ML041190475

Final Exercise Report Oconee Nuclear Station

ML041190475
Person / Time
Site:	Oconee
Issue date:	04/15/2004
From:	Mark Miller Federal Emergency Management Agency
To:	Reye L Region 2 Administrator
schneck D 415-3079 nrr/eppo
References
Download: ML041190475 (52)

Text

l '.S. D)peparIlmnu't fri I lome l dS.ctiril '

Region 1\\'-,

3013 (CI:himibe Tucker Road,

Allanta. GA 3(0341 3 -3 tFEMA Final Exrcs Reor Ocone Nula. tto Licensee:,.

Exercise Date:

Report Date:

Duke Energy January 13, 2004

-April 15, 2004 D-I LI Is is %$.femna.gov

V.S. D)epabrtmen1 t uU 11nuclialn Sccuritr:

Reuilll IV 3003 h(mble;ei TcLker Road Atlainta. (;A 30341 t FEMA

i April 15,2004 Mr. Luis A. Reyes Regional Administrator-RII Nuclear Regulatory Commission 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303

Dear Mr. Reyes:

Enclosed is the final report for the Oconee Nuclear Station Exercise that was conducted on January 13, 2004.

This was a full participation, plume exposure pathway exercise designed to evaluate the offsite radiological emergency response plans site-specific to the Oconee Nuclear Station. The report addresses the evaluation of the plans and preparedness for the State of South Carolina and Oconee and Pickens counties within the 10-mile Emergency Planning Zone (EPZ), and Anderson and Greenville, host counties. The final exercise report was prepared by the Federal Emergency Management Agency Region IV staff. Copies of this report will be forwarded to the State of South Carolina, FEMA Headquarters, and NRC Headquarters by my staff.

In addition to the Oconee Nuclear Station, State and county personnel, many volunteers, and several elected officials participated in this exercise. Out-of-sequence activities included lake clearance, state traffic control points, protective actions for schools, emergency worker decontamination and reception and congregate care centers. The LP-I Emergency Alert System radio station for the site, WFBC in Greenville, participated and added realism to the overall exercise. The State conducted operations from their facility on Fish Hatchery Road in West Columbia. and the Department of Health and Environmental Control operated from a forward location at the National Guard Armory in Clemson.

All agreed upon evaluation area criteria for the exercise were demonstrated. No Deficiencies or Areas Requiring Corrective Action (ARCA) were identified during this exercise. All ARCAs identified during the 2002 exercise have been corrected.

Based on the results of the January 13, 2004, exercise and FEM A's review of the State's Annual Letter of Certification for 2002 and 2003, the offsite radiological emergency response plans for the State of South Carolina and the affected local jurisdictions, site-specific to the Oconee Nuclear Station, can be implemented, and are www.fema.gov

1. adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency at the site. The Title 44 CFR, Part 350, approval of the State of South Carolina's offsite radiological emergency response plans and preparedness site-specific to the Oconee Nuclear Station, granted on February 23, 1983, will remain in effect.

Should you have any questions, please contact Lawrence A. Robertson at 770/220-5466.

Sincerely, Mary Lynne Miller Acting Regional Director Enclosure cc:

Ms. Vanessa E. Quinn, Chief Federal Emergency Management Agency Headquarters Radiological and Emergency Preparedness Branch - NP-TS-RP 500 C Street, SW, Room 202 Was ington, D. C. 20472' is. Debra A. Schneck, Chief Emergency Preparedness and Health Physics Section Operator Licensing, Human Performance and Plant Support Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001

lV.S. I)LD:par cndidt o IflomiuehRilCI Scitrit!

IRcim)l IV 3(X()3 (Chamblce Tticker Roaid Atlantalz. (A 30341

,I.

I, 4i FEMA Final Exercise Report Oconee Nuclear Station Licensee:

Exercise Date:

Report Date:

Duke Energy January 13, 2004 April 15, 2004 Ad Id %%.f'emla.qo

TABLE OF CONTENTS Paec

1.

EXECUTIVE

SUMMARY

.................................................................................................I II.

INTRODUCTION.................................

2 111.

EXERCISE OVERVIEW.................................

4 A.

Plume EPZ Description.................................

4 B.

Exercise Participants....

4....................

C.

Exercise Timeline.................................

5 IV.

EXERCISE EVALUATION AND RESULTS...............................

7 L

A.

Summary Results of Exercise Evaluation -Table 2.................

................7 L

B.

Status of Jurisdictions Evaluated.............................................................................9

1.

STATE OF SOUTH CAROLINA.

1 L

1.1 State Emergency Operations Center.........................

1.1 1.2 Dose Assessment - EOC Liaison........................

II 1.3 Dose Assessment - Clemson........................

12 1.4 Radiological Laboratory........................

13 1.5 Lake Clearing........................

15 1.6 LP-I Radio Station-WFBC........................

5 l

1.7 State Traffic Control Points........................

16

2.

JOINT OPERATIONS........................

16 2.1 Joint Information Center........................

16 2.2 Emergency Operations Facility..................................................... 17

3.

RISK JURISDICTIONS 17 3.1 OCONEECOUNTY........................

17 3.1.1 Emergency Operations Center........................

17 3.1.2 Protective Actions for Schools...........

............. 18 3.1.3 Emergency Worker Decontamination........................

18

3.2 PICKENS COUNTY...............................................

19 3.2.1 Emergency Operations Center........................................... 19 3.2.2 Protective Actions for Schools.......................................... 20 3.2.3 Emergency 'Worker Decontamination............................... 20

4.

HOST JURISDICTIONS.

21 4.1 ANDERSON COUNTY 21 4.1.1 Reception and Congregate Care........................................ 21 4.2 GREENVILLE COUNTY 21 4.2.1 Reception and Congregate Care........................................ 21

5.

SUMMARY

OF AREAS REQUIRING CORRECTIVE ACTION......... 23 5.1 PRIOR ARCAs RESOLVED

................................... 23 5.1.1 42-02-4.c.1-A-01 State of South Carolina Radiological Laboratory (Mobile Laboratory).................. 23 List of Appcndices APPENDIX I - ACRONYMS AND ABBREVIATIONS.26 APPENDIX 2 - EXERCISE EVALUATORS.28 APPENDIX 3 - EXERCISE CRITERIA AND EXTENT-OF-PLAY AGREEMENT.30 APPENDIX 4 - EXERCISE SCENARIO.31 List of Tables Table I -

Exercise Timeline

.6 Table 2 -

Summary Results of Exercise Evaluation

.8 ii

1.

EXECUTIVE

SUMMARY

On January 13, 2004, a partial participation exercise wvas conducted in the plume exposure pathway emergency planning zone (EPZ) around the Oconee Nuclear Station.

The purpose of the exercise was to assess the level of State and local preparedness in responding to a radiological emergency. The State of South Carolina, Oconee and Pickens Counties, the risk counties, and Anderson and Greenville Counties, the host counties, participated in the exercise. This exercise was held in accordance with DHS/FEMA's policies and guidance concerning the exercise of State and local radiological emergency response plans (RERP) and procedures.

The previous exercise at this site was conducted on September 17, 2002. The qualifying emergency preparedness exercise was conducted on March 10 and 11, 1982.

DH-S/FEMA wishes to acknowledge the efforts of the many individuals, both paid staff and -volunteers, in South Carolina, and in Oconee, Pickens, Anderson, and Greenville Counties who planned and participated in this exercise. The State and counties through the efforts of these individuals demonstrated their commitment to protect the health and safety of the residents within the 10-mile EPZ. The support of volunteers is essential to the emergency response efforts. Cooperation and teamwork of all the participants were evident during this exercise. The State and local organizations demonstrated knowledge of their emergency response plans and procedures and implemented them.

During this exercise no Deficiencies or Areas Requiring Corrective Action (ARCA) were identified. During the 200? Oconee exercise five ARCAs were identified. Two ARCAs were corrected immediately. two ARCAs concerning the condition of field monitoring team equipment were corrected during the July 2003 V. C. Summer exercise. One remaining ARCA concerning laboratory contamination control was corrected during this exercise.

1

11.

INTRODUCTION On December 7, 1979, the President directed DI-IS/FEMA to assume the lead responsibility for all offsite nuclear planning and response. DIIS/FEMA's activities 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.

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

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

Taking the lead in offsite emergency planning and in the review and evaluation of radiological emergency response plans (RERP) 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 NRC pursuant to the Memorandum of Understanding between the NRC and DHS/FEMA dated June 17, 1993 (Federal Register, Vol. 58, No. 176, September 14. 1993).

Coordinating the activities of Federal agencies with responsibilities in thc radiological emergency planning process:

Department of Agriculture, Department of Commerce, Department of Energy, Department of Health and Human Services, Department of the Interior, Department of Transportation, Environmental Protection Agency, Food and Drug Administration and Nuclear Regulatory Commission.

Representatives of these agencies serve on the DHS/FEMA Region IV Regional Assistance Committee (RAG) Which is chaired by DHS/FEMA.

2

Formal submission of the RERPs for the Oconee Nuclear Station to DIlIS/FEMIA Region IV by the State of South Carolina and involved local jurisdictions occurred on May 7.

1982. Formal approval of the RERP was granted by DI-S/FEMA on February 23, 1983, under 44 CFR 350. Tile State of South Carolina certifies the currency of these plans and preparedness through submittal of an Annual Letter of Certification to DHS/FEMA.

A partial participation plume exposure pathway exercise was conducted on January 13, 2004. DHS/FEMA Region IV assessed the capabilities of State and local emergency preparedness organizations in implementing their RERPs and procedures to protect public health and safety during a radiological emergency involving the Oconec Nuclear Station. The purpose of this report is to present the results and findings on the performance of the offsite response organizations (ORO) during a simulated radiological emergency.

The findings presented are based on the evaluations of the Federal evaluator team, with final determinations made by the Chief Evaluator and RAC Chairperson, and approved by the Regional Director.

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

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

'"Interim REP Program Manual," August, 2002.

Section III of this report. entitled "Exercise Overview," presents basic information and data relevant to the exercise. This section contains a description of the plume pathway EPZ. a listing of all participating jurisdictions and functional entities which were evaluated, and a tabular presentation of the time of actual occurrence 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 evaluation area criteria at each jurisdiction or functional entity. This section also contains the description of the correction of the ARCA concerning contamination control at the mobile laboratory identified during the 2002 Oconee Exercise.

3

111.

EXERCISE OVERVIEW This section contains data and basic information relevant to the January 13, 2004, exercise to test the offsite emergency response capabilities in the area surrounding the Oconee Nuclear Station.

A.

Plume EPZ Description The Oconee Nuclear Station is located in eastern Oconee County, South Carolina.

approximately 8 miles northeast of Seneca, South Carolina, on the eastern shore of Lake Keowee. The Oconee Nuclear Station has three Babcock & Wilcox pressurized water nuclear reactors with a combined electric power generating capacity of approximately 2.658 megawatts. Unit I began commercial operation on July 15, 1973. Unit 2 began commercial operation on September 8, 1974 followed by Unit 3 on December 16, 1974.

The 1 0-mile plume exposure pathway EPZ encompasses parts of Oconee and Pickens Counties in South Carolina, with the site being physically located in Oconee County. Land use is primarily agriculture and timber, with light industries scattered throughout both counties. The Oconee County Airport is located Xwest of Clemson, South Carolina. inside the 10-mile EPZ. The Norfolk &

Southern Railway passes within six miles of the plant. Railways connect the towns of Walhalla, Seneca, Clemson, and Norris.

The major population centers within the 1 0-mile EPZ include WValhalla, Seneca.

and Clemson, including Clemson University. Total population for the 10-mile EPZ is 74,185.

Prevailing winds move generally from west to east over the facility, but due to foothill terrain, may not always follow this pattern. There are 13 emergency response planning areas.

B.

Exercise Participants In addition to the Oconee Nuclear Station. the following agencies. organizations, and units of government participated in the Oconee Nuclear Station exercise on January 13, 2004.

4

STATE OF SOUTH CAROLINA Office of the Adjutant General, Emergency Management Division Department of Health & Environmental Control, Bureau of Land Waste Management Department of Social Services Department of Public Safety, Bureau of Protective Services, and Highway Patrol Department of Natural Resources, Law Enforcement Division RISK JURISDICTIONS Oconee County Pickens County IhOST.JURISDICTIONS Anderson County Greenville County PRIVATE/VOLUNTEER ORGANIZATIONS American Red Cross Radio Amateur Civil Emergency Service Salvation Army C.

Exercise Timeline Table 1. on the following page, presents the time of key events and activities during the Oconee Nuclear Station exercise on January 13, 2004.

5

r~- -

r----

r-,--

r~--

r-oe r----

F--

r--f-l-

V--

F-r---

rV-Table 1. Exercise Tinieline F:- eFm row DATE AND SITE: January 13, 2004 - Oconee Nuclear Station Emergency Time Time That Notification Was Received or Action Was Taken Classification Utility LCYCI or Event Declared SoOC DeSE-FEOC LP-I Radio Stalion JIC OCONEECO PICKENS CO Alert 0816 0836 0844 0836 0829 0835 Site Area Emergency 0952 1007 1008 0959 1005 0944 General Emergency 1115 1125 1115 1118 1129 1100 Simulated Rad.

0952 1051 0945 1050 1044 0935 Release Started Simulated Rad.

End Exercise Release Terminated Facility Declard Operational I1 008ioJ 0855 0845 0939 1006 0842 Declaration of State of Emergency 0900 0900 l

0905 l

0922 0940 ExerciseTerminated IEOF 12501 l

1214 1310 1248 1212 1143 I-arly Precautionary Actions:

Clemson University Evacuation 10SS 1018 0830 Schools evacuated/relocated 1 0U4 and special needs notified and/or evacuated (0836 1040 Lake clearing I

1 1044 I' Protective Action Decision:

1044 1044 1044 Notify piblic. stay tuned l1 Siren Activation-Acttial 1047 10S0 1047 1049 lI EAS Message 10St(

J I()S0 1050 1050 1052 l

1050 2"' Protective Action Decision 1140 j

1150 I

t)0 1140 1140 Evacuate Zone(s): Al. A2.11.132. Fl Shelter-in-Place: All other zones 2'dSiren Activation-Simulated 1145 1150 1150 1145 1145 2 EAS Message-Simulated 1148 l

1150 1150 !

1148 1148 l KI Administration t)ecision:

T I

I I

I Distribute to EWs and institutionalized only 1040 1

00 1 21 0

1104 1

1044 llDo not inuest.-

I

IV.

EXERCISE EVALUATION AND RESULTS Contained in this section are the results and findings of the evaluation of all jurisdictions and fuinctional entities, which participated in the January 13, 2004 exercise to test the offsite emergency response capabilities of State and local governments in the 10-mile EPZ, surrounding the Oconee Nuclear Station.

Each jurisdiction and functional entity wvas evaluated on the basis of its demonstration of criteria delineated in the Exercise Evaluation Areas, Interim REP Program Manual, August 2002. The agreed upon Exercise Evaluation Criteria and the extent-of-play agreement used in this exercise, are listed in Appendix 3 of this report.

A.

Summary Results of Exercise Evaluation - Table 2 The matrix presented in Table 2, on the following page(s), presents the status of all exercise evaluation area criteria, Interim REP Program Manual, August 2002, vwhich were scheduled for demonstration during this exercise, by all participating jurisdictions and functional entities. Exercise evaluation areas are listed and the demonstration status of the 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) 7

K-7r-F.---.

F.7 I-V.

r7 r

r---

r--

r -- - -

w-, [--r v -

Table 2. Summary Results of Exercise Evaluation DATE AND SITE: January 13, 2004 - Oconee Nuclear Station ELEI ENT/Criterion SECo' D)HIEC OCONEE PICKENS ANDERSON GREENVILLE COUJNTY COUNTY COUNTY' COlJNTY

1. EM! ERGENCY OPERATIONS NIANAGEM ENT COUNTY COUNTYCOUNTYCOUNTY I.a.l. Nlobili ation M

NI NI NI I.b.1. Facilities I.c. I. Direction and Control NI Ni NI N1i I.d. l. Communications Equipment NI NI N1 NI NI NI I.e. 1. Eqtuipment & Supplics to Sapport Operationis M

N1 NI NI

2. PROTECTIVE ACTION DECISION IMAKING 2.a. 1. Emergency Workcr Exposure Control Ni Ni NI 2.h.1. Radiological Assessment & PARs Based on Available Infirmation N1I 2.h.2. PAIs for the General ltihlic NI NI Ni N1 2.c. 1. Protective Action Decisions fIor Special P'opuIlations Ni NI 2.d.1. Radiological Assessment & Dccision NMaking fIor Ingestion Elxposurc 2.c. i. Rad Assessment & Decision NMaking lor Rclocation. Re-entry & Return

3. PROTECTIVE ACTION IMPLEMENTATION 3.a. 1. Implementation ol Elmergency Worker Control N1 N

NI NI N

NI 3.h. 1. Implemenlation or KI Decisions NI M

NI NI 3.c. 1. Implementation of l'ADs fir Special Populations

_I N

N1h1 3.c.2. Implementation oll'fADs for Schools NI Ni 3.d. 1. Implementation of lraffic and Access Control NI 3.d.2. Impediments to livacuation and TraI1ic and Access Control NI 3.e. I. Implementation of Ingestion Decisions Using Adequate Infloiation 3.c.2. Implementation of 11' I)ecisions Showing Strategics and Instructional Niaterials

_ 3.1:.1. Implcientation ofRelocation. Re-eyarnd Retr m cisions_

4. FIELD MIEASUREM^ENT and ANAIYSIS 4.a.1. Pluime Phase Field N1casurement & Analysis l anipmentN 4.a.2. Ac1time aihase F ield N leasurament & Anatysis NMnarnIIent N1 4.a.3. I'lttme l'hasec Field Nivasuirements &, Analysis l'rniceduires 4.h. 1. I'ost Plunic F~idd M~easuircment & Analysis _=

4.bh.2. Lahoratorv Operations N1 S. El\\ERGENCY NOTIFICATION & PUBLIC INFORMNATION S.a. I.Activation ol Prompt Alen and Notilication N1 N1 h

N S.a.2. Activation of 'rompt Alert and Notification 15 NMintite lReservedl 5.a.3. Activation o l'Prompt Alert and Notification Backup Alert and Notification1 NI N1 5.h. I. E.mergencv Information and Instmnctions for the Public and the NMedia NI NI N1

6. SUPPORT OPERATIONS/FACILITIES 6.a.1. Monitorinpand Decon ol E vacuees and EWs and Registration of lEvactuees Ni NI Ni NI 6.h. 1. NMonitoring and I)econtamination of Emereency Worker Equiipment NI N1 6.c. I. Temporary Care of E-vactices NI N1 6.d. L.-Tramportation andIreatment ofiContamniated Injured Individual; LEGEND:

N1 = MET A = ARCAs D = DEFICIENCY

• SEOC includes traffic control and lake clearing

B.

Status of Jurisdictions Evaluated This subsection provides information on the evaluation of each participating jurisdiction and functional entity, in a jurisdiction based, issues only format. Presented below is a definition of the terms used in this subsection relative to criterion demonstration status.

Met - Listing of the demonstrated exercise criteria under which no Deficiencies or 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 the demonstrated exercise criteria under which one or more ARCAs %vere assessed during the current exercise or ARCAs assessed during prior exercises that remain unresolved.

Included is a description of the ARCAs assessed during this exercise and the corrective action demonstrated if ARCA w 'as corrected on the spot or the recommended corrective action to be demonstrated before or during the next biennial exercise.

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

Prior ARCAs - Resolved - Descriptions of ARCAs assessed during a previous exercise. which wvere resolved in this exercise, or during a previous exercise, and the corrective actions demonstrated.

Prior ARCAs - Unresolved - Descriptions of ARCAs assessed during a previous exercise, which were not resolved in this exercise. Included is the reason the ARCA remains unresolved and recommended corrective actions to be demonstrated before or during the next biennial exercise.

The following are definitions of the only two types of exercise issues which may be discussed in an exercise report.

A Deficiency is defined in DHS/FEMA-REP Interim Program Manual, August 2002: "...an observed or identified inadequacy of organizational performance in an exercise that could cause a finding that offsite 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."

9

An ARCA is defined in DHS/FEMA-REP Interim Program Manual," August 2002 as "...an observed or identified inadequacy of organizational performance in an exercise that is not considered. by itself, to adversely impact public health and safety."

DHS/FEMA has developed a standardized system for numbering exercise issues (Deficiencies and ARCAs). This system is used to achieve consistency in num11nbering exercise issues among DI-IS/FEMA Regions and site-specific exercise reports within each Region. It is also used to expedite tracking of exercise issues on a nationwide basis.

The identifying number for Deficiencies and ARCAs includes the following elements, 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.

Exercise Evaluation Element - A number, letter and number corresponding to the evaluation area criteria number, REP Interim Program Manual, August 2002.

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

Exercise Issue Identification Number - A separate two digit indexing number assigned to each issue identified in the exercise.

10 L

1.

STATE OF SOUTH CAROLINA 1.1 State Emergency Operations Center The State Emergency Operations Center (SEOC) is a modern facility with state of the art technology. Direction and control was coordinated and demonstrated by the Emergency Management Director and Chief of Operations. which resulted in a well executed emergency response by the overall staff. The Internet Routed Information System (IRIS) and checklists being utilized by all staff members provided up-to-date situational information and a systematic approach to problem solving. Protective action recommendations (PAR) and decisions Xwere made in coordination with the counties.

They Nvere discussed during periodic briefings in the SEOC with input from Department of Health and Environmental Control (DIHEC) and the utility. The SEOC staff is commended for their attention to detail in the decision-making process. Alert and notification of the public following the Site Area Emergency (SAE) and General Emergency (GE) were well executed and performed with a sense-of-urgency.

a.

MET EVALUATION AREAS: L.a.1, I.c.I, 1.d.1, L.e.1, 2.b.2, 5.a.I and 5.b.l

b.

DEFICIENCY: NONE

c.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE

c.

PRIOR ARCAs - RESOLVED: NONE

f.

PRIOR ARCAs-UNRESOLVED: NONE 1.2 Dose Assessment - EOC Liaison The DHEC Emergency Response Coordinator (ERC) demonstrated the ability to organize and coordinate DHEC s operation su.pporting PARs and radiological exposure control.

The ERC was aggressive in getting data both from the Forward Emergency Operations Center (FEOC) and the plant. One instance of note was obtaining clarification directly from the plant when there was confusion concerning the extent of the radiological release. The DHEC staff at the SEOC maintained close communications with all DHEC field elements throughout the exercise. The ERC developed appropriate and timely PARs for the Emergency Management Director. The ERC monitored exposure control and conducted an ongoing assessment regarding the use of potassium iodide (KI). The ERC demonstrated an excellent understanding of the accident conditions at the Oconee Nuclear Station as portrayed in the exercise. The ERC and staff were knowledgeable of the State Plan and the agency specific standard operating procedures (SOP).

11

a.

MET EVALUATION AREAS: I.a.l, I.c.], I.d.l. 2.a.1, 2.b.1 and 2.b.2

b.

DEFICIENCY: NONE

c.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE

c.

PRIOR ARCAs - RESOLVED: NONE

f.

PRIOR ARCAs - UNRESOLVED: NONE 1.3 Dose Assessment - Clemson The Director of the FEOC demonstrated good command and control. Proactive efforts were made to obtain data in a timely manner by directly contacting the Oconee dose assessment staff. The use of the IRIS system for monitoring events and logging in key activities was effectively demonstrated. The dose assessment coordinator competently performed dose projections using the RASCAL computer model. Reasonable agreement was obtained with the Oconee plant dose model results. This information was provided to the DHEC Emergency Response Coordinator at the SEOC. Field team management and coordination with the Oconee plant field teams was effectively demonstrated. The mobile laboratory capability to receive, screen and analyze field samples was demonstrated.

a.

MIET EVALUATION AREAS: Criteria l.a.l, I.c.l. I.d.l, L.e.l. 2.a.1, 2.b.1, 3.a.1, 3.b.I and 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 12 L

1.4 Radiological Laboratory '

DHEC's Radiological Laboratory personnel demonstrated their ability to conduct analysis of environmental samples out-of-seqLience. The laboratory staff is qualified in radioanalytical techniques and contamination control procedures. The personnel were also knowledgeable of radiological exposure control. The DIHEC radiological laboratory staff demonstrated the capability to'perform laboratory analyses of radioactivity in air, liquid and environmental samples.

The mobile laboratory was deployed to the FEOC. The staff demonstrated the use of forms and contamination control techniques. They successfully demonstrated the correction of the ARCA identified during the 2002 Oconee exercise.

a.

MET EVALUATION AREAS: L.e.l, 3.a.I and 4.c.1

b.

DEFICIENCY: NONE C.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED:' NONE

e.

PRIOR ARCAs - RESOLVED:

Mobile Laboratory IssueNo: 42-02-4.c.1-A-02

==

Description:==

Existing practices and procedures by both the field monitoring teams and mobile laboratory staff were inadequate to control and prevent cross-contamination of environmental'samples. 1) The chain-of-custody form has spaces for recording multiple samples and if used for more than one sample could easily be separated from its associated samples during processing in the mobile lab. 2) A standardized method of labeling environmental 'samples was not used.

3) Environmental samples were not double-bagged to prevent cross-contamination. 4) At the mobile lab. the technician assigned to sample receipt used one pair of rubber gloves throughout the entire exercise. This same technician also performed vehicle and personnel radiation monitoring activities.

There was no organization or segregation between potentially contaminated areas and the known clean area at the sample reception area. The sample receipt table zvas not dedicated to that task. Instruments, personnel dosimeter documents, various supplies and an empty soda can were all on the table at one time.

Although a step off pad was established several individuals crossed the pad ignoring standard exit control practices.

13

Corrective Action Demonstrated: The mobile laboratory wvas pre-staged at the FEOC. Laboratory personnel arranged a sample receipt and screening process in the back yard of the armory referred to in procedures as a restricted area. A table covered in disposable paper was placed at the back gate of the armory. A sample relay carrier or field teams were to be stopped at this point. A laboratory person dressed in protective clothes was responsible for unloading the bagged field samples and also for conducting a radiological survey of personnel and the delivery vehicle. If the v'ehicle is found to be contaminated the FEOC Coordinator was to be contacted as to wvhere the vehicle should be sent for decontamination. Any sample reading above the background level was taken to the table for smears and smear counting. The samples were placed in a zip lock bag and the bag smear was attached along with the results of the smear count.

The sample delivery person or field team member would then be asked to proceed to processing station two. At this location personnel wvould step through a portal monitor. If it alarmed they would be stopped for manual survey and appropriate processing. The bagged samples were handed to the receiving table where they were surveyed. If the surface dose rate was below 100 milli rem per hour the bags were to be processed for transfer to the laboratory in Columbia. If the dose rate exceeded this level it was to be processed for counting at the mobile laboratory.

At Station 2, the chain of custody form on the sample was filled out and a unique identification number assigned. One chain of custody form per sample was prepared. Contamination control was exercised. A demonstration of this process was conducted using an iodine air cartridge sample.

All laboratory personnel wore protective clothing including gloves and eye protection. Contamination control measures were in effect. Adequate contamination control supplies wvere available.

The bagged air cartridge sample and the chain of custody form were transferred to the mobile laboratory for counting. The mobile laboratory is equipped with a Lithium drifted Germanium detector and a Canberra gamma spectrum analyses system. The iodine cartridge information was input into the computer and the cartridge was counted for a representative time. A print out of the results displayed the unique identification number and other chain of custody information.

Laboratory personnel demonstrated their capability to screen samples, maintain chain of custody, exercise contamination control, and process samples in the mobile laboratory.

f.

PRIORARCAs-UNRESOLVED: NONE 14

1.5 Lake Clearing Two law enforcement officers from the Department of Natural Resources (DNR) successfully demonstrated the ability to clear the lake. The officers were wetell trained and lknowledgeable of their procedures and individual radiological protection. The officers took the evaluator, by boat, over Lake Hartwell to other designated public boat landings.

The signage pertaining to public emergency actions in event of siren activation wvas inspected at the boat landings. The signs were clearly visible and generally well maintained. The DNR law enforcement personnel were professional and well prepared.

a.

MET EVALUATION AREAS: I.d.l, 3.a.1, 3.b.1 and 5.a.3

b.

DEFICIENCY: NONE

c.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE PRIOR ARCAs-RESOLVED: NONE

f.

PRIOR ARCAs - UNRESOLVED: NONE 1.6 LP-1 Radio Station -WFBC The primary Emergency Alert System (EAS) radio station for the Oconee Nuclear Station is WFBC (93.7 FM) in Greenville, South Carolina. At 1045. the station received a request from the SEOC to broadcast a pre-approved test message for the Oconee Nuclear Station drill. The radio station personnel followed established procedures for authenticating the message with the SF.OC before initiating a live broadcast of message at 1050. The station's staff was knowledgeable of their role in supporting the EAS process and very professional in performing their responsibilities.

a.

MET EVALUATION AREA: 5.a.l

b.

DEFICIENCY: NONE

c.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE

e.

PRIOR ARCAs RESOLVED: NONE

f.

PRIOR ARCAs UNRESOLVED: NONE 15

1.7 State Traffic Control Points A Lieutenant of the South Carolina Highway Patrol (SCHP) was interviewed at the Oconee County Emergency Operations Center (EOC). He discussed SCHP operating procedures. the information packets provided troopers staffing traffic control points (TCP), and the pre-deployment briefing provided to the troopers. The packets contained operating instructions, dosimetry equipment, a copy of the Oconee Nuclear Station 2004 Emergency Planning Calendar, and information to assist the public. SCHP troopers established two designated TCPs. They were interviewed and demonstrated their knowledge of the operation of each TCP, radiological exposure control procedures and the use of K!. The troopers and the Lieutenant were aware of how to obtain assistance from the Department of Transportation for establishment of barriers and information on the removal of evacuation impediments.

All members of the SCHP were well trained, very well prepared. and highly professional in the execution of their assigned responsibilities.

a.

IMET EVALUATION AREAS: L.d.l. I.e.l, 3.a.l. 3.b.1. 3.d.1 and 3.1d.2

b.

DEFICIENCY: NONE

c.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE

e.

PRIOR ARCAs - RESOLVED: NONE

f.

PRIOR ARCAs-UNRESOLVED: NONE

2.

JOINT OPERATIONS 2.1 Joint Information Center The performance of the State, county and utility members of the Oconee Nuclear Station Joint Infornation Center (JIC) exemplified cooperation. coordination. and high professional standards. In the preparation and conduct of three media briefings and numerous emergency news releases, the experience of the more senior individuals ensured that utility and government spokespersons were well prepared to meet the media and impart timely, correct, and detailed information to the public. Actions taken in response to public and media inquiries were timely. Upon identification of trends or rumors, rapid actions were initiated to quell them. Concern for the safety of the population in the 1 0-mile EPZ was paramount in the actions of the JIC.

a.

MET EVALUATION AREAS: I.a.I, I.c.I, I.d.1, L.e.I and 5.b.1

b.

DEFICIENCY: NONE 16

c.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE C.

PRIOR ARCAs - RESOLVED: NONE

f.

PRIOR ARCAs - UNRESOLVED: NONE 2.2 Emergency Operations Facility, The utility operator's Emergency Operation's Facility (EOF) is an excellent facility from which all participating response organizations can effectively manage ongoing emergency operations. Communications, coordination, and the flow of technical information between the utility operator and the State officials were outstanding. All of the State officials deployed to the EOF were well trained. followed procedures; and overall, they performed their respective responsibilities in an efficient and professional manner.

a.

MET EVALUATION AREAS: l.b.l, l.c.l; 1.d.l, 1.e.1 and 2.b.1

b.

DEFICIENCY: NONE C.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE C.

PRIOR ARCAs - RESOLVED: NONE

f.

PRIOR ARCAs - UNRESOLVED: NONE

3.

RISK JURISDICTIONS 3.1 OCONEE COUNTY 3.1.1 Emergency Operations Center The EOC is staffed by a dedicated and progressive thinking group of professionals. The Emergency Management Director provided excellent direction and control. During briefings he requested frequent staff inputs. The flow of information and communication between the agencies was outstanding. The alert and notification of the public was accurate and timely with input from the County Council. The special needs program plans and procedures were'superb.'-

a.

MET EVALUATIONS AREAS: I.a.1, I.c.l, 1.d.1, L.e.1, 2.a.1, 2.b.2,2.c.1, 3.b.1, 3.c.1, 3.c.2, 5.a.1, 5.a.3 and 5.b.1 17

b.

DEFICIENCY: NONE

c.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE

c.

PRIOR ARCAs - RESOLVED: NONE

f.

PRIOR ARCAs - UNRESOLVED: NONE 3.1.2 Protective Actions for Schools Oconee County demonstrated the ability to implement protective actions for schools through interviews with the principals and staff at the James Brown Elementary, Code Elementary, Keowee Elementary, Ravenel Elementary and Tamassee-Salem Middle/Highl Schools. All schools had detailed plans and the staff was knowledgeable of their procedures and responsibilities for evacuation. The County has sufficient resources to relocate all students.

a.

IET EVALUATION AREAS: 3.a.1 and 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 3.1.3 Emergency Worker Decontamination The emergency worker and vehicle decontamination demonstration wvas conducted at the Westminster Middle School. Members of the Walhalla Fire Department were the primary wvorkers. The Westminster Fire Department supplied members for support roles.

The firefighters described the procedures for monitoring and documentation of individuals and equipment in accordance with their plans. Members of both departments reviewed the vehicle monitoring and decontamination process, and subsequent individual monitoring process. Communications was provided by mobile and hand held radios; both systems had repeater and local capability on six radio channels. The Walhalla Fire Department was dispatched to respond to a structure fire. and the remainder of the demonstration was curtailed.

18

a.

MET EVALUATION AREAS: L.e.1, 3.a.1, 6.a.I and 6.b.1

b.

DEFICIENCY: NONE

c.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE

c.

PRIOR ARCAs-RESOLVED: NONE

f.

PRIOR ARCAs - UNRESOLVED: NONE 3.2 PICKENS COUNTY 3.2.1 Emergency Operations Center The EOC Director and the Assistant Director effectively managed emergency response operations. They involved a competent and cooperative staff in the decision making process. EOC staff consistently coordinated waith the State and Oconee County in implementing precautionary actions and protective action decisions (PAD). EOC briefings and informative agency updates w ere conducted. Message distribution, public inquiry, and public information functions, and coordination to activate the sirens and issue EAS messages were accomplished. The participation of the County Administrator, a County Councilman, the State liaison, arid the utility representative provided vital input to this successful EOC operation.

a.

MET EVALUATION AREAS: I.a.], I.c.1, I.d.1, I.e.1, 2.a.1, 2.b.2, 2.c.1, 3.b. 1, 3.c. 1, 3.c.2, 5.a; 1, 5.a.3 and 5.b. 1

b.

DEFICIENCY: NONE

c.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE

c.

PRIOR ARCAs - RESOLVED: NONE

f.

PRIOR ARCAs - UNRESOLVED: NONE 19

3.2.2 Protective Actions for Schools Pickens County successfully demonstrated the ability to formulate and implement protective actions for schools through interviews conducted with the principals of Clemson Elementary, R.C. Edwards Middle School, and Daniel High School. The Clemson University representative, the Pickens County Transportation Coordinator, and the Pickens County Emergency Management Director also participated in the interviewv.

All were conscientious and very knowledgeable of the plans and procedures for emergency preparedness and evacuation of their institutions. All schools are equipped with primary and backup means of communications and are able to coordinate with buses supporting the evacuation. Clemson University provides its own transportation as needed for students, while public school buses are provided for the three other schools.

a.

MET EVALUATION AREAS: 3.a.1 and 3.c.2

b.

DEFICIENCY: NONE C.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE

e.

PRIOR ARCAs-IRESOLVED: NONE

f.

PRIOR ARCAs - UNRESOLVED: NONE 3.2.3 Emergency Worker Decontamination Members of the Pickens County Hazardous Materials Team (HAZMAT) successfully demonstrated emergency worker and vehicle decontamination at the Pickens County Prison Farm. An emergency vehicle was monitored, after which, the driver and passenger exited and were monitored for contamination. The HAZMIAT team properly monitored the emergency wvorkers and equipment and documented their findings on the appropriate forms according to their procedures. The Pickens County Command Unit provided external communications and coordination.

a.

MIET EVALUATION AREAS: 1.e.l, 3.a.1. 6.a.1 and 6.b.l

b.

DEFICIENCY: NONE C.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE C.

PRIOR ARCAs-RESOLVED: NONE

f.

PRIOR ARCAs - UNRESOLVED: NONE 20

4.

HOST JURISDICTIONS 4.1 ANDERSON COUNTY 4.1.1 Reception and Congregate Care.

Anderson County used the T. L. Hanna High School as its reception and congregate care facility. Experienced, well-trained personnel provided an excellent demonstration of vehicle and personnel monitoring and decontamination. The command and control function was strong and communication 'vas very good. The setup for vehicle and evacuee monitoring and decontamination was excellent.

The American Red Cross (ARC) managed the congregate care facility. The shelter manager and support staff demonstrated that they could provide services consistent with ARC guidelines. Congregate care staff assured that evacuees had been monitored before being registered into the facility. Anderson County management and staff are to be commended

a.

MET EVALUATION AREAS

I.e.1, 3.a.1, 6.a.1 and 6.c.1

b.

DEFICIENCY: NONE

c.

AREA REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE

c.

PRIOR ARCAs RESOLVED: NONE

f.

PRIOR ARCAs UNRESOLVED: NONE 4.2 GREENVILLE COUNTY 4.2.1 Reception and Congregate Care Greenville County demonstrated its procedures to monitor, decontaminate, register, and care for evacuees at its reception and congregate care centers at the Berea and Wade Hampton High Schools. Well-trained and professional members of the Berea Fire Department and the Wade Hampton Fire Department conducted the monitoring and decontamination of evacuees and their vehicles. They wvere knowledgeable of radiological exposure control, and successfully demonstrated their ability to monitor and decontaminate evacuees and their vehicles.

The Upstate and Greenville County Chapters of the ARC managed the congregate care centers with assistance from the South Carolina Department of Social Services (DSS) and the Sheriff's Department. The ARC verified that evacuees had been monitored prior to 21

being allowed to enter the congregate care facility. The ARC shelter managers and support staff demonstrated that the centers had the resources to provide services and accommodations consistent wvith ARC planning guidelines. Volunteers were well versed in their responsibilities and extremely professional in their demeanor.

a.

MET EVALUATION AREAS: l.e.l, 3.a.l, 6.a.l and 6.c.1

b.

DEFICIENCY: NONE

c.

AREAS REQUIRING CORRECTIVE ACTION: NONE

d.

NOT DEMONSTRATED: NONE

c.

PRIOR ARCAs - RESOLVED: NONE

f.

PRIOR ARCAs - UNRESOLVED: NONE 22 L

5.

SUMMARY

OF AREAS REQUIRING CORRECTIVE ACTION 5.1 PRIOR ARCAs RESOLVED 5.1.1 42-02-4.c.1-A-01 State of South Carolina Radiological Laboratory (Mobile Laboratory)

==

Description:==

Existing practices and procedures by both the field monitoring teams and mobile laboratory staff were inadequate to control and prevent cross-contamination of environmental samples. 1)

The chain-of-custody form has spaces for recording multiple samples and if used for more than one sample could easily be separated from its associated samples during processing in the mobile lab. 2) A standardized method of labeling environmental samples was not used. 3)

Environmental samples wvere not double-bagged to prevent cross-contamination. 4)

At the mobile lab, the technician assigned to sample receipt used one pair of rubber gloves throughout the entire exercise. This same technician also performed vehicle and personnel radiation monitoring activities.

There was no organization or segregation between potentially contaminated areas and the known clean area at the sample reception area. The sample receipt table was not dedicated to that task. Instruments, personnel dosimeter documents, various supplies and an empty soda can were all on the table at one time. Although a step off pad was established several individuals crossed the pad ignoring standard exit control practices.

Corrective Action Demonstrated: The mobile laboratory was pre staged at the FEOC. Laboratory personnel arranged a sample receipt and screening process in the back yard of the armory referred to in procedures as a restricted area. A table covered in disposable paper wvas placed at the back gate of the armory. A sample relay carrier or field teams were to be stopped at this point. A laboratory person dressed in protective clothes was responsible for 23

unloading the bagged field samples and also for conducting a radiological survey of personnel and the delivery vehicle. If the vehicle is found to be contaminated the FEOC Coordinator was to be contacted as to where the vehicle should be sent for decontamination. Any sample reading above the background level was taken to the table for smears and smear counting. The samples were placed in a zip lock bag, and the bag smear was attached along with the results of the smear count.

The sample delivery person or field team member would then be asked to proceed to processing station two. At this location personnel would step through a portal monitor. If it alarmed they would be stopped for manual survey and appropriate processing. The bagged samples were handed to the receiving table where they wcre surveyed. If the surface dose rate was below 100 milli rem per hour the bags were to be processed for transfer to the laboratory in Columbia. If the dose rate exceeded this level it was to be processed for counting at the mobile laboratory.

At Station 2, the chain of custody form on the sample was filled out and a unique identification number assigned. One chain of custody form per sample was prepared.

Contamination control was exercised. A demonstration of this process was conducted using an iodine air cartridge sample.

All laboratory personnel wore protective clothing including gloves and eye protection. Contamination control measures were in effect. Adequate contamination control supplies were available.

The bagged air cartridge sample and the chain of custody form were transferred to the mobile laboratory for counting. The mobile laboratory is equipped with a 24

Lithium drifted Germanium detector and a Canberra gamma spectrum analyses system.

The iodine cartridge information wvas input into the computer and the cartridge was counted for a representatix'e time. A print out of the results displayed the unique identification number and other chain of custody information.

Laboratory personnel demonstrated their capability to screen samples, maintain chain of custody, exercise contamination control, and process samples in the mobile laboratory.

25

APPENDIX 1 ACRONYMS AND ABBREVIATIONS The following is a list of the acronyms and abbreviations, Xwhich may have been used in this report.

ARC American Red Cross ARCA Area Requiring Corrective Action CFR Code of Federal Regulations DHEC South Carolina Department of Health and Environmental Control DIHS Department of Homeland Security DNR Department of Natural Resources DSS South Carolina Department of Social Services EAS Emergency Alert System EOC Emergency Operations Center EOF Emergency Operations Facility EOP Extent of Play EPZ Emergency Planning Zone FEMA Federal Emergency Management Agency FEOC Forward Emergency Operations Center GE General Emergency IRIS Internet Routed Information System JIC Joint Information Center KI Potassium Iodide NRC Nuclear Regulatory Commission NUREG-0654 NUREG-0654/FEMA-REP-1, Rev. 1, "Crileria for Preparation and Evaluation of Radiological Emnergency Response Plans and Preparedness in Support of Nuclear Powler Plants, Ndovember 1980 ORO Offsite Response Organization PAD Protective Action Decision PAR Protective Action Recommendation 26

RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Service REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan SAE Site Area Emergency SCLIP South Carolina Highway Patrol SEOC State Emergency Operations Center SOP Standard Operating Procedure TCP Traffic Control Point 27 L

APPENDIX 2 EXERCISE EVALUATORS The following is a list of the personnel who evaluated the Oconee Nuclear Station exercise on January 13, 2004. The organization represented by each evaluator is indicated by the following abbreviations:

DHS/FEMA

- Department of Homeland Security/

Federal Emergency Management Agency ICF

- ICF Incorporated NRC

- Nuclear Regulatory Commission Lawrence A. Robertson Co-RAC Chairman EVALUATION SITE EVALUATOR ORGANIZATION STATE OF SOUTH CAROLINA State Emergency Operations Center Stan Copeland DHS/FEMA DHEC Liaison Radiological Laboratory Emergency Operations Facility Joint Information Dose Assessment State TCP Lake Clearing LP-I Radio Station WFBC-Greenville 501 Rutherford Street OCONEE COUNTY Emergency Operations Center Helen Wilgus Dale Petroff Dale Petroff Robert Trojanowski Bill Larrabee Henry Christiansen Reginald Rogers Daniel Inman DHS/FEMA ICF ICF NRC ICF ICF ICF ICF ICF ICF Daniel Inman Rosemary Samsel Tom Reynolds Beth Massey Mike Dolder DHS/FEMA DHS/FEMA DHS/FEMA 28

Protective Actions for Schools Rosemary Samsel Emergency Worker Decontamination Paul Ringheiser PICKENS COUNTY ICF ICF Emergency Operations Center Robert Perdue Wendy Swygert Protective Actions for Schools Wendy Swygert Emergency Worker Decontamination Paul Ringheiser GREENVILLE COUNTY Reception/Congregate Care James Liglitner Wendy Swygert DI IS/FEMA ICF ICF ICF 1CF ICF 29

APPENDIX 3 EXERCISE CRITERIA AND EXTENT-OF-PLAY AGREEMENT This appendix contains the exercise criteria and the extent-of-play agreement which were scheduled for demonstration during the Oconee Nuclear Station exercise on January 13, 2004.

A.

Exercise Evaluation Area Criteria B.

Extent-of-Play Agreement The extent-of-play agreement on the following pages was submitted by the State of South Carolina, and was approved by DHS/FEMA Region IV. The extent-of-play agreement includes any significant modification or change in the level of demonstration of each criterion listed.

30

Extent of Play Agreement Oconee Nuclear Site Partial Participation REP Exercise January 13, 2004

1. Emergency Operations Marnagement.

Sub-element 1.a, Mobilization Criterion 1.a.1: OROs 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.1, 2, H.4)

All state and local government personnel will be pre-positioned. Alert rosters will be provided to FEMA evaluators and a discussion of call-down procedures will be conducted.

Sub-element 1.b, Facilities

'Criterion 1.b.1: Facilities are sufficient to support the emergency response.

(NUREG -0654, H)

Counties were evaluated to e'stablish a baseline for this exercise evaluation criteria during the September 17, 2002 biennial exercise.

Sub-element 1.c, Direction and Control Criterion 1.c.1: Key personnel with leadership roles for the' ORO provide direction and control to that part of the overall response effort for which they are responsible. (NUREG-0654, A.1.d., 2.a., b.)

Direction and Control will be at'the State Emergency Operations Center (SEOC). County Direction and Control will take place at the Oconee County and Pickens County Emergency Operations Centers (EOC).

State Emergency Response Team (SERT) participants include the 'Emergency Management Division (EMD);

ESF 8, Health and Medical Services (Department of Health & 'Envir6nmental Control); 'ESF 10, Hazardous Materials, (Department of Health and Environmental Control); and ESF 16, Emergency Traffic Management, (Departmient of Public Safety). A simulation cell will represent-the Office of the Governor, Office of the Adjutant General, FEMA Region IV, Georgia,; North Carolina and non-playing South Carolina state agencies. AII telephone calls will be made'by calling the simulation cell.

Sub-element 1.d, Communications Criterion 1.d.1: At least two communications 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.)

The Selective Signaling System (SSS) is the primary means of communication to notify off-site response forces. Backup to the SSS are commercial telephone lines, satellite telephone and the Local Government Radio (LGR).

Sub-element 1.e, Equipment and Supplies to Support Operations Criterion 1.e.1: Equipment, maps, displays, dosimetry, Potassium iodide (KI),

and other supplies are sufficient to support emergency operations. (NUREG-0654, H., J.10.a.b.e.f.j.k., 11, K.3.a.)

Potassium Iodide for emergency workers will be simulated by candy or other means (empty envelope marked KI).

A 14-day supply of KI for 7000 Emergency Workers and Institutionalized Individuals is stored at FNF County EOCs, and Health Departments and at DHEC headquarters in Columbia, SC.

Advance rosters of emergency workers are not maintained.

All radiation detection equipment will be inspected, inventoried, and operationally checked before each use. SCEMD maintained equipment will be calibrated or leak tested in accordance with existing plans by the South Carolina Emergency Management Division Radiological Lab.

At locations where traffic and access control personnel are deployed, the availability of appropriate equipment (e.g., vehicles, barriers, traffic cones and signs, etc,) will be described by 12w enforcement personnel.

2. Protective Action Decision Making.

Sub-element 2.a., Emergency Worker Exposure Control Criterion 2.a.1: 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.)

Dose limits for emergency workers are pre-determined. Emergency workers may voluntarily exceed dose limits only after being fully informed by OHEC of J:\\RESPONSE\\TRAINING\\REP\\ONS\\Extent of Play Agreement 04.doc 2

the biological effects of radiation and possible consequences of excessive exposure.

Sub-element -; 2.b.

Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency Criterion 2.b.1: 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.)

Protective action recommendations by DHEC will be based on an evaluation of information received from the licensee, independent dose assessments and simulated field monitoring data input.

Dose Assessment will be demonstrated and evaluated at the SCARNG Armory, Clemson, SC.

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., 1 0.M.)

Sub-element 2.c, Protective.Action Decisions Consideration for the Protection of 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.)

3. Protective Action Implementation.

Sub-element 3.a, Implementation of Emergency Worker Exposure Control Criterion 3.a.1: 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.)

Emergency Workers or emergency,-worker teams will use Self Reading Dosimeters (SRDs) and simulated Permanent Record Dosimeters (PRDs) to monitor and control their radiation exposure. Emergency workers in low exposure rate areas will use PRDs and may use direct reading dosimeters or place them in centralized areas.

J:NRESPONSE\\TRAINING\\REP\\ONS\\Extent of Play Agreement 04.doc 3

Dosimeters are distributed through county emergency operations centers.

Each county has an adequate inventory to support first-shift personnel.

Supplemental dosimeters will be provided in accordance with the South Carolina Dosimetry Redistribution Standard Operating Procedures, and will be discussed at the State Emergency Operations Center (SEOC).

Department of Public Safety, Highway Patrol and DHEC maintain and distribute their own SRDs.

Emergency workers will be interviewed to determine their knowledge of radiation exposure limits.

Sub-element 3.b, Implementation of KI Decision Criterion 3.b.l: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keepiny of the administration of KI for emergency workers and institutionalized individuals (not general public) is maintained. (NUREG-0654, E.7., J., 1 0.e.,f.)

KI is distributed to Emergency Workers prior to their being dispatched. KI is ingested by emergency workers on order by the DHEC State Health Officer or designee. Record keeping will be discussed at Oconee County and Pickens County EOCs.

Sub-element 3.c, Implementation of Protective Actions for Special Populations Criterion 3.c.1: Protective action decisions are implemented for special populations other than schools within areas subject to protective actions.

(NJUREG-0654, E.7., J.9., 10.c.d.e.g.)

O co ncc County and Pickens County will demonstrate the ability and resources to implement appropriate protective actions for special population groups. A list of people with special transportation needs will be provided to evaluators. Evacuation assistance will not take place.

Criterion 3.c.2: OROs/School officials decide upon and implement protective actions for schools. (NUREG-0654, J. 1 0.c., d., g.)

Oconee County will simulate school evacuations by out-of-sequence interviews with key school staff members.

Oconee County schools to be evaluated at 1:00 P.M., January 14, 2004 are:

James Brown Elementary Ravenel Elementary Code Elementary Tamassee-Salem Middle/High School Keowee Elementary J:\\RESPONSEXTRAINING\\REP\\ONS\\Extent of Play Agreement 04.doc 4

Pickens County schools to be evaluated at 8:00 A.M., January 14, 2004 are:

Clemson Elementary Edwards Jr. High Daniel High Clemson University Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654, J.1 0.g., j., k.)

Traffic and Access Control Points (TACP's) are pre-determined. The South Carolina Highway Patrol will demonstrate Traffic and Access Control on-scene. TACPs to be evaluated are:

A-1, Gap Hill and SC 183 B-1, Ridgedale Road and Dan Ross Road B-2, Old Seneca Road and Jones Mill Road C-1, Old Seneca Road and Toby Hills Road D-1, SC 130 and Katelynn Lane E-1, SC 130 and SC 183 Lake clearing operations will immediately follow TACP demonstration at Lawrence Bridge Public Boat Landing, Oconee County.

Oconee County Public Boat Landings to be inspected are:

Holder's Landing Seneca Creek Lawrence Bridge Seneca Marina Pickens County Public Boat Landings are:

Clemson Park and Recreation.

Twelve Mile Criterion 3.d.2: Impediments to evacuation are identified and resolved.

(NUREG-0654, J.1 O.,k.)

Actions to identify and remove impediments.to -evacuation will be demonstrated by discussion with the highway patrol supervisor at the Oconee County EOC.

J:\\RESPONSE\\TRAINING\\REP\\ONS\\Extent of Play Agreement 04.doc 5

4. Field Measurement and Analysis.

Sub-element 4.c, Plume Phase Field Measurements and Analyses Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654, C.3., 1.8., 9.,

J.11.)

The DHEC Mobile Radiological Laboratory and staff will be pre-staged for sample screening evaluation at the SCARNG Armory, Clemson, SC.

Laboratory sample analysis will be demonstrated out of sequence, 9:00 a.m.,

January 14, 2004 at the DHEC Radiological Laboratory, 2600 Bull Street, Columbia, SC.

Transportation of radiological samples will be simulated.

Analysis will be performed in compliance with (NUREG-0654, C.3., 1.8., 9., J.11.)

5. Emergency Notification and Public Information Sub-element 5.a, Activation of the Prompt Alert and Notification System Criterion 5.a.1: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized off-site emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current FEMA REP guidance.

(10 CFR Part 50, Appendix E & NUREG-0654, E.., a5.,

6., 7.)

The State Vvill coordinate Protective Action Decisions (PAD) with ihe CNief South Carolina county elected officials or designees. At Site Area Emergency, sirens and the Emergency Alert System (EAS) will be activated. A test EAS message will be transmitted to the Local Primary (LP-1) EAS station, (WFBC, Greenville, SC). A simulated EAS message and follow-on news release will be prepared but will not be transmitted to the LP-1 station. Copies of the simulated EAS message and news release will be provided to the FEMA evaluator at the SEOC. The LP-1 station will have staff available for interview during the EAS demonstration. At General Emergency, activation of the sirens and EAS broadcast will be simulated.

Criterion 5.a.3: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized off-site emergency officials to notify the public of an emergency situation. Backup alert and notification of the pubic is completed J:\\RESPONSE\\TRAINING\\REP\\ONS\\Extent of Play Agreement 04.doc 6

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)

If there is a siren failure, Oconee County and Pickens County will describe the back-up alerting system.

Sub-element 5.b, Emergency-Informration and Instructions for the Public and the Media Criterion 5.b.1: 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.ic.)

The State, Oconee County and Pickens County will demonstrate the ability to coordinate the formulationiand dissemination of accurate information and instructions to the news media at the Joint Information Center (JIC). Rumor control for the State will be demonstrated at the JIC.

Rumor control for Oconee and Pickens Counties will be demonstrated at the county EOC.

Rumor control personnel will provide a rumor calls log to the FEMA Evaluator.

6. Support Operations! Facilities Sub-element 6.a, Monitoring and Decontamination of Evacuees and Emergency Workers, and Registration of Evacuees 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.)

Reception Centers will be demonstrated out-of-sequence. At least six people will be monitored and 'registered. - Personnel decontamination will be demonstrated via walk-through and discussion. All necessary supplies will be on-hand. Walkways will not-be covered with barrier material. A monitoring productivity rate will be developed by the FEMA evaluator. Demonstration will include the necessary portable portal monitors and monitoring teams required to monitor 20% 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 />. At least two vehicles will be monitored and one vehicle decontaminated in accordance with local SOPs. Water will be used to demonstrate vehicle decontamination procedures.

Reception Centers to be evaluated are:

Anderson County, T. L. Hanna High School Greenville County, Berea High School and Wade Hampton High School J:\\RESPONSE\\TRAINING\\REP\\ONS\\Extent of Play Agreement 04.doc

7

Sub-element 6.b, Monitoring and Decontamination of Emergency Worker Equipment Criterion 6.b.1: The facility/ORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency worker equipment including vehicles. (NUREG-0654, K.5.b)

Emergency Worker Monitoring and Decontamination will be demonstrated out of sequence.

Two emergency workers will be monitored. Personnel decontamination will be demonstrated via walk-thru and discussion. One emergency vehicle will be monitored and decontaminated in accordance with local SOPs.

DHEC will provide technical liaisons to the respective county EOC's for consultation.

Emergency Worker Decontamination Points to be evaluated are:

Oconee County, Westminster Middle School Pickens County, County Prison Farm, 6:30 P.M., January 12, 2004 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 anrpriate prior to entering congregate care facilities. (NUREG-0654, J.10.h., 12.)

County shelters will be demonstrated out-of-sequence and concurrently with Evaluation Area 6.a, above.

Procedures that assure that only non-contaminated persons enter shelters will be demonstrated.

J:\\RESPONSE\\TRAINING\\REP\\ONS\\Extent of Play Agreement 04.doc 8

APPENDIX 4 EXERCISE SCENARIO This appendix contains a summary of the simulated sequence of events, which was used as the basis for invoking emergency response actions by OROs in the Oconee Nuclear Station exercise on January 13, 2004.

This exercise scenario was submitted by the State of South Carolina and approved by DFIS/FEMA Region IV.

31

Oconiee Nuiclear Site 2004 Einerg'ency Resv)ouwse Drill Drill 04-01 l Iilial Co(lndiiois n!

O

i,.;

t,;;.

i.rt,.e',

i,.

INITIAL CONDITIONS Unit I 100° O Power Core is at 410 Effective Full Power Days (EFPD) withi a continuous run of 185 days. End Of Cycle (EOC) -22 refueling outage is scheduled to begin on January 24th.

At 0700 the control room received an alami indicating low oil level in IA2 Reactor Coolant Pump (RCP). Maintenance personnel are in the Reactor Building investigating the alann.

I KI Inverter is bypassed.

Unit 2 Shutdown w ith the reactor defueled. Unit was siutdowin based on B&W analysis and NRC recommendation to investigate potential of core barrel cracking. Cracks were found earlier in December in another B&W unit.

Condensate System is being maintained in recirc/cleanup mode. Condenser and Upper Surge Tank are full. Condenser Cooling Water (CCW) System is in operation with A, B, and D CCW pumps in service.

Main1Iransfonner is backcharged to provide power to unit's auxiliary electrical loads.

Unit 3 Slhuitdown willith tle reactor defueled. Unit was siutdown i based on B&W analysis and NRC reconimmendation Lu investigate potential of core barrel cracking. Cracks were found earlier in December in another B&W unit.

Condensate System is beint maintained in recirc !lckanup modc. Condenser --d UIpp-r Surge Tank are full. Condenser Cooling Water (CCW) System is in operation with A, B, and C CCW pumps in senrice.

Main Transfomier is backcharged to provide power to unit's auxiliary electrical loads.

Keowee Ilydro Units 1&2 are operable; no problems Lee Combustion Turbines available if needed; no problems The Aux Service W\\ater Pump Switchgear is energized from CT-5 for perfonmance test of the Aux Service VNater Pump. Testing of the Aux Service Water Pump is scheduled to begin at approximately 0800.

Oconee Nuclear Site 2004 Emergency Response Drill Drill 04-01 Initial Conditions I.

t;*

• s,.'

INITIAL CONDITIONS Weather Forecast A slow moving Low Pressure Front has moved into South Carolina wdith a stationary Lowv Pressure Area located near Columbia.

Winds from South-West (225°) and from 0 - 15 mph are expected. The low lemperature for January 13 is 320F with a higch of 58TF.

Oconce ANucclear Sitc 2004 Emzergecy Responise Drill Drill 04-01 Sequence Of Events K

SEQUENCE OF EVENTS 0800 Two Maintenance Technicians enter Unit l's Rxl3 to detennine the oil level in IA2 RCP Lower Oil Pot.

While closing the personnel hatch from inside the reactor building, the keyway Ley on the door's hand wheel drops out and falls between the personnel hatch and the reactor building floor. The maintenance technician's are unable to retrieve this key.

0810 Design Basis Earthquake (>0.05g, O.0Sg actual) occurs:

Control Room/Site personnel feel tremor L

Seismic Trigger Alann, ISA-9, E-l, actuates MIC SEISM1IC RECORDER (DO201) is recorded on alarm typer Strong Motion Accelerometer (SINIA-3) event indicator changed from black to white -

L I A Feedwatcr (FDU') Pump Recirc piping shears at cOnderiser Condenser looses vacuum Turbine trips L

IA and IB Ft) W Pumps trip Reactor (Rx) trips All Emergency FD% pumps start j

Aux Service Water pump suction piping fails at pump - Aux Building begins to L

flood t 800-1000 gpm.

Unit I & 3 Low Activity Waste Tank levels start to slowly increase L

ltMiscellaneous Waste Holdup Tank levels start to slowvly increase LPI Pump Rooms start to flood 4

~Maintenance Technicians exit the RxB through the Emergency Personnel Hatch While exiting the hatch, the Inner Hatch Door fails to secure and latch; Outer llatch Door is secured. Control room does not receive Inner Hatch Door Open light due to an electrical fault.

L

Oconiee Niclear Site 2004 Eniertgency Respons.ve Driill Driill 04-01 wSeqenCe Of Eveims SEQUENCE OF EVENTS 0815 Control Room personnel initiate APl/IAJll700/05, Earthquake Operations Shif NManager (OSNI) initiates Emergency Plan using I1l'i'O//li000l, Emergency Classification Conditions for an Alert classification exist 0815 - 0825 OSM initiates RP,0/1B/1000102, Control Room Emergency Coordinator Procedure 4

TSC. OSC, EOF activation initiated 4

Site Assembly initiated per RPl'OlIlOB0010/9, Procedure For Site Assembly 4

Control Room Offsite Communicator prepares Emergency Notification Form per RP/0/1/1000/15A, Offsite Communications From The Control Room 4

Control Room personnel request I&E to analyze data from Tendon Gallery Peak Acceleration Recorder (PAR-400) and the Strong Motion Accelerometer (SNIA-3) 4 Control Room personnel notified of flooding in Aux Building and of damape to the UWorlid Of Energy 0825 - 0830 Alert declared based on Tremor Felt and Seismic Trigg.er Alarm Actuales (6.0 go).

4 Ofl'site agencies notified as per RMOll3/1ooo/15A, Offsite Communications From Thc Control Room 0845 - 0855 Site Assembly Completed (30 minutes after initiation of Site Assembly)

TSC/OSC Staffed and operational. turnover completed between OSMI and TSC Emergency Coordinator. TSC is activated.

Operations personnel secure Aux Service Water leaklage by securing Unit 2 Condenser Cooling Water (CC"i') pumps and closing their respective discharge valves and 2CCW-4 I.

Even wvith the discharoe valves close z 3.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of water remains in the CCW piping.

L Oconiee Nuclear Site 2004 Emergency Response Drill Drill 04-01 Sequence Of Events SEQUENCE OF EVENTS 0855 - 0910 OSC teams asscss plant damage - damage is obscrved at the Oconee Office Building and L

Administration Building Efforts in progress to recover from Aux Building Flood Emergency Coordinator may relocate personnel from the Oconee Office Building and L

Administration Building based on observed damage and personnel safety concerns. If personnel are relocated, RP/O/B/1000/10, Procedure For Emergency Evacuntion/

Relocation or Site Personnel and NSD 114, Site Assembly/Sile Evacuation vould be utilized to determine appropriate actions.

L tActnal relocation of personnel, n be simnulated.

0910 NRC notificd over ENS; ERDS started (data hill not be provided to NRC)

L EOF Director notifies TSC Emergency Coordinator that the EOF is Operational and ready for turnover L

Field Monitoring Team(s) report damage to H fighway 183/130 approaches to bridge over

-intaloe canal L

0920 lA2 RCP motor seizes due to loss of oil 4

Control room receives indications of severe vibration L

A2 RCP breaker trips open

- >0925 t4O Fuel Clad damagc occurs as a rcsult of metal fragments cenerated by damage to IA2 K

RCP Impeller 0925 - 0935 Turnover completed between TSC and EOF: EOF declared activated RCS samples indicate DEI 300 CLCi'ml; increase in Aux Bldg RIAs observed 0945 Small break-LOCA (-400 gpm) occurs inside Reactor Building (RxB) on I B I RCP L

discharge line 4

RxB pressure increases Full High Pressure Injection is unable to maintain Sub Cooling Margin

>0°F 4

IA LPI pump starts on ES Signal

Oconee ANutclear Sile 2004 Enzergency Response Drill Dr-ill 04-01

.Sequence Of Events SEQUENCE OF EVENTS 0945 1 1 B Lill pump will not start on ES Signal; if Control Room operators attempt to manually start IC LPI pump it wvill not start either (Boilt pumps amre ih roomlis riat have heen affected krnflooding) 4 RIA-57 increases to 80 RMir; RIA-58 increases to 40 Rhr Conditions exist forSite Area Enmergencigy classification 1000 Site,rea EniergenL3 declared based on Loss Any Two Barriers - RCS Leak Rate >

Available Makeup Capacity As Indicated By A Loss Of Subcooling; RIA 57/58 > 80/40 RMhr (or Coolant Activity Ž 300 pCinil DEII)

EOF Director notifies State/Count)' Emergency Preparedness Director(s) of classification upgrade TSC notifies NRC of classification upgrade Emergency Coordinator may relocate/exacuate non-essential personnel. Site EvacuationiRelocation would be conducted using RP/0/B/1 000/10. Procedure For Emergencv Evacuation/Relocation or Site Personnel and NSD 114, Site Assemblv iSite Evacuatiuro.

,Atuafl evactUuationlrehlcutiton o(fjersonlnlLel will he Sinmulated.

1000 - 1015 Almil and Notification Sxstcim activated by Counties (Sirens and EAS Niessacet 1030 IA LPI tumpim) trips (if-in.service) due to floodimn in the A LPI Pump room If not inl ser-vice, 1.1 LPI punmp wtill not srart oni ES Signal Aner I 100 Afler-shock itMl a magnitude of- 0.05 g occurs 4

Aflershock enables Emergency Personnel Outer I latch door to fail 4

Control Room receives open indication lig-hts for both the Inner and Outer Emergency Personnel Hatch doors - Stat Alarm Activated Due to othe, control roommi activities, opcrators way not notice open indication lights (red) 1100 - 1145 Steam is observed leaking from the RxB around RxB Emergency Personnel Hlatch Field Monitoring Teams begin to detect activity at Site Boundan' Conditions exist for General Enmergency Classification L

I A and I B BS Pumps unavailable due to flooding conditions L

Ocoizee Nuclear Site 2004 Emergenicy Reuporise Drill Drill 04-01 Sequence Of Events SEQUENCE OF EVENTS 1115 Ge eral Fme-iergency declared based on:

Loss or All Three Blarriers - RCS Leak Rate > Available Makeup Capacity As Indicated By A Loss Of Subcooling; RiA 57/58 2 80/40 Rl/hr (or Coolant Acti ity 2 300 pCi/mI DEI); and, Containment Isolation Is Incomnplete And A Release Path To The Environment Exists.

S115

- 1130 EOF Director notifies State/Counties The following Protective Action Recommendations are provided to State/Counties:

Evacuate sectors in a two mile radius and five miles downwind. Slicter any sectors not evacuated.

Additional Protection Action Recommendations may be made, depending upon Field Monitoring Team readings/Dose Assessment recommendations.

1130 - 13Q00 Exercise continues until objectives are tested TSC/OSC!EOF develop Reco'er.'Re-entry plan