ML100040008

Submittal of the Final Report for the September 15, 2009 Radiological Emergency Preparedness Partial Participation Plume

ML100040008
Person / Time
Site:	Cook
Issue date:	01/04/2010
From:	Odeshoo J US Dept of Homeland Security, Federal Emergency Management Agency
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML100040008 (43)

Text

U.S. Department of Homeland Security Region V 536 South Clark Street, Floor 6 Chicago, IL 60605 0FEMA

'I4ND5~

NRC Headquarters Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 To Whom It May Concern:

Enclosed is one copy of the Final Report for the September 15, 2009, Radiological Emergency Preparedness (REP) Partial Participation Plume for the D.C. Cook Nuclear Plant.

The State of Michigan, Berrien County, and the utility owner/operator, American Electric Power, participated in this exercise.

No Deficiencies were identified for any jurisdiction during this exercise.

There were no new Areas Requiring Corrective Action (ARCAs) identified and one prior ARCA was not successfully redemonstrated for the State of Michigan during this exercise.

There was one new ARCA identified and one prior ARCA successfully redemonstrated for ,

Berrien County.

There was one prior ARCA for the State of Michigan identified during the August 19, 2008, Palisades Nuclear Power Plant REP Exercise, ARCA Number 44-08-5bl-A-1 Criterion 5.b.1 -

Emergency Notification and Public Information, whereby two news releases were issued with 2 incorrect and/or incomplete information. This ARCA was not successfully redemonstrated during this exercise.

There was one ARCA identified during this exercise for Berrien County. The ARCA identified for Berrien County was ARCA Number 15-09-3bl-A-01 under Criterion 3.b. I -

Implementation of KI decision, whereby the decision to take KI was made by the State, however the implementation of that decision was not carried out by the Berrien County EOC in a timely manner.

One prior ARCA for Berrien County identified during the'September 14, 2007, D.C. Cook Nuclear Power Plant exercise, Number 15-07-5.a. I-A-02 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 officials to notify the public of an emergency situation. This ACRA was successfully redemonstrated during the exercise.

A detailed discussion of these issues can be found in Part IV of the Final Report.

www.fema.gov

NRC Headquarters Document Control Desk Page 2 Based on the results of the September 15, 2009, exercise, the offsite radiological emergency response plans and preparedness for the State of Michigan and affected local jurisdictions, site-specific to the D.C. Cook Nuclear Plant, can be implemented and are adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency at the site.

Therefore, the Title 44 CFR, Part 350, approval of the offsite radiological emergency response plans. and preparedness for the State of Michigan site-specific to D.C. Cook Nuclear Plant, granted on July 16, 1985 and August 8-9, 1989, remain in effect.

Copies of this report have been provided to the DHS/FEMA National Office, Nuclear Regulatory Commission (NRC) Region III, and the State of Michigan.

If you have any questions, please contact William E. King, Chairman, Regional Assistance Committee, DHS/FEMA, Region V, at (312) 408-5575.

Sincerely, f Janet M. Odeshoo Acting Regional Administrator Enclosures (1)

D.C. Cook Nuclear Plant Exercise Report - 2009-09-15 Draft Report - Radiological Emergency Preparedness (REP) Program OlfA'2009-12-21 F EAA

FEM Exercise Report D.C. Cook Nuclear Plant Exercise Date: 2009-09-15 Report Date: 2009-12-21 U.S. DEPARTMENT OF HOMELAND SECURITY Federal Emergency Management Agency REP Program 536 S. Clark St. 6th floor Chicago, IL 60605

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 Michigan Jurisdictions 4.2.1.1 Initial Notification Point 4.2.1.2 State Emergency Operations Center 4.2.1.3 Technical Support Group 4.2.1.4 Field Team Center Cell 4.2.1.5 Joint Information Center 4.2.1.6 Joint Information Center Hotline 4.2.1.7 State Liaison - Berrien County EOC - D.C. Cook and Palisades 4.2.1.8 State DEQ Rep - Berrien Springs Fire Department 4.2.1.9 State DEQ Rep - New Buffalo High School 4.2.2 Risk Jurisdictions 4.2.2.1 Berrien County Initial Notification Point*

4.2.2.2 Berrien County Emergency Operations Center 4.2.2.3 Berrien County Traffic and Access Control Point 4.2.2.4 County Personnel in JIC 4.2.2.5 Emergency Alert System Radio Station WSJM 4.2.2.6 Evacuee Monitoring and Decontamination - New Buffalo High School 4.2.2.7 Evacuee Registration - New Buffalo High School 4.2.2.8 Congregate Care Center - New Buffalo High School 4.2.2.9 Evacuee Vehicle Monitoring and Decontamination - New Buffalo High School 4.2.2.10 Emergency Worker Monitoring - Berrien Springs Fire Department 4.2.2.11 Emergency Worker Decontamination - Berrien Springs Fire Department 4.2.2.12 Emergency Worker Equipment/Vehicle Monitoring and Decontamination - Berrien Springs Fire Department

Appendices Appendix 1 - Acronyms and Abbreviations Appendix 2 - Exercise Evaluators and Team Leaders Appendix 3 - Exercise Evaluation Areas and Extent of Play Agreement Appendix 4 - Exercise Scenario and Timeline

1. Executive Summary On September 15, 2009, a Radiological Emergency Preparedness (REP) Partial Participation Plume Exposure Pathway Exercise was conducted in the.1 0-mile Emergency Planning Zone (EPZ) around the D.C. Cook Nuclear Plant by the U.S.

Department of Homeland Security, Federal Emergency Management Agency (DHS/FEMA), Region V. The purpose of this exercise was to assess the level of State and local preparedness in responding to a radiological emergency. This exercise was held in accordance with DHS/FEMA's policies and guidance concerning the exercise of State and local Radiological Emergency Response Plans (RERPs) and procedures.

The most recent exercise at this site was conducted on August 14, 2007. Qualifying emergency preparedness exercises were conducted on July 16, 1985, and August 8-9, 1989.

FEMA wishes to acknowledge the efforts of the many individuals in the State of Michigan and Berrien County who participated in the exercise.

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

This Final Report contains the evaluation of the biennial exercise and the evaluation of the following out-of-sequence activities:

State of Michigan: Department of Environmental Quality: Evacuee Monitoring, Decontamination, and Registration; Evacuee Vehicle Monitoring and Decontamination; Emergency Worker Monitoring and Decontamination; Emergency Worker Equipment/Vehicle Monitoring and Decontamination; and Medical Services (MS-i) Drill.

Berrien County: Congregate Care Center; Evacuee Monitoring, Decontamination, and Registration; Evacuee Vehicle Monitoring and Decontamination; Emergency Worker Monitoring and Decontamination; Emergency Worker Equipment/Vehicle Monitoring and Decontamination; School Interviews (EV-2); and Medical Services (MS-i) Drill -

Transportation and Medical Facility.

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

No Deficiencies were identified during this exercise.

There were no new Areas Requiring Corrective Action (ARCAs) identified and one prior ARCA was not successfully redemonstrated for the State of Michigan during this exercise. There was one new ARCA identified and one prior ARCA successfully redemonstrated for Berrien County.

There was one prior ARCA for the State of Michigan identified during the August 19, 2008, Palisades Nuclear Power Plant REP Exercise, ARCA Number 44-08-5b1-A-1 Criterion 5.b.1 - Emergency Notification and Public Information, whereby two news releases were issued with incorrect and/or incomplete information. This ARCA was not successfully redemonstrated during this exercise.

There was one ARCA identified- during this exercise for Berrien County. The ARCA identified for Berrien County was ARCA Number 15-09-3b1-A-01 under Criterion 3.b.1 -

Implementation of KI decision, whereby the decision to take KI was made by the State, however the implementation of that decision was not carried out by the Berrien County EOC in a timely manner.

One prior ARCA for Berrien County identified during the September 14, 2007, D.C.

Cook Nuclear Power Plant exercise, Number 15-07-5.a.1-A-02 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 officials to notify the public of an emergency situation. This ACRA was successfully redemonstrated during the exercise.

A detailed discussion of these issues can be found in Part IV of this report.

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2. Introduction On December 7, 1979, the President directed FEMA to assume the lead responsibility for all off-site nuclear planning and response. FEMA's activities are conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 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 off-site emergency planning and in the review and evaluation of RERPs and procedures developed by State and local governments;

- Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by State and local governments;

- Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17, 1993 (Federal Register, Vol. 58, No. 176, dated September 14, 1993); and

- Coordinating the activities of Federal agencies with responsibilities in.the radiological emergency planning process:

U.S. Department of Agriculture; U.S. Department of Energy; U.S. Department of Health and Human Services; U.S. Department of the Interior; U.S. Department of Transportation; U.S. Environmental Protection Agency; U.S. Food and Drug Administration; and

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U.S. Nuclear Regulatory Commission.

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

Formal submission of the RERPs for the D. C. Cook Nuclear Plant to FEMA Region V by the State of Michigan and involved local jurisdictions occurred on January 23, 1986.

Formal approval of these RERPs was granted by FEMA to the State of Michigan on June 15, 1987, under 44 CFR 350.

A REP Partial Participation Plume Exposure Pathway Exercise was conducted in the 10-mile EPZ around the D.C. Cook Nuclear Plant on September 15, 2009, by DHS/FEMA Region V, to assess the capabilities of State and local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving the D.C. Cook Nuclear Plant. The purpose of this exercise report is to present the exercise results and findings on the performance of the off-site response organizations (ORO) during a simulated radiological emergency.

The findings presented in this report are based on the evaluations of the Federal evaluator team, with final determinations made by the DHS/FEMA Region V RAC Chairperson, and approved by the FEMA Headquarters' Acting Technical Hazards Division Director.

The criteria utilized in the DHS/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;

- FEMA-REP-14, "Radiological Emergency Preparedness Exercise Manual", September 1991; and

• FEMA "Radiological Emergency Preparedness: Exercise Evaluation Methodology" as published in the Federal Register NoticeNol. 67, No. 80, dated April 25, 2002.

Section III of this report, entitled "Exercise Overview", presents basic information and data relevant to the exercise. This section of the report contains a description of the 4

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 IV of this report, entitled "Exercise Evaluation and Results," presents detailed information on the demonstration of applicable exercise criteria at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format. This section also contains: (1) descriptions of all Deficiencies and ARCAs assessed during this exercise, recommended corrective actions, and the State and local governments' schedule of corrective actions for each identified exercise issue; and (2) descriptions of unresolved ARCAs assessed during previous exercises and the status of the OROs' efforts to resolve them.

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3. Exercise Overview Contained in this section are data and basic information relevant to the September 15, 2009, REP Partial Participation Plume Exposure Pathway Exercise to test the off-site emergency response capabilities in the area surrounding the D.C. Cook Nuclear.Plant.

This section of the exercise report includes a description of the 10-mile plume pathway EPZ, a listing of all participating jurisdictions and functional entities that were evaluated, and a tabular presentation of the time of the actual occurrence of key exercise events and activities.

3.1. EPZ Description The D. C. Cook Nuclear Plant is located in the State of Michigan, Berrien County, in the City of Bridgman on the eastern shore of Lake Michigan.

The eastern half of the primary 10-mile EPZ lies entirely within Berrien County. The following jurisdictions are located within the EPZ: Baroda Township, Baroda Village, City of Benton Harbor, Benton Township, City of Bridgman, City of Buchanan, Buchanan Township, Chikaming Township, Lake Township, Lincoln Township, Stevensville, Cronoko Township, Village of Berrien Springs, Royalton Township, City of St. Joseph, St Joseph Township, Village of Shoreham, Sodus Township, and Weesaw Township. The western half of the EPZ extends into Lake Michigan in an approximate 10-mile radius.

Within the 10-mile EPZ, located on Lake Michigan, are summer resorts offering camping facilities, light housekeeping cottages, tourist attractions, and the Warren Dunes State Park, which has a capacity of 22,000 people. The area has a population that varies from season to season. The permanent population is estimated to be over 80,000 people. Seasonal fresh fruit and vegetable farming and processing takes place during the spring, summer, and fall months. A portion of the large seasonal work force is Spanish-speaking. Lake Michigan is the cooling water source for the plant.

Transportation facilities include the CSX Railroad.

3.2. Exercise Participants 6

Agencies and organizations of the following jurisdictions participated in the D.C. Cook Nuclear Plant exercise:

State Jurisdictions Emergency Management and Homeland Security Division Michigan Courts Judiciary Emergency Management Michigan State Police Michigan Department of Agriculture MichiganDepartment of Community Health Michigan Department of Corrections Michigan Department of Environmental Quality Michigan Department of Human Services Michigan Department of Information Technology Michigan Department of Labor and Economic Growth Michigan Department of Management and Budget Michigan Department of Military and Veteran Affairs Michigan Department of Natural Resources Michigan Department of Transportation Michigan Fire Services Fire Marshal Michigan Office of Services to the Aging Michigan Office of the Governor Michigan Department of Community Health Michigan Department of Environmental Quality (MDEQ)

Michigan Police Department Michigan Departement of Attorney General Michigan State University Extension" Risk Jurisdictions Berrien County Chief Executive Berrien County Chief of Staff Berrien County Sheriffs Department Berrien County Emergency Management Berrien County Health Department Berrien County Public Information Officer Berrien County Public Safety Communications Dispatch Center Berrien County Sheriffs Department Hazardous Materials Unit Berrien Springs Oronoko Fire Department Berrien Springs Oronoko Township Fire Department Community Health Emergency Coordination Center 7

New Buffalo Police Department New Buffalo City Fire Department Private Jurisdictions Adventist Disaster Response Community Services Amateur Radio Emergency Services American Red Cross Andrews University D.C. Cook Nuclear Plant Representative, WSJM Radio Station Radio Amateur Civil Emergency Services (RACES) 3.3. Exercise Timeline Table 1, on the following page, presents the times at which key events and activities occurred during the REP Partial Participation Plume Exposure Pathway Exercise that was conducted in the 10-mile EPZ around the D. C. Cook Nuclear Plant on September 15, 2009. Also included are times that notifications were made to the participating jurisdictions/functional entities.

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Table 1 - Exercise Timeline DATE: 2009-09-15, SITE: D.C. Cook Nuclear Plant, MI iEmergency: Classification Level or i:"*

Unusual Event N/A N/A N/A N/A N/A Alert 0809 0824 0851 N/A 0824 Site Area Emergency 0901 0918 929 N/A 0919 General Emergency 1005 1008 1012 1015 1017 Simulated Rad. Release Started 0956 1008 1012 1015 1017 Simulated Rad. Release N/A N/A N/A N/A N/A Terminated Facility Declared Operational 0846 N/A 1000 0911 Declaration of State Disaster 1016 N/A 1030 1023 Declaration of Berrien County Local Disaster N/A N/A N/A 0923 Exercise Terminated 1210 1210 1215 1212 Early Precautionary Action: 1st Agricultural 0932 0932 0957 0935 Advisory: Livestock Early Precautionary Action: 2nd Agricultural 1023 N/A 1030 1023 Advisory: Feed, Food, Fruit, and Veg.

1st Protection Action Order: Evacuate Areas 1 1018 1018 1030 1029 and 3 1st Siren Activation: N/A N/A N/A 1030 1st EAS Message N/A N/A N/A 1031 2nd Protective Action Order: Evacuate Areas 1, 2, 1040 1055 1045 1045 3, and 5 2nd Siren Activation N/A N/A N/A 1048 2nd EAS Message N/A N/A N/A 1048 3rd Protective Action Order: Evacuate Areas 1-5 1125 1130 1135 1130 3rd Siren Activation N/A N/A N/A 1132 3rd EAS Message N/A N/A N/A 1132 KI Administration Decision: EW Areas 1,3, and 5 1028 1040 N/A 1036 KI Administration Decision: Institutionalized 1037 1050 1042 1041 Pop. Areas 1,3, and 5 KI Administration Decision: EW Add Area 2 1042 1133 N/A 1049 KI Administration Decision: Institutionalized 1044 1133 1050 1050 Pop. Add Area 2 KI Administration Decision: EW. Areas 1-5 1127 1133 N/A 1135 KI Administration Decision: Institutionalized 1131 1155 1135 1136 Pop. Areas 1-5 9

4. Exercise Evaluation and Results Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities that participated in the September 15, 2009, REP Partial Participation Plume Exposure Pathway exercise and out-of-sequence MS-1 Drill and EV-2 interviews to test the off-site emergency response capabilities of State and local governments in the 10-mile EPZ surrounding the D. C. Cook Nuclear Plant.

Each jurisdiction and functional entity was evaluated based on its demonstration of criteria delineated in exercise criteria contained in Federal Register Notice/Vol. 67, No.

80, dated April 25, 2002. Detailed information on the exercise criteria and the extent-of-play agreement used in this exercise are found in Appendix 3 of this report.

4.1. Summary Results of Exercise Evaluation The matrix presented in Table 2, on the following page(s), presents the status of all exercise criteria from Federal Register Notice/Vol. 67, No. 80, dated April 25, 2002, that was scheduled for demonstration during this exercise by all participating jurisdictions and functional entities. Exercise criteria are listed by number and the demonstration status of those criteria are indicated by the use of the following letters:

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

D - Deficiency (ies) assessed A - ARCA(s) assessed or unresolved ARCA(s) from prior exercise(s)

N - Not Demonstrated (Reason explained in Section IV.B.)

Blank - Not scheduled for demonstration 10

Table 2 - Summary of Exercise Evaluation (2 pages)

C C

DATE: 2009-09-15 z SITE: D.C. Cook Nuclear Plant, MI UU E- U -..

Mobilization lal m m M M M I M M Facilities INlb Direction and Control lcl M M M M M Communications Equipment ldl M M M M M M M. M.

Equip & Supplies to support operations le] M M M M M M MM Protecti eAct on Demsimin Makin ,-,:* ,:S ?: :* ,., : ,;* ... ..... *i: * :;i  ;' *:: **l* *;, r Emergency Worker Exposure Control MMNM 2aM: MD Radiological Assessment and PARs 2b]l M M IM Decisions for the Plume Phase -PADs 2b2 m I mm PADs for protection of special populations 2c] Im*

M MM, Rad Assessment and Decision making for the Ingestion Exposure Pathway 2di Rad Assess/Decision making concerning Relocation. Reentry, and Return 2e]

Protectve: AcItmnlm 11,1PILMCI Li 101)i  ::i Implementation of emergency worker exposure control 3alM M Implementation of KI decision 3bl M Implementation of protective actions for special populations - EOCs 3c] M suppuo~~

Op  : - acltc -Lab Implementation of protective actions for Schools 3c2 *m Implementation of traffic and access control 3dl :M M

.Impediments to evacuation are identified and resolved 3d2 M Implementation of ingestion pathway decisions - availab ility/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions 3fl Adequate Equipment for Plume Phase Field Measurements 4a]

Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b1 Laborato. operations *4c Activation of the prompt alert and notification system 5al M M M Activation of the prompt alert and notification system - Fast Breaker 5a2I Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5bl M A M. M M Mon / decon of evacuees and emergency workers, and registration of evacuees M. Ma Mon / decon of emergency worker equipment 6bd M Temporary care of evacuees M _6c]

Transportation and treatment of contaminated injured individuals 6dP 11

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

Cfj DATE:.2009-09-15 z C SITE: D.C. Cook Nuclear Plant, MI U V)

A:ARCA, D: Deficiency, M: Met, N: Not Demonstrated L- C, 0 z L) c s:

• u.* r,., <1 w) ..

z.l .

'E *E < < <

Mobilization lal M Facilities Ib]

Direction and Control ]cI M M M M M M M Communications Equipment Idl M M M M M.M M M M Equip & Supplies to support operations let M M M M .M M M M Emergency Worker Exposure Control 2a]

Radiological Assessment and PARs 2bl Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populatihns 2c]

Rad Assessment and Decision making for the Ingestion Exposure Pathway 2d]

Rad Assess/Decision makin concerning Relocation, Reentr.,and Return 2el Implementation of emergency worker exposure control 3a] M M M M M M M Implementation of KI decision 3bl A Implementation of protective actions for special populations - EOCs 3c]

Implementation of protective actions for Schools 3c2 Implementation of traffic and access control 3d1 M Impediments to evacuation are identified and resolved 3d2 Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 I.mplementation of relocation. re-entry, and return decisions M3f Field Measurement and oialysis<  : , ,  : :< : , ii;:

Adequate Equipment for Plume Phase Field Measurements 4al Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b]

Laboratory operations 4c I Emergency Nontifcation aud Public Into < 'i Activation of the prompt alert and notification system 5al M Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5bl M Mon / decon of evacuees and emergency workers, and registration of evacuees 6a] M M M M M Mon / decon of emergency worker equipment 6b1 M Temporary care of evacuees 6c1 M Transportation and treatment of contaminated injured individuals 6d1 12

This Page Intentionally Left Blank 13

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 are definitions 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 exercises remain unresolved.

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

• Areas Requiring Corrective Action - Listing of the demonstrated exercise criteria under which one or more ARCAs were assessed during the current exercise or ARCAs assessed during prior exercises remain unresolved. Included is a description of the ARCAs 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 that were not demonstrated as scheduled during this exercise and the reason(s) they were not demonstrated.

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

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

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

- A Deficiency is defined in FEMA-REP-14 as "...an observed or identified inadequacy of organizational performance in an exercise that could cause a finding that offsite emergency preparedness is not adequate to provide reasonable assurance that 14

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

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

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

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

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

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

• Criterion Number - An alpha and two-digit number corresponding to the criteria numbers in the six Exercise Evaluation Areas described in Federal Register NoticeNol.

67, No. 80 dated April 25, 2002, which amends FEMA-REP-14, Radiological Emergency Preparedness Exercise Manual.

- Issue Classification Identifier - (D = Deficiency, A = ARCA). Only Deficiencies and ARCAs are included in exercise reports. Plan Issues are reported to the State(s) via a letter from the Regional Administrator. Therefore, standardized issue numbers are not assigned to Plan Issues.

- Exercise Identification Number - A separate two- (or three-) digit indexing number assigned to each issue identified in the exercise.

4.2.1. Michigan Jurisdictions 15

4.2.1.1. Initial Notification Point

a. MET: 1.a.1, 1.d.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.1.2. State Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.1.3. Technical Support Group

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.1.4., Field'Team Center Cell

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 16

4.2.1.5. Joint Information Center

a. MET: 1.a.1,1.c.1,1.d.1,1.e.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES-UNRESOLVED: 5.b.1.

ISSUE NO.: 44-08-5b1-A-1 ISSUE: Two News Releases were issued with incorrect and/or incomplete information. One contained the wrong emergency classification level. Both did not include all of the information that was contained in the Agricultural Advisories.

REASON UNRESOLVED: At 1010 hours0.0117 days <br />0.281 hours <br />0.00167 weeks <br />3.84305e-4 months <br />, the Michigan Department of Agriculture initiated Agricultural Advisories for Food Establishments and Facilities, Feed Operators. and Facilities, and Fruit and Vegetable Growers and Distributors. These advisories were issued for Areas 1, 3 and 5 which were in conflict with the PAO to evacuate Areas 1 and 3 that was issued at 1018 hours0.0118 days <br />0.283 hours <br />0.00168 weeks <br />3.87349e-4 months <br />. The advisories were faxed to the Berrien County EOC and the JIC at 1026 hours0.0119 days <br />0.285 hours <br />0.0017 weeks <br />3.90393e-4 months <br /> for dissemination to the public.

RECOMMENDATION: Evaluate the individual simultaneous processes for intitiating and disseminating protective actions to the public to determine how to minimize the chance for dissemination to the public of conflicting protective actions.

4.2.1.6. Joint Information Center Hotline

a. MET: 5.b.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

,e. PRIOR ISSUES - RESOLVED: None 17

f. PRIOR ISSUES - UNRESOLVED: None 4.2.1.7. State Liaison - Berrien County EOC - D.C.

Cook and Palisades

a. MET: 2.a.1,2.b.1,5.a.1, 5.b.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.1.8. State DEQ Rep - Berrien Springs Fire Department

a. MET: 1.c.1,1.d.1,1.e.1,3.a.1,6.a.1,6.b.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.1.9. State DEQ Rep - New Buffalo High School

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.2. Risk Jurisdictions 18

4.2.2.1. Berrien County Initial Notification Point

a. MET: 1.a.1,1.d.1,1.e.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.2.2. Berrien County Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: 5.a.1.

ISSUE NO.: 15-07-5al-A-02 ISSUE: The first instructional message failed to identify the local government organization and the official with the authority for providing the alert signal and instructional message. Instead, the Utility was listed as the agency with the authority for issuing the evacuation order.

CORRECTIVE ACTION DEMONSTRATED: The initial message included that there was a General Emergency declared at the D.C. Cook Nuclear Power Plant, that the Governor has declared a State of Disaster and has ordered the evacuation of Areas 1 and 3, that persons leaving the areas should follow steps outlined in the Emergency Information Calendar mailed by American Electric Power, and to stay tuned to the following radio and TV stations for further information. A list of 13 radio stations and three television stations followed. This was all the correct information needed and the previous issue number 15-07-5.a.1-A-02 is corrected.

f. PRIOR ISSUES - UNRESOLVED: None 19

4.2.2.3. Berrien County Traffic and Access Control Point

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

b. AREAS REQUIRING CORRECTIVE ACTION: 3.b.1.

ISSUE NO.: 15-09-3b1-A-01 CRITERION: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the admin of KI for emergency workers and institutionalized individuals (not general public) is maintained. (NUREG-0654, E.7., J.10.e.f.)

CONDITION: The decision to take KI was made by the State; however the implementation of that decision was not carried out by the Berrien County EOC in a timely manner.

POSSIBLE CAUSE: The procedures for the implementation of KI for EW in Berrien County were confusing and unorganized. Each agency implements the KI decision separately. Berrien County Dispatch does not prioritize requests as they are issued to them and other requests were completed by Berrien County Dispatch before the request for the ingestion of KI by the EW.

REFERENCE:

NUREG-0654, J.10.e EFFECT: The Berrien County Sheriffs EW in sub area 2 were never told to ingest KI and the EWs in Area 1,3, 5 were in the plume for 32 minutes before the Berrien County Dispatch instructed them to ingest KI. Depending on plume composition, the delay of notification could have the affected EWs to receive unnecessary radioiodine exposure to the thyroid.

RECOMMENDATION: Develop a method to inform all EWs (no matter what discipline) to ingest KI as one action, in the Berrien County EOC, perhaps by Dispatch. In addition, ensure that Berrien County Dispatch has a method to prioritize actions that are time sensitive.

c. DEFICIENCY: None 20

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.2.4. County Personnel in JIC

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None e.' PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.2.5. Emergency Alert System Radio Station WSJM

a. MET: 5.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.2.6.. Evacuee Monitoring and Decontamination -

New Buffalo High School

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 21

4.2.2.7. Evacuee Registration - New Buffalo High School

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.2.8. Congregate Care Center - New Buffalo High School

a. MET: 1.c.1,1.d.1,6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.2.9. Evacuee Vehicle Monitoring and Decontamination - New Buffalo High School

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None d., NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.2.10. Emergency Worker Monitoring - Berrien Springs Fire Department 22

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. 'DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.2.11. Emergency Worker Decontamination -

Berrien Springs Fire Department

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 4.2.2.12. Emergency Worker Equipment/Vehicle Monitoring and Decontamination - Berrien Springs Fire Department

a. MET: 1.c.1, 1.d.1, 1.e.1, 3.a.1,6.b.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. NOT DEMONSTRATED: None

e. PRIOR ISSUES - RESOLVED: None

f. PRIOR ISSUES - UNRESOLVED: None 23

APPENDIX 1 ACRONYMS AND ABBREVIATIONS ADRCS Adventist Disaster Response Community Services AEP American Electric Power ALARA As Low As Reasonably Achievable ARC American Red Cross ARCA Area Requiring Corrective Action BCRC Berrien County Road Commission BCSO " Berrien County Sheriff's Office CDC Communications Dispatch Center CIMS Critical Incident Management System CME Chief Medical Executive DAT Dose Assessment Team DO Duty Officer DRD Direct Reading Dosimeter EAS Emergency Alert System ECL Emergency Classification Levels EMC Emergency Management Coordinator EMD Emergency Management Division EMS Emergency Medical Services ENC Emergency News Center EOC Emergency Operations Center EPZ Emergency Planning Zone ERDS Emergency Response Data. System FAA Federal Aviation Administration FMT Field Monitoring Team FRA Federal Railroad Administration FTC Field Team Center FTCC Field Team Center Coordinator GE General Emergency GIS Geospatial Information System HF High Frequency ICS Incident Command System INP Initial Notification Point IWP Initial Warning Point JIC Joint Information Center LEIN Law Enforcement Information Network MARS Military Affiliated Radio System MIOC Michigan Intelligence Operations Center MPSCS Michigan Public Safety Communications System MSP Michigan State Police NBCFD New Buffalo City Fire Department NFEMP Nuclear Facility Emergency Management Plan NP Nuclear Plant NPP Nuclear Power Plant 24

NRC Nuclear Regulatory Commission PAA Protective Action Areas PAO Protective Action Orders PAR Protective Action Recommendation PIO Public Information Officer PM Portal Monitor PSAP Public Safety Answering Point RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Services REP Radiological Emergency Preparedness RO RADEF Officer SAE Site Area Emergency SEOC State Emergency Operations Center SOP Standard Operating Procedure TLD Thermal Luminescence Dosimeter TSG Technical Support Group VHF Very High Frequency 25

APPENDIX 2 EXERCISE EVALUATORS AND TEAM LEADERS DATE: 2009-09-15, SITE: D.C. Cook Nuclear Plant, MI LOCATION ~j~YEVALUATOR ~ ýAGENCY Initial Notification Point George R MacDonald ICF State Emergency Operations Center George R MacDonald ICF Clayton Spangenberg ICF Technical Support Group Sonia Eischen ICF Field Team Center Cell Michael Henry ICF Joint Information Center Robert Duggleby ICF Joint Information Center Hotline Robert Duggleby ICF State Liaison - Berrien County EOC - D.C. Cook and Palisades Clinton Crackel DHS/FEMA State DEQ Rep - Berrien Springs Fire Department Robert Black ICF State DEQ Rep - New Buffalo High School Frank Cordaro ICF Berrien County Initial Notification Point Edward Diaz DHS/FEMA Onalee Grady-Erickson ICF Berrien County Emergency Operations Center Edward Diaz DHS/FEMA Deborah Fulk DHS/FEMA Richard Grundstrom ICF.

Berrien County Traffic and Access Control Point Onalee Grady-Erickson ICF County Personnel in JIC Robert Duggleby ICF Emergency Alert System Radio Station WSJM Bruce Swiren ICF Evacuee Monitoring and Decontamination- New Buffalo High Clinton Crackel DHS/FEMA School Evacuee Registration - New Buffalo High School Nathalie Valley ICF Congregate Care Center - New Buffalo High School Nathalie Valley ICF Evacuee Vehicle Monitoring and Decontamination - New Buffalo Frank Cordaro ICF High School Emergency Worker Monitoring - Berrien Springs Fire Bruce Swiren ICF Department.

Emergency Worker Decontamination - Berrien Springs Fire Bruce Swiren ICF Department Emergency Worker Equipment/Vehicle Monitoring and Robert Black ICF Decontamination - Berrien Springs Fire Department 7 §b;~~~~Team Leader u______

26

STATE OF MICHIGAN AND BERRIEN COUNTY EXTENT OF PLAY AGREEMENT FOR THE D.C. COOK NUCLEAR PLANT REP EXERCISE September 15, 2009 Evaluation Area 1 - Emergency OperationsManagement Criterion 1.a.1: OROs use effective procedures to alert, notify and mobilize emergency personnel and activate facilities in a timely manner.

State of Michigan

1. The State Emergency Operations Center (SEOC) will be fully activated. State personnel reporting to the SEOC will be mobilized in accordance with procedures.

2. State personnel reporting to the county EOC will be pre-positioned and will report when mobilized by the SEOC. (approximately 30 minutes)

3. State personnel reporting to the Joint Information Center (JIC) will be pre-positioned and will begin participation after the arrival of county JIC personnel.

4. State personnel involved in out of sequence demonstrations willbe prestaged.

Berrien County

1. The Berrien County EOC will be activated and mobilized in accordance with procedures.

2. Berrien County JIC personnel will be mobilized in accordance with procedures.

Note: The use and interaction with E-team will not be evaluated.

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

State of Michigan

1. This criterion was demonstrated during the Palisades exercise on September 16, 2008.

2. The State Emergency Operations Center (SEOC) is maintained in operational readiness and set up will not be demonstrated.

Berrien County

1. This criterion was.demonstrated during the Palisades exercise on September 16, 2008.

2. Berrien County EOC will be set up prior to the start of the exercise.

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

27

State of Michigan, & Berrien County

1. This criterion will be demonstrated at the SEOC, county EOC, and JIC and in all out of sequence demonstrations.

Criterion 11.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.

State of Michigan, and Berrien County This criterion will be demonstrated by the SEOC, county EOC, the JIC, and Access Control. If both the primary and back-up systems fail, this objective may be demonstrated by successful use of an alternate method of communication.

Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI) and other supplies are sufficient to support emergency operations.

State of Michigan, and Berrien County

1. Equipment, maps, displays, and other supplies will be demonstrated to support emergency operations at the SEOC, JIC, and county EOC. in addition, out of sequence events.

2. Personnel involved in-traffic and access control points will demonstrate knowledge of where to secure traffic control equipment.

3. Potassium iodide and dosimetry are stored at each county's emergency management office the remaining at the Community Health office and at the MSP/EMHSD office in Lansing.

4. The Michigan Department of Environmental Quality maintains supplies of potassium iodide and dosimetry for use by its personnel.

5. Documentation related to KI shelf life extension is maintained by MSP/EMHSD and will be provided in the Evaluators Handbook.

Evaluation Area 2 - Protective Action Decision Makinq 28

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

State of Michigan

1. The ability to make the decision to recommend the use of KI to emergency workers will be demonstrated by the SEOC.

2. Authorization to exceed state exposure limits will be demonstrated. If the scenario does not provide an opportunity to demonstrate these items, a controller inject will be issued to demonstrate the ability to, perform these actions.

Note: The Chair of the Radiological Preparedness Coordinating Committee on a case-by-case basis may approve of the re-demonstration of this criterion.

Berrien County

1. This criterion does not apply to the counties.

Criterion 2.b.1: Appropriate protective action recommendations are based on available information on plant conditions, fieldmonitoring data and licensee and ORO dose projections, as well as knowledge of on-site and off-site environmental conditions.

State of Michigan

1. The Technical Support G*oup in the SEOC will evaluate licensee and FTC provided information and complete an independent analysis of scenario data.

2. Dose assessment evaluation will be conducted via interview with the individual performing the FTC role at the MSP/EMHSD office in Lansing.

Note: The Chair of the Radiological Preparedness Coordinating Committee on a case-by-case basis may approve of the re-demonstration of this criterion.

Berrien County

1. This criterion does not apply to the counties.

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

State of Michigan

1. The SEOC Executive Group in conjunction with applicable support staff will demonstrate this criterion. i.e. FTC, Tech support group.

Note: The Chair of the Radiological Preparedness Coordinating Committee on a case-by-case basis may approve of the re-demonstration of this criterion.

Berrien County

1. This criterion does not apply to the counties.

Criterion 2.c.1: Protective action decisions are made, as appropriate, for special population groups.

29

State of Michigan

1. This criterion will be demonstrated by the SEOC Executive Group in conjunction with applicable support staff, through the decision to recommend the use of KI to institutionalized persons.

Berrien County

1. Lists of transportation dependent and special needs populations are kept by the county. No personnel will be moved. No phone calls to transportation dependent persons will be made. Simulation of calls will be logged as such.

2. Equipment lists and rosters will be available in the county EOC.

3. The School Services Representatives in the Berrien County EOC will make phone contact with affected school districts if schools are in session. No scenario information will be discussed during these calls.

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

This criterion will not be demonstrated during this exercise.

Criterion 2.e.1: Timely re-location, re-entry and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the OROs plan and/or procedures.

This criterion will not be demonstrated during this exercise.

Evaluation Area 3 - Protective Action Implementation Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plan 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.

State of Michigan

1. This criterion will not be demonstrated by the state.

Berrien County

1. Berrien County will demonstrate this criterion out of sequence at the reception center and decontamination centers.

2. Berrien County will demonstrate this criterion at the access control point when emergency workers are issued dosimeters for use.

Note: The evaluator at his/her discretion may approve immediately for credit of the re-demonstration of this criterion.

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 30

for emergency workers and institutionalized individuals (not the general public) is maintained.

State of Michigan

.1. The State will demonstrate this objective through decision-making and directives to implement appropriate Protective Action Orders.

Berrien County

1. This criterion will be demonstrated during the traffic and access control demonstrations for, Berrien County. Response personnel will demonstrate knowledge of when it is appropriate to take KI, but not actually ingest it.

2. KI will be distributed to emergency workers in Berrien County along with their dosimeters.

Criterion 3.c.1: Protective action decisions are implemented for special population groups within areas subject to protective actions.

State of Michigan

2. This criterion will not be demonstrated by the state.

Berrien County 1 This criterion will be demonstrated in the county EOC via EOC staff discussions that may include evacuation of hospitals, nursing homes, correctional facilities, mobility impaired individuals, and transportation dependent. These discussions will be documented in situation logs.

3. Actual contacts to special population groups will not be made. Simulation of calls will be logged as such.

4. Berrien County will contact a minimum of four providers of transportation services, which may include public transit authorities, school systems for buses, ambulance services, or fire/rescue services. An endeavor will be made to contact a third of the total number of transportation providers. There will be no discussion of scenario information during these calls.

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

State of Michigan

1. This criterion will not be demonstrated by the state.

Berrien County

1. This criterion will be demonstrated Berrien County EOC as driven by the scenario. If schools are not in session, the DHS/FEMA evaluator will conduct an interview with the schools representative in the county EOC.

2. An EV-2 interview will be conducted in Berrien County. Refer to the Table of Exercise Demonstrations for specific times and locations.

Criterion 3.d.1: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel.

31

State of Michigan

1. This criterion will be demonstrated by the SEOC through the simulated opening or closing of: air, rail and waterways.

Berrien County

.1. Decisions related to traffic and access control will be demonstrated in Berrien County EOC. Berrien County demonstration locations will be determined during the exercise at a time agreed upon by the DHS/FEMA evaluator, the MSP/EMHSD Controller, and the county emergency management coordinator.

2. Staffing of all other access and traffic control points will be simulated.

Note: The evaluator at his/her discretion may approve immediately, for credit, the re-demonstration of this criterion.

Criterion 3.d.2: Impediments to evacuation are identified and resolved.

State of Michigan

1. This criterion will not be demonstrated by the state.

Berrien County

1. This will be demonstrated through discussions at the county EOC. Messages will be injected by MSP/EMHSD Controllers to drive these demonstrations.

Personnel will deal with the impediments by discussing the need for equipment, discussing its estimated time of arrival, etc. If the impediment posed involves road closures that would have been known to exercise participants during the course of normal .operations, this information will be provided to the players as part of the initial conditions for the exercise. All contacts, actual or simulated will be logged.

Note: The evaluator at his/her discretion may approve immediately for credit of the re-demonstration of this criterion.

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

This criterion will not be demonstrated during this exercise.

Criterion 3.e.2: Appropriate measures, strategies and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk and agricultural production.

This criterion will not be demonstrated during this exercise.

32

Criterion 3.f.11: Decisions regarding controlled re-entry of emergency workers and relocation and return of the public are coordinated with appropriate organizations and implemented.

This criterion will not be demonstrated during this exercise.

Evaluation Area 4 - Field Measurement and Analysis 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.

This criterion will not be demonstrated during this exercise.

Criterion 4.a.2: Field teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure.

This criterion will not be demonstrated during this exercise.

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

This criterion will not be demonstrated during this exercise.

Criterion 4.b.1: The field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making.

This criterion will not be demonstrated during this exercise.

Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions.

This criterion will not be demonstrated during this exercise.

33

Evaluation Area 5 - Emergency Notification and Public Information 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.

State of Michigan

1. The State will provide information to Berrien County for release in the Emergency Alert System messages.

Berrien County

1. The Berrien County Sheriff Department is the primary activation point for the public warning sirens. Berrien County also activates the Emergency Alert System. An interview with WSJM personnel will be conducted by DHS/FEMA following transmittal of EAS messages.

2. ARCA Issue 15-07-5a1-A-02 The first instructionalmessage failed to identify the local government organization and the official with the authority for providing the alert signal and instructionalmessage. Instead, the Utility was listed as the agency with the authority for issuing the evacuation order.

Note: The Chair of the Radiological Preparedness Coordinating Committee on a case-by-case basis may approve of the re-demonstration of this criterion.

Criterion 5.a.2: [RESERVED]

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

The D.C. Cook EPZ does not contain any DHS/FEMA approved exception areas.

This criterion will not be demonstrated during this exercise.

34

Criterion 5.b.1: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner.

State of Michigan, Berrien County

1. This will be demonstrated at the JIC via dissemination of emergency information and instructions through joint media briefings and news release announcements in coordination with the SEOC and county EOCs. All media briefings will be conducted at the JIC.

2. ARCA Issue 44-08-5b1-A-1 Two news releases were issued with incorrectand / or incomplete information. One contained the wrong emergency classification level. Both did not include all of the information that was contained in the AgriculturalAdvisories.

3. AEP Indiana Michigan will operate a public inquiry hotline during the exercise by personnel based at the Service Center in Buchanan. Trending is performed by the Public Inquiry Coordinator, who identifies trends and ensures appropriate information is provided to the public inquiry operators and the JIC for inclusion in media briefings.

Note: The Chair of the Radiological Preparedness Coordinating Committee on a case-by-case basis may approve of the re-demonstration of this criterion.

Evaluation Area 6 - Support Operation/Facilities 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.

State of Michigan'

1. State DEQ HP personnel will provide assistance as requested during these demonstrations.

Berrien County 1.. Berrien County will fully demonstrate separate emergency worker and public reception/decontamination centers out-of sequence from the exercise.

2. Public reception centers will demonstrate 1/3 of the monitoring teams required to monitor 20% of the population allocated to that facility within a 12-hour period, and will process six individuals through radiological monitoring.

Note: The Location for the Public Reception Decontamination Center is New Buffalo High School.

Note:. The evaluator at his/her discretion may approve immediately, for credit, the re-demonstration of this criterion.

Criterion 6.b.1: The facility/ORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency worker equipment including vehicles.

35

State of Michigan

1. State DEQ HP personnel will provide assistance as requested during these demonstrations.

Berrien County

1. Berrien County will each fully demonstrate an emergency worker/equipment decontamination center out of sequence with the exercise.

2. Emergency vehicles will be monitored and decontaminated as appropriate.

Note: The location for the Emergency Worker Decontamination Center is Berrien Spring Fire Station.

Note: The evaluator at his/her discretion may approve immediately, for credit, the re-demonstration of this criterion.

Criterion 6.c.1: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines. Managers demonstrate the procedures to assure that evacuees have been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities.

Berrien County

1. Berrien County will fully demonstrate a congregate care center out of sequence with the exercise. This facility will be set up in advance of the demonstration. Personnel operating the center will not go through alert, mobilization,. activation, or shift changes.

Note: The location for the Congregate Care Center will be the New Buffalo High School.

Note: The evaluator at his/her discretion may approve immediately, for credit, the re-demonstration of this criterion.

Criterion 6.d.I: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals.

Note: This criterion will be demonstrated during the MS-1 exercise on May 13, 2009.

Note: The evaluator at his/her discretion may approve immediately, for credit, the re-demonstration of this criterion.

Note:

The Lakeland Hospital in St. Joseph is currently under construction, and probably will be for the next few years. Because of this, there may be areas of the hospital that would normally be used for demonstration purposes that are under construction. Therefore, some demonstrations may need to be simulated in another area of the hospital that will not represent exactly what the area would look like under normal conditions. Please consider these issues at the time of the graded exercise.

36

SYNOPSIS D. C. Cook Unit 2 is a four loop Westinghouse ice condenser plant rated for approximately 1140 MW. The simulator is a full scope simulation of Unit 2. The release of radioactive material for this scenario is via the Unit 2 RHR suction line through the Containment Isolation valves. The valves are part of a system used to remove Decay Heat from the reactor during emergency operation of the plant.

The Auxiliary Exhaust system removes air from the RHR pump room and flows into the Unit 2 Auxiliary Building Ventilation Stack. A small fraction of the release will be from contaminated water in the Auxiliary Building Sump to the environment via the Unit 1 Ventilation Stack.

TIMELINE CLOCK TIME ELAPSED SCENARIO EVENT(S)

A.M. EDT TIME 0715 -00:45 Start Simulator Met Data APP 0755 -00:05 Shift turnover complete.

0800 00:00 Digital Impact Monitoring System alarm 0801 00:01 Locked Rotor #21 RCP 0801 00:01 Conditions met for Alert S-1 0805 00:05 Failed Fuel event. Plant and CNTMT radiation levels rise.

Event When attempt is made to close Containment Pressure Relief Isolation Valves after Driven performing a Containment Pressure Relief, the valves will not fully close.

0845 00:45 Containment radiation levels rise to >250 R/hr. Criteria met for Site Area Emergency (1.2L and 2.3L.)

0915 01:15 Large Break Loss of Coolant Accident event. Failed fuel released to CNTMT in preparation for release to Auxiliary Building and Atmosphere.

Event Crew begin Recirculation from Containment when RWST at 20%. ICM306 fails.

Driven 1000 02:00 Residual Heat Removal rupture event. Failed fuel released to Auxiliary Building and Atmosphere. GENERAL EMERGENCY (1.2L and 2.3L or 2.1L or 2.1P ,and 3.2L OR R-1.2)

• Release from Auxiliary building will drive doses off-site to indicate > 5 REM CDE at 5-6 miles from site. If dose assessment evaluation is performed dose assessment values will indicate >1 Rem at 5 miles driving a PAR due to EAL (1.2L and 2.3L or 2.1L or 2.1P ,and 3.2L OR.R-1.2 Offsite dose >1 R TEDE or >5 R Thyroid CDE).

-1115 03:15 Wind direction changes to WSW, stability class to F. A change in PAR transmitted to State of Michigan. Evacuate section 4 to Ten (10) miles.

-1145 03:45 Drill Terminates (except the Joint Information Center) when all drill objective activities have been observed/evaluated.

-1245 04:45 Joint Information Center terminates following completion of final media brief.

• NOTE: The release indicated on the U2 Vent Stack RMS monitors will be sufficient to cause off-site dose rates high enough to drive a change in PAR. A small fraction of the release will be through the Unit 1 Vent Stack RMS.

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