ML082380247

Submittal of Radiological Emergency Preparedness Exercise Final Report for 04/22/2008

ML082380247
Person / Time
Site:	Peach Bottom, Vermont Yankee
Issue date:	08/18/2008
From:	Hammons D US Dept of Homeland Security, Federal Emergency Management Agency
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML082380247 (223)

Text

U.S. Department of Homeland Security Region Ill One Independence Mall, Sixth Floor 615 Chestnut Street Philadelphia, PA 19106-4404 FEMA August 18, 2008 NRC Headquarters Document Control Desk US Nuclear Regulatory Commission Washington, DC 20555-0001 Enclosed is the final report for the Peach Bottom Atomic Power Station (PBAPS) Radiological Emergency Preparedness Exercise that was held on April 22, 2008.

If you have any questions, please contact Darrell Hammons at (215) 931-5546.

Sincerely, Darrell Hastmoncs Regional Assistance Committee Chair Enclosure 4~Lcs*

www.fema.gov

Neacbh Bottom Atomic Power. Staioion Exercise - Ap*{1 22=235 2008 Final Report- Radiological Emergency Preparedness Program July 31, 2008 TTT EIMVIA Region III

Final Exercise Report Peach Bottom Atomic Power Station Licensee: Exelon Nuclear Exercise Date: April 22-23, 2008 Report Date: July 31, 2008 U.S. DEPARTMENT OF HOMELAND SECURITY FEMA REGION III NATIONAL PREPAREDNESS DIVISION TECHNOLOGICAL HAZARDS BRANCH ONE INDEPENDENCE MALL, 6 FLOOR 615 CHESTNUT STREET PHILADELPHIA, PENNSYLVANIA 19106-4404 ii

TABLE OF CONTENTS

1. Executive Sum mary ...................................................................................................... 1 II. Introduction ....................................................... 3 III. Exercise O verview ............................................................................................................. 6 A. Plume Emergency Planning Zone Description ......................................................... 6 B . Exercise Participants ................................................................................................... 8 C. Exercise Timeline ............................................... 14 IV . Evaluation and R esults ...................................................................................................... 17 A. Summary Results of Exercise Evaluation ................................................................ 17 B. Status of Jurisdictions Evaluated ............................................................................... 23 1.0 Comm onwealth of Pennsylvania ........................................................................ 25 1.1 Pennsylvania State Emergency Operations Center .................................. 25 1.2 Joint Information Center/Pennsylvania (Emergency Operations Facility -

C oatesville) ............................................................................................. .. 25 1.3 Emergency News Center (Harrisburg at State Emergency Operations C enter) .................................................................................................... .. 25 1.4 Accident Assessment Center (at State Emergency Operations Center) ........ 26 1.5 State Traffic and Access Control Points (Lancaster Barracks) ................ 26 2.0 Pennsylvania Risk Jurisdictions ................................... 27 2.1 C hester C ounty ........................ ............................................................... 27 2.1.1 Chester County Emergency Operations Center .......................... 27 2.2 Lancaster C ounty ....................................................................................... 27 2.2.1 Lancaster County Emergency Operations Center .................. 27 2.2.2 Emergency Worker Monitoring/Decontamination (Lampeter Strasburg School Complex - Field House) ................................. 29 2.2.3 East Drumore Township Emergency Operations Center ............. 30 2.2.4 Fulton Township Emergency Operations Center ......................... 31 2.2.5 Little Britain Township Emergency Operations Center .............. 31 2.2.6 Quarryville Borough Emergency Operations Center ................... 31 iii

0 2.2.7 Quarryville Township Route Alerting ........................................ 32 2.3 York County ............................................................................................. 33 2.3.1 York County Emergency Operations Center ............................... 33 2.3.2 Delta Township/Peach Bottom Township Emergency Operations C enter ........................................................................................ . . 34 2.3.3 Delta Township/Peach Bottom Township Route Alerting ....... 34 3.0 Pennsylvania Schools .......................................................................................... 38 3.1 C hester C ounty ....................................................................................... 38 3.1.1 Jordan Bank Elementary School (Oxford Area School District) ...... 38 3.1.2 Nottingham Elementary School (Oxford Area School District) ....... 38 3.2 Lancaster C ounty ..................................................................................... 38 3.2.1 Penn Manor High School (Penn Manor School District) ............ 38 3.2.2 Swift Middle School (Solanco School District) ........................... 39 3.2.3 Quarryville Elementary School (Solanco School District) .......... 39 3.3 Y ork C ounty .................................................................................................. 39 3.3.1 South Eastern Middle School West (South Eastern School D istrict) ...................................................................................... . . 39 3.3.2 Kennard Dale High School (South Eastern School District) ..... 40 3.3.3 Red Lion Junior High School (Red Lion School District) ........... 40 4.0 State of M aryland ................................................................................................. 41 4.1 Maryland State Emergency Operations Center ........................................ 41 4.2 Accident Assessment (Maryland Department of Environment) .............. 42 4.3 Joint Information Center, Maryland (Emergency Operations Facility -

C oatesville) ............................................................................................ .. 43 4.4 State Field Monitoring Team A ............................................................... 45 4.5 State Field Monitoring Team B .............................................................. 45 5.0 Maryland Risk Jurisdictions ................................................................................. 46 5.1 C ecil C ounty ............................................................................................ 46 5.1.1 Cecil County Emergency Operations Center ............................... 46 5.1.2 Reception Center and Monitoring/Decontamination (Perryville H igh School) ................................................................................. 50 iv iv0

5.1.3 Emergency Worker Monitoring/Decontamination (Rising Sun Fire Department) ................................... 50 5.1.4 Congregate Care (Perryville High School) ................................. 50 5.1.5 Traffic and Access Control Point (Interview at Emergency O perations C enter) ............................................................. ............... 51 5.1.6 R oute Alerting ............................................................................. 51 5.1.7 Ambulance (MS-1 Drill) Rising Sun Emergency Medical Services ......................................... 51 5.1.8 Union Hospital (MS-1 Drill) .............................................................. 52 5.2 Harford C ounty ........................................................................................ 52 5.2.1 Harford County Emergency Operations Center ........................... 52 5.2.2 Reception Center and Monitoring/Decontamination (Fallston H igh School) ............................................................................... 56 5.2.3 Emergency Worker Monitoring/Decontamination (Fallston High School) ...................................................................................... .. 57 5.2.4 Congregate Care (Fallston High School) ..................................... 57 5.2.5 Traffic and Access Control Point .................................................. 57 5.2.6 R oute A lerting ............................................................................. 58 6.0 M aryland Schools ................................................................................................. 60 6.1 Cecil County Public School District ........................................................ 60 6.1.1 Conowingo Elementary School ................................................... 60 6.2 Harford County Public School District .................................................... 60 6.2.1 North Harford Elementary School ............................................... 60 6.2.2 North Harford Middle School ...................................................... 60 6.2.3 North Harford High School .......................................................... 61 V

APPENDICES APPENDIX 1: Acronyms and Abbreviations .......................................................................... 62 APPENDIX 2: Exercise Evaluators and Team Leaders .......................................................... 64 APPENDIX 3: Exercise Evaluation Area Criteria and Extent of Play Agreement ................. 72 A PPEN D IX 4: Exercise Scenario ................................................................................................ 201 A PPEN D IX 5: Planning Issues .................................................................................................... 208 A PPEN D IX 6: Additional Prior Issues ........................................................................................ 215 LIST OF TABLES Table 1 - Exercise T im eline .................................................................................................. 15 Table 2 - Summary Results of Exercise Evaluation .............................................................. 18 vi vi0

I. EXECUTIVE

SUMMARY

On April 22-23, 2008, a full-scale plume exercise was conducted in the 10-mile plume exposure pathway, emergency planning zone (EPZ) around the Peach Bottom Atomic Power Station (PBAPS) by the Federal Emergency Management Agency (FEMA), Region III. Out-of-sequence demonstrations were conducted on April 22, 2008. The purpose of the exercise and the out-of-sequence demonstrations 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 April 25, 2006.

FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Pennsylvania and its three risk counties (Chester, Lancaster, and York), and five risk municipalities (East Drumore Township, Fulton Township, Little Britain Township, Quarryville Borough, and Delta Township/Peach Bottom Township) as well as the State of Maryland and its two risk counties (Cecil and Harford), which were evaluated in 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:

Commonwealth of Pennsylvania

• Emergency Worker Monitoring and Decontamination:Conducted on April 22, 2008 between 1900 and 2130 hours0.0247 days <br />0.592 hours <br />0.00352 weeks <br />8.10465e-4 months <br /> in Lancaster County.

• State Police Traffic/Access ControlPoints: Conducted on April 22, 2008 between 1000 and 1200 hours0.0139 days <br />0.333 hours <br />0.00198 weeks <br />4.566e-4 months <br /> by the Lancaster Barracks.

• Schools: Conducted on April 22, 2008 between 0900 and 1100 hours0.0127 days <br />0.306 hours <br />0.00182 weeks <br />4.1855e-4 months <br /> in Chester, Lancaster, and York Counties State of Maryland

• Emergency Worker Monitoring and Decontamination:Conducted on April 22, 2008 between 1900 and 2130 hours0.0247 days <br />0.592 hours <br />0.00352 weeks <br />8.10465e-4 months <br /> in Cecil and Harford Counties.

" Reception Center and Monitoring/Decontamination:Conducted on April 22, 2008 between 1900 and 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> in Cecil and Harford Counties.

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• Congregate Care: Conducted on April 22, 2008 between 1900 and 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> in Cecil and Harford 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 four Deficiencies and eight Areas Requiring Corrective Actions (ARCAs) identified as a result of this exercise. Two of the Deficiencies and one of the ARCAs were successfully re-demonstrated during the exercise; two more Deficiencies and five ARCAs were successfully re-demonstrated during a remedial exercise on June 11, 2008. Ten ARCAs from a previous exercise were successfully demonstrated at this exercise. Two new planning issues were identified and nine planning issues from previous exercises were successfully demonstrated (see Appendix 5 for resolution for all planning issues). One ARCA and one planning issue from a previous exercise remain unresolved.

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II. Introduction On December 7, 1979, the President directed the Federal Emergency Management Agency (FEMA) to assume the lead responsibility for all off-site nuclear planning and response. FEMA's activities were conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351 and 352. These regulations are a key element in the Radiological Emergency Preparedness (REP)

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

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 III Radiological Assistance Committee (RAC), which is chaired by FEMA.

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0 A REP exercise was conducted on April 22-23, 2008, 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 Peach Bottom Atomic Power Station (PBAPS). The purpose of this exercise report is to present the exercise results and findings on the performance of the off-site response organizations (OROs) during a simulated radiological emergency.

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

These reports are provided to the NRC and participating States. State and local governments utilize the findings contained in these reports for the purposes of planning, training, and improving emergency response capabilities.

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

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

• FEMA Guidance Memoranda MS-i, "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 Areas Requiring Corrective Action (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 ARCAs assessed during previous exercises and resolved at this exercise, 4 440

including the corrective action demonstrated, as well as ARCAs assessed during previous exercises and scheduled for demonstration at this exercise which remain unresolved.

The final section of the report is comprised of the appendices, which present the following supplementary information: acronyms and abbreviations, exercise evaluators and team leaders, exercise evaluation area criteria and extent of play agreement, and the exercise scenario. It also presents information on planning issues (both new planning issues identified during this exercise and resolved planning issues identified during previous exercises), and additional prior issues not scheduled for demonstration at this exercise.

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0 I11. Exercise Overview Contained in this section are data and basic information relevant to the April 22-23, 2008 exercise to test the off-site emergency response capabilities in the area surrounding Peach Bottom Atomic Power Station (PBAPS). This section of the exercise report includes 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.

A. Plume Emergency Planning Zone Description Exelon Nuclear owns and operates the PBAPS. The station consists of one 40-megawatt (MW), high-temperature, gas-cooled reactor (Unit 1), decommissioned in October 1974, and two operating boiling water reactors (Units 2 and 3) rated at 1,065 MW per unit. The operating licenses for the facility were granted in October 1973 (Unit 2) and July 1974 (Unit 3); commercial operation began at the site in July 1974 (Unit 2) and December 1974 (Unit 3).

The coordinates of the plant site are 39045,32" north (latitude) by 76' 16'9" west (longitude). The site consists of 620 acres located on the west shore of Conowingo Pond, a reservoir formed by the backwater of the Conowingo Dam on the Susquehanna River.

The site is primarily in Peach Bottom Township, York County, Pennsylvania; a small portion of the property lies in Lancaster County in southeastern Pennsylvania near the mouth of Rock Run Creek. The minimum exclusion distance (distance from the center point of the reactor vessel to the site area boundary) specified for the PBAPS is 2,700 feet. Exelon Nuclear owns all the land within the exclusion area; there are no private residences on site.

The plant is located about 38 miles north-northeast of Baltimore, Maryland; 45 miles southeast of Harrisburg, Pennsylvania; and 20 miles south-southeast of Lancaster, Pennsylvania. The nearest communities are Delta, Pennsylvania, and Cardiff, Maryland, which are located approximately four and five miles west-southwest of the site, respectively. There are 97 sirens providing coverage for the 10-mile EPZ; 65 are in Pennsylvania.

Soils of the Manor-Glenelg Association predominate in the site area. These soils, which are generally underlain by schist or phyllite, are shallow to moderately deep and are found on moderate to very steep slopes. The general topography of the site is hilly, with elevations ranging from 110 feet to over 460 feet above mean sea level (MSL); the plant is 116 feet above MSL. The site is characterized by broad ridge tops and steep hillsides along the river.

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The climate in this area of York County is mild but humid. Prevailing winds are from the west. The average rainfall is approximately 40.5 inches, and the average annual temperature is 52.80 Fahrenheit.

The area in the immediate vicinity of the plant is mostly agricultural. There are no commercial airports within a 10-mile radius. The closest major airport is in Harrisburg, about 50 miles northwest of the site. A smaller airport servicing commuter and private aircraft is located in Lancaster, about 25 miles north of the site. No public highways pass through the plant, and no major arterial highways pass near it. Access to the plant is by two roads: one, from the nearby town of Delta, leads to the decommissioned Unit 1 area and Information Center; the other passes north of Delta and enters the plant area near Units 2 and 3.

The 10-mile EPZ for PBAPS, with a total risk population of approximately 57,645, covers the following jurisdictions:

" Chester County, Pennsylvania West Nottingham Township

" Lancaster County, Pennsylvania Drumore Township East Drumore Township Fulton Township Little Britain Township Martic Township Providence Township Quarryville Borough

" York County, Pennsylvania Delta Borough Peach Bottom Township Fawn Township Fawn Grove Borough Lower Chanceford Township

" Cecil County, Maryland

" Harford County, Maryland 7

0 B. Exercise Participants The following agencies, organizations, and units of government participated in the PBAPS out-of-sequence activities on April 22, 2008, or the exercise on April 22-23, 2008.

COMMONWEALTH OF PENNSYLVANIA Maryland Emergency Management Agency Pennsylvania Department of Aging Pennsylvania Department of Agriculture Pennsylvania Department of Conservation and Natural Resources Pennsylvania Department of Education Pennsylvania Department of Environmental Protection Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection Pennsylvania Department of General Services Pennsylvania Department of Health Pennsylvania Department of Military and Veterans Affairs Pennsylvania Department of Public Welfare Pennsylvania Department of Transportation Pennsylvania Fish and Boat Commission Pennsylvania Public Utility Commission Pennsylvania State Police Pennsylvania State Police, State Police Headquarters Pennsylvania State Police, Troop H (York Barracks)

Pennsylvania State Police, Troop J (Lancaster Barracks)

Pennsylvania Turnpike Commission Pennsylvania Emergency Management Agency Pennsylvania Emergency Management Agency, Bureau of Plans United State Department of Agriculture PENNSYLVANIA RISK JURISDICTIONS Chester County Chester County Board of Commissioners Chester County Department of Emergency Services Chester County Sheriff's Department Pennsylvania Department of Transportation Pennsylvania Emergency Management Agency United States Department of Agriculture United States Department of Agriculture, Farm Services Agency 8

Lancaster County East Drumore Township Emergency Management Coordinator Fulton Township Emergency Medical Services Fulton Township Fire Department Fulton Township Public Works Lampeter Fire Company Lancaster County Animal Rescue Team Lancaster County Commissioners Lancaster County Emergency Management Agency Lancaster County GIS Department Lancaster County Mental Health and Retardation Department Lancaster County Sheriff's Department Manheim Fire Department Manheim Police Department North Holland Borough Police Department Penn State Agriculture Extension Service Pennsylvania Department of Agriculture Pennsylvania Department of Health Pennsylvania Department of Transportation Pennsylvania Emergency Management Agency Pennsylvania State Police Quarryville Borough Fire Department Quarryville Borough Police Department Quarryville Borough Public Works Department Strasburg Borough Police Department Willow Street Fire Company York County Delta/Cardif Fire Department Delta/Peach Bottom Emergency Management Manchester Township Fire Department Penn State Agriculture Extension Service Pennsylvania Department of Transportation Pennsylvania Emergency Management Agency Pennsylvania State Police York County 911 Center York County Commissioners York County Emergency Management Agency York County Mental Health York County Parks York County Sheriffs Department 9

PENNSYLVANIA SCHOOLS Chester County Jordan Banks Elementary School Oxford Area School District Lancaster County Penn Manor High School Penn Manor School District Quarryville Elementary School Solanco School District Swift Middle School York County Kennard Dale High School Kennard Dale High School Principal.

Pennsylvania Emergency Management Agency Red Lion Junior High School Red Lion School District South Eastern Middle School West South Eastern School District, Business Manager STATE OF MARYLAND Maryland Department of Agriculture Maryland Department of Education Maryland Department of General Services Maryland Department of Health and Mental Hygiene Maryland Department of Housing and Urban Development Maryland Department of Human Resources Maryland Department of Labor License and Regulation Maryland Department of Natural Resources Maryland Department of Natural Resources Police Maryland Department of Public Safety and Correctional Services Maryland Department of the Environment Maryland Department of Transportation Maryland Emergency Management Agency Maryland Fire and Rescue Institute Maryland Highway Administration Maryland Institute for Emergency Medical Service Systems Maryland Military Department Maryland State Police 10

United States Coast Guard MARYLAND RISK JURISDICTIONS Cecil County Cecil County Cooperative Extension Cecil County Department of Emergency Services Cecil County Department of Public Works Cecil County Department of Social Services Cecil County Emergency Medical Services Cecil County Fire Department Cecil County Haz Mat Cecil County Health Department Cecil County Public Schools Cecil County Sheriff's Department Maryland State Police Perryville Police Department Port Deposit Police Department Rising Sun Volunteer Fire Department Union Hospital Harford County Aberdeen Proving Ground Chaplain City of Havre de Grace Emergency Medical Services Darlington Emergency Medical Services Harford County Community Services Harford County Corporate Counsel Harford County County Administrator Harford County Department of Agriculture Harford County Department of Community Services Harford County Department of Health Harford County Department of Inspections, License & Permits Harford County Department of Natural Resources and Highway Administration Harford County Department of Public Works Harford County Department of Public Works, Highways Harford County Department of Public Works, Water & Sewer Harford County Division of Emergency Operations Harford County Emergency Communications Center Harford County Fire and Emergency Medical Services Harford County HAZ MAT Response Team Harford County Health Department Harford County Human Resources Harford County Parks & Recreation 11

0 Harford County Schools Harford County Sheriff's Department Harford County Social Services Harford County Transportation Maryland Department of Social Services Maryland State Police State Liaison Town of Aberdeen Emergency Medical Services Town of Bel Air Emergency Medical Services MARYLAND SCHOOLS Cecil County Cecil County Public School District Cecil County Public Schools Bus Driver Conowingo Elementary School Harford County Harford County Emergency Management Office Harford County Public School District North Harford Elementary School North Harford High School North Harford Middle School PRIVATE/VOLUNTEER ORGANIZATIONS The following private and volunteer organizations participated in the PBAPS exercise at many different locations throughout the area. We thank them and all those who volunteer their services to State, county, and municipal governments during emergencies.

Amateur Radio Emergency Services (ARES) and Radio Amateur Civil Emergency Services (RACES), including the following clubs:

Chester County ARES/RACES Harford County RACES (Harford County)

Lancaster County RACES (Lancaster County)

York County ARES RACES Skywarn American Red Cross, including the following local chapters:

Central Maryland Chapter Susquehanna Valley American Red Cross York County Chapter of the American Red Cross Core Service Agency (Harford County)

Exelon Nuclear 12

Little Britain Township Emergency Management Team Mobile Crisis (mental health care professionals)(Harford County)

North Hampton Community College (observers)

Verizon York County Volunteers 13

0]

C. Exercise Timeline Table 1, on the following page, presents the times at which key events and activities occurred during the PBAPS exercise on April 22-23, 2008. Also included are times notifications were made to the participating jurisdictions/functional entities.

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0 0 0 TABLE 1: EXERCISE TIMELINE DATE and SITE: April 23, 2008 - Peach Bottom Atomic Power Station

~' K ,< Tim~e*1hat Notification Was Received or Action Was Taken 7 J~Time'IP&D1 &MD. iPEast EEmergency Classification Level! .. Accident Emergency Even Utility .or Joint Chester Lancaster Drsr Fulton L Britai Quarryvill York Delta/Peach DeclaredM ennsylvani, Assessmen News Center Information County County rumore wp. e Boro. County Bottom Twp.

State EOC t Center S (Harnisburg- Center (EOF EOC EOC Twp. EOC Twp. EOC EOC EOC EOC (at EOC) at EOC) Coatesville) EOC E E EOC Unusual Event - N/A N/A N/A N/A Alert 1640 1651 1657 1706 1739 1651 1651 1700 1700 1702 1706 1651 1700 Site Area Emergency 1827 1835 1840 1848 1830 1835 1835 1858 1840 1840 1842 1835 1848 General Emergency 1937 1943 1950 2004 1937 1943 1943 2000 1953 1950 1952 1943 2005 Simulated Radioactivity 1827 1835 1832 1835 1835 1835 1835 1953 1840 1840 N/R 1923 1923 Release Began Simulated Radioactivity Release Terminated Facility Declared Operational 1709 1602 1704 1754 1656 1721 N/R 1739 1815 1746 1715 1711 Declaration of State of Emergency 1850 1850 1940 1940 1940 N/R 2044 2056 2100 1944 1950 Exercise Terminated 2204 2204 2204 2200 2120 2204 2115 2114 2115 2128 2115 2050 Precautionary Actions: FAA TFR-1 1817 1817 1929 1925 1915 - - - - 1915 -

FAA TFR-2 2018 N/A 2018 1929 1902 Rail Restricted 1815 1815 1929 1915 1915 N/A N/A N/A N/A 1915 N/A Rivers Cleared 1904 1904 1915 1929 - 1915 Other: Animals Shelter. Store Feed 1854 1854 1920 1922 1854 1920 -

'r A&N Decision (State [made]; local 1905 N/R N/R 1915 1905 1905 1953 1905 1913 1905 1905 1905

-[received]) ____ ___ _________ ____I____

I't Siren Activation 1915 N/R N/R 1915 1915 1915 1915 1915 1915 1915 1915 1915 Is EAS Message 1918 N/R N/R 1915 1918 1918 1918 1918 1918 1918 1918 1918 2nd A&N Decision (State [made]; local 2015 N/R N/R 2016120151201512020 202012020 20201201512030

[received]) 2015 N/R N/R 2016 2 25 20 20 2nd Siren Activation 2025 N/R N/R 2016 2025 2025 2025 2025 2025 2025 2025 2025 2nd EAS Message 2028 N/R N/R 2016 2028 2028 2028 2028 2028 2028 2028 2028 KI Decision: 2015 2015 2016 2015 2015 - - - -1 2015 _

Advisory received at location 2015 2015 2029 2021 2020 2101 2015 2040 Action taken at location 2015 2015 2029 2027 2038 2101 2015 2040 15

TABLE 1: EXERCISE TIMELINE DATE and SITE: April 22, 2008 - Peach Bottom Atomic Power Station Time That Notification Was Received or Action Wars Taken ~

Ei crg nc C- l assif'i~idofEe n o*u>

Le>:e; *U ti lit y* Accident H a r for d r Event Ui Maryland Cecil County Harford Conowingo Harford Harford High D State EOC i :*Center-MDE Csentsme*rD EOC County EOC Elementary Middle School School Elementary ISchool Unusual Event N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Alert 0715 0730 0735 0730 0737 0737 0825 0858 0900 0905 Site Area Emergency 0845 0902 0907 0846 0909 0908 0917 0914 0915 0915 General Emergency 1015 1035 1028 1015 1042 1040 N/A 1104 1105 1110 Simulated Radioactivity 1015 1035. 1035 1015 1042 1040 N/A N/A N/A N/A Release Began Simulated Radioactivity N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Release Terminated Facility Declared Operational 0818 0830 0830 0833 0835 N/A N/A N/A N/A Declaration of State of Emergency 1117 N/A N/A 1120 1 120 N/A N/A N/A N/A Exercise Terminated 1329 1330 1330 1320 1320 1045 1130 1130 1115 Precautionary Actions:

Stored Feed 10 mile, KI EW 0941 0941 N/A 0953 0956 N/A N/A N/A N/A Other: Stored Feed to 50 mile DW 1253 1250 1254 1254 1"A&N Decision (State [made]; local 1100 1100 N/A 1100 1100 N/A N/A N/A N/A

[received])

I" Siren Activation 1115 N/A N/A 1115 1115 N/A N/A N/A N/A I" EAS Message 1118 N/A N/A 1118 1118 N/A N/A N/A N/A KI Decision: EW to take KI 0941 0959 1 N/A 0941 1 0941 N/A N/A N/A N/A KI Decision: Public to take KI 1100 1100 1100 1100 16 000 0 9

IV. Evaluation and Results Contained in this section are the, results and findings of the evaluation of all jurisdictions and locations that participated in the April 22-23, 2008, biennial Radiological Emergency Preparedness (REP) exercise. The exercise was held to test the offsite emergency response capabilities of local governments in the 10-mile Emergency Planning Zone (EPZ) surrounding the Peach Bottom Atomic Power Station (PBAPS).

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

Detailed information on the exercise evaluation 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 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 Area Requiring Corrective Action (ARCA) assessed and no unresolved ARCAs from prior exercises)

D Deficiency D1 Deficiency assessed, but successfully re-demonstrated A ARCA(s) assessed A' ARCA(s) assessed, but successfully re-demonstrated R Resolved ARCA(s) from prior exercises N Not Demonstrated (Reason explained in Section IV. B) 17

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: April 22-23, 2008 Peach Bottom Atomic Power Station 1.1 Pennsylvania EOC M M M M M M M I M M M 1.2 Joint Information Center/PA - (EOF M M Coatesville) 1.3 Emergency News Center M M (Harrisburg - at EOC) 1.4 Accident Assessment Center M M M M M 1.5* State Police Barracks - Lancaster Barracks M M M M M M TCPs*

2 PENNSYLVANIA RISK JURISDICTIONS, ý ** ' :I [ *. I  !  ! .  ::J 2.1 Chester County 2.1.1 Chester Co. EOC M MMMM M M M M M M M M _ M 2.2 - Lancaster County 2.2.1 Lancaster County EOC M M/R M M M/R M M M M M M M M M M/

R Emergency Worker Monit./Decon.-

2.2.2* Lampeter Strasburg School Complex (Field M/R M A' M House)*

2.2.3 East DrumoreTownship EOC M M M M M M M M M M M M 2.2.4 Fulton Township EOC M M M M M M M M M M M M 2.2.5 Little Britain Township EOC M M M M M M M M M M M M M 2.2.6 Quarryville Borough EOC R M M (Partial) 2.2.7 Quarryville Borough Route Alerting M M M M M M 2.3 York County' 2.3.1 York CountyEOC M M MMM N M M M M M M M M _ M M A 2.3.2 Delta Township/Peach BottomTownship M M M M M M M M M M M M M EOC 2.3.3 Delta Township/ Peach Bottom Township A' M M M Route Alerting A-LEGEND: M = Met (no Deficiency or ARCA(s) assessed) A = ARCA(s) assessed A' = ARCA(s) assessed but successfully re-demonstrated R = Resolved ARCA(s) from prior exercises Blank = Not scheduled for demonstration D' = Deficiency assessed but successfully re-demonstrated

• '= Out of Sequence (4/22/08) 18 40 00 0 0

0 00 TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: April 22-23, 2008 Peach Bottom Atomic Power Station Oxford Area SD- M 31.1

• Jordan Bank ES*

3.1.2* Oxford Area SD-Nottingham ES* M 5.2 LancasterCount. .,. - .:F ]-:- . - " -----------

Penn Manor SD-

.2.1* Penn Manor HS* M 3.2. Solanco SD- M Swift MS*

3.2-3* Solanco SD-Quanyville ES*

33 York Count .

South Eastern SD-

_3.1_*SE Middle School West*

3.3.2* South Eastern SD-Kennard Dale HS*

3.3* Red Lion SD-

__3.3* Red Lion Jr. HS* M LEGEND: M = Met (no Deficiency or ARCA(s) assessed) A = ARCA(s) assessed A' = ARCA(s) assessed but successfully re-demonstrated R = Resolved ARCA(s) from prior exercises Blank = Not scheduled for demonstration D' = Deficiency assessed but successfully re-demonstrated

• = Out of Sequence (4/22/08) 19

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: April 22-23, 2008 Peach Bottom Atomic Power Station Emergency rotective Acio &>Etrgn OperationsMMerations/

Proetv ca Field Measurement. Ntfit DecMProtective Action Implementation a-Management.Emeroenn Facitic ati Faclities

1. OFFSITE RESPONSE1 Join InormaionCener/MI-forFmato 4-.1 _Marylad Mon n Ta AM M M M M M M 4.4 State Field Monitoring Team A M M M M M M 5.0 MARST LAND RISK JURISDICTIONS 5.1 C ecil C ourt i:..  : ::; " ". *...... ,: ,. .:. . .

5.1. Cecil County EOC M DA M M M M M M M M _ M _ M At 5.1.2 Reception Center and MonitJDecon.-

A M M Perryville HS*

5.1.3" Emergency Worker Mions n.ac-liMy M M Rising, Sun Fire Dept.*M 5.1.4" Congregate Care- Perryville HS* M 5.1.5 Traffic and Access Control Point M M 5.1.6 Soute Alerting M M M M M 5.1.7 An~bulance (MS- I Drill) M M Risen Sun EMS 5.1.8 Union Hospital (MS- I Drill) M M/R M 5.2 Hai-ford Coinity' **'11I! l  :" ': ","l  : l.[ ""

5.2.1 HafclrdCountyEOC M M M M M M M M M M M M M DA M DA 5.2.2" Reception Center and Monit.Decon.- M M Fallston High School* I 5.2.3* Emergency Worker Monit./Decon- Fallston M M M High School*

5.2.4* Congregate Care- M Fallston High School*

5.2.5* Traffic and Access Control Point* M M M M M M 5..6 Route Alerting M M M M M LEGEND: M = Met (no Deficiency or ARCA(s) assessed) A = ARCA(s) assessed A' = ARCA(s) assessed but successfully re-demonstrated R = Resolved ARCA(s) from prior exercises Blank = Not scheduled for demonstration D' = Deficiency assessed but successfully re-demonstrated

• = Out of Sequence (4/22/08) 20 0 00 0 0

0 0 ~000 0 0 TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: April 22-23, 2008 Peach Bottom Atomic Power Station Emerency Emergency nie> -rtcieAtin~Pb Suppor Protective Ac tion Field Measurement Notification & 1&

Operatiand I"PrtetveAcinsmpeenato Operations/

Managemniit DeiinM-'igadAayi ulc Facilities~>

1. OFFSITE RESPONSE~

I II ,3- ..I> .. "I.. -Dý-

i01 MARYLAND'SCHOOLS [

61:=; Cecil County Public SD

.1.1

• Conowingo ES M i.2 Harford County Public SD 2.1* North Harford ES M 2.2* North Harford MS M 6.2.3* North Harford HS M LEGEND: M = Met (no Deficiency or ARCA(s) assessed) A = ARCA(s) assessed A' = ARCA(s) assessed but successfully re-demonstrated R = Resolved ARCA(s) from prior exercises Blank = Not scheduled for demonstration D' = Deficiency assessed but successfully re-demonstrated

• = Out of Sequence (4/22/08) 21

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: April 22-23, 2008 Peach Bottom Atomic Power Station 6.0 MARYLAND SCHOOLS 6.1 Cecil County Public SD 6.1.1. Conowingo ES M]

6.2 Harford County Public SD 6.2.1* North Harford ES M 6.2.2* North Harford MS M 6.2.3* North Harford HS M LEGEND: M = Met (no Deficiency or ARCA(s) assessed) A = ARCA(s) assessed A' = ARCA(s) assessed but successfully re-demonstrated R = Resolved ARCA(s) from prior exercises Blank = Not scheduled for demonstration D' = Deficiency assessed but successfully re-demonstrated

• = Out of Sequence (4/22/08) 22 01 0 41

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."

23

0 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."

The Federal Emergency Management Agency (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.

24

1.0 COMMONWEALTH OF PENNSYLVANIA 1.1 Pennsylvania State Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.b.1 5.a.1 1.c.1 2.b.2 3.d.1 1.d.1 3.d.2 1.e.I

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 Joint Information Center/Pennsylvania (Emergency Operations Facility -

Coatesville)

a. MET: 1.d. 1 5.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 1.3 Emergency News Center (Harrisburg at State Emergency Operations Center)

a. MET: 5.a. 1 5.b.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None 25

0

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 1.4 Accident Assessment Center (at State Emergency Operations Center)

a. MET: 1.a.1 2.a.1 1.c.1 2.b.1 1.d.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 1.5 State Traffic and Access Control Points (Lancaster Barracks)

a. MET: 1.d.1 3.a.1 1.e.1 3.b.1 3.d.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 26

2.0 PENNSYLVANIA RISK JURISDICTIONS 2.1 Chester County 2.1.1 Chester County Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.1 5.a.l 1.c.1 2.c.1 3.b.1 5.b.1 1.d.1 3.c.1 1.e.1 3.c.2 3.d.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 Lancaster County 2.2.1 Lancaster County Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.1 5.a.1 1.c.1 2.c.1 3.b.1 5.a.3 1.d.1 3.c.1 .5.b.1 1.e.1 3.c.2 3.d.1 3.d.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: Three Issue No.: 46-06-1.c.1-A-01 Condition: A preliminary Protective Action Recommendation (PAR) to evacuate the Emergency 27

0 Planning Zone 360 degrees and out to five miles was received by the Emergency Operations Center (EOC) and was inadvertently released to the Municipalities. A Protective Action Decision (PAD) was subsequently issued to evacuate the entire EPZ instead of the five miles as recommended in the PAR.

Corrective Action Demonstrated: The Lancaster County EOC instituted effective communications control and exercised appropriate diligence to ensure that PADs were transmitted to the local EOCs and that PARs were received and held internally.

Issue No.: 46-06-2.a.1-A-02 Condition: The Radiological Officer did not conduct a radiological briefing to the Emergency Operations Center staff who would be dispatched into the Emergency Planning Zone.

Corrective Action Demonstrated: The Radiological Officer completed a thorough radiological briefing to emergency workers who would potentially be dispatched into the Emergency Planning Zone.

Issue No.: 46-06-5.b.1-A-03 Condition: Lancaster County issued a Special News Bulletin, referred to in the plan as local Emergency Alert Service messages, to the local media that did not meet the requirements for a press release and did not contain complete information of protective actions for the public.

Corrective Action Demonstrated: Lancaster County issued three press releases (simulated) as part of the Peach Bottom Atomic Station exercise on April 23, 2008. Each press release was clear and contained up to date information on the status of the emergency and all protective action measures for the public.

f. PRIOR ARCAs - UNRESOLVED: None 28

2.2.2 Emergency Worker Monitoring/Decontamination (Lampeter Strasburg School Complex - Field House)

a. MET: 1.e.1 3.a.1 6.b.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: One [6.b. 1 (Re-demonstrated)]

Issue Number: 46-08-6.a.1-A-01 (Re-demonstrated)

Condition: During thyroid monitoring of an emergency worker at 2000 on Tuesday, April 22, 2008 at the Lampeter-Strasburg School Complex Field House, the monitor held the pancake probe so that the front of the probe (with the window) was toward the thyroid. The proper orientation of the probe should be with the back or shielded side toward the thyroid.

Possible Cause: Inadequate training in thyroid screening techniques.

References:

• NUREG-0654, K.5.a

• Lancaster County Radiological Emergency Response Procedures, Appendix 13 (Radiological Exposure Control), Attachment A, (Monitoring/

Decontamination Procedures), section 2, (Procedures for Monitoring/Decontamination Teams), paragraph b, (Thyroid Gland Screening for Emergency Workers)

Effect: With the pancake probe incorrectly oriented, the reading may be higher than the correct value due to the lack of probe shielding. This could result in a reading greater than 300 counts per minute (cpm) above background and would necessitate referring the individual to a medical facility for further evaluation. With proper probe orientation such an evaluation may not be necessary.

Corrective Action Demonstrated: After retraining was performed by another monitor, the original monitor correctly oriented the probe and successfully completed the thyroid screening.

29

0

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: One Issue No.: 46-06-1.e.1-A-04 Condition: For the emergency worker decontamination station at the Lancaster Strasburg School Complex, the CDV-700 survey meters listed in the Lancaster County Radiological Emergency Response Procedure (RERP) were not calibrated and available. Ludlum survey meters were substituted for the CDV-700s and utilized for contamination monitoring. Although substitute survey meters are allowed per the RERP, a procedure for operational source checks was not available.

Corrective Action Demonstrated: On April 23, 2008 at the Lancaster County Emergency Operations Center from 1750 to 1800, a new procedure (Ludlum 2241-2 Survey Meter Set Up) which adequately addresses a meter's response to a known source was successfully demonstrated.

f. PRIOR ARCAs - UNRESOLVED: None 2.2.3 East Drumore Township Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.1 5.a.1 1.c.1 2.c.1 3.b.1 1.d.1 3.c.1 1.e.1 3.d.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 30

2.2.4 Fulton Township Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.1 5.a.1 1.c.1 2.c.1 3.b.1 1.d.1 3.c.1 1.e.1 3.d.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 2.2.5 Little Britain Township Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.1 5.a.1 1.b.1 2.c.1 3.b.1 1.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 2.2.6 Quarryville Borough Emergency Operations Center

a. MET: 3.a.1 3.b.1 3.c.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None 31

0

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: Two Issue No.: 46-06-3.a.1-A-05 Condition: The Radiological Officer was not familiar with the Lancaster County or Quarryville Radiological Emergency Response Plans to carry out the duties of the position.

Corrective Action Demonstrated: The Radiological Officer (RO) showed emergency workers a radiological briefing video and successfully briefed them on the proper use of dosimetry, reporting requirements, and use of KI in accordance with the Quarryville Borough Radiological Emergency Response Plan. Throughout the exercise, the RO demonstrated a thorough understanding of his duties and acted in a way to minimize exposure to emergency workers in the event of an actual emergency.

Issue No.: 46-06-3.c.l-A-06 Condition: Quarryville Borough did not simulate contacting the daycare centers within their Emergency Planning Zone (EPZ) nor did they realize they were supposed to.

Corrective Action Demonstrated: The Quarryville Borough Radiological Emergency Response Implementing Procedure was updated to include two daycare centers within the EPZ. These daycare centers were successfully notified during the exercise (simulated) in accordance with the Quarryville Borough Radiological Emergency Response Implementing Procedure and extent-of-play.

f. PRIOR ARCAs - UNRESOLVED: None 2.2.7 Quarryville Township Route Alerting

a. MET: 1.d.1 3.a.1 5.a.1 1.e.1 3.b.1 5.a.3

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None 32

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.3 York County 2.3.1 York County Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.1 5.a.1 1.b.1 2.c.1 3.b.1 5.a.3 1.c.1 3.c.1 1.d.1 3.c.2 1.e.1 3.d.1 3.d.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: One (5.b. 1)

Issue Number: 46-08-5.b.1-A-02 Condition: Inaccurate and incomplete information was provided to the media and the public by public information officials in York County. A media release dealing with the evacuation, issued at 2020, was entitled "Evacuation Recommended," but the first sentence in the media release stated "The York County Commissioners through the Office of Emergency Management confirm that Governor Edward Rendell is ordering/recommending an evacuation..."

Possible Cause: York County public information officials were unfamiliar with procedures and other provisions for providing complete and accurate information to the media and the public regarding events involving a nuclear facility.

References:

0 NUREG-0654, E.5, 7; G.3, 4 4 York County Public Information Officer's Checklist EFFECT: Members of the public may have taken incorrect protective actions during this event.

33

0 RECOMMENDATION: Ensure that plans and procedures are followed.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 2.3.2 Delta Township/Peach Bottom Township Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.1 5.a.1 1.b.1 2.c.1 3.b.1 1.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 2.3.3 Delta Township/Peach Bottom Township Route Alerting

a. MET: 1.e.1 3.a.1 3.b.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: Two [1.d. 1, 5.a.3 (Re-demonstrated)]

Issue Number: 46-08-1.d.1-A-03 (Re-demonstrated)

Condition: During the back-up route alerting for a failed siren, the Delta/Peach Bottom Township EOC was unable to communicate with the field team for extensive periods of time.

34

Possible Cause: The combination of equipment restrictions and the terrain in the area hindered the quality of communications. High hills, low valleys and dense forestation adversely effected communications. Also the antenna location at the EOC is somewhat restricted.

References:

NUREG-0654, F. 1, 2 Effect: Poor communications could result in failure to update the field units to emergency alert level changes as well as Potassium Iodide (KI) and evacuation instructions.

Recommendation: Ensure that radio communications are adequate.

Commonwealth Response: During a Remedial Exercise Demonstration on June 11, 2008, York County (Delta/Peach Bottom Township EOC) successfully demonstrated route alerting for failure of siren 32. Peach Bottom Township's Route 2 was split into 2a- Red Route and 2b- Blue Route. The Red Route is the more difficult route in terms of terrain and distance. The Red Route field unit, equipped with one of the new radio system units being rolled-out this year, conducted three successful communications tests with the Delta/Peach Bottom EOC.

The upgraded radio technology was successfully conducted with handheld units; no building antenna required. Two of the communications were conducted in low valley heavily forested areas. Note: The Delta/Peach Bottom EOC's Incident Manager, also a York County employee, is the project manager for the county-wide radio system upgrade.

The Commonwealth believes this successful re-demonstration specifically addresses the Peach Bottom Township's Route 2 sector and that adequate radio system coverage demonstrations are appropriate for other sectors in future exercises.

FEMA Response: We concur.

Corrective Action Demonstrated: During a Remedial Exercise Demonstration on July 11, 2008, Delta/Peach Bottom Township successfully demonstrated radio communications.

Issue Number: 46 5.a.3-A-04 (Re-demonstrated) 35

0 Condition: The back up route alerting for failed siren area (siren 32, Delta/Peach Bottom route 2) was not completed in the 45 minutes required.

Possible Cause: The area is comprised of several dead-end streets. There are winding, narrow roads with many steep hills. Many of these streets are not maintained by any government unit. They are privately owned and some are in serious need of repair and improvement. The nature of the long dead end streets requires the alerting vehicle to drive in, turn around (or back out) past homes that have already been notified. During the exercise the route alerting team left the Emergency Operations Center (EOC) at 1935. At 2030 less than half of the route had been completed. Failing to complete even half of the assignment in almost an hour proved conclusively that the total route could not be completed in the time allowed by only one vehicle.

Running the route with emergency lights and siren would not have significantly improved the time required. The area contains many seasonal homes and summer tourist activity would further delay the operation. Unfavorable weather would also increase the time needed to complete the route.

References:

NUREG-0654, E.6; Appendix 3.B.2.C Effect: Not all residences in a failed siren area would receive timely notification of impending needed actions during an emergency at the Peach Bottom Atomic Station.

Recommendation: Reassess and revise route alerting assignments.

Corrective Action Demonstrated: During a Remedial Exercise Demonstration on June 11, 2008, York County (Delta Township) successfully demonstrated route alerting for failure of siren 32. Delta Township's Route 2 was split into 2a - Red Route and 2b - Blue Route. Two teams were briefed/dispatched from the Township EOC. Both routes were carefully driven at sufficient slow speed to present the PA announcement of an accident at Peach Bottom and for residents to tune to their radio for further announcements.

Route 2a was completed in 36 minutes and Route 2b in 38 minutes, well below the 45 minute maximum allowed.

d. NOT DEMONSTRATED: None 36

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 37

0 3.0 PENNSYLVANIA SCHOOLS 3.1 Chester County 3.1.1 Jordan Bank Elementary School (Oxford Area School District)

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 3.1.2 Nottingham Elementary School (Oxford Area School District)

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

g. PRIOR ARCAs - UNRESOLVED: None 3.2 Lancaster County 3.2.1 Penn Manor High School (Penn Manor School District)

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None 38

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 3.2.2 Swift Middle School (Solanco School District)

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 3.2.3 Quarryville Elementary School (Solanco School District)

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

g. PRIOR ARCAs - UNRESOLVED: None 3.3 York County 3.3.1 South Eastern Middle School West (South Eastern School District)

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None 39

0

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 3.3.2 Kennard Dale High School (South Eastern School District)

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 3.3.3 Red Lion Junior High School (Red Lion School District)

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 40

4.0 STATE OF MARYLAND 4.1 Maryland State Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.d.1 5.a.1 1.d.1 2.b.1 5.b.1 1.e.1 2.b.2 2.c.1

b. DEFICIENCY: None

d. AREAS REQUIRING CORRECTIVE ACTION: One (1.c.1)

Issue Number: 46-08-1.c.1-A-05 Condition: The Prompt Notification System (PNS) and Emergency Alert System (EAS) were not activated after the Site Area Emergency declaration at 0845 in accordance with 5.4.1.3 Step 3 of the Maryland State Radiological Emergency Response Plan. The Plan delineates actions that will be initiated at the State and/or County levels.

Possible Cause: The PNS and EAS were not activated after the Site Area Emergency declaration at 0845 in accordance with 5.4.1.3 Step 3 of the Maryland State Radiological Emergency Response Plan because only Precautionary Protective Action Decisions of "Placing animals on stored feed and water" and "Emergency Workers administer Potassium Iodide (KI)" were in effect. These decisions were transmitted on the 0930 Conference Call between the Maryland Emergency Management Agency, Maryland Department of the Environment, and the two Risk Counties of Cecil and Harford.

References:

• NUREG-0654, A.l.d; A.2.a, b

• Maryland State Radiological Emergency Response Plan, 5.4.1.3 (Site Area Emergency), Step 3 Effect: The public was not alerted that there was an emergency at the Peach Bottom Atomic Power Station until the 1115 PNS activation. Prior to the 1115 activation, press releases and informational messages were disseminated from the risk counties, which may have led to confusion of the general public.

Recommendation: The PNS and EAS must be activated after the Site Area Emergency declaration in accordance with 5.4.1.3 Step 3 41

0 of the Maryland State Radiological Emergency Response Plan.

This activation is to alert the general public that there is an emergency at the Fixed Nuclear Facility and that possible protective actions may be warranted at a later time and that those actions will be transmitted over the EAS.

State Response: The Maryland State Radiological Emergency Response Plan. Step 5.4.1.3 Step 3 states "Activate prompt notification system to notify the public of emergency status, activate EAS system, and provide periodic information updates "if warranted." (emphasis added) This is clearly intended to leave PNS and EAS as an option as other conditions (school evacuations) may necessitate waiting to sound sirens. This issue should be removed from the final report. The State correctly implemented the plan as written and does not intend to change an approved process.

FEMA Response: We have reviewed 5.4.1.3 under Site Area Emergency in the Maryland State Emergency Operations Plan and have determined that "if warranted" is applicable only to providing periodic updates; therefore, this ARCA will remain as classified.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.2 Accident Assessment (Maryland Department of Environment)

a. MET: 1.a.1 2.a.1 4.a.2 1.c.1 2.b.1 4.a.3 1.d.1 2.b.2 i.e. 1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: Two Issue No.: 64-06-2.a.1-A-07 42 0

Condition: Confusing terminology was used when communicating the potassium iodide (KI) decision for emergency workers. The term "field teams" was used when referring to emergency workers.

Corrective Action Demonstrated: At 0915 after the Site Area Emergency declaration, the Radiological Assessment Director in the Maryland Department of Environment (MDE) Accident Assessment Center in accordance with procedure MDE-304 Step III.B.4a recommended to the Secretary of the MDE that the field monitoring teams be given the instruction to take potassium iodide tablets (KI). The Secretary MDE decided that this recommendation would include all emergency workers. She discussed this proposed decision with MEMA and the two counties of Harford and Cecil using the terminology emergency worker. At 0959 the Secretary of MDE signed the Protective Action Decision Form with the box checked for emergency workers in the 10-mile EPZ to ingest KI.

Issue No.: 46-06-2.b.1-A-08 Condition: The decision to recommend potassium iodide (KI) for the Maryland general public was not in accordance with the basis requirements as specified in the Maryland Emergency Operations Plan.

Corrective Action Demonstrated: At 0915 after the Site Area Emergency declaration, the Radiological Assessment Director in.

the Maryland Department of Environment (MDE) Accident Assessment Center in accordance with procedure MDE-304 Step III.B.4a, Rev. 10 dated 02/2008, recommended to the Secretary of the MDE that the field monitoring teams be given the instruction to take potassium iodide tablets (KI). The Secretary MDE decided that this recommendation would include all emergency workers.

She discussed this proposed decision with MEMA and Harford and Cecil Counties. At 0959 the Secretary of MDE signed the Protective Action Decision Form with the box checked for emergency workers in the 10-mile EPZ to ingest KI.

f. PRIOR ARCAs - UNRESOLVED: None 4.3 Joint Information Center, Maryland (Emergency Operations Facility -

Coatesville)

a. MET: 5.b.1

b. DEFICIENCY: None 43

0

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: One Issue No.: 46-06-5.b.1-A-09 Condition: Some of the information in public announcements and emergency alert system (EAS) messages was not accurate. For example, the EAS Announcement - 2 included the appropriate text that a General Emergency was declared, but the heading of the announcement listed the classification as Site Area Emergency. Also, the Public Information Announcement 3 listed an incorrect time of 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> when it should have been 1900 (a previous announcement actually occurred at 1845). Additionally, none of the public announcements and EAS messages referred the public to the main radio station receiving the EAS message (WAMD 970 AM) (as required by the Public Information Officer (PIO) procedures).

Several of the public announcements and EAS messages refer to a calendar for information on protective action procedures; however, the PIO said that they no longer produce an emergency calendar. Finally, the announcements and EAS messages did not contain a public inquiry telephone number.

Corrective Action Demonstrated: During the remedial exercise demonstration updates (Special New bulletins),

and EAS massages, were draft individually utilizing approved pre-scripted massages with appropriate heading and accurate information. As appropriate, the bulletins and EAS message to the public accurately referenced: the rumor Control inquiry phone number; to stay tuned to EAS stations WXCY, WOEL, WBAL and WJSS); and to refer to the school information and public information previously furnished.

Prior to submission to the emergency Services Director, the PIO ensured that each message was individually numbered, dated and saved. After his detailed review to ensure completeness and accuracy, the Director approved each message by signature and time stamp. The PIO then made any necessary corrections and re-saved each message prior 44

to release to the public (media) and other appropriate agencies.

f. PRIOR ARCAs - UNRESOLVED: None 4.4 State Field Monitoring Team A

a. MET: 1.d.1 3.a.1 4.a.1 1.e.1 3.b.1 4.a.3

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 4.5 State Field Monitoring Team B

a. MET: 1.d.1 3.a.1 4.a.1 1.e.1 3.b.1 4.a.3

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 45

0 5.0 MARYLAND RISK JURISDICTIONS 5.1 Cecil County 5.1.1 Cecil County Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.1 5.a.1 1.d.1 2.b.1 3.b.1 5.a.3 1.e.1 2.b.2 3.c.1 2.c.1 3.c.2 3.d.1 3.d.2

b. DEFICIENCY: TWO (1.c.1 & 5.b.1) (Re-demonstrated)

c. AREAS REQUIRING CORRECTIVE ACTION: One 5.b. 1 Issue Number: 46-08-1.c.1-D-01 (Re-demonstrated)

Condition: At 1030, the Emergency Services Director (ESD) instructed the Public Information Officer (PIO) to issue a message notifying the public of the Site Area Emergency, the Agricultural protective action recommendations, and the decision for Emergency Workers to ingest potassium iodide (KI). This message was written as an Emergency Alert System (EAS) message and broadcast without coordination with the State and risk counties, and without benefit of the coordination of siren activation with the other risk county.

At 1042, the ESD directed the PIO to issue an EAS message with updated information. The ESD then attempted to contact Maryland Department of the Environment (MDE) and Harford County, but was unsuccessful. He then directed the PIO to initiate siren activation and message broadcast at 1050 without benefit of coordination with the State and Harford County. The sirens were sounded as contact was made with MDE and Harford County, but the message was not broadcast.

Possible Cause: The ESD did not follow Cecil County Radiological Emergency Response Procedures (RERP) for Direction and Control regarding coordination of initial alert and notification procedures for EAS message broadcast.

46

References:

• NUREG-0654, A.l.d; A.2.a, b

• Cecil County RERP - Section IV.B.2 o(1); Annex B, Attachment 1.1 (second paragraph).

Effect: The message would have been forwarded directly to the general public before the public had received the appropriate alert and notification, potentially causing confusion and panic. In addition, the message included information that was not appropriate for public information (ingestion of KI by emergency workers.)

Recommendation: The ESD must follow the Cecil County RERP concerning Alert and Notification procedures regarding coordination of siren activation and EAS message broadcasting.

Corrective Action Demonstrated: At 1041, a conference call was held with State and County officials, at which time appropriate siren activation and EAS message broadcast logistics were discussed and agreed upon by all parties as of 1100. Siren activation occurred at 1115 and the appropriate EAS message was broadcast at 1118, as coordinated and as specified in the plan and procedures.

Issue Number: 46-08-5.b.1-D-02 (Re-demonstrated)

Condition: After the alert and notification sequence at 1115, Cecil County did not issue a Special News Broadcast or follow-up news release on the evacuation. The public did not receive information regarding evacuation routes, reception center locations, what to take with you, or instructions on pets.

Possible Cause: The Cecil County Public Information Officer (PIO) was modifying informational updates issued at either an early exercise or a recent Cecil County event.

The Director of Emergency Services did not review and sign off on the informational updates.

References:

• NUREG-0654, E.5, 7; G.3.a; G.4.a, b, c

• Kay Goss Memorandum, dated February 2, 1999, "Guidance for Providing Emergency Information and Instructions to the Public for Radiological 47

0 Emergencies," page B-2, paragraph 1-6, 8-9, page C-3, paragraph 4.a, b. 4-7 Effect: The public was not provided with the necessary instructions on routes that were open to traffic, what items to bring with them, or what reception centers were available. This could have caused delays in the public evacuating. People may have not brought necessary items from homes such as important documents or medications.

Recommendation: The Cecil County Director and PIO should issue follow-on informational updates after each alertand notification sequence is complete. Pre-scripted messages should be utilized. The pre-scripted messages should contain all necessary information including but not limited to, evacuation driving directions, reception center locations, items to bring from the home (clothing, bedding, important documents, and medications), information on the handling of pets, etc.

Corrective Action Demonstrated: During a Remedial Exercise Demonstration on June 11, 2008, Cecil County coordinated all decisions with Harford County, Maryland Department of the Environment/Maryland Emergency Management Agency, and Pennsylvania Emergency Management Agency, and then followed up each EAS message with the proper informational updates. Sequencing of the sirens followed by EAS message was followed and all pre-scripted messages were appropriately updated and issued in a timely manner. The sirens were inadvertently (actually) sounded during the first sequence at 1120.

According to the control panel, all sirens activated properly. The Director immediately ordered that the PIO send radio station WXCY an EAS message that the sirens were sounded in error and that no emergency exists. The radio station actually interrupted play at 1132 and broadcast the PIO's EAS Message. A full call-down of local officials and surrounding counties was also accomplished to dispel any concerns.

Issue Number: 46-08-5.b.1-A-08 (Re-demonstrated)

Condition: The Cecil County Public Information Officer (PIO) issued nine informational updates for public dissemination. The informational updates were continuously overwritten. Two of the informational updates 48

contained incomplete sentences. Some of the informational updates were given the same document number, while others were not numbered at all. Some information updates contained titles, dates and times of issuance, while others did not.

Possible Cause: The Cecil County PIO was modifying informational updates issued at either an early exercise or real world event. The PIO did not electronically save the informational updates. The Director of Emergency Services did not review the informational updates.

References:

NUREG-0654, E.5, 7; G.3.a; G.4.c Effect: The media outlets were furnished with incomplete or inaccurate information to the public.

Recommendation: All informational updates should be numbered, titled, dated, and time stamped. Each individual informational update should be saved permanently in electronic format. The Director of Emergency Services should review each update before it is released to the media to verify completeness and accuracy. Pre-scripted messages should be utilized and should contain all necessary information.

Corrective Action Demonstrated: During the remedial exercise demonstration on June 11, 2008, all informational updates (Special News Bulletins) and EAS messages were drafted individually utilizing approved pre-scripted messages with appropriate information. Prior to submission to the Emergency Services Director, the P1O ensured that each message was individually numbered, dated and saved.

After his detailed review to ensure completeness and accuracy, the Director approved each message by signature and time stamp. The P1O then made any necessary corrections and re-saved each message prior to release to the public (media) and other appropriate agencies.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 49

0 5.1.2 Reception Center and Monitoring/Decontamination (Perryville High School)

a. MET: 3.a.1 6.a.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 5.1.3 Emergency Worker Monitoring/Decontamination (Rising Sun Fire Department)

a. MET: 3.a.1 6.a.1 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 5.1.4 Congregate Care (Perryville High School)

a. MET: 6.c. 1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 50

5.1.5 Traffic and Access Control Point (Interview at Emergency Operations Center)

a. MET: I.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 5.1.6 Route Alerting

a. MET: 1.d.1 3.a.1 5.a.3 1.e.1 3.b.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 5.1.7 Ambulance (MS-1 Drill) Rising Sun Emergency Medical Services

a. MET: 3.a.1 6.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 51

0 5.1.8 Union Hospital (MS-1 Drill)

a. MET: 1.e.1 3.a.1 6.d.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: One Issue Number: 46-04-3.a.1-A-02 Condition: The Cecil County Hospital Plan does not identify radiation exposure limits for emergency workers.

Corrective Action Demonstrated: The Cecil County Hospital (Union Hospital) Radiation Policy (Code Silver),

Policy EP-835 approved on 4/15/2008 contains a chart of Protective Action Guidelines for Whole Body Exposure for Emergency Workers. The following dose limits are provided: 5 Rem, all; 10 Rem, protecting valuable property; 25 Rem, lifesaving or protection of large populations; and

+25 Rem, lifesaving or protection of large populations (only on a voluntary basis to persons fully aware of the risks involved, with an upper limit of 75 Rem).

f. PRIOR ARCAs - UNRESOLVED: None 5.2 Harford County 5.2.1 Harford County Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.1 5.a.3 1.c.1 2.b.1 3.b.1 1.d.1 2.b.2 3.c.1 1.e.1 2.c.1 3.c.2 3.d.1 3.d.2

b. DEFICIENCY: Two (5.a.1 & 5.b.1) (Redemonstrated)

c. AREAS REQUIRING CORRECTIVE ACTION: One (5.a. 1) 52 0

Issue Number: 46-08-5.a.1-A-09 (Re-demonstrated)

Condition: Emergency Alert System (EAS) message #5 had inaccurate information. EAS message #5, which was broadcast at 1118, and which was preceded by siren sounding at 1115, stated on the first page that sirens would be sounded at 12:05 p.m.

Possible Cause: The reference to the 1205 siren activation time might have been a typographical error, or possibly a remnant from a previous pre-scripted message draft.

References:

NUREG-0654, E.5, 6, 7 Effect: The references to 1205 siren activation would have been confusing to the public and to other jurisdiction's officials.

Recommendation: Emphasize the need for thorough editing and checking of final EAS messages.

Corrective Action Demonstrated: Harford County, MD adequately re-demonstrated their pubic alert and Notification (A&N) sequence during a remedial exercise held on June 11, 2008. The re-demonstration included Two A&N sequences by sounding sirens, followed by issuance of an EAS message. In both A& n sequences, The EAS message followed siren activation and accurately provided information meeting the four elements required by FEMA guidance (66 FR 47546, September 12, 2001). Each EAS message was reviewed and approved by the Harford county Emergency Manager prior to broadcast. This re-demonstration resolves issue #46-08-5.a. 1-A-09.

Issue Number: 46-08-5.a.1-D-03 (Re-demonstrated)

Condition: Harford County officials prepared four Emergency Alert System (EAS) messages (EAS #1 through EAS #4) which were not coordinated with the other jurisdictions, and which were not preceded by siren activation, as required by the County plan.

Possible Cause: County officials may not have realized the difference between routine news releases and more significant Emergency Alert System messages intended for immediate broadcast to the public.

53

References:

• NUREG-0654, E.5, 6, 7

• Harford County Emergency Operations Plan, Appendix 1, Radiological Emergency Response Plan, Change 10, 02/08, pages APP-1-5, App 1-Tab 1-B-2, App 1-Tab 1-B-4, App 1-Tab 1-B-9, App 1-Tab l-B-12.

Effect: Without coordination with other jurisdictions, and sounding of sirens to alert the public, confusion could have resulted when significant information was broadcast by the EAS stations.

Recommendation: Follow the Harford County plans and procedures for the EAS.

Corrective Action Demonstrated: Harford County officials successfully demonstrated alert and notification to the public, with the required coordination with the State and Cecil County, when they sounded sirens at 1115 and broadcast the EAS message (EAS #5) at 1118.

Issue Number: 46-08-5.b.1-D-04 (Re-demonstrated)

Condition: Harford County officials prepared an Emergency Alert System (EAS) message at 1139, which was not coordinated with the other jurisdictions, and which was not preceded by siren activation, as required by the Harford County plan. This EAS message also had an inaccurate reference to a 1205 siren activation time.

Possible Cause: County officials may not have realized the difference between routine news releases and more significant EAS messages intended for immediate broadcast to the public. The reference to the 1205 siren activation time might have been a typographical error, or possibly a remnant from a previous pre-scripted message draft.

References:

• NUREG-0654, E.5, 7; G.3.a; G.4.a, b, c

• Kay Goss Memorandum, dated February 2, 1999, "Guidance for Providing Emergency Information and Instructions to the Public for Radiological 54

Emergencies," page B-2, paragraph 1-6, 8-9, page C-3. paragraph 4.a, b. 4-7 Effect: Without coordination with other jurisdictions, and sounding of sirens to alert the public, confusion could have resulted when significant information was broadcast by the EAS stations. Also, the reference to the 1205 siren activation time would have been confusing to the public and to other jurisdictions' officials Recommendation: Follow the Harford County plans and procedures for the EAS. Also, emphasize the need for thorough editing and checking of final EAS messages.

Corrective Action Demonstrated: During a remedial exercise held on June 11, 2008, Harford County emergency management personnel followed their procedures and successfully demonstrated the public alert and notification sequence through two siren activations, issuance of two EAS messages and five special news broadcasts. The County Emergency Director reviewed each EAS message for accuracy prior to broadcast.

During the exercise, notification of a Site Area Emergency (SAE) was received at approximately 1051. A conference call was immediately established with Maryland Emergency Management Agency (MEMA), Maryland Department of the Environment (MDE) and Cecil County.

MEMA, Cecil and Harford Counties all concurred with MDE's recommendation to shelter livestock and companion animals; additionally, MDE stressed that potassium iodide (KI) was not advised for emergency workers or the general public. A separate conference call was immediately held to coordinate sounding of sirens and broadcast of an EAS message with the groups above and affected jurisdictions in Pennsylvania. With all parties concurring, the first siren activation sequence was initiated at 1120 from the Harford County 911 Call Center. The Public Information Officer faxed and emailed a pre-scripted EAS message to WXCY 103.7 FM (the Harford County primary EAS radio station). Three special news broadcasts were additionally issued: (1) additional information on the SAE, (2) an agricultural advisory for livestock, and (3) a message regarding school evacuations and closures. Special news broadcasts were appropriately 55

6 sent by facsimile and e-mail to multiple predefined media outlets.

At 1144, the Harford County Emergency Director received notification of a General Emergency ECL. Two conference calls, as described for the SAE above, were held to discuss protective actions and to coordinate sirens and EAS messages with all affected jurisdictions. All Maryland jurisdictions concurred with MDE's recommendation to evacuate all areas in Harford and Cecil County within the 10-mile Emergency Planning Zone, and to recommend KI for Emergency Workers and the general public. Sirens were sounded from the 911 Call Center at 1205 and an EAS message broadcast from WXCY at 1208. Two special news broadcasts were issued to the media outlets described above: (1) a message regarding evacuation that included instructions to evacuees and, (2) a message stating that KI was available at specified reception centers.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 5.2.2 Reception Center and Monitoring/Decontamination (Fallston High School)

a. MET: 3.a.1 6.a.1 6.b.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: One Issue Number: 46-06-1.e.1-A-11 Condition: Harford County - Emergency Worker KI has an expiration date of 3/2005. However, KI for the public had an expiration date of 4/2007.

56

Corrective Action Demonstrated: Potassium Iodide was available for distribution to emergency workers and the public at the Fallston High School Reception/Monitoring and Decon facility. The expiration date for the KI was in the year 2014. Sufficient doses were available for the emergency workers and the general public, along with instructions for ingestion.

f. PRIOR ARCAs - UNRESOLVED: None 5.2.3 Emergency Worker Monitoring/Decontamination (Fallston High School)

a. MET: 3.a.1 6.a.1 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 5.2.4 Congregate Care (Fallston High School)

a. MET: 6.c. 1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 5.2.5 Traffic and Access Control Point

a. MET: 1.d.1 3.a.1 1.e.1 3.b.1 3.d.1 3.d.2 57

a

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 5.2.6 Route Alerting

a. MET: 1.d.1 2.a.1 3.a.1 5.a.3 1.e.1

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: One (3.b. 1)

Issue Number: 46-08-3.b.1-A-10 (Re-demonstrated)

Condition: At 0955, the Harford County Sheriff's Office representative in the Emergency Operations Center (EOC) received authorization for emergency workers to take Potassium iodide (KI) and he transmitted these instructions to take KI on the Sheriff's Office (SO) radio. The Route Alerting officers were in a garage attending a briefing and did not hear the instructions to take KI, and did not ingest KI.

Possible Cause: In interviewing the Route Alerting officers, it was determined that the Sheriff in the EOC was using an alternate SO radio frequency, just for the demonstration, to avoid noise of normal SO radio frequency traffic in the EOC.

The Route Alerting officers were using their SO hand held radios to monitor the normal SO radio frequency and their SO vehicle radio to monitor the alternate frequency used by the Sheriff.

However, when the Sheriff transmitted the instruction to take KI, the Route Alerting Officers were inside the EOC garage attending the emergency worker briefing and could 58

hear only the normal SO frequency on their hand-held radios.

Reference:

NUREG-0654, 3.10.e Effect: Because the Route Alerting officers did not take KI, they could receive unnecessary radiation exposure to radioactive iodine.

Recommendation: The Sheriff could communicate with the Route Alerting officers through the SO dispatcher using the normal SO radio frequency.

Corrective Action Demonstrated: During a remedial exercise on June 11, 2008, Route Alerting Officers received information by radio from the Harford County Sheriff Officer representative that emergency workers and the public were authorized to take Potassium Iodide and they simulated the ingestion of KI.

d. NOT DEMONSTRATED: None

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 59

a 6.0 MARYLAND SCHOOLS 6.1 Cecil County Public School District 6.1.1 Conowingo 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 6.2 Harford County Public School District 6.2.1 North Harford 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 6.2.2 North Harford Middle School

a. MET: 3.c.2

b. DEFICIENCY: None

c. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None 60

e. PRIOR ARCAs - RESOLVED: None

f. PRIOR ARCAs - UNRESOLVED: None 6.2.3 North Harford 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 61

0 APPENDIX 1:

Acronyms and Abbreviations ACP Access Control Point ANS Alert & Notification System ARC American Red Cross ARC 3031 American Red Cross document Mass Care - Preparednessand Operations ARCA Area Requiring Corrective Action ARES Amateur Radio Emergency Service ATL Assistant Team Leader ATWS Anticipated Transient Without Scram A&N Alert and Notification CFR Code of Federal Regulations cpm Counts per minute DILs Derived Intervention Levels DRD Direct Reading Dosimeter EAL Emergency Action Level EAS Emergency Alerting System EBS Emergency Broadcast System ECL Emergency Classification Level ENC Emergency News Center EOC Emergency Operations Center EOF Emergency Operations Facility EPLO Emergency Preparedness Liaison Officer EPZ Emergency Planning Zone ESD Emergency Services Director FAA Federal Aviation Administration FDA Food and Drug Administration 0 FEMA Federal Emergency Management Agency FR Federal Register FRERP Federal Radiological Emergency Response Plan HQ Headquarters ICFI ICF International IPZ Ingestion Pathway Emergency Planning Zone JIC Joint Information Center KI Potassium Iodide 62

LOCA Loss of Coolant Accident MDE Maryland Department of the Environment MEMA Maryland Emergency Management Agency MSIV Main Steam Isolation Valve MS-I Medical Services Drill MW Megawatt NRC U.S. Nuclear Regulatory Commission NUREG-0654 NUREG-0654/FEMA-REP-1, Rev. 1 (Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants), November 1980 ORO Offsite Response Organization PAD Protective Action Decision PAG Protective Action Guidance PAR Protective Action Recommendation PBAPS Peach Bottom Atomic Power Station PEMA Pennsylvania Emergency Management Agency PIO Public Information Officer PRD Permanent Record Dosimeter PSP Pennsylvania State Police R Roentgen(s)

RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Services Rem Roentgen Equivalent Man REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RO Radiological Officer RPS Reactor Protection System RWCU Reactor Water Clean-Up R/hr Roentgens per hour SAE Site Area Emergency SD School District SEOC State Emergency Operations Center SGTS Stand-by Gas Treatment System SOP Standard Operating Procedure TCP Traffic Control Point TL Team Leader TSC Technical Support Center TWP Township 63

0 APPENDIX 2:

Exercise Evaluators and Team Leaders The following is a list of the personnel who evaluated the Peach Bottom Atomic Power Station (PBAPS) exercise on April 22-23, 2008 and Out-of-Sequence activities on April 22, 2008.

Evaluator Team Leaders (TL) and Assistant Team Leaders (ATL) are indicated by the letters after their organization's name. The organization each evaluator represents is indicated by the following abbreviations:

FEMA Federal Emergency Management Agency ICF ICF International 40 NRC U.S. Nuclear Regulatory Commission I. BIENNIAL PLUME EXERCISE - April 22, 2008 STATE OF MARYLAND EVALUATION SITE EVALUATOR ORG.

State Emergency Operations Center Wierman, Ken FEMA - TL Wood, Kim ICF - ATL Duggleby, Robert ICF Accident Assessment - MDE Rodgers, Reggie ICF - TTL Emergency News Center See Pennsylvania ICF (Evaluated on 4/23/08 at JIC) assignment State Field Monitoring Team A Blunt, Deborah ICF State Field Monitoring Team B Cormier, Paul ICF 01 64

I. BIENNIAL PLUME EXERCISE - April 22, 2008 (Cont.)

MARYLAND RISK JURISDICTIONS EVALUATION SITE EVALUATOR ORG.

Cecil County County Emergency Operations Center Smith, Roy ICF - TL Johnson, Nancy ICF - ATL Swygert, Wendy ICF Traffic and Access Control Point Black, Robert ICF Route Alerting Lemeshka, Robert ICF Ambulance (MS-I Drill) Edmonson, William ICF Union Hospital (MS-I Drill) Taylor, Patrick ICF Harford County County Emergency Operations Center Rospenda, Robert ICF - TL Smith, Richard ICF - ATL Borchardt, Lenora ICF Traffic and Access Control Point Nelson, Sam ICF Route Alerting Green, Tracy ICF 65

a II. BIENNIAL PLUME EXERCISE - April 23, 2008 COMMONWEALTH OF PENNSYLVANIA EVALUATION SITE EVALUATOR ORG.

State Emergency Operations Center Christiansen, Henry ICF - TL Singleton, Jacque FEMA - ATL lannazzo, Quirino (Bud) ICF Jobe, Roger ICF Joint Information Center (JIC) Nied, Paul (PA) ICF (EOF Coatesville) Palmer, William (MD) ICF 0

Emergency News Center White, David ICF (Harrisburg)

Accident Assessment Center Thome, Daryl ICF (Harrisburg)

Delta Township/Peach Bottom Township (York County)

Township Emergency Operations Center Bolender, Gary ICF Route Alerting Flynn, John ICF 0

66 0

II. BIENNIAL PLUME EXERCISE - April 23, 2008 (Cont.)

COMMONWEALTH OF PENNSYLVANIA EVALUATION SITE EVALUATOR ORG.

Chester County County Emergency Operations Center Shych, Wayne FEMA - TL McClanahan, James ICF - ATL Burniss, Michael ICF O'Brien, Bill ICF Lancaster County County Emergency Operations Center Freeman, Bait, FEMA - TL Sosler, Louis ICF - ATL McPeak, Richard ICF Ray, Bart ICF East Drumore Township (Lancaster County)

Township Emergency Operations Center Vork, Robert ICF Fulton Township (Lancaster County)

Township Emergency Operations Center Cordaro, Frank ICF Little Britain Township (Lancaster County)

Township Emergency Operations Center Boaze, Earnest ICF Quarryville Borough (Lancaster County)

Borough Emergency Operations Center Earnshaw, Keith ICF (Partial)

Route Alerting Dalton, Mark ICF York County County Emergency Operations Center Hough, Angela FEMA - TL Samsel, Rosemary ICF - ATL Davidson, Todd ICF Wessman, Richard ICF 67

a III. OUT-OF SEQUENCE DEMONSTRATIONS A. COMMONWEALTH OF PENNSYLVANIA - RED CROSS April 22, 2008 - 0830-1200 hours EVALUATION SITE EVALUATOR ORG.

American Red Cross Telephone interview and verification of resources listed in the Extent of Play Chester County Southeast Pennsylvania Chapter McClanahan, James ICF (Philadelphia, PA)

Lancaster County ARC of the Susquehanna Valley Sosler, Louis ICF (Harrisburg, PA)

York County York County Chapter Hough, Angela FEMA (York, PA) 0 68 0

III. OUT-OF SEQUENCE DEMONSTRATIONS (Cont.)

B. COMMONWEALTH OF PENNSYLVANIA - SCHOOLS April 22, 2006 - 0900-1100 hours Bell, Deborah ICF - TL (TL- All PA Schools) (Schools)

EVALUATION SITE EVALUATOR ORG.

Chester County Jordan Bank Elementary School Bell, Deborah ICF - TL (Oxford Area S.D.)

Nottingham Elementary School O'Brien, Bill ICF (Oxford Area S.D.)

Lancaster County Penn Manor High School Earnshaw, Keith ICF (Penn Manor S.D.)

Swift Middle School Ray, Bart ICF (Solanco S.D.)

Quarryville Elementary School Dalton, Mark ICF (Solanco S.D.)

York County SE Middle School West Flynn, John ICF (South Eastern S.D.)

Kennard Dale High School Davidson, Todd ICF (South Eastern S.D.)

Red Lion Jr. High School Wessman, Richard ICF (Red Lion S.D.)

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0 III. OUT-OF SEQUENCE DEMONSTRATIONS (Cont.)

C. STATE OF MARYLAND - SCHOOLS April 22, 2008 - 0900-1100 hours Goldberg, Gary ICF - TL (TL - All MD schools) (Schools)

EVALUATION SITE EVALUATOR ORG.

Cecil County Conowingo Elementary School Lowe, Nick ICF (Cecil Co. Public S.D.)

Harford County 0 North Harford Elementary School MacDonald, George ICF (Harford Co. Public S.D.)

North Harford Middle School Himle, Doug ICF (Harford Co. Public S.D.)

North Harford High School Goldberg, Gary ICF - TL (Harford Co. Public S.D.)

0 70 40

III. OUT-OF SEQUENCE DEMONSTRATIONS (Cont.)

D. COMMONWEALTH OF PENNSYLVANIA - TCP/ACP April 22, 2008 - 1000-1200 hours EVALUATION SITE EVALUATOR ORG.

State Police Traffic Control Points/Access Petta, David ICF Control Points - Lancaster Barracks E. STATE OF MARYLAND - RECEPTION/MONITORING &

DECONTAMINATION April 22, 2008 - 1900-2100 hours EVALUATION SITE EVALUATOR ORG.

Cecil County Reception Center and Monitoring/ Harrington, Larry ICF Decontamination (Perryville High School)

Emergency Worker Monitoring/ Bonner, Ronald ICF Decontamination (Rising Sun Fire Dept.)

Congregate Care (Perryville High School) Harrington, Larry ICF Harford County Reception Center and Monitoring/ Bevan, Alan ICF Decontamination (Fallston High School)

Emergency Worker Monitoring/ Bevan, Alan ICF Decontamination (Fallston High School)

Congregate Care Bevan, Alan ICF (Fallston High School)

F. COMMONWEALTH OF PENNSYLVANIA - EMERGENCY WORKER PMC April 22, 2008 - 1900-2100 hours EVALUATION SITE EVALUATOR ORG.

Lancaster County Emergency Worker Denson, Steve ICF Monitoring/Decontamination (Lampeter Strasburg School Complex - Field House) 71

6 APPENDIX 3:

Exercise Evaluation Area Criteria and Extent of Play Agreement This appendix contains the extent of play agreements from the Commonwealth of Pennsylvania and the State of Maryland, both were approved on February 27, 2008 by the Federal Emergency Management Agency (FEMA) Region III.

The exercise evaluation area criteria, contained in the "FEMA Radiological Emergency Preparedness Exercise Evaluation Methodology", 67 FR 20580, April 25, 2002, represent a functional translation of the planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for the Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980.

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

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Pennsylvania Extent-of-Play Agreement PEACH BOTTOM ATOMIC POWER STATION 2008 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE METHOD OF OPERATION FINAL 2/05/08

1. Peach Bottom Atomic Power Station (PBAPS)

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. A pre-approved exercise scenario will beused. PBAPS will notify the State EOC, the Bureau of Radiation Protection and Risk Counties of emergency classifications.

2. Bureau of Radiation Protection (BRP)

Personnel will be present at the State EOC, the nuclear facility EOF, TSC and field locations; BRP Field Teams will not be evaluated.

3. PEMA Operations at State EOC This "Method of Operation" Document includes activities for the Full-Scale Plume Exercise (April 23, 2008), and the "Out of Sequence" Activities (April 22, 2008).

A. Plume Exercise - April 23, 2008 PEMA Bureau of Operations and Training staff, augmented by designated PEMA personnel from the Fire Commissioner's Office, the Bureau of Administration, Technical Services, Plans, plus Emergency Preparedness Liaison Officers (EPLOs) with accompanying response team members from designated state departments/agencies will comprise initial operations at the State Emergency Operations Center (EOC). The State EOC will be evaluated during this exercise.

PEMA EOC will maintain a cell to support Maryland's daytime plume exercise held on April 22, 2008.

B. Plume Exercise - "Out of Sequence" Activities - April 22, 2008.

PEMA Bureau of Operations and Training staff, augmented by designated PEMA personnel will disseminate exercise related messages to the participating Counties for dissemination to the participating School Districts during the morning of April 22, 73

0 2008. The State Emergency Operations Center (EOC) and County EOCs will NOT be evaluated during the "Out of Sequence" component. PEMA personnel will serve as "observers" at the identified School Districts.

The Pennsylvania State Police (PSP) demonstration will take place at PSP York Barracks, located at the Loganville Exit on 1-83, York County. The PSP briefing will be performed out of sequence in a demonstration window of 10:00 a.m. to 12:00 a.m.

on April 22. 2008.

PEMA personnel will serve as "Observers" at the Lampeter Strasburg School Complex (Field House) exercise location during the evening "Out-of-Sequence" component April 22, 2008. An exercise coordinator will remain in the State EOC.

The State Emergency Operations Center (EOC) and Counties will NOT be evaluated during the evening "Out of Sequence" component.

One Emergency Worker location, Lampeter StrasburgSchool Complex (Field House), will be evaluated on April 22, 2008. All otherfacilities, i.e., Reception Centers, Mass Care Centers, and Monitoring/DecontaminationCenters (for the public) and Stations (forEmergency Workers other than Lampeter StrasburgSchool Complex) are exemptedfrom evaluationduring this exercise.

4. PEMA Area Office Operations The PEMA Area Offices (Harrisburg-Central Area and Hamburg-Eastern Area) will not be activated nor evaluated during this exercise. Selected staff of the Area Offices will serve as Liaison Officers to Risk Counties as assigned. Liaison Officers are exercise participants.

5. Counties Designated to Participate The three risk counties (Chester, York and Lancaster), in coordination with PEMA, will demonstrate the capability to mobilize appropriate staff, activate their respective Emergency Operations Centers and implement emergency response operations to include sheltering and/or evacuation. County government will provide direction and coordination to risk municipalities. Actual sheltering or evacuation of the general public will be simulated.

6. PEMA Liaison Officers Liaison officers will be present at the participating risk county EOCs, Maryland State EOC, the PBAPS Emergency Operations Facility (EOF), and PBAPS Joint Information Center (JIC) to provide assistance, guidance, and support. These liaison officers will participate as players in the exercise.

7. Controllers 74

A lead controller will be present in the State EOC. A controller will be present at the emergency worker monitoring/decontaminating station at the Lampeter Strasburg School Complex (Field House) on the evening of April 22, 2008. Controllers are not players.

Controllers will provide pre-approved injects and information to the players, as appropriate, regarding radiological readings during the monitoring of personnel. Live radioactive sources will not be used. Exception: individuals tasked with the setup of portal monitoring equipment (if used) will use a standard1 micro curie Cesium 137 sourcefor the purpose of conducting operationaltests. Additionally, appropriatetest sources will be available and used to verify the operationof the monitoring / survey instrumentsper manufacturers' recommendations.

April 22, 2008 schools demonstration: PEMA will provide controllers at the risk county EOCs to provide inject messages. Schools exercise messages will NOT come from PEMA EOC.

8. PEMA Observers PEMA staff, qualified county emergency management personnel, and/or 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 proceedings,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 identified 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 Chester, Lancaster and York Counties.

Plume Phase Exercise (April 23, 2008): Federal evaluators will be present at the identified risk and support county EOC's to evaluate player response to the actual and simulated events in the exercise scenario. Additionally, one-third of the risk municipalities will be federally evaluated.

Out of Sequence A.M. Period (April 22, 2008): Federal evaluators will be present at the identified "out-of-sequence" demonstration sites per Attachment A,Section I.B.1. These include the identified Public School Districts.

The Pennsylvania State Police (PSP) demonstration will take place at PSP York Barracks, located at the Loganville Exit on 1-83, York County. The PSP briefing will be performed out of sequence in a demonstration window of 10:00 a.m. to 12:00 a.m. on April 22, 2008.

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Out of Sequence P.M. Period (April 22, 2008): Federal evaluators will be present at the identified Emergency Worker Monitoring and Decontamination (Lampeter Strasburg School Complex - Field House) as identified in Attachment A,Section I.B.5.

10. Demonstration Windows In order to provide for more effective demonstrations, as well as to permit the release of volunteers from exercise play at a reasonable hour, periods of time (Demonstration Windows) have been designated during which specified actions will be accomplished /

demonstrated.

The "demonstration windows" for this exercise are:

A. Plume Phase Exercise The out-of-sequence MS-I hospital demonstration was federally evaluated at York Hospital, York County on June 6, 2007.

County and municipal EOC operations will be conducted on April 23, 2008. (Please refer to the Extent of Play Demonstration Tables, Attachment A, Sections I.A. 1 and I.A.2).

The out-of-sequence exercise window for school demonstrations will be from 9:00 -

11:00 a.m. on April 22, 2008.

The out-of-sequence interview of Pennsylvania State Police traffic control / access control points will be from 10:00 a.m. - 12:00 noon. April 22, 2008.

The out-of sequence demonstration for one (1) emergency worker station will be conducted from 7:00 - 9:30 p.m. on April 22, 2008 per Attachment A,Section I.B.5.

One Emergency Worker location, Lampeter StrasburgSchool Complex (FieldHouse),

will be evaluated on April 22, 2008. All otherfacilities,i.e., Reception Centers, Mass Care Centers, and Monitoring/DecontaminationCenters (forthe public )and Stations (forEmergency Workers other than Lampeter StrasburgSchool Complex) are exemptedfrom evaluation during this exercise.

All demonstrations will commence promptly and, barring any complications, not continue beyond the time of the designated demonstration window.

B. Post Plume Exercise A post-plume phase exercise is not scheduled during this evaluation.

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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 stand-down their portion of the exercise.

b. The risk county EOC will remain operational until the exercise is officially terminated by the State Lead Controller. The State EOC will issue an Exercise Termination Message.

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.

13. Re-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 may be provided by the players, observers, and/or controllers.

Evaluators are not permitted to provide refresher training. Re-demonstrations will be negotiated between the players, observers, controllers, and evaluators. PEMA may advise the RAC Chair prior to initiating any re-demonstrations. It is permissible to extend the demonstration window, within reason, to accommodate the re-demonstration. Activities corrected from a re-demonstration will be so noted.

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0 PEACH BOTTOM ATOMIC POWER STATION 2008 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE EXTENT OF PLAY AGREEMENT EVALUATION AREA 1 Emergency Operations Management Sub-element L.a - Mobilization INTENT This sub-element is derived 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 1.a.l: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654, A.4; D.3, 4; E.1, 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 individual's duty location or residence. Further, pre-positioning of staff for out-of-sequence demonstrations is appropriate in accordance with the extent of play agreement.

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

PEMA NegotiatedExtent of Play:

Pre-positioningof state emergency personnel (Liaison Officers) at the Emergency Operations Facility(EOF), the Utility Joint Information Center (JIC)and at Risk Counties is appropriate due to the commuting distancefrom the individual'sduty location or residence. Risk counties may pre-positionEOC staff, call-outprocedures will be conducted through interviews. Risk municipalities will conduct call-outs to demonstrate the mobilization of key personnel.

• Actual calls (orpager notifications)will be made to the municipal EOC personnel Jbr the Plume Phase exercise per plans and procedures.

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" In all instances, the demonstrationof a shift change is NOT required. Twenty-four hour staffing will be demonstrated by means of a rosteror staffing chart.

" All out-of-sequence players and equipment will be pre-positioned (School District personnel, PennsylvaniaState Police ACP, Reception Centers, Emergency Worker Monitoring and DecontaminationStations and Monitoringand DecontaminationCenters).

• Individuals working in statefacilities and county EOCs may be pre-positionedfor the plume phase.

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

Criterion 1.b.l: 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 and/or alternate facility (if required to support operations).

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

PEMA NegotiatedExtent of Play: None Sub-element 1.c - Direction and Control INTENT This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to control their overall response to an emergency.

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

(NUREG-0654, A.l.d; A.2.a, b) 79

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

All activities associated with direction and control must be performed based on the ORO's plans and procedures and completed as they would be in an actual emergency, 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 is derived 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 1.d.1: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations. (NUREG-0654, F.1, 2)

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.

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

PEMA NegotiatedExtent of Play:

Risk Counties will communicate with the State EOC via SEVAN (primary)and e-mail (secondary.) PASTAR, State 800 MHz Radio System, and commercial telephone are available fJr back-up. The State EOC may communicate with the utility and the risk counties via dedicated telephone circuits, commercial "dial-up" lines, or other availablemeans.

Risk Counties will communicate with their risk municipalitiesvia public safety radio frequencies (EMA Radio), Commercial Telephone, Fax, or Amateur Radio Communications (ARES / RACES) or other availablemeans.

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

Criterion 1.e.l: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG-0654, H.7, 10; J.10.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 ORO's plans and/or procedures in support of emergency operations. Use of maps and displays is encouraged.

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

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

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

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

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

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

Pharmacopoeia standards.

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

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

PEMA NegotiatedExtent of Play:

In PennsylvaniaCDV-700s are calibratedevery 4-years; modern instrumentsare calibrated every 2 years. Support county functions outside of the EPZ do not have DRDs, or KI, but those responsiblefor reception centers and/ormonitoring and decontaminationcenters will have PRDs.

Evaluation of KI quantities will be verified using inventory sheets. KI will not be removed from storage locations and boxes /packages will not be opened. KI questions will be addressed through interviews.

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

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All DRDs "read" in units of Roentgens. The commonwealth, counties and municipalitiesdo not use direct reading dosimeters which "read" in units of milli-Roentgens.

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0 EVALUATION AREA 2 Protective Action Decision-Making Sub-element 2.a - Emergency Worker Exposure Control INTENT This sub-element is derived 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 ORO's plans and procedures, to authorize emergency worker exposure limits to be exceeded for specific missions.

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

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.10.e, f)

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 KI as a protective measure, based on the ORO's plan and/or procedures or projected thyroid dose compared with the established Protective Action Guides (PAGs) for KI administration.

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

PEMA NegotiatedExtent of Play: None 84

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

Criterion 2.b.l: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654, 1.8, 10 and Supplement 3)

EXTENT OF PLAY During the initial stage of the emergency response, following notification of plant conditions that may warrant offsite protective actions, the ORO should demonstrate the capability to use appropriate means, described in the plan and/or procedures, to develop protective action recommendations (PARs) for decision-makers based on available information and recommendations from the licensee and field monitoring data, if available..

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

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

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

PEMA Negotiated Extent of Play: None 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 ORO policy). (NUREG-0654, J.9; J.10.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 ORO staff.

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

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

If more than one ORO is involved in decision-making, OROs should communicate and coordinate PADs with affected OROs. OROs should demonstrate the capability to communicate the contents of decisions to the affected jurisdictions. 0 All decision-making activities by ORO personnel must be performed based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play: None Sub-element 2.c - Protective Action Decisions Consideration for the Protection of Special Populations 86

INTENT This sub-element is derived 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 (e.g., hospitals, nursing homes, correctional facilities, schools, licensed day care centers, mobility impaired individuals, and transportation dependent individuals). Focus is on those special population groups that are (or potentially will be) affected by a radiological release from a nuclear power plant.

Criterion 2.c.1: Protective action decisions are made, as appropriate, for special population groups. (NUREG-0654, J.9; J.10.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, Evacuation Time Estimates, 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 ORO personnel, the ECL at which these recommendations are received, preplanned strategies for protective actions for that ECL, and the location of students at the time (for example, whether the students are still at home, en route to the school, or at the school).

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

PEMA NegotiatedExtent of Play: None 87

0 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 is derived from NUREG-0654, which provides that OROs should have the capability to provide for the following: distribution, use, collection, and processing of direct-reading 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 (e.g., written procedures and/or co-workers) in providing responses.

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S Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission and adequate control of exposure can be effected for all members of the team by one dosimeter worn by the team leader. Emergency workers who are assigned to low exposure rate areas, e.g., at reception centers, counting laboratories, emergency operations centers, and communications centers, may have individual direct-reading dosimeters or they may be monitored by dosimeters strategically placed in the work area. It should be noted that, even in these situations, each team member must still have their 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 ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA Negotiated Extent of Play:

Radiological briefings will be provided to address exposure limits and procedures to replace those approachinglimits 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.

Distributionof KI will be simulated.A maximum of six (6) Dosimetry-KI reportforms will be demonstrated.

OROs should also demonstrate the use offorms to emergency workers.

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

In Pennsylvania, emergency workers outside of the EPZ do not have turnback 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 individualdirect-readingdosimeters or they may be monitored by dosimeters strategically placed in the work area. In Pennsylvaniathis will be accomplishedthrough the use of an area kit. In Pennsylvania this will be accomplished through the use of an area kit. The area kit process is explained in State, County and Municipal Plans.

Standardissue of dosimetry and potassium iodidefor each category of emergency worker is as follows:

Category A: 1 PRD, 1 DRD, and 1 unit of KI Category B: 1 PRD and 1 unit of KI Category C: 1 PRD 90

All locations that have dosimetry equipment indicated within their RadiologicalEmergency Response Plan (RERP), will make the dosimetry equipment (and KI) availablefor inspection by the FederalEvaluator.Simulation PRDs with mock serial numbers will be used.

Sub-element 3.b - Implementation of KI Decision INTENT This sub-element is derived 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 ORO option and is reflected in ORO's 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 (not the general public) is maintained. (NUREG-0654, J.10.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 ORO plan and/or procedures, to members of the general public. OROs should demonstrate the capability to accomplish distribution of KI consistent with decisions made. Organizations should have the capability to develop and maintain lists of emergency workers and institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest KI. The ingestion of KI recommended by the designated ORO health official is voluntary.

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

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

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

PEMA Negotiated Extent of Play:

Within Pennsylvania, the PennsylvaniaDepartmentof Health is responsiblefor distributionof KI to the generalpublic located within the EPZ. Pre-distributionis accomplishedon an annual basis. KI is not distributedto the generalpublic at the time of an emergency.

Evaluation of emergency worker KI quantities will be verified using inventory sheets. KI will not be removedfrom storage locations and boxes will not be opened. KI questions will be addressed through interviews.

Personnelassigned to operate Monitoring/ Decontaminationcenters and stations are not issued DRDs or KI since the centers/stationsare located outside the EPZ. Each will be issued a simulated PRD with mock serial numbers. For purposes of demonstration,a maximum of six PRDs will be issued.

Sub-element 3.c - Implementation of Protective Actions for Special Populations INTENT This sub-element is derived 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.1: Protective action decisions are implemented for special populations other than schools within areas subject to protective actions. (NUREG-0654, J.10.c, d, g)

EXTENT OF PLAY Applicable OROs should demonstrate the capability to alert and notify (e.g., 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 ORO's plans and procedures.

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

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

PEMA Negotiated Extent of Play:

The names, locations and contact information of identified individuals with identified special needs are maintained on a list at their respective municipal FOC (based upon residential jurisdiction). Copies of these lists will not be provided to the evaluators; however, evaluators will be allowed to inspect the lists during the exercise.

Initial contact with special populations and receptionfacilities will be actual (hospitals, nursing homes and correctionalfacilities). All subsequent calls will be simulated. Actual contacts (up to two per risk county) will be made with transportationproviders as per plan. All actual and simulated contacts should be logged.

Criterion *3.c.2: OROs/School officials decide upon and implement protective actions for schools. (NUREG-0654, J.1O.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 director/bus dispatcher), and at least one bus driver (and the bus driver's escort, if applicable) should be available to demonstrate knowledge of their role(s) in the evacuation of school children. Communications capabilities 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 ORG's plans and procedures as negotiated in the Extent of Play Agreement.

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

PEMA Negotiated Extent of Play:

School Students will not be involved during the exercise. Actions and activities associated with the demonstrationof Criterion3. c. 2 will be limited to the School DistrictAdministration key personnel and the County. Evacuation of students will be conducted through an interview process with School Districtpersonnel or the buildingprincipal.

The -roleof the bus drivermay be conducted through an interview with school or transportation officials (or designee) if a bus driver is not available.Actual demonstrationof the bus route is not requiredand will not be demonstrated.Maps or route descriptions will be availablefor 0 illustrationpurposes.

Risk County school plans do not require communications between the school and vehicles. Bus drivers are not consideredemergency workers and therefore do not requiredosimetry.

Privateschools, private kindergartens,and day care centers do not participatein REP exercises.

However, OROs will be preparedto show evaluatorslists of thesefacilitiesthat they would contact in the event of an emergency in accordancewith plans and procedures.Any simulatedcontacts should be logged.

Sub-element 3.d. - Implementation of Traffic and Access Control INTENT This sub-element is derived 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 evacuated/sheltered 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.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654, J.10.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 94

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

PEMA NegotiatedExtent of Play:

Municipal Traffic and Access control will be demonstrated by interview at the applicableEOC of jurisdiction..The traffic / access control personnel will not be deployed to the traffic / access control point(s). If the designatedassignment is a location within the EPZ, a radiological briefing will be provided to the assigned individuals.

Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654, J.10.k)

EXTENT OF PLAY 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 ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA Negotiated Extent of Play:

ORO's should demonstrate the capability, as requiredby the scenario, to identify and take appropriateactions concerning impediments to evacuation. Actual dispatchof resources to deal with impediments, such as tow trucks, need not be demonstrated; however, simulated contacts will be logged.

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0 Sub-element 3.e - Implementation of Ingestion Pathway Decisions This sub-element will not be evaluated during this exercise.

Sub-element 3.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 is derived from NUREG-0654, which provides that OROs should have the capability to deploy field teams with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654 indicates that OROs should have the capability to use field teams within the plume emergency planning zone to measure airborne radioiodine in the presence of noble gases and to measure radioactive particulate material in the airborne plume.

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

Criterion 4.a.l: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates. (NUREG-0654, H.10; 1.8, 9, 11)

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

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

PEMA Negotiated Extent of Play:

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

Criterion 4.a.2: Field teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654, 1.8, 11; J.10.a)

EXTENT OF PLAY Responsible OROs should demonstrate the capability to brief teams on predicted plume location and direction, travel speed, and exposure control procedures before deployment.

Field measurements are needed to help characterize the release and to support the adequacy of implemented protective actions or to be a factor in modifying protective actions. Teams should be directed to take measurements in such locations, at such times to provide information sufficient to characterize the plume and impacts.

If the responsibility to obtain peak measurements in the plume has been accepted by license field monitoring teams, with concurrence from OROs, there is no requirement for these measurements to be repeated by State and local monitoring teams. If the license teams do not obtain peak measurements in the plume, it is the ORO's decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coordination of plume measurement information among all field teams (licensee, federal, and ORO ) is essential.

Coordination concerning transfer of samples, including a chain-of-custody form, to a radiological laboratory should be demonstrated.

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

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

PEMA Negotiated Extent of Play:

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

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Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654, 1.8, 9, 11)

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

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

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

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

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.IV.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 ORO's plan and/or procedures, completion of system activation should be accomplished in a timely manner (will not be subject to specific time requirements) for primary alerting/notification. The initial message should include the elements required by current FEMA REP guidance.

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

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

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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 ORO's plans and procedures and completed as they would be in an actual emergency, except as noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

The Commonwealth of Pennsylvaniahas implemented a Statewide EAS Control system in cooperationwith the PennsylvaniaAssociation of Broadcastersper the State Emergency Communications Committee and Pennsylvania Emergency Alert System State EAS Plan (April 1, 2004). The State EOC (PEMA) is the initiatingpointfor the activation of the EAS. Risk Counties have the control equipmentfor activation of sirens. Coordinationwill occur between the State EOC and the affected counties with respect to the Alert and NotificationSystem (ANS) process.

Sirens will be coordinatedand the sounding simulated at the appropriatetime with the simulated activation of EAS taking place approximately 3 minutes following the simulated activation of the sirens. Regular Broadcastingwill not be interruptedon the EAS Stations. Broadcast of the message(s) or test message(s) is NOT requiredand NOT requested. Counties may elect to simulate county specific supplemental messages to their electronic local media.

Following the decision to activate the alert and notification system, in accordance with the ORO's plan and/orprocedures,ANS activationshould be accomplished in a timely mannerforprimary alerting/notification.This action will NOT be subject to specific time requirements.

All actions to broadcaststations will be simulated. Systems that use automatic sending technology may be demonstrated by explanation during an interview.

Each evaluated municipality per risk county will demonstrate, by interview, route alerting of any identifyied hearing impaired residents within theirjurisdiction.Hearing impairednotification teams will NOT be deployed.

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 101

a the detection by the ORO of a failure of the primary alert and notification system.

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

EXTENT OF PLAY Offsite Response Organizations (ORO) with FEMA-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(s) within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The 45-minute clock will begin when the OROs make the decision to activate the alert and notification system for the first time for a specific emergency situation. The initial message should, at a minimum, include: a statement that an emergency exists at the plant and where to obtain additional information.

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

Backup alert and notification of the public should be completed within 45 minutes following the detection by the ORO of a failure of the primary alert and notification system. Backup route alerting only needs to be demonstrated and evaluated, in accordance with the ORO's plan and/or procedures and the extent of play agreement, if the exercise scenario calls for failure of any portion of the primary system(s), or if any portion of the primary system(s) actually fails to function. If demonstrated, only one route needs to be selected and demonstrated. All alert and notification activities along the route should be simulated (that is, the message that would actually be used is read for the 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 ORO's plans and procedures and completed as they would be in an actual emergency, except as noted above or otherwise indicated in the extent of play agreement.

PEMA Negotiated Extent of Play:

Back-up alert notification of the public due to a simulated sirenfailure will be demonstrated (Refer to Attachment A, Section LA.3). County liaisons/controllerswill give a sirenfailure inject to the county siren dispatcher,upon confirmation that sirens were sounded, that a particular siren has failed in the municipalitiesscheduled to demonstrate back-up route alerting.Notice of the sirenfailure will then be communicated to the appropriatemunicipalities/locationsso they can demonstrate their 45-minute pre-identifiedback-up route alert run as per Attachment A, Section LA.3. Pennsylvaniadoes not have any "exception areas.

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Sub-element 5.b - Emergency Information and Instructions for the Public and the Media INTENT This sub-element is derived 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.

Criterion 5.b.l: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E.5, 7; G.3.a, G.4.c)

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

The ORO should ensure that emergency information and instructions are consistent with protective action decisions made by appropriate officials. The emergency information should contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, 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 ORO should also be prepared to disclose and explain the Emergency Classification Level (ECL) of the incident. At a minimum, this information must be included in media briefings and/or media releases. OROs should demonstrate the capability to use language that is clear and understandable to the public within both the plume and ingestion pathway EPZs. This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas.

The emergency information should be all-inclusive by including previously identified protective action areas that are still valid, as well as new areas. The OROs should demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. In addition, the OROs should demonstrate the capability to ensure 103

a that current emergency information is repeated at pre-established intervals in accordance with the plan and/or procedures.

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

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

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

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

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

PEMA Negotiated Extent of Play:

Subsequent emergency information and instructionsshould be provided to the public and the media in a timely manner. This will NOT be subiect to specific time requirements. One media briefing will be demonstrated in each risk county.

Risk Counties will receive and handle "PublicInquiry" messages via their individual "Public Inquiry" processes (In compliance with National Incident Management System terminology, Rumor Control is now considered to be "PublicInquiry"). Counties will receive approximately ten (10) public inquiry callsfrom the State Exercise cell assigned this responsibility. Counties will be expected to receive and log the calls, identify any trends and take appropriateactions to includefollow-up message development, distributionsand/or briefings.

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EVALUATION AREA 6 Support Operation/Facilities Sub-element 6.a - Monitoring and Decontamination of Evacuees and Emergency Workers and Registration of Evacuees INTENT This sub-element is derived 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 center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers.

(NUREG-0654, J.10.h; J.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 />. Prior to using monitoring instrument(s), the monitor(s) should demonstrate the process of checking the instrument(s) for proper operation.

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

emergency planning zone (EPZ) population planning base within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This monitoring productivity rate per hour is the number of evacuees that can be 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 met. Monitoring of emergency workers does not have to meet the twelve-hour requirement. However, appropriate monitoring procedures should be demonstrated for a minimum of two emergency workers.

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

The availability of provisions for separately showering should be demonstrated or explained. The staff should demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs and appropriate means (e.g., partitions, roped-off areas) to separate 105

0 clean from potentially contaminated areas. Provisions should also exist to separate contaminated and uncontaminated individuals, provide changes of clothing for individuals whose clothing is contaminated, and store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities. In addition, for any individual found to be contaminated, procedures should be discussed concerning the handling of potential contamination of vehicles and personal belongings.

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

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

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

PEMA NegotiatedExtent of Play:

One Emergency Worker location, Lampeter Strasburg School Complex (Field House), will be evaluated on April 22, 2008. All otherfacilities, i.e., Reception Centers, Mass Care Centers, and Monitoring/DecontaminationCenters (forthe public)and Stations (forEmergency Workers) are exempted from evaluation during this exercise.

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

At the emergency worker monitoring/decontaminationstations two (2) emergency workers will be monitored. Discussions concerningprocessing of contaminatedpersonnel will include capabilitiesand written proceduresfor showeringfemales separatefrom males. Showering will be simulated, water will not be used. Suitable radiologicalmonitoring instruments will be issued to the initialmonitoring team. Note: If portal monitors are used, the PortalMonitor Extent of Play described below shall be used.

PortalMonitor Use: Risk and Support counties may, during this exercise, utilize portal monitors to monitor simulated evacuees and / or emergency workers. The monitoring / decontamination team requirements will be based on the portal monitor capabilitiesas applicablebased on the 106

procedure / guidelines, and the recommendations of the manufacturer.Note: PEMA Monitoring and DecontaminationCircular[C2004-2] shall apply.

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

Category "C" Dosimetry applies. Simulatedpersonal record dosimeters (PRDs) will be worn.

Radiation readings/ contaminationdatafor the evacuees and vehicle will be provided by the controlleras appropriatebased upon information contained in the scenariopackage. Set-up of the facility will be performed the same asfor an actual emergency with all route markings and contamination control measures in place including step-off pad (if used). Long runs of plastic covered with paper will not be demonstrated, but the materialsshall be availableand explained.

Positioningof afire apparatuson-site may be simulated if otherwise required.

Note: Re-demonstrationsmay be performed as appropriateand time permitting.

Sub-element 6.b - Monitoring and Decontamination of Emergency Worker Equipment INTENT This sub-element is derived 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.

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 air intake systems, 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.

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U1 Decontamination capabilities, and provisions for vehicles and equipment that cannot be decontaminated, may be simulated and conducted by interview.

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

PEMA Negotiated Extent of Play:

One Emergency Worker location, Lampeter StrasburgSchool Complex (FieldHouse), will be evaluated on April 22, 2008.

Emergency worker station personnel will consist of a minimum of one monitor and one recorder and sifficient personnel to demonstrate monitoring of at least one vehicle. Schematics of these monitoring/decontaminationstations will be available to show organizationand space management within the facility. The evaluator will request that decontaminationprocedures be explained after the vehicle which has simulated contamination has been monitored. One radiologicalsurvey meter will be issued to each monitoring/decontaminationteam. One vehicle and/orpiece of equipment will not be able to be decontaminated.Simulated radiation contamination data will be included in the scenariopackage, and injected by a controller.Set-up of the facility will be performed as closely as possible to thatfor an actual emergency with all route markings in place including clearly defined exit areas,per contamination control procedures and/or step-off pads (if used); with the exception of long runs of plastic covered with paper which will not be demonstrated,but the materials will be available and explained.

Decontaminationcapabilities,and provisionsfor vehicles and equipment that can not be decontaminated,will be simulated and conducted by interview.

Note: Re-demonstrationsmay be performed as appropriateand time permitting.

Sub-element 6.c - Temporary Care of Evacuees INTENT This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) demonstrate the capability to establish relocation centers in host areas.

Congregate care is normally provided in support of OROs by the American Red Cross (ARC) under existing letters of agreement.

Criterion 6.c.1: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines. (Found in MASS CARE - Preparedness Operations, ARC 3031) Managers demonstrate the procedures to assure that evacuees have 108

been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities. (NUREG-0654, J.10.h, J.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.

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

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

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

PEMA NegotiatedExtent of Play:

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

Note: The responsibleRed Cross Chapter(s) will be telephonically contacted during business hours on April 23, 2008, by an exercise evaluator to discussfacility planning capacities.

American Red Cross Chapters and POCs are as follows:

Chester County Southeast Pennsylvania Chapter 2 3 rd & Chestnut Streets Philadelphia PA 19103 Richard Tesauro (215) 299-4889/4063 ARC of the Susquehanna Valley P.O. Box 5740 Harrisburg, PA 17110 Chris Weidehammer (717) 257-1822 109

0 York County Chapter 724 South George Street York, PA 17403 Robert Straw (717) 845-2751 Sub-element 6.d - Transportation and Treatment of Contaminated Injured Individuals This sub-element was evaluated on June 6, 2007 at York Hospital.

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ATTACHMENT A Peach Bottom Atomic Power Station Extent of Play Demonstration Tables I. PLUME PHASE EXERCISE A. Activities - April 23, 2008

1. County Emergency Operations Center (EOCs)

Time: Per Exercise Scenario DEMONSTRATION FOR EOC MOBILIZATION FOR COUNTIES COUNTY DATE Time Chester April 23, 2008 Exercise Scenario Lancaster April 23, 2008 Exercise Scenario York April 23, 2008 Exercise Scenario

2. Municipal Emergency Operations Center (EOCs)

Time: Per Exercise Scenario DEMONSTRATION FOR EOC MOBILIZATION FOR MUNICIPALITIES RISK COUNTY MUNICIPALITY DATE Chester EXEMPT REQUEST - W. Nottingham Twp (2006) April 23, 2008 Lancaster - ARCA Drumore Twp (2006) April 23, 2008 East Drumore Twp April 23, 2008 Fulton Twp April 23, 2008 Little Britain Twp April 23, 2008 Martic Twp April 23, 2008 Providence Twp April 23, 2008 ARCA - Quarryville Borough (Partial) April 23, 2008 York (new EOC) *Delta/Peach Bottom Twps (new EOC) April 23, 2008

• Fawn Grove Twp/Fawn Borough (2006) April 23, 2008 Lower Chanceford Twp April 23, 2008

• Joint EOC 111

3. One back-up route alerting demonstration by one municipality in each risk county. (During scenario Exercise)

Back-up Route Alerting COUNTY MUNCIPALITY/SIREN/ROUTE DATE Chester EXEMPT April 23, 2008 Lancaster Quarryville/ #96 /#1 (sector) April 23, 2008 York Delta-Peach Bottom/ #32 / #2 April 23, 2008

4. Traffic and Access Control Points

a. Each municipal/regional police force with a TCP assigned in its plan will demonstrate all preparation duties including TCP responsibilities and radiological briefing. Dispatch of persons to the TCP site will not occur during the exercise.

b. Municipal and county staffs will be prepared to brief the FEMA evaluator on actions to be taken should there be an impediment to evacuation on a designated route. This will be demonstrated between 7:00pm - 9:30pm on April 23, 2008.

These municipal/regional police forces are (by county): N/A Chester Lancaster York N/A Quarryville - N/A N/A B. Activities - April 22, 2008

1. Risk Public School Districts with schools located within the EPZ and those districts situated outside the EPZ, but with students living within the EPZ, will participate and be evaluated by FEMA. Each identified District Administration Office will be evaluated. When a school system is comprised of multiple buildings (High School, Middle School, Elementary School), the affected buildings (those with students from the EPZ) will be evaluated on a rotational basis to coincide with the six-year exercise cycle.

Time: Out of Sequence - 9:00 - 11:00 AM

• Asterisks (*) items indicate buildings not in EPZ - students may live in the EPZ

• "Bold" indicated those facilities that are scheduled for federal evaluation.

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COUNTY SCHOOL DISTRICT SCHOOLS (approx. 1/3"' evaluated) Evaluated Chester Oxford Area (5) 1. Jordan Bank/Elementary School

• 2008

2. Nottingham Elementary School

• 2008

3. Elk Ridge School

• 2002 (2)

4. Penn's Grove Middle School

• 2006

5. Oxford Area HS

• 2004 Lancaster Penn Manor (3) 1. Martic Elementary 2006

2. Penn Manor High School

• 2008

3. Marticville Middle School * (1)

Solanco (6) 1. Solanco High School

2. Swift Middle School 2006

3. Smith Middle School 2008

4. Quarryville Elementary School 2008

5. Clermont Elementary School 2002 (2)

6. Providence Elementary School

• York South Eastern SD (5) 1. Fawn Elementary

2. Delta/ Peach Bottom Elementary 2006

3. SE Middle School East (2)

4. SE Middle School West 2008

5. Kennard Dale High School 2008

1. Red Lion Sr High * (1)

Red Lion (5) 2. Red Lion Jr High

• 2008

3. Chanceford Elementary

• 2004 1 14. Clearview Elementary

• 2006

2. Traffic and Access Control Points

a. The Pennsylvania State Police from all three county troop locations will be briefed at the PSP York Barracks, located at the Loganville Exit on 1-83, York County. Members attending the briefing will not actually deploy to the TCP/ACPs.

b. The PSP briefing will be performed out of sequence in a demonstration window of 10:00 a.m. - 12:00 noon on April 22, 2008.

3. Reception Centers: The asterisks (*) indicate monitoring/decontamination center activities at the respective reception centers.

Demonstration of Reception Centers COUNTY DATE TIME Chester (1) EXEMPT - current 6 yr cycle N/A Lancaster EXEMPT - current 6 yr cycle N/A York (2) EXEMPT - current 6 yr cycle N/A 113

01 Reception Centers Locations COUNTY LOCATION EVALUATED Chester (1)

• Octorara Middle School 2006 Lancaster Willow Street Career Technical Center 2006 York (2) Red Lion High School 2006 Southern School Complex MS 2005 (TMI)

4. Mass Care Centers: The asterisks (*) indicate monitoring/decontamination center activities at their mass care centers.

Demonstration of Mass Care Centers / Host School COUNTY DATE TIME Chester (1) EXEMPT - current 6 yr cycle N/A 0 Lancaster (6) EXEMPT - current 6 yr cycle N/A York (2) EXEMPT - current 6 yr cycle N/A Mass Care Center Locations COUNTY LOCATION EVALUATED Chester (1) Octorara High School 2006 Lancaster (6)

• Penn Manor High School 2006 Manheim Township School Complex: 2007 Manheim Township MS Manheim Township HS Lampeter Strasburg School Complex: 2004 Lampeter Strasburg High School Lampeter Strasburg Martin Mylin Middle School Lampeter Strasburg Hans Herr Elementary School York (4)

• Red Lion High School Southern School Complex:

Southern Middle School Southern Elementary School Susquehannock High School 0

114 40

5. Emergency worker monitoring/decontamination station(s) for the risk county.

Emergency Worker Monitoring / Decontamination Station COUNTY LOCATION EVALUATED Chester (1) EXEMPT _ Penns Grove Middle School 2006 Lancaster (1) ARCA - Lampeter Strasburg School Complex (Field House) 2006/08 (1)

York (2) EXEMPT - Brogue Ambulance Company 2006 EXEMPT - Stewartstown Fire Company 2004 115

ATTACHMENT B FEDERAL EVALUATION PROCESS MATRIX Evaluation Area Consolidate Frequency Out-of- Credit Staff Sequence Assistance of Exercise Visit

_ ___________Scenario

1. Emergency Operations 1, 2, 3,4, 5,,

Management 14, 17, 30 Mobilization Every NO YES NO Exercise Facilities Once if new' NO YES YES Direction and Control Every NO NO NO Exercise 0 Communications Equipment Once if new' YES YES YES Equipment and Supplies to Every YES YES YES Support Operations Exercise

2. Protective Action 5, 7, 9, 14, 15, Decision-making 16, 17, 26, 28 Emergency Worker Exposure Every YES YES YES Control ________Exercise _______

Radiological Assessment & Every NO NO NO Protective Action Exercise Recommendations & Decisions for the Plume Phase of the Emergency Protective Action Decisions for Every NO NO NO the Protection of Exercise Special Populations Radiological Assessment & Once in 6 NO NO NO Decision-making for the yrs.

Ingestion Exposure Pathway- ______

Radiological Assessment & Once in 6 NO NO NO Decision-making Concerning yrs.

Relocation, Re-entry, and 2

Return

3. Protective Action 5, 14, 15, 16, 0 Implementation 17, 27, 29 Implementation of Emergency Every YES YES NO Worker Exposure Control Exercise Implementation of KI Decision Once in 6 YES NO NO

____________________________ ____________yrs.

Implementation of Protective Once in 6 YES YES YES Actions for Special Populations yrs. 3 Implementation of Traffic and I per YES YES YES Access Control14 Organization per exercise Implementation of Ingestion Once in 6 NO NO NO Pathway Decisions yrs.____________

116 40

Evaluation Area Consolidate Frequency Out-of- Credit Staff Sequence Assistance of Exercise Visit Scenario Implementation of Relocation, Once in 6 NO NO NO Re-entry, and Return decisions yrs.

4. Field Measurement and 6, 8, 24, 25 Analysis Plume Phase Field Every Full YES YES NO Measurements & Analysis Participation Exercise Post Plume Phase Field Once in 6 YES YES NO Measurements and Sampling yrs.

Laboratory Operations Once in 6 YES YES NO yrs.

5. Emergency Notification and 10, 11, 12, 13 Public Information Activation of the Prompt Alert 10 Every NO NO NO and Notification System exercise Activation of the Prompt Alert 10 NO NO NO and Notification System (Fast Separate Breaking) Drill once in 6 yrs.

Emergency Information & Every NO NO NO Instructions for the Public and exercise the Media

6. Support 18, 19, 20, Operations/Facilities 21, 22 Monitoring & Decontamination Once in 6 YES NO NO of Evacuees 3

and Emergency yrs.

Workers

& Registration of Evacuees Monitoring & Decontamination Once in 6 YES NO NO of Emergency3 Worker yrs.

Equipment Temporary Care of Evacuees 6 Once in 6 YES YES YES yrs.

Transportation and Treatment of Every 2 years YES YES NO Contaminated Injured Individuals 117

0 Will be evaluated if new or changed substantially.

2 The plume phase and the post-plume phase (ingestion, relocation, re-entry and return) can be demonstrated separately.

3 All facilities must be evaluated once during the six-year exercise cycle.

4 Physical deployment of resources is not necessary.

5 Facilities managed by the American Red Cross (ARC), under the ARC/FEMA MOU, will be evaluated once when designated or when substantial changes occur; all other facilities not managed by the ARC must be evaluated once in the six-year exercise cycle.

6 Each State within the 10-mile EPZ of a commercial nuclear power site shall fully participate in an exercise jointly with the licensee and appropriate local governments at least every two years. Each State with multiple sites within its boundaries shall fully participate in a joint exercise at some site on a rotational basis at least every two years. When not fully participating in an exercise at a site, the State shall partially participate at that site to support the full participation of the local governments.

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ATTACHMENT C 2008 Peach Bottom Exercise Listing of Prior Issues (Pennsylvania)

Ref. OLD FACILITY EVALUATED NEW No. NUMBER CRITERIA 1 PA Emergency News Center (EOF 46-06-5.b.l-P-01 Coatesville) 2 York Co. EOC 46-02-3.e.2-P-03 3 York Co. Reception Mon/Decon (Southern 46-04-6.a.1-P-01 School Complex MS) 4 Lancaster Co. EOC 46-06-1.c.l-A-01 5 Lancaster Co. EOC 46-06-2.a.l-A-02 6 Lancaster Co. EOC 46-06-5.b.l-A-03 7 Lancaster Co. EOC 46-02-3.e.2-P-01 8 EWMD - Lampeter Strasburg School 46-06-1.e.1-A-04 Complex - Field House 9 EWMD - Lampeter Strasburg School 46-06-6.a.1-P-02 Complex - Field House 10 Quarryville Twp EOC 46-06-3.a.l-A-05 11 Quarryville Twp EOC 46-06-3.c.l-A-06 12 Quarryville Twp EOC 46-06-3.a.1-P-03 13 46-98-29-A-01 Pennsylvania State EOC - Ingestion Exercise 3.f.1 14 46-98-27-A-02 Chester Co. EOC - Ingestion Exercise 3.e.1 15 46-98-29-A-03 Lancaster Co. EOC - Ingestion Exercise 5.b.1 16 46-98-27-A-04 York Co. EOC - Ingestion Exercise 5.b.1 119

0 Reference No. 1 Pennsylvania Emergency News Center (EOF Coatesville)

Issue No.: 46-06-5.b.1-P-01 Condition: Terminology to identify the several public information generation and dissemination facilities is inconsistent and confusing.

Two locations are referred to as "Joint Information Center," one at the Pennsylvania Emergency Operations Center (EOC) in Harrisburg and the other in Coatesville. A media guide prepared for the Peach Bottom exercise makes reference to a Commonwealth Joint Information Center (CJIC). The utility characterizes its public information operation as an "Emergency News Center" (ENC) while referring to the auditorium used for press conferences as a Joint Information Center (JIC). Exelon's JIC Activation Standard Operating Procedure (SOP) simply designates the room used for press conferences as the auditorium, while the staff call it the JIC. The Pennsylvania Radiological Emergency Preparedness Plan (RERP) states: "Multiple media centers will be established to include the CENIC [Commonwealth Emergency News and Information Center], County information offices, and the utility media center. State and Federal media representatives are assigned to the utility media centers (sometimes called a Joint Information Center) during response to an emergency or disaster" (RERP E-16-3). The utility, on the other hand, never refers to its own facility as a "Utility Media Center."

There also are occasional references to a Joint Public Information Center. For example, signs throughout the ENC are labeled "JPIC" while the Pennsylvania Emergency Management Agency (PEMA) Media Liaison Duties procedure also uses Joint Public Information Center (JPIC). That term, however, appears to be vestigial.

The overall concept of media operations is characterized by the State as a Joint Information System (RERP E-16-3). Finally, in the media guide for the Peach Bottom exercise, the acronym guide does not include JIC, CENIC, or ENC.

Possible Cause: Public information material and statements, including news releases, are generated at the CENIC and transmitted to Coatesville for dissemination. Similarly, PEMA and other State spokespersons appear "live" at the Capitol Media Center, part of CENIC, and are transmitted by satellite to the press conferences in Coatesville.

Confusion emerged when PEMA news release no. 2 was received in Coatesville at 1742, with the headline: "Commonwealth Joint Information Center and Rumor Control Established." Just as it was to be disseminated to the media, an ENC staff member saw the headline and notified the PEMA Media Liaison there that the JIC had not yet been declared activated. The Media Liaison then quickly pulled the news release. Phoning CENIC, he learned that the headline referred not to the JIC in Coatesville, but to the JIC at CENIC in Harrisburg (i.e., the CJIC), while the ENC staff member thought it referred to the JIC function in Coatesville.

120

It appears that each staff member - PEMA and the utility, in Harrisburg and Coatesville -

is confident in the use of their terms. But general agreement has not been reached across the various organizations to assure that all terms are used and understood to mean the same things. In an effort to create a system where information generation is decentralized while dissemination is centralized, multiple and imprecise terms have been created, causing confusion rather than clarity.

References:

NUREG-0654, E.5, 7; G.3.a; G.4.c; Pennsylvania Radiological Emergency Preparedness Plan, Appendix 16; PEMA Media Liaison Duties for Peach Bottom Atomic Power Station Disasters/Exercises; Exelon, Coatesville JIC Activation procedures, EP-AA- 112-600-F-18.

Effect: The only direct effect was a delay in the release of PEMA news release no. 2 until it was determined that the JIC referred to.in the text meant the Commonwealth's facility in Harrisburg rather than the operation in Coatesville. However, the multiple and unclear use of the many terms requires all users to repeatedly define their terms when speaking with one another and, more importantly, could confuse members of the media.

Recommendation: All affected organizations should agree on a single set of terms to characterize each of the facilities and revise their plans, procedures, and acronym lists accordingly. In particular, the Commonwealth should refer to its media operations in Harrisburg by the term used in the RERP, "Capitol Media Center" rather than Joint Information Center or CJIC, and use JIC (and not utility media center or Emergency News Center) exclusively to refer to the media center in Coatesville.

State Response: The Commonwealth and utilities agree to revising terms regarding identification of the various JICs. Plans and procedures will be reviewed and revised accordingly.

121

0 Reference No. 2 York County Emergency Operations Center Issue No.: 46-02-3.e.2-P-03

Description:

York County Radiological Emergency Response Plan Annex E, Appendix 15, Ingestion Exposure Pathway Emergency Planning Zone, is not current. The Annex references the U.S. Food and Drug Administration (FDA) 1982 protective action guidelines (PAGs) and other dated information. According to FEMA HQ guidance, plans were to be updated by April 2000 with the new FDA guidance, dated August 13, 1998, and entitled, "Accidental Radioactive Contamination of Human Food and Animal Feeds:

Recommendations for State and Local Agencies," including the changes to Derived Intervention Levels (DILs). (NUREG-0654, p. 4.)

CORRECTIVE ACTION DEMONSTRATED:

The York County Plan Appendix 15, Annex E, Revision 2, Change 2 was provided for the April 23, 2008 exercise. Changes have been made to address the current FDA Guidance Document dated August 13, 1998. Pages E-15-3, E-15-13 and E-15-18 have been revised and are consistent with the current FDA Guidance.

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Reference No. 3 York County Reception and Monitoring/Decontamination Center-Southern School Complex Middle School Issue No.: 46-04-6.a.1-P-01 Condition: There was confusion among the reception center emergency workers, as to when, and where evacuees' vehicles are to be decontaminated.

Possible Cause: There were no traffic pattern diagrams, or description as to when and where vehicles will be decontaminated.

Reference:

NUREG-0654, J. 12 Effect: Confusion among staff members regarding the procedures for handling possibly contaminated vehicles. Precious time was wasted while exploring various avenues for handling possibly contaminated vehicles.

Recommendation: Prepare drawings for vehicle traffic patterns, and train staff responsible for vehicle monitoring and decontamination. Designate certain area, as "contaminated vehicles parking" area. Establish procedures on when and where vehicles will be decontaminated. Pay special attention to proximity to water supply outlets and storm drains.

State Response: The revised plan and process was demonstrated as part of the May 4, 2005 out-of-sequence exercise for the Three Mile Island biennial exercise.

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0 Reference No. 4 Lancaster County Emergency Operations Center Issue No.: 46-06-1.c.1-A-01 Condition: A preliminary Protective Action Recommendation (PAR) to evacuate the Emergency Planning Zone (EPZ) 360 degrees and out to five miles was received by the Emergency Operations Center (EOC) and was inadvertently released to the Municipalities. A Protective Action Decision (PAD) was subsequently issued to evacuate the entire EPZ instead of the five miles as recommended in the PAR.

Possible Cause: The process to accurately receive and coordinate protective action information was not adequately followed/executed.

References:

NUREG-0654, A. 1.d; A.2.a, b Effect: Despite an immediate corrective message being issued, one Municipality had already acted on the PAR.

Recommendation: Command staff should approve distribution of all communications prior to release.

State Response: Procedural steps will be examined thoroughly and training will be conducted. This objective will be demonstrated during the next federally evaluated exercise.

124

Reference No. 5 Lancaster County Emergency Operations Center Issue No.: 46-06-2.a.1-A-02 Condition: The Radiological Officer (RO) did not conduct a radiological briefing to the Emergency Operations Center (EOC) staff who would be dispatched into the Emergency Planning Zone (EPZ).

Possible Cause: The RO did not follow the list of briefing topics in implementing procedures IP-9-4.

References:

NUREG-0654, K.4; J. 1O.e, f Effect: Staff assigned to distribution of dosimetry and potassium iodide (KI) to local municipalities might have been sent out in the field unprepared to deal with radiation exposure.

Recommendation: The RO briefing needs to be conducted in accordance with their plans.

State Response: Radiological Officer duties will be examined thoroughly and training will be conducted. This objective will be demonstrated during the next federally evaluated exercise.

125

Reference No. 6 Lancaster County Emergency Operations Center Issue No.: 46-06-5.b.1-A-03 Condition: Lancaster County issued a Special News Bulletin, referred to in the plan as local Emergency Alert Service (EAS) messages, to the local media that did not meet the requirements for a press release and did not contain complete information of protective actions for the public.

Possible Cause: The Public Information Officer (PIO) was not aware of the need to develop a press release from pre-scripted text, rather than simply transmitting the pre-scripted text to the media.

References:

NUREG-0654, E.5, 7; G.3.a; G.4.c; Lancaster County, Annex E, Radiological Emergency Response Procedures, Part Two, For Incidents at Nuclear Power Plants, Appendix 4, 3.d; 4.d, e.

Effect: The general public would not have received accurate protective action information.

Recommendation: Personnel responsible for public information should be trained in public information procedures.

State Response: Plans and procedures will be thoroughly examined and revised as needed. Additional training will be conducted to ensure appropriate actions are taken in providing media messages. This objective will be demonstrated during the next federally evaluated exercise.

126

Reference No. 7 Lancaster County Emergency Operations Center Issue No.: 46-02-3.e.2-P-01

Description:

The Lancaster County Radiological Emergency Response Plan Annex E, Appendix 15, Ingestion Exposure Pathway Emergency Planning Zone, is not current. The Annex references the U.S. Food and Drug Administration (FDA) 1982 protective action guidelines (PAGs) and other dated information. According to FEMA HQ guidance, plans were to be updated by April 2000 with the new FDA guidance, dated August 13, 1998, and entitled, "Accidental Radioactive Contamination of Human Food and Animal Feeds:

Recommendations for State and Local Agencies," including the changes to Derived Intervention Levels (DILs). (NUREG-0654, p.4.)

Reason Issue Unresolved: Plans have not been updated to include the new FDA August 13, 1998, guidance.

Recommendation: Update the plans to include the new FDA August 13, 1998, guidance.

State Response: PEMA will ensure county plans will be updated to address the new FDA Guidance.

127

0 Reference No. 8 Emergency Worker Monitoring/Decontamination (Lampeter Strasburg School Complex -

Field House)

Issue No.: 46-06-1.e.1-A-04 Condition: For the emergency worker decontamination station at the Lancaster Strasburg School Complex, the CDV-700 survey meters listed in the Lancaster County Radiological Emergency Response Procedure (RERP) were not calibrated and available.

Ludlum survey meters were substituted for the CDV-700s and utilized for contamination monitoring. Although substitute survey meters are allowed per the RERP, a procedure for operational source checks was not available.

Possible Cause: CDV-700 survey instruments are required to be calibrated every four years per RERP Attachment C Appendix 13. A Lancaster Emergency Management Agency (LEMA) representative stated that the CDV-700 instruments were not used for the exercise because they were all out of calibration. Per RERP Attachment B, there are 13 CDV-700 instruments available for use at this location. This could not be verified as the instruments were not brought to the site. Per the LEMA representative, the three Ludlum Model 2241-2 survey meters brought to the site were purchased in early 2006 (exact date unknown, but the calibration date was in September 2005) to replace the CDV-700 instruments. The Ludlum instruments were all were within calibration and on an annual calibration cycle. The last calibration date was 09/07/2005, and due on 09/07/2006. The RERP had not been updated to reflect the use of the Ludlum instruments. Procedures for operational and source checks had not been developed by LEMA, nor incorporated into the RERP, and were not provided to emergency worker decontamination station personnel.

References:

NUREG-0654, H.7, 10; J.10.a, b, e; J.11; K.3.a.

Effect: Participants were not familiar with the Ludlum instruments provided for contamination monitoring of personnel and vehicles and did not know how to conduct an operational and source check to ensure instrument reliability. This could result in personnel and equipment being contaminated above the stated contamination limit of 300 counts per minute (cpm) above background (when using a pancake probe).

Recommendation: LEMA must revise the RERP to reflect the inventory of Ludlum survey meters being used. In addition, a procedure for operational and source checks needs to be developed by LEMA and incorporated into the RERP for the Ludlum survey instruments and training needs to be conducted for emergency worker decontamination station personnel. Calibrate the CDV700 instruments as long as they remain in inventory.

State Response: Plans and procedures will be updated to reflect the proper inventory of equipment. Training will be conducted. This objective will be demonstrated during the next federally evaluated exercise.

128

Reference No. 9 Lancaster County EWMD (Lampeter Strasburg School Complex - Field House)

Issue No.: 46-06-6.a.1-P-02 Condition: Set up of the emergency worker monitoring and decontamination station was not consistent with available schematics. In addition, schematics did not reflect the current facility layout.

Set up of the facility, including routes for clean and contaminated personnel, and monitoring and decontamination stations were established without use of a plan schematic. A Pennsylvania Emergency Management Agency (PEMA) representative informed the Lancaster County Fire Services (LCFS) Chief that a schematic was available, and one was eventually found. The schematic was outdated as the layout of the field house was inconsistent with the drawing. Further, the schematic did not indicate personnel pathways from the parking areas to the field house and a step-off-pad location for initial personnel monitoring.

Set up of the facility for vehicle monitoring was established without use of a plan schematic.

A Pennsylvania Emergency Management Agency (PEMA) representative informed the Willow Street Fire Company (WSFC) Chief that a schematic was available, and one was eventually found. The schematic was outdated as the area identified by the WSFC Chief for contaminated vehicles was inconsistent with the schematic. Further, the schematic did not indicate a location for initial vehicle monitoring.

Possible Cause: The PEMA representative was familiar with the existence of schematics, but the LCFS Chief and WSFC Chief were unaware of them. The schematics were outdated as they did not reflect the current facility layout. Further, the schematics were not included in the Lancaster Radiological Emergency Response Procedure (RERP).

References:

NUREG-0654, J.1O.h; J.12; K.5.a, b Effect: Without an adequate schematic, facility setup for emergency working monitoring and decontamination could not be consistently established. Although the current LCFS Chief and the WSFC Chief were familiar with how to set up their areas, this could not be guaranteed for future events due to personnel changes. Without consistent setup per an established and approved facility schematic for monitoring and decontamination operations, problems with contamination control could result.

Recommendation: Develop updated facility schematics for emergency worker monitoring and decontamination operations, considering means of effective contamination control (including separation of clean and contaminated persons and personal items, equipment and vehicles, and all access/egress potentialities). Include the schematics in the RERP.

129

0 State Response: The facility materials will be updated and demonstrated during the next federally evaluated exercise.

130

Reference No. 10 Quarryville Township Emergency Operations Center Issue No.: 46-06-3.a.1-A-05 Condition: The Radiological Officer (RO) was not familiar with the Lancaster County or Quarryville Radiological Emergency Response Plans to carry out the duties of the position.

Possible Cause: Inadequate training or experience with radiological equipment.

References:

NUREG-0654, K.3.a, b Effect: Emergency workers might have been sent out in the field unprepared to deal with radiation exposure with no point of contact knowledgeable enough to manage their exposure according to sound ALARA (as low as reasonably achievable) principles.

Recommendation: Provide training in radiological responsibilities.

State Response: Radiological Officer duties will be examined thoroughly and training will be conducted. This objective will be demonstrated during the next federally evaluated exercise.

131

Reference No. 11 Quarryville Township Emergency Operations Center Issue No.: 46-06-3.c.1-A-06 Condition: Quarryville Borough did not simulate contacting the daycare centers within their Emergency Planning Zone (EPZ) nor did they realize they were supposed to.

Possible Cause: The Quarryville Borough plan does not include the daycare centers within their EPZ, while the Lancaster County plan lists two.

References:

NUREG-0654, J. 10.c, d, g Effect: The daycare centers in Quarryville Borough would not have been contacted and notified of the events at the Peach Bottom Atomic Power Station.

Recommendation: Train the Quarryville Borough responders on the actions to be taken for daycare centers. Ensure that the Borough plan is updated to include identification of the daycare centers that are reflected in the county plan.

State Response: The Quarryville EOC staff will be trained to not over-simulate their actions and to demonstrate this objective accordingly during the next federally evaluated exercise.

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Reference No. 12 Quarryville Borough Emergency Operations Center Issue No.: 46-06-3.a.1-P-03 Condition: There is a difference between the Quarryville Borough Plan and the radiological training video provided by the utility as to where dosimetry is to be returned.

Possible Cause: The plan most likely has not been updated to reflect the most recent produced video.

References:

NUREG-0654, E. 1; P.4 Effect: Dosimetry may not end up in the proper location for recordkeeping and exposure limits would not be accounted for.

Recommendation: Update the plan appropriately to reflect the most accurate information.

State Response: The plan will be updated to reflect continuity of information.

133

0 Reference No. 13 Pennsylvania State Emergency Operations Center Issue No.: 46-98-29-A-01 (3.f.1)

Description:

A representative from the Department of Public Welfare did not participate in the State Response Task Force (SRTF). Consequently, issues concerning short- and long-term psychological impacts of the incident, and individual and family counseling for stress and other evacuation-related emotional or psychological problems, were not adequately addressed. (NUREG-0654, N.1.a)

Reason ARCA Unresolved: The April 25, 2006 exercise was not a post-plume phase exercise.

134

Reference No. 14 Chester County Emergency Operations Center Issue No.: 46-98-27-A-02 (3.e.1)

Description:

Chester County officials did not simulate contacting the Chester Water Authority to close off, or coordinate the closing of, county's water intake (#123004), which is in the Susquehanna River in Lancaster County near the PBAPS. This surface water intake was located in Zone A (i.e., the Restricted Zone defined by the Commonwealth of Pennsylvania). (NUREG-0654, J.9, 11)

Reason ARCA Unresolved: The April 25, 2006 exercise was not a post-plume phase exercise.

135

Reference No. 15 Lancaster County Emergency Operations Center Issue No.: 46-98-29-A-03 (5.b.1)

Description:

The press release did not describe the procedures according to the Lancaster County plans, Appendix 16, Annex E.VI.C, 19, a.5., for the return of evacuees. Also, it failed to identify known landmarks and geographical boundaries or to identify protective action measures for milk and other food products. (NUREG-0654, M. 1, 3; N. 1.a)

Reason ARCA Unresolved: The April 25, 2006 exercise was not a post-plume phase exercise.

136 0

Reference No. 16 York County Emergency Operations Center Issue No.: 46-98-27-A-04 (5.b.1)

Description:

The lead-in scenario for the Ingestion Pathway Exercise, Day 2, indicated that milk and agricultural products within the "footprint" in AreaE were unsuitable for consumption. However, the media map advisory, which was prepared and released by York County, stated that "Print D represents the area in which agricultural products, including milk and crops, are unsuitable for consumption or market sale." Because Area D is smaller than Area E, the media and public would assume that the foods in a large area between the limits of Areas D and E were safe, whereas they actually were unsafe.

(NUREG-0654, E.5, 7; J.9, 11)

Reason ARCA Unresolved: The April 25, 2006 exercise was not a post-plume phase exercise.

137

0 Maryland Extent-of-Play Agreement PEACHBEX 2008 STATE OF MARYLAND EXERCISE OBJECTIVES AND EXTENT OF PLAY PEACH BOTTOM ATOMIC POWER STATION Maryland Jurisdictions REVISION 3 PEACH BOTTOM ATOMIC POWER STATION PEACHBEX 2008 April 22, 2008 138

INTRODUCTION The purpose of this document is to establish those exercise evaluation areas and corresponding extent of play parameters expected to be demonstrated during the Peach Bottom Atomic Power Station graded exercise to be conducted on April 22, 2008.

These evaluation areas have been developed through reviews of past exercises, associated plans and procedures, the proposed exercise scenario, applicable FEMA guidance documents, and extensive discussions with FEMA representatives.

All demonstrations will be conducted in accordance with established plans and procedures, except as noted for specific exercise evaluation areas described herein.

Out-of-sequence evaluations will be conducted on April 22, 2008 involving the two Peach Bottom risk jurisdictions in Maryland. The out-of-sequence activities to be demonstrated are:

" Special Facilities - Schools

" Reception Center, Monitoring and Decontamination

" Emergency Worker, Equipment and Vehicles Monitoring and Decontamination

• Congregate Care The full-scale graded exercise will be conducted on April 22, 2008 involving all the Peach Bottom risk jurisdictions and selected State agencies in Maryland. Demonstration activities will be initiated following a simulated accident at the plant.

Maryland Emergency Management Agency (MEMA) and Maryland Department of the Environment (MDE) will participate at the Coatesville Emergency Operations Facility (EOF) and Joint Information Center (JIC) to support the Pennsylvania plume phase activities on April 23, 2008. MEMA and MDE will also support the April 23, 2008 PA Plume Phase activities with a control cell at each of their locations in Reisterstown, MD and Baltimore, MD. Cecil and Harford Counties will participate on the Utility notification line, however, no other participation is expected of the Maryland Counties on April 23, 2008.

Actions will be taken in accordance with each jurisdiction's county emergency plan and procedures unless specified under the specific extent of play.

139

11 PEACHBEX 2008 Evaluation Schedule Date / Time Harford County Cecil County April 22 Harford County EOC Evaluation Harford County EOC Evaluation 0700- 1400 1.a.1, 1.c.1, 1.d.1, 1.e.1 1.a.1, 1.c.1, 1.d.1, 1.e.1 2.a.1, 2.b.1, 2.b.2, 2.c.1 2.a.1, 2.b.1, 2.b.2, 2.c.1 3.a.1, 3.b.1, 3.c.1, 3.d.1, 3.d.2 3.a.1, 3.b.1, 3.c.1, 3.d.1, 3.d.2 5.a.1, 5.a.3, 5.b.1 5.a.1, 5.a.3, 5.b.1 TCP/ACP: Harford County EOC TCP/ACP: Harford County EOC 1.d.1, 1.e. 1 1.d.1, 1.e. 1 01 2.a.1 2.a.1 3.a. 1, 3.b..1, 3.d. 1, 3.d.2 3.a.1, 3.b.1, 3.d.1, 3.d.2 Route Alerting: Harford County Route Alerting: Harford County EOC EOC 1.d.1, 1.e. 1 1.d.1, 1.e. 1 2.a.1 2.a.1 3.a.1, 3.b.1 3.a.1, 3.b.1 5.a.3 5.a.3 Schools: North Harford Elementary, Schools: Conowingo Elementary North HarfordMiddle, North 3.c.2 Harford High 3.c.2 OBSERVE ONLY. Hospital,MS-J: Rising Sun Hospital, MS-1: Darlington EMS/Union Hospital EMS/Upper Chesapeake Medical 6.d. 1 Center 6.d.1 140 40

April 22 Reception Center: FallstonHigh Reception Center: PerryvilleHigh 1900-2100 School School 3.a.1 3.a.1 6.a.1, 6.b.1 6.a.1, 6.b.1 CongregateCare: FallstonHigh Congregate Care: PerryvilleHigh School School 6.c.1 6.c.1 E- Worker Monitoring: Fallston E- Worker Monitoring: Rising Sun High School Middle School 3.a.1 3.a.1 6.a.1, 6.b.1 6.a.1, 6.b.1 141

0 EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element L.a - Mobilization Criterion L.a.l: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654, A.4, D.3, 4; E.1, 2; H.4)

Was this Criterion selected? YES X NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to alert, notify, and mobilize emergency personnel and to activate and staff emergency facilities.

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

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

State of Maryland Extent of Play:

During the Out of Sequence activities on April 22, 2008, the emergency workers will prestage at various locations to reduce the amount of travel time. During April 22, 2008, the State of Maryland Department of the Environment, MEMA Public Information staff and other drill players that report to the Emergency Operations Facility in Coatesville will pre-stage to reduce the amount of travel time involved in the exercise. MEMA will mobilize only key State agencies at the Maryland EOC. All other facilities will activate according to plans.

Key State Agencies are: MEMA, Maryland Military Department/National Guard, Maryland Department of the Environment, Maryland Department of Health and Mental Hygiene, Maryland Department of Natural Resources, Maryland Department of Agriculture, Maryland 142

Department of Transportation, Maryland State Police, Maryland Department of Education and the Maryland Institute for Emergency Medical Services Systems.

The Maryland Department of the Environment field monitoring teams will not prestage.

The County Agencies involved are Harford County Division of Emergency Operations and Cecil County Emergency Department of Emergency Services.

Union Hospital in Cecil County will not pre-stage it's players. However, the Rising Sun EMS staff will pre-stage at the location that will begin the MS-1 portion of the exercise on April 22, 2008 In all instances, the demonstration of a shift change is NOT required. Twenty-four hour staffing will be demonstrated by means of a roster or staffing chart.

All out-of-sequence players and equipment will be pre-positioned (Reception Centers, Emergency Worker Monitoring and Decontamination Stations and Monitoring and Decontamination Centers).

143

6 EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.b - Facilities Criterion 1.b.l: Facilities are sufficient to support the emergency response.

(NUREG-0654, H)

• Was this Criterion selected? YES X NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs have facilities to support the emergency response.

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 and/or alternate facility (if required to support operations).

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

State of Maryland Extent of Play:

In accordance with plans 144

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.c - Direction and Control Criterion 1.c.1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.

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

• Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs have the capability to control their overall response to an emergency.

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

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

State of Maryland Extent Of Play:

In accordance with plans 145-

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.d - Communications Equipment Criterion 1.d.1: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations. (NUREG-0654, F.1, 2)

Was this Criterion selected? YES X NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should establish reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as the following: appropriate contiguous governments within the emergency planning zone (EPZ), Federal emergency response organizations, the licensee and its facilities, emergency operations centers (EOC), and field teams.

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.

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

State of Maryland Extent of Play:

This element will be demonstrated during the April 22, 2008 exercise in accordance with plans. Failure of communications equipment will not be provided in the scenario but may be discussed with appropriate personnel.

146

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element i.e - Equipment and Supplies to Support Operations Criterion 1.e.l: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG-0654, H, J.10.a, b, e, f, j, k; J.11; K.3.a)

• Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs have emergency equipment and supplies adequate to support the emergency response.

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

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

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

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

147

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

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

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

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

State of Maryland Extent of Play:

In accordance with plans.

In Maryland, CDV-700s are calibrated every 4 years and modem pancake instruments (such as Ludlum units) are calibrated every 1 year. However, in MD risk counties, primarily pancake detectors are used.

KI for the Emergency Workers will be evaluated through inventory sheets and/or inspection.

KI will not be removed from the storage locations. KI questions will be addressed through interviews.

KI has been pre-distributed to the general public. However, availability and dissemination of KI for the general population will be demonstrated for the evaluator during this exercise up to the point of actual distribution at the Reception/Monitoring & Decontamination Centers/Congregate Care Centers.

DRD and PRD quantities and calibration dates will be provided to the evaluator(s) upon request. All DRDs (except hospital DRDs) read out in Roentgens.

Outstanding Issues:

46-06-i.e. 1-A-il - Harford County - Emergency Worker KI has an expiration date of 3/2005. However, KI for the public had an expiration date of 4/2007.

148 0

EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.a - Emer2encv Worker Exposure Control Criterion 2.a.l: OROs use a decision-making process, considering relevant factors and appropriate coordination, to insure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.

(NUREG-0654, K.4)

• Was this Criterion selected? YES X NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that an ORO have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place as specified in the ORO's plans and procedures to authorize emergency worker exposure limits to be exceeded for specific missions.

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

EXTENT OF PLAY 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 KI, as a protective measure, based on the ORO's plan and/or procedures or projected thyroid dose compared with the established protective action guides (PAGs) for KI administration.

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

State of Maryland Extent of Play:

In accordance with plans 149

6 Outstanding Issues:

46-06-2.a. l-A MDE, Accident Assessment Center - Confusing terminology used when communicating KI decision for emergency workers. The term field teams was used instead of emergency workers.

150

EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.b. Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency Criterion 2.b.1: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions. (NUREG-0654, 1.8, 10, 11 and Supplement 3)

• Was this Criterion selected? YES X NO N/A INTENT This sub-element is derived from NUREG-0654, which indicates that OROs have the capability to independently project integrated dose from exposure rates or other information and compare the estimated dose savings with the protective action guides. OROs have the capability to choose, among a range of protective actions, those most appropriate in a given emergency situation. OROs base these choices on protective action guides (PAGs) from the ORO's plans and procedures, or EPA 400-R-92-001 and other criteria, such as, plant conditions, licensee protective action recommendations, coordination of protective action decisions with other political jurisdictions (e.g. other affected OROs), availability of appropriate in-place shelter, weather conditions, evacuation time estimates, and situations that create higher than normal risk from evacuation.

EXTENT OF PLAY During the initial stage of the emergency response, following notification of plant conditions that may warrant offsite protective actions, the ORO should demonstrate the capability to use appropriate means, described in the plan and/or procedures, to develop protective action recommendations (PARs) for decision-makers based on available information and recommendations from the licensee and field monitoring data, if available.

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

Differences greater than a factor of 10 between projected doses by the licensee and the ORO should be discussed with the licensee with respect to the input data and assumptions used, the 151

0 use of different models, or other possible reasons. Resolution of these differences should be incorporated into the PAR if timely and appropriate. The ORO should demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated PARs.

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

State of Maryland Extent of Play In accordance with MDE plans and procedures. The MDE Decision Maker will not travel to the Exelon Nuclear Coatesville EOF. He/She will remain local to the MDE or MEMA facility.

Outstanding Issues:

46-06-2.b. l-A MDE, Accident Assessment Center - The decision to recommend KI for public was not in accordance with the basis requirements as stated in the Maryland EOP.

152 0

EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.b. Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PADs) for the general public (including the recommendation for the use of KI, if ORO policy). (NUREG-0654, J.9, J.10.m)

Was this Criterion selected? YES X NO N/A INTENT This sub-element is derived from NUREG-0654, which indicates that OROs have the capability to independently project integrated dose from exposure rates or other information and compare the estimated dose savings with the protective action guides. OROs have the capability to choose, among a range of protective actions, those most appropriate in a given emergency situation and base these choices on protective action guides (PAGs) from the ORO's plans and procedures, FRC Reports Numbers 5 and 7 or EPA 400-R-92-001 and other criteria, such as, plant conditions, licensee protective action recommendations, coordination of protective action decisions with other political jurisdictions (e.g. other affected OROs), availability of appropriate in-place shelter, weather conditions, evacuation time estimates, and situations that create higher than normal risk from evacuation.

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

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

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

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

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

State of Maryland Extent of Play In accordance with plans. Maryland counties have the authority to initiate or expand a PAD.

If a recommendation is made for the general public to take KI, appropriate information will be provided to the public by the means of notification specified in the plan and/or procedures.

The Maryland Department of the Environment will decide whether or not to issue KI to the public based on a calculation to determine if protective thyroid dose (CDE Thyroid) exceeds 5 Rem during a General Emergency. This decision is made at the MDE Accident Assessment Center.

154 S

EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.c - Protective Action Decisions Consideration for the Protection of Special Populations Criterion 2.c.1: Protective action decisions are made, as appropriate, for special population groups. (NUREG-0654, J.9; J.10.c, d, e, g)

• Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to determine protective action recommendations, including evacuation, sheltering and use of potassium iodide (KI), if applicable, for special population groups (e.g., hospitals, nursing homes, correctional facilities, schools, licensed day care centers, mobility impaired individuals, and transportation dependent individuals). Focus is on those special population groups that are (or potentially will be) affected by a radiological release from a nuclear power plant.

EXTENT OF PLAY 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, Evacuation Time Estimates, 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.

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

State of Maryland Extent of Play In accordance with plans and procedures 155

a EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.d. -Radiological Assessment and Decision-Making for the Ingestion Exposure Pathway Criterion 2.d.1: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO planning criteria. (NUREG-0654, 1.8; J.11)

• Was this Criterion selected? YES NO_X_ N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs have the means to assess the radiological consequences for the ingestion exposure pathway, relate them to the appropriate protective action guides (PAGs), and make timely, appropriate protective action decisions to mitigate exposure from the ingestion pathway.

During an accident at a nuclear power plant, a release of radioactive material may contaminate water supplies and agricultural products in the surround areas. Any such contamination would likely occur during the plume phase of the accident, and depending on the nature of the release could impact the ingestion pathway for weeks or years.

EXTENT OF PLAY It is expected that the ORO will take precautionary actions to protect food and water supplies, or to minimize exposure to potentially contaminated water and food, in accordance with their respective plans and procedures. Often such precautionary actions are initiated by the OROs based on criteria related to the facility's emergency action levels (EAL).

Such action may include recommendations to place milk animals on stored feed and to use protected water supplies.

The ORO should use its procedures (for example, development of a sampling plan) to assess the radiological consequences of a release on the food and water supplies. The ORO assessment should include the evaluation of the radiological analyses of representative samples of water, food, and other ingestible substances of local interest from potentially impacted areas, the characterization of the releases from the facility, and the extent of areas potentially impacted by the release. During this assessment, OROs should consider the use of agricultural and watershed data within the 50-mile EPZ. The radiological impacts on the food and water should then be compared to the appropriate ingestion PAGs contained in the ORO's plan and/or procedures.

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

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

OROs should use Federal resources, as identified in the Federal Radiological Emergency Response Plan (FRERP), and other resources (e.g., compacts, nuclear insurers, etc), if available.

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

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

State of Maryland Extent of Play:

Not applicable for this evaluation.

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0 EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.e. - Radiological Assessment and Decision-Making Concerning Relocation, Re-entry, and Return Criterion 2.e.l: Timely relocation, re-entry, and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the ORO's plan and/or procedures. (NUREG-0654, A.l.b; 1.10; M)

Was this Criterion selected? YES NO_X_ N/A INTENT The sub-element is derived from NUREG-0654, which provides that OROs have the capability to make decisions on relocation, re-entry, and return of the general public. These decisions are essential for the protection of the public from the direct long-term exposure to deposited radioactive materials from a severe accident at a commercial nuclear power plant.

EXTENT OF PLAY Relocation: OROs should demonstrate the capability to estimate integrated dose in contaminated areas and to compare these estimates with PAGs, apply decision criteria for relocation of those individuals in the general public who have not been evacuated but where projected doses are in excess of relocation PAGs and control access to evacuated and restricted areas. Decisions are made for relocating members of the evacuated public who lived in areas that now have residual radiation levels in excess of the PAGs. Determination of areas to be restricted should be based on factors such as the mix of radionuclides in deposited materials, calculated exposure rates vs. the PAGs and field samples of vegetation and soil analyses.

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

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

Responsible OROs should demonstrate the capability to develop a strategy for authorized re-entry of individuals into the restricted zone, based on established decision criteria. OROs should demonstrate the capability to modify those policies for security purposes (e.g., police patrols), for maintenance of essential services (e.g., fire protection and utilities), and for other 158

critical functions. They should demonstrate the capability to use decision-making criteria in allowing access to the restricted zone by the public for various reasons, such as to maintain property (e.g., to care for the farm animals or secure machinery for storage), or to retrieve important possessions. Coordinated policies for access and exposure control should be developed among all agencies with roles to perform in the restricted zone. OROs should demonstrate the capability to establish polices for provision of dosimetry to all individuals allowed to re-enter the restricted zone. The extent that OROs need to develop policies on re-entry will be determined by scenario events.

Return: Decisions are to be based on environmental data and political boundaries or physical/geological features, which allow identification of the boundaries of areas to which members of the general public may return. Return is permitted to the boundary of the restricted area that is based on the relocation PAG.

Other factors that the ORO should consider are, for example: conditions that permit the cancellation of the emergency classification level and the relaxation of associated restrictive measures, basing return recommendations (i.e., permitting populations that were previously evacuated to reoccupy their homes and businesses on an unrestricted basis) on measurements of radiation from ground deposition; and the capability to identify services and facilities that require restoration within a few days and to identify the procedures and resources for their restoration. Examples of these services and facilities are: medical and social services, utilities, roads, schools, and intermediate term housing for relocated persons.

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

State of Maryland Extent of Play:

Not applicable for this evaluation.

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0 EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.a - Implementation of Emergency Worker Exposure Control Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. (NUREG-0654, K.3)

Was this Criterion selected? YES X NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimeters and permanent record dosimeters; provide for direct-reading dosimeters to be read at appropriate frequencies by emergency workers; maintain a radiation dose record for each emergency worker; and provide for establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of protective action guides, always applying the ALARA (As Low As is Reasonably Achievable) principle as appropriate.

EXTENT OF PLAY OROs should demonstrate the capability to provide appropriate direct-reading and permanent record dosimetry, dosimetry chargers, and instructions on the use of dosimetry to emergency workers. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows individual(s) to read the administrative reporting limits (that are pre-established at a level low enough to consider subsequent calculation of Total Effective Dose Equivalent) and maximum exposure limits (for those emergency workers involved in life saving activities) contained in the OROs 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 160 0

and at what exposure levels. Emergency workers may use any available resources (e.g. written procedures and/or co-workers) in providing responses.

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

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

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

State of Maryland Extent of Play:

In accordance with plans and procedures.

At the MDE Accident Assessment Center, dosimetry will be used by the Field Team workers.

At Cecil and Harford Counties, personnel performing route alerting will receive radiological briefings, dosimetry, simulated KI and forms at the County EOC during the April 22, 2008 plume phase activities. Radiological briefings will be provided to address exposure limits and procedures to replace those approaching limits and how permission to exceed limits is obtained from the county. Emergency workers will also be briefed on when to take KI and on whose authority. Distribution of KI will be simulated. Forms should also be demonstrated to emergency workers. Forms used by emergency workers to track dosimetry and KI should be filled out completely and, when appropriate, serial numbers should be entered on forms for dosimetry.

At Cecil and Harford Counties, personnel working at evacuee or emergency worker monitoring and decontamination facility will receive dosimetry and forms from their officer in charge while on site. This will be demonstrated out of sequence on April 22, 2008. 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.

At Union Hospital in Cecil County, personnel working at the hospital will follow procedural guidance regarding use of dosimetry and KI. The Rising Sun EMS staff will receive their player briefing and dosimetry at the Cecil County staging area, Rising Sun Middle School.

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

All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP), will make the dosimetry equipment (and KI) available for inspection by the Federal Evaluator. Simulation PRDs with mock serial numbers may be used.

Outstanding Issues:

46-04-3.a. l-A The Cecil County Hospital Plan does not identify radiation exposure limits for emergency workers.

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EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.b - Implementation of KI Decision Criterion 3.b.l: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals (not the general public) is maintained. (NUREG-0654, E.7; J.10.e, f)

• Was this Criterion selected? YES_X_ NO N/A _

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

EXTENT OF PLAY OROs should demonstrate the capability to make KI available to emergency workers,

• institutionalized individuals, and, where provided for in the ORO plan and/or procedures, to members of the general public. OROs should demonstrate the capability to accomplish distribution of KI consistent with decisions made. Organizations should have the capability to develop and maintain lists of emergency workers and institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest KI. The ingestion of KI recommended by the designated ORO health official is voluntary. For evaluation purposes, the actual ingestion of KI is not necessary. OROs should demonstrate the capability to formulate and disseminate appropriate instructions on the use of KI for those advised to take it. If a recommendation is made for the general public to take KI, appropriate information should be provided to the public by the means of notification specified in the ORO's plan and/or procedures.

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

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

State of Maryland Extent of Play 163

0 In accordance with plans and procedures. KI has been pre-distributed to the general public.

However, availability and dissemination of KI for the general population will be demonstrated for the evaluator during this exercise up to the point of actual distribution at the Reception/Monitoring & Decontamination Centers/Congregate Care Centers.

KI for the Emergency Workers will be evaluated through inventory sheets and/or inspection. KI will not be removed from the storage locations. KI questions will be addressed through interviews. Simulated KI may be used. The quantity of KI available for Emergency Workers will be made known to evaluators through inspection or inventory sheets.

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EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.c - Implementation of Protective Actions for Special Populations Criterion 3.c.1: Protective action decisions are implemented for special populations other than schools within areas subject to protective actions. (NUREG-0654, E.7; J.9; J.10.c, d, e, g)

• Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to implement protective action decisions, including evacuation and/or sheltering, for all special populations. Focus is on those special populations that are (or potentially will be) affected by a radiological release from a nuclear power plant.

EXTENT OF PLAY Applicable OROs should demonstrate the capability to alert and notify (e.g., 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 ORO's plans and procedures.

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

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

State of Maryland Extent of Play:

In accordance with plans and procedures. The names, locations and contact information of identified individuals with identified special needs are maintained at each County EOC. Copies of these lists will not be provided to the evaluators; however, evaluators will be allowed to inspect the lists during the exercise.

Contact with special populations and reception facilities will be simulated (hospitals, nursing homes and correctional facilities). Actual contacts (up to two per risk county) will be made with transportation providers as per plan. All actual and simulated contacts should be logged.

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0 EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.c - Implementation of Protective Actions for Special Populations Criterion 3.c.2: OROs/School officials decide upon and implement protective actions for schools. (NUREG-0654, J.10.c, d, g)

Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to implement protective action decisions, including evacuation and/or sheltering, for all special populations. Focus is on those special population groups that are (or potentially will be) affected by a radiological release from a nuclear power plant.

EXTENT OF PLAY Applicable OROs should demonstrate the capability to alert and notify all public school systems/districts, licensed day care centers, and participating private schools within the emergency planning zone of emergency conditions that are expected to or may necessitate protective actions for students.

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

Implementation of protective actions should be completed subject to the following provisions:

At least one school in each affected school system or district, as appropriate, needs to demonstrate the implementation of protective actions. The implementation of canceling the school day, dismissing early, or sheltering should be simulated by describing to evaluators the procedures that would be followed. If evacuation is the implemented protective action, all activities to coordinate and complete the evacuation of students to reception centers, congregate care centers, or host schools may actually be demonstrated or accomplished through an interview process. If accomplished through an interview process, appropriate school personnel including decision making officials (e.g., superintendent/principal, transportation director/bus dispatcher), and at least one bus driver (and the bus driver's escort, if applicable) should be available to demonstrate knowledge of their role(s) in the evacuation of school children.

Communications capabilities between school officials and the buses, if required by the plan and/or procedures, should be verified.

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

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

State of Maryland Extent of Play In accordance with plans and procedures. This element will also be evaluated during the out-of-sequence evaluations on April 22, 2008 in Harford and Cecil Counties. In Harford and Cecil Counties, the interview of the School Principal will be done at each school.

School Students will not be involved during the exercise. Actions and activities associated with the demonstration of Criterion 3.c.2 will be limited to the School District Administration key personnel and the County. Evacuation of students will be conducted through an interview process with School District personnel or the building principal.

The role of the bus driver may be conducted through an interview with school or transportation officials (or designee) if a bus driver is not available. Actual demonstration of the bus route is not required and will not be demonstrated. Maps or route descriptions will be available for illustration purposes. Risk County.school plans do not require communications between the school and vehicles. Bus drivers are not considered emergency workers and therefore do not require dosimetry. Potassium Iodide may be available at the school (pre-distributed) for the bus driver.

The School Services Officer is staged at the County EOC and will be coordinating activities with the Principal, including notifications. Private schools and kindergartens will not participate.

Lists of these facilities will be provided and procedures for contacting them will be described.

Licensed Day Care Facilities will be listed in the County EOC and the following information will be available for each:

• Name of Facility or Operator Name

• Facility Contact Name (if different from Operator Name)

• Facility Address

• Contact Phone Number These Day Care Facilities will not be contacted.

Outstanding Issues:

46-04-3.c.2-P North Harford Elementary School was unable to monitor EAS 970 AM.

46-06-3.c.2-A Harford County - Dublin Elementary School did not send KI authorization letters to parents for the 2005-2006 school year.

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a EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.d. - Implementation of Traffic and Access Control Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654, J.10.g, j, k)

• Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs have the capability to implement protective action plans, including relocation and restriction of access to evacuated/sheltered areas. This sub-element focuses on selecting, establishing, and staffing of traffic and access control points and removal of impediments to the flow of evacuation traffic.

EXTENT OF PLAY 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 agreement.

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

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

State of Maryland Extent of Play In accordance with plans and procedures. This element will also be evaluated during the April 22, 2008 plume phase activities in Harford and Cecil Counties.

Traffic and Access control will be demonstrated by interview at the County EOC. The traffic /

access control personnel will not be deployed to the traffic / access control point(s). If the designated assignment is a location within the EPZ, a radiological briefing will be provided to the assigned individuals.

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EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.d. - Implementation of Traffic and Access Control Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654, J.10.k)

• Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs have the capability to implement protective action plans, including relocation and restriction of access to evacuated/sheltered areas. This sub-element focuses on selecting, establishing, and staffing of traffic and access control points and removal of impediments to the flow of evacuation traffic.

EXTENT OF PLAY 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 ORO's plans and procedures and completed, as they would be in an actual emergency, unless specified above or indicated in the extent of play agreement.

State of Maryland Extent of Play In accordance with plans and procedures. This element will also be evaluated during the out-of-sequence evaluations on April 22, 2008 in Harford and Cecil Counties.

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 tow trucks, need not be demonstrated; however, simulated contacts will be logged.

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0 EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.e - Implementation of Ingestion Pathway Decisions Criterion 3.e.l: The ORO demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk, and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective actions. NUREG-0654, J.9, 11)

Was this Criterion selected? YES NO_X_ N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to implement protective actions, based on criteria recommended by current Food and Drug Administration guidance, for the ingestion pathway emergency planning zone (IPZ), the area within an approximate 50-mile radius of the nuclear power plant. This sub-element focuses on those actions required for implementation of protective actions.

EXTENT OF PLAY Applicable OROs should demonstrate the capability to secure and utilize current information on the locations of dairy farms, meat and poultry producers, fisheries, fruit growers, vegetable growers, grain producers, food processing plants, and water supply intake points to implement protective actions within the ingestion pathway EPZ.

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

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

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

State of Maryland Extent of Play 170

EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.e - Implementation of In2estion Pathway Decisions Criterion 3.e.2: Appropriate measures, strategies, and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk, and agricultural production. (NUREG-0654, E.5, 7; J.9, 11)

Was this Criterion selected? YES NO_X_ N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to implement protective actions, based on criteria recommended by current Food and Drug Administration guidance, for the ingestion pathway emergency planning zone (IPZ), the area within an approximate 50-mile radius of the nuclear power plant. This sub-element focuses on those actions required for implementation of protective actions.

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

For example, communications and coordination with agencies responsible for enforcing food controls within the IPZ should be demonstrated, but actual communications with food producers and processors may be simulated.

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

State of Maryland Extent of Play 171

0 EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.f. - Implementation of Relocation, Re-entry, and Return Decisions Criterion 3.f.1: Decisions regarding controlled re-entry of emergency workers and relocation and return of the public are coordinated with appropriate organizations and implemented. (NUREG-0654, M.1, 3)

• Was this Criterion selected? YES NO_X_ N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should demonstrate the capability to implement plans, procedures, and decisions for relocation, re-entry, and return.

Implementation of these decisions is essential for the protection of the public from the direct long-term exposure to deposited radioactive materials from a severe accident at a commercial nuclear power plant.

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

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

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

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

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

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Return: OROs should demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase. OROs should demonstrate the capability to identify and prioritize services and facilities that require restoration within a few days, and to identify the procedures and resources for their restoration. Examples of these services and facilities are medical and social services, utilities; roads, schools, and intermediate term housing for relocated persons.

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

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

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

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

State of Maryland Extent of Play 173

0 EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS Sub-element 4.a - Plume Phase Field Measurements and Analyses Criterion 4.a.l: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates. (NUREG-0654, H.10; 1.8, 9, 11)

Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to deploy field teams with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654 indicates that OROs should have the capability to use field teams within the plume emergency planning zone to measure airborne radioiodine in the presence of noble gases and to measure radioactive particulate material in the airborne plume.

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

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

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

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State of Maryland Extent of Play In accordance with the MDE procedures. Harford and Cecil counties do not dispatch field teams.

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0 EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS Sub-element 4.a - Plume Phase Field Measurements and Analyses Criterion 4.a.2: Field teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654, 1.8, 11; J.10.a)

• Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to deploy field teams with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654 indicates that OROs should have the capability to use field teams within the plume emergency planning zone to measure airborne radioiodine in the presence of noble gases and to measure radioactive particulate material in the airborne plume.

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

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

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

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

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

State of Maryland Extent of Play In accordance with the MDE procedures. Plume peak monitoring is the responsibility of the utility field teams. MDE teams monitor plume edge. MDE will only perform air and ambient measurements at appropriate locations determined by the Field Team Leader in response to the scenario. No Federal participation will be demonstrated during the exercise.

Each Field Monitoring Team will take a minimum of six (6) open air dose rate measurements to demonstrate determination of plume location. Each sample location will include a closed window (gamma only) dose rate reading and open window (beta and gamma) dose rate reading. Two (2) dose rate measurements will be taken at three (3) locations for a minimum total of six (6) measurements per team.

Each team will demonstrate obtaining and analyzing at least one (1) air sample for airborne radioiodine. Additional airborne samples may be taken by field monitoring teams if re-demonstration is required. The transfer of the chain-of-custody of the samples should be evaluated through discussion with the players, however, actual demonstration is not required.

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0 EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS Sub-element 4.a - Plume Phase Field Measurements and Analyses Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654, 1.8, 9, 11)

Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to deploy field teams with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654 indicates that OROs should have the capability to use field teams within the plume emergency planning zone to measure airborne radioiodine in the presence of noble gases and to measure radioactive particulate material in the airborne plume.

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

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

OROs should share data in a timely manner with all appropriate OROs. The methodology, including contamination control, instrumentation, preparation of samples, and a chain-of-custody form for transfer to a laboratory, will be in accordance with the ORO plan and/or procedures.

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

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

178

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

State of Maryland Extent of Play In accordance with the MDE procedures. MDE will only perform air and ambient measurements at appropriate locations determined by the Field Team Leader in response to the scenario. Laboratory analysis will not be demonstrated.

Each team will demonstrate obtaining and analyzing at least one (1) air sample for airborne radioiodine. Additional airborne samples may be taken by field monitoring teams if re-demonstration is required. The transfer of the chain-of-custody of the samples should be evaluated through discussion with the players, however, actual demonstration is not required.

179

11 EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS Sub-element 4.b - Post Plume Phase Field Measurements and Sampling Criterion 4.b.l: The field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making. (NUREG-0654, 1.8; J.11)

• Was this Criterion selected? YES NO_X_ N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to assess the actual or potential magnitude and locations of radiological hazards in the ingestion emergency planning zone (IPZ) and for relocation, re-entry and return measures.

This sub-element focuses on the collection of environmental samples for laboratory analyses that are essential for decisions on protection of the public from contaminated food and water and direct radiation from deposited materials.

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

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

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

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

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

State of Maryland Extent of Play 180

EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS Sub-element 4.c - Laboratory Operations Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654, C.3; 1.8, 9; J.11)

Was this Criterion selected? YES NO X N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to perform laboratory analyses of radioactivity in air, liquid, and environmental samples to support protective action decision-making.

EXTENT OF PLAY The laboratory staff should demonstrate the capability to follow appropriate procedures for receiving samples, including logging of information, preventing contamination of the laboratory, preventing buildup of background radiation due to stored samples, preventing cross contamination of samples, preserving samples that may spoil (e.g., milk), and keeping track of sample identity. In addition, the laboratory staff should demonstrate the capability to prepare samples for conducting measurements.

The laboratory should be appropriately equipped to provide analyses of media, as requested, on a timely basis, of sufficient quality and sensitivity to support assessments and decisions as anticipated by the ORO's plans and procedures. The laboratory instrument calibrations should be traceable to standards provided by the National Institute of Standards and Technology.

Laboratory methods used to analyze typical radionuclides released in a reactor incident should be as described in the plans and procedures. New or revised methods may be used to analyze atypical radionuclide releases (e.g. transuranics or as a result of a terrorist event) or if warranted by circumstances of the event. Analysis may require resources beyond those of the ORO.

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

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

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

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

State of Maryland Extent of Play 181

a EVALUATION AREA 5: EMERGENCY NOTIFICATION & PUBLIC INFORMATION Sub-element 5.a - Activation of the Prompt Alert and Notification System 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 &

NUREG-0654, E.1, 4, 5, 6, 7)

Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to provide prompt instructions to the public within the plume pathway EPZ. Specific provisions addressed in this sub-element are derived from the Nuclear Regulatory Commission (NRC) regulations (10 CFR Part 50, Appendix E.IV.D.), and FEMA-REP-10, "Guide for the Evaluation of Alert and Notification systems for Nuclear Power Plants."

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

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

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.

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

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

State of Maryland Extent of Play In accordance with State and County plans and procedures. Procedures for activation of the siren system will be described and simulated to the point of activation. Siren sounding will not occur. Coordination will occur between the State EOCs (MD and PA) and the affected counties with respect to the Alert and Notification System (ANS) process.

Following the decision to activate the alert and notification system, in accordance with the ORO's plan and/or procedures, ANS activation should be accomplished in a timely manner for primary alerting/notification. This action will NOT be subject to specific time requirements.

All actions to broadcast stations will be simulated. Systems that use automatic sending technology may be demonstrated by explanation during an interview.

There are hearing impaired persons in both the Cecil and Harford County Emergency Planning Zones. These persons are identified through an annual survey. These lists are maintained on file at the respective EOC. Each evaluated risk county will demonstrate, by interview, notification of any identified hearing impaired residents within their jurisdiction.

Hearing impaired notification teams will not be deployed.

Outstanding Issues:

46-06-5.a. 1-P Maryland Emergency Operations Center - The MD EOP, Annex Q, and the Cecil and Harford County EOPs, including approved EAS messages use "Site Emergency" instead of "Site Area Emergency".

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0 EVALUATION AREA 5: EMERGENCY NOTIFICATION & PUBLIC INFORMATION Sub-element 5.a - Activation of the Prompt Alert and Notification System Criterion 5.a.2: RESERVED Was this Criterion selected? YES NO N/A X INTENT State of Maryland Extent of Play None 184

EVALUATION AREA 5: EMERGENCY NOTIFICATION & PUBLIC INFORMATION Sub-element 5.a - Activation of the Prompt Alert and Notification System Criterion 5.a.3: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.

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

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

Was this Criterion selected? YES X NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to provide prompt instructions to the public within the plume pathway EPZ. Specific provisions addressed in this sub-element are derived from the Nuclear Regulatory Commission (NRC) regulations (10 CFR Part 50, Appendix E.IV.D.) and FEMA-REP- 10, "Guide for the Evaluation of Alert and Notification systems for Nuclear Power Plants."

EXTENT OF PLAY OROs with FEMA-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(s) within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The 45-minute clock will begin when the OROs make the decision to activate the alert and notification system for the first time for a specific emergency situation. The initial message should, at a minimum, include: a statement that an emergency exists at the plant and where to obtain additional information.

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

Backup alert and notification of the public should be completed within 45 minutes following the detection by the ORO of a failure of the primary alert and notification system. Backup route alerting needs only be demonstrated and evaluated, in accordance with the ORO's plan and/or procedures and the extent of play agreement, if the exercise scenario calls for failure 185

4 of any portion of the primary system(s), or if any portion of the primary system(s) actually fails to function. If demonstrated, only one route needs to be selected and demonstrated. All alert and notification activities along the route should be simulated (e.g., the message that would actually be used is read for the evaluator, but not actually broadcast) as agreed upon in the extent of play. Actual testing of the Public Address system will be conducted at some agreed upon location.

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

State of Maryland Extent of Play In accordance with State and County plans and procedures.

Back-up alert notification of the public, through route alerting due to a simulated siren failure will be demonstrated. An inject will be provided to the county 911 center supervisor, upon confirmation that sirens were sounded, that a particular siren has failed in the area scheduled to demonstrate back-up route alerting. Notice of the Siren failure will then be communicated to the appropriate County EOC participant so the 45-minute pre-identified back-up route alert run can be demonstrated.

Lights and sirens WILL NOT be used by emergency workers to travel from the staging location to the starting point of the route.

Harford County's staging area is the County EOC. The radiological briefing will occur at this facility and the dispatch of emergency workers to conduct route alerting will occur from the Harford County EOC. The siren that has been selected to fail in Harford County is Siren 65.

Cecil County's staging area is the Rising Sun Fire Department. The radiological briefing will occur at this facility and the dispatch of emergency workers to conduct route alerting will occur from the Rising Sun Fire Department. The siren that has been selected to fail in Cecil County is Siren 80.

Maryland does not have any "exception areas" in the 10-mile EPZ.

186

EVALUATION AREA 5: EMERGENCY NOTIFICATION & PUBLIC INFORMATION Sub-element 5.b - Emergency Information and Instructions for the Public and the Media Criterion 5.b.l: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E.5, 7; G.3.a; G.4.a, b, c)

Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to disseminate to the public appropriate emergency information and instructions including any recommended protective actions. In addition, NUREG-0654 provides that OROs should ensure the capability exists for providing information to the media. This includes the availability of a physical location for use by the media during an emergency.

NUREG-0654 also provides that a system be available for dealing with rumors. This system will hereafter be known as the public inquiry hotline.

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

The OROs should ensure that emergency information and instructions are consistent with protective action decisions made by appropriate officials. The emergency information should contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, 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. OROs should demonstrate the capability to use language that is clear and understandable to the public within both the plume and ingestion pathway EPZs. This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas.

The emergency information should be all-inclusive by including previously identified protective action areas that are still valid as well as new areas. The OROs should demonstrate 187

4 the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. In addition, the OROs should demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plan and/or procedures.

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

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

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

OROs should demonstrate that an effective system is in place for dealing with calls to the public inquiry hotline. Hotline staff should demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate information source.

Information from the hotline staff, including information that corrects false or inaccurate information when trends are noted, should be included, as appropriate, in emergency information provided to the public, media briefings, and/or media releases.

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

State of Maryland Extent of Play In accordance with State and County plans and procedures. Subsequent emergency information and instructions should be provided to the public and the media in a timely manner. This will NOT be subject to specific time requirements. Press releases and EAS messages are developed at the State and County Emergency Operations Centers.

The State media briefing is conducted in cooperation with the Exelon Nuclear Joint Information Center briefing. The State of Maryland will participate in Exelon Nuclear media briefing during the April 23, 2008 Pennsylvania plume phase activities.

The Risk Counties will provide area for the media to receive a briefing during the April 22, 2008 Maryland plume phase activities. There will be no media actually participating in the 188

briefing. Evaluation of the message provided to the media will be done through interview of the players.

Risk Counties will receive and handle "Public Inquiry" messages via their individual "Public Inquiry" processes (In compliance with National Incident Management System terminology, Rumor Control is now considered to be "Public Inquiry"). Counties will receive approximately ten (10) public inquiry calls from the State Exercise cell assigned this responsibility. Counties will be expected to receive and log the calls, identify any trends and take appropriate actions to include follow-up message development, distributions and/or briefings.

Outstanding Issues:

46-06-5.b. l-A Cecil County - Some info in EAS messages was not correct. For example, headers, times, radio station, lack of public inquiry number and calendar versus brochure were incorrect.

46-06-5.b. l-P Cecil County - The wrong street address is referenced in the Cecil County RERP.

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a EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES Sub-element 6.a - Monitoring and Decontamination of Evacuees and Emergency Workers, and Registration of Evacuees Criterion 6.a.l: The reception center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers.

(NUREG-0654, J.10.h; K.5.b)

Was this Criterion selected? YES X NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs have the capability to implement radiological monitoring and decontamination of evacuees and emergency workers, while' minimizing contamination of the facility, and registration of evacuees at reception centers.

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 />. Prior to using a monitoring instrument(s), the monitor(s) should demonstrate the process of checking the instrument(s) for proper operation.

Staff responsible for the radiological monitoring of evacuees should demonstrate the capability to attain and sustain a monitoring productivity rate per hour needed to monitor the 20% 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 (e.g. partitions, roped-off areas) to separate clean from potentially contaminated areas. Provisions should also exist to 190

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

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

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

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

State of Maryland Extent of Play In accordance with plans and procedures. This element will also be evaluated during the out-of-sequence evaluations on April 22, 2008 in Harford and Cecil Counties.

Radiological monitoring demonstration sites should possess a roster of the monitoring personnel required to process 20% of the population planning base within a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period.

Water from 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.

In both Counties, the radiological monitoring of the public is co-located with both the reception center and the mass care center. Note: Co-located facilities do not require strip maps or written directions. Other mass care centers could be activated by the County to shelter the public.

Monitoring and Decontamination and Mass Care Centers will be demonstrated during the out-of-sequence window. The counties will provide space at designated mass care centers for operation of monitoring/decontamination centers. Schematics of these monitoring

/decontamination centers will be available to show the organization and layout within the facility and space management for monitoring and decontamination. Procedures will be demonstrated to show the separation of contaminated and non-contaminated (clean) individuals to minimize cross contamination.

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a At the evacuee monitoring/decontamination centers, both portal monitors and hand held meters will be used. Centers using portal monitors will not be required to demonstrate the timing aspect of processing six individuals - three (3) will suffice.

Suitable radiological monitoring instruments will be issued to and demonstrated by the initial monitoring team(s). A monitoring team consists of one monitor and one recorder equipped with one survey instrument. Those individuals found to be free of "contamination", based upon scenario injects, will be directed to the mass care registration point for further processing. Note: Actual radiological sources will not be attached to or hidden upon the volunteer evacuees.

One of the simulated evacuees, based upon controller injects, will not be able to be decontaminated. Discussions concerning the processing of contaminated personnel will include capabilities and written procedures for showering females separate from males.

Showering will be simulated, water will not be used. Note: If portal monitors are used, the Portal Monitor Extent of Play described below shall be used.

At the emergency worker monitoring/decontamination stations, two (2) emergency workers will be monitored. Discussions concerning processing of contaminated personnel will include capabilities and written procedures for showering females separate from males.

Showering will be simulated, water will not be used. Suitable radiological monitoring instruments will be issued to the initial monitoring team. Note: If portal monitors are used, the Portal Monitor Extent of Play described below shall be used.

Portal Monitor Use: Risk and Support counties may, during this exercise, utilize portal monitors to monitor simulated evacuees and / or emergency workers. The monitoring /

decontamination team requirements will be based on the portal monitor capabilities as applicable based on the procedure / guidelines, and the recommendations of the manufacturer.

Radiation readings / contamination data for the evacuees and vehicle will be provided by the controller as appropriate based upon information contained in the scenario package. Set-up of the facility will be performed the same as for an actual emergency with all route markings and contamination control measures in place including step-off pad (if used). Positioning of a fire apparatus on-site may be simulated if otherwise required.

Note: Re-demonstrations may be performed as appropriate and time permitting.

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EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES Sub-element 6.b - Monitoring and Decontamination of Emergency Worker Equipment 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)

• Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs have the capability to implement radiological monitoring and decontamination of emergency worker equipment, including vehicles.

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

The area to be used for monitoring and decontamination should be set up as it 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 air intake systems, 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 ORO's plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

State of Maryland Extent of Play In accordance with plans and procedures. This element will also be evaluated during the out-of-sequence evaluations on April 22, 2008 in Harford and Cecil Counties.

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0 Emergency worker station personnel will consist of a minimum of one monitor and one recorder and sufficient 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 and the exterior of the facility. This schematic will show how contamination control measures will be utilized. An explanation of the decontamination procedures will be explained after the vehicle which has simulated contamination has been monitored. One radiological survey meter will be issued to each monitoring/decontamination team. One vehicle and/or 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 performed as closely as possible to that for an actual emergency with all route markings in place including clearly defined exit areas, per contamination control procedures and/or step-off pads (if used).

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

Note: Re-demonstrations may be performed as appropriate and time permitting.

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EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES Sub-element 6.c - Temporary Care of Evacuees Criterion 6.c.1: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines (found in MASS CARE-Preparedness Operations, ARC 3031). Managers demonstrate the procedures to assure that evacuees have been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities. (NUREG-0654, J.10.h; J.12)

• Was this Criterion selected? YES_X_ NO N/A INTENT This sub-element is derived from NUREG-0654, which provides that OROs demonstrate the capability to establish relocation centers in host areas. Congregate care is normally provided in support of OROs by the American Red Cross under existing letters of agreement.

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

Given the substantial differences between demonstration and simulation of this criteria, exercise demonstration expectations should be clearly specified in extent-of-play agreements.

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

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

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

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0 State of Maryland Extent of Play In accordance with plans and procedures. Actual set-up of facilities will not be demonstrated.

Operation of the center will be explained to the evaluator. This element will also be evaluated during the out-of-sequence evaluations on April 22, 2008 in Harford and Cecil Counties.

Counties demonstrating the operation of mass care centers during the out-of-sequence window will provide floor plans of the mass care centers to show organization within the facility and space management during a real emergency.

For both Cecil and Harford Counties, the Department of Social Services (Community Services) will work in cooperation with the American Red Cross to operate the mass care shelters.

Demonstration by these organizations will occur on April 22, 2008. The responsible organization will show the supplies to be provided to mass care centers to support the 24-hour operation. The responsible organization will be interviewed during the out of sequence activities on April 22, 2008 at the mass care facility.

Schematics of these mass care centers will be available, during the demonstration window, to show organization within the facility and space allocation for the registration and sheltering the evacuating public. Necessary signs, directional arrows and forms will be available and used to demonstrate registration, at a minimum, of three evacuees requiring emergency housing.

Evacuees will be shown the location where they would be housed in an actual situation.

Bedding, cots, food, etc. normally associated with mass care will not be moved to the site, but the sources of those items should be explained to FEMA evaluators.

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EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES Sub-element 6.d - Transportation and Treatment of Contaminated In jured Individuals Criterion 6.d.1: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals. (NUREG-0654, F.2; H.10; K.5.a, b; L.1, 4)

Was this Criterion selected? YES_X_ NO N/A FOR EVALUTION: CECIL COUNTY FOR OBSERVATION: HARFORD COUNTY INTENT This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

EXTENT OF PLAY Monitoring, decontamination, and contamination control efforts will not delay urgent medical care for the simulated victim.

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

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

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

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

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

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

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

State of Maryland Extent of Play In accordance with County and Hospital Procedures.

Cecil County is being evaluated for this objective. Cecil County's staging area is the Rising Sun Fire Department. The radiological briefing will occur at this facility and the dispatch of emergency workers to transport the radiologically contaminated person will occur from the Rising Sun Fire Department.

Harford County is NOT being evaluated for this objective. The radiological briefing of the EMS Emergency Workers will not be performed during this demonstration. The emergency workers will utilize the Fire Stations Bay to pick up the radiologically contaminated person.

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Location of Key Exercise Facilities:

STATE LOCATIONS State EOC Camp Frettered Military Reservation 5401 Rue Saint Lo Drive Reisterstown, Maryland 21136 Department of Environment Emergency Response Division 1800 Washington Boulevard, Suite 105 Baltimore, Maryland 21230 HARFORD COUNTY LOCATIONS Harford County Division of Emergency Operations 2220 Ady Road Forest Hill, Maryland 21050 Harford County Joint Information Center 399 Thomas Run Road Bel Air, Maryland 21015 Fallston High School 2301 Carrs Mill Road Fallston, Maryland 21047 Darlington Fire Department/EMS 2600 Castleton Road Darlington, Maryland 21034 Upper Chesapeake Medical Center 500 Upper Chesapeake Drive Bel Air, Maryland 21014 CECIL COUNTY, LOCATIONS Cecil County Department of Emergency Services 107 Chesapeake Boulevard Elkton, Maryland 21921 Cecil County Joint Information Center 107 Chesapeake Boulevard Elkton, Maryland 21921 Rising Sun Fire Department/EMS 300 Biggs Highway Rising Sun, Maryland 21911 199

a Union Hospital 109 Bow Street Elkton, Maryland 21921 Perryville High School 1696 Perryville Road Perryville, Maryland 21903 UTILITY LOCATIONS PBAPS Emergency Operations Facility and Joint Public Information Center 175 North Caln Road Coatesville, Pennsylvania 19320 200

APPENDIX 4:

Exercise Scenario This appendix contains a summary of the simulated sequence of events used as the basis for invoking emergency response actions by Offsite Response Organizations (OROs) during the Peach Bottom Atomic Power Station (PBAPS) exercise on April 22-23, 2008.

The exercise scenarios were submitted by the Commonwealth of Pennsylvania and the State of Maryland. The scenarios were approved by the Federal Emergency Management Agency (FEMA) Region III on March 3, 2008.

The summary presented in this appendix is a compilation of exercise scenario materials submitted by the Commonwealth of Pennsylvania, State of Maryland, and Exelon Nuclear.

Events at the plant site that are not pertinent to the ORO response have been omitted.

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a EXELON NUCLEAR EMERGENCY PREPAREDNESS NARRATIVE

SUMMARY

PEACH BOTTOM ATOMIC POWER STATION (MARYLAND ONLY) CONTROL CELL APRIL 22, 2008 Control Cell Initial Conditions Unit 2 has been on-line at 100% power for the last 272 days. There is no surveillance in progress.

"A" Stand-by Gas Treatment System (SGTS) is inoperable and out of service to maintenance to replace the "A" fan motor bearing. The "A" fan and motor are uncoupled and removed. Expected return to service is 4/24/08 at 10:00. The Outage Control Center is staffed at minimal levels.

The weather forecast is for partly cloudy and cool today, with light winds from the west-northwest at 7-9mph. Highs this evening will be in the mid 40s. The skies will become clear tonight with lows in the low 40s. Fair and cool conditions tomorrow with winds shifting from the northwest at 8-10 mph. The high temperature for tomorrow will be 40 to 45 degrees. Probability of precipitation is 0% tonight.

Sequence of Events At 07:00, operations personnel begin to investigate a report of a crash of a large construction dump truck into the Emergency Cooling Tower on-site and within the Protected Area. (This is not a security event.) The dump truck was on-site to deliver stone to a construction job and the brakes on the vehicle apparently failed. The wall of the Emergency Cooling Tower has a large crack in it and the Emergency Cooling Tower bay level (inventory) is lowering rapidly.

At 07:15, the Shift Manager assumes the position of Shift Emergency Director and declares an ALERT in accordance with EAL HA5.3 due to the vehicle crash resulting in visible damage to a plant structure. There is NO non-routine radioactive release in progress. The plants remain at 100% power at this time.

At 07:30, the State and Local Communicator delivers the ALERT notification to the State of Maryland and Risk Counties over the NARS network. There is NO non-routine radioactive release in progress at the ALERT.

At 8:30, an unexpected plant transient results in the failure of the reactor protection system (RPS) to shutdown the plant - an Anticipated Transient Without Scram (ATWS) has occurred.

Following the ATWS, the introduction of a small amount of fuel damage begins (postulated to occur due to the ATWS and pressure transient); a small primary system steam leak inside the primary containment (drywell) begins; and because of the fuel damage and steam leak inside the drywell, slowly increasing containment temperature, pressure, and radiation.

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At 08:45, the Station Emergency Director in the Technical Support Center (TSC) assumes Command and Control of the emergency and declares a SITE AREA EMERGENCY (SAE) based on EAL MS3 - failure of the RPS to shutdown the plant. The reactor is subsequently shutdown by operations personnel.

At 09:00, the State and Local Communicator delivers the SITE AREA EMERGENCY notification to the State of Maryland and Risk Counties over the NARS network. There is NO non-routine radioactive release in progress at the time of the SITE AREA EMERGENCY.

At 10:00, a Loss of Coolant Accident (LOCA) occurs. The reactor core is briefly uncovered and subsequent to the LOCA, a Primary Containment Failure occurs. An elevated monitored non-routine radioactive release begins following the Primary Containment Failure.

At 10:15, the Station Emergency Director in the TSC declares a GENERAL EMERGENCY (GE) based on EAL FG loss of all three Fission Product Barriers with a non-routine radioactive release in progress.

At 10:30, the Corporate Emergency Director in the Coatesville Emergency Operations Facility (EOF) will develop, approve, and deliver a plant-based Protective Action Recommendation (PAR) for the State of Maryland.

At 11:30, engineering and dose assessment personnel determine that the available SGTS Charcoal Filters have saturated with moisture following the Post-LOCA Primary Failure into the Reactor Building, and are no longer effective for iodine absorption. Field Teams are reporting back elevated iodine being detected downwind of the plant in Cecil County, Maryland.

At 11:30, a wind shift occurs and is recognized, requiring the development, approval, and issuance of a REVISED Utility PAR to now include an additional (fourth) affected downwind sector to evacuate.

At 11:45, EOF Protective Measures Group personnel, using field team data and the DAPAR dose assessment model, determine that Adult Thyroid Dose due to iodine has exceeded the Protective Action Guideline beyond 5 miles in Cecil County, Maryland. This information is subsequently delivered to the State of Maryland.

At 12:00, a REVISED Utility PAR to now include an additional (fourth) affected downwind sector to evacuate is delivered by the EOF Corporate Emergency Director to the Maryland Senior State Official.

At -13:00, upon concurrence of all utility lead controllers, the State, and FEMA evaluators that opportunity for all objectives to be demonstrated has been provided, the Control Cell will be terminated.

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01 EXELON NUCLEAR EMERGENCY PREPAREDNESS NARRATIVE

SUMMARY

PEACH BOTTOM ATOMIC POWER STATION (PENNSYLVANIA ONLY) CONTROL CELL APRIL 23, 2008 Exercise Initial Conditions Unit 2 has been on-line at 100% power for the last 272 days. There is no surveillance in progress.

"A" Stand-by Gas Treatment System (SGTS) is inoperable and out of service to maintenance to replace the "A" fan motor bearing. The "A" fan and motor are uncoupled and removed. Expected return to service is 4/25/08 at 10:00.

"B" SGTS was declared AVAILABLE BUT INOPERABLE at 15:00 today when engineering

,completed a preliminary evaluation of a deficiency report received earlier today from the manufacturer of the SGTS charcoal absorber material and concluded that some of the installed SGTS charcoal in the "B" train is potentially defective. Engineering determined that the SGTS charcoal iodine absorption efficiency of the "B" train is potentially reduced to only -70% of design values. The "B" train is available but inoperable "as is" with potentially limited (-70%)

iodine absorption capacity. Replacement charcoal is en route to the plant with an estimated arrival time of 17:00 today. Maintenance expects replacement of the "B" train charcoal will be complete by 23:00 today. Station management has concluded that, in accordance with procedure OP-PB-100, there is NO need to commence a controlled plant shutdown at this time due to this issue. The Engineering Duty Manager has the lead for this issue.

The Outage Control Center is staffed at minimal levels.

The weather forecast is for partly cloudy and cool today, with light winds from the south-southeast at 7-9mph. Highs this evening will be in the mid 40s. The skies will become clear tonight with lows in the low 40s. Fair and cool conditions tomorrow with winds shifting from the southwest at 8-10 mph. The high temperature for tomorrow will be 40 to 45 degrees. Probability of precipitation is 0% tonight.

Sequence of Events At -16:20, operations personnel begin to investigate an unexpected 125 VDC power system trouble alarm. Operations personnel determine that 2 PPB 125 VDC (Unit 2 B DC Power) is lost.

Operations personnel enter alarm response procedure (20C209R H-3). The low voltage condition results in the High Pressure Coolant Injection system, the valve position indication and DC solenoid power for the outboard Main Steam Isolation Valves (MSIVs), and the power to several main control room annunciator panels being lost. Procedure SE-13, Attachment 3, Part 1 is to be followed. Multiple plant Emergency Core Cooling Systems are rendered inoperable by this loss of DC power. No plant transient occurs, by design, and time is available for operations to begin to investigate the annunciator and resultant loss of 125 VDC control power.

204

At -16:30, a momentary lowering of the 220-34 off-site electrical power source voltage is introduced. This momentary lowering in voltage, coincident with the existing loss of DC control power results in a significant plant transient. The lowering of the 220-34 off-site electrical power source causes as designed 4 kV emergency electrical bus fast transfer to occur and the momentary loss of numerous AC plant electrical power busses. In particular, the fast transfer, by design, results in the momentary loss of AC power to the Outboard MSIVs and the inadvertent closure of the Outboard MSIVs with the existing loss of 125 VDC control power to the DC MSIV AO solenoid valves.

At -<16:31, the inadvertent closure of the MSIVs results in an increase in reactor pressure at power. A Reactor High Pressure condition annunciator is received, immediately followed by an (automatic) Reactor Protection System (RPS) Reactor High Trip condition annunciator; however all automatic RPS trip functions have failed and an Anticipated Transient Without Scram (ATWS) event is now in progress. Licensed operators are expected to recognize the ATWS and enter procedure T-101.

At -<16:32, the reactor operator recognizes the reactor scram condition and ATWS event and places the reactor mode switch in the "Shutdown" position. The reactor mode switch scram function is defeated; however, the manual scram pushbuttons successfully initiate control rod movement and the reactor is successfully manually shutdown by the reactor operator. Following the manual scram, the reactor operator recognizes the 15 control rods did not fully insert.

Operator actions per T-101 continue. Reactor pressure is being manually controlled using MSIVs as the MSIVs are now closed and the Main Turbine Electric Hydraulic Control system and Main Condenser are no longer available for reactor pressure control At -16:33, numerous additional malfunctions are introduced to further challenge the licensed operator crew and include: the introduction of a small amount of fuel damage (postulated to occur due to he ATWS and pressure transient); a small primary system steam leak inside the primary containment (drywell); and because of the fuel damage and steam leak inside the.

drywell, slowly increasing containment temperature, pressure, and radiation. To prevent the operators from taking action manually to drive in the 15 control rods, the "B" Control Rod Drive pump inadvertently trips. The licensed operators will need to take immediate action to control reactor pressure using MSIVs and will take action to respond to the fuel damage and steam leak into the drywell. Because the MSIVs are closed and the Primary Containment is intact, there is no non-routine radioactive release occurring.

At -<16:45, the Shift Manager assumes the position of Shift Emergency Director and declares an ALERT (MA-3) due to the failure of the RPS to initiate an automatic reactor scram.

Notifications to off-site agencies and activation of the Emergency Response Organization and Emergency Response Facilities are underway. There is NO non-routine radioactive release in progress at the time of the ALERT.

At -17:00, the "A" Control Rod Drive pump is started and the 15 control rods which did not insert following the manual scram are manually driven full in.

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0]

At -17:30, the on-site Technical Support Center (TSC) and Operations Support Center emergency response facilities are staffed and activated. Transfer. of Command and Control of the Emergency from the Shift Emergency Director to the Station Emergency Director in the TSC should be underway.

At -18:15, a small unisolable steam leak from a cracked pipe on the Reactor Water Clean-up (RWCU) system in the reactor building is initiated. The steam leak results in a local fire alarm (smoke detector senses the high humidity in the area), increasing area temperatures, and increasing local area radiation levels. Annunciators for the smoke detector, high area temperature, and high area radiation levels are received in the main control room. Control room licensed operators respond to these conditions in accordance to procedures. The TSC is able to monitor the increasing area temperatures and area radiation levels using the Emergency Parameter Display System (EPDS) monitors in the TSC. A non-routine radiological release is observed on plant main stack radiation monitoring equipment as a result of the elevated RCS activity and unisolable steam leak into the reactor building.

At -<18:30, a SITE AREA EMERGENCY (FS-1) is declared due to the loss of two fission product barriers: the loss of the RCS barrier due to the leak into the drywell and the loss of the Primary Containment Barrier, due to the unisolable RWCU system leak into the reactor building.

Due to the increasing radiation levels in the reactor building, the normal reactor building ventilation equipment automatically shuts down as designed, and the known to be degraded, inoperable but available "B" SGTS automatically starts and processes the radioactive atmosphere from the reactor building, through the (degraded - no more than 70% effective) SGTS filter, and out to the environment via the plant stack. The non-routine radioactive release, which begins with the unisolable RWCU steam leak inside the reactor building, continues for the duration of the exercise.

At -18:45, due to the RWCU steam leak inside the reactor building, conditions are met which require licensed operators to initiate an emergency depressurization of the reactor (primary system) in accordance with procedures T-103 and T- 112. Using five MSIVs, the reactor is rapidly depressurized into the torus to further reduce the driving head of the unisolable steam leak into the reactor building. Reactor water level is always maintained above the Top of Active Fuel.

At -19:00, control room operators continue to monitor the degrading conditions inside the drywell. Containment radiation levels continue to slowly increase due to the ongoing RCS steam leak into containment.

At -19:40, containment radiation increases to > 840 R/hr, leading to the declaration of the loss of the third Fission Product Barrier, the declaration of a GENERAL EMERGENCY, and the delivery of a Protective Action Recommendation (PAR).

At -<19:55, The Station Emergency Director is expected to declare a GENERAL EMERGENCY, based on the loss of all three Fission Product Barrier s, with a radioactive release in progress. The Corporate Emergency Director in the Coatesville Emergency Operations Facility will develop, approve, and deliver a plant-based PAR for the Commonwealth of 206

Pennsylvania. A non-routine radioactive release will be in progress at the time of the declaration of a GENERAL EMERGENCY.

At -20:45, a wind shift occurs and is recognized, requiring the development, approval, and issuance of a REVISED Utility PAR to now include an additional (fourth) affected downwind sector to evacuate.

At -22:00, upon concurrence of all utility lead controllers, the NRC evaluators, and the State and FEMA evaluators that opportunity for all objectives to be demonstrated has been provided, the exercise will be terminated.

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0 APPENDIX 5:

Planning Issues This appendix contains the Planning Issues assessed during the April 22-23, 2008, exercise at Peach Bottom Atomic Power Station (PBAPS) and those outstanding from earlier exercises.

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 radiological emergency response plans (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.

NEW PLANNING ISSUES Pennsylvania Schools, York County (Red Lion Junior High School)

Issue Number: 46-08-3.c.2-P-01 Condition: The Principal's notebook and checklists used by the Red Lion Junior High School Principal contained out-of-date information. Checklists were dated December 1997 and one page referred to the Limerick facility. The list of students who would not be allowed to return to their homes if school was dismissed during an emergency at PBAPS was dated 10/28/06 and did not reflect the current school population. (The Red Lion Junior High School is located outside the PBAPS EPZ but some of the students reside within the EPZ).

Possible Cause: The Red Lion Junior High School Principal's notebook had not been reviewed and updated. Critical student lists at the Junior High School were not updated to reflect lists maintained at the School District.

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Reference:

Emergency Procedures for Radiological Incidents at the Peachbottom Atomic Power station - Red Lion Area - School District Superintendent (September 2007), School District EPZ students list dated 4/21/08.

Effect: Emergency response actions may not be consistent with School District Procedures. Also, the Red Lion Junior High School would have to contact the School District Office to obtain the current list of students that should not be allowed to reenter the EPZ Recommendation: Review and update the Red Lion Junior High School Principal's notebook, checklists, and student lists to assure they are consistent with District procedures and student information.

Commonwealth Response: The school district's notebook will be reviewed on a more frequent basis to insure updates are filed accordingly. The updated information was available though it had not been placed in the school district notebook. The new listings will be available for review in September at the beginning of the new school year.

Maryland Schools, Harford County Public School District Issue Number: 46-08-3.c.2-P-02 Condition: The Checklist for a Radiological Emergency at the Peach Bottom Atomic Power Station for all Harford County Risk Schools indicates that the EAS station to be monitored is WAMD 970 AM. However, the correct EAS station is WXCY 103.7 FM.

Possible Cause: The change in EAS station from WAMD 970 AM to WXCY 103.7 FM was not included in the April 2008 Checklist revision.

References:

• NUREG-0654, J.10.c, d, g

+ Checklist for a Radiological Emergency at the Peach Bottom Atomic Power Station Effect: School officials unfamiliar with the new EAS station may not have been able to monitor EAS stations without taking a corrective action such as contacting the Harford County EOC for the correct station.

Recommendation: Coordinate with Harford County personnel to provide a revised Checklist for a Radiological Emergency at the Peach Bottom Atomic Power Station showing the correct EAS station.

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0 PRIOR PLANNING ISSUES RESOLVED Lancaster County Emergency Operations Center Issue No.: 46-02-3.e.2-P-01 Condition: The Lancaster County Radiological Emergency Response Annex E, Appendix 15, Ingestion Exposure Pathway Emergency Planning Zone, is not current. The Annex references the U.S. Food and Drug Administration (FDA) 1982 protective action guidelines (PAGs) and other dated information. According to FEMA HQ guidance, plans were to be updated by 2000 with the new FDA guidance, dated August 13, 1998, and entitled, "Accidental Radioactive Contamination of Human Food and Animal Feeds: Recommendations for State and Local Agencies," including the changes to Derived Intervention Levels (DILs). (NUREG-0654, p.4)

Corrective Action Demonstrated: Revision 4 to Annex E, Appendix 15 of the Lancaster County Emergency Response Plan refers to the FDA Guidance appropriately.

Lancaster County Emergency Worker Monitoring/Decontamination (Lampeter Strasburg School Complex - Field House)

Issue No.: 46-06-6.a.1-P-02 Condition: Set up of the emergency worker monitoring and decontamination station was not consistent with available schematics. In addition, schematics did not reflect the current facility layout.

Set up of the facility, including routes for clean and contaminated personnel, and monitoring and decontamination stations were established without use of a plan schematic. A Pennsylvania Emergency Management Agency (PEMA) representative informed the Lancaster County Fire Services (LCFS) Chief that a schematic was available, and one was eventually found. The schematic was outdated as the layout of the field house was inconsistent with the drawing.

Further, the schematic did not indicate personnel pathways from the parking areas to the field house and a step-off-pad location for initial personnel monitoring.

Set up of the facility for vehicle monitoring was established without use of a plan schematic. A Pennsylvania Emergency Management Agency (PEMA) representative informed the Willow Street Fire Company (WSFC) Chief that a schematic was available, and one was eventually found. The schematic was outdated as the area identified by the WSFC Chief for contaminated vehicles was inconsistent with the schematic. Further, the schematic did not indicate a location for initial vehicle monitoring.

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Corrective Action Demonstrated: On April 23, 2008 a new schematic was presented for review. This schematic shows the actual building configuration in the Emergency Worker Monitoring and Decontamination Station and the new routing through the Emergency Worker Monitoring and Decontamination Station.

Quarryville Borough Emergency Operations Center Issue No.: 46-06-3.a.1-P-03 Condition: There is a difference between the Quarryville Borough Plan and the radiological training video provided by the utility as to where dosimetry is to be returned.

Corrective Action Demonstrated: The Quarryville Borough Radiological Emergency Implementing Procedure was updated to be consistent with the 2008 radiological briefing video and to reflect the proper location where dosimetry is to be returned by emergency workers. Per this procedure, emergency workers are to report to a monitoring and decontamination station at the Lampeter-Strasburg High School Complex Field House upon completion of their task.

York County Emergency Operations Center Issue Number: 46-02-3.e.2-P-03 Condition: York County Radiological Emergency Response Plan Annex E, Appendix 15, Ingestion Exposure Pathway Emergency Planning Zone, is not current. The Annex references the U.S. Food and Drug Administration (FDA) 1982 protective action guidelines (PAGs) and other dated information. According to FEMA HQ guidance, plans were to be updated by April 2000 with the new FDA guidance, dated August 13, 1998, and entitled, "Accidental Radioactive Contamination of Human Food and Animal Feeds: Recommendations for State and Local Agencies," including the changes to Derived Intervention Levels (DILs). (NUREG-0654, p.4.)

Corrective Action Demonstrated: The York County Radiological Emergency Response Plan, Annex E, Appendix 15, Ingestion Exposure Pathway Emergency Planning Zone, Revision 2, Change 2 removed all references to FDA 1982 PAGs and has incorporated the FDA 1998 guidelines.

Maryland Emergency Operations Center Issue No.: 46-06-5.a.1-P-04 Condition: The Maryland Emergency Operations Plan (EOP), Annex Q, and the Cecil and Harford Counties' EOPs, including the approved Emergency Alert 211

0 System (EAS) message templates, utilize SITE EMERGENCY for the SITE AREA EMERGENCY classification level.

Corrective Action Demonstrated: Maryland Emergency Operations Plan Annex Q, Section 5, Concept-of Operations,Subsection 5.4, PlanImplementation, 5.4.1.3; Cecil County Radiological Emergency Response Plan (RERP),Section IV Concept of Operations, Part B, Emergency Action Levels, Subsection 3; Cecil County RERP, Annex H, Attachment 4, page H-8; and Harford County Emergency Operations Plan, Appendix 1, Section C, Concept of Operations, Part 2, Emergency Classification Levels, Subsection C all identify the Emergency Classification Level (ECL) as "Site Area Emergency." Pre-scripted EAS messages correctly identify the ECL as Site Area Emergency.

Cecil County Emergency Operations Center Issue No.: 46-06-5.b.1-P-05 Condition: In September 2005, the Cecil County Emergency Operations Center (EOC) moved to a new location. The Cecil County Radiological Emergency Response Plan (updated February 2006) still lists the old location for the EOC (Annex A-1 Direction and Control, II Responsibility Section B) and lists the old location for the public media briefings (Annex H Public Information, IV Direction and Control Section C).

Corrective Action Demonstrated: The correct address has been added to the RERP.

Maryland Schools, Harford County Public School District (North Harford Elementary School)

Issue Number: 46-04-3.c.2-P-07 Condition: North Harford Elementary School was unable to monitor EAS 970 AM.

Corrective Action Demonstrated: During the Peach Bottom Atomic Power Station exercise conducted on April 22, 2008, the North Harford Elementary School demonstrated the ability to monitor the new primary emergency alert station (EAS), WXCY, 103.7 FM.

The assistant principal's office had a portable AM/FM radio/CD player with both battery and electric wall outlet power tuned to the new primary EAS station.

Information obtained through interview identified other EAS stations that could be used and monitored as required. They were: WHFC, 91.1 FM, WBAL 1090 212

AM radio; and, the Harford County cable system through Comcast, channel 3, and Clearview, channel 7.

Maryland Schools, Harford County Public School District (Dublin Elementary School)

Issue No.: 46-06-3.c.2-A-12 Condition: Authorization letters for potassium iodide (KI) use by students for the 2005-2006 school year were not sent to parents.

Corrective Action Demonstrated: Authorization letters for Potassium Iodide (KI) use by students for the 2007-2008 school year were sent out to parents on October 2, 2007 by the Harford County Superintendent of Schools.

PRIOR PLANNING ISSUES UNRESOLVED Pennsylvania Emergency News Center (EOF Coatesville)

Issue No.: 46-06-5.b.1-P-01 Condition: Terminology to identify the several public information generation and dissemination facilities is inconsistent and confusing.

Two locations are referred to as "Joint Information Center," one at the Pennsylvania Emergency Operations Center (EOC) in Harrisburg and the other in Coatesville. A media guide prepared for the Peach Bottom exercise makes reference to a Commonwealth Joint Information Center (CJIC). The utility characterizes its public information operation as an "Emergency News Center" (ENC) while referring to the auditorium used for press conferences as a Joint Information Center (JIC). Exelon's JIC Activation Standard Operating Procedure (SOP) simply designates the room used for press conferences as the auditorium, while the staff call it the JIC. The Pennsylvania Radiological Emergency Preparedness Plan (RERP) states: "Multiple media centers will be established to include the CENIC [Commonwealth Emergency News and Information Center],

County information offices, and the utility media center. State and Federal media representatives are assigned to the utility media centers (sometimes called a Joint Information Center) during response to an emergency or disaster" (RERP E 3). The utility, on the other hand, never refers to its own facility as a "Utility Media Center."

There also are occasional references to a Joint Public Information Center. For example, signs throughout the ENC are labeled "JPIC" while the Pennsylvania Emergency Management Agency (PEMA) Media Liaison Duties procedure also uses Joint Public Information Center (JPIC). That term, however, appears to be vestigial.

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6 The overall concept of media operations is characterized by the State as a Joint Information System (RERP E-16-3). Finally, in the media guide for the Peach Bottom exercise, the acronym guide does not include JIC, CENIC, or ENC.

Reason ARCA Unresolved: Upon interview with the Pennsylvania Emergency Management Agency (PEMA) Planning representative at the Coatesville, Joint Information Center, it was determined that PEMA has reviewed and revised their plans and procedures to reflect a single set of terms to characterize each of the facilities. However, the revisions have yet to be approved, released and implemented.

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APPENDIX 6:

Additional Prior Issues This appendix contains the description and status of Areas Requiring Corrective Action (ARCAs) that were assessed during prior exercises at Peach Bottom Atomic Power Station (PBAPS). These were either (1) assessed at jurisdictions or functional entities which were exempt from demonstration during this exercise or (2) for ingestion exposure pathway objectives not scheduled for demonstration during this exercise.

Pennsylvania State Emergency Operations Center Issue No.: 46-98-29-A-01 (3.f.1)

Condition: A representative from the Department of Public Welfare did not participate in the State Response Task Force (SRTF). Consequently, issues concerning short- and long-term psychological impacts of the incident, and individual and family counseling for stress and other evacuation-related emotional or psychological problems, were not adequately addressed. (NUREG-0654, N. l.a.)

Reason ARCA Unresolved: The April 22-23, 2008 exercise was not a post-plume phase exercise.

Chester County Emergency Operations Center Issue No.: 46-98-27-A-02 (3.e.1)

Condition: Chester County officials did not simulate contacting the Chester Water Authority to close off, or coordinate the closing of, county's water intake

(#123004), which is in the Susquehanna River in Lancaster County near the PBAPS. This surface water intake was located in Zone A (i.e., the Restricted Zone defined by the Commonwealth of Pennsylvania). (NUREG-0654, J.9, 11)

Reason ARCA Unresolved: The April 22-23, 2008 exercise was not a post-plume phase exercise.

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01 Lancaster County Emergency Operations Center Issue No.: 46-98-29-A-03 (5.b.1)

Condition: The press release did not describe the procedures according to the Lancaster County plans, Appendix 16, Annex E.VI.C, 19, a.5., for the return of evacuees. Also, it failed to identify known landmarks and geographical boundaries or to identify protective action measures for milk and other food products. (NUREG-0654, M.1, 3; N.l.a)

Reason ARCA Unresolved: The April 22-23, 2008 exercise was not a post-plume phase exercise.

York County Emergency Operations Center Issue No.: 46-98-27-A-04 (5.b.1)

Condition: The lead-in scenario for the Ingestion Pathway Exercise, Day 2, indicated that milk and agricultural products within the "footprint" in Area E were unsuitable for consumption. However, the media map advisory, which was prepared and released by York County, stated "Print D represents the area in which agricultural products, including milk and crops, are unsuitable for consumption or market sale." Because Area D is smaller than Area E, the media and public would assume that the foods in a large area between the limits of Areas D and E were safe, whereas they actually were unsafe. (NUREG-0654, E.5, 7; J.9, 11)

Reason ARCA Unresolved: The April 22-23, 2008 exercise was not a post-plume phase exercise.

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