ML092860002

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Final Exercise Report for Vermont Yankee
ML092860002
Person / Time
Site: Vermont Yankee Entergy icon.png
Issue date: 06/10/2009
From:
Federal Emergency Management Agency
To:
Office of Nuclear Security and Incident Response
References
Download: ML092860002 (167)
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Text

Vermont Yankee Plume Exercise - June 10, 2009 Final Exercise Report Radiological Emergency Preparedness Program FEMA Region I

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Final Exercise Report Vermont Yankee Power Station Licensee: Entergy Northeast Nuclear Vermont Yankee Exercise Date: June 10, 2009 Report Date: September 28, 2009 U.S. DEPARTMENT OF HOMELAND SECURITY FEDERAL EMERGENCY MANAGEMENT AGENCY FEMA REGION I 99 High Street Boston, MA 02110-2320

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TABLE OF CONTENTS I. Executive Summary...........................................................................................................................1 II. Introduction ........................................................................................................................................2 III. Exercise Overview .............................................................................................................................5 A. Plume Emergency Planning Zone Description ................................................................... 5 B. Exercise Participants........................................................................................................... 7 C. Exercise Timeline ............................................................................................................. 18 IV. Evaluation and Results.....................................................................................................................22 A. Summary Results of Exercise Evaluation......................................................................... 23 B. Status of Jurisdictions Evaluated ...................................................................................... 27 1.0 State of Vermont ................................................................................................... 29 1.1 State Emergency Operations Center ......................................................... 29 1.2 Emergency Operations Facility................................................................. 30 1.3 Joint Information Center ........................................................................... 32 1.4 Vermont Tracking Teams ......................................................................... 35 1.5 Incident Field Office ................................................................................. 36 1.6 Vermont Warning Points .......................................................................... 36 1.6.1 Vermont State Police Dispatch Unit - Rockingham .................... 36 1.6.2 Vermont State Police Dispatch Unit - Derby................................ 37 1.7 Vemont United Way 211 Call Center - Burlington ................................. 37 2.0 Risk Jurisdictions (Vermont) ................................................................................ 37 2.1 Brattleboro Emergency Operations Center........................................................... 37 2.2 Dummerston Emergency Operations Center ........................................................ 38 2.3 Halifax Emergency Operations Center ................................................................. 39 2.4 Guilford Emergency Operations Center ............................................................... 40 2.5 Vernon Emergency Operations Center ................................................................. 40 2.6 Schools, Hospital, Nursing Homes and Child Care Facilities .............................. 41 2.6.1 Windham Southwest Supervisory Union.................................................. 41 2.6.2 Brattleboro Retreat (Private Hospital) ...................................................... 42 2.6.3 Private Schools.......................................................................................... 42 2.6.3.1 Vermont Center for the Deaf and Hard of Hearing ................ 42 i

2.6.3.2 Meadows School..................................................................... 42 2.6.4 Child Care Facilities ................................................................................. 43 2.6.5 WTSA AM/FM (Primary EAS Station) ................................................... 44 2.6.6 Thompson House (Nursing Home)........................................................... 44 3.0 Support Jurisdictions (Vermont)........................................................................... 44 4.0 State of New Hampshire ....................................................................................... 45 4.1 State Emergency Operations Center ......................................................... 45 4.2 Emergency Operations Facility................................................................. 45 4.3 Joint Information Center ........................................................................... 46 4.4 State Police Troop C (Keene) ................................................................... 46 4.5 New Hampshire Field Teams.................................................................... 47 4.5.1 New Hampshire Field Team 1 ...................................................... 47 4.5.2 New Hampshire Field Team 2 ...................................................... 47 4.6 Warning Point ........................................................................................... 48 5.0 Risk Jurisdictions (New Hampshire) .................................................................... 48 5.1 Chesterfield Emergency Operations Center.............................................. 48 5.2 Hinsdale Emergency Operations Center................................................... 49 5.3 Richmond Emergency Operations Center ................................................ 49 5.4 Swanzey Emergency Operations Center................................................... 50 5.5 Winchester Emergency Operations Center............................................... 51 5.6 Schools, Day Care Centers, and Nursing Home Facilities ....................... 51 5.6.1 School Administrative Unions (SAU) .......................................... 51 5.6.2 Child Care Facilities ..................................................................... 52 5.6.3 Nursing Home Facilities ............................................................... 52 6.0 Support Jurisdictions (New Hampshire)............................................................... 53 6.1 Keene Emergency Operations Center....................................................... 53 6.2 Local Warning Point - Southwest New Hampshire District Fire Mutual Aid............................................................................................................. 53 6.3 Transportation Staging Area - First Student Bus Company, Swanzey, NH

................................................................................................................... 54 6.4 Cheshire County Dispatch - Cheshire County Sheriff Department ......... 54 6.5 WKNE Radio Station................................................................................ 55 6.6 Keene Reception Center - Keene High School ........................................ 55 7.0 Commonwealth of Massachusetts......................................................................... 60 7.1 State Emergency Operations Center & 211 Information Line.................. 60 7.2 Emergency Operations Facility................................................................. 61 7.3 Joint Information Center ........................................................................... 62 ii

7.4 Massachusetts State Police ....................................................................... 62 7.4.1 State Police Shelburne Dispatch Warning Point........................... 62 7.4.2 State Police Troop B Northampton Dispatch Northeast ............... 63 7.5 Massachusetts Field Teams....................................................................... 63 7.5.1 Massachusetts Field Team 1 ......................................................... 63 7.5.2 Massachusetts Field Team 2 ......................................................... 64 7.6 Massachusetts Emergency Management Agency Region III/IV .............. 65 7.7 Executive Office of Environmental Affairs..66 8.0 Risk Jurisdictions (Massachusetts) ....................................................................... 66 8.1 Bernardston Emergency Operations Center.............................................. 66 8.2 Colrain Emergency Operations Center ..................................................... 66 8.3 Gill Emergency Operations Center........................................................... 67 8.4 Greenfield Emergency Operations Center ................................................ 67 8.5 Leyden Emergency Operations Center ..................................................... 68 8.6 Northfield Emergency Operations Center ................................................ 68 8.7 Warwick Emergency Operations Center .................................................. 69 8.8 Schools, Day Care Centers, and Nursing Home Facilities ....................... 70 8.8.1 Mohawk Trail Regional School District ....................................... 70 8.8.2 Private Schools.............................................................................. 70 8.8.3 Camps 71 9.0 Support Jurisdictions (Massachusetts).................................................................. 71 9.1 School Bus Transportation - First Student Bus Company, Shelburne Falls ........ 71 APPENDICES APPENDIX 1: Acronyms and Abbreviations .....................................................................................73 APPENDIX 2: Exercise Evaluators and Team Leaders......................................................................76 APPENDIX 3: Exercise Evaluation Area Criteria and Extent of Play Agreement ..........................83 APPENDIX 4: Exercise Scenario ......................................................................................................157 LIST OF TABLES Table 1 - Exercise Timeline ..........................................................................................................19 Table 2 - Summary Results of Exercise Evaluation......................................................................24 iii

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I. EXECUTIVE

SUMMARY

On June 10, 2009, the Federal Emergency Management Agency (FEMA), Region I, conducted an exercise in the plume exposure pathway emergency planning zone (EPZ) around the Vermont Yankee Nuclear Power Station. The purpose of the exercise was to assess the level of State and local preparedness in responding to a radiological emergency. This exercise was held in accordance with FEMAs policies and guidance concerning the exercise of State and local radiological emergency response plans (RERP) and procedures.

The most recent exercise at this site was conducted on October 17, 2007. The qualifying emergency preparedness exercise was conducted on February 18, 1982.

FEMA wishes to acknowledge the efforts of the many individuals who participated in this exercise.

The various agencies, organizations, and units of government from the State and local jurisdictions within the States of Vermont, New Hampshire, and the Commonwealth of Massachusetts, who participated in the exercise, are listed in Section III.B of this report.

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:

  • Vermont: Vermont State Police, one EAS radio station, two public schools, one school supervisory union, two private special education schools, thirteen child care centers, one private hospital, and one nursing home.
  • New Hampshire: New Hampshire State Police, the Cheshire County Sheriffs Office, one EAS radio station, two public schools, one school administrative union (SAU), 4 child care facilities, the state transportation staging area, the Keene Reception Center, and one nursing home.
  • Massachusetts: Massachusetts Environmental Police (MEP), Department of Conservation and Recreation (DCR), Massachusetts State Police (MSP), one regional school district superintendents office, one elementary school, three private schools, 3 camps, and one bus transportation company.

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 two Areas Requiring Corrective Action (ARCAs) identified as a result of this exercise; both ARCAs were successfully re-demonstrated during the exercise. Four ARCAs from a previous exercise were successfully demonstrated and one ARCA-Unresolved during the exercise.

There were eighty-eight evaluators evaluating five hundred fifty-one criteria.

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II. Introduction On December 7, 1979, the President directed FEMA to assume the lead responsibility for all offsite nuclear planning and response. FEMAs activities are 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.

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

FEMAs 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 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).
  • Coordinating the activities of Federal agencies with responsibilities in the radiological emergency planning process:

- U.S. Department of Commerce.

- U.S. Nuclear Regulatory Commission.

- U.S. Environmental Protection Agency.

- U.S. Department of 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.

- U.S. Food and Drug Administration.

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

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Formal submission of the RERPs for the Vermont Yankee Nuclear Power Station to FEMA Region I, by the State of Vermont and involved local jurisdictions occurred in April 1980, by the State of New Hampshire in October 1981, and by the Commonwealth of Massachusetts in December 1979.

A REP plume exposure pathway exercise was conducted on June 10, 2009 by FEMA Region I, to assess the capabilities of State and local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving the Vermont Yankee Nuclear Power Station. The purpose of this exercise report is to present the exercise results and findings on the performance of the offsite response organizations (ORO) during a simulated radiological emergency.

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

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.
  • Radiological Emergency Preparedness: Exercise Evaluation Methodology, published in the Federal Register on September 12, 2001, and amended 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 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 criteria at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format. This section also contains (1) descriptions of all Deficiencies and ARCAs assessed during this exercise, recommended corrective actions, and the State and local governments schedule of corrective actions for each identified exercise issue, and (2) descriptions of unresolved ARCAs assessed during previous exercises and the status of the OROs efforts to resolve them.

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III. Exercise Overview Contained in this section are data and basic information relevant to the June 10, 2009 exercise to test the off-site emergency response capabilities in the area surrounding Vermont Yankee Nuclear Power Station. 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 The Vermont Yankee Nuclear Power Station is located in the State of Vermont in southeast Windham County on the west bank of the Connecticut River, immediately upstream of the Vernon Hydroelectric Station. The topography of the 10-mile EPZ is gently rolling terrain and low hills along the Connecticut River valley.

The 10-mile EPZ contains a total population of 34,405 within three counties and three states:

Windham County, Vermont 16,352 Cheshire County, New Hampshire 10,474 Franklin County, Massachusetts 7,579.

The land use is a mixture of industrial and diversified agricultural production.

The area is served by limited access highways such as Interstate 91, and secondary traffic roads such as Route 5, Route 9, Route 10, Route 30, Route 63, Route 78, and Route 119.

There is non-commercial boat traffic within the Connecticut River. The New England Central Railroad has access through the 10-mile EPZ.

Major parks and recreational areas located within the EPZ include (for all three states)--

Vermont: Ft. Dummer (Summer), Brattleboro; Camp Waubanoug (Summer 8am-5pm), Brattleboro; Living Memorial Park (Annual), Brattleboro; KOA Camp Ground (Summer), Dummerston; Green Mountain Camp (summer) Dummerston; Massachusetts: Camp Northfield (Summer), Northfield; Camp Keewanee (July-Early August 9am-3pm), Greenfield; Camp Lion Knoll (July, August 9am-3:45pm),

Greenfield; Purple Meadow Campground (May-October), Bernardston; Travelers Woods Camping Area (May-October), Bernardston; Mt. Grace Recreational Area, Warwick State Park (May-Labor Day), Warwick; Barton Cove (Memorial Day-Labor Day), Gill; Franklin County Boat Club (April 15-October 30), Gill; 5

New Hampshire: Spofford Lake Area (Summer), Chesterfield; Pisgah State Park (Year Round), Winchester, Hinsdale and Chesterfield; Wantastiquet Natural Area (Year Round) Chesterfield; Shir-Roy (Summer), Richmond; Camp Takodah (Summer), Richmond; and Camp Wiyaka (Summer), Richmond.

The EPZ is divided into three States and 17 towns:

5 towns in Vermont.

5 towns in New Hampshire.

7 towns in Massachusetts.

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B. Exercise Participants The following agencies, organizations, and units of government participated in the Vermont Yankee Nuclear Power Station exercise on June 10, 2009.

STATE OF VERMONT STATE EMERGENCY OPERATIONS CENTER Governors Office Vermont Department of Public Safety Emergency Management Division Vermont State Police Division Fire Safety Division Criminal Justice Services Division Homeland Security Unit Vermont Military Department Vermont Department of Health Vermont Department of Public Service Vermont Department of Fish & Wildlife Vermont Agency of Agriculture, Foods & Market Vermont Department of Buildings and General Services Vermont Agency of Natural Resources Vermont Department of Environmental Conservation Vermont Agency of Human Services Vermont Agency of Transportation Addison County Regional Planning Commission Three Dog Geographics Vermont United Way 211 Community Information & Referral Ctr Vermont Agency of Commerce and Community Development Vermont Department of Education Vermont Department of Information and Innovation Vermont Commission on National and Community Service Vermont Police Academy American Red Cross Radio Amateur Civil Emergency Services (RACES)

Federal Emergency Management Agency, Region I EMERGENCY OPERATIONS FACILITY Vermont Emergency Management Division Vermont Hazardous Materials Response Team/Division of Fire Safety Department of Public Services Vermont Department of Health 7

Radio Amateur Civil Emergency Services (RACES)

Entergy Nuclear Northeast JOINT INFORMATION CENTER Windham Regional Commission Two Rivers - Ottauquechee Regional Commission Vermont United Way 211 Community Information & Referral Ctr Windham County Community Emergency Response Team (CERT)

RADIOLOGICAL TRACKING TEAMS Vermont Hazardous Materials Response Team/Division of Fire Safety INCIDENT FIELD OFFICE Vermont State Police Vermont Emergency Management Division Vermont Department of Fish and Wildlife Vermont Department of Health Vermont National Guard Vermont Agency of Transportation Windham County Sheriffs Department American Red Cross, Green Mt. Chapter Radio Amateur Civil Emergency Services (RACES)

Rescue Inc.

STATE WARNING POINTS Vermont State Police Dispatch Unit - Rockingham, VT Vermont State Police Dispatch Unit - Derby, VT RISK JURISDICTIONS (VERMONT)

BRATTLEBORO Selectboard Members Emergency Management Director Treasurers Office Planning Services Department Fire Department Police Department Public Works Department Human Services Department Finance Department 8

Windham South East Supervisory Union School District Radio Amateur Civil Emergency Services (RACES)

DUMMERSTON Selectboard Members Emergency Management Director Highway Department Fire Department Windham County Sheriffs Office Public Information Officer Health Officer Radio Amateur Civil Emergency Services (RACES)

Volunteers HALIFAX Selectboard Members Town Clerk Emergency Management Director Volunteer Fire Department Constable Highway Department Radio Amateur Civil Emergency Services (RACES)

Volunteers GUILFORD Selectboard Members Town Office Emergency Management Director Volunteer Fire Department Highway Department Radio Amateur Civil Emergency Services (RACES)

Volunteers VERNON Selectboard Members Emergency Management Director Town Clerks Office Police Department Volunteer Fire Department Highway Department Radio Amateur Civil Emergency Services (RACES) 9

Volunteers Vernon Advent Christian Home SCHOOLS, CHILDCARE AND NURSING HOME FACILITIES Schools Windham South West Supervisory Union, Superintendents Office Halifax West School Guilford Central School Vermont Center for the Deaf and Hard of Hearing - Private Meadows School (co-located with Brattleboro Retreat)

Child Care Brattleboro Child Care Guilford Child Care Dummerston Child Care Halifax Child Care Vernon Child Care Nursing Homes Thompson House Thompson House Residential Brattleboro Retreat SUPPORT FACILITIES (Vermont)

Emergency Worker Monitoring and Decontamination Facility (IFO- Dummerston)

STATE OF NEW HAMPSHIRE STATE EMERGENCY OPERATIONS CENTER Office of the Governor New Hampshire Bureau of Emergency Management New Hampshire State Police New Hampshire Department of Transportation New Hampshire Department of Resources and Economic Development New Hampshire Development Parks Division of Fish and Game New Hampshire Environmental Services New Hampshire Department of Agriculture New Hampshire Department of Education New Hampshire Department of Education-Pupil Transportation New Hampshire Division of Public Health Services 10

New Hampshire Department of Health and Human Services American Red Cross National Guard Civil Air Patrol (CAP)

Public Utilities Commission Emergency Medical Services Radio Amateur Civil Emergency Service (RACES) 211 Info Line Entergy Nuclear Northeast EMERGENCY OPERATIONS FACILITY Division of Fire Safety and Emergency Management Division of Public Health and Human, Public Health Division JOINT INFORMATION CENTER New Hampshire Bureau of Emergency Management Vermont Emergency Management Agency Massachusetts Emergency Management Agency Entergy Northeast Nuclear STATE POLICE TROOP C State Patrol Troop C RADIOLOGICAL FIELD MONITORING TEAMS Team #1:

Department Health and Human Services, Radiation Control Program State Police Laboratory Health Management Office EPTAM Plastics Team #2:

Health and Human Services, Childhood Lead Program Occupational Health and Safety Coordinator U.S. Fish & Wildlife STATE WARNING POINT New Hampshire State Police 11

RISK JURISDICTIONS (NEW HAMPSHIRE)

CHESTERFIELD Selectman Office of Emergency Management Police Department Fire Department Spofford Fire Department Highway Department Chesterfield Schools HINSDALE Hinsdale Select Board Police Department Highway Department Fire Department (Volunteer)

RICHMOND Board of Selectmen Emergency Management Fire Department Police Department Rescue Squad Amateur Radio Emergency Services (ARES)

SWANZEY Board of Selectman Emergency Management Director Police Department Fire Department Public Works RADEF Officer (Volunteer)

Communications Center 12

WINCHESTER Board of Selectmen Emergency Management Fire, Rescue, and Ambulance Group Police Department Department of Health and Welfare Highway Department Radio Amateur Civil Emergency Service (RACES)

KEENE City Manager Fire Department Police Department Information Management Systems Public Works Department Health Department American Red Cross Radio Amateur Civil Emergency Service (RACES)

SCHOOLS, CHILD CARE Chesterfield Elementary School Hinsdale Elementary School Hinsdale High School Winchester High School Winchester High School Julies Day Care Dreamland Day Care Winchester Learning Center LOCAL WARNING POINT (SWNHFDMA)

Southwest New Hampshire Fire District Mutual Aid EAS RADIO STATION WKNE Radio, Keene, NH CHESHIRE COUNTY DISPATCH (KEENE, NH)

County Communications Specialist County Communications Supervisor County Sheriff Staff 13

STATE TRANSPORTATION STAGING AREA (West Swanzey)

First Student Transportation Services COMMONWEALTH OF MASSACHUSETTS STATE EMERGENCY OPERATIONS CENTER Office of the Secretary of State for the Commonwealth of Massachusetts Massachusetts Emergency Management Agency Massachusetts State Police Massachusetts Highway Department Massachusetts Department of Public Health/ Radiation Control Program Massachusetts Department of Mental Health MASS 211 Massachusetts National Guard American Red Cross FEMA Region I Vermont Yankee Representative EMERGENCY OPERATIONS FACILITY Massachusetts Emergency Management Agency (MEMA)

Massachusetts Department of Public Health/ Radiation Control Program (MDPH)

JOINT INFORMATION CENTER Massachusetts Emergency Management Agency Vermont Emergency Management Agency New Hampshire Bureau of Emergency Management Entergy Nuclear Northeast MASSACHUETTS STATE POLICE State Police Troop B, Northampton Shelburne Control, Troop B, Shelburne RADIOLOGICAL FIELD MONITORING TEAMS Massachusetts Department of Public Health/Radiation Control Program 14

REGION III/IV EMERGENCY OPERATIONS CENTER Massachusetts Emergency Management Agency Region III Massachusetts State Police Troop B Massachusetts Highway Department District 2 Massachusetts Department of Conservation & Recreation, District 9 Fire Warden Massachusetts Environmental Police American Red Cross Radio Amateur Civilian Emergency Services (RACES) Operators DEPARTMENT OF CONSERVATION AND RECREATION DISTRICT 9 DCR District 9 Fire Personnel MASSACHUSETTS ENVIRONMENTAL POLICE (MEP)

MEP Staff RISK JURISDICTIONS (MASSACHUSETTS)

BERNARDSTON Board of Selectman Emergency Management Director Fire Department Police Department Highway Department Board of Health COLRAIN Board of Selectman Emergency Management Director Police Department Fire Department Health Department Boy Scouts of America 15

GILL Emergency Management Director Board of Health Fire Department Police Department Highway Department GREENFIELD Emergency Management Director Fire Department Police Department Board of Health Department of Public Works Department of Transportation Animal Control Radio Amateur Civil Emergency Services (RACES)

LEYDEN Selectman Emergency Management Director Police Department Volunteer Fire Department Highway Department NORTHFIELD Board of Selectman Emergency Management Director Fire Department Police Department Highway Department Board of Health Pioneer Valley Regional School District - Superintendent Radio Amateur Civil Emergency Services (RACES) 16

WARWICK Board of Selectman Emergency Management Director Fire Department Police Department Board of Health Highway Department Massachusetts SCHOOLS Mohawk Trail Regional School District Superintendents Office Colrain Central School Giving Tree School (Private)

SUPPORT JURISDICTIONS (MASSACHUSETTS)

School Bus Transportation Host Schools (Not Evaluated in 2009)

Greenfield Community College- Greenfield Reception Center (Not Evaluated in 2009) 17

C. Exercise Timeline Table 1, on the following page, presents the times at which key events and activities occurred during the Vermont Yankee Nuclear Power Station plume exposure pathway exercise on June 10, 2009. Also included are the times notifications were made to the participating jurisdictions/functional entities.

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TABLE 1. EXERCISE TIMELINE DATE AND SITE: June 10, 2009 Vermont Yankee Nuclear Power Station STATE OF VERMONT Emergency Utility Dummer-Classification VT SEOC VT JIC VT EOF IFO Brattleboro Halifax Guilford Vernon Declared ston Level or Event Unusual Event 8:28 ---- 8:37 ---- 8:46 8:45 8:57 8:45 9:05 Alert N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Site Area 9:16 9:40 9:24 9:40 9:42 9:34 9:40 10:02 9:30 10:02 Emergency General Emergency 10:39 10:41 10:47 10:41 10:58 11:02 11:00 11:02 11:00 10:59 Simulated Rad. Release Started 10:41 11:00 10:41 10:58 11:02 11:00 11:02 11:00 10:59 Simulated Rad. Release Terminated ---- ---- ---- ---- ---- ---- ---- ----

Facility Declared Operational 10:05 9:22 10:05 10:25 9:55 9:44 9:44 9:25 9:29 Declaration of State Governor 10:09 10:04 10:09 10:26 10:10 10:10 10:11 10:05 10:08 of Emergency Local ---- ---- ---- ---- ---- ---- ---- ----

Exercise Terminated 13:23 13:00 13:23 13:04 13:23 13:22 13:22 13:23 13:22 Early Precautionary Actions 10:16 ---- ---- 10:14 ---- ---- 10:16 ---- ----

Close parks and beaches 10:16 10:04 11:15 10:14 11:13 10:16 11:14 10:20 School transfer 10:16 10:04 11:15 10:14 11:13 11:12 11:14 10:24 10:44 Protective Action Decision ---- ---- ---- ---- ---- ---- ---- ---- ----

1st Protective Action Decision 10:55 ---- 11:15 11:09 11:08 10:17 ---- 11:07 ----

1st Siren Activation 10:13 10:20 11:15 10:14 10:13 10:14 10:14 10:13 10:14 1st EAS Message 10:16 10:20 11:15 ---- 10:17 10:17 10:17 10:13 10:17 2nd Protective Action Decision ---- 11:00 ---- ---- ---- ---- ---- 11:08 ----

2nd Siren Activation ---- 11:00 ---- 11:09 11:09 11:09 11:09 11:09 11:09 2nd EAS Message ---- 11:00 ---- ---- 11:12 11:12 11:17 11:12 11:12 3rd Protective Action Decision ---- ---- ---- ---- ---- ---- ---- ---- ----

3rd Siren Activation ---- ---- ---- ---- ---- ---- ---- ---- ----

3rd EAS Message ---- ---- ---- ---- ---- ---- ---- ---- ----

Use of KI ---- ---- ---- 11:03 10:55 10:49 10:57 10:55 10:59 Emergency Workers ---- 10:53 ---- 11:03 10:55 10:49 10:57 10:55 11:12 General Public ---- 10:53 ---- 11:03 10:55 10:49 ---- 10:55 11:30 Legend: N/A - Not Applicable 19

STATE OF NEW HAMPSHIRE Emergency Utility NH NH SW NH Chester- Rich- Win-Classification NH EOF Cheshire Hinsdale Swanzey Keene Declared SEOC JIC DFMA field mond chester Level or Event Unusual Event 8:28 8:40 8:54 8:37 8:45 8:45 8:59 9:00 8:49 8:49 8:50 8:28 Alert N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Site Area 9:16 9:25 9:29 9:29 9:29 9:34 9:51 9:23 9:34 9:34 9:35 9:35 Emergency General Emergency 10:39 10:50 10:55 10:41 10:56 10:59 10:52 10:46 10:49 10:46 11:01 10:48 Simulated Rad. Release Started 10:39 ---- 10:39 11:13 ---- 11:13 11:15 11:07 10:46 11:10 11:13 Simulated Rad. Release Terminated ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ----

Facility Declared Operational 9:34 10:00 10:10 ---- ---- 10:20 9:54 9:38 10:04 9:28 10:08 Declaration of State Governor 10:24 10:24 10:24 ---- ---- 10:24 10:24 10:35 ---- 10:35 10:30 of Emergency Local ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ----

Exercise Terminated 12:31 13:26 13:23 12:37 ---- 12:35 12:32 12:32 12:32 12:45 12:36 Early Precautionary Actions 10:01 ---- 10:25 ---- ---- 10:25 10:01 10:35 10:32 10:35 ----

Close parks and beaches 10:01 10:43 ---- ---- ---- 10:10 ---- 10:32 ---- 10:35 10:32 School transfer 10:01 10:43 ---- ---- ---- 11:10 10:08 ---- 10:32 10:08 10:03 Protective Action Decision ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ----

1st Protective Action Decision 10:55 9:51 ---- 11:08 ---- 11:08 11:08 11:07 11:08 11:08 11:08 1st Siren Activation 10:13 10:13 10:13 10:05 ---- 10:13 10:13 10:13 10:13 10:13 10:13 1st EAS Message 10:16 10:16 10:16 10:16 ---- 10:16 10:16 10:16 10:16 10:16 10:16 2nd Protective Action Decision ---- ---- 11:05 ---- ---- ---- ---- ---- ---- ---- ----

2nd Siren Activation 11:09 11:09 ---- 11:09 ---- 11:09 11:09 11:09 11:09 11:09 11:09 2nd EAS Message 11:12 11:12 ---- 11:12 ---- 11:12 11:12 11:12 11:12 11:12 11:12 3rd Protective Action Decision ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ----

3rd Siren Activation ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ----

3rd EAS Message ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ----

Use of KI 11:52 ---- 11:51 ---- ---- ---- ---- ---- ---- ---- ----

Emergency Workers 11:52 WebEOC 11:52 ---- ---- 11:57 11:58 11:59 11:58 12:03 ----

General Public 11:52 ---- ---- ---- ---- ---- ---- ---- ---- ---- ----

Legend: N/A - Not Applicable 20

COMMONWEALTH OF MASSACHUSETTS Emergency Region Utility MA MA MA MA Bernard North- Green-Classification III//IV Colrain Gill Leyden Warwick Declared SEOC 211 JIC EOF -ston field field Level or Event EOC Unusual Event 8:28 8:40 9:13 ---- 8:40 ---- 8:47 8:47 8:46 8:28 8:55 8:46 8:45 Alert N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A N/A Site Area Emergency 9:16 9:28 9:32 10:11 9:16 ---- 9:39 9:41 9:28 9:40 9:44 9:38 9:34 General Emergency 10:39 10:44 11:57 10:43 10:51 10:41 10:59 11:05 10:58 11:00 10:58 11:00 10:58 Simulated Rad. Release Started 10:40 10:40 10:43 10:51 10:39 11:30 11:30 10:58 11:30 ---- 11:31 11:30 Simulated Rad. Release Terminated ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ----

Facility Declared Operational 9:50 9:50 10:12 9:30 10:07 9:07 9:05 9:35 9:15 9:50 8:55 9:03 Declaration of State Governor 9:37 9:45 10:00 9:38 9:37 10:03 9:52 9:48 9:46 9:37 ---- 9:40 of Emergency Local ---- ---- 12:47 ---- ---- ---- ---- ---- 9:47 10:00 10:03 ----

Exercise Terminated 11:57 11:57 ---- 11:50 13:23 11:57 11:52 11:52 11:51 11:55 11:57 11:50 Early Precautionary Actions 9:37 9:53 10:10 ---- 10:00 ---- 10:13 ---- ---- ---- 9:55 9:34 Close parks and beaches 9:38 9:48 10:10 9:34 10:00 ---- 10:13 9:50 9:46 ---- 10:09 10:12 School transfer 9:38 9:53 10:10 9:34 10:00 9:54 10:13 9:40 9:46 9:38 9:58 ----

Protective Action Decision ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ----

1st Protective Action Decision 10:52 ---- 10:55 10:54 10:52 ---- ---- ---- N/A ---- 11:00 10:58 1st Siren Activation 10:12 10:18 10:12 10:12 10:12 10:09 10:12 10:12 10:04 ---- 10:12 10:12 1st EAS Message 10:15 10:18 10:15 10:13 10:15 10:09 10:15 10:15 ---- ---- 10:15 10:15 2nd Protective Action Decision 10:52 ---- 10:55 10:54 ---- ---- ---- 11:00 N/A 10:58 ---- 11:09 2nd Siren Activation 11:09 11:12 11:09 11:09 11:09 11:05 11:04 11:09 11:02 11:09 11:09 11:12 2nd EAS Message 11:12 11:14 11:12 11:12 11:12 11:05 11:09 11:12 ---- 11:12 11:12 ----

3rd Protective Action Decision ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ----

3rd Siren Activation ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ----

3rd EAS Message ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ----

Use of KI 10:57 ---- 10:55 10:51 ---- ---- 11:04 ---- ---- ---- 11:00 11:04 Emergency Workers 10:57 ---- 10:55 10:51 10:45 10:55 11:07 11:00 ---- 10:58 11:00 11:04 General Public 10:57 ---- 10:55 10:51 10:52 10:55 11:07 11:00 ---- 11:39 11:00 11:04 Legend: N/A - Not Applicable 21

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IV. Evaluation and Results Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities that participated in the June 10, 2009, exercise to test the offsite emergency response capabilities of State and local governments in the 10-mile EPZ surrounding the Vermont Yankee Nuclear Power Station.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of criteria delineated in Radiological Emergency Preparedness: Exercise Evaluation Methodology, published in the Federal Register on September 12, 2001, and amended April 25, 2002.

Detailed information on the exercise evaluation areas 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 was scheduled for demonstration during this exercise by all participating jurisdictions and functional entities. Exercise evaluation area criteria are listed by number and the demonstration status of the criteria is indicated by the use of the following letters:

M Met (No Deficiency or Area Requiring Corrective Action (ARCA) assessed and no unresolved ARCAs from prior exercises)

D Deficiency A ARCA(s) assessed N Not Demonstrated (Reason explained in Section IV.B) 23

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: June 10, 2009 Vermont Yankee Nuclear Power Station

1. 1. 1. 1. 1. 2. 2. 2. 2. 2. 2. 3. 3. 3. 3. 3. 3. 3. 3. 3. 4. 4. 4. 4. 4. 5. 5. 5. 5. 6. 6. 6. 6.

JURISDICTION/LOCATION a. b. c. d. e. a. b. b. c. d. e. a. b. c. c. d. d. e. e. f. a. a. a. b. c. a. a. a. b. a. b. c. d.

1 1 1 1 1 1 1 2 1 1 1 1 1 1 2 1 2 1 2 1 1 2 3 1 1 1 2 3 1 1 1 1 1 STATE OF VERMONT State Emergency Operations M M M M M M M M M M M M Center Emergency Operations Facility M/R M M M M M M Joint Information Center M M M M M M M M/R Vermont Tracking Team 1 M M M M M M M M Vermont Tracking Team 2 M M M M M M M M Incident Field Office M M M M M M M M M Primary Warning Point M Alternate Warning Point M M M 211 Call Center M M M RISK JURISDICTIONS (VERMONT)

Brattleboro M M M M M M M M M M M M Dummerston M M M M M M M M M M M M 1

Halifax M M M M M M M A M M M M Guilford M M M M M M M M M M M M Vernon M M M M M M M M M M M M Schools, Day Care Centers, and M M Nursing Home Facilities Wyndham Southwest Supervisory Union M M Superintendent Office Brattleboro Retreat M M Private Schools M M WTSA AM/FM (Primary EAS M M Station)

LEGEND: M = Met (no Deficiency or ARCA(s) assessed) A = ARCA(s) assessed A1 = 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 24

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: June 10, 2009 Vermont Yankee Nuclear Power Station

1. 1. 1. 1. 1. 2. 2. 2. 2. 2. 2. 3. 3. 3. 3. 3. 3. 3. 3. 3. 4. 4. 4. 4. 4. 5. 5. 5. 5. 6. 6. 6. 6.

JURISDICTION/LOCATION a. b. c. d. e. a. b. b. c. d. e. a. b. c. c. d. d. e. e. f. a. a. a. b. c. a. a. a. b. a. b. c. d.

1 1 1 1 1 1 1 2 1 1 1 1 1 1 2 1 2 1 2 1 1 2 3 1 1 1 2 3 1 1 1 1 1 STATE OF NEW HAMPSHIRE State Emergency Operations Center M M M M M M M M M M M M M M/R Emergency Operations Facility M M M M M M M M Joint Information Center M M M M M M M State Police Troop C M M M M M M M New Hampshire Field Team 1 M M M M M M M M New Hampshire Field Team 2 M M M M M M M M Warning Point M M M RISK JURISDICTIONS (NEW HAMPSHIRE)

Chesterfield M M M M M M M M M M M M M Hinsdale M M M M M M M M M M M M Richmond M M M M M M M M M M M M Swanzey M M M M M A1 M M M M M Winchester M M M M M M M M M M M M Schools, Day Care Centers, and Nursing Home Facilities School Administrative Unions M M

  1. 27 and #38 Child Care Facilities M Nursing Home Facilities M SUPPORT JURISDICTIONS (NEW HAMPSHIRE)

Keene EOC M M M M M M M M M M M M M Local Warning Point M M M Transportation Staging Area M M M M M Cheshire County Dispatch M M M WKNE Radio Station M R(2)

Keene Reception Center M M M M M M M/R U(1)

LEGEND: M = Met (no Deficiency or ARCA(s) assessed) A = ARCA(s) assessed A1 = 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 25

TABLE 2.

SUMMARY

RESULTS OF EXERCISE EVALUATION DATE AND SITE: June 10, 2009 Vermont Yankee Nuclear Power Station

1. 1. 1. 1. 1. 2. 2. 2. 2. 2. 2. 3. 3. 3. 3. 3. 3. 3. 3. 3. 4. 4. 4. 4. 4. 5. 5. 5. 5. 6. 6. 6. 6.

JURISDICTION/LOCATION a. b. c. d. e. a. b. b. c. d. e. a. b. c. c. d. d. e. e. f. a. a. a. b. c. a. a. a. b. a. b. c. d.

1 1 1 1 1 1 1 2 1 1 1 1 1 1 2 1 2 1 2 1 1 2 3 1 1 1 2 3 1 1 1 1 1 COMMONWEALTH OF MASSACHUSETTS State Emergency Operations Center M M M M M M M M M M M M M M Emergency Operations Facility M M M M M M M M M Joint Information Center M M M M M M M State Police Shelburne Dispatch M M M State Police Troop B Dispatch M M M M M M M M M M M M M M M M M M M M M M M M M M M M M M M Massachusetts Field Team 1 M M M M M M M M Massachusetts Field Team 2 M M M M M M M M MEMA Region III/IV M M M M M M RISK JURISDICTIONS (MASSACHUSETTS)

Bernardston M M M M M M M M M M M M M Colrain M M M M M M M M M M M M Gill M M M M M M M M M M M M Greenfield M M M M M M M M M M M M Leyden M M M M M M M M M M M M Northfield M M M M M M M M M M M M Warwick M M M M M M M M M M M M SUPPORT JURISDICTIONS (MASSACHUSETTS)

School Bus Transportation M M M LEGEND: M = Met (no Deficiency or ARCA(s) assessed) A = ARCA(s) assessed A1 = 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 26

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.

y 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.

y 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.

y 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.

y 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.

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

y 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.

y 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.

27

y 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 (-).

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

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

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

y Issue Classification Identifier: D (Deficiency) or A (ARCA). Only Deficiencies and ARCAs are included in exercise reports.

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

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1.0 STATE OF VERMONT 1.1 State Emergency Operations Center The Vermont Emergency Management Staff and participating agencies clearly demonstrated their knowledge of Vermont Emergency Management plans and procedures and melded themselves into one unit as a unified command by aggressive communications and coordination and being able to develop consensus so appropriate and timely decisions could be made.

The Dose Assessment Team (DAT) members in the Vermont State Emergency Operation Center (VSEOC) were knowledgeable, dedicated, and conscientious professionals. They worked together very well as a team and cooperated well with other agencies involved in the exercise.

a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.2, 2.b.2, 2.c.1, 3.d.1, 3.d.2, 5.a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: One ISSUE: 67-05-1.c.1-A-02 (Scheduled for 2011 Ingestion Pathway Exercise)

CONDITION: During the Ingestion Phase portion of the exercise on Day 3, The Incident Field Office only had the Exclusion Area Map.

They were unaware of other maps showing the food control zones as established at the State Emergency Operations Center. Traffic and access control points were only established for restricting access into the Exclusion Zone (restricted area). It was the IFOs understanding that the Exclusion Zone was the same area as the food control and that the access control point for the exclusion area was also for the food control zone.

POSSIBLE CAUSE: Accurate information and maps showing the food control zone were not received from the State Emergency Operation Center. There was a lack of communication from the State Emergency Operations Center to the IFO.

REFERENCE:

NUREG-0654 J.9.11 29

EFFECT: The IFO did not provide access and control of the correct food control zone and underestimated the number of access control points and manpower needed to control the food control zone.

RECOMMENDATION: Ensure that the State Emergency Operations Center establishes a communications link with the IFO to relay accurate and timely information, and to include the IFO in decision making conferences. Ensure that the IFO has all the correct maps when discussing resources obtained from the IFO.

SCHEDULE OF CORRECTIVE ACTIONS: This criterion is under review, and the response expected at the IFO will be described better in the extent of play for the 2011 exercise. Methods of providing detailed maps to EPZ facilities from either the State EOC or the FRMAC will be improved.

1.2 Emergency Operations Facility The Vermont Plume Tracking Team Director (PTTD) monitored and evaluated plant conditions and meteorological data and worked with personnel at the State Emergency Operations Center to effectively manage the Plume Tracking Teams.

The information gathered was used to assist decision makers in determining appropriate protective actions. The PTTD also ensured that the PTTs were aware of their dosimetry, dose limits, and Potassium Iodide requirements and monitored PTT dose during the exercise. The PTTD activities were carried out in a professional manner throughout the exercise.

The Vermont Emergency Management Liaison (VEML) in the utility EOF responded in a very energetic and pro-active manner. This constant movement to all the Vermont representatives work stations in four different rooms to gather information and provide big-picture updates to the team. The VEML also used the utility-supplied information display system and sought clarifying information to provide insight to Vermont decision makers.

a. MET: 1.c.1, 1.d.1, 1.e.1, 2.b.1, 3.a.1, 3.b.1, 4.a.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None 30
e. PRIOR ARCAs - RESOLVED: One ISSUE: 67-07-1.c.1-A-02 CONDITION: The VT field monitoring teams at the IFO, located at the Vermont Transportation Garage in Dummerston, were deployed to the field to conduct field monitoring activities at the direction of the Field Team Director (FTD) located at the Vermont Yankee (VY)

Emergency Operations Facility (EOF). The direction was given to evacuate the IFO while the teams were conducting the field monitoring. The IFO was then notionally evacuated. The field monitoring teams were not given the evacuation order/information.

POSSIBLE CAUSE: The Field Team Director was located at the EOF at a location separate from the IFO. Being disparate from the Field Teams, from the Radiological Sample Coordinator (RSC) and from the IFO Director and other IFO management, the FTD may not have been aware that the information had not been passed to the teams, thinking that it would be accomplished by the RSC, IFO Director, or other IFO management. It is also possible that the FTD may not have received the information from management at the EOF or VT EOC.

This could have resulted from the EOF management not knowing the chain-of-command relationship between the FTD and the field, specifically the disparate locations and the need for specific lines of communications regarding safety issues and urgent messages.

REFERENCE:

NUREG-0654, A.1.d, 2.a, b EFFECT: Nothing negative resulted from this oversight during this exercise, probably because it occurred toward the end of the exercise, i.e. the exercise ended within 30 minutes of the evacuation of the IFO.

In a real accident, Field Teams could have been unnecessarily exposed, equipment unnecessarily contaminated (or contaminated for an unnecessarily long period). Samples could have been unnecessarily contaminated and important data lost, because the contaminated samples would not be valid.

RECOMMENDATION: Vermont and its subordinate organizations must clarify the relationships, especially the lines of communication for critical information, and address direction and safety information required for deployed field teams or other deployed individuals and workers. For an evacuation of individuals located in a different location, procedures must be confirmed to ensure notification of those individuals where they may not otherwise receive such notification.

31

SCHEDULE OF CORRECTIVE ACTIONS: A thorough review of the information flow from the State EOC (SEOC) and groups not part of one of the RERP facilities, such as field teams, will be conducted.

Contingencies such as evacuation of facilities including the IFO, Transportation Staging Area, Emergency Worker RM&D, etc., will be studied. Plans and procedures will be revised by the next plan revision to include these changes. The provision of additional staff to the Radiological Health Advisor will also be considered. Training on the plan and procedure changes will occur in calendar 2008.

CORRECTIVE ACTION DEMONSTRATED: For this exercise the scenario did not create a situation where it would require the Incident Field Office (IFO) to be evacuated as it was in 2007. Therefore, the Plume Tracking Team Director (PTTD) was interviewed concerning the actions that would be taken in the event the IFO had to be evacuated with respect to notifying the Plume Tracking Teams (PTT).

The PTTD stated that once the decision was made at the Vermont SEOC to evacuate the IFO (he would normally be involved in this discussion, and in some cases he would initiate the discussion) he would immediately be notified if not already on the line with the SEOC. He would then notify the PTTs of this action and inform them what alternate site to report to for sample turnover and monitoring and decontamination of the PTT members and equipment. Even if the IFO is not evacuated, it is the policy to inform the PTTs where to report to at the end of their shift or the event.

f. PRIOR ARCAs - UNRESOLVED: None 1.3 Joint Information Center The State of Vermont successfully demonstrated emergency information for the public at the JIC during this exercise. Activation of the JIC was timely. Upon arrival, JIC personnel quickly established communications connectivity with the SEOC. The JIC is within the 10-mile EPZ, and the Vermont JIC staff exercised excellent contamination control. Dosimeters were read and recorded every 30 minutes throughout the exercise. JIC personnel monitored the SEOC decision-line, which provided an excellent transfer on needed information concerning PADs. Media briefings were conducted in a commendable manner. Vermont JIC personnel were experienced, well-trained, and highly-motivated toward the JIC mission.
a. MET: 1.a.1, 1.b.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None 32
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: One ISSUE: 67 5.b.1-A-01 CONDITION: The Vermont Emergency Management (VEM) representatives at the Vermont Yankee Joint Information Center (VY-JIC) located within the Vermont Yankee Training Support Center (VY-TSC) in Brattleboro, Vermont failed to provide a Media Inquiry Procedure to the news media representatives present at the VY-JIC as required by the new VEM JIC Representative Implementing Procedure dated September 2007.

It should be noted that the VEM JIC Representatives used the rest of the new procedure, which is in the form of a checklist. However, they indicated that the Media Inquire Procedure mentioned in the procedure was unclear to them.

POSSIBLE CAUSE: The new VEM JIC Representative Implementing Procedure dated September 2007 provided to the VEM JIC Representatives was incomplete, and they had not received any training in the use of this new procedure prior to the exercise. It should be noted that an additional procedure for a VEM JIC Assistant was also provided to the VEM JIC Representatives on the day of the exercise. However, it was unclear what relationship existed between that second VEM procedure and the existing procedure established by Vermont Yankee Nuclear Power Station (VYNPS) for the designated State PIO Assistant.

The VEM JIC Representatives indicated that they had received the new VEM JIC Representative Implementing Procedure dated September 2007 for the first time the day of the exercise. That document had not been available during the dress rehearsal conducted on September 27, 2007.

Furthermore, the copy of the JIC Representative Implementing Procedure dated September 2007 was incomplete, as it did not include the Media Inquire Procedure referenced within that the VEM JIC Representatives were supposed to provide to the media.

REFERENCES:

NUREG-0654, G.4.a, G.5 VEM JIC Representative Implementing Procedure (September 2007; no version or release number) and JIC Assistant Implementing Procedure (May 2005; no version or release number) 33

Vermont Radiological Emergency Response Plan, Section 17, A. Public Information and Instruction During an Emergency (Rev. 6; Revised September 2007).

EFFECT: The purpose of the Media Inquire Procedure mentioned in the new VEM JIC Representative Implementing Procedure dated September 2007 is unclear considering that the operation of the VY-JIC is conducted in accordance with procedures established by Vermont Yankee Nuclear Power Station (VYNPS), which are implemented in coordination with the State JIC Representatives from Vermont, Massachusetts, and New Hampshire. Therefore, the actual or potential effect of the failure to provide to the media the Media Inquire Procedure cannot be ascertained at this time.

RECOMMENDATION: The Vermont Radiological Emergency Response Plan (VRERP) and its associated procedures related to the functions to be performed by VEM personnel at the VY-JIC (including the new VEM JIC Representative Implementing Procedure and the JIC Assistant Implementing Procedure) should be reviewed to ensure that they are clear and complete, as well as consistent with the procedures developed by VYNPS for operation of the VY-JIC. As necessary, VT-RERPs procedures related to the functions to be performed by VEM personnel at the VY-JIC should include explicit reference to the applicable VYNPS procedures for operation of the VY-JIC, including those related to the VYNPS State PIO Assistant, as well as those related to activation and operation of the Alternate VY-JIC.

Additionally, all VEM personnel designated to serve at the VY-JIC should receive proper training in the specific procedures related to the function they are to perform. Their training should include familiarization with the procedures established by VYNPS for operation of the VY-JIC, including those related to activation and operation of the Alternate VY-JIC.

SCHEDULE FOR CORRECTIVE ACTIONS: The PUBLIC INFORMATION OFFICE (SSF-14)-JIC REPRESENTATIVE ALL HAZARDS IMPLEMENTING PROCEDURE will be revised to change the Make contact with media personnel and provide the Media Inquiry Procedure task and delete the reference to the Media Inquiry Procedure. JIC personnel will be trained on that and any other changes in the JIC procedure in calendar 2008.

CORRECTIVE ACTION DEMONSTRATED: The PUBLIC INFORMATION OFFICE (SSF-14)-JIC REPRESENTATIVE- ALL HAZARDS IMPLEMENTING PROCEDURE has been revised and is dated May, 2009. The procedure no longer contains any reference to Media Inquiry. All Vermont JIC personnel demonstrated that they were 34

well trained on all aspects of their responsibilities, during the June 10, 2009 exercise. For these reasons, this issue was resolved.

f. PRIOR ARCAs - UNRESOLVED: None 1.4 Vermont Tracking Teams 1.4.1 Tracking Team 1 The Vermont Tracking Team # 1 demonstrated a good knowledge of the Plume Tracking Procedures. They were familiar with the area and were able to locate their sampling points. They also demonstrated excellent contamination control procedures. Sampling data was promptly reported to the PTT Leader at the IFO.
a. MET: 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.2, 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 1.4.2 Tracking Team 2 The Vermont Tracking Team # 2 performed their assignments in a professional manner. Their experience in hazardous materials response provided a good background for contamination control which they used during the drill. They followed their procedures for completing sampling functions and maintained records of their communications and actions.

They exhibited ALARA awareness by determining that an alternate route back to the IFO would be preferred to re-traversing the plume encountered when traveling to their assigned sampling point.

a. MET: 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.2, 4.a.3
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None 35
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 1.5 Incident Field Office The Vermont Incident Field Office was well managed by the IFO Director assisted by the Vermont Emergency Management Liaison. Decisions were passed to the proper agencies in a timely manner and coordinated with Vermont towns within the 10-mile EPZ around the Vermont Yankee Nuclear Power Station. IFO agencies communicated well. Roles and responsibilities were well understood and plans/procedures were followed.
a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 3.a.1, 3.b.1, 3.d.1, 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 1.6 Vermont Warning Points 1.6.1 Vermont State Police Dispatch Unit - Rockingham The Rockingham Dispatch Center recently has a change in mission of becoming the primary warning point. The dispatch staff knew their plans and procedures with no lapses in performance.
a. MET: 1.d.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 36

1.6.2 Vermont State Police Dispatch Unit - Derby The staff at the Alternate State Warning Point worked as a team in the response to the incident at the Vermont Yankee Nuclear Plant. This allowed them to provide a prompt notification when the incident escalated to Site Area Emergency.

a. MET: 1.a.1, 1.b.1, 1.d.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 1.7 Vermont United Way 211 Call Center - Burlington The Vermont 211 Community Information and Referral Center (CIRC) demonstrated an exceptional capability to provide timely and accurate information to the public. All CIRC staff members demonstrated outstanding professionalism and knowledge of all aspects of the publics questions and concerns. The volunteers who augmented the CIRC deserve special thanks for a job extremely well done.
a. MET: 1.d.1, 1e.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.0 RISK JURISDICTIONS (VERMONT) 2.1 Brattleboro Emergency Operations Center The Brattleboro Emergency Management Director (EMD) demonstrated outstanding flexibility in adjusting to the failure of more than half of the EOCs 37

commercial telephone and facsimile machine service from the onset of the exercise to near its conclusion. Upon opening the EOC, she advised the EOC staff and the State EOC of the Brattleboro EOCs reduced telephone capability. She also instructed the staff that it must adjust by maximizing the use of cellular phones to make outgoing calls, telling callers that their calls must be limited to emergency situation matters, and providing alternate numbers for facsimile machine messages.

The efforts made and results achieved in the Brattleboro EOC to prepare for possible execution of protective actions for special populations other than public schools were outstanding, especially those involving the Fire, Human Services, and Transportation Desks. Their achievements were all the more impressive because of their ability to work around the steep reduction of commercial telephone service in the EOC for most of the exercise.

a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.2 Dummerston Emergency Operations Center The Dummerston Emergency Operations Center (EOC) staff was knowledgeable and enthusiastic in their response to the scenario. The Emergency Management Director provided numerous briefings and updates throughout the exercise. The Radiological Officer provided an exemplary briefing on dosimetry packets and exposure limits. Throughout the day persons in the EOC and emergency workers in the field consistently recorded dosimeter readings.
a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None 38
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.3 Halifax Emergency Operations Center The PIO at the Halifax EOC developed a unique form entitled YANKEE DRILL NEWS RELEASE for the purpose of keeping the State EOC informed regarding activities at the Halifax EOC. She completed the form immediately after each briefing by the EMD, submitted it to the Chairman of the Select Board for approval, and faxed it to the State EOC.

Halifax EOC recently acquired DisasterLAN computer software which provided them direct contact with the State EOC for current event information. This software was utilized throughout the exercise by one of the Selectmen, who provided the EOC staff with confirmation of events overheard over the radios, prior to receiving the hard copy.

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

ISSUE: 67-09-3.c.2-A-01 (Re-demonstrated)

CONDITION: At 1114, the Halifax Emergency Management Director (EMD) received VEM 6 Form advising Halifax of a precautionary transfer of school children and child care centers. This action was posted on the EOC Status Board. At approximately 1135 the EMD was asked what time he notified the school of this action.

The EMD stated that he did not make the call and immediately called the school at 1135 and notified them of the transfer. The EMD called the day care center at 1137 advising them of the transfer.

POSSIBLE CAUSE: The EMD got involved in other actions and forgot to make the phone call.

REFERENCE:

NUREG-0654, J.10.c, d, g EFFECT: Depending on the wind direction, the children may not have left the Emergency Planning Zone in sufficient time to escape from the plumes footprint. However, for this exercise Halifax would not have received any deposition because of the wind direction NNE to SSW. Halifax is west of the power plant.

39

CORRECTIVE ACTION DEMONSTRATION: In discussion with the State Controller and the EMD the decision was made to accept the 1135 and 1137 calls as a re-demonstration showing that the action of precautionary transfer of school children and child care centers was accomplished. During the Corrective Action Demonstration the EMD notified schools and child care centers of any actions required of them during an incident at the power plant.

d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.4 Guilford Emergency Operations Center The Guilford Emergency Operations Center (EOC) staff was organized and worked well together as a team. The staff communicated effectively with each other. The Selectboard Chair provided strong support for the Emergency Management Director (EMD). The Selectboard Chair maintained the status boards with up-to-date pertinent information and was knowledgeable in EOC operation. The Selectboard Chair and EMD worked well together, and they discussed what to do if a different scenario were to happen during the exercise.

The EMD briefed the staff on a regular basis when new information was received in the EOC.

a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 3.b.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 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 2.5 Vernon Emergency Operations Center The Vernon EOC staff were competent and responded quickly to the situation as it unfolded throughout the day. The EMD directed operation with control and accuracy. Frequent briefings of the VYNP situation kept the staff well informed.

40

Members of the EOC staff performed their duties and executed a sufficient emergency response.

a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 3.b.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 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 2.6 Schools, Hospital, Nursing Homes and Child Care Facilities 2.6.1 Windham Southwest Supervisory Union Superintendent Office: The Superintendent was always aware of incidents that could have had an impact upon the Halifax School. The Superintendent arranged for the transportation required to evacuate the Halifax School.

Halifax Elementary School: The principal at the Halifax school had only been in that position for a year. She clearly demonstrated her knowledge of the radiological emergency response plans and procedures and how to implement them if needed.

Guilford Central School: School staff was knowledgeable of radiological emergency response plans and procedures.

a. MET: 3.b.1, 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 41

2.6.2 Brattleboro Retreat (Private Hospital)

Administrative staff was well-trained in radiological emergency response plans and procedures.

a. MET: 3.b.1, 3.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 2.6.3 Private Schools 2.6.3.1 Vermont Center for the Deaf and Hard of Hearing The administrative staff demonstrated knowledge of the schools radiological emergency response plans and procedures. The campus covered several large buildings, yet staff in all of the buildings demonstrated knowledge of the required response.
a. MET: 3.b.1, 3.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 2.6.3.2 Meadows School The staff was integrated with the staff and resources of the Brattleboro Retreat. There was co-planning and training between both facilities to ensure safety of clients and students.
a. MET: 3.b.1, 3.c.1 42
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.6.4 Child Care Facilities All of the child care Directors demonstrated their knowledge of their radiological emergency preparedness plans and procedures.

Brattleboro Center for Children Clarke Child Care Dummerston Child Care Ferencz Child Care Guilford Child Care Halifax Child Care Houle Child Care J. Gilbeau Child Care Jeans Family Day Care Lane Child Care Little Peoples Day Care M. Gilbeau Child Care Mulbury Bush Early Learning Center Neighborhood School House Reynolds Child Care Rice Child Care Sprague Child Care The Gathering Place Vernon Child Care West Bee Nursery School

a. MET: 3.b.1, 3.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 43

2.6.5 WTSA AM/FM (Primary EAS Station)

The news director/engineer demonstrated the stations capability of broadcasting important Emergency Alert System messages as well as Vermonts follow-on information messages. The station was also tied into the national weather stations for broadcasting weather alerts and other types of National Emergency Messages.

a. MET: 3.b.1, 5.a.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 2.6.6 Thompson House (Nursing Home)

The director and staff demonstrated their knowledge of their radiological emergency preparedness plans and procedures.

a. MET: 3.b.1, 3.c.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 3.0 SUPPORT JURISDICTIONS (VERMONT)

Emergency Worker Monitoring and Decontamination Facility Vermont support jurisdictions were not evaluated during the June 10, 2009, exercise.

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4.0 STATE OF NEW HAMPSHIRE 4.1 State Emergency Operations Center Considering that the Exercise went from Unusual Event to Site Area Emergency, the Command Staff worked together to make decisions that were usually made with a full staff in the Emergency Operations Center. Once the entire staff arrived, the Director held a briefing to ensure everyone was current on the emergency status.

The NH EOC Accident Assessment group performed like a well-oiled engine.

The group worked closely together and anticipated each others needs. Their outstanding performance and support allowed the EOC Radiation Health Technical Advisor (RHTA) the freedom he needed to interface with and provide needed information to his counterparts in the EOF and decision makers in the EOC.

a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.1, 2.b.2, 2.c.1, 3.b.1, 3.c.1, 3.d.1, 3.d.2, 5.a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 4.2 Emergency Operations Facility The New Hampshire EOF group worked effectively as a team. They actively sought clarification of information provided by the Utility and communicated well within the group.

The NH Monitoring Team Coordinator (MTC) was very knowledgeable regarding the NH Office of Community and Public Health (OCPH) Emergency Response Procedures. He interfaced well with the Vermont and Massachusetts field team coordinators and the NH State RSO. He positioned the NH field teams in a timely manner and correctly recorded field team data.

a. MET: 1.a.1, 1.d.1, 1.e.1, 2.a.1, 2.b.1, 3.a.1, 3.b.1, 4.a.2
b. DEFICIENCY: None 45
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 4.3 Joint Information Center The New Hampshire JIC tracked the important response activities and protective action recommendations, effectively passing along critical information to the gathered news media during a series of four news briefings. Initially hampered by a non-working fax machine, they developed a quick and effective work around until the problem was solved.
a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 4.4 State Police Troop C (Keene)

The Troop Commander and Duty Supervisor of Troop C, New Hampshire State Police, located in Keene, were professional and very knowledgeable of the procedures for ensuring emergency workers had appropriate dosimetry and KI, and for establishing, staffing, and managing traffic and access control points.

They routinely used their checklists and never hesitated to refer directly to appropriate plans and manuals to ensure they were saying and doing the correct thing. The decisions were responsive and timely and helped to ensure a successful demonstration of the Troops capabilities.

a. MET: 1.c.1, 1.d.1, 3.a.1, 3.b.1, 3.d.1, 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None 46
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 4.5 New Hampshire Field Teams 4.5.1 New Hampshire Field Team 1 The RADeCo H-809C air sampler was energized using a Black and Decker Model JU300CB Jump Starter. In the past, the air sampler was powered using the car battery, potentially exposing personnel to the engines moving parts such as the fan and belts. Additionally, exposure to battery acid was a possibility, requiring personnel to wear additional personal protective equipment. Using the jump starter eliminated hazards associated with work procedures and also potentially avoided complications associated with the car fan re-suspending deposited radioactive particulates.

A telephone list was used which included the cell phone numbers for each member of the three field monitoring teams as well as numbers to reach the Monitoring Team Coordinator (MTC). The region of South Western New Hampshire is very rugged and, in the past, has challenged communications; and low- band radio communications were, at best, spotty. Providing as many means as possible for field teams to communicate with each other and the MTC further increased the ability to provide critical field team data to those who needed it in order to make necessary public health decisions.

a. MET: 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.2, 4.a.3
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 4.5.2 New Hampshire Field Team 2 In the past the field monitoring teams had to open the hood of their vehicles and connect the air sampler to the vehicle battery and, while the vehicle was running, operate the air sampler while balancing it on the radiator and/or the top of the grille. The field monitoring teams were equipped with a portable jump starter capable of operating the air sampler for at least 2 air samples. This allowed the 47

team to pull an air sample without having to access the vehicle battery and without having to walk around the vehicle, making the air sampling process safer and more efficient.

a. MET: 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.2, 4.a.3
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 4.6 Warning Point The Warning Point State Police Shift Supervisor did a great job following the plans and procedures during the alert and notification. She was able to quickly access the appropriate forms and used the technology available to accurately provide the information.
a. MET: 1.a.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 5.0 RISK JURISDICTIONS (NEW HAMPSHIRE) 5.1 Chesterfield Emergency Operations Center The Chesterfield EOC was a well-coordinated and functional EOC. The EOC staff took the exercise seriously, and all participants performed efficiently and effectively with each other. The new EOC facility, in the town hall, meets the needs and space requirements of a functional EOC.
a. MET: 1.a.1, 1.b.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5a.1, 5.b.1 48
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 5.2 Hinsdale Emergency Operations Center The staff of the Hinsdale EOC demonstrated they could effectively carry out the duties assigned to them in their Emergency Plans to protect the health and safety of the citizens of Hinsdale. Though largely volunteer, the staff performed in a very professional manner during the exercise and demonstrated a thorough understanding and knowledge of their responsibilities.
a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 5.3 Richmond Emergency Operations Center The Richmond EOC was staffed with an experienced group of volunteers who were energetic and knowledgeable about the function and duties of the EOC.

Several participants were cross-trained in key positions. The staff worked well together and accomplished their job well.

The Richmond, NH, emergency response organization demonstrated a high degree of training, experience, and cooperation. Members shared responsibilities and worked as a team throughout the exercise.

a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.2, 3.d.1, 3.d.2, 5a.1
b. DEFICIENCY: None 49
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 5.4 Swanzey Emergency Operations Center The Town of Swanzey EOC was staffed with personnel who were experienced and knowledgeable in their procedures. The EOC activities were conducted professionally, and identified issues were effectively addressed. The Chairman of the Board of Selectmen and the Emergency Management Director worked well as a team to coordinate the EOC activities. Procedures were implemented in a timely manner.
a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: 3.b.1 ISSUE: 67-09-3.b.1-A-02 (Re-demonstrated)

CONDITION: Emergency workers were unfamiliar with potassium iodide policies and procedures. When interviewed, emergency workers were uncertain when to ingest KI, how long to take KI, and what the side effects were, etc.

POSSIBLE CAUSE: The RADEF Officer elected to omit the potassium iodide (KI) portion of his briefing guide telling the emergency workers to ignore the KI portion of their instruction sheets unless they were advised to take KI.

REFERENCE:

NUREG-0654, J.10.e EFFECT: Emergency workers could take KI at an inappropriate time, neglect to take KI, take it in improper doses, and/or fail to recognize side effects.

CORRECTIVE ACTION DEMONSTRATION: The RADEF Officer re-briefed the workers emphasizing the KI instructions. Follow-up interviews indicated that the personnel understood KI procedures, and side effects.

50

d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 5.5 Winchester Emergency Operations Center A Town of Winchester Selectman served at the Towns Emergency Management Director for this exercise. He provided excellent overall direction to his operations, planning, and logistics staffs located in the command and control area of the Towns Emergency Operations Center. He also encouraged his staff to be proactive and think ahead, enabling more timely response as conditions deteriorated at the VYNPS.
a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 5.6 Schools, Day Care Centers, and Nursing Home Facilities 5.6.1 School Administrative Unions (SAU)

Chesterfield Elementary School (SAU #27)

Hinsdale Elementary School (SAU #38)

Hinsdale High School (SAU #38)

Winchester Elementary School (SAU #38)

All school principals or designated staff demonstrated their knowledge and understanding of the schools radiological emergency preparedness plans and procedures. None of the schools had a potassium iodide program as the State of New Hampshire would conduct a precautionary transfer of students.

a. MET: 3.b.1, 3.c.2 51
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 5.6.2 Child Care Facilities Dreamland Day Care Julies Day Care Winchester Learning Center Child Care Directors and staff demonstrated knowledge of their radiological emergency preparedness plans.
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 5.6.3 Nursing Home Facilities Applewood Care & Rehabilitation Center This facility had 72 residents that were wheelchair bound. These residents presented special considerations for the Director of Nursing who conducts a variety of emergency responses during the year. The Director of Nursing demonstrated her knowledge of the Applewood Radiological Emergency Response Plans and Procedures.
a. MET: 3.c.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None 52
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 6.0 SUPPORT JURISDICTIONS (NEW HAMPSHIRE) 6.1 Keene Emergency Operations Center In the Keene EOC, the key city officials (Fire, Police, and Public Works Department) successfully demonstrated the ability to operate the EOC in support of an emergency at the Vermont Yankee Power Station. All participants immediately assumed their designated roles and took the exercise very seriously which generated a very positive experience for all. The EMD conducted regular staff briefings to the EOC which kept all the players heavily involved in the exercise. The EOC staff worked as a team to accomplish the mission at hand and contributed to the success of the exercise.
a. MET: 1.a.1, 1.b.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 6.2 Local Warning Point - Southwest New Hampshire District Fire Mutual Aid The South West New Hampshire District Fire Mutual Aid Dispatch Center (SWNHDFMA) was a full-time 24/7 operation dispatching 78 fire and EMS agencies in New Hampshire, Vermont, and Massachusetts. The on-duty personnel demonstrated excellent skills and coordination. During the Vermont Yankee Exercise they dispatched for actual emergency calls and an additional drill exercise for State Farm Prom Night in Dummerston, Vermont. The facility was state-of-the-art with extensive communications and computer capabilities.
a. MET: 1.c.1, 1.d.1, 1.e.1
b. DEFICIENCY: None 53
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 6.3 Transportation Staging Area - First Student Bus Company, Swanzey, NH This commercial entity took on the emergency response mission to support the evacuation of New Hampshire school children from the Vermont Yankee Emergency Planning Zone. The bus station manager and staff clearly demonstrated their knowledge of their radiological emergency plans and procedures.
a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 6.4 Cheshire County Dispatch - Cheshire County Sheriff Department The Cheshire County Dispatch Center was a well-equipped facility with modern computer technology and an extensive computer-controlled radio system. It was able to communicate with many different jurisdictions throughout the three-state area. The Cheshire County Dispatch personnel were well-trained and dedicated.
a. MET: 1.b.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 54
f. PRIOR ARCAs - UNRESOLVED: None 6.5 WKNE Radio Station The Director of Engineering for Monadnock Radio Group, parent company of WKNE Radio, was very knowledgeable of the requirements for being a primary EAS station, as well as the capabilities of the EAS equipment itself. The two broadcasters interviewed had a good understanding of the procedures to be followed in the event of EAS being used during an incident at the VYNPS.
a. MET: 5.a.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 6.6 Keene Reception Center - Keene High School This high school was new to the New Hampshire Radiological Emergency Preparedness Program. The building was such that one would think it was designed to be used for a reception center. Locations of operations rooms, locker rooms, registration rooms, and corridors were situated so that evacuee traffic flowed through the school building. The Keene Fire Department were key players. They employed a Unified Command with Emergency Management, Homeland Security, Health and Human Services, Keene Police Department, Red Cross, and school officials. The command and reception center staff executed an excellent reception center operation.
a. MET: 1.a.1, 1.b.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 6.a.1, 6.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: Three ISSUE: 67-05-6.a.1-A-18 55

CONDITION: After many attempts to check all the sensors, the portal monitor was not working properly. The portal monitor, TSA model TPM 703, ID# 703012, was declared inoperable.

POSSIBLE CAUSE: The portal monitor had been calibrated the month prior to the demonstration and may have been damaged during transport to the facility.

REFERENCE:

NUREG-9654, J.10.h, K.5.b EFFECT: The improper operation of the monitor would cause potentially contaminated evacuees from being properly detected.

RECOMMENDATION: Repair or replace the defective portal monitor. (Note: during the previous reception center evaluation, there was a similar issue with the portal monitor.)

SCHEDULE OF CORRECTIVE ACTIONS: A new Portal Monitor has been procured to replace the equipment that failed CORRECTIVE ACTION DEMONSTRATED: 2 Portal Monitors were available for evacuee and emergency worker initial monitoring.

One was set up for use in monitoring, and one was in reserve as a back-up. The primary unit functioned within manufacturers specifications and was marked with current calibration stickers. The back-up unit was available for use, but not set up. This corrects ARCA 67-05-6.a.1-A-18.

ISSUE: 67-05-6.a.1-A-19 CONDITION: A guide was stationed at the entrance doors handing each evacuee a public letter describing the process and that each person should shower within the next two or three days. This letter should have been a State Form 102A. However, those forms were in short supply, so the guide issued State Form 103A as well. State Form 103A was to be distributed by the secondary monitoring team when an evacuee was determined to be contaminated above the 300 cpm level established by the plans.

POSSIBLE CAUSE: A lack of thorough training or confusion on the part of the team members on the proper use of the form.

REFERENCE:

New Hampshire Plan Volume 8, Section 5.8, Figure 5.8.1.

56

EFFECT: Evacuees received the incorrect public letter. A guide was stationed at the entrance doors handing each evacuee a public letter describing the process and that each person should shower within the next two or three days. This letter should have been a State Form 102A. However, those forms were in short supply, so the guide issued State Form 103A as well. State Form 103A was to be distributed by the secondary monitoring team when an evacuee was determined to be contaminated above the 300 cpm level established by the plans. The secondary monitoring team didnt know that they were supposed to issue form 103A to any person determined to be contaminated by the portal monitoring team. This form explained that being identified as potentially contaminated, the individuals vehicle interior might have been contaminated as well, and a request would have been made to monitor the vehicles interior.

RECOMMENDATION: Review the plans and procedures and re-train the secondary monitoring team about the importance of the public letters. Also insure a sufficient supply of the forms is available.

SCHEDULE OF CORRECTIVE ACTIONS: This was a first demonstration of a newly revised procedure. Ongoing training will assure that this issue is discussed and that proper forms are distributed in the future.

CORRECTIVE ACTION DEMONSTRATED: All evacuees and emergency workers were given NH Form 102A at the door explaining Reception Center procedures. Adequate numbers of forms were on hand.

When exercise controller indicated a person triggered the portal monitor, the person was instructed to remove the green portion of the triage card received at the door and move on to secondary monitoring.

If a controller indicated the person was still contaminated, that person was given NH Form 103A explaining that contamination was still present on his/her body and what would be the proper decontamination procedures. The person was then directed to a decontamination station.

This corrected ARCA 67-05-6.a.1-A-19.

ISSUE: 67-05-6.b.1-A-20 CONDITION: Vehicles in which contaminated individuals traveled may not be checked for contamination or decontaminated if necessary.

57

POSSIBLE CAUSE: According to the plan, vehicle owners who have been found to be contaminated are to be encouraged to have their vehicles checked for contamination.

This advisory does not fully explain the consequences to the vehicle owners. It asks the owners to volunteer for the vehicle monitoring, yet the owners face having the vehicle impounded unless it can be proved clean.

REFERENCE:

NUREG-0654, K.5.b EFFECT: Vehicle owners who would otherwise be cooperative with monitoring and decontamination processes may block the procedures.

RECOMMENDATION: The advisory should mention that vehicles that transported contaminated individuals will be impounded until they are verified clean or decontaminated if needed.

SCHEDULE OF CORRECTIVE ACTIONS: This was the first evaluation of a newly revised procedure. BEM will review this issue and assure that Reception Center personnel are aware of the appropriate manner in which to deal with potentially contaminated vehicles.

CORRECTIVE ACTION DEMONSTRATED: When an evacuee or emergency worker was confirmed to be contaminated their vehicle information was transmitted via radio to the ICP where a Vehicle Monitoring Team was dispatched to find the vehicle and monitor it for possible contamination. The Teams followed their IPs and scanned areas of the vehicle as indicated in their IPs. They found contaminated areas on vehicle exteriors and interiors. Vehicles were properly marked and isolated with safety cones and tape.

Vehicle Monitoring Team results were transmitted via radio to the ICP where NH State Department of Health personnel assigned to the Reception Center ICP were informed and the Command Staff set up security for the contaminated vehicles with NH State Police.

NH Dept. of Health personnel interviewed indicated final disposition and decontamination of vehicles would be done by NH dept. of Health representatives at the NH SEOC.

f. PRIOR ARCAs - UNRESOLVED: One (from Vermont Yankee Plume Exercise 2005)

ISSUE: 67-05-6.a.1-A-17 58

CONDITION: Dosimetry briefings provided to male and female emergency workers at the Keene reception Center did not provide additional information about female workers making a declaration if they were or not pregnant.

POSSIBLE CAUSE: Oversight on the requirements of NRC Regulation 8-13.

REFERENCE:

NRC Regulation 8-13, FEMA NUREG 0654, Schedule K, NH RERP VOL. 10, Section 10-8 EFFECT: If a female emergency worker were pregnant and did not make that declaration, there might have been a chance that worker could come in contact with a level of exposure that could possibly damage the fetus.

RECOMMENDATION: Incorporate into the plan and procedures for dosimetry briefings a warning to female workers to make a declaration if they are/are not pregnant. There should also be a requirement to make that declaration in writing.

SCHEDULE OF CORRECTIVE ACTIONS: Training will highlight the need to include NRC Regulation 8-13 requirements for all emergency workers. (NOTE: Subsequent research indicates that NRC Regulatory Guideline 8-13 is advisory and not mandatory regulation.)

REASON ISSUE UNRESOLVED: (Results of 2009 Keene Reception Center Drill) ISSUE 67-05-6.a.1-A-17 is not corrected due to the inadequate dosimetry briefing given by a member of the dosimetry team. Although the information should be provided to emergency workers in a written format, the briefing is important to ensure all emergency workers understand the content. The evaluator approached the controller and discussed the incomplete briefing. The controller informed the dosimetry team and conducted training about the information in Section 10-8 of the NH RERP. The opportunity was given to re-demonstrate the dosimetry briefing. Again the radiological officer failed to cover all of the required/recommended items in Vol.

10, Section 10-8.

The following is a list of items that were not completed correctly:

1. No opportunity for pregnancy disclosure was addressed for the female workers. Section 10-8, Paragraph 5 needs to be rewritten in easy-to-understand language along with instructions as to what 59

a female should do in the event a DRD should reach .05 mR or higher.

2. Clear verbal instructions for filling out the Emergency Worker Information Form 305A (Dosimetry Report Form) were not provided.
3. After reading their DRDs, workers were not told to record their readings on the Emergency Worker Information Form.
4. The briefer was not clear as to what emergency worker reporting levels were. Emergency Workers were queried and stated they had no idea what the reporting levels meant or what they were to do.

Recommendation: Update the Rev 13 RERP Plan. Change VOL 10, Section 10-8, and identify in the plan that the information in Section 10-8 is in fact the script for a dosimetry briefing. Change Paragraph 5 about the effects of exposure to the fetus to a plain language definition easily understood by a lay emergency worker. Provide information concerning possible negative effects if a pregnant emergency worker receives an exposure above the .05 R value. Ensure the briefer clearly understands what is in the briefing so questions from emergency workers can be answered. Ensure that the reporting levels are clearly explained and easily understood as to what the emergency worker responsibilities are, including what the emergency worker is required to do when the workers DRD reaches each reporting level. Each emergency worker should acknowledge receipt of and understanding of the dosimetry briefing.

7.0 COMMONWEALTH OF MASSACHUSETTS 7.1 State Emergency Operations Center & 211 Information Line The leadership and staff of the Massachusetts State Emergency Operations Center (EOC) were proficient and proactive in providing statewide direction, control and coordination of off-site response activities. The forward-thinking staff planned for contingencies and closely coordinated with key emergency support function representatives and the risk jurisdictions, which enabled all parties to make complex decisions promptly. All State EOC staff demonstrated a degree of competence indicative of a well-trained organization.

The Massachusetts Department of Public Health Coordinator in consultation with the EOC Director clearly demonstrated a strong working relationship that resulted in clear and concise decisions. They exercised sound judgment and indicated a 60

constant concern for the safety of the Emergency Workers and general public at all times.

The Mass 211 Call Center activities were conducted in a new and recently renovated facility that was equipped with the latest in communications, displays and comforts to support a 24/7 mode of operation. The supervisor and staff were professional and demonstrated courteous services to callers and interacted in a timely and positive manner with their liaison in the SEOC. Positive and cooperative staff interactions also contributed to a very successful operation.

a. MET: 1.a.1, 1.b.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.1, 2.b.2, 2.c.1, 3.c.1, 3.d.1, 3.d.2, 5a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 7.2 Emergency Operations Facility The representatives from the MEMA and the MDPH who responded to the Vermont Yankee Emergency Operations Facility (EOF) worked well with staffs from Vermont, New Hampshire, and the licensee who were also deployed to the EOF. MDPH Radiation Control Program personnel worked as a team using the Nuclear Incident Advisory Team (NIAT) plan and procedures. All of the Massachusetts staff were well versed in their duties and responsibilities and performed their assigned tasks efficiently. The NIAT Director and the MEMA EOF Liaison provided the State Emergency Operations Center (SEOC) staff with timely information and recommendations.
a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.1, 3.a.1, 3.b.1, 4.a.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 61

7.3 Joint Information Center The Massachusetts State Public Information Officer (PIO) and his assistants did an outstanding job of organizing information received and distributing it in a timely manner to the media. They worked as an effective team with the public safety as their overall goal. The work was distributed evenly and fairly with all three contributing to the effort. All messages were documented and verified when necessary to assure that media information was timely and accurate. There was no evading of issues that were presented by media representatives or furnishing of information of questionable origin or veracity. Media questions were answered tactfully and completely by the PIO when possible, and unanswered questions were researched by the entire team for later consideration. Follow-up to previous questions was complete, and no media representatives were treated unfairly or in an antagonistic manner. Press briefings were given on a regular basis and sometimes were announced in advance. Briefings were concise and to the point, and all media representatives were given ample opportunity to ask pertinent questions.

a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 7.4 Massachusetts State Police 7.4.1 State Police Shelburne Dispatch Warning Point The Massachusetts State Police (MSP) Shelburne Control staff demonstrated their ability to receive and transmit critical information from their location with no undue delay. The performance of their duties was highly professional and reflected credit to their organization.

The MSP Troopers in Shelburne demonstrated knowledge of the EPZ town contingency plans in the event any of the towns could not provide emergency management services and communications to the EPZ townspeople. They also issued proper dosimetry to two MSP Troopers and provided the appropriate information concerning dosimetry reading, recording reading changes along with turn-back values, and the required 62

actions. The Radiological Officer provided the appropriate briefing to two female troopers on the trooper declaration in case the female troopers were pregnant.

a. MET: 1.a.1, 1.c.1, 1.d.1, 3.a.1, 3.b.1, 3.d.1, 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 7.4.2 State Police Troop B Northampton Dispatch Northeast Through interview, Troop B Headquarters demonstrated knowledge of implementing the Traffic Access Control point plans along Route 2 and Interstate 91. They explained that they would have requested assistance in obtaining traffic cones, signs and barriers from Mass Highway, District 2 in Northampton. The MSP Troop B Rad Officer issued dosimetry to two troopers and conducted an excellent briefing emphasizing how to read the dosimeters and how often to record any reading changes on the exposure record form. The MSP Rad Officer also briefed one female trooper on NRC Regulation 8-13 and obtaining a declaration that she was not pregnant. He also stated that should a VY incident occur, dosimetry would have been issued to troopers in the field.
a. MET: 1.c.1, 1.d.1, 3.a.1, 3.b.1, 3.d.1, 3.d.2
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 7.5 Massachusetts Field Teams 7.5.1 Massachusetts Field Team 1 63

The Field Monitoring Team (FMT) No.1 staff was very knowledgeable, professional, and worked very well together. Both team members were very meticulous and thorough while collecting samples and recording data. They were familiar with all sampling procedures and knowledgeable on contamination control. Inter-team support also was demonstrated when the EOF had difficulty communicating with FMT 2. Recognizing the problem, FMT 1 supported FMT 2 by relaying information from the EOF to FMT 2. All members of FMT 1 and FMT 2 recognized the communication problems and worked together with the EOF Communicator to solve them. Their past working experience was evident in their performance.

a. MET: 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.2, 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 7.5.2 Massachusetts Field Team 2 The members of NIAT Field Monitoring Team No. 2 demonstrated excellent technique in ensuring that their monitoring data was accurately recorded on data forms and accurately reported to the Vermont Yankee EOF over the radio. The data forms were legible and complete, and radio protocol used to report data was effective and included careful confirmation of information. This good communications discipline was helpful in overcoming intermittent radio problems encountered by the team due to weak radio signal strength and communication dead spots.
a. MET: 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.2, 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 64

7.6 Massachusetts Emergency Management Agency Region III/IV The coordination and communication flowed seamlessly within the MEMA Region III/IV EOC. The Manager and Technological Hazards Specialist were knowledgeable of plant conditions, plans and procedures, and communicated coordinated guidance to all those in the EOC. Their management style provided diplomatic correction when needed.

The MSP and MHD personnel assigned to the Region III/IV EOC exhibited good cooperation and coordination with each other. They were physically located next to each other, which facilitated coordination. They were knowledgeable in their own roles and missions and those of the other agency in responding to the needs to deploy traffic control points and respond to other emerging issues during the exercise.

a. MET: 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.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 7.7 Executive Office of Environmental Affairs 7.7.1 Department of Conservation and Recreation - Division of State Parks and Recreation - Fire District Nine (Evaluated in 2007) 7.7.2 Office of Law Enforcement The Office of Law Enforcement played an integral part in the alert and notification system along the Connecticut River south of the New Hampshire border to the Irving Dam by notifying all campers along the river banks and on the islands who may not have had radio or television communications to hear about a Vermont Yankee NPS incident.
a. MET: 1.d.1, 1.e.1, 3.a.1, 3.b.1, 5.a.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None 65
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 8.0 RISK JURISDICTIONS (MASSACHUSETTS) 8.1 Bernardston Emergency Operations Center The Town of Bernardston was a tightly knit community, and the EOC and took pride in the work that they did. Discussions on the events that were unfolding and how to best approach issues occurred frequently. Three Selectman participated in the exercise, showing their commitment not only for the Town of Bernardston, but for the Radiological Emergency Preparedness program as well. Additionally, the level of training and familiarity with procedure was evident by their level of professionalism and ability to respond to the incident.

Command and Control was very effective with the EMD carefully reviewing past and current events and requesting updates and unmet needs from each of the ESFs during briefings. The Fire Chief demonstrated a thorough review of the special needs groups and coordinated effectively with the Highway Department and Region III/IV to provide required transportation. The Communications Officer was very busy but managed to keep all communications logged, accurate, and timely.

a. MET: 1.a.1, 1.b.1, 1.c.1, 1.d.1, 1.e.1, 2.c.1, 3.a.1, 3.b.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 8.2 Colrain Emergency Operations Center The Colrain EOC staff displayed an admirable commitment to the performance of their responsibilities. The safety and welfare of the residents of their town was always predominant when carrying out tasks associated with responding to this 66

exercise. It was apparent that the staff was knowledgeable in their assigned duties and worked well together.

The Colrain EOC was well-equipped for the needs of the town. All emergency responders were very professional and motivated to accomplish the task at hand.

The newly appointed Emergency Management Director handled his inexperience very well and greatly benefited from the exercise. His showed leadership by involving other officers of his staff in finding out the answer he needed.

a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 8.3 Gill Emergency Operations Center Members of the Gill EOC were knowledgeable and professional as they worked towards a common goal. The EMD was confident in his actions,m and the staff members focused on their individual tasks. Members of the staff were comfortable in sharing information and ideas with others. There was a positive esprit de corps by the EOC staff.
a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 8.4 Greenfield Emergency Operations Center 67

The Greenfield EOC was a knowledgeable, proactive response organization. They worked well together and made good use of plans and procedures. All demonstrated a sincere concern for the safety of the citizens in their community.

The Emergency Management Director was especially thorough in accomplishing his Direction and Control responsibilities.

a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 8.5 Leyden Emergency Operations Center The Emergency Management Director (EMD) at the Leyden Emergency Operations Center (EOC) did an exemplary job of direction and control during this exercise. The EMD was always one step ahead of the situation, making sure that all EOC staff members were prepared to act if the emergency progressed. He was extremely thorough in communicating to his staff all information received, and the interactions between the EMD and EOC staff members represented excellent teamwork. The dedication of the EOC to the health and safety of the residents of Leyden was evident in every action taken.
a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 8.6 Northfield Emergency Operations Center 68

Emergency Management Staff worked well together under less than ideal physical conditions. Some staff demonstrated exceptional personal initiative by responding to the EOC proactively, prior to receiving individual call-out as they routinely monitored radio and pager traffic. The EOC was somewhat small for the task at hand; however, the staff performed harmoniously, professionally, and efficiently.

The Northfield EOC Dosimetry Coordinator did an excellent job with the emergency worker briefing. She read all of the information from a prepared sheet to the workers. All three workers were able to answer questions at the conclusion of the briefing without referring to cue cards given to them along with their dosimetry.

a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 8.7 Warwick Emergency Operations Center The Warwick EOC was mobilized at the NOUE by reporting to the Fire Station.

All responders worked together as a well-coordinated team. All response procedures were implemented very smoothly and efficiently. The staff worked together in a professional manner and was knowledgeable of their respective responsibilities. All group leaders appropriately coordinated their respective decisions with others in the EOC. The Radiological Officer gave a good demonstration of emergency worker exposure control, and the EMD handled the direction and control function very well.

a. MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b.1
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None 69
f. PRIOR ARCAs - UNRESOLVED: None 8.8 Schools, Day Care Centers, and Nursing Home Facilities 8.8.1 Mohawk Trail Regional School District Superintendents Office Colrain Central Elementary School The Administrative Assistant in the Superintendents Office and the Principal at the Colrain Central Elementary School both had written plans and procedures and demonstrated their knowledge of the plans through interview. The nurse at the Colrain School displayed the potassium iodide (KI) they had in stock as well as the parental permission slips for the ingestion of KI. The principal knew the number of buses needed to evacuate the children from the school if necessary. The principal knew the telephone numbers of the local EMD in Colrain.
a. MET: 3.c.1, 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 8.8.2 Private Schools Giving Tree Pre-School - Gill Northfield Mount Herman - Gill Linden Hill School - Northfield Through interview, the School Directors demonstrated knowledge of the applicable radiological emergency response plans and procedures. They knew the EMD location of the town EOC, the telephone number of the supporting bus company, and the transportation coordination in the applicable town EOC. The medical staffs at each of the schools displayed the potassium iodide (KI) that they had on hand, their distribution plan, and the authorizations for issue of KI.
a. MET: 3.c.1, 3.c.2 70
b. DEFICIENCY: None
c. AREAS REQUIRING CORRECTIVE ACTION: None
d. NOT DEMONSTRATED: None
e. PRIOR ARCAs - RESOLVED: None
f. PRIOR ARCAs - UNRESOLVED: None 8.8.3 Camps Camp Keewanee Camp Lion Knoll Northfield Bible Conference These camps, a mixture of day and residential camps during the summer season, usually rotated attendance on a weekly basis. All three Camp Directors displayed their applicable radiological emergency response plan and through interview demonstrated their knowledge of their plan(s). They knew the local EMD and telephone number, local transportation coordinator, and the number of buses needed should they have to evacuate from the camp. These Directors opted out of the potassium iodide (KI) program because of the turnover of campers every week.
a. MET: 3.c.1, 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 9.0 SUPPORT JURISDICTIONS (MASSACHUSETTS) 9.1 School Bus Transportation - First Student Bus Company, Shelburne Falls First Student demonstrated (simulated) taking students from the Colrain Central Elementary School to the Greenfield Community College in Greenfield, MA. The Radiological Officer from Colrain came to the school and issued dosimetry to the 71

bus driver. The Radiological Officer conducted the dosimetry briefing in an excellent manner. Because the driver was female, she was given the required briefing and information regarding pregnancy declaration. The driver was issued a map with instructions on driving to the Greenfield Community College (GCC).

The driver proceeded along the specified route without mishap and arrived at the GCC.

a. MET: 3.b.1, 3.c.1, 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 72

APPENDIX 1:

Acronyms and Abbreviations A&N Alert and Notification AAT Accident Assessment Team ACP Access Control Point ARC American Red Cross ARCA Area Requiring Corrective Action ARES Amateur Radio Emergency Services CCC Congregate Care Center CDD Civil Defense Director CF Cubic Feet CFM Cubic Feet per Minute CFR Code of Federal Regulations CPM Counts per Minute DEM Department of Environmental Management DFG Department of Fish and Games DOT U.S. Department of Transportation DPHS Division of Public Health Services DPW Department of Public Works DRD Direct Reading Dosimeter EA Evaluation Area EAL Emergency Action Level EAS Emergency Alert System EBS Emergency Broadcast System ECL Emergency Classification Level EM Emergency Management EMA Emergency Management Agency EMD Emergency Management Director EMS Emergency Medical Services EMT Emergency Medical Technician EOC Emergency Operations Center EOF Emergency Operations Facility EPA U.S. Environmental Protection Agency EPI Emergency Public Information EPZ Emergency Planning Zone ERO Emergency Response Organization ERP Emergency Response Plan EW Emergency Worker 73

FDA U.S. Food and Drug Administration FEMA Federal Emergency Management Agency FEMA HQ Federal Emergency Management Agency Headquarters FEMA RI Federal Emergency Management Agency Region I FMT Field Monitoring Team FR Federal Register FTC Field Team Coordinator GE General Emergency ICF ICF Consulting IFO Incident Field Office JIC Joint Information Center KI Potassium Iodide MA Massachusetts MARERP Massachusetts Radiological Emergency Response Plan MDPH Massachusetts Department of Public Health MEMA Massachusetts Emergency Management Agency METPAC Meteorological Plume Assessment Computer mR milliroentgen mR/h milliroentgen per hour MSP Massachusetts State Police MTC Monitoring Team Coordinator NAS Nuclear Alert System NH New Hampshire NHDOT New Hampshire Department of Transportation NHOCPH New Hampshire Office of Community Public Health NHDSFSEM New Hampshire Department of Safety, Fire Safety and Emergency Management NHOHM New Hampshire Office of Health Management NHRERP New Hampshire Radiological Emergency Response Plan NIAT Nuclear Incident Advisory Team NID Nuclear Information Director NMC News Media Center NOAA National Oceanic and Atmospheric Administration NOUE Notification of Unusual Event NPS Nuclear 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 OEM Office of Emergency Management ORO Offsite Response Organization OSC On-Scene Coordinator PAD Protective Action Decision PAR Protective Action Recommendation PHAAP Public Health Accident Assessment Program 74

PIO Public Information Officer R Roentgen RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Service RADEF Radiological Defense REM Roentgen Equivalent Man REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RHTA Radiological Health Technical Advisor SAE Site Area Emergency SAV Staff Assistance Visit SEOC State Emergency Operations Center SRM Site Recovery Manager SWNHDFMA Southwest New Hampshire District Fire Mutual Aid TCP Traffic Control Point TDD Telecommunications Device for the Deaf TL Team Leader TLD Thermoluminescent Dosimeter TSC Technical Support Center TTY Teletypewriter UE Unusual Event UHF Ultra High Frequency USDA U.S. Department of Agriculture VEM Vermont Emergency Management VRERP Vermont Radiological Emergency Response Plan VSP Vermont State Police VT Vermont VY Vermont Yankee VYNPS Vermont Yankee Nuclear Power Station 75

APPENDIX 2:

Exercise Evaluators and Team Leaders The following is a list of the personnel who evaluated the Vermont Yankee Nuclear Power Station exercise on June 10, 2009 and the associated out-of-sequence activities. Evaluator Team Leaders (TL) and Assistant Team Leaders (ATL) are indicated by the letters after their organizations name. The organization each evaluator represents is indicated by the following abbreviations:

FAA Federal Aviation Administration FEMA Federal Emergency Management Agency ICF ICF International NRC U.S. Nuclear Regulatory Commission EVALUATION SITE EVALUATOR ORGANIZATION STATE OF VERMONT State Emergency Operations Center R. Swartz FEMA RI D. Carlton FEMA RI R. Vork ICF J. Hickey ICF G. Goldberg ICF A. Miron ICF Vermont Dispatch Unit - Rockingham, VT N. Costa FEMA RI Vermont Dispatch Unit - Derby, VT S. Nelson ICF Vermont United Way 211 Call Center R. Duggleby ICF Emergency Operations Facility D. Seebart ICF A. Bevan ICF Joint Information Center H. Christiansen ICF Vermont Tracking Teams R. Biernacki ICF J. Ziedler ICF Incident Field Office (Dummerston) Roy Smith ICF W. Gawlak ICF M. Stuart FEMA RI 76

EVALUATION SITE EVALUATOR ORGANIZATION RISK JURISDICTIONS (Vermont)

Brattleboro L. Sosler ICF D. Petta ICF Dummerston T. Blackmon ICF N. Costa FEMA RI Guilford R. Samsel ICF R. Bonner ICF Halifax Q. Iannazzo ICF C. McCoy ICF Vernon G. Kinnear ICF R. Fontenot FEMA Hq.

SCHOOLS, CHILD CARES and NURSING HOMES Windham South West Supervisory Union -

Superintendents Office R. Swartz FEMA RI D. Carlton FEMA RI Halifax West School R. Swartz FEMA RI D. Carlton FEMA RI Dummerston Elementary School R. Swartz FEMA RI D. Carlton FEMA RI Guilford Central School R. Swartz FEMA RI D. Carlton FEMA RI Vermont Center for The Deaf

& Hard of Hearing School - Private R. Swartz FEMA RI D. Carlton FEMA RI 77

EVALUATION SITE EVALUATOR ORGANIZATION Meadows School R. Swartz FEMA RI (located Brattleboro Retreat) D. Carlton FEMA RI Brattleboro Child Care R. Swartz FEMA RI D. Carlton FEMA RI Guilford Child Care R. Swartz FEMA RI D. Carlton FEMA RI Dummerston Child R. Swartz FEMA RI D. Carlton FEMA RI Halifax Child Care R. Swartz FEMA RI D. Carlton FEMA RI Vernon Child Care R. Swartz FEMA RI D. Carlton FEMA RI Thompson House R. Swartz FEMA RI D. Carlton FEMA RI Thompson House Residence R. Swartz FEMA RI D. Carlton FEMA RI The Gathering Place R. Swartz FEMA RI D. Carlton FEMA RI Brattleboro Retreat R. Swartz FEMA RI D. Carlton FEMA RI STATE OF NEW HAMPSHIRE State Emergency Operations Center W. Gaudet FEMA RI M. Herndon ICF NH 211 Info Line J. McClanahan ICF NH State Warning Point D. Solomon ICF 78

Emergency Operations Facility VT M. Henry ICF D. Jacobson ICF Joint Information Center VT T. Hegele ICF State Police Troop C, Keene C. Spangenberg ICF Cheshire County Dispatch J. Flynn ICF (Cheshire County Sherriffs Dept.)

Radiological Field Teams Team 1 T. Honnellio EPA RI Team 2 M. Leal FDA RI Radio Station - WKNE C. Spangenberg ICF RISK JURISDICTIONS (New Hampshire)

Chesterfield D. Kayen ICF C. Wentzell ICF Hinsdale R. Gannt ICF M. Burriss ICF Richmond D. Blunt ICF R. McPeak ICF 79

EVALUATION SITE EVALUATOR ORGANIZATION Swanzey R. Rodgers ICF J. Greer ICF Winchester R. Black ICF R. Smith ICF NH Schools Supervisory Administrative Union #38 R. Swartz FEMA RI Chesterfield Elementary School R. Swartz FEMA RI Hinsdale Elementary School R. Swartz FEMA RI Hinsdale R. Swartz FEMA RI High School R. Swartz FEMA RI Winchester Elementary School R. Swartz FEMA RI NH Child Cares Julies Day Care - Hinsdale R. Swartz FEMA RI Dreamland Day Care - Winchester R. Swartz FEMA RI The Winchester Learning Center -

Winchester R. Swartz FEMA RI NH Nursing Homes Applewood Care and Rehabilitation Center Winchester R.Swartz FEMA RI Transportation Staging Area (Swanzey) R. Swartz FEMA RI First Student Bus Company D. Carlton FEMA RI P. Foster FEMA RI T. Hollins FEMA RI H. LaForge FEMA RI SUPPORT JURISDICTIONS (New Hampshire)

Keene Emergency Operations Center R. Grundstrom ICF W. Palmer ICF Southwest NH District Fire Mutual Aid J. Flynn ICF 80

EVALUATION SITE EVALUATOR ORGANIZATION COMMONWEALTH OF MASSACHUSETTS State Emergency Operations Center T. Hollins FEMA RI M. Meshenberg ICF W. Swygert ICF K. Tosch ICF 211 Info Line D.White ICF Emergency Operations Facility VT J. Keller ICF Joint Information Center VT M. Dalton ICF State Police Troop B, Northampton R. Swartz FEMA RI State Police, Shelburne G. Bolender ICF Radiological Field Teams Team 1 E. Scholenberger ICF Team 2 N. DePierro ICF Region III/IV Emergency J. Rice FEMA RI Operations Center G. Banner HHS RI H. LaForge FEMA RI P. Foster FEMA RI RISK JURISDICTIONS (Massachusetts)

Bernardston P. Neid ICF O. Grady-Erickson ICF Colrain G. Bolender ICF P. Gardner ICF Gill R. Lemeshka ICF B. Swiren ICF Greenfield S. Eischen ICF H. Ryals ICF 81

EVALUATION SITE EVALUATOR ORGANIZATION Leyden N. Johnson ICF T. Davidson ICF Northfield W. OBrien ICF M. Petullo ICF Warwick D. Wessman ICF E. Boaze ICF Massachusetts Schools Mohawk Trail Regional School District Superintendents Office R. Swartz FEMA RI Colrain Central School R. Swartz FEMA RI Giving Tree School (Private) R. Swartz FEMA RI SUPPORT JURISDICTIONS (Massachusetts)

School Bus Transportation, First Student R. Swartz FEMA RI Host Schools (Not Evaluated in 2009)

Greenfield Community College-Greenfield Reception Center (Not evaluated 2009)

KI Dispensing Site (Not Evaluated in 2009) 82

APPENDIX 3:

Exercise Evaluation Area Criteria and Extent of Play Agreement This appendix contains the exercise criteria that were scheduled for demonstration in the Vermont Yankee Nuclear Power Station exercise on June 10, 2009, and the extent-of-play agreement approved by FEMA Region I in May 2009.

The Evaluation Areas contained in the Federal Register Notice; Federal Emergency Management Agency - Radiological Emergency Preparedness: Exercise Evaluation Methodology, published on September 12, 2001, and amended on April 25, 2002, represent a functional translation of the planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for the Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, November 1980.

Because the exercise 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(s) and approved by FEMA to provide evaluators with guidance on expected actual demonstration of the evaluation area criteria.

A. Exercise Criteria Listed below are the specific radiological emergency preparedness criteria scheduled for demonstration during this exercise.

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

Sub-Element 1.b - Facilities Criterion 1.b.1: Facilities are sufficient to support the emergency response. (NUREG-0654, H.3)

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

Sub-Element 1.d - Communications Equipment 83

Criterion 1.d.1: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations. (NUREG-0654, F.1, 2)

Sub-Element 1.e - Equipment and Supplies to Support Operations Criterion 1.e.1: 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)

EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-Element 2.a - Emergency Worker Exposure Control Criterion 2.a.1: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides. (NUREG-0654, J.10.e, f; K.4)

Sub-Element 2.b - Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency Criterion 2.b.1: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654, I.8, 10 and Supplement 3)

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

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

EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-Element 3.a - Implementation of Emergency Worker Exposure Control Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. (NUREG-0654, K.3.a, b) 84

Sub-Element 3.b - Implementation of KI Decision Criterion 3.b.1: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals is maintained. (NUREG-0654, J.10.e)

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

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

(NUREG-0654, J.10.c, d, g)

Sub-Element 3.d - Implementation of Traffic and Access Control Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654, J.10.g, j)

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

EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS Sub-Element 4.a - Plume Phase Field Measurements and Analyses Criterion 4.a.1: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates.

(NUREG-0654, H.10; I.7, 8, 9)

Criterion 4.a.2: Field teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654, H.12; I.8, 11; J.10.a)

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

EVALUATION AREA 5: EMERGENCY NOTIFICATION AND PUBLIC INFORMATION Sub-Element 5.a - Activation of the Prompt Alert and Notification System Criterion 5.a.1: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initial instructional message to the 85

public must include as a minimum the elements required by current FEMA REP guidance. (10 CFR Part 50, Appendix E.IV.D; NUREG-0654, E.5, 6, 7)

Sub-Element 5.b - Emergency Information and Instructions for the Public and the Media Criterion 5.b.1: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E.5, 7; G.3.a, G.4.c)

EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES Sub-Element 6.a - Monitoring & Decontamination of Evacuees and Emergency Workers and Registration of Evacuees Criterion 6.a.1: The reception center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers. (NUREG-0654, J.10.h; J.12; K.5.a) 86

CONSOLIDATED - MA/NH/VT EVALUATION AREAS AND EXTENT OF PLAY VERMONT YANKEE NUCLEAR POWER STATION EXERCISE JUNE 10, 2009 87

EVALUATION AREA 1: Emergency Operations Management Sub-element 1.a - Mobilization Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to alert, notify, and mobilize emergency personnel and to activate and staff emergency facilities.

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

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

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

Massachusetts Extent of Play State EOC: SEOC emergency staff who normally work at the SEOC will report to work at their usual time unless they are notified and directed to report for duty. SEOC emergency staff who do not normally work at the SEOC will use a compressed reporting time of 10 minutes/hour of normal travel.

Region III/IV EOC: REOC emergency staff who normally work at the REOC will report to work at their usual time unless they are notified and directed to report for duty. REOC emergency staff who do not normally work at the SEOC will use a compressed reporting time of 10 minutes/hour of normal travel.

EOF: MEMA and MDPH emergency staff will be in the area of the EOF awaiting notification.

Once notified to report, they will use a compressed reporting time of 10 minutes/hour of normal travel.

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Joint Information Center: MEMA and emergency staff will be in the area of the JIC awaiting notification. Once notified to report for duty, they will use a compressed reporting time of 10 minutes/hour of normal travel.

EPZ Local EOCs: LEOC emergency response staff will use a compressed reporting time of 10 minutes/hour of normal travel.

NIAT Field Monitoring Team Personnel: NIAT Field Team emergency response staff will use a compressed reporting time of 10 minutes/hour of normal travel.

Massachusetts State Police Troop B-2 Dispatch Center, Shelburne Control: Will notify MA towns.

Regional School District Superintendents Offices: Initial calls will be made from the Superintendents Office to schools within their jurisdiction.

New Hampshire Extent of Play Rosters for 2nd shift personnel will be available for all facilities/locations staffed on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis.

Emergency facilities will be alerted in accordance with the NHRERP. Those facilities that are to participate in the exercise will mobilize accordingly. Rosters for relief shifts will be available in each participating facility. Those facilities that are not participating will acknowledge receipt of notification, but will take no further action. Controllers will simulate facilities not participating.

Vermont Extent of Play Rosters for 2nd shift personnel will be available for all facilities/locations staffed on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis.

Real time notification of emergency response staff will be demonstrated during this exercise with the following exceptions:

The Nuclear Engineer will be in Brattleboro or Vernon in the normal course of his duties and will deploy to the EOF when he is paged out.

If there are any responders to other facilities that would have more than a 1-hour drive, they will go to a designated mobilization staging area and await the notification before deploying.

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

Criterion 1.b.1: Facilities are sufficient to support the emergency response. (NUREG-0654, H.3)

Extent of Play Facilities will only be specifically evaluated for this criterion if they are new or have substantial changes in structure or mission. Responsible OROs should demonstrate the availability of facilities that support the accomplishment of emergency operations. Some of the areas to be considered are adequate space, furnishings, lighting, restrooms, ventilation, backup power and/or alternate facility (if required to support operations). However, FEMA will evaluate all facilities, as a baseline, during the first exercise under the new Evaluation Criteria.

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

Massachusetts Extent of Play The new Bernardston EOC will be evaluated under this criterion.

New Hampshire Extent of Play The new State EOC in Concord will be evaluated under this criterion.

The following facilities will be demonstrating their capabilities: State EOC, EOF, IFO, Joint Information Center, and Municipal EOCs in Hinsdale, Winchester, Chesterfield, Richmond, Swanzey, and Keene (host).

The following facilities will demonstrate their capabilities out-of-sequence: State Transportation Staging Area (STSA) and Schools.

Vermont Extent of Play The following facilities are new or have an expanded role and will be evaluated under this criterion:

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The Rockingham Public Safety Answering Point (PSAP) was the alternate State Warning Point for only RERP issues but is now the primary State Warning Point (SWP) for most Vermont Emergency Management issues. The previous SWP at Headquarters in Waterbury, VT has been closed.

The Derby Public Safety Answering Point (PSAP) is now the alternate State Warning Point for most Vermont Emergency Management issues.

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

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

(NUREG-0654, A.1.d; A.2.a, b)

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

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

Massachusetts Extent of Play EPZ EOCs: If any towns are directed to evacuate, EOC personnel will demonstrate continuity of government through a discussion of logistics. Closing of the local EOC and relocation to a facility outside the EPZ will be simulated through discussion.

New Hampshire Extent of Play Participating state and local facilities will demonstrate their ability to direct and control emergency operations in accordance with the NHRERP.

Vermont Extent of Play State EOC- Communications with the Governor and his staff will be simulated where necessary.

EPZ Town EOCs- If any towns are directed to evacuate, EOC personnel will simulate closing and transfer of their operation to the Incident Field Office and demonstrate continuity of government through a discussion. All appropriate communications with the State EOC and the IFO will continue to be demonstrated at the town EOC.

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ARCA:

ISSUE: 67-07-1.c.1-A-02 CONDITION: The Vermont field monitoring teams at the IFO, located at the Vermont Transportation Garage, Dummerston, were deployed to the field to conduct field monitoring activities at the direction of the Field Team Director (FTD) located at the Vermont Yankee (VY)

Emergency Operations Facility (EOF). The direction was given to evacuate the IFO while the teams were conducting the field monitoring. The IFO was then, notionally evacuated. The field teams were not given the evacuation order/information.

ARCA:

ISSUE: 67-05-1.c.1-A-02 (Scheduled for 2011 Ingestion Pathway Exercise)

CONDITION: During the Ingestion Phase portion of the exercise on Day 3, The incident Field Office only had the Exclusion Map. They were unaware of other maps showing the food control zones as established for restricting access into the Exclusion Zone (restricted area). It was the IFOs understanding that the Exclusion Zone was the same area as the food control and that access control for the exclusion area was also the food control zone 93

Sub-element 1.d - Communications Equipment Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) should establish reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as the following:

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

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

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

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

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

NOTE: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant. After an on the spot re-training by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

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Massachusetts Extent of Play Contact with locations not playing will be simulated.

New Hampshire Extent of Play Pursuant to the NHRERP, facilities participating in this exercise will demonstrate their primary and a back up communications systems. Other communications systems and capabilities may also be used.

ARCA:

ISSUE: 67-05-1.d.1-A-13 CONDITION: The radio system encountered intermittent and frequent loss of radio communication while in transit due to the local terrain. The procedure section on communications directs the team to contact the Monitoring Team Coordinator (MTC) at least hourly. This required the team to occasionally leave their assigned area and find an area where transmission via radio was possible. Additionally, pay phones are difficult to find especially with the advancement of cellular/digital technology.

Communications with the Monitoring Team Coordinator (MTC) were interrupted for several periods during the exercise. This included one period of over one hour (1255 to 1440) when the Field Monitoring Team (FMT) #1 was unable to make contact with the MTC as required by their procedure.

Vermont Extent of Play All facilities (State EOC, SWPs, IFO, Town EOCs, and EOF) will demonstrate that a primary and at least one backup system are fully functional. For all above facilities, contact with locations or organizations that are not participating in the exercise or are demonstrating out of sequence will be simulated by placing an entry in the log at the appropriate time(s) in the exercise unless otherwise noted.

The following chart represents the primary and secondary communications between the State EOC and the listed facility:

FACILITY PRIMARY BACK UP ADDITIONAL Incident Field Office EPZ Radio 45.52. MHz Commercial Phone RACES Radio, FAX, Disaster LAN, NAS phone Joint Information Center Commercial Phone FAX Disaster LAN Emergency Operations EPZ Radio 45.52. MHz & Commercial Phone RACES & Disaster LAN, Facility (VT) FAX, & FMT Freq.

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FACILITY PRIMARY BACK UP ADDITIONAL Brattleboro EPZ Radio 45.52. MHz Commercial Phone RACES Radio,, Disaster LAN, FAX Dummerston EPZ Radio 45.52. MHz Commercial Phone RACES Radio, , Disaster LAN, FAX Guilford EPZ Radio 45.52. MHz Commercial Phone RACES Radio,, Disaster LAN, FAX Halifax EPZ Radio 45.52. MHz Commercial Phone RACES Radio,, Disaster LAN, FAX Vernon EPZ Radio 45.52. MHz Commercial Phone RACES Radio,, Disaster LAN, FAX BFUHS Reception Center EPZ Radio 45.52. MHz Commercial Phone, FAX RACES Radio Public Inquiry, 211* Commercial Phone FAX, Disaster LAN Rockingham SWP Commercial Phone FAX Disaster LAN Derby ASWP Commercial Phone FAX Disaster LAN Note: The BFUHS Reception Center was successfully evaluated in December 2008.

Note: United Way 211 provides the public multiple ways to reach them with a question or comment. The Public Inquiry line 800-736-5530 is forwarded to 211 in an emergency. The public can dial 211, and any persons who call E-911 with an emergency related, but not life threatening question or comment, will be referred to 211.

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

Criterion 1.e.1: 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 OROs 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 manufacturers recommendations.

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

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

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

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

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

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

Pharmacopoeia standards.

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

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

NOTE: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant. After an on the spot re-training by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

Massachusetts Extent of Play FEMA will provide copies of the Annual Letter of Certification to evaluators, as appropriate.

New Hampshire Extent of Play FEMA will provide copies of the Annual Letter of Certification to evaluators as appropriate.

Pursuant to the NHRERP, facilities participating in this exercise will demonstrate the equipment, maps, displays, dosimetry, potassium iodide (KI) and other supplies available to them.

Vermont Extent of Play FEMA will provide copies of the Annual Letter of Certification to evaluators, as appropriate.

Instrument data will be an attachment to the Annual Letter of Certification.

Pursuant to the VTRERP, facilities participating in this exercise will demonstrate the equipment, maps, displays, dosimetry, potassium iodide (KI) and other supplies available to them. Some procedures state that if kit boxes are sealed and have an inventory form attached, the teams do not need to perform an additional inventory prior to deployment. Instrument calibration certificates are on file at both VT Emergency Management Offices and can be viewed by FEMA evaluators.

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

Radiation exposure limits for emergency workers are the recommended accumulated dose limits or exposure rates that an emergency worker may be permitted to incur during an emergency.

These limits include any pre-established administrative reporting limits (that take into consideration Total Effective Dose Equivalent or organ-specific limits) identified in the OROs plans and procedures.

Criterion 2.a.1: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides. (NUREG-0654, K.4; J.10.e, f)

Extent of Play OROs authorized to send emergency workers into the plume exposure pathway EPZ should demonstrate a capability to meet the criterion based on their emergency plans and procedures.

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

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

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

Massachusetts Extent of Play There will be no exceptions to this sub-element in the Massachusetts Extent of Play.

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New Hampshire Extent of Play This Evaluation Area will be demonstrated in accordance with the NHRERP by appropriate facilities that participate in the exercise.

Vermont Extent of Play There will be no exceptions to this sub-element in the Vermont extent of play.

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

Criterion 2.b.1: Appropriate protective action recommendations are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions.

(NUREG-0654, I.8, 10 and Supplement 3)

Extent of Play During the initial stage of the emergency response, following notification of plant conditions that may warrant offsite protective actions, the ORO should demonstrate the capability to use appropriate means, described in the plan and/or procedures, to develop protective action recommendations (PAR) 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 ORO also considers these data.

The ORO should demonstrate a reliable capability to independently validate dose projections.

The types of calculations to be demonstrated depend on the data available and the need for assessments to support the PARs appropriate to the scenario. In all cases, calculation of projected dose should be demonstrated. Projected doses should be related to quantities and units of the PAG to which they will be compared. PARs should be promptly transmitted to decision-makers in a prearranged format.

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

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

Massachusetts Extent of Play There will be no exceptions to this sub-element in the Massachusetts Extent of Play.

New Hampshire Extent of Play This Evaluation Area will be demonstrated in accordance with the NHRERP at the State EOC in the context of the exercise scenario. Public Heath Accident Assessment Program and other accident assessment models will be used.

Protective action recommendations will be made in accordance with the NHRERP.

Monitoring teams and accident assessors will be provided field radiological data by controllers in an appropriate sequence according to the scenario timeline and the limitations of exercise play.

This accommodation does not absolve the accident assessment team from making appropriate strategic decisions with respect to the deployment and coordination of field monitoring resources at their disposal.

Vermont Extent of Play There will be no exceptions to this sub-element in the Vermont extent of play.

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

(NUREG-0654, J.9; J.10.f, m)

Extent of Play Offsite Response Organizations (ORO) should have the capability to make both initial and subsequent PADs. They should demonstrate the capability to make initial PADs in a timely manner appropriate to the situation, based on notification from the licensee, assessment of plant status and releases, and PARs from the utility and ORO staff.

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

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

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

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

Massachusetts Extent of Play There will be no exceptions to this sub-element in the Massachusetts Extent of Play.

New Hampshire Extent of Play There will be no exceptions to this sub-element in the New Hampshire extent of play.

Vermont Extent of Play There will be no exceptions to this sub-element in the Vermont extent of play.

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Sub-element 2.c - Protective Action Decisions Consideration for the Protection of Special Populations Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to determine protective action recommendations, including evacuation, sheltering and use of potassium iodide (KI), if applicable, for special population groups (e.g., hospitals, nursing homes, correctional facilities, schools, licensed day care centers, mobility impaired individuals, and transportation dependent individuals). Focus is on those special population groups that are (or potentially will be) affected by a radiological release from a nuclear power plant.

Criterion 2.c.1: Protective action decisions are made, as appropriate, for special population groups. (NUREG-0654, J.9; J.10.d, e)

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

In accordance with plans and/or procedures, OROs and/or officials of public school systems/districts should demonstrate the capability to make prompt decisions on protective actions for students. Officials should demonstrate that the decision making process for protective actions considers (i.e., either accepts automatically or gives heavy weight to) protective action recommendations made by ORO personnel, the ECL at which these recommendations are received, preplanned strategies for protective actions for that ECL, and the location of students at the time (e.g., whether the students are still at home, en route to the school, or at the school).

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

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

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Massachusetts Extent of Play There will be no exceptions to this sub-element in the Massachusetts Extent of Play.

New Hampshire Extent of Play There will be no exceptions to this sub-element in the New Hampshire extent of play.

Vermont Extent of Play There will be no exceptions to this sub-element in the Vermont extent of play.

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Sub-element 2.d. -Radiological Assessment and Decision-Making for the Ingestion Exposure Pathway Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the means to assess the radiological consequences for the ingestion exposure pathway, relate them to the appropriate PAGs, and make timely, appropriate protective action decisions to mitigate exposure from the ingestion pathway.

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

Criterion 2.d.1: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO's planning criteria.

(NUREG-0654, J.11)

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

The ORO should use its procedures (for example, development of a sampling plan) to assess the radiological consequences of a release on the food and water supplies. The OROs assessment should include the evaluation of the radiological analyses of representative samples of water, food, and other ingestible substances of local interest from potentially impacted areas, the characterization of the releases from the facility, and the extent of areas potentially impacted by the release. During this assessment, OROs should consider the use of agricultural and watershed data within the 50-mile EPZ. The radiological impacts on the food and water should then be compared to the appropriate ingestion PAGs contained in the ORO's plan and/or procedures. (The plan and/or procedures may contain PAGs based on specific dose commitment criteria or based on criteria as recommended by current Food and Drug Administration guidance.) Timely and appropriate recommendations should be provided to the ORO decision-makers group for implementation decisions. As time permits, the ORO may also include a comparison of taking or not taking a given action on the resultant ingestion pathway dose commitments.

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

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

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

Massachusetts Extent of Play This sub-element will not be evaluated in this exercise.

New Hampshire Extent of Play This sub-element will not be evaluated in this exercise.

Vermont Extent of Play This sub-element will not be evaluated in this exercise.

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Sub-element 2.e. - Radiological Assessment and Decision-Making Concerning Relocation, Re-entry, and Return Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to make decisions on relocation, re-entry, and return of the general public. These decisions are essential for the protection of the public from the direct long-term exposure to deposited radioactive materials from a severe accident at a nuclear power plant.

Criterion 2.e.1: Timely relocation, re-entry, and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the OROs plan and/or procedures. (NUREG-0654, I.10; M.1)

Extent of Play Relocation: OROs should demonstrate the capability to estimate integrated dose in contaminated areas and to compare these estimates with PAGs, apply decision criteria for relocation of those individuals in the general public who have not been evacuated but where projected doses are in excess of relocation PAGs, and control access to evacuated and restricted areas. Decisions are made for relocating members of the evacuated public who lived in areas that now have residual radiation levels in excess of the PAGs.

Determination of areas to be restricted should be based on factors such as the mix of radionuclides in deposited materials, calculated exposure rates vs. the PAGs, and field samples of vegetation and soil analyses.

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

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

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

They should demonstrate the capability to use decision-making criteria in allowing access to the 108

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

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

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

Massachusetts Extent of Play This sub-element will not be evaluated in this exercise.

New Hampshire Extent of Play This sub-element will not be evaluated in this exercise.

Vermont Extent of Play This sub-element will not be evaluated in this exercise.

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

Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart.

(NUREG-0654, K.3.a, b)

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

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

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

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

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

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

NOTE: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant. After an on the spot re-training by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

Massachusetts Extent of Play State Police Troop B Headquarters, Northampton: Dosimetry packets will be issued to two State Police traffic control personnel, who will demonstrate knowledge of the use of dosimetry and Massachusetts policies on dosimetry through an interview with the FEMA Evaluator out of sequence.

State Police Troop B-2 Barracks, Shelburne Falls: Dosimetry packets will be issued to two State Police traffic control personnel, who will demonstrate knowledge of the use of dosimetry and Massachusetts policies on dosimetry through an interview with the FEMA Evaluator out of sequence.

EPZ EOCs: Dosimetry packets will be issued to a minimum of three individuals who will be working inside each EPZ EOC. Knowledge of the use of dosimetry and MDPHs policies on dosimetry will be demonstrated through an interview with the FEMA Evaluator.

New Hampshire Extent of Play The RADEF Officer in each facility will issue appropriate dosimetry in accordance with the NHRERP. The Municipal EOCs in Hinsdale, Winchester, Chesterfield, Richmond, Swanzey, JIC, Field Teams, and NHSP Troop C will demonstrate their ability to meet this criterion 111

ARCA:

ISSUE: 67-05-3.a.1-A-14 CONDITION: During the first reading of the Direct Reading Dosimeters (DRD) one team member noted that his 0-200 milliroentgen (mR) dosimeter no longer had the hairline visible and the condition could not be corrected. This condition was not reported to the Monitoring Team Coordinator (MTC) as required by procedure, but the reading of his coworker was used as his reading, constituting a group dosimeter.

On Day 1, the two-member FMT#1 arrived with dosimetry packets which had been issued to them prior to leaving their staging area. Each person had one 0-20 R Direct Reading Dosimeter (DRD) and one 0-200 mrem DRD and a TLD. During the first reading of the DRDs one member noted that his 0-200 mrem dosimeter no longer had the hairline visible and could not be corrected. This condition was not reported to the Monitoring Team Coordinator (MTC) but the reading of his coworker was used as his reading, constituting a group dosimeter. The team member stated that his dosimeter had read 0 mrem when it was issued at the staging area. The DRDs had been leak checked 4/05.

Vermont Extent of Play Each of the following facilities will provide a minimum of 2 emergency workers to discuss with the FEMA evaluator the turn back values according to their procedures.

Brattleboro EOC Dummerston EOC Guilford EOC Halifax EOC Vernon EOC EOF JIC IFO Staff at the above facilities will demonstrate actions described in their plans to determine whether to replace an exposed worker or get authorization for the worker to incur additional exposure.

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Sub-element 3.b - Implementation of KI Decision Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to provide radioprotective drugs for emergency workers, institutionalized individuals, and, if in the plan and/or procedures, to the general public for whom immediate evacuation may not be feasible, very difficult, or significantly delayed.

While it is necessary for OROs to have the capability to provide KI to emergency workers and institutionalized individuals, the provision of KI to the general public is an ORO option and is reflected in OROs plans and procedures. Provisions should include the availability of adequate quantities, storage, and means of the distribution of radioprotective drugs.

Criterion 3.b.1: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals is maintained. (NUREG-0654, J.10.e)

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

For evaluation purposes, the actual ingestion of KI is not necessary. OROs should demonstrate the capability to formulate and disseminate appropriate instructions on the use of KI for those advised to take it. If a recommendation is made for the general public to take KI, appropriate information should be provided to the public by the means of notification specified in the OROs 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 OROs plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Massachusetts Extent of Play Actual distribution and ingestion of KI will not occur. Empty KI tablet containers (small zip-lock bags) will be included in the dosimetry packets for emergency workers. There are no institutionalized persons in the EPZ.

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A FEMA Evaluator will interview school staff, including the school nurse and/or teacher who administer KI, out of sequence.

The evaluator will check the availability of adequate quantities, storage, and means of KI distribution, to include forms and equipment to be used.

New Hampshire Extent of Play The capability to issue KI to emergency workers will be demonstrated at appropriate state and local facilities. The RADEF officer at each facility (including Troop C and Field Teams) will talk through the issuing process. No KI will be ingested. Quantities of KI are stored at local EOCs, EPZ nursing homes, hospitals, and the IFO. Calls to institutions will be simulated.

The simulated ingestion of KI by emergency workers and the general public will be driven by scenario specifics.

Vermont Extent of Play Actual distribution and ingestion of KI will not occur. Radiological Officers and Dosimeter Coordinators will show the FEMA evaluator the supply of pills and explain that they would place the foil wrapped pill in each Emergency Worker packet. KI is pre-distributed to the members of the general public residing or working in the EPZ communities.

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

Criterion 3.c.1: Protective action decisions are implemented for special populations other than schools within areas subject to protective actions.

(NUREG-0654, J.10.c, d, g)

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

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

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

Massachusetts Extent of Play Massachusetts Department of Fish and Game, Office of Law Enforcement: OLE emergency response staff will be interviewed by a FEMA Evaluator out of sequence.

Bernardston EOC: EOC staff will simulate contacting persons on their special needs lists by logging the calls at the appropriate time. The list of special needs individuals will be shown to the FEMA Evaluator; however, the information is confidential and copies will NOT be provided.

No vehicles for alerting persons with special needs or providing transportation to the transportation-dependent will be mobilized.

The Fire Liaison will simulate dispatching personnel to alert, notify, and clear persons from the Travelers Woods (KOA) Campground and the Crumpin-Fox Golf Club.

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Colrain EOC: EOC staff will simulate contacting persons on their special needs lists by logging the calls at the appropriate time. The list of special needs individuals will be shown to the FEMA Evaluator; however, the information is confidential and copies will NOT be provided.

No vehicles for alerting persons with special needs or providing transportation to the transportation-dependent will be mobilized.

Gill EOC: EOC staff will simulate contacting persons on their special needs lists by logging the calls at the appropriate time. The list of special needs individuals will be shown to the FEMA Evaluator; however, the information is confidential and copies will NOT be provided.

No vehicles for alerting persons with special needs or providing transportation to the transportation-dependent will be mobilized.

The Fire Liaison will simulate the notification of the Franklin County Boat Club and the Oak Ridge Golf Club, if seasonally open.

Greenfield EOC: EOC staff will simulate contacting persons on their special needs lists by logging the calls at the appropriate time. The list of special needs individuals will be shown to the FEMA Evaluator; however, the information is confidential and copies will NOT be provided.

No vehicles for alerting persons with special needs or providing transportation to the transportation-dependent will be mobilized.

The capability to correctly operate a TTY will be demonstrated in Greenfield by sending and receiving a test message to/from a TTY at the SEOC in Framingham.

Leyden EOC: EOC staff will simulate contacting persons on their special needs lists by logging the calls at the appropriate time. The list of special needs individuals will be shown to the FEMA Evaluator; however, the information is confidential and copies will NOT be provided.

No vehicles for alerting persons with special needs or providing transportation to the transportation-dependent will be mobilized.

Northfield EOC: EOC staff will simulate contacting persons on their special needs lists by logging the calls at the appropriate time. The list of special needs individuals will be shown to the FEMA Evaluator; however, the information is confidential and copies will NOT be provided.

No vehicles for alerting persons with special needs or providing transportation to the transportation-dependent will be mobilized.

Warwick EOC: EOC staff will simulate contacting persons on their special needs lists by logging the calls at the appropriate time. The list of special needs individuals will be shown to the FEMA Evaluator; however, the information is confidential and copies will NOT be provided.

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No vehicles for alerting persons with special needs or providing transportation to the transportation dependent will be mobilized.

New Hampshire Extent of Play The response of transportation resources will be simulated. State EOC, IFO, and local transportation resource personnel will demonstrate their capability to coordinate and dispatch appropriate transportation resources with the support of a control cell during the exercise. The State EOC will make the initial call to transportation providers as well as subsequent calls to a control cell. Calls to special facilities are already contained in the local EOCs demonstration. A TDD/Relay Operator will be demonstrated at the EOC in Concord.

The ability and resources to implement protective actions for special populations will be demonstrated in accordance with the NHRERP at the state and municipal EOCs. Each municipal EOC will simulate calls to special needs populations per their special needs call lists and arrange for appropriate resources to meet the special needs. Controller messages will simulate requests for assistance from the general public beyond the special needs call list. The dispatch of resources and response to requests for assistance will be simulated.

An out-of-sequence demonstration of the New Hampshire State Transportation Staging Area will take place to demonstrate the ability to distribute transportation resources to support the risk municipalities in New Hampshire and the Vermont State Transportation Staging area with appropriate transportation resources. Transportation resources will not be dispatched.

Vermont Extent of Play EPZ EOCs will discuss their special needs list with the FEMA evaluators. Contact with special needs individuals will be simulated by making an entry in the appropriate log. Where possible special facilities will be interviewed by FEMA in March 2009 in a site visit. Those facilities such as state parks and summer camps that are not open in March will be interviewed in the Summer (TBD) in a site visit when they are open. The contact with the camps and parks will be simulated by making an entry in the appropriate log.

Transportation resources will not be dispatched.

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Criterion 3.c.2: OROs/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. The implementation of canceling the school day, dismissing early, or sheltering should be simulated by describing to evaluators the procedures that would be followed. If evacuation is the implemented protective action, all activities to coordinate and complete the evacuation of students to reception centers, congregate care centers, or host schools may actually be demonstrated or accomplished through an interview process. If accomplished through an interview process, appropriate school personnel including decision making officials (e.g., superintendent/principal, transportation director/bus dispatcher), and at least one bus driver (and the bus drivers escort, if applicable) should be available to demonstrate knowledge of their role(s) in the evacuation of school children. Communications capabilities between school officials and the buses, if required by the plan and/or procedures, should be verified.

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

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

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

Massachusetts Extent of Play EPZ EOCs: Initial notification will be made to all public school Superintendents Offices and private schools. All further calls to schools will be simulated.

First Student, Inc: In an out-of-sequence demonstration on May 19, 2009, one bus escort will give a dosimetry briefing to one bus driver. Following that, the bus escort will demonstrate the ability to drive the route from Colrain Central School to the schools host facility at Greenfield Community College.

Mohawk Trail Regional School District: Will be interviewed regarding knowledge of their plan by a FEMA evaluator on May 19, 2009.

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Locations to be interviewed are:

Public Schools Superintendents Office Colrain Central School Private Schools Linden Hill School Northfield Mt. Hermon School Giving Tree New Hampshire Extent of Play Notification of schools and special facilities will be demonstrated at the State EOC and IFO and at each municipal EOC.

Calls will be made to each School Administrative Unit (SAU) and each school to verify transportation resource requirements. Calls will be made to transportation providers to verify resource capabilities. Default values will be used in determining resource requirements. The dispatch of transportation resources to schools will be simulated.

Protective Action Decisions for schools are made at the State EOC. Schools and special facilities in Hinsdale, Winchester and Chesterfield will be interviewed out of sequence.

There are no schools in the Richmond EPZ, and the schools in Swanzey are located outside the EPZ.

Vermont Extent of Play EPZ EOCs will contact schools, licensed and registered childcare centers, nursing homes and hospitals according to their procedures. Students and patients/residents will not be involved. No vehicles will be dispatched for precautionary transfer or evacuation. Special facilities will be interviewed by FEMA out of sequence in March of 2009.

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

Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654, J.10.g, j)

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

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

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

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

Massachusetts Extent of Play SEOC: Massachusetts State Police and Massachusetts Highway Department Liaisons will demonstrate coordination of traffic and access control, but no personnel or equipment will actually be deployed. The demonstration will include interstate coordination of traffic and access control, if appropriate.

Massachusetts State Police Troop B at Headquarters, Northampton: Two personnel who might be assigned traffic and access control duties will be interviewed by the FEMA evaluator out of 120

sequence on the procedures for operating an access control point. No deployment to TCP/ACP locations will occur.

Region III/IV EOC: The Massachusetts State Police Liaison will demonstrate coordination of traffic and access control through discussion and communication, but no personnel or equipment will be deployed to field locations.

EPZ EOCs: EPZ EOCs will demonstrate the ability to direct and monitor traffic control operations within their jurisdictions through discussions and communications with the evaluator.

The EOC local highway representative will participate in a discussion of procedures and resources available for traffic control. No personnel or equipment will be deployed to field locations.

Hampshire Extent of Play Municipal police will be asked to describe their traffic control plan for their jurisdiction at the municipal EOC. Troop C New Hampshire State Police will describe the state access control plan at troop Headquarters in Keene.

These demonstrations will occur during the exercise at times to be coordinated between the Keene EOC controllers and FEMA evaluators.

Vermont Extent of Play EPZ EOCs and the IFO will discuss their traffic and access control procedures with their respective FEMA Evaluators. Coordination will be demonstrated through discussion and phone calls which will be logged but no personnel or equipment will be dispatched.

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

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

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

Massachusetts Extent of Play A member of each affected EOC staff will demonstrate decision making regarding rerouting of traffic following a traffic impediment, in response to a controller inject. No personnel or equipment will be deployed to the simulated scene but the EOC staff will demonstrate decision making and coordination with appropriate agencies and other EOCs as needed.

New Hampshire Extent of Play Municipal Police, NH Department of Transportation, and State Police personnel will discuss the resources to remove impediments as part of the traffic and access control briefing at the municipal EOCs and at Troop C HQ.

Vermont Extent of Play Each affected EOC staff (the five towns, the IFO, and the state EOC) will demonstrate decision making regarding rerouting of traffic following a traffic impediment, in response to a controller inject. No personnel or equipment will be deployed to the simulated scene but the EOC staff will demonstrate decision making and coordination with appropriate agencies and other EOCs as needed.

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Sub-element 3.e - Implementation of Ingestion Pathway Decisions Intent This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to implement protective actions, based on criteria recommended by current Food and Drug Administration guidance, for the ingestion pathway zone (IPZ), the area within an approximate 50-mile radius of the nuclear power plant. This sub-element focuses on those actions required for implementation of protective actions.

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

Extent of Play Applicable OROs should demonstrate the capability to secure and utilize current information on the locations of dairy farms, meat and poultry producers, fisheries, fruit growers, vegetable growers, grain producers, food processing plants, and water supply intake points to implement protective actions within the ingestion pathway EPZ.

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

Massachusetts Extent of Play This sub-element will not be evaluated in this exercise.

New Hampshire Extent of Play This sub-element will not be evaluated in this exercise.

Vermont Extent of Play This sub-element will not be evaluated in this exercise.

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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, J.9, 11)

Extent of Play Development of measures and strategies for implementation of Ingestion Pathway Zone IPZ protective actions should be demonstrated by formulation of protective action information for the general public and food producers and processors. This includes either pre-distributed public information material in the IPZ or the capability for the rapid distribution of appropriate pre-printed and/or camera-ready information and instructions to pre-determined individuals and businesses.

OROs should demonstrate the capability to control, restrict or prevent distribution of contaminated food by commercial sectors. Exercise play should include demonstration of communications and coordination between organizations to implement protective actions.

Actual field play of implementation activities may be simulated. For example, communications and coordination with agencies responsible for enforcing food controls within the IPZ should be demonstrated, but actual communications with food producers and processors may be simulated.

For example, communications and coordination with agencies responsible for enforcing food controls within the IPZ should be demonstrated, but actual communications with food producers and processors may be simulated.

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

Massachusetts Extent of Play This sub-element will not be evaluated in this exercise.

New Hampshire Extent of Play This sub-element will not be evaluated in this exercise.

Vermont Extent of Play This sub-element will not be evaluated in this exercise.

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Sub-element 3.f - Implementation of Relocation, Re-entry, and Return Decisions Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) should demonstrate the capability to implement plans, procedures, and decisions for relocation, re-entry, and return. Implementation of these decisions is essential for the protection of the public from the direct long-term exposure to deposited radioactive materials from a severe accident at a commercial nuclear power plant.

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: OROs should demonstrate the capability to coordinate and implement decisions concerning relocation of individuals, not previously evacuated, to an area where radiological contamination will not expose the general public to doses that exceed the relocation PAGs. OROs should also demonstrate the capability to provide for short-term or long-term relocation of evacuees who lived in areas that have residual radiation levels above the (first-, second-, and fifty-year)

PAGs.

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

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

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

Return: OROs should demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase. OROs should 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 125

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

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

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

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

Massachusetts Extent of Play This sub-element will not be evaluated in this exercise.

New Hampshire Extent of Play This sub-element will not be evaluated in this exercise.

Vermont Extent of Play This sub-element will not be evaluated in this exercise.

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EVALUATION AREA 4: Field Measurement And Analysis Sub-element 4.a - Plume Phase Field Measurements and Analyses Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to deploy field teams with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654 indicates that OROs should have the capability to use field teams within the plume emergency planning zone to measure airborne radioiodine in the presence of noble gases and to detect radioactive particulate material in the airborne plume.

In the event of an accident at a nuclear power plant, the possible release of radioactive material may pose a risk to the nearby population and environment. Although accident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties. During an accident, it is important to collect field radiological data in order to help characterize any radiological release. Adequate equipment and procedures are essential to such field measurement efforts.

Criterion 4.a.1: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates. (NUREG-0654, H.10; I.7, 8, 9)

Extent of Play Field teams should be equipped with all instrumentation and supplies necessary to accomplish their mission. This should include instruments capable of measuring gamma exposure rates and detecting the presence of beta radiation. These instruments should be capable of measuring a range of activity and exposure, including radiological protection/exposure control of team members and detection of activity on the air sample collection media, consistent with the intended use of the instrument and the OROs plans and procedures. An appropriate radioactive check source should be used to verify proper operational response for each low range radiation measurement instrument (less than 1 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 instruments should be inspected, inventoried, and operationally checked before each use.

Instruments should be calibrated in accordance with the manufacturers recommendations.

Unmodified CDV-700 series instruments and other instruments without a manufacturers recommendation should be calibrated annually. Modified CDV-700 instruments should be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration should be on each instrument, or calibrated frequency can be verified 127

by other means. Additionally, instruments being used to measure activity should have a range of readings sticker affixed to the side of the instrument.

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

NOTE: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant. After an on the spot re-training by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

Massachusetts Extent of Play Two NIAT field teams, each consisting of two people, will be dispatched in accordance with the NIAT Handbook from the Greenfield Fire Department located on 512 Main Street, Greenfield, MA.

The NIAT Field Teams will collect a minimum of one complete sample (monitoring and air samples) as specified by the procedures in the NIAT Handbook, Section D.4.

Charcoal filter cartridges will simulate use of Silver Zeolite filter media. Simulated cartridges will be prepared for transportation to the Lab for analysis.

New Hampshire Extent of Play For the purposes of this exercise, two NH DPHS radiological monitoring teams will be dispatched. Charcoal filter cartridges will simulate use of Silver Zeolite filter media. Simulated cartridges will be prepared for transportation to the Lab for analysis. Field data may be provided by Controllers to the Accident Assessment Team to facilitate the accident assessment process during the exercise.

In accordance with the NHRERP, field monitoring teams pick up their equipment and are initially dispatched from the DPHS Laboratory in Concord. Field Teams should collect two complete samples and continue to pick up samples until the exercise terminates.

Monitoring teams and accident assessors will be provided field radiological data by controllers in an appropriate sequence according to the scenario timeline and the limitations of exercise play.

This accommodation does not absolve the accident assessment team from making appropriate strategic decisions with respect to the deployment and coordination of field monitoring resources at their disposal.

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Vermont Extent of Play A minimum of two field teams will each pick up a minimum of two complete samples each consisting of an ambient radiation measurement and an air sample.

Charcoal filter cartridges may simulate use of Silver Zeolite filter media. Simulated cartridges will be prepared for transportation to the Lab for analysis.

Field data may be provided by Controllers to the Accident Assessment (Plume Tracking) Team to facilitate the accident assessment process during the exercise.

By agreement with Vermont Yankee, Vermont plume tracking teams will define the edge of the plume occurring in Vermont or other designated area while VY tracking teams will determine the center line of the plume.

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Criterion 4.a.2: Field teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654, H.12; I.8, 11; J.10.a)

Extent of Play Responsible Offsite Response Organizations (ORO) should demonstrate the capability to brief teams on predicted plume location and direction, travel speed, and exposure control procedures before deployment.

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

If the responsibility to obtain peak measurements in the plume has been accepted by licensee field monitoring teams, with concurrence from OROs, there is no requirement for these measurements to be repeated by State and local monitoring teams. If the licensee teams do not obtain peak measurements in the plume, it is the OROs decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coordination of plume measurement information among all field teams (licensee, Federal, and ORO) is essential. Coordination concerning transfer of samples, including a chain-of-custody form, to a radiological laboratory should be demonstrated.

OROs should use Federal resources as identified in the Federal Radiological Emergency Response Plan (FRERP), and other resources (e.g., compacts, 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 OROs plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Massachusetts Extent of Play The Field Team Coordinator (FTC) located at the utility EOF manages the NIAT Field Teams.

The FTC will brief and dispatch two teams to sampling locations in accordance with the NIAT Handbook, Section D.4.

NIAT Field Team personnel will prepare sample media, survey forms, and chain of custody documents as if they were being shipped to the Massachusetts Environmental Radiation Laboratory (MERL) for analysis. Actual transport of samples to the MERL will be simulated.

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New Hampshire Extent of Play In accordance with the NHRERP, field monitoring teams pick up their equipment and are dispatched from DPHS Lab in Concord by the DPHS Lab Supervisor. Upon their arrival in the EPZ, or while en-route, monitoring teams may receive assignments from the Monitoring Team Coordinator, who is located in the EOF. The Monitoring Team Coordinator coordinates the activity of state monitoring teams. The DPHS EOF RHTA, in coordination with the Monitoring Team Coordinator, is responsible for coordinating the monitoring teams strategy with other States and the Licensee. This coordination occurs at the EOF in Brattleboro.

Vermont Extent of Play Coordination of the transfer of samples to a lab will be simulated and discussed in an interview with the FEMA Evaluator.

By agreement with Vermont Yankee, Vermont plume tracking teams will define the edge of the plume occurring in Vermont or other designated area while VY tracking teams will determine the center line of the plume.

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Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654, 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. OROs should share data in a timely manner with all appropriate OROs. All methodology, including contamination control, instrumentation, preparation of samples, and a chain-of-custody form for transfer to a laboratory, will be in accordance with the OROs plan and/or procedures.

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

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

NOTE: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant. After an on the spot re-training by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

Massachusetts Extent of Play Coordination concerning transfer of samples to the Massachusetts Environmental Radiation Laboratory (MERL) will be simulated and discussed in an interview with the FEMA Evaluator.

New Hampshire Extent of Play Each of the deployed monitoring teams will demonstrate the implementation of their procedures for taking measurements and collecting particulate samples at two locations selected by the Monitoring Team Coordinator.

For this demonstration, two (2) complete samples will be taken whether in-sequence or out-of-sequence with the scenario timeline.

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Vermont Extent of Play A minimum of two field teams will each pick up a minimum of two complete samples each consisting of an ambient radiation measurement and an air sample.

Charcoal filter cartridges may simulate use of Silver Zeolite filter media. Simulated cartridges will be prepared for transportation to the Lab for analysis.

Field data may be provided by Controllers to the Accident Assessment (Plume Tracking) Team to facilitate the accident assessment process during the exercise.

By agreement with Vermont Yankee, Vermont plume tracking teams will define the edge of the plume occurring in Vermont or other designated area while VY tracking teams will determine the center line of the plume.

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Sub-element 4.b - Post Plume Phase Field Measurements and Sampling Intent This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to assess the actual or potential magnitude and locations of radiological hazards in the IPZ and for relocation, re-entry and return measures.

This sub-element focuses on the collection of environmental samples for laboratory analyses that are essential for decisions on protection of the public from contaminated food and water and direct radiation from deposited materials.

Criterion 4.b.1: 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, I.8; J.11)

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

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

OROs should use Federal resources as identified in the FRERP, and other resources (e.g., compacts, 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 must be based on the OROs plans and procedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Massachusetts Extent of Play This sub-element will not be evaluated in this exercise.

New Hampshire Extent of Play This sub-element will not be evaluated in this exercise.

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Vermont Extent of Play This sub-element will not be evaluated in this exercise.

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Sub-element 4.c - Laboratory Operations Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to perform laboratory analyses of radioactivity in air, liquid, and environmental samples to support protective action decision-making.

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

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

Instruments should be calibrated in accordance with the manufacturers recommendations.

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

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 OROs 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 (e.g., transuranics or as a result of a terrorist event) or if warranted by circumstances of the event. Analysis may require resources beyond those of the ORO.

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

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

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.

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

Massachusetts Extent of Play This sub-element will not be evaluated in this exercise.

New Hampshire Extent of Play This sub-element will not be evaluated in this exercise.

Vermont Extent of Play This sub-element will not be evaluated in this exercise.

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

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

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

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

For exercise purposes, timely is defined as the responsible ORO personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay. If message dissemination is to be identified as not having 138

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

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

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

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

Massachusetts Extent of Play Actions to demonstrate performance of initial notification of the public will be performed up to the point of actual transmission of the Emergency Alert System (EAS) message. The State Primary EAS Station of WBZ and the Local Primary EAS Station of WHYN will be contacted and notified that activations of the EAS System will be handled out of the SEOC. Actual activation of the Emergency Alert System will be simulated by SEOC staff.

All States will coordinate activities for the activation of the NOAA tone-alert radios throughout the EPZ. Activation of the NOAA tone-alert radios by the State of Vermont will be demonstrated using a test message.

The simulated activation of the Rapid Emergency Notification Telephone System (RENTS) for all three States by the State of New Hampshire will be demonstrated.

The MA SEOC will demonstrate the actions necessary to perform the siren activation for all three States up to the point of actually sounding the sirens. Siren sounding will be simulated.

New Hampshire Extent of Play Emergency notification and public information will be disseminated to the public in accordance with the NHRERP.

The activation of NOAA tone alert radios, sounding of sirens and broadcast of EAS/EPI messages will be simulated. EAS/EPI messages will be formulated and distributed by the New Hampshire EOC. Activation of the EAS system will be coordinated with Vermont and Massachusetts officials. WKNE will receive EAS/EPI messages but will not broadcast them.

Broadcast will be simulated. EPZ communities will demonstrate this objective through the receipt of siren and EAS activation times from their local liaisons in the IFO and will demonstrate their capability to monitor EAS stations and EPI outlets.

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All States will coordinate activities for the activation of the NOAA tone-alert radios throughout the EPZ. Activation of the NOAA tone-alert radios by the State of Vermont will be demonstrated using a test message.

The simulated activation of the Code Red notification system for all three States by the State of New Hampshire will be demonstrated.

ARCA:

ISSUE: 67 5.a.1-A-16 CONDITION: At 1226, The Emergency Classification Level (ECL) at Vermont Yankee Nuclear Power Station was increased to General Emergency (GE). The Southwestern New Hampshire District Fire Mutual Aid (SWNHDFMA) heard the GE announcement over New Hampshire Homeland Security and Emergency Management (HSEM) Emergency Operations Center Radio system at 1229. Sirens were to be sounded at 1309 and EAS message was to be broadcast at 1312. However, the OFFICIAL GE ECL message was not received direct from HSEM (over the telephone or dedicated Nuclear Alert System [NAS] dedicated telephone line) in accordance with the SWNHDFMA Emergency Response Procedures, Vol.4/Rev.13, Dated Dec.2004. At 1242, the SWNHDFMA Communications Supervisor contacted the OEM Radio Center and was told that there was no GE information available (from HSEM) at that time. The HSEM Operations Officer called SWNHDFMA at 1243 and gave a heads-up that a GE was about to be declared. The SWNHDFMA Controller then received a state pager message regarding the GE ECL at 1245. Concerned that the designated time for sounding the Sirens was approaching, at 1301 the Communications Supervisor again called the HSEM Radio Center and requested OFFICIAL GE ECL notification. The HSEM Communicator stated that the notification was sent to all parties at 1300 on the VY Status Report, FORM 301B. However, since the SWNHDFMA procedures do not use the FORM 301B, the SWNHDFMA Communications Supervisor again contacted the HSEM Communicator at 1305 and at that time, the HSEM Operations Officer confirmed the OFFICIAL GE ECL. The sirens were successfully sounded on time as scheduled at 1309 (simulated).

Vermont Extent of Play Actions to demonstrate performance of the notifications of the public will be performed up to the point of actual transmission of the EAS message. In the initial notification the National Weather Service will be contacted and a Test message will actually be transmitted. The IFO and the five town EOCs will report receipt (or non receipt) of the test message. The three states (VT, NH, & MA) will coordinate each public notification.

The simulated activation of the sirens for all three States by the Commonwealth of Massachusetts will be demonstrated. Brattleboro and Vernon may demonstrate actions necessary to sound the sirens but will not activate the sirens.

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All three States will coordinate activities for the activation of the NOAA tone-alert radios throughout the EPZ. Activation of the NOAA tone-alert radios by the State of Vermont will be demonstrated using a test message.

The simulated activation of the Code Red notification system for all three States by the State of New Hampshire will be demonstrated.

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Criterion 5.a.2: [RESERVED]

Criterion 5.a.3: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. Backup alert and notification of the public is completed within 45 minutes following the detection by the ORO of a failure of the primary alert and notification system. (NUREG-0654, E. 6, Appendix 3.B.2.c)

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

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

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

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

Massachusetts Extent of Play This sub-element will not be demonstrated in this exercise.

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New Hampshire Extent of Play This sub-element will not be demonstrated in this exercise.

Vermont Extent of Play This sub-element will not be demonstrated in this exercise.

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

Criterion 5.b.1: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E. 5, 7; G.3.a; G.4.c)

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

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

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

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

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

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

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

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

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

NOTE: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant. After an on the spot re-training by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

Massachusetts Extent of Play Joint Information Center: Rumor trends generated as a result of public inquiry calls to the Mass-211 Public Information Line will be included in news briefings by the MEMA PIO.

State EOC: Simulation Cell personnel will make calls simulating members of the public and media to the Mass-211 Public Information Line. This process will commence after the initial siren activation. Information on rumor trends recognized at the Mass-211 Public Information Line will be forwarded to the Public Affairs Office at the SEOC.

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Mass-211 Operations Center: Staff from Mass-211 and the Office of the Secretary of the Commonwealth will demonstrate the ability to handle inquiry calls. Information on rumor trends recognized will be forwarded to the Public Affairs Office at the SEOC.

EPZ Towns: Simulation Cell personnel at the SEOC will make calls to the local EOCs simulating members of the public with inquiries. Each local EOC will demonstrate the ability to properly handle these inquiries.

New Hampshire Extent of Play The primary responsibility for briefing the media with respect to off-site activities in New Hampshire lies with the state. The State EOC and Joint Information Center (JIC) are the facilities where this process takes place. The JIC is jointly staffed by the states, the licensee and federal response agencies. Controllers at these facilities will simulate media inquiries.

New Hampshire will coordinate media information with Vermont, Massachusetts, and Vermont Yankee personnel at the Joint Information Center.

New Hampshire EPZ municipalities do not have representatives at the JIC. EPZ municipal officials may respond to questions about local emergency response but are encouraged to refer press inquiries to the JIC. A controller message will be generated for each community to initiate a response and referral to media inquiries made to local officials.

A Public Inquiry line is established to provide members of the public with a supplemental source of accurate emergency information. A control cell will provide incoming calls. Calls to the public inquiry center will occur when a Site Area Emergency and/or General Emergency classification level (ECL) is reached during the course of the exercise.

Public Inquiry personnel will provide callers with accurate information and screen calls for trends. Rumor trends will be handled. Communities will refer calls that address issues beyond local jurisdiction to the Public Inquiry. A controller message will be generated for each community to initiate a response and referral to the public inquiry center. WKNE repeats New Hampshire Emergency Public Information Messages every fifteen minutes until they are changed by the state. The repetition or broadcast of any exercise message will be simulated for the purposes of this exercise.

Vermont Extent of Play State EOC- Control cell personnel will make calls simulating members of the public and media personnel. The Public Information staff will demonstrate receiving calls on the public information line. They will demonstrate identifying and properly handling rumor trends.

Joint Information Center- Controllers will act as media representatives. Information generated as a result of incoming calls to the Public Information staff at the state EOC will be included in a news briefing. At least one rumor trend will be included.

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EPZ EOCs- Control cell personnel will make calls to each town EOC simulating members of the public. Each EOC will demonstrate determining which call(s) may be handled by the town EOC (inquiries about town response actions) and which call(s) must be referred to the Information Officer staff at the State EOC.

ARCA:

ISSUE: 67-07-5.b.1-A-01(Page 34)

CONDITION: The Vermont Emergency Management (VEM) representatives at the Vermont Yankee Joint Information Center (VY-JIC) located within the Vermont Yankee Training Support Center (VY-TSC) in Brattleboro, Vermont failed to provide a Media Inquire Procedure to the news media representatives present at the VY-JIC as required by the new VEM JIC Representative Implementing Procedure dated September 2007. It should be noted that the VEM JIC Representatives used the rest of the new procedure, which is in the form of a checklist.

However they indicated that the Media Inquire Procedure mentioned in the procedure was unclear to them.

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

Criterion 6.a.1: The reception center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers. (NUREG-0654, J.10.h; J.12; K.5.a)

Extent of Play Radiological monitoring, decontamination, and registration facilities for evacuees/ emergency workers should be set up and demonstrated as they would be in an actual emergency or as indicated in the extent of play agreement. This would include adequate space for evacuees vehicles.

Expected demonstration should include 1/3 of the monitoring teams/portal monitors required to monitor 20% of the population allocated to the facility within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Prior to using monitoring instrument(s), the monitor(s) should demonstrate the process of checking the instrument(s) for proper operation.

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

Instruments should be calibrated in accordance with the manufacturers recommendations.

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

Staff responsible for the radiological monitoring of evacuees should demonstrate the capability to attain and sustain a monitoring productivity rate per hour needed to monitor the 20% emergency planning zone (EPZ) population planning base within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This monitoring productivity rate per hour is the number of evacuees that can be monitored per hour by the total complement of monitors using an appropriate monitoring procedure. A minimum of six individuals per monitoring station should be monitored, using equipment and procedures specified in the plan and/or procedures, to allow demonstration of monitoring, decontamination, and registration capabilities.

The monitoring sequences for the first six simulated evacuees per monitoring team will be timed by the evaluators in order to determine whether the twelve-hour requirement can be meet. Monitoring 148

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

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

The availability of provisions for separately showering should be demonstrated or explained. The staff should demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs and appropriate means (e.g., partitions, roped-off areas) to separate clean from potentially contaminated areas. Provisions should also exist to separate contaminated and uncontaminated individuals, provide changes of clothing for individuals whose clothing is contaminated, and store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities. In addition, for any individual found to be contaminated, procedures should be discussed concerning the handling of potential contamination of vehicles and personal belongings.

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

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

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

Massachusetts Extent of Play This sub-element will not be evaluated in this exercise.

New Hampshire Extent of Play This sub-element will not be demonstrated in this exercise.

ARCAs:

ISSUE: 67-05-6.a.1-A-17 CONDITION: Dosimetry briefings provided to male and female emergency workers at the Keene reception Center did not provide additional information about female workers making a declaration if they were or not pregnant.

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ISSUE: 67-05-6.a.1-A-18 CONDITION: After many attempts to check all the sensors, the portal monitor was not working properly. The portal monitor, TSA model TPM 703, ID# 703012, was declared inoperable.

ISSUE: 67-05-6.a.1-A-19 CONDITION: A guide was stationed at the entrance doors handing each evacuee a public letter describing the process and that each person should shower within the next two or three days.

This letter should have been a State form 102A. However, those forms were in short supply, so the guide issued State form 103A as well. State form 103A was to be distributed by the secondary monitoring team when an evacuee was determined to be contaminated above the 300 cpm level established by the plans.

Vermont Extent of Play The Emergency Worker Radiological Monitoring and Decontamination at the IFO was demonstrated in November 2007 and will not be evaluated in 2009.

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

Criterion 6.b.1: The facility/ORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency worker equipment, including vehicles. (NUREG-0654, K.5.b)

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

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

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

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

Massachusetts Extent of Play This sub-element will not be evaluated in this exercise.

ARCA: 9 (to be rectified in May 2011 Graded Exercise)

ISSUE: 67-05-6.b.1-A-25 (Page 93, Greenfield RC)

CONDITION: Contaminated personnel traveling through the secondary monitoring room were potentially contaminating the floor. There was no provision for a masslinn mop for the staff in the secondary monitoring to use on the portion of the floor where the contaminated individuals walked.

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New Hampshire Extent of Play This sub-element will not be demonstrated in this exercise.

ARCA:

ISSUE: 67-05-6.b.1-A-20 CONDITION: Vehicles in which contaminated individuals traveled may not be checked for contamination or decontaminated if necessary.

Vermont Extent of Play The Emergency Worker Radiological Monitoring and Decontamination at the IFO was demonstrated in November 2007 and will not be evaluated in 2009.

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

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

Criterion 6.c.1: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines. (Found in MASS CARE - Preparedness Operations, ARC 3031) Managers demonstrate the procedures to assure that evacuees have been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities. (NUREG-0654, J.10.h; J.12)

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

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

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

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

Massachusetts Extent of Play This sub-element will not be evaluated in this exercise.

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New Hampshire Extent of Play Congregate care centers will not be activated. Current shelter surveys will be provided to FEMA for review. Based on FEMAs survey review, a tour of selected (some, all, or none) congregate care facilities that support the Keene reception center will be conducted if needed with a controller and an American Red Cross representative out of sequence.

Vermont Extent of Play Congregate care centers will not be activated. Current shelter surveys will be provided to FEMA for review. Based on FEMAs survey review, a tour of selected (some, all, or none) congregate care facilities that support the Bellows Falls reception center will be conducted if needed with a controller and an American Red Cross representative out of sequence.

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Sub-element 6.d - Transportation and Treatment of Contaminated Injured Individuals Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

Criterion 6.d.1: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals. (NUREG-0654, F.2; H.10; K.5.a, b; L.1, 4)

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

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

Monitoring of the victim may be performed prior to transport, and done while enroute, or deferred to the medical facility. Prior to using a monitoring instrument(s), the monitor(s) should demonstrate the process of checking the instrument(s) for proper operation. All monitoring activities should be completed, as they would be in an actual emergency. Appropriate contamination control measures should be demonstrated prior to and during transport and at the receiving medical facility.

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

Instruments should be calibrated in accordance with the manufacturers recommendations.

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

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

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

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

Massachusetts Extent of Play The Franklin Medical Center was demonstrated out-of-sequence on November 13, 2008.

New Hampshire Extent of Play The Cheshire Medical Center was demonstrated out-of-sequence on October 19, 2006.

Vermont Extent of Play The Brattleboro Memorial Hospital was demonstrated out-of-sequence on August 28, 2008.

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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 Vermont Yankee Nuclear Power Station exercise on June 10, 2009 The exercise scenario was submitted by the State of Vermont and approved by Federal Emergency Management Agency (FEMA) Region I.

VERMONT YANKEE NUCLEAR POWER STATION EMERGENCY PREPAREDNESS EXERCISE 2009 General Timeline for 06/10/09 Vermont Yankee Plume Exercise 0745 - 0800 Alert 0945 - 1000 SAE 1200 - 1215 GE 1245 - 1300 Release - not significant - NG only, no or low Iodine levels 1345 Wind direction shift to include an upgrade in the PARs towards VT/NH.

Forecast to predict a wind shift.

1430 Terminate the release 1500 Exercise terminated Have 10 R&CA teams dispatched from TSC/OSC.

No security or earthquake.

Plume goes to VT/NH this exercise (winds from 160 and 185 degrees)

Scenario Storyboard 06/10/2009 Exercise - Revision 01 Note: All times are approximate Drill Weather Information Wind direction: Prevailing from the NNE to SSW Wind speed: Between 3 and 8 mph Temperatures: Temperatures to reach the upper 70s today. Tonight expect lows into the lower 50s.

Forecast: Sunny with some clouds moving through the area. High near 80º F. Winds from the North-northeast between 3 and 8 mph with occasional gusts to 15 mph.

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Plant Conditions for Exercise Reactor power 100%

Summertime operations - Steady state Time Event 0475 - 0815 Control Room (CR) briefed, takes watch & start announcement made to site.

0820 Stores calls CR - bringing in resin for demineralizer resin change-out.

0825 Call to CR - Crashed vehicle into Cooling Tower (CT) 2-1. No damage observed.

0825 CR dispatches FSS/AO/Engineer to investigate CT 2-1 condition.

0835 FSS/AO/Engineer confirms vehicle hit CT 2-1. Inspection indicates Risers OK - no damage.

0840 Emergency Response Officer (ERO) receives 000-111 page from Security per OP 3547 - Att. 9.7. NOUE PA made.

0855 CR notifies States of NOUE (U-8-b) (PI opportunity).

0905 AO/Stores reports inability to close TB west roll-up door.

0909 Reactor Pressure Vessel (RPV) level starts to rise (slowly). No turbine trip or scram.

0910 Prior to RPV level = 173, CR initiates manual scram, turbine trip, &

RFP trip per OT 3114.

0910 Anticipated Transient Without Scram (ATWS) condition. All rods initially fail to insert (hydraulic lock).

0912 CR attempts to inject SLC (boron). Fails to inject from PNL 9-2.

0925 CR uses EOP-2 Appendix 1 for Alternate SLC injection to RPV.

0925 CR declares SAE per EAL S-7-c(PI Opportunity).

0930 ERO receives 000-333 page from Security per OP 3547 - Att. 9.4.

SAE PA made.

0930 Fuel cladding damage occurring from ATWS. DW dose rates start rising.

0940 CR notifies States of SAE (S-7-c) (PI Opportunity) 0950 Emergency Response Functions (ERFs) staffing and starting to go operational.

0955 Accountability performed. Emergency Operations Facility (EOF) working toward taking command and control from CR.

1000 Dispatch repair teams: Monitoring SCL, inserting rods, & closing TB roll-up door.

1005 Technical Support Center (TSC) reports Engineering determined no damage to CT 2-1.

1020 Stuck control rod recovery continues - 8 rods remain unable to insert.

1020 Simulated evacuees report to EOF for survey.

1030 Rising temperatures and radiation levels in TB. TB HVAC trips.

Evacuate TB.

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1030 C Main Steam Injection Valves (MSIVs) remain open when CR closes MSIVs for TB High Radiation 1035 Repair team at TB roll-up door reports loud noise & retreat to OSC.

Door still open.

1040 Security (BRE #6) reporting wisps of steam emanating from TB roll-up door area.

1045 SB dose rates indicate 1000 mRem TEDE via field team surveys.

1100 EOF generates GE/PAR based on EAL G-1-a radiological event (PI Opportunity) 1100 to 1245 Radiological monitoring teams continue to track release.

1115 EOF notifies States of GE & PAR (G-1-a) (PI Opportunity) 1115 Outboard MSIV drifts close, stopping steam leak into TB.

1115 Repair teams making sure C MSIVs closed. Troubleshoot RPS, restore TB HVAC.

1130 TSC habitability (elevated TB dose rates) & chemistry sampling activities.

1145 Plant cool down continues. Placing unit in safe condition.

1230 All ERFs briefed on transition to recovery phase.

1240-1300 Evaluate transition to recovery operations. Recall Field Monitoring Teams.

1305 Verify all facility objectives met via Lead Exercise Controllers.

1315 Clean up, restore ERFs, and conduct facility post-exercise critiques.

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