's Chief Executive Officer Town of Montville Fire Marshalls Office (Several individuals)

Montville Police Department (Dispatch)

Mohegan Fire Department (Volunteer assistance)

Superintendent of Schools Montville Radiological Defense Office 8

CITY OF NEW LONDON EOC Chief Executive Officer (New London City Manager)

City of New London Office of Civil Preparedness City of New London Police Department City of New London Fire Department City of New London Communications Office City of New London Department of Heath and Welfare City of New London Superintendent of Schools City of New London Department of Public Works, Building Official City of New London Parks and Recreation Director OLD LYME EOC Old Lyme Selectman Old Lyme Chief Executive Officer Old Lyme Emergency Management Agency Connecticut State Police Old Lyme Police Department Old Lyme Fire Department Old Lyme Department of Public Works Old Lyme Communications Office WATERFORD EOC Waterford First Selectman Waterford Emergency Management Waterford Police Department Waterford 911 Center Waterford Fire Marshal's Office Waterford Department of Health Waterford Department of Public Works Waterford Department of Recreation and Parks Waterford EMAC Special Needs Waterford Board Of Education Waterford Tax Office 9

SCHOOLS/BUS EVACUATION FISHERS ISLAND Fishers Island School TOWN OF GROTON Valley View School MONTVILLE Montville High School SPECIAL POPULATIONS - NURSING HOMES Mariner Nursing Home (East Lyme)

Camelot Nursing Home (New London)

Mystic Manor (Groton) 10

C. Exercise Participants (Support Jurisdictions)

The following agencies. organizations, and units of government participated in the Millstone Power Station Plume Exposure Pathway exercise on June

1. 2002.

NEW HAVEN EOC Mayor of New Haven Chief Administrator Officer New Haven Emergency Management Agency New Haven Police Department New Haven Fire Department New Haven Health Department New Haven Department of Public Works New Haven Board of Education New Haven American Red Cross NEW HAVEN HOST COMMUNITY/RECEPTION CENTER New Haven Fire Department New Haven Municipal Employees New Haven American Red Cross NEW HAVEN CONGREGATE CARE FACILITIES Jackie Robinson Middle School Sheriden Middle School Troup Middle School Wilbur Cross High School James Hillhouse High School Roberto Clemente Middle School D. Exercise Timeline Table 1, on the following page, presents the time at which key events and activities occurred during the Millstone Power Station Plume Exposure Pathway exercise on May 1, 2002. Also included are times that notifications were made to the participating jurisdictions/functional entities.

11

TABLE I. EXERCISE TIMELINE DATE AND SITE: May 1, 2002, Millstone Power Station Time That Notification Was Received or Action was Taken Emergency Time Classification Utility State FOF A IV Media East Fishers City of Town of edyard lyme Center lyrne Island Groton Groton "

Level or Event Declared FOC F0 N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Unusual Event N/A 0808 N/A 0812 0808 0809 0808 0808 0809 0812 0812 Alert 0757 0957 0945 0958 0957 1000 0958 0958 0954 0958 0958 Site Area Emergency 0945 1118 1133 1128 1132 1125 1125 1120 1130 1129 General Emergency 1118 1128 0930 0958 1004 0947 0949 0945 0945 0946 0945 Simulated Radiation Release 0930 0930 Started Simulated Radiation Release Terminated 0843 0915 0920 0855 0857 1015 0839 0840 0843 Facility Declared Operational 0905 Declaration of State of Emergency 1007 - - - (Southold 1036) 1325 1331 1336 1333 1325 1331 1335 1329 1329 Exercise Terminated 1331

- - 1054 - 0940 0940 -

Early Precautionary Actions: 0920 -

Students school school Animals under cover, stored feed, closed parks relocated dismissal dismissal and boat ramps I st Protective Action Decision 1148 Shelter: D, F Evacuate: A, I, C, E 1016 1014 1015 1012 1014 1014 1st Siren Activation 1015 1st EAS or EBS Message 1017 "

2nd Protective Action Decision)

Shelter:

Evacuate:

1154 1140* 1152 1153 1151 1151 2nd Siren Activation 1152 2nd EAS or EBS Message 1156 (KIAdniinistration Decision: 1135 Decision: Emergency Workers I .( ND): S, -- Stupp1ort Jtirl-itiction

.NA

1) i )Wý101OI \'IKIIIL' M] !ý> CLt 011 C \" I U , S.

NotAnnlic)hlc

... . . [ [ ... .

• Refer to ISY IF on Risk ,Jurisdiction 2.2 l lam let ofl'Iishel's Is!and.

12

TABIE 1. EXERCISE TIMELINE DATE AND SITE: May 1 2002 Millktonn Power £tatinn Emergency Time ......... Time That Notification Was Received or Action was Taken Classification Utility State New Old Water- C/SP Level or Event Declared FOC Montville l~ondon Iynie ford Montvillc Unusual Event N/A N/A N/A N/A N/A N/A N/A Alert 0757 0808 0809 0808 0808 0957 0857 Site Area Emergency 0945 0957 0958 0957 0958 0957 1005 General Emergency 1118 1128 1134 1132 1128 1133 1145 Simulated Radiation Release 0930 0930 1001 0945 0958 0952 0945 Started Simulated Radiation Release - - - - -

Terminated Facility Declared Operational 0905 0905 0830 0855 0840 0858 Declaration of State of Disaster Emergency 1007 1028 1028 1028 1027 1035 Exercise Terminated DATSIE ANa~ 1 2002 MillstoePowerStatio 1331 1331 1330 1330 1335 1250 Early Precautionary Actions: 0920 - 1012 - 1110 Clear parks. forest, boat landings Evac hosp 1st Protective Action Decision 1148 - - -

Shelter: D, F Evacuate: A, B, C, E 1st Siren Activation 1015 1015 1014 1013 1014 1st EAS or EBS Message 1017 - - -

2nd Protective Action Decision) - - - -

Shelter:

Evacuate:

2nd Siren Activation 1152 1152 1151 1152 1152 2nd EAS or EBS Message 1156 - - -

KI Administration Decision: 1135 - 1159 1147 D)ecision:

___________________ J .1

___________________ .1___________________

1 ___________________

1 ___________________

L L __________________

II (TENI): S Sý pport ,ulrisdictioll I) l)ccision Making Jurisdiction Acti\ating im-isdiction N/A - Not Applicahle 13

IV. EXERCISE EVALUATION AND RESULTS Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities which participated in the May 1, 2002, plumne exposure pathway exercise to test the off-site emergency response capabilities of State and local governments in the I0-mile EPZ surrounding the Millstone Power Station.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of criteria contained in the September 12. 2001. FederalRegister Notice (revised April 25. 2002).

Detailed information on the exercise criteria and the extent-of-play agreement used in this exercise are found in Appendix 3 of this report.

A. Summary Results of Exercise Evaluation The matrix presented in Table 2. on the following page(s), presents the status of all evaluation area criteria that were scheduled for demonstration during this exercise bN all participating jurisdictions and functional entities. Exercise criteria are listed by number and the demonstration status of those criteria is indicated by the use of the following letters:

M Met (No Deficiency or ARCAs assessed and no unresolved ARCAs from prior exercises)

D Deficiency assessed A ARCA(s) assessed or unresolved ARCA(s) from prior exercise(s)

N Not demonstrated (Reason explained in Subsection B) 14

TABLE 2. 2002 EXERCISE EVALUATION GRID DATE AND SITE: May 1. 2002, Millstone Power Station TI.L. . 2.

L2.] 3. 3. 3. 3. 4. 4. 4. 4. 6.

3. 3.' ý1. '4.

I. 5. 6.

IA RISI)IC'TIONS/.)(x',I'ION a. b. d. c. a. hb.b).

c. 2.

b. 5. 5. 5. b. 6.

d. a. b. c. c. c.

1b. d.

11 1. 12 11 12 1 1.1211 a. 1a. 1 a. a. a. d.111 STATE OF CONINECTICUT State Emergency Operations Center M IV A M M M M Department of Enivironinental Protection M M

IV MM M MV Emergency Operations Facility M MM State Field Monitoring Team A MTMNIIIIN---rm MIm State Field Monitoring Area B ( A M M Joint Media Center MMM M

I M ' M Deptmo M M A OM Ariea IV,Coenter ntlifeFsuIlin MM M A M StaePlic APs/TC Ps M Staty Department Of TrCanspoth elt M

'VI M/1 M M1 M

S[owno Tranotion nC M M M 11 1 1 TNI T - - tM

- IM

- I- I - +/- - + - F- F- F- 4-4-1-1-1--k - -

M M M vl EALyme EO C M M M MF A [V M vM

-M M -MM M M TV /1 MM - -

M M MM MM M47 -' -- M-------------M M M N' I MM M M MM Montamletf FOClr sln O M NI M M M

City of Nwrondon E OC M NMI NI I M M/ M M MM M ImIm' I I mI I Im -M -M-MM -- - M MM NI M M MM -MM MM M M M M

M MMMM M MM MIM M M M M t 4 M1 I Old L~yme EOC 1 ,4 I --

M M MM M M MM raterford \I M M M M M vi m N1 NI M N1 M I .,I *1Mi MIMIMIMIM F (F \l

", \', r (.ctho l)ch i,wlc', or ,\R('"+*

\ <,: ciid MM MNIm NI NI A \R(' \Ni inqsescd Oit ril f cirrLh hi fllh and ki.* c !l\ pubi l c) I1rik rchodulc derirlrori li oll

~',, ~ rlt(\~ d ~ol luiro

\orl I \(t* \) ,M~'! / i)([hl~ l i

1) ~~ ~ ~ ~ ~ ~ ~ ~ ~ u*k, I' jmlwr*.: ,,

15

B. Status of Jurisdiction Evaluations This subsection provides information on the evaluation of each participating juri sdicoi1 and functional entity, in a jurisdiction-based. issues-only format. Presented belo\\ is i definition of the terms used in this subsection.

"* Met - Listing of the demonstrated exercise criteria under which no Deficiencies oF ARCAs were assessed during this exercise and under which no ARCAs assessed during prior exercises remain unresolved.

" Deficiency - Listing of the demonstrated exercise criteria under which one or more Deficiencies was assessed during this exercise. Included is a description of each Deficiency and recommended corrective actions.

" Area Requiring Corrective Actions - Listing of demonstrated exercise criteria under which one or more ARCAs were assessed during the current exercise or ARCAs assessed during prior exercises remain unresolved. Included is a description of the ARCAs assessed during this exercise and the recommended corrective action to be demonstrated before or during the next biennial exercise.

"* Not Demonstrated - Listing of the exercise criteria that were not demonstrated as scheduled during this exercise and the reason they were not demonstrated.

"* Prior ARCAs - Resolved - Descriptions of ARCAs assessed during previous exercises that were resolved in this exercise and the corrective actions demonstrated.

" Prior ARCAs - Unresolved - Descriptions of ARCAs assessed during prior exercises that were not resolved in this exercise. Included is the reason the AR(i.

remains unresolved and recommended corrective actions to be demonstrated before or during the next biennial exercise.

The following are definitions of the two types of exercise issues that are discussed inI this report.

" A Deficiency is defined in FEMA-REP-14 as -...an observed or identified inadequacy of organizational performance in an exercise that could cause a find inU that off-site emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in the event of a radiological emergency to protect the health and safety of the public living in the vicinity of a nuclear power plant."

" An ARCA is defined in FEMA-REP- 14 as "'...an observed or identified inadc 1 tucae of organizational performance in an exercise that is not considered, by itself' to adversely impact public health and safety."

FEMA has developed a standardized system for numbering exercise issues (D)eficiencies and ARCAs). This system is used to achieve consistency in numbering exercise issue, 17

among FEMA Regions and site-specific exercise reports within each Region. It i al1o used to expedite tracking of exercise issues on a nationwide basis.

The identifying number for Deficiencies and ARCAs includes the following. elenient>.

with each element separated by a hyphen (-).

"* Plant Site Identifier - A two-digit number corresponding to the Utility Billable Plant Site Codes.

"* Exercise Year - The last two digits of the year the exercise was conducted.

" Criterion Number - An alpha-numeric number corresponding to the criterion numbers as contained in the FederalRegister Notice dated September 12. 200 I. and revised April 25, 2002.

• Issue Classification Identifier - (D = Deficiency, A = ARCA). Only Deficiencnus and ARCAs are included in exercise reports.

• Exercise Issue Identification Number - A separate two (or three) digit indexiln number assigned to each issue identified in the exercise.

18

1. STATE OF CONNECTICUT 1.1 State Emergency Operations Center The State Emergency Operations Center (EOC) Communications staff received, deli\ ered. and transmitted all messages in an efficient and organized mainer allowing for rapid exchange of' important information between the Utility, State. and local emergency response organizatlions.

All messages were logged and filed and were retrievable for quick reference if needed.

The Public Inquiry Function (formerly called Rumor Control) was accomplished in an outstanding manner. The communication and coordination provided by the Joint Media (Center (JMC) Supervisor were efficient and effective. The staff quickly identified trends from the telephone calls, which were immediately communicated to the JMC Liaison. This resulted inl the Media being advised of needed information so that they could then advise the public accurately on conditions in their communities and of any needed actions on their part.

The Office of Emergency Management (OEM) staff and staffs of the various State agencies that participated in the Millstone Exercise clearly demonstrated their knowledge and expertise of' their procedures of the Radiological Emergency Response Plan. They demonstrated a common purpose of caring and safety for the people of Connecticut. The OEM Director demonstrated that he was in charge by conducting several staff meetings with the lead agency representatli es.

Based upon recommendations, he made precautionary and Protective Action Decisions for the general public.

a. MET: Evaluation Area Criterion 1 - a. 1. b. 1. d. 1. e. 1 2- a. 1, b.2 5- al. b. 1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: 1.c. 1 Issue No.: 3 8-02-1.c. 1-01 Condition: The State OEM and the towns did not coordinate effectively, e.g..

implementing the same precautionary activities and protective actions. This had the potential to negatively impact public safety.

For example. at 1100. the OEM Director denied the deployment of ambulances to Nc%\

London to support evacuation. Meanwhile, the State Transportation Staging Area (STSA) log reported sending and then not sending ambulances to the City of Ne\\

London from 1300 to 1330. Also during this time, the Town of East Lyme relocated special needs citizens to the L&M Hospital. which had been closed. Furthermore. the\

did not communicate this relocation to State OEM Area IV as required. (The Io\\ n reported that they did not tell Area IV because they did not need any assistance. i.e.. the\

had their own buses.) Similarly, the Town of Groton dismissed students at 09)4()

without notifying the State or Area IV. While this action was allowable per pirocedrce, 19

since it was before the State Declaration at 1007, the State Radiological EmergLent5c Response Plan still requires coordination.

The State Division of Public Health (DPH) directed the City of New London and other towns to shelter-in-place all hospital and special needs patients. While this int'6omation was purportedly provided to towns via the DPH intranet "Public Health Netxmor-k (to which only the City of New London was connected), it was not contained in either Emergency Alert System message (EAS).

Possible Cause: The towns did not share information with OEM Area IV. nor did thc\

comply with DPH directions. It is also unclear if the State DPH was coordinating its direction to towns and/or the Director of OEM, resulting in the OEM Director not having a full understanding of the actions taken by towns after the Declaration of a State of Emergency. As detailed in the State RERP, once the Declaration has been made.

towns shall comply with the direction and control from the State and take no unilateral actions.

Reference:

(NUREG-0654, A.l.d, 2.a.. b.)

Effect: Based on the lack of communication and coordination, it appears the (it\ of' New London was evacuating patients, although the DPH had directed that the\ shelter in-place. Presumably DPH thought it would be safer to remain in the hospital. This could result in people requiring hospitalization not being directed to the facilit\. The Town of East Lyme could have potentially taken hospital patients into harm's %\ay onkI to arrive at a closed hospital. Both events could have resulted in a negative impact to public safety.

Recommendation: The State OEM Director must reinforce to State agencies that all direction given to towns be coordinated through the Director's office, e.g., the DIlI I should have shared this recommendation during the Director's meeting with ke\ stall and disseminated the message to all towns through the conference call. FurthenmoiC.

the State must ensure that towns are compliant with its direction and do not take independent actions once a Declaration of a State of Emergency has been made.

Schedule of Corrective Action: The State agrees that there were some coordination issues as described above particularly with regards to the precautionary actions taken and not conveyed to the State (e.g. Town of East Lyme for schools and special needs people and the protective action directed for L&M Hospital in New London). The local officials involved were acting in the best interests of their municipalities and the issues resulted from misunderstandings on mutual coordination and notification procedures.

These issues will need to be corrected by additional planning, further training in local and State coordination protocols and, possibly. some change in procedures.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED:

20

Issue No: 38-95-05-A-03

Description:

Bus drivers wxere not issued dosimetry. (Objective 5/Evaluation \rea Criterion I.e. I (2.a. 1, 3.a. 1)) (NUREG-0654. K.3.a)

Corrective Action Demonstrated: The STSA demonstrated corrective action 1`61 ARCA 38-00-14-A-04. Two 130 milligram (rng) tablets of potassium iodide (KI) \ci-c issued to drivers when they picked up their dosimetry packets and received a bric floe on dosimetry and KI. The drivers were provided with information sheets on the use oflKI and were provided with a verbal briefing on when they could ingest KI, its side eflectN.

and precautions. This ARCA is considered resolved.

Issue No.: 38-00-04-A-01

Description:

A new pager system from Millstone for use by key personnel xsas used throughout the exercise. The system generally reached one of several pagers. hoitlt unreliable in terms of all key persons being able to receive messages. Typically. out of five pagers. one would receive a complete message and the other pagers receix ed garbled messages, if they received anything at all. (Objective 4

/Evaluation Area Criterion 1.d. 1) (NUREG-0654, E. 1, E.2: F. l a)

Corrective Action Demonstrated: The paging system was activated seven times during the exercise. Key personnel within the State EOC received all pages. Pertsooncl responded to the pagers by calling the designated number for a more detailed sumt1at-\

of information. The taped messages were clear, concise, and easily understood. The State EOC Communication Center called the Area IV OEM Director to ensure that the Director had received each page and message. The Area Director indicated that the messages had been received and understood. The Area IV OEM Director was responsible for ensuring that the key town emergency responders had received the information contained in the pages and taped messages.

No failures of the pagers or garbled messages were reported. The State EOC Communicator and the Area IV 0I1 \M Director were prepared to provide the information to any organization if a failue had occurred. This ARCA is considered resolved.

f. PRIOR ARCAs - UNRESOLVED: None 21

1.2 Department of Environmental Protection The Dose Assessment staff functioned as a well-trained and experienced integrated team I ach individual displayed expertise in executing his/her responsibilities and duties. The close coordination with the Millstone Power Station's Field Team Coordinator was commenda>l\

demonstrated.

a. MET: Evaluation Area Criterion I - b.1, d. 1, e.1 2-b.1 3 -a. 1 4 - a.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 1.3 Emergency Operations Facility The two State Department of Environmental Protection (DEP) liaison representatives at the Emergency Operations Facility (EOF) were professional in their interactions with the t'tilit\

staff and in assuring that their counterparts at the State Emergency Operations Center (Statc EOC) had advance information on plant status. They were well versed on DEP informatlio needs and the sources from which to satisfy them. They also facilitated getting appropriIte Utility personnel to clarify questions from the State EOC.

a. MET: Evaluation Area Criterion 1 -b.1, d.I, e.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None

1.4 State Field Monitoring Teams (A & B)

The Field Teams did an outstanding job. They knexw their procedures and performed them \x\l.

They understood the need to prevent contamination of their equipment, their vehicles.

and themselves, and strove to do so. They demonstrated knowledge of the area in which the\-,erl sampling and were able to travel to assigned sampling locations in a timely manner.

a. MET: Evaluation Area Criterion 1 - d. 1. e. 1 3-aa. 1 b.l 4 - a. 1. a.2. a.3

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 1.5 Joint Media Center The Joint Media Center supervisor, assistant, and staff were well organized and had eilen considerable thought to the details of managing the timely distribution of information to the Media and the public in clear, concise language.

The use of a sign language interpreter at the press briefings showed that the needs of special populations were considered in responding to the incident.

The Joint Media Center (JMC) staff demonstrated a coordinated partnership with the State I ()C staff. Governor's press staff, and Millstone Power Station representatives.

The press advisories, news releases, and fact sheets xwere well written in simple. clear langnage.

a. MET: Evaluation Area Criterion I - b. 1. e. 1 5 -b.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None 23

1.6 State Department of Public Health willing to assist Public Health Command Post staff worked very well as a team. They were The as a team previously.

that they have worked together each other and it was very clear 1- e.1 MET: Evaluation Area Criterion "b- -I a.

I

b. DEFICIENCY: None 3.c.1 REQUIRING CORRECTIVE ACTION:

c. AREAS 2

Issue No.: 38-02-3.c.1-0 Note: This issue was identified at the New London EOC but the issue and the at the of Public Health, both responsibility for its correction lies with the Department position in the State EOC.

DPH EOC and the Liaison New London Health Director discussed the evacuation of the Condition: At 1000 the facilities were polled the EMS Coordinator at the hospital. The support patients. The Hospital with all the number of bed spaces identified to receive assets. This action was and the required and mutual aid commenced at 1012 utilizing town evacuation contrary to the State RER-P.

and the EMS Coordinator Their at the hospital acted The Health Director Cause:and without notifying Area IV or the State EOC. actions did not possible independently (l.c.l).

plans. This appears to be a direction and control issue comply with 6 54 , E.7: J.9. 10.c., d.. e., g.

Reference- NUREG-0 diverted the ambulances to move the patients could have for could become Effect: The requirement by the State. The evacuation routes assigned assets for another mission strain on the hospital staff.

congested. There was a WV and State staff to coordinate all actions with the Area the plans and Recommendation: Train decisions. Ensure that the staff follow their such agencies before making procedures.

issues The State concurs that there were coordination State Actions: The Schedule of Corrective regarding protective actions for L&M Hospital. and between all parties involved (DPH) has authority over all health care facilities Department of Public Health for these facilities evacuation or sheltering-in-place always has the option to recommend the fact that DPH However. the State needs to reinforce depending on the situation. need additional training to ensure that and all participants does have this prerogative evacuation or sheltering options.

to respond to both they are ready None

d. NOT DEMONSTRATED:

25

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 1.7 OEM Area IV, Colchester The strength of the Connecticut Office of Emergency Management Area IV Coordinator and staff was demonstrated by their combined knowledge of the plan and procedures, experience in emergency situations, and confidence in themselves and in their team.

a. MET: Evaluation Area Criterion 1 - a.1, b.1, d.l. e.1 3 -c.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: 1 .c. 1 Issue No.: 38-02-1.c.1-03 Condition: Area IV staff did not inform the State EOC of early dismissal of schools in the Town and City of Groton.

Possible Cause: Message received via telephone was given a routine priority classification. Immediately after receipt of the early school dismissal for the Groton School District, the Area IV Coordinator was in the process of establishing an emergency planning zone town conference call. The message may have been forgotten due to the immediate requirement of establishing the conference call.

No specific requirement requires the Area Coordinator to keep the State EOC informed as to status changes in local EPZ communities. This reporting requirement should be repeated for all emergency classification levels. (This requirement would be applicable to all CT-OEM Area Coordinators checklists.)

Reference:

State of Connecticut Agency Procedures CTAP 3.2, OEM-6, Area IV Coordinator.

Effect: The State EOC and Media Center did not receive information about the Groton School District early dismissal. This prevented the Director and the State Media Center from providing information to the public as to the status of the school children in the Groton School District. The lack of information about the Groton School District would have brought undue stress and concern to the parents who have children in these schools.

Recommendation: Conduct training on the need to pay more attention to incoming messages and ensure that messages are distributed to appropriate staff members for proper action.

26

Change the plan to reflect a requirement for the Area IV Coordinator to advise the State EOC of any actions taken by EPZ communities.

Schedule of Corrective Action: The State concurs. Appropriate changes need to be made to Area 4 procedures in the State Plan emphasizing the requirement that all actions taken by EPZ towns, both before and after a declaration of a State of Emergency, be reported to the State EOC for resource management and public information purposes.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 1.8 State Police Access Control Points/Traffic Control Points The State Police Troop E Incident Cormnander (IC) did an excellent job with command and control at Troop E. The IC found an issue with traffic control points (TCPs) in the traffic management plan and took immediate action to correct the problem.

a. MET: Evaluation Area Criterion 1 - d.1, e.1 3- a.1, d.1. d.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 1.9 Connecticut Department of Transportation Department of Transportation (DOT) District H1 Radiological Officer did an excellent job in her dosimetry issuance and briefing. DOT staff were knowledgeable of their plans and procedures.

a. MET: Evaluation Area Criterion 1 -d.1, e.1 3 -a.l, d.1. d.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None 27

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 1.10 State Transportation Staging Area The STSA functioned smoothly with effective direction and control by the Staging Area Supervisor. STSA personnel appeared to be well trained and familiar with the functions of all five staging stations. The STSA equipment and supplies are organized and stored in a manner that promotes efficient setup. During the exercise. the STSA was activated within seven minutes of being notified of the Alert. The system for tracking vehicle status was enhanced by using magnetic stickers representing different vehicles.

a. MET: Evaluation Area Criterion 1 - a. 1. b. 1, c. 1, d. 1. e. 1 3-c.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None Issue No.: 38-02-3.c. 1-04 (Corrected per on the spot corrections initiative)

Condition: The Radiological Officer did not brief emergency workers concerning potential allergic reactions to ingesting potassium iodide. However, the information packets did contain the caution in a conspicuous location where the workers should see it as they filled out information on their **Potassium Iodide (KI) Report."

Possible Cause: The Radiological Officer overlooked this information required in the procedures.

Reference:

(NUREG-0654, E.7; J. 10.e.,f.

Effect: An emergency worker with allergies to iodine could ingest the KI and have an adverse reaction if he/she did not read the information provided with the KI tablets.

Recommendation: Include a statement in the briefing that persons who are allergic to iodine should not ingest KI. The Radiological Officer successfully re-demonstrated the briefing and included the information.

Corrective Action Demonstrated: The Radiological Officer successfully re demonstrated the briefing and included the warning to the emergency wvorkers.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED:

Issue No.: 38-00-14-A-04

Description:

Potassium iodide was not issued with dosimetry: therefore, if KI is recommended after the emergency driver leaves the STSA. it could not be taken until the KI was issued. (Objective 14/Evaluation Area Criterion 3.a. 1) (NUREG-0654, J.10.e)

Corrective Action Demonstrated: The STSA demonstrated corrective action for ARCA 38-00-14-A-04. Two 130 mg tablets of KI were issued to drivers when they picked up their dosimetry packets and received a briefing on dosimetry and KI.

The drivers were provided with information sheets on the use of KI and were provided with a verbal briefing on when they could ingest KI, its side effects, and precautions.

f. PRIOR ARCAs - UNRESOLVED: None

2. RISK JURISDICTIONS 2.1 East Lyme EOC The East Lyme Emergency Operations Center staff demonstrated knowledge of their plans and procedures. Everyone communicated and coordinated with one another. which kept the EOC operating smoothly. The RACES operator did an excellent job in monitoring and maintaining radio communications traffic.

a. MET: Evaluation Area Criterion 1 - a. 1, b. 1, c. 1, d. 1. e. 1 3- a.1, c.2 5 -a.I

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: 2.c. 1 Issue No.: 3 8 2.c.1-05 Condition: Early in the exercise, the Chief Executive Officer (CEO) relocated students from schools to the high school. The transfer was executed without coordination or approval of the CT-OEM Area IV.

The CEO also made a decision to move several special needs patients to L&M Hospital.

This was done without coordination or approval.

Possible Cause: Lack of understanding of requirement in the Radiological Emergency Response Plan of the need to coordinate/notify CT-OEM Area IV.

Reference:

NUREG-0654 A. L.d: East Lyme RERP; LCP-3.5. page 3 of 12.

29

Effect: A potential existed of using transportation assets pre-designated to other areas in the EPZ. Appropriate and timely decisions cannot be made at the State and area levels when communities make their own uncoordinated decisions or actions, when under a Govemor's Emergency Declaration.

Recommendation: There needs to be more training of the RERP so that emergency officials clearly understand the need for continuous communication and coordination.

Schedule of Corrective Action: The State concurs with the need for municipalities to advise and coordinate with the State whenever taking any emergency actions. However.

the State has the following reservation: towns clearly have the authority to take precautionary actions without State approval prior to the State's Declaration of an Emergency.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED:

Issue No.: 38-00-05-A-05

Description:

The Fire Chief at the East Lyme EOC was not aware of the difference between the low range (0-5R) and high range (0-200R) dosimeters. He thought he had one direct-reading dosimeter (DRD) as back-up. (Objective 5/Evaluation Area 2.a. 1)

(NUREG-0654, K.3. K.4)

Corrective Action Demonstrated: Through the issue of a dosimetry packet and interview of the State Trooper about the proper use of the direct-reading dosimeters (DRDs). ARCA 38-00-05-A-05 was demonstrated correctly. The State Trooper explained the difference in readings of the 0-5 R and 0-200 R dosimeters. This demonstration and interview corrects this ARCA.

f. PRIOR ARCAs - UNRESOLVED: None 2.2 Hamlet of Fishers Island, NY, EOC Staff at the Fishers Island EOC worked very well together and conducted themselves in a professional manner. The Deputy Director of Fishers Island Emergency Management maintained excellent communications with other emergency response organizations. Especially noted was the constant contact he made with the Fishers Island Ferry District Manager to get the latest information on the status and availability of ferries that could be sent to Fishers Island in the event an evacuation order was given.

a. MET: Evaluation Area Criterion 1 - a. 1, b. 1. c. 1. d. 1. e. 1 2 -c.1 3- a. 1, c. 1. c.2 5- a.1 30

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.3 City of Groton EOC The exercise conducted by the leadership and staff of the City of Groton was a model for how an exercise can be used to prepare for handling a real event. The Chief Executive Officer (Mayor) and Civil Preparedness Director (CPD) treated the drill with a high degree of reality.

thereby setting the tone for all participants. The CEO was continuously alert to events, responding with sensible, proactive actions to protect the public. The CEO encoura2ed frank discussion, but was decisive in his decision-making.

The CEO has obviously prepared the staff well. The Radiological Officer performed his duties in an exemplary fashion. The police department representative is to be commended for making significant contributions to the EOC deliberations.

a. MET: Evaluation Area Criterion 1 - a. 1. b. 1. c. 1. d. 1. e. 1 2

-c. 1 3 - a.1. d.1. d.2

-a.l. a.3

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION:

None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 31

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.6 Lyme EOC The Lyme EOC Director and staff were able to overcome the failure of their primary radio and place a duplicate back-up in service without losing any messages.

The Emergency Management Director (EMD) and the First Selectman encouraged staff participation and shared ideas to arrive at the best solution to the task being discussed.

There was constant discussion within the EOC of the possible scenarios that might occur, and they anticipated and prepared for a variety of eventualities.

The EOC Director displayed judicious decision-making and included all ideas into the process.

He showed good leadership and dealt fairly with his staff.

a. MET: Evaluation Area Criterion I- a. 1, b. 1. c. 1, d. 1, e. 1 2- c.1 3- a.1, c.1. c.2, d.1, d.2 5 - a.1, a.3. b.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 33

2.7 Montville EOC The Montville EOC was well arranged and setup. with excellent equipment and all the necessary status boards. logs, plans. procedures. and rosters.

for The communications procedures were well handled, with constant attention to procedures confirmation and record keeping.

plan All staff members fully utilized their checklists, logs, etc.. provided in their emergency throughout the exercise.

in Montville A careful analysis of possible scenarios for releases and protective actions needed sheltering-in-place for led to a decision for an early protective action by the town to implement and problems schools. This decision was followed by a well-reasoned discussion of the issues involved in such an action.

a. MET: Evaluation Area Criterion I - a. 1, b.1, c.1, d.1, e.1 2-c.1 3- c.1, c.2, d.1, d.2 5- a.1, a.3, b.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: 3.a. 1 Issue No.: 38-02-3.a.1-06 contain Condition: The briefing regarding emergency worker exposure control did not key information included in town procedures. During a re-demonstration the key Radiological Defense Officer (RDO) again did not follow procedures and omitted information.

the prescribed Possible Cause: The RDO and Assistant RDO did not use or follow procedure for briefings, resulting in the omission of key steps in the process.

Reference:

NUREG 0654. K.3 and Montville Plan: Attachment 1 to Radiation Exposure Control, LCP-4.2 of the Effect: The briefed emergency worker did not fully understand the purpose or maximum dosimeter kit and its components, was not clear as to call-back, turn-back, exposure limits, and did not sign the briefing acknowledgement form.

local Recommendation: Four improvements are recommended: (1) the prescribed procedure should be utilized by the RDO during the briefing; (2) the instructional adequate language should be simplified; (3) the worker should be questioned to ensure be completed understanding of the exposure control concepts: and (4) all forms should and signed.

34

Schedule of Corrective Actions: The State concurs. The Montville EOC staff is highly motivated and professional and this incident was a rare performance issue that certainly will be addressed immediately by the Emergency Management Director. This issue can be corrected by providing additional radiological staff training emphasizing the need to follow Plan procedures and, as suggested, to ensure that emergency workers are quizzed after briefings to ensure that they understand exposure control requirements.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.8 City of New London EOC The City of New London EOC staff are very dedicated individuals that work extremely well together with the ultimate goal of the health and safety of their cormnunity. Discussions observed during this exercise were consistently centered around the safest and most effective measures to be taken concerning both emergency workers and the general public.

Although this EOC is not a permanent facility, the cooperation from the City of New London in providing the space and advanced technology through the communications and computer divisions currently available is impressive. Recent advancements already in place and current plans to improve others indicated a high level of dedication on the part of the EOC and the City.

a. MET: Evaluation Area Criterion 1 - a. 1. b. 1. c. 1, d. 1. e. 1 2-c.1 3 -a.1, c.1. c.2, d.1. d.2 5 - a.1, a.3. b.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None

2.9 Old Lyme EOC The Old Lyme EOC staff functioned in an efficient and cohesive manner. The leadership of its CEO and Emergency Management Director was outstanding. All supporting staff contributed with distinction. The EOC facility provided a very good work environment.

The Town of Old Lyme EOC demonstrated a well-organized emergency response. Out of the five-member team, only one was a paid employee.

a. MET: Evaluation Area Criterion I - a.1. b.1, c.1, d.1, e.1 2 - c. 1 3 -a.1. c.1,c.2, d.1, d.2 5 - a.1, a.3, b.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED:

Issue No.: 38-00-30-A-07

Description:

The shift change required by the extent-of-play was not adequately demonstrated at the Old Lyme EOC because only the CEO position was changed during the drill. All other positions were changed by rotating personnel who were already participating in different positions at the EOC (i.e., communication officer. status board recorder). (NUREG-0654. A.4)

Corrective Action Demonstrated: Per the extent-of-play agreement. a roster containing the names for each of the key positions for two 12-hour shifts was presented to the evaluator. This serves to demonstrate Corrective Action to ARCA Issue No. 38 00-30-A-07.

f. PRIOR ARCAs - UNRESOLVED: None 36

2.10 Waterford EOC The Waterford EOC provided an excellent facility to support emergency management operations. The staff are professional and performed extremely well. It was evident that the staff are well trained and competent.

a. MET: Evaluation Area Criterion I - a.1, b.1I. c.1I. d.1,. e. 1 2- b.2, c.1 3 -a. 1, b. 1. c. 1. c.2, d.1, d.2 5- a.1, a.3. b.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.11 Schools/Bus Evacuation The Superintendents of the schools interviewed were well aware of the importance of their responsibilities of protecting the school children as early as possible. They were knowledgeable of their plans and procedures. They kept their school principals informed as the situation changed.

a. MET: Evaluation Area Criterion 1 - e.1 3 - c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 37

2.12 Special Populations - Nursing Homes The nursing home staff are experienced in dealing with medical emergencies involving moving patients to special facilities.

a. MET: Evaluation Area Criterion 1 -e. 1 3 -c.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None

3. SUPPORT JURISDICTIONS 3.1 New Haven EOC The Staff at the EOC in New Haven adequately demonstrated their knowledge of their plans and procedures. Soon after arriving, EOC Staff members worked together to alert and mobilize the Host Community/Reception Center. The EOC Director also directed the New Haven Police Liaison to implement the traffic control plan from 1-95 to the Reception Center. The EOC director continually briefed the staff as to status changes concerning the Millstone NPS and the staff frequently briefed the Director when tasks were completed concerning traffic control and the establishment of the reception center. There was constant communication between the EOC and the Reception Center Manager as status changed.

a. MET: Evaluation Area Criterion 3 - a.l1 b.1, c.1, d.1, e.1 3 - d.lI

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 38

3.2 New Haven Host Community Reception Center The New Haven Host Community/Reception Center performed their duties and responsibilities with enthusiasm and intimate knowledge of their plans and procedures. The Incident Commander (Reception Center Manager) immediately briefed the staff of the situation at the Millstone Power Station and then proceeded to task his section chiefs to establish the reception center. Communications was established between the section chiefs and the New Haven EOC.

The reception center became operational in a timely manner and then the staff proceeded to conduct the drill requirements as specified by the evaluation criteria and extent of play.

a. MET: Evaluation Area Criterion 1 - a.1, b.1. c.1, d.1. e.1 3-a. 1, d. 1 6-a. 1, b.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None Issue No. 38-02-6.a. 1-07 (Corrected per on the spot corrections initiative)

Condition: While monitoring a field team member, the secondary monitor placed his knee on the potentially contaminated paper covered walkway.

Possible Cause: This issue was caused by not adhering to procedures and concentrating on getting the monitoring completed.

Reference:

NUREG-0654. J.10.h: K.5b Effect: This cross contamination would have affected the further monitoring of emergency workers or evacuees and raised the background levels in the area.

Corrective Action Demonstrated: This issue was corrected immediately by review of the procedures and training conducted by the controller and evaluator. The next emergency worker monitored was completed correctly.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED:

Issue No. 29-96-18-A-15

Description:

Both vehicle monitors demonstrated a lack of training and confidence in the use of the monitoring equipment and the procedures. For example one worker held the probe to far from the surface to pickup any potential contamination, while another worker passed the monitoring probe over the surface to quickly to pick up any contamination. On one occasion the front driver's side fender and wheel well were 39

monitored and found to have been contaminated, the monitor leaned over the fender to monitor the vehicle hood.

Corrective Action Demonstrated: Members of the vehicle monitoring teams demonstrated their proficiency in monitoring vehicles. All members kept a good steady pace and maintained at least an inch distance from the probe to the vehicle surface.

Issue No. 29-96-18-A-16

Description:

The Reception Center plan calls for three personnel in the female decontamination area and only two were present, the monitor and attendant who were positioned at the exit of the shower. The attendant and monitor, who should have been at the entrance to the shower to provide instructions and decontamination supplies such as soap, shampoo, and brushes, were not there. A controller escorted the evacuee to be decontaminated and was the person that provided the paperwork showing areas to be decontaminated to the monitor on the other side of the shower. The three staff called for in the plan are necessary to the implementation of this objective. (Objective 18 and 22 (NUREG-0654, J. 10.h, J. 12).

Corrective Action Demonstrated: There were three Female Decontamination staff at the New Haven Reception Center (RC). as specified in the Reception Center Plan. This corrects ARCA 29-26-18-A 16.

Issue No. 29-96-18-A-17

Description:

A provision for changing clothes was available for males but the garments shown the evaluator (an Army fatigue shirt but no pants) was not sufficient.

The decontamination personnel were not aware of any additional clothing to supplement what was shown. Alternate clothing was not available for females who required decontamination. (Objective 18 and 22) (NUREG-0654, J. 1O.h, J. 12).

Corrective Action Demonstrated: Replacement clothing sets were provided for evacuees whose clothes were found to be contaminated. This corrects ARCA 29-96-18 A-17.

f. PRIOR ARCAs - UNRESOLVED: None 40

3.3 New Haven Congregate Care Facilities

a. MET: Evaluation Area Criterion 6 - c. I

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 41

APPENDIX 1 ACRONYMS AND ABBREVIATIONS The following is a list of the acronyms and abbreviations that were used in this report.

ACP Access Control Point ALARA As Low As is Reasonably Achievable ARC American Red Cross ARCA Area Requiring Corrective Action CEO Chief Executive Officer CFR Code of Federal Regulations CPD Civil Preparedness Director CT-OEM Connecticut Office of Emergency Management DEP Department of Enviromnental Protection DHHS U.S. Department of Health and Human Services DNC Dominion Nuclear Connecticut, Inc.

DOC U.S. Department of Commerce DOE U.S. Department of Energy DOI U.S. Department of the Interior DOT U.S. Department of Transportation DPH Department of Public Health DRD Direct-Reading Dosimeter EAS Emergency Alert System EBS Emergency Broadcast System EMD Emergency Management Director EMS Emergency Medical Service ENRS Emergency Notification Response System EOC Emergency Operations Center EOF Emergency Operations Facility EPA U.S. Environmental Protection Agency EPZ Emergency Planning Zone FAA Federal Aviation Agency FCC Federal Communications Commission FDA U.S. Food and Drug Administration FEMA Federal Emergency Management Agency FR Federal Register FRERP Federal Radiological Emergency Response Plan 42

FTC Field Team Coordinator GE General Emergency IC Incident Commander JIC Joint Information Center JMC Joint Media Center KI Potassium Iodide L&M Lawrence & Memorial NOAA National Oceanic and Atmospheric Administration NRC U.S. Nuclear Regulatory Commission NUREG-0654 NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980 NY New York OEM Office of Emergency Management ORO Off-site Response Organization PAD Protective Action Decision PAG Protective Action Guide PAR Protective Action Recommendation PAS Public Alerting System PIADC Plum Island Animal Disease Center P10 Public Information Officer PRD Permanent Reading Dosimeter R Roentgen R/h Roentgen(s) per hour RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Service RC Reception Center RDO Radiological Defense Officer REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RO Radiological Officer SAE Site Area Emergency 43

SCSU Southern Connecticut State University SERO State Emergency Response Organization SRD Self-reading Dosimeter STSA State Transportation Staging Area TCP Traffic Control Point TL Team Leader TLD Thermoluminescent Dosimeter USCG U.S. Coast Guard USDA U.S. Department of Agriculture 44

APPENDIX 2 EXERCISE EVALUATORS AND TEAM LEADERS The following is a list of the personnel who evaluated the Millstone Power Station Plume Exposure Pathway exercise on May 1, 2002. Evaluator Team Leaders are indicated by the letters "TL" after their names. The organization which each evaluator represents is indicated by the following abbreviations:

FEMA HQ Federal Emergency Management Agency - Headquarters FEMA RI Federal Emergency Management Agency - Region I FEMA RI1 Federal Emergency Management Agency - Region II EPA RAC U.S. Environmental Protection Agency - Regional Assistance Committee Member ICF ICF Consulting NRC RI U.S. Nuclear Regulatory Commission - Region I DOT RAC U.S. Department of Transportation - Regional Assistance Committee Member USDA RAC U.S. Department of Agriculture -Regional Assistance Committee Member EVAluIATION SITE EVALUATOR ORGANIZATION EVAL ATION SITE GENERAL OBSERVATIONS K. Horak FEMA RI STATE OF CONNECTICUT State Emergency Operations Center B. Swartz (TL) FEMA RI D. Bell (TL) FEMA RI B. Black ICF H. Christiansen ICF A. Kellogg ICF Department of Environmental Protection D. Thom6 (TL) ICF Emergency Operations Facility R. Bores NRC RI J. Chemiak EPA RAC Field Monitoring Teams E. Penner USDA RAC Joint Media Center J. Melton FEMA RI 45

EVALUATION SITE EVALUATOR ORGANIZATION State Department of Public Health W. Gaudet FEMA RI OEM Area IV. Colchester R. Poole FEMA RI H. LaForge (Shadow) FEMA RI Connecticut State Police Access Control R. Quinlan FEMA RI Points/Traffic Control Points State Department of Transportation R. Quinlan FEMA RI State Transportation Staging Areas W. Vocke ICF RISK JURISDICTIONS East Lyme EOC O.C. Payne FEMA HQ Hamlet of Fishers Island EOC B. Hasemann FEMA RE City of Groton EOC W. Gawlak ICF Town of Groton EOC M. Brazel FEMA RI Ledvard EOC P. Ford FEMA RI Lyme EOC B. Waters FEMA RI Montville EOC D. Palmer ICF City of New London EOC J. Austin ICF N. Johnson (Shadow) ICF Old Lyme EOC D. Petta DOT RAC E. D'Avanzo FEMA RI Waterford D. Blunt ICF School/Bus Evacuation - Fishers Island B. Haseinann FEMA RII 46

EVALUATION SITE EVALUATOR ORGANIZATION J. Gibbons FEMA RI School/Bus Evacuation (Demonstrated May 2. 2002)

J. Gibbons FEMA RI Special Populations, Nursing Homes (Demonstrated May 2. 2002)

SUPPORT JURISDICTIONS W. Gaudet FEMA RI New Haven EOC FEMA RI L. Record (Demonstrated June 1. 2002)

D. McElhinnev FEMA RI New Haven Host Community Drill FEMA RI D. Bell (Demonstrated June 1. 2002) FEMA RI R. Poole R. Swartz FEMA RI J. Gibbons FEMA RI W. Gaudet FEMA RI L. Record FEMA RI R. Swartz FEMA RI New Haven Congregate Care Centers (Demonstrated May 31. 2002) 47

APPENDIX 3 EXERCISE CRITERIA AND EXTENT-OF-PLAY AGREEMENT This appendix lists the exercise criteria that were scheduled for demonstration in the Millstone Power Station Plume Exposure Pathway exercise on May 1. 2002. and the extent-of-play agreement approved by FEMA Region I on April 5, 2002. An out-of-sequence demonstration was conducted on May 2.

2002, as per the extent-of-play. approved April 5, 2002. An additional extent-of-play agreement for the out-of-sequence demonstrations was submitted by the State of Connecticut for Evaluation Area 6, to be demonstrated on June 1, 2002, and was approved by FEMA Region I on May 1. 2002.

The Evaluation Areas contained in the FederalRegister Notice; Federal Emergency Management Agency - Radiological Emergency Preparedness: Exercise Evaluation Methodology, published on September 12, 2001, revised April 25, 2002, represent a functional translation of the planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1, Rev. 1. -Criteria for the Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants." November 1980.

Because the exercise criteria are intended for use at all nuclear power plant sites. and because of variations among off-site plans and procedures, an extent-of-play agreement is prepared by the State and approved by FEMA to provide evaluators with guidance on expected actual demonstration of the criteria.

48

Extent of Play

-Millstone Station FEMA EvaluatedPlume Pathway Exercise May 1, 2002 Rev. January-25, 2002 A. Exercise Criteria and Extent of Play for Millstone Evaluation Area 1 - Emergency Operations Management Sub-Element L.a Mobilization Previous Objective 1. Mobilization of Emergency Personnel Criterion L.a.l: Off-site Response Organizations use (ORO) effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner.

(NUREG-0654, A.4.; D.3., 4.; E.I., 2.; H.4)

INTENT This sub-element is derived from NUREG-0654 which provides that OROs should have the capability to alert, notify,. and mobilize emergency personnel and to activate and staff emergency facilities.

EXTENT OF PLAY - GENERAL Responsible OROs should demonstrate the capability to receive notification of an emergency situation from the licensee. verify the notification. and contact, alert. and mobilize key emergency personnel in a timely manner. In addition, responsible OROs should demonstrate the activation of facilities for immediate use by mobilized personnel when they arrive to begin emergency operations. Activation of facilities should be completed in accordance with the plan and/or procedures. Pre-positioning of emergency personnel is appropriate, in accordance with the extent of play agreement. at those facilities located beyond a normal commuting distance from the individual's duty location or residence. Further, pre-positioning of staff for an out-of-sequence demonstration is appropriate in accordance with the extent of play agreement.

All activities must be based on the ORO's plans and procedures and completed as they would be in an actual emergency. unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. The following locations and agencies will be pre-positioned and/or demonstrated off-line from the exercise scenario:

"* State Department of Environmental Protection Field Teams will be pre-staged at State Police Barracks E in Montville in conjunction with the exercise.

"* A selected sample of nursing care facilities will be surveyed off-line during the Wxeek of 4/29/02. (Approximately 1/3 of the total number is demonstrated during each evaluated exercise.) The designated nursing homes include: Mariner in East Lyme. Camelot in New London, and My-stic Manor in Groton. (See Sub-element 3.c.1.)

"* School district demonstrations will be conducted off-line during the week of 4/29'02 at Fishers Island. Groton City/Town (same school department) and Montville. (See Sub element 3.c.2.)

49

Extent of Play

-AMilstone Station FEMA Evaluated Plume Pathlrqay Exercise Mlai 1, 2002 Rev. Jamrn-a 25, 2002 Sub-Element L.a Mobilization (Continued)

(i.e. those

2. A roster and/or procedures indicating 24-hour staffing capability for key positions and/or emergency personnel necessary to carry out critical functions). as indicated in the plan of a shift change is not procedures, should be provided to the evaluator (demonstration required).

Areas Requiring Corrective Action (ARCA)

(None) 50

Extent of Play

-Millstone Station,FE.11A Evaluated Plume Pathwav Exercise May 1, 2002 Rev. January 25, 2002 Evaluation Area 1 - Emergency Operations Management Sub-element L.b Facilities Previous Objective 2. Facilities - Equipment Displays and Work Environment Criterion 1.b.l: Facilities are sufficient to support the emergency response. (NUREG 0654, H)

INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have facilities to support emergency response.

EXTENT OF PLAY - GENERAL Facilities will only be specifically evaluated for this criterion if they are new or have substantial changes in structure or mission. Responsible OROs should demonstrate the availability of facilities that support the accomplishment of emergency operations. Some of the areas to be considered are:

adequate space, furnishings. lighting. restrooms, ventilation, back-up power. and/or alternate facility (if required to support operations).

"Facilities must be set up based on the ORO's plans and procedures and demonstrated, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. This objective will be demonstrated by all participating organizations (OROs), where applicable, since it is the first evaluation using the new criteria.

2. This objective will be demonstrated by State and local EOCs to include: radiological emergency status board/s and EOC equipment.

3. The facility activation will be appropriate for a one-shift operation.

4. A source of back-up power and maintenance logs, if available, will be discussed.

Areas Requiring Corrective Action (ARCA)

(None) 51

Extent of Play

-Millstone Station FEMA Evaluated Plume Pathiway Exercise May 1, 2002 Rev. Januarv25. 2002 Evaluation Area 1 - Emergency Operations Management Sub-element 1.c Direction and Control Previous Objective 3. Direction and Control Criterion 1.c.1: Key personnel with leadership roles for the Off-Site Response Organization provide direction and control to that part of the overall response effort for which they are responsible. NUREG-0654, A.l.d., 2.a., b.)

INTENT This sub-element provides that the ORO have the capability to control their overall response to an emergency.

EXTENT OF PLAY - GENERAL Leadership personnel should demonstrate the ability to carry out essential functions of the response effort. for example, keeping the staff informed through periodic briefings and/or other means.

coordinating with other appropriate OROs. and ensuring completion of requirements and requests.

All activities associated with direction and control must be performed based on the ORO's plans and procedures and completed. as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC (No site-specific modifications.)

Areas Requiring Corrective Action (ARCA)

(None) 52

Extent of Play

-Millstone Station FEMA EvaluatedPlume Pathway Exercise Afai 1, 2002 Rev. Januarv 25. 2002 Evaluation Area 1 - Emergency Operations Management Sub-element 1.d Communications Equipment Previous Objective 4. Communications Criterion 1.d.1: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations.

(NUREG-0654, F.1., 2.)

INTENT This sub-element is derived from NUREG-0654. which provides that OROs should establish reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as the following: appropriate contiguous governments within the emergency planning zone.. Federal emergency response organizations, the licensee and its facilities, emergency operations centers, and field teams.

EXTENT OF PLAY - GENERAL OROs will demonstrate that a primary, and at least one backup system, are fully functional at the beginning of an exercise. If a communications system or systems are not functional, but exercise performance is not affected. no exercise issue will be assessed. Communications equipment and procedures for facilities and field units should be used as needed for the transmission and receipt of exercise messages. All facilities and field teams should have the capability to access at least one conmmunication system that is independent of the commercial telephone system. Responsible OROs should demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt the conduct of emergency operations. OROs should ensure that a coordinated communications link for fixed and mobile medical support facilities exists.

The specific communications capabilities of OROs should be commensurate with that specified in the response plan and/or procedures. Exercise scenarios could require the failure of a communications system and the use of an alternate system.

All activities associated with the management of cormnunications capabilities must be demonstrated based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Extent of Play

-Millstone Station FEMA Evaluated Plume Pathwta Exercise Mav 1. 2002 Rev. January 25. 2002 Sub-element 1.d Communications and Equipment (Continued)

EXTENT OF PLAY - SPECIFIC

1. Communications from the State to the EPZ communities will be relayed through the State Office of Emergency Management Area IV Coordinator.

2. Direct communications between the State and the Utility will be established between the site emergency operations facility and the State EOC (Department of Environmental Protection, Division of Radiation and through the Millstone Power Station (Dominion) Nuclear News Group).

3. Millstone Power Station (Dominion) dispatches a company representative to act as liaison to the State EOC in Hartford.

Areas Requiring Corrective Action (ARCA) 38-00-04-A-01: NEW- Problem of erratic readouts on Millstone issued pagers. (State BOC) 54

Extent of Placi

-M\1illstone Station FEMA Evaluated Plume Pathway Exercise May 1, 2002 Rev. January 25, 2002 Evaluation Area 1 - Emergency Operations Management Sub-element L.e Equipment and Supplies to Support Operations Previous Objective 5. Emergency Worker Exposure Control Previous Objective 14. Implementation of Protective Actions - KI for Emergency Workers, Institutionalized Individuals and the General Public (for KI inventory only)

INTENT This sub-element is derived from N-UREG-0654. which provides that OROs have emergency equipment and supplies adequate to support the emergency response.

EXTENT OF PLAY - GENERAL Equipment within the facility(ies) should be sufficient and consistent with the role assigned to that facility in the ORO's plans and/or procedures in support of emergency operations. Use of maps and displays is encouraged.

All instruments, including air sampling flow meters (field teams only), should be inspected.

inventoried, and operationally checked before each use. They should be calibrated in accordance with the manufacturer's recommendations (or at least annually for the unmodified CDV-700 series, or if there are no manufacturerfs recommendations for a specific instrument, modified CDV-700 instruments should be calibrated in accordance with the recommendation of the modification manufacture.). A label indicating such calibration should be on each instrument or be verifiable by other means. Note: Field team equipment is evaluated under 4.a. 1; radiological laboratory equipment is evaluated under 4.c. 1; Reception Center and emergency worker facilities' equipment is evaluated under 6.a. 1: and ambulance and medical facilities' equipment is evaluated under 6.d. 1.

Sufficient quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers should be available for issuance to all categories of emergency workers that could be deployed from that facility. Appropriate direct-reading dosimeters should allow individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans and procedures.

Dosimeters should be inspected for electrical leakage at least annually and replaced. if necessary.

CDV-138s. due to their documented history of electrical leakage problems. should be inspected for electrical leakage at least quarterly and replaced if necessary. This leakage testing will be verified during the exercise, through documentation submitted in the Annual Letter of Certification. and/or through a staff assistance visit.

55

Extent of Play

-A illstone Station FEMA Evaluated Phime Pathwav Exercise May 1. 2002 Rev. Januari 25, 2002 Sub-element 1.e. Equipment and Supplies to Support Operations (Continued)

MI sufficient for use by Responsible OROs should demonstrate the capability to maintain inventories of in capacity emergency workers. as indicated on rosters; institutionalized individuals, as indicated members of the general public lists for facilities; and. where stipulated by the plan and/or procedures, (including transients) within the plume pathway EPZ.

by physical Quantities of dosimetry and KI available and storage locations(s) will be confirmed submitted during the inspection at storage location(s) or through documentation of current inventory during a Staff exercise, provided in the Annual Letter of Certification submission, and/or verified date indicated on KI bottles Assistance Visit. Available supplies of KI should be within the expiration indicating that the KI or blister packs. As an alternative, the ORO may produce a letter from FEMA (FDA) guidance. FEMA supply remains potent. in accordance with Food and Drug Administration that performed the issues these letters based upon the findings of the certified independent laboratory analysis at the ORO's request and expense.

equipment (e.g.,

At locations where traffic and access control personnel are deployed, appropriate described.

vehicles, barriers, traffic cones and signs, etc.) should be available or their availability as they would be in an All activities must be based on the ORO's plans and procedures and completed of play agreement.

actual emergency, unless noted above or otherwise indicated in the extent EXTENT OF PLAY - SPECIFIC Dosimetry:

control has been

1. Each community and Connecticut State Police location involved in traffic a Permanent Record provided with emergency worker dosimetry packets. These packets include:

two self-reading Dosimeter or PRD (in lieu of a thermoluminescent dosimeter(TLD)) and dosimeters (SRD) in the OR (Roentgen) to 5R and the OR to 200R ranges.

leakage

2. Each direct-reading dosimeter has a sticker with the date of the last calibration/electrical test.

Potassium Iodide - KI:

iodide (KI) for

1. The State Radiological Emergency Response Plan outlines the use of potassium 1).

State emergency workers only in Section 10.3 of the basis document (Volume site town of Waterford.

2. The only EPZ community that uses KI for town emergency workers is the homes, or other

3. Under the State RERP plan. KI is not distributed to the general public, nursing institutionalized individuals.

Areas Requiring Corrective Action (ARCA)

EOC) 38-95-05-A-03: UNRESOLVED - Bus drivers were not issued dosimetry. (State 56

Extent of Play

-Millstone Station FEjL4 Evaluated Phlme Pathwiray Exercise May,1 2002 Rev. January 25, 2002 Evaluation Area 2 - Protective Action Decision-Making Sub-element 2.a. Emergency Worker Exposure Control Previous Objective 5. Emergency Worker Exposure Control Criterion 2.a.l: OROs use a decision-making process, considering relevant factors and appropriate coordination, to insure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides. (NUREG-0654, K.4.)

INTENT This sub-element is derived from NUREG-0654. which provides that an ORO have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place as specified in the ORO's plans and procedures to authorize emergency worker exposure limits to be exceeded for specific missions.

Radiation exposure limits for emergency workers are the recommended accumulated dose limits or exposure rates that emergency workers may be permitted to incur during an emergency. These limits include any' pre-established administrative reporting limits (that take into consideration Total Effective Dose Equivalent or organ-specific limits) identified in the ORO's plans and procedures.

EXTENT OF PLAY - GENERAL OROs authorized to send emergency workers into the plume exposure pathway EPZ should demonstrate a capability to meet the criterion based on their emergency plans and procedures.

Responsible OROs should demonstrate the capability to make decisions concerning the authorization of exposure levels in excess of pre-authorized levels and to the number of emergency workers receiving a radiation dose above pre-authorized levels.

As appropriate, OROs should demonstrate the capability to make decisions on the distribution and administration of KI, as a protective measure, based on the ORO's plan and/or procedures or projected thyroid dose compared with the established protective action guides (PAGs) for KI administration.

All activities must be based on the ORO's plans and procedures and completed. as they would be in an actual emergency. unless noted above or otherwise indicated in the extent of play agreement.

57

Extent of Play

-,1'illstoneStation FEAIA Evalhated Phlme Pathi-ra" Exercise av 1. 2002 Rer. January 25, 2002 Sub-element 2.a Emergency Worker Exposure Control (Continued)

EXTENT OF PLAY - SPECIFIC (No site-specific modifications.)

Areas Requiring Corrective Action (ARCA) 38-95-05-A-03: UNRESOLVED - Bus drivers were not issued dosimetry. (State EOC) 38-00-05-A-05: Personnel unfamiliar with Low and High Range Dosimeters. (East Lyme) 38-00-05-A-06: CDV-700 used in EOC was not calibrated within last 12 months. (Groton) 58

Extent of Play

-Millstone Station FEMA Evaluated Plume PaihiwaV Exercise May 1, 2002 Rev. January 25, 2002 Evaluation Area 2 - Protective Action Decision-Making Sub-element 2.b RAD Assessment - Protective Action Recommendations and Decisions Plume Phase Previous Objective 7. Plume Dose Projection Criterion 2.b.l: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions.

(NUREG-0654, 1.8., 10., 11. and Supplement 3.)

INTENT This sub-element is derived from NUREG-0654, which indicates that OROs have the capability to independently project integrated dose from exposure rates or other information and compare the estimated dose savings with the protective action guides. OROs have the capability to choose, among a range of protective actions. those most appropriate in a given emergency situation and base these choices on protective action guides (PAGs) from the ORO's plans and procedures, or EPA 400-R-92 001 and other criteria, such as, plant conditions, licensee protective action recommendations.

coordination of protective action decisions with other political jurisdictions (e.g., other affected OROs), availability of appropriate in-place shelter, weather conditions. evacuation time estimates, and situations that create higher than normal risk from evacuation.

EXTENT OF PLAY - GENERAL During the initial stage of the emergency response, following notification of plant conditions that may warrant off-site protective actions. the ORO should demonstrate the capability to use appropriate means.

described in the plan and/or procedures. to develop protective action recormnendations (PARs) for decision-makers based on available information and recommendations from the licensee and field monitoring data, if available.

When release and meteorological data are provided by the licensee, the ORO also considers these data.

The ORO should demonstrate a reliable capability to validate dose projections. The types of calculations to be demonstrated depend on the data available and the need for assessments to support the PARs appropriate to the scenario. In all cases. calculation of projected dose should be demonstrated. Projected doses should be related to quantities and units of the PAGs to which they will be compared. PARs should be promptly transmitted to decision-makers in a prearranged format.

Differences greater than a factor of 10 between projected doses by the licensee and the ORO should be discussed with the licensee with respect to the input data and the assumptions used in different models. or other possible reasons. Resolution of these differences should be incorporated into the PAR if timely and appropriate. The ORO should demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated PARs.

59

Extent of Pla),

-Millstone Station FEMA Evaluated Plume Pathway Exercise Mar 1, 2002 Rev. Januarv 25, 2002 Sub-element 2.b RAD Assessment - Protective Action Recommendations and Decisions Plume Phase (Continued)

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. DEP staff will perform dose projections at the State EOC with site-specific input from Dominion Nuclear Connecticut (DNC). The DNC staff at the EOF will perform parallel dose calculations for comparison and discussion with State staff. The DEP dose calculation staff will also receive frequently updated meteorological and radiological data via the DNC radiological staff.

2. Dose calculations will be demonstrated using dose assessment model computer codes.

Areas Requiring Corrective Action (ARCA)

(None) 60

Extent of Play

-Millstone Station FEMA Evaluated Plume Pathlirav Exercise Mai 1. 2002 Rev. January25. 2002 Evaluation Area 2 - Protective Action Decision-Making Sub-element 2.b RAD Assessment- Protective Action Recommendations and Decisions Plume Phase Previous Objective 9. Plume Protective Action Decision Making Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PADs) for the general public (including the recommendation for the use of KI, if ORO policy).

(NUREG-0654, J.9., 10.m.)

INTENT This sub-element is derived from NUREG-0654, which indicates that OROs have the capability to independently project integrated dose from exposure rates or other information and compare the estimated dose savings with the protective action guides. OROs have the capability to choose, among a range of protective actions. those most appropriate in a given emergency situation and base these choices on protective action guides (PAGs) from the ORO's plans and procedures. FRC Reports Numbers 5 and 7, or EPA 400-R-92-001 and other criteria, such as, plant conditions, licensee protective action recommendations, coordination of protective action decisions with other political jurisdictions (e.g., other affected OROs). availability of appropriate in-place shelter. weather conditions, evacuation time estimates. and situations that create higher than normal risk from evacuation.

EXTENT OF PLAY - GENERAL OROs should have the capability to make both initial and subsequent PADs. They should demonstrate the capability to make initial PADs within a timely manner appropriate to the situation. based on notification from the licensee, assessment of plant status and releases, and PARs from the Utility and ORO staff.

The dose assessment personnel may provide additional PARs based on the subsequent dose projections, field data. or information on plant conditions. The decision-makers should demonstrate the capability to change protective actions as appropriate based on these projections.

If the ORO has determined that KI will be used as a protective measure for the general public under off site plans. then the ORO should demonstrate the capability to make decisions on the distribution and administration of KI as a protective measure for the general public to supplement shelter and evacuation protective actions. This decision should be based on the ORO's plan and/or procedures or projected thyToid dose compared with the established PAG for KI administration. The KI decision-making process should involve close coordination with appropriate assessment and decision-making staff.

61

Extent of Play

-Millstone Station FEMA Evaluated Plume Pathway Exercise May 1, 2002 Reo. January 25. 2002 Sub-element 2.b RAD Assessment- Protective Action Recommendations and Decisions Plume Phase (Continued)

If more than one ORO is involved in decision-making, OROs should communicate and coordinate PADs with affected OROs. OROs should demonstrate the capability to communicate the contents of decisions to the affected jurisdictions.

All decision-making activities by ORO personnel must be performed based on the ORO's plans and procedures and completed. as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. Initial plume protective action decisions will be based on the exercise scenario emergency classification level and State posture codes as specified in the State Radiological Emergency Response Plan. The RERP provides for recommended actions for State and local officials that may be used during rapidly developing events. Specific decision-making criteria, including the influence of extenuating factors such as environmental conditions, plant conditions, and established radiological thresholds. are provided in the RERP for both State and local officials. Inputs. such as Utility protective action recommendations. will also be used/considered in decision-making.

the

2. When the EOF is activated, its staff will forward Utility protective action recommendations to State EOC.

3. The State EOC. as specified in the RERP, will direct and coordinate protective action implementation through State and local agencies.

4. KI is not used for the general public per Section 10.3 of the RERP.

5. EPZ towns may implement their own local PADs. However, any PADs made must be communicated to the State EOC.

Areas Requiring Corrective Action (ARCA)

(None) 62

Extent of Play

-Millstone Station FEMA Evaluated Plume Pathwiiay Exercise May 1. 2002 Rev. Januarv 25, 2002 Evaluation Area 2 - Protective Action Decision-Making Sub-element 2.c PADs Consideration of Protective Actions for Special Populations Previous Objective 15. Implementation of Protective Actions - Special Populations Criterion 2.c.1: Protective action decisions are made, as appropriate, for special population groups. (NUREG-0654, J.9., 10.c., d., e., g.)

INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to determine protective action recommendations, including evacuation, sheltering, and use of potassium iodide (KI). if applicable, for special population groups (e.g., hospitals. nursing homes. correctional facilities, schools, licensed day care centers, mobility impaired individuals, and transportation dependent individuals). Focus is on those special population groups that are (or potentially will be) affected by a radiological release from a nuclear power plant.

EXTENT OF PLAY - GENERAL Usually, it is appropriate to implement evacuation in areas where doses are projected to exceed the lower end of the range of PAGs, except for situations in which there is a high-risk environment or in which high-risk groups (e.g., the immobile or infirm) are involved. In these cases, examples of factors that should be considered are weather conditions. shelter availability, evacuation time estimates, availability of transportation assets, risk of evacuation vs. risk from the avoided dose. and precautionary school evacuations. In situations in which an institutionalized population cannot be evacuated, the administration of KI should be considered by the OROs.

All decision-making activities associated with protective actions, including consideration of available resources. for special population groups must be based on the ORO's plans and procedures and completed. as they would be in an actual emergency. unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. KI is not used for special populations per Section 10.3 of the State RERP.

Area Requiring Corrective Action (ARCA)

(None) 63

Extent of Play

-Millstone Station FEMA Evaluated Phlme Pathwn av Exercise Mayi 1. 2002 Rev. January 25. 2002 Evaluation Area 3 - Protective Action Implementation Sub-element 3.a Implementation of Emergency Worker Exposure Control Previous Objective 5. Emergency Worker Exposure Control Criterion 3.a.l: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans and procedures.

Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. (NUREG-0654, K.3.)

INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimeters and permanent record dosimeters; provide for direct-reading dosimeters to be read at appropriate frequencies by emergency workers; maintain a radiation dose record for each emergency worker: and provide for establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of protective action guides. always applying the ALARA (As Low As is Reasonably Achievable) principle as appropriate.

EXTENT OF PLAY - GENERAL OROs should demonstrate the capability to provide appropriate direct-reading and permanent record dosimetry, dosimetry chargers, and instructions on the use of dosimetry to emergency workers. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows individual(s) to read the administrative reporting limits (that are pre-established at a level low enough to consider subsequent calculation of Total Effective Dose Equivalent) and maximum exposure limits (for those emergency workers involved in life saving activities) contained in the ORO's plans and procedures.

Each emergency worker should have the basic knowledge of radiation exposure limits as specified in the ORO's plan and/or procedures. Procedures to monitor and record dosimeter readings and to manage radiological exposure control should be demonstrated. During a plume phase exercise, emergency workers should demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. The emergency worker should report accumulated exposures during the exercise as indicated in the plans and procedures. OROs should demonstrate the actions described in the plan and/or procedures by determining whether to replace the worker, to authorize the worker to incur additional exposures or to take other actions. If scenario events do not require emergency workers to seek authorizations for additional exposure. evaluators should interview at least two emergency workers. to determine their knowledge of whom to contact in the event authorization is needed and at what exposure levels. Emergency workers may use any available resources (e.g..

written procedures and/or co-workers) in providing responses.

64

Extent of'Plav'

-Millstone Station FEMA Evaluated Plume Pathway Exercise May 1. 2002 Rev. January 25. 2002 Sub-element 3.a Implementation of Emergency Worker Exposure Control (Continued)

Although it is desirable for each emergency workers to have a direct-reading dosimeter, there may be situations in which team members will be in close proximity to each other during the entire mission and adequate control of exposure can be effected for all members of the team by one dosimeter worn by the team leader. Emergency workers who are assigned to low exposure rate areas (e.g., at reception centers, counting laboratories, emergency operations centers, and communications centers) may have individual direct-reading dosimeters or they, may be monitored by dosimeters strategically placed in the work area. It should be noted that, even in these situations. each team member must still have their own permanent record dosimeter.

Individuals without specific radiological response missions. such as farmers for animal care, essential utility service personnel, or other members of the public who must re-enter an evacuated area following or during the plume passage, should be limited to the lowest radiological exposure commensurate with completing their missions.

All activities must be based on the ORO's plans and procedures and completed as they would be in an actual emergency. unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. Each community has been provided with emergency worker dosimetry packets. These packets include: a Permanent Record Dosimeter and two self-reading dosimeters (SRD) in the OR to 5R and the OR to 200R ranges. (PRDs have replaced TLDs.)

2. One dosimetry packet will be issued to each emergency worker who is leaving any EOC. In addition, in each EOC, one staff member will be issued one dosimetry packet to represent those issued to all appropriate personnel. The EOC worker issued a packet will demonstrate dosimetry turn-in and necessary paperwork. Evaluators will be shown a stockpile of dosimetry packages that will represent a sufficient supply for all emergency workers required to wear them.

3. Emergency worker exposure control training, including a basic knowledge of exposure control procedures (turn-back values, call-in values, and periodic monitoring), may be demonstrated through evaluator interviews.

4. Emergency workers will discuss procedures to be followed in the event that exposure limits or turn back values are achieved. Controller inject will be used to prompt demonstration of these procedures.

5. KI is issued only to State emergency workers and to town emergency workers in the site town of Waterford per Section 10.3 of the State RERP.

Areas Requiring Corrective Action (ARCA)

(None) 65

Extent of Play

-.\fillstone Station FEMA Evaluated Plume Pathwai Exercise AMav 1. 2002 Rev. January 25, 2002 Evaluation Area 3 - Protective Action Implementation Sub-element 3.b Implementation of KI Decision Previous Objective 14. Implementation of Protective Actions - KI for Emergency Workers, Institutionalized Individuals and the General Public Criterion 3.b.l: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals (not the general public) is maintained. (NUREG-0654, E. 7.; J. 10. e., f.)

INTENT This sub-element is derived from NUREG-0654. which provides that OROs should have the capability to provide radioprotective drugs for emergency workers, institutionalized individuals, and, if in the plan and/or procedures. to the general public for whom immediate evacuation may not be feasible, very difficult. or significantly delayed. While it is necessary for OROs to have the capability to provide KI to emergency workers and institutionalized individuals, the provision of KI to the general public is an ORO option, reflected in the ORO's plans and procedures. Provisions should include the availability of adequate quantities, storage, and means to the distribute radioprotective drugs.

EXTENT OF PLAY - GENERAL OROs should demonstrate the capability to make KI available to emergency workers. institutionalized individuals, and, where provided for in the ORO plan and/or procedures, to members of the general public. OROs should demonstrate the capability to accomplish distribution of KI consistent with decisions made. Organizations should have the capability to develop and maintain lists of emergency workers and institutionalized individuals who have ingested KI. including documentation of the date(s) and time(s) they were instructed to ingest KI. The ingestion of KI recommended by the designated ORO health official is voluntary. For evaluation purposes. the actual ingestion of KI is not necessary.

OROs should demonstrate the capability to formulate and disseminate appropriate instructions on the use of KI for those advised to take it. If a recommendation is made for the general public to take KI, appropriate information should be provided to the public by the means of notification specified in the ORO's plan and/or procedures.

Emergency workers should demonstrate the basic knowledge of procedures for the use of K! ,whether or not the scenario drives the use of KI. This can be accomplished by an interview with the evaluator.

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency. unless noted above or otherwise indicated in the extent of play agreement.

66

Extent of Play

-Millstone Station FEMA Evaluated Plume Pathiway Exercise May 1. 2002 Rev. January 25, 2002 F (Continued)

EXTENT OF PLAY - SPECIFIC

1. The State Radiological Emergency Response Plan discusses the issue of potassium iodide policy and implementation in Section 10.3 of the basis document (Volume 1).

2. The State of Connecticut KI policy provides for the use of KI by State emergency workers only.

The State policy does not provide for issuance of KI to the general public.

33. The only EPZ community that stockpiles and issues KI to its emergency workers is the site town of Waterford.

4. The use of KI by people who are institutionalized has not been recommended by the Connecticut Public Health Department per Section 10.3 of the State RERP.

5. State emergency workers with assigned duties inside the plume exposure EPZ take one tablet of KI when responding to an incident classification GENERAL EMERGENCY Posture Code Alpha, unless they are otherwise instructed.

6. The State Public Health Commissioner makes the decision regarding the use of KI, based on the recommendation made by the State Department of Environmental Protection. Division of Radiation.

Areas Requiring Corrective Action (ARCA)

(None) 67

Extent of Play

-MA illstone Station FEMA EvaluatedPlume Pathwi ay Exercise May 1. 2002 Rev. January 25. 2002 Evaluation Area 3 - Protective Action Implementation Sub-element 3.c Implementation of Protective Actions - Special Populations Previous Objective 15. Implementation of Protective Actions - Special Populations Criterion 3.c.1: Protective action decisions are implemented for special population groups, other than schools, within areas subject to protective actions. (NUREG-0654, E.7.;

J.9., 1O.c.,d.,e.,g.)

INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to implement protective action decisions, including evacuation and/or sheltering, for all special populations. Focus is on those special populations that are (or potentially will be) affected by a radiological release from a nuclear power plant.

EXTENT OF PLAY - GENERAL Applicable OROs should demonstrate the capability to alert and notify (e.g.. provide protective action recormiendations and emergency information and instructions) special populations (hospitals. nursing homes. correctional facilities, mobility impaired individuals, transportation dependent. etc). OROs should demonstrate the capability to provide for the needs of special populations in accordance with the ORO's plans and procedures.

Contact with special populations and reception facilities may be actual or simulated. as agreed to in the extent of play. Some contacts with transportation providers should be actual. as negotiated in the extent of play. All actual and simulated contacts should be logged.

All implementing activities associated with protective actions for special populations must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency. unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. Department of Corrections EOC liaison will demonstrate contacting the Gates and York Correctional facilities in Niantic (identified jointly as the Niantic Correctional Institution in the State RERP). NOTE: The State EOC evaluator wmill interview the Departmentof Corrections liaison as to actions taken/implemented at the Niantic Correctional.facilities.The State Public Health Department. through the EOC liaison and their own EOC, will simulate contacting nursing facilities within the plume EPZ.

2. Communities will demonstrate this objective by table-top discussion to include: identification of special needs populations, transportation requirements, and the coordination of activities with the State OEM to obtain additional transportation resources as necessary.

68

Extent of Pla'

-Millstone Station FEA1L4 Evaluated PluMe Pathway Exercise May 1. 2002 Rev. Janutary 25, 2002 Sub-element 3.c Implementation of Protective Actions - Special Populations (Continued)

3. During the week of 4/29/02. three pre-designated specialized nursing care facilities will be surveyed to discuss their emergency procedures. The designated nursing homes include: Mariner in East Lyme. Camelot in New London, and Mystic Manor in Groton.

Area Requiring Corrective Action (ARCA)

(None) 69

Extent of Play

-Millstone Station FEMA Evaluated Phlme Pathwtav Exercise May 1, 2002 Rev. Jainarly25, 2002 Evaluation Area 3 - Protective Action Implementation Sub-element 3.c Implementation of Protective Actions - Special Populations Previous Objective 16. Implementation of Protective Actions - Schools Criterion 3.c.2: OROs/School officials decide upon and implement protective actions for schools. (NUREG-0654, J.10.c., d., g.)

INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to implement protective action decisions, including evacuation and/or sheltering, for all special populations. Focus is on those special population groups that are (or potentially will be) affected by a radiological release from a nuclear power plant.

EXTENT OF PLAY - GENERAL Applicable OROs should demonstrate the capability to alert and notify all public school systems/districts.

licensed day care centers, and participating private schools within the emergency planning zone of emergency conditions that are expected to or may necessitate protective actions for students.

In accordance with plans and/or procedures, OROs and/or officials of participating public and private schools and licensed day care centers should demonstrate the capability to make and implement prompt decisions on protective actions for students. Officials should demonstrate that the decision-making process for protective actions considers (e.g., either accepts automatically or gives heaxy weight to) protective action recommendations made by ORO personnel, the ECL at which these recommendations are received, preplanned strategies for protective actions for that ECL. and the location of students at the time (e.g., whether the students are still at home, en route to the school. or at the school).

Implementation of protective actions should be completed subject to the following provisions: At least one school in a school system or district within the EPZ. as appropriate, needs to demonstrate the implementation of protective actions. The implementation of canceling the school day. dismissing early, or sheltering should be simulated by describing to evaluators the procedures that would be followed. If evacuation is the implemented protective action, all activities to coordinate and complete the evacuation of students to reception centers, congregate care centers. or host schools may actually be demonstrated or accomplished through an interview process. If accomplished through an interview process, appropriate school personnel, including decision-making officials (e.g.,

superintendent/principal, transportation director/bus dispatcher), and at least one bus driver (and the bus driver's escort. if applicable) should be available to demonstrate knowledge of their roles in the evacuation of school children. Communications capabilities between school officials and the buses. if required by the plan and/or procedures, should be verified.

70

Extent of Play

-Millstone Station FEMA Evaluated Plume Pathway Exercise May 1, 2002 Rev. Jantarv25, 2002 Sub-element 3.c Implementation of Protective Actions - Special Populations (Continued)

Officials of the participating school(s) or school system(s) should demonstrate the capability to develop and provide timely information to OROs for use in messages to parents, the general public, and the media on the status of protective actions for schools.

All activities must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless specified above or indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. To start the new six year cycle, the following three selected communities will demonstrate and discuss the ability and resources necessary to implement protective actions for school children:

• Fishers Island

• Groton City/Town (Both share same education department.)

• Montville

2. Appropriate activities associated with the demonstration of school protective actions will be discussed/simulated in those EPZ communities affected by the scenario plume on 5/1/02.

3. During the week of April 29, 2002. the towns of Fishers Island. Groton City/Town and Montville will conduct a discussion of their plans with the respective school superintendents and one designated school principal in each district. One vehicle will be dispatched to the pre-designated host communities: Norwich (for the Grotons) and East Hartford (for Montville). The vehicle demonstration does not apply to Fishers Island since school evacuees walk to the Fishers Island ferry and control of evacuees is transferred to the State once the ferry docks in Connecticut.

Area Requiring Corrective Action (ARCA)

(None) 71

Extent of Play

-Millstone Station FEMA Evaluated Plume Pathwait a Exercise Maiy 1, 2002 Rev. January 25. 2002 Evaluation Area 3 - Protective Action Implementation Sub-element 3.d Implementation of Traffic and Access Control -TCP/ACP are established Protective Objective 17. Traffic and Access Control Criterion 3.d.l: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654, J.10.g., j., k.)

INTENT This sub-element is derived from NUREG-0654, which provides that OROs have the capability to implement protective action plans. including relocation and restriction of access to evacuated areas.

This sub-element focuses on selecting, establishing, and staffing of traffic and access control points and removal of impediments to the flow of evacuation traffic.

EXTENT OF PLAY - GENERAL OROs should demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with evacuation/sheltering decisions (for example evacuating, sheltering, and relocation), in a timely manner. OROs should demonstrate the capability to provide instructions to traffic and access control staff on actions to take when modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled.

Traffic and access control staff should demonstrate accurate knowledge of their roles and responsibilities. This capability may be demonstrated by actual deployment or by interview in accordance with the extent of play agreement.

In instances in which OROs lack authority necessary to control access by certain types of traffic (rail.

water, and air traffic), they should demonstrate the capability to contact the State or Federal agencies with authority to control access.

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency. unless specified above or indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC I. Decision-making activities at the State and local EOCs to determine and implement initial traffic access and control points will be discussed if the EPZ town is in the scenario plume wind.

Coordination and implementation of Connecticut's traffic management plan is a State Police responsibility.

2. The State police liaison in the State EOC will direct implementation of the plan by the State Police barracks in the affected area. Each barracks assigns troopers or officers to control points within its jurisdiction.

72

Extent of Play

-Millstone Slation FEMA Evaluated Plume Pathiway Exercise aoy 1, 2002 Rev. Jamnarv 25, 2002 Sub-element 3.d Implementation of Traffic and Access Control -TCP/ACP are established (Continued)

3. Local EOC staff will discuss the establishment of traffic control points within their respective communities. Since this is a scenario-driven criterion, EPZ municipalities with a full-time paid police force (Groton City, Groton Town, New London, and Waterford) will discuss the establishment of traffic and access control points if they are in the exercise scenario plume pathway. All other EPZ cormnunities are covered by the State Police.

4. Actual/physical implementation of traffic control points will not be demonstrated. However, barrier materials will be observed by FEMA evaluators after the plume phase. Towns using Resident State Police Officers will arrange for FEMA evaluators to view State DOT barrier materials at the end of the exercise.

Area Requiring Corrective Action (ARCA)

(None) 73

Extent of Play

-Millstone Station FEM41A Ei-aluated Plume Pathwaiy Exercise May 1. 2002 Rev. Januiary 25. 2002 Evaluation Area 3 - Protective Action Implementation Sub-element 3.d Implementation of Traffic and Access Control -TCP/ACP are established Previous Objective 17. Traffic and Access Control Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654, J.10., k.)

INTENT This sub-element is derived from NUREG-0654, which provides that OROs have the capability to implement protective action plans, including relocation and restriction of access to evacuated areas. This sub-element focuses on selecting, establishing, and staffing of traffic and access control points and removal of impediments to the flow of evacuation traffic.

EXTENT OF PLAY - GENERAL OROs should demonstrate the capability, as required by the scenario, to identify and take appropriate actions concerning impediments to evacuation. Actual dispatch of resources to deal with impediments, such as wreckers, need not be demonstrated; however, simulated contacts should be logged.

All activities must be based on the ORO's plans and procedures and completed. as they would be in an actual emergency, unless specified above or indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. State Police and Department of Transportation officials will discuss the process of securing additional resources, such as tow trucks, required to move traffic impediments.

2. Since this is a scenario-driven criterion, EPZ municipalities with a full-time paid police force (Groton City, Groton Town, New London, and Waterford) will discuss the process of securing additional resources, such as tow trucks, required to move traffic impediments. All other EPZ communities are covered by the State Police.

3. A control cell will inject two State and two local impediment events during the exercise.

Area Requiring Corrective Action (ARCA)

(None) 74

Extent of Pl/ai

-Millstone Station FEMA Evaluated Phlne Pathwiay Exercise May 1, 2002 Rev. January 25, 2002 Evaluation Area 4 - Field Measurement and Analysis Sub-element 4.a Plume Phase field teams are equipped to perform measurement Previous Objective 6. Field Radiological Monitoring - Ambient Radiation Monitoring Criterion 4.a.l: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates. (NUREG-0654, H.10; 1.8., 9., 11.)

INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to deploy field teams with the equipment. methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654 indicates that OROs should have the capability to use field teams within the plume emergency planning zone to measure airborne radioiodine in the presence of noble gases and to measure radioactive particulate material in the airborne plume.

In the event of an accident at a nuclear power plant, the possible release of radioactive material may pose a risk to the nearby population and environment. Although accident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties. During an accident, it is important to collect field radiological data in order to help characterize any radiological release. This does not imply that plume exposure projections should be made from the field data. Adequate equipment and procedures are essential to such field measurement efforts.

EXTENT OF PLAY - GENERAL Field teams should be equipped with all instruments and supplies necessary to accomplish their missions. This should include instruments capable of measuring gamma exposure rates and detecting the presence of beta radiation. These instruments should be capable of measuring a range of activity and exposure. including radiological protection/exposure control of team members and detection of activity on the air sample collection media, consistent with the intended use of the instrument and the ORO's plans and procedures. An appropriate radioactive check source should be used to verify proper operational response for each low range radiation measurement instrument (less than 1 R/hr) and for high range instruments when available. If a source is not available for a high range instrument, a procedure should exist to operationally test the instrument before entering an area where only a high range instrument can make useful readings.

All activities must be based on the ORO's plans and procedures and completed. as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

75

Extent of Play

-Millstone Station FEMA Ei-aluatedPlume Pathw ay Exercise Mai 1, 2002 Rev. Janmary 25, 2002 Sub-element 4.a Plume Phase field teams are equipped to perform measurement (Continued)

EXTENT OF PLAY - SPECIFIC

1. Air sample cartridges used during the exercise have been specifically designated for drill or exercise use only. These cartridges may be used more than once during the exercise. The inventory of air sample cartridges to be used in an actual emergency is located at the DEP in Hartford, at the Millstone Power Station, and at the Montville State Police barracks. The actual inventory list will be made available.

Area Requirino Corrective Action (ARCA)

(None) 76

Extent of Play

-Millstone Station FEMA EvaluatedPhlme Pathway Exercise "Way 1, 2002 Rev. Januar3,25, 2002 Evaluation Area 4 - Field Measurement and Analysis Sub-element 4.a Plume Phase Field Teams Collected Data Previous Objective 8. Field Radiological Monitoring - Airborne Radioiodine and Particulate Activity Monitoring Criterion 4.a.2: Field teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654, 1.8., 11.; J.10.a).

INTENT This sub-element is derived from NUREG-0654. which provides that OROs should have the capability to deploy field teams with the equipment. methods. and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654 indicates that OROs should have the capability to use field teams within the plume emergency planning zone to measure airborne radioiodine in the presence of noble gases and to measure radioactive particulate material in the airborne plume.

In the event of an accident at a nuclear power plant. the possible release of radioactive material may pose a risk to the nearby population and environment. Although accident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties. During an accident, it is important to collect field radiological data in order to help characterize any radiological release. This does not imply that plume exposure projections should be made from the field data. Adequate equipment and procedures are essential to such field measurement efforts.

EXTENT OF PLAY - GENERAL Responsible OROs should demonstrate the capability to brief teams on predicted plume location and direction, travel speed. and exposure control procedures before deployment. Field measurements are needed to help characterize the release and to support the adequacy of implemented protective actions or to be a factor in modiflying protective actions. Teams should be directed to take measurements in such locations, at such times to provide inforimation sufficient to characterize the plume and impacts.

If the responsibility to obtain peak measurements in the plume has been accepted by licensee field monitoring teams, with concurrence from OROs. there is no requirement for these measurements to be repeated by State and local monitoring teams. If the licensee teams do not obtain peak measurements in the plume, it is the ORO's decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coordination of plume measurement information among all field teams (licensee, Federal. and ORO ) is essential. Coordination concerning transfer of samples, including a chain-of-custody form. to a radiological laboratory should be demonstrated.

77

Extent of Play

-Millstone Station FEMA Evaluated Plume Pathwi1'cn Exercise May 1, 2002 Rev. January.25. 2002 Sub-element 4.a Plume Phase Field Teams Collected Data (Continued)

OROs should use Federal resources as identified in the Federal Radiological Emergency Response Plan (FRERP), and other resources (e.g.. compacts. etc.), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC (No site-specific modifications.)

Area Requirin2 Corrective Action (ARCA)

(None) 78

Extent of Play

-A illstone Station FEMA Evaluated Plume Pathwayv Exercise May 1. 2002 Rev. January 25, 2002 Evaluation Area 4 - Field Measurement and Analysis Sub-element 4.a Radiation Measured and Samples Collected Previous Objective 6. Field Radiological Monitoring - Ambient Radiation Monitoring Previous Objective 8. Field Radiological Monitoring - Airborne Radioiodine and Particulate Activity Monitoring Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654, 1.8., 9., 11.)

INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to deploy field teams with the equipment. methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NLTREG-0654 indicates that OROs should have the capability to use field teams within the plume emergency planning zone to measure airborne radioiodine in the presence of noble gases and to measure radioactive particulate material in the airborne plume.

In the event of an accident at a nuclear power plant, the possible release of radioactive material may pose a risk to the nearby population and environment. Although accident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties. During an accident. it is important to collect field radiological data in order to help characterize any radiological release. This does not imply that plume exposure projections should be made from the field data. Adequate equipment and procedures are essential to such field measurement efforts.

EXTENT OF PLAY - GENERAL Field teams should demonstrate the capability to report measurements and field data pertaining to the measurement of airborne radioiodine and particulates to the field team coordinator, dose assessment, or other appropriate authority. If samples have radioactivity significantly above background. the appropriate authority should consider the need for expedited laboratory analyses of these samples.

OROs should share data in a timely manner with all other appropriate OROs. The methodology.

including contamination control. instrumentation, preparation of samples. and a chain-of-custody form for transfer to a laboratory, will be in accordance with the ORO plan and/or procedures.

79

Extent of Play

-Millstone Station FEMA Evaluated Plume Pathiray Exercise Mal" 1, 2002 Rev. Januarv 25. 2002 Sub-element 4.a Radiation Measured and Samples Collected (Continued)

OROs should use Federal resources as identified in the FRERP, and other resources (e.g.. compacts, etc.).

if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

EXTENT OF PLAY - SPECIFIC

1. Teams using provided equipment and procedures will demonstrate field radiation measurements in accordance with the RERP Field monitoring teams will be pre-staged and dispatched from State Police Troop E (Montville) barracks.

2. DEP will deploy two, 2-person field teams who will determine plume characteristics by field measurements.

.3. Pre-selected reference points demonstrated during the exercise in a given area will be a function of wind speed and direction, distance from the nuclear power facility, topography, population density, and accessibility by road.

4. Each DEP Field Monitoring Team will be dispatched to three sampling points where they will take radiation (dose rate) measurements and report them to their Field Team Controller (FTC). The FTC will direct that air samples (particulate and iodine) be taken at two locations where the simulated exposure rate indicates plume immersion and/or where a dose rate of 30 mRlhr, as indicated by controller inject, represents the plume center line.

Area Requirina Corrective Action (ARCA)

(None) 80

Extent of Play

-Millstone Station FEMA Evaluated Plume Pathiway Exercise Mall 1, 2002 Rev. January 25, 2002 Evaluation Area 5 - Emergency Notification and Public Information Sub-element 5.a Primary Alert Completed in Timely Manner Previous Objective 10. Alert and Notification Criterion 5.a.l: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum: (1) identification of the State or local government organization and the official with the authority for providing the alert signal and instructional message; (2) identification of the commercial nuclear power plant and a statement that an emergency situation exists at the plant; (3) reference to REP-specific emergency information (e.g., brochures and information in telephone books) for use by the general public during an emergency; and (4) a closing statement asking the affected and potentially affected population to stay tuned for additional information. (10 CFR Part 50, Appendix E & NUREG-0654, E. 1., 4., 5., 6., 7.)

INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to provide prompt instructions to the public within the plume pathway EPZ. Specific provisions addressed in this sub-element are derived from the NRC regulations (10 CFR Part 50, Appendix E.1V.D.), and FEMA-REP-10, "Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants."

EXTENT OF PLAY - GENERAL Responsible OROs should demonstrate the capability to sequentially provide an alert signal followed by an initial instructional message to populated areas (permanent resident and transient) throughout the 10 mile plume pathway EPZ. Following the decision to activate the alert and notification system, in accordance with the ORO's plan and/or procedures. completion of system activation should be accomplished in a timely manner (will not be subject to specific time requirements) for primary alertina./notification. The initial message should include the elements required by current FEMA REP guidance.

For exercise purposes. timely is defined as "the responsible ORO personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay." If message dissemination is to be identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

81

Extent of Pla/'

-Millstone Station FEMA Evalhiated Plume Pathiway Exercise May 1, 2002 Rev. JaCuary 25. 2002 Sub-element 5.a Primary Alert Completed in Timely Manner (Continued)

Procedures to broadcast the message should be fully demonstrated as they wvould in an actual emergency up to the point of transmission. Broadcast of the message(s) or test messages is not required. The alert signal activation may be simulated. However, the procedures should be demonstrated up to the point of actual activation.

The capability of the primary notification system to broadcast an instructional message on a 24-hour basis should be verified during an interview with appropriate personnel from the primary notification system.

All activities for this criterion must be based on the ORO's plans and procedures and completed. as they would be in an actual emergency. except as noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. Activation of the public alerting systems (PAS) (sirens) will be simulated.

2. Alert and notification activities leading to EAS simulation and the release of EAS messages will be demonstrated. Local officials would then simulate activation of their public alerting system to precede an instructional message release.

3. Activation of the EAS will occur at State OEM only. However, actual transmission of EAS messages to the public will be simulated. The State RERP does not permit activation of EAS by local CEOs after the Governor declares a State of Emergency.

4. Demonstration of all EAS activities will include: selection of the EAS message to be broadcast, arranging communications with the appropriate EAS station for message transmission. and simulated narration of the selected message.

5. Additional information and amplified instructions, in the form of press releases and news advisories, will supplement EAS messages.

6. In accordance with the new FEMA evaluation criteria, the "15 minute clock" noted in the EAS Coordinator's Procedures, OEM-8, of the CTAgencv Procedureswill not be implemented. but rather, primary alert will be completed in a "timely manner."

Area Requiring Corrective Action (ARCA)

(None) 82

Extent of Play

-Millstone Station FEMA Evaluated Plume Pathirai Exercise May 1, 2002 Rev. Jamnraiv 25, 2002 Evaluation Area 5 - Emergency Notification and Public Information Sub-element 5.a Notification of Exception Areas and/or Back-up Alert and Notification System within 45 minutes Previous Objective 10. Alert and Notification Criterion 5.a.3: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. Backup alert and notification of the public is completed within 45 minutes following the detection by the ORO of a failure of the primary alert and notification system. (NUREG-0654, E. 6.;

Appendix 3.B.2.c)

INTENT This sub-element is derived from NUREG-0654. which provides that OROs should have the capability to provide prompt instructions to the public within the plume pathway EPZ. Specific provisions addressed in this sub-element are derived from the Nuclear Regulatory Commission (NRC) regulations (10 CFR Part 50, Appendix E.IV.D.) and FEMA-REP-10. "Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants."

EXTENT OF PLAY - GENERAL OROs with FEMA-approved exception areas (identified in the approved Alert and Notification System Design Report) five to 10 miles from the nuclear power plant should demonstrate the capability to accomplish primary alerting and notification of the exception area(s) within 45 minutes following the initial decision by authorized off-site emergency officials to notify the public of an emergency situation. The 45-minute clock will begin when the OROs make the decision to activate the alert and notification system for the first time for a specific emergency situation. The initial message should, at a minimum, include: a statement that an emergency exists at the plant and where to obtain additional information.

For exception area alerting. at least one route needs to be demonstrated and evaluated. The selected routes should vary from exercise to exercise. However, the most difficult route should be demonstrated at least once every six years. All alert and notification activities along the route should be simulated (e.g., the message that would actually be used is read for the evaluator, but not actually broadcast) as agreed upon in the extent of play. Actual testing of the mobile public address system xill be conducted at some agreed upon location.

83

Extent of Play

-M illstone Station FE.AL4 Eva/iated P/ime Pathwi ay Exercise Mvfaf1. 2002 Rev. Jaiuari,25. 2002 Sub-element 5.a Notification of Exception Areas and/or Back-up Alert and Notification System within 45 minutes (Continued)

Back-up alert and notification of the public should be completed within 45 minutes following the detection by the ORO of a failure of the primary alert and notification system. Back-up route alerting needs only be demonstrated and evaluated, in accordance with the ORO's plan and/or procedures and the extent of play agreement, if the exercise scenario calls for failure of any portion of the primary system(s), or if any portion of the primary system(s) actually fails to function. If demonstrated. only one route needs to be selected and demonstrated. All alert and notification activities along the route should be simulated (e.g., the message that would actually be used is read for the evaluator, but not actually broadcast) as agreed upon in the extent of play. Actual testing of the Public Address system will be conducted at some agreed upon location.

EXTENT OF PLAY - SPECIFIC

1. There are no Exception Areas within the Millstone EPZ.

Area Requiring Corrective Action (ARCA)

(None) 84

Extent of Play

-Millstone Station FEMA Evaluated P/ume Pathway Exercise May 1, 2002 Rev. Januarv 25. 2002 Evaluation Area 5 - Emergency Notification and Public Information Sub-element 5.b Notification of Information to Public in a Timely Manner Previous Objective 11. Public Instructions and Emergency Communications Previous Objective 12. Emergency Information - Media Previous Objective 13. Emergency Information - Rumor Control Criterion 5.b.l: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E. 5., 7.; G.3.a.,

G.4.,a.,b.,c.)

INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to disseminate to the public appropriate emergency information and instructions including any recommended protective actions. In addition, NUREG-0654 provides that OROs should ensure that the capability exists for providing information to the media. This includes the availability of a physical location for use by the media during an emergency. NUREG-0654 also provides that a system be available for dealing with rumors. This system will hereafter be known as the Public Inquiry Hotline.

EXTENT OF PLAY - GENERAL Subsequent emergency information and instructions should be provided to the public and the media in a timely manner (will not be subject to specific time requirements). For exercise purposes, timely is defined as "-theresponsible ORO personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay." If message dissemination is to be identified as not having been accomplished in a timely manner. the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

The OROs should ensure that emergency information and instructions are consistent with protective action decisions made by appropriate officials. The emergency information should contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes. reception center locations, wN-hat to take when evacuating, information concerning pets. shelter-in-place instructions.

information concerning protective actions for schools and special populations. public inquiry telephone number, etc.) to assist the public in carrying out protective action decisions provided to them. OROs should demonstrate the capability to use language that is clear and understandable to the public within both the plume and ingestion pathway EPZs. This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas.

85

Extent of Play

-Millstone Station FEWA Evaluated P/ume Pathiay,Exercise May 1. 2002 Rev. Janum'ary 25. 2002 Sub-element 5.b Notification of Information to Public in a Timely Manner (Continued)

EXTENT OF PLAY - SPECIFIC Public Instructions and Emergency Communications:

1. Protective action implementation will be initiated and coordinated by the State OEM through transmission to its Area office and subsequent relaying to the affected local governments.

2. The State RERP does not permit activation of EAS by local CEOs after the Governor declares a State of Emergency.

in

3. Local governments may choose to develop and simulate release of their own news advisories their respective towns. Activation of a Joint Media Center at the State Armory will be demonstrated. Representatives from the Governor's press office and the Utility public information of group will be present. This activity will include: distribution of media kits, detailed discussion protective actions, site remedial actions, instructional messages and press release copy distribution, use of plant equipment graphic displays during briefings, and internal coordination of media information prior to its release.

Rumor Control (Informational Call Line):

cell

1. A control cell will initiate rumors into the system at the State and Utility level. The control rumor will demonstrate this criteria by the insertion of approximately six rumors per hour to each State control staff person (excluding the rumor control supervisor) beginning after the Governor's of Emergency declaration. There will be four rumor control staff members and one supervisor.

updates,

2. Demonstrated rumor control activities will include securing current information, receiving and relaying information to callers.

EAS operability

3. Since actual EAS broadcasts will not be made, monitoring of the EAS stations and testing will be demonstrated/simulated in the EAS room (operability testing) and the State Joint Media Center (monitoring).

Areas Requiring Corrective Action (ARCA) 38-00-1 l-A-02: The wording of statements in some press releases was subject to misinterpretation.(State EOC) and media 38-00-12-A-03: Status boards in the Joint Media Center were not consistently maintained representatives were not being consistently apprised of plant status. (State EOC) 87

Extent of Plai

-Millstone Station FEMA Eva/nated Plume Pathway Exercise May 1. 2002 Rei. January 25, 2002 Sub-element 5.b Notification of Information to Public in a Timely Manner (Continued)

The emergency information should be all-inclusive by including previously identified protective action areas that are still valid as well as new areas. The OROs should demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media.

In addition, the OROs should demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plan and/or procedures.

OROs should demonstrate the capability to develop emergency information in a non-English language when required by the plan and/or procedures.

If ingestion pathway measures are exercised. OROs should demonstrate that a system exists for rapid dissemination of ingestion pathway information to pre-determined individuals and businesses in accordance with the ORO's plan and/or procedures.

OROs should demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the situation warrants. The OROs should demonstrate the capability to respond appropriately to inquiries from the news media. All information presented in media briefings and media releases should be consistent with protective action decisions and other emergency information provided to the public. Copies of pertinent emergency information (e.g.. EAS messages and media releases) and media information kits should be available for dissemination to the media.

OROs should demonstrate that an effective system is in place for dealing with calls to the Public Inquiry Hotline. Hotline staff should demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate information source. Information from the hotline staff, including information that corrects false or inaccurate information when trends are noted, should be included, as appropriate, in emergency information provided to the public, media briefings, and/or media releases.

All activities for this criterion must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

86

Extent of Play

-Neii Haven FEMA Evaluated Host Coinwin"it Exercise June 1, 2002 April 10, 2002 B. Exercise Criteria and Extent of Play for New Haven Host Community and Congregate Care Centers Evaluation Area 1 - Emergency Operations Management Sub-Element L.a Mobilization Previous Objective 1. Mobilization of Emergency Personnel Criterion 1.a.l: Off-site Response organization use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG 0654, A.4.; D.3., 4.; E.I., 2.; H.4)

INTENT This sub-element is derived from NUREG-0654 which provides that OROs should have the capability to alert, notify, and mobilize emergency personnel and to activate and staff emergency facilities.

EXTENT OF PLAY - GENERAL Responsible OROs should demonstrate the capability to receive notification of an emergency situation from the licensee, verify the notification, and contact, alert, and mobilize key emergency personnel in a timely manner. In addition, responsible OROs should demonstrate the activation of facilities for immediate use by mobilized personnel when they arrive to begin emergency operations. Activation of facilities should be completed in accordance with the plan and/or procedures. Pre-positioning of emergency personnel is appropriate, in accordance with the extent of play agreement. at those facilities located beyond a normal commuting distance from the individual's duty location or residence. Further, pre-positioning of staff for an out-of-sequence demonstration is appropriate in accordance with the extent of play agreement.

All activities must be based on the ORO's plans and procedures and completed. as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. The Host Community EOC and Reception Center will be pre-positioned and demonstrated off-line in New Haven on June 1, 2002.

2. Drill play will be initiated by a phone call from Area 2 to the New Haven Fire Dispatcher. Fire Service and Civilian personnel manning various facilities will respond to a simulated call-up and be on-site at approximately 0800 for the EOC and at approximately 0900 for the Reception Center. A copy of the sign-in roster and a copy of the second shift roster will be provided to the evaluator/s.

3. Activation of Congregate Care facilities (shelters) will be simulated.

Areas Requiring Corrective Action (ARCA)

(None) 88

Extent of Play

-Neir Haven FEMA Evaluated Host Comiunitv Exercise June 1, 2002 April 10. 2002 Evaluation Area 1 - Emergency Operations Management Sub-element 1.b Facilities Previous Objective 2. Facilities - Equipment Displays and Work Environment.

Criterion 1.b.1: Facilities are sufficient to support the emergency response. (NUJREG 0654, H)

INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have facilities to support emergency response.

EXTENT OF PLAY - GENERAL Facilities will only be specifically evaluated for this criterion if they are new or have substantial changes in structure or mission. Responsible OROs should demonstrate the availability of facilities that support the accomplishment of emergency operations. Some of the areas to be considered are:

adequate space, furnishings, lighting, restrooms, ventilation, back-up power. and/or alternate facility (if required to support operations).

Facilities must be set up based on the ORO's plans and procedures and completed. as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. This objective will be demonstrated by the New Haven Host Community organization (EOC and Reception Center), where applicable, since it is the first evaluation using the new criteria.

2. This will include radiological emergency status board/s and EOC equipment.

3. The facility activation will be appropriate for a one-shift operation.

4. A source of back-up power and maintenance logs, if available, will be discussed.

5. Immediate correction of issues relating to displays and equipment where remediation is possible will be allowed.

Areas RequirinE Corrective Action (ARCA)

(None) 89

Extent of Plact

-Neit, Haven FEMAJ Evaluated Host Comm unity Exercise June 1, 2002 April 10. 2002 Evaluation Area 1 - Emergency Operations Management Sub-element 1.c Direction and Control Previous Objective 3. Direction and Control Criterion 1.c.1: Key personnel with leadership roles for the Off-Site Response Organization provide direction and control to that part of the overall response effort for which they are responsible. NUREG-0654, A.l.d., 2.a., b.)

INTENT This sub-element provides that the ORO have the capability to control their overall response to an emergency.

EXTENT OF PLAY - GENERAL Leadership personnel should demonstrate the ability to carry out essential functions of the response effort, for example. keeping the staff informed through periodic briefings and/or other means.

coordinating with other appropriate OROs and ensuring completion of requirements and requests.

All activities associated with direction and control must be performed based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC (No site-specific modifications.)

Areas Requiring Corrective Action (ARCA)

(None) 90

Extent of Play

-Niew Haven FEMA Evaluated Host Comnninity Exercise June 1, 2002 April 10, 2002 Evaluation Area 1 - Emergency Operations Management Sub-element 1.d Communications and Equipment Previous Objective 4. Communications.

Criterion 1.d.1: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations.

(NUREG-0654, F.1., 2.)

INTENT This sub-element is derived from NUREG-0654, which provides that OROs should establish reliable primary and back-up communication systems to ensure communications with key emergency personnel at locations such as the following: appropriate contiguous governments within the emergency planning zone. Federal emergency response organizations, the licensee and its facilities, emergency operations centers, and field teams.

EXTENT OF PLAY - GENERAL OROs will demonstrate that a primary, and at least one back-up system, are fully functional at the beginning of an exercise. If a communications system or systems are not functional, but exercise performance is not affected, no exercise issue will be assessed. Communications equipment and procedures for facilities and field units should be used as needed for the transmission and receipt of exercise messages. All facilities and field teams should have the capability to access at least one communication system that is independent of the commercial telephone system. Responsible OROs should demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt the conduct of emergency operations. OROs should ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

The specific communications capabilities of OROs should be commensurate with that specified in the response plan and/or procedures. Exercise scenarios could require the failure of a communications system and the use of an alternate system.

All activities associated with the management of communications capabilities must be demonstrated based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

91

Extent of Play

-New Haven FEMA Evaluated Host Community Exercise June 1, 2002 April 10, 2002 Sub-element 1.d Communications and Equipment (Continued)

EXTENT OF PLAY - SPECIFIC

1. Communications will be demonstrated as follows by the New Haven Host Community organization since it is the first evaluation using the new criteria:

"* A communications check will be conducted between the OEM Area 2 office and the New Haven EOC and also between the Reception Center and the New Haven EOC.

"* Other communications will be limited to the Reception Center.

"* Radio communication is primary with cell phone and/or regular telephone as back-up.

"* Separate power sources for communications equipment are not required.

Areas Requirino Corrective Action (ARCA)

(None) 92

Extent of Play

-New Haven FEMA EvaluatedHost Connnmunity Exercise June 1. 2002 April 10, 2002 Evaluation Area 1 - Emergency Operations Management Sub-element i.e Equipment and Supplies to Support Operations Previous Objective 5. Emergency Worker Exposure Control Previous Objective 14. Implementation of Protective Actions - KI for Emergency Workers, Institutionalized Individuals and the General Public (for KI inventory only)

Criterion 1.e.l: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG-0654, H.;

J.1O.a., b., e., f., j., k., 11; K.3.a.)

INTENT This sub-element is derived from NUREG-0654. which provides that OROs have emergency equipment and supplies adequate to support the emergency response.

EXTENT OF PLAY - GENERAL Equipment within the facility(ies) should be sufficient and consistent with the role assigned to that facility in the ORO's plans and/or procedures in support of emergency operations. Use of maps and displays is encouraged.

All instruments. including air sampling flow meters (field teams only), should be inspected, inventoried, and operationally checked before each use. They should be calibrated in accordance with the manufacturer's recommendations (or at least annually for the unmodified CDV-700 series or if there are no manufacturer's recommendations for a specific instrument, modified CDV-700 instruments should be calibrated in accordance with the recommendation of the modification manufacturer). A label indicating such calibration should be on each instrument or verifiable by other means. Note: Field team equipment is evaluated under 4.a. 1: radiological laboratory equipment is evaluated under 4.c. 1: Reception Center and emergency worker facilities' equipment is evaluated under 6.a. 1: and ambulance and medical facilities' equipment is evaluated under 6.d. 1.

Sufficient quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers should be available for issuance to all categories of emergency workers that could be deployed from that facility. Appropriate direct-reading dosimeters should allow individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans and procedures.

93

Extent of Play

-New Haven FEMA Evaluated Host CommuniOt Exercise June 1, 2002 April 10, 2002 Sub-element i.e Equipment and Supplies to Support Operations (Continued)

Dosimeters should be inspected for electrical leakage at least annually and replaced, if necessary.

CDV-138s, due to their documented history of electrical leakage problems, should be inspected for electrical leakage at least quarterly and replaced if necessary. This leakage testing will be verified during the exercise, through documentation submitted in the Annual Letter of Certification, and/or through a staff assistance visit.

Responsible OROs should demonstrate the capability to maintain inventories of KI sufficient for use by emergency workers, as indicated on rosters: institutionalized individuals, as indicated in capacity lists for facilities; and, where stipulated by the plan and/or procedures. members of the general public (including transients) within the plume pathway EPZ.

Quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical inspection at storage location(s) or through documentation of current inventory submitted during the exercise, provided in the Annual Letter of Certification submission, and/or verified during a Staff Assistance Visit. Available supplies of KI should be within the expiration date indicated on KI bottles or blister packs. As an alternative, the ORO may produce a letter from FEMA indicating that the KI supply remains potent, in accordance with FDA guidance. FEMA issues these letters based upon the findings of the certified independent laboratory that performed the analysis at the ORO's request and expense.

At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones and signs, etc.) should be available or their availability described.

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. Displays applicable to the Host Community Reception Center:

"* Shelter Status

"* Shelter Locations

". Radiation Background Readings 94

Extent of Play

-New Haven FEMA EvaluatedHost Comnuniti' Exercise June 1. 2002 April 10. 2002 Sub-element i.e Equipment and Supplies to Support Operations (Continued)

2. Dosimetry will only be issued to radiological emergency workers at the Reception Center and not to other emergency workers such as Registration, Red Cross, etc., that are not exposed to potential contamination. Packets include: a permanent record dosimeter (in lieu of a TLD) and two self-reading dosimeters in the OR to 5R and the OR to 200R ranges. However, the OR to 200R dosimeter is not used at the Reception Center.

3. Each direct-reading dosimeter has a sticker with the date of the last calibration/electrical leakage test.

4. Immediate correction will be allowed if, after initially not being able to show proper equipment, supplies or documentation, the issue is corrected with further effort/instruction.

Areas Reciuirina Corrective Action (ARCA)

(None) 95

Extent of Play

-New 1-Haven FEMA Evaluated Host Coinnmnitv Exercise June 1, 2002 April 10. 2002 Evaluation Area 3 - Protective Action Implementation Sub-element 3.a Implementation of Emergency Worker Exposure Control Previous Objective 5. Emergency Worker Exposure Control Criterion 3.a.l: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. (NUREG-0654, K.3.)

INTENT This sub-element is derived from NUREG-0654. which provides that OROs should have the capability to provide for the following: distribution, use, collection, and processing of direct reading dosimeters and permanent record dosimeters; provide for direct-reading dosimeters to be read at appropriate frequencies by emergency workers; maintain a radiation dose record for each emergency worker; and provide for establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of protective action guides, always applying the ALARA principle as appropriate.

EXTENT OF PLAY - GENERAL OROs should demonstrate the capability to provide appropriate direct-reading and permanent record dosimetry, dosimetry chargers, and instructions on the use of dosimetry to emergency workers. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows individual(s) to read the administrative reporting limits (that are pre established at a level low enough to consider subsequent calculation of Total Effective Dose Equivalent) and maximum exposure limits (for those emergency workers involved in life saving activities) contained in the ORO's plans and procedures.

Each emergency worker should have the basic knowledge of radiation exposure limits as specified in the ORO's plan and/or procedures. Procedures to monitor and record dosimeter readings and to manage radiological exposure control should be demonstrated.

Extent of Play

-Newi Haven FE1 14 EvaluatedHost Communit" Exercise June 1, 2002 April 10, 2002 Sub-element 3.a Implementation of Emergency Worker Exposure Control (Continued)

During a plume phase exercise, emergency workers should demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. The emergency worker should report accumulated exposures during the exercise as indicated in the plans and procedures. OROs should demonstrate the actions described in the plan and/or procedures by detennining whether to replace the worker, to authorize the worker to incur additional exposures, or to take other actions. If scenario events do not require emergency workers to seek authorizations for additional exposure. evaluators should interview at least two emergency workers, to determine their knowledge of whom to contact in the event authorization is needed and at what exposure levels. Emergency workers may use any available resources (e.g., written procedures and/or co-workers) in providing responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations in which team members will be in close proximity to each other during the entire mission and adequate control of exposure can be effected for all members of the team by one dosimeter worn by the team leader. Emergency workers who are assigned to low exposure rate areas. e.g., at Reception Centers, counting laboratories. Emergency Operations Centers, and communications centers. may have individual direct-reading dosimeters or they may be monitored by dosimeters strategically placed in the work area. It should be noted that, even in these situations, each team member must still have their own permanent record dosimeter.

Individuals without specific radiological response missions, such as farmers for animal care, essential utility service personnel, or other members of the public who must re-enter an evacuated area following or during the plume passage, should be limited to the lowest radiological exposure commensurate with completing their missions.

All activities must be based on the ORO*s plans and procedures and completed. as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. Each community has been provided with emergency worker dosimetry packets. These packets include: a permanent record dosimeter and two self-reading dosimeters in the OR n) to 5R and the OR to 200R ranges.

2. Dosimetry packets will be issued to all Reception Center radiological emergency workers.

Evaluators will obserne dosimetry turn-in and necessary paperwork.

97

Extent of Play

-AYeli Haven FEMVIA Evaluated Host Comnzunitv Exercise June 1, 2002 April 10. 2002 Sub-element 3.a.1. Implementation of Emergency Worker Exposure Control (Continued)

3. Radiological emergency worker exposure control training, including a basic knowledge of exposure control procedures (turn-back values, call-in values, and periodic monitoring), will be demonstrated through evaluator interviews.

4. Host Community emergency workers do not need to use or wear the OR to 200R self-reading dosimeters.

5. Dosimetry will only be issued to radiological emergency workers at the Reception Center and not to other emergency workers such as Registration, Red Cross. etc., that are not exposed to potential contamination.

6. Immediate correction will be allowed for issues relating to the issuing of dosimetry, briefing, and, subsequently. the demonstration by emergency worker knowledge of radiation control.

Areas Requiring Corrective Action (ARCA)

(None) 98

Extent of Play

-Neii' Haven FEMA EvaluatedHost Community Exercise June 1. 2002 April 10. 2002 Evaluation Area 3 - Protective Action Implementation Sub-element 3.d Implementation of Traffic and Access Control -TCP/ACP are Established Protective Objective 17. Traffic and Access Control Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654, J.10.g., j., k.)

INTENT This sub-element is derived from NUREG-0654. which provides that OROs have the capability to implement protective action plans, including relocation and restriction of access to evacuated areas. This sub-element focuses on selecting. establishing, and staffing of traffic and access control points and removal of impediments to the flow of evacuation traffic.

EXTENT OF PLAY - GENERAL OROs should demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with evacuationL/sheltering decisions (for example evacuating, sheltering, and relocation), in a timely manner. OROs should demonstrate the capability to provide instructions to traffic and access control staff on actions to take when modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled.

Traffic and access control staff should demonstrate accurate knowledge of their roles and responsibilities. This capability may be demonstrated by actual deployment or by interview in accordance with the extent of play agreement.

In instances in which OROs lack authority necessary to control access by' certain types of traffic (rail, water, and air traffic), they should demonstrate the capability to contact the State or Federal agencies with authority to control access.

All activities must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency. unless specified above or indicated in the extent of play agreement.

99

Extent of Play

-Neit Haven FEMA EvaluatedHost Communitu Exercise June 1, 2002 April 10, 2002 Sub-element 3.d Implementation of Traffic and Access Control -TCP/ACP are Established (Continued)

EXTENT OF PLAY - SPECIFIC

1. The New Haven Police Department representative, at the Cit EOC. will discuss traffic control responsibilities assigned to the New Haven Police Department.

"2. A representative of the Southern Connecticut State University (SCSU) Police Department, at the Reception Center, will discuss traffic control responsibilities assigned to the SCSU Police Department.

Area Requiring Corrective Action (ARCA)

(None) 100

Extent of Play

-Neew Haven FEMA Evaluated Host Communiti Exercise June ], 2002 April 10, 2002 Evaluation Area 6 - Support Operations/Facilities Sub-element 6.a Monitoring and Decontamination of Evacuees and Emergency Workers and Registration of Evacuees Previous Objective 18: Reception Center - Monitoring, Decontamination and Registration Previous Objective 22: Emergency Workers, Equipment and Vehicles - Monitoring and Decontamination Criterion 6.a.1: The Reception Center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers. (NUREG 0654, J.10.h.; K.5.b.)

INTENT This sub-element is derived from NUREG-0654. which provides that OROs have the capability to implement radiological monitoring and decontamination of evacuees and emergency workers, while minimizing contamination of the facility, and registering evacuees at Reception Centers.

EXTENT OF PLAY - GENERAL Radiological monitoring, decontamination, and registration facilities for evacuees/emergency workers should be set up and demonstrated as they would be in an actual emergency or as indicated in the extent of play agreement. This would include adequate space for evacuees' vehicles.

Expected demonstration should include 1/3 of the monitoring teams/portal monitors required to monitor 20 percent of the population allocated to the facility within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Prior to using a monitoring instrument(s), the monitor(s) should demonstrate the process of checking the instrument(s) for proper operation.

Staff responsible for the radiological monitoring of evacuees should demonstrate the capability to attain and sustain a monitoring productivity rate per hour needed to monitor the 20 percent EPZ population planning base within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This monitoring productivity rate per hour is the number of evacuees that can be monitored per hour by the total complement of monitors using an appropriate monitoring procedure. A minimum of six individuals per monitoring station should be monitored, using equipment and procedures specified in the plan and/or procedures, to allow demonstration of monitoring, decontamination, and registration capabilities.

The monitoring sequences for the first six simulated evacuees per monitoring team will be timed by the evaluators in order to determine whether the 12-hour requirement can be met. Monitoring of emergency workers does not have to meet the 12-hour requirement. However, appropriate monitoring procedures should be demonstrated for a minimum of two emergency workers.

101

Extent of Play

-New Haven FEMA EvaluatedHost Community Exercise June 1, 2002 April 10, 2002 Sub-element 6.a Monitoring and Decontamination of Evacuees and Emergency Workers and Registration of Evacuees (Continued)

Decontamination of evacuees/emergency workers may be simulated and conducted by interview.

The availability of provisions for separately showering should be demonstrated or explained.

The staff should demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate clean from potentially contaminated areas. Provisions should also exist to separate contaminated and uncontaminated individuals, provide changes of clothing for individuals whose clothing is contaminated, and store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities. In addition, for any individual found to be contaminated, procedures should be discussed concerning the handling of potential contamination of vehicles and personal belongings.

Monitoring personnel should explain the use of action levels for determining the need for decontamination. They should also explain the procedures for referring evacuees who cannot be adequately decontaminated for assessment and follow up in accordance with the ORO's plans and procedures. Contamination of the individual will be determined by controller inject and not simulated with any low-level radiation source.

The capability to register individuals upon completion of the monitoring and decontamination activities should be demonstrated. The registration activities demonstrated should include the establishment of a registration record for each individual, consisting of the individual's name.

address, results of monitoring, and time of decontamination, if any. or as otherwise designated in the plan. Audio recorders, camcorders, or written records are all acceptable means for registration.

EXTENT OF PLAY - SPECIFIC

1. New Haven w*ill activate its Reception Center for demonstration of this objective. These activities will take place out of sequence from a regular exercise scenario. Demonstration is off-line on June 1, 2002.

2. The following will be demonstrated by the Reception Center:

"* The four portal monitors specified in the plan will be set-up. operationally tested. and demonstrated.

"* Since portal monitors are used during the demonstration, at least one staff radiological monitor will demonstrate hand-held instrument monitoring techniques for personnel at the Secondary Monitoring Station.

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Extent of Play

-New Haven FEAMA EvaluatedHost Coninmunin Exercise June 1, 2002 April 10, 2002 Sub-element 6.a Monitoring and Decontamination of Evacuees and Emergency Workers and Registration of Evacuees (Continued)

"* Contamination control measures and decontamination techniques for at least one male and one female subject will be demonstrated.

"* Vehicle monitoring will be demonstrated as follows:

a. Three vehicle monitoring lanes, of the three specified in the plan, will be set-up and demonstrated.

b. Three vehicle monitoring teams, of the seven in the plan, will be demonstrated.

c. Three vehicles will be externally monitored and parked in a designated "clean" or

"'contaminated" area. (One of the three vehicles will be designated

"-contaminated- by controller inject.)

"* A representative sample of replacement clothing resources available for decontaminated individuals will be shown in both Male and Female Decon areas.

3. hImmediate correction of issues will be allowed relating to setup of facilities, actual monitoring (including time concerns), and decontamination procedures and registration of personnel. This will also include monitoring of vehicles.

Areas Requiring Corrective Action (ARCA) 29-96-18-A- 15: Vehicle monitors needed more training in use of monitoring instruments.

29-96-18-A-16: Female decon had only two personnel assigned vice the three required by the plan.

29-96-18-A- 17: Replacement clothing for evacuees was not available in female decon and incomplete in male decon.

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Extent of Play

-Xei' Haven FEMA Evaluated Host Commnunil" Exercise June 1. 2002 April 10. 2002 Evaluation Area 6 - Support Operations/Facilities Evacuees and Emergency Worker Sub-element 6.b Monitoring and Decontamination of Equipment Decontamination and Previous Objective 18: Reception Center - Monitoring, Registration and Vehicles - Monitoring and Previous Objective 22: Emergency Workers, Equipment Decontamination and resources for the Criterion 6.b.l: The facility/ORO has adequate procedures of emergency worker accomplishment of monitoring and decontamination equipment including vehicles. (NUREG-0654, K.5.b)

INTENT that OROs have the capability to This sub-element is derived from NUREG-0654, which provides emergency worker equipment.

implement radiological monitoring and decontamination of including vehicles.

EXTENT OF PLAY - GENERAL monitor equipment. including vehicles, The monitoring staff should demonstrate the capability to procedures. Specific attention should for contamination in accordance with the ORO's plans and with individuals found to be be given to equipment, including vehicles, that was in contact capability to make decisions on the contaminated. The monitoring staff should demonstrate the based on guidance levels and need for decontamination of equipment. including vehicles, procedures stated in the plan and/or procedures.

be set up as it would be in an The area to be used for monitoring and decontamination should record keeping. and contamination actual emergency, with all route markings, instrumentation, be demonstrated for a minimum of one control measures in place. Monitoring procedures should surface of vehicles. However. the vehicle. It is generally not necessary to monitor the entire radiator grills, bumpers, wheel wells. tires, capability to monitor areas such as air intake systems.

of vehicles that were in contact with and door handles should be demonstrated. Interior surfaces individuals found to be contaminated should also be checked.

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Extent of Play

-Newi Haven FEMA EvaluatedHost Comimiiniti-Exercise June 1, 2002 April 10. 2002 Sub-element 6.b Monitoring and Decontamination of Emergency Worker Equipment (Continued)

Decontamination capabilities, and provisions for vehicles and equipment that cannot be decontaminated, may be simulated and conducted by interview.

All activities associated with this criterion must be based on the ORO's plans and procedures and completed. as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. Procedures for collection of dosimetry from one emergency worker will be demonstrated, as well as monitoring, decontamination, and registration of that individual.

2. Vehicle monitoring will be demonstrated under criteria sub-element 6.a. 1.

3. Vehicles that were in contact with individuals found to be contaminated will be identified and that information communicated to vehicle monitors so that those vehicles are tagged for later monitoring.

4. Decontamination capabilities, and provisions for vehicles and equipment that cannot be decontaminated, will be simulated and demonstrated by discussion.

5. Immediate correction of issues will be allowed relating to setup of facilities and monitoring procedures. This also would include the discussion of decontamination of vehicles.

Areas Requiring Corrective Action (ARCA)

(None) 105

Extent of Play

-Neii' Haven FEMA EvaluatedHost Conununity Exercise June 1, 2002 April 10, 2002 Evaluation Area 6 - Support Operations/Facilities Sub-element 6.c Temporary Care of Evacuees Criterion 6.c.1: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines (found in MASS CARE-Preparedness Operations, ARC 3031). Managers demonstrate the procedures to assure that evacuees have been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities. (NUREG-0654, J.10.h., 12.)

INTENT This sub-element is derived from NIJREG-0654. which provides that OROs demonstrate the capability to establish relocation centers in host areas. Congregate care is normally provided in support of OROs by the American Red Cross under existing letters of agreement.

EXTENT OF PLAY - GENERAL Under this criterion, demonstration of Congregate Care Centers may be conducted out of sequence with the exercise scenario. The evaluator should conduct a walk-through of the center to determine, through observation and inquiries, that the services and accommodations are consistent with ARC 3031. In this simulation, it is not necessary to set up operations, as they would be in an actual emergency. Alternatively, capabilities may be demonstrated by setting up stations for various services and providing those services to simulated evacuees. Given the substantial differences between demonstration and simulation of this criteria, exercise demonstration expectations should be clearly specified in extent of play agreements.

Congregate care staff should also demonstrate the capability to ensure that evacuees have been monitored for contamination, have been decontaminated as appropriate, and have been registered before entering the facility. This capability may be determined through an interview process.

If operations at the Center are demonstrated, material that would be difficult or expensive to transport (e.g.. cots, blankets. sundries, and large-scale food supplies) need not be physically available at the facility(ies). However, availability of such items should be verified by providing the evaluator a list of sources with locations and estimates of quantities.

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Extent of Play

-New Haven FEMA Evaluated Host Communiti Exercise June 1, 2002 April 10, 2002 Sub-element 6.c Temporary Care of Evacuees (Continued)

All activities associated with this criterion must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

EXTENT OF PLAY - SPECIFIC

1. Activation of congregate care (shelter) facilities will be simulated on the day of the exercise.

2. A walk-through of New Haven congregate care facilities will be scheduled with dates TBD by advance coordination between FEMA. the American Red Cross. and New Haven. The Red Cross retains shelter survey documentation and a copy will be provided to FEMA.

Areas Requiring Corrective Action (ARCA)

(None) 107

List of Evaluation Sub-Elements Not to be Demonstrated in this Exercise Sub-Element Description 2.d. I Radiological Assessment and Decision-Making for the Ingestion Exposure Pathway. (Old #20) 2.e. 1 Radiological Assessment and Decision-Making Concerning Relocation, Re-entry, and Return. (Old #28) 3.e. I Implementation of Ingestion Pathway Decisions. (Old #27) 3.e.2 Implementation of Ingestion Pathway Decisions. (Old #27) 3.f.1 Implementation of Relocation, Re-entry, and Return Decisions.

(Old #28) 4.b. 1 Post Plume Phase Field Measurements and Sampling. (Old #24) 4.c. 1 Laboratory Operations. (Old #25) 5.a.2 (Reserved by FEMA for future use.)

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APPENDIX 4 MILLSTONE PLUME EXPOSURE PATHWAY EXERCISE SCENARIO This appendix contains a summary of the simulated sequence of events -- Exercise Scenario -

that was used as the basis for invoking emergency response actions by off-site response organizations (OROs) in the Millstone Power Station Plume Exposure Pathway exercise on May 1.2002.

This exercise scenario was submitted by the State of Connecticut on March 1, 2002 and approved by FEMA Region I on April 5, 2002.

During the exercise, controllers gave "inject messages." containing scenario events and/or relevant data. to those persons or locations who would normally receive notification of such events. These inject messages were the method used for invoking response actions by off-site response organizations.

SCENARIO

SUMMARY

Clock Time Major Event 0745 Exercise play begins at Millstone Station.

0747 Indications received of Excess Steam Demand: Reactor is tripped.

0755 Millstone declares an ALERT. State Posture Code Charlie One.

0810 State. local communities and State Emergency Response Organization (SERO) Emergency Notification Response System (ENRS) notifications made for Alert emergency classification.

State, local conmnunities have the option to activate EOCs. but as a mniniunnm, staff should be put on standby.

0940 Millstone declares a SITE AREA EMERGENCY (SAE), State Posture Code Charlie Two.

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Clock Time Major Event 0955 State. local communities and SERO ENRS notifications made for SAE emergency classification.

State. local Emergency Operations Centers (EOCs) must be activated.

A simulated siren activation should be coordinatedby Area IV. The State is responsiblefor issuing a simulated Emergency Alert System (EAS) message.

The Governor (simulated)will most likelI declare a State of Emergenco.

1120 Millstone declares a GENERAL EMERGENCY, State Posture Code Alpha.

1135 State and local community ENRS notifications made for General Emergency classification.

Millstone expected to issue the following Protective Action Recommendations to the State:

Evacuate Zones: A, B, E. and both Montville and Waterford in C Shelter Zones: D. F, and East Lyme in C The State will make protective action decision based on Millstone's input.

as well as other implementation considerations.

A simulated siren activation should be coordinatedbh Area IV The State is responsiblefor issuing a simulated EAS message.

State and local communities will demonstrate various implementation actionsfor protective action decisions.

1430 Exercise is terminated (as directed by the Drill Manager).

Termination + 15 Local controllers may delay termination to allow actions to be completed.

minutes Copies of timelines and logs should be obtained. FEMA/Controllers perform local player debriefs.

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APPENDIX 5 HOST COMMUNITY EXERCISE SCENARIO This appendix contains a summary of the simulated sequence of events -- Exercise Scenario -

that was used as the basis for invoking emergency response actions by the Millstone host communities on June 1. 2002.

During the exercise, controllers gave -inject mnessages," containing scenario events and/or relevant data, to those persons or locations who would normally receive notification of such events. These inject messages were the method used for invoking response actions by off-site response organizations.

SCENARIO

SUMMARY

Clock Time Event EOC PHASE:

0800. Message from Area 2 Coordinator (control cell) to notify Host Community via telephone call.

New Haven 911 Dispatcher makes calls to Chief Administrative. Office for permission to call EMD.

0815 to 0830 Staff begin to arrive at EOC. located in basement of the Hall of Records.

Following EOC Communication check is conducted with Area 2 Office.

activation.

0845. (Update message from Area 2, informs EMD that an evacuation of EPZ towns including East Lyme. Lyme, and Old Lyme is expected.)

The EMD requests 911 Fire Dispatcher to notify Fire Department staff to activate the Reception Center.

0900 The Fire Department Administrative. Staff is responsible for evacuee registration.

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Clock Time Event 0900 (about) The Police Department. is responsible for Traffic Control from 1-95 to Reception Center.

0915 to0930 EOC provides support staff for activation of the Reception Center.

Red Cross and school administrative personnel discuss plan for opening shelter(s). These will be posted on the EOC shelter board.

Red Cross calls out for Reception Center representative.

RECEPTION CENTER SET-UP PHASE:

0900 or earlier The SCSU Police Department. is responsible for Traffic Control in the vicinity of the Reception Center.

0915 Reception Center staff begin to set-up monitoring.

decontamination, and registration areas.

0930 to 1030 Communications check is conducted. The Reception Center Manager is the main contact with EOC and remote Reception Center locations. Primary communication is via radio.

0930 to 1030 Dosimetry is prepared and issued to emergency workers in accordance with procedures. Briefings are conducted as each station is called to receive their instruments.

0930 to 1030 Preparation/set up of monitoring instruments (CDV-700 survey meters, three Eberline (PPM) portal monitors and one NRC portal monitor) are set up and operationally checked per procedure.

Survey meters will be issued to staff ready for use.

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Clock Time Event 0930 to 1030 Set up of a Secondary Monitoring Area is staffed to monitor evacuees or emergency workers who alarm the portal monitors.

0930 to 1030 Set up of two decontamination areas, one male and one female, per procedure and diagram.

0930 to 1030 Vehicle monitoring lanes and clean/contaminated parking areas are established per the extent of play.

0930 to 1030 A registration area is set up and staffed according to the plan in the field house gymnasium per procedure.

1030 to 1100 Communication checks are conducted at the Reception Center, and between the Reception Center and remote locations throughout the Reception Center, including the vehicle monitoring area.

1030 to 1100 Reception Center Manager notifies EOC when Reception Center is fully staffed and operational.

Start demonstration once Reception Center is operational and EOC has been notified.

RECEPTION CENTER DEMONSTRATION PHASE:

1 I Flf I IVU At this point, there may be a reduction of EOC play and non essential staff will be released.

1100to 1130 At least three vehicles will be externally monitored in each of the three monitoring lanes and directed to park in a designated

"-clean" or "contaminated" area as appropriate.

1100to 1130 Portal Monitoring demonstration:

Six individuals are assembled and consecutively monitored through each of four portal monitors per controller inject when sufficient number of "evacuees" are available.

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Clock Time Event 1130 to 1230 At least two individuals will be "contaminated" per controller inject, one female, one male. One of these individuals is an evacuated EPZ emergency worker and will be wearing dosimetry 1130 to 1230 Secondary Monitoring will survey individuals with hand-held survey meters.

1130 to 1230 Each of the two decontamination areas will demonstrate/discuss contamination control measures, decontamination, and radiological monitoring techniques.

1130to1230 Evacuees are directed from decontamination stations to registration area via clean path.

1230 to 1300 Exercise is terminated. Play ends and all areas are returned to normal condition.

POST DEMONSTRATION PHASE:

1230 to 1300 Players will be directed to return their areas to a normal condition and report to a specified area for their comments.

1300 to 1330 The Lead Controller will lead the player critique.

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