Text

FEMA Final Exercise Report Perry Nuclear Power Plant Exercise Date Oct 5, 2004
	ML050810184
Person / Time
Site:	Perry
Issue date:	02/14/2005
From:	; US Dept of Homeland Security, Federal Emergency Management Agency
To:	; Office of Nuclear Reactor Regulation
References
	Download: ML050810184 (87)
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FEMA Final Exercise Report Perry Nuclear Power Plant Licensee: FirstEnergy Corporation Exercise Date: October 5,2004 Report Date: February 14,2005 U.S. DEPARTMENT OF HOMELAND SECURITY FEMA REGION V 536 South Clark Street, 6th Floor Chicago, Illinois 60605-1521

TABLE OF CONTENTS Page I. EXECUTIVE

SUMMARY

................................................................................................. 1 TI. INTRODUCTION ................................................................................................................. 3 111. EXERCISE OVERVIEW .................................................................................................... 4 A. Plume Emergency Planning Zone Description ....................................................... 4 B. Exercise Participants ............................................................................................... .5 C. Exercise Timeline ................................................................................................. ..S IV. EXERCISE EVALUATION AND RESULTS .................................................................. ..,Q A. Summary Results of Exercise Evaluation ............................................................... 9 B. Status of Jurisdictions Evaluated .......................................................................... .12

1. STATE OF OHIO ..................................................................................... 14 1.1 Initial Notification Point ............................................................... .14 1.2 State Emergency Operations Center ............................................. .14 1.3 State Assessment Room ................................................................. 1.1 1.4 Joint Public Information Center ..................................................... 15 1.5 Emergency Operations Facility. ..................................................... 15 1.6 Field Monitoring Team I. ............................................................... 15 1.7 Field Monitoring Team I1............................................................... 16 State Communicatlons Van ............................................................ 16 1.8 1.9 Sample Screening Point ................................................................. 16 1.10 Lake County Field Team Manager ................................................. 17

2. RISK JURISDICTIONS .............................................................................. 17 2.1 LAKE COUNTY ........................................................................... 17 2.1.1 Initial Notification Point .................................................... 17 2.1.2 Lake County Emergency Operations Center ...................... 17 2.1.3 Joint Public Information Center ......................................... 18 2.1.4 Traffic and Access Control ................................................ 19 2.1.5 Lake County Field Monitoring Team I ............................. .19 2.1.6 Lake County Field Monitoring Team I1 ............................. 20 i

2.1.7 Monitoring and Decontamination - Public South High School ............................................................. 20 2.1 .S Congregate Care CenterRegistration South H. S .......................................................................... 21 2.1.9 School District Madison School ................................................................. 2 1 2-1.10 School District Fairport School .................................................................. -- 77 2.1.11 Back-up Route Alerting ....................................................... 7 9 2.1.13 Medical Services - Transportation Perry Nuclear Power Plant ................................................... 7 3 2.1.13 Medical Services - Facilities Lake West Hospital ............................................................ -- 1 2.2 ASHTABULA COUNTY ........................................................... ..X 2.2.1 Initial Notification Point ................................................... .23 2.2.2 Ashtabula County Emergency Operations Center .............23 2.2.3 Joint Public Information Center ........................................ 24 2.2.4 Traffic and Access Control Points ..................................... 24 2.2.5 Back-up Route Alertin ...................................................... 24 2.2.6 Monitoring and Decontamination Center - Emergency Workers - Vehicles Saybrook Elementary School ........................................... ..25 2.2.7 Monitoring and Decontamination Center -Emergency Workers Saybrook Elementary School............................................. j .

2.3 GEAVGA COUNTY ..................................................................... 26 2.3.1 Initial Notification Point ................................................... .26 2.3.2 Geauga County Emergency Operations Center .................26 2.3.3 Joint Public Information Center ....................................... .26 2.3.4 Traffic and Access Control Points ..................................... 27 2.3.5 Monitoring/Decontamination/Registration- Public Newbury High School ....................................................... 27 2.3.6 Back-up Route Alerting ..................................................... 28 2.3.7 Congregate Care CenterRegistration Newbury High School. ...................................................... 2 s

ist of Appendices APPEYDIX 1 - ;IICRONYhIS AND XBBREVI.4TIONS ............................................................ ~9

- APPEXDIX 2 - EXERCISE EVALUATORS AND TEAhII LEADERS ...................................... 3 1 XPPENDIX 3 - EXERCISE CRITEFUX AND EXTEXT-OF-PLAY AGREEhlENT .................- - ?

3 -

APPEXDIX 4 - EXERCISE SCENARIO ..................................................................................... .S 1 List of Tables Table 1 - Exercise Timeline ............................................................................................................ 7 Table 2 - Summary Results of Exercise Evaluation ...................................................................... 10

I. EXECUTIVE

SUMMARY

On October 5,2004, an exercise was conducted in the plume emergency planning zone (EPZ) around the Perry Nuclear Power Plant (PNPP) by the Department of Homeland Security Federal Emergency Management Agency (DHSFEMA) Region V. The purpose of the exercise was to assess the level of State and local preparedness in responding to a radiological emergency. This exercise was held in accordance with DHSFEMA's policies and guidance concerning the exercise of State and local radiological emergency response plans (REW)and procedures.

The most recent exercise at this site was conducted on April 9,2002. The qualifying emergency preparedness exercise was conducted on November 28, 1984.

DHSEEMA wishes to acknowledge the efforts of the many individuals who participated in this exercise. In the State of Ohio, the risk counties of Lake, Ashtabula, and Geauga participated along with the State government.

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

This report contains the final evaluation of the October 5,2004, biennial exercise and the following out-of-sequence activities:

State of Ohio Plume Phase Field Measurement and Analysis State Field Monitoring Team I and Team II State of Ohio Laboratory Operations Sample Screening Point- Ledgemont Elementary School State of Ohio Equipment and Supplies to Support Operations State Communications Van - Ledgemont Elementary School Lake County Emergency Notification and Public Information Back-up Route Alerting - Concord Fire Department Lake County Plume Phase Field Measurement and Analysis Lake County Field Monitoring Team I and Team I1 Lake County Monitoring and Decontamination of Evacuees South High School Lake County Temporary Care of Evacuees South High School Lake County Implementation of Protective Actions for Schools - (EV-2)

Madison School District 1

Lake County Implementation of Protective Actions for Schools - (EV-2)

Fairport School District Ashtabula County Emergency Notification and Public Information Back-up Route Alerting - Harpersfield Volunteer Fire Department Ashtabula County MonitoringDecontamination of Evacuees and Emergency Workers Saybrook Elementary School Geauga County MonitoringDecontamination/Registration of Evacuees Newbury High School Geauga County Emergency Notific.ation and Public Information Back-up Route Alerting - Thompson Fire Department The State and local organizations demonstrated knowledge of their emergency response plans

- and procedures and adequately implemented them. There were no Deficiencies. Two Areas Requiring Corrective Action (ARCAs) were identified for Lake County. The first ARCA was related to Criterion 1.c. 1: Direction and Control. When Lake County Officials staff received

- notification that a release at the PNPP began at 1202 hours0.0139 days 0.334 hours 0.00199 weeks 4.57361e-4 months exceeding Protective Action Guides, this information was not passed on to the staff in the Operations Room. The second ARCA identified was related to Criterion 4.a.3: Plume Phase Measurement and Analysis of Equipment.

- -4 small zip lock plastic bag containing the (AgZ) cartridge was placed on the surface designated for potentially contaminated articles and when moved, no attempt was made to ensure that that the outside of the bag had not become contaminated, Sample handling and contamination

- control was successfully re-demonstrated.

One ARCA was identified for Ashtabula County. The ARCA identified was related to Criterion 3.a. 1: Implementation of Emergency Worker Exposure Control. The Radiological Officers briefing to the Public Information Officer, who was leaving the emergency operations center and traversing the emergency planning zone, did not address the following elements: frequency for reading the Direct Reading Dosimeters, maximum radiation exposure limits, and procedures to followed at the conclusion of the emergency or mission. At the conclusion of the exercise the Radiological Officer successfully re-demonstrated a dosimetry briefing that included the information previously omitted.

- One prior ARCA for Geauga County identified in Issue: 47-02-6.a.1-A-03: Criterion 6.a. 1:

Monitoring and decontamination of registration of evacuees and emergency worker. Interviewing the monitoring personnel and their supervision at that time revealed that they did not know the

- amount of contamination in mR/hr was needed to comply with their procedure and the Geauga County Plan. This ARCA was corrected during this exercise.

2

INTRODUCTION On December 7, 1979, the President directed DHS/TEMIA to assume the lead responsibility for all offsite nuclear planning and response. FEMA's activities are conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 35 1 and 352.

These regulations are a key element in the Radiological Emergency Preparedness (REP)

Program that was established following the Three Mile Island Nuclear Station accident in March 1979.

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

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

0 Taking the lead in offsite emergency planning and in the review and evaluation of RERPs and procedures developed by State and local governments;

Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by State and local governments; e Responding to requests by the US.Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the hRC and FEMA dated June 17, 1993 (Federal Register, Vol. 58, No. 176, September 14, 1993);

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

U.S. Department of Commerce, U.S. Nuclear Regulatory Commission, U.S. Environmental Protection Agency, U.S. Department of E n e r g ,

US.Department of Health and Human Services, U.S. Department of Transportation, U.S . Department of Agriculture, U.S.Department of the Interior, and U.S. Food and Drug Administration.

Representatives of these agencies serve on the DHSiFEhL4 Region V Regional

.4ssistance Committee gWC) which is chaired by DHS/FE;LIX. Formal submission of the REWs for the Perry Nuclear Powe: Plant to DHSEEMA Region V by thz State of Ohio and involved local jurisdictions occurred on May 24, 1989. Formal approval ofthe RERP was granted by DHSIFEMA on June 17, 1994, under 14 CFR 250.

A REP exercise was conducted on October 5: 2003, by DHSFEM.4 Region V 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 Perry Nuclear Power Plant. The purpose of this exercise report is to present the exercise results and findings on the performance of the offsire response organizations (ORO) during a simulated radiological emergency.

The findings presented in this report are based on the evaluations of the Federal evaluator team: with final determinations made by the DHS/FEIVl-A Region V R4C Chairperson:

and approved by the Regional Director.

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

e NLTR?2G-0654/FEiVfA-WP-l,Rev, 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Xuclear Power Plants," November 1980; e FEMA-REP-14, "Radiological Emergency Preparedness Exercise Manual,"

September 199 1J and FEM.4 "Radiological Emergency Preparedness: Exercise Evaluation Methodology," as published in the Federal Register NoticeNol. 67, No. SO, April 25, 2002.

Section I11 of this report, entitled "Exercise Overview," presents basic information and data relevant to the exercise. This section of the report contains a description of the plume pathway EPZ, a listing of all participating jurisdictions and functional entities that were evaluated, and a tabular presentation of the time of actual occurrence of key exercise events and activities.

Section IV of this report, entitled "Exercise Evaluation and Results," presents detailed information on the demonstration of applicable exercise objectives at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format. This section also contains: (1) descriptions of all ARCAs assessed during this exercise: recommended corrective actions, and the State and local governments' schedule of corrective actions for each identified exercise issue and (2) descriptions of resolved ARCAs assessed during previous exercises and the status of the OROs' efforts to resolve them.

111. EXERCISE OVERVIEW Contained in this section are data and basic information relevant to the October 5 , 2064,

- exercise to test the offsite emergency response capabilities in the area surrounding the Perry Yuclear Power Plant. This section of the exercise report includes a description of the plume pathway EPZ, a listing of all participating jurisdictions and functional entities that were evaluated, and a tabular presentation of' ihe time of actual occunecce of key exercise events and activities.

A. Plume Emergency Planning Zone Description The Perry lu'uclear Power Plant (PNPP)reactor uilits one and two are located on the southeast shoreline of Lake Erie in Lake County, Ohio. The site is approximately 7 miles northeast of Painesville, Ohio and thirty-five miles east of Cleveland. Ohio.

The plant site occupies approximately 1 100 acres on a lake plain fifty feet abo1.e the lake low-water datum. The tei-rain surrounding the plant is essentially flat within 5 iniles of the lal<eshore. Rising generally to the south, the site is broken onl~,by a lattice work of shallow, north-south stream beds and low, aliiiost Liimoticeable east-\vest ridges: the latter are reinnants of ancient lake-shores.

About 5 miles inland, the shoreline plane is abruptly cut by a 100-foot-deep ravine of the Grand River. The terrain south of the river is more rolling. inteinipted by north-south ravines of tributaries of the Grand. Kellogg. Big. Paine. and hclill creeks and selreral smaller streams. -4 large poi-tion of the site is forested. some two hundred and fifiy acres are devoted to the plant strucrural complex and the remainder is open grassland.

Lake County, where the nuclear power plant is located, is the smallest of Ohio's eighty-eight counties, with two hundred and thii-ty-two square miles. The 2000 census approximates the population to be 103,920 residents cuireiirly within the 1 0-mile einergeiicy planning zone (EPZ); 13, 59 1 are residents of Geneva and Harpersfield Townships in Ashtabula County with an estimated 1,930 in Geauga County.

FirstEnergy Corporation owns the Perry Nuclear Power Plant.

5

- B. Exercise Participants The following agencies, organizations. and units of government pacicipated in the Perry 'Nuclear Power Plant exercise on October 5 , 2004.

ST-ATE OF OHIO Ohio Department of Health Ohio Department of Public Safety Emersency Management BLgency Ohio State Highway Patrol Ohio Environmental Protection Agency Ohio National Guard LA4KECOVNTY Lake County Emergency Management Agency Lake County Emergency Operation Center Staff Lake County EOC Esecutive G ~ O L I ~

Lake County Field IMonitoring Teams Lake County P I 0 Liaison at the EOC Lake County Public Information Officer (PIO) at the JPIC Lake County General Health District Lake County Sheriffs Department Concord Fire Depai-tment Perry Township Fire Department Willougliby Fire Department Fairport School District Madison School District South High School Lake West Hospital Ohio State Highway Patrol ASHTABULA COUNTY Ashtabula County Emergency Management Agency Ashtabula County Emergency Operations Center Staff Ashtabula County EOC Executive Group Ashtabula County P I 0 Liaison at the Ashtabula County EOC Ashtabula County Public Information Officer at the JPIC Ashtabula County Sheriffs Department Harpersfield Township Fire Department Saybrook Fire Department 6

Saybroo k Elementary School Ghio State Hishway Patrol GEAUGA COIITTY Geauga County Emergency Operations Center Staff Geauga County Department of Emergency Senrices Geauga County EOC Executive Group Geauga County P I 0 at the JPIC Geauga County P I 0 Liaison at the Geauga County EOC Geauga County Sheriffs Office Thompson Township Fire Department Bainbridge Fire Department Sewbury Fire Department Newbury School District American Red Cross County Amateur Radio C. Exercise Timeline Table 1, on the following page, presents the time at which key events and actilities occurred during the Perry Nuclear Power plant Exercise on October 5 .

2004. Also, included are times notifications were made to the participating jurisdictioiislfunctional entities.

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I I I I I I I I I I I I I TABLE 1. EXERCISE TIMELINE DATE AND SITE: October 5, 2004 Perr! Vuclear Power Plant Emergency Classification Level o r Event Unusual Event OB00 0805 0010 0810 0810 08 10 NA Alert 0820 0828 0828 ORB 0828 0828 bIA Site Area Emergency 0937 0952 0952 0952 0952 0052 0945 General Emergency 1202 1214 1214 1214 1214 1214 1217 Simulated Release of Radio Active Materials Started 1200 1202 1 '1206 1 1209 1 1209 1 1209 1 1208 1 Simulated Release of Radio Active Materials Terminated 1425

~

1428 1431 NA NA I NA I NA acility Declared Operational 0930 1040 0933 0912 0839 I in35 Declaration of State of Disaster Emergency (State a n d Local) 1000 0955 0955 0955 0955 1027 Exercise Terminated: Plunie Pathway Phase co 1428 1430 1430 1432 1442 1430 Early Precautionary Actions:

Daycare. nurseries. and preschools c l o s e d NA NA NA 1010 NA NA Early Precautionary Actions:

Animals o n stored feed and protected water o u t t o IO-miles 1007 1035 1037 1037 in37 1045 SI Protective Action Decision Evacuate Sub-areas 1,2,3,5,6 a n d Lake E r i e out to 10-miles 1226 1218 1218 1219 1218 1218 Sub-areas 4 and 7 go inside a n d l i s t e n t o l o c a l EAS 1st Siren Activation NA NA 1228 NA NA NA NA NA 1231 NA NA NA

"" Protective Action Decision Evacuate 1,2,3,4.5,6 and Lake Erie o u t t o IO-miles 1342 1348 1348 1348 1348 1400 Sub-Area 7 g o inside a n d listen t o l o c a l EAS 2nd Siren Activation NA NA 1358 NA NA NA 2nd E A S NA NA 1401 NA NA NA KI Administration Decision:

1207 NA NA NA NA NA Eiriergency Workers o u t t o 10 miles K I Administration Decision:

NA 1218 1218 1219 1218 NA General Ptrblic and Eincrgency Workers in Sub-areas 1,2,3,5,6 KI Administration Decision:

NA 1318 1348 1318 I348 NA General Public a n d Emergency W o r k e r s in Sub-Area 4 I LEGEND: S - Support Jurisdiction D - Decisic Last priiited 1/25/2005 9 19 00 A M

IV. EXERCISE EVALUATION AND RESULTS Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities that participated in the October 5,2004, exercise to test the offsite emergency response capabilities of State and local governments in the 10-mile EPZ surrounding the Perry Nuclear Power Plant.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of exercise criteria contained in FEMA "Radiological Emergency Preparedness: Exercise Evaluation Methodoloa," as published in the Federal Register NoticeNol. 67, dated No. 80, dated April 25, 2002. Detailed information on the exercise criterion and the extent-of-play agreement used in this exercise 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(s), presents the status of all exercise criteria FEMA "Radiological Emergency Preparedness: Exercise Evaluation Methodology," as published in the Federal Register NoticeNol. 67, dated No. SO, dated April 25, 2002, that were scheduled for demonstration during this exercise, by all participating jurisdictions and functional entities. Exercise criterion is listed by number and the demonstration status of those objectives is indicated by the use of the following letters:

M - Met (No Deficiency or ARCAs assessed and no unresolved ARCA(s) 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)

Blank - Not scheduled for demonstration 9

I I I I I I I I I I I I I I I I I Site and Date.Perry Nuclear Power Plant Oclober 5, 2004

B. Status of Jurisdictions Evaluated

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

0 iMet - 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.

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

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

0 Not Demonstrated - Listing of the exercise criteria which were not demonstrated as scheduled during t h s exercise and the reason they were not demonstrated.

0 Prior Issues - Resolved - Descriptions of ARCAs assessed during previous exercises, which were resolved in this exercise and the corrective actions, demonstrated.

0 Prior Issues - Unresolved - Descriptions of ARCAs 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 following are definitions of the two types of exercise issues, which are discussed in this report.

0 A Deficiency is defined in FEMA-REP-14 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."

0 An ARCA is defined in FEMA-REP-14 as "...an observed or identified in adequacy of organizational performance in an exercise that is not considered, by 12

itself, to adversely impact public health and safety."

DH9FEM.4 has developed a standardized system for numbering exercise issues (Deficiencies and ARCAs). This system is used to achieve consistency in numbering exercise issues among DHSEEMA Regions and site-specific exercise reports within each Region. It also expedites tracking of exercise issues on a nationwide basis.

The identifying number of Deficiencies and ARC As includes the following elements, with each element separated by a hyphen (-).

e Plant Site Identifier - A two-digit number, corresponding to the Utility Billable Plant Site Codes.

e -

Exercise Year Last two digits of the year the exercise was conducted.

0 Criterion Number - An alpha and two-digit number corresponding to the criterion in as published in the Federal Register NoticeNol. 67, No. 80, dated April 25: 2002, which amends FEMA-REP 14: Radiological Emergency Preparedness Manual.

e Issue Classification Identifier - (D = Deficiency, A = ARCA)

Only Deficiencies and ARCAs are included in exercise reports.

Plan issues are reported to the State(s) via letter from the Regional Director.

Therefore, standardized issue numbers are not assigned to Plan Issues.

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

13

- 1. STATE OF OHIO

- 1.1 Initial Notification Point

a. MET: Criteria 1.a. 1. and 1.d.1.

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

- d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ,4RCAs - UNRESOLVED: NONE

- 1.2 State Emergency Operations Center

- a. MET: Criteria l,a,l, l.b.1, l.c.1, l.d.1, l.e.1, 2.b.1,2.b.2, 3.b.1, 5.a.l. and 5.b.l.

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

- d. KOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 1.3 State Assessment Room

- a. MET: Criteria 1 . ~ l.e.ly

~ 1 ~2.a.l,2.b.ly 2.b.2, 3.a.1, 3.b.l. and 3.d.l

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 14

1.3 Joint Public Information Center

a. MET: Criteria 5.b.l.

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NOM3

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NOhT

f. PRIOR ARCAS - UNRESOLVED: NOhT 1.4 Emergency Operations Facility

a. MET: Criteria 1.c. 1.and 1.d. 1 ,

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMORSTRATED: NONE

e. PRIOR ARCAs - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 1.5 Field Monitoring Team I

a. MET: Criteria 3.a.l. and 3.b.l.

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 15

- 1.6 Field Monitoring Team II

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

b. DEFICIENCY: NONE

c. AREAS REQUIFUNG CORRECTIVE ACTION: NONE

- d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - CWRESOLVED: NONE,

- 1.7 State Communications Van

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

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 1.8 Sample Screening Point

a. MET: Criteria l.d.1, l.e.l>3.a.1, 3.b.1, 4.a.l. and 4.a.3.

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

- e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCA4s- UNRESOLVED: NONE 16

- 1.9 Lake County Field Team Manager

- a. ,MET: Criterion 4.a.2.

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

- e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NOTU'E

2. RISK JURISDICTIONS 2.1 LAKE COUNTY

- 2.1.1 Initial Notification Point

- a. MET: Criteria 1.a. 1 and 1.d. 1.

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

- d. NOT DEMONSTRATED: NONE

e. -

PRIOR ARCAS RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.1.2 Lake County Emergency Operations Center

a. MET: Criteria I.a.1, l.b.1, l , e . l , I.d.l,2.a.l,2.b.2,2.c.l, 3.a.133.b.133.c.1, 3.c.2, 3.d.1, 3.d.2,4.a.2, 5.a.l. and 5.b.l.

b. DEFICIENCY: NONE

- C. AREAS REQUIRING CORRECTIVE ACTION: 1.c. 1.

Issue Number: 47-04-l.c.1-A-01 17

Condition: In the Operations Room, the Operations Officer, and at various times throughout the exercise, the Emergency Management Agency Director or the Assessment Center Coordinator briefed the Operations Group staff of actions being taken by the County. However, when Lake County Officials staff received notification that a release at the Perry Nuclear Power Plant (PhTP) began at 1302 hour0.0151 days 0.362 hours 0.00215 weeks 4.95411e-4 months s: exceeding Protective -4ction Guides, this information was not passed on to the staff in the Operations Group.

- Possible Cause: No mechanism is in place to remind those who brief the Operations Group that release data needs to be provided in a timely fashion.

Reference:

NUREG-0654, A. 1.d; 2.a,b Effect: Operations Group Staff could make inappropriate decisions based upon

- the lack of current release data from the Utility which could affect the publics health and safety.

Recommendation: Placement of a notification of a release in an obvious location in the Operations Room.

Schedule of Corrective Action: Lake County will ensure a sign is placed in the Operations Room that can be activated when there is a release in progress and that will have an audible alarm and be visible to the entire room.

d. NOT DEiMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

- f. PRIOR ARCAS - UNRESOLVED: NONE 2.1.3 Joint Public Information Center

a. MET: Criteria l.c.1, l.e.1, 5.a.l. and5.b.l.

b. DEFICIENCY: NONE

- c. AREA4SREQUIRING CORRECTIVE ACTION (ARCA): NONE

a. NOT DEMONSTRATED: NONE

e. PFUOR ARCAS - RESOLVED: NONE

- f. PRIOR ARCAS - UNRESOLVED: NONE

- 2.1.4 Traffic and Access Control

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

a. DEFICIENCY: NOKE C. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

- d. NOT DEMONSTFUTED: YONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.1.5 Lake County Field Monitoring Team I

- a. MET: Criteria 1 .d.1 , 3.b. 1. and 4.a.3

b. DEFICIENCY: NONE C. AREAS REQUIRING CORRECTIVE ACTION (ARCA): 4.a.3 Issue Number: 47-04-4.a.3-A-02 Condition: A small zip lock plastic bag containing the (AgZ) cartridge was placed on the surface designated for potentially contaminated articles. When the bag was picked up to be placed in the counter, no attempt was made to ensure that that the outside of the bag had not become contaminated.

Possible Cause: The team member was focusing on the fact that the cartridge was possibly internally contaminated, and therefore should be with the contaminated items and forgot about the contamination bai-rier that had just been established by putting the cartridge inside of the plastic bag. The team ineniber was also focusing 011 that gamma radiation was being counted and would penetrate the bag.

Reference:

NUREG-O654,1.8, 9. 11 Effect: Contamination of the detector and counter could have occuned. The team member used the same gloved hand, presuming that this hand was "clean",

to place the new air filter and AgZ cartridge into the air sample assembly. These items could have become contaminated. The contamination would have been recorded as positive readings on the next sample.

19

Corrective Action Demonstrated: Sample handling and contamination control was successfully re-demonstrated by Lake County Field Monitoring Team I members on October 7,2004, at 110 hours0.00127 days 0.0306 hours 1.818783e-4 weeks 4.1855e-5 months , at the Lake County Emergency Operations Center. The AgZ cartridge was removed from the sampling probe by the member with the dirty hands. The team member with the clean hands held the small plastic zip-lock bag open as the AgZ cartridge was placed into the bag. The bag was sealed and placed directly onto the counter.

Results of the field measurements were transmitted to the Field Monitoring Team Coordinator using the SO0 MHz radio system. Results were established by controller inject.

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.1.6 Lake County Field Monitoring Team I1

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

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. NOT DEMONSTRhTED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.1.7 Monitoring/Decontamination - Public South High School

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

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. IVOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE 20

f. PRIOR ARCAS - UNRESOLVED: NONE

- 2.1.8 Congregate Care CenterRegistration South High School

a. MET: Criterion 6.c.1

- b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

- f. PRIOR ARCAS - UNRESOLVED: NONE 2.1.9 School District Madison School

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

b. DEFICIENCY: NONE C. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

- d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.1.10 School District Fairport School

a. MET: Criteria l.e.1, 3.a.1, 3.b.l.and3.c.2.

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. NOT DEMONSTRATED: NONE 21

- e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UWRESOLVED: NONE 2.1.11 Back-up Route Alerting

a. MET: Criteria l.d.1, l.e.1, 3.a.1, 3.b.l.and 5.b.l.

- b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION: NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE!

f. PRIOR ARCAS - UNRESOLVED: NONE 2.1.12 Medical Services - Transportation

- Perry Nuclear Power Plant

- a. MET: Criteria l.d.1, l.e.1: 3.a.1, 3.b.l.and6.d.l.

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

- d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.1.13 Medical Services - Facilities Lake West Hospital

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

b. DEFICIENCY: NONE

- c. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. NOT DEMONSTRATED: NONE 22

- e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.2 ASHTABULA COUNTY 2.2.1 Initial Notification Point

- a. MET: Criteria 1.a. 1 and 1.d. 1.

b. DEFICIENCY: NONE

e. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. NOT DEMONSTRATED: NONE

- e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.2.2 Ashtabula County Emergency Operations Center

a. MET: Criteria l.a.1, l.c.1, l.d.1, l.e.1, 2.a.1, 2.b.2, 2.c.1, 3.a.1, 3.b.1, 3.c.1, 3.d.1, 3.d.2, 5.a.l.and 5.b.l.

b. DEFICIENCY: NONE

- C. AREAS REQUIRING CORRECTIVE ACTION (ARCA): 3.a. 1.

Issue Number: 47-02-3.a. 1.-A-03 Condition: The Radiological Officers (RO) briefing to the Public Information Officer (PIO), who was leaving the emergency operations center and traversing the emergency planning zone, did not address the following elements: frequency for reading the Direct Reading Dosimeters, maximum radiation exposure limits, and procedures to followed at the conclusion of the emergency or mission.

Possible Cause: The RO did not use available informational checklists when giving his briefing.

Effect: The PIO, traversing the emergency planning zone, was not provided with a briefing on how to manage his radiological exposure. Therefore he could have been exposed to radioactive materials without his knowledge of his exposure rates.

23

Corrective Action Demonstrated: At the end of the exercise, at 1430 hours0.0166 days 0.397 hours 0.00236 weeks 5.44115e-4 months , the Radiological Officer re-demonstrated his briefing to a Controller acting in the role of the PIO. The briefing included the information previously omitted, was accurate, and complete. Therefore, the issue was successfully resolved during the re-demonstration.

- d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.2.3 Joint Public Information Center

- a. MET: Criterion 5.b. 1,

b. DEFICIENCY: NONE C. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. NOT DE-MONSTRrlTED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. -

PRIOR ARCAS UNRESOLVED: NONE 2.2.4 Traffic and Access Control Points

- a. MET: Criteria l.d.1, l.e.1, 3.a.1, 3.a.b. and3.d.l.

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. NOT DEMONSTRATED: NONE

- e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.2.5 Back-up Route Alerting

a. MET: Criteria 3.a. 1. 3.b. 1. and 5.a.3.

24

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. NOT DEMONSTRATED: NONE

- e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - CNRESOLVED: NONE 2.2.6 Monitoring and Decontamination Center - Emergency

- Workers - Vehicles Saybrook Elementary School

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

- b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. NOT DEiMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

- f. PRIOR ARCAS - UNRESOLVED: NONE 2.2.7 Monitoring and Decontamination Center - Emergency Workers Saybrook Elementary School

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

b. DEFICIENCY: NONE

- c. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

- f. PRIOR ARCAS - UNRESOLVED: NONE 25

- 2.3 GEAUGA COUNTY 2.3.1 Initial Notification Point

a. MET: Criteria 1.a. 1. and 1 .d.1.

b. DEFICIENCY: NONE

- c. AREAS REQUIRING CORRECTIVE ACTIOY (ARCA): S O N E

d. EOT DENIOYSTRATED: NONE

e. PRIOR ARCA4s- RESOLVED: NOKE

f. PRIOR ARCAS - RESOLVED: NONE

- 2.3.2 Geauga County Emergency Operations Center

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

3.d.l. 3.d.2, 5.a.l. and 5.b.l.

b. DEFICIENCY: NONE C. AREAS REQUIRING CORRECTIVE ACTIOK (ARCA): NONE

d. NOT DEMORSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - RRSOLVED: NONE 2.3.3 Joint Public Information Center

a. MET: Criterion 5.b. 1.

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

a. KOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE 26

- f. PRIOR ARCAS - UNRESOLVED: NONE 2.3.4 Traffic and Access Control

a. MET: Criteria 1.e. 1 and 3.d. 1.

b. DEFICIENCY: NONE

- C. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE

- 2.3.5 141o ni to rin g/Decon ta m i n a ti on/Regis t rati on - P ublic Newbury High School

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

- b. DEFICIENCY: NONE

c. AREA4SREQUIRING CORRECTIVE ACTION (ARCA): 6.a.1 Issue No.: 47-02-6.a. 1-.4-03 Condition: The amount of contamination in niR/hr that was simulated to be present on one of the volunteer evacuees was not determined or recorded by monitoring personnel. Interviewing the monitoring personnel and their supervision at that time revealed that they did not know that this value was needed to comply with their procedure and the Geauga County Plan.

Possible Cause: The monitoring person found the simulated contaminated areas but he never looked at the meter, thereby not determining a m R h r value or a detection that would have identified a contaminated individual who would have had to be referred to a hospital.

Reference:

NUREG-0654, J. 10.h, K.5.b.

Effect: Monitors were not aware of mR/hr readings.

Corrective Action Demonstrated: The monitoring personnel were interviewed and knew that the contamination action level was 300 counts per minute above 27

- background with a CD V - 700RP or 0.1 mWhr above background with a CD V -

700. The second phase of initial monitoring (for levels on shoes) used the CD V-700W and performed this function adequately.

d. NOT DEMONSTRATED: NONE

- e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 2.3.6 Back-up Route Alerting l

a. MET: Criteria l.d.1, l.e.1, 3.a.1, 3.b.l. and5.a.3.

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

- f. PRIOR ARCAS - UNRESOLVED: NONE 2.3.7 Congregate Care Centermegistration Newbury High School

- a. MET: Criterion 6.c. 1

b. DEFICIENCY: NONE

c. AREAS REQUIRING CORRECTIVE ACTION (ARCA): NONE

d. NOT DEMONSTRATED: NONE

e. PRIOR ARCAS - RESOLVED: NONE

f. PRIOR ARCAS - UNRESOLVED: NONE 28

&4PPENDIX1 ACRONYM 5 -AND ABBRE VTATIQYS The follouhg is 3 list of the acronyms and abbreviations that were used in this report.

CFX Code of Federal Regulations CPLl Counts per Minute DPXD Direct Reading Dosimeter EL4L Emergency Action Level E.AS Emergency Alert System EBS Emergency Broadcast System ECL Emergency Classification Level EEL1 Exercise Evaluation Methodology EOC Emergency Operations Center EOF Emergency Operations Facility EP.4 U.S. Enviroixnental Protection Agent?.

EPZ Emergency Planning Zone ET.4 Estimated Time of rlrrisd ETE Evacuation Time Estimate EL; hIDS Emergency Worker Monitoring and Decontamination Station YE1 1-4 Federal Emergency Management Agency FTC Field Team Coordinator iLmin fcet per iniiiute fi min cubic feet per minute GE General Emergency GM Guidance Memorandum JPIC Joint Public Information Center KI Potassium Iodide inR milliroentgen inR h milliroentgen per hour NOW Notification of Unusual Event NRC U.S. Nuclear Regulatory Commission X\JUREG-0654 K C R E G - O ~ ~ ~ / F E ~ ~1,ARev.

- R E1,PCriteria

- for Preparation ami Evaltiation of Radiological Eiw-gencv Respoiise Plaris rind Preppilredmss in Sipport of AViicleiri-Power Plcmts, I iVovenibel. 1980 29

Kational Weather Service P-4D Protec:ive Action Decision P.AG Protective -4ction Guide PAR Protective Action Recoinmendation

- PI0 Public Information Officer Offsite Response Organizations Regional Assistance Committee Radio Amateur Civil Emergency Service Radiological Emer,oency Response Plan Roentgen(s) per hour Site Area Emergency State Emergency Operations Center TL Team Leader TLD Thermoluminescent Dosimeter 30

APPENDIX 2 EXERCISE EVALUATORS AND TEAM LEADERS The following is a list of the personnel who evaluated the Perry Nuclear Power Plant exercise on October 5: 2004. Evaluator Team Leaders are indicated by the letters "(TL)" after their names.

The organization m-hich each evaluator represents is indicated by the following abbreviations:

DHSiFEMA - Federal Emergency Management Agency ICF ICF Consulting Inc.

EPA - U. S. Environmental Protection Agency FHWA - Federal Highway Administration EVALUATION SITE EVALUATOR ORGANIZATION Exercise Director Gary Naskrent DHSIFEMA Site Specialist Terri Connors-Hartman DHS/FEMA STATE OF OHIO Roy Smith (TL) Evaluator DHSiFEMX Hollis Berry Evaluator ICF Earne st Boaze Evaluator ICF Terry Blaclman Evaluator ICF Deborah Blunt Evaluator ICF Richard Gnindstroin Evaluator IC F Harry Harrison Evaluator ICF Larry Jensen Evaluator EPA James McClanalian Evaluator ICF LAKE COUNTY Terri Connors- Hartman (TL) Evaluator DHSEEMA Rowena Xrgall Evaluator ICF Hollis Berry Evaluator ICF Walter Gawlick Evaluator ICF Jan Jackson Evaluator ICF AL Lookabough Evaluator ICF Paul Nied Evaluator ICF Patrick Taylor Eva1uator ICF Larry Visniesky Evaluator ICF ASHTABULA COUNTY Sandra Bailey (TL) Evaluator DHSiFEiMA Terry Blackman Evaluator ICF Paul Nied Evaluator ICF 31

Alej andro Feriiandez Evaluator ICF Walter Gawlick Evaluator ICF Larry Jensen Evaluator ICF Lynn Mariano Evaluator IC F Paul Reigheiser Evaluator ICF GEXUGA COLYTY Robert Rospenda (TL) Evaluator DH S/F E M A Jim Buckson Evaluator FHWA Henry Chistiansen Evaluator ICF James McClanahan Evaluator ICF

\Vendy Su-ygert Evaluator ICF 32

APPENDIX 3 T!iis mper,dix lists the exercise criterion that were scheduled for demonstration in the Perry Suclear Pewe: Plant exercise on October 5. 2004, extent-of-play agreement approveci by F E M I Regior, J-on Septembe: 30: 3004.

The exercise c132rio11, contained in F E X 4 "Radiological Emergency Preparedness Exercise 5T..aiuation hkrhodology." as published in the Federal Register Notice,Vol. 67, dami Xo. SO.

dated April 75. 2002. represents a functional translation of the planning standards and evaluation criteria of NUREG-0654FEbLI-FEP- 1 Rev. 1, "Criteria for the Preparation and Evaluation of

~

Radioiogical Emergency Response PIaiis and Preparedness in Support of Xuclesr Poxer Plants."

November 1950 Because Tht esercise criterion are intended for use at all nuclear power plant sites, and because of varixiiions among offsits plans and procedures. an extent-of-play agreement is prepared by the State and approved by FEMA to provide evaluators with guidance on expected actual demonsrration of the objectives.

A. Exercise Criterion Listed be!ow are the specific radiological emergency preparedness criteria scheduled for demonsrration during this exercise.

33

PERRY NUCLEAR POWER PLANT FULL PARTICIPATION EXERCISE EXTENT OF PLAY AGREEMENT State of Ohio OCTOBER 5,2004

- Rev 6/9/04 Criteria that can be re-demonstrated immediately for credit, at the decision of the evaluator, include the following:

- 3.a.l. 3.d. 1. 3.d.2, 6.a.l. 6.b.1, 6.c.l and 6.d.I. Criteria that may be re-demonstrated, as approved on a case-by-case basis by the Chairperson of the Regional Assistance Committee, include the following: 2.a.1. 2.b. 1 , 2.b.2, 5.a.l and 5.b.l.

EV.ALUATION AREA 1 - EMERGENCY OPERATIONS MANAGEMENT Criterion 1.a.l: OROs use effective procedures to alert, notify and mobilize emergency personnel and activate facilities in a timely manner.

Extent of Plav The State Emergency Operations Center (SEOC) and the Ohio Highway Patrol Dispatch Center \\-ill receive initial notification over the 24-hour phone line. Once the SEOC Assessmeiit Room is activated all phone communications will be received there. SEOC personnel will noti@ and mobilize State agencies to respond at the appropriate Emergency Classification Level (ECL) in accordance with procedures. The following State Agencies will participate in the exercise:

.4tnerican Red Cross Ohio Dept of Public Safety.'Highway Patrol Attorney General's Office Ohio Emergency Management Agencq Governor's Office Ohio Dept of Mental Health Ohio Dept of Agriculture Ohio Dept of Natural Resources Ohio Dept of Health Ohio Dept of Transportation Ohio National Guard Ohio Environmental Protection Agency Ohio Dept of Insurance Ohio Dept of Job and Family Services Public Utilities Commission of Ohio State personnel who staff field positions will be pre-positioned. These functions are:

Communications Van E.mergeiicy Operations Facility Field Monitoring Teams Field Sample Screening Point Joint Public Information Center County Liaison Criterion 1 .b.l: Facilities are sufficient to support the emergency response.

Extent of Plav The baseline exercise for demonstration of this criterion was conducted in April 2002.

The State of Ohio will demonstrate the availability of facilities to support the 35

Rev 6/9;@4 accomplishment of emergency operations (e.g., adequate space, furnishings: lighting, restrooms and ventilation).

Criterion l.c.1: Key personnel with leadership roles for the O R 0 provide direction and control to that part of the overall response effort for which they are responsible.

Extent of Plav Direction and control of state activities will be demonstrated at the SEOC. The Executive Director of Ohio EMA will be positioned in the SEOC Executive Room and \vi11 coordinate decisions on behalf of the Governor's office. The Operations Officer will conduct periodic briefing for the SEOC Operations Room staff. The Ohio Department of Health is responsible for the decision making process in the SEOC Assessment Room.

Criterion l.d.1: At least two communication systems are available and operate properly and conimunication links are established with appropriate locations. Communications capabilities are managed in support of emergency operations.

Extent of Plav The primary means of communications between the State EOC and the County EOC.

JPIC, and the EOF is by commercial and/or dedicated telephone. Backup coniinunications (radio and/or cellular phones) will be demonstrated.

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

Extent of Plav The state will demonstrate the use of equipment, maps and displays to support emergency operations. The maps traditionally used in the EOC will be available and used for exercise evaluation purposes. The state will demonstrate the use of dosimetry and potassium iodide supplies during the state field team demonstrations.

The baseline for the State EOC, including Assessment Room, was established in April 2002.

EVALCATIOS AREA2 -PROTECTIVE ACTIONDECISION MAKING Criterion 2.a.l: OROs use a decision-making process, considering relevant factors and appropriate coordination, to insure that an exposure control system, including the use of KI, is in 36

Rev. 6/9/04 place for emergency workers including provisions to authorize radiation exposure in excess of adniinistrative limits or protective action guides.

Extent of Plav The State EOC Assessment Room staff will consider PAGs and Administrative Limits to develop recommendations: including KI, based on their technical evaluation of the available data. Recommendations will be forwarded to the State Field Monitoring Teams and the .4shtabula. Geauga and Lake County EOCs. County EOCs will disseminate recommendations to their emergency workers.

Criterion 2.b.l: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data and licensee and O R 0 dose projections, as cvell as knowledge of on-site and off-site environmental conditions.

Extent of Play The State EOC Assessment Room \vi11 evaluate the licensee information and complete independent dose projections based on that information and simulated field-monitoring data. Assessment Room staff will evaluate the data and forward protective action recommendations to the EOC Executive Room. Approved recommendations \vi11 then be forwarded to the Ashtabula. Geauga and Lake County EOCs via a dedicated conference line established in the Assessment Room.

Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PADS) for the general public (including the recommendation for the use of KI, if O R 0 policy).

Extent of Plav The Governor or his designee will demonstrate the ability to make appropriate protective action recoinmendations based on technical information froin the EOC Assessment Room. Recommendations concerning the use of KI for the general public and emergency workers are the responsibility of the Ohio Department of Health. They are made in the SEOC Dose Assessment Room and will accompany the protective action recommendation.

Coordination will take place in the Executive Room with Ashtabula, Geauga and Lake Counties to ensure consideration of local needs. After the decisioii is made, counties will disseminate protective actions to the general public.

A t least two (2)Protective Action Decisions will be demonstrated.

37

Criterion 2.c.l: Protective action decisions are made. as appropriate, for special population groups Extent of Plav N,'A - This is a county function Criterion 2.d. 1 : Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the O R 0 planning criteria.

Extent of Plav The State demonstrated this criterion at the May 2001 DBNPS exercise. It will be demonstrated again at the June 2006 BVPS exercise.

Criterion 2.e.1 : Timely re-location, 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,"orprocedures.

Extent of Plav The State demonstrated this criterion at the May 2001 DBNPS exercise. It will be demonstrated again at the June 3006 BVPS exercise.

EVALUATION AREA 3 - PROTECTIVE ACTION IMPLEMENTATION Criterion 3.a.l: The OROs issue appropriate dosimetry and procedures and manage radiological exposure to emergency workers in accordance with the plan 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.

Extent of Plav Direct reading dosimeters and KI will be issued to State of Ohio workers who have assignments in the 10-mile EPZ. The Field Monitoring Team Leader will record the exposure of the Field Monitoring Teams, Communications Van and Sample Screening Point. All State field activities are pre-positioned.

If the scenario does not provide for the demonstration of turn back limits, turn back values Miill be covered by interview with the evaluator.

38

- Rev 6/9/04

- Criterion 3.b.l: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals (not the general public) is maintained.

Extent of Plav

- The State demonstrated this criterion at the May 2001 DBNPS exercise. It will be demonstrated again at the June 2096 BVPS exercise.

Criterion 3.c.l: Protective action decisions are implemented for special population groups within areas subject to protective actions.

Extent of Plav N / A - This is a county fiinction.

Criterion 3.c.2: OROs/school officials decide upon and implement protective actions for scho o 1s.

Extent of Plav N/'A - This is a county function.

Criterion 3.d.l: Appropriate traffic and access control is established. Accurate instructions are pro\rided to traffic and access control personnel.

Extent of Plav The State EOC Dose Assessment Room will procedurally demonstrate restricting air, water and rail traffic within the Emergency Planning Zone.

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

Extent of Plav N/A - This is a county function.

Criterion 3.e.l: The O R 0 demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective actions.

39

Rev 6i9iOJ Extent of Plav The State demonstrated this criterion at the May 2001 DBNPS exercise. It will be demonstrated again at the June 2006 BVPS exercise.

- 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.

Extent of Plav

- The State denionstrated this criterion at the May 2001 DBNPS exercise. It will be demonstrated again at the June 2006 BVPS exercise.

Criterion 3.f.l: Decisions regarding controlled re-entry of emergency workers and relocation and return of the public are coordinated with appropriate organizations and implemented.

Extent of Plav The State demonstrated this criterion at the May 3001 DBNPS exercise. It will be demonstrated again at the June 2006 BVPS exercise.

EVALUATIOS A R E A 4 - FIELDh'lEASC'REhlENT AND AN..\LYSIS Criterion 4.2.1: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates.

Extent of Play Two Field Monitoring Teams (FMTs) will participate in the exercise. The teams will be demonstrated out-of-sequence at the Lake County EOC I0:OO A-Lf on October 4. FMTs will be fiilly equipped to perform field measurements and will function in accordance with their SOPS. However, charcoal cartridges will be used in the air samplers instead of the more costly silver zeolite filters. Samples u:ill be taken to the Field Sample Screening point, but will not be transported to the lab in Columbus.

Criterion 4.a.2: Field teams are managed to obtain sufficient information to help characterize the reiease and to control radiation exposure.

40

Rev 6/9/01 Extent of Plav FMTs n i l 1 be demonstrated out-ofsequence cit 1O:OO AM on October 4th. They will receive information about predicted plume location and direction, travel speed. and exposure control procedures by controller messages to the FMT Leader. Controllers will provide FMT radiation readings to the State Dose Assessment Room during the plume phase demonstration.

Chain of Custody will be demonstrated by the use of forms that are filled out by FhlTs and passed on to the Sample Screening Point when samples are dropped off.

There will be no federal play in this exercise.

- Criterion l.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will niove 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.

Measurements will be made by Department of HealtWOhio E M 4 FMTs in accordance Lvitli their Standard Operating Procedures (SOPS).Two mobile monitoring teams will demonstrate ambient radiation monitoring, radioiodine and particulate sampling. FhlTs n-ill be equipped with appropriate dosimetry and KI. The FMT Leader will direct each team from the Columbiana County EOC, FMTs \vi11 perform radiation measurements and air samples. Readings will be reported to the FMT Leader and samples will be taken to the Sample Screening Point. In place of silver zeolite cartridges. charcoal cartridges will be used for the exercise. Evaltiators will meet the FMTs at the Lake County EOC at 1O:OO A M O H October 4th. Controllers will provide FMT radiation readings to the State Dose Assessment Room during the plume phase demonstration.

Criterion 4 b . l : The field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making.

- Extent of Plav The State demonstrated this criterion at the iMay 2001 DBNPS exercise. It will be demonstrated again at the June 2006 BVPS exercise.

- Criterion 4.c.l: The laboratory is capable of performing required radiological analyses to support protective action decisions.

41

Re\ 6/9/04 Extent of Plav The State demoiistrated this criterion at the May 3001 DBNPS exercise. It will be demonstrated again at the June 3006 BVPS exercise.

EVALLIATIOS 'AREA 5 -EMERGENCY NOTIFICATION AND PUBLIC 1NFORM.ATIOU Criterion 5.a.l: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized off-site emergency

- officials to notif? the public of an emergency situation. The initial instructional message to the public must include:

1. Identification of the state or local government organization and the official with the authority

- for providing the alert signal and instructional message

2. Identification of the commercial nuclear power plant and a statement that an emergency situation exists at the plant

- 3 . Reference to REP-specific emergency inforination (e.g.. brochures and information in telephone books) for use by the general public during an emergency

4. X closing statement asking the affected and potentially affected population to stay tuned for additional information.

Extent of Plav The State will consult with Ashtabula, Geauga and Lake Count!. EOCs to determine the best immediate protective action for the populace. Once a decision is reached that requires the activation of the alert and notification system, Lake County will simulate the initiation of the sirens. EAS messages will be prepared by Lake County EMA who will simulate providing them to the EAS Station. (See Lake County Extent of Play Agreement for fiirther details.)

Criterion 5.a.2: [RESERVED]

Criterion 5.a.3: Activities associated with FEiMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to noti@ the public of an emergency situation. Backup alert and notification of the public is completed within 45 minutes following the detection by the O R 0 of a failure of the primary alert and notification system.

Extent of Plav N/A - This is a county function.

42

- Rev. 61'91'0.1 Criterion 5.b.l: OROs provide accurate emergency information and instructions to the public and the nen.s media in a timely manner.

Extent of Plav The State P I 0 and a representative from the Ohio Department of Health will be present at the JPIC to address protective actions being implemented and the activities taking place at the State and county level. Public information representatives from Ohio EhlA will be present in the State EOC to communicate with the JPIC.

A Public Inquiry telephone will be established and demonstrated at the State EOC and driven by controller injects. Public Inquiry will address an average of 3 calls per hour once Site Area Emergency is declared for two (2) hours, Trends in rumors will be

- identified and responded to as needed.

EVALUATION AREA6 - SUPPORT OPERATION~FACILITIES Criterion 6.a.l: The reception centeriemergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of

- evacuees and/or emergency workers.

Extent of Plav N/'A - This is a county function.

Criterion 6.b.l: The facility/ORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency worker equipment including vehicles.

Extent of Plav

- WA - This is a county function.

Criterion 6.c.l: Managers of congregate care facilities demonstrate that the centers have resources

- to provide services and accommodations consistent with American Red Cross planning guidelines.

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.

Extent of Plav N,'A - This is a county function.

Rev 6/9/04

- Criterion 6.d.l: The facility/ORO has the appropriate space, adequate resources. and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals.

Extent of Plav YjA4- This is a county fimction.

44

Week of October 4,2004 45

Perry Nuclear Power Plant Lake County October 2004 Evaluated Exercise Extent-of-Play Agreement The exercise will take place on October 5, 2004.

Criteria that can be re-demonstrated immediately for credit, by a dscision of the evaluator, include the following: 3.a. 1, 3.d. 1, 2.d.3, 6.a. 1, 6.b. 1>6.c. 1 and 6.d. 1 . Criteria That may be re-demonstrated, as approved on a case-by-case basis by the Chairperson cf rhe Resional Assistarice Committee, include the follolving: 2.a.1, 2.b.1, 2.b.3, 5.a.l: and 5.1;. 1.

Criterion 1.3.1: OROs use effective procedures to alert, notify and mobilize emergency personnel and activate facilities in a timely manner.

Esterit of Plav

- Lake County EOC Staff will mobilize upon notification froin the Lake Count!

Sheriff 5 Central Communications Dispatch Center. Full field notification utilizing primar:; means of communication will be completed one time only from the EOC.

- nr the Sire -Area Emergency classificaIion. All other notifications will be simulated.

The primary means of notification is a dedicated line: therefore, a verification call

\\-ill cot be performed. If a back-up means of communication is necessary, then a

- verification call will be made.

Field asencq demonstrations will be conducted out-of sequence and participants will be pre-positioned.

Field activity participants:

Concord Fire District - Back-up Route Alerting Willoughby Fire Department - Public Monitoring 62 Decontamination Fairport School District - Risk School Madison School District - Risk School American Red Cross - Care Center Lake County General Health District Field Monitoring Teams Lake West Hospital - Medical Sewices (PIS-1)

Lake County Sheriffs Department - TrafficiAccess Control - at EOC Ohio State Highway Patrol - TraffciAccess Control - at EOC Perry Tmp. Fire Department - Medical Services Transportation South High School - Care Center Lake County 45 Revision 4

Perry Nuclear Power Plant Lake County October 2004 Evaluated Exercise Extent-of-P lay Agreement Criterion l.b.1: Facilities are sufficient to support the emergency response.

Extent of Plav Participating facilities other than the EOC and SherifFs Disparch Office will be evaluated during this exercise in order to establish a baseline. The EOC 2nd Sheriffs Dispatch Office were evaluated during the 2002 Exercise.

Criterion l.c.1: Key personnel with leadership roles for the OR0 provide direction and control to that part ofthe overall response effort for which they are responsible.

Extent of Plav Direction and control of emergency operations will be demonstratsd in accordance mi:h the exercise scenario: the Lake County Radiological Emergency Response P!an, Xgeccy SOP and as appropriate for out-of-sequence field demonstrations.

Criterion I.d.3: At least tlvo communication systems are available and operate properly and communication links are established with appropriate locations. Cominunications capabilities are managed in suppoi-t of emergency operations.

Extent of Plav Primary (dedicated phone linzs aiid coinmercial telephone) and secondary iradio/pagers/cell phones) means of communications mill be demonstrated at the EOC and as appropriate for out-of-sequence field demonstrations. Controllers wiil drive field play.

Criterion 1.e.I: Equipment, maps, displays, dosimetry, potassium iodide (KI) and other supplies are sufficient to support emergency operations.

Extent of Plav Baselines were established during the 2002 Exercise for the EOC maps, displays and equipment.

Lake County 46 Revision 4

Perry Nuclear Power Plant Lake County October 2004 Evaluated Exercise Extent-of-Play Agreement Durinz 3003,KI was pre-distributed to the general public at designated !ocations by the Ohio Department of Health JODH) through the local health department.

Additional KI is stcckpiled at the EOC and would be transported to the care centers by the local heaith department and distributed by the local health department. as requested.

Dosirnet? and KI have been pre-distributed to Offsite Response Organizations (OROs);the monitoring kits and dosimetry are exchanged annually by the State of Ohio.Supporting documentation is included in the Annual Letter of Certification.

EVALLLATION AREA 2 - PROTECTIVE ACTION DECISION M i K I Y G Criterion 2.a.l: OROs use a decision-making process, considering relevant factors and appropriate coordination, to insure that an exposure control system, including the use of KI. is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.

Extent of Plav Lake County relies on the Ohio Department of Health for the recommendation to take KI and for the authorization to exceed Protective Actior, Guides. For field agency demonstrations, this will be demonstrated by interview n.ith exercise participants or, if necessary, by controller inject.

Criterion 2.b.l: Appropriate protective action recorninendations are based on available infoi-mation on plant conditions, field monitoring data and licensee and O R 0 dose projections: as well as knowledge of on-site and off-site environmental conditions.

N/A - Lake County does not demonstrate this criterion; it relies on the State of 0hio .

Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PADS) for the general public (including the recommendation for the use of KI, if OR0 policy).

Extent of Plav The Lake County EOC Executive Group will demonstrate this criterion in coordination with Geauga and Ashtabula counties Executive Groups and the State of Ohio.

The Director: or designee, of the Ohio Department of Health (ODH)makes the decision for the general public and emergency workers to take KI.

Lake County 47 Revision 4

Perry Nuclear Power Plant Lake County October 2004 Evaluated Exercise Extent-of-Play Agreement The ODH:through the local health departments makes KI available to the general public, by pre-distribution and by supplies available for distribution at the time of the emergency at care centers.

Criterion 2.c.l: Protective action decisions are made, as zppropriatq for special population groups.

Extent of Plav The Lake County EOC Executive Group will demonstrate this criterion in coordination with Geauga and Ashtabula counties Executive Groups. Schools follow the protective action decisions for the general public; they are nor considered a special population group.

Criterion 2.d. 1: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the O R 0 plaiming criteria.

Extent of Plav N.4 - Lake County relies on the State of Ohio.

Criterion 2.e. 1: Timely re-Iocation, re-entry and retuin decisions are made and coordinated as appropriate, based on assessmeiits of the radiological conditions and criteria in the OROs plan and/or procedures.

Extent of Plav NIA - This criterion was successfillly demonstrated during the 2002 Exercise.

EVXLUATIOY AARE.43 - PROTECTIVE ACTION INIPLEMEYTATIOY Criterion 3.a.l: The OROs issue appropriate dosimetry and procedures and manage radiological exposure to emergency workers in accordance with the plan 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.

Extent of Plav The Lake County EOC Radiological Officer will demonstrate radiation exposure control capabilities by interview. Dosimetry and exposure control procedures will be demonstrated by field agencies during out-of-sequence exercise activities by interview with participants or, if necessary, by controller inject.

Lake County 45 Revision 4

Perry Nuclear Power Plant Lake County October 2004 Evaluated Exercise Extent-of-Play Agreement Criterion 3.b.l: KI and appropriate instructions are available should a decision to recommend use of KI be made. -4ppropriate record keeping of the administration of KI for emergency worksrs and institutionalized individuals (not the general public) is maintained.

Extent of Plav The Ohio Department of Health (ODH) will make recommendations regarding the use of KI. Lake County's preparedness measures for RI include pre-distribution to emergency responsz agencies and to the general public, if they chose to pick it up at designated centers. At the time of the emergency: the agencies distribute the dosimetry and KI to the emergency workers. Demonstration of this criterion may be facilitared by discussion with the Lake County General Health District Coordinator at the EOC. For field agency demonstrations? KI procedures will be dznionstrated by interview with exercise participants or, if necessary, b y exercise controller inject.

Criterion 3.c.l: Protective action decisions are implemented for special population g o u p s within areas subject to protective actions.

Extent of Plav Notification to individuals with special needs within the Lake County portion of the EPZ \vi11 be simulated. A list of special needs residents within the Lake County portion of the EPZ is maintained by the Lake County Department of Job and Family Services and the Lake County EMA.

The Department of Job and Family Services Coordinator at the EOC will coordinate special needs notification activities and, upon request, will present the confidential list for review by the FEMA evaluator. At least 4 transportation providers, which in Lake County include school districts, will be contacted to ensure availability of buses and drivers.

Criterion 3.12.2: OROs/school officials decide upon and implement protective actions for schools.

Extent of Plav The school districts will demonstrate this criterion out-of-sequence, by interview with the superintendent, high school principal, transportation supervisor and a bus operator. School officials follow the protective action decisions made by the elected officials for the general public. The use of dosimetry and KI will be discussed with transportation personnel only. All Lake County 49 Revision 4

Perry Nuclear Power Plant Lake County October 2004 Evaluated Exercise Extent-of-Play Agreement schools in the EPZ will be notified as identified in Criterion 1.a.l: Extent of Play. There will be no mol-ement of buses or students.

Field Aaencv

Participants:

Fairport School District - Superintendent and Principal Only Madison School District Criterion 3.d.l: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel.

Extent of Play A representative of the Lake County Sheriffs Department (Law Enforcemect Coordinator) and a representative of the Ohio State Highway Patrol (OSHP)\vi11 demonstrate Traffic and .4ccess Control by interview at tlie Lake County EOC during the exzrciss. Notification of rail, water and air traffic is a State function.

Criterion 3.d.2: Impediments to evacuation are identified and resclved.

Extent of Plav Lake County EOC will demonstrare the capability to identie and take the appropriate actions in dealing u-ith impediments to evacuation. Actual resources will not be utilized. If an impediment cannot be removed in a timely manner. the decision to reroute traffic will be discussed and implemented by the appropriate EOC Staff.

Criterion 3.e.l: The O R 0 demonstrates tlie availability and appropriate use of adequate information regarding water, food supplies, milk and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective

actions, Extent of Plav N/A - Lake County relies on the State of Ohio.

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.

Extent of Plav NiA - Lake County relies on the Stare of Ohio.

Lake County 50 Revision 4

Perry Nuclear Power Plant Lake County October 2004 Evaluated Exercise Extent-of-P lay Agree ment Criterion 3.f.l: Decisions regarding controlled re-entr:' of emergency workers and relocation and return of the public are coordinated wilh approprists organizations and implemented.

Extent of Plav Wj This criterion was successfully demonstrated during the 2002 Exercise.

EV.4LUATION AREA 4 - FIELD MEASUREMENT .AND A8ALYSIS 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.

Extent of Plav Lake County General Health District will demonstrate the use of two Field Monitoring Teams (FhlTs), in sequence.

Prior to the exercise and at the Lake County EOC, a FEIMA evaluator will review contents of the FhfT vehicles; an equipment inventory list will be provided to the evaluator to verify availability of supplies and equipment. .4t the conclusion of the equipment review, all seals will be replaced in order to indicate that all required supplies and equipment are contained within.

Criterion 4.n.2: Field teains are managed to obtain sufficient information to help characterize the release and to control radiation exposure.

Extent of Plav Lake County Health District will demonstrate the use of two Field Monitoring

- Teams (FMTs), in sequence.

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.

- Extent of Plav For the exercise, expired silver zeolite cartridges will be used; new cartridges will be available for the FEMA evaluator's observation.

- Lake County 51 Revision 4

Perry Nuclear Power Plant Lake County October 2004 Evaluated Exercise Extent-of-Play Agreemeni Criterion 4.b.l: The field teams demonstrare the capability to make appropriate measurements and to collect appropriate samples ( e g , food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making.

Extent of Plav N/,4 - Lake County relies on the State of Ohio Criterion 4.c.l: The laboratory is capable of performing required radiological analyses to support protective action decisions.

Extent of Plav N/A - Lake County relies on the State of Ohio EVALLTATIOK AREA5 - EMERGENCY XOTIFICATION AYD PUBLIC INFORMATION Criterion 5.a.l: Activities associated with primary alerting and notification of the public are completzd in a timely manner following the initial decision by authorized off-site emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include:

I. Identificaticn of the state or local government organization and the official with the aurhority for providing the alert signal and instructional message

2. Identification of the commercial nuclear power plant and a statement that an emerzency situation exists at the plant

3. Reference to REP-specific emergency information (e.g.- brochures and infomiation in telephone books) for use by the general public during an emergency

4. -4closing statement asking the affected and potentially affected population to stay tuned for additional information.

Extent of Plav Upon a protective action decision (PAD) by the combined Executive Groups of Ashtabula. Geauga and Lake counties, the Lake County EOC Staff will prepare the appropriate Emergency Alert System @AS) message and simulate sounding the sirens and sending the message over the AS system. A quiet siren test will be demonstrated by the Lake County EOC in lieu of an actual siren sounding.

Simulation of sending the EAS message(s) will be conducted as follows:

- The procedure for the E.4S encoder will be followed to deliver the message to WTA4-M,the Local Primary Station, with the exception that the telephone number to

- Lake County 52 Revision 4

Perry Nuclear Power Plant Lake County October 2004 Evaluated Exercise Extent-of-Play Agreement the station will not be dialed. By not connecting to WTAkl, there is no possibi1it)- of accidentally broadcasting the message over one or more of the participating EAS stations. The send button on the Lake County EAS encoder will be dzpressed, and this action will activate the outgoing alen: light and playback of the recorded message. Also, a data sheet will automatically be printed by the encoder and the time recorded on the data sheet. Ashtabula and Geauga counties have EXS equipment (encoder) and could perform t h s function: if required.

Lake County will fax a copy of the AS inessage(s) to the Joint Public Information Center (JPIC) where Public Information Officers (PIOs) may distribute hard copies to the news media representatives and may, if time and circumstances permit, mak?

an announcement regarding the msssage. Otherwise, the AS message can be announced at the next scheduled press briefing or in response to news media inquiries about the PAD message. In delivering information about the EAS message just released, the counties PIOs may indicate that a corresponding Special News Bulletin (SNB) will be issued soon. Lake County will also fax a copy of the EAS message to Ashtabula and Geauga counties EOCs.

Criterion 5.3.3: (RESERVED)

Criterion 5.a.3: Activities associated with FEhL4 approved exception areas (\vliere applicablej are completed within 45 minutes following the initial decision by aurhorized offsite emergency officials to iiotifv the public of an emergency situation. Backup alert and notification of the public is completed within 45 minutes following the detection by the O R 0 of a failure of the primary alert and notification system.

E.xtent of Plav The Concord Fire Department will demonstrate back-up route alerting as an out-of-sequence, propositioned field activity. One predetermined siren located in Concord Township will not sound (simulated) and back-up route alerting will be conducted in the siren coverage area. Use of the mobile PL4system will be simulated. The demonstration will be initiated by the exercise controller.

Criterion 5.b.l: OROs provide accurate emergency infomation and instructions to the public and the news media in a timely manner, Extent of Plav Based upon the combined PAD(s) of the Executive Groups of Ashtabula, Geauga and Lake counties, the Lake County EOC Staff will prepare and issue the appropriate AS message(s) and the corresponding Special News Bulletins(sj (ShB). SNBs are the same message as their corresponding EAS message except ShBs provide greater detail. Lake County will FAX the S?B(s) to the Joint Public Lake County 53 Revision 4

Perry Nuclear Power Plant Lake County October 2004 Evaluated Exercise Extent-of-Play Agreement Information Center ( P I C ) where one of the counties PIOs will represent the three counties by directly proceeding to the briefing room and reading the contents of the message to the assembly of news media representatives and answering any questions pertaining to the message. This briefing should begin in a timely manner after transmission of the EAS message from the Lake County EOC to the Local Primary EAS Station. Hard copies of the ShB(s) will be distributed to the news media representatives.

Ashtabula, Lake and Geauga counties will also coordinate release of other informational and instructional message as necessary. Such messages may include Special Information Bulletins (SIBS), which are a third category of prepared messages contained in the counties SOP for EAS Messages, Special News Bulletins, and Special Iilfonnation Bulletins pertaining to the P m y Nuclear Power Plant. These SIBS are considered routine, meaning that they are to be delivered by one of the counties PIOs at the next scheduled press briefing.

Criterion 6.a.l: The reception centeriemergency worker facility has agpropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of ev-acuees and/or emergency workers.

Field activity participants:

Willoughby Fire Department South High School American Red Cross Extent of Play Willoughby Fire Department will demonstrate the evacuee portion of this criterion out-of-sequence at South High School, 5000 Shankland Road, Willoughby. One locker room will be fiilly set up and demonstrated. Decontamination will be simulated: demonstrated by interview. A walk-through of die remaining locker room will be conducted upon request. An American Red Cross representative will describe registration procedures. Set-up of care center equipment and;or supplies will be at the discretion of the American Red Cross Disaster Action Team Leader.

Six (6) monitoring demonstrations will be conducted using a portal monitor. One individual with simulated contamination will be walked through the monitoringidecontamination process, which includes whole body monitoring using a CDV-700RP survey meter; contamination levels will be provided by a controller.

Decontamination will be simulated.

Lake County 54 Revision 3

Perry Nuclear Power Plant Lake County October 2904 Evaluated Exercise Extent-of-Play Agreement Criterion 6.b.l: The facilityiOR0 has adequate procedures and resources far the accomplishment of monitoring and decontamination of emergency worker equipment including vehicles.

Extent of P!av W Lake County will not demonstrate this criterion.

Criterion 6.c.l: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross plam~ngguidelines. Mmagers demonstrate the procedures to assure that evacuees have been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities.

Extent of Plav The American Red Cross will demonstrate the congregate care center portion of this criterion out-of-sequence at South High School, 5000 Shankland Road, Willoughby. American Red Cross personnel will provide a walk-through of the facility and describe their capabilities. Set-up of care center equipment or supplies will be at the discretion of the American Red Cross.

Criterion 6.d.l. : The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals.

Extent of Plav The Perry Township Fire Department will demonstrate this criterion in sequence with the on-site scenario. A simulated contaminatedlinjured victim from the Perry Power Plant will be transported to Lake West Hospital. No emergency lights and/or sirens will be used.

Dosimetry (CDV- 138s) and survey instruments owned by the Perry Fire Department may be used in addition to that issued by the State of Ohio and the Utility.

Lake County 55 Revision 4

For the Perry Nuclear Power Plant.

Evaluated Exercise October 4,2004 56

Perry Yuclear Power Plant Ashtabula County October 2004 Evaluated Exercise Extent of Play A,Ureement The exercise will take place on October 5, 2004.

Criieria that can be re-demonstrated immediately for credit, by a decision of the evaluator, including the following: 3.a. 1, 3.d. 1, 3.d.2, 6.a.1, 6.b. 1, 6.c.1: and 6.d. 1.

Criteria that may be re-demonstrated, as approved on a case-by-case basis by the Chairperson of the Regional Assistance Committee, including the following: 3.a. 1 2.b. 1 ,

~

2.b.2: 5.a.l and 5,b.l Criterion 1.2.1: OROs use effective procedures to alert, notify and mobilize emergency personnel and activate facilities in a timely manner.

Extent of Plav Ashtabula County EOC Staff will mobilize upon notification from the Ashtabula County Sheriffs Dispatch Center. Full field notification utilizing primary means of cammunication will be completed one time only from the EOC, at the Site .Area Emergency classification. All other notifications will be simulatsd. The primary means of notification is a dedicated line; therefore, a verification call will not be performed. If a backup means of communication is required, then verification n-ill be performed.

Field agency denionstrations will be conducted out-of sequence and participants will be pre-positioned.

Field activity participants:

Harpersfield Township Fire Department - Back-up Route Alerting Saybrook Fire Department - Emergency Worker MonitoringDecon Saybrook Elementary School - Emergency Worker Monitoring/Decon Station Ashtabula County Sheriffs Department - Traffic/Access Control - at EOC Criterion 1.b.l: Facilities are sufficient to support the emergency response.

E.xtent of Plav Participating facilities other than the EOC and SheriffSs Dispatch Office will be evaluated during this exercise in order to establish a baseline. T'ne EOC and Sheriffs Dispatch Office were evaluated during the 2002 Exercise.

Ashtabula County 57 Revision 4

Perry Nuclear Power Plant Ashtabula County October 2004 Evaluated Exercise Extent of Play Agreement Criterion 1 . ~ 1Key: personnel with leadership roles for the OR0 provide direction and control to that part of the overall response effort for w h c h they are responsible.

Extent of Plav Direction and control of emergency operations will be demonstrated in accordant; with the exercise scenario? the Ashtabula County Radiological Emergency Response Plan, Agency SOP and as appropriate for out-of-sequence field demonstrations.

Criterion 1.d.l: At least two communication systems are available and operate properly and communication links are established with appropriate locations. Communications capabilities are managed in suppoi-t of emergency operations.

Extent of Plav Primary (dedicated phone lines and commercial telephone) and secondary (radioipagerscell phones) means of communications will be demonstratzd at the EOC and as appropriate for out-of-sequence field demonstrations. Controllers will drive field play.

Criterion Le. 1 : Equipment, maps, displays, dosimetry, potassium iodide (KI) and other supplies are sufficient to support emergency operations.

Extent of Plav Baselines were established during the 2002 Exercise for the EOC maps, displays and equipment.

During 2003, KI was pre-distributed to the general public at designated locations by the Ohio Department of Health (ODH) through the local health department.

Additional KI is stockpiled at the EOC and would be transported to the care centers by the local health department and distributed by the local health department, as requested.

Dosimetry and KI have been pre-distributed to Offsite Response Organizations (OROsj; the monitoring kits and dosimetry are exchanged annually by the State of Ohio. Supporting documentation is included in the Annual Letter of Certification.

Ashtabula County 58 Revision 4

Perry Yudear Power Plant Ashtabula County October 3004 Evaluated Exercise Extent of Play A,*reanent Evaluation Area 2 - Protective Action Decision Makiiw Criterion 2.a.l: OROs use a decision-making process, considering relevant factors and appropriats coordination, to insure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.

Extent of Plav Ashtabula County relies on the Ohio Department of Health for the recommendation to take KI and for the authorization to exceed Protective Action Guides. For 5eld agency demonstrations, this \vi11 be demonstrated by inten:iew kb-ith exercise participants or, if necessary: by controller inject.

Criterion 2.b.l: Appropriate protective action recommendations are based on available infoilnation on plant conditions, field monitoring data and licensee and OR0 dose projections, as well as laowledge of on-site and off-siIe environmental conditions.

Extent of Plav NIX - Ashtabula County does not demonstrate this criterion. It relies on the Stats of Ohio for field monitoring.

Aslitahla County 59 Revision 4

Perry Nuclear Power Plant Ashtabula County October 2004 Evaluated Exercise Extent of Play Agreement Criterion 2.b.3: X decision-making process involvins consideration of appropriate factors and necessary coordination is used to make protective aciion decisions (P-ADsj h r the general public (including the recommendation for the use of KI, if OR0 policyj.

Extent of P!av The Ashtabula County EOC Execuive Group will demonstrate this criterion in coordination with Lake and Geauga counties' Executive Groups and the State of Ohio. The Director, or designee, of the Ohio Department of Health inakes the decision for the general public and emergency workers to take KI.

The ODH through the local health departments makes KI ayailabls to the general public, by pre-distribution and by supplies available for distribution at the time of the emergency at care centers, Criterion 2.c.l: Protective action decisions are made, as appropriate: for special population groups, Extent of Plav The Ashtabula County EOC Executive Group will demonstrate this criterion in coordination with Lake and Geauga counties' Executive Groups. Schools follow the protective action decisions for the general public; they are not considered a special population group.

Criterion 2.d.l: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the O R 0 planning criteria.

Extent of Plav N/A - Ashtabula County relies on the State of Ohio.

Criterion 2.e.l: Timely re-location, 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.

Extent of Plav N/A - 'Illis criterion was successfully demonstrated during the 2002 Exercise.

Ash t abula C o unty 60 Revision 4

Perry Nuclear Power Plant Ashtabula County Ociober 2004 Evaluated E,xercise Extent of Play A,Ureement Evaluation ;ire2 3 - Protective :ktion Implementation Criterion 3.a. 1: The OROs issue appropriate dosimetry and procedures and manage radiological exposure to emergency workers in accordance with the plan and procedures.

Emergency workers periodically and a1 the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart.

E,xtent of Plav The Ashtabula County EOC Radiological Officer will demonstrate radiation exposure control capabilities by interview. Dosimetry and exposure control procedures will be demonstrated by field agencies during out-of-sequence exercise activities by interview with participants or, if necessary, by controller inject.

Criterion 3.b.l: KI and appropriate instructions are available should a decision to reconimend use of KI be made. Appropriate record keeping of the adiniiiistration of KI for e m q e n c y workzrs and institutionalized individuals (not the general public) is maintained.

Extent of Plav The Ohio Department of Health (ODH)will make recommendations regarding the use of KI. Ashtabula Countys preparedness measures for KI include pre-distribution to emergency response agencies and the general public, if they chose to pick it up at designated centers. At the time of the emergency: the agencies distribute the dosimetry and KI to the emergency workers.

If the ODH recomrneiidation for use of KI excludes the portion of the EPZ that is in Ashtabula County, demonstration of this criterion will be facilitated by discussion with the Ashtabula County Radiological Officer at the EOC. For field agency demonstrations, KI procedures will be demonstrated by interview with exercise participants or, if necessary, by exercise controller inject.

Criterion 3.c.l: Protective action decisions are implemented for special population croups within areas subject to protective actions.

I Extent of Plav Notification to individuals with special needs within the Ashtabula County portion Ashtabula County 61 Revision 4

Perry Nuclear Power Plant Ashtabula County October 2004 Evaluated Exercise Estent of Play Agreement of the EPZ will be simulated. The Ashtabula Counq EMA maintains a list of special needs residents withn the Ashtabula County portion of the EPZ. The EOC Job and Family Services Rspresentative will coordinate special needs notification activities and, upon request. will present the confidential list for re7;isw by the FEicfX evaluator. At least 3 transportation providers will be notified to determine the number of buses and drivers availabie for evacuation.

Criterion 3.c.2: OROs/school officials decide upon and implement protective actions for schools.

Estent of Plat N,A - Ashtabula County will not demonstrate this Criterion. It was demonstrated in 2002 by the Geneva School District, the only -4shtabula County EPZ district.

Criterion 3.d.l: Appropriate traf5c and access control is established. Accurate instructions are providcd to traffic and access control personnel.

Extent of Plav A representative of the Sheriffs Department (Law Enforcement Coordinator) will demonstrate Traffic and Access Control by interview at the .4slitabula EOC during the exercise. Notification of rail, water and air traffic is a State fiinction.

Criierion 3.d.2: Impediments lo evacuation are identified and resolved.

Extent of Plav Ashtabula County EOC will demonstrate the capability to identify and take the appropriate actions in dealing with impediments to evacuation. Actual resources will not be utilized. If an impediment cannot be removed in a timely manner: the decision process to re-route traffic will be discussed with the Transportation Officer.

Criterion 3.e.l: The OR0 demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk and agricultural production withn the ingestion exposure pathway emergency planning zone for implementation of protective actions.

Ashtabula County 62 Revision 4

Perry Nuclear Power Plant Ashtabula County October 2004 Evaluated Exercise Extent of Play A,*reemen t Extent of Plav N/A - Ashtabula County relies on the State of Ohio.

Criterion 3.e.2: Appropriate measures, strategies and pre-printed instructionai material are developed for implementing protective action decisions for contaminated water, food products: milk and agricultural production.

Extent of Plav Ni.4 - -4shtabula County relies on the State of Ohio.

Criterion 3.f.l: Decisions regarding controlled re-entry of emerzency workers and relocation and rehim of the public are coordinated with appropriate organizations a i d implemented.

Extent of PIav X/A - This criterion was successfully demonstrated during the 2002 Exercise.

Criterion 4.a.l: The field teams are equipped to perform field measu,remeiits of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates.

Extent of Plav

- N/X - Ashtabula County does not demonstrate this criterion.

Criterion 4.a.2: Field teams are managed to obtain sufficient information to help

- characterize the release and to control radiation exposure.

Extent of Plav N/,4 - Ashtabula County does not demonstrate this criterion.

- Criterion 4.3.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and paniculate samples are collected. Teams will move

- As ht a b ul a C ounty 63 Revision 4

Perry Kuclear Power Plant Ashtabula County October 2004 Evaluated Exercise Extent of Play A, ee m ent to an appropriate low background location to determine whether any significm (as specified in The plan and/or procedures) amount of radioactivity has been collected on the sampling media.

Extent of Plav W -4shtabula County does not demonstrate this criterion.

Criterion 4.b.l: The field teams demonstrate the capability to inake appropriats measurements and to collect appropriate samples (e.g., food crops: milk, R'ater,

\.egetarion, and soil,) to support adequate assessments and protective action decision-making.

Extent of Plav

- Ashtabula County does not demonstrate this criterion.

Criterion 4.c.l: Tne laboratory is capable of performing required radiological analyses to support protective action decisions.

Extent of Plav X/A - Ashtabula County does not demonstrate this criterion.

EV.ALU.I\TION AREA 5 -EMERGENCY NOTIFICATION A N D PUBLIC IYFOR1I.ATION Criterion 5.a.l: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized off-site emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include:

1. Identification of the state or local government organization and the official with the authority for providing the alert signal and instructional message

2. Identification of the commercial nuclear power plant and a statement that an emergency situation exists at the plant

3. Reference to REP-specific emergency information (e.g., brochures and information in telephone books) for use by the general public during an emergency

4. A closing statement asking the affected and potentially affected population to stay tuned for additional information.

Ashtabula County 64 Revision 4

Perry Nuclear Power Plant Ashtabula County October 2004 Evaluated Exercise Extent of Play Agreement Extent of Plav Upon a protective action decision (PAD) by the combined Executive Groups of

.qshtahula, Lake and Geauga counties, the Lake County EOC Staff will prepare the appropriate Emergency Alert System (EAS) rnessaze and simulate sounding the sirens and sendins the message over the E4S system. A quiet siren test will be demonstrated by the Lake County EOC in lieu of an actual siren sounding. Lake County will send a fax of the AS message to -4shtabula and Geauga counties.

Simulation of sending the E.4S message(s) will be conducted as follows:

The procedure for the EAS encoder will be followed to deliver the message to PVTAM, the Local Primary Station, with the exception that the telephone number to the station will not be dialed. By not connecting to WTAM, there is no possibilirqr of accidentally broadcasting the message over one or more of the participating AS stati oils .

The "send" button on the Lake County EAS encoder will be depressed, and tllis action will activate the ourgoing alert light and playback of the recorded message.

,41so, a data sheet will automatically be printed by the encoder and the time recorded on the data sheet. Ashtabula and Geauga counties have equipment (encoder) and could provide this function if required.

Lake County will fax a copy of the EAS message(s) to the Joint Public Information Center ( P I C ) where Public Infomiation Officers (PIOs) may distribute hard copies to the news media representatives and may, if time and circumstances permit, make an announcement regarding the message. Otherwise, the EAS message can be announced at the nexi scheduled press briefing or in response to news media inquiries about the PAD message. In delivering information about the EAS message just released, the counties' PIOs may indicate that a corresponding Special News Bulletin (SNB) will be issued soon. Lake County will also fax a copy of the EAS message to Ashtabula and Geauga counties' EOC's.

Criterion S.a.2: (RESERVED)

- Ashtabula County 65 Revision 3

Perry Nuclear Power Plant Ashtabula County October 2004 Evaluated Exercise Exrent of Play Agreement Criterion 3.2.3: -4ctivities associated with FEMA approved exception areas (where applicable) are completed within 15 minutes following the initial decision by authorized offsite emergency officials to norifj the public of an emergency situation. Backup a l c t and notification of the public is completed within 45 minutes following the detection by the OR0 of a failure of the primzry alsrt and r,otificarion system.

Extent of Plav Harpsrsfield Township Fire Department will demonstrate back-up route alerting as an out-of-sequence, pre-positioned field activity. One pre-determined siren located in Harpersfield To-mship will be out-of-service (simulated) and back-up route alerting will be conducted in the siren coverage area. Use of the mobile Public Address (PA) system will be simulated. The demonstration will be initiated by the exercise controller.

Criterion 5.b.l: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner, Extent of Plav Based upon the combined PrlD(s) of the Executive Groups of Ashtabula, Geauga and Lake Counties, the Lake County EOC Staff will prepare and issue the appropriate EAS rnessage(s) and the corresponding Special News Bulletins(s)

(SNB). SNB's are the same message as their corresponding EAS message except S m ' s provide greater detail. Lake County will FAX the SNB(s) to the Joint Public Information Center (JPIC) where one of the counties' PIOs will represent the three counties by directly proceeding to the briefing room and reading the contents of the message to the assembly of news media representatives and answering any questions pertaining to the message. This briefing should begin in a timely manner after transmission of the EAS message from the Lake County EOC to the Local Primary E44S Station. Hard copies of the SNB(s) will be distributed to the news media representatives.

Ashtabula, Geauga and Lake Counties will also coordinate release of other informational and instructional message as necessary. Such messages may include Special Information Bulletins (SBs), which are a third category of prepared messages contained in the counties' "SOP for AS Messages, Special News Bulletins, and Special Information Bulletins pertaining to the Perry Wuclear PoLver Ashtabula County 66 Revision 4

Perry Nuclear Power Plant Ashtabula County October 2004 Evaluated Xsercise Extent of Play A,Oreemenf Plant." These SIBS are considered routine, meaning that they are to be delivered by one of the counties' PIOs at the next scheduled press briefing.

EV.ALL.4TION AREA 6 - SUPPORT OPERATION/FACILITIES Criterion 6.a.l: The receprion center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers.

Field Activity

Participants:

Saybrook Fire Depanment Saybrook Elementary School Extent of Plav Saybrook Fire Department will demonstrate the emergency worker facility out-af-sequence at Sa>.brook Elementary School, Saybrook Township. Two monitorins demonstrations will be conducled using a portal monitor. One individual \kith simulated contamination will be walked through the monitoring and decontamination process, which includes whole body monitorin2 usiiig a CDV 700W-sumey meter; contamination levels will be provided by a controller.

Decontamination will be simulated.

Criterion 6.b.l: The facility/ORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency worker equipment including vehicles.

Estent of Plav Saybrook Township Fire Department will demonstrate the emergency worker faciliry out-of-sequence at Saybrook Elementary School: Saybrook Township.

Vehicle monitoring will be demonstrated by intei-view. If requested: one emergency response vehicle will be monitored; contamination levels will be provided by a controller. Vehicle decontamination procedures will be simulated.

Criterion 6.c.l: Managers of congregatz care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines. Managers demonstrate the procedures to assure that evacuees have

- Ashtabula County 67 Revision 4

Perry Yuclear Power Plant A4shtabulaCount?:

October 2004 Evaluated Exercise Extent of Play Agreement been monitored for contamination and have been decontaminated as appropriate prior io entering congregate care facilities.

Extent of Plav X1 Ashtabula Counq: has 2 care centers. The American Red Cross (ARC) successfully demonstrated this criterion at the Edgewood H. S. Care Center in 3002.

The -ARCwill demonstrate at Conneaut Middle School in the 2006 Exercise.

Criterion 6.d.l: The facility/ORO has the appropiate space, adequate resources. and trained personnel to provide transport: monitoring: decontamination, and medical senices to contaminated injwed individuals.

Extent of Play N Asl~tabulaCounty does not demonstrate this criterion.

Ashtabula County 65 Revision 3

Week of October 4,2004 69

Perry Yuclear Power Plant Geauga County October 2004 Evaluated Exercise Extent-of-Play Agreement The exercise will take place on October 5, 2004.

Criteria that can be re-demonstrated immediately for credit. by a decision of the evaluator, include the foilow-ing: 3.a. 1. 3.d. 1, 3.d.2. 6.3.1, 6.b. 1. 6.c. 1 and 6.d. 1. Criteria that may bc re-demonstrated. as approved on a case-by-case basis by the Chairperscn of the Regional Assistance Committee, include the followins: 2.a. 1 , 2.b. 1. 2.b.2. 5.a.1 and 5.b.l.

Criterion 1.a.l: OROs use effective procedures to alert, notify and mobilize emergency personnel and activate facilities in a timely manner.

Extent of Plav Geauga County EOC Staff will mobilize upon notification from the Geauga County Sheriffs Dispatch Center. Full field notification utilizing primary means of communication will be completed one time only from the EOC, at the Site Area Emergency classiiication. All other notifications nil1 be simulated. The primarji means of notification is a dedicated line: therefore a verification call will not be performed. If a back-up ineans of communication is necessary. then verification will be conducted.

Field agency demonstrations will be conducted out-of sequence and participants tvill be pre-positioned.

Field activity participants:

Newbury Fire Department - Public Monitoring & Decontamination Newbury School District - Care Center American Red Cross - Care Center Thompson Township Fire Department - Back-up Route -4lerting Geauga County SherifPs Office - TraffidAccess Control - at EOC Bainbridge Fire Department - to clear ARCA - Issue No.:47-02-6.a.1-A-O3 Criterion 1.b.l: Facilities are sufficient to support the emergency response.

Extent of Plav Participating facilities other than the EOC and Sheriff's Office will be evaluated during this exercise in order to establish a baseline. Tlx EOC and Sheriffs Office were evaluated during the 2002 Exercise.

Geauga County 70 Revision 4

Perry Nuclear Power Plant Geauga County October 2004 Evaluated Exercise Extent-of-Play Agreement Criterion 1.c.I: Key personnel with leadership roles for the OR0 provide direction and control to that part of the overall response effort for which they are respcnsible.

Extent of Plav Direction and control of emergency operations will be demonstrated in accordance with the exercise scenario, the Geauga County Radiological Emergency Response Plan, A,oency SOP and as appropriate for out-of-sequznce fieid dernonstrnrions.

Criterion 1.d.I: At least two communication systems are available and operate properly and communication links are established with appropriate locations. Communications capabilities are manased in support of emergency operations.

Extent of Plav Primary (dedicatsd phone lines and commercial telephone) and secondary (radiolpagersicell phones) means of communications will be demonstrated at the EOC and as appropriate for out-of-sequence field demonstrations. Controllers will drive field play.

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

Extent of Plav Baselines were established during the 2002 Exercise for the EOC maps, displays and equipment.

During 2003, KI was pre-distributed to the general public at designated locations by the Ohio Department of Health (ODH) through the local health department.

Additional KI is stockpiled at the EOC and would be transported to the care centers by the local health department and distributed by the local health department, as requested.

Dosimetry and KI have been pre-distributed to Offsite Response Organizations (OROs); the monitoring kits and dosimetry are exchanged annually by the State of Ohio. Supporting documentation is included in the Annual Letter of Certification.

EV.ALPATION . i R E A 2 - PROTECTIVE ACTION DECISION hI.4KING Criterion 2.a.l: OROs use a decision-making process, considering relelrant factors and appropriate coordination, to insure that an exposure control system, including the use of Geauga County 71 Revision 4

Perry Nuclear Power Plant Geauga County October 2004 Evaluated Exercise Extent-of-Play Abareement Ki, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.

Extent of Plav Geauga County relies on the Ohio Department of Health for the recommendation to take KI and for the authorization to exceed Protective Action Guides. For Ge!d agency demonstrations, this will be demonstrated by interview nith exercise participants or, if necessary, by controller inject.

Criterion 2.b.l: Appropriate prorective action recommendations are based on available information on plant conditions, field monitoring data and licensee and OR0 dose projections, as well as knowledge of on-site and off-site environmental conditions.

Extent of Plav N/A - Geauga County does not demonstrate t h s criterion; it relies on the State of O l i o for field monitoring.

Criterion 3.b.2: .q decision-making process involving consideration of appropriate factors and necessar:d coordination is used to make protective action decisions (PADS) for the zeneral public (including the recommendation for the use of KI:if OR0 policy).

Extent of Plav The Geauga County EOC Executive Group will demonstrate this criterion in coordination with Lake and Ashtabula counties Executive Groups and the State of Ohio. The Director, or designee, of the Ohio Department of Health (ODH) makes the decision for the general public and emergency workers to take KI.

The ODH through the local health department makes KI available to the general public, by pre-distribution and by supplies available for distribution at the time of the emergency at care centers.

Criterion 2.c.l: Protective action decisions are made, as appropriate, for special population groups.

Extent of Plav The Geauga County EOC Executive Group will demonstrate this criterion in coordination with Lake and Ashtabula counties Executive Groups. Schools follow the protective action decisions for the general public; they are not considered a special population group.

Geauga County 72 Revision 4

Perry Nuclear Power Plant Geauga County October 2004 Evaluated Exercise Extent-of-Play Agreement Criterion 2.d.l: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the O R 0 planning criteria.

Extent of Plav Xi.4 - Geauga County relies on the State of Ohio.

Criterion 2.e.l: Timely re-locaticn, re-sntry and return decisions are made and coordinated as appropriate, based on assessments of the radioiogical conditions and criteria in the OROs plan andior procedures.

Extent of Plav W A - This criterion was successfiiily demonstrated during the 2002 Exercise.

Criterion 3.a.l: The OROs issue appropriate dosimetry and procedures and manage radiological exposure to emergency workers in accordance with the plan 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.

Extent of Plav

-3 I ne Geauga County EOC Radiolo,oical Officer will demonstrate radiation exposure control capabilities by interview. Dosimetry and exposure control procedures will be demonstrated by field agencies during out-of-sequence exercise activities by interview with participants or, if necessary, by controller inject.

Criterion 3.b.l: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals (not the general public) is maintained.

Extent of Plav The Ohio Department of Health (ODH) will make recommendations regarding the use of KI. Geauga Countys preparedness measures for KI include pre-distribution to emergency response agencies and to the general public, if they chose to pick it up at designatzd centers. At the time of the emergency, the agencies distribute the dosimetry and KI to the emergency workers. If the ODH recommendation for use of KI excludes the portion of the EPZ that is in Geauga County, demonstration of this criterion may be facilitated by discussion with the Geauga County Radiological Officer at the EOC. For field agency demonstrations, KI procedures will be Geauga County 73 Revision 4

f e r r y Kuclear Power Plant Gesuga County October 2004 Evaluated Exercise Extent-of-l'lay A, re em e at demonsaated by interview with exercise participants cr? if necessary, by exercise controller inject.

Criterion 3.c. 1: Protective action decisions are implemented for special population Loroups within areas subject to protecti~~e actions.

Extent of P!av Notification to individuals with special needs within the Geauga County portion of the EPZ \vi11 be simulated. A list of special needs residents within the Cieauga County portion of the EPZ is maintained by the Geauga County Department of Emergency Services (DES).

The Fire,ZhfS Officer at the EOC will coordinate special needs notification activilies and. upon request, will present the confidential list for review by the FEh1.A evaluator. At least 2 transportation providers, which in Geauga County are school disrricts, will be coctacted to ensure availability of buses and drivers.

Criterion 3.22: ORCdschool officials decide upon and iinplemziit protective actions for schcols.

Extent of Plav XI Geauga Count:; will not demonstrate this criterion. It was deixonstrated in 2000 by the Ledgemont School District, the only Geauga County EPZ district.

Criterion 3.d.l: rlppropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel.

Extent of Plav A representative of the Geauga County Sheriffs Office (Sherifrs Designate) wi!l demonstrate Traffic and Access Control by interview at the Geauga County EOC during the exercise. Notification of rail, water and air traffic is a State fimction.

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

Extent of Plav Geauga County EOC will demonstrate the capability to identify and take the appropriate actions in dealing with impediments to evacuation. ilcnial resources will not be utilized. If an impediment cannot be removed in a timely manner, the decision to reroute traffic will be discussed and iinplemented by the appropriate EOC staff.

Geauga County 74 Revision 3

Perry Yuclear Power Plant Geauga County October 2004 Evaluated Exercise Extent-of-Play A bUreement Criterion 3.e.l: The O R 0 demonstrates the availability and appropriate use of adequatz information regarding water, food supplies, milk and agricultural production bvithin the ingestion exposure pathway emergency planning zone for implementation of protectiaie actions.

Extsnt of Plav N/A - Geauga County relies on the State of Ohio.

Criterion 3.e.2: -4ppropriate measures: strategies and pre-printed iiistnictional material are developed for implementing protective action decisions for contaminated water, food products, milk and agricultural production.

Exrent of Plav

>!/'-A - Geauga County relies on the State of Ohio.

Criterion 3.f.l: Decisions regarding controlled re-entry of emergency v,-orkers and relocation and return of the public are coordinated with appropriate organizations and implzinented.

Extent of Plav W.4 - This criterion was successfully demonstrated during the 2002 Exercise.

Criterion 4.a.l: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates.

Extent of Plav N/A - Geauga County does not demonstrate this criterion.

Criterion 4.a.2: Field teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure.

Extent of Plav N/A - Geauga County does not demonstrate this criterion.

- Geauga County 75 Revision 4

~ ~~

Perry Nuclear Power Plant Geauga County October 2004 Evaluated Exercise Extent-of-Play A,areemenf Criterion 4.n.3 ?imbier,t radiation measurements are made and recorded 2 appropriate locztions, and radioiodine and pai5culate samples zrz collected. Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan andlor procedures) amount of radioactivity has been collected on the sampling media.

Extent of Plav NiA - Geauga County does not demonstrate this criterion.

Criterion 4.b.l: The field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetaiiun, and soil) to support adequate assessments and protective action decision-making.

Estent of Flav SiA - Geauga County does not demonstrate this criterion.

Criterion 4.2.1 : The laboratory is capable of performing required radiological analyses io sc,pporr prctective action decisions.

Extent of Plav X Geauga County does not demonstrate this criterion.

EV.4LUATION AREA 5 - EMERGENCE NOTIFICATION AND PUBLIC INFORMATION Criterion 5.a.l: -4ctivities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized off-site erner,oency officials to notify the public of an emergency situatim. The initial instructional message to the public must include:

1. Identificztion of the state or local government organization and the official with the authority for providing the alert signal and instructional message

2. Identification of the commercial nuclear power plant and a statement that an emergency situation exists at the plant

3. Reference to REP-specific emergency information (e.g., brochures and information in telephone books) for use by the general public during an emergency

4. A closins statement asking the affected and potentially affected population to stay tuned for additional information.

Extent of Play Upon a protective action decision (PAD) by the combined Executive Groups of Ashtabula, Lake and Geauga counties, the Lake County EOC Staff will prepare the Geauga County 76 Revision 1

Perry Nuclear Power Plant Geauga County October 2004 Evaluated Exercise Extent-of-Play A,or eement appropriate Emergency Alert System (EAS) message and simulate sounding the sirens and sending the message over the EAS system. A quiet siren test \\-ill be demonstrated by the Lake County EOC in lieu of an actual siren sounding. Lake County tviil fax a copy of the EAS message to Ashtabula and Geauga counties.

Simulation of sending the E M message(sj will be conducted as follows:

The procedure for the E-AS encoder will be followed to deliver the message to WTXM, the Local Primar]i Station, with the exception that the telephone number to the station byill not be dialed. By not connecting to WTAM, there is no possibility of accidentally broadcasting the message over one or more of the participating EAS stations. The "send" button on the Lake County EAS encoder will be depressed, and this action will activate the outgoing alert light and playback of the recorded message. Also? a data sheet will automatically be printed by the encoder and the time recorded on the data sheet. Ashtabula and Geauga counties have EAS equipment (encoder) and could perform this hnction, if required.

Laks County will fax a copy of the EAS message(sj to the Joint Public Information Center (JPIC) where Public Information Officers (PIOs) may distribute hard copies to the news media representatives and may, if time and circumstances permit. make an announcement regarding the message. Otherwise, the EAS message can be announced at the nest scheduled press briefing or in response to news media inquiries about the P-4D message. In delivering information about the EXS message just released, the counties' PIOs may indicate that a corresponding Special Yews Bulletin (SXB) will be issued soon. Lake County will also fax a copy of the ELAS message to Ashtabula and Geauga counties' EOCs.

Criterion 5.a.2: (RESERVED)

Criterion 5.a.3: Activities associated with FEMA approved exception areas (where applicable) are completed withn 35 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency sihiation. Backup alert and notification of the public is completed within 45 minutes following the detection by the O R 0 of a failure of the primary alert and notification system.

Extent of Plav The Thompson Volunteer Fire Department will demonstrate back-up route alerting as an out-of-sequence, pre-positioned field activity. One pre-determined siren located in Thompson Township will be out-of-service (simulated) and back-up route alerting will be conducted in the siren coverage area. Use of the mobile PA system will be simulated. The demonstration will be initiated by the exercise controller.

Geauga County 77 Revision 4

Perry Muclear Power Plant Geauga County October 2004 Evaluated Exercise Extent-of-Play A,areement Criterion 5.b.l: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner.

Extent of Tlav Based upon the combined PXD(s) of the Executive Groups of Ashtabula. Geauga and Lake Counties, the Lake Couity EOC Staff will prepare and issue the appropriate E-AS message(s) and the corresponding Special Yews Bulletins(s)

(SNB). ShB's are the same message as their conesponding EAS message except SNB's provide greater detail. Lake C o u q will FAAXthe SNB(s) to the Joint Public Information Center ( P I C ) where one of the counties' PIOs will represent the t h e e counties by directly proceeding to the briefing rooin and reading the coments of the message to the assembly of news media representatives and answering any questions pertaining to the message. This briefing should begin in a timely maimer after transmission of the E X message from the Lake County EOC to the Local Priniary EAS Station. Hard copies of the SNB(s) will be distributed to the news media representatives.

Ashtabula. Geauga and Lake Counties &ill also coordinate release of other inforniaiional and iiistructional message as necessary. Such messages may include Special Information Bulletins (SIBs), which are a third catesory of prepared messages contained in the counties' "SOP for EAS Messages. Special N e x s Bulletins, and Special Information Bulletins pertaining to the Peiiy Nuclear PouFer Plant." These SIBs are considered routine, meaning that they are to be delivered by oiie of the counties' PIOs at the next scheduled press briefing.

EVALUATION AREA 6 - SUPPORT OPEEUTION/FACILITIES Criterion 6.a.l: The reception center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide rnonitcring, decontamination, and registration of evacuees a n d o r emergency workers.

Field activity participants:

Newbury Volunteer Fire Department Newbury High School American Red Cross Bainbridge Fire Department - Representative for interview to clear the ARCA -

Issue No.:U-@-6.a. 1-A-O3 Extent of Plav Geauga County 78 Revision 4

Perry Nuclear Power Plant Geauga County October 2004 Evaluated Exercise Extent-of-Play A,areemenf Yenbury Volunteer Fire Depanment \vi11 demonstrate the evacuee portion of this criterion out-of-sequence at Newbury High School, 14775 Auburn Road, Sewbury Township. One locker room will be fully set up and demonstrated.

Deccntamination will be simulated, demonstrated by interview. A walk-though of the remaining locker room will be conducted upon request. An American Red Cross representative will describe registration procedures. Set-up of care center equipment andlor supplies will be at the discretion of the American Red Cross Disaster Action Tzam Leader.

Six (6) monitoring deinonstrations will be conducted using a portal monitor. One individual with simulated contamination will be walked through the monitoriiigidecontamination process: which includes whole body monitoring using a CDV-700W survey meter; contamination levels will be provided by a controller.

Decontamination will be simulated.

ARCA - Issue NO.:47-02-6.a.l-A-03 A representative of the Bainbridge Fire Department will be available for inteiTiew by the Evaluator the night of the Newbury High School dernonstratim to clear this issue. The representative will discuss the monitoring process to demonsirae an-areness of the value that indicates a person is contaminated. No actual demonstration of monitoring will take place.

Criteyion 6.b.l: The facility-IORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency Lvorker equipment including vehicles.

Extent of Plav NIA4- Geauga County will not demonstrate this criterion.

Criterion 4.c.l: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines, 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.

Extent of Plav The American Red Cross will demonstrate the congregate care center portion of this criterion out-of-sequence at Newbury High School, 14775 Auburn Road, Newbury Township. American Red Cross personnel will provide a walk-through of the facility and describe their capabilities. Set-up of care center equipment or supplies will be at the discretion of the American Red Cross Disaster Action Team Leader.

Geauga County 79 Revision 4

Perry Yuclear Power Plant Geauga County October 2004 Evaluated Exercise Esten t-of-Play Agreement Criterion 6.d.l: The facility/ORO has the appropriate space, adequate resources. and trained personnel io provide transport: monitoring, decontamination, and medical s e n k e s to contaminated injured ifidividuals.

Extent of Plav Xi Geauga County daes not demonstrate this criterion Geauga County 80 Revision 4

APPENDIX d This appendix contains a summary ofthe simulated exercise scenario events. which was used as the basis for involting emergency response actions by Offsite Rzsponse Organizations in the Perry Nuclear Power Plant exercise on October 5: 2004 This exercise scenario was submitted by the State of Ohio and First Energy Corporation: and approved by FEbIX Region V on September 30,2004.

During the exercise! controllers from the State of Ohio inject messages: containing scenario events andior relevant daia, to those persons or locations who would nomially receive notification of such eveilts. These inject messages were the method used for invoking response actions by OROs.

S CEN-RIO SUitLMARY:

073G Initial cmditions have been established in the C o ~ r o Room l Simulnror. The 2004 ERO Team *A* Drill commences following the announcement from the Simulator.

Preparation being made to raise reacior power to 1OO?/o.

0750 The Shift hIaanager declares an Unusual Event using WI-A41,initiating condition FU-1, Fire within a Safe Shutdovn Building NOT extinguished within 15 minutes.

0805 Report from the field that an earthquake was felt. (First Earthquake) 0807 CDR A trips due to suction filter diff. Press.

Crew dispatches XLOs to swap suction filrers.

0820 Contaminated Injured person 81

0830 The Shift Manager declares an Alert using EP7-.A1, initiating condition LA-1, Natural OR destructive phenomena affecting Safe Shutdown Buildings Failure, or OS-1, Emergency Coordinator Judgment.

Upon declaring the Alert: the Shifi manager should activarc rlie T e c h c a l Support Center (TSC),

Operations Support Center (OSC), and Public Information Response Team (PIRT).

0920 Rzport from the field that another earthquake is fdt. (Second Eanhqcalte) 09211 Reactor scram due to loss of scram air pressure. On the scram, all control rods dc not insert. Operators take actions per PEI-B 13: RPV Control (.ATWS j! and power stabilizes at -8%

092 5 SLC \vi11 be initiated - SLC-A pump is defective and does not start. SLC-Bwill start but will not inject due to pipe break.

0935 The Shift Manager declares a Site Area Emergerncy using EPI-AI, initiating condition CS-I, Failure to initiate or complete an automatic Reacror Scram once an RPS funciion is required, AND a manual Scram was NOT successfd, or OS-1, Emergency Coordinator Judgment.

Vpon declarinz the SPIE: THE Shift Manager should activate the Eme:scncy Operations Facilicr c'EOFj and the Joint Public Information Center (JPIC).

-0925 Operator actions taken per PEI: SPIs 1.1-1.8 are successful in shuttin,o dcwn the reactor.

1 130 Mode select will only allow individual mode, insei-t can only be accomplished using the insert pushbutton (in timer skip is not working. IC1 IF0003 PCV fails as is.

-1 130 A stream leak develops in the STM Tunnel causing an MSIV isolation signal and initiation of the 29 minute RCIC isolation timer on high temperature. hlSL B fails to isolate with 1B21F0022B & 1B21F003SB fail to close. lNllF0020B will not close.

The failure o f the 1BB21F0022B, 1B21F00283 & 1YllF0020B dose and isolate the steam line break results in a challenge of the Reactor Coolant System (RCS) and a loss of the Containment barrier, resulting in a second event classifiable (AS3) as a SITE: AREA EMERGENCY.

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1200 Rzport from the field that another earthquake is felt. (Third Earthquake)

- I200 LOCA initiates leads to ED not able to maintain level >-2 or not able to maintain PSP -

(Third Earthquake)

-131 5 The event classification should be escalated to a GENERAL E-MERGENCE per EPI-AI, Initiating Condition:

1. AGI, Loss of two barriers, AND a loss or challenge to the third barrier OR

2. HG-I, Site Boundary &!ease Limits 3 . OG-I, Emergency Coordinator Judgement.

Based 011 the wind direction of 329 degrees, wind speed of 6mph the General Emergency default recommendation ofEV.4CG;ATION Sub-areas 1, 2, 3, 5 & 6 should be recommended.

PAR change based on stability and wind direction change - 325 degrees EVXCU.4TION Sub-areas 1: 2. 3, 4.5 & 6 should be recommended.

Offsite reltase plume has dissipated. Preliminary plant re-entry/recoveqr discussions should focus on actions required to terminate from the Emergency Phase and entry into ihe Recovei-y Phase.

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ML050810184

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