ML041820212

Final Exercise Report for St. Lucie Nuclear Power Plant, 02/18/04

ML041820212
Person / Time
Site:	Saint Lucie
Issue date:	04/23/2004
From:	Mark Miller US Dept of Homeland Security, Federal Emergency Management Agency
To:	Reyes L NRC/RGN-II
schneck D 415-2079 nsir dpr
References
Download: ML041820212 (88)

Text

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- FEMA FL Exercise Report Li Li ST. LUCIE NUCLEAR POWER PLANT Licensee: Florida Power and Light Company Exercise Date: February 18, 2004 Li Report Date: April 23, 2004 LI LI Li Li Li Li ivi %4esfania.gov

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- FEMA April 23, 2004

-Mr. Luis A. Reyes Regional Administrator - RIl Nuclear Regulatory Commission 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30323

Dear Mr. Reyes:

L Enclosed is a copy of the final exercise report for the partial participation, plume exposure pathway exercise of the offsite radiological emergency response plans site-specific to the St. Lucie Nuclear Power Plant. This report addresses the evaluation of the plans and preparedness for the State of Florida, the Risk Counties of St.

Lucie and Martin, as well as, the Host Counties of Indian River, Palm Beach and Brevard. Copies of this report will be forwarded to the State of Florida, FEMA and NRC headquarters by my staff.

The State of Florida has a unique method of decision-making. The State Forward Emergency Response Team and the decision-makers from St. Lucie and Martin Counties co-locate in Florida Power and Light Company's EOF. This location allows for rapid and thorough communication between the utility and the offsite authorities. Decisions are rapidly communicated to the respective County EOCs for implementation.

St. Lucie and Martin Counties demonstrated their commitment to public health and safety during this L exercise, both through operations at their respective EOCs and excellent demonstrations of emergency worker monitoring and decontamination.

The Host Counties of Brevard, Indian River and Palm Beach demonstrated the distribution of potassium iodide (K!) to the public during their demonstrations at their reception centers. This was the first distribution of KI to the public demonstrated in the State of Florida and all three Counties did an excellent job with the X. process. No Deficiencies were identified, however, Palm Beach County did have two Areas Requiring Corrective Action (ARCA) identified during their demonstration of evacuee monitoring. Both ARCAs have been corrected and pose no threat to the public. The first ARCA was for equipment that had not been properly calibrated; this has been corrected by both calibration by the State and documentation from the manufacturer specifying calibration requirements. The second ARCA was for lack of contamination control

• and was corrected immediately by on-site training and re-demonstration. All agreed upon evaluation criteria

- for the exercise were demonstrated.

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Based on the results of the February 18, 2004, exercise and FEMA's review of Florida's Annual Letter of Certification for 2003, the offsite radiological emergency response plans and preparedness for the State of Florida and the appropriate local jurisdictions site-specific to the St. Lucie Nuclear Power Plant can be implemented and are 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 offsite radiological emergency response plans and preparedness for the State of Florida site-specific to the St. Lucie Nuclear Power Plant, granted on February 14, 1984, will remain in effect.

Should you have questions, please contact Helen Wilgus at 770/220-5560.

Sincerely, Mary Lynne Miller Acting Regional Director Enclosure cc: Ms. Vanessa E. Quinn, Chief Department of Homeland Security/FEMA Headquarters Radiological and Emergency Preparedness Branch - PT-CR-RP 500 C Street, Suite 202 Washington, D. C. 20472 Ms. 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 Commission Washington, D.C. 20555-0001

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>flat FEMA Exercise Report ST. LUCIE NUCLEAR POWER PLANT Licensee: Florida Power and Light Company Exercise Date: February 18, 2004

!L Report Date: April 23, 2004 I

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TABLE OF CONTENTS Paae TABLE OF CONTENTS ................. i I. EXECUTIVE

SUMMARY

.................................................................................................I II. INTRODUCTION ................................ ;2 LII. EXERCISE OVERVIEW ................................. 4 A. Plume EPZ Description ................................. 4 B. Exercise Participants ................................. 4 C. Exercise Timeline ................................. 5 IV. EXERCISE EVALUATION AND RESULTS ....... ......................... 7 A. Summary Results of Exercise Evaluation - Table 2 ................................... 7

!L B. Status of Jurisdictions Evaluated .................................... 9

1. STATE OF FLORIDA ................................... 10 1.1 State Emergency Operations Ccnter ....................................... 10 1.2 Forwnard State Emergency Response Team ................................... 10 L 1.3 Emergency News Center ....................................... 11 1.4 Dose Assessment ........................................ 11 1.5 Emergency Operations Facility ....................................... 12 1.6 Radiological Field Monitoring Teams ....................................... 12 1.7 Radiological Laboratory ............ ........................... 13

2. RISK JURISDICTIONS . . ................................13 2.1 St. LUCIE COUNTY ....................................... 13 2.1.1 Emergency Operations Center ....................................... 13 L 2.1.2 Protective Actions for Schools ....................................... 14 2.1.3 Emergency Worker & Vehicle Decontamination .............. 14 L 2.1.4 Traffic and Access Control ....................................... 15 L

2.2 MARTIN COUNTY ......................................... 15 Emergency I2.2.1 Operations Center ......................................... 5S 2.2.2 Protective Actions for Schools ......................................... 16 2.2.3 Emergency Worker & Vehicle Decontamination .............. 17 2.2.4 Traffic Control Points ......................................... 17

3. SUPPORTJURISDICTIONS .18 L 3.1 BREVARD COUNTY .................... 18 3.1.1 Reception Center .................... 18 33.1.2 Temporary Care .................... 18 3.1.3 Traffic Control Points .................... 19

_ 3.2 INDIAN RIVER COUNTY .................... 19 L 3.2.1 Reception Center .................... 19 3.2.2 Temporary Care .................... 20 3.2.3 Traffic Control Points .................... 20 3.3 PALM BEACH COUNTY .................... 21 3.3.1 Reception Center .................... 21 3.3.2 Temporary Care .................... 23 3.3.3 Traffic Control Points .................... 23

4.

SUMMARY

OF AREAS REQUIRING CORRECTIVE ACTION. 25 4.1 2004 ARCAs . . . 25 4.1.1 04 I.e. I -A-0I Palm Beach County Reception Center Equipment ....................................... 25 4.1.2 04-55-6.a.1-A-02 Palm Beach County Reception Center-Evacuee Monitoring and Decontamination . 26 L

L

List of Appendices APPENDIX I - ACRONYMS AND ABBREVIATIONS ....................................... 28 APPENDIX 2 - EXERCISE EVALUATORS ........... ............................ 30 APPENDIX 3 - EXERCISE CRITERIA AND EXTENT-OF-PLAY AGREEMENT. 33 L APPENDIX 4 - EXERCISE SCENARIO .34 List of Tables Table I - Exercise Timeline ........... 6 L Table 2 - Summary of Exercise Evaluation ...................... 8 L

L iii

1. EXECUTIVE

SUMMARY

On February 18, 2004. the Department of Hlomneland Security-Federal Emergency Management Agency (FEMA) Region IV conducted a full participation plume exposure pathway exercise in the emergency-planning zone (EPZ) around the St. Lucie Nuclear Power Plant. The purpose of the exercise wvas to assess the level of State and local preparedness in responding to a radiological emergency. This exercise was conducted in accordance with FEMA's policies and guidance for offsite preparedness exercises in order to reach a determination of reasonable assurance that the State and County?

governments are able to protect the health and safety of the public. The previous federally evaluated exercise at this site was conducted on February 20, 2002. The qualifying emergency preparedness exercise wvas conducted February 10-12. 1982.

The State of Florida, Risk Counties of Martin and St. Lucie, and Support Counties of Brevard. Indian River. and Palm Beach participated in this exercise. The State Emergency Operations Center (SEOC) in Tallahassee played in this exercise until direction and control was handed off to the Forward State Emergency Response Team (FSERT). FEMA Region IV wishes to acknowledge the exceptional efforts of the many individuals who planned, prepared for and participated in this exercise. The enthusiasm.

cooperation and teamwork displayed by all participants highlighted the obvious training and preparation invested in this successful demonstration. Protecting the public health and safety is the full-time job of some exercise participants and an assigned responsibility for others. Others have Willingly sought this responsibility by volunteering to provide vital emergency services to their communities.

Although this was a plune exposure pathway exercise, all three Support Counties participated as well in order to demonstrate the distribution of potassium iodide (K!) to the public for the first time in the State of Florida.

This report contains the evaluation of the exercise, as %vellas out-of-sequence activities demonstrated during the week of January 19-23. 2004. which included: Distribution of KI to the public. traffic control points (TCP), emergency worker decontamination (END).

protective actions for schools. reception centers, registration and congregate care.

The State and local organizations demonstrated the knowledge and ability to implement their emergency response plans and procedures. No Deficiencies wvere noted during the exercise, however, two Areas Requiring Corrective Action (ARCA) were identified during out of sequence activities in Palm Beach County. One ARCA Xwas due to cross-contamination during the initial monitoring phase and was immediately corrected by on the spot training and re-demonstration; the other wvas a result of equipment calibration and has been corrected by documentation provided by the manufacturer, through Palm Beach County, specifying calibration requirements.

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11. INTRODUCTION On December 7. 1979, the President directed FEMA to assume the lead responsibility for all offsite nuclear planning and response. FEMA's activities are conducted pursuant to Title 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 wvas established following the Three Mile Island Nuclear Station accident in March 1979.

Title 44, CFR 350 establishes the policies and procedures for 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.

FEMA's responsibilities in radiological emergency planning for fixed nuclear facilities (FNF) 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 Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding betwvecn the NRC and FEMA (Federal Register. Vol. 58. No. 176. September 14. 1993).

• Coordinating the activities of Federal agencies with responsibilities in the 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 FEMA Region IV Regional Assistance Committee (RAC) which is chaired by FEMA.

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Formal submission of the RERPs for the St. Lucie Nuclear Power Plant to Department of Homeland Security, FEMA Region IV by the State of Florida was made on August 26, 1983. Formal approval of these RERPs was granted on February 14, 1984.

A REP exercise was conducted on February 18, 2004. with out of sequence activities conducted during the week of January 19-23 in both risk and host counties, by FEMA Region IV 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 St. Lucie Nuclear Power Plant.

This report presents the exercise 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 being made by the FEMA Region IV RAC Co-Chair and Chief Evaluator vwith final approval 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;

• FEMA-REP-14, "Radiological Emergency Preparedness Exercise Manual.

Sections A. B and C dated September 1991; and

• FEMA "Interim Radiological Emergency Preparedness Manual," dated August 2002.

Section III. entitled "Exercise Ovexriew." 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 table presentation of the time of actual occurrence of key exercise events and activities.

Section IV, entitled "Exercise Evaluation and Results," presents summary information on the demonstration of applicable exercise criteria at each jurisdiction or functional entity evaluated in a results only format.

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111. EXERCISE OVERVIEW Contained in this section are data and basic information relevant to the February 18, 2004 exercise and out of sequence activities during the week of January 19-23. to test the offsite emergency response capabilities in the area surrounding the St. Lucie Nuclear Power Plant.

A. Plume EPZ Description The St. Lucie Nuclear Power Plant is located on Hutchinson Island approximately 4 miles east-northeast of the City of Port St. Lucie. approximately 8 miles southeast of the City of Fort Pierce in St. Lucie County, approximately 5.5 miles north of the Martin County/St. Lucie County boundary line. This facility is owned an operated by the Florida Power & Light Company (FPL).

Both Hutchinson Island and the southern portion of North Hutchinson Island are located within the EPZ. Three causeways link Hutchinson Island to the mainland.

which leads to U S Highway I and 1-95. Parts of St. Lucie and Martin Counties lie within the 10-mile EPZ. The main use of the land is residential and recreational. Approximately 170.000 people reside within the 10-mile EPZ.

B. Exercise Participants The following agencies. organizations, and units of government participated in the St. Lucie Nuclear Power Plant exercise on February 18. 2004.

STATE OF FLORIDA Department of Health. Bureau of Radiation Control Department of Transportation Division of Emergency Management Florida Highway Patrol RISK JURISDICTIONS Martin County St. Lucie County SUPPORT JURISDICTIONS Brevard County Indian River County Palm Beach County 4

PRIVIATE/VOLUNTEER ORGANIZATIONS American Red Cross Amateur Radio Emergency Services (ARES)

Radio Amateur Civil Emergency Service (RACES)

C. Exercise Timeline Table 1. on the following page. presents the time at which key events and activities occurred during the St. Lucie Nuclear Power Plant exercise on February 18, 2004.

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r--- r r-- r------ row F7 r-- F___ fa F[a ( - -FV- F- FTfl -

'Fable 1. Exercise Timeline DATE AND SITE: St. Lucie Nuclear Power Plant - February 18. 2004 Emergency Time Time That Notification \Vas Received or Action Was aken Classification Utility Level or Event Declared l Sl:(K l rI-siiwr l EINt' 1(F1 E ST. LUICII- sARTI N M

Unusual Event 0830 0831) 0830 0839 0841t Alert (958 0958 1004 0958 I()() 1009 SiteArea Emergency 1222 1237 1222 1225 1222 1231 1239 (eneral Emergency 1238 1323 1238 1238 1248 1322 Simulated Rad. Release Started Simulated Rad. Release Terminated 0855 104i IOO 100( 08,4 lacility Declared Operational I)eclaration or State or Emergency 0854 0851 local I15 1135 1050 State 1401 1400 1400 1400 1400 1400 Esercise Terminaeted Early Precautionary .ctions:

1031 0855 ID special needs; cvncuate schools 1035 0918 Evacuate special necds and parks 10)33 1025 1023 lst Protective Action l)ecision -Stay tuned message 1035 1035 1035 lit Siren Activation 10)35 1035 1035 Ist EAS Message 1246 1248 1247 2nd Protective Action Decision EvactiateZones: 1.2.5.6.7andS Shelter Zones: 3 and 4 1300 1301(1 1300 2nd Siren Activation 13010 1300 130)0) 2nd EAS.tcssage KI l)ecislon:

1243 1256 1259 1258 Emergency Workers: Ingest 135)0 1352 Public: Ingest Special Popilations:

1314 1334 Prisoners and Institutionalized

IV. EXERCISE EVALUATION AND RESULTS Contained in this section are the results and preliminary findings of the evaluation of all jurisdictions and functional entities, which participated in the February 18. 2004 exercise and out of sequence activities during the week of January 19-23, 2004. to test the offsite emergency response capabilities of State and local governments within the I 0-mile EPZ around the St. Lucie Nuclear Power Plant.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of criteria as delineated in REP Exercise Evaluation Methodology, dated December 2001.

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

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

I- VT-, r F- V -: I- [- UT V rVT F- 77 [7> W V F>7- LW VT I 7" 1>-I TABLE 2. Summary of Exercise Evaluation DATE AND SITE: February 18, 2004 - St. Lucie Nuclear Power Plant ELEMENT/Sub-Element SEOC F DOSE ENC EOF RAD FIELD ST. LUCIE MARTIN BREVARD INDIAN' RIVER PALM B3EACHI EEEetSFRT TSbEe -DOIl LAD TEAM I. EMERGENCY OPERATIONS MANAGEMENT I.a.l. Mobilization hi I hI I NI NI Ni I.b.l. Facilities . -

I.c. I. Direction and Control I NI . hi NI Ni _

I.d. I. Communications Equipment NI %I Ni N M N hI NI ILe.I. Equipment&SupplicstoSupportOperalions NI M NI SI NI Ni NI NI NI II ANIS

2. PROTECTIVE ACTION DECISION MAKING =

2.a. 1. Emergency Worker Exposurc Control I SI Ni NSI 2.b.1. Rad Assessment & PARs Based on Available Information WI _ _ _______

2.b.2. Rad Assessment and PADs for the General Public SI NI Ni Ni 2.c. 1. Protective Action Decisions for Special Populations hi Ni 2.d. L. Rad Assessment & Decision Making for Ingestion Exposure 2.e. 1. Rad Assessment & Decision Making for Relocation. Re-entrv & Relum

3. PROTECTIVE ACTION IIPLEMENTATION 3.a. 1. Implementation of Emergency Worker Control _I M Ni %I NI hi NI 3.b. 1. Implementation of Kl Decisions NI-tI Ni NI 3.c. 1. Implementation of PADs for Special Populations =M SI 3.c.2. Implementation of PADs for Schools hi Si N

3d. 1. Implementation of Traffc and Access Control I NI Ni hi Ni 3.d.2. Impediments to Evacuation and Traffc and Access Control IM Ni NI hI Ni 3.e. 1. Implementation of Ingestion Decisions Using Adequate Info 3.e.2. Implementation of IP Decisions Sho%%ing Strategies and Insir. Materials 3.fI. Implementation of Relocation. Re-entry and Retum Decisions

4. FIEI.D MEASUREMIENT and ANALYSIS 4.a. 1. Plume Phase Field Measurement & Analysis Equipment NI 4.a.2. Plume Phase Field Measurement & Analysis Management = xI NI _

4.a.3. Plume Phase Field Measurements & Analysis Procedures NI 4.b. I. Post Plume Field Measurement & Analvsis 4.c. I. Laboratory Operations =I = __

5. EMERGENCY NOTIFICATION & PUBLIC INFO 5.a. 1. Activation of Prompt Alert and Notification NI-C M-c hi NI _

5.a.2. Activation of Prompt Alert and Notification 15 Minute (Fast Breaker) 5.a.3. Activation of Prompt Alert and Notification backup Alert and Notification NI NI 5.b.I. Emergency Info and Instructions for the Public and the Media _ I NI NI _

6. StUPPORTOPERATIONS/FACILITIES 6.a. i. Monitoring and Decon of Evacuees and EWs and Registration of Evacuees Ni Ni N NSI ANI 6.b. 1. Monitoring and Decon of Emergency Worker Equipment xI i

6.c. 1. Temporary Care of Evacuees NI NI hI 6.d 1. Transport and-rreatment orConmaminated Injured Individuals .

I. ECENt1. KA - NAMa A = ARCA A/KA AprAlrr-s. c.tc K M c == coodintio

- - M.

..rlc,. Kl = tdisrbui to flUI

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B. Status of Jurisdictions Evaluated This subsection provides information on the evaluation of each participatingjurisdiction and functional entity in ajurisdictional results based 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.

• I)cficiency - Listing of the demonstrated exercise criterion 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 criterion under which one or more ARCAs were assessed during the current exercise or ARCAs assessed during prior exercises that remain unresolved. Included is a description of the ARCA 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, wvhich wvere not demonstrated as scheduled during this exercise and the reason, they were not demonstrated.

• Prior ARCAs - Resolved - Description(s) of ARCA(s) assessed during previous exercises, which were resolved in this exercise and the corrective actions demonstrated.

• Prior ARCAs - Unresolved - Description(s) of ARCA(s) assessed during prior exercises. 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 followina are definitions of the two types of exercise issues. which may be discussed in this report.

• A Deficiency is defined in FEMA Interim REP Manual as "...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."

• An ARCA is defined in Interim REP Manual 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."

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1. STATE OF FLORIDA 1.1 State Emergency Operations Center The SEOC Director successfully managed the radiological emergency response by Federal, State and local agencies. The SEOC staff conducted recurring briefings and held discussions on protective action recommendations (PAR). Decisions were made between the State and Counties and coordinated through the SEOC. All members of the staff displayed a positive attitude as they carried out their functions and procedures. The SEOC was equipped with communications technology and supplies to support the emergency response personnel and operations.

a. MET: Criteria l.a.l, l.c.l, l.d.l, L.e.l and 5.a.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 Forward State Emergency Response Team The F-SERT staff was pre-positioned. They were professional and proficiently carried out their duties. The F-SERT assumed direction and control of the operation at 1045. They used the EM2000 tracker computer system to inform the SEOC and to process requests for assistance. They coordinated actions with the County decision-makers who were also present in the Emergency Operations Facility (EOF). The arrangement allowed for excellent coordination between the licensee and the offsite authorities. Protective action decisions (PAD) were discussed among the State and County representatives, concurred by the County Emergency Operations Center (EOC) managers and effectively implemented by the Counties. The State provided additional resources and called for assistance from both the Federal Radiological Monitoring and Assessment Center (FRMAC) and the Southern Mutual Radiation Assistance Plan (SMRAP).

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

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE 10

c. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 1.3 Emergency News Center The joint staff of the St. Lucie Nuclear Power Plant Emergency News Center (ENC) is well-trained and accomplished their responsibilities in a highly professional manner. In the preparation and conduct of three media briefings and development and release of 40 news releases, this Federal/State/local and utility team exhibited a well-coordinated effort focused on safeguarding the interests of the public. The effective media management effort included tile development of aides to enhance operations. such as the ENC Procedural Manual in the emergency management power-point presentation. This operation should be considered an example of the "best practices" for the ENC.

a. MET: Criteria l.a.l, 1.e.l 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 1.4 Dose Assessment State officials professionally conducted independent accident analysis, including radiological dose assessment. Dose assessment calculations wvere performed to confirm actual field team measurements and to develop projected dose consequences to support, if necessary. revising the protective actions. Both the utility operator and Nuclear Regulatory Commission (NRC) projections were in excellent agreement with the independent results calculated by the State.

a. MET: Criteria l.a.I, I.c.l, I.d.l. I.e.l, 2.a.1, 2.b.1, 2.b.2. 3.b.1 (DOH-KI to public) and 4.a.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE 11

c. PRIOR ARCAs - RESOLVEI): NONE

f. PRIOR ARCAs -UNRESOLVED: NONE 1.5 Emergency Operations Facility The utility operator's EOF is an excellent facility from which all participating organizations can effectively manage ongoing emergency operations. Command and control, decision-making, communications, coordination, and the flow of technical information between the utility operator and the State and applicable local government officials, and representatives of the NRC vere exemplary. All State and local government officials, deployed to the EOF were well trained, followed applicable procedures; and overall, carried out their respective responsibilities in an efficient and professional manner, consistent with the preservation of public health and safety.

a. MIET: Criteria 1.a.l, l.c.1, I.d.1 and 1.e.l

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

c. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 1.6 Radiological Field Monitoring Teams The Florida Bureau of Radiation Control (BRC) deployed three field-monitoring teams (FMT). FMTs wvere equipped with appropriate, calibrated instruments. The teams were dispatched to fixed monitoring locations identified within the St. Lucie 10-mile EPZ.

The teams demonstrated their ability to use the equipment to measure ambient radiation levels and collect air samples. The FMTs demonstrated an understanding of their mission and wvere aware of their dose limits.

a. NIET: Criteria 1.d.1, L.e.l, 3.a.1, 3.b.1, 4.a.1, 4.a.2 and 4.a.3

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE 12

e. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs- UNRESOLVED: NONE 1.7 Radiological Laboratory The personnel assigned to the Mobile Emergency Response Laboratory (MERL) successfully demonstrated their assigned duties. The MERL was equipped to perform analyses of gamma emitting radionuclides. Samples were properly prepared and documented in accordance with procedures to avoid contamination of equipment and facilities, and to maintain the chain of custody. Survey meters used for contamination control functioned properly and had current calibration dates. All laboratory personnel had appropriate dosimetry and were aware of dose limits and administrative reporting levels.

a. MET: Criteria 1.e.1, 3.a.1 and 4.c.l

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAs - RESOLVED: NONE

£ PRIOR ARCAs -UNRESOLVED: NONE

2. RISK JURISDICTIONS 2.1 ST. LUCIE COUNTY 2.1.1 Emergency Operations Center The St. Lucie EOC staff, although pre-positioned for the exercise per the extent-of-play, demonstrated through interview and staff rosters the capability to receive notification of an emergency and to mobilize appropriate personnel. The Emergency Operations Chief and REP Coordinator provided excellent leadership as well as direction and control. Staff members implemented the plan and followed procedures, ensuring a well organized and coordinated response. Staff briefings were conducted regularly. The public information effectively responded to public inquiries. PADs were coordinated and implemented per plans and procedures, ensuring the safety of the public. The staff, including volunteers and federal partners, is commended for their exceptional display of teamwork. The investment of the County and the responding staff effort was evident and reflected an excellent, well managed and coordinated effort.

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a. M1 ET: Criteria I.a. 1, l.c. l. I.d.1, .e. l, 2.a. 1, 2.b.2. 2.c. 1, 3 .a. 1, 3.b. 1, 3.c. 1, 3.c.2, 3.d.1, 5.a.1, 5.a.3 and 5.b.1

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT D)EMONSTRATED: NONE

c. PRIOR ARCAs- RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 2.1.2 Protcctivc Actions for Schools The St. Lucie County School District demonstrated protective actions for schools through a series of interviews conducted at 15 public schools. The school administrators interviewed were knowledgeable of District procedures. had individual school policies in place, and took actions to maintain staff, faculty and parental awareness of evacuation policies and procedures. Procedures also addressed requirements of students with special needs. All personnel interviewed wvere professional and had planned for the well being of students, staff and faculty in the event of an emergency.

a. MIET: Criterion 3.c.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT I)EMONSTRATED: NONE

c. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 2.1.3 Emergency Worker & Vehicle Decontamination The St. Lucie County Public Safety Division, Fire Rescue District and Sheriffs Office successfully demonstrated emergency worker equipment monitoring and decontamination at St. Lucie West Middle School. There was sufficient space and facilities to handle the anticipated number of emergency wvorkers, vehicles and equipment. Personnel were knowledgeable of dosimetry, turn-back values and their individual responsibilities. They) demonstrated the ability to monitor personnel and material, and manage contamination control. The Team displayed cooperation, control of resources and teamwork. The quality of training wvas quite apparent.

14

a. M1ET: Criteria L.e.l, 3.a.1, 3.b.1, 6.a.I and 6.b.I

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

c. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs- UNRESOLVED: NONE 2.1.4 Traffic and Access Control TCPs were demonstrated through interview with two County Sheriff's Deputies and evaluation of the representatives from the Sheriff's Office and County Public Works in the EOC. The staffs were very familiar with traffic and access control procedures, evacuation routes, procedures necessary to remove impediments to evacuation and the location of the reception centers to which they were required to direct traffic. Public Works staff fulfilled a request to deliver barricades to several TCPs. The Deputies also demonstrated good knowledge of the use of dosimetry, KI. and exposure limits for emergency workers.

a. M1ET: Criteria I.e.I. 3.a.1. 3.b.1, 3.d.I and 3.d.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

c. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 2.2 MARTIN COUNTY 2.2.1 Emergency Operations Center The well-coordinated EOC wvas led by the Director of Emergency Management. The REP program administrator, serving as operations Chief provided capable leadership to a competent and supportive staff. The EOC staff coordinated with St. Lucie County, the State and the EOF in the formulation of the evacuation and shelter-in-place PADs, siren sounding and issuance of Emergency Alert System (EAS). Periodic EOC briefings and 15

informative agency updates wvere conducted. Demonstrations of public inquiry, relocation of school children and special populations, policy discussion on KI distribution and ingestion and public information were professionally accomplished. The presence of the Chairman of the County Commission and participation of State, utility and local responders represent the commitment of the community to attain and sustain the capacity demonstrated in this successful EOC operation.

a. MET: Criteria I.a.1, l.c.1, 1.d.l. l.e.l. 2.a.1, 2.b.2. 2.c.1, 3.a.1, 3.b.1, 3.c.l. 3.c.2.

3.d.I. 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 2.2.2 Protective Actions for Schools An interviewv was conducted with the Administrator of the Environmental Studies Center in Jensen Beach in the Martin County Independent School District. The Administrator is X'ery knowledgeable of the plans and procedures for preparing students for relocation to host schools. The Administrator and teachers are equipped wvith Nextel telephones and all buses are equipped with 800 Megahertz radios. Buses are kept at the school and available wshen needed. Other buses are available for dispatch to the two elementary schools within the 10-mile EPZ so all students could be evacuated in one pickup.

a. MET: Criterion 3.c.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

c. PRIOR ARCAs- RESOLVED: NONE

f. PRIOR ARCAs -UNRESOLVED: NONE 16

2.2.3 Emergency Worker & Vehicle Decontamination The Martin County Fire Services demonstrated emergency worker monitoring and decontamination. The team was briefed on assignments, issued appropriate personal dosimetry, monitoring and decontamination equipment and performed pre-operational checks. The demonstration included the proper monitoring of four emergency workers and three vehicles. The operational area wvas well laid out facilitating the process. The team demonstrated excellent contamination control, and displayed good communications and teamwork.. Personnel were knowledgeable and wvell trained.

a. M1 ET: Criteria I.e. . 3).a. 1, 3.b. 1. 6.a. 1 and 6.b. I

b. DEFICIENCY: NONE C. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE C. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 2.2.4 Traffic Control Points A deputy from the County Sherif-ts Department demonstrated TCP procedures by interview. He described his responsibilities in establishing and staffing both traffic control and access points. He was familiar with information he might be required to impart to evacuees to include evacuation routes and locations of shelters. The deputy was provided personal dosimetry and described the use of direct-reading and permanent-record dosimetry. exposure limits. KI and its side ciects. He wias familiar with impediment removal and the means to access cones, barriers and other materials required to support his activities.

a. N1ET: Criteria L.e.l, 3.a.1, 3.b.1, 3.d.I and 3.d.2

b. DEFICIENCY: NONE C. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMIONSTRATED: NONE C. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 17

3. SUPPORT JURISDICTIONS 3.1 BREVARD COUNTY 3.1.1 Reception Center Personnel demonstrated the ability to manage contamination control, displayed good communications and teamrwork. The County Health Department demonstrated the ability to dispense KI to evacuees in an informative and efficient process. American Red Cross (ARC) registration of the evacuees was well organized. Although approximately 8.000 evacuees are anticipated. there is ample space and facilities to handle approximately 100,000 evacuees and vehicles. should the need arise. Special equipment for surv'ey and decontamination of non-ambulatory evacuees wvas also available. Emergency workers wvere issued the appropriate dosimetry. All personnel were wvell trained and demonstrated a high degree of knowledge on evacuee processing procedures.

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

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE C. PRIORARCAs-RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 3.1.2 Temporary Care The Space Coast Chapter of the ARC professionally demonstrated congregate care at Peace Lutheran Church. Five evacuees were processed at the reception center on 1-95.

The evacuees carried their registration forms to the shelter. All personnel were knowledgeable of their responsibilities, professional. and very cooperative. The Brevard County Sheriff's Department provided security and traffic management at the shelter and ARES provided back up communications.

a. MET: Criteria l.e.1 and 6.c.1

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE 18

c. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 3.1.3 Traffic Control Points Personnel from the Brevard County Sheriff Department and Florida Highway Patrol successfully demonstrated TCPs on January 22, 2004. The TCPs were established at the Valkeria Rest Area on 1-95 to direct evacuees to the monitoring and decontamination station. They clearly explained their duties in directing traffic, how to remove traffic impediments. and knew what procedures to follow in case they were exposed to radiation.

They had a working knowledge of KI and the dosimetry they carried.

a. M ET: Criteria L.e.l, 3.a.l. 3.d.1 and 3.d.2

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 INDIAN RIVER COUNTY 3.2.1 Reception Center Evacuee monitoring, registration and reception was demonstrated at the Indian River County Regional Park. The County Fire and Rescue Service assisted by the Departments of Health and REP provided a full display and superb demonstration of established procedures. The available area wvas well organized with appropriate signage and control mechanisms to control the flow of the anticipated evacuees. Personnel demonstrated excellent knowledge of personal dosimetry, monitoring equipment, procedures and contamination control protocols. They displayed good communication and teamwork.

The County Health Department demonstrated the ability to dispense KI to evacuees in an efficient and informative process. Personnel representing each agency were highly professional, motivated. knowledgeable and well trained.

a. MET: Criteria 1.e.l, 3.a.1, 3.b.1 and 6.a.1

b. DEFICIENCY: NONE 19

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

c. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 3.2.2 Temporary Care The Treasure Coast Chapter of the ARC successfully demonstrated activities during an out-of-sequence interview conducted at the Sebastian River Middle School Evacuee Center. The manager interviewed was well aware of his responsibilities and how to request additional personnel, equipment. supplies and food to support the evacuee population. The manager was aware of additional assistance that could be provided by the School District and the County EOC. He is very experienced, professional, and displays a positive attitude.

a. M ET: Criteria 1.e. I and 6.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 3.2.3 Traffic Control Points County Sheriff's Office personnel successfully demonstrated TCPs by interview. The Deputy interviewed was wvell aware of his responsibilities and how to request additional equipment required from the EOC. The Deputy also described the standard process to request or other assistance to clear the road of vehicles that break down or other impediments to traffic flow. He was aware that he would be issued dosimetry and a detailed radiological briefing prior to being dispatched to the TCP. The Officer understood his responsibilities, was ready to follow instructions, provided correct information, was professional and displayed a positive attitude.

a. MET: Criteria .e.1, 3.a.1, 3.d. Iand 3.d.2

b. DEFICIENCY: NONE 20

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE C. PRIOR ARCAs -RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 3.3 PALM BEACH COUNTY 3.3.1 Reception Center The County Emergency Management Coordinator established a unified command to coordinate the activities of supporting elements from the County Fire and Rescue, Department of Health, Sheriff's Office, Public Information, and the ARC. Personnel demonstrated all phases of personnel and equipment registration, monitoring and decontamination. The Incident Commander was advised of concerns with aspects of the demonstration concerning cross-contamination, and after a short training period the procedures were satisfactorily re-demonstrated. Additionally, it was noted that the portal monitors used for initial and post decontamination monitoring were outside the required calibration date. Personnel were generally wvell versed in their responsibilities and displayed a positive attitude.

a. NIET: Criteria 3.a.1 and 3.b.1

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION:

Issue No.: 04-55-l.e.l-A-01 Condition: Portal Monitors are used to identify contaminated evacuees. The facility utilizes Ludlum model 52-1 portal monitors to check all incoming evacuees for contamination and again after any needed decontamination. Both portal monitors used xvere labeled with the calibration due date of July 29. 2003.

Monitoring staff did not revert to using hand held instruments to check incoming evacuees.

Possible Cause: Monitoring staff did not identify this condition as a fatal problem during instrument setup.

Reference:

NUREG-0654, H.7, 10; J.I0 a,b.e; J.l 1; K.3.a, Interim REP Manual, dated August 2002, criterion l.e.].

21

Effect: Use of instruments beyond recommended calibration date would not provide assurance that all contaminated evacuees were identified. The result could cause the contamination of clean areas, previously clean evacuees and emergency workers.

Recommendation: Bring portal monitors into current calibration or provide documentation with other than annual requirements. Provide evacuee-monitoring personnel with calibrated instruments in sufficient numbers to enable checking the required 20% of the evacuees assigned to this location within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Provide training for monitoring personnel including actions to be taken when this condition is identified. Develop and implement a means for checking that monitoring equipment is within the current calibration timeframe and meets operational requirements.

Corrective Action Demonstrated: The County obtained and provided a letter from the manufacturer. Pulcir, incorporated stating "The Model 52-1 series Portable portal Monitors are designed by Ludlum Measurements to be used without calibration as long as operational check is performed prior to use using the check source provided with the instrument."

Issue No: 04-55-6.a.1-A-02 Condition: The first simulated evacuee was identified as being contaminated on the feet. He was directed to return to his vehicle and drive it to the impound area.

His returned to his vehicle using the same path as he entered on. Monitoring personnel did not check this path or the portal monitor for contamination after he left. There was no use of a step-off pad or replaceable surface walkway was not used. The next evacuee was directed to use the same path. Effective contamination control was not in place.

Possible Cause: Clean and contaminated walkways were not appropriately identified at the initial monitoring point. Procedures did not call for the monitoring of walkways after contamination was detected.

Reference:

NUREG-0654 J.l0.h; J.12; K.5.a. Interim REP Manual, dated August 2002.

Effect: Contamination would be spread to other evacuees who may not have been contaminated.

Recommendation: Provide training for monitoring personnel on actions to take when contamination is identified. Revise procedures to reflect the process that was implemented for the re-demonstration. Provide visual aids for monitoring personnel to ensure these critical steps are consistently performed. Provide a supply of shoe covers and contaminated material waste bag at this location.

22

Corrective Actions Demonstrated: A re-demonstration was performed successfully after the Unified Command reviewed this problem and provided direction to monitoring staff. Clean and contaminated flow paths were implemented. Use of removable surface of brown paper wvas simulated at the entrance and exit of the portal monitor. A change of the simulated removable surface and checking of the monitor was demonstrated after foot contamination was found.

d. NOT DEMONSTRATED: NONE

c. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs- UNRESOLVED: NONE 3.3.2 Temporary Care Interview and a walk-through of eight shelters successfully demonstrated congregate care on January 21, 2004, by the Greater Palm Beach Chapter of the ARC. The Greater Palm Beach ARC includes Henry, Glade, Okeechobee and Palm Beach Counties. All officials vere knowledge of the evacuee registration, feeding, sleeping, health, and mental health services offered at each of the eight congregate care centers visited. The eight shelters visited provided sufficient restroom. feeding. shower, and administrative space. The ARC has arrangements with the schools and local vendors to provide food and owns twenty-one trailers loaded with cots. blankets. signs and other necessary sheltering supplies.

a. MET: Criteria 1.e.I and 6.c.1

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

c. PRIORARCAs-RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE 3.3.3 Traffic Control Points TCPs were successfully demonstrated by the County Sheriff Department through interview on January 20, 2004 at John Prince Park. The Deputy knewv the purpose of the TCPs. He explained how evacuees coming from Martin and St. Lucie Counties would come down 1-95 and the Florida Turnpike. He knew the location of the shelters, how to remove traffic impediments and explained that his duty wvas to keep traffic flowing.

Another officer manifested a working knowledge of dosimetry, call and turn back values.

23

and exposure control. The Officers had maps. direct reading and permanent record dosimetry.

a. MET: Criteria L.e.l. 3.a.1. 3.d.1 and 3.d.2

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE L c. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAs - UNRESOLVED: NONE L

L L

I.

24

4.

SUMMARY

OF AREAS REQUIRING CORRECTIVE ACTION 4.1 2004 ARCAs 4.1.1 04-55-I.e.1-A-O1 Condition: Portal Monitors are used to Palm Beach County screen evacuees for contamination evacuees.

Reception Center The facility uses Ludlum model 52-1 portal Equipment monitors to check all incoming evacuees for contamination and again after an) needed decontamination. Both portal monitors used were labeled with the calibration due date of July 29, 2003. Monitoring staff did not revert to using hand held instruments to check incoming evacuees.

Possible Cause: Monitoring staff did not identify this condition as a fatal problem during instrument setup.

Reference:

NUREG-0654, H.7, 1O; J.10 a,b,e; J.1 1; K.3.a. Interim REP Manual, dated August 2002, criterion 1.e.I.

Effect: Use of instruments beyond recommended calibration date would not provide assurance that all contaminated evacuees were identified. The result could cause the contamination of clean areas.

previously clean evacuees and emergency workers.

Recommendation: Bring portal monitors into current calibration or provide documentation with other than annual requirements. Provide evacuee-monitoring personnel with calibrated instruments in sufficient numbers to enable checking the required 20% of the evacuees assigned to this location within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Provide training for monitoring personnel including actions to be taken when this condition is identified. Develop and implement a means for checking that monitoring equipment is within the current calibration timeframe and meets operational requirements.

25

Corrective Action Demonstrated: The County obtained and provided a letter from the manufacturer, Pulcir, incorporated stating "The Model 52-1 series Portable portal Monitors are designed by Ludlum Measurements to be used without calibration as long as operational check is performed prior to use using the check source provided with the instrument."

4.1.2 04-55-6.a.1-A-02 Condition: The first simulated evacuee was Palm Beach County identified as being contaminated on the feet.

Reception Centcr - lie was directed to return to his vehicle and Evacuce NMonitorina drive it to the impound area. 1His returned to and Decontamination his vehicle using the same path as he entered on. Monitoring personnel did not check this path or the portal monitor for contamination after he left. There wvas no use of a step-off pad or replaceable surface walkway was not used. The next evacuee was directed to use the same path. Effective contamination control was not in place.

Possible Cause: Clean and contaminated walklvays were not appropriately identified at the initial monitoring point. Procedures did not call for the monitoring of walkways after contamination was detected.

Reference:

NUREG-0654 J. I O.h; J. 12; K.5.a, Interim REP Manual, dated August 2002.

Effect: Contamination would be spread to other evacuees wvho may not have been contaminated.

Recommendation: Provide training for monitoring personnel on actions to take when contamination is identified. Revise procedures to reflect the process that was implemented for the re-demonstration.

Provide visual aids for monitoring personnel to ensure these critical steps are consistently performed. Provide a supply of shoe covers 26

and contaminated material waste bag at this location.

Corrective Actions Demonstrated: A re-demonstration was performed successfully after the Unified Command reviewed this problem and provided direction to monitoring staff. Clean and contaminated flow paths wvere implemented. Use of removable surface of brown paper wvas simulated at the entrance and exit of the portal monitor. A change of the simulated removable surface and checking of the monitor was demonstrated after foot contamination was found.

27

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

ARC American Red Cross ARCA Area Requiring Corrective Action ARES Amateur Radio Emergency Services BRC Bureau of Radiation Control CFR Code of Federal Regulations DEM Division of Emergency Management DHHS Department of Health and Human Services DOH Department of Health EAS Emergency Alert System ENC Emergency News Center EOC Emergency Operation Center EOF Emergency Operations Facility EPZ Emergency Planning Zone FEMA Federal Emergency Management Agency FMT Field Monitoring Team FPL Florida Power and Light FR Federal Register FRERP Federal Radiological Emergency Response Plan FRMAC Federal Radiological Monitoring and Assessment Center F-SERT Forward State Emergency Response Team GE General Emergency ICF ICF Consulting. Incorporated KI Potassium Iodide MERL Mobile Emergency Radiological Laboratory NRC Nuclear Regulatory Commission NUREG-0654 NUREG-0654/FEMA-REP-1, Rev. 1, "CrileriaforPreparation and Evaluation of RadiologicalEmergency Response Plans and Preparednessin SuqpporI ofNtclear PoirterPlans,November 1980 28

ORO Offsite Response Organization PAD Protective Action Decision PAR Protective Action Recommendation PlO Public Information Officer RAC Regional Assistance Committee REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RACES Radio Amateur Civil Emergency Services SAE Site Area Emergency SEOC State Emergency Operations Center SOP Standard Operating Procedure SMRAP Southern Mutual Radiation Assistance Plan TCP Traffic Control Point(s) 29

L L

APPENDIX 2 EXERCISE EVALUATORS The following is a list of the personnel who evaluated the St. Lucie Nuclear Power Plant exercise L on February 18, 2004. The organization represented by each evaluator is abbreviated below.

I . DHS/FEMA - Department of Homeland Security

- Federal Emergency Management Agency L FDA ICF

- Food & Drug Administration

- ICF Consulting. Incorporated L NRC - Nuclear Regulatory Commission EVALUATION SITE EVALUATOR ORGANIZATION L

STATE OF FLORIDA State Emergency Operations Center Pat Tenorio DHS-FEMA FIQ Forward State Emergency Response Team Larry Robertson DHS-FEMA L

L Roy Smith ICF L

I:

L Emergency News Center Bill Larrabee Quirino lannazzo ICF ICF L Dose Assessment Robert Trojanowski NRC L Emergency Operations Facility Robert Trojanowski NRC Radiological Field Monitoring Teams Deborah Blunt ICF Edward Wojnas ICF L

Radiological Laboratory James Hickey ICF L St. LUCIE COUNTY i

L Emergency Operations Center Stan Copeland DHS-FEMA L James McClanahan ICF L

Protective Action for Schools Bill Larrabee ICF Ernie Boaze ICF 30

Emergency Worker Decontamination Roy Smith ICF Rosemary Samsel ICF Bill Neidermeyer ICF L Traffic Control Points Rob Noecker ICF MARTIN COUNTY I Emergency Operations Center Robert Perdue DHS-FEMA Rosemary Samsel ICF Tom Trout FDA Protective Action for Schools Ernie Boaze ICF Emergency Worker Decontamination Roy Smith ICF L Rosemary Samsel ICF Bill Neidermeyer ICF L Traffic Control Pints Bill Neidermeyer ICF L INDIAN RIVER COUNTY L Reception Center Rosemary Samsel Bill Neidermeyer ICF ICF L Bill Larrabee ICF Lo I,

Congregate Care Roy Smith ICF I: Traffic Control Points Roy Smith ICF BREVYARD COUNTY L

L1.

Reception Center Roy Smith ICF Bill Neidermeyer ICF Rosemary Samsel ICF I:

Congregate Care Robert Perdue DHS-FEMA Traffic Control Points Robert Perdue DHS-FEMA 31

L I PALM BEACH COUNTY Reception Center Bill Neidermeyer ICF Rosemary Samsel ICF Roy Smith ICF Congregate Care Robert Perdue DIHS-FEMA Traffic Control Points Robert Perdue DHS-FEMA L

L L

L L

L l

II L

32

APPENDIX 3 EXERCISE CRITERIA AND EXTENT-OF-PLAY AGREEMENT This appendix contains the exercise criteria and the extent-of-play that were scheduled for demonstration during the Saint Lucie Nuclear Power Plant exercise on February 18, 2004.

A. Exercise Evaluation Area Criteria (In Final Report Only)

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

(In Final Report Only) 33

1. EMERGENCY OPERATIONS MANAGEMENT l.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; 11.4)

Extent of Plav 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. 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 out-of-sequence demonstrations is appropriate in accordance weith the extent-of-play agreement.

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

Martin: Martin Countv s 24-hour answeringpoint wt'ill answier andfill out the Florida Notification Formlz withill the information provided byr the utility The answt'eringpoint i ill then provide a cop)y to, or read the copy, to Emergency AM'anagement Staff.

St. Lucie EOC: All personnel will be pre-positioned.Response to FloridaPowt'er&

Light 's Emergency OperationsFacility ii'ill be scenarlio driven BRC: BRC will prepositionfield teans, the mobile laboratoiyand sample prep vehicle.

EOFpersonnel will arrive within 1-hour after the Aler-t enzergency classification declaration.

DEAM: F-SERT 1t'ill preposition at the EOFat appro.xilmzately 8:30 AAM in t'lticipatiol of the EOF being declared operational.

DEM. SEOCpersonnel will begin arrivingbya 9:00AM in anticipation]of a Site Area Emnergency.

Brevard: N/A Indian Riv'er: N/A.

Palm Beach: N/A

1. EMERGENCY OPERATIONS MANAGEMENT l.a - Mobilization:

Criterion l.a.l: 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.l, 2; 1.4)

Extent of Plav 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. 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 out-of-sequence demonstrations 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.

Martin: M'artin Counitv' s 24-hour answveringpoint is'ill answer and fill out the Florida Notification Form wt'ith the informationp rovided by the utility. Thc ansliverinlgpoint will then: provide a copy to, or read the copy to Emergency Management Staff St. Lucie EOC: All personnel will be pre-positioned. Response to FloridaPower &

Light 's Emergency OperationsFacilityaill he scenatrio ldriven BRC: BRC wtillpprepositiontfieldteams, the mlobile laboratori and sanipleprep vehicle.

EOFpersonnel will arrive wt'ithin 1-hour after the Alert emergency classification (leclaration.

DEM: F-SERT till preposition at the EOF at approxim~zately 8:30 AM il alticip)atioll of the EOFbeing declaredoperational.

DEA: SEOC personnel wtill begin arriving by 9:00 AM in anticipationof a Site Area Emnergency.

Brevard: NMA Inldian River: N/A.

Palm Beach: N/A

1.b - Facilities:

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

(NUREG-0654, 11.3)

Extent of Plav 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, backup 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 used in an actual emergency, unless noted above or otherwise indicated in the extent-of-play agreement.

BRC: BRC *willfollowt procedutres as stated iii SOPs.

Martinz: A/A St. Lucie: In agree'nient Bre'ard-: N/A Indian River: N/A Pain,Beach: N/A DEAM N/A I.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.I.d; A.2.a, b)

Extent of Play 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, 2

unless otherwise noted above or indicated in the extent-of-play agreement.

M'artini: Direction and control wtill be (lemonlstratedin the EOC by the Directorof Entergeiicyj MAIanagemnent, and the RacliologicalEmtergenqcy PlanAchninistrator.

The Directorof Emergency Services will direct operationsof Aartin County s staff at the EOF.

St. Lucie: In aigreeinent BRC: BRC it'illfolloit'proce(dulresas stated in SOPs.

DEA: (SEOC, F-SERT) In agreement.

Bre'ardl: I/A Indian River: N/A Pahn: Beach:: N/A 1.d - Communications Equipment:

Criterion I.d.l: 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)

Extent of Plav 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 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, as negotiated in the extent-of-play agreement.

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 otherwise noted above or in the extent-of-play agreement.

3

Afartin: Prilai3ycommunuications wvill be hle/tl on commercial telephone, augmented byh cellularphones. Back-uip systeems are 800AMhz radio, and ARES-RA CES radio.

St. Lucie: In Agreement BRC: BRC will use comzmnunications equipment as stated in SOPs.

DEAL (SEOC, F-SERT) In agreement.

Brev'ard: N/A Indiani Rii'er: N/A Paln Beach: N/A L.e - Equipment and Supplies to Support Operation:

Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG-0654, 11.7,10; J.10.a, b, e, J.I1; K.3.a)

Extent of Plav Equipment within the facility (facilities) should be sufficient and consistent with the role assigned to that facility in the ORG's plans and/or procedures in support of emergency operations. Use of maps and displays is encouraged.

All instruments, should be inspected, inventoried, and operationally chccked before each use. Instruments should be calibrated in accordance with the manufacturer's recommendations. Unmodified CDV-700 series instruments and other instruments without a manufacturer's recommendation should be calibrated annually. 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 calibrated frequency can be verified by other means. Additionally, instruments being used to measure activity should have a range of readings sticker affixed to the side of the instrument. The above considerations should be included in 4.a.1 for field team equipment; 4.c.I for radiological laboratory equipment (does not apply to analytical equipment); reception center and emergency worker facilities' equipment under 6.a.1; and ambulance and medical facilities' equipment 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 dosimetry should allow individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans and procedures.

4

Dosimetry should be inspected for electrical leakage at least annually and replaced, if necessary. CDV-l 38s, 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 wvill 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 tile general public (including transients) within the plume pathway EPZ.

Quantities of dosimetry and KI available and storage locations(s) will be confinned 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 a certified private or State laboratory indicating that the KI supply remains potent, in accordance with U.S. Pharmacopoeia standards.

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 othenvise indicated in the cxtent-of-play agreement.

Manrtin: Maps. diagrams and visual aids will be Used in the EOC as needed, mcore information can be gatheredby interv'iewt as speeded. Survey instr-wnnents dosinzeters, and K! were all checked dcuring site visits St. Lucie: Demnomnstration of equipment and supplies to support the Emtergency Operations Center will be scenario dlriven during the exercise. Inspection of instnrnents, dosimeters and KI will be conducted driinga FEMA site visit scheduledfor December 8, 2003. A report of the visit will be availablefor review upon ,request.If the visit is canicelled,inspection of instrumientationand K! will be conducted during the evaluation.

BRC: Will use equipinent and supplies as stated in the SOPs.

DEMl: The SEOC wi'll have sqfficient equipment to support their mission as defined in the REP Plan.

DEM.: Tie F-SERT will have sifficiezt eqtipmenit to support their mlissiol as defined il the REP Plan. Dosimetmy and KI will not be distributedfrom the SEOC orfirom the EOF.

5

A discussion on issuance of dosilmUett and KI to State Emniergenc' WI'orker-s can be provided bY the REP technical E-xpert at the EOF, if necessa),.

Brevnard: N/A Indian River: N/A Pahln Beach: N/A

2. PROTECTIVE ACTION DECISION MAKING 2.a - Emergency Worker Exposure Control:

Criterion 2.a.1: OROs use a decision making process, considering relevant factors and appropriate coordination, to ensure 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, KA4, J.10. e, f)

Extent of Plav 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 preauthorized levels and to the number of emergency workers receiving 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.

M'artin: JPashdowi'n, Decon. and FieldExposure Control it'ill be demonstratedoGit of sequence. KI decision making will occur in the EOF, andEOC, if driveu bya the scenario Decisions to allow exposure above authorizedlevels can be evaluatedby interview.

St. Lucie: In agreement.

BRC: BRC wi'll use dosimneti)' and instrumentation as stated iln SOPs.

6

DEM F-SER T: Infor-maition1 reltitve to State Em oergency JJ'orkerexposaic control wtill be provided tlhroughl discussions wit/h tihe REP technical Expert in ti/e EOF, if necessary.

Brevard: AINA Indian River: AVA Pahl Beach: N/A 2.b- Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency:

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 ivell as knowledge of onsite and offsite environmental conditions. (NUREG-0654, 1.8, 10 and Supplement 3)

Extent of Plah During the initial stage of the emergency response, following notification of plant conditions that may warrant offsite protective actions, the ORO should demonstrate the capability to use appropriate means, described in the plan and/or proccdurcs, to develop protective action recommendations (PAR) 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 independently validate dose projections. The types of calculations to be demonstrated depend oil 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 PACT 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 assumptions used, the use of 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.

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

BRC: BRC will use RASCAL dose assessment code as stated in SOPs.

7

Marlitn: N/A St. Lucie: N/A Brev'ard: N/A Indian River: A/A Pa/ni Beach: NM4 DEAL N/A Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PAD) for the general public (including the recommendation for the use of K1, if ORO policy). (NUREG-0654, .. 9, 10.f, m)

Extent of Play Offsite Response Organizations (OROs) should have the capability to make both initial and subsequent PADs. They should demonstrate the capability to make initial PADs in 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 monitoring 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 wvill be used as a protective measure for the general public under offsite 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 sheltering and evacuation. This decision should be based on the ORO's plan and/or procedures or projected thyroid 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.

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.

8

Martin: MI'artin Countp-KI decisions are the responsibility of the state. Evacuationi and or sheltering will be dletermiiedl based oni PARs, local information, byi the county1t decision maker at the EOF, coordinatedand1 validated with the EOC and St. Lucie Couutni. Threshold K! would be iuncluded in the PARs, or independentliy determined, and recommenided bya BRC.

St. Lucie: This objective wvill be scenariodri veil. Proceduresnot observed will be accomplishedthrough interviewii withl appropriatepersonnel in the FloridaPower anl Light Emnergeicy OperationsFacility and the St. Lucie County Emergency Operations Centern BRC: BRC will use RASCAL close assessmient code (Is statedin SOPs.

DEAI F-SERT: In Agreemtent Brevard: N/A Indiani River: N/A Pahln Beacli: N/A 2.c -Protective Action Decisions for Protection of Special Populations:

Criterion 2.c.I: Protective action decisions are made, as appropriate, for special population groups. (NUREG-0654, J.9, J.1O.d, e)

Extent of Plav 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 where there is a high-risk environment or where high-risk groups (e.g., the immobile or infirm) are involved. In these cases, examples of factors that should be considered arc: weather conditions, shelter availability, availability of transportation assets, risk of evacuation vs. risk from the avoided dose, and precautionary school evacuations. In situations where an institutionalized population cannot be evacuated, the administration of KI should be considered by the OROs.

Applicable OROs should demonstrate the capability to alert and notify all public school systems/districts of emergency conditions that are expected to or may necessitate protective actions for students. Contacts wvith public school systems/districts must be actual.

In accordance with plans and/or procedures, OROs and/or officials of public school systems/districts should demonstrate the capability to make prompt decisions on protective actions for students. Officials should demonstrate that the decision making process for protective actions considers (that is, either accepts automatically or gives heavy weight to) protective action recommendations made by ORO personnel, the ECL 9

at which these recommendations are received, preplanned strategies for protective actions for that ECL, and the location of students at the time (for example, whether the students are still at home, en route to the school, or at the school).

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 othenvise indicated in the extent-of-play agreement.

AMartin: Martin Counly ivill iuake decisions on Special Needs an(1 Schools based of plant conditions, plant trends, PARs and local conditions.

St. Lugcie: Actual initialnotification it'll be made to the St. Lucie School District Siperintendentand/the TransportationDirector.All other calls will be simnulatel.

Brevard: AtM Indiani River: N/A Palh Beachl: AtM BRC. N/A DEM: N/A 2.d. -Radiological Assessment and Decision-Making for the Ingestion Exposure Pathway Criterion 2.d.1: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO planning criteria.

(NUREG-0654, 1.8., J.1 1)

Extent of Plav It is expected that the ORO will take precautionary actions to protect food and water supplies, or to minimize exposure to potentially contaminated water and food, in accordance with their respective plans and procedures. Often such precautionary actions are initiated by the OROs based on criteria related to the facility's emergency classification levels (ECL). Such actions may include recommendations to place milk animals on stored feed and to use protected water supplies.

The ORO should use its procedures (for example, development of a sampling plan) to assess the radiological consequences of a release on the food and water supplies. The ORO assessment should include the evaluation of the radiological analyses of representative samples of water, food, and other ingestible substances of local interest from potentially impacted areas, the characterization of the releases from the facility, and the extent of areas potentially impacted by the release. During this assessment, OROs should consider the use of agricultural and watershed data within the 50-10

mile EPZ. The radiological impacts on the food and water should then be compared to the appropriate ingestion PAGs contained in the ORO's plan and/or procedures. (The plan and/or procedures may contain PAGs based on specific dose commitment criteria or based on criteria as recommended by current Food and Drug Administration guidance.) Timely and appropriate recommendations should be provided to the ORO decision-makers group for implementation decisions. As time permits, the ORO may also include a comparison of taking or not taking a given action on the resultant ingestion pathway dose commitments.

The ORO should demonstrate timely decisions to minimize radiological impacts from the ingestion pathway, based on the given assessments and other information available. Any such decisions should be communicated and to the extent practical, coordinated wvith neighboring and local OROs.

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

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.

AMartin: Martin Counity will provide inject in the EOCfor law enforcement and agriculluralagenciesforp-actice anld training. Notfor evaluation St. Lucie: N/A Brevard: N/A Inclian River: N/A Palun Beaclh: N/A RRC.: N/A DEAf. N/A 2.e. - Radiological Assessment and Decision-Alaking Concerning Relocation, Re-entry, and Return Criterion 2.e.l: Timely relocation, re-entry, and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the ORO's plan and/or procedures. (NUREG-0654, A.1.b., 1.10; Mi.1)

Extent of Plav Relocation: OROs should demonstrate the capability to estimate integrated dose in contaminated areas and to compare these estimates with PAGs, apply decision criteria for relocation of those 11

individuals in the general public who have not been evacuated but where projected doses are in excess of relocation PAGs and control access to evacuated and restricted areas. Decisions are made for relocating members of the evacuated public who lived in areas that now have residual radiation levels in excess of the PAGs. Detennination of areas to be restricted should be based on factors such as the mix of radionuclides in deposited materials, calculated exposure rates vs. the PAGs and field samples of vegetation and soil analyses.

Re-entry: Decisions should be made regarding the location of control points and policies regarding access and exposure control for emergency workers and members of the general public who need to temporarily enter the evacuated area to perform specific tasks or missions.

Examples of control procedures are: the assignment of, or checking for direct-reading and non-direct-reading dosimetry for emergency workers; questions regarding the individual's objectives and locations expected to be visited and associated time frames; availability of maps and plots of radiation exposure rates; advice on areas to avoid; and procedures for exit including; monitoring of individuals, vehicles, and equipment; decision criteria regarding decontamination and proper disposition of emergency worker dosimetry and maintenance of emergency worker radiation exposure records.

Responsible OROs should demonstrate the capability to develop a strategy for authorized re-entry of individuals into the restricted zone, based on established decision criteria. OROs should demonstrate the capability to modify those policies for security purposes (e.g., police patrols), for maintenance of essential services (e.g., fire protection and utilities), and for other critical functions. They should demonstrate the capability to use decision making criteria in allowing access to the restricted zone by the public for various reasons, such as to maintain property (e.g., to care for farm animals or secure machinery for storage), or to retrieve important possessions.

Coordinated policies for access and exposure control should be developed among all agencies with roles to perform in the restricted zone. OROs should demonstrate the capability to establish policies for provision of dosimetry to all individuals allowed re-entry to the restricted zone. The extent that OROs need to develop policies on re-entry will be determined by scenario events.

Return: Decisions are to be based on environmental data and political boundaries or physical/geological features, wvhich allow identification of the boundaries of areas to which members of the general public may return. Return is permitted to the boundary of the restricted area that is based on the relocation PAG Other factors that the ORO should consider are, for example: conditions that permit the cancellation of the Emergency Classification Level and the relaxation of associated restrictive measures; basing return recommendations (i.e., permitting populations that were previously evacuated to reoccupy their homes and businesses on an unrestricted basis) on measurements of radiation from ground deposition; and the capability to identify services and facilities that require restoration within a few days and to identify the procedures and resources for their restoration.

Examples of these services and facilities are: medical and social services, utilities, roads, schools, and intermediate term housing for relocated persons.

12

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.

AMfartin: Martin CountYp-Notfor Evaluation, will address and disczuss theses issues if driven iy the scenario.

St. Luicie: N/A Brevardk: At/A Iiznian Riper: N/A Pahl Beach: N/A BRC. /AI DEAL N/1

3. PROTECTIVE ACTION IMPLEMENTATION 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.a, b)

Extent of Plav OROs should demonstrate the capability lo provide appropriate direct-rcading and permanent record dosimetry, dosimeter 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 tumback 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 13

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 ws horn 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 coworkers) in providing responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where 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 owvn pernanent record dosimetry.

Individuals without specific radiological response missions, such as fanners for animal care, essential utility service personnel, or other members of the public wV'ho 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.

Martini: Martini Countiy wt-ill demnonistrate Emergency IVorker Erposure Control out of sequence at Fire Station 14 at the southern end of Hutchison Island. Dosimetry wiill be 0-20 REM And 0-200 nuzREA. TLD holders iwill be used to siulnate TLDs, Candy will be used to represent KI. Personnel will demonst,-ate a wvashdowt'n and decon operation.

Personnel will ecmonstratc the rscs ofsui-vcy instruments, andtl use and readsclf reading dosimneters. Any criterianot seen by evaluators will be detennined bhi interviewt.

St. Lucie: This demonstration will be out of sequence and will OLcur duiring the emergency wt'ash down'm drill onl January21, 2004. All enmergency workers will receive the appropriatedosimletmy as specified in the REP Plan. Dosimeterbadges wt'ill be simulated witih plastic badges. K! pills will be simulated wt'ith aspirin tablets. Anli proceduresnot observed during the demonstration wt'ill be addressed byr interview'.

Brev'ard: Brevard Counmty will demonstrate on January22, 2003 at the 1-95 Rest Stop Site.

Indian River: Indian,River Counity demonstration ofIniplemzentation of Emergency Worker Exposure Control will take place out of sequence ol Janzary 22, 2004 at the 14

Indian River Count)' Regional Park/SebastianRiver Middle School 9450 CR. 512, SebastianFl.

Palm Beach: Palni Beach County dlemnolnstratioll of Implementation of E,1n1ergenc' Worker Exposu re Control iwill take place out of sequence on Januariy 20, 2004 at John Prince Park.

BRC: BRC will use dosimuceti and instrumentation as stated in SOPs.

DEAL N/A 3.b - Implementation of KI Decisions.

Criterion 3.b.1: KI and appropriate instructions are available should a decision to recommend use of K1 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.)

Extent of Play OROs should demonstrate the capability to make KI available to emergency workers, institutionalized individuals, and, wx'here 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 wvith 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 K! 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 proccdures.

Emergency wvorkers should demonstrate the basic knowledge of procedures for the use of KI 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.

Martin: Martin County-Emergencq Worker KI decisions will be made at the EOC. BRC will provide dose projections, EOCstaff will determine iffield personnel are in the affected areas. Personnelknowledge ofKI vill be determined by interview at the wvashdown, decom site.

St. Lucie: This procedure will be scenario driven. Demonstration will be done through interviewitw'ith appropriateEOCpersonnel.

15

BRC: BRC ithill use potassium iodide aS stated in SOPs.

Brevard: N/A Iindianl River: NI/A Palmuz Beach: N/A DEAL N/A 3.c - Implementation of Protective Actions for Special Populations:

Criterion 3.c.l: Protective action decisions are implemented for special populations other than schools within areas subject to protective actions. (NUREG-0654, J.IO.c, d, g)

Extent of Plav Applicable OROs should demonstrate the capability to alert and notify (for example, provide protective action recommendations 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 Xwith 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.

Martin: Martin County wt'illprovide a cuirent Special Neels client roster, The Special Needs Coordinatorand TransportationCoordinatorwill be availableforinterview,. All of their actions during the drill will be simulations. There wtill! be no actualcontact wt'ith Special NeedlsClients. AnY elements of this criterianot observed may be determined by interviews.

St. Lucie: A clurent list of special needs population it'ill be provided to the St. Lrmcie Count)' evalutator(s)for reviewv. Evacutation/relocationrequirements will be demonstrated through discussions at time EOC, based on the scenario and counti' implementation procedures. All calls thill be simulated.

16

Brev'ard1: N/A Indiani River: N/A Painh Beach: N/A BRC. N/A DEAl: N/A Criterion 3.c.2: OROs/Sclhool officials implement protective actions for schools.

(NUREG-0654, J.1O.c, d, g)

Extent of Plav Public school systems/districts shall demonstrate the ability to implement protective action decisions for students. The demonstration shall be made as follows: At least one school in each affected school system or district, 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 role(s) in the evacuation of school children. Communications capabilities betwveen school officials and the buses, if required by the plan and/or procedures, should be verified.

Officials of the 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.

The provisions of this criterion also apply to any private schools, private kindergartens and day care centers that participate in REP exercises pursuant to the ORO's plans and procedures as negotiated in 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.

Martin: Martin County-School districtpersonnel ivill be in the EOC, and will take actions to safeguardstudents andstaff Iffor some unforeseen reason districtpersonnel can not be ill the EOC they it'ill be contacted via phone and directed to take the appropriateactions. Martin Counit does not intend to have a bits driver availablefor 17

interview, The School District representativein the EOC will i(dcntifj that all of the transportation emiployees (lo inflict know where the 3 schools are in the EPZ and where the host schools are.

Out of Sequence: Evaluator(s) it'ill conduct intervwiewvs with school official at the Jenson Beach EnviromwentalStudyl Center on Jan 21 at 9:30 AM.

St. Lucie: Scenario (ldiiven. School officials ini tile eilnergeuicy operationscenter will sintlate required actionsfollowing local procedures. Calls to affecte(d schools wvill be simuzilated. The Emzergency Operations Center Coordinator wt'ill noti/j' the School District Superinten(lent and TransportationDirectorIA 1V local procedures. Procedluresnot observedl wtill be addressed by intervieit'. Out ofsequence: Evalitator((s) wvill cond(uth interviews with schuoolpriinciplesor their lesignee at 15 public schools to denmonstrate their knoit'ledge of evacuation plans. The intevieki's wcill be counducted during the it'eek of Januain 19, 2004. Schools to be visited are:

North Port Midlle FortPierce CentralHigh Forest Grove Middle Dale Cassenis Park-waiy Elenienitay Dami McCartyl Middle Lawn wood Eleni. FairlawrnElenientary Fort Pierce School ofthe Ar-ts F.K. Sweet Elemn. Bayjshore Elemnentaq Manatee Elemzental)

St. Lucie IfJest Middle Pindin ill Point Elemn St. Lucie JMest Centennial High Brevard: N/A Indianu River: N/A Palm Beach: N/A BRC. NIA DEAI: A'M 3.d - Implementation of 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.1 O.g, j)

Extent of Plav OROs should demonstrate the capability to select, establish, and staff appropriate traffic and access control points, consistent with protective action 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.

18

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

In instances where 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 wvould be in an actual emergency, unless noted above or othenvise indicated in the extent-of-play agreement.

Aartin: Martin Counlty-TCP evaluation u4ill takeplace out of sequence at Fire Station 14 at the saine Ii))Je as decon and i'ashdot'nare demonstrated.Personnelffrom Martin Cotuuit) Shzeriff's Office, Sewtalls Point PD i ill be therefor interiielt .

St. Lucie: Ji'ill demonstrate the objective through intervniewt, with lawn enforceunent agencies iln the EOC. Tws o Law enforcenient officers ill thefield, will be called to the EOCfor inter'ieit'by the EOC evaluator:

Brevard: Brevard County wtbill be done by interviewt, with lait' enforcement onl Janual)'22, 2003 at the 1-95 Rest Stop Site.

Indian River: Indian River County SherdijDepartnzentit'ill demonstrate inmplenientation of Traffic and Access Control bi' intervnieu'. The interview will take place out ofsequence o11 Januajy 22, 2004 at the Indian River Couunty Regional Park/SebastianRiver Middle Sc/ool 9450 CR. 512, Sebastian Fl.

Palni Beach: Palhn Beach Counlty Sheriffs Office will demonstrate inliplemnelltatiollof Traffic andAccess Control by interl'ieit. The interviewv will take place out of sequence oi Januar.)u 20, 2004 at John Prince Park. This activit) canl be rue- demonstrated during the evaluation ifWnd wi'hen necessanr in order to satisfy the r-equiremnents of the criteria.

BRC: N/A DEAP N/A 3.d. - Implementation of Traffic and Access Control Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654, J.1O., k.)

Extent of Plav 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 19

with impediments, such as wreckers, need not be demonstrated; however, all contacts, actual or simulated should be logged.

All activities must be based onl 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.

Aratin: Martin Countyi-Theere will be a unuber of evercise ihyects that cause law enforcenemt and fire rescue personnel to react to traffic impediments. Ai) ' additional information requiredmy)' be (letermine(l bja iitelvieWW.

St. Lucie: JWill demonstrate this objective through interviews with law enforcemient agencies in the EOC Brev'adl: Brevarci Cowitn iw'ill be done bya interview with law enforcemnent on Januamll) 22, 2003 at the I-95 Rest Stop Site.

Indian River: Indian River County SlieriffDepartnient1%'ill dlemionstrate imnplemnewatation of Traffic and Access Control by interview. The interyview hill take place out of sequence on Janutamy 22, 2004 at the Indiani River Count)y Regional Park/SebastianRiver Middle School 9450 C.R. 512. Sebastian Fl.

Pahl Beach: Palmin Beach Counzty Sheeriffs Office we'ill demonstrate implementation of Traffic and Access Control bya initeriewt. The interview wt'ill take place out of sequencec on Januzar 20, 2004 at John 11 PrincePark. This activity can be r e- demnonstratiedduring the evaluatiom if and when necessary in order to satisfy the requiremients of the criteria.

BRC: NM.

DEAl: N/A 3.e - Implementation of Ingestion Pathway Decisions Criterion 3.e.1: The ORO demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk, and agricultural production witlhin the ingestion exposure pathway emergency planning zone for implementation of protective actions. NUREG-0654, J.9, 11.)

Extent of Plav Applicable OROs should demonstrate the capability to secure and utilize current information on the locations of dairy farms, meat and poultry producers, fisheries, fruit growers, vegetable growers, grain producers, food processing plants and water supply intake points to implement protective actions within the ingestion pathway EPZ. OROs should use Federal resources as identified in the FRERP, and other resources (e.g. compacts, nuclear insurers, etc), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

20

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 othenvise indicated in tihe extent of play aureenmerit.

Alantin: AVA St. Lucie: N/A Brevai'a: N/A Inclian Rifler: N/A Palm Beach: N/A BRC N/M DEAL: N/A 3.e - Implementation of Ingestion Pathway Decisions Criterion 3.e.2: Appropriate measures, strategies, and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk, and agricultural production. (NUREG-0654, E.5, 7, J.9, 11.)

Extent of Plav Development of measures and strategies for implementation of ingestion pathway zone (IPZ) protective actions should be demonstrated by formulation of protective action information for the general public and food producers and processors. This includes the capability for the rapid reproduction and distribution of appropriate reproduction-ready information and instructions to pre-determined individuals and businesses. OROs should demonstrate the capability to control, restrict or prevent distribution of contaminated food by commercial sectors. Exercise play should include demonstration of communications and coordination between organizations to implement protective actions. However, actual field play of implementation activities may be simulated. For example, communications and coordination with agencies responsible for enforcing food controls within the IPZ should be demonstrated, but actual communications with food producers and processors may be simulated.

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.

anrtin: N/A St. Lucie: N/A 21

Brev'ard: N/A Indian,River: N/A Panl Beach: N/A BRC: N/A DEML N/A 3.f -Implementation of Relocation, Re-entry and Return Decisions Criterion 3.f.1: Decisions regarding controlled re-entry of emergency workers and relocation and return of the public are coordinated wvith appropriate organizations and implemented. (NUREG-0654, M%.1, 3.)

Extent of Plav Relocation: OROs should demonstrate the capability to coordinate and implement decisions concerning relocation of individuals, not previously evacuated, to an area where radiological contamination will not expose the general public to doses that exceed the relocation PAGs.

OROs should also demonstrate the capability to provide for short-term or long-term relocation of evacuees wvho lived in areas that have residual radiation levels above the PAGs.

Areas of consideration should include the capability to communicate with OROs regarding timing of actions, notification of the population of the procedures for relocation, and the notification of, and advice for, evacuated individuals who will be converted to relocation status in situations where they will not be able to return to their homes due to high levels of contamination. OROs should also demonstrate the capability to communicate instructions to the public regarding relocation decisions.

Re-entrv: OROs should demonstrate the capability to control re-entry and exit of individuals who need to temporarily re-enter the restricted area, to protect them from unnecessary radiation exposure and for exit of vehicles and other equipment to control the spread of contamination outside the restricted area. Monitoring and decontamination facilities will be established as appropriate.

Examples of control procedure subjects are: (1) the assignment of, or checking for, direct-reading and non-direct-reading dosimetry for emergency workers; (2) questions regarding the individuals' objectives and locations expected to be visited and associated timeframes; (3) maps and plots of radiation exposure rates; (4) advice on areas to avoid; and procedures for exit, including monitoring of individuals, vehicles and equipment, decision criteria regarding contamination, proper disposition of emergency worker dosimetry and maintenance of emergency worker radiation exposure records.

Return: OROs should demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase. OROs should 22

demonstrate the capability to identify and prioritize services and facilities that require restoration within a few days, and to identify the procedures and resources for their restoration. Examples of these services and facilities are medical and social services, utilities, roads and schools and intermediate tern housing for relocated persons.

Communications among OROs for relocation, re-entry and return may be simulated; however all simulated or actual contacts should be documented. These discussions may be accomplished in a group setting.

OROs s hould u se F ederal r esources a s i dentified i n t lhe F RERP, a nd o tiler r esources (e.g.

compacts, nuclear insurers, etc), if available. Evaluation of this criterion Still 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.

Martin: N/Aj St. DLcie: N/A Breai'rd1: N/A Indian River: N/A Paln Beach: N/A BRC: N/A DEN!: At/

4. FIELD MEA SUREMENT AND ANALYSIS 4.a - Plume Phase Field Measurements and Analysis:

Criterion 4.a.1: 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, 11.10; 1.7, 8, 9)

Extent of Plav Field teams should be equipped with all instrumentation and supplies necessary to accomplish their mission. 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 23

and procedures. An appropriate radioactive check source should be used to verify proper operational response for each low range radiation measurement instrument (less than I R/hr) and for high range instnhments 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 wvould be in an actual emergency, unless noted above or otherwise indicated in the extent-of-play agreement.

Ala rtin: Martin Counlt Field Teanns will be assignedto predeterminedsites to take background readiingsand report to the EOC. Notfor evaluation.

St. Lucie: N/A B3RC: BRC will use instrumentation and measurement techniques as stated in SOPs.

Brevar-d: N/A Indian River: N/A Pa/ln Beaclz: N/A DEAl: ArM Criterion 4.a.2: Field teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654, 11.12; 1.8, 11; J.1O.a)

Extent of Plav Responsible Offsite Response Organizations (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 modifying protective actions. Teams should be directed to take measurements in such locations, at such times to provide information 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 24

(licensee, Federal, and ORO) is essential. Coordination concerning transfer of samples, including a chain-of-custody form, to a radiological laboratory should be demonstrated.

OROs should use Federal resources as identified in the Federal Radiological Emergency Response Plan (FRERP), and other resources (for example, compacts, utility, 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.

BRC: BRC wiill itse instriumentationand1 meastoreienlttechniques as statedin SOPs.

Alartilt: N/A St. Lucie: N/A Brevarda: N/A Indian River: N/A Palm Beach: N/A DEM.: A'M 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. 9)

Extent of Plan Field teams should demonstrate the capability to report measurements and field data pertaining to the measurement of airborne radioiodine and particulates and ambient radiation 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 appropriate OROs. All 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's plan and/or procedures.

OROs should use Federal resources as identified in the FRERP, and other resources (for example, compacts, utility, etc.), if available. Evaluation of this criterion will take into 25

consideration the level of Federal and other resources participating in the exercise.

All activities must be 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.

BRC: BRC will use insstrumentation and measuremnent techniques as statel in SOPs.

iartin.: N/A St. Lucie: N/A Brevard: N/A Ind(ian River: N/A Palni Beach: N/A DEM. N/A 4.b - Post Plume Phase Field Measurements and Sampling Criterion 4.b.1: The field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, %vater, vegetation, and soil) to support adequate assessments and protective action decision-making. (NUREG-0654, 1.8., J.1 1.)

Extent of Plav The ORO's field teams should demonstrate the capability to take measurements and samples, at such times and locations as directed, to enable an adequate assessment of the ingestion pathway and to support re-entry, relocation, and return decisions. When resources are available, the use of aerial surveys and in-situ gamma measurement is appropriate. All methodology, including contamination control, instrumentation, preparation of samples, and chain-of-custody form for transfer to a laboratory, will be in accordance with the ORO's plan and/or procedures.

Ingestion pathway samples sh9uld be secured from agricultural products and water. Samples in support of relocation and return should be secured from soil, vegetation, and other surfaces in areas that received radioactive ground deposition.

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

compacts, nuclear insurers, etc), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

26

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

Martin: N/A St. Lucie: NAV Brevtrl: N/A Ind(ian River: N/A Palin: Beach: AVA BRC: N/A DEAP N/A 4.c-Laboratory Operations Criterion 4.c.l: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654, C.3; J.1 1)

Extent of Plan The laboratory staff should demonstrate the capability to follow appropriate procedures for receiving samples, including logging of information, preventing contamination of the laboratory, preventing buildup of background radiation due to stored samples, preventing cross contamination of samples, preserving samples that may spoil ( for example, milk),

and keeping track of sample identity. In addition, the laboratory staff should demonstrate the capability to prepare samples for conducting measurements.

The laboratory should be appropriately equipped to provide analyses of media, as requested, on a timely basis, of sufficient quality and sensitivity to support assessments and decisions as anticipated by the ORO's plans and procedures. The laboratory (laboratories) instniment calibrations should be traceable to standards provided by the National Institute of Standards and Technology. Laboratory methods used to analyze typical radionuclides released in a reactor incident should be as described in the plans and procedures. New or revised methods may be used to analyze atypical radionuclide releases (for example, transuranics or as a result of a terrorist event) or if warranted by circumstances of the event. Analysis may require resources beyond those of the ORO.

The laboratory staff should be qualified in radioanalytical techniques and contamination control procedures.

OROs should use Federal resources as identified in the FRERP, and other resources (for 27

example, compacts, utility, nuclear insurers, 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.

BRC: BRC will use instrumentation and measurement techniques as stated in SOPs.

AMartin: N/A St. Lucie: IN/A Brevard: N/A Inlian River: N/A Palln Beach: N/A DEAf: N/A

5. EMERGENCY NOTIFICATION AND PUBLIC INFORMATION 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 offsite 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 FENIA REP guidance. (10 CFR Part 50, Appendix E.INV.D and NUREG-0654, E.5, 6, 7)

Extent of Plav Responsible Offsite Response Organizations (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 alerting/notification. The initial message should include the elements required by current FEMA REP guidance.

Offsite Response Organizations (OROs) with route alerting as the primary method of 28

alerting and notifying the public should demonstrate the capability to accomplish the primary route alerting, following the decision to activate the alert and notification system, in a timely manner (will not be subject to specific time requirements) in accordance with the ORO's plan and/or procedures. At least one route needs to be demonstrated and evaluated. The selected routc(s) 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 (that is, 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 will be conducted at some agreed-upon location. The initial message should include the elements required by current FEMA REP guidance.

For exercise purposes, timely is defined as "tile 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.

Procedures to broadcast the message should be fully demonstrated as they would in an actual emergency up to the point of transmission. Broadcast of the message(s) or test messages is niot 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.

Martin: Martin Count)- I Vill simulate the siren sounding at site and general enmergency and ail)' other tine plant condition, or PADs changes warrant. The EOC PIO Iswill have all of the mnedia contact information The Ops Chief, and or the EM Dir. wtill coor. it'ith St.

Lucie Co. and The EOF.

St. Lucie: Once the fimnal decision to implenment protective actions is madefor Site Area Emtergency, St. Lucie County twill activate tihe 10 nzile EPZ Sireni Systemn quarterly test message and wthill simnulate the issuance of the appropriateEAS message IA IV local procedures. Anly additionalrequirement to sound sirens and issue EAS messages wt-ill be sinmldatedfollowinglocalprocedures.

DEM F-SERT: Time F-SERT wtill play a coordination role oll)y. The F-SERTwt'ill not be responsiblefor the actualsounding of the sirens, nor the EAS messages.

29

Brevard: NMA Ind(ian Rivwer: N/A Palni Beach: N/A BRC: N/A Criterion5.a.2: Actitvation of the ProntjptAlert and Notification Systels IRESER J'ED at this tmide]

Criterion 5.a.3: Activities associated with FENIA 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)

Extent of Plav Offsite Response Organizations (OROs) with FEMA-approved exception areas (identified in the approved Alert and Notification System Design Report) 5-10 miles from the nuclear powver 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 offsite 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. Thc 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 route(s) 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 (that is, 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 will be conducted at some agreed-upon location.

Backup 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. Backup route alerting only needs to 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 (that is, the message that would actually be used is read for the 30

evaluator, but not actually broadcast) as agreed upon in the extent-of-play. Actual testing of the mobile public address system will be conducted at some agreed-upon location.

All activities for this criterion must be based on1the 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.

Martin: Martin county- lvll demonstrate Back-up Route Alerting only If there is a failure of0/an) of the outdoor warning sirens in Martin Count).

St. Lucie: There are 1no exception areas wt'ithin the 10 mile EPZ. Sholdl a siren/aillure occur at any siren site, backutp alert routingforthat site will be incorporatedinto the e.rercise. Appropriate law elnforcement agencies in the EOC will identi5'units to complete the notification. Notification for dispatching it'ill be simulated. Ifall actual failure is not aeperienced, all inject will be usedl to demonstrate back tip alerting capability, ais described above.

Brev'ard: N/A Indian Rih'er. N/A Palni Beach: N/A BRC. N/A DEA!: N/A 5.b - Emergency Information and Instructions for the Public and the Media:

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.c)

Extent of Plav 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 "the responsible ORO personnel/representatives demonstrate actions to disseminate the appropriate informnationlinstructions 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 withy a message was not considered timely.

The ORO should ensure that emergency information and instructions are consistent with protective action decisions made by appropriate officials. The emergency information 31

should contain all necessary and applicable instructions ( for example, evacuation instructions, evacuation routes, reception center locations, what 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. Tile ORO should also be prepared to disclose and explain the Emergency Classification Level (ECL) of the incident. At a minimum, this information must be included in media briefings and/or media releases. 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.

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 (for example, Emergency Alert System LEAS] 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 othervise 32

indicated in the extent-of-play agreement.

M'artin: Martin Counjt- W1ill /halecopies of EAS anl news releases availableat the EANC for the media. We Hill staff rumor control lines wit/h I person, andi generate enough call so tlalt the operatorwill recognize a trend of errantinformation anl report it to the EOC PIO, who wt'illforit'ardt/he information to tie EANC PlO wh'/o will wi'rite a releasefortihe niedia to correct tihe misperception. Tile ENC w'ill dlemonsstmate tihe ability to rescind no longer valid information if driven by tihe scenario. Any criteria not obseri'el may be deterninued by interview.

St. Lucie: In agreement.

Brevard: N/A Indian River: N/A Pa/ni Beachu: NAV BRC. N/A DEM: N/A

6. SUPPORT OPERATION/FACILITIES 6.a - Monitoring and Decontamination of Evacuees and Emergency Workers and Registration of Evacuees:

Criterion 6.a.1: The reception centcr/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; J.12; K.5.a)

Extent of Plav Radiological monitoring, decontamination, and registration facilities for cvacuees/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% 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 />. Before using 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% emergency planning zone (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 33

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 allo v 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 twelve-hour requirement can be met. Monitoring of emergency workers does not have to meet the twelve-hour requirement. However, appropriate monitoring procedures should be demonstrated for a minimum of two emergency workers.

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 (for example, 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.

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 othervise indicated in the extent-of-play agreement.

Martin: Martin Couinty-J Vill demonstrateEmergency, Jorker Decontaminationout of sequence at the w'ashdown site. See 6.b.

St. Lucie: This objective it-ill be demonstrated during the emner-gency it'orker/equipment wash dowt'n drill on Jain taiy 21, 2004. The St. Lucie Counlty FireDistrict will demonstratemonitoriing2 emnergency personnel,following localprocedures.

34

Brevard: (For Evacuees and not emergency iworkers) To take place on Januaiy 22, 2003, in the morning hours 9:30 am. Demnonstrationfor monitoring wvill occcirat th/e Brevard counyt reception center: Located 1-95 rest stop site, interviewv will deal wit/i procedures for decontamination anid movement of evwacuees fi-om reception center.

Indian River: Indian River County will demonstrate f1/e Monitoring,Registration and Decountamnination of Evaciuees. Ilndian River Coulty illprovide to time Ind(/ianl Rirer Counlty Health Departmient tables, chairs, signage and tape for the DOH designated K!

disbursementareas. All demonstrations it'ill take place out of sequence on Januar) 22, 2004 at1:00 at the Indian River County Regional Park/SebastianRiver Middle School 9450 C.R. 512, Sebastian Fl.

Pa/ni Beach: Pal/ Beach County will dlemonstrate the Moiiitoringand Decontaininatioi of 6 evacuees /persoils at the Johii PrincePark Site using volunteers. Registration activities will be lemnonstmated at t/ie monitoringstation. Additionally, Palh Beach Couznty, itill provide to the Palhn Beach Counlty Health Departmnemit tables, chairs, signage, tape, amid direct decontaminatedpersons to the DOH designated areafor K!

disbursement. All demonstratioins it'ill take place out ofsequence omi Januam)y 20, 2004 at John Prince Park.This activity can: be re- demonstrated during tJhe evaluatiou if andl when necessamy in ordeer to satisfy th/e requirements of t/e criteria.

BRC: N/A DEA. N/A 6.b - Monitoring and Decontamination of Emergency 'orker 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)

Extent of Plav The monitoring staff should demonstrate the capability to monitor cquipment, including vehicles, for contamination in accordance wvith the Offsite Response Organization's (ORO's) plans and procedures. Specific attention should be given to equipment, including vehicles, that was in contact with individuals found to be contaminated. The monitoring staff should demonstrate the capability to make decisions on the need for decontamination of equipment, including vehicles, based on guidance levels and procedures stated in the plan and/or procedures.

The area to be used for monitoring and decontamination should be set up as it wvould be in an actual emergency, wvith all route markings, instrumentation, record keeping and contamination control measures in place. Monitoring procedures should be demonstrated for a minimum of one vehicle. It is generally not necessary to monitor the entire surface 35

of vehicles. However, the capability to monitor areas such as radiator grills, bumpers, xwheel wells, tires, and door handles should be demonstrated. Interior surfaces of vehicles that wvere in contact with individuals found to be contaminated should also be checked.

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

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.

Martin: Martin County- Vill set up it's operation out of sequence at Fire Stationi 14 on the southern end of Hultcheson Island. Staff wtill demonstrate vehicle survey, wtashldoii'n routing of clean and or contamzinated vehicles, at least one staffmneinber wvill befound to be contalninatedl. Time contamninlatedpersonnel iv'ill be leconned. Vehicles at randomi iv'ill be found to be cleai, or contaiinated,and ma)' have contamninatedpersonnelonboard.

The FEWA evaluator wt-ill be ask to idenlift/'which vehicles are contaminated wt'hen they are in position to mnake observations, that vehicle 's driver will be given ihjects indicating the location anl levels. Tihe FEMA evaluatorwvill also be asked to identify it'hmich drivers a1nd orpassengersof contaminated vehicles are conta imated when they are in position and ready,to observe the denmonstration. Injects will be given the participantsindicating locution aiid levels of contamination.

St. Lucie: This objective It'ill be denmonstratedduringthe emllergemicy persoznnel/lehicle 1as/h doiwnl demzonstrationz drill oii Januaiy 21 2004. Tle St. Lucie County FireDistrict wt'ill process 2 emzergency vehicles,followving local procedures.

Brevard: N/A Indian River: N/A Paln Beach: JN/A BRC. N/A DEAI: N/A 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 vitlh 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.10.1i, J.12) 36

Extent of Plan Under this criterion, demonstration of congregate care centers may be conducted out of sequence with the exercise scenario. The evaluator should conduct a wvalk-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 objective, 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 interviewv 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 (facilities). However, availability of such items should be verified by providing the evaluator a list of sources with locations and estimates of quantities.

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.

Brevard: To be demonstratedon Jan ual3 22, 2003, in the morning TBD. At the Brevard County r-eception center, located at the I-95 Rest Stop Site.

Indian River: Indian River Counlty demonstrationof Temnporamy Care of Evacuees will take place out ofscqueLncc on Januay), 22, 2004 at the Indian River County Regional Park/SebastianRiver Middle School 9450 C.R. 512, Sebastian Fl.

Panlm Beach: Palim Beach County demoristratioiiof Temporal) Care of Evacuees ii'ill take place out of sequence onl Jadniain 21. 2004 at 8 shelter sites: (PalniBeach Communmiity College Gymniasiuim, Lake Worth Middle School, Pal/m Beach CentralHigh School, Boynton Beach High school, Odyssey Middle School, Bear Lakes Middle School, and W'atson B. Duincan Middle School). All school inspections must be completed by 3:00pm on Januamy 21, 2004. The shelter-ingprocedulresiwill be demlonistr-atedthroutgh walk throughs of the host shelterfacilities,discussion wt'ith an AmInerican Red Cross representativ'e, and observation of the host shelterfacilitymnap to determine that criterion ofARC 3031 are met. Congregatecare staff will be able to verbally demz onstratetheir capability to ensure that evacutees have been nmonitoredfor contamzination at the reception center priorto eiatth3 into the host shelter, that evacutees are registered,and that registrationforms are availablefor inspection byt FEMA. Actual set-up offacility and 37

equipmlien iwill not occur at tie host shelteringsites. The transportationprocessfor evacutees who were contamnincatedanld, therefore, clo not have transportationl%'ill be demonstratedIverbally through a discussion wt'ith the appropriatePahni Trall representativewho will be onsite at John Prince Par* on Januwa) 20, 2003. This activity can be re- demonistrated(luring the evaluation if andI when necessary in ordler to satisfy tfle requirements of the criteria.

AMarlin: N/A St. Lucie: N/A BRC. N/A DEA: N/A 6.d - Transportation and Treatment of Contaminated Injured Individuals:

Criterion 6.d.1: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals. (NUREG-0654, F.2; 11.10; K.5.a, b; L.1, 4)

Extent of Plav Monitoring, decontamination, and contamination control efforts will not delay urgent medical care for the victim.

Offsite Response Organizations (OROs) should demonstrate the capability to transport contaminated injured individuals to medical facilities. An ambulance should be used for the response to the victim. However, to avoid taking an ambulance out of service for an extended time, any vehicle (e.g., car, truck, or van) may be utilized to transport the victim to the medical facility. Normal communications between the ambulance/dispatcher and the receiving medical facility should be demonstrated. If a substitute vehicle is used for transport to the medical facility, this communication must occur before releasing the ambulance from the drill. This communication would include reporting radiation monitoring results, if available. Additionally, the ambulance crew should demonstrate, by interview, knowledge of where the ambulance and crew would be monitored and decontaminated, if required, or whom to contact for such information.

Monitoring of the victim may be performed before transport, done enroute, or deferred to the medical facility. Before using a monitoring instrument(s), the monitor(s) should demonstrate the process of checking the instrument(s) for proper operation. All monitoring activities should be completed as they would be in an actual emergency.

Appropriate contamination control measures should be demonstrated before and during transport and at the receiving medical facility.

38

The medical facility should demonstrate the capability to activate and set up a radiological emergency area for treatment. Equipment and supplies should be available for the treatment of contaminated injured individuals.

The medical facility should demonstrate the capability to make decisions on the need for decontamination of the individual, to follow appropriate decontamination procedures, and to maintain records of all survey measurements and samples taken. All procedures for the collection and analysis of samples and the decontamination of the individual should be demonstrated or described to the evaluator.

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.

AMartin: N/A St. Lutcie: N/A Brevardcl: N/A Indian Riv'er. N/A Pali Beacli: N/A BRC. N/A DEAP AT/A 39

L APPENDIX4 L EXERCISE SCENARIO

- This appendix contains a summary of the simulated sequence of events, which was used as the I basis for invoking emergency response actions by offsite response organizations in the Saint Lucie Nuclear Power Plant exercise on February 18, 2004.

L This exercise scenario was submitted by the State of Florida and approved by FEMA Region IV.

jK (In Final Report Only)

L L

Lx L.

34 L

CONFIDENTIAL (until 2-18-04)

FLORIDA POWER AND LIGHT COMPANY ST. LUCIE PLANT 2004 EMERGENCY PREPAREDNESS EVALUATED EXERCISE FEBRUARY 18,2004 4.1 NARRATIVE

SUMMARY

During the turnover briefing, the Operations crew is informed that (1) the 2A Component Cooling Water (CCW) Pump is out-of-service (OOS) for an oil change and (2) the Operations Supervisor has requested that the monthly surveillance run of the 2B Emergency Diesel Generator (EDG) begin prior to 0800. The 2B EDG fails to start. This condition places the Unit in a Technical Specification Action Statement.

The Unit 2 Turbine Generator Building (TGB) Gantry Crane is undergoing maintenance. As the crane operator attempts to engage the auxiliary hoist crane, the hook free falls and strikes the B phase of the 2B Startup Transformer. The transformer is lost and combined with the earlier loss of the 2B EDG, renders B Train of electric power out-of-service. This condition places the Unit in another Technical Specification Action Statement.

The Reactor Coolant System (RCS) experiences a small break leak which is determined to be in excess of 50 gallons per minute (GPM). The Shift Manager/Emergency Coordinator (EC) declares an ALERT based on the RCS leakage. The Operators initiate a downpower, but experience feedwater control problems and are forced to trip the turbine and reactor. At the trip, the 2B EDG is unavailable and electrical loads are being maintained by the 2A Startup Transformer.

The break on the 2B Hot Leg increases such that the loss of RCS exceeds makeup capacity and the EC declares a SITE AREA EMERGENCY. On the Safety Injection Actuation Signal (SIAS), the 2A Low Pressure Safety Injection (LPSI) Pump shows fluctuating amperage in the Control Room Simulator. The 2A High Pressure Safety Injection (HPSI) Pump is operating normally and provides safety injection to the core.

A bearing problem develops and shuts down the 2A HPSI Pump. Re-entry Teams are requested to investigate the loss of the 2A HPSI and 2A LPSI Pumps. The 2A HPSI Pump is not recoverable. The 2A LPSI Pump is found to be air bound. The Re-entry Teams will eventually recover both the 2A LPSI Pump and the 2B EDG, but not before the core is heated to 700 F and gas gap activity is released into the RCS. The potential for release of large amounts of radioactive material prompts the EC to declare a GENERAL EMERGENCY and the Recovery Manager (RIM) to recommend protective actions for the general public.

Radioactive material escapes the Reactor Containment Building (RCB), but is filtered and monitored by the Plant Vent prior to release to the atmosphere. Field Monitoring Teams (FMlTs) will monitor and track the resulting plume.

With the restoration of the Emergency Core Cooling System (ECCS) and as conditions improve at the plant, the RM wvill initiate discussions of recovery and re-entry with the off-site officials at the Emergency Operations Facility (EOF).

FPL PSL

• -. ,..' r-'- (uw

- f----. I----

CONFIDENTIAL (uilil 2-i8-(4 FLORIDA POWER AND LIGHT COMPANY ST. LUCIE PLANT 2004 EMERGENCY PREPAREDNESS EVALUATED EXERCISE FEBRUARY 18, 2004 4.2 SCEINARI0 TIMELINE I2 SIMULATOR EVENT EVENT S-TIME CLOCK' STMUCTON NO DESCRIPTION ANTICIPATED RESPONSE ACTIONS 00/00 0700 Initial Setup Shift Turnovcr The initial conditions establish that Mechanical

- Restore IC Set #11 Initial Conditions Maintcnancc replacing the oil in thc 2A CCW Pump and

- Start 2C CCW Pump the Opcrations Crew is about to commence thei monthly

- Put 2A CCW Pump in surveillance of the 20 Emergency Dicsel Generator.

"Pull to Lock" position

- Place ECO Tag on 2A CCW Pump Switch

- 2A LPSI Pump Air Bound

- Start Recorder 00130 0730 2B EDG I 2B Emergency Diesel Generator fails NLO checks 2B EDG failurc to start.

to start 00/45 0745 2B S/U XFRMR 2 Loss of 2B Startup Transformer NWE/NLO report damage to the buswork of thl 13' side Startup Transformers.

S-Time = Scenario time, which begins at zero.

2 Clock = Actual time, all times approximate.

r Pt J/PSL - 56 of 107 -

I I r-- f7-- F- n- rT-- r- IL- r--~- F-7 1-1 ..- F---'. F-.

r--F7 [7 F.- wfI,-- - F---

.-.. im - -- -

CONFIDENTIAL (until 2-18-04)

FLORIDA POWER AND LIGHT COMPANY ST. LUCIE PLANT 2004 EMERGENCY PREPAREDNESS EVALUATED EXERCISE FEBRUARY 18,2004 4.2 SCENARIOTIMELINE, (conlinued)

EVENT DESCIPTION ANTICIPATED RESPONSE ACTIONS

.S-TI INSTIMUCTION 0815 RCS l eak 3 Reactor Coolant System Leakage The EC classifies the emergency in accordancc with (1/15 EPIP-01.

ALERT Declaration The EC completes the Alert Declaration Checklist pcr EPIP-02.

Due to ILA: RCS-Leakape GREATER The FPL Emergency Response Organization (ERO) is THAN 50 activated in accordance with EPIP-03.

spm

1. UnisolableRCS leakage as The State and Counties are notified per EPIP-08.

indicatedby Charging/Letdown The NRC is notified per EPIP-08.

inismatchgreaterthan 50 gpm but less than availablechargingpump aTccordance with EPpP-04.

capacity.

OR The Operational Support Center (OSC) activates in

2. Utiisolablemeasured RCS leakage accordance with EPIP-05.

indicatinggreater than JOgpm but The Emergency Operations Facility (EOF) begins Icss than availablechargingpump preliminary activation in accordance wiltl EPJP-06.

capacity. Health Physics (I-1P) implements the HP-200 Emergeicy Plan implementing procedures and dispatches the 'Rcd' Field Monitoring Team.

Field monitoring activities are initiated in accordance with EPIP-Io.

The EC duties arc turned over in accordance wilh EPIP-02.

S-Time = Scenario timc, %whichbegins at zero.

~Clock = Actual timc, all times approxiriatc.

r-w } }

1 i- -7 1-7,

[77 r--- 17 F-- I fJJNFr----A-1 ru un 11111 ~-u 1 ,-

FLORIDA POWER AND LIGHT COMPANY ST. LUCIE PLANT 2004 EMERGENCY PREPAREDNESS EVALUATED EXERCISE FEBRUARY 18, 2004 4.2 SCENARIO TIMELINE (continued)

S-TIM rt. CLOCK2 SIMULATOR EVENT EVENT ANTICIPATED RESPONSE ACTIONS

________ INSTRUCTION NO. DESCRIPTION ATCPTDRSOS CIN 01/40 0840 None Contingency Afessagefor thte Alert No Ently.

(if appropriate) 02/20 0920 FCV-9021 Problem 4 Flow Control Valve 1FCV-9021 creates Operators arc unable to control fccdwater, manually trip feedwater control problem the turbinc and rcactor.

Operations personncl perform Standard Post Trip Actions (SPTAs) in accordancc willt 2-EOI'-01.

Chemistry is requcsted to sample both Steam Gcnerators (S/Gs) in accordancc with 2-EOP-03/15.

03/00 1000 LOCA S Large Brcak Loss of Coolant Accident The EC classifics tile cmergency in accordancc with (LOCA) EPIP-01.

SITE AREA EMERGENCY The EC completes the Sitc Area Emergency Checklist Declaration per EPIP-02.

The State and Counties are notified per EPIP-08.

Due to I.A: LOCA GREATER TIHAN Thc NRC is notified per EP11'-08.

cagacity of charging numps The Recovcry Managcr (R(M) declares the EOF

1. RCS leakage greaterthan operational if hie has not already done so.

availablechargingpump capacity Additional Field Monitoring Teams arc dispatched in occurringwith RCS pressure accordance with EPlIP- 0.

above HPSI A utoff head. All Rc-cntry activities arc controlled through the OSC in accordance with EPIP-05.

s-Trimc =Scenario time, which begins at zero.

2Clock = Actual time, all times applroximate.

rT1J11SL -58 ort07-

r7-- -- , rF- n - n- r- rE-- ran fIr--- r--1 r- r-- Fr-- r- - <--- F7-, 17-CONFIDENTIAL (until 2-18-04)

FLORIDA P'OWER AND LIGHT COMPANY ST. LUCIE PLANT 2004 EMERGENCY PREPAREDNESS EVALUATED EXERCISE FEBRUARY 18, 2004 4.2 SCENARIO TIN ELINE (continud)

SirIMULATOi z EVENT EVENT ANTICIPATED RESPONSE ACTIONS S-TIMIE'I CLOCK' INSTRUCTION NO. DESCRIPTION LOCA 5 All non-essential personnel are evacuated.

03/00 1000 The Assembly Area Supervisor is dispatched.

(continuled)

NLOs are directed to report to the OSC following completion of immediate operator actions.

At tile Safety Injection Actuation NRC Site Team is dispatched from Region IV office in Signal (SIAS): Atlanta, GA.

• 2A High Pressure Safety Injection NLO to evaluate fluctuating amperage on 2A LPSI Pump (HPSI) operational Pump.

• 2A Low Pressure Safety Injection Pump (LPSI) shows fluctuating

__ amps.

None ... C'onhingency Messagefor the Site No Entry.

03/15 1015

_A raEtmergency 2A I IPSI Loss 6 2A I IPSI Pump fails due to a bearing Re-entry Team is sent to troubleshoot 2A H-IPSI Puump.

04/30 1130 problem.

Insert "'Small Mad" 7 CET temperatures > 70001, initiate Off-site assessment is performed in accordance vith 05/30 1230 release of gas gap activity. EPIP-09.

Monitored low level release begins Core damage assessment is performed in accordance through Plant Vent. with EPIP-I 1.

The Problem Solving Team (PST) begins reviewing the Sevcre Accident Management Guidelines (SAMGs).

S-Timc = Scenario time, %whichbegins at zero.

- Clock = Actual time, all times approxhilate.

Fi' I./I'SLI

- 59 or107-

. I I I I I -*F r-- (F7 T rV- l*r F Fr.- [- r-- r- v-CONFIDENTIAL (until 2-18-04)

FLORIDA POWER AND LIGHT COMPANY ST. LUCIE PLANT 2004 EMERGENCY PREPAREDNESS EVALUATED EXERCISE FEBRUARY 18, 2004 4.2 SCENARIO TIMELINE (continued)

EVENT EVENT ATCPTDRSOS CIN S-TIME' CLOCK SIMULATOR INSTRUCTION NO. DESCRIPTION ANTICIPATED RESPONSE ACTIONS Insert "Small Rad" 7 GENERAL EMERGENCY Thc EC classifies thC emergency in accordance with 05/30 1230 Declaration  ; EPIP'-O1.

(continucd)

Duc to 6.A: Increased Awareness or The EC completes the General Emergency Checklist per potential corc melt. EPIP-02.

Emergency Coordinator'sjudgemnent The RlM develops Protective Action Recommendation.s that plant conditionsexist that make (PARs) in accordance with EP11'-08.

release of large amounts of The State and Counties are notified per El'IP-08.

radioactivity in a shiortperiodappear possible or likely (any core melt The NRC is notified per EPIP-08.

sirttalionJ. Ofrrsitc dosc assessment is performed in accordance wilth

1. LOCA withfailure ofEGCCS EPIP-09.

leadingtosevere core degradation Corc damage assessment is performed in accordance or melt. with EPIP-l 1.

The RM will update thle PAlls in accordance with EPIP-08.

Field Monitoring Tennis wvill track tile plume of radioactive material in accordance with EPIP-IO.

1245 None -. Contimugency MJessagefor General No Entr.

05/45 Emergency__

1300 Restore 2A LPS[ 8 2A LPSI pump vented Operators arc able to restore 'A' side ECCS.

06/00

. Insert "Large Rad" S-Time = Scenario time, which begins at zero.

2 Clock = Actual time, all times approximate.

F-11Jl'Sl - 60 of 107 -

1-I I .. [7--I r177 r - lT I-- T F7 [-*-- rr:- - [-- r--T r[.

CONFIDENTIAL (until 2-18-04)

FLORIDA POWER AND LIGHT COMPANY ST. LUCIE PLANT 2004 EMERGENCY PREPAREDNESS EVALUATED EXERCISE FEBRUARY 18,2004 4.2 SCENARIOnTIM ELI NE (continucd)

S-Tim r. CLOCK' SIMULATroi EVENT EVENT ATCPTDRSOS CIN S-TI M 'IINSTRUCTION NO. DESCRIPTION ANTICIPATED RESPONSE ACTIONS 06/15 1315 lRestore 213 IDl)G 9 2U EDG Recovered Operators able to restore 'B' side ECCS.

06/30 1330 Noule ... Recovery/Re-entry The RM commences discussions of de-escalation of thc emergency and recovery/re-entry in accordance wiltl

_ EPIP-06.

07/00 1400 Noll The Evaluated Exercise is terminated. All Players and Controllers attend in-facility criligiles.

S-Timc = Scenario time, which begins at zero.

2Clock = Actual tinc, all limes approximate.

1-171 /pql. -61 of 107-