ML083170380

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Final Report for North Anna Power Station Plume and Ingestion Pathway Radiological Emergency Preparedness Exercises Held on July 22 and 23, 2008
ML083170380
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 11/05/2008
From: Hammons D
US Dept of Homeland Security, Federal Emergency Management Agency
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML083170380 (115)
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Text

U.S. Department of Homeland" One Independence Mall, Sixth Floor 615 Chestnut Street Philadelphia, PA 19106-4404

~FEMA NOV 5 2008 NRC Headquarters Document Control Desk US Nuclear Regulatory Commission Washington, DC 20555-0001 Enclosed is the final report for the North Anna Power Station (NAPS) Plume and Ingestion Pathway Radiological Emergency Preparedness Exercises that were held on July 22 and 23, 2008.

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

Sincerely, Darrell Hammons Regional Assistance Committee Chair Enclosure' LIIILQYe7 I1/4Y~S www.fema.gov

Norith Arnia Power Stcatioii Eermise- JSutly 22=23, 2008 Final Report - Radiological Emergency Preparedness Program October 28, 2008 FEMA Region III

Final Exercise Report North Anna Power Station Licensee: Dominion Generation Exercise Date: July 22-23, 2008 Report Date: October 28, 2008 U.S. DEPARTMENT OF HOMELAND SECURITY OFFICE OF INFRASTRUCTURE PROTECTION CHEMICAL & NUCLEAR PREPAREDNESS AND PROTECTION DIVISION RADIOLOGICAL EMERGENCY PREPAREDNESS FEMA REGION III ONE INDEPENDENCE MALL, 6 FLOOR 615 CHESTNUT STREET PHILADELPHIA, PENNSYLVANIA 19106-4404 ii

TABLE OF CONTENTS

1. Executive Sum m ary ................................................................................................................ 1 II. In tro du ctio n ......................................... ....................................................... ............................ 2 III. Exercise O verview .................................................................................................................... 5 A. Plume Emergency Planning Zone Description ............................................................ 5 B . Exercise Participants ..................................................................................................... 7 C . Exercise Tim eline ...... .......................................................... ............. 16 1...........................

IV . Evaluation and Results ....................................................................................................... 18 A. Summary Results of Exercise Evaluation .. 18 1.............................

B. Status of Jurisdictions Evaluated ................................................................................. 22 1.0, Commonwealth of Virginia .................................................................................. 24 1.1 State Emergency Operations Center ............ ......................................... 24 1.2 State Emergency Operations Center (Division of Radiation Protection/

Radiological Health Program) ..... ............................. .. 25 1.3 Joint Public Information Center (Dominion-Innsbrook Technical Center). 25 1.4 Joint Inform ation C enter .............................................................................. 25.

1.5 Local Emergency Operations Facility (Division of Radiological Health and Virginia Department of Emergency Management) .......................... 26 1.6 State Field Monitoring Team 1 ........................... 26 26............................

1.7 State Field Air Monitoring Team 2............................................................ 26 1.8 State Field Sampling Team 1 ......................................................... ............... 27 1.9 State Mobile Laboratory .......................................................................... 27 1.10 Medical Services - Transportation (Spotsylvania Volunteer Rescue Squad) ................................................................................................ . .. 27 1.11 Medical Services - Facility (Mary Washington Hospital) ..................... 28 2.0 R isk Jurisdictions .............................................................................................. 29 2.1 C aroline C ounty ..................................................................................... 29 2.1.1 Caroline County Emergency Operations Center .......................... 29 2.1.2 Staging Area - Traffic Control Point/Access Control Point............ 29 2.1.3 Field Monitoring Team .............................................................. 29 2.1.4 Exception Area Route Alerting (Route A) ............. ............. 3..............

30 iii

2.1.5 Back-up Route Alerting (Siren 36) ............................................ 30 2.1.6 Evacuation Assembly Center (Caroline High School) .................... 31 2.1.7 School District (Ladysmith Elementary School) ......................... 31 2.2 H anover C ounty ..................................................................................... 32 2.2.1 Hanover County Emergency Operations Center .......................... 32 2.2.2 Staging Area - Traffic Control Point/Access Control Point ..... 32 2.2.3 Field M onitoring Team .................................................................... 32 2.2.4 Exception Area Route Alerting (Route B) ................................... 33 2.2.5 Back-up Route Alerting (Siren 41) ............................................ 33 2.2.6 Evacuation Assembly Center (Liberty Middle School) ......... 33

,2.2.7 School District (Liberty Middle School) ..................................... 34 2.3 L ouisa C ounty 3.............................

34 2.3.1 Louisa County Emergency Operations Center ............................ 34 2.3.2 Staging Area - Traffic Control Point/Access Control Point...* ........ 35 2.3.3 Field Monitoring Team ........................................ ...................... 35 2.3.4 Primary Route Alerting (Route V, Assignment 2) ...................... 35 2.3.5 Exception Area Route Alerting (Route L, 0, Assignment 5) ..... 36 2.1.6 School District (Ladysmith Elementary School) ......................... 36 2.4 Orange County ......................................... 36 2.4.1 Orange County Emergency Operations Center ............................ 36 2.4.2 Staging Area - Traffic Control Point/Access Control Point ..... 37 2.4.3 Field M onitoring Team ............................................................... 37 2.4.4 Exception Area Route Alerting (Route B) .................... I.................. 38 2.4.5 Back-up Route Alerting (Siren 10) ................... :........................ 38 2.4.6 School District (Lightfoot Elementary School) .......................... 39 2.5 Spotsylvania County ............................................................................... 39 2.5.1 Spotsylvania County Emergency Operations Center .................. 39 2.5.2 Staging Area - Traffic Control Point/Access Control Point ........ 40 2.5.3 Field Monitoring Team ............................................................... 40 2.5.4 Primary Route Alerting (Route Q, Assignment 13) ..................... 41 2.5.5 Exception Area Route Alerting (Route H, I, Assignment 8) ..... 41 2.5.6 Evacuation Assembly Center (Massaponax High School) ...... 41 2.5.7 School District (Spotsylvania County High School) ................... 42 3.0 Ingestion Jurisdictions ..................................................................................... 43 3.1 Virginia Jurisdictions .............................................................................. 43 iv

3.1.1 Caroline County (Risk) ............................................................... 43 3.1.2 Hanover County (Risk) .............................................................. 43 3.1.3 Louisa County (Risk) ................................................................... 43 3.1.4 Orange County (Risk) ................................................................. 44 3.1.5 Spotsylvania County (Risk) ........................................................ 44 3.1.6 Albemarle County/Charlottesville ............................................... 44 3.1.7 A melia County ........... ................................................................ 45 3.1.8 Buckingham County ................................................................... 45 3.1.9 Chesterfield County ................................. 46 3.1.10 C ulpeper County .......................................................................... 46 3.1.11 Cum berland County ...................................................................... 46 3.1.12 Essex County ..................................... 47 3.1.13 Fairfax C ounty ............................................................................ 47 3.1.14 Fauquier C ounty ........................................................................... 48 3.1.15 Fluvanna County ......................................................................... 48 3.1.16 Fredericksburg City ..................................................................... 48 3.1.17 Goochland County .................................. 49 3.1.18 Greene County ......................................... 49 3.1.19 H enrico C ounty ............................................................................ 50 3.1.20 King and Queen County .............................. 50 3.1.21 King George County ................................................................... 50 3.1.22 King William County ................................ 51 3.1.23 M adison C ounty ......................................................................... . 51 3.1.24 Manassas City County ................................................................. 52 3.1.25 N ew K ent County ...................................................................... 52 3.1.26 Page C ounty ................................................................................. 52 3.1.27 Pow hatan County ........................................................................ 53 3.1.28 Prince William County .............................. 53 3.1.29 Rappahannock County ................................................................. 54 3.1.30 Richm ond County ........................................................................ 54 3.1.31 Richm ond C ity ............................................................................. 54 3.1.32 Rockingham County ................................ 55 3.1.33 Stafford C ounty ............................................................................. 55 3.1.34 Westmoreland County ................................................................. 56 v

APPENDICES APPENDIX 1: Acronyms and Abbreviations ............................................................... 57 APPENDIX 2: Exercise Evaluators and Team Leaders .............................................................. 59 APPENDIX 3: Exercise Evaluation Area Criteria and Extent of Play Agreement ................. 65 A PPEND IX 4: Exercise Scenario ............................................................................................ 99 A PPEND IX 5: Planning Issues ................................................................................................... 101 LIST OF TABLES Table 1 - E xercise T im eline .......................................................................................... ... ..... 17 Table 2 - Summary Results of Exercise Evaluation ..................................... I............................ 19 vi

I. EXECUTIVE

SUMMARY

On July 22, 2008, a full-scale plume exercise was conducted in the 10-mile plume exposure pathway, emergency planning zone (EPZ) around the North Anna Power Station (NAPS) by the Federal Emergency Management Agency (FEMA), Region III. An ingestion exercise was held on July 23, 2008. Out-of-sequence demonstrations were conducted on June 9-11, 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 December 5, 2006. The qualifying emergency preparedness exercise was conducted on September 18, 1983.

FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Virginia; the risk jurisdictions of Caroline, Hanover, Louisa, Orange, and Spotsylvania counties; and the ingestion jurisdictions of Albemarle, Amelia, Buckingham, Caroline, Chesterfield, Culpeper, Cumberland, Essex, Fairfax, Fauquier, Fluvanna, Goochland, Greene, Hanover, Henrico, King and Queen, King George, King William, Louisa, Madison, New Kent, Orange, Page, Powhatan, Prince William, Rappahannock, Richmond, Rockingham, Spotsylvania, Stafford, and Westmoreland counties and Fredericksburg, Manassas and Richmond-cities who were evaluated at this exercise.

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

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

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

  • Evacuation Assembly Centers: Conducted on June 9, 2008 in Caroline County and on June 10, 2008 in Hanover and Spotsylvania Counties.
  • Medical Services: Conducted on June 9-11, 2008 in Spotsylvania County and the City of Fredericksburg.

The State and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Deficiencies and no Areas Requiring Corrective Action (ARCAs) identified as a result of this exercise. Five ARCAs from a previous exercise were successfully demonstrated at this exercise.

Two new planning issues were identified. Four planning issues from a previous, exercise were successfully demonstrated; two planning issues from a prior exercise remain unresolved (see Appendix 5 all planning issues).

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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.

2

A REP exercise was conducted on July 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 North Anna Power Station (NAPS). 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:

  • 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;

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, 3

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).

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III. Exercise Overview Contained in this section are data and basic information relevant to the July 22-23, 2008 exercise to test the off-site emergency response capabilities in the area surrounding North Anna Power Station (NAPS). 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 Dominion Generation owns and operates the North Anna Power Station. It consists of two units (Unit 1 and Unit 2) each of which includes a three-loop pressurized light water, reactor nuclear steam system and turbine generator. Each reactor unit is designed for an initial core power output of 2,893 megawatts (thermal), which results in a gross electrical output of approximately 960 megawatts (electrical). Cooling water, contained by an earthen dam structure, is obtained from the 17-mile long Lake Anna. Commercial operations began at Unit 1 in June 1978, and at Unit 2 in December 1980. The operating license for Unit 1 will expire in April 2018, and for Unit 2 in August 2020.

Location The North Anna Power Station is located in Mineral, Virginia. The site and exclusion area consist of approximately 1,856 acres. The units are located on a peninsula on the southern shore of Lake Anna in Louisa County approximately 40 miles north-northwest of Richmond, 38 miles east of Charlottesville, and 24 miles southwest of Fredericksburg.

PopulationDensity Population centers of 25,000 or more (based on the 2000 census) within a 50-mile radius of the station site are Richmond, 40 miles south-southeast of the site; Charlottesville, 38 miles west of the site; and Fredericksburg, 24 miles northeast of the site. The largest residential area within a ten-mile radius of the site is the Town of Mineral and the area around the Lake Anna. The residential population within a five-mile radius as determined by using 2000 census data is approximately 4,052. The residential population to a distance of ten miles from the site using 2000 census data is about 20,292. The largest population within the 10-mile EPZ is the town of Mineral, which has 471 residents. Five risk county boundaries are located within the 10-mile EPZ. The 50-mile ingestion exposure pathway EPZ includes 30 counties and three city jurisdictions, with a total population of 1,286,156.

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Sixty-six sirens have been strategically placed throughout the 10-mile EPZ for notifying the public in case an accident occurs at one of the two units. In addition, there are several areas requiring route-alerting teams for notifying residents.

No large airports lie within the 10-mile EPZ. No railroad lines or major interstate highways pass through the 10-mile EPZ. Because most of the soil in the areais sandy or marshy, the primary crops are animal feeds. The few dairies and other food sources primarily serve local residents.

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B. Exercise Participants The following agencies, organizations, and units of government participated in the NAPS out-of-sequence activities on June 9-11, 2008, or the plume and ingestion exercises on July 22-23, 2008.

COMMONWEALTH OF VIRGINIA Center for Disease Control Department of Energy Environmental Protection Agency Federal Radiological Monitoring and Assessment Center Food and Drug Administration Nuclear Regulatory Commission Spotsylvania County Department of Fire, Rescue, and Emergency Management Spotsylvania County Rescue Squad Station #5 United States Department of Agriculture Virginia Cooperative Extension Virginia Department of Agriculture and Consumer Affairs Virginia Department of Corrections Virginia Department of Criminal Justice Services Virginia Department of Emergency Management Virginia Department of Emergency Management, External Affairs, 4 participants Virginia Department of Game and Inland Fisheries Virginia Department of Health Virginia Department of Health, Bureau of Radiological Health Virginia Department of Military Affairs Virginia Department of Social Services Virginia Department of Transportation Virginia Information Technology Agency Virginia Secretary of Public Safety Virginia State Police RISK JURISDICTIONS Caroline County Alexandria Fire-EMS Arlington County Fire Department Caroline County Department of Fire and Rescue/Emergency Services Caroline County Department of Social Services Caroline County Dispatch Center Caroline County Emergency Management Caroline County Hazardous Material Team Caroline County Public Schools Caroline County Sheriff s Department 7

Caroline County Superintendent of Schools Ladysmith Volunteer Fire Station No. 2 Virginia Department of Emergency Management Virginia Department of Transportation Virginia Health Department Virginia Polytechnic Institute and State University Extension Division Virginia State Police Hanover County Ashland Police Department Hanover County 911/Emergency Communications Center Hanover County Administration Hanover County Fire Department/Emergency Medical Service Hanover County Fire EMS Station No. 2 Hanover County Local Emergency Planning Committee Hanover County Office of Emergency Services Hanover County Public Schools Hanover County Sheriff s Department Hanover Department of Social Services Virginia Cooperative Extension Service Virginia Department of Emergency Management Virginia Department of Health/Hanover County Department of Public Health Louisa County Coast Guard Auxiliary Henrico County Fire Department Henrico County Hazmat Incident Team Louisa County Administrator Louisa County CERT Team Louisa County Department of Emergency Services Louisa County Extension Office Louisa County Facilities Management Louisa County Finance Department Louisa County Fire Association Louisa County Health Department Louisa County IT Department Louisa County Middle School Louisa County Public Schools Louisa County Public Schools Superintendent's Office Louisa County Sheriff s Department Louisa County Social Services Louisa Town Police Department Town of Mineral Virginia Department of Transportation Virginia State Police York County 8

Orange County City of Fredericksburg Fire Department Fredericksburg Hazardous Material Regional Response Team Orange County Administration Orange County Attorney's Office Orange County Board of Supervisors Orange County Department of Emergency Services Orange County Department of Health Orange County Emergency Communications Center Orange County Emergency Management Agency Orange County Fire and Emergency Management Services Department Orange County Health Department Orange County Office of Emergency Services Orange County Public School System Orange County Sheriffs Department Orange County Volunteer Fire Company Virginia Department of Emergency Management Spotsylvania County Fredericksburg Volunteer Fire Spotsylvania County Agricultural Extension Service Spotsylvania County Department of Fire, Rescue and Emergency Services Spotsylvania County Department of General Services Spotsylvania County Department of Geographical Information Systems Spotsylvania County Department of Health Spotsylvania County Department of Social Services Spotsylvania County Emergency Services Spotsylvania County Fire Company. #1 Spotsylvania County High School Spotsylvania County High School Principal Spotsylvania County School Superintendent Spotsylvania County School Transportation Department Spotsylvania County Schools Spotsylvania County Sheriff s Department Spotsylvania County Social Services Spotsylvania Sheriffs Office Spotsylvania Volunteer Fire Department, Station 1 Virginia Department of Emergency Management Virginia Department of Emergency Management, Controller Virginia Department of Health Virginia Department of State Parks Virginia Department of Transportation Virginia State Police 9

INGESTION JURISDICTIONS Caroline County Agriculture Extensions Caroline CountyCommunications Caroline County Emergency Management Caroline County Public Information Officer Virginia Department of Health Hanover County Hanover County Fire/EMS Virginia Department of Health Louisa County Louisa County Administrator Louisa County Agricultural Extension Office Louisa County Emergency Services Louisa County Sheriff's Office Thomas Jefferson Health District Orange County Orange County Attorney/Public Information Officer Orange County Emergency Services Orange County Extension Service Orange County Public Health Department Spotsylvania County Spotsylvania County Agricultural Extension Service Spotsylvania County Department of Fire, Rescue and Emergency Support Spotsylvania County Social Services Albemarle County/Charlottesville County Albemarle County Office of the County Executive, Community Relations Manager/PIO Charlottesville/UVA/Albemarle County Thomas Jefferson Health District, Environmental Health Supervisor Virginia Cooperative Extension, Extension Agent Amelia County Amelia County Administrator Amelia County Emergency Services Coordinator Amelia County Sheriffs Office Virginia Department Agriculture and Customer Services Virginia Department of Health 10

Buckingham County Buckingham County Administration Buckingham County Board of Supervisors Buckingham County Health Department Buckingham County Sheriff s Office US Department of Agriculture, Farm Service-Agency Chesterfield County Chesterfield County Emergency Management Department Chesterfield County Fire Department Chesterfield County Health Department Chesterfield County Police Department Chesterfield County Public Affairs Office Chesterfield County Utility Department Virginia Cooperative Extension Service Culpeper County Culpeper County Department of Emergency Services Culpeper County Volunteer Fire and Rescue Department Virginia Cooperative Extension Office, Culpeper County Office Virginia Department of Health, Culpeper County Office Cumberland County Cumberland County Board of Supervisors Cumberland County Emergency Services Cumberland County Health Department Cumberland County Sheriff's Department Virginia Cooperative Extension Service Essex County Essex County 9-1-1 Communications Essex County Administrator's Office Essex County Office of Emergency Management Essex County Sheriffs Office Fairfax County Fairfax City Police Department Fairfax County 911 Fairfax County Department of Human Services Fairfax County Fire and Rescue Fairfax County Health Department Fairfax County Information Technology Services Department Fairfax County Office of Emergency Management Virginia Department of Agriculture and Consumer Affairs Virginia Department of Emergency Management 11

Fauquier County Fauquier County 911 Services Fauquier County Cooperative Agriculture Fauquier County Fire Rescue Emergency Services Fauquier County Health Department Fluvanna County "

Fluvanna County Sherriff's Department Palmyra Fire Department Virginia Agriculture and Natural Resource Department Virginia Department of Health Fredericksburg City City of Fredericksburg Fire Department City of Fredericksburg Police Department City of Fredericksburg, Communications Officer Virginia Department of Health Goochland County Goochland County Administrator Goochland County Emergency Manager Goochland County GIS Goochland County Health Department Goochland County Sheriffs Office Greene County Greene County Board of Supervisors Greene County Department of Public Safety Greene County Sheriffs Office Virginia Department of Agriculture Virginia Department of Emergency Management Virginia Department of Health Henrico County Henrico County Division of Fire Henrico County Division of Police (Communications/9-1-1)

Henrico County Emergency Management Henrico County Environmental Health Henrico County Extension Office Henrico County Hazmat Henrico County Health Department Henrico County Public Relations & Media Services Henrico County Public Utilities Henricopolis Soil & Water Conservation District 12

King and Queen County Virginia Cooperative Extension, King and Queen County Office Virginia Department of Health, King and Queen County Health Department King George County King George County 911 King George County Administrator/Public Information Officer King George County Communications Director King George County Deputy Emergency Management Coordinator King George County Emergency Management Coordinator King George County Emergency Management Planner King George County Finance Director King George County GIS Coordinator King George County Procurement Manager King George County RACES and 911 Lead Dispatcher King George County Service. Authority Virginia Cooperative Extension King William County King William County Emergency Management King William County Public Information Office King William County Sheriff s Office Three Rivers Health District Virginia Cooperative Extension Madison County Madison County Emergency Services Coordinator Madison County 9-1 -1 Communications Director Madison County Health Department Madison County Cooperative Extension Agent Manassas City Manassas City Communication Supervisor Manassas City Deputy Emergency Management Coordinator Manassas City HAZMAT/Safety Officer Manassas City Public Information Officer New Kent County New Kent County Emergency Management Agency New Kent County Health Department Providence Forge Fire Department Page County Page County Communication Page County Emergency Services Page County Extension Agent 13

Page County Fire Rescue Page County Sheriff Office Virginia Department of Health Virginia State Police Powhatan County Chesterfield Health District Powhatan County Administration Powhatan County Emergency Management Powhatan County GIS Coordinator Powhatan County Health Department Powhatan County Sheriffs Office Virginia Department of Agriculture Prince William County Prince William County Emergency Management Prince William County Extension/Agriculture Prince William County Fire and Rescue Prince William County GIS/Mapping Prince William County HazMat Prince William County Health District Prince William County Planning Prince William County Police Prince William County Public Affairs Prince William County Public Health Planning Prince William County Public Safety Communications Prince William County Public Works Rappahannock County Rappahannock County Administration Rappahannock County Emergency Dispatch (911)

Rappahannock County Health Department Rappahannock County Office of Emergency Management Rappahannock County Sheriffs Office Virginia Cooperative Extension Richmond County Richmond County Agricultural Agent Richmond County Emergency Services Richmond County Sheriffs Office Richmond City City of Richmond Fire Department City of Richmond Health District City of Richmond Office of Emergency Management Richmond Ambulance Authority 14

Rockingham County Agricultural Extension Office City of Harrisonburg/Rockland County Emergency Management Rockland County Department of Health Stafford County Stafford County 911 Communication Center Stafford County Fire/Rescue Department Virginia County Extension Virginia Department of Public Safety Westmoreland County Westmoreland County Administrator Office Westmoreland County Emergency Services Westmoreland County Public Works PRIVATE/VOLUNTEER ORGANIZATIONS The following private and volunteer organizations participated in the NAPS 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:

Caroline County ARES/RACES Orange County RACES Team Spotsylvania County ARES/RACES American Red Cross, including the following local chapters:

Central Virginia Regional Chapter Dominion Resources Services, Inc Hanover County Fire/EMS Volunteers Mary Washington Hospital Virginia Nation Guard, 3 4 th Civil Support Team 15

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

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0 V El 0 TABLE 1. EXERCISE TIMELINE DATE AND SITE: July 22, 2008 - North Anna Power Station Ii Time That Notification Was Received Emergency Classification Time Utility Emergency Joint Public Caroline Hanover Louisa Orange Spotsylvania Level or Event Declared Operations Information County County County County County Virginia EOC Facility Center EOC EOC EOC EOC EOC Unusual Event N/A N/A N/A N/A N/A N/A N/A N/A N/A Alert 0815 0823 0815 0835 0839 0855 0832 0842 0834 Site Area Emergency 1000 1011 1000 1011 1017 1031 1015 1014 1019 General Emergency 1123 1140 1123 1150 1150 1158 1147 1153 1154

[Simulated Radiation Release Started 1123 1140 1123 1150 1150 1158 1147 1153 1154 ISimulated Radiation Release Terminated N/A NA N/A N/A N/A N/A N/A N/A N/A Facility Declared Operational 0800 0943 0854 0930 1036 0856 0920 0840 Declaration of State of Emergency Local 1207 1207 1233 1210 1212 1019 1207 1207 Exercise Terminated 1329 1319 1319 1345 1435 1344 1330 1337 Precautionary Actions: Air, Rail, Waterways (if made) 1050 N/A N/A N/A N/A N/A N/A N/A

.e -- -----...

.r.e.ca.ti.na...........

Precautionary evacuation aut.......of schools Local ...................................

  • ...........................L...!...... N AN N/A N/AAN N/AAN N/AANj N/AAN N/AAN N/AA0 09313 Livestock advisory - stored food & water, shelter 1020 1205 1039 1045 1143 1049 1043 1100 Local - Livestock Advisory N/A N/A N/A 1205 1140 N/A N/A 1140 1st A&N Decision (State [made]; local [received])

Evac-4,6,7,8,9,10,25 Shelter 5,11,22,26 1207 1207 1211 1211 1211 1211 1211 1211 1st Siren Activation 1222 VIM = 11222 1222 1st EAS Message 1226 ___ , ,-_____,___________

KI Administration Decision: Emergency Workers advised 1247 1243 1255 1255 1255 .1255 1255 not to take KI 1255 Legend: N/A - Not Applicable 17

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 July 22, 2008, biennial Radiological Emergency Preparedness (REP) plume exercise and the July 23, 2008 ingestion exercise. The exercises were held to test the offsite emergency response capabilities of local governments in the 10-mile Emergency Planning Zone (EPZ) surrounding the North Anna Power Station (NAPS).

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)

R Resolved ARCA(s) from prior exercises U Unresolved ARCA(s) from prior exercises 18

0 S 0 0 TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: July 22-23, 2008- North Anna Power Station I c]T2. 1 2. 12. .12*T- 2. 3. 313.13. 3 3* 3..1 3. 3 4 4.4. 14f41. 5 5a. 5*a f 6I 6 16 1 JURISDICTION/LOCATION a.blcd.

1 1e.

1I a1 b b.

2 c.

1 d

1 e.

1 1

. b.

1 c

1 2 J.d.

1 d.

2 1 e.

2 f

1 a"Ta.1"a.2 a.

3 b,

1 c 11 1 2 3 1"

1"1 1"

COMMONWEALTH OF VIRGINIA State Emergency Operations M M M M M M M M M M M M M M Center Stat&EOC (DRP-RPH) M_ M M M M M Joint Public Information Center M (Dominion-Innsbrook Tech. Ctr.) _

Joint Information Center M Local EOF (DRH & VDEM) M M M M M M M M M State Field Monitoring Team I M M M M M M State Field Monitoring Team 2 M M M M M M State Field Sampling Team 1 M M M M State Mobile Laboratory M M M M Medical Services - Transportation M M (Spotsylvania Vol. Rescue Squad) I I Medical Services - Facility (Mary M M M Washington Hospital)

RISK JURISDICTIONS Caroline County Caroline County EOC M M M M M M M M M M M M M M Staging Area - TCP/ACP M M M M M M M Field Monitoring Team M M M M M M/R M Exception Area Route Alerting M M M M M M (Route A)

Back-up Route Alerting (Siren 36) M M M M M M EAC (Caroline [IS) M M M M M M School District (Ladysmith ES) M Hanover County Hanover County EOC M M M M M M M M M M M M M M Staging Area - TCP/ACP M M M M M M M Field Monitoring Team M M M M M M M Exception Area Route Alerting M M M M M M (Route B)

Back-up Route Alerting (Siren 41) M MM M M M EAC (Liberty MS) M M M M M M School District (Ladysmith ES) M Louisa County Louisa County EOC M M M M M M M M M M M M M M Staging Area - TCP/ACP M M M M M M M Field Monitoring Team M M M M M M M Primary Route Alerting (Route V, M M M M M M Assignment 2)

LEGEND: M = Met (no Deficiency or ARCA(s) assessed) A = ARCA(s) assessed ýAl = ARCA(s) assessed but successfully re-demonstrated R = Resolved ARCA(s) from prior exercises U = Unresolved ARCA(s) from prior exercise Blank = Not scheduled for demonstration 19

0 0 TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: July 22-23, 2008 - North Anna Power Station JURISDICTION/LOCATION l l _ --.... ce a. i b.

2. 2.13.11 i

2[1.2.1112.12 31

" J lJc3 .J3.

cI 2 e. l l 4414124.41411141

e. a. a 4 a.5.5 a l a li~ 61il1

. b"a 6 16 6

[66 d

Exception Area Route Alerting M M M M M M (Route L,O, Assignment 5)

School District (Louisa Co. MS) M Orange County Orange County EOC M M M M M M M M M M M M M M Staging Area - TCP/ACP M M M M M/R M M Field Monitoring Team M M M M M M/R M Exception Area Route Alerting M M M M M M (Route B)

Back-up Route Alerting (Siren 10) M M M M M M School District (Lightfoot ES) M Spotsylvania County SpotsylvaniaCounty EOC M M M M M M M M M M M M M M Staging Area - TCP/ACP M M M M M M M Field Monitoring Team M/R M *M M M M M Primary Route Alerting (Route Q, M M M M M M Assignment 13)

Exception Area Route Alerting M MM MM M 8)

(Route H, 1,Assignment EAC (Massaponax HS) M M M M M M School District Spotsylvania M County HS)

INGESTION JURISDICTIONS Risk/Ingestion Counties Caroline County M M M M M M M Hanover County M M M M M M M Louisa County M M M MM M M Orange County M M M M M M .

  • M Spotsylvania County M M M M M M M Virginia Jurisdictions Albemarle County/Charlottesville M M M M M M M M Amelia County M M M M M M M M Buckingham County M M M M M M M M Chesterfield County M M M M M M M M Culpeper County M M M M M M M . M Cumberland County M M M M M M M M Essex County M M M M M M M M Fairfax County M M M M M. M M M Fauquier County M M M M M .. M M M Fluvanna County M M M M M . M M .. M Fredericksburg City MM M M M M M M Goochland County M M M 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 U = Unresolved ARCA(s) from prior exercise Blank = Not scheduled for demonstration 20

0 0 TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: July 22-23, 2008 - North Anna Power Station 1 13 .4_

JURISDICTION/LOCATION c.

l l 1. . 2.

2a .. 2. 2.lrc.

2. c. 2 d .2.

12.1 3. aa 1 44 1[5. 5. 6 b c

[6161 d.1 Greene County M M MMM M M M Henrico County M M M M M M M M King and Queen County M M M M M M M M King George C6unty M M M M M M M M King William County M M M M M M M M Madison County M M M M M M M M Manassas City M M M M M M M M New Kent County M M M M M M M M Page County M M M M M M M M Powhatan County M M M M M M M M Prince William County M M M M M M M M Rappahannock County M M M M M M M M Richmond County M M M M M M M M Richmond City M M M M M M M M Rockingham County M M M M M M M M Stafford County M M M M M M M M Westmoreland County M M M M M _ M M _ 1_N 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 U- Unresolved ARCA(s) from prior exercise Blank = Not scheduled for demonstration 21

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."

22

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.

23

1.0 COMMONWEALTH OF VIRGINIA 1.1 State Emergency Operations Center

a. MET: 1.a.1 2.B.1 3.b.1 5.a.1 1.c.1 2.b.2 3.e.1 5.b.1 1.d.1 2.d.1 3.e.2 1.e.1 2.e.1 3.f.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: One Issue No.: 41-06-1.e.1-A-01 Condition: The modified administrative exposure limit (0.45 R reporting level) could not be read using the issued dosimetry. This condition was also identified during the 2006 Surry exercise.

Reason ARCA Unresolved: The State replaced the 0-20R Direct Reading Dosimeters with SAIC Model PSD-03 Digital Alarming Dosimeters which are capable of accurately reading any dose that an emergency worker could receive including very low doses.

However, each county was not provided with the number of Digital Alarming Dosimeters that is currently specified for Model 622 0-20R Dosimeters in Tab E to Appendix 7 of the Virginia Emergency Operations Plan. The following is the number of dosimeters specified/provided for each risk county: Caroline 32/20, Hanover 26/10, Louisa 50/10, Orange 28/10, and Spotsylvania 49/10.

Recommendation: Provide each risk county with dosimetry as specified in Tab E to Appendix 7. Also, change the column heading from "0-20R Dosimeter Model 622" to "SAIC Model-03 Digital Alarming Dosimeter."

24

1.2 State Emergency Operations Center (Division of Radiation Protection/Radiological Health Program)

a. MET: 1.a.1 2.a.1 3.b.1 1.d.1 2.b.1 i.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 1.3 Joint Public Information Center (Dominion-Innsbrook Technical Center)
a. MET: 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 1.4 Joint Information Center
a. MET: 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 25

1.5 Local Emergency Operations Facility (Division of Radiological Health and Virginia Department of Emergency Management)

a. MET: 1.c.1 2.a.1 3.a.1 4.a.2 1.d.1 2.b.1 3.b.1 1.e.1 2.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 1.6 State Field Monitoring Team 1
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 1.7 State Field Air Monitoring Team 2
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 26

1.8 State Field Sampling Team 1

a. MET: 1.d.1 3.a.1 4.b.1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None C. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 1.9 State Mobile Laboratory
a. MET: 1.d.1 3.a.1 4.c.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 1.10 Medical Services - Transportation (Spotsylvania Volunteer Rescue Squad)
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 27

1.11 Medical Services - Facility (Mary Washington Hospital)

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 28

2.0 RISK JURISDICTIONS 2.1 Caroline County 2.1.1 Caroline County Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.I 4.a.2 5.a.1 1.c.1 2.c.1 3.b.1 5.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 2.1.2 Staging Area - Traffic Control Point/Access Control Point
a. MET: 1.a.1 3.a.1 1.d.1 3.b.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 2.1.3 Field Monitoring Team
a. MET: 1.a.1 3.a.1 4.a.1 1.d.1 3.b.1 4.a.3 i.e.1
b. DEFICIENCY: None 29
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: One Issue No.: 41-06-4.a.1-A-03 Condition: The Ludlum 2240 Survey Meter Probe was not wrapped in a probe cover before leaving the Staging Area.

Corrective Action Demonstrated: The Caroline County Radiological Officer first cautioned the teams to cover the Ludlum 2240-1 probes with thin plastic covers during her briefing at the staging area. This instruction was also contained in the ESF #10 field monitoring procedure. Each team was issued at least six probe covers at the staging area. Both Field Monitoring Teams 1 and 2 assured that the probes were covered prior to deployment to the Emergency Planning Zone and throughout monitoring operations in the field.

f. PRIOR ARCAs - UNRESOLVED: None 2.1.4 Exception Area Route Alerting (Route A)
a. MET: 1.a.1 3.a.1 5.a.3 1.d.1 3.b.1 i.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 2.1.5 Back-up Route Alerting (Siren 36)
a. MET: 1.a.1 3.a.1 5.a.3 1.d.1 3.b.1 1.e.1 30
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.1.6 Evacuation Assembly Center (Caroline High School)
a. MET: 1.e.1 3.a.1 6.a.1 3.b.1 6.b.1 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 2.1.7 School District (Ladysmith 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 31

2.2 Hanover County 2.2.1 Hanover County Emergency Operations Center

a. MET: 1.a.1 2.a.1 3.a.1 4.a.2 5.a.1 1.c.1 2.c.1 3.b.1 5.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 2.2.2 Staging Area - Traffic Control Point/Access Control Point
a. MET: 1.a.1 3.a.1 1.d.1 3.b.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 2.2.3 Field Monitoring Team
a. MET: 1.a.1 3.a.1 4.a.1 1.d.1 3.b.1 4.a.3 i.e. 1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None 32
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.2.4 Exception Area Route Alerting (Route B)
a. MET: 1.a.1 3.a.1 5.a.3 1.d.1 3.b.1 i.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 2.2.5 Back-up Route Alerting (Siren 41)
a. MET: 1.a.1 3.a.1 5.a.3 1.d.1 3.b.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 2.2.6 Evacuation Assembly Center (Liberty Middle School)
a. MET: 1.e.1 3.a.1 6.a.1 3.b.1 6.b.1 6.c.1
b. DEFICIENCY: None 33
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs.- RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.2.7 School District (Liberty Middle School)
a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.3 Louisa County 2.3.1 Louisa County Emergency Operations Center
a. MET: 1.a.1 2.a.1 3.a.1 4.a.2 5.a.1 1.c.1 2.c.1 3.b.1 5.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 34

2.3.2 Staging Area - Traffic Control Point/Access Control Point

a. MET: 1.a.1 3.a.1 1.d.1 3.b.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 2.3.3 Field Monitoring Team
a. MET: 1.a.1 3.a.1 4.a.1 1.d.1 3.b.1 4.a.3 L.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 2.3.4 Primary Route Alerting (Route V, Assignment 2)
a. MET: 1.a.1 3.a.1 5.a.3 1.d.1 3.b.1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None 35
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.3.5 Exception Area Route Alerting (Route L, 0, Assignment 5)
a. MET: 1.a.1 3.a.1 5.a.3 1.d.1 3.b.1 i.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 2.1.6 School District (Ladysmith 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 2.4 Orange County 2.4.1 Orange County Emergency Operations Center
a. MET: 1.a.1 2.a.1 3.a.1 4.a.2 5.a.1 1.c.1 2.c.1 3.b.1 5.b.1 1.d.1 3.c.1 1.e.1 3.d.1 3.d.2
b. DEFICIENCY: None 36
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.4.2 Staging Area - Traffic Control Point/Access Control Point
a. MET: 1.a.1 3.a.1 1.d.1 3.b.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: One Issue No.: 41 3.b.1-A-05 Condition: Although simulated potassium iodide (KI) was available at the Orange County Staging Area, it was not issued to emergency workers (including the field monitoring team) prior to their deployment to the field.

Corrective Action Demonstrated: The staging area manager provided a briefing and issued KI to all emergency workers at the, staging area prior to their deployment to the field.

f. PRIOR ARCAs - UNRESOLVED: None 2.4.3 Field Monitoring Team
a. MET: 1.a.1 3.a.1 4.a.1 1.d.1 3.b.1 4.a.3 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None 37
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: One Issue No.: 41-06-4.a.1-A-06 Condition: The Ludlum 2240 Survey Meter Probe was not wrapped in a probe cover before leaving the Staging Area.

Corrective Action Demonstrated: During the North Anna Power Station Exercise on 07/22/08, the Radiological Officer included the wrapping of the probe in his briefing prior to deployment of the field monitoring teams. The teams wrapped the probes in plastic and maintained them in that condition throughout the exercise. Also, Item "E" under the Alert section of the Field Monitoring Team procedures directs the teams to wrap the probe before leaving the staging area.

f. PRIOR ARCAs - UNRESOLVED: None 2.4.4 Exception Area Route Alerting (Route B)
a. MET: 1.a.1 3.a.1 5.a.3 1.d.1 3.b.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 2.4.5 Back-up Route Alerting (Siren 10)
a. MET: 1.a.1 3.a.1 5.a.3 1.d.1 3.b.1 1.e.1
b. DEFICIENCY: None 38

C. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.4.6 School District (Lightfoot 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 2.5 Spotsylvania County 2.5.1 Spotsylvania County Emergency Operations Center
a. MET: 1.a.1 2.a.1 3.a.1 4.a.2 5.a.1 1.c.1 2.c.1 3.b.1 5.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 39

2.5.2 Staging Area - Traffic Control Point/Access Control Point

a. MET: 1.a.1 3.a.1 1.d.1 3.b.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 2.5.3 Field Monitoring Team
a. MET: 1.a.1 3.a.1 4.a.1 1.d.1 3.b.1 4.a.3 i.e. 1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: One Issue No.: 41-06-1.a.1-A-07 Condition: The Spotsylvania County Field Monitoring Team (FMT) was not dispatched in a timely manner.

Corrective Action Demonstrated: Procedures were revised to dispatch the monitoring team at Site Area Emergency. The Site Area Emergency Notification was received at the assembly point for the FMT at 1036. At 1055 the FMT was proceeding to their first monitoring location.

f. PRIOR ARCAs - UNRESOLVED: None 40

2.5.4 Primary Route Alerting (Route Q, Assignment 13)

a. MET: 1.a.1 3.a.1 5.a.3 1.d.1 3.b.1 i.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 2.5.5 Exception Area Route Alerting (Route H, I, Assignment 8)
a. MET: 1.a.1 3.a.1 5.a.3 1.d.1 3.b.1 i.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 2.5.6 Evacuation Assembly Center (Massaponax High School)
a. MET: 1.e.1 3.a.1 6.a.1 3.b.1 6.b.1 6.c.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None 41
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.5.7 School District (Spotsylvania County 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 42

3.0 INGESTION JURISDICTIONS 3.1 Virginia Jurisdictions 3.1.1 Caroline County (Risk)

a. MET: 1.c.1 3.e.1 5.b.1 1.d.1 3.e.2 1.e.1 3.f.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.2 Hanover County (Risk)
a. MET: 1.c.1 3.e.1 5.b.1 1.d.1 3.e.2 1.e.1 3.f.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.3 Louisa County (Risk)
a. MET: 1.c.1 3.e.1 5.b.1 1.d.1 3.e.2 1.e.1 3.f.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None 43
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.4 Orange County (Risk)
a. MET: 1.c.1 3.e.1 5.b.1 1.d.1 3.e.2 1.e.1 3.f.1
b. DEFICIENCY: None C. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.5 Spotsylvania County (Risk)
a. MET: 1.c.1 3.e.1 5.b.1 1.d.1 3.e.2 1.e.1 3.f.1
b. DEFICIENCY: None C. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.6 Albemarle County/Charlottesville
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 1.e.1 44
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.7 Amelia County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c. 1 1.d.1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.8 Buckingham County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.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 45

3.1.9 Chesterfield County

a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d. 1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.10 Culpeper County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c. 1 1.d. 1 i.e. 1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.11 Cumberland County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 i.e.r1
b. DEFICIENCY: None 46

C. AREAS REQUIRING CORRECTIVE ACTION: None

d. NOT DEMONSTRATED: None
e. rKIUK AK {AS - KLN:UL *VED: None
f. PRIOR ARCAs - UNRES OLVED: None 3.1.12 Essex County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.13 Fairfax County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.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 47

3.1.14 Fauquier County

a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.15 Fluvanna County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.16 Fredericksburg City
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c. 1 1.d. 1 i.e. 1
b. DEFICIENCY: None 48
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.17 Goochland County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.18 Greene County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.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 49

3.1.19 Henrico County

a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.20 King and Queen County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.21 King George County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 1.e.1
b. DEFICIENCY: None 50
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.22 King William County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 i.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.23 Madison County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c. 1 1.d. 1 i.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 51

3.1.24 Manassas City County

a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.25 New Kent County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c. 1 1.d. 1 i.e. 1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.26 Page County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 i.e. 1
b. DEFICIENCY: None 52
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.27 Powhatan County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.28 Prince William County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.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 53

3.1.29 Rappahannock County

a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.d.1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.30 Richmond County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c. 1 1.d.1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.31 Richmond City
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c. 1 1.d. 1 1.e. 1
b. DEFICIENCY: None 54
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.32 Rockingham County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c. 1 1.d. 1 1.e.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.1.33 Stafford County
a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c. 1

.1.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 55

3.1.34 Westmoreland County

a. MET: 1.a.1 3.e.1 5.b.1 1.b.1 3.e.2 1.c.1 1.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 56

APPENDIX 1:

Acronyms and Abbreviations A&N Alert and Notification ACP Access Control Point ARCA Area Requiring Corrective Action ATL Assistant Team Leader CFR Code of Federal Regulations COVRERP Commonwealth of Virginia Radiological Emergency Response Plan DRH Division of Radiological Health DRP Division of Radiation Protection EAL Emergency Action Level EAS Emergency Alerting System EBS Emergency Broadcast System ECL Emergency Classification Level EOC Emergency Operations Center EOF Emergency Operations Facility EPZ Emergency Planning Zone ERP Emergency Response Plan ES Elementary School ESF Emergency Support Function of the National Response Plan FDA Food and Drug Administration FEMA Federal Emergency Management Agency FMT Field Monitoring Team FR Federal Register FRERP Federal Radiological Emergency Response Plan HS High School I Ingestion ICF ICF International IPZ Ingestion Pathway Emergency Planning Zone JPIC Joint Public Information Center KI Potassium Iodide LEOF Local Emergency Operations Facility LOCA Loss of Coolant Accident 57

MS Middle School NAPS North Anna Power Station 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 P Plume PAD Protective Action Decision PAG Protective Action Guidance PAR Protective Action Recommendation PIO Public Information Officer PRD Permanent Record Dosimeter R Roentgen(s)

RAC Regional Assistance Committee Rem Roentgen Equivalent Man REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan REP Radiological Health Program R/hr Roentgens per hour SAE Site Area Emergency SEOC State Emergency Operations Center SRD Self-Reading Dosimeter TCP Traffic Control Point TEDE Total Effective Dose Equivalent TL Team Leader VDEM Virginia Department of Emergency Management VDOT Virginia Department of Transportation VEOC Virginia Emergency Operations Center 58

APPENDIX 2:

Exercise Evaluators and Team Leaders The following is a list of the personnel who evaluated the North Anna Power Station (NAPS) exercise on July 22-23, 2008 and out-of-sequence activities on June 9-11, 2008. Theletter P indicates plume exercise; I indicates ingestion exercise. Evaluator Team Leader (TL) and Assistant Team Leader (ATL) are indicated by the letters after their organization's name. The organization each evaluator represents is indicated by the following abbreviations:

DHS Department of Homeland Security FEMA Federal Emergency Management Agency ICF ICF International NRC U.S. Nuclear Regulatory Commission OBSERVERS-AT-LARGE NAME ORGANIZATION RAC Chairman Darrell Hammons DHS Project Officer Joseph Suders DHS ICF Regional Coordinator Roger Kowieski ICF

1. Biennial Plume Exercise - July 22, 2008 EVALUATION SITE EVALUATOR ORGANIZATION COMMONWEALTH OF VIRGINIA State Emergency Operations Center Bart Freeman (TL) DHS/FEMA Marcy Campbell (P & I) ICF Pat Taylor (P & I) ICF Ronald Biemacki (P & I) ICF Robert Trojanowski - NRC (Ingestion only) - Wednesday State Emergency Operations Center Ronald Biernacki ICF (DRP/RHP)

Melody Geer ICF JPIC @ Dominion-Innsbrook Technical Quirino Iannazzo ICF Center Joint Information Center Bruce Swiren ICF Emergency Operations Facility Robert Trojanowski NRC (DRHIVDEM)

State Field Monitoring Team 1 Paul Cormier ICF State Field Monitoring Team 2 Garianne Howard ICF Mobile Laboratory Reggie Rodgers ICF 59

M Biennial Plume Exercise - July 22, 2008 (cont.)

EVALUATION SITE EVALUATOR ORGANIZATION RISK JURISDICTIONS CAROLINECOUNTY Caroline County EOC Al Lookabaugh (TL) ICF Henry Christiansen (ATL) ICF Gary Goldberg ICF Staging Area & TCP/ACP Robert Nelson Young ICF Field Monitoring Team Richard Watts ICF Exception Area Route Alerting, Route A Charlie Zeppenfeld ICF (5-10 miles)

Back Up Route Alerting Gary Bolender ICF School District, Ladysmith Elementary Robert Nelson Young ICF HANOVER COUNTY Hanover County EOC John Price (TL) FEMA Paul Nied (ATL) ICF Kim Wood ICF Staging Area & TCP/ACP Alejandro Fernandez ICF Field Monitoring Team Kent Tosch ICF Exception Area Route Alerting (5-10 Tracey Green ICF miles)

Back-Up Route Alerting Bart Ray ICF School District - Liberty Middle School Alejandro Fernandez ICF LOUISA COUNTY Louisa County EOC Roy Smith (TL) ICF Wendy Swygert (ATL) ICF Nancy Johnson ICF Staging Area & TCP/ACP David Petta ICF Field Monitoring Team Earl Shollenberger ICF Primary Route Alerting (0-5 miles) Deborah Bell ICF Exception Area Route Alerting (5-10 Larry Visniesky ICF miles)

School District, Louisa County Middle David Petta ICF 60

1. Biennial Plume Exercise - July 22,2008 (cont.)

EVALUATION SITE EVALUATOR ORGANIZATION ORANGE COUNTY Orange County EOC James McClanahan (TL) ICF Lyle Slagle (ATL) ICF Robert Duggleby ICF Staging Area & TCP/ACP Todd Sniffin ICF Field Monitoring Team James Hickey ICF Exception Area Route Alerting (5-10 W. Morrison Jackson ICF miles)

Back-Up Route Alerting Deborah Blunt ICF School District, Lightfoot Elementary Todd Sniffin ICF SPOTSYLVANIA COUNTY Spotsylvania County EOC Wayne Shych (TL) DHS/FEMA Rosemary Samsel (ATL) ICF Jon Christiansen ICF Staging Area & TCP/ACP (Sheriff's Harold Spedding office) ICF Field Monitoring Team Bemis Hannah ICF Primary Route Alerting (0-5 miles) Frank Cordaro ICF Exception Area Route Alerting (5-10 Keith Eamshaw ICF miles) _

School District - Spotsylvania High Harold Spedding ICF School 61

2. Post Plume - July 22, 2008 P.M.

EVALUATION SITE EVALUATOR ORGANIZATION COMMONWEALTH OF VIRGINIA State Emergency Operations Center Bart Freeman DHS/FEMA Ronald Biemacki ICF Mobile Laboratory Reggie Rodgers ICF State Field Sampling Team 1 Paul Cormier ICF Post Plume - July 23, 2008 A.M.

EVALUATION SITE EVALUATOR ORGANIZATION COMMONWEALTH OF VIRGINIA State Emergency Operations Center Bart Freeman DHS/FEMA Marcy Campbell ICF Bob Trojanowski NRC Ronald Biemacki ICF Pat Taylor JCF Mobile Laboratory Reggie Rodgers ICF 62

3. Ingestion Jurisdictions -July 23, 2008 11:00 am EVALUATION SITE EVALUATOR ORGANIZATION Virginia Jurisdictions Nancy Johnson (TL) ICF Caroline County (Risk) Carl Wentzell ICF Hanover County (Risk) Robert Host ICF Louisa County (Risk) Robert Lemeshka ICF Orange County (Risk) David White ICF Spotsylvania County (Risk) Jim Torgler ICF Albemarle County/Charlottesville City Lenora Borchardt ICF Amelia County Michael Burriss ICF Buckingham County Terry Blackmon ICF Chesterfield County Robert Black ICF Culpeper County Greg Vanden-Eykel ICF Cumberland County David Stuhan ICF Essex County Gregg Dawkins ICF Fairfax County DeeEll Fifield ICF Fauquier County John Flynn ICF Fluvanna County James Foster ICF Fredericksburg City Jon Fox ICF Goochland County Robert Gantt ICF Greene County Simon Guereca ICF Henrico County Thomas Hegele ICF King and Queen County Doug Himle ICF King George County Daniel Inman ICF King William County Roger Jobe ICF Madison County Nick Lowe ICF Manassas City George MacDonald ICF New Kent County Richard McPeak ICF Page County Ronald Bonner ICF Powhatan' County William Obrien ICF Prince William County William Palmer ICF Rappahannock County Michael Petullo ICF Richmond County Glenn Kinnear ICF Richmond City Richard Smith ICF Rockingham County Denise Solomon ICF Stafford County Clark Cofer ICF Westmoreland County Alexis Kacho ICF
3. Ingestion Jurisdictions - July 23, 2008 11:00 am (cont.)

State of Maryland Charles Jurisdictions' County (Not to be evaluated) 63

4. Out-of-Sequence Exercises - June 9-11, 2008 CAROLINE COUNTY Evacuation Assembly Center - Caroline Wayne Shych DHS/FEMA County High School Bart Freeman HANOVER COUNTY Evacuation Assembly Center - Liberty Wayne Shych DHS/FEMA Middle School Bart Freeman SPOTSYLVANIA COUNTY Evacuation Assembly Center - Massaponax Wayne Shych DHS/FEMA Bart Freeman Medical Services - Transportation (Spotsylvania County Volunteer Rescue Bart Freeman DHS/FEMA Squad)

Medical Services - Hospital DHS/FEMA (Mary Washington Hospital) Wayne Shych 64

APPENDIX 3:

Exercise Evaluation Area Criteria and Extent of Play Agreement This appendix contains the extent of play agreement from the Commonwealth of Virginia approved by the Federal Emergency Management Agency (FEMA) Region III on July 14, 2008.

The exercise evaluation area criteria, contained in the "FEMA Radiological Emergency Preparedness Exercise Evaluation Methodology", 67 FR 20580, April 25, 2002, represent a Tunctional 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.

65

Exercise Evaluation Criteria and Extent of Play

1. EMERGENCY OPERATIONS MANAGEMENT l.a Mobilization Criterion 1.a.l: Offsite Response Organization's 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 Offsite Response Organization's 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 Offsite Response Organization's 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 Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

State:

The State will notify and mobilize appropriate response agencies noted below which have responsibilities in the Virginia Emergency Operations Center (VEOC), at the appropriate emergency classification level and in accordance with established plans and procedures in a timely manner. No other state agencies will be notified. Personnel assigned to the Local Emergency Operations Facility at North Anna Power Station (VDEM and DRH personnel), Joint Public Information Center (JPIC), Mobile laboratory at VDOT Residency Shop, Louisa County, and field monitoring teams will be pre-positioned. VDEM and DRH will provide staffing as per procedures.

The State will demonstrate the capability to receive notification of an emergency situation from the licensee and verify notification. The State will demonstrate the activation of facilities for immediate use by mobilized personnel when they arrive to begin emergency operations.

On the afternoon of July 22 through July 23, DRH will be interacting with the Federal Radiological Monitoring and Assessment Center (FRMAC). In addition, the mobile lab will be staffed.

On July 23, a representative from the Department of Agriculture and Consumer Services will be present at the VEOC and will be available to provide technical support to the public information function. DRH will be represented by the staff of DRH.

Risk Jurisdiction (Caroline,Hanover,Louisa, Orange and Spotsvlvania Counties):

Will notify and mobilize appropriate response agencies and key personnel assigned to the local Emergency Operations Centers (EOC's).and media centers, field workers and Evacuation 66

Assembly Centers, (out of sequence, June 9-10, 2008) if activated, at the appropriate Emergency Classification Level (ECL) and as per procedures in a timely manner.

Will demonstrate the capability to receive notification of an emergency situation from the licensee and verify notification: The risk jurisdictions will demonstrate the activation of facilities for immediate use by mobilized personnel when they arrive to begin emergency operations.

Ingestion Pathway Jurisdictions:

Albemarle County/ Fredericksburg City Powhatan County Charlottesville City Goochland County Prince William County Amelia County Greene County Rappahannock County Buckingham County Henrico County Richmond County Chesterfield County King and Queen County Richmond City Culpeper County King George County Rockingham County Cumberland County King William County Stafford County Essex County Madison County Westmoreland County.

Fairfax County Manassas City Fauquier County New Kent County State of Maryland (Charles Fluvanna County Page County County)*

On July 23, 11 a.m., risk and ingestion jurisdictions will mobilize the appropriate personnel (emergency services coordinator or deputy coordinator, a communication officer, health department representative, public information officer, and extension agent). The personnel will be pre-staged. Activities will consist of receiving and verifying calls from the VEOC and table top interviews.

Outstanding Issues:

41-06-l.a. 1-A-07: Spotsylvania County Field Monitoring Team. The Spotsylvania County Field Monitoring Team was not dispatched in a timely manner.

  • The State of Maryland (Charles County) requested and has been granted an exercise exemption.

1.b Facilities 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 Offsite Response Organization's 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 Offsite Response Organization's plans and procedures and be demonstrated as they would be used in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Ingestion Pathway Jurisdictions:

67

Albemarle County/ Fredericksburg City Powhatan County Charlottesville City Goochland County Prince William County Amelia County Greene County Rappahannock County Buckingham County Henrico County Richmond County Chesterfield County King and Queen County Richmond City Culpeper County King George County Rockingham County Cumberland County King William County Stafford County Essex County Madison County Westmoreland County Fairfax County Manassas City Fauquier County New Kent County State of Maryland (Charles Fluvanna County Page County County)*

Ingestion Jurisdictions: On July 23, 11 a.m., ingestion jurisdictions will demonstrate that-adequate space, supplies, equipment, plans and procedures will be used to the extent required to respond to the simulated emergency. The simulated emergency is not guaranteed to require use of every item described in the plans, only to exercise major portions.

,, Backup power capability will be reviewed only. The generators will not be operated.

Outstanding Issues:

None

  • The State of Maryland (Charles County) requested and has been granted an exercise exemption.

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

Extent of Play Leadership personnel should demonstrate the ability to carry out essential functions of the response effort, for example: keeping the staff informed through periodic briefings and/or other means, coordinating with other appropriate Offsite Response Organization's and ensuring completion of requirements and requests. All activities associated with direction and control must be performed based on the Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless otherwise noted above or indicated in the extent of play agreement.

VirginiaDepartmentof Emermencv Management VirginiaDepartmentof Health - Division of RadiologicalHealth On July 22, overall direction and control of state activities will be demonstrated in the VEOC, Local Emergency Operations Facility (LEOF) and Joint Public Information Center (JPIC). The Governor's representative or a simulated designee will be present and will simulate coordinating decisions with the Governor's Office. The State Coordinator or designee will demonstrate the ability to keep staff informed, hold briefings and coordinate activities with other offsite response 68

organizations. Both the State and risk jurisdictions should ensure the completion of requirements and requests. Demonstration will be in accordance with plans and procedures.

Risk Jurisdiction (Caroline,Hanover,Louisa, Orangeand Spotsylvania Counties):

The emergency services coordinator or designee will demonstrate his ability to keep staff informed, hold briefings, and coordinate activities with other offsite response organizations. Both the State and risk jurisdictions should ensure the completion of requirements and requests.

Demonstration will be in accordance with plans and procedures.

Ingestion Pathway Jurisdictions:

Albemarle County/ Fredericksburg City Powhatan County Charlottesville City Goochland County Prince William County Amelia County Greene County Rappahannock County Buckingham County Henrico County Richmond County Chesterfield County King and Queen County Richmond City Culpeper County King George County Rockingham County Cumberland County King William County Stafford County Essex County Madison County Westmoreland County Fairfax County Manassas City Fauquier County New Kent County State of Maryland (Charles Fluvanna County. Page County County)*

On July 23, 11 a.m., ingestion jurisdictions will demonstrate via tabletop interview the ability, to keep staff informed, hold briefings and coordinate activities with other offsite response organizations. Demonstration will be in accordance with plans and procedures.

  • The State of Maryland (Charles County) requested and has been granted an exercise exemption.

1.d Communications Equipment Criterion 1.d.l: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations.

(NUREG-0654, F.1, 2)

Extent of Play Responsible Offsite Response Organization's 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 Offsite Response Organization's 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. Offsite Response Organization's should ensure that a coordinated communication link for fixed and mobile medical support facilities exists. The specific communications capabilities of Offsite 69

Response Organization's should be commensurate with that specified in the response plan and/or procedures. Exercise scenarios could require the failure of a communications system and the use of an alternate system, as negotiated in the extent of play agreement. All activities associated with the management of communications capabilities must be demonstrated based on the Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless otherwise noted above or in the extent of play agreement.

Virginia Department of Emergency Management Virginia Departmentof Health - Division of RadioloeicalHealth Risk Jurisdiction (Caroline,Hanover, Louisa, Orange and Spotsvlvania Counties):

This evaluation area will be demonstrated in all participating locations, in accordance with plans and procedures. OROs will demonstrate that at least one communication system is functional.

Facility and field workers will have access to at least one communications system that is independent of commercial landline telephone. The use of primary communication pathways will be demonstrated during this exercise. A backup communication pathway will be demonstrated only if primary communication pathway fails.

Ingestion Pathway Jurisdictions:

Albemarle County/ Fredericksburg City Powhatan County Charlottesville City Goochland County Prince William County Amelia County Greene County Rappahannock County Buckingham County Henrico County Richmond County Chesterfield County King and Queen County Richmond City Culpeper County King George County Rockingham County Cumberland County King William County Stafford County Essex County Madison County Westmoreland County Fairfax County Manassas City Fauquier County New Kent County State of Maryland (Charles Fluvanna County Page County County)*

On July 23, 11 a.m., this evaluation area will be demonstrated by tabletop interview and during the exercise through documentation of messages sent and received.

  • The State of Maryland (Charles County) requested and has been granted an exercise exemption.

i.e Equipment and Supplies to Support Operation 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 Offsite Response Organization's plans and/or procedures in support of emergency operations. Use of maps and displays is encouraged. All instruments, should be inspected, inventoried, and operationally checked before each use. Instruments should be calibrated in accordance with the manufacturer's recommendations. Unmodified CDV-700 70

series instruments and other instruments without a manufacturer's recommendation should be calibrated annually. Modified CDV-700 instruments should be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration should be on each instrument or calibrated frequency can be verified by other means. Additionally, instruments being used to measure activity shouid have a range of readings sticker affixed to the side of the instrument. The above considerations should be included in the following criteria:

4.a. 1 for field team equipment, 4.c. 1 for radiological laboratory equipment (does not apply to analytical equipment), 6.a. 1 for reception center and emergency worker facilities' equipment and 6.d. 1 for ambulance and medical facility equipment. 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 Offsite Response Organization'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 Offsite Response Organization's 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 Emergency Planning Zone.

Available quantities of dosimetry and KI and their storage locations(s) will be confirmed by physical inspection at the 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 Offsite Response Organization's 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 have their availability described. All activities must be based on the Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

VirgainiaDepartment of Emergency Management Virginia Departmentof Health - Division of RadiologicalHealth Risk Jurisdiction (Caroline,Hanover, Louisa, Orange and Spotsylvania Counties):

Equipment within the facility 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 will be demonstrated.

Sufficient quantities of appropriate dosimetry should be available for issuance to all emergency workers.

Responsible ORO's should demonstrate the capability to maintain inventories of KI sufficient for use by emergency workers, as indicated on rosters.

71

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.

  • TCP/ACP maps (pagesfrom the plans may be used)
  • Population by protective action zone (pagesfrom the plans may be used)

Demonstration of the KI inventory rosters for the general public will occur in the local EOC's by Health Representatives.

Ingestion Pathway Jurisdictions:

Albemarle County/ Fredericksburg City Powhatan County Charlottesville City Goochland County Prince William County Amelia County Greene County Rappahannock County Buckingham County Henrico County Richmond County Chesterfield County King and Queen County Richmond City Culpeper County King George County Rockingham County Cumberland County King William County Stafford County Essex County Madison County Westmoreland County Fairfax County Manassas City Fauquier County New Kent County State of Maryland (Charles Fluvanna County Page County County)*

On July 23, 11 a.m. ingestion jurisdictions will be evaluated by out-of-sequence interview. Staff will discuss how equipment within the facility is sufficient and consistent with the role assigned to that facility in the ORO's plans and/or procedures in support of emergency operations. Maps and displays should be discussed.

Outstanding Issues: 41 .e. 1-A-0 1: State EOC. The modified administrative exposure limit (0.45 R reporting level) could not be read using the issued dosimetry.

  • The State of Maryland (Charles County) requested and has been granted an exercise exemption.
2. PROTECTIVE ACTION DECISION MAKING 2.a Emergency Worker Exposure Control Criterion 2.a.1: Offsite Response Organizations 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 Responsible Offsite Response Organization's authorized to send emergency workers into the plume exposure pathway Emergency Planning Zone should demonstrate a capability to meet the criterion based on their emergency plans and procedures. Responsible Offsite Response Organization's should demonstrate the capability to make decisions concerning the authorization of exposure levels in excess of preauthorized levels and to the number of emergency workers, 72

receiving radiation dose above pre-authorized levels. As appropriate, Offsite Response Organization's should demonstrate the capability to make decisions on the distribution and administration of KI as a protective measure, based on the Offsite Response Organization's plan and/or procedures or projected thyroid dose compared with the established Protective Action Guides (Protective Action Guides) for KI administration. All activities must be based on the Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Virginia Department of Emergency Managemen & Virginia Departmentof Radiological Health:

VDEM and DRH working in the EOF will rely on the facility's area monitor system and will not perform 30-minute dosimeter readings. If the area monitoring system fails or facility dose rates are shown to increase, dosimetry will be issued to facility personnel in accordance with Dominion Generation procedures, and Dominion Generation facility monitoring personnel will monitor exposure. State field monitoring teams and mobile lab workers will demonstrate emergency worker exposure control, as per procedures. As appropriate, DRH will demonstrate the capability to make decisions on the distribution and administration of KI, as a protective measure, based on the calculated thyroid dose resulting from a field sample exceeds the established protective action guides (PAGs) for KI administration.

Risk Jurisdiction (Caroline,Hanover, Louisa, Orange and Spotsvlvania Counties):

Risk Jurisdictions authorized to send emergency workers into the plume exposure pathway EPZ will demonstrate a capability to meet the criterion based on their emergency plans and procedures. As appropriate, risk jurisdictions will demonstrate the capability for 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. This distribution will occur only if the State Commissioner of Health or his designee orders the ingestion of KI by emergency workers. /

2.b Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency Criterion 2.b.l: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data, and licensee and Offsite Response Organization 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 Offsite Response Organization's should demonstrate the capability to use appropriate means, described in the plan and/or procedures, to develop protective action recommendations for decision-makers based on available information and recommendations from the licensee and field monitoring data, if available. When the licensee provides release and meteorological data, the Offsite Response Organization's also considers this data. The Offsite Response Organization's 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 Protective Action 73

Recommendations 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 Protective Action Guide to which they will be compared. Protective Action Recommendations 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 Offsite Response Organization's 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 Protective Action Recommendation if timely and appropriate. The Offsite Response Organization's should demonstrate the capability to use any additionaldata to refine projected doses and exposure rates and revise the associated Protective Action Recommendations. All activities must be based on the Offsite Response Organization's plans..

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

VirginiaDepartmentof RadiologicalHealth:

The initial Protective Action Recommendation (PAR) is based on plant conditions. Scenario driven doses may not exceed EPA PAGs, as the plant condition-based PAR will dictate the appropriate evacuation/sheltering recommendation.

Dose projections will be developed by the Division of Radiological Health at the LEOF to confirm or modify, as necessary, the PAR in effect. The protective action recommendation will be forwarded from the LEOF to the VEOC with any information necessary to support the recommendation.

Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions for the general public (including the recommendation for the use of KI, if Offsite Response Organization policy). (NUREG-0654, J.9; J.10.f, m)

Extent of Play Offsite Response Organizations should have the capability to make both initial and subsequent Protective Action Decisions. They should demonstrate the capability to make initial Protective Action Decisions in a timely manner appropriate to the situation, based on notification from the licensee, assessment of plant status and releases, and Protective Action Recommendations from the utility and Offsite Response Organization staff. The dose assessment personnel may provide additional Protective Action Recommendations 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 Offsite Response Organization's has determined that KI will be used as a protective measure for the general public under offsite plans, then the Offsite Response Organization's should demonstrate the capability to make decisions on the distribution and administration of KI as a protective .

measure for the general public to supplement sheltering and evacuation. This decision should be based on the Offsite Response Organization's plan and/or procedures or projected thyroid dose compared with the established Protective Action Guide for KI administration. The KI decision making process should involve close coordination with appropriate assessment and decision-making staff. If more than one Offsite Response Organization's is involved in decision-making, 74

Offsite Response Organizations should communicate and coordinate Protective Action Decisions with affected Offsite Response Organization's. Offsite Response Organization's should demonstrate the capability to communicate the contents of decisions to the affected jurisdictions.

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

Virginia Departmentof Emergency Management Virginia Department of Radiological Health:

Decisions to evacuate and shelter any portion of the affected population will be demonstrated by the VDEM State Coordinator or his representative in the VEOC. These decisions will be coordinated with risk jurisdictions. The State Commissioner of Health (or designee) will determine whether and when to authorize the administration of KI to emergency workers within the 10-mile EPZ.

2.c Protective Action Decisions for 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.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 Protective Action Guides, except for situations where there is a high-risk environment or where high-risk groups (e.g., the immobile or infirm) are involved. In these cases, examples of factors that should be considered are: weather conditions, shelter availability, availability of transportation assets, risk of evacuation vs. risk from the avoided dose, and precautionary school evacuations. In situations where an institutionalized population cannot be evacuated, the administration of KI should be considered by the Offsite Response Organization's. Applicable Offsite Response Organization's 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, Offsite Response Organization's and/or officials of public school systems/districts should demonstrate the capability to make prompt decisions on protective actions for students. Officials should demonstrate that the decision making process for protective actions considers (that is, either accepts automatically or gives heavy weight to) protective action recommendations made by Offsite Response Organization 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 (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 Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

75

Risk Jurisdiction (Caroline,Hanover,Louisa, Orange and Spotsvlvania Counties):

All risk jurisdictions will have a school representative and social services representatives available at their EOC. When dictated by events and according to procedures, officials will demonstrate what protective action decision they would make for schools located within the 10 mile EPZ, impact on students residing in the 10 mile EPZ, but attending schools outside the EPZ, and the impact on other special needs populations. EOC representatives will consider relevant factors, such as weather, shelter availability and time evacuation estimates when determining what protective actions to recommend for special populations. EOC representatives will also consider relevant factors such as the availability of transportation assets, risk ,ofevacuation vs.

risk from the avoided dose, precautionary school evacuation, and the administration of KI in situations where an institutionalized population cannot be evacuated.

2.d. Radiological Assessment and Decision-Making for the Ingestion Exposure Pathway Criterion 2.d.l: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made-based on the Offsite Response Organization planning criteria. (NUREG-0654, 1.8; J.11)

Extent of Play It is expected that the Offsite Response Organization 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 Offsite Response Organization's based on criteria related to the facility's emergency classification levels. Such actions may include recommendations to place milk animals on stored feed and to use protected water supplies. The Offsite Response Organization shoulduse its procedures (for example, development of a sampling plan) to assess the radiological consequences of a release on the food and water supplies. The Offsite Response Organization's 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, Offsite Response Organization's should consider the use of agricultural and watershed data within the 50-mile Emergency Planning Zone. The radiological impacts on the food and water should then be compared to the appropriate ingestion Protective Action Guides contained in the Offsite Response Organization's plan and/or procedures. The plan and/or procedures may contain Protective Action Guides 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 Offsite Response Organization decision-makers group for implementation decisions. As time permits, the Offsite Response Organization may also include a comparison of taking or not taking a given action on the resultant ingestion pathway dose commitments. The Offsite Response Organization 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 Offsite Response Organization's.

Offsite Response Organization's should use Federal resources, as identified in the Federal Radiological Emergency Response Plan, and other resources (e.g., compacts, nuclear insurers, etc), if available. Evaluation of this criterion will take into consideration the level of Federal and 76

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

Virginia Departmentof RadiologicalHealth:

DRH will complete their initial sampling plan at the conclusion of the plume phase of the exercise on July 22. The ingestion phase will be demonstrated at the VEOC by tabletop exercise.

Controller data will provide sample results to DRH on July 22. Additionally, the Aerial Monitoring Survey (AMS) results (controller inject) will be provided to DRH. Sample results will be provided to DRH via controller inject.

DRH will be prepared to provide their dose assessment results and protective action recommendations to VDEM. Protective action recommendations will be based on the EPA 400 guideline and will be provided for the following:

1 st year - 2 rem 2nd year - .5 rem 50 year- 5 rem On July 23, VDEM and local jurisdictions will coordinate and make protective action decisions based on the information provided to them. Protective action decision-making may involve all of the impacted jurisdictions and the State of Maryland.

2.e. Radiological Assessment and Decision-Making Concerning Relocation, Reentry, 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 Offsite Response Organization's plan and/or procedures. (NUREG-0654, A.l.b; 1.10; M.1)

Extent of Play Relocation: Offsite Response Organizations should demonstrate the capability to estimate integrated dose in contaminated areas and to compare these estimates with Protective Action Guides, 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 Protective Action Guides 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 Protective Action Guides. 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 Protective Action Guides and field samples of vegetation and soil analyses.

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

Examples of control procedures are: the assignment of, or checking for direct reading and non-direct-reading dosimetry for emergency workers; questions regarding the individual's objectives and locations expected to be visited and associated time frames; availability of maps and plots of 77

radiation exposure rates; advice on areas to avoid; and procedures for exit including; monitoring of individuals, vehicles, and equipment; decision criteria regarding decontamination and proper disposition of emergency worker dosimetry and maintenance of emergency worker radiation exposure records. Responsible Offsite Response Organizations should demonstrate the capability to develop a strategy for authorized re-entry of individuals into the restricted zone, based on established decision criteria. Offsite Response Organizations should demonstrate the capability to modify those policies for security purposes (e.g., police patrols), for maintenance of essential services (e.g., fire protection and utilities), and for other critical functions. They should demonstrate the capability to use decision making criteria in allowing access to the restricted zone by the public for various reasons, such as to maintain property (e.g., to care for farm animals or secure machinery for storage), or to retrieve important possessions. Coordinated policies for access and exposure control should be developed among all agencies with roles to perform in the restricted zone. Offsite Response Organizations should demonstrate the capability to establish policies for provision of dosimetry to all individuals allowed re-entry to the restricted zone. The extent that Offsite Response Organizations 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 Protective Action Guide. Other factors that the Offsite Response Organization 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 Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Virginia Departmentof Emergency Management:

Risk Jurisdiction(Caroline,Hanover, Louisa, Orange and Spotsvlvania Counties):

DRH will provide their dose assessment results and any additional protective action recommendations concerning relocation, re-entry, and return to VDEM at the VEOC. These protective action recommendations will be based on the projected dose for 1 year and will involve relocation, re-entry and/or return of the population within the 10-mile emergency planning zone (EPZ).

VDEM will make protective action decisions based on information provided by DRH. This protective action decision-making is a joint process and will involve the. impacted risk jurisdictions.

An evaluator will be present in each risk jurisdiction and the VEOC to observe the decision-making process between the VEOC and the risk jurisdictions by monitoring communications via 78

Instaphone. The implementation of the protective action decisions for relocation, re-entry and/or return will be conducted by evaluator interviews.

Outstanding Issues:

None

3. PROTECTIVE ACTION IMPLEMENTATION 3.a Implementation of Emergency Worker Exposure Control:

Criterion 3.a.l: The Offsite Response Organizations 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 Offsite Response Organizations 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 (pre-established at a level low enough to consider subsequent calculation of Total Effective Dose Equivalent) and maximum exposure limits (pre-established for those emergency workers involved in life saving activities) contained in the Offsite Response Organization's plans and procedures. Each emergency worker should have the basic knowledge of radiation exposure limits as specified in the Offsite Response Organization'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. Offsite Response Organizations 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 coworkers) in providing responses. Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission and adequate control of exposure can be maintained 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.

Individualswithout 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 79

radiological exposure commensurate with completing their missions. All activities must be based on the Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Virginia Department of Emergency Management Virginia Department of Radiological Health:

VDEM and DRH working in the LEOF will rely on the facility's area monitor system and will not perform 30-minute dosimeter readings. If the area monitoring system fails or facility dose rates are shown to increase, dosimetry will be issued to facility personnel in accordance with Dominion Generation procedures, and exposure will be monitored by Dominion Generation facility monitoring personnel. State field monitoring teams and mobile lab workers will demonstrate emergency worker exposure control, as per procedures.

Risk Jurisdiction (Caroline,Hanover,Louisa, Orange and Spots lvania Counties):

Appropriate emergency workers in the risk jurisdictions will demonstrate emergency worker, exposure control, as per procedures. Radiological Officers will be evaluated on their management (equipping and briefing) of field workers at the staging area location where field workers are equipped and briefed.

3.b Implementation of KI Decisions 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)

Extent of Play Offsite Response Organizations should demonstrate the capability to make KI available to emergency workers, institutionalized individuals, and, where provided for in the Offsite Response Organization plan and/or procedures, to members of the general public. Offsite Response Organizations 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 Offsite Response Organization health official is voluntary. For evaluation purposes, the actual ingestion of KI is not necessary. Offsite Response Organizations 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 Offsite Response Organization'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 Offsite Response Organization's plans and procedures and be 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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Virginia Departmentof RadiologicalHealth:

The State Commissioner of Health will determine whether and/or when to authorize the administration of KI to emergency workers.

Risk Jurisdiction (Caroline,Hanover,Louisa, Orange and Spotsvlvania Counties):

Risk jurisdictions will have a sufficient quantity of KI on hand in their EOC or at some other storage location or be capable of demonstrating its availability through written documentation (inventory sheets or letter). The KI intended for use will not exceed the expiration date.

Emergency workers, as appropriate, will receive KI according to their procedures and will be briefed or given information on its use. Included organizations will have the capacity to develop and maintain lists of emergency workers who have ingested KI, including documentations of the date(s) and time(s) they were instructed to ingest KI. Simulated KI can be used. Emergency workers will demonstrate through interview the basic knowledge of procedures for the use of KI whether or not the scenario drives the use of KI. Implementation of KI use by the general public will not be demonstrated.

Outstanding Issues:

41-06-3.b. 1-A-05: Orange County TCP/ACP. Although simulated potassium iodide (KI) was available at the Orange County staging area, it was not issued to emergency workers (including the field monitoring team) prior to their deployment to the field.

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, J.10.c,-d, g)

Extent of Play Applicable Offsite Response Organizations should demonstrate the capability to alert and notify (for example, provide protective action recommendations and emergency information and instructions) special populations (hospitals, nursing homes, correctional facilities, mobility impaired individuals, transportation dependent, etc.). Offsite Response Organizations should demonstrate the capability to provide for the needs of special populations in accordance with the Offsite Response Organization'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 Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Risk Jurisdiction (Caroline,Hanover,Louisa, Orangme and Spots lvania Counties):

Jurisdictions will demonstrate that a list of any special needs individuals within their portion of the 10-mile EPZ is maintained by Social Services. If resources are needed to assist these individuals for areas included in the Protective Action Decision, the availability of these resources will be verified (e.g., through discussion and presentation of transportation methods or providers, available vehicles, etc.). Contact with'any special needs individuals will be simulated.

Contact with the transportation providers will occur in the EOC with transportation' providers (e.g., rescue squad). All actual or simulated communications will be logged.

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Criterion 3.c.2: Offsite Response Organizations/School Officials implement protective actions for schools. (NUREG-0654, J.10.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. Implementation procedures for canceling the school day, dismissing early or sheltering should be simulated by describing those procedures to evaluators. 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

  • thebus driver's escort, if applicable) should be available to demonstrate knowledge of their role(s) in the school evacuation process. 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 info rmation to Offsite Response Organizations 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 Radiological Emergency Preparedness exercises pursuant to the Offsite Response Organization's plans and procedures as negotiated in the extent of play agreement. All activities must be based on the Offsite Response Organization's plans and procedures and be completed as they would inan actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Risk Jurisdiction(Caroline,Hanover, Louisa, Orange and Spotsvlvania Counties).

This evaluation area will be demonstrated during the exercise at the local EOC. An inject message will be provided to the school superintendent or designee to initiate the table-top interview. The superintendent or designee will discuss procedures and appropriate actions to be taken for school closing due to a radiological emergency at North Anna Power Station.. The' superintendent or designee will make notifications via telephone to school representatives, i.e.,

School principal, transportation director, etc. from the local EOC. The evaluator will have actual contact with the designated school and be given the opportunity to speak with the school principal or designee to affirm that the actions they take when notification is received are appropriate and in accordance with their procedure. The school superintendent or designee. will have the radiological plan available and show the pre-scripted EAC message regarding school children. In addition, the superintendent or designee will illustrate a letter to parents informing them of policies and procedures regarding early dismissal of children due to a radiological incident.

The following schools will be contacted:

u Caroline County - Ladysmith Elementary School Li Hanover County - Liberty Middle School Li Louisa County - Louisa County Middle School 82

u Orange County - Lightfoot Elementary School u Spotsylvania County - Spotsylvania County High School 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)

Extent of Play Offsite Response Organizations 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. Offsite Response Organizations 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 Offsite Response Organizations 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 Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

VirgainiaDepartmentof Emergencv Management:

The VEOC, driven by Protective Action Decisions will need to demonstrate the requesting of control of air, rail and waterways to the appropriate organizations. All communication will be, simulated and logged.

Risk Jurisdiction (Caroline,Hanover, Louisa, Orange and Spotsvlvania Counties):

Risk Jurisdictions, driven by the Protective Action Decision (PAD) to activate traffic control points and access control points will activate one traffic control point (TCP) and one access control point (ACP) simulated at the staging area. Both the TCP and the ACP will be established and held until evaluated. One unit (officer) will be provided to demonstrate thisevaluation area.

The personnel used to activate the TCP can also be the one to activate the ACP.

Risk jurisdictions will demonstrate the capability to provide instructions to traffic and access control staff on actions to take when modifications to protective action strategies necessitate change in evacuation patterns or in the area(s) where access is controlled.

The TCP/ACP officers will be knowledgeable of the following:

" Traffic Control

  • Access Control
  • Location of the EAC

" Dosimetry and exposure limits (reporting and turnback levels)

  • Required Protective Actions 83

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

Extent of Play Offsite Response Organizations 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 Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Risk Jurisdiction(Caroline,Hanover, Louisa, Orange and Spotsvlvania Counties):

Risk jurisdictions will demonstrate the capability and knowledge of procedures to identify and take appropriate actions concerning impediments to evacuation, as required by the scenario or controller inject messages. Actual dispatch of resources to deal with impediments, such as -

wreckers, will not be demonstrated; however, all contacts, actual or simulated will be logged.

3.e Implementation of Ingestion Pathway Decisions Criterion 3.e.l: The Offsite Response Organization 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)

Extent of Play Applicable Offsite Response Organizations 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 Emergency Planning Zone. Offsite Response Organizations should use Federal resources as identified in the Federal Radiological Emergency Response Plan, 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 Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Virginia Department of Emergency Management Virginia Departmentof Health - Division of RadiologicalHealth DRH will report their protective action recommendations to VDEM regarding ingestion pathway decisions. VDEM will demonstrate the capability to obtain copies of ingestion information in a timely manner. VDEM will notify the risk jurisdictions of the protective action decisions via instaphone. VDEM will notify the host and ingestion jurisdictions via Virginia Criminal Information Network (VC1N) or fax.

Risk Jurisdiction(Caroline,Hanover, Louisa, Orange and Spotsvlvania Counties):

The local risk jurisdictions will demonstrate the capability to obtain copies of ingestion information in a timely manner and demonstrate their knowledge of the appropriate use of the 84

information of ingestion pathway planning for the implementation of protective actions. The emergency services coordinator, health department and the extension agent will demonstrate that all water sources, dairies, and agricultural production sources within the ingestion pathway planning zone are identified and know how to utilize the information and materials to implement ingestion pathway decisions according to their plan and procedures.

Ingestion Pathway Jurisdictions:

Albemarle County/ Fredericksburg City Powhatan County Charlottesville City Goochland County Prince William County Amelia County Greene County Rappahannock County Buckingham County Henrico County Richmond County Chesterfield County King and Queen County Richmond City Culpeper County King George County Rockingham County Cumberland County King William County Stafford County Essex County Madison County Westmoreland County Fairfax County Manassas City Fauquier County New Kent County State of Maryland (Charles Fluvanna County Page County County)*

On July 23, ingestion jurisdictions will receive information via VCIN and confirm receipt of information via VCIN or fax. No further actions will be taken or evaluated.

  • The State of Maryland (Charles County) requested and has been granted an exercise exemption.

3.e Implementation of Ingestion Pathway Decisions Criterion 3.e.2: Appropriate measures, strategies, and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk, and agricultural production. (NUREG-0654, E.5, 7; J.9, 11)

Extent of Play Development of measures and strategies for implementation of ingestion pathway zone 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 predetermined individuals and businesses. Offsite Response Organizations 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 Ingestion Pathway Zone should be demonstrated, but actual communications with food producers and processors may be simulated. All activities must be based on the Offsite Response Organization's plans and procedures and be 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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Virgainia Departmentof Emergency Management On July 23, the State Public Affairs Officer at the VEOC will demonstrate that pre-printed instructional materials are available and strategies are developed to implement ingestion pathway decisions by drafting and distributing appropriate news release in a timely manner. No public inquiry calls or media briefings will occur on July 23.

Risk Jurisdiction (Caroline,Hanover,Louisa, Orange and Spotsvlvania Counties):

On July 23, at 11 a.m., the Emergency Services Coordinator or designee, the public information officer (PIO) and the extension agent will demonstrate that pre-printed instructional materials are available and strategies are developed to implement ingestion pathway decisions. No public inquiry calls or media briefing will occur on July 23. All actions will be demonstrated in accordance to the plan and procedures.

Ingestion Pathway Jurisdictions:

Albemarle County/ Fredericksburg City Powhatan County Charlottesville City Goochland County Prince William County Amelia County Greene County Rappahannock County Buckingham County Henrico County Richmond County Chesterfield County King and Queen County Richmond City Culpeper County King George County Rockingham County Cumberland County King William County Stafford County Essex County Madison County Westmoreland County Fairfax County Manassas City Fauquier County New Kent County State of Maryland (Charles Fluvanna County Page County County)*

On July 23, at 11 a.m., the Emergency Services Coordinator or designee, the public information officer (PIO) and the extension agent will demonstrate that pre-printed instructional materials are available and strategies are developed to implement ingestion pathway decisions. No public inquiry calls or media briefing will occur on July 23. All actions will be demonstrated in accordance to the plan and procedures.

  • The State of Maryland (Charles County) requested and has been granted an exercise exemption.

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.)

Extent of Play Relocation: Offsite Response Organizations 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 Protective Action Guides. Offsite Response Organizations 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 Protective Action-Guides. Areas of consideration should 86

include the capability to communicate with Offsite Response Organizations 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. Offsite Response Organizations should also demonstrate the capability to communicate instructions to the public regarding relocation decisions.

Re-entry: Offsite Response Organizations should demonstrate the capability to control re-entry and exit of individuals who need to temporarily re-enter the restricted area, to protect them from unnecessary radiation exposure and for exit of vehicles and other equipment to control the spread of contamination outside the restricted area. Monitoring and decontamination facilities will be established as appropriate. Examples of control procedure subjects are: (1) the assignment of, or checking for, direct-reading and non-direct-reading dosimetry for emergency workers; (2) questions regarding the individuals' objectives and locations expected to be visited and associated timeframes; (3) maps and plots of radiation exposure rates; (4) advice on areas to avoid and procedures for exit, including monitoring of individuals, vehicles and equipment, decision criteria regarding contamination, proper disposition of emergency worker dosimetry and maintenance of emergency worker radiation exposure records.

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

Offsite Response Organizations 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 and schools and intermediate term housing for relocated persons.

Communications among Offsite Response Organizations 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. Offsite Response Organizations should use Federal resources as identified in the Federal Radiological Emergency Response Plan, 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 Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Virginia Department of Emergency Management VDEM will make protective action decisions based on information provided by DRH. This protective action decision-making is a joint process and will involve the impacted risk jurisdictions.

.Risk Jurisdiction (Caroline,Hanover, Louisa, Orangeand Spots lvania Counties):

On July 23, an evaluator will observe the decision-making process between the VEOC and the local risk jurisdictions by monitoring communications via instaphone. The implementation of the protective action decisions for relocation, re-entry and/or return will be conducted by evaluator interviews. All decisions will be in accordance with plans and procedures.

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4. FIELD MEUREMENT AND ANALYSIS 4.a Plume Phase Field Measurements and Analysis 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; 1.7, 8, 9)

Extent of Play Field teams should be equipped with all instrumentation and supplies necessary to accomplish their mission. This should include instruments capable'of measuring gamma exposure rates and detecting the presence of beta radiation. These instruments should be capable of measuring a range of activity and exposure, including radiological protection/exposure control of team members and detection of activity on the air sample collection media, consistent with the intended use of the instrument and the Offsite Response Organization'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 Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Virginia Departmentof Health, Division of RadiologicalHealth Two State Field Monitoring Teams (FMTs), consisting of at least two individuals perteam, will be staged at the Louisa County and Post Oak VDOT Residency Shops. The team will be briefed and equipped with the appropriate field monitoring instruments and the team will check the equipment for operability before deployment into the field.

Risk Jurisdiction(Caroline,Hanover,Louisa, Orange and Spotsvlvania Counties):

Each jurisdiction will deploy one FMT, consisting of at least two individuals per team, from the staging area within their jurisdiction.

The Radiological Officer will provide a briefing, survey meters and appropriate forms to field monitors.

The field monitors will perform an operational check on the meters before being deployed into the field.

If an instrument is found to be broken or working incorrectly, the radiological officer will take appropriate actions according to plans and procedures.

Outstanding Issues:

41-06-4.a. 1-A-03: Caroline County Field Monitoring Team. The Ludlum 2240 Survey Meter probe was not wrapped in a probe cover before leaving the staging area.

41-06-4.a. l-A-06: Orange County Field Monitoring Team. The Ludlum 2240 Survey Meter probe was not wrapped in a probe cover before leaving the staging area.

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Criterion 4.a.2: Field teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654, H.12; 1.8, 11; J.10.a)

Extent of Play Responsible Offsite Response Organizations should demonstrate the capability to brief teams on predicted plume location and direction, travel speed, and exposure control procedures before deployment. Field measurements are needed to help characterize the release and to support the adequacy of implemented protective actions or to be a factor in modifying protective actions.

Teams should be directed to take measurements in such locations, at such times to provide information sufficient to characterize the plume and impacts. If the responsibility to obtain peak measurements in the plume has been accepted by licensee field monitoring teams, with concurrence from Offsite Response Organizations, there is no requirement for these measurements to be repeated by State and local monitoring teams. If the licensee teams do not obtain peak measurements in the plume, it is the Offsite Response Organization'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 Offsite Response Organization) is essential. Coordination concerning transfer of samples, including a chain-of-custody form, to a radiological laboratory should be demonstrated. Offsite Response Organizations should use Federal resources as identified in the Federal Radiological Emergency Response Plan, and other resources (for example, compacts, utility, etc.), if available.

Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise. All activities must be based on the Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play-agreement.

VirginiaDepartment of Health, Division of RadiologicalHealth Two State Field Monitoring Teams (FMTs), consisting of at least two individuals per team, will be staged at the Louisa County and Post Oak VDOT Residency Shop. Each team will communicate results, as necessary, to the DRH representative at the LEOF. It should be noted that the overall monitoring effort is coordinated by DRH from the LEOF.

Risk Jurisdiction(Caroline,Hanover, Louisa, Orange and Spotsvlvania Counties):

Each jurisdiction will deploy one FMT (at least two individuals per team)-from the staging area within their jurisdiction. The Radiological Officer will provide a briefing, survey meters and appropriate forms to field monitors. The field monitoring team will be in contact with the Radiological Officer (RO). The field teams will report field readings to the RO who will then forward the appropriate information to DRH at the LEOF. In addition, the RO will be responsible to inform the field teams, in a timely manner, all relevant information, including weather conditions, changes in wind direction, and all protective action decisions.

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 89

the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654, I. 9)

Extent of Play Field teams should demonstrate the capability to report measurements and field data pertaining to the measurement of airborne radioiodine and particulates and ambient radiation to the field team coordinator, dose assessment, or other appropriate. authority. If samples have radioactivity.

significantly above background, the appropriate authority should consider the need for expedited laboratory analyses of these samples. Offsite Response Organizations should share data in a timely manner with all appropriate Offsite Response Organizations. 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 Offsite Response Organization's plan and/or procedures. Offsite Response Organizations should use Federal resources as identified in the Federal Radiological Emergency Response Plan, and other resources (for example, compacts, utility, etc.), if available. Evaluation of this criterion will take into consideration the level of both Federal and other resources participating in the exercise. All activities must be must be based on the Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in,.the extent of play agreement.

Virginia Department of Health, Division of RadiologicalHealth Two State Field Monitoring Teams (FMTs), consisting of at least two individuals per team, will be staged at the Louisa County and Post Oak VDOT Residency Shops.

Each team will take measurements at a minimum of two locations and will operate according to procedures. A minimum of six total sets of readings will be taken per team (for example, each team may visit two locations and take three sets of readings per location, or another combination may be used).

The field teams will demonstrate the capability to determine the location of the plume. Each team will communicate results, as necessary, to the DRH representative at the LEOF. It should be noted that the overall monitoring effort is coordinated by DRH from the LEOF. Controllers will provide data to the field teams.

Each State field monitoring team will demonstrate the collection of at least one air sample in the field. A second air sample may be taken if needed. At least one sample will be taken to the mobile laboratory for gamma spectral analysis. Chain of Custody procedures shall be demonstrated.

Laboratory operations will not be demonstrated for the sample at the mobile laboratory.

Appropriate sample analysis information will be forwarded to DRH at the LEOF.

Risk Jurisdiction(Caroline,Hanover, Louisa, Orange and Spotsvlvania Counties):

Each jurisdiction will deploy one FMT, consisting of at least two individuals per team, to a minimum of two monitoring points located within their jurisdiction. Teams will take measurements and operate according to their procedures. The monitoring results will be reported 90

to their EOC, which will then be forward the appropriate information DRH at the LEOF. The controllers will have the necessary data to provide radiation levels to these teams.

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)

Extent of Play The Offsite Response Organization's field teams should demonstrate the capability to take measurements and samples, at such times and locations as directed, to enable an adequate assessment of the ingestion pathway and to support re-entry, relocation, and return decisions.

When resources are available, the use of aerial surveys and in-situ gamma measurement is appropriate. All methodology, including contamination control, instrumentation, preparation of samples, and chain of custody form for transfer to a laboratory, will be in accordance with the Offsite Response Organization'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. Offsite Response Organizations should use Federal resources as identified in the Federal Radiological Emergency Response Plan, 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 Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Virginia Department of Health, Division of RadiologicalHealth Department of Agriculture and Consumer Services Office of Water Engineering The State environmental sampling teams will be comprised of the State agencies listed above will demonstrate post-emergency sampling on the afternoon of July 22. A minimum of two State environmental sampling teams will be established. The two teams will take a total of 4 samples.

These samples will be one of narrow leaf vegetation, surface water, and soil. The locations where these samples will be taken will be included as a controller inject. Note that these pre-selected sample, points are not necessarily points, which will be selected as part of Division of Radiological Health's dose assessment process.

The appropriate procedures will be followed for this demonstration. Each sample will be transported to the Mobile Laboratory for analysis.

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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; J.11)

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 (for example, milk), and keeping track of sample identity. In addition, the laboratory staff should demonstrate the capability to prepare samples for conducting measurements. The laboratory should be appropriately equipped to provide analyses of media, as requested, on a timely basis, of sufficient quality and sensitivity to support assessments and decisions as anticipated by the Offsite Response Organization's plans and procedures. The laboratory (laboratories) 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 (for example, transuranics or as a result of a terrorist event) or if warranted by circumstances of the event. Analysis may require resources beyond those of the Offsite Response Organization. The laboratory staff should be qualified in radioanalytical techniques and contamination control procedures. Offsite Response Organizations should use Federal resources as identified in the Federal Radiological Emergency Response Plan, and other resources (for example, compacts, utility, nuclear insurers, etc.), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise. All activities must be based on the Offsite Response Organization's plans and procedures and.be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

VirginiaDepartmentof Health, Division of RadiologicalHealth Laboratory operations will be demonstrated for the sample at the mobile laboratory. Appropriate sample analysis information will be forwarded to the Radiological Health Programs representative in the LEOF.

5. EMERGENCY NOTIFICATION AND PUBLIC INFORMATION 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 Federal Emergency Management Agency Radiological Emergency Preparedness guidance. (10 CFR Part 50, Appendix E.IV.D and NUREG-0654, E.5, 6, 7)

Extent of Play Responsible Offsite Response Organizations 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 Emergency Planning Zone.

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Following the decision to activate the alert and notification system, in accordance with the Offsite Response Organization'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 Federal Emergency Management Agency Radiological Emergency Preparedness guidance.

Offsite Response Organizations with route alerting as the primary method of alerting and notifying the public should demonstrate the capability to accomplish the primary route alerting, following the decision to activate the alert and notification system, in a timely manner (will not be subject to specific time requirements) in accordance with the Offsite Response Organization's plan and/or procedures. At least one route needs to be demonstrated and evaluated. The selected route(s) should vary from exercise to exercise. However, the most difficult route should be demonstrated at least once every six years. All alert and notification activities along the route should be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast) as agreed upon in the extent of play. Actual testing of the, mobile public address system will be conducted at an agreed upon location. The initial message should include the elements required by current Federal Emergency Management Agency Radiological Emergency Preparedness guidance. For exercise purposes, timely is defined as "the responsible Offsite Response Organization personnel or representatives demonstrate actions to disseminate the appropriate information or 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. 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 Offsite Response Organization's plans and procedures and be.

completed as they would be in an actual emergency,. except as noted above or otherwise indicated in the extent of play agreement.

Virginia Department of Emergency Management Risk Jurisdictions: Louisa County and Spotsylvania County Coordination will occur between the VEOC and the affected counties with respect to the Alert and Notification System (ANS) process. Louisa County and Spotsylvania County have the control equipment for activation of sirens. Sirens will be coordinated and the sounding simulated at the appropriate time with the simulated activation of EAS taking place approximately 3 minutes following the simulated activation of the sirens. The VEOC is the initiating. point for the activation of the EAS. Regular Broadcasting will not be interrupted on the EAS Stations.

Broadcast of the message(s) or test message(s) is NOT required and NOT requested. 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. Each risk county will 93

demonstrate, by interview, route alerting of the hearing impaired residents within their jurisdiction. Hearing impaired notification teams will not be deployed.

Louisa and Spotsylvania Counties will conduct primary route alerting for exception areas located within 0-5 miles from North Anna Power Station. The designated route should be completed in a timely manner following the decision to alert and notify the public.

Each risk county will demonstrate, by interview, route alerting of the hearing impaired re'sidents within their jurisdiction. Hearing impaired notification teams will not be deployed.

Criterion 5.a.3: Activities associated with Federal Emergency Management Agency 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 Offsite Response Organization 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 with Federal Emergency Management Agency 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 Offsite Response Organizations 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 an agreed upon location.

Backup alert and notification of the public should be completed within 45 minutes following the detection by the Offsite Response Organization of a failure of the primary alert and notification system. Backup route alerting only needs to be demonstrated and evaluated, in accordance with the Offsite Response Organization'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 an agreed upon location. All activities for this criterion must be based on the Offsite Response Organization's plans and procedures and be completed as they 94

would be in an actual emergency, except as noted above or otherwise indicated in the extent of play agreement.

Risk Jurisdictions:

Caroline, Hanover, Louisa, Spotsylvania and Orange Counties Will conduct route alerting for exception areas located within 5-10 miles from North Anna Power Station. The designated route should be completed within 45 minutes of the decision to alert and notify the public.

Caroline, Hanover, and Orange Counties will conduct backup route alerting for a failed siren.

The designated route should be completed within 45 minutes following the detection by the offsite response organization of the siren failure.

5.b Emergency Information and Instructions for the Public and the Media Criterion 5.b.l: Offsite Response Organizations 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 and will not be subject to specific time requirements. For exercise purposes, timely is defined as "the responsible Offsite Response Organization personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay." If message dissemination is 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 Offsite Response Organization should ensure that emergency information and instructions are consistent with protective action decisions made by appropriate officials. The emergency information should contain all necessary and applicable instructions (for example, evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, information concerning pets, shelter-in-place instructions, information concerning protective actions for schools and special populations, public inquiry telephone number, etc.) to assist the public in carrying out protective action decisions provided to them. The Offsite Response Organization should also be prepared to disclose and explain the Emergency Classification Level of the incident. At a minimum, this information must be included in media briefings and/or media releases. Offsite Response Organizations should demonstrate the capability to use language that is clear and understandable to the public within both the plume and ingestion pathway Emergency Planning Zones. 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 Offsite Response Organizations 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 Offsite Response Organizations should demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plan and/or procedures. Offsite Response Organizations should demonstrate the capability to develop emergency information in languages other than English when required by the plan and/or procedures. If ingestion pathway measures 95

are exercised, Offsite Response Organizations should demonstrate that a system exists for rapid dissemination of ingestion pathway information to pre-determined individuals and businesses in accordance with the Offsite Response Organization's plan and/or procedures. Offsite Response Organizations 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 Offsite Response Organizations should demonstrate the capability to respond appropriately to inquiries from the news media. All information presented in media briefings and media releases should be consistent with protective action decisions and other emergency information provided to the public. Copies of pertinent emergency information (for example, Emergency Alert System messages and media releases) and media information kits should be available for dissemination to the media. Offsite Response Organizations 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 Offsite Response Organization's plans and procedures and be completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Virginia Departmentof Emergfency Management This evaluation area will be demonstrated at the JPIC on July 22. A VDEM Public Affairs Officer will prepare news releases. The news releases will be coordinated and exchanged with local jurisdictions. Dissemination of news releases may be accomplished by the use of fax or other means. One simulated media briefing will be demonstrated at the JPIC.

VDEM will establish a public inquiry function at the JPIC with a minimum of two individuals.

Some calls will be designed so as to allow public inquiry staff to demonstrate the capability to identify trends in rumors (e.g., frequently expressed false or misleading information). The hotline staff will demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate source. Information from the hotline staff, including information that correct false, or inaccurate information when trends are noted will be included as appropriate in emergency information provided to the public, media briefings and/or media releases.. Public inquiry telephone number(s) will be designated and published during the Alert Emergency Classification Level (ECL). Public information staff will simulate monitoring EAS broadcasts to determine whether false or misleading information is being disseminated to the public. Media monitoring equipment will be available. Since no actual exercise related broadcasts will be made, the media monitoring equipment will be tested for operability and the staff will be demonstrate their capability to monitor area EAS stations. All subsequent emergency information and instruction will be provided to the public and the media in a timely manner. All emergency information and instructions are consistent with protective action decisions made by appropriate officials. The emergency information will contain all necessary and applicable instructions (e.g. evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, information concern pets, shelter in place, information concerning protective action for schools and special populations, public inquiry telephone numbers, etc. The 96

State will demonstrate the capability to use familiar landmarks and boundaries to describe protective action areas. The.emergency information will be all-inclusive by including previously identified protective actions areas that are still valid as well as new areas. The State will demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. The State will demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals.

Risk Jurisdiction(Caroline,Hanover, Louisa, Orange and Spotsvlvania Counties):

On July 22, each jurisdiction will demonstrate this evaluation area. One simulated media briefing will be demonstrated. Each risk jurisdiction will establish a public inquiry phone line and will respond to calls. Some calls will be designed so as to allow public inquiry staff to demonstrate the capability to identify trends in rumors (e.g., frequently expressed false or misleading information). The public inquiry staff will demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate source. Information from the hotline staff, including information that correct false, or inaccurate information when trends are noted will be included as appropriate in emergency information provided to the public, media briefings and/or media releases. Public inquiry number(s) will be designated and published according to each jurisdiction's procedures. Since no actual exercise related broadcasts will be made, the media monitoring equipment will be tested for operability and demonstration of reception on local EAS stations, however, continued monitoring will not be demonstrated.

All subsequent emergency information and instruction will be provided to the public and the media in a timely manner. All emergency information and instructions are consistent with protective action decisions made by appropriate officials. The emergency information will contain all necessary and applicable instructions (e.g. evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, information concern pets, shelter in place, information concerning protective action for schools and special populations, public inquiry telephone numbers, etc. The risk jurisdictions will demonstrate the capability to use familiar landmarks and boundaries to describe protective action areas. The emergency information will be all-inclusive by including previously identified protective actions areas that are still valid as well as new areas. The risk jurisdictions will demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. The risk jurisdictions will demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals.

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Ingestion Pathway Jurisdictions:

Albemarle County/ Fredericksburg City Powhatan County Charlottesville City Goochland County Prince William County Amelia County Greene County Rappahannock County Buckingham County Henrico County Richmond County Chesterfield County King and Queen County Richmond City -

Culpeper County King George County Rockingham County Cumberland County King William County Stafford County Essex County Madison County Westmoreland County Fairfax County Manassas City Fauquier County New Kent County State of Maryland (Charles Fluvanna County Page County County)*

Ingestion Jurisdictions: On July 23 at 11 a.m., each ingestion jurisdiction will demonstrate this evaluation area through discussion with the evaluator.

  • The State of Maryland (Charles County) requested and has been granted an exercise exemption.

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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 North Anna Power Station (NAPS) exercise on July 22, 2008 The exercise scenario was submitted by the Commonwealth of Virginia. The scenario was approved by the Federal Emergency Management Agency (FEMA) Region III on July 7, 2008.

The summary presented in this appendix is a compilation of exercise scenario materials submitted by the Commonwealth of Virginia and Dominion Generation. Events at the plant site been omitted.

that are not pertinent to the ORO response have 99

North Anna 2008 - Plume Scenario 0800 Exercise begins 0804 "Loose Parts" alarm received; letdown radiation ALERT conditions (Tab C-8) monitor begins to increase due to fuel damage exists at 0808 0916 Charging pump trips; letdown isolates; letdown isolation valve fails closed at 0932.

0956 Electrical fault on emergency bus; diesel generator SITE AREA EMERGENCY starts, but does not load; other charging pump not conditions (Tab A-i) exist available 1053 Small break loss of coolant accident (LOCA) GENERAL EMERGENCY causes safety injection to actuate; reactor coolant conditions (Tab C-I and pump fails to secure - operator dispatched; pump potentially Tab C-5) exist IF secured after high head safety injection flow charging pump not returned to established, service.

PAR: evacuate 0 - 2 miles, 3600 (Louisa & Spotsylvania Counties); 2 --.5 miles in sectors H, J, K (Louisa County) 1113 Degrade to large break LOCA. Containment depressurization signal will be actuated. "B train" recirculation spray pumps start and then immediately trip/fail; "A train" unavailable due to loss of emergency bus (at 0956). No containment or recirculation spray available to depressurize the containment structure after the LOCA.

1117 Weld leak occurs on the containment hogger drain GENERAL EMERGENCY, line outside of containment. The inside conditions (Tab B-1) exists if containment isolation valve for this flow path not declared earlier.

(although indicating fully closed) is partially open PAR: evacuate 0 - 2 miles,

- release path to the environment through the main 3600 (Louisa & Spotsylvania.

stack. Counties); 2-'- 5 miles in sectors H, J, K (Louisa County).

Insufficient radioiodine in plume for KI use to be recommended.

1330 Plume Exercise terminated.

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APPENDIX 5:

Planning Issues This appendix contains the Planning Issues assessed during the July 22-23, 2008, exercise at North Anna Power Station (NAPS) 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 State Emergency Operations Center Issue No.: 41-08-2.a.1-P-01 Condition: Changes were made to the Radiological Exposure Control Appendix of the Virginia Emergency Operations Plan (Appendix 7, dated 05/08) that are consistent with the EPA graduated dose limit system for emergency workers; however, the changes have not been carried throughout the Commonwealth's and counties' plans.

The EPA dose limits are incorrectly stated in the Commonwealth of Virginia Radiological .Emergency Response Plan (COVRERP), Appendix 7, Tab B2, table at top of page. The correct limits are 5, 10, 25, and >25 rem.

The Commonwealth has replaced the 0 - 20 R self-reading dosimeters with, electronic dosimeters; however, references to the old dosimeters are stillincluded throughout the Commonwealth's and counties' plans.

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The trigger level for the use of potassium iodide (KI) by emergency workers was changed to 5 Rem in the Health Department's Appendix (8 of COVRERP);

however, in many of the tables throughout both the Commonwealth and Division of Radiological Health plans, it is still given as "25 Rem."

The units for the Total Effective Dose Equivalent (TEDE), Rem, and for the Self-Reading Dosimeter (SRD), Roentgen (R), are used interchangeably and incorrectly in many places.

The following list is for example only and is not an exhaustive list:

COVRERP (05/08 version):

Tab B2 toAppendix 7 correctly lists the "Emergency Worker Exposure Limits" of Self-Reading Dosimeter (SRD) readings of 1.5 R (reporting),

2.5 R (tumback), 12.5 R (lifesaving), and >12.5 R (Voluntary Lifesaving);

it would be helpful to include that the assumed initial ratio is "2." Tab C and Tab E refer to the 0 - 20 R dosimeter. Tab G lists the old limits of 3 R, 5 R, 8 R, and >8 R and references the use of a 0 - 20 R dosimeter.

Appendix 8 details information about Potassium Iodide (KI)

Administration and states, on page 8-5 that KI may be recommended for use by the general public and emergency workers when a dose assessment predicts a thyroid exposure threshold of 5 rem or if an actual measurement of 5 rem is obtained offsite; the age group for the calculation is not detailed. However, on page 8-7 (Tab A to Appendix 8), the administration of KI for emergency workers is given as 25 rem in Table 2. There is also an error in the first table since the predicted thyroid exposure threshold should be 5 rem for all age groups, but information is not included on how this calculation is performed.

" VDH/DRH Emergency Response Manual (1/30/08 version):

Appendix 6, Radiological Exposure Control, lists the correct emergency worker limits in step 2.1, but then refers to the old limits in step 2.4 (and also incorrectly states that the limits are in "R TEDE" instead of "R"; a TEDE is Rem only). A footnote in step 2.1 incorrectly states that "Federal Guideline is 25 rem for emergency workers [to ingest KI]..." The guidance provided by EPA stated that KI should be used by emergency workers where atmospheric releases include radioiodine without a dose threshold. In Appendices 17.2 and 17.4, the reporting level, turnback level, etc. are listed in units of "rem" instead of "R" in multiple places (pages 17.2-5, 17.2-9, 17.2-11, 17.4-2, 17.4-3, 17.4-5, etc.).

" Risk County RERPs (either 10/06 version for Caroline County or 05/08 for all other counties):.

In the Basic Plan,Section V.D. Situation, Protection Against the Hazard, incorrectly gives the dose thresholds in terms of "R" instead of "rem." In Section VIII.B.F.2, Concept of Operations, Accident Assessment, Exposure Limits, Emergency Workers, the Exposure Control Ratio is 102

given as "3" instead of "2;" for all but Caroline County, the administrative limits are given correctly but have a note that "minors and the unborn are limited to one-tenth of these values;" however, minors and pregnant women should not be used as emergency workers.

In the Public Health ESF, the KI limit is correct, but the emergency worker exposure control levels are incorrect.

Possible Cause: Incomplete search and change done during procedure changes.

References:

NUREG-0654, J.10.f; K.4 All State and local plans/procedures.

Effect: The incorrect dose limits or administrative exposure levels could be used resulting in excess exposures being received by emergency workers.

Recommendation: Review every page of the plans and procedures to ensure that all instances of the administrative limits (including the trigger level for the use of KI) are correctly updated. Ensure that the correct units are used throughout the plans: "R" for the dosimeter readings (exposure limits) and "Rem" for the dose limits.. All references to "0 - 20 R SRD" should be changed to "electronic.

dosimeter" or "pocket dosimeter" or just "self-reading dosimeter."

State Response: The VDH/DRH Emergency Response Manual plan corrections have been made. Inconsistencies in the COVRERP have been identified and will be addressed in the next scheduled plan update 60 days prior to the 2009 Surry biennial exercise. Inconsistencies in the risk county plans have been identified and will be addressed in the next scheduled plan update 60 days prior to the 2010 North Anna biennial exercise.

State Emergency Operations Center Issue No.: 41-08-2.e.1/3.f.l-P-02 Condition: There are errors and insufficient information in the COVRERP, VDH/DRH ERP, and ingestion county RERPs for the exposure control of workers entering a contaminated area.

COVRERP, Appendix 11, Decontamination, Re-Entry, Return, and Recovery:

Step 11.1.3, Concept of Operations, Re-Entry and Return, states that individuals entering the restricted zone should be controlled in accordance with dose limitations and other procedures for control of occupationally-exposed workers. This is in accordance with the guidance from EPA-400-103

R-92-001. However, specific information is not given about what this dose limitation is.

" VDH/DRH Appendix 17.4, Local Emergency Operations Facility (LEOF), Nuclear Emergency Response - Plume Phase:

Step 3.4, Radiological Assessment Officer, states that "During the recovery phase, consider lowering the exposure control limits for emergency workers to 5 rem TEDE..." This is a requirement based on the COVRERP and federal guidance. Also, during the recovery phase, the workers are no longer considered "emergency workers."

  • Risk County RERPs, Basic Plan and Hazardous Materials ESF:

There is no discussion in the basic plan about post-emergency activities including worker exposure control.

In the Hazardous Materials ESF, the Radiological Officer's procedure includes a statement that "Each person requesting re-entry is only allowed an exposure of 2 R/yr and must be given appropriate dosimetry, consisting of one digital alarming dosimeter and one TLD. Each re-entrant's exposure must be logged and tracked." This limit of 2 R/yr is inconsistentwith the Virginia limit of 5 Rem/yr.

" Ingestion County RERPs, Basic Plan,Section VIII.E.3, Concept of Operations, Exposure Limits, Emergency Workers:

There is a discussion about Emergency Worker limits (including those for lifesaving and protecting valuable property or large populations). There is no discussion about the dose limit system for post-emergency activities which will be carried out in the ingestion counties.

Possible Cause: Since these procedures are rarely used, the confusion and errors were not recognized during development.

References:

NUREG-0654, J.9; J.11; M.1 COVRERP VDH/RHP ERP Risk County RERPs Ingestion County RERPs Effect: Worker exposure control for individuals entering the restricted zone after the emergency phase could be compromised resulting in'overexposures.

Recommendation: Review the procedures for post-plume activities and remove confusing wording and incorrect information. Ensure that the established dose limit system for individuals entering the restricted zone is consistent with the normal Virginia occupationally-exposed worker dose limit system (i.e., the same as established in 10 CFR 20).

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State Response: The VDH!DRH Emergency Response Manual plan corrections have been made. Inconsistencies in the COVRERP have been identified and will be addressed in the next scheduled plan update 60 days prior to the 2009 Surry biennial exercise. Inconsistencies in the risk county plans have been identified and will be addressed in the next scheduled plan update 60 days prior to the 2010 North Anna biennial exercise.

PRIOR PLANNING ISSUES RESOLVED State Emergency Operations Center (Virginia Department of Health/Radiological Health Program)

Issue No.: 41-06-2.a.1-P-01 Condition: The Commonwealth of Virginia uses the Environmental Protection Agency (EPA) "lifesaving or protective of large populations" dose limit (25 rem) as the dose limit for all of their emergency workers. This is contrary to the guidance delineated by the EPA on the use of a graduated dose limit system for emergency workers under various conditions. This issue was previously identified at the 2006 Surry exercise.

Corrective Action Demonstrated: This issue .was resolved at the Surry Power Station exercise on June 27, 2007. The Commonwealth of Virginia RERP has been revised and Appendix 7 and 8 now conform to EPA guidance for emergency worker exposure control.

State Emergency Operations Center (Virginia Department of Health/Radiological Health Program)

Issue No.: 41-06-2.a.1-P-02 Condition: Justification and selection criteria for lifesaving actions have not been specified for emergency workers to exceed administrative exposure limits.

In addition, no specific emergency response position at the State level has been tasked with the responsibility to authorize State emergency workers to exceed the administrative limits (tumback and lifesaving).

Also, at the local level, the Emergency Operations Center Radiological Officer has the authority to approve exposure in excess of the turnback limit. There is no specific emergency response position that has been assigned the authority to authorize exposures above the lifesaving limit (corresponding to the maximum EPA dose limit of 25 rem).

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This issue was previously identified at the 2006 Surry exercise.

Corrective Action Demonstrated: This issue was resolved at the Surry Power Station exercise on June 27, 2007. The York County, James City County, and Isle of Wight County (Appendix 6, page 6-4, respectively) procedures have been revised to more clearly define persons who are authorized to allow emergency workers to exceed administrative dose limits.

State Emergency Operations Center (Virginia Department of Health/Radiological Health Program)

Issue No.: 41-06-2.b.1-P-03 Condition: The Virginia Department of Health (VDH) implementing procedure Appendix 17.2 states that a Protective Action Recommendation (PAR) must be given to the Virginia Department of Emergency Management (VDEM) within 15 minutes from the time the licensee declares a General Emergency (GE). However, this time requirement is not specified in federal regulations nor is it specified in federal guidelines. The licensee requirement for informing the offsite authorities of the GE declaration is within 15 minutes of that declaration and mustbe accompanied by a PAR (which is the minimum that should be implemented by the offsite authorities unless conditions exist that would make implementation of the PAR more risky than the dose savings from the implementation).

Corrective Action Demonstrated: This issue was resolved at the Surry Power Station exercise on June 27, 2007. The Virginia Department of Health, Division of Radiological Health Emergency Plan Implementing Procedures have been revised to eliminate the requirement to provide a Protective Action Recommendation to VDEM within 15 minutes after the utility declares a General Emergency.

State Emergency Operations Center (Virginia Department of Health/Radiological Health Program)

Issue No.: 41-06-2.d.1-P-04 Condition: Virginia Department of Health/Radiological Health Program Procedures have not been updated to reflect the 1998 Food and Drug Administration (FDA) guidelines for radioactive contamination of human food and animal feeds.

This issue was previously identified at the 2006 Surry exercise.

Corrective Action Demonstrated: This issue was resolved at the Surry Power Station exercise on June 27, 2007. Virginia Department of Health, Division of 106

Radiological Health Emergency Plan Implementing Procedures, Appendix 17.8 Post Plume Projection Procedure now cites the 1998 FDA guidelines for radioactive contamination of human food and animal feeds.

PRIOR PLANNING ISSUES UNESOLVED Caroline County Exception Area Route Alerting Issue No.: 41-06-5.a.3-P-05 Condition: There is a typographical error in the procedure sheet that is furnished to the offsite response organization performing the exception area alerting. It presently directs the Deputy to turn right from Country Road (Route 679) onto a driveway for house number 23015. The directions then say to drive tothe end of that drive and alert to the second house. There is no house number 23015 on Country Road (Route 679) in Caroline county. The numbers begin at the Spotsylvania /Caroline County line at 18482 and progressconsecutively to 19444.

Reason Issue Remains Unresolved: Caroline County Emergency Management Director and Ladysmith Volunteer Fire Station #2 Radiological Officer were not aware that this issue existed.

Recommendation: County procedure should be changed to, reflect correct address.

Spotsylvania County Evacuation Assembly Center (Chancellor High School)

Issue No.: 41-04-6.a.1-P-06 Condition: The Spotsylvania County Radiological Emergency Response Plan, Appendix 8, Evacuation Assembly Center Operation Procedure, has the inconsistencies listed below and does not address some aspects of monitoring/decontamination:

" The posting of background readings for monitoring locations is not required by the plan.

" The area diagram for Chancellor High School shows two entrances into the parking area instead of indicating that one would be used as the exit.

" Vehicle monitoring would be performed on all vehicles entering the area (both evacuee vehicles and emergency worker vehicles). Instructions are given for external monitoring only. No instructions are included on monitoring the driver of the vehicle or how that individual would get back to the school entrance.

" A method for decontaminating a vehicle with a contaminated air filter is not specified.

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" The route for returning a decontaminated vehicle to the clear parking area is not indicated on the area diagram.

" The procedure is unclear on where contaminated individuals (as identified from an alarm on the portal monitor) were to be monitored using a survey instrument. This was done next to the portal monitor (which did not allow it to be used until the person was taken into the locker room for decontamination) and then repeated inside the locker room prior to decontamination.

" The list of Attachments on page 8-17 does not match the actual attachments (Attachment 7 is listed as Form REC-3; however, Attachment 7 is now the Portal Monitor Operating Instructions Ludlum Model 52, while Attachment 8 is Form REC-3).

Reason Issue Remains Unresolved: This location was not scheduled for demonstration at this exercise. It will be scheduled for demonstration at the next biennial exercise.

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