ML061290194

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FEMA Final Exercise Report - Limerick Generating Station (Dtd 01/18/2006)
ML061290194
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Site: LaSalle  Constellation icon.png
Issue date: 01/18/2006
From:
Federal Emergency Management Agency
To:
Office of Nuclear Reactor Regulation
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Download: ML061290194 (104)
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Limeric tation Exercise - N r 15,2005 Final Report - Radiological Emergency Preparedness Program January 18,2006 FEMA FEMA Region IIl

Final Exercise Report Limerick Generating Station Licensee: Excelon Nuclear Exercise Date: November 15,2005 Report Date: January 18,2006 U.S. DEPARTMENT OF HOMELAND SECURITY FEDERAL EMERGENCY MANAGEMENT AGENCY REGION I11 ONE INDEPENDENCE MALL, gTHFLOOR 615 CHESTNUT STREET PHILADELPHIA, PENNSYLVANIA 19106-4404

TABLE OF NTENT I. Executive Summary ................................................................................................................... 1 I1. Introduction ................................................................................................................................ 3 I11. Exercise Overview ..................................................................................................................... 5 A . Plume Emergency Planning Zone Description .............................................................. 5 B . Exercise Participants ...................................................................................................... 6 C. Exercise Timeline ........................................................................................................ 12 IV .Evaluation and Results............................................................................................................. 15 A . Summary Results of Exercise Evaluation ...................................................................... 15 B . Status of Jurisdictions Evaluated .................................................................................... 19 1.0 Commonwealth of Pennsylvania ...................................................................... 21 1.1 Commonwealth of Pennsylvania EOC (Observed) ..................................... 21 1.2 Accident Assessment (State BRP) (Observed) ............................................ 21 1.3 Emergency News Center (ENC) .................................................................. 21 1.4 Emergency Operations Facility (State BRP) (Observed) ............................ 22 1.5 State Traffic/Access Control ........................................................................ 22 2.0 Risk Jurisdictions .............................................................................................. 23 2.1 Berks County ............................................................................................... 23 2.1.1 Berks County EOC ................................................................................ 23 2.1.2 Emergency Worker MonitoringDecontamination Station (Daniel Boone Complex)................................................................................................ 24 2.1.3 Reception and MonitoringDecontamination Center (Boscovs Outlet) 24 2.1.4a MonitoringDecontamination Center (Hamburg High School) ............. 24 2.1.4b Mass Care Center (Hamburg High School) ........................................... 25 2.1.5 Colebrookdale Township EOC .............................................................. 25 2.1.6 Earl Township EOC ............................................................................... 25 2.1.6a Earl Township Route Alerting ............................................................... 26 2.1.7 Union Township EOC............................................................................ 26 111

2.2 Chester County............................................................................................. 26 2.2.1 Chester County EOC .............................................................................. 26 2.2.2 Emergency Worker MonitoringlDecontamination Station (Lionville Middle School)....................................................................................... 28 2.2.3a Reception Center (West Whiteland) ...................................................... 28 2.2.3b Monitoring/Decontamination Center (West Whiteland) ....................... 29 2.2.4 Mass Care Center (North Brandywine Middle School) ......................... 29 2.2.5 East Pikeland Township EOC ................................................................ 29 2.2.5a East Pikeland Township Route Alerting ................................................ 30 2.2.6 East Vincent Township EOC ................................................................. 30 2.2.7 North Coventry Township EOC ............................................................ 30 2.2.8 Phoenixville Borough EOC ................................................................... 31 2.2.9 Uwchlan Township EOC ....................................................................... 32 2.3 Montgomery County .................................................................................... 32 2.3.1 Montgomery County EOC ..................................................................... 32 2.3.2 Emergency Worker MonitoringDecontamination Station (Indian Valley Middle School)....................................................................................... 34 2.3.3a Reception Center (Metroplex) ............................................................... 36 2.3.3b MonitoringDecontamination Center (Fire Academy)........................... 36 2.3.4a Mass Care Center (Sandy Run Middle School) ..................................... 37 2.3.4b Mass Care Center (Upper Dublin School) ............................................. 38 2.3.4~ Mass Care Center (Upper Moreland Middle School) ............................ 38 2.3.5 Green Lane Borough/ Marborough Township EOC .............................. 38 2.3.6 Limerick Township EOC ....................................................................... 39 2.3.7 Lower Frederick Township EOC ........................................................... 39 2.3.8 New Hanover Township EOC ............................................................... 39 2.3.9 Perkiomen Township EOC .................................................................... 40 2.3.10 Schwenksville Borough EOC ................................................................ 40 2.3.1 1 Trappe Borough EOC ............................................................................ 41 2.3.1 l a Trappe Borough Route Alerting............................................................. 42 2.3.12 West Pottsgrove Township EOC ........................................................... 42 3.0 Support Jurisdictions......................................................................................... 43 3.1 Bucks County ............................................................................................... 43 3.1.1 Bucks County EOC ................................................................................ 43 3.1.2a Recepion Center (County Line Plaza) ................................................... 43 3.1.2b MonitoringDecontamination Center (County Line Plaza) .................... 43 3.1.3 Mass Care Center (Palisades Junior/Senior High School)..................... 44 iv

3.2 Lehigh County ............................................................................................. 44 3.2.1 Lehigh County EOC .............................................................................. 44 3.2.2 Reception Center (Emmaus High School) ............................................. 44 3.2.3a MonitoringDecontamination Center (Salisbury High School) ............. 45 3.2.3b Mass Care Center (Salisbury High School) ........................................... 45 4.0 School Districts ................................................................................................. 46 4.1 Berks County School Districts..................................................................... 46 4.1.1 Boyertown Area School District (Earl Elementary School) .................. 46 4.1.2 Daniel Boone School District (Birdsboro Elementary School) ............. 46 4.2 Chester County School Districts .................................................................. 46 4.2.1 Downington Area School District (Pickering Valley Elementary School) .............................................................................................. 46 4.2.2 Great Valley School District (Charlestown Elementary School) ..........47 4.2.3 Owen J . Roberts School District (French Creek Elementary School) .. 47 4.2.4 Phoenixville Area School District (Barkley Elementary School).......... 47 4.3 Montgomery County School Districts ......................................................... 48 4.3.1 Methacton Area School District (Woodland Elementary School)......... 48 4.3.2 Perkiomen Valley School District (Perkiomen Valley Middle School) 48 4.3.3 Pottsgrove School District (Pottsgrove High School) ........................... 48 4.3.4 Pottstown School District (Pottstown High School).............................. 49 4.3.5 Souderton Area School District (Salford Hills Elementary School) .....49 4.3.6 Spring-Ford Area School District (West Center for Tech Studies) .......50 4.3.7 Upper Perkiomen School District (Upper Perkiomen Middle School) . 50 APPENDICES APPENDIX 1 .Acronyms and Abbreviations ..................................................................... 51 APPENDIX 2 .Exercise Evaluators and Team Leaders ..................................................... 53 APPENDIX 3 .Exercise Evaluation Area Criteria and Extent of Play Agreement ............57 APPENDIX 4 .Exercise Scenario ....................................................................................... 90 APPENDIX 5 .Prior Issues Resolved for Locations Not Scheduled for Demonstration at This Exercise .......................................................................................... 92 APPENDIX 6 .Planning Issues ........................................................................................... 94 V

LIST OF ABLES Table 1 . Exercise Timeline................................................................................................. 13 Table 2 - Summary Results of Exercise Evaluation ............................................................ 16 vi

Executive Summary On November 15,2005, an exercise was conducted in the 10-mile plume exposure pathway, emergency planning zone (EPZ) around the Limerick Generating Station (LGS) by the Department of Homeland Security Federal Emergency Management Agency (FEMA),

Region 111. Out-of-sequence demonstrations of reception center-monitoring, decontamination, and registration, congregate care, and emergency worker, equipment and vehicle-monitoring and decontamination activities, as well as the implementation of school protective actions, were also conducted on August 25,2005 and November 16,2005. The purpose of the exercise was to assess the level of State and local preparedness in responding to a radiological emergency. The exercise and out-of-sequence demonstrations were held in accordance with FEMA's policies and guidance concerning the exercise of State and local radiological emergency response plans (RERP) and procedures.

The most recent prior full-scale exercise at this site was conducted on November 18,2003.

FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Pennsylvania; the risk jurisdictions of Berks, Chester, and Montgomery Counties; the support jurisdictions of Bucks and Lehigh Counties; and 15 participating municipalities who were evaluated at this exercise.

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

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

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

Reception Center - Monitoring, Decontamination, and Registration: Conducted between 1700 and 1930 on November 16,2005, in Berks, Bucks, Chester, Montgomery, and Lehigh counties.

Mass Care: Conducted between 1700 and 1930 on August 25,2005, in Bucks, Chester, and Montgomery counties, and between 1700 and 1930 on November 16,2005, in Berks and Lehigh counties.

Emergency Workers, Equipment, and Vehicles - Monitoring and Decontamination:

Conducted between 1700 and 1930 on November 16,2005, in Berks, Bucks, Chester, Lehigh, and Montgomery counties.

School Interviews: Conducted between 0900 and 1100 on November 16,2005, in Berks, Chester, and Montgomery counties.

The State and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Deficiencies and nine Areas Requiring Corrective Action (ARCA) identified as a result of this exercise. Three of these ARCAs were successfully re-demonstrated during the exercise. One ARCA from a previous exercise was successfully demonstrated at this exercise; four other ARCAs at locations not scheduled for demonstrated at this exercise were also resolved.

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roduction On December 7, 1979, the President directed FEMA to assume the lead responsibility for all off-site 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.

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

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

Taking the lead in offsite emergency planning and in the review and evaluation of Radiological Emergency Response Plans (RERPs) and procedures developed by State and local governments; Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by State and local governments; Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17,1993 (Federal Register, Vol. 58, No. 176, September 14, 1993); and Coordinating the activities of the following Federal agencies with responsibilities in the radiological emergency planning process:

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

Representatives of these agencies serve on the FEMA Region 111 Regional Assistance Committee (RAC), which is chaired by FEMA.

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A REP exercise was conducted on November 15, 2005, by FEMA Region I11 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 LGS. The purpose of this exercise report is to present the exercise results and findings on the performance of the off-site response organizations (ORO) during a simulated radio1ogic a1 emergency.

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

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

NUREG-0654FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, November 1980; FEMA Guidance Memoranda MS-1, Medical Services, November 1986; FEMA-REP-14, Radiological Emergency Preparedness Exercise Manual, September 1991; 66 FR 47546, FEMA Radiological Emergency Preparedness: Alert and Notification, September 12,2001; and 67 FR 20580, FEMA Radiological Emergency Preparedness: Exercise Evaluation Methodology, April 25,2002.

Section III of this report, entitled Exercise Overview, presents basic information and data relevant to the exercise. This section of the report contains a description of the plume pathway emergency planning zone (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 evaluation areas at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format. This section also contains: (1) descriptions of all Deficiencies and ARCAs assessed during this exercise, recommended corrective actions, and the Tribal, State, and local governments schedule of corrective actions for each identified exercise issue and (2) descriptions of unresolved ARCAs assessed during previous exercises and the status of the OROs efforts to resolve them.

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111. Exercise Overview Contained in this section are data and basic information relevant to the November 15,2005 exercise to test the off-site emergency response capabilities in the area surrounding the Limerick Generating Station (LGS). This section of the exercise report includes a description of the plume pathway EPZ, a listing of all participating jurisdictions and functional entities that were evaluated, and a tabular presentation of the time of actual occurrence of key exercise events and activities.

A. Plume Emergency Planning Zone Description LGS is located in southeastern Pennsylvania on the Schuylkill River about 1.7 miles southeast of Pottstown Borough. The river passes through the site, separating the western portion, which is in East Coventry Township in Chester County, from the eastern portion, which is in Limerick and Lower Pottsgrove Townships in Montgomery County. The plant is owned and operated by Exelon Nuclear. Two boiling water reactors each generate an electrical output of 1,050 megawatts ( M W ) . Unit 1 was issued a full-power license in August 1985; commercial operations began in February 1986. Unit 2 was issued a full-power license in August 1989 with commercial operations beginning in January 1990.

The site encompasses 595 acres and is divided into three (3) parts. The principal portion, where the major operating equipment and buildings are located, is on the east bank of the Schuylkill River. This portion is separated from the second segment, where the cooling water intake is located, near the main line of the Reading Railroad. The third portion lies on the west bank of the river, adjacent to Conrail railroad tracks. The site coordinates are approximately 40O1327N and 753515W.

The minimum exclusion distance for the LGS is 2,500 feet from the center of each reactor. The utility owns all the land within the exclusion area. No private residences are located within the exclusion area; however, some farming may be permitted.

There are 165 sirens installed to cover the 10-mile plume exposure pathway EPZ. These sirens are activated three (3) minutes before the Emergency Alert System (EAS) messages issued by the Commonwealth of Pennsylvania are broadcast.

Soils in this area are of the Reaville-Penn-KlinesvilleAssociation and are characteristic of rolling uplands. They are underlain by sedimentary rocks of the Brunswick Formation, consisting mostly of red shale with some fine-grained sandstone interbedding.

The normal pool elevation of the Schuylkill River in this area is 200 feet above mean sea level (msl). The topography of the area is hilly, with elevations ranging from 100-300 feet above msl within five (5) miles of the site. The plant is approximately 217 feet above msl.

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The climate in this area is dominated by prevailing westerly winds that produce humid, continental-type weather characterized by warm summers and moderately cold winters.

Montgomery County is the warmest part of Pennsylvania, with an average annual temperature of 57°F. Annual precipitation is approximately 42 inches.

The area in the immediate vicinity of the plant is made up mostly of agricultural and other open land. The Pottstown Borough in Montgomery County is the nearest community and has a population of 21,859 based on the 2000 Census. The nearest major population center (more than 25,000 people) is Philadelphia that lies 25 miles to the southeast of the site.

Two major industries employ a total of 850 persons within two (2) miles of the plant.

Two small airfields are also located nearby. A small private airfield is about one (1) mile to the northeast, but its runway is oriented so that the flight path does not pass over the plant. The Pottstown Municipal Airport is 4.3 miles northwest of the site. The LGS does not lie in the approach pattern for this airport.

No major thoroughfares are located in the immediate vicinity of the plant. The main line of the Reading Railroad runs along the north bank of the Schuyllull River and traverses the site about 500 feet from the plant.

B. Exercise Participants The following agencies, organizations, and units of government participated in the LGS out-of-sequence activities on August 25,2005, and November 16,2005, or the exercise on November 15,2005.

COMMONWEALTH OF PENNSYLVANIA Pennsylvania Army National Guard Pennsylvania Department of Agriculture Pennsylvania Department of Environmental Protection - Bureau of Radiation Protection Pennsylvania Department of Environmental Protection - Bureau of Water Supply Management Pennsylvania Emergency Management Agency Pennsylvania Emergency Management Agency (Controller)

Pennsylvania Fish and Boat Commission Pennsylvania Game Commission Pennsylvania State Police, Troop K Pennsylvania Turnpike Commission RISK JURISDICTIONS BERKS COUNTY Berks County Emergency Management Agency Berks County Commissioner Berks County Communication Center 6

Berks County Department of Facilities & Operations Berks County District Court Administration Berks County Emergency Ambulance and Rescue Service Berks County FirePolice Berks County Intermediate Unit Berks County Personnel Department Berks County Planning Commission Berks County Sheriff's Department Berks A r e a e a d i n g Transportation Authority Pennsylvania Department of Transportation Pennsylvania Emergency Management Agency Pennsylvania National Guard Pennsylvania State Police Pennsylvania State University - Agricultural Extension Service U.S. Department of Agricultural (USDA) - Farm Service Agency COLEBROOKDALE TOWNSHIP Colebrookdale Township Manager (and staff)

Colebrookdale Township Police Department Colebrookdale Township Public Works Department EARL TOWNSHIP Earl Township Fire Company UNION TOWNSHIP French Creek State Park Union Township Supervisors CHESTER COUNTY Chester County Commissioner Chester County Department of Emergency Services Chester County Fire Group Chester County Department of Health Chester County Sheriff's Office Chester County Contracts and Purchasing Chester County Department of Public Works Chester County Hazardous Materials Response Team Chester County Human Resources Department Chester County Telecommunications Office Chester County Geographic Information Systems Department Pennsylvania Department of Transportation Pennsylvania Emergency Management Agency Pennsylvania State Police 7

EAST PIKELAND TOWNSHIP East Pikeland Township Police Department East Pikeland Township Public Works Department EAST VINCENT TOWNSHIP East Vincent Police Department East Vincent Public Works Department NORTH COVENTRY TOWNSHIP North Coventry Township Police Services North Coventry Township Public Works PHOENIXVILLE BOROUGH Phoenixville Borough Emergency Management Agency Phoenixville Fire Department Phoenixville Police Department UWCHLAN TOWNSHIP Uwchlan Township Highway Department Uwchlan Township Manager Uwchlan Township Police Department Uwchlan Township Public Works Uwchlan Township Supervisors MONTGOMERY COUNTY Montgomery County Commissioners Office Communications Director Montgomery County Department of Agriculture Montgomery County Department of Health Montgomery County Emergency Dispatch Services Montgomery County Emergency Medical Services Montgomery County Fire Academy Montgomery County Hazmat Team Montgomery County HAZMAT Team Montgomery County Industrial Liaison Montgomery County Office of Emergency Preparedness Montgomery County Office of Public Safety Montgomery County Parks and Heritage Montgomery County Public Works Department Montgomery County Sheriff's Office Montgomery County Transportation Coordinator Montgomery Intermediate Unit (Schools)

Pennsylvania Army National Guard Pennsylvania Department of Transportation Pennsylvania Emergency Management Agency Pennsylvania State Police 8

GREEN LANE BOROUGWMARBOROUGH TOWNSHIP Marlborough Township Department of Public Works Marlborough Township Fire and Rescue Services Marlborough Township Police Department LIMERICK TOWNSHIP Limerick Fire Department Montgomery County RACES Office of Emergency Management Police Department LOWER FREDERICK TOWNSHIP Lower Frederick Township Police NEW HANOVER TOWNSHIP Fire Marshall New Hanover Township Department of Public Works New Hanover Township Emergency Management New Hanover Township Police Department PERKIOMEN TOWNSHIP Assistant Township Building Inspector Chairman, Perkiomen Township Board of Supervisors Township Building Inspector Township Manager SCHWENKSVILLE BOROUGH Schwenksville Borough Fire Department Schwenksville Borough Police Department TRAPPE BOROUGH Office of the Emergency Management Coordinator Trappe Borough Emergency Management Coordinator Trappe Fire and Ambulance Company WEST POTTSGROVE TOWNSHIP Volunteers from West Pottsgrove Fire Department SUPPORT JURISDICTIONS BUCKS COUNTY Bucks County Commissioners Office Bucks County Communications Division Bucks County Emergency Management Agency Bucks County Emergency Medical Services Bucks County Fire Marshal 9

Bucks County Hazardous Materials Response Team Bucks County Information Technology Department Bucks County Public Information Department Bucks County Public Works Bucks County Sheriffs Department Pennsylvania Emergency Management Agency LEHIGH COUNTY Centronia Ambulance Corps Coplay Borough Emergency Management Coordinator Eastern Pennsylvania EMS Council Emmaus Fire Department Lehigh County Agricultural Department Lehigh County Department of Public Affairs Lehigh County Emergency Management Agency Lower Milford Fire Company Pennsylvania State Police Upper Saucon Ambulance Company Upper Saucon Fire Department USDA Farm Service SCHOOLS BERKS COUNTY Boyertown Area School District Earl Elementary School Daniel Boone School District Birdsboro Elementary School CHESTER COUNTY Downington Area School District Pickering Valley Elementary School Great Valley School District Charlestown Elementary School Owen J. Roberts School District French Creek Elementary School Phoenixville Area School District Samuel K. Barkley Elementary School East Pikeland Elementary School MONTGOMERY COUNTY Methacton Area School District Woodland Elementary School Perkiomen Valley School District Perhomen Valley Middle School 10

Pottsgrove School District Pottsgrove High School Pottstown School District Pottstown High School Souderton Area School District Salford Hills Elementary School Spring-Ford Area School District West Center for Technical Studies Upper Perkiomen School District Upper Perkiomen Middle School PRIVATENOLUNTEER ORGANIZATIONS Amateur Radio Emergency Services (ARES)

American Red Cross Amity Township Fire Department Birdsboro Fire Company Boyertown Ambulance Civil Air Patrol Colebrookdale Township Volunteer Fire Department - Station 17 Collegeville Fire Company No. 1 Critical Incident Stress Management Team (Montgomery Hospital)

Earl Township Fire Company Eastern Salisbury Volunteer Fire Department Friendship Fire Company Gilbertsville Ambulance Squad 332 Gilbertsville Fire Company No. 1 Hamburg Fire Company Horsham Township Volunteer Fire Department - Station 15 Kimberton Fire Company Kulpstown Fire Department Lehigh County Hazmat Team Liberty Fire Company Lionville Fire Company Lower Frederick Regional Ambulance Corps Lower Frederick Township Fire Company Lower Salford Township Fire Department Members of the East Vincent Township Community Military Amateur Radio Service Monarch Firem01ice Department Montgomery County Fire Station 74 (Perseverance Volunteer Fire Company)

Montgomery County RACES Montgomery Township Volunteer Fire Department - Station 18 New Hanover Volunteer Fire Company NORCO Volunteer Fire Department North Coventry Township Town Watch Oley'Fire Department 11

Perkiomen Township Fire Company Pottstown Area Amateur Radio Club Plymouth Fire Company # 43 Radio Amateur Civil Emergency Services (RACES)

Reading Radio Club Salisbury Ambulance Sassamansville Volunteer Fire Company Souderton Fire Department Southeast Pennsylvania Red Cross Southern Berks Regional EMS Telford Volunteer Fire Company Trappe Fire Ambulance Company Trappe Fire Company Upper Frederick Township Fire Department Uwchlan Ambulance Service Valley Forge Volunteer Fire Company Western Salisbury Volunteer Fire Department West Whiteland Volunteer Fire Department C. Exercise Timeline Table 1, on the following page, presents the time at which key events and activities occurred during the LGS exercise on November 15,2005. Also included are times notifications were made to the participating jurisdictions/functional entities.

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TABLE 1. EXERCISE TIMELINE Legend: NIA - Not Applicable *EOC Relocated NR -Not Received 13

TABLE 1. EXERCISE TIMELINE Legend: N/A - Not Applicable *EOC Relocated NR - Not Received 14

IV. Evaluation and Contained in this section are the results and findings of the evaluation of all jurisdictions and locations that participated in the November 15,2005, biennial REP exercise. The exercise was held to test the offsite emergency response capabilities of local governments in the 10-mile EPZ surrounding the LGS.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of the exercise evaluation area criteria contained in the FEMA REP Exercise Evaluation Methodology.

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

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

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

A ARCA(s)assessed A' ARCA(s) assessed, but successfully redemonstrated R Resolved ARCA(s) from prior exercises 15

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION LEGEND: M = Met (no Deficiency or ARCA(s) assessed) A = ARCA(s) assessed A' = ARCA assessed but successfully redemonstrated R = Resolved ARCA(s) froin prior exercises Blank = Not scheduled for demonstration 16

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION LEGEND: M = Met (no Deficiency or ARCA(s) assessed) A = ARCA(s) assessed A' = ARCA assessed but successfully redemonstrated R =Resolved ARCA(s) from prior exercises Blank = Not scheduled for demonstration 17

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION LEGEND: M = Met (no Deficiency or ARCA(s) assessed) A = ARCA(s) assessed A' = ARCA assessed but successfully redemonstrated R = Resolved ARCA(s) from prior exercises Blank = Not scheduled for demonstration 18

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

Met - Listing of the demonstrated exercise evaluation area criteria under which no Deficiencies or ARCAs were assessed during this exercise and under which no ARCAs assessed during prior exercises remain unresolved.

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

Area Requiring Corrective Action - Listing of the demonstrated exercise evaluation area criteria under which one or more ARCAs were assessed during the current exercise. Included is a description of the ARCAs assessed during this exercise and the recommended corrective actions to be demonstrated before or during the next biennial exercise.

Not Demonstrated - Listing of the exercise evaluation area criteria that were scheduled to be demonstrated during this exercise, but were not demonstrated and the reason they were not demonstrated.

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

Prior ARCAs - Unresolved - Descriptions of ARCAs assessed during prior exercises that were not resolved in this exercise. Included are the reasons the ARCAs remain unresolved and recommended corrective actions to be demonstrated before or during the next biennial exercise.

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

A Deficiency is defined in the 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.

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

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

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

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

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

Evaluation Area Criterion - A letter and number corresponding to the criteria in the FEMA REP Exercise Evaluation Methodology.

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

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

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1.0 COMMONWEALTH OF PENNSYLVANIA 1.1 Commonwealth of Pennsylvania EOC (Observed)

a. MET: N/A
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 1.2 Accident Assessment (State BRP) (Observed)
a. MET: N/A
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 1.3 Emergency News Center (ENC)
a. MET: l.b.1 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 21

1.4 Emergency Operations Facility (State BRP) (Observed)

a. MET: N/A
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 1.5 State TraffdAccess Control
a. MET: l.d.1 3.a.l l.e.1 3.b.l 3.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 22

2.0 RISK JURISDICTIONS 2.1 Berks County 2.1.1 Berks County EOC

a. MET: l.a.1 2.a.l 3.a.l 5.a.l l.b.1 2.b.2 3.c.l 5.b.l l.c.1 2.c.l 3.c.2 1.d. 1 3.d. 1 1.e.1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: 1 (3.b.l)

Issue No.: 35-05-3.b.l-A-01 Condition: The decision by the Secretary of the Department of Health for emergency workers to ingest potassium iodide (KI) was not communicated to the Earl Township Emergency Operations Center (EOC).

Possible Cause: Neither the Municipal Liaison or the Radiation Officer at Berks County contacted Earl Township.

Reference:

NUREG-0654, J. 10.e Effect: Emergency Workers could have had their thyroids unnecessarily exposed to radioactive iodine.

Recommendation: Procedures should include a prompt to verify that all municipal EOCs were contacted.

State Response: Additional measures, as needed, and training will be conducted to ensure this issue will be demonstrated during the next scheduled Limerick Generating Station exercise.

d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 23

2.1.2 Emergency Worker MonitoringDecontamination Station (Daniel Boone Complex)

a. MET: l.e.1 3.a.l 6.a.l 6.b. 1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.1.3 Reception and Monitoring/Decontamination Center (Boscovs Outlet)
a. MET: l.e.1 3.a.l 6.a.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. -

PRIOR ARCAs UNRESOLVED: None 2.1.4a MonitoringAlecontamination Center (Hamburg High School)

a. MET: l.e.1 3.a.l 6.a.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 24

2.1.4b Mass Care Center (Hamburg High School)

a. MET: l.e.1 6.c.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.1.5 Colebrookdale Township EOC
a. MET: l.a.1 2.a.l 3.a.l 5.a.l l.b.1 3.b.l l.c.1 3.c.l l.d.1 3.d. 1 1 .e.1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. -

PRIOR ARCAs UNRESOLVED: None 2.1.6 Earl Township EOC

a. MET: l.a.1 2.a.l 3.a.l 5.a.l l.b.1 3.b.l l.c.1 3.c.l l.d.1 3.d.l 1 .e. 1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None 25
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.1.6a Earl Township Route Alerting
a. MET: l.d.1 3.a.l 5.a.l 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 2.1.7 Union Township EOC
a. MET: 1.a.l 2.a.l 3.a.l 5.a.l l.b.1 3.b. 1 l.c.1 3.c.l l.d.1 3.d.l 1.e.1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.2 Chester County 2.2.1 Chester County EOC
a. MET: l.a.1 2.a.l 3.a.l 5.a.l 1.c.l 2.b.2 3.b.l l.d.1 2.c.l 3.c.l 1.e.1 3.c.2 3.d.l 3.d.2 26
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: 1 (5.b.l)

Issue No.: 35-05-5.b.l-A-02 Condition: The Chester County news release at 2103 did not specify that the general public and special populations should ingest potassium iodide (KI).

Possible Cause: At 2008, Pennsylvania Emergency Management Agency (PEMA) provided the Chester County Emergency Operations Center (EOC) with information that KI should be taken according to the State Plan. Further, at 2028, an Emergency Alert System (EAS) message reiterated that the Pennsylvania Secretary of Health recommends that emergency workers, special populations, and the general public take KI. The Chester County Public Information Officer (PIO) did not fully understand both the PEMA message to the Chester County EOC and the EAS message which instructed that the general public and special populations should also take KI.

The P I 0 did not coordinate with PEMA or others to clarify or verify who should take KI and to determine if the Secretary of Health recommended the taking of KI. Also, approximately 30 minutes elapsed from the broadcast of the EAS message until PEMA sent the e-mail version of the EAS message to the Chester County PIO. As a result of the above, the Chester County P I 0 did accurately convey the KI information in the news release.

Reference:

NUREG-0654, E.7 Effect: There could have been confusion by the general public and special populations because the County news release excluded KI information contained in the EAS message. Also, inaccurate information regarding K J could have been given to citizens calling the Chester County Rumor Control.

Recommendation: The PI0 should assure the Chester County news releases are accurate by clarifying any potentially confusing information through discussions with PEMA or other members of the Chester County EOC.

They should monitor TV and radio EAS re-broadcasts.

27

Timely e-mails from PEMA of EAS messages should be provided to the County.

State Response: Additional measures and training, as needed, will be addressed to ensure this Area Requiring Corrective Action will be demonstrated during the next scheduled Limerick Generating Station exercise.

d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.2.2 Emergency Worker MonitoringDecontamination Station (Lionville Middle School)
a. MET: l.e.1 3.a.l 6.a.l 6.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 2.2.3a Reception Center (West Whiteland)

a. MET: l.e.1 3.a.l 6.a.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. -

PRIOR ARCAs UNRESOLVED: None 28

2.2.38 MonitoringlDecontamination Center (West Whiteland)

a. MET: l.e.1 3.a.l 6.a.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.2.4 Mass Care Center (North Brandywine Middle School)
a. MET: l.e.1 6.c.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.2.5 East Pikeland Township EOC
a. MET: 1.a.l 2.a.l 3.a.l 5.a.l 1.b.l 3.b.l 1.c.1 3.c.l 1.d.1 3.d.l 1.e.1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 29

2.2.5a East Pikeland Township Route Alerting

a. MET: l.d.1 3.a.l 5.a.l 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 2.2.6 East Vincent Township EOC

a. MET: l.a.1 2.a.l 3.a.l 5.a.l 1.b.1 3.b.l l.c.1 3.c. 1 1.d.1 3.d. 1 1.e. 1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.2.7 North Coventry Township EOC
a. MET: l.a.1 2.a.l 3.c.l 5.a.l 1.b. 1 3.d.l 1.c. 1 3.d.2 1.d. 1 1.e.1
b. DEFICIENCY: None 30
c. AREAS REQUIRING CORRECTIVE ACTION: 1 (3.a.l and 3.b. 1)

Issue No.: 35-05-3.a.1,3.b.l-A-03 Condition: Emergency Workers did not receive a radiological briefing.

Possible Cause: Neither designated nor alternate Radiological Officers (RO) were familiar with procedures, roles, and responsibilities of the municipal radiological officer.

Reference:

NUREG-0654, K.3.a, b Effect: Emergency workers were not made aware of the proper use of dosimetry and exposure control limits.

Recommendation: Ensure that the RO and designated alternates are provided training on their procedures, roles, and responsibilities.

State Response: Additional training will be conducted to ensure this Area Requiring Corrective Action will be demonstrated during future exercises.

d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.2.8 Phoenixville Borough EOC
a. MET: 1.a.l 2.a.l 3.a.l 5.a.l 1.b.l 3.b.l l.c.1 3.c.l 1.d.l 3.d.l 1.e.1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None 31
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.2.9 Uwchlan Township EOC
a. MET: l.a.1 2.a.l 3.a.l 5.a.l l.b.1 3.b.l l.c.1 3.c.l 1.d.1 3.d. 1 1 .e. 1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.3 Montgomery County 2.3.1 Montgomery County EOC
a. MET: 1.a.l 2.a.l 3.a.l 5.a.l 1.c.l 2.b.2 3.b.l 5.b.l l.d.1 2.c.l 3.c.l l.e.1 3.c.2 3.d.l 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: 1 (5.b. 1Re-demonstrated)

Issue No.: 35-05-5.b.l-A-04 (Re-demonstrated)

Condition: The County Public Information Officer (PIO) issued a news media release (Release #3) advising (in paragraph 2) that an S A E had been declared and that there was an airborne non-routine radiological release in progress above Federal1y-approved operating limits. The same news media release erroneously advised (in 32

paragraph 5 ) that the control rods in the Unit #1 reactor are in place and there has been no release of radiation.

Possible Cause: The PI0 did not delete paragraph 5 which had been issued in release # 2 and was erroneously carried over to release # 3.

Reference:

NUREG-0654, E.5,7; G.3.a, G.4.c Effect: The issuance of conflicting information in this release could cause confusion among the public and emergency workerdoff-site response organizations.

Recommendation: That greater care be exercised in the preparation, review and issuance of news media releases.

Corrective Action Demonstrated: A successful re-demonstration of this element was accomplished through the issuance of a corrected media release #3 which was expeditiously redrafted and issued within five minutes of the original.

d. NOT DEMONSTRATED: None
e. PRIOR ARCAS-RESOLVED: 1 (l.c.1)

Issue No.: 35-03-l.c.1-A-01 Condition: All municipalities in Montgomery County reported problems receiving information from the County Emergency Operations Center (EOC). For example, Collegeville Borough did not receive messages regarding precautionary actions, plant conditions, weather data, press releases, or faxes. Lower Pottsgrove Township did not receive messages regarding plant conditions or precautionary actions. Pottstown Borough did not receive messages regarding weather data, plant conditions, precautionary actions or press releases.

Possible Cause: The County used Radio Amateur Civil Emergency Service (RACES)/Amateur Radio Emergency Services (ARES) as the primary means of communication instead of following the Montgomery County Radiological Emergency Response Procedure which states that the Montgomery County Emergency Management Communication System (800 MHz radio) is the primary means of communication in the County.

33

References:

NUREG-0654, A.2.a Montgomery County RERP, Annex E, Revision 1, July 2003, Appendix 2, Paragraph 4.g, Page E-2-3 Effect: The municipalities might not carry out functions necessary to protect the heath and safety of their citizens.

Recommendation: The County procedure should be followed regarding the use of communications to ensure the receipt of pertinent information.

Corrective Action Demonstrated: All updates of emergency information and decisions and were immediately passed to the municipalities over the County Communication system (800 MHz radio), as the primary means of communication in the County. Similar information was passed by commercial telephone and over the Radio Amateur Civil Emergency Services (RACES) radios to RACES operators located in each Municipality.

Municipalities reported timely receipt of all information.

f. PRIOR ARCAs - UNRESOLVED: None 2.3.2 Emergency Worker MonitoringRIecontamination Station (Indian Valley Middle School)
a. MET: 3.a.l 6.a.l 6.b. 1
b. DEFICIENCY: None
c. AREAS REQUIRINGCORRECTIVEACTION: 2(1.e.l, 6.a.l Re-demonstrated)

Issue No.: 35-05-l.e.1-A-05 Condition: There were insufficient equipment and supplies available on the Montgomery County HAZMAT trailer to support operation of the Indian Valley Middle School Emergency Worker Monitoring and Decontamination Station.

Possible Cause: Equipment and supplies are stored at the Montgomery County Emergency Operations Center and have not been distributed to the mobile facility.

34

Reference:

NUREG-0654, K.3.a, b Montgomery County Plan Appendix 13, Attachment C, Inventory and Maintenance Procedures, August 2005 FEMA-REiP-2lMarch 1995: Contamination Monitoring Standard for a Portal Monitor Used for Radiological Emergency Response Effect:

No permanent record dosimeters (PRDs) were available for the Category C Emergency Workers staffing the Monitoring and Decontamination Station; therefore, their exposure could not be measured as required.

The minimum number of survey instruments was provided. When one of the instruments failed its operational check, a back-up instrument was not available for vehicle monitoring.

One portal monitor was available for personnel monitoring. When it failed its operational check, there was no back-up available and there were no extra survey meters available.

Recommendation: Ensure that there are sufficient equipment and supplies in the County HAZMAT trailer to carry out the required functions.

State Response: This Area Requiring Corrective Action will be demonstrated during the next scheduled Limerick Generating Station exercise. Sufficient equipment and available supplies for use is being addressed to include the proper distribution of drill kit dosimetry and staff training as required.

Issue No.: 35-05-6.a.l-A-06 (Re-demonstrated)

Condition: The setup of the HAZMAT decontamination trailer at the Indian Valley Middle School Emergency Worker Monitoring and Decontamination Station did not allow easy decontamination of hands without spreading the decontamination to other body parts.

Possible Cause: The Montgomery County HAZMAT trailer does not have a wash basin for hand washing.

35

Decontamination methods other than shower wands are not available.

Reference:

NUREG-0654, J.1O.h; J.12; K.5.a Effect: While attempting to use the normal shower sprays to decontaminate hands, the waste water spread the contamination to the workers legs and feet.

Recommendation: Equip the HAZMAT trailer with a wash basin or other decontamination methods for use on isolated areas of decontamination.

Corrective Action Demonstrated: The decontamination of an emergency workers hands was accomplished by having the worker stand outside the shower and insert his arms through the curtains. Although this allowed the hands to be decontaminated without spreading the contamination to other body parts, it was very cumbersome and required that the decontamination team manipulate the shower head remotely.

d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.3.3a Reception Center (Metroplex)
a. MET: 1.e.l 3.a.l 6.a.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.3.3b Monitoring/Decontamination Center (Fire Academy)
a. MET: l.e.1 3.a.l 6.a.l
b. DEFICIENCY: None 36
c. AREAS REQUIRING CORRECTIVE ACTION: 1 (6.a. 1 Re-demonstrated)

Issue No.: 35-05-6.a.l-A-07 (Re-demonstrated)

Condition: The monitoring technique demonstrated at the Montgomery County Monitoring and Decontamination center was unsatisfactory. The probe of the CDV 700 was held too far from the contaminated individual (4 to 5).

Possible Cause: The monitoring team was inexperienced.

Reference:

NUREG - 0654, J.1O.h; J.12; K.5.a Effect: Contamination on the individual could not be detected.

Recommendation: Provide additional training and practice opportunities.

Corrective Action Demonstrated: The monitoring team supervisor provided team members with retraining on the contaminated survey procedure. The team re-demonstrated the individual contamination survey maintaining a probe distance of W to 1. The re-demonstration was performed correctly.

d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.3.4a Mass Care Center (Sandy Run Middle School)
a. MET: l.e.1 6.c.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 37

2.3.4b Mass Care Center (Upper Dublin School)

a. MET: l.e.1 6.c.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.3.4~ Mass Care Center (Upper Moreland Middle School)
a. MET: l.e.1 6.c.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.3.5 Green Lane Borough/ Marborough Township EOC
a. MET: l.a.1 2.a.l 3.a.l 5.a.l l.b.1 3.b.l l.c.1 3.c.l l.d.1 3.d. 1 1 .e.1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 38

2.3.6 Limerick Township EOC

a. MET: l.a.1 2.a.l 3.a.l 5.a.l l.b.1 3.b. 1 1,c.l 3.c.l 1.d. 1 3.d.1 l.e.1 3.d.2
b. DEFICIENCY: None C. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. -

PRIOR ARCAs UNRESOLVED: None 2.3.7 Lower Frederick Township EOC

a. MET: l.a.1 2.a.l 3.a.l 5.a.l l.b.1 3.b.l 1.c. 1 3.c.l 1.d.1 3.d.l l.e.1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.3.8 New Hanover Township EOC
a. MET: l.a.1 2.a.l 3.a.l 5.a.l l.b.1 3.b.l 1.c.l 3.c. 1 l.d.1 3.d.l 1.e. 1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None 39
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.3.9 Perkiomen Township EOC
a. MET: 1.a.l 2.a.l 3.a.l 5.a.l l.b.1 3.b.l 1.c.l 3.c. 1 1.d. 1 3.d.l 1.e. 1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.3.10 Schwenksville Borough EOC
a. MET: 1.a.l 2.a.l 3.c.l 5.a.l 1.b.l 3.d. 1 1.c.l 3.d.2 1.d. 1 1.e. 1
b. DEFICIENCY: None
e. AREAS REQUIRING CORRECTIVE ACTION: 1 (3.a.l and 3.b.l)

Issue No.: 35-05-3.a.1,3.b.l-A-08 Condition: The Schwenksville EOC Radiological Officer briefing was not adequate and did not include radiological monitoring requirements, dosimetry, monitoring procedures, potassium iodide (KI) use, precautions for the ingestion of KI, KI reporting requirements, and other radiological briefing requirements.

40

Possible Cause: The RadioIogical Officer had not been trained for radiological responsibilities and in the use of and precautions for KI ingestion.

Reference:

NUREG-0654, K.3.a, b Effect: Emergency workers did not receive adequate instruction in the use of dosimetry and KI ingestion, and would not be aware of the procedures to manage the control of radiological exposure and the procedures and precautions in ingesting KI.

Recommendation: Provide training in the use of dosimetry and emergency procedures to the Schwenksville Radiological Officer.

State Response: Additional training will be conducted to ensure this Area Requiring Corrective Action will be demonstrated during future exercises.

d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. -

PRIOR ARCAs UNRESOLVED: None 2.3.11 Trappe Borough EOC

a. MET: l.a.1 2.a.l 3.a.l 5.a.l l.b.1 3.b.l 1.c.l 3.c.l l.d.1 3.d.l 1 .e. 1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 41

2.3.11a Trappe Borough Route Alerting

a. MET: l.d.1 3.a.l 5.a.l 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 2.3.12 West Pottsgrove Township EOC

a. MET: l.a.1 2.a.l 3.a.l 5.a.l l.b.1 3 .b. 1 1.c. 1 3.c.l 1.d. 1 3.d. 1 1.e. 1 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 42

3.0 SUPPORT JURISDICTIONS 3.1 Bucks County 3.1.1 Bucks County EOC

a. MET: l.a.l l.c.1 1.d.l 1.e. 1
b. DEFICIENCY: None C. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. -

PRIOR ARCAs UNRESOLVED: None 3.1.2a Reception Center (County Line Plaza)

a. MET: l.e.l 3.a.l 6.a.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. -

PRIOR ARCAs UNRESOLVED: None 3.1.2b Monitoring/Decontamination Center (County Line Plaza)

a. MET: l.e.l 3.a.l 6.a.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None 43
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 3.1.3 Mass Care Center (Palisades Junior/Senior High School)
a. MET: l.e.1 6.c.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.2 Lehigh County 3.2.1 Lehigh County EOC
a. MET: 1.a.l 1.c.l l.d.1 1.e. 1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 3.2.2 Reception Center (Emmaus High School)
a. MET: l.e.1 3.a.l 6.a.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None 44
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.2.3a Monitoring/Decontamination Center (Salisbury High School)
a. MET: l.e.1 3.a.l 6.a.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. -

PRIOR ARCAs UNRESOLVED: None 3.2.3b Mass Care Center (Salisbury High School)

a. MET: 1.e.l 6.c.l
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 45

4.0 SCHOOL DISTRICTS 4.1 Berks County School Districts 4.1.1 Boyertown Area School District (Earl Elementary School)

a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.1.2 Daniel Boone School District (Birdsboro Elementary School)
a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.2 Chester County School Districts 4.2.1 Downington Area School District (Pickering Valley Elementary School)
a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None 46
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.2.2 Great Valley School District (Charlestown Elementary School)
a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.2.3 Owen J. Roberts School District (French Creek Elementary School)
a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. -

PRIOR ARCAs UNRESOLVED: None 4.2.4 Phoenixville Area School District (Barkley Elementary School)

a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. -

PRIOR ARCAs UNRESOLVED: None 47

~~ ~~

4.3 Montgomery County School Districts 4.3.1 Methacton Area School District (Woodland Elementary School)

a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. -

PRIOR ARCAs UNRESOLVED: None 4.3.2 Perkiomen Valley School District (Perkiomen Valley Middle School)

a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.3.3 Pottsgrove School District (Pottsgrove High School)
a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. -

PRIOR ARCAs UNRESOLVED: None 48

4.3.4 Pottstown School District (Pottstown High School)

a. MET: None
b. DEFICIENCY: None C. AREAS REQUIRING CORRECTIVE ACTION: 1 (3.c.2)

Issue No.: 35-05-3.c.2-A-09 Condition: The primary and secondary communications systems between the County Emergency Operations Center and the Pottstown School District Administration Center were inoperable.

Possible Cause: Lack of proper equipment maintenance.

Reference:

NUREG-0654, J.1O.c.d.g Effect: Communication with the districts schools would not have existed or been greatly reduced.

Recommendation: Ensure that responsible officials follow established procedures for communication equipment maintenance.

State Response: School District staff acknowledges the importance of proper functioning communications systems.

The School District will adhere to the equipment maintenance needs. This Area Requiring Corrective Action will be demonstrated during the next Limerick Generating Station exercise.

d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.3.5 Souderton Area School District (Salford Hills Elementary School)
a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None 49
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.3.6 Spring-Ford Area School District (West Center for Tech Studies)
a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. -

PRIOR ARCAs RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.3.7 Upper Perkiomen School District (Upper Perkiomen Middle School)
a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. -

PRIOR ARCAs UNRESOLVED: None 50

APPEN Acronyms and Abbreviations A&N Alert and Notification ACP Access Control Point ALARA As Low As is Reasonably Achievable ARC American Red Cross ARCA Area Requiring Corrective Action BRP Bureau of Radiation Protection CFR Code of Federal Regulations CRD Control Rod Drive DECON Decontamination DRD Direct Reading Dosimeter EAS Emergency Alert System ECL Emergency Classification Level EMS Emergency Medical Service ENC Emergency News Center EOC Emergency Operations Center EOF Emergency Operations Facility EPA U.S. Environmental Protection Agency EPLO Emergency Preparedness Liaison Officer EPZ Emergency Planning Zone FEMA Federal Emergency Management Agency FR Federal Register FRERP Federal Radiological Emergency Response Plan FTC Field Team Coordinator GE General Emergency HS High School KI Potassium Iodide LGS Limerick Generating Station mPh Miles Per Hour mWhr milli-Roentgen(s)/hr MS Middle School 51

MS Medical Services msl Mean Sea Level MSO Maximum Safe Operating Mw Megaw att(s)

N/A Not Applicable NRC U.S. Nuclear Regulatory Commission NUREG-0654 NUREG-0654FEMA-REP-1, Rev. 1 (Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants), November 1980 OEP Office of Emergency Preparedness 00s Out of Service OR0 Offsite Response Organization osc Operations Support Center PAD Protective Action Decision PAG Protective Action Guide PAR Protective Action Recommendation PEMA Pennsylvania Emergency Management Agency PI0 Public Information Officer PRD Permanent Record Dosimeter R Roentgen ( s )

Whr Roentgen(s) per hour RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Service RDCS Rod Drive Control System REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RHR Residual Heat Removal RO Radiological Officer RWCU Reactor Water Clean Up SAE Site Area Emergency SSES Susquehanna Steam Electric Station TCP Traffic Control Point TL Team Leader TLD Thermoluminescent Dosimeter TSC Technical Support Center USDA U.S. Department of Agriculture 52

APPENDIX 2 Exercise Evaluators and earn Leaders The following is a list of the personnel who evaluated the Limerick Generating Station exercise on November 15,2005, and the out-of-sequence demonstrations on August 25,2005 and November 16,2005. Evaluator Team Leaders are indicated by the letters "TL" after their names.

The organization which each evaluator represents is indicated by the following abbreviations:

I FEMA 1 Federal Emergency Management Agencv ICF ICF Consulting NRC Nuclear Rezulatorv Commission POSITION NAME ORGANIZATION RAC Chairman Darrell Hammons FEMA Project Officer Angela Hough FEMA ICF Regional Coordinator Roger Kowieski ICF I. Biennial Plume Exercice -November 15,2005 EVALUATION SITE EVALUATOR ORGANIZATION Commonwealth of Pennsylvania Emergency OperationsCenter Wayne Shych (TL) FEMA Accident Assessment Melody Geer (Tech TL) ICF e

Frank Bold ICF Emergency News Center Paul Nied ICF Emergency OperationsFacility Shem Minnick NRC RISK JURISDICTIONS Berks County County EOC Ken Wierman (TL) FEMA Marcy Campbell ICF Jon Christiansen ICF William Vocke ICF Colebrookdale Township EOC Ken Lott ICF Earl Township EOC Glenn Kinnear ICF Earl Township - Route Alerting Sam Nelson ICF Union Township Richard Holtzman ICF 53

Chester County County EOC John Price (TL,) FEMA Rosemary Samsel ICF David Goldbloom-Helzner ICF Jerry Rossman ICF East Pikeland Township EOC Robert Duggleby ICF East Pikeland Township - Route Alerting Richard Smith ICF East Vincent Township EOC Henry Christiansen ICF North Coventry Township EOC Richard Wessman ICF Phoenixville Borough EOC Ernest Boaze ICF Uwchlan Township EOC Steve Denson ICF Montgomery County County EOC A1 Henryson (TL) FEMA Roy Smith ICF Jan Jackson ICF Bill Wark ICF Green Lane BoroMarborough Twp EOC Larry Visniesky ICF Limerick Township EOC Harold Spedding ICF Lower Frederick Township EOC John Flynn ICF New Hanover Township EOC Walter Gawlak ICF Perkiomen Township EOC Robert Fernandez ICF Schwenksville Borough EOC Gary Goldberg ICF Trappe Borough EOC William Edmunson ICF Trappe Borough Route Alerting David Henry ICF West Pottsgrove Township EOC Charles Phillips ICF SUPPORT JURISDICTIONS Bucks County County EOC Michael Bums ICF Lehigh County County EOC Gregg Dawkins ICF

11. Out-of-SequenceDemonstrations: November 16,2005 9:OO a.m. - 11:OO a.m.

EVALUATION SITE EVALUATOR ORGANIZATION Commonwealth of Pennsylvania State TraffidAccess Control Ed Wojnas ICF RISK SCHOOLS Berks County Boyertown Area School District Bernis Hannah ICF (Earl Elementary School) 54

EVALUATION SITE EVALUATOR ORGANIZATION Daniel Boone Area School District Reggie Rodgers ICF (Birdsboro Elementary School)

Chester County Downington Area School District (Pickering Robert Lemeshka I ICF Valley Elementary School)

Great Valley School District George MacDonald ICF (Charlestown Elementary School)

Owen J. Roberts Area School District Lynn Mariano ICF (French Creek Elementary School)

Phoenixville Area School District Tom McCance ICF (Barkley Elementary School)

Montgomery County Methacton Area School District Neil1 Howey ICF (Woodland Elementary School)

Perkiomen Valley School District Paul Nied ICF (Perkiomen Valley Middle School)

Pottsgrove School District Bart Ray ICF (Pottsgrove High School)

Pottstown Area School District Jerry Staroba ICF (Pottstown High School)

Souderton Area School District Dave Moffet ICF (Salford Hills Elementary School)

Spring-Ford Area School District Tracey Green ICF (Western Center for Tech Studies)

Upper Perkiomen School District Pat Taylor ICF (Upper Perkiomen Middle School) 111. Out-of-SequenceDemonstrations: November 16,2005 7:OO p.m. - 9:30 p.m.

EVALUATION SITE EVALUATOR ORGANIZATION RISK JURISDICTIONS Berks County Emergency Worker Monitoring Ed Wojnas (Tech) ICF Decontamination Station (Daniel Boone Complex)

Reception Center Tom McCance ICF (Boscovs Outlet Center)

Mass Carehlonitoring & Decon Center Lyle Slagle (Tech) ICF (Hamburg High School)

Chester County Emergency Worker Monitoring Pat Taylor (Tech) ICF Decontamination Station (Lionville Middle School) 55

EVALUATION SITE EVALUATOR ORGANIZATION Reception & MonitoringDecon Center David Schweller (Tech) ICF (West Whiteland Township Building)

Montgomery County Emergency Worker Monitoring/ Reggie Rodgers (Tech) ICF Decontamination Station (Indian Valley Middle School)

MonitoringDecon Center (Fire Academy) Tracey Green (Tech) ICF SUPPORT JURISDICTIONS Bucks County Reception & Monitoring/ Decon Center James Reese (Tech) ICF (County Line Plaza)

Lehigh County Reception Center Dennis Wilford ICF (Emmaus High School)

MonitoringDecontamination Center Raymond Wood (Tech) ICF and Mass Care Center (Salisbury K g h School)

IV. Out-of-Sequence Demonstrations: August 25,2005 4:OO p.m. - 7:30 p.m.

EVALUATION SITE EVALUATOR ORGANIZATION RISK JURISDICTIONS Chester County Mass Care Center (N. Brandywine Middle Wayne Shych FEMA School)

Montgomery County Reception Center (Metroplex) Wayne Shych FEMA Mass Care Center (Sandy Run Middle School) Wayne Shych FEMA Mass Care Center (Upper Dublin School) Wayne Shych FEMA Mass Care Center (Upper Moreland Middle Wayne Shych FEMA School)

Bucks County Mass Care Center (Palisades Jr/Sr High Wayne Shych FEMA School) 56

Exercise Evaluation Area Criteria and Extent o lay Agreement LIMERICK GENERATING STATION 2005 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE METHOD OF OPERATION Revised Final 8/19/05

1. Limerick Generating Station (LGS)

The facility normally uses off-watch section personnel to participate in the exercise. The plant's simulated events, radiation readings, and emergency classifications will trigger offsite exercise actions.

2. Bureau of Radiation Protection (BRP)

Personnel will be present at the State EOC, the nuclear facility EOF and field locations; however, BRP field team personnel will not be evaluated.

3. PEMA Operations at State EOC PEMA Bureau of Operations staff, augmented by designated PEMA personnel from the Fire Commissioner's Office, the Bureaus of Administration, Technical Services, Plans, plus Emergency Preparedness Liaison Officers (EPLOs) with accompanying response team members from designated State departments/agencies,including representatives from the USDA State Emergency Board, will comprise initial operations at the State EOC. The State EOC will not be evaluated.
4. PEMA Regional Office Operations The State Area Offices at Hamburg and Hamsburg will not be activated and will staff control cells. Neither Area Offices will be evaluated.
5. Counties Designated to Participate Berks, Chester, and Montgomery Counties, in coordination with PEMA, will demonstrate the capability to implement emergency response operations to include sheltering and/or evacuation. County government will provide direction and coordination to risk municipalities. Bucks and Lehigh Counties will participate in their assigned support roles.

57

6. PEMA Liaison Officers Liaison officers will be present at the participating risk county EOC, the LGS Emergency Operations Facility (EOF), and Emergency News Center (ENC) to provide assistance, guidance, and support. These liaison officers will participate as players in the exercise.
7. Controllers Exelon Nuclear Corp. will provide controllers at the monitoring/decontaminating stations, monitoring/ decontamination centers and BRP field team locations.
8. PEMA Observers PEMA staff, qualified county emergency management personnel, andor nuclear power plant personnel will be assigned if required to key locations for the purpose of observing, noting response actions and conditions, and recording observations for future use.

Observers will not take an active part in the proceedinEs, but will interact with staff members to the extent necessary to fulfill their observer responsibilities. Coaching of players by observers is not permitted except to provide training to participants awaiting a re-demonstration. (Refer to paragraph 13)

9. FEMA Evaluators Federal evaluators will be present at the risk and support county EOCs and risk municipal EOCs, and at appropriate field locations to evaluate player response to the actual and simulated events in the exercise scenario. FEMA will evaluate one-third of the risk municipalities in Berks, Chester, and Montgomery Counties.
10. Demonstration Windows The demonstration windows are those periods of time designated in the exercise during which specified demonstrations will be accomplished out of sequence. The purpose of the windows is to provide for more effective demonstrations as well as permitting the release of volunteers from the exercise play at a reasonable hour. There will be out-of-sequence demonstrations during the exercise.

The out-of-sequence MS-1 hospital demonstration was evaluated at Reading Hospital on May 25,2005.

The window for school demonstrations will be conducted out-of-sequence from 9:OO - 11:OO a.m. on November 16,2005.

County and municipal EOC operations will be conducted on the evening of November 15,2005.

58

The demonstration for reception centers,

  • mass care centers, monitoring/ decontamination centers and stations will be conducted out-of-sequence from 7:OO - 9:30 p.m. on November 16,2005.
  • Five mass care centers, three in Montgomery County and one each in Bucks and Chester Counties will receive walk-down baseline evaluations on Thursday, August 25,2005.

These five mass care centers will not be evaluated during the evening of November 16has they are not co-located with monitoring decontamination centers. Mass care centers in Berks and Lehigh Counties will be evaluated on the evening of November 16th.

The out-of-sequence demonstration Pennsylvania State Police traffic control/access control points will be from 9:00 a.m. - 11:OO a.m. on November 16,2005.

All demonstrations will commence promptly and, barring any complications, not continue past the end of the windows. (Refer to extent of Play Demonstration Tables)

11. Stand-down All jurisdictions will request approval on a jurisdiction by jurisdiction basis prior to stand-down.
a. Upon completion of all requirements and after having informed the FEMA evaluator that all evaluation areas have been demonstrated and/or completed, the risk municipality EOCs may request approval from their county EOC to terminate the exercise.
b. Support counties may likewise request approval to terminate the exercise upon completion of all evaluated objectives from the state EOC.
c. The risk county EOC will remain operational until the exercise is officially terminated by the State.
12. General Concepts An emergency plan is drafted to address the generally expected conditions of an emergency. Not everything in the emergency plan may be applicable for a given scenario. The main purpose of an emergency plan is to assemble sufficient expertise and officials so as to properly react to the events as they occur. The responders should not be so tied to a plan that they cannot take actions that are more protective of the public.

Therefore, if, by not following the plan, the responders protect the public equally as well as provided in the plan, it should be noted for possible modification of the plan, but not classified as a negative incident. Furthermore, if, by following the plan there is a failure to protect the public health and safety, it should be noted so that the plan can be modified and the appropriate negative assessment applied.

59

13. Re-demonstrations During the out of sequence demonstrations or the plume phase demonstrations any activity that is not satisfactorily demonstrated may be re-demonstrated by the participants during the exercise provided it does not negatively interfere with the exercise. Refresher training can be provided by the players, observers, and/or controllers. Evaluators are not permitted to provide refresher training. Re-demonstrations will be coordinated between the players, observers, controllers, and evaluators with prior approval from the RAC Chair. It is permissible to extend the evaluation time to accommodate the re-demonstration.

Activities corrected from a re-demonstration will be so noted.

60

LIMERICK GENERATING STATION 2005 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE EXTENT OF PLAY AGREEMENT EVALUATION AREA 1 Emergency Operations Management Sub-element 1.a - Mobilization INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to alert, notify, and mobilize emergency personnel and to activate and staff emergency facilities.

Criterion l.a.1: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654, A.4; D.3,4; E.l, 2; H.4)

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

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

PEMA Negotiated Extent of Play:

State agencies, risk and support counties may be pre-positioned during the plume. Counties will discuss call-out procedures and provide 24-hour stafing lists. All risk municipalities will demonstrate call-outs. All out-of sequence players and equipment will be pre-positioned.

Commonwealth personnel reporting to the EOF, ENC and TSC not anticipate admittance prior to activation of the utility sites. This does not apply to the PEMA satellite crew to the ENC.

61

Sub-element 1.b - Facilities INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have facilities to support the emergency response.

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

(NUREG-0654, H.3)

EXTENT OF PLAY Facilities will only be specifically evaluated for this criterion if they are new or have substantial changes in structure or mission. Responsible OROs should demonstrate the availability of facilities that support the accomplishment of emergency operations. Some of the areas to be considered are: adequate space, furnishings, lighting, restrooms, ventilation, backup power andor alternate facility (if required to support operations.)

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

PEMA Negotiated Extent of Play:

One-third of O R 0 facilities will be evaluated during this exercise in order to establish a baseline.

Sub-element 1.c - Direction and Control INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to control their overall response to an emergency.

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.

(NUREG-0654, A.1.d; A.Z.a, b)

EXTENT OF PLAY Leadership personnel should demonstrate the ability to carry out essential functions of the response effort, for example: keeping the staff informed through periodic briefings and/or other means, coordinating with other appropriate OROs, and ensuring completion of requirements and requests.

62

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

PEMA Negotiated Extent of Play: None Sub-element 1.d - Communications Equipment INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should establish reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as the following:

appropriate contiguous governments within the emergency planning zone (EPZ), Federal emergency response organizations, the licensee and its facilities, emergency operations centers (EOC), and field teams.

Criterion l.d.1: A t least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations. (NUREG-0654, F.l, 2)

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

OROs should ensure that a coordinated communication link for fixed and mobile medical support facilities exists. The specific communications capabilities of OROs should be commensurate with that specified in the response plan and/or procedures. Exercise scenarios could require the failure of a communications system and the use of an alternate system, as negotiated in the extent of play agreement.

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

PEMA Negotiated Extent of Play: None 63

Sub-element 1.e - Equipment and Supplies to Support Operations INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have emergency equipment and supplies adequate to support the emergency response.

Criterion l.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG-0654,H.7, 10; J.lO.a, b, e, J.11; K.3.a)

EXTENT OF PLAY Equipment within the facility (facilities) should be sufficient and consistent with the role assigned to that facility in the OROs plans andor procedures in support of emergency operations. Use of maps and displays is encouraged.

All instruments should be inspected, inventoried, and operationally checked before each use.

Instruments should be calibrated in accordance with the manufacturers recommendations.

Unmodified CDV-700 series instruments and other instruments without a manufacturers recommendation should be calibrated annually. Modified CDV-700 instruments should be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration should be on each instrument, or calibrated frequency can be verified by other means. Additionally, instruments being used to measure activity should have a range of reading sticker affixed to the side of the instrument. The above considerations should be included in 4.a.l for field team equipment; 4.c. 1 for radiological laboratory equipment (does not apply to analytical equipment; reception center and emergency worker facilities equipment under 6.a. 1; and ambulance and medical facilities equipment under 6.d. 1.

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

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

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

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

64

Quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical inspection at storage location(s) or through documentation of current inventory submitted during the exercise, provided in the Annual Letter of Certification submission, and/or verified during a Staff Assistance Visit. Available supplies of KI should be within the expiration date indicated on KI bottles or blister packs. As an alternative, the OR0 may produce a letter from a certified private or State laboratory indicating that the KI supply remains potent, in accordance with U.S.

Pharmacopoeia standards.

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

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

PEMA Negotiated Extent of Play:

In Pennsylvania CDV-700s are calibrated every 4-years.

Leakage testing verification and KI extension letters will be available to the evaluator upon request.

65

EVALUATION AREA 2 Protective Action Decision-Making Sub-element 2.a - Emergency Worker Exposure Control INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place, as specified in the OROs plans and procedures, to authorize emergency worker exposure limits to be exceeded for specific missions.

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

Criterion 2.a.l: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.

(NUREG-0654, K.4, J.lO.e, 9 EXTENT OF PLAY OROs authorized to send emergency workers into the plume exposure pathway EPZ should demonstrate a capability to meet the criterion based on their emergency plans and procedures.

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

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

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

PEMA Negotiated Extent of Play: None 66

Sub-element 2.b - Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to use all available data to independently project integrated dose and compare the estimated dose savings with the protective action guides. OROs have the capability to choose, among a range of protective actions, those most appropriate in a given emergency situation. OROs base these choices on PAGs from the OROs plans and procedures or EPA 400-R-92-001 and other criteria, such as, plant conditions, licensee protective action recommendations, coordination of protective action decisions with other political jurisdictions (for example, other affected OROs), availability of appropriate in-place shelter, weather conditions, and situations that create higher than normal risk from evacuation.

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

This criterion will not be evaluated during this exercise.

Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PAD) for the general public (including the recommendation for the use of KI, if O R 0 policy). (NUREG-0654,J.9, lO.f, m)

EXTENT OF PLAY OROs should have the capability to make both initial and subsequent PADs. They should demonstrate the capability to make initial PADs in a timely manner appropriate to the situation, based on notification from the licensee, assessment of plant status and releases, and PARs from the utility and OR0 staff.

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

If the OR0 has determined that KI will be used as a protective measure for the general public under off-site plans, then the OR0 should demonstrate the capability to make decisions on the distribution and administration of KI as a protective measure for the general public to supplement shelter and evacuation. This decision should be based on the OROs plan and/or procedures or projected thyroid dose compared with the established FAG for KI administration.

The KI decision-making process should involve close coordination with appropriate assessment and decision-making staff.

67

If more than one O R 0 is involved in decision-making, OROs should communicate and coordinate PADSwith affected OROs. OROs should demonstrate the capability to communicate the contents of decisions to the affected jurisdictions.

All decision-makingactivities by O R 0 personnel must be performed based on the OROs plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA Negotiated Extent of Play: None Sub-element 2.c - Protective Action Decisions Consideration for the Protection of Special Populations INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to determine protective action recommendations, including evacuation, sheltering and use of potassium iodide (KI), if applicable, for special population groups (for example, hospitals, nursing homes, correctional facilities, schools, licensed day care centers, mobility impaired individuals, and transportation dependent individuals). Focus is on those special population groups that are (or potentially will be) affected by a radiological release from a nuclear power plant.

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

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

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

In accordance with plans and/or procedures, OROs and/or officials of pubic school systems/districts should demonstrate the capability to make prompt decisions on protective actions for students. Officials should demonstrate that the decision making process for protective actions considers (that is, either accepts automatically or gives heavy weight to) protective action recommendations made by O R 0 personnel, the ECL at which these 68

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

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

PEMA Negotiated Extent of Play: None Sub-element 2.d - Radiological Assessment and Decision-Making for the Ingestion Exposure Pathway This sub-element will not be evaluated during this exercise.

Sub-element 2.e - Radiological Assessment and Decision-Making Concerning Relocation, Re-entry, and Return This sub-element will not be evaluated during this exercise.

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EVALUATION AREA 3 Protective Action Implementation Sub-element 3.a - Implementation of Emergency Worker Exposure Control INTENT This sub-element derives from NUREG-0654, which provides that OROs should have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; the reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for each emergency worker; and establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of protective action guides, always applying the ALARA (As Low As is Reasonably Achievable) principle as appropriate.

Criterion 3.a.l: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. (NUREG-0654, K.3.a, b)

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

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

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

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

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

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

PEMA,Negotiated Extent of Play:

Radiological briefings will be provided to address exposure limits and procedures to replace those approaching limits and how permission to exceed limits is obtainedfrom the municipality and county. Emergency workers will also be briefed on when to take KI and on whose authority.

Distribution of KI will be simulated. The completion of a KI report form will be demonstrated.

OROs should also demonstrate the use of all dosimetryforms to emergency workers.

At any time, players may ask other players or supervisors to clarify radiological information.

In Pennsylvania, emergency workers outside of the EPZ do not have tumback values.

Emergency workers who are assigned to low exposure rate areas, e.g., at reception centers, counting laboratories, emergency operations centers, and communications centers, may have individual direct-reading dosimeters or they may be monitored by dosimeters strategically placed in the work area. In Pennsylvania this will be accomplished through the use of an area kit.

Standard issue of dosimetry and potassium iodide for each category of emergency worker is as follows:

Category A: I PRD, 1 DRD, and 1 unit of KI Category B: I PRD and I unit of KI Category C: I PRD Sample kits will be pre-distributed to the municipalities for demonstration purposes. These sample kits will consist of 5-DRDs, charger, simulated PRDs and simulated KI, and instructions.

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Sub-element 3.b - Implementation of KI Decision INTENT This sub-element derives from NUREG-0654,which provides that Offsite Response Organizations (ORO) should have the capability to provide radioprotective drugs for emergency workers, institutionalized individuals, and, if in the plan and/or procedures, to the general public for whom immediate evacuation may not be feasible, very difficult, or significantly delayed. While it is necessary for OROs to have the capability to provide KI to emergency workers and institutionalized individuals, the provision of KI to the general public is an OR0 option and is reflected in OROs plans and procedures. Provisions should include the availability of adequate quantities, storage, and means of the distribution of radioprotective drugs.

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 is maintained.

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

EXTENT OF PLAY Offsite Response Organizations (ORO) should demonstrate the capability to make KI available to emergency workers, institutionalized individuals, and, where provided for in the O R 0 plan and/or procedures, to members of the general public. OROs should demonstrate the capability to accomplish distribution of KI consistent with decisions made. Organizations should have the capability to develop and maintain lists of emergency workers and institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest KI. The ingestion of KI recommended by the designated O R 0 health official is voluntary.

For evaluation purposes, the actual ingestion of KI is not necessary. OROs should demonstrate the capability to formulate and disseminate appropriate instructions on the use of KI for those advised to take it. If a recommendation is made for the general public to take KI, appropriate information should be provided to the public by the means of notification specified in the OROs plan andor procedures.

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

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

PEMA Negotiated Extent of Play:

Pennsylvania plans call for pre-distribution of KI to the general public.

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Evaluation of KI quantities emergency workers will be verified using inventory sheets and no KI will be removed from the storage location. Boxes will not be opened. KI questions will be addressed through interviews.

Monitoring/decontaminationcenters and stations personnel are not issued DRDs/KI since the centers/stations are located outside the EPZ.

Sub-element 3.c - Implementation of Protective Actions for Special Populations INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to implement protective action decisions, including evacuation and/or sheltering, for all special populations. Focus is on those special populations that are (or potentially will be) affected by a radiological release from a nuclear power plant.

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

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

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

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

PEMA Negotiated Extent of Play:

Lists of people with special needs are maintained at the municipal EOCs. Copies of these lists will not be provided to the evaluators however; evaluators will be able to inspect these lists during the exercise.

Initial contact with special populations and reception facilities will be actual (hospitals, nursing homes and correctional facilities). All subsequent calls will be simulated. Actual contacts (up to 73

two) will be made with transportation providers as per plan. All actual and simulated contacts should be logged.

Criterion 3.c.2: OROs/School officials implement protective actions for schools.

(NUREG-0654,J.lO.c, d, g)

EXTENT OF PLAY Public school systems/districts shall demonstrate the ability to implement protective action decisions for students. The demonstration shall be made as follows: At least one school in each affected school system or district, as appropriate, needs to demonstrate the implementation of protective actions. The implementation of canceling the school day, dismissing early, or sheltering should be simulated by describing to evaluators the procedures that would be followed. If evacuation is the implemented protective action, all activities to coordinate and complete the evacuation of students to reception centers, congregate care centers, or host schools may actually be demonstrated or accomplished through an interview process. If accomplished through an interview process, appropriate school personnel including decision making officials (e.g., superintendent/principal, transportation directorhus dispatcher), and at least one bus driver (and the bus drivers escort, if applicable) should be available to demonstrate knowledge of their role(s) in the evacuation of school children. Communications capabilities between school officials and the buses, if required by the plan and/or procedures, should be verified.

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

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

All activities must be based on the O R 0 3 plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA Negotiated Extent of Play:

Evacuation of students will be conducted through an interview process.

Role of the bus driver may be conducted through an interview with school or transportation oficials i f a bus driver is not available. Actual demonstration of the bus route is not required and will not be demonstrated.

Risk County school plans do not require communications between the school and vehicles.

Private schools, private kindergartens, and day care centers do not participate in REP exercises.

However, OROs will be prepared to show evaluators lists of thesefacilities that they will contact in the event of an emergency in accordance with plans and procedures.

74 I .

Sub-element 3.d - Implementation of Traffic and Access Control INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to implement protective action plans, including relocation and restriction of access to evacuatedsheltered areas. This sub-element focuses on selecting, establishing, and staffing of traffic and access control points and removal of impediments to the flow of evacuation traffic.

Criterion 3.d.l: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654, J.lO.g, j)

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

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

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

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

PEMA Negotiated Extent of Play:

Ti-afic and access control will be demonstrated by interview - no deployment. A radiological briefing will be provided.

Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654, J.1O.k)

EXTENT OF PLAY 75

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

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

PEMA Negotiated Extent of Play:

Upon request municipal and county stafs will be prepared to brief the evaluator on actions to be taken should there be an impediment to evacuation on a designated route.

Sub-element3.e - Implementation of Ingestion Pathway Decisions This sub-element will not be evaluated during this exercise.

Sub-element3.f - Implementation of Relocation, Re-entry, and Return Decisions This sub-element will not be evaluated during this exercise.

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EVALUATION AREA 4 Field Measurement and Analysis Sub-element 4.a - Plume Phase Field Measurements and Analyses INTENT This sub-element derives from NUREG-0654, which provides that OROs should have the capability to deploy field teams with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654 indicates that OROs should have the capability to use field teams within the plume emergency planning zone to measure airborne radioiodine in the presence of noble gases and to measure radioactive particulate material in the airborne plume. In the event of an accident at a nuclear power plant, the possible release of radioactive material may pose a risk to the nearby population and environment. Although accident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties. During an accident, it is important to collect field radiological data in order to help characterize any radiological release. Adequate equipment and procedures are essential to such field measurement efforts.

Criterion 4.a.l: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates. (NUREG-0654, H.lO; I.7,8,9)

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

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

PEMA Negotiated Extent of Play:

This sub-element will not be evaluated during this exercise.

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Criterion 4.a.2: Field teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654, H.12; I.&, 11; J.1O.a).

PEMA Negotiated Extent of Play:

This sub-element will not be evaluated during this exercise.

Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654,I.g)

EXTENT OF PLAY Field teams should demonstrate the capability to report measurements and field data pertaining to the measurement of airborne radioiodine and particulates and ambient radiation to the field team coordinator, dose assessment, or other appropriate authority. If samples have radioactivity significantly above background, the appropriate authority should consider the need for expedited laboratory analyses of these samples. OROs should share data in a timely manner with all appropriate OROs. All methodology, including contamination control, instrumentation, preparation of samples, and a chain-of-custody form for transfer to a laboratory, will be in accordance with the O R 0 plan and/or procedures.

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

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

PEMA Negotiated Extent of Play:

This sub-element will not be evaluated during this exercise.

Sub-element 4.b - Post Plume Phase Field Measurements and Sampling This sub-element will not be evaluated during this exercise.

Sub-element 4.c - Laboratory Operations This sub-element will not be evaluated during this exercise.

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EVALUATION AREA 5 Emergency Notification and Public Information Sub-element 5.a - Activation of the Prompt Alert and Notification System INTENT This sub-element derives from NUREG-0654, which provides that OROs should have the capability to provide prompt instructions to the public within the plume pathway EPZ. Specific provisions addressed in this sub-element are derived from the Nuclear Regulatory Commission (NRC) regulations (10 CFR Part 50, Appendix E.N.D.), and FEMA-REP-IO, Guide for the Evaluation of Alert and Notification systems for Nuclear Power Plants.

Criterion 5.a.l: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current FEMA REP guidance. (10 CFR Part 50,Appendix E.1V.D and NUREG-0654, E.5,6,7)

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

Offsite Response Organizations (OROs) with route alerting as the primary method of alerting and notifying the public should demonstrate the capability to accomplish the primary route alerting, following the decision to activate the alert and notification system, in a timely manner (will not be subject to specific time requirements) in accordance with the OROs plan and/or procedures. At least one route needs to be demonstrated and evaluated. The selected route(s) should vary from exercise to exercise. However, the most difficult route should be demonstrated at least once every six years. All alert and notification activities along the route should be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast) as agreed upon in the extent of play. Actual testing of the mobile public address system will be conducted at some agreed upon location. The initial message should include the elements required by current FEMA REP guidance.

For exercise purposes, timely is defined as the responsible O R 0 personnel/representatives demonstrate actions to disseminate the appropriate infonnatiodinstructions with a sense of urgency and without undue delay. If message dissemination is to be identified as not having 79

been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

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

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

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

PEMA Negotiated Extent of Play:

Actual contact will take place with the radio stations as per county plans. All subsequent actions to broadcast stations will be simulated. Systems that use automatic sending technology may be demonstrated by interview.

One municipality per risk county will demonstrate route alerting for hearing impaired residents within their jurisdiction.

Criterion 5.a.2: [RESERVED]

Criterion 5.a.3: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.

Backup alert and notification of the public is completed within 45 minutes following the detection by the O R 0 of a failure of the primary alert and notification system.

(NUREG-0654, E.6, Appendix 3.B.2.c)

EXTENT OF PLAY Offsite Response Organizations (ORO) with =MA-approved exception areas (identified in the approved Alert and Notification System Design Report) 5-10 miles from the nuclear power plant should demonstrate the capability to accomplish primary alerting and notification of the exception area@)within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The 45-minute clock will begin when the OROs make the decision to activate the alert and notification system for the first time for a specific emergency situation. The initial message should, at a minimum, include: a statement that an emergency exists at the plant and where to obtain additional information.

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

Backup alert and notification of the public should be completed within 45 minutes following the detection by the O R 0 of a failure of the primary alert and notification system. Backup route alerting only needs to be demonstrated and evaluated, in accordance with the OROs plan and/or procedures and the extent of play agreement, if the exercise scenario calls for failure of any portion of the primary system(s), or if any portion of the primary system(s) actually fails to function. If demonstrated, only one route needs to be selected and demonstrated. All alert and notification activities along the route should be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast) as agreed upon in the extent of play. Actual testing of the mobile public address system will be conducted at some agreed-upon location.

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

PEMA Negotiated Extent of Play:

There are no exception areas in the LGS EPZ.

Sub-element 5.b - Emergency Information and Instructions for the Public and the Media INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to disseminate to the public appropriate emergency information and instructions, including any recommended protective actions. In addition, NUREG-0654 provides that OROs should ensure that the capability exists for providing information to the media. This includes the availability of a physical location for use by the media during an emergency. NUREG-0654 also provides that a system should be available for dealing with rumors. This system will hereafter be known as the public inquiry hotline.

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Criterion 5.b.l: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E.5,7; G.3.a,

.4.c)

EXTENT OF PLAY Subsequent emergency information and instructions should be provided to the public and the media in a timely manner (will not be subject to specific time requirements). For exercise purposes, timely is defined as the responsible OR0 personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay. If message dissemination is to be identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

The O R 0 should ensure that emergency information and instructions are consistent with protective action decisions made by appropriate officials. The emergency information should contain all necessary and applicable instructions (for example, evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, information concerning pets, shelter-in-place instructions, information concerning protective actions for schools and special populations, public inquiry telephone number, etc.) to assist the public in carrying out protective action decisions provided to them. The O R 0 should also be prepared to disclose and explain the Emergency Classification Level (ECL) of the incident. At a minimum, this information must be included in media briefings and/or media releases. OROs should demonstrate the capabihty to use language that is clear and understandable to the public within both the plume and ingestion pathway EPZs. This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas.

The emergency information should be all-inclusive by including previously identified protective action areas that are still valid, as well as new areas. The OROs should demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. In addition, the OROs should demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plan and/or procedures.

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

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

OROs should demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the situation warrants. The OROs should demonstrate the capability to respond appropriately to inquiries from the news media. All information presented in media briefings and media releases should be consistent with protective action decisions and other 82

emergency information provided to the public. Copies of pertinent emergency information (e.g.,

EAS messages and media releases) and media information kits should be available for dissemination to the media.

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

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

PEMA Negotiated Extent of Play: None 83

EVALUATION AREA 6 Support OperatiodFacilities Sub-element 6.a - Monitoring and Decontamination of Evacuees and Emergency Workers and Registration of Evacuees INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to implement radiological monitoring and decontamination of evacuees and emergency workers, while minimizing contamination of the facility, and registration of evacuees at reception centers.

Criterion 6.a.l: The reception centedemergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers.

(NUREG-0654, J.1O.h; 5.12; K.5.a)

EXTENT OF PLAY Radiological monitoring, decontamination, and registration facilities for evacuees/ emergency workers should be set up and demonstrated as they would be in an actual emergency or as indicated in the extent of play agreement. This would include adequate space for evacuees vehicles. Expected demonstration should include 1/3 of the monitoring teams/portal monitors required to monitor 20% of the population allocated to the facility within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Before using monitoring instrument(s), the monitor(s) should demonstrate the process of checkmg the instrument(s) for proper operation.

Staff responsible for the radiological monitoring of evacuees should demonstrate the capability to attain and sustain a monitoring productivity rate per hour needed to monitor the 20%

emergency planning zone (EPZ) population planning base within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This monitoring productivity rate per hour is the number of evacuees that can be monitored per hour by the total complement of monitors using an appropriate monitoring procedure. A minimum of six individuals per monitoring station should be monitored, using equipment and procedures specified in the plan and/or procedures, to allow demonstration of monitoring, decontamination, and registration capabilities. The monitoring sequences for the first six simulated evacuees per monitoring team will be timed by the evaluators in order to determine whether the twelve-hour requirement can be meet. Monitoring of emergency workers does not have to meet the twelve-hour requirement. However, appropriate monitoring procedures should be demonstrated for a minimum of two emergency workers.

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

The availability of provisions for separately showering should be demonstrated or explained. The staff should demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs and appropriate means (for example, partitions, roped-off areas) to separate clean from potentially contaminated areas. Provisions should also exist to separate contaminated and uncontaminated individuals, provide changes of clothing for individuals whose 84

clothing is contaminated, and store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities. In addition, for any individual found to be contaminated, procedures should be discussed concerning the handling of potential contamination of vehicles and personal belongings.

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

The capability to register individuals upon completion of the monitoring and decontamination activities should be demonstrated. The registration activities demonstrated should include the establishment of a registration record for each individual, consisting of the individuals name, address, results of monitoring, and time of decontamination, if any, or as otherwise designated in the plan. Audio recorders, camcorders, or written records are all acceptable means for registration.

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

PEMA Negotiated Extent of Play:

Expected demonstration should include a roster of the monitoring teams/portal monitors required to monitor 20% of the population allocated to the facility within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

A minimum of six individuals per monitoring station should be monitored (or one person six times)....

Waterfrom decontamination activities may go directly to a storm drain or other sewer or drain system or area normally designated for wastewater that has been used for bathing or washing of vehicles and or equipment.

At each reception center, a minimum of three volunteer evacuees will be processed, briefed, issued the appropriate strip map or directions, and instructed to proceed to a mass care center designated for demonstration of monitoring, decontamination, and registration. A sample of the appropriate strip maps or directions will be made available for the demonstration.

One mass care center and one monitoring/decontaminationcenter per risk county will be demonstrated during the out-of sequence window. All monitoring and decontamination teams will demonstrate monitoring, decontamination and registration procedures at one mass care center or reception center (as applicable) per county. The risk counties will provide space at designated mass care centers or reception center (as applicable) for operation of monitoring/decontaminationcenters. Schematics of these monitoring /decontamination centers will be available to show organization within the facility and space management for monitoring and for decontamination of the evacuating public. Procedures will be demonstrated to show 85

minimizing contamination of the facility and separation of contaminated and non-contaminated (clean) individuals.

At the evacuee monitoring/decontamination centers each team, consisting of a minimum of two persons (monitor and recorder), will monitor a minimum of six (6)volunteer evacuees or one ( I )

volunteer evacuee six times , complete the MonitoringLDecontaminationReport Form (either by demonstration or explanation), and instruct the evacuees to proceed to the mass care registration points for firther processing. The teams will demonstrate: radiological monitoring of at least one vehicle and the simulated decontamination of at least two evacuees, one unable to be decontaminated based on controller inject data. Discussions concerning processing of contaminated personnel will include capabilities and written procedures for showering females separate from males A CD V-700,or other survey meter, will be issued to team. For Portal Monitor Use refer to paragraph below. PRDs will be simulated.

At the emergency worker monitorinddecontamination stations each team, consisting of a minimum of two persons (monitor and recorder), will monitor one emergency worker, complete the Monitoring/DecontarninationReport Form (either by demonstration or explanation.)

Discussions concerning processing of contaminated personnel will include capabilities and written procedures for showering females separate from males. A CD V-700,or other survey meter, will be issued to & team. For Portal Monitor Use refer to next paragraph. PRDs will be simulated.

(Portal Monitor Use) Risk and Support counties may, during this exercise, utilize portal monitors to monitor simulated evacuees, emergency workers and/or vehicles. In the instances where a portal monitor is used a draft/interim procedure/guidelines may be used, for this evaluation. The monitoring/ decontamination team requirements will be based on the portal monitor capabilities as applicable based on the drafhterim procedure/guidelines, and manufactures recommendations.

Monitoring/decontamination centers and station personnel are not issued DRDs or KI since the centers and stations are outside the EPZ.

Radiation contamination data for the evacuees and vehicle will be provided by the controller and must be included in the scenario package. Set-up of the facility will be pegormed the same as for an actual emergency with all route markings and contamination control measures in place including step-oflpads; with the exception of long runs of plastic covered with paper which will not be demonstrated, but the materials will be available and explained. Positioning of afire apparatus on-site may be simulated if otherwise required.

Sub-element 6.b - Monitoring and Decontamination of Emergency Worker Equipment INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to implement radiological monitoring and decontamination of emergency worker equipment, including vehicles.

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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. (NUREG-0654, K.5.b)

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

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

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

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

PEMA Negotiated Extent of Play:

Emergency worker station personnel will consist of a minimum of one monitor and one recorder and suficient personnel to demonstrate monitoring of at least one vehicle. Schematics of these monitoring/decontamination stations will be available to show organization and space management within the facility. The evaluator will request that decontamination procedures be explained after the vehicle which has simulated contamination has been monitored. One CD V-700, or other survey meter, will be issued to each monitoring/decontamination team. One vehicle andor piece of equipment will not be able to be decontaminated. Simulated radiation contamination data will be included in the scenario package, and injected by a controller. Set-up of the facility will be pe$ormed as closely as possible to that for an actual emergency with all route markings in place including step-ofSpads; with the exception of long runs of plastic covered with paper which will not be demonstrated, but the materials will be available and explained.

Decontamination capabilities, and provisions for vehicles and equipment that can not be decontaminated, y J be simulated and conducted by interview.

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Sub-element 6.c - Temporary Care of Evacuees INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) demonstrate the capability to establish relocation centers in host areas. The American Red Cross (ARC) normally provides congregate care in support of OROs under existing letters of agreement.

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. (Found in MASS CARE Preparedness Operations, ARC 3031) Managers demonstrate the procedures to assure that evacuees have been monitored for contamination and have been decontaminated as appropriate before entering congregate care facilities. (NUREG-0654, J.lO.h, 5.12)

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

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

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

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

PEMA Negotiated Extent of Play:

Capabilities will be demonstrated through an interview process. Personnel, at a minimum, will consist of one manager and assistant for each mass care center opened.

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Sub-element 6.d - Transportation and Treatment of Contaminated Injured Individuals This sub-element will be evaluated at Reading Hospital on May 25,2005.

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APPEN Exercise Scenario Constellation Energy Group Emergency Scenario Summary Limerick Generating Station November 15,2005 TIME EVENT DESCRIPTION LGS Initial Conditions:

Unit 1 - 100% power for the last 183 days. All Unit 1 systems and equipment are operable except as noted below.

Unit 2 - 100% power for the last 238 days. All Unit 2 systems and equipment are operable except as noted below.

Out-Of-Service (00s)Equipment:

Unit 1 - HV-51-1F027A blocked and out of service for repair due to failing to open during ST-6-051-231-1.

Unit 2 -None.

On-coming Shift ActionsDuties:

Maintain 100%power on Units 1 and 2.

Weather ConditiondForecast:

Partly sunny today with light winds from the northwest. Highs today will be in the low-to-mid 50s. Probability of precipitation is 40%. The skies will become cloudy this evening with lows in the low 40s and winds shifting to the east at 5-10 mph. Probability of precipitation is 30%

tonight. Fair and warm tomorrow. The high tomorrow will be 55-58 degrees.

Drill begins EVENT 1: Greater than 10 gpm Reactor Water Clean-up ( R W o UNIDENTIFIED leak inside drywell.

UNUSUAL EVENT DECLARATION (per MU7 - unidentified Drimarv svstem leakage > 10 m m into the Drvwell)

EVENT 2: Rod Drive Control System (RDCS) becomes inoperable.

16:20 EVENT 3: Helicopter crash into the A Spray Network at the Spray Pond.

16:35 ALERT DECLARATION (per HA3 - Natural or Destructive Phenomena Affecting a Vital Area) - NOTE: Not a terrorist event EVENT 4: The 1A Control Rod Drive (CRD) pump trips due to low suction pressure.

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TIME EVENT DESCRIPTION 17:35 Technical Support Center (TSC), Operations Support Center (OSC), and Emergency Operations Facility (EOF) should be at minimum staffing and in the process of activating the respective facilities.

17:45 EVENT 5: 1B Reactor Recirculation Pump high vibrations.

17:55 EVENT 6: RDCS restoration.

18:lO EVENT 7: 1B Reactor Recirculation pump shaft binds resulting in pump trip.

18:15 EVENT 8: lB Main Steam Line leak in the steam chase. Minor radiological release (non-routine airborne release) through ventilation system (filtered).

18:30 SITE AREA EMERGENCY (SAE) DECLARATION (per FS1-Fission Product Bamer Matrix - Reactor Coolant System barrier -

POTENTIAL LOSS; or, Reactor Coolant System barrier - LOSS; and, Primary Containment - LOSS) 19:OO EVENT 9: Onset of fuel damage. The cooling starved fuel bundles begin to fail and fuel damage begins to ramp in. Offsite release increases as fuel damage increases.

-19:OO EVENT: HV-5 1- 1F027B, RHR B SUPPRESSION POOL SPRAY valve fails to open.

19:30 EVENT 9a: Further Fuel Degradation. Degradation continues to the point of exceeding the Fuel Clad barrier threshold (2.8% damage per Core Damage Assessment Model - CDAM) at approximately 1945.

19:35 EVENT 9b: Maximum Safe Operating (MSO) value for radiation in two (2) or greater areas of the plant.

1950 GENERAL EMERGENCY (GE) DECLARATION (per FG1-Fission Product Barrier Matrix - Fuel Clad - LOSS; and Reactor Coolant System - LOSS; and Previous Primary Containment - LOSS).

PAR from Licensee to State: Evacuate 5 mile radius and 10 miles in downwind sectors (SW, WSW, W, and WNW); Recommend KI for general public in evacuated areas; Advise remainder of the EPZ to monitor EAS messages.

Expected PAD from State: Evacuate 10 mile radius; Recommend KI for general public and emergency workers in 10 mile radius.

-21130 Termination of Exercise.

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APPENDIX 5 Prior Issues Resolved For Locations Not Scheduled For Demonstration at This Exercise This appendix contains the resolution of ARCAs that were assessed during a prior ingestion exposure pathway exercise LGS and a prior plume exposure pathway exercise at Susquehanna Steam Electric Station (SSES).

Issue No.: LIMXSS-06R (4.b.l)

Description:

The water sampling teams were not fully briefed on the plume conditions and had no protective clothing, respirators, or radiation detection equipment. Also, they were not trained specifically for obtaining samples in a radiation situatiodenvironment. (NUREG-0654, K.3.a)

Corrective Action Demonstrated: This issue was resolved at the August 17 - 19,2004, SSES ingestion exposure pathway exercise. The water and soil sampling team, was fully briefed on the status of the emergency situation prior to their departure to obtain water and soil samples. The briefing included an area map showing the extent of plume deposition, radiological readings, and an outline of the restricted zone. Respirators and protective clothing are not required equipment for the sampling team, with the exception of protective gloves for sample handling, which were provided in the environmental sample kit. Thus, there was no protective clothing or respirators provided or required. Sampling team members were issued Direct Reading Dosimeters (DRD) and had TLD cards. The DRDs were individually assigned and the serial numbers were recorded as well as the readings taken. Radiation meters were used by the sampling team to take ambient readings. Sampling teams were experienced in taking and managing water and soil samples.

Issue No.: LIMXSS-07R (4.b.l)

Description:

There was no obvious control of the time the samples were to be obtained to assure they represented the radioactivity which would have been deposited in the river; i.e.,

to maximize the usefulness of the data obtained. (NUREG-0654, I. 10)

Corrective Action Demonstrated: This issue was resolved at the August 17 - 19,2004, SSES ingestion exposure pathway exercise. The water and soil sampling team recorded the time each sample was taken. The exact time of sampling was recorded throughout the chain of custody accounting.

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Issue No.: LIMXSS-08R (4.b.l)

Description:

Agricultural sampling teams were not notified in a timely manner by the Pennsylvania Department of Agriculture to report to the dispatch point at the Montgomery County EOC. Since team members did not report until the termination of the exercise, no agricultural sampling procedures could be demonstrated. Also, a prior inadequacy regarding team members use of dosimetry cannot be cleared since a demonstration of proficiency was not performed. (NUREG-0654,1.8)

Corrective Action Demonstrated: This issue was resolved at the August 17-19,2004, SSES ingestion exposure pathway exercise. The agricultural sampling team was notified to report to the Columbia County Agricultural Extension Office for the out-of sequence demonstration. The team reported at the required time (9:30 a.m.). All team members were issued an electronic dosimeter (MGP Instruments Model DMC 2000s) and a credit-card type thermoluminescent dosimeter (if not pre-assigned). The electronic dosimeters were checked every hour as required by procedure (BRP-ER-8.02, Rev. 1,07/04). Team members recorded their dosimeter readings on the Intermediate and Recovery Phase Personnel Monitoring form as required by BRP-ER-8.02.

Issue No.: 63-00-l.e.1-A-01 Condition: Teams 1 and 2 could not find two preselected monitoring locations and had difficulty finding other monitoring locations since the Field Team Coordinator (FK) and the two field teams were using different maps with different monitoring locations posted on the maps.

Possible Cause: The map used by Teams 1 and 2 was not the same as that used by the FTC. In addition, preselected locations were not related to identifying landmarks.

Reference:

NUREG-0654,I.S and J.1O.a Effect: The teams had difficulty in finding monitoring locations that interfered with their ability to perform their duties in a timely manner.

Recommendation: All maps used by the FTC and the field teams should be the same.

Corrective Action Demonstrated: Administratively resolved. The Field Teams used Global Positioning Systems for the LGS Exercise. This system enabled the teams to identify exactly their location at all times, to include sampling times. The teams are no longer dependent on maps and the finding of fixed monitoring locations.

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ENDIX 6 Planning Issues This appendix contains the Planning Issues assessed during the November 15,2005, exercise at LGS. Planning Issues are issues identified in an exercise or drill that do not involve participant performance, but rather involve inadequacies in the plan or procedures. Planning Issues are required to be corrected through the revision and update of the appropriate State and local RERPs and/or procedures in accordance with the following schedule:

Within 120 days of the date of the exercise/drill when the Planning Issue is directly related to protection of the public health and safety.

During the annual plan review and update (reported in the Annual Letter of Certification) when the Planning Issue does not directly affect the public health and safety. However, when the date for the annual plan review and update is imminent and the responsible organization does not have sufficient time to make the necessary revisions in the plans and/or procedures, the revised portion of the plans and/or procedures should be submitted in the subsequent annual plan review and update and reported in the Annual Letter of Certification.

Any requirement for additional training of responders to radiological emergencies necessitated by the revision and update of the plans and/or procedures must be completed within the timeframes described above in order for the Planning Issue to be considered resolved.

Berks County EOC Issue No.: 35-05-3.a.l-P-01 Condition: Discrepancies exist between the dosimetry information on the emergency worker radiological briefing videotape and the Risk Township Radiological Emergency Response Plans.

Possible Cause: The emergency worker radiological briefing videotape states that 0-200 R Direct Reading Dosimeters (DRD) are no longer used. Workers are advised to disregard the 0-200 R DRD section of the Dosimetry-KI Report Form.

The Township Radiological Emergency Response Plans include the following information, A supply of 0-200 Roentgen DRDs has been established at the county and each risk municipality. These would be issued in the extremely unlikely event of a life-saving mission requirement in a known, high radiation area.

The videotape also includes a briefing on emergency worker exposure limits. The tape covers the requirement to obtain approval from the County Radiological Officer prior to exceeding 5 Rem. The Dosimetry-KI Report Form that was 94

provided to emergency workers in Colebrookdale Township states, Do not exceed 25 R cumulative total, but does not provide instructions for the 5 R limit.

References:

Emergency Worker Radiological briefing tape (provided by the Pennsylvania Emergency Man agement Agency)

Colebrookdale Township Radiological Emergency Response Plan, section G.6, Municipal Emergency Workers Dosimetry-KI Report Form, PEMA BOP-REP-3 (4/97)

Effect: Emergency Workers may not be aware that they need a 0-200 R dosimeter to monitor their exposure when responding to life-saving activities in high exposure rate areas.

Recommendation: Update the videotape to reflect the 0-200 R DRD use information in the Countys plan. Modify the Emergency Worker Dosimetry-KI Report form to include emergency worker actions for the 5 R limit.

State Response: The Commonwealth appreciates the information and will seek to address this issue during the next video update.

Berks County Emergency Worker MonitoringDecontamination Center (Hamburg Junior-Senior High School)

Issue No.: 35-05-6.a.l-P-02 Condition: Evacuees arriving at the Registration Area of the Hamburg High School Mass Care Center were not designated according to plan nor provided authorization to allow admittance to the facility.

Possible Cause: The existing procedure does not specify how to designate uncontaminated individuals or what kind of authorization is needed. Therefore, nothing was provided to the evacuees.

References:

NUREG-0654,5.12 Radiological Monitoring and Decontamination Center Hamburg Junior-Senior High School, Implementing Procedure, Section 7.L, June 2005 Effect: Without a positive means to assure that evacuees have been appropriately monitored and decontaminated, if necessary, the Mass Care Center could be contaminated by evacuees who, either knowingly or unknowingly, bypass the monitoring process.

Recommendation: Specify how uncontaminated evacuees will be designated and what will constitute authorization to allow admittance to a mass care 95

facility. Train both the monitoring and decontamination personnel and the Registration Area personnel on the revised procedure.

State Response: Plans and training will be addressed to ensure a positive method for identifying uncontaminated people for admittance to mass care centers.

Colebrookdale Township EOC Issue No.: 35-05-l.c.1-P-03 Condition: There are discrepancies in the Colebrookdale Radiological Emergency Response Plan as to the location of the alternate Emergency Operation Center.

Possible Cause: The Colebrookdale Township Radiological Emergency Response Plan states, The alternate EOC is located at the Earl Township Fire Company. Annex A states, Completion of emergency tasks and after the general population has departed, direct EOC staff and municipal personnel to evacuate to the alternate EOC at the Earl Township Municipal Building on Schoolhouse Road off Route 73.

References:

Colbrookdale Township Radiological Emergency Response Plan, section II.B.2.f, Municipal Government Emergency Operations Colbrookdale Township Radiological Emergency Response Plan, Annex A, Emergency Management Coordinator Effect: The discrepancy in the alternate EOC location could cause confusion during EOC relocation activities.

Recommendation: Modify the Plan and Annex to reflect the correct location of the alternate EOC.

State Response: The discrepancy is noted. Plans will be addressed to ensure the alternate EOC location is clearly understood in all reference documents.

Montgomery County Emergency Worker MonitoringLlecontamination Station Issue No.: 35-05-6.a.l-P-04 Condition: Female workers did not have a separate decontamination dressing/

undressing and shower stall arrangement.

The County HAZMAT Decontamination trailer and tent were used and set up in the parking lot of the Indian Valley Middle School. The decontamination trailer had one row of shower stalls separated by curtains. The other half of the trailer was not in use.

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Possible Cause: Plans and procedures were not in place to ensure that the County HAZMAT trailer is set up for a separate female decontamination process.

Reference:

NUREG-0654, J. 10.h; J.12; K.5.a Effect: A lack of adequate decontamination capability for females can result in some female workers refusing the process.

Recommendation: Plans and procedures need to be in place to ensure that the County HAZMAT trailer be equipped to provide separate decontamination facilities for females.

State Response: The female half of the decontamination trailer was not used during this exercise demonstration. Plans will be reviewed to determine if added language is needed and that all personnel have the knowledge to explain the purpose of female half of the trailer even if not used during the exercise demonstrations.

Perkiomen Township EOC Issue No.: 35-05-3.a.l-P-05 Condition: The Perkiomen Township Radiological Emergency Response Plan (RERP) specifies that the control Permanent Record Dosimeter (PRD) is to be delivered to the Schwenksville Emergency Operations Center (EOC) for pickup by Montgomery County Office of Emergency Preparedness (OEP). The Perkiomen Township Implementing Procedures indicate that the Control PRD was to be picked up by the county at Perkiomen Township EOC.

Possible Cause: The discrepancy in the instructions was caused by possible changes to the actual procedure to have the county pickup the PRD at Perkiomen.

The pickup was demonstrated (discussed) at the training tabletop as indicated in the Implementing Procedures, but the RERP was not corrected.

Reference:

NUREG-0654, K.3.a, b 0 Perkiomen Township RERP, Annex E, 11Basic Plan, G Radiological Exposure Control, 5 Control PRDs, Steps c and d, Revision 3,2005.

0 Perkiomen Township RERP, Annex G, Implementing Procedure - Oil and Hazardous Materials ICs Category: Operations ESF ## 10, GE checklist, Revision 3, no date.

Effect: If the RERP is correct, the Control PRD would not have been picked up in a timely manner, which may cause a discrepancy in the baseline to determine individual exposure to radiation.

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Recommendation: Correct the RERP to reflect that the Control PRD is to be picked up at the Perkiomen EOC by the county.

State Response: Plans will be corrected to clarify the appropriate Control PRD pickup/delivery procedures.

Daniel Boone Area School District Issue No.: 35-05-3.c.2-P-06 Condition: Plans and procedures have not been updated to indicate that Daniel Boone Middle School has been moved. The Daniel Boone High School, instead of the Middle School, is now the host school for the students evacuated from other Daniel Boone Area schools.

Possible Cause: The new middle school was opened for the 2005 - 2006 school year.

Reference:

NUREG -0654, J.lOC, d, g Daniel Boone Area School District Procedure Effect: Although the Superintendents office personnel demonstrated they knew what to do, plans and procedures have not been changed. Different personnel may be confused if trying to follow the existing procedures during an emergency.

Recommendation: Update the School District plan and procedures to include the designation of the host school for evacuated students as the Daniel Boone High School.

State Response: The School District plans and procedures will be updated to identify the appropriate host school.

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