ML093370415

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Exercise Report - 2009-07-21, Final Report - Radiological Emergency Preparedness (REP) Program 2009-11-23, 11/27/2009
ML093370415
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 11/23/2009
From:
US Dept of Homeland Security, Federal Emergency Management Agency
To:
NRC Region 4
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ML093350122 List:
References
Download: ML093370415 (59)


Text

Fort Calhoun Nuclear Station Exercise Report - 2009-07-21 Final Report - Radiological Emergency Preparedness (REP) Program 2009-11-23

Exercise Report Fort Calhoun Nuclear Station Exercise Date: 2009-07-21 Report Date: 2009-11-23 U.S. DEPARTMENT OF HOMELAND SECURITY Federal Emergency Management Agency REP Program 9221 Ward Parkway, Suite 300 Kansas City, MO 64114

Table of Contents Chapter 1 Executive Summary Chapter 2 Introduction Chapter 3 Exercise Overview Section 3.1 EPZ Description Section 3.2 Exercise Participants Section 3.3 Exercise Timeline Chapter 4 Exercise Evaluation and Results Section 4.1 Summary Results of Exercise Evaluation Section 4.2 Status of Jurisdictions Evaluated 4.2.1 Iowa Jurisdictions 4.2.1.1 Iowa State Emergency Operations Center 4.2.1.2 Iowa Dose Assessment 4.2.1.3 Iowa Field Team Coordination 4.2.1.4 Iowa Radiological Monitoring Team # 1 - EPZ 4.2.1.5 Iowa Radiological Monitoring Team # 2 - EPZ 4.2.1.6 Iowa Joint Information Center 4.2.2 Risk Jurisdictions 4.2.2.1 Harrison County EOC/Forward Command Post 4.2.2.2 Missouri Valley School District (High) 4.2.2.3 Missouri Valley School District (Middle) 4.2.2.4 Pottawattamie County EOC 4.2.3 Support Jurisdictions 4.2.3.1 Council Bluffs Ambulance 4.2.3.2 Crawford County Reception and Care Center 4.2.4 Nebraska Jurisdictions 4.2.4.1 Nebraska State Emergency Operations Center 4.2.4.2 Nebraska Dose Assessment & Field Team Coordination 4.2.4.3 Nebraska Radiological Monitoring Team # 1 - EPZ 4.2.4.4 Nebraska Radiological Monitoring Team # 2 - EPZ 4.2.4.5 Nebraska Joint Information Center 4.2.4.6 Nebraska Forward Command Post (GAR) 4.2.4.7 University of Nebraska Medical Center 4.2.5 Risk Jurisdictions 4.2.5.1 Washington County Emergency Operations Center

4.2.5.2 Blair School District (Arbor Park) 4.2.5.3 Fort Calhoun Fire and Rescue 4.2.6 Private Jurisdictions 4.2.6.1 EAS Station KFAB 4.2.7 Federal Jurisdictions 4.2.7.1 National Weather Service, Valley, Nebraska Appendices Appendix 1 - Exercise Evaluators and Team Leaders Appendix 2 - Exercise Evaluation Areas and Extent of Play Agreement Appendix 3 - Exercise Scenario and Timeline

1. Executive Summary On July 21, 2009, the Department of Homeland Security (DHS)/Federal Emergency Management Agency (FEMA), Region VII, conducted an exercise in the plume emergency planning zone (EPZ) around the Fort Calhoun Nuclear Station. In addition, out of sequence drills were conducted for two school districts on May 19-20, 2009, a reception center on 20 July, 2009, and medical services on July 23, 2009, and September 14 and 15, 2009. Further, a remedial exercise was conducted on November 12, 2009. The purpose of the exercise, remedial exercise, and drills was to assess the level of State and local preparedness in responding to a radiological emergency. These exercises and drills were held in accordance with FEMA's policies and guidance concerning the exercise of State and local radiological emergency response plans and procedures.

The previous exercise at this site was conducted on October 16-17, 2007. The qualifying emergency preparedness exercise was conducted on July 22, 1981.

FEMA wishes to acknowledge the efforts of the many individuals who participated in this exercise. In the State of Nebraska, the Risk County of Washington, the Blair School District, the Fort Calhoun Fire and Rescue Department, and the University of Nebraska Medical Center participated along with the state government. In the State of Iowa, the Risk Counties of Harrison and Pottawattamie, the Support County of Crawford, the Missouri Valley School District, and the Council Bluffs Fire and Rescue Department participated along with the state government. The efforts of the utility should also be commended for their work on the scenario development and exercise preparation.

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. A special thank you is once again extended to those wonderful volunteers.

This report contains the evaluation of the biennial exercise, out of sequence drills, and the remedial exercise.

The State and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately 1

implemented them. There were two Deficiencies and two Areas Requiring Corrective Action (ARCAs) identified as a result of this exercise and one of these ARCAs was successfully re-demonstrated and is now closed. There were three ARCAs identified during the previous Fort Calhoun Nuclear Station exercise and one of them was successfully resolved and is now closed. The other two remained unresolved. There were two ARCAs identified during the previous Cooper Nuclear Station exercise and both were successfully resolved and are now closed. During the Remedial Exercise, conducted November 12, 2009, both Deficiencies, the one remaining ARCA from the exercise, and the two remaining previously identified ARCAs were adequately corrected by re-demonstration and are now CLOSED.

The final protective action decision (PAD) for Nebraska during the emergency phase was an evacuation of sub areas 1 and 2. The Nebraska cities and villages impacted by the evacuation were Blair and Kennard. Approximately 9,459 residents in Nebraska were affected by the evacuation. The final PAD for Iowa during the emergency phase was an evacuation of sub areas 10, 11, 12, and 13. Iowa cities and towns impacted by the evacuation were Missouri Valley and Modale. Approximately 3,409 residents in Iowa were affected by the evacuation.

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2. Introduction On December 7, 1979, the President directed FEMA to assume lead responsibility for all offsite nuclear planning and response. FEMA's 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 FEMA's 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 governments' participation in joint exercises with licensees.

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

  • Taking the lead in offsite emergency planning and in the review and evaluation of radiological emergency response plans (RERP) and procedures developed by State and local governments.
  • Determining whether such plans and procedures can be implemented on the basis of 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 (Federal Register, Vol. 58, No. 176, September 14, 1993).
  • Coordinating the activities of the following Federal agencies with responsibilities in the radiological emergency planning process:

- U.S. Department of Commerce

- U.S. Nuclear Regulatory Commission

- U.S. Environmental Protection Agency

- U.S. Department of Energy

- U.S. Department of Health and Human Services

- U.S. Food and Drug Administration 3

- U.S. Public Health Service

- U.S. Department of Transportation

- U.S. Department of Agriculture

- U.S. Department of the Interior Representatives of these agencies serve on the FEMA Region VII Regional Assistance Committee (RAC), which is chaired by FEMA.

Formal submission of the RERPs for the Fort Calhoun Nuclear Station to FEMA Region VII by the States of Iowa and Nebraska and involved local jurisdictions occurred on June 29, 1984. Formal approval of these RERPs was granted by FEMA on December 17, 1984, for Nebraska and on May 20, 1987, for Iowa under 44 CFR 350. The alert and notification system was approved by FEMA on April 27, 1989.

A REP exercise was evaluated on July 21, 2009, out of sequence drills were evaluated on May 19-20, 2009, and Medical Service Drills were evaluated on September 14-15, 2009, by FEMA Region VII to assess the capabilities of the States and local offsite emergency preparedness organizations in implementing their RERPs and procedures to protect the public during a radiological emergency involving the Fort Calhoun Nuclear Station. The purpose of this exercise report is to present the exercise results and findings on the performance of the offsite response organizations (OROs) during a simulated radiological emergency.

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

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

  • 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 as published in the Federal Register September 12, 2001 and April 25, 2002.

Section 3 of this report, entitled "Exercise Overview," presents basic information and 4

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, which were evaluated, and a tabular presentation of the time of actual occurrence of key exercise events and activities.

Section 4 of this report, entitled "Exercise Evaluation and Results," presents basic 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 ARCAs assessed during previous exercises and the status of the OROs efforts to resolve them.

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3. Exercise Overview Contained in this section are data and basic information relevant to the July 21, 2009, exercise, and the out of sequence drills for two school districts on May 19-20, 2009, a reception center on July 20, 2009, and medical services on July 23, 2009, and September 14-15, 2009, and the remedial exercise on November 12, 2009, to test the offsite emergency response capabilities in the area surrounding the Fort Calhoun Nuclear Station. This section of the exercise report includes a description of the plume EPZ, a listing of all participating jurisdictions and functional entities, which were evaluated, and a tabular presentation of the time of the actual occurrence of key exercise events and activities.

3.1. EPZ Description A. Plume EPZ Description The Fort Calhoun Nuclear Station is located along the west bank of the Missouri River, in Washington County, Nebraska.

The topography of the 10-mile EPZ varies from relatively flat east and south of the site, to rolling hills to the west and north of the site.

The 10-mile EPZ contains a total population of 18,424 within four counties: Washington (includes the towns of Blair, Fort Calhoun, and Kennard) and Douglas Counties in Nebraska, and Harrison (includes the towns of Missouri Valley, Modale, and California Junction) and Pottawattamie (includes the town of Loveland) Counties in Iowa. The land use within the EPZ is predominantly diversified agricultural production. There are four recreational areas in the EPZ: Wilson Island State Park, Fort Atkinson, Boyer Chute Recreation Area, and Desoto National Wildlife Refuge. Various forms of transportation serve the area. Interstate Highway 29 passes eight miles to the east and northeast of the site, U.S. Highway 75 passes within one mile to the south, and U.S. Highway 30 passes within two miles to the north and west. The Union Pacific Railroad passes approximately two and one half miles to the north and there is seasonal boat traffic on the Missouri River.

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3.2. Exercise Participants Agencies and organizations of the following jurisdictions participated in the Fort Calhoun Nuclear Station exercise:

State Jurisdictions Iowa Governor's Office Iowa State Homeland Security, Emergency Management Division Iowa National Guard Iowa Department of Public health Iowa Department of Human Services Iowa Department of Public Safety Iowa Department of Natural Resources Iowa Department of Transportation Iowa Department of Agriculture Iowa Department on Aging Iowa State Patrol Iowa State University Environmental Health and Safety University of Iowa Hygienic Lab Iowa State University Extension Iowa Department of Inspections and Appeals Iowa Communications Network Iowa State Motor Vehicle Enforcement Iowa Department of Commerce - Iowa Utilities Board Nebraska Governor's Office Nebraska State Emergency Management Agency Nebraska National Guard Nebraska Department of Health and Human Services Nebraska State Patrol Nebraska Department of Roads Nebraska Game and Parks Commission Nebraska Region 5/6 Office of Emergency Management and Homeland Security Risk Jurisdictions Harrison County Board of Supervisors Harrison County Emergency Management Director Harrison County Roads Department Harrison County Sheriff's Department 7

Harrison County Human Services Missouri Valley School District Pottawattamie County Board of Supervisors Pottawattamie County Emengency Management Department Pottawattamie County Sheriff's Office Pottawattamie County Engineer's Office Pottawattamie County Board of Health Washington County Board of Commissioners City of Blair Mayor and City Management Washington County Sheriff's Office Blair Police Department Washington County Public Information Officer Washington County Radiological Officer Three Rivers District Health Department Blair School District Fort Calhoun Fire and Rescue Council Bluffs Fire and Rescue Support Jurisdictions Crawford County Reception/Registration Center Radio Amateur Communications Emergency Services (RACES)

Private Jurisdictions Radio Station KFAB American Red Cross Federal Jurisdictions National Weather Service 3.3. Exercise Timeline Table 1, on the following pages, presents the time at which key events and activities occurred during the Fort Calhoun Nuclear Station exercise held on July 21, 2009. Also included are times that notifications were made to the participating jurisdictions/functional entities.

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Table 1 - Exercise Timeline DATE: 2009-07-21, SITE: Fort Calhoun Nuclear Station, NE Emergency Classification Level or Event Time Utility Declared Iowa State EOC Iowa Dose Assessment Iowa Field Team Coordination Iowa Rad Team # 1 Iowa Rad Team # 2 Iowa Joint Information Center Unusual Event N/A N/A N/A N/A N/A N/A N/A Alert 0744 0753 0803 0816 0820 0821 0759 Site Area Emergency 0938 0947 0947 0944 0952 0952 0948 General Emergency 1122 1125 1126 1123 1123 1123 1129 Simulated Rad. Release Started 1108 1124 1124 1113 1123 1123 1115 Simulated Rad. Release Terminated N/A N/A N/A N/A N/A N/A N/A Facility Declared Operational 0829 0824 0943 1012 1049 0835 Governor Declaration of State of Emergency 0830 0830 N/A N/A N/A 0855 Exercise Terminated 1400 1400 1357 1357 1357 1410 Precautionary Decision: Nebraska and Iowa -

Clear Parks 0825 0825 N/A 1104 N/A 0920 Precautionary Decision: Nebraska - Schools and Specials Needs Evacuated N/A N/A N/A N/A N/A N/A Precautionary Decision: Nebraska - Relocate EOC N/A N/A N/A N/A N/A N/A 1st Protective Action Decision: Nebraska and Iowa - Dairy Animals on Stored Feed and Water 1001 1001 1140 1141 1141 1001 1st Siren Activation 1005 1005 N/A N/A N/A 1005 1st EAS Message 1015 1015 N/A N/A N/A 1015 2nd Protective Action Decision: Nebraska -

Evacuate Area 1; Iowa - Evacuate Areas 10,11, 12, and 13 1145 1145 N/A N/A N/A 1145 2nd Siren Activation 1148 1148 N/A N/A N/A 1148 2nd EAS Message 1158 1158 N/A N/A N/A 1158 3rd Protective Action Decision: Nebraska -

Evacuate Area 1 & 2 N/A N/A N/A N/A N/A N/A 3rd Siren Activation N/A N/A N/A N/A N/A N/A 3rd EAS Message N/A N/A N/A N/A N/A N/A Agriculture Embargo N/A N/A N/A N/A N/A N/A KI Administration Decision:

1135 1127 1130 1127 1130 1135 9

Table 1 - Exercise Timeline DATE: 2009-07-21, SITE: Fort Calhoun Nuclear Station, NE Emergency Classification Level or Event Time Utility Declared Harrison County EOC/FCP Pottawattamie County EOC Nebraska EOC NE Dose Assessment & FTC NE Rad Monitoring Team # 1 NE Rad Monitoring Team # 2 Unusual Event N/A N/A N/A N/A N/A N/A N/A Alert 0744 0753 0755 0750 0754 0801 0801 Site Area Emergency 0938 0947 0947 0939 0944 0945 0946 General Emergency 1122 1128 1125 1123 1124 1125 1125 Simulated Rad. Release Started 1108 1128 1125 1123 1108 1125 1125 Simulated Rad. Release Terminated N/A N/A N/A N/A N/A N/A N/A Facility Declared Operational 0835 0820 0836 0850 0925 0925 Governor Declaration of State of Emergency 0838 0836 1000 N/A N/A N/A Exercise Terminated 1400 1357 1357 1358 1400 1351 Precautionary Decision: Nebraska and Iowa -

Clear Parks 0837 0854 0845 N/A N/A N/A Precautionary Decision: Nebraska - Schools and Specials Needs Evacuated N/A N/A N/A N/A N/A N/A Precautionary Decision: Nebraska - Relocate EOC N/A N/A N/A N/A N/A N/A 1st Protective Action Decision: Nebraska and Iowa - Dairy Animals on Stored Feed and Water 1001 1001 0939 0947 N/A N/A 1st Siren Activation 1005 1005 0947 N/A N/A N/A 1st EAS Message 1015 1015 0955 N/A N/A N/A 2nd Protective Action Decision: Nebraska -

Evacuate Area 1; Iowa - Evacuate Areas 10,11, 12, and 13 1143 1145 1130 1125 1140 1140 2nd Siren Activation 1148 1148 1132 N/A N/A N/A 2nd EAS Message 1158 1158 1137 N/A N/A N/A 3rd Protective Action Decision: Nebraska -

Evacuate Area 1 & 2 N/A N/A 1238 1238 1244 1244 3rd Siren Activation N/A N/A 1243 N/A N/A N/A 3rd EAS Message N/A N/A 1248 N/A N/A N/A Agriculture Embargo N/A N/A N/A N/A N/A N/A KI Administration Decision:

1128 1137 1117 1116 1117 1116 10

Table 1 - Exercise Timeline DATE: 2009-07-21, SITE: Fort Calhoun Nuclear Station, NE Emergency Classification Level or Event Time Utility Declared Nebraska JIC Nebraska FCP (GAR)

EAS Station KFAB National Weather Washington County EOC Unusual Event N/A N/A N/A N/A N/A N/A Alert 0744 0753 0759 N/A N/A 0750 Site Area Emergency 0938 0950 0939 N/A 0944 0944 General Emergency 1122 1129 1124 N/A 1128 1128 Simulated Rad. Release Started 1108 1129 1124 N/A N/A 1128 Simulated Rad. Release Terminated N/A N/A N/A N/A N/A N/A Facility Declared Operational 0835 0859 N/A N/A 0836 Governor Declaration of State of Emergency 0945 0939 N/A N/A 0939 Exercise Terminated 1410 1357 N/A N/A 1330 Precautionary Decision: Nebraska and Iowa -

Clear Parks N/A N/A N/A N/A 0939 Precautionary Decision: Nebraska - Schools and Specials Needs Evacuated N/A N/A N/A N/A 1009 Precautionary Decision: Nebraska - Relocate EOC N/A N/A N/A N/A 1255 1st Protective Action Decision: Nebraska and Iowa - Dairy Animals on Stored Feed and Water 0945 0939 0947 0955 0939 1st Siren Activation 0952 0952 N/A N/A 0952 1st EAS Message 0955 0955 0955 0957 0955 2nd Protective Action Decision: Nebraska -

Evacuate Area 1; Iowa - Evacuate Areas 10,11, 12, and 13 1132 1123 1148 1133 1130 2nd Siren Activation 1132 1132 N/A 1141 1132 2nd EAS Message 1137 1137 N/A N/A 1137 3rd Protective Action Decision: Nebraska -

Evacuate Area 1 & 2 1243 1242 1204 N/A 1242 3rd Siren Activation 1250 1243 N/A N/A 1244 3rd EAS Message 1250 1248 1248 N/A 1248 Agriculture Embargo 1243 1340 N/A N/A N/A KI Administration Decision:

1123 1117 N/A N/A 1119 11

4. Exercise Evaluation and Results Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities, which participated in the July 21, 2009, exercise, the out of sequence drills for two school districts on May 19-20, 2009, a reception center on July 20, 2009, and medical services on July 23, 2009 and September 14-15, 2009, and the remedial exercise on November 12, 2009, to test the offsite emergency response capabilities of the States of Iowa and Nebraska, and local Iowa and Nebraska governments in the 10-mile EPZ surrounding the Fort Calhoun Nuclear Station.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of criteria delineated in Emergency Preparedness: Exercise Evaluation Methodology as printed in the Federal Register September 12, 2001 and April 25, 2002. Detailed information on the exercise criteria and the extent-of-play agreement for this exercise is found in Appendix 3 of this report.

4.1. Summary Results of Exercise Evaluation The matrix presented in Table 2, on the following pages, presents the status of all exercise criteria, which were scheduled for demonstration during this exercise, at all participating jurisdictions and functional entities. Exercise criteria are listed by number and the demonstration status of those criteria is indicated by the use of the following letters:

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

D - Deficiency assessed A - Area Requiring Corrective Action (ARCA) assessed or unresolved ARCA(s) from prior exercises N - Not Demonstrated 12

Table 2 - Summary of Exercise Evaluation (2 pages)

DATE: 2009-07-21 SITE: Fort Calhoun Nuclear Station, NE A: ARCA, D: Deficiency, M: Met, N: Not Demonstrated Iowa State EOC Iowa Dose Assessment Iowa Field Team Coordination Iowa Rad Team # 1 Iowa Rad Team # 2 Iowa Joint Information Center Harrison County EOC/FCP MOi Valley School Dist. (High)

MO Valley School Dist. (Middle)

Pottawattamie County EOC Council Bluffs Ambulance Crawford County Reception Ctr Emergency Operations Management Mobilization 1a1 M M M M M M M M

M Facilities 1b1 Direction and Control 1c1 M

M M

M Communications Equipment 1d1 M M M M M M M M

M Equip & Supplies to support operations 1e1 M M M M M M M M M M M M Protective Action Decision Making Emergency Worker Exposure Control 2a1 M M M

M Radiological Assessment and PARs 2b1 M M Decisions for the Plume Phase -PADs 2b2 M M M

M PADs for protection of special populations 2c1 M

Rad Assessment and Decision making for the Ingestion Exposure Pathway 2d1 Rad Assessment and Decision making concerning Relocation, Reentry, and Return 2e1 Protective Action Implementation Implementation of emergency worker exposure control 3a1 M M M M M M M M M Implementation of KI decision 3b1 M M M M M M M M Implementation of protective actions for special populations - EOCs 3c1 M

Implementation of protective actions for Schools 3c2 M M M Implementation of traffic and access control 3d1 M M

M Impediments to evacuation are identified and resolved 3d2 M

M Implementation of ingestion pathway decisions - availability/use of info 3e1 Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions.

3f1 Field Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4a1 M M Field Teams obtain sufficient information 4a2 M

Field Teams Manage Sample Collection Appropriately 4a3 M M Post plume phase field measurements and sampling 4b1 Laboratory operations 4c1 Emergency Notification and Public Info Activation of the prompt alert and notification system 5a1 M

M Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 M

M Emergency information and instructions for the public and the media 5b1 M M M M

Support Operations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6a1 M

Mon / decon of emergency worker equipment 6b1 Temporary care of evacuees 6c1 Transportation and treatment of contaminated injured individuals 6d1 M

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Table 2 - Summary of Exercise Evaluation (Continued. page 2/2)

DATE: 2009-07-21 SITE: Fort Calhoun Nuclear Station, NE A: ARCA, D: Deficiency, M: Met, N: Not Demonstrated Nebraska EOC NE Dose Assessment & FTC NE Rad Monitoring Team # 1 NE Rad Monitoring Team # 2 Nebraska JIC Nebraska FCP (GAR)

EAS Station KFAB National Weather University of NE Med. Ctr.

Washington County EOC Blair School Dist.(Arbor Park)

Fort Calhoun Fire and Rescue Emergency Operations Management Mobilization 1a1 M M M M M M M

Facilities 1b1 Direction and Control 1c1 M

M M

Communications Equipment 1d1 M M M M M M M

Equip & Supplies to support operations 1e1 M M M M M M M M M M Protective Action Decision Making Emergency Worker Exposure Control 2a1 M

M M

Radiological Assessment and PARs 2b1 M

M Decisions for the Plume Phase -PADs 2b2 M M M

M PADs for protection of special populations 2c1 M

M Rad Assessment and Decision making for the Ingestion Exposure Pathway 2d1 Rad Assessment and Decision making concerning Relocation, Reentry, and Return 2e1 Protective Action Implementation Implementation of emergency worker exposure control 3a1 M M M M

M M M M Implementation of KI decision 3b1 M M M M

M M M Implementation of protective actions for special populations - EOCs 3c1 M

Implementation of protective actions for Schools 3c2 M M Implementation of traffic and access control 3d1 M M

M Impediments to evacuation are identified and resolved 3d2 M M

Implementation of ingestion pathway decisions - availability/use of info 3e1 Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions.

3f1 Field Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4a1 M M Field Teams obtain sufficient information 4a2 M

Field Teams Manage Sample Collection Appropriately 4a3 M M Post plume phase field measurements and sampling 4b1 Laboratory operations 4c1 Emergency Notification and Public Info Activation of the prompt alert and notification system 5a1 M M M

Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 M

Emergency information and instructions for the public and the media 5b1 M M M M M

Support Operations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6a1 Mon / decon of emergency worker equipment 6b1 Temporary care of evacuees 6c1 Transportation and treatment of contaminated injured individuals 6d1 M

M 14

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

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

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

Area Requiring Corrective Actions (ARCA) - Listing of the demonstrated exercise criteria under which one or more ARCAs were assessed during the current exercise.

Included is a description of the ARCA(s) assessed during this exercise and the recommended corrective action to be demonstrated before or during the next biennial exercise.

Not Demonstrated - Listing of the exercise criteria which were not demonstrated as scheduled during this exercise and the reason they were not demonstrated.

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

Prior ARCAs - Unresolved - Descriptions of ARCAs assessed during prior exercises, which were not resolved in this exercise. Included is the reason 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, which are discussed in this report.

  • A Deficiency is defined by FEMA 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 15

a.

b.

appropriate protective measures can be taken in the event of a radiological emergency to protect the health and safety of the public living in the vicinity of a nuclear power plant."

  • An ARCA is defined by FEMA 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."

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

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

  • Plant Site Identifier - A three-digit number corresponding to the Utility Billable Plant Site Codes.
  • Exercise Year - The four digits of the year the exercise was conducted.
  • Criterion Number - A three-digit number corresponding to the criteria numbers in FEMA Exercise Evaluation Areas.
  • Issue Classification Identifier - (D = Deficiency, A = ARCA). Only Deficiencies and ARCAs are included in exercise reports.
  • Exercise Issue Identification Number - A separate two (or three) digit indexing number assigned to each issue identified in the exercise.

4.2.1. Iowa Jurisdictions 4.2.1.1. Iowa State Emergency Operations Center MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.b.2, 3.d.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None 16

c.

d.

e.

f.

a.

b.

c.

d.

e.

f.

a.

b.

c.

d.

e.

f.

a.

b.

c.

d.

e.

f.

DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.2. Iowa Dose Assessment MET: 1.a.1, 1.d.1, 1.e.1, 2.a.1, 2.b.1, 2.b.2.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.3. Iowa Field Team Coordination 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.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.4. Iowa Radiological Monitoring Team # 1 -

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

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 17

a.

b.

c.

d.

e.

f.

a.

b.

c.

d.

e.

f.

a.

b.

c.

4.2.1.5. Iowa Radiological Monitoring Team # 2 -

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

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.1.6. Iowa Joint Information Center MET: 1.a.1, 1.d.1, 1.e.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2. Risk Jurisdictions 4.2.2.1. Harrison County EOC/Forward Command Post MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.2, 2.c.1, 3.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.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: 5.a.1.

ISSUE NO.: 25-09-5a1-D-01 CRITERION: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite officials to notify the public of an emergency situation. (10 CFR Part 50, Appendix E & NUREG-0654, E.1.,4.,5.,6.,7.)

18

CONDITION: Criterion 5a1, Activation of the prompt alert and notification system Following receipt of the Site Area Emergency Classification, Harrison County did not provide KFAB radio station accurate instructions as to the appropriate messages to broadcast for the public. They did not instruct KFAB to follow the broadcast of the Preliminary EAS Message with the Follow up to Initial EAS Message per the plans. Therefore, the follow up message was never broadcast which would have resulted in the public within the Iowa portion of the 10-mile Emergency Planning Zone receiving incomplete information concerning emergency actions and instructions related to the simulated emergency at the Fort Calhoun Nuclear Station.

Additional problems noted by the evaluators during the initial alerting and notification sequence were:

1) The NWS only simulated broadcasting the initial EAS message once versus the three consecutive times, with tones, as required by their plan and procedures. The procedures were placed out on a desk but never consulted during the exercise.

2) Harrison County Emergency Operations Center (EOC) did not coordinate with Washington County, Nebraska, concerning the timing of sirens and/or the Initial EAS message to be broadcast by the National Weather Service (NWS). When Harrison County EOC contacted the NWS to request them to broadcast the Initial EAS message, NWS informed the county that they had already broadcast the Initial EAS, at 0957, based upon a request from Washington County, Nebraska. As a result of this lack of coordination, the sirens within the Iowa portion of the EPZ were activated approximately 13 minutes after the sirens in the Nebraska portion of the EPZ. Persons in the Iowa portion of the EPZ would not have been alerted to the Initial EAS message for the first broadcast (0957) and may not have heard this information until subsequent broadcasts of similar information by KFAB. This could have caused confusion for people in Iowa as to whether they were affected by the emergency situation. The plans must be revised to ensure that the initial alerting and notification process is appropriately coordinated among all affected jurisdictions.

19

3) Following the General Emergency declaration, Harrison County EOC, at 1148, contacted the National Weather Service (NWS) in error, instead of contacting KFAB radio station as required by the plans, to have them broadcast Iowa Message # 1, the Preliminary EAS message. The NWS informed Harrison County that Washington County, Nebraska had already requested this at 1141 so they would not be acting on the Harrison County request. In fact, NWS broadcast the wrong message for Nebraska (the Initial EAS Message). If NWS had followed through with the Harrison County request, the same wrong message would have broadcast for Iowa which would have conflicted with a broadcast of critical protective action instructions for the public being broadcast by KFAB radio station. It should be noted that, after incorrectly contacting NWS, Harrison County subsequently did contact KFAB radio station to have them broadcast the correct messages.

POSSIBLE CAUSE: The possible cause for the above was the failure of Harrison County EOC to ensure that clear and complete instructions were provided to KFAB Radio Station concerning which messages to broadcast.

In addition, Harrison County did not effectively coordinate the release time of their respective messages with the Washington County, Nebraska.

REFERENCE:

(NUREG-0654, E.5., 7., G.3.a., G.4.a.b.c.)

EFFECT: The follow up message was never broadcast which would have resulted in the public within the Iowa portion of the 10-mile Emergency Planning Zone receiving incomplete and/or confusing information concerning emergency actions and instructions related to the simulated emergency at the Fort Calhoun Nuclear Station.

CORRECTIVE ACTION DEMONSTRATED: RECOMMENDATION: Because of the potential impact this finding has on public health and safety, it must be corrected with 120 days after the exercise date (July 21, 2009) through a remedial exercise. Other remedial actions required to be accomplished prior to the remedial exercise include: 1) Completion of in-depth operating procedures concerning how the EAS process will function in Iowa; 2)Training for all individuals and agencies involved in the EAS process based on the new or modified procedures; 3) Establishment of a verification and monitoring 20

d.

process of the EAS; 4) Establishment of an increased multi-jurisdictional coordination process within each state and between both states; and 5)

Modification of all plans to reflect the new and existing procedures. All of these actions will require coordination with Nebraska.

SCHEDULE OF CORRECTIVE ACTIONS: State will submit updated or new procedures on EAS actions for the State EOC, Harrison County, National Weather Service, and KFAB Radio Station to the FEMA Regional Office by September 21, 2009. State will submit proposed plan changes to the FEMA Regional Office by September 21, 2009. FEMA Regional Office will review for approval by September 24, 2009. Omaha Public Power District will submit Remedial Exercise Scenario to FEMA Regional Office for approval by October 14, 2009. Harrison County will re-demonstrate this issue during the remedial exercise on November 12, 2009.

CORRECTIVE ACTION DEMONSTRATED: During the remedial Exercise conducted on November 12, 2009, following receipt of the Site Area Emergency notification at 1240, the Harison County Cmmunications Section coordinated with the Washington County Communications Section for siren activation to begin at 1245, with Washington County notifing the National Weather Service to play the Initial EAS Message # 2 at 1250, and the Nebraska SEOC contacting KFAB to play Message # 3, the combined Special News Broadcast at 1254. National Weather called back to Harrison County at 1254 to validate that Message # 2 was broadcast at 1250. On November 12, 2009, the state of Iowa submitted a letter indicating how they would integrate their procedures into the Fort Calhoun Family of Plans which was acceptable to FEMA Region VII. Also included in the letter was an acceptable schedule to submit, by January 15, 2010, to FEMA Region VII for approval the plan changes to the Harrison, Pottawattamie, and Crawford County Radiological Emergency Response Plans. In addition, they will submit, by the same date, the revised Emergency Alert System Message Manual. They will provide a date, not later than February 15, 2010, for the submission of revised Letters of Agreement for the National Weather Service and KFAB Radio Station. Based on the above information this criterion was successfully re-demonstrated and the Deficiency is now CLOSED.

NOT DEMONSTRATED: None 21

e.

PRIOR ISSUES - RESOLVED: 5.a.1, 5.b.1.

ISSUE NO.: 25-07-5a1-A-02 ISSUE: The Harrison County Emergency Operations Center (EOC) did not adequately coordinate the timing of the initial EAS message with the National Weather Service EAS radio station. This failure allowed the NWS station to begin broadcast of the EAS message at the same time that the sirens were being sounded in Harrison County.

CORRECTIVE ACTION DEMONSTRATED: RECOMMENDATION: The activation of the initial alert and notification was not handled in a timely manner. The failure of Nebraska and Iowa to coordinate the activation of sirens and the broadcast of the Initial EAS message resulted in the EAS message being broadcast 13 minutes prior to the activation of the Harrison County sirens. There was no repeat broadcast of the message as the NWS failed to (simulate) broadcast the message more then one time. This issue was not corrected and remains unresolved.

SCHEDULE OF CORRECTIVE ACTIONS: This issue will be redemonstrated during the remedial exercise scheduled for November 12, 2009.

CORRECTIVE ACTION DEMONSTRATED: During the Remedial Exercise on November 12, 2009, following receipt of the Site Area Emergency notification at 1240, the Harison County Communications Section coordinated with the Washington County Communications Section for siren activation to begin at 1245, with Washington County notifing the National Weather Service to play the Initial EAS Message # 2 at 1250. National Weather called back to Harrison County at 1254 to validate that Message # 2 was broadcast at 1250. Based on the above information this criterion was successfully re-demonstrated and is now CLOSED.

ISSUE NO.: 25-07-5b1-A-03 ISSUE: The Harrison County Emergency Operations Center (EOC) did not adequately coordinate the timing of the Special News Broadcast (SNB) 22

message with KFAB Radio Station. This failure allowed KFAB to begin broadcast of the SNB message before the sirens were being sounded in Harrison County.

CORRECTIVE ACTION DEMONSTRATED: RECOMMENDATION:

Following receipt of the Site Area Emergency Classification, Harrison County did not provide KFAB radio station accurate instructions as to the appropriate messages to broadcast for the public. They did not instruct KFAB to follow the broadcast of the Preliminary EAS Message with the Follow up to Initial EAS Message per the plans. Therefore, the follow up message was never broadcast which would have resulted in the public within the Iowa portion of the 10-mile Emergency Planning Zone receiving incomplete information concerning emergency actions and instructions related to the simulated emergency at the Fort Calhoun Nuclear Station. Based on the above this issue is not corrected and remains unresolved.

SCHEDULE OF CORRECTIVE ACTIONS: A remedial exercise is planned for November 12, 2009. Harrison County will correct this issue during the Remedial Exercise.

CORRECTIVE ACTION DEMONSTRATED: During the Remedial Exercise, conducted on November 12, 2009, when notified of the General Emergency at 1326, Harrison County EOC coordinated with the State EOC concerning what protective actions to take. At 1349, the County contacted KFAB Radio Station and instructed them that the sirens would be ativated at 1350 and they were to broadcast Message # 2 at 1355 followed by Message # 6 at 1356. Message number 2 is an alert message with EAS tones, while Message # 6 is a Special News Broadcast with the protective actions to evacuate subareas 10, 11, and 12. Based on the above action, this issue was successfully re-demonstrated and is now CLOSED.

ISSUE NO.: 25-07-5b1-A-04 ISSUE: The Harrison County Emergency Operations Center (EOC) did not send a 2-minute or less EAS before the transmission of Special News Broadcast (SNB) messages from KFAB Radio Station. By not sending the attention getting short EAS message which generates the attention signal 23

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tones, the additional alerting to the public was not provided.

CORRECTIVE ACTION DEMONSTRATED: During the General Emergency, the County contacted KFAB and asked them to broadcast Message # 1 with tones and to broadcast Message # 11 (evacuation ) as a Special News Broadcast. Although this was accomplished after the County incorrectly contacted the NWS, their action with KFAB corrected this issue which is now closed.

PRIOR ISSUES - UNRESOLVED: None 4.2.2.2. Missouri Valley School District (High)

MET: 1.e.1, 3.a.1, 3.b.1, 3.c.2.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.3. Missouri Valley School District (Middle)

MET: 1.e.1, 3.a.1, 3.b.1, 3.c.2.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.2.4. Pottawattamie County EOC MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.2, 3.a.1, 3.b.1, 3.d.1, 3.d.2, 5.a.1, 5.a.3, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None 24

e.

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b.

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PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.3. Support Jurisdictions 4.2.3.1. Council Bluffs Ambulance MET: 1.e.1, 3.a.1, 3.b.1, 6.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.3.2. Crawford County Reception and Care Center MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 6.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.4. Nebraska Jurisdictions 4.2.4.1. Nebraska State Emergency Operations Center MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.b.2, 3.d.1, 3.d.2, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None 25

f.

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PRIOR ISSUES - UNRESOLVED: None 4.2.4.2. Nebraska Dose Assessment & Field Team Coordination MET: 1.a.1, 1.d.1, 1.e.1, 2.a.1, 2.b.1, 2.b.2, 3.a.1, 3.b.1, 4.a.2.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.4.3. Nebraska Radiological Monitoring Team # 1

- EPZ MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.3.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.4.4. Nebraska Radiological Monitoring Team # 2

- EPZ MET: 1.a.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.3.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 26

a.

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4.2.4.5. Nebraska Joint Information Center MET: 1.a.1, 1.d.1, 1.e.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: 5.b.1.

ISSUE NO.: 25-09-5b1-A-06 CRITERION: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E.5.,

7., G.3.a, G.4.a.b.c)

CONDITION: The Nebraska PIO issued the second press release at 1152 due to the escalation to a General Emergency (GE). This press release informed citizens to evacuate Sub-area 1. The press release contained the boundaries for Sub-area 1. Instructions were provided on what citizens should take with them, as well as instructions for providing for pets/livestock.

However, the press release did not tell evacuating citizens where to go or provide evacuation routes.

POSSIBLE CAUSE: The PIO did not thoroughly check the content of the pre-scripted press releases.

REFERENCE:

NUREG 0654, E.7 EFFECT: This could cause evaucees to have a radiological uptake because of not being monitored and decontaminated as necessary at the registration center.

CORRECTIVE ACTION DEMONSTRATED: The third press release from the Nebraska PIO was issued at 1337 due to the order to evacuate Sub-area 2 as well as Sub-area 1. The press release contained a description of the boundaries of both Sub-areas. The PIO included evacuation routes as well as the location of the registration center. This issue is now closed DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None 27

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PRIOR ISSUES - UNRESOLVED: None 4.2.4.6. Nebraska Forward Command Post (GAR)

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.a.1, 3.b.1, 3.d.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.4.7. University of Nebraska Medical Center MET: 1.e.1, 3.a.1, 6.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.5. Risk Jurisdictions 4.2.5.1. Washington County Emergency Operations Center MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.b.2, 2.c.1, 3.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.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: 5.a.1.

ISSUE NO.: 25-09-5a1-D-02 CRITERION: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite officials to notify the public of an emergency situation. (10 28

CFR Part 50, Appendix E & NUREG-0654, E.1.,4.,5.,6.,7.)

CONDITION: Criterion 5a1, Activation of the prompt alert and notification system Following the Site Area Emergency declaration, messages containing emergency information for people in Nebraska were broadcast in the incorrect sequence. This would have resulted in some emergency information not being provided to the public as well as causing confusion of the public.

Specifically, the Preliminary EAS Message #1 and the Follow up to Initial EAS Message were simulated to have begun broadcast by KFAB Radio Station prior to the broadcast of the Initial EAS Message being initiated by the National Weather Service (NWS). The Washington County Emergency Operations Center (EOC) contacted the NWS at 0955 with the request for them to begin the broadcast of the "Initial EAS Message" immediately.

Without coordination between Washington County and the State EOC to ensure that this "Initial EAS Message" had been broadcast, the State EOC contacted KFAB Radio Station at 0947 to request them to begin broadcast of the "Preliminary EAS Message # 1" and the "Follow up to Initial EAS Message" at 0955. The KFAB broadcast actually began (simulated by the station personnel) at 0955. The NWS broadcast of the "Initial EAS Message" actually began (simulated by NWS personnel) at 0957. The KFAB broadcast of the "follow up to Initial EAS Message" would have still been ongoing and would have been interrupted by this 0957 NWS EAS initiation. This is significant because the "Follow Up" message is the one that contains more specific information for the public concerning what emergency actions were taking place in response to the simulated emergency at the Fort Calhoun Station. The "Follow Up" message also contains specific instructions for the public such as placing animals on stored feed and water and truning to EAS stations for further information.

Following the General Emergency declaration, a similar situation as above occurred once again. The State of Nebraska and Washington County made a coordinated decision at 1130 to evacuate (simulated subarea 1.

Coordination occurred to activate sirens at 1132. The State EOC provided KFAB Radio Station instructions to broadcast Preliminary EAS Message # 1 29

and Message # 11 (subarea 1 evacuation instructions) at 1137. However, with no coordination between the State EOC and Washington County, the county inappropriately contacted the National Weather Service (NWS) to request them to broadcast these Messages. The NWS incorrectly elected to broadcast the "Initial EAS Message" again instead of Preliminary EAS Message # 1 and Message # 11. This broadcast was simulated to occur at 1141. The inappropriate broadcast of this message at this time would have interrupted the KFAB broadcast of Preliminary EAS Message # 1 and Message # 11 that contained critical protective action instructions for the public.

Additional problems identified during this exercise, concerning alerting and notification of the public, which contributed to this Deficiency were: 1) The NWS only simulated broadcasting the initial EAS message once versus the three consecutive times, with tones, required by their plan and procedures.

The procedures were placed out on a desk, but never consulted during the exercise; 2) The Washington County EOC did not coordinate with Harrison County, Iowa concerning the timing of sirens and/or the Initial EAS Message to be broadcast by the NWS. When Harrison County, Iowa contacted the NWS to request them to broadcast the Initial EAS message, NWS informed them that they had already broadcast the Initial EAS, at 0957, based upon a request from Washington County. As a result of this lack of coordination, the sirens in Iowa were activated approximately 13 minutes after the sirns in Nebraska. The plans must be revised to ensure that the initial alerting and notification process is appropriately coodinated among all affected jurisdictions. 3) KFAB Radio Station failed to activate tones for Message #

12 (subarea 1 and 2 evacuation). Following a wind shift in the scenario, the State EOC made the decision at 1238 to add subarea 2 to the areas recommended for evacuation. Sirens were to be activated at 1243 and KFAB was request to broadcast Message # 12 at 1248. It should be noted that an operator shift change had occurred at KFAB Radio Station at 1208. The new shift operator stated to the FEMA evaluator that, based on instructions from the Federal Communications Commission (FCC) he was not allowed to initiate the alerting tones for an EAS message. The failure to initiate the EAS tones could have prevented some of the public from being alerted to the seriousness of the situation and to protective actions being recommended for them. 4) No "code word" (required by the plans) was given by the State EOC to the KFAB operator nor was one asked for by KFAB. 5) Following 30

broadcast of the "Initial EAS Message" NWS, the State EOC failed to contact NWS, per their procedures, to inform them that their alerting/notification role for this simulated emergency was now complete. Had this action occurred, it could have possibly prevented further issues later in the exercise.

POSSIBLE CAUSE: The possible cause for the above was the failure of all affected jurisdictions, including Washington County EOC and the State EOC to fully coordinate the alerting and notification process, including the times for siren activation and the broadcast of emergency information for the public.

REFERENCE:

(NUREG-0654, E.5., 7., G.e.a., G.4.a.b.c.)

EFFECT: The failure of Washington County and the State EOC to coordinate the timing for the initial alerting and notification sequence would have resulted in at least a portion of the public within the 10 mile Emergency Planning Zone within Nebraska not receiving critical information concerning the emergency actions and instructions related to the simulated emergency at the Fort Calhoun Nuclear Station.

CORRECTIVE ACTION DEMONSTRATED: RECOMMENDATION: Because of the potential impact this finding has on public health and safety, it must be corrected with 120 days after the exercise date (July 21, 2009) through a remedial exercise. Other remedial actions required to be accomplished prior to the remedial exercise include: 1) Completion of in-depth operating procedures concerning how the EAS process will function in Nebraska; 2)Training for all individuals and agencies involved in the EAS process based on the new or modified procedures; 3) Establishment of a verification and monitoring process of the EAS; 4) Establishment of an increased multi-jurisdictional coordination process within each state and between both states; and 5) Modification of all plans to reflect the new and existing procedures. All of these actions will require coordination with Iowa.

SCHEDULE OF CORRECTIVE ACTIONS: State will submit updated or new procedures on EAS actions for the State EOC, Washington County, National Weather Service, and KFAB Radio Station to the FEMA Regional Office by September 21, 2009. State will submit proposed plan changes to the FEMA Regional Office by September 21, 2009. FEMA Regional Office will review for approval by September 24, 2009. Omaha Public Power District will 31

submit Remedial Exercise Scenario to FEMA Regional Office for approval by October 14, 2009. Remedial Exercise will be conducted on November 12, 2009.

CORRECTIVE ACTION DEMONSTRATED: During the remedial exercise conducted on November 12, 2009, following receipt of the Site Area Emergency notification at 1240, the Washington County Communications Section coordinated with the Harrison County Communications Section for siren activation to begin at 1245, with Washington County notifing the National Weather Service to play the Initial EAS Message # 2 at 1250, and the Nebraska SEOC contacting KFAB to play Message # 3, the combined Special News Broadcast at 1254. National Weather called back to Washington County at 1254 to validate that Message # 2 was broadcast at 1250. Following receipt, at 1326, of the General Emergency notification the SEOC, GAR, and Washington County were on the COP line discussing the General Emergency. At 1332, Washington County reported that they concurred in releasing Message # 18 (evacuation of subareas 1 and 2) and that the county had activated the siren system. The GAR, at 1333, instructed the SEOC to contact KFAB and have them broadcast KFAB EAS Message

  1. 2 and Special News Broadcast, Message # 18. At 1334, the SEOC contacted KFAB to broadcast Message # 2 and Message # 18. KFAB activated the EAS encoder/decoder (tones) at 1339 for Message # 2 which was completed at 1341. KFAB began the broadcast of Message # 18 at 1342, which ended at 1346. Also re-demonstrated during the remedial exercise, 1) the National Weather Service followed their revised procedures without incident. 2) Washington County and Harrison County coordinated with each other concerning the time of siren activation and the time of broadcast of the Initial EAS Message # 1. 3) KFAB Radio Station broadcast (simulated) EAS message # 2 with appropriate tones. 4) Code/Passwords were provided to KFAB by the Nebraska SEOC, Washington County and Harrison County as indicated in their revised procedures. 5) The National Weather Service, following broadcast of the Initial EAS Message # 1 and notification of the broadcast time to the Nebraska SEOC, Washington, and Harrison counties appropriately discontinued their participation in the exercise. Based on the above information this criterion was successfully re-demonstrated and the Deficiency is now CLOSED.

32

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NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.5.2. Blair School District (Arbor Park)

MET: 1.e.1, 3.a.1, 3.b.1, 3.c.2.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.5.3. Fort Calhoun Fire and Rescue MET: 1.e.1, 3.a.1, 3.b.1, 6.d.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 4.2.6. Private Jurisdictions 4.2.6.1. EAS Station KFAB MET: 5.a.1, 5.b.1.

AREAS REQUIRING CORRECTIVE ACTION: 5.a.1.

ISSUE NO.: 25-09-5a1-A-03 CRITERION: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite officials to notify the public of an emergency situation. (10 CFR Part 50, Appendix E & NUREG-0654, E.1.,4.,5.,6.,7.)

33

c.

d.

e.

CONDITION: The code word was not provided by the Nebraska caller and the KFAB radio station employee did not ask the caller for the code word.

POSSIBLE CAUSE: When questioned by this evaluator if the code word was provided the KFAB employee responded that the code word was not provided but that he recognized the caller by having previous and recent direct and telephone contact with the caller.

REFERENCE:

EFFECT: Had the KFAB person participating in the exercise had not been available and another radio station employee was receiving the call and failing to require the correct code word the radio station could conceivably broadcast erroneous and incomplete emergency protective action information to the public.

CORRECTIVE ACTION DEMONSTRATED: RECOMMENDATION: KFAB should develop in-depth station standard operating procedures and train all staff on the procedures to ensure all employees are aware and familiar with procedures and are aware that there are specific precautions that must be implemented before any broadcasts are to be considered.

SCHEDULE OF CORRECTIVE ACTIONS: This criterion will be re-demonstrated during the Remedial Exercise on November 12, 2009.

CORRECTIVE ACTION DEMONSTRATED: During the Remedial Exercise conducted on November 12, 2009, KFAB, Nebraska SEOC, Washington and Harrison Couties followed their revised procedures and asked for and provided password/code words. Base upon the above information, this criterion was successfully re-demonstrated and is considered CLOSED.

DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: 5.b.1.

ISSUE NO.: 16-08-5b1-A-10 34

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ISSUE: The radio station employee broadcasting the Emergency Alert System (EAS) message did not preface the message with the attention getting EAS tones.

CORRECTIVE ACTION DEMONSTRATED: This issue was corrected by the successful demonstration of tone activation on the initial EAS message. This issue is now closed.

ISSUE NO.: 16-08-5b1-A-11 ISSUE: The radio station employee broadcasting the Emergency Alert System (EAS) message was instructed to send out the Preliminary EAS Message (Message A) in front of the follow up message and all messages numbered from C to Q. Instead of sending the Preliminary EAS Message he sent the Initial EAS Message which is intended only for the National Weather Service as the first message to be broadcast.

CORRECTIVE ACTION DEMONSTRATED: This issue was corrected by successfully broadcasting a preliminary message followed by a Special News Broadcast message when Nebraska asked for their evacuation messages to be broadcast. This issue is now closed.

PRIOR ISSUES - UNRESOLVED: None 4.2.7. Federal Jurisdictions 4.2.7.1. National Weather Service, Valley, Nebraska MET: 5.a.1.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 35

APPENDIX 1 EXERCISE EVALUATORS AND TEAM LEADERS DATE: 2009-07-21, SITE: Fort Calhoun Nuclear Station, NE LOCATION EVALUATOR AGENCY Iowa State Emergency Operations Center John Flynn Onalee Grady-Erickson

  • Rex Jennings ICF ICF FEMA VII Iowa Dose Assessment
  • Kim Steves Kansas Dept of Health Iowa Field Team Coordination
  • Chuck Hooper EPA Iowa Radiological Monitoring Team # 1 - EPZ
  • Mario Vigliani ICF Iowa Radiological Monitoring Team # 2 - EPZ
  • Debra Schneck ICF Nebraska State Emergency Operations Center Gary Goldberg
  • Jeff McSpaden ICF DOT Nebraska Dose Assessment & Field Team Coordination
  • Richard Grundstrom ICF Nebraska Radiological Monitoring Team # 1 - EPZ
  • James Hickey ICF Nebraska Radiological Monitoring Team # 2 - EPZ
  • Wendy Swygert ICF Nebraska Forward Command Post (GAR)
  • Audie Canida Judy Dodgen David Petta FEMA VII FEMA VII ICF University of Nebraska Medical Center Richard Grundstrom ICF Harrison County EOC/Forward Command Post
  • Al Lookabaugh Bart Ray Charles Zeppenfeld ICF ICF ICF Missouri Valley School District (High)

Joe Schulte FEMA VII Missouri Valley School District (Middle)

Joe Schulte FEMA VII Pottawattamie County EOC Robert Black Jeff Clark

  • Quirino Iannazzo ICF FEMA R7 ICF Washington County Emergency Operations Center Glenn Kinnear Sharron McDuffie
  • David Smith ICF FEMA VII FEMA VII Blair School District (Arbor Park)
  • Andrew Chancellor FEMA VII Fort Calhoun Fire and Rescue Al Lookabaugh ICF Council Bluffs Ambulance Al Lookabaugh ICF Crawford County Reception and Care Center
  • Richard Grundstrom James Hickey Bart Ray Earl Shollenberger ICF ICF ICF ICF EAS Station KFAB
  • Dan Feighert FEMA VIII National Weather Service, Valley, Nebraska
  • James Greer ICF
  • Team Leader 36

www.fema.gov APPENDIX 2 March 31, 2009 David L. Miller, Administrator Iowa Homeland Security & Emergency Management 7105 NW 70th Avenue Johnston, Iowa 50131

Dear Mr. Miller:

The following are provided as the exercise requirements for the full-scale exercise at the Fort Calhoun Nuclear Station on July 21, 2009, and for related, out of sequence evaluations to be conducted as part of the overall Fort Calhoun exercise. Dates and times for the out of sequence demonstrations have been agreed upon and are provided at the end of this letter. The dress rehearsal will be conducted May 19, 2009, and will not be observed by FEMA/contract staff based on instructions from your staff during the Extent of Play Meeting conducted by a conference call on February 11, 2009.

The requirements set forth herein are those IN ADDITION to the generic extent of play criteria for each evaluation area/location. The generic extent of play requirements are INCLUDED as requirements for this exercise. Refer to the previously provided Due Dates List and the enclosed Generic Extent of Play for complete listing of the locations and details of the criteria to be evaluated. The following requirements clarify, modify or extend those generic criteria.

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.a - Mobilization 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)

All telephone calls to mobilize personnel or place them on standby must actually be made.

The demonstrations at the Missouri Valley School District and the Council Bluffs Ambulance will occur out of sequence and all personnel at these facilities may be prepositioned. The issuance of radiological instrumentation and operability checks, where applicable, must not be accomplished prior to evaluator arrival.

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www.fema.gov Pre-positioning of the State EOC staff, State Liaison, IDPH Liaison, Field Team Controller, Field Teams, and the PIO were approved at the EOP Meeting. However, the pre-positioned staff, excluding the State EOC staff, may not enter their duty facility until one hour after the Alert notification.

Although demonstration of a shift change is not required, all evaluated facilities and functions shall provide current rosters identifying the individuals that will maintain around the clock operation. A roster for 24-hour staffing must be provided to the evaluation team at each location.

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

All facilities and field teams that are evaluated must demonstrate communications capability. The evaluators will request copies of all messages and logs of message traffic at each site.

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.,

J.10.a.b.e.f.j.k., 11, K.3.a.)

Verification of dosimetry and KI supplies, as applicable, will occur at the Harrison and Pottawattamie County EOCs, Missouri Valley School District, Council Bluffs Ambulance, and all other facilities that maintain dosimetry and/or KI supplies in accordance with the plans. KI is maintained in blister packs that are grouped by location with the number of packs on the outside. Evaluator will not open the group pack but will utilize the number on the outside of the package for verification.

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

During the emergency phase of the exercise, all appropriate actions (e.g. notification, EAS messages, etc.)

must be demonstrated by the County EOC staffs for any public schools affected by protective action recommendations. Contacts with public school systems/districts must be actual and all public school systems/districts in the EPZ must be notified. The telephone calls should be more like a Communications Check versus relaying the Exercise message to simplify and reduce the chance of false alarms. If there are any private schools or day care centers that require notification and are in the plan, they must also be notified.

EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.a - Implementation of Emergency Worker Exposure Control 38

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.)

Emergency workers must wear appropriate direct reading and permanent record dosimeters and have access to a dosimeter charger in accordance with state and local plans and procedures. In addition, they must be able to demonstrate basic knowledge of dosimeters, radiation exposure limits, and turn-back exposure limits through an interview process. Procedures to monitor and record dosimeter readings and to manage radiological exposure control must be demonstrated.

Missouri Valley School District must provide a minimum of one bus driver to be interviewed concerning the above. In addition, the individual who issues the dosimetry to the bus drivers must be available. The driver must have appropriate dosimeters, per the plan, and a dosimeter charger and be knowledgeable of their use and of their exposure limits.

At the Council Bluffs Ambulance, emergency workers must demonstrate their knowledge of emergency worker exposure control. In addition, workers must have dosimeters and a dosimetry charger and be knowledgeable of procedures for their use.

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 (not the general public) is maintained.

(NUREG-0654, E. 7., J. 10. e., f.)

Although the decision to recommend the use of KI is not due for demonstration during this exercise, it is possible that the scenario could require it. If the decision to use KI is made, the instructions must be appropriately disseminated to all personnel including those deployed (simulated) for traffic and access control and other missions. However, if the decision to use KI is not required by the scenario, all emergency workers, at all facilities, will be expected to demonstrate this criterion through an interview of their knowledge of the procedures for the authorization and the use of KI. Actual administration of KI will be simulated. If any emergency workers indicate they would refuse to take KI, procedures must be demonstrated to ensure the individual does not exceed the exposure limits.

During the Out of Sequence evaluation, on May 19, 2009, at 2:00 p.m., Missouri Valley School District bus drivers and the Out of Sequence evaluation, on September 15, 2009, at 1:00 p.m., Council Bluffs Ambulance staff must have KI available and be knowledgeable of procedures for the authorization and use of KI.

Sub-element 3.c - Implementation of Protective Actions for Special Populations Criterion 3.c.1: Protective action decisions are implemented for special populations other than schools within areas subject to protective actions. (NUREG-0654, E.7., J.9., 10.c.d.e.g.)

Telephone calls to special facilities, individuals with special needs, and transportation providers (except as indicated below) may actually be made or simulated. Actual telephone calls must be made to at least 1/3 of the transportation providers, including special resources for disabled individuals, during this exercise.

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However, all facilities, individuals with special needs, and transportation providers required to be notified must be clearly identified and the actual or simulated contacts appropriately documented. Demonstration of Telecommunications Device for the Deaf (TDD) will be conducted by interview at each EOC or 911 center equipped with TDD devices. In addition, documentation of the latest test of the device will be provided to the evaluator.

Sub-element 3.c - Implementation of Protective Actions for Special Populations - Schools Criterion 3.c.2: OROs/School officials decide upon and implement protective actions for schools. (NUREG-0654, J.10.c., d., g.)

During the out-of sequence drill, on May 19, 2009, at 2:00 p.m., we will expect the capability to take appropriate protective actions for school to be demonstrated by the Missouri Valley School District being evaluated. An exercise evaluator will be assigned to interview the district superintendent (or other designated school official), and principal. This demonstration will be out of sequence.

In addition, at least one school bus driver from the district must be available for an interview to determine their awareness of and preparedness for the evacuation of school children.

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

Deployment of traffic and access control personnel to assigned locations will be simulated. However, the locations where traffic and access control would be established must be appropriately documented. Staffing of traffic and access control points must be appropriately coordinated with all involved jurisdictions.

At least two individuals who would perform traffic and access control must be available at both the Harrison and Pottawattamie County EOCs for an interview. An Iowa State Patrol liaison will be interviewed at the Forward Command Post. During the interviews, all personnel will be expected to demonstrate knowledge of their roles and responsibilities concerning traffic and access control, as well as appropriate knowledge concerning dosimetry and potassium iodide procedures.

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.8., 9., 11.)

Each of the deployed field monitoring teams must take radiation measurements at a sufficient number of locations to identify the plume. A demonstration of an operational check of the instruments utilizing a check source is required. Information on the proper reading or range of readings should be attached to or accompany the instrument. Radiological detection instruments, equipment, and protective clothing as 40

annotated in Section II, Part I of the Iowa State Plan should be available for the demonstrations. The Field Teams will be deployed from the Fort Calhoun Emergency Operations Facility (EOF). An evaluator will meet the field teams to evaluate the pre-departure instrument checks. This will be accomplished on July 21, 2009, at a time to be determined later.

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.8., 9., 11.)

The field teams from the State of Iowa must demonstrate the criteria as they would in an actual emergency.

Activities related to the use of equipment and procedures for the collection and transport of samples from areas that received deposition from the airborne plume must be demonstrated. The evaluator will interview the field teams as to the procedures for the physical turn over of the samples (to include transfer of custody forms) to the Civil Air Patrol. The Civil Air Patrol is not required to participate.

EVALUATION AREA 5: EMERGENCY NOTIFICATION & 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 public must include as a minimum the elements required by current FEMA REP guidance. (10 CFR Part 50, Appendix E & NUREG-0654, E. 1., 4., 5., 6., 7.)

An evaluator will be assigned at KFAB (EAS radio station) and the National Weather Service to observe the stations procedures for broadcasting all exercise related messages. We expect to see the actual receipt of the messages from the county EOC(s). Following receipt at the station, procedures to broadcast the message must be fully demonstrated up to the point of transmission. Actual broadcast of the messages or EAS test messages are not required. The FEMA evaluator will remain at the EAS station and the National Weather Service until the termination of the exercise to observe receipt and broadcast procedures for all EAS messages and Public Information messages. Copies of all EAS messages and Public Information messages will be requested from the facility.

The following basic criteria should be included in the initial EAS announcements:

1. Identification of the State or local government organization and the official with authority for providing the alert signal and instructional message.
2. Identification of the commercial nuclear power plant and a statement that an emergency exists at the plant.
3. Reference to Radiological Emergency Preparedness site-specific emergency information (e.g.

brochures and/or phone book information) for use by the general public during an emergency.

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

The procedures for siren activation must be demonstrated up to the point of actual activation. Actual siren activation may be simulated. Adequate coordination of siren activated and EAS message release must be demonstrated to correct Issue Number 25-07-5a1-A-02 from the 2007 exercise.

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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)

To be demonstrated only if there is a (real or simulated) failure in the primary alert and notification sequence.

Evaluators may conduct an interview at the county EOCs concerning procedures for backup alerting and notification.

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,a.,b.,c.)

All subsequent protective action instructions provided to the public after the initial notification should be disseminated in a timely manner. Messages should be all inclusive by including previously identified protective action areas as well as new areas. Procedures must be demonstrated, if appropriate, to ensure that EAS messages and Public Information messages containing Protective Action Decisions(s) (PADs) that have been changed are rescinded and not repeated by the EAS station. In addition, procedures must be demonstrated to ensure that EAS messages and Public Information messages containing current PADs are repeated at pre-established intervals. Adequate coordination of siren activated and Special News Broadcast message release must be demonstrated to correct Issue Number 25-07-5a1-A-03 from the 2007 exercise. In addition, the simulated broadcast of a 2 minute or less attention getting EAS message before any Special News Broadcast message that includes a Protective Action Decision to the public must be demonstrated to correct Issue Number 25-07-5b1-A-04 from the 2007 exercise.

Media briefings will be conducted at the Joint Information Center (JIC) located at the OPPD Headquarters in Omaha, Nebraska. Press Releases will be prepared at the State EOC and printed for distribution at the JIC.

The State Information Hotline (rumor control) staff at the State EOC must demonstrate this criterion. Each rumor control staff member must demonstrate the capability to respond to an average of at least six calls per hour throughout the emergency phase. Calls will be made on the phone; however, use of the Internet is allowed and a printout of each call and response must be provided to the evaluator.

The staff should demonstrate the capability to monitor the contents of broadcast media coverage of the emergency situation. Any trends in rumors identified by State Information Hotline staff (formerly rumor control) must be addressed by the State EOC in news releases or by the JIC in media briefings. Therefore, appropriate demonstration will require close coordination between utilitys public information staff, state EOC staff, and state public information staff at the JIC. At least one message should address a false or misleading rumor for which measures should be taken.

Evaluators will be assigned to the Joint Information Center to monitor public information and public inquiry.

Copies of all messages, message logs, news releases, and public information statements will be provided to the evaluators at each site.

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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 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.; K.5.b.)

At the Denison Reception and Care Center on July 20, 2009, at 6:30 p.m., the number of evacuees required to be monitored within twelve hours is 756 (20% of the evacuees assigned to the center) plus 600 transients from DeSoto Wildlife Refuge and Wilson Island State Park for a total of 1,356.. The plans indicate that evacuee monitoring will be accomplished by use of a TMP903A Portal Monitor at the rate of approximately 30 seconds for each person and is capable of monitoring 20% of the evacuee population within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or less. The plans indicate that additional monitoring teams are available to monitor those evacuees that activate the portal alarm, who cannot be accommodated by the portal monitor, or in the event the portal monitor becomes inoperable and there is no backup portal monitor. These monitoring teams are from the Denison Volunteer Fire Department (DVFD). For this exercise, two monitoring teams consisting of one monitor and one recorder each will use CDV-700 survey meters to survey evacuees for contamination should there be problems with the portal monitor. In addition, two monitors (male and female) must be available for evacuee re-monitoring following decontamination.

Plans and procedures must be in place concerning how evacuees vehicles will be monitored and decontaminated. An evaluator will conduct an interview concerning operation of the vehicle monitoring and decontamination areas.

The facilities at the Denison High School utilized for monitoring, decontamination, and registration of evacuees, must be fully activated and setup to receive evacuees for evaluation. This will require full staffing of personnel required to accomplish monitoring and decontamination of evacuees and vehicles. At least six evacuees must be processed to demonstrate registration, monitoring, and decontamination capabilities.

Monitoring and decontamination procedures should be initiated for at least one male and one female evacuee. Decontamination procedures may be simulated and completed through an interview process.

The individuals who perform monitoring must demonstrate an operational check of the portal monitor and other survey instruments utilizing a check source, prior to monitoring. Information on the proper reading or range of readings should be attached to or accompany the instruments.

All organizations that, per the plan, provide resources in support of reception center activities must be present for evaluation at the Denison Reception and Care Center. These organizations are the Crawford County Emergency Management Agency (CCEMA), Denison Volunteer Fire Department (DVFD), American Red Cross (ARC), and the Crawford County Sheriffs Department (CCSP).

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

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The Council Bluffs Ambulance will demonstrate this criterion out of sequence on September 15, 2009, at 1:00 p.m. The use of flashing lights and sirens are not necessary during this drill. Monitoring, decontamination, and contamination control efforts will not delay urgent medical care for the simulated victim. A non-specialized vehicle may be used to transport the simulated victim to the medical facility. However, prior to transport, communications between the ambulance and the receiving medical facility must be demonstrated as in the discussion in the generic extent of play.

Before 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.

The ambulance and crew must be monitored before release back into service. In addition, the crew will be interviewed as to knowledge of where decontamination of their vehicle will be accomplished.

NOTE: In the event that, during an out-of-sequence or exercise demonstration an evaluator identifies an exercise issue, the evaluator will discuss it with the Team Leader, Controller, and Trainer (State representative). If possible, the trainer will provide immediate instruction and a re-demonstration will occur to correct the issue. The exercise report will reflect the exercise issue and that it has been corrected.

Out of Sequence Evaluations:

5/19/2009 2:00 p.m.

Missouri Valley School District (High & Middle Schools) 7/20/2009 6:30 p.m.

Denison Reception and Care Center 9/15/2009 1:00 p.m..

Council Bluffs Ambulance If you have any questions concerning the above, please contact Joe Schulte at 816-283-7016.

Sincerely, Ronald L. McCabe, RAC Chairman, Chief, Technological Hazards Branch

Enclosure:

Generic Extent of Play cc:

Vanessa Quinn, HQ REP w/o encl.

Lisa Banks-Robinson, HQ REP w/o encl.

Bill Maier, NRC IV w/o encl.

Carl Simmons, OPPD w/o encl.

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March 31, 2009 Al Berndt, Assistant Director Nebraska Emergency Management Agency 1300 Military Road Lincoln, NE 68508-1090

Dear Mr. Berndt:

The following are provided as the exercise requirements for the full-scale exercise at the Fort Calhoun Nuclear Station on July 21, 2009, and for related, out of sequence evaluations to be conducted as part of the overall Fort Calhoun exercise. Dates and times for the out of sequence demonstrations have been agreed upon and are provided at the end of this letter. The dress rehearsal will be conducted May 19, 2009, and will be observed by FEMA/contract staff based on instructions from your staff during the Extent of Play Meeting conducted by a conference call on February 11, 2009.

The requirements set forth herein are those IN ADDITION to the generic extent of play criteria for each evaluation area/location. The generic extent of play requirements are INCLUDED as requirements for this exercise. Refer to the previously provided Due Dates List and the enclosed Generic Extent of Play for complete listing of the locations and details of the criteria to be evaluated. The following requirements clarify, modify or extend those generic criteria.

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.a - Mobilization 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)

All telephone calls to mobilize personnel or place them on standby must actually be made.

The demonstrations at the Blair School District (Arbor Park School), University of Nebraska Medical Center, and Fort Calhoun Fire & Rescue, will occur out of sequence and all personnel at these facilities may be prepositioned. The issuance of radiological instrumentation and operability checks, where applicable, must not be accomplished prior to evaluator arrival.

Pre-positioning of Nebraska Emergency Management Agency staff, NEMA County Liaison, and Nebraska Health and Human Services staff to the Ft. Calhoun Emergency Operations Facility, and the Joint Information Center were approved during the Extent of Play Meeting. However, the pre-positioned staff, excluding the State EOC staff may not enter their duty facility until one hour after the Alert notification.

In addition, only the Nebraska Region 5/6 Area Coordinator may be pre-positioned at the Washington County EOC by 7:30 a.m.

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Although demonstration of a shift change is not required, all evaluated facilities and functions shall provide current rosters identifying the individuals that will maintain around the clock operation. A roster for 24-hour staffing must be provided to the evaluation team at each location.

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

All facilities and field teams that are evaluated must demonstrate communications capability. The evaluators will request copies of all messages and logs of message traffic at each site.

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.,

J.10.a.b.e.f.j.k., 11, K.3.a.)

Verification of dosimetry and KI supplies, as applicable, will occur at the Washington County EOC, Blair School District, University of Nebraska Medical Center, Fort Calhoun Fire and Rescue, and all other facilities that maintain dosimetry and/or KI supplies in accordance with the plans.

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

During the emergency phase of the exercise, all appropriate actions (e.g. notification, EAS messages, etc.)

must be demonstrated by the Washington County EOC staff for any public or private schools affected by protective action recommendations. Contacts with public school systems/districts must be actual and all public school systems/districts in the EPZ must be notified. The telephone calls should be more like a Communications Check versus relaying the Exercise message to simplify and reduce the chance of false alarms. If there are any private schools or day care centers that require notification and are in the plan, they must also be notified.

EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.a - Implementation of Emergency Worker Exposure Control 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 46

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.)

Emergency workers must wear appropriate direct reading and permanent record dosimeters and have access to a dosimeter charger as applicable in accordance with state and local plans and procedures. In addition, they must be able to demonstrate basic knowledge of dosimeters, radiation exposure limits, and turn-back exposure limits through an interview process. Procedures to monitor and record dosimeter readings and to manage radiological exposure control must be demonstrated.

Blair School District must provide a minimum of one bus driver to be interviewed concerning the above. In addition, the individual who issues the dosimetry to the bus drivers must be available. The driver must have appropriate dosimeters, per the plan, and a dosimeter charger and be knowledgeable of their use and of their exposure limits.

At the University of Nebraska Medical Center and Fort Calhoun Fire & Rescue, emergency workers must demonstrate their knowledge of emergency worker exposure control. In addition, workers must have dosimeters and a dosimetry charger and be knowledgeable of procedures for their use.

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 (not the general public) is maintained.

(NUREG-0654, E. 7., J. 10. e., f.)

Although the decision to recommend the use of KI is not due for demonstration during this exercise, it is possible that the scenario could require it. If the decision to use KI is made, the instructions must be appropriately disseminated to all personnel including those deployed (simulated) for traffic and access control and other missions. However, if the decision to use KI is not required by the scenario, all emergency workers, at all facilities, will be expected to demonstrate this criterion through an interview of their knowledge of the procedures for the authorization and the use of KI. Actual administration of KI will be simulated. If any emergency workers indicate they would refuse to take KI, procedures must be demonstrated to ensure the individual does not exceed the exposure limits.

During the Out of Sequence drills, on September 15, 2009, at 7:00 p.m., the Fort Calhoun Fire and Rescue must have KI available and be knowledgeable of procedures for the authorization and use of KI.

Sub-element 3.c - Implementation of Protective Actions for Special Populations Criterion 3.c.1: Protective action decisions are implemented for special populations other than schools within areas subject to protective actions. (NUREG-0654, E.7., J.9., 10.c.d.e.g.)

Telephone calls to special facilities, individuals with special needs, and transportation providers (except as indicated below) may actually be made or simulated. Actual telephone calls must be made to at least 1/3 of the transportation providers, including special resources for disabled individuals, during this exercise.

However, all facilities, individuals with special needs, and transportation providers required to be notified must be clearly identified and the actual or simulated contacts appropriately documented. Demonstration 47

of Telecommunications Device for the Deaf (TDD) will be conducted by interview at each EOC or 911 Center equipped with TDD devices. In addition, documentation of the latest test of the device will be provided to the evaluator.

Sub-element 3.c - Implementation of Protective Actions for Special Populations - Schools Criterion 3.c.2: OROs/School officials decide upon and implement protective actions for schools. (NUREG-0654, J.10.c., d., g.)

During the out-of sequence drill, on May 18, 2009, at 1:00 p.m., we will expect the capability to take appropriate protective actions for school to be demonstrated by the Blair School District (Arbor Park) being evaluated. An exercise evaluator will be assigned to interview the district superintendent (or other designated school official), and principal. This demonstration will be out of sequence.

In addition, at least one school bus driver from the district must be available for an interview to determine their awareness of and preparedness for the evacuation of school children.

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

Deployment of traffic and access control personnel to assigned locations will be simulated. However, the locations where traffic and access control would be established must be appropriately documented.

Staffing of traffic and access control points must be appropriately coordinated with all involved jurisdictions.

At least two individuals who would perform traffic and access control must be available at the Washington County EOC for an interview. In addition, a Nebraska State Patrol representative from Troop A must also be available at the Washington County EOC for an interview. During the interviews, all personnel will be expected to demonstrate knowledge of their roles and responsibilities concerning traffic and access control, as well as appropriate knowledge concerning dosimetry and potassium iodide procedures.

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.8., 9., 11.)

Field monitoring teams will be composed of integrated members from Nebraska Health and Human Services and the Cooper Nuclear Station. Each of the deployed field monitoring teams must take radiation measurements at a sufficient number of locations to identify the plume. A demonstration of an operational check of the instruments utilizing a check source is required. Information on the proper reading or range of readings should be attached to or accompany the instrument. Radiological detection instruments, 48

equipment, and protective clothing as annotated in Attachment 11 of the Nebraska State Plan should be available for the demonstrations. The Field Teams will be deployed from the Fort Calhoun Emergency Operations Facility (EOF) in Omaha, Nebraska. An evaluator will meet the teams at the EOF to evaluate the pre-departure instrument checks. This will be accomplished on July 21, 2009, at a time to be determined later.

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.8., 9., 11.)

The field teams must demonstrate the criteria as they would in an actual emergency. Activities related to the use of equipment and procedures for the collection and transport of samples from areas that received deposition from the airborne plume must be demonstrated. The evaluator will interview the field teams as to the procedures for the physical turn over of the samples (to include transfer of custody forms) to the agency which will transfer the samples to the laboratory. Actual transport to the laboratory will not be evaluated.

EVALUATION AREA 5: EMERGENCY NOTIFICATION & 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 public must include as a minimum the elements required by current FEMA REP guidance. (10 CFR Part 50, Appendix E & NUREG-0654, E. 1., 4., 5., 6., 7.)

An evaluator will be assigned at KFAB (EAS radio station) and the National Weather Service to observe the stations procedures for broadcasting all exercise related messages. We expect to see the actual receipt of the messages from the county EOC or the State EOC. Following receipt at the station, procedures to broadcast the message must be fully demonstrated up to the point of transmission. Actual broadcast of the messages or EAS test messages are not required. The FEMA evaluator will remain at the EAS station and the National Weather Service until the termination of the exercise to observe receipt and broadcast procedures for all EAS messages and Public Information messages. Copies of all EAS messages and Public Information messages will be requested from the facility.

The following basic criteria should be included in the initial EAS announcements:

1. Identification of the State or local government organization and the official with authority for providing the alert signal and instructional message.
2. Identification of the commercial nuclear power plant and a statement that an emergency exists at the plant.
3. Reference to Radiological Emergency Preparedness site-specific emergency information (e.g.

brochures and/or phone book information) for use by the general public during an emergency.

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

49

The procedures for siren activation must be demonstrated up to the point of actual activation. Actual siren activation may be simulated.

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)

To be demonstrated only if there is a (real or simulated) failure in the primary alert and notification sequence. Evaluators may conduct an interview at the county EOCs concerning procedures for backup alerting and notification.

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,a.,b.,c.)

All subsequent protective action instructions provided to the public after the initial notification should be disseminated in a timely manner. Messages should be all inclusive by including previously identified protective action areas as well as new areas. Procedures must be demonstrated, if appropriate, to ensure that EAS messages and Public Information messages containing Protective Action Decision(s) (PADs) that have been changed are rescinded and not repeated by the EAS station. In addition, procedures must be demonstrated to ensure that EAS messages and Public Information messages containing current PADs are repeated at pre-established intervals. Successfully prefacing EAS messages with the attention getting EAS tones and sending out the Preliminary EAS Message A (simulated) must be demonstrated by KFAB to correct Issues Numbers 16-08-5b1-A-10 and 16-08-5b1-A-11 indentified during the 2008 Cooper Nuclear Station Exercise.

Media briefings will be conducted at the Joint Information Center (JIC) located at the OPPD Headquarters in Omaha, Nebraska. Press Releases will be prepared at the State EOC and printed for distribution at the JIC.

Rumor control is the responsibility of the State Public Information Officer and his/her staff at the JIC.

Each rumor control staff member must demonstrate the capability to respond to an average of at least six calls per hour throughout the emergency phase. Calls will be made on the phone; however, use of the Internet is allowed and a printout of each call and response must be provided to the evaluator.

The staff should demonstrate the capability to monitor the contents of broadcast media coverage of the emergency situation. This will be accomplished at the office of contractor for OPPD. Any trends in rumors identified must be addressed by the State EOC in news releases or by the JIC in media briefings.

Therefore, appropriate demonstration will require close coordination between utilitys public information staff and state public information staff at the Joint Information Center. At least one message should address a false or misleading rumor for which measures should be taken.

Evaluators will be assigned to the Joint Information Center to monitor public information and public inquiry hotline activities. Copies of all messages, message logs, news releases, and public information 50

statements will be provided to the evaluators at each site. We understand that copies of the EAS and EPI messages are NOT provided to the JIC by the State or County EOC.

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

The Fort Calhoun Fire and Rescue and the University of Nebraska Medical Center will demonstrate this criterion out of sequence on September 15, 2009, at 7:00 p.m. and July 23, 2009, at 10:00 a.m.,

respectively. The use of flashing lights and sirens are not necessary during this drill. Monitoring, decontamination, and contamination control efforts will not delay urgent medical care for the simulated victim. A non-specialized vehicle may be used to simulate the transport to the medical facility.

However, prior to transport, communications between the ambulance and the receiving medical facility must be demonstrated as in the discussion in the generic extent of play.

Before 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 by the ambulance crew and at the University of Nebraska Medical Center.

The medical center 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 center 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.

The ambulance and crew must be monitored before release back into service. In addition, the crew will be interviewed as to knowledge of where decontamination of their vehicle will be accomplished.

NOTE: In the event that, during an out-of-sequence or exercise demonstration an evaluator identifies an exercise issue, the evaluator will discuss it with the Team Leader, Controller, and Trainer (State representative). If possible, the trainer will provide immediate instruction and a re-demonstration will occur to correct the issue. The exercise report will reflect the exercise issue and that it has been corrected.

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Out of Sequence Evaluations:

DATE TIME LOCATION 5/18/2009 1:00 p.m..

Blair School District (Arbor Park) 7/23/2009 10:00 a.m..

University of Nebraska Medical Center 9/15/2009 7:00 p.m..

Fort Calhoun Fire & Rescue 9/16/2009 10:00 a.m.

Council Bluffs Ambulance If you have any questions concerning the above, please contact Joe Schulte at 816-283-7016.

Sincerely, Ronald L. McCabe, RAC Chairman, Chief, Technological Hazards Branch

Enclosure:

Generic Extent of Play cc:

Vanessa Quinn, HQ REP w/o encl.

Lisa Banks-Robinson, HQ REP w/o encl.

Bill Maier, NRC IV w/o encl.

Carl Simmons, OPPD w/o encl.

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APPENDIX 3 53

Narrative Timeline Initial Conditions: 100 % power with the following equipment out service for repairs: RM-057 (CONDENSER EVACUATION IN-LINE GAS RADIATION MONITOR) and RM-52 (STACK RADIATION MONITOR REMOTE RATEMETER). Several leaking fuel pins have been identified since startup from the last refueling outage. We are currently in Action Level 2 of the Fuel Reliability Plan. Tornado watch in Washington County until 0830. Thunderstorms are in progress. Sirens 61 in Blair Ne. and Siren 131in Harrison Co. are out of Service. Repair date/time unknown.

07:40 Tornado touches down inside the protected area. Damage to the ISFSI and Intake Structure (Fire Pump) ALERT HA1 ( Natural or Destructive Phenomena Affecting VITAL AREAS) Initiating Conditions.

07:50 Security call Control Room. All Clear on the Tornado. No personnel injuries.

08:15 Relief valve on one Air Compressor lifts. It remains stuck in a partially open position.

08:20 Traffic Accident happens at the intersection of HYWY 30 and Desoto Rd. A Tractor Trailer and an SUV collide. Two people in the SUV are injured in the collision.

09:30 An Instrument Airline rupture occurs downstream of IA-550 (INSTRUMENT AIR RISER "BL"; ISOLATION VALVE) in Room 81. With a loss of instrument air on Riser "BL" and a failure of the air accumulators for HCV-1041A (STEAM GENERATOR RC-2A; MS ISOLATION VALVE), MSIV trips shut. Several RPS Limiting Safety System Settings will be exceeded. The Reactor Protection System will fail to automatically trip the reactor as will the manual trips from CB-4, AI-31, and both trip switches on AI-66A/B.

The reactor can be tripped from AI-57 by opening the CEDM Clutch Power Supply Breakers. The transient on the plant results a 10-gpm RCS leak in the Containment, MS-275 (MAIN STEAM LINE "A"; RELIEF VALVE) to stick about 25 % open, and challenges the Fuel Cladding. Site Area Emergency SS2 ( Automatic Trip Fails to Shutdown the Reactor and Manual Actions Taken From the Reactor Control Console are not Successful in Shutting Down The Reactor) Initiating Conditions are met.

09:40 Ten minutes after HCV-1041A trips, HCV-1042A (STEAM GENERATOR RC-2B; MS ISOLATION VALVE) trips shut due to air leaks from the valves accumulators.

~09:45 When sirens are activated Siren # 69 in Washington County and Siren # 135 in Harrison County fail to activate.

11:00 Tubes in RC-2A (STEAM GENERATOR 'A' (LOOP 1) rupture causing a 200 gpm primary to secondary leak and an off-site radiological release via the stuck open MS-275 relief valve and possibly via FW-10 if steam is not isolated from RC-2A.

2009 Fort Calhoun Station Exercise 1.1-1 54

With the Fuel Cladding Challenged the dose assessment performed shows greater than 1REM TEDE or greater than 5 REM Thyroid CDE at the site boundary. Classification to General Emergency with Initiating Conditions for General Emergency FG1( Loss of Any Two Fission Product Barriers with Loss or Potential Loss of a Third) or AG1 (Offsite Dose from an Actual or Imminent Release Exceeds 1 REM TEDE or 5 REM Thyroid CDE for the Actual or Projected Release using Actual Meteorology). A Protective Action Recommendation to Evacuate 2-Mile Radius All Sectors is required and 5 miles downwind in the affected sectors based on dose assessment.

12:30 Wind Shift causes PAR change.

13:30 Secure from scenario activities, restore Emergency Facilities.

13:30+

Commence Facility Critiques, Sign Attendance Sheets, and complete comment sheets.

2009 Fort Calhoun Station Exercise 1.1-2 55