ML100610611

FEMA, Submittal of Final After Action Report for Limerick Generating Station Plume Exercise

ML100610611
Person / Time
Site:	Limerick
Issue date:	02/09/2010
From:	Hammons D US Dept of Homeland Security, Federal Emergency Management Agency
To:	Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
Download: ML100610611 (204)

Text

U.S. Department of Homeland Security Region III One Independence Mall, Sixth Floor 615 Chestnut Street

%0 FEMA Philadelphia, PA 19106-4404 NRC / NSIR Office MEB 0 9 20 M NRC Headquarters' Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Enclosed is the final After Action Report (AAR) for the Limerick Generating Station plume exercise. This report contains the results from the Federal Emergency Management Agency (FEMA) evaluated full scale plume phase exercise conducted the week of November 16-20, 2009 as well as a series of Out Of Sequence (OOS) demonstrations conducted June 10, 2009 and October 6-8, 2009.

No deficiencies were identified during the exercise. Nine (9) Areas Requiring Corrective Action (ARCAs) were identified; four (4) were successfully re-demonstrated during the exercise and four (4) were re-demonstrated on December 14, 2009. Nineteen (19) new planning issues were identified and fourteen (14) planning issues from a previous exercise were successfully resolved as part of this exercise.

Based on the results of the exercise, the offsite radiological emergency response plan and preparedness for the Commonwealth of Pennsylvania and the affected local jurisdictions, site specific to the Limerick Generating Station are adequate to protect the public health and safety and provide reasonable assurance that appropriate measures can be taken in the event of a radiological emergency at the site.

If you have any questions, please contact Michael E. Shuler, Sr., Limerick Generating Station Project Officer at (215) 931-5526.

Sincerely, Darrell Hammons Regional Assistance Committee Chairperson, Region III Enclosure ,,J(2YL www.fema.gov

Limerick Generating Station After Action Report/

Improvement Plan Exercise Date - November 17, 2009 Radiological Emergency Preparedness (REP) Program

• • FEMA Published February09, 2010

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-Unclassified Radiological, Emergency Preparedness. Program (REP)

After Action Report/Impro*'ement Plan Limerick Generating Station 4

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'Radiological Emergency Preparedness, Program (REP)

After Action Reportl/mprovement Plan Limerick Generating Station Limerick Generating Station After Action Report/Improvement Plan Published February09, 2010 Contents Executive Summary 10 Section 1: Exercise Overview 1.2 1.1 Exercise Details 12 1.2 Exercise Planning Team Leadership 12 1.3 Participating Organizations 16 Section 2: Exercise Design Summary 24 2.1 Exercise Purpose and Design 24 2.2 Exercise Objectives, Capabilities and Activities 28 2.3 Scenario Summary............... . 28 Section 3: Analysis of Ca'pabilities 31 3.1 Exercise Evaluation and Results 31 3.2 Summary Results of Exercise Evaluation 32 3.3 Criteria Evaluation Summaries 46 3.3.1 Pennsylvania Jurisdictions 46 3.3.1.1 Pennsylvania Emergency Operation Center 46 3.3.1.2 Pennsylvania Joint Information Center 48 3.3.1.3 Pennsylvania Accident Assessment Center, State 48 Emergency Operations Center-Bureau of Radiation Protection 3.3.1.4 Pennsylvania Bureau of Radiation Protection 48 Activities, Exelon Emergency Operating Facility, Coatesville 3.3.1.5 Pennsylvania State Traffic and Access Control 48 Points, State Police Barracks Skippack 3.3.1.6 Pennsylvania Bureau of Radiation Protection, 48 Radiological Rapid Response Vehicle 3.3.1.7 PA State Field Monitoring Team A, South East 49 Region 1

0 Unclassified Radiolcgical Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.1.8, PA State Field Monitoring Team B, South East 49 Region 3.3.2 Risk Jurisdictions 49 33.2.1 Berks County Emergency Operation Center 49 3.3.2.2 Berks County Reception Center, Morgantown 49 Crossing 3.3.2.3 Berks County Reception Center, Robeson Township 49 Building 3.3.2.4 Berks County Monitoring and Decontamination 50 Center, Governor Mifflin Senior High School 3.3.2.5 Berks County Mass Care Center, Governor Mifflin 51 40 Senior High School 3.3.2.6 Berks County Monitoring and Decontamination 52 Station, Muhlenberg Senior High School 3.3.2.7 Berks County Mass Care Center, Muhlenberg Senior 52 High School 3.3.2.8 Berks County Monitoring and Decontaminatiion 52 Center, Schuylkill Valley School Complex 3.3.2.9 Berks CountyMass Care Center, Schuylkill Valley 53 School Complex 3.3.2.10 Berks County Monitoring and Decontamination 53 Station, Wilson Central Junior High School 3.3.2.11 Berks County Mass Care Center, Wilson Senior 53 High School 3.3.2.12 Berks County, Boyertown Borough/Colebrookdale 54 Township Emergency Operations Center 3.3.2.13 Berks County, Colebrookdale Township Traffic and 56 Access Control 3.3.2.14 Berks County, Douglass Township Emergency 58 Operations Center 40 3.3.2.15 Berks County, Douglass Township Traffic and 59 Access Control 3.3.2.16 Berks County, Union Township Emergency 59 Operations Center 3.3.2.17 Berks County, Union Township Back-up Route 60 Alerting A 3.3.2.18 Berks County, Union Township Back-up Route 60 Alerting B 3.3.2.19 Berks County, Union Township Back-up Route 60 Alerting C 2

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'Un'classified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Statibn 3.3.2.20 Berks County, Washington Township Emergency 60 Operations Center 3.3.2.21 Chester County Emergency Operations Center 61 3.3.2.22 Chester County Emergency Worker Monitoring and 61 Decontamination Station, Valley Forge Intermediate School 3.3,.2.23 Chester County Reception Center, Downingtown 63

'*i High School 3.3.2.24 Chester County.Monitoring and Decontamination 63 Center, Downington High School 3.3.2.25 Chester County Mass Care Center, Avon Grove High 66 School 3.3.2.26 Chester County Mass Care Center, Fred Engle 66 Middle School 3.3.2.27 Chester County Mass Care Center, Gordon Middle 66 School 3.3.2.28 Chester County, Charlestown Emergency Operations 67 Center 3.3.2.29 Chester County, East Coventry Township 68 Emergency Operations Center-3.3.2.30 Chester County, East Coventry Township Traffic 69 and Access Control 3.3.2.31 Chester County, South Coventry Township 69 Emergency Operations Center 3.3.2.32 Chester County, Schuylkill Township Emergency 71 Operatiofis Center 3.3.2.33 Chester County, Schuylkill Township Back-up Route 71 Alerting A 3.3.2.34 Chester County, Schuylkill Township Back-up Route 71 Alerting B 3.3.2.35 Chester County, Schuylkill Township Back-up Route 73 Alerting C 3.3.2.36 Chester County, Schuylkill Township Traffic and 73 Access Control 3.3.2.37 Chester County, West Pikeland Emergency 74 Operations Center 3.3.2.38 Chester County, West Pikeland Township Traffic 75 and Access Control 3.3.2.39 Chester County, West Vincent Township Emergency 75 Operations Center 3

Ur.classified RadiologicalEmergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.40 Chester County. West Vincent Township Traffic and 75 Access Control 3.3.2.41 Montgomery County Emergency Operations Center 76 3.3.2.42 Montgomery County Emergency Worker Monitoring 77 and Decontamination Station, Upper Perkiomen High School 3.3.2.43 Montgomery County, Douglass Township 77 Emergency Operations Center 3.3.2.44 Montgomery County, Lower Providence Township 78 Emergency Operations Center 3.3.2.45 Montgomery County, Lower Providence Township 78 Traffic and Access Control 3.3.2.46 Montgomery County, Lower Salford Township 78 Traffic and Access Control 3.3.2.47 MontgomeryCounty, Lower Salford Township 79 Emergency Operations Center 3.3.2.48 Montgomery County, Pottstown Borough 80 Emergency Operations Center 3.3.2.49 Montgomery County; Pottstown Borough Traffic and 80 Access Control 3.3.2.50 Montgomery County, Upper Frederick Township 80 Emergency Operations Center 3.3.2.51 Montgomery County, Upper Pottsgrove Township 81 Emergency Operation Center 3.3.2.52 Montgomery County, Upper Pottsgrove Township 82 Back-up Route Alerting 3.3.2.53 Montgomery County, Upper Pottsgrove Township, 83 Traffic and Access Control 3.3.2.54 Berks County, Boyertown Area School District 84 3.3.2.55 .Berks County, Boyertown Area District, Boyertown 84 Elementary School 3.3.2.56 Berks County, Boyertown Area School District, 84 Boyertown Senior High School 3.3.2.57 Berks County, Boyertown Area School District, 84 Boyertown Junior High School West 3.3.2.58 Berks County, Boyertown Area School District, New 85 Hanover/Upper Frederick Elementary School 3.3.2.59 Berks County, Boyertown Area School District, 85 Washington Elementary School 3.3.2.60 Berks County, Daniel Boone Area School District 85 4

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Unclassified Radiological Emergency Preparedness: Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.6,1 Berks County, Daniel Boone Area District, 86 Monocacy Elementary Center 3.3.2.62 Berks County, Daniel Boone Area SchoolDistrict, 86 Daniel Boone High School 3.3.2.63 Chester County, Downingtown Area School District 86 3.3.2.64 Chester County, Downingtown Area School District, 87 Downingtown High.School East 3.3.2.65 Chester County, Downingtown Area School District, 87 Downingtown High School West 3.3.2.66 Chester County, Downinirgtown Area School District, 87 Lionville Middle School.

3.3.2.67 Chester County, D6wningtown Area School District, 88 Shamona Creek Elementary School 3.3.2.68 Chester County, D6wningtown Area School District, 88 Uwchlan Hills Elementary School.

3.3.2.69 Chester County, Great Valley' School District, Great 88 Valley Middle School 3.3.2.70 Chester County, Great ValleySchool District, KD 88 Markley Elementary School 3.3.2.71 Chester County, Owen J. Roberts School District 89 3.3.2.72 Chester County, Owen J. Roberts School. District, 89 East Coventry Elementary School 3.3.2.73 Chlester County, Owen J. Roberts School District, 89 East Vincent Elementary School 3.3.2.74 Chester County, Owen J. Roberts School District, 90 Owen J. Roberts High School 3.3.2.75 Chester County, Phoenixville Area School District 90 3.3.2.76 Chester County, Phoenixville Area School District, 90 Phoenixville Area High School 3.3.2.77 Chester County, Phoenixville Area School District, 90 Kindergarten Center 3.3.2.78 Montgomery County, Methacton School District, 91 3.3.2.79 Montgomery County, Methacton School District, 91 Methacton High School 3.3.2.80 Montgomery County, Methacton School District, 91 Arcola Intermediate School 3.3.2.81 Montgomery County, Methacton School District, 91 Eagleville Elementary School 5

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.82 Montgomery County, Perkiomen Valley School 92 District 3.3.2.83 Montgomery County, Perkiomen Valley District, 92 Schwenksville Elementary School 3.3.2.84 Montgomery County, Perkiomen Valley School 92 District, Perkiomen Valley Elementary South 3.3.2.85 Montgomery County, Perkiomen Valley School 92 District, Perkiomen Valley High School 3.3.2.86 Montgomery County, Pottsgroye School District 93 3.3.2.87 Montgomery County, Pottsgrove, School District, 94 Lower Pottsgrove Elementary School 3.3.2.88 Montgomery County, Pottsgrove School District, 95 West Pottsgrove Elementary School 3.3.2.89 Montgomery County, Pottstown Area School District 95 3.3.2.90 Montgomery County, Pottstown Area School 95 District, Edgewood Elementary School 3.3.2.91 Montgomery County, Pottstown Area School 95 District, Franklin Elementary School 3.3.2.92 Montgomery County, Pottstown Area School 96 District, Lincoln Elementary School 3.3.2.93 Montgomery'County, Pottstown Area School 96 District, Pottstown Middle School 3.3.2.94 Montgomery County, Souderton Area School 96 District 3.3.2.95 Montgomery County, Souderton Valley Area School 96 District, Indian Valley Middle School 3.3.2.96 Montgomery County, Spring-Ford Area School 97 District 3.3.2.97 Montgomery County, Spring-Ford Area School 99 District, 5th, 6th, &7th Grade Center 3.3.2.98 Montgomery County, Spring-Ford Area School 99 District, Limerick Elementary School.

3.3.2.99 Montgomery County, Spring-Ford Area School 99 District, Spring-Ford Area High School 3.3.2.100 Montgomery County, Spring-Ford Area School 99 District, Evans Elementary School 3.3.2.101 Montgomery County, Spring-Ford Area School 100 District, Upper Providence Elementary School 3.3.2.102 Montgomery County, Spring-Ford Area School 100 District, Royersford Elementary School 6

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.103 Montgomery County, Upper Perkiomren School 100 District 3.3.2.104 Montgomery County, Upper Perkiomen School 102 Distirct, Upper Perkiomen High School 3.3.2.105 Montgomery County, Upper Perkiomen School 102 District, Marlborough Elementary School 3.3.3 Support Jurisdictions. 102 3.3.3.1 Bucks County Emergency Operations Center 102 3.3.3.2 Bucks County Mass Care Center, Bucks County 102 Community College, 3.3.3.3 Bucks County Mass Care Center, Central Bucks 103 West High School 3.3.3.4 Bucks County Mass Care Center, Central Bucks East 103 Complex 3.3.3.5 .Bucks County Mass Care Center, Delaware Valley 103 College 3.3.3.6. Bucks County Mass Care Center, New'Hope- 104 Solebury Jr./Sr. High School , . .

3.3.3.7 Bucks County Mass Care .Center, Palisades JrSr 104 High School 3.3.3.8 Bucks County Mass Care Center,. Pennridge Central 104 Junior High School 3.3.3.9 Bucks County Mass Care Center, Pennridge Lower 104 High School 3.3.3.10. Bucks County Mass Care Center, Pennridge South 105 Jr. High School 3.3.3.11 Bucks County Mass Care Center, Pennridge Upper 105 High School 3.3.3.12 Bucks County Mass Care Center, Unami Jr. High 105 School 3.3.3.13 Lehigh County Emergency Operations Center 105 3.3.3.14 Lehigh County Mass Care Center, DeSales 106 University 3.3.3.15 Lehigh County Mass Care Center, Eyer Jr. High 106 School 3.3.3.16 Lehigh County Mass Care Center, Orefield Middle 106 School 3.3.3.17 Lehigh County Mass Care Center, Salisbury Middle 106 School 7

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.3.18 Lehigh County Mass Care Center, South Mountain 107 Middle School 3.3.3.19 Lehigh County Mass Care Center, Springhouse 107 Middle School 3.3.3.20 Lehigh County Mass Care Center, Troxell Jr. High 107 School 3.3.3.21 Chester County, Great Valley School District 107 3.3.3.22 Chester County, Great Valley School District, Great 108 Valley High School 3.3.4 Private Organizations 108 3.3.4.1 Exelon Joint Information Center 108 Section 4: Conclusion 109 Appendix A: Improvement Plan 110 Appendix B: Exercise Timeline 119 Appendix C: Exercise Evaluators and Team Leaders 123 Appendix D: Acronyms and Abbreviations 129 Appendix E: Exercise Plan 132 8

Unclassified Radiological Emergency Preparedness Program (REP)

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station EXECUTIVE

SUMMARY

During the week of November 16, 2009, a full-scale evaluated plume exercise was conducted in the 10-mile plume exposure pathway, Emergency Planning Zone (EPZ) around the Limerick Generating Station (LGS) by the Federal Emergency Management Agency (FEMA), Region III.

Out-of-sequence Mass Care demonstrations were conducted the 6th,7th, and 8th of October 2009. A Medical Services (MS-1) drill was also evaluated June 10, 2009. The purpose of the exercise and the out-of-sequence demonstrations were to assess the State and local offsite response organization preparedness in responding to a radiological emergency. The exercise and out-of-sequence demonstrations were held in accordance with FEMA's policies and guidance concerning the exercise of State and local radiological emergency response plans (RERP) and procedures.

The most recent prior full-scale exercise at this site was conducted on August 7, 2007.

FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Pennsylvania; the risk jurisdictions of Berks, Chester, and Montgomery Counties; the support jurisdictions of Bucks and Lehigh Counties; and 16 participating municipalities who were evaluated during this exercise.

Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility as volunteers providing vital emergency services twenty four (24) hours to the communities of which they live. Cooperation and teamwork of all the participants was observed during this exercise.

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

- Mass Care evaluations were conducted on October 6-8, 2009 in Bucks, Chester, and Lehigh Counties.

- Mass Care evaluations were also conducted as part of the out-of-sequence acativites November 18, 2009 in Berks and Montgomery Counties.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan I I Limerick Generating Station Emergency Workers, Equipment, and Vehicles - Monitoring and Decontamination were conducted on November 18, 2009 in Berks, Chester, and Montgomery Counties.

• School Interviews were conducted on November 17, 2009 in Berks, Chester, Montgomery, and Berks Counties.

- Traffic/Access Control interviews with the Pennsylvania State Police Skippack Barracks 2047C, Bridge Road, Schwenksville, Montgomery County were conducted on November 17, 2009.

The Commonwealth of Pennsylvania and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Deficiencies. Nine (9) Areas Requiring Corrective Action (ARCAs) were identified as a result of this exercise. Four (4) of the ARCAs were successfully re-demonstrated during the exercise and four(4) were re-demonstrated on December 14, 2009.

There were no ARCAs from the previous exercise demonstrated during this exercise. Nineteen (19) new planning issues were identified of which 5 were closed and 1 ARCA remains open.

Fourteen (14) planning issues from a previous exercise were successfully demonstrated with 2 planning issues unresolved. (see Appendix A for all planning issues).

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Unclassified Radiological Emergency' Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Limerick Generating Station Type of Exercise Plume Exercise Date November 17, 2009 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Michael Shuler FEMA Project Officer/Site Specialist FEMA Technological Hazards Program Specialist 1 Independence Mall, 6th Floor 615 Chestnut St Philadelphia, Pennsylvania, 19106 215-931-5526 michael.shuler@dhs.gov 12 6

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Martin Westermann Drill & Exercise Coordinator Exelon Nuclear Drill & Exercise Coordinator 200 Exelon Way Kennett Square, Pennsylvania, 19348 610-156-5638 martin.westermann@exeloncorp.com Jeffrey Dean Off-site EP Coordination Exelon Nuclear Off-Site EP Coordinator 298 Longview Road Royersford, Pennsylvania, 19468 610-718-2022 jeffrey.dean@exeloncorp.com Alan Brinser Planning Coordination Pennsylvania Emergency Management Agency Emergency Managment Specialist 2605 Interstate Drive Harrisburg, Pennsylvania, 17110 717-651-2217 abrinser@state.pa.us John Price Alternate Site Specialist Federal Emergency Management Agency Senior Technological Hazards Program Specialist 615 Chestnut Street Philadelphia, Pennsylvania, 19106 13

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 215-931-5570 john.price@dhs.gov Victor Wilson, Sr.

Emergency Management Specialist Pennsylvania Emergency Management Agency Emergency Management Specialist 2605 Interstate Drive Harrisburg, Pennsylvania, 17110 717-651-2136 vicwilson@state.pa.us Henry Tamanini Planning Coordination Pennsylvania Emergency Management Agency Chief, Technological Hazards Division 2605 Interstate Drive Harrisburg, Pennsylvania, 17110 717-651-2723 hetamanini@state.pa.us Karl Mehn Planning Coordination Chester County Department of Emergency Management Deputy Director for Emergency Management 601 Westtown Road West Chester, Pennsylvania, 19380 610-344-5000 kmehn@chesco.org 14 S

.Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Stati6n Tony Przychozien Planning Coordination Chester County Emergency Management Radiological Response Coordinator 601 WestTown Road West Chester, Pennsylvania, 19380 610-344-5000 tprzychodzien@chesco.6rg Jeffrey Weidner Planning Coordination Berks County Department of Emergency Services Planning Manager Direct Link Technology Center 2561 Bernville Road Reading, Pennsylvania, 19605 610-236-8211 jweidner@countyofberks.com Jason Wilson Planning Coordination Montgomery County Office of Emergency Management Radiological Planner/ Trainer 50 Eagleview Road Eagleville, Pennsylvania, 19403 610-631-6524 jwilson@montcopa.org 15

>Unclassified Radiological Emergency. Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Thomas Nervine Planning Coordination Lehigh County Emergency Management Agency Director 640 W. Hamilton Street Allentown, Pennsylvania, 18102 610-782-4600 thomasnervine@lehighcounty.org John Dougherty, Jr.

Planning Coordination Bucks County Emerency Management Agency Coordinator 911 Freedom Way Ivyland, Pennsylvania, 1,8974 215-340-8700 jdougherty@co.bucks.pa.us 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Limerick Generating Station exercise:

State Jurisdictions Pennsylvania Emergency Management Agency Pennsylvania Department of Agriculture Pennsylvania Department of Community & Economic Development Pennsylvania Department of Corrections Pennsylvania Department of Environmental Protection Pennsylvania Department of Environmental. Protection-Bureau of Radiation Protection Pennsylvania Department of Fish and Boat Commission Pennsylvania Departmnent of General Services Pennsylvania Department of Health Pennsylvania Department of Industry 16

'Unclassified Radiological Emergency Preparedness, Program (REP)

After Action Report/Improvement Plan Limerick GeneratingStation Pennsylvania Department of Natural Resources Pennsylvania Department of Public Welfare Pennsylvania Department of Transportation Pennsylvania National Guard Pennsylvania Office of Administration Pennsylvania State Police Pennsylvania State University - Agricultural Extension Service Pennsylvania Turnpike Commission Pennsylvania Utility Commission Risk Jurisdictions Berks County Emergency Management Agency (EOC)

Berks County Fire/ Police/ EMS Berks County Planning Commission Berks County Public Works Department Berks County Sheriffs Office Berks County Radio Amateur Civil Emergency Services (RACES)

Berks County Amateur Radio Emerency Services (ARES)

Berks County, Boyertown Borough, Public Works Department Berks County, Boyertown Borough, Emergency Medical Servces (EMS)

Berks County, Boyertown Borough, Boyertown Area School District Berks County, Colebrookdale Township Emergency Management Agency (EOC)

Berks County, Colebr6okdaie Township, Public Works Department Berks County, Colebrookdale Township, LibertyFire Company/New Berlinville Berks County, Caernarvon Township Emergency Management Agency (EOC)

Berks County, Caernarvon Township, Police Department Berks County, Caernarvon Township, Administration Berks County, Daniel Boone Area School District Berks County, Douglass Township Emergency Management Agency (EOC)

Berks County, Douglass Township, Police Department Berks County, Grill Fire Department Berks County, Goodwill Fire Company Berks County, Kenhorst Fire Department Berks County, Mohnton Borough, Mohnton Fire Company Berks County ,Robeson Township, Department of Roads 1.7

'Uncassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Berks County;RobesonTownship, Police Department Berks County, Shillington Borough, Shillington Fire Department Berks County, Spring Township, Volunteer Fire Department Berks County, Temple Fire Company Berks County, Twin Valley Fire/Police/EMS Berks County, Union Township Emergency Managment Agency (EOC)

Berks County, Union Township, Kulptown,Fire Company Berks County, Washington Township, Board of Supervisors Berks County, Washington Township Emergency Management Agency (EOC)

Berks County, Washington Township, Public Works Department Berks County, Washington Township, Barto Fire Company Berks County West Side Regional Emergency Management Agency (EOC)

Chester County Department of Emergency Services (EOC)

Chester County Hazardous Materials Response Team - Station 15 Chester County Radio0Amateur Civil Emergency services (RACES)

Chester County Amateur Radio Emergency Services (ARES)

Chester County Fire/Police/EMS Chester County Debris Management Chester County Donation Management Chester County Public Informatiofi Chester County Department of Transportation Chester County Parks and Recreation Chester County Public Works Department Chester County Sheriffs Office Chester County Agriculture Chester County Animal Care Chester County Energy Chester County Urban Search and Rescue Chester County, Charlestown Township Emergency Management Agency (EOC)

Chester County, Charlestown Township, Public Works Department Chester County, Charlestown Township, Board of Supervisors Chester County, East Whiteland Township, Volunteer Fire Company Chester County, East Coventry Township Emergency Management (EOC)

Chester County, East Coventry Township, Police Department 18 0

Unclassified Radiological Emergency Preparedness,Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Chester County, East Coventry Township, Public Works Department Chester County, East.Coventry Township, Board of Supervisors Chester County, East Coventry Township, Ridge Fire Company Chester County, East Nantmeal Township Emergency Management Agency (EOC)

Chester County, ElversonBorough, Fire/Police/EMS Chester County, Liberty Steam Fire Company, Chester County, Lionville Fire Company Chester County,.North Coventry, Fire Department Chester County, North Coventry,. Police Department Chester County, North Coventry Township Emergency Management Agency (EOC)

Chester County, Schuylkill, Township Emergency Management (EOC)

Chester County, Schuylkill Township, Fire & Rescue .*

Chester County, Schuylkill Township, Police Department Chester County, Schuylkill Township, Public Works Department Chester County, Schuylkill Township, Public Health Department Chester County, Schuylkill Township, Transportation Department Chester County, South Coventry Township, Public Works Department Chester County, Spring City Borough, Chester County, Twin Valley Fire Department Chester County, Upper Uwchlan Township Emergency Management Agency EOC.

Chester County, Upper Uwchlan Township, Police/EMS Chester County, Upper Uwchlan Township, Public Works Department Chester County, Valley Forge Volunteer Fire Station Chester County, Warwick Township, Board of Supervisors Chester County, West Pikeland Township, Police Department Chester County ,West Pikeland Township Emergency Management (EOC)

Chester County, West Vincent Township, Police Department Chester County, West Vincent Township Emergency Management (EOC)

Chester County, West Vincent Township, Ludwigs Comer Volunteer Fire Department .

Chester County, West Vincent Township, Public Health Department Chester County, West Vincent Township, Public Works Department Chester County, West Vincent Township, Board of Supervisors 19

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Chester County, Downingtown: Area School District Chester County, Great ValleySchool District Chester County, Owen J. Roberts School District, Chester County, Phoenixville Area School District Montgomery County Office of Emergency Preparedness (EOC)

Montgomery County Commissioners Office Montgomery County Critical Incident Stress Management Team Montgomery County Public Safety Department Montgomery County Public Works Department Montgomery County Attorneys Office 6 Montgomery County Emergency Management Services Montgomery County Fire/Police/EMS Montgomery County Radio Amateur Civil Emergency services (RACES)

Montgomery County Amateur Radio EmergencyServices (ARES)

Montgomery County Health Care Support Zone Montgomery County Health Services Department Montgomery County Sheriffs Office.

Montgomery County, Collegeville Borough Emergency Management Agency (EOC)

Montgomery County, Collegeville Borough, Fire Department Montgomery County, Collegeville Borough, Police Department Montgomery County, Douglass Township, Highway Department Montgomery County, Douglass Township, Police Department Montgomery County, Friendship Fire Company Montgomery County, Gilbertsville Ambulance Service Montgomery County, Gilbertsville Fire and Rescue..

Montgomery County, Greater Philadelphia Search and Rescue Montgomery County, Lansdale, Volunteer Medical Services Corporation Montgomery County, Lower Salford, Harleysville Community Fire Company Montgomery County, Pottstown Borough, Emergency Management Agency (EOC)

Montgomery County, Lower SalfordTownship, Police Department Montgomery County, North Penn Volunteer Fire Company Montgomery County, Oaks Volunteer Fire Department 20 0

Unclassified Radiological Emergency Preparedness Piogram (REP)

After Action Report/Improvement Plan Limerick Generating Station Montgomery County,. Pottstown Borough,. Police Department -

Montgomery County, Pottstown Borough, Fire Department Montgomery County, Pottstown Borough, Public Works Department Montgomery County, Philadelphia Office of Emergency Management Montgomery County, Perkiomen Township, Red Hill Volunteer Fire Company Montgomery County, Royersford Borough, Friendship Volunteer Fire Company Montgomery County, Royersford Borough, Humane Volunteer Fire Company Montgomery County, Royersford Borough, Police Department Montgomery County, Royersfofd Borough, Public Works Department Montgomery County, Schwenksville Borough, Emergency Managment Agency (EOC) ..

Montgomery County, Schwenksville, Borough,'Fire Department Montgomery County, Schwenksville Borough, Police Department-Montgomery County, Skippack Township, Board of Supervisors Montgomery County, Skippack Township, Fire Company Montgomery County, .Skippack Township; Public Works Department Montgomery County, Trappe Borough, Fire Department Montgomery County, Upper Frederick Township, Volunteer Fire Department Montgomery County, Upper Frederick Township, Board of Supervisors Montgomery County, Upper Pottsgrove Township Emergency Management Agency (EOC)

Montgomery County, Upper Pottsgrove Township, Police Department Montgomery County, Upper Pottsgrove Township, Fire Company Montgomery County, Upper Pottsgrove Township, Public Works, Department Montgomery County, Upper PottsgroveTownship, Goodwill Ambulance Service Montgomery County, Upper Providence Township, Administration Office Montgomery County, Upper Providence. Township, Board-of Supervisors Montgomery County, Upper Providence Township Emergency Management Agency (EOC)

Montgomery. County, Upper Providence Township, Fire Department Montgomery County, Upper Providence Township, Police Department Montgomery County, Upper Providence Township, Public Works Department Montgomery County, Upper Salford Township, Police Department Montgomery County, Upper Salford Township, Volunteer Fire Company 21

'Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Montgomery County, Methacton Area School District Montgomery County, Perkiomen Valley School District Montgomery County, Pottsgrove School District Montgomery County, Pottstown Area School District Montgomery County, Spring -Ford Area School District Montgomery County, Upper Perkiomen School District Support Jurisdictions Bucks County Emergency Management Agency (EOC)

Bucks County, Emergency Medical Services Bucks County, Fire Marshall Bucks County, Health Department Bucks County, Public Information Office Bucks County, Regional Health Department Bucks County, Sheriffs Office Bucks County, Bensalem Township, Police Department Bucks County, Trevose Fire Company Lehigh County, Coopersburg Borough, Police Department Lehigh County, Eastern Pennsylvania Emergency Medical Services Council Lehigh County, Emmaus Borough, Volunteer Fire Department Lehigh County, Agricultural Extension Lehigh County Emergency Management Agency (EOC)

Lehigh County, Public Information Lehigh County, Public Works Department Lehigh County, Sheriffs Department Lehigh County, Tech Rescue Lehigh County, Allentown Township, Fire Department Lehigh County, Animal Response Team Lehigh County, Radio Amateur Civil Emergency Services (RACES)

Lower Milford Township, Volunteer Fire Department Lehigh County Southern Lehigh School District Lehigh County, Upper Saucon Township, Ambulance Lehigh County, Upper SauconTownship, Volunteer Fire Department Private Organizations Albert Einstein Medical Center 22 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station American Red Cross-Berks County American Red Cross-Greater Lehigh Valley American Red Cross-Lower Bucks County American Red Cross-Southeastern Pennsylvania Bucks County Amateur Radio Emergency Services Chester County Amateur Radio Emergency Services, Civil Air Patrol Delaware Valley Health CareCentral Exelon Nuclear Holy Redeemer Health System Lehigh Valley Amateur Radio Emergency Services Mercy Suburban Hospital Montgomery County Amateur, Radio Emergency Services, Reading Hospital Medical Center Saint Joseph Hospital Stace's Towing Service (Berks County)..

Federal Jurisdictions Federal Emergency Management Agency, Nuclear Regulatory. Commission' U.S. Department of Agriculture (USDA) - Farm Service Agency 23

.Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station SECTION 2: EXERCISE DESIGN

SUMMARY

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

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

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

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

A. Taking the lead in offsite emergency planning and in the review and evaluation of Radiological Emergency Response Plans (RERPs) and procedures developed by State and local governments; B. 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; C. Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17, 1993 (Federal Register, Vol. 58, No. 176, September 14, 1993; and D. 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, 24 0

. Unclassified Radiological Emergency Preparedness' Program (REP)

After Action Report/Improvement Plan 'Limerick Generating Station

- U.S. Environmental Protection. Agency,

- U.S. Department of Energy,

- U.S. Department of Health and Human Services,

- U.S. Department of Transportation,

- U.S. Department of Agriculture,

- U.S. Department of the Interior, and

- U.S. Food and Drug Administration.

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

A REP exercise was conducted on Novewmber 17, 2009, 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 Limerick Generating Station (LGS). The purpose of this exercise report is to present the exercise results and findings on the performance of the off-site response organizations (OROs) during a simulated radiological emergency. "

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

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

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

A. 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; B. FEMA Guidance Memoranda MS-1, "Medical Services," November 1986; C. FEMA-REP-14, "Radiological Emergency Preparedness Exercise Manual," September 1991; 25

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station D. 66 FR 47546, "FEMA Radiological Emergency Preparedness: Alert and Notification,"

September 12, 2001; and E. 67 FR 20580, "FEMA Radiological Emergency Preparedness: Exercise Evaluation Methodology," April 25, 2002.

Section III of this report, entitled "Exercise: Overview," presents basic information and data relevant to the exercise. This section of the report contains a description of the plume pathway emergency planning zone (EPZ), a listing of all participating jurisdictions and functional entities that were evaluated, and a tabular presentation of the time of~actual occurrence of key exercise events and activities.

Section IV of this report, entitled "Exercise Evaluation, andResults," presents detailed information on the demonstration of applicable exercise evaluation areas at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format. This section also contains:

(1) descriptions of all Deficiencies and Areas Requiring Corrective Action (ARCAs) assessed during this exercise, recommended corrective actions, and the Tribal, State, and local governments' schedule of corrective actions for each identified exercise issue and (2) descriptions of ARCAs assessed during previous exercises and resolved at this exercise, including the corrective action demonstrated, as well as ARCAs assessed during previous exercises and scheduled for demonstration at this exercise which remain unresolved.

The final section of the report is comprised of the appendices, which present the following supplementary information: acronyms and abbreviations, exercise evaluators and team leaders, exercise evaluation area criteria and extent of play agreement, and the exercise scenario. It also presents information on planning issues (both new planning issues identified during this exercise and resolved planning issues identified during previous exercises).

Contained in this section is a basic description of the plume pathway emergency planning zone (EPZ).

LGS is located in southeastern Pennsylvania on the Schuylkill River about 1.7 miles southeast of Pottstown Borough. The river passes through the site, separating the western portion, which is in East Coventry Township in Chester County, from the eastern portion, which is in Limerick and 26 0

Unclassified Radiological Emergency Preparedness Peogram (REP)

After Action Report/Improvement Plan Limerick Generating Station Lower Pottsgrove Townships in Montgomery County. The plant is owned and operated by Exelon Nuclear Two boiling water reactors each generate an electrical output of 1,050 megawatts (MW). Unit 1 was issued a full-power license in August 1985; commercial operations began in February 1986. Unit 2 was issued a full-power license in August 1989 with commercial operations beginning in January 1990.

The site encompasses 595 acres and is divided into three (3) parts. The principal portion, where the major operating equipment and buildings are located, is on the east bank of the Schuylkill River. This portion is separated from the second segment, where the cooling water intake is located, near the main line of the Reading Railroad.. The third portion lies on the west bank of the river, adjacent to Conrail railroad tracks. .,The site coordinates are approximately 40'13'27"N and 75035 '15"W.

The minimum exclusion distance for the:LGS is 2,500 feet from the center of eachreactor. The utility owns all the land within the exclusion .area. No private residences are located within the exclusion area; however, some farming may -be permitted.

There are 165 sirens installed to cover the 10-mile plume exposure pathway EPZ. These sirens are activated three (3) minutes before the Emergency Alert System (EAS) messages issued by the Commonwealth of Pennsylvania .are broadcast.

Soils in this area are of the Reaville-Penn-Klinesville Association and are characteristic of rolling uplands. They are underlain by sedimentary rocks of the Brunswick Formation, consisting mostly of red shale with some fine-grained sandstone interbedding.

The normal pool elevation of the Schuylkill River in this area is 200 feet above mean sea level (msl). The topography of the area is hilly, with elevations ranging from 100-300 feet above msl within five (5) miles of the site. The plant is approximately 217 feet above msl.

The climate in this area is dominated.by prevailing westerly winds that produce humid, continental-type weather characterized by warm summers and moderately cold winters.

Montgomery County is the warmest part of Pennsylvania, with an average annual temperature of 57°F. Annual precipitation is approximately 42 inches.

The area in the immediate vicinity of the plant is made up mostly of agricultural and other open 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station land. The Pottstown Borough in Montgomery County is the nearest community and has a population of 21,859 based on the 2000 Census. The nearest major population center (more than 25,000 people) is Philadelphia that lies 25 miles to the Southeast of the site.

Two major industries employ a total of 850 persons within two (2) miles of the plant. Two small airfields are also located nearby. A small private airfield is about one (1) mile to the northeast, but its runway is oriented so that the flight path does not pass over the plant. The Pottstown Municipal Airport is 4.3 miles northwest of the site. The LGS does not lie in the approach pattern for this airport.

No major thoroughfares are located in the immediate vicinity of the plant. The main line of the Reading Railroad runs along the north bank of the Schuylkill River and traverses the site about 500 feet from the plant.

2.2 Exercise Objectives, Capabilities and Activities Exercise objectives and identified Capabilities/REP Criteria selected.to be exercised are discussed in Appendix D "Exercise Plan"..

2.3 Scenario Summary 1500 Start Exercise Wind Direction from 45 degrees @ 6 MPH "E" Stability Class. Equipment Out of Service: "A" Residual Heat Removal' (RHR) (Planned Motor Work), "A" Drywell Chiller (emergent system outage) 1515 Event # 1: Greater than 10 gpm Reactor Water Clean-Up (RWCU) UNIDENTIFIED leak inside drywell. A body-to-bonnet leak develops on the inboard Reactor Water Cleanup (RWCU) suction isolation valve (HV44-1F001) in the Drywell. Drywell pressure increases but stabilizes at a value of approximately 0.7-0.9 psig.

1545 Unusual Event declared MU7 Reactor Coolant System Leakage Unidentified primary system leakage > 10 gpm into the Drywell. (As indicated on Flow Indicators FI-61-115 and 135) 1640 Event #2: Drywell Pressures increases above 1.68 # due to Reactor Coolant System Leak.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating.Station Operators should scram the reactor and transfer plant electrical "house loads"'prior to the 1.68#

scram signal. D/W pressure ramp to 1.68# -10 minutes. Ramp rise stops at -3.00#. Controller Interject: Maintain Rx Pressure - 500#. Failures: High Pressure Coolant Injection (HPCI ) failed flow controller, Reactor Enclosure Recirculation System (RERS) will not restart, "B" D/W Chiller trip. .

1700 Alert Declaration: FA-1 (2.B.1 and2.B.2): D/W Pressure 1.68# and D/W pressure rise due to Reactor Coolant System (RCS) Leakage.

1740 Event #3: Loss of Condensate Pumps due to Fire Header Failure. Fire Header located in Condensate Pump Area (Turbine Enclosure) north wall develops a flange leak. Flange leak creates a water spray onto the Condensate Pumps. The condensate. pumps trip on motor overcurrent.

1825 Event #4: Recirculation Pump line -failure in containment. D/W pressure increases..

RPV Level drops below -186". Expect Reactor level to reach -210" prior to the ECCS pumps injection. All Low Pressure Emergency Core Coolant System (ECCS) will be available for injection. Loss of Fuel Clad Barrier per 1.A. 1 Reactor Level < -186",

1840 Site Area Emergency declared FS 1 Fission Product Barrier Matrix.. Loss of Fuel Clad Barrier 1.A. 1; RPV Level < -186" AND the Loss of the Reactor Coolant Barrier 2.B.2 D/W pressure >1.68# and D/W pressure rise due to RCS leakage.

1950 Event #5: Loss of Primary Containment. Containment hatch seal fails causing containment pressure -10# to decrease rapidly to about 5#. Pressure enters the secondary containment (Reactor Building). Pressure in secondary containment remains negative. There is not an unmonitored release from secondary containment.

START OF RELEASE IN PROGRESS There is a change to North Stack Effluent Iodine. North Stack Wide Range Accident Monitor (WRAM) effluent levels increase to 1.9 E7 uc/sec.

2005 General EMERGENCY (GE) DECLARATION FS 1 Fission Product Barrier Matrix; Loss of Fuel Clad Barrier l.A. 11. RPV Level < -186" AND Loss of the Reactor Coolant Barrier 2.B.2 29

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

1. D/W pressure >1.68# and

2. D/W pressure rise due to RCS leakage AND Loss'ofPrimary Containment Barrier 3.b. 1.

Rapid unexplained drop in D/W pressure following an initial rise.

PAR Notification; Wind Speed 6mph; Wind Direction from: 49 degrees Downwind Sectors:

SSW/SW/WSW Determine/ Issue the appropriate Protective Action Recommendation (PAR).

" Evacuate 5 Mile radius and 10 Mile downwind or Shelter based on offsite impediments

" Recommend KI for general public in evacuated areas

" Advise the remainder of the EPZ to monitor EAS Messages 2045 PAR Revision due to Wind Shift; Wind Speed 6 mph; Wind Direction from 54 degrees Downwind sectors SSW/SWiWSW/W 2130 Exercise termination. If objectives and demonstrations have been completed, onsite and offsite teams have been evaluated, federal/state/local government officials and, facility lead controllers are satisfied that objectives and demonstration criteria have been completed, the exercise will be terminated at an agreed upon time. -

Abbreviations: D/W = Drywell: MPH = miles per hour: RPV = Reactor Pressure Vessel: # =

pounds per square inch 30 0

Unclassified Radiological, Emergency.Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station SECTION 3: ANALYSIS OF CAPABILITIES, 3.1 Exercise Evaluation and Results The matrix presented in Table 3.1, on the following pages, presents the status of the exercise evaluation area criteria from the REP Exercise Evaluation Methodology that were scheduled for demonstration during this exercise by all participating jurisdictions and functional entities.

Exercise evaluation area criteria are listed by number and the demonstration status of the criteria is indicated by the use of the following. letters:

(M) Met: status of a REP exercise Evaluation Area Criterion indicating that the participating ORO demonstrated all demonstration criteria.for the Evaluation Area Criterion to the level required in the extent of-of-play agreement with no Deficiencies or ARCAs assessed in the current exercise and no unresolved prior ARCAs.,.

(A) Area Requiring Corrective Action (ARCA): an observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety.

(D) Deficiency: an observed or identified inadequacy of organizational performance in an exercise that could cause a finding that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in the event of a radiological emergency to protect the health and safety of the public living in the vicinity of a nuclear power plant.

(P) Plan Issue: an observed or identified inadequacy in the ORO's emergency plan or implementing procedures, rather than in the ORO's performance. Plan Issues are not exercise issues and are required to be corrected through the revision of the appropriate plans or procedures during the next annual plan review and update, submitted for FEMA review, and reported in the State Annual Letter of Certification.

(N) Not Demonstrated: term applied to the status of a REP exercise Evaluation Area Criterion indicating that the ORO, for a justifiable reason, did not demonstrate the Evaluation Area Criterion, as required in the extent-of-play agreement or at the two -year or six-year interval required in the FEMA REP Program Manual.

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. Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.2 Summary Results of'Exercise Evaluation Contained in this section are the results and findings of the evaluation of all jurisdictions and locations that participated in the November 17; 2009, biennial Radiological Emergency Preparedness (REP) exercise. The exercise was held to test the offsite emergency response capabilities of local governments in the 10-mile Emergency Planning Zone (EPZ) surrounding the Limerick Generating Station (LGS).

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

Detailed information on the exercise evaluation area criteria and the extent-of-play agreement used in this exercise are found in Appendix D of this report.

All activities were based on the plans and procedures and completed as they would have been in an actual emergency except as noted in the extent of play agreement.

32 0

,Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Table 3.1 - Summary of Exercise Evaluation (1,3 pages)

DATE: 2009-11-17 .

SITE: Limerick Generating Station, PA C U M M: Met, A: ARCA, D: Deficiency; P: Plan Issue, N: Not U < U m =- C Demonstrated W = U < - 0 Mobilization lal N N M N. M Facilities lbl M M Direction and Control Icl N M Communications Equipment Idl N N M M M Equip & Supplies to support operations lel M M M Protetive A\tuon Decision Makin", .. .

Emergency Worker Exposure Control 2al N N M Radiological Assessment and PARs " 2bl N N Decisions for the Plume Phase -PADs 2b2 N N PADs for protection of special populations 2cl N I M Rad Assessment and Decision making for the Ingestion Exposure Pathway 2d]

Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return P*rL-t.c<iv.: tion " pl, " ,nt:at-n-.

Implementation of emergency worker exposure control 3a P N M M M Implementation of KI decision 3bl N M M Implementation of protective actions for special populations - EOCs 36 N M Implementation of protective actions for Schools 3c2 N M Implementation of traffic and access control 3d1 N M M Impediments to evacuation are identified and resolved 3d2 N M M Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3f1 e and 4al Adequate Equipment for Plume Phase Field Measurements Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b1 Laboratory operations 4c 1 Em~ergencyNotification and NbicInfo*i, ,,,lio Activation of the prompt alert and notification system 5al N 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 5bl N N M M Mon / decon of evacuees and emergency workers, and registration of evacuees 6al M Mon / decon of emergency worker equipment 6bl Temporary care of evacuees 6c I Transportation and treatment of contaminated injured individuals 6dl 33

0 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 2/13)

U CL CL.

DATE: 2009-11-17 --

SITE: Limerick Generating Station, PA x C > C -0

.U =

M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not , Q -

Demonstrated 0 U U U U U U U U o 0 0 0 0 00 0 0 0 0 Mobilization lal M 40 Facilities lbi Direction and Control lIc M Communications Equipment Idl M M Equip & Supplies to support operations lel M M M M __ M M M Frotecuve Action D i*ii Making_

Emergency Worker Exposure Control 2al A Radiological Assessment and PARs 2b1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2cl Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Protective Action hImleme itation ~ 1 Implementation of emergency worker exposure control 3al M M M M M M M Implementation of KI decision 3bl M M Implementation of protective actions for special populations - EOCs 36 M 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 M Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3fl Eield Measurmia an.. d Analysisi3/4 .

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 4bl Laboratory operations 4c 1 LEiieýi-,Laic Notification aridPubli Info 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 Mon / decon of evacuees and emergency workers, and registration of evacuees 6al M M M IM M Mon / decon of emergency worker equipment 6bl Temporary care of evacuees 6c I M M M P 34 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limeri*k Generating Station Transportation and treatment of contaminated injured individuals . 16dll II II I I I1 Table 3.1 - Summary of Exercise Evaluation (Continued. page 3/13)

DATE: 2009-11-17 8U-SITE: Limerick Generating Station, PA M M" M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not H H H a U Demonstrated -0 0 0 0 0 0 w w 04 Mobilization lal M M MIM Facilities lbl M M Direction and Control lcl M M MM M_

Communications Equipment Idl M M M M M M M M Equip & Supplies to support operations lel M M M M M P P I'rote,tiv-e Action Decision Nlakwn,4 Emergency Worker Exposure Control 12al1 M1 M _ M M Radiological Assessment and PARs 2b 1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2cl ,. M M .

Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return ProteclveiAction Im lementation i -lt '*;*'::':: "'" ,!I*,,,*:',ii i;'iiI,3!'=* I Implementation of emergency worker exposure control 3al P M M M M M M MM M Implementation of KI decision 3bl M M M M M M M M Implementation of protective actions for special populations - EOCs 3cl M M M M Implementation of protective actions for Schools 3c2 M M. M M Implementation of traffic and access control 3dl M M M M M Impediments to evacuation are identified and resolved 3d2 M M M M M Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3n _

FieldMe ei-nAnyss w 4 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 4bl Laboratory operations 4c 1 Lme::::ency ;>i Nu:il! d Public* I .........

Activation of the prompt alert and notification system 5al M 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 M M M Emergency information and instructions for the public and the media 5bl M Mon / decon of evacuees and emergency workers, and registration of evacuees 6al M M M Mon / decon of emergency worker equipment 6bl M Temporary care of evacuees 6c I Transportation and treatment of contaminated injured individuals 6dl 35

0 Unclassified RadiologicalEmergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 4/13)

DATE: 2009-11-17 0 SITE: Limerick Generating Station, PA U Q l t " * *"- "

M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not U U U Demonstrated U w w V L E ( (n Mobilization lal P M M M Facilities 1bi1 Direction and Controi lcl M M P M Communications Equipment Idl M M M M M M Equip & Supplies to support operations lel M M M M M -

Protective Action Decision Making -

Emergency Worker Exposure Control 2al M M M M Radiological Assessment and PARs 2b1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c1 Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return

ýrtetvectd4L1Impiemfentatton" Implementation of emergency worker exposure control 3a. I I M M M M M M M Implementation ofKI decision 3bl M M M M MIM M Implementation of protective actions for special populations - EOCs 3cl M M M M Implementation of protective actions for Schools 3c2 M M M M Implementation of traffic and access control 3d1 M M M M M Impediments to evacuation are identified and resolved 3d2 M M M M M Implementation of ingestion pathway decisions - availability/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 4al Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b1 a Laboratory operations 4c 1 Emergency Notificatiomp and Publita tifi'cation system 5a M M M M Activation of the prompt alert and notification system 5aF M MBa M M5a2 Activation of the prompt alert and notification system - Fast Breaker 5a2 M Activation of the prompt alert and notification system - Exception areas 5a3 M M M M Emergency information and instructions for the public and the media 5bl Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6b1 Temporary care of evacuees 6c0 M M M Transportation and treatment of contaminated injured individuals 6d1 36 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 5/13) 0.)

DATE: 2009-11-17 <. -U U 0 - 0 0. U .

SITE: Limerick Generating Station, PA v- o < <

M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not - S Demonstrated Em~erkency OperationsiviaiagemenL t'> . >:

Mobilization lal M M M M

• Facilities IbI M Direction and Control Icl M M M M Communications Equipment Id1 M :M M M M M M M M Equip & Supplies to support operations lel M M M M M M M P M M M Protective Action Decision mkia/!

n  :

Emergency Worker Exposure Control 2al M M M M Radiological Assessment and PARs 2b]

Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2cl M Rad Assessment and Decision making for the Ingestion Exposure Pathway, -2dl Rad Assessment and Decision making concerning Relocation, :Reentry, and 2el, Return Protective Action [mplementation *7 Implementation of emergency worker exposure control 3al M M M M M M M M M M Implementation of KI decision 3bl M M M M M IM MIM Implementation of protective actions for special populations - EOCs 3cl M M M M Implementation of protective actions for Schools 3c2 M iM M M Implementation of traffic-and access control- -: 3dl M M M M M M M M P Impediments to evacuation are identified and resolved 3d2 M M M M MMM M M Implementation of ingestion pathway decisions - availability/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 4al Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b I Laboratory operations 4c I Emergencnotification adulimf5al M M M Activation of the prompt alert and notification system Sal M 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 Emergency information and instructions for the public and the media 5b] M Suppurt OperauuionsFailities t Mon / decon of evacuees and emergency workers, and registration of evacuees 6al M Mon / decon of emergency worker equipment 6b1 M Temporary care of evacuees 6c 1 Transportation and treatment of contaminated injured individuals 6dl 37

0 Unclassified

-Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 6/13) 0 Cn DATE: 2009-11-17 < U- U SITE: Limerick Generating Station, PA F-' U M M,)

M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not , to 0 Q Demonstrated 0 0 0 0 Emergency. operations Mlaiagemuww Mobilization lal M M MM M Facilities " 1bl Direction and Control Icl M M M M M Communications Equipment Idl M M M M M M M M Equip & Supplies to support operations lel M M M M M M M Prot"ive A:%4ow1D~ision Making-Emergency Worker Exposure Control 2al M M M M Radiological Assessment and PARs 2bl Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c1 Rad Assessment and Decision making for the Ingestion Exposure Pathway 2d1 Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Pt ecth;w"Action iiiate Implementation of emergency worker exposure control 3al M M M M M M-mMe M Implementation of KI decision 3bl M M M M MM Implementation of protective actions for special populations - EOCs 3cd M M M M Implementation of protective actions for Schools 3c2 M M M M Implementation of traffic and access control 3dl M M M M M M M

Impediments to evacuation are identified and resolved 3d2 M M M M M M Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 31f1 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 4b1 a

Laboratory operations 4c I ficati an *:n*4i .ublicI.......

Activation of the prompt alert and notification system 5a1 M 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 P P M +

Emergency information and instructions for the public and the media 5bl Support Operat'nIoLsacilities :

Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6bl Temporary care of evacuees 6cl M M M Transportation and treatment of contaminated injured individuals 6dl 38 6

Unclassified Radiological Emergency. Preparedness:Prbgram (REP)

After Action Report/Improvement Plan Limerick Generating Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 7/13)

DATE: 2009-11-17 U SITE: Limerick Generating Station, PA M z P. 0.

M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not  :  ::  : w Demonstrated U.00 U 0 U 0 0 oa Q 0 U 0 UU0 U0 Limcigýhcy Oprtin Managemwit C,.l Mobilization lal M Facilities 1bi M Direction and Control IcI M Communications Equipment *dI dl M Equip & Supplies to support operations l el M Emergency Worker Exposure Control 2al Radiological Assessment and PARs 2bl Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2cl Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry, and 2e1l Return Implementation of emergency worker exposure control, 3al Implementation of KI decision 3bl Implementation of protective actions for sjecial populations - EOCs - 3cl Implementation of protective actions for Schools 3c2 Implementation of traffic and access control 3dl Impediments to evacuation are identifiedand resolved 3d2 Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3f' HutIdMvasureinciet and Analysiis 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 4bl Laboratory operations 4c1 A fthepromptalert vo adotiict Activation of the prompt alert and notification system 5a2 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 5b1 Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6b I Temporary care of evacuees 6cl M M M M M M M M M Transportation and treatment of contaminated injured individuals 6d]

39

0 Unclassified Radiological Emergency Preparedness Program(REP)

After Action Report/Improvement Plan Limerick Generating Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 8/13)

DATE:2009-11-17 n n U C C CIO C SITE: Limerick Generating Station, PA E-4 w 4 M: Met, A: ARCA, D: Deficiency, P: Pldn Issue, N: Not Demonstrated 0 '0 0 0 0 0 0 0 o 0

. . .. . . + .. .. . .. . .. ... ... . . - . . . .. . Y Oren lbadions agmn&

Mobilization lal Facilities lbl Direction and Control Ic1 Communications Equipment I dl Equip & Supplies to support operations. lel Emergency Worker Exposure Control 2al Radiological Assessment and PARs 2b]

Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2cl Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Protective Acton~mlretto Implementation of emergency worker exposure control 3al-Implementation of KI decision 3b1 Implementation of protective actions for special populations -,EOCs 3c]

Implementation of protective actions for Schools 3c2 M M M M Implementation of traffic and access control 3d1 Impediments to evacuation are identified and resolved 3d2, 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. 3f.]

Field Analysis ..

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 4bl 0 Laboratory operations 4cl At iv o aet and notificatosye 5al_ __ __ __

Activation of the prompt alert and notification system - FsB r5a2 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 5b 1 Sutpport Operations/Facilities Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6bl Temporary care of evacuees 6c0 M M M M M M Transportation and treatment of contaminated injured individuals 6dl 40 0

Unclassified

-Radiological Emergency Preparedness' Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Table 3.1 - Summary of Exercise"Evaluation (Continued. page 9/13)

DATE:2009-11-17 SITE: Limerick Generating Station, PA Z  :

M: Met, A: ARCA, D: Deficiency, P: Plan.Issue, N: Not < < < < < <

Demonstrated ' 0 00 0 z < <

Mobilization lal Facilities 1b1 Direction and Control Ic1 Communications Equipment Id1 Equip & Supplies to support operations lel Protective Action Dcsisonrylig -.

Emergency Worker Exposure Control 2al Radiological Assessment and PARs 2bl Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2cl Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry,,and . 2el Return Protective cto s- >>' V Implementation of emergency worker exposure control 3al Implementation of KI decision 3bl Implementation of protective actions for special populations - EOCs . 3cl Implementation of protective actions for Schools 3c2 M M M M M M M M M M Implementation of traffic and access control 3dl 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 Implementation of relocation, re-entry, and return decisions. 3fl Fi*dMeasi~metianiialisis ..

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 4b1 Laboratory operations 4c I Emergency Notification and Public Ino'",. '  : L' Activation of the prompt alert and notification system 5al 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 5bI

+upport~tuperan ionsFilac tie&/<'Yi+++++++++!+  :+:+i!+:++++:+++,:+

+++:++++<m* + +* +*:+ ... ...........

+++: +'~

, K!

+:++++i:+

+++*

Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6bl Temporary care of evacuees 6c I Transportation and treatment of contaminated injured individuals 6dl 41

0 Unclassified Radiological Emergency Preparedness Prcgram (REP)

After Action Report/linprovement Plan Limerick Generating Station Table 3.1 - Summary of Exercise Evaluation (Continued: page 10/13)

DATE: 2009-11-17 U >

SITE: Limerick Generating Station, PA w wL *o M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not < > > > > 4 4 <

Demonstrated c 0 C:) 0 0 0 0 0 Mobilization lal Facilities Ibi Direction and Control Ic1 Communications Equipment I dl Equip & Supplies to support operations lel 0 Protect iv ACtoDcsoMai _____

Emergency Worker Exposure Control 2al Radiological Assessment and PARs 2bl Decisions for the Plume Phase -PADs "_2b2 PADs for protection of special populations 2c 1 Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Implementation of emergency worker exposure control 3al Implementation of KI decision 3b1 Implementation of protective actions for special populations - EOCs 3cl Implementation of protective actions for Schools 3c2 M M M M M M M M M M Implementation of traffic and access control 3d1 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 Implementation of relocation, re-entry, and return decisions. 3fl 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 4bl Laboratory operations 4c] 0 Emerg;iLýcy Notificatiwnidmý Public Info .>>

Activation of the prompt alert and notification system 5al 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 5ba Eof I tem Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6bl Temporary care of evacuees 6c I Transportation and treatment of contaminated injured individuals 6dl 42 0

.Unclassified

,Radiological Emergency Preparedness'Program (REP)

After Action Report/Improvement Plan , Limerick Generating Station Table 3.1 - Summary of Exercise Evaluation (Continued, page 11/13)

DATE:2009-11-17 . C > >

SITE: Limerick Generating Station, PA M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not <. >

Demonstrated U U U U U U U U U Emergency Oprations Maldagciiwii i 9 Mobilization Ila1 Facilities IbI Direction and Control Ic]

Communications Equipment Idl Equip & Supplies to support operations lel ProtectiN e ActIonDcsiiMkigull~' -<'t Emergency Worker Exposure Control 2al Radiological Assessment and PARs. 2bi Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c0 Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation,.Reentry, anrd 2el Return Implementation of emergency worker exposure control 3al Implementation of KI decision 3bl Implementation of protective actions for special populations - EOCs 36 Implementation of protective actions. for Schools 3c2 M M M M M M M M M M Implementation of traffic and access control 3dl Impediments to evacuation are identified and resolved 3d2 Implementation of ingestion pathway decisions - availability/use of info 3e Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions. 3fl 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 4bl Laboratory operations 4c 1 Activation of the prompt alert and notification system 5a ,

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 5b1 Support OperationS/FaCilitie!,

Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6b 1 Temporary care of evacuees 6c 1 Transportation and treatment of contaminated injured individuals 6dl 43

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 12/13)

C/))

DATE: 2009-11-17 (A SITE: Limerick Generating Station, PA M: Met, A: ARCA, D:- Deficiency, P: Plan Issue, N: Not < < < < < C)< <C CA Cn Ci) on Demonstrated . . a. a C C Cn Emergencya operations Managemeiw .

Mobilization I al Facilities Ibi Direction and Control Idl Communications Equipment I dl Equip & Supplies to support operations lel 0 Emergency Worker Exposure Control 2al Radiological Assessment and PARs 2b1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c0 Rad Assessment and Decision making for the Ingestion Exposure Pathway' 2di Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Implementation of emergency worker exposure control -3al Implementation of KI decision 3bl Implementation of protective actions for special populations - EOCs 3cl Implementation of protective actions for Schools 3c2 .P M M M M M M M M M Implementation of traffic and access control 3d1 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 Implementation of relocation, re-entry, and return decisions. 3f1 Field Mcasurcment adtdAmalysis Adequate Equipment for Plume Phase Field Measurements 4a I.

Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4bl Laboratory operations 4c 1 0

Activation of the prompt alert and notification system . 5al Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception B reas 5a3 Emergency information and instructions for the public and the media 5bl Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon_/ decon of emergency worker equipment 6b1 Temporary care of evacuees 6cl Transportation and treatment of contaminated injured individuals 6dl 44

Unclassified Radiological Emergency Preparedness Program'(REP)

After Action Report/Improvement Plan Limerick Generating Station Table 3.1 - Summary of Exercise Evaluation (Continued' page 13/13)

U/ CIn DATE: 2009-11-17 "n =

SITE: Limerick Generating Station, PA M n 0 1: n Cn) CI) CI CI) CI) C) I M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated U U U U U U U U U Emergency Oper-atiovNs Iaiwsgc;uiietL Mobilization lal Facilities IbI Direction and Control Ic1 Communications Equipment Id1 Equip & Supplies to support operations lel Protectve Aciiu Decýioion MIkaiig~ ' ~ ~ ~ ~ ~

Emergency Worker Exposure Control 2al Radiological Assessment and PARs 2b1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c1 Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Implementation of emergency worker exposure control 3al Implementation of KI decision 3b I Implementation of protective actions for special populations - EOCs 3c1 Implementation ofprotective actions for Schools 3c2 P M M M M M M P M M Implementation of traffic and access control 3dl Impediments to evacuation are identified and resolved 3d2 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. 3fl Fil Anralys5is,;K'K~'

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 1 Activation of the prompt alert and notification system 5al 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 5b1 Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6bI Temporary care of evacuees 6cl Transportation and treatment of contaminated injured individuals 6dl 45

'Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReportdImprovement Plan Limerick Generating Station 3.3 Criteria Evaluation Summaries 3.3.1 Pennsylvania Jurisdictions 3.3.1.1 Pennsylvania Emergency Operation Center

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 3.a.l.

ISSUE NO.: 35-09-3al-P-02 CRITERION: OROs issue appropriate dosimetry and'procedures, and manage radiological exposure to emergency workers IAW plans and procedures. Emergency workers periodically and at the end of each mission read and record dosimeter reading. (NUREG-0654, K.3).

CONDITION: Local jurisdictions (boroughs and townships) do not maintain 0-200 R Direct Reading Dosimeters (DRDs); all 0-200 R DRDs are maintained at the County EOC.

POSSIBLE CAUSE: The Commonwealth of Pennsylvania has developed policy, guidance and information, relative to dosimetry applicableto all risk counties.

REFERENCE:

NUREG-0654, K.3.a,b; Douglass Township Radiological Emergency Response Plan, September 2009,Section III.K.6.aiii(c) and III.L.7.c.

EFFECT: Emergency workers may have to delay a life-saving mission while a local jurisdiction coordinates with the risk county to obtain dosimetry or an replacement emergency worker, and potentially not be able to monitor personal exposure during the mission.

RECOMMENDATION: Plans should address coordination of 0-200 R DRD issuance to avoid delays in life-saving situations. This issue is being assigned to the Commonwealth of Pennsylvania because it affected several counties. The 46 0

Unclassified Radiological Emergency Pteparedness. Program (REP)

After Action Report/Improvement Plan . Limerick, Generating Station Commonwealth will review its policies,.guidance, and information to provide clear direction to its counties on the coordination of 0-200 R DRD issuance to avoid delays in life-saving situations.

e. NOT DEMONSTRATED: 1.a.1, l~c.1, 1.d.l, 2.a.1, 2.b.1; 2.b.2, 2.c.1, 31c.1, 3.c.2, 3.d.1, 3.d.2, 5.a.1, 5.b. 1.

f. PRIOR ISSUES - RESOLVED: None.

g. PRIOR ISSUES - UNRESOLVED: 3.a.1.

ISSUE NO.: 35-07-3al-P-01 ISSUE: Discrepancies exist between the dosimetry information on the emergency worker radiological briefing.videotape and the Risk Township Radiological Emergency Response Plans..

REASON UNRESOLVED: Planning issue 35-07-3.a.1-PZ01 has partially been corrected by PEMA by issuance of a new videotape to the Risk Counties to be used by them to brief Emergency. Workers on emergency worker exposure, control.

In addition, Pennsylvania Annex E, Radiological Emergency Preparedness Response to Nuclear Power Plant Incidents, Change 4 dated March 2002, to the State Emergency Operations Plan is currently undergoing a major revision. PEMA has provided interim guidance in a memo dated April 6, 20091 to be used until all necessary changes have been made and incorporated into Annex E. Until all of the changes are made and incorporated into Annex E, this issue will remain unresolved.

When the issue was presented in 2007 the recommendation was to "Revise the radiological briefing videotape and Dosimetry-KI Report Form to reflect current information." Both of these items have been addressed. Additionally, other electronic and specific 3-part hardcopy forms were updated and provided to the various participating agencies to ensure continuity of plans. It is also true that Annex E of the State Emergency Operation Plan is currently undergoing a major revision and that PEMA had issued the interim guidance dated April 6, 2009. The interim guidance coupled with the updated video and forms should insure that such discrepancies, as stated in the issue above, are resolved.

47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.1.2 Pennsylvania Joint Information Center

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: 1.a.1, 1.d.1, 5.b.1.

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.3 Pennsylvania Accident Assessment Center, State Emergency Operations Center-Bureau of Radiation Protection

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: 1.a.1, 2.a.1, 2.b.1, 2.b.2, 3.a.1, 3.b.1.

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.4 Pennsylvania Bureau of Radiation Protection Activities, Exelon Emergency Operating Facility, Coatesville 3.3.1.5 Pennsylvania State Traffic and Access Control Points, State Police Barracks Skippack

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 48 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.1.6 Pennsylvania Bureau of Radiation Protection, Radiological Rapid Response Vehicle 3.3.1.7 PA State Field Monitoring Team A, South East Region 3.3.1.8 PA State Field Monitoring Team B, South East Region 3.3.2 Risk Jurisdictions 3.3.2.1 Berks County Emergency Operation Center

a. M ET: 1.a.1, 1.b.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 2.c.1, 3,a.1, 3.b.1, 3.c.1, 3.c.2,3.d*. , 3.d.2, 5.a. 1, 5.a.3, 5.b. 1.

b. AREAS REQUIRING, CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.2 Berks County Reception Center, Morgantown Crossing

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.3 Berks County Reception Center, Robeson Township Building

a. MET: L.e.1,3.a.1,6.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.4 Berks County Monitoring and Decontamination Center, Governor Mifflin Senior High School

a. MET: L.e.1, 3.a.1, 6.a.l.

b. AREAS REQUIRING CORRECTIVE ACTION: 6.a. 1.

ISSUE NO.: 35-09-6al-A-01 CRITERION: 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. 1O.h.,

K.5.b)

CONDITION: The survey instrument probes used to perform evacuee monitoring were not covered with a plastic bag as required by Berks County Radiological Emergency Response Plan, SOG#12, Appendix 14.

POSSIBLE CAUSE: Failure to follow SOG#12, Appendix 14.

REFERENCE:

NUREG-0654: J.1O.h; J.12: K.5.a. Berks County Radiological Emergency Response Plan, SOG#12, Appendix 14.

EFFECT: Not covering the probes with a plastic bag provides the opportunity to contaminate the probe while performing monitoring activities. Contaminating the probe would have comprised the ability for that instrument to be used for contamination monitoring. Since there were no spare. instruments, this would have impacted the center's capability to performing all monitoring activities.

CORRECTIVE ACTION DEMONSTRATED: When the probes were not covered with a plastic bag, the demonstration was stopped, a controller provided training, and each probe was successfully covered with a plastic bag that was secured to the probe's handle with tape.

ISSUE NO.: 35-09-6al-A-02 50 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station CRITERION: 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)

CONDITION: While performing radiological monitoring in both the female and the male monitoring and decontamination areas, the individual performing the monitoring held the monitoring probe approximately eight inches.from the simulated contaminated evacuee. As stated in Berks County Radiological Emergency Response Plan, SOG#12, Appendix 1, the probe should be held approximately one-half inch from the person being monitored.

POSSIBLE CAUSE: Failure to follow SOG#12, Appendix 1.

REFERENCE:

NUREG-0654: J.10.h; J.12: K.5.a. Berks County Radiological Emergency Response Plan, SOG# 12, Appendix 1.

EFFECT: Maintaining the probe at approximately eight inches from the evacuee being monitored could result in not identifying contamination that would warrant decontamination.

CORRECTIVE ACTION DEMONSTRATED: When it was observed that the monitoring probe was held at approximately eight inches from the evacuee, the demonstration was stopped, a controller provided training on the correct monitoring technique, and this was successfully re-monitored with the detector held at approximately one-half inch from the evacuee.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 51

Unclassilied Radiological Emergency.Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Geneiating Station 3.3.2.5 Berks County Mass Care Center, Governor Mifflin Senior High School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.6 Berks County Monitoring and Decontamination Station, Muhlenberg Senior High School

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

b. AREAS REQUIRING CORRECTIVE ACTION:None.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.7 Berks County Mass Care Center, Muhlenberg Senior High School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.8 Berks County Monitoring and Decontaminatiion Center, Schuylkill Valley School Complex

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None 52 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

f. PRIOR ISSUES - RESOLVED:.None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.9 Berks County Mass Care Center, Schuylkill Valley School Complex

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES- RESOLVED: None! .

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.10 Berks County Monitoring and Decontamination Station, Wilson Central Junior High School

a. MET: 1.e.1, 3.a.1, 6.a.l.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.11 Berks County Mass Care Center, Wilson Senior High School

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 6.c.1.

ISSUE NO.: 35-09-6cl-P-19 CRITERION: 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. (NUREG-0654, J. 1O.h., 12) 53

• nUclassifled Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station CONDITION: The Berks County Emergency Plan lists the capacity of the Wilson High School Mass Care Center as- 647 people. The*Berks County Chapter of the American Red Cross is the responsible organization for staffing and equipping the mass care center. The inventory of equipment that the Red Cross chapter provided during the demonstration is not sufficient to meet the needs of the Wilson High School Mass Care Center (416 cots vs 647 people capacity of the Center). Also, the inventory of equipment appears to be intended for distribution to multiple mass care centers.

POSSIBLE CAUSE: The inventory of equipment provided during the demonstration was just' for the local Red Cross Chapter and'did not 'include the resources available through the mutual aid agreements with other Red Cross Chapters.

REFERENCE:

NUREG 0645, J.10.h and J.12 EFFECT: The number of evacuees, may be larger thanthat which the immediate available supplies can support.

RECOMMENDATION: List the available supplies that would be obtained through agreements between the American Red Cross Berks County Chapter and other agencies to ensure they are sufficient for the number of expected evacuees.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.12 Berks County, Boyertown Borough/Colebrookdale Township Emergency Operations Center

a. M ET: l.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.c.1, 3.c.2, 3.d.1,'3.d.2, 5.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: 1.c.1, 2.a.1.

ISSUE NO.: 35-09-icl-A-03 CRITERION: Key personnel with functional roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.

54 0

Unclassified Radiological Emergency Preparedness, Program (REP)

After Action Report/Improvement Plan Limerick'Generating Station CONDITION: Critical KI advisory information disseminated via the Emergency Communications System (ECS) was not received by Colebookdale Township Emergency Operations Center (EOC).

POSSIBLE CAUSE: In accordance with the Colebookdale Township Radiological Emergency Response Plan, (RERP), the primary means of communications between Colebookdale Township EOC and Berks County EOC are facsimile (fax) messages, radio/pager system and ARES/RACES. Recently, Colebrookdale Township EOC was additionally equipped with a computer workstation that provided internet access into Berks County's EmergencyCommunications System (ECS).,.The Emergency Management Coordinator (EMC) attempted to access the ECS, however he had an incorrect password and was unable to~enter the site. He did not notify Berks County EOC about the ECS connectivity issue because it was a secondary means to receive notifications.

REFERENCE:

NUREG-0654 E. 1, Berks County RERP, Annex J-3-2, Section C, Colebrookdale Township RERP,Section III.G :

EFFECT: If receipt of critical information is not confirmed by the sender and/or is unknown, protective actions may not be taken by the general public and emergency workers; this could result in unnecessary radiation exposure.

CORRECTIVE ACTION DEMONSTRATED: The Colebrookdale Township Emergency Management Coordinator (EMC) successfully re-demonstrated. the ability to access, transmit and receive information using the Berks County Emergency Communications System (ECS) on December 14, 2009. Berks County Emergency Operations Center provided an exercise message through Berks County EOC using the ECS from the Governor and the Secretary of Health ordering all emergency workers and the general public to take Potassium Iodide. Supporting documentation was provided from Colebrookdale Township to the Evaluator.

ISSUE NO.: 35-09-2al-A-04 55

Unclassified Radiologica! Emergency Preparedness Program (REP)

After Action Reportl/mprovement Plan Limerick Generating Station CRITERION: OROs use a decision-making process to insure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of admin or PAGs.

CONDITION: The Colebrookdale Radiological Officer (RO) authorized KI for emergency workers without authorization from the State Health Officer.

POSSIBLE CAUSE: The RO stated that it was within his authority to authorize the ingestion of KI for emergency workers (EWs). The RO was unaware of the KI content in News Statement #8 that advised individuals in the 10-mile Emergency Planning Zone to take KI.

REFERENCE:

NUREG 0654 J. 110.e, Berks County, Radiological Emergency Response Plan (RERP), Annex J-3-12, Section C.2, Colebrookdale RERP, Section P EFFECT: The RO could put the health of emergency workers at unnecessary risk of KI exposure or side effects by not following the Plan.

RECOMMENDATION: Provide additional training for the RO to ensure he understands the limits of his responsibility regarding K(I.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.13 Berks County, Colebrookdale Township Traffic and Access Control

a. MET: 1.d. 1, L.e. 1, 3.a. 1, 3.b. 1, 3.d. 1, 3.d.2.

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

ISSUE NO.: 35-09-3dl-A-05 CRITERION: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel (NUREG-0654, 56 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station J. 10.g.j.k.)

CONDITION: Local law enforcement personnel did not participate in the exercise; traffic control activities were not demonstrated.

POSSIBLE CAUSE: The Colebrookdale Township/ Boyertown Borough RERPs assign local law enforcement responsibility for establishing and staffing Traffic Control Points (TCPs) with support from other public works organizations.

The Colebrookdale Emergency Management Coordinator (EMC)' informed the evaluators that he had notified the Colebrookdale Chief of Police on a previous date that an emergency exercise under the Radiological Emergency Response Plan (RERP) was to take place on November 17, 2009 and the EMC understood that a representative from the Police Department would participate in the exercise. During the exercise, the Chief of Police informed the EMC that he would not send a representative to participate in the exercise. The Police Chief stated that he did not have adequate staff available to participate in the exercise.

Failure of local law enforcement participation in this exercise caused a lack of adequate attention being paid to the TCP function. Secondly, when the EMC became aware that there would be no participation by local law enforcement, he failed to address the TCP function in evacuation preparations and execution.

REFERENCE:

NUREG-0654 J. I0.g.j, Colebrookdale Township RERP,Section IV.L, ESF-13, Law Enforcement EFFECT: Failure to establish TCPs and thereby insure an orderly traffic flow during evacuation would increase the possibility of accidents and injuries to evacuees and increase the possibility that they may be exposed to dangerous levels of radiation.

CORRECTIVE ACTION DEMONSTRATED: Colebrookdale Township successfully re-demonstrated December 14, 2009 their ability to establish traffic and access control. The Colebrookdale Township Emergency Management Coordinator and the Chief of police were present for a re-demonstration of the Traffic Control Point (TCP)/ Access Control Points (ACP). The officer clearly demonstrated through 57

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station interview that he had an in-depth understanding of his role and responsibilities. The discussion included restriction and control to affected areas both at the EOC and traffic. The officer was knowledgeable about the use, dosage, side affects and documentation associated with Potassium Iodide (KI). The officer was familiar and placement and use of dosimeter and personal safety as an emergency worker.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES,- UNRESOLVED: None 3.3.2.14 Berks County, Douglass Township Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 3.a.1.

ISSUE NO.: 35-09-3al-P-01 CRITERION: OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers IAW plans and procedures. Emergency workers periodically and at the end of each mission read and record dosimeter reading. (NUREG-0654, K.3)

CONDITION: The radiological briefing video used at the Douglass Township (Berks County) Emergency Operations Center (EOC) contained information that was inconsistent with the Douglass Township Radiological Emergency Response Plan (RERP). Inconsistencies included the following items:

The video specifies that permanent record dosimeters (PRDs) should be worn outside the clothing. The Douglass Township RERP specifies that "Dosimeters (PRDs, and as appropriate, DRDs) are to be worn in the pocket of an outer garment."

The video states that emergency workers given missions outdoors will be issued a 0-200 R direct-reading dosimeter (DRD). The Douglass Township RERP states that workers who have outdoor assignments will receive a Category A Standard Issue of dosimetry, which includes a 0-20 R DRD, but no 0-200 R DRD. 0-200 R DRDs must 58 0

Unclassified Radiologica! Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station be obtained from Berks County.

POSSIBLE CAUSE: The radiological briefing video and the RERP Were produced by different entities.

REFERENCE:

NUREG-0654, K.3.a, b; Douglass Township Radiological Emergency Response Plan, September 2009,Section III.K.

EFFECT: Emergency workers could receive conflicting information on dosimetry.

RECOMMENDATION: The radiological briefing video and the RERP should be aligned, or additional radiological briefing should be provided to address these discrepancies.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.15 Berks County, Douglass Township Traffic and Access Control

a. MET: 1.d. 1, L.e. 1, 3.a. 1, 3.b. 1, 3.d. 1, 3.d.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None.

3.3.2.16 Berks County, Union Township Emergency Operations Center

a. M ET: 1.a.1, 1.c.1, 1.d.1, L.e.1, 2.a.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.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 59

-Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.17 Berks County, Union Township Back-up Route Alerting A

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.18 Berks County, Union Township Back-up Route Alerting B

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.19 Berks County, Union Township Back-up Route Alerting C

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.20 Berks County, Washington Township Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 60

. Unclassified Radiological Emergency Preparedness, Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.21 Chester County Emergency, OperationsCenter

a. M ET: 1.a.1, 1.b.1, 1.c.1, 1.d.1, 1.e.1, 2.a.1, 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.b.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None -

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.22 Chester County Emergency Worker Monitoring and Decontamination Station, Valley Forge Intermediate School

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None ,

d. PLAN ISSUES: 1.e.1, 6.a.l.

ISSUE NO.: 35-09-lel-P-04 CRITERION: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations.

CONDITION: The Chester County Hazardous Materials Team demonstrated operational checks of (2) Ludlum Model 3 Survey Meters with 44-9 Pancake Probes (S/N: 203947 & S/N 205818). During the demonstration it was observed that the instruments did not have a sticker affixed to it with the range of readings for a source check.

POSSIBLE CAUSE: The individuals responsible for the calibration and maintenance of the equipment were not aware of the need to' place labels with the source check range of readings on the instruments.

REFERENCE:

NUREG-0654, H 10, Interim REP Program Manual ? August 2002 (Page 111-66), Sub-element 1.e; Criterion i.e. 1; Extent of Play EFFECT: The lack of an affixed range readings sticker to the side of the instrument 61

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station prohibits the operator from performing an accurate operational check of the instrument. In this specific situation, the operators of each instrument had to refer to range readings documentation which was maintained separately from their instruments.

RECOMMENDATION: The source check of range reading stickers should be affixed to survey instruments at the time of calibration.

ISSUE NO.: 35-09-6al-P-03 CRITERION: Reception center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide lmonitoring, decontamination, and registration of evacuees and/or emergency workers. (NUREG-0654, J.10.h.,

K.5.b)

CONDITION: There are conflicting dec6fitarmination trigger levels within the Chester County plans and procedures. In Appendix 13, page 4 the decontamination trigger level when using a pancake probe is shown as >1000 cpm including background. Allowable background count rate is shown'as 150 cpm. In Attachment A to Appendix 13, Section B. 1.b, page E- 13-18 the decontamination trigger level for a pancake probe is shown as >300 cpm above background. Allowable background count rate is shown as 100 cpm.

POSSIBLE CAUSE: Lack of a quality assurance program when preparing plans and procedures.

REFERENCE:

NUREG 0654, K.5.a EFFECT: Depending on which trigger level is established, emergency workers and/or general public could be released with contamination levels over twice the established levels. On the other hand, additional time and resources could be spent decontaminating workers and/or the general public unnecessarily.

CORRECTIVE ACTION DEMONSTRATED: Plan Changes were implemented to 62 40

Unclassified

'Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Gerferating Station address trigger level inconsistencies and two copies of the revised County Plan were provided to FEMA on 01/13/10.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES -UNRESOLVED: None 3.3.2.23 Chester County Reception Center, Downingtown High School

a. MET: 6.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None.

c. DEFICIENCY: None

d. PLAN ISSUES: None, e., NOT DEMONSTRATED1 None,

f. PRIOR ISSUES -.RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.24 Chester County Monitoring and Decontamination Center, Downington High School

a. MET: 3.a.1, 6.a.l.

b. AREAS REQUIRING CORRECTIVE ACTION: 6.a. 1.

ISSUE NO.: 35-09-6al-A-06 CRITERION: 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)

CONDITION: The Downingtown Evacuee Monitoring and Decontamination Center (Decon Center) did not provide a method to record the names of individuals who are found to be free of contamination after initial monitoring. This is required by the Chester County Radiological Emergency Response Procedure for Incidents at the Limerick Generating Station, Annex E, Part One, Attachment A, Appendix 13, Section F, page E-13-16.

POSSIBLE CAUSE: The Downingtown Evacuee Monitoring and Decontamination 63

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Center (Decon Center) did not follow procedures.

REFERENCE:

NUREG-0654, J. 12 EFFECT: The County Emergency Response Organization would have no record that individuals who are found to be free of contamination after initial monitoring were actually monitored.

CORRECTIVE ACTION DEMONSTRATED: A registration record was developed and has been implemeted as a plan change in The Chester County Radiological Emergency Response Plan, Annex E Appendix 13 page E13-16. Chnages were included in tab 1, Attachment page E&23.

c. DEFICIENCY: None.

d. PLAN ISSUES: 1.e.1, 6.a.l.

ISSUE NO.: 35-09-1el-P-05 CRITERION: Equipment, maps, displays, dosimetry; potassium iodide (KI), and other supplies are sufficient to support emergency operations.

CONDITION: The Chester County Hazardous Materials Team demonstrated operational checks of (2) Ludlum Model 3 Survey Meters with 44-9 Pancake Probes (S/N: 203947 & S/N 205818). During the demonstration it was observed that the instruments did not have a sticker affixed to it with the.range of readings for a source check.

POSSIBLE CAUSE: The individuals responsible for the calibration and maintenance of the equipment were not aware of the need to place labels with the source check range of readings on the instruments.

REFERENCE:

NUREG-0654, H 10, Interim REP Program Manual - August 2002 (Page 111-66), Sub-element 1.e; Criterion 1.e. 1; Extent of Play EFFECT: The lack of an affixed range readings sticker to the side of the instrument 64 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick GeneratingýStation prohibits the operator from performing -an accurate operational check of the instrument. In this specific situation, the operators of each instrument had to refer to range readings documentation which was maintained separately from their instruments.

RECOMMENDATION: The source check of range reading stickers should be affixed to survey instruments at the time of calibration.

ISSUE NO.: 35-09-6al-.P-06' CRITERION: 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. 1O.h.,

K.5.b)

CONDITION: There are conflicting decontamination trigger levels within the Chester County plans and procedures. In Appendix 13, page 4 the decontamination trigger level when using a pancake probe is shown as> 1000 cpm including background. Allowable background- count rate is shown as 150 cpm. In Attachment A to Appendix 13, Section B.l.b, page E-13-18 the decontamination trigger level for a pancake probe is shown as >300 cpm above background. Allowable background count rate is shown as 100 cpm.

POSSIBLE CAUSE: Lack of a qualityassurance program when preparing plans and procedures.

REFERENCE:

NUREG 0654, K.5.a EFFECT: Depending on which trigger level is established, emergency workers and/or general public could be released with contamination levels over twice the established levels. On the other hand, additional time and resources could be spent decontaminating workers and/or the general public unnecessarily.

CORRECTIVE ACTION DEMONSTRATED: Plan changes were implementd to 65

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station address trigger levels inconsistencies and two copies of the revised County Plan were provided to FEMA on January 13, 2010.

A review by the FEMA Limerick Site Specialist of the Chester County Radiological Emergency Plan, showed Appendix 13 Page 3 was revised to read ?Hand held monitor with a Geiger-Mueller Beta/Gamma pancake probe ? greater than 300 cpm including background?. The Plan also show the revision incorporated language to read ?Instrumentation with pancake detectors - if greater than 300 cpm above background is detected while monitoring an individual, decontamination procedures shall be initiated? In' Ap*pendix" 13 Attachment A Section B. 1.b. This satisfies this issue.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.25 Chester County Mass Care Center, Avon Grove High School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.26 Chester County Mass Care Center, Fred Engle Middle School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 66 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.27 Chester County Mass Care Center,.Gordon Middle School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None.

3.3.2.28 Chester County, CharlestownEmergency: Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: L.a.l.

ISSUE NO.: 35-09-lal-P-07 CRITERION: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner.

CONDITION: The location of the Charlestown Township Emergency Operations Center (EOC) was incorrectly cited in the Radiological Emergency Response Plan for Incidents at the Limerick Generating Station (LGS) Annex E to the Township Emergency Operations Plan utilized by the Charlestown Emergency Management EOC Staff during the Exercise.

POSSIBLE CAUSE: Verification of information provided during revision of the Plan may not include a peer review by the Township Emergency Management Coordinator (EMC).

REFERENCE:

1. NUREG-0654, H.3, 2. Charlestown Township Radiological Emergency Response Plan, revision 2, page 15 EFFECT: Delay in arrival of resources from Chester County or other Offsite Response Organizations to support the Township's emergency response.

67

Unclassified Radiological -Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station RECOMMENDATION: The Charlestown Township Radiological Emergency Response Plan should be revised.. Prior to distribution, the Plans should be reviewed by the County, Township, and Licensee.

New address: 1580 Charlestown Road, Phoenixville, PA,19460

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.29 Chester County, East Coventry Township Emergency Operations Center

a. MET: 1.a.1, 1.c.1, l.d.1, L.e.i,2.a.l,3.a.1,3.b.1,-3.c.1;3.c.2,3.d.l,3.d.2,5.a.4.

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

ISSUE NO.: 35-09-3al-A-07 CRITERION: OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers IAW plans and procedures. Emergency workers periodically and at the end of eacih mission read and record dosimeter reading. (NUREG-0654, K.3)

CONDITION: The Radiological Officer (RO) incorrectly identified the State and County as the authorizing agency for emergency worker doses for over 25 REM for lifesaving operations.

POSSIBLE CAUSE: A lack of understanding of the radiological dose limit approval process for lifesaving missions.

REFERENCE:

NUREG-0654, K.3.a.b, East Coventry Township Emergency Plan, Annex E, page 42, section H, subsection 7c.

EFFECT: The possible consequences could have been delays in the authorization of emergency workers to perform lifesaving tasks. The East Coventry Township Emergency Plan "Protective Action Guide for Emergency Worker # 7 -c details the needs for the on scene senior supervisor to make the decision.

68 0

'Unclassified Radiological Emergency. Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station CORRECTIVE ACTION DEMONSTRATED: The RO and his deputy reviewed the plan and satisfactorily redemonstrated this portion of the briefing.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.30 Chester County, East Coventry Township Traffic and Access Control

a. MET: 1.d.1; 1.e.1, 3.a.1, 3.b.1, 3.d.1, 3.d.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None:

3.3.2.31 Chester County, South Coventry Township Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 1.a.1, l.c.1.

ISSUE NO.: 35-09-lal-P-08 CRITERION: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner.

CONDITION: The location of the South Coventry Township Emergency Operations Center (EOC) was incorrectly cited in the Radiological Emergency Response Plan for Incidents at the Limerick Generating Station (LGS) Annex E to the Township Emergency Operations Plan utilized by the South Coventry Township Emergency Management EOC Staff during the Exercise.

69

Unclassified Radiological Emergency Preparedness Program'(REP)

After Action Report/improvement Plan Limerick Generating Station POSSIBLE CAUSE: Verification of information provided during revision of the Plan may not include a peer review by the Township Emergency Management Coordinator (EMC).

REFERENCE:

1. NUREG-0654, H.3, 2. South Coventry Township Radiological Emergency Response Plan, revision 2, page 13 EFFECT: Delay in arrival of resources from Chester County or other Offsite Resp~onse Organizations to support the Township?s emergency response.

CORRECTIVE ACTION DEMONSTRATED:' A review by FEMA showed the South Coventry Township EOC Radiological Emergency Response Plan was revised to correct the new location of the EOC at the Township Building at 1371 New Philadelphia Road, Pottstown PA 19465. The revision is captured in revision 2, Section B.2.a page 13.

ISSUE NO.: 35-09-icl-P-09 CRITERION: Key personnel with functional roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.

CONDITION: The South Coventry Township Emergency Manager did not complete steps identified in the South Coventry Township Radiological Response Plan because the "recommendation" of evacuation did not prompt steps to be completed.

POSSIBLE CAUSE: The South Coventry Township Radiological Emergency Response Plan (SCTRERP) does not provide clear direction for the staff of the South Coventry Emergency Operations Center (SCEOC) to implement steps in the plan upon receipt of a "recommendation" of evacuation.

REFERENCE:

NUREG-0654, A. 1.d; A.2.a.

EFFECT: South Coventry Township personnel may not evacuate when 70 L]

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station recommended by the SEOC.

RECOMMENDATION: Revise SCTRERP, section II. P.1 .d (b) on page 48 to read "If evacuation is directed or recommended..."

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 33.2.32 Chester County, Schuylkill Township Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None.

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.33 Chester County, Schuylkill Township Back-up Route Alerting A

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.34 Chester County, Schuylkill Township Back-up Route Alerting B

a. MET: l.d. 1, 3.a. 1, 3.b. 1, 5.a.3.

b. AREAS REQUIRING CORRECTIVE ACTION: 5.a.3.

ISSUE NO.: 35-09-5a3-A-08 CRITERION: Activities associated with FEMA approved exception areas are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. Backup A&N of 71

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station the public is completed within 45 minutes following the detection by the ORO of a failure*of the primary A&N system. (NUREG-0654, E.6., Appendix 3.B.2.c)

CONDITION:, The Valley Forge Volunteer Fire Company backup route alerting teams A and B did not complete their pre-assigned backup route alerting in the prescribed time of 45 minutes.

POSSIBLE CAUSE. At 19.17, Chester County received an inject indicating failure of siren #95 within Schuylkill Township. Chester County notified Schuylkill Township of the siren failure Viae-mail at 1923. At 1,927,,a message was received at the Schuylkill Township. EOC through ARES/RACES:stating that Siren #95 had failed.

The route alert teams were notified at 1929 by the Radiological Officer to dispatch to perform the route alert in sectors 68-D-1 and 68-D-2. There was a brief discussion between the EMC and the AEMC and at 1930 the EMC stopped the dispatch of the route alert team. There was a review of the plan by the AEMC and another discussion between the AEMC and the EMC. The discussion involved a question as to the requirement to perform route alerting outside of a declaration of General Emergency ECL. It appeared that the EMC was unsure of procedures regarding route alert initiation and was unfamiliar with sections of the plan.

At 1943, the EMC dispatched the route alert teams and they began their route at 1945. Route Alert Team A completed route alerting of sector 68-D-1 at 2022 (65 minutes). Route Alert Team B completed- route alerting of sector 68-D-2 at 2025 (68 minutes). Alert routes 68-D- 1 and 68-D-2 are unusually long (at least 31 directional turns) and are largely in residential sub-divisions.

REFERENCE:

NUREG- 0654, E.6, Appendix 3.B.2.c EFFECT: Not alerting the public of an incident at the Limerick Generating Station in a timely manner could significantly impact the ability to protect the public.

CORRECTIVE ACTION DEMONSTRATED: On 12/14/2009 the backup alert teams performed a re-demonstration of the failure of Siren 95. At 1910 hours0.0221 days <br />0.531 hours <br />0.00316 weeks <br />7.26755e-4 months <br /> the Chester County EOC was notified of the Siren Failure. The notification of the siren failure was received at the Valley Forge Fire Station at 1913 hours0.0221 days <br />0.531 hours <br />0.00316 weeks <br />7.278965e-4 months <br />. As recommended 72 0

Unclassified Radiological Emergency Preparedness Program!(REP)

After Action Report/Improvement Plan Limerick Generating Station above 68-D-1 and 68-D-2 were converted into three separate backup alert routes.

They weredesignated as routes 68-D-1, 68-D-2, and 68-D-3. The route 68-D-1 team was dispatched at 1915 hours0.0222 days <br />0.532 hours <br />0.00317 weeks <br />7.286575e-4 months <br /> and completed the route at 1942 hours0.0225 days <br />0.539 hours <br />0.00321 weeks <br />7.38931e-4 months <br /> with 72 notifications of the emergency at Limerick.Generating Station (LGS) announced. The route 68-D-2 team was dispatched at 1915 hours0.0222 days <br />0.532 hours <br />0.00317 weeks <br />7.286575e-4 months <br /> and completed the route at 1945 with 50 notifications of the emergency at LGS; The route 68-D-3 team was dispatched at 1915 hours0.0222 days <br />0.532 hours <br />0.00317 weeks <br />7.286575e-4 months <br /> and completed the route at 1931 with 35 notifications of the emergency at LGS. In accordance with the extent of play for the re-demonstration the radiological briefing was not required. -All teams consisted of a 3 person squad that were briefed on the route, issued an appropriate route alerting map and conducted a radio and equipment check. Emergency -announcements were made at approximately 30 second intervals. Each route alerting team traveled at the recommended speed of

.20 mph and obeyed all traffic sighs. The emergency announcement consisted of identifying an emergency existed at the LGS and to tune into EAS stations WHYY FM 90.9 or WMGK FM 102.9 for further information.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES- UNRESOLVED: None 3.3.2.35 Chester County, Schuylkill Township Back-up Route Alerting C

a. MET: 5.a.3.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 73

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.36 Chester County, Schuylkill Township Traffic and Access Control

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.37 Chester County, West Pikeland Emergency Operations Center

a. MET: l.a.1, I.c.1, l.d.1, L.e.1, 2.a.1, 3:a.1, 3.b.1-,3.c.1, 3.c.2, 3:d.1, 3.d.2, 5.a.l.

b. AREAS REQUIRING CORRECTIVE ACTION:. None

c. DEFICIENCY: None

d. PLAN ISSUES: l.a.l.

ISSUE NO.: 35-09-lal-P-10 CRITERION: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner.

CONDITION: The location of the West Pikeland Township Emergency Operations Center (EOC) was incorrectly cited in the Radiological Emergency Response Plan for Incidents at the Limerick Generating Station (LGS) Annex E to the Township Emergency Operations Plan utilized by the West Pikeland Emergency Management EOC Staff during the Exercise.

POSSIBLE CAUSE: Verification ofiniformation provided during revision of the Plan may not include a peer review by the Township Emergency Management Coordinator (EMC).

REFERENCE:

1. NUREG-0654, H.3, 2. West Pikeland Township Radiological Emergency Response Plan, revision 2, page 15 EFFECT: Delay in arrival of resources from Chester County or other Offsite Response Organizations to support the Township's emergency response.

74 0

Unclassified Radiological Emergency Preparedress Program (REP)

After Action Report/Improvement Plan Limerick Generating Station CORRECTIVE ACTION DEMONSTRATED: A;review by FEMA shows the West Pikeland Radiological Emergency Response Plan was revised to updated to location of the Pikeland EOC at the West Pikeland Township building, at 1645 Art School Road, Chester Springs, PA 19425 in Section B.2.a page 15..

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.38 Chester County, West Pikeland Township Traffic and Access Control

a. MET: 1.d1l, 1.e.1, 3.a.1, 3.b.-1, 3.d.1, 3.d.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None-,_

3.3.2.39 Chester County, West Vincent Township Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None,

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.40 Chester County, West Vincent Township Traffic and Access Control

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None 75

Unclassifid Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.41 Montgomery County Emergency Operations Center

a. M ET: 1.a. 1, 1.b. 1, I.c. 1, 1.d. 1, L.e.1, 2.a. 1, 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.b.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: L.e.1.

ISSUE NO.: 35-09-lel-P- 1I CRITERION: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations.

CONDITION: The potassium iodide (KI) inventory maintained at the Montgomery County Emergency Operations Center (EOC) is insufficient to cover the needs of the staff and inmate population at the County Correctional Facility.

POSSIBLE CAUSE: The EOC maintains'an inventory Of KI consistent with the Montgomery County Radiological Emergency Response Plan (RERP). The planning assumption (an inmate population of 1,200, plus a county staff of 120) in the RERP at the County Correctional Facility differs from the actual inmate population. During an interview, the Public Safety and Security Unit Officer explained that the facility currently had over 1,800 inmates and that the population sometimes exceeded 2,000.

REFERENCE:

NUREG-0654, J. 10.d. and e EFFECT: In the event that a radiological release would impact the area where the County Correctional Facility is located, Montgomery County may not be able to achieve the requirement to ensure the protection of those persons whose mobility is impaired due to their institutional confinement.

CORRECTIVE ACTION DEMONSTRATED: Montgomery County officials reviewed Potassium Iodine (KI) data needs to address shortfalls. On December 14, 2009, 6,600 KI tablets for 1,650 people (2-day supply) was provided by the Pennsylvania Emergency Management Agency (PEMA) to Montgomery County to 76

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station cover the shortfall. FEMA was provided a copy of the supplemental KI Custody Receipt on January 13, 2010. FEMA and PEMA recommend closing this planning issue.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.42 Montgomery County Emergency Worker Monitoring and Decontamination Station, Upper Perkiomen High School

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

b. AREAS REQUIRING CORRECTIVE ACTION:. None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED:.None

f. PRIOR ISSUES - RESOLVED: None.

g. PRIOR ISSUES -UNRESOLVED." None: ..

• 3.3.2.43 Montgomery County, Douglass Township Emergency Operations Center

a. MET: None,

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None,

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: i.e. 1.,

ISSUE NO.:.35-07-lel-P-06 ISSUE: The Radiological Equipment Distribution sheet provided with dosimetry at the Douglass Township was incomplete and inaccurate. It was dated July 2007 for distribution, but did not have any information about when the direct-reading dosimeters (DRDs) were last leak tested. Additionally, the sheet does not include the serial numbersof the permanent record dosimeters (PRDs).

The Radiological Equipment Distribution sheet indicated that the box contained 44 77

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Model DCA-622 (0-20 R) DRDs and 18 Model CD V-742 (0-200 R) DRDs. An inspection of the inventory indicated that included 39 Model DCA-622 (0-20 R)

DRDs; 5 Arrow-Tech Model 730, (0:20 R) DRDs 4 Model CD V-730 (0-20 R)

DRDs, and 14 CD V-742 (0-200 R) DRDs. In summary, the box contained four fewer 0-200 R DRDs than indicated on the inventory list and four more 0-20 R DRDs than indicated on the inventory list.

REASON UNRESOLVED: Montgomery County officials will review and correct any inventory and documentation discrepancies. -In late 2009, Montgomery County officials began working with Douglass Township Administration to replace the current Emergency Management Coordinator (EMC). A candidate has been identified by Douglass Township in the first quarter of 2010. After the new EMC is officially appointed by the Commonwealth of Pennsylvania, a full plan review will be completed and any discrepancies corrected.,

3.3.2.44 Montgomery County, Lower Proyidence Township Emergency Operations Center

a. MET: 1.a.1, 1.c.1, 1.d.1, L.e.1, 2.a.1, 13a. 1, 3.b. 1, 3.c.:1, 3.c.2, 3.d.1, 3.d2, 5.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.45 Montgomery County, Lower Providence Township Traffic and Access Control

a. MET: 1.d. 1, L.e. 1, 3.a. 1, 3.b. 1, 3.d. 1, 3.d.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 78

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.46 Montgomery County, Lower Salford Township Traffic and Access Control

a. MET: 1.d.1, 1.e.1, 3.al.I, 3.b.1, 3.d.2-.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None,

d. PLAN ISSUES: 3.d.l.

ISSUE NO.: 35-09-3dl-P-12 CRITERION: Appropriatetraffic and access control is established. Accurate instructions are-provided to traffic and access control personnel (NUREG-0654, J.10.g.j.k.)

CONDITION: The Lower SalfordTownship plan states that TCPs/ACPs will be manned at the Site Area Emergency classification by township personnel. The Police/Public Works checklist did not contain this information in their checklists.

POSSIBLE CAUSE:: Radiologichl Emergency Plan iniformation was not transitioned to functional area implementation checklists actually used for emergency response.

REFERENCE:

NUREG-0654, J.0O.g, j EFFECT: The applicable TCPs/ACPs would not have been manned at the Site Area Emergency classification, which could result in a more difficult evacuation process if the TCPs were manned after the General Emergency declaration.

RECOMMENDATION: Incorporate the specific TCPs/ACPs from the Lower Salford Township Plan, Attachment D, into the Police/Public Works checklists for the Site Area Emergency classification.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 79

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.47 Montgomery County, Lower Salford Township Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.48 Montgomery County, Pottstown Borough Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None,

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.49 Montgomery County, Pottstown Borough Traffic and Access Control

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.50 Montgomery County, Upper Frederick Township Emergency Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 5.a.3.

ISSUE NO.: 35-09-5a3-P-13 CRITERION: Activities associated with FEMA approved exception areas are 80 a

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station completed within 45 minutes following the initial decision by authorizedoffsite emergency officials to notify the public of an emergency situation. Backup A&N of the public is completed within 45 minutes following the detection by the ORO of a failure of the primary A&N system. (NUREG-0654, E.6., Appendix 3.B.2.c)

CONDITION: Newer housing developments and other recent construction ,has caused route alert maps to be out of date.--,

• POSSIBLE CAUSE: The maps of the route alerting sections/routes for Upper Frederick Township are'at least four years old,.

REFERENCE:

NUREG- 0654, E.6, Appendix3.B.2.c.

EFFECT: It is possible that some people living in the area where the siren failed may not have been alerted to tune their radios to the designated'EAS station for critical protective action information within the 45-minute period following identification of a siren failure.

RECOMMENDATION: Upper Frederick Township should'review andupdate all route alerting maps to reflect the most recent changes, to ensure new residential housing areas and roads are reflected on the maps. Then, the fire companies should actually drive the routes and determine if existing routes are too long and may need to be further divided to ensure the 45-minute requirement can be met.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.51 Montgomery County, Upper Pottsgrove Township Emergency Operation Center

a. M ET: L.a. 1, 1.c. 1, 1.d. 1, 1.e. 1, 2.a.*l, 3.a. 1, 3.b. 1, 3.c. 1, 3.c.2, 3.d. 1, 3.d.2, 5.a. 1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 5.a.3.

ISSUE NO.: 35-09-5a3-P-14 81

0 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station CRITERION: Activities associated with FEMA approved exception areas are completed within 45 .niinutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. Backup A&N of the public is completed within 45 minutes following the detection by the ORO of a failure of the primary A&N.system. (NUREG-0654, E.6., Appendix 3.B.2.c)

CONDITION: Newer housing developments and other recent construction has caused route alert maps to.be out of date.

POSSIBLE CAUSE: The mapsý of the route alerting sections/routes&for Upper Pottsgrove Township are at least four years old..

REFERENCE:

NUREG-.0654, E.6, Appehdix.3.B1.2.c.

EFFECT: It is possible that some people living in the area where the siren failed may not have been alerted to tune their radios to the designated EAS station for critical protective action information within the 45-minute period following identification of a siren failure.

RECOMMENDATION: Upper Pottsgrove Township should'review and update all route alerting maps to reflect .the most recent changes, to ensure new residential housing areas and roads are reflected on the maps. Then, the fire companies should actually drive the routes and determine if existing routes are too long and may need to be further divided to ensure the 45-minute requirement can be met.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.52 Montgomery County, Upper Pottsgrove Township Back-up Route Alerting

a. MET: 1.d.l,3.a.l,3.b.1, 5.a.3.

b. AREAS REQUIRING CORRECTIVE ACTION: 5.a.3.

ISSUE NO.: 35-09-5a3-A-09 82 6

'Unclassified Radiological Emergency Preparedness, Program (REP)

After Action Report/Improvement Plan Limerick Generating Station CRITERION: Activities associated with FEMA approved exception areas are completed within 45 minutes following the initial- decision by authorized offsite emergency officials to notify the public of an.emergency-situation. Backup A&N of the public is completed within 45 minutes following, the detection by the ORO of a failure of the primaryA&N system. (NUREG-0654, E.6., Appendix 3.B.2.c)

CONDITION: Back-up route alerting by the Upper Pottsgrove Fire' Company #1 was not accomplished within the 45-minutetime requirement; POSSIBLE CAUSE: New housingdevelopments in the route-alerting zone 79-D significantly increased the route alerting implementation time.

REFERENCE:

NUREG-0654,. E.6, Appendix .3.B.2.cand'I0 CFR Part 50, Appendix E.IV.D EFFECT: Notification of an emergency at .the Limerick Generating Station and the message to tune to your.Emergency. Alert System station KYW 1060 AM would not have been completed for a portion of siren zone 79-D.

CORRECTIVE ACTION DEMONSTRATED: This issue was re-demonstrated successfully, utilizing two vehicles. The two-vehicle method- successfully completed the route alerting within the 45-minute requirement.

c. DEFICIENCY: None.

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.53 Montgomery County, Upper Pottsgrove Township Traffic and Access Control

a. MET: 1.d. 1, L.e. 1, 3.a. 1, 3.b. 1, 3.d. 1, 3.d.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None 83

Unclassified Radiological Emergency Preparedness Program (REP)

After Action:Report/lmprovement Plan Limerick Generating Station

e. NOT DEMONSTRATED: None,

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.54 Berks County, Boyertown Area School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED:, None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.55 Berks County, Boyertown Area District, Boyertown Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.56 Berks County, Boyertown Area School District, Boyertown Senior High School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 84 0

'Unclassified Radiological Emergency PreparednessProgram (REP)

After Action Report/Improvement Plan I Limerick Generating Station 3.3.2.57 Berks County, Boyertown Area School District, Boyertown Junior High School West

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.58 Berks County, Boyertown Area School District, New Hanover/Upper Frederick Elementary School

a. MET: 3.c.2.

b. AREAS'REQUIRING CORRECTIVE ACTION: Nofie

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.59 Berks County, Boyertown Area School District, Washington Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.60 Berks County, Daniel Boone Area School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None 85

Unclassified Radiological Emergency Preparedness Program (REP)

After-Action Report/Improvement Plan Limerick Generating Station

f. PRIOR ISSUES - RESOLVED: 3.c.2.

ISSUE NO.: 35-07-3c2-P-10 ISSUE: The Daniel Boone Area School District Radiological Emergency Response Plan, in Attachment 1, page 2, states that Amity Intermediate School requires zero buses for evacuation.

CORRECTIVE ACTION DEMONSTRATED: Revised plan, Section A1-2 dated September 10, 2009 specifics the, number of bises required, and the number of buses available, including vans for students requiring special assistance. The student and staff population of the Amity Intermediate School is shown as 779 and the number of buses required and available-is 13, which is adequate for this student population.

This plan revision resolves the prior planning issue.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.61 Berks County, Daniel Boone Area District, MonocacyýElementary Center

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.62 Berks County, Daniel Boone Area School District, Daniel Boone High School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 86

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.63 Chester County, Downingtown Area School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.64 Chester County, Downingtown Area School District, Downingtown High School East

a.

• MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED:.None,' ,

3.3.2.65 Chester County, Downingtown Area School District, Downingtown High School West

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.66 Chester County, Downingtown Area School District, Lionville Middle School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None 87

,Unclassified Radiological Emergency, Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

f. PRIOR ISSUES - RESOLVED: None .:

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.67 Chester County, Downingtown Area School District, Shamona Creek Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None ,

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.68 Chester County, Downingtown Area School District, Uwchlan Hills Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES:None ,,

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.69 Chester County, Great Valley School District, Great Valley Middle School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None 0

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 88 40

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.70 Chester County, Great Valley School District, KD Markley Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None-'

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.71 Chester County, Owen J. Roberts School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None'

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED" None" 3.3.2.72 Chester County, Owen J. Roberts School District, East Coventry Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None*'

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.73 Chester County, Owen J. Roberts School District, East Vincent Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None 89

,Unclassified Radiological. Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.74 Chester County, Owen J. Roberts School District, Owen J. Roberts High School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None ,

3.3.2.75 Chester County, Phoenixville Area School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None - ,

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.76 Chester County, Phoenixville Area School District, Phoenixville Area High School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.77 Chester County, Phoenixville Area School District, Kindergarten Center

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None 90

Unclassified Radiological.Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.78 Montgomery County, Methacton School District,

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.79 Montgomery County, Methacton School District, Methacton High School

a. M ET: 3.c.2. , . ,' ' - .

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.80 Montgomery County, Methacton School District, Arcola Intermediate School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.81 Montgomery County, Methacton School District, Eagleville Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None 91

Unclassified Radiological.Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

e. NOT DEMONSTRATED:None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.82 Montgomery County, Perkiomen Valley School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.83 Montgomery County, Perkiomen Valley District, Schwenksville Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.84 Montgomery County, Perkiomen Valley School District, Perkiormen Valley Elementary South

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 92 a

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.85 Montgomery County, Perkiomen Valley School District, Perkiomen Valley High School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.86 Montgomery County, Pottsgrove School District

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 3.c.2.

ISSUE NO.: 35-09-3c2-P-15 CRITERION: OROs/school officials decide upon and implement protective actions for schools (NUREG-0654, J.10.c.d.g.)

CONDITION: The Western Montgomery County Area Vocational/Technical School, which is located Within the Spring-Ford Area School District, serves students from the Spring-Ford, Upper Perkiomen, and Pottsgrove School Districts. Questions were raised regarding whether or not Spring-Ford relocated all the Vocational/Technical School students, or whether each district handled the relocation of their own student population attending the school.

POSSIBLE CAUSE: The Plans did not specify which school district(s) had responsibility for re-locating students from multiple School districts that attended a shared school located in the Spring-Ford school District.

REFERENCE:

Spring-Ford School District Radiological Emergency Response Plan for Incidents at the Limerick Generating Station, August 2009; Pottsgrove School District Radiological Emergency Response Plan for Incidents at the Limerick Generating Station June 2007; Upper Perkioman School District Radiological 93

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Emergency Response Plan for Incidents at the Limerick Generating Station 2003; Western Montgomery County Area Vocational/Technical School Radiological Emergency Response Plan for Incidents at the Limerick Generating Station.

EFFECT: Confusion on student relocation could result in redundant relocation actions or parents not knowing where their child had been taken during a relocation.

RECOMMENDATION: The three school districts and the Administration of the Vocational/Technical School, in consultation with: the Montgomery County Authority, jointly resolve the approach for relocating Vocational/Technical School students and update their'plans accordingly.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 3.c.2.

ISSUE NO.: 35-07-3c2-P-15 ISSUE: The school plans used by the Pottstown do not include any instructions regarding KI deployment.

CORRECTIVE ACTION DEMONSTRATED: The Pottstown School District has revised their Radiological Emergency Resposne Plan, which no longer requires the deployment of Potassium Iodide (KI).

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.87 Montgomery County, Pottsgrove School District, Lower Pottsgrove Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 94 a

-Unclassified Raiological Emergency PreparednessProgram (REP,)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.88 Montgomery County, Pottsgrove School District, West Pottsgrove Elementary School ,

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.89 Montgomery County, Pottstown Area School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.90 Montgomery County, Pottstown Area School District, Edgewood Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.91 Montgomery County, Pottstown Area School District, Franklin Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None 95

Unclassified Radiological.Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.92 Montgomery County, Pottstown Area School District, Lincoln Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.93 Montgomery County, Pottstown Area School District, Pottstown Middle School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None.

c. DEFICIENCY: None

d. PLAN ISSUES:.None,

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None,.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.94 Montgomery County, Souderton Area School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.95 Montgomery County, Souderton Valley Area School District, Indian Valley Middle School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None 96 41

Unclassified Radiological.Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.96 Montgomery County, Spring-Ford Area School District

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 3.c.2.

ISSUE NO.: 35-09-3c2-P-16 CRITERION: OROs/school officials decide upon and implement protective actions for schools (NUREG-0654, J.0O.c.d.g.)'

CONDITION: The County Plan contained a map showing the route to be taken from Spring-Ford School District to the Montgomery County Community College; however there were no directions regarding where on the college campus the students from each school would be sheltered. Without clear plan guidance, management of the relocation activities, and pick-up of evacuated students on the college campus would be difficult.

POSSIBLE CAUSE: Montgomery County Community College was recently designated as the relocation venue for Spring-Ford School System students. College officials and the Spring-Ford School District officials had not worked out the details of where individual school populations would be placed on a large college campus.

REFERENCE:

Spring-Ford School District Radiological Emergency Response Plan for Incidents at the Limerick Generating Station, August 2009.

EFFECT: Bus drivers would not know where to discharge the students on their bus, once they arrived at Montgomery County Community College. Parents or guardians would not know where to pick-up their children.

RECOMMENDATION: Update the School District Plan to provide specific 97

Unclassified Radiological Emergency Preparedness.Program (REP)

,After Action Report/Improvement Plan Limerick Generating Station information regarding relocation of students once they arrive at the Montgomery County Community College.

ISSUE NO.: 35-09-3c2-P-17 CRITERION: OROs/school officials decide upon and implement protective actions for schools (NUREG-0654, J.10.c.d.g.)

CONDITION: The Western Montgomery County Area Vocational/Technical School, which is located within the Spring-Ford Area School District, serves students from the Spring-Ford, Upper Perkiomen, and Pottsgrove School Districts. Questions were raised regarding whether or not Spring-Ford relocated all the Vocational/Technical School students, or whether each district handled the relocation of their own student population attending the school.

POSSIBLE CAUSE: The Plans did not specify which school district(s) had responsibility for re-locating students from multiple School districts that attended a shared school located in the Spring-Ford school District.

REFERENCE:

Spring-Ford School District Radiological Emergency Response Plan for Incidents at the Limerick Generating Station, August 2009; Pottsgrove School District Radiological Emergency Response Plan for Incidents at the Limerick Generating Station June 2007; Upper Perkioman School District Radiological Emergency Response Plan for Incidents at the Limerick Generating Station 2003; Western Montgomery County Area Vocational/Technical School Radiological Emergency Response Plan for Incidents at the Limerick Generating Station.

EFFECT: Confusion on student relocation could result in redundant relocation actions or parents not knowing where their child had been taken during a relocation.

RECOMMENDATION: The three school districts and the Administration of the Vocational/Technical School, in consultation with the Montgomery County Authority, jointly resolve the approach for relocating Vocational/Technical School students and update their plans accordingly.

98 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.97 Montgomery County, Spring-Ford Area School District, 5th, 6th, &7th Grade Center

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None.

f. PRIOR ISSUES - RESOLVED: None-

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.98 Montgomery County, Spring-Ford Area School District, Limerick Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None;

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.99 Montgomery County, Spring-Ford Area School District, Spring-Ford Area High School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 99

Unclassified Radiological Emergency Preparedness Prcgram (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.2.100 Montgomery County, Spring-Ford Area School District, Evans Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.101 Montgomery County, Spring-Ford Area, School District, Upper Providence Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None;,

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR.ISSUES - RESOLVED: None

g. PRIOR ISSUES UNRESOLVED: None 3.3.2.102 Montgomery County, Spring-Ford Area School District, Royersford Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.103 Montgomery County, Upper Perkiomen School District

a. MET: None

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 3.c.2.

100 61

Unclassified Radiological Emergency Preparedness Program,(REP)

After Action Report/Improvement Plan Limerick Generating Station ISSUE NO.: 35-09-3c2-P-18 CRITERION: OROs/school officials decide upon and implement protective actions for schools (NUREG-0654, J.10.c.d.g.)

CONDITION: The Western Montgomery County Area Vocational/Technical School, which is located within the Spring-Ford Area School District, serves students from the Spring-Ford, Upper Perkiomen, and Pottsgrove School Districts. Questions were raised regarding whether or not Spring-Ford relocated all the Vocational/Technical School students, or Wvhethere*ach'disfrict.handled the relocation oftheir own student population attending the school.

POSSIBLE CAUSE: The Plan's did not specify, "whichschooldistrict(s)'had responsibility for re-locating students from multiple School districts that attended a shared school located in the Spring-Ford school District.

REFERENCE:

Spring-Ford School District Radiological Emergency Response Plan for Incidents at the Limerick Generating Station,. August 2009; Pottsgrove School District Radiological Emergency Response Plan for Incidents at the Limerick Generating Station' June 2007; Upper Perkioman S6hoolDistrict Radiological Emergency Response Plan for Incidents at the Limerick Generating Station 2003; Western Montgomery County Area Vocational/Technical School Radiological Emergency Response Plan for Incidents at the Limerick Generating Station.

EFFECT: Confusion on student relocation could result in redundant relocation actions or parents not knowing where their child had been taken during a relocation.

RECOMMENDATION: The three school districts and the Administration of the Vocational/Technical School, in consultation with the Montgomery County Authority, jointly resolve the approach for relocating Vocational/Technical School students and update their plans accordingly.

e. NOT DEMONSTRATED: None 101

Unclzssified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.104 Montgomery County, Upper Perkiomen School Distirct, Upper Perkiomen High School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.105 Montgomery County, Upper Perkiomen School District, Marlborough.

Elementary School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3 Support Jurisdictions 3.3.3.1 Bucks County Emergency Operations 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. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 102 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/lmprovement Plan Limerick Generating Station 3.3.3.2 Bucks County Mass Care Center, Bucks County. Community College

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.3 Bucks County Mass Care Center, Central Bucks West High School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES:None.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: Nohe 3.3.3.4 Bucks County Mass Care Center, Central Bucks East Complex

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.5 Bucks County Mass Care Center, Delaware Valley College

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 103

Unclassified Radiological Emergency Preparedness Program (REP)

After. Action Report/Improvement Plan Limerick Generating Station 3.3.3.6 Bucks County Mass Care Center, New Hope-Solebury Jr./Sr. High School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.7 Bucks County Mass Care Center, Palisades JrSr High School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.8 Bucks County Mass Care Center, Pennridge Central Junior High School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.9 Bucks County Mass Care Center, Pennridge Lower High School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 104 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.3.10 Bucks County Mass Care Center, Pennridge South Jr. High School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.11 Bucks County Mass Ca're Center, Pennridge Upper High School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.12 Bucks County Mass Care Center, Unami Jr. High School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.13 Lehigh County Emergency: Operations Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 105

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.3.14 Lehigh County Mass Care: Center. DeSales. University

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.15 Lehigh County Mass Care Center, Eyer Jr. High School.

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION:-N6ne

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.16 Lehigh County Mass Care Center, Orefield Middle School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.17 Lehigh County Mass Care Center, Salisbury Middle School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 106 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.3.18 Lehigh County Mass Care Center,,.South Mountain Middle School

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.19 Lehigh County Mass Care'Center, Springhouse Middle School,

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.20 Lehigh County Mass Care Center, Troxell Jr. High School,'

a. MET: 6.c.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.21 Chester County, Great Valley School District

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 107

0 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station 3.3.3.22 Chester County, Great Valley SchoolDistrict, Great.Valley High School

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.4 Private Organizations 3.3.4.1 Exelon Joint Information Center

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 108 0

Unclassified Radiological Emergency Preparedness.Program (REP)

After Action Report/improvement Plan Limerick Generating Station SECTION 4: CONCLUSION The Commonwealth of Pennsylvania and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Deficiencies. Nine (9) Areas Requiring Corrective Action (ARCAs) were identified as a result of this exercise. Four (4) of the ARCAs were successfully re-demonstrated during the exercise and four(4) were re-demonstrated on December 14, 2009.

There were no ARCAs from the previous exercise demonstrated during this exercise. Nineteen (19) new planning issues were identified of which 5 were closed and 1 ARCA remains open.

Fourteen (14) planning issues from a previous exercise were successfully demonstrated with 2 planning issues unresolved. (see Appendix A for all planning'issues),.

109

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Limerick Generating Station APPENDIX A: IMPROVEMENT PLAN I~ b r 31"0 Iss- l,,_Ig Cr itei'  : I ISSUE: The Berks County Emergency Plan lists the capacity of the Wilson High School Mass Care Center as 647 people. The Berks County Chapter of the American Red Cross is the responsible organization for staffing and equipping the mass care center. The inventory of equipment that the Red Cross chapter provided during the demonstration is not sufficient to meet the needs of the Wilson High School Mass Care Center (416 cots vs 647 people capacity of the Center). Also, the inventory of equipment appears to be intended for distribution to multiple mass care centers.

RECOMMENDATION: List the available supplies that would be obtained through agreements between the American Red Cross Berks County Chapter and other agencies to ensure they are sufficient for the number of expected evacuees.

0 CORRECTIVE ACTION DESCRIPTION: Berks County will work with the American Red Cross Berks County Chapter to review agreements and to document inventories between the County red Cross Chapter and other agencies to ensure supplies are sufficient.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Mass Care (Sheltering, Feeding, and RelatedServices)' Berks County Emergency Management Agency CAPABILITY ELEMENT: START DATE:

Planning 2009-11-17 AGENCY POC: COMPLETION DATE:

Berks County Emergency Management Coordinator 610- 2010-11-17 236-8211 ISSUE: The Colebrookdale Radiological Officer (RO) authorized KI for ..emergency  ; ..! workers I without authorization from the State Health 'Officer.

RECOMMENDATION: Provide additional training for the RO to ensure he understands the limits of his responsibility regarding KI.

CORRECTIVE ACTION DESCRIPTION: Corrective instruction was provided to the Radiological Officer (RO) in the aftermath of his decision. Additional training will be provided to ensure limits and responsibilities are understood. Though the Commonwealth of Pennsylvania believes this issue has been corrected, the issue may be demonstrated and officially resolved during the next biennial exercise.

0 CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Emergency Operations Center Management Berks county Emergency Managment Agency CAPABILITY ELEMENT: START DATE:

Organization and Leadership 2009-11-17 AGENCY POC: COMPLETION DATE:

Planning Manager 610-236-8211 2010-11-17 110 0

.. Unclassified Radiological Emergency Preparedness Program (REP)

Afler Action Report/Improvement Plan Limerick Generating Station I e m f3 9a* _al ICriterion:

ti ISSUE: The radiological briefing video used at the Douglass ToWnship (Berks County) Emergency Operations Center (EOC) contained information that was inconsistent with the Douglass Township Radiological Emergency Response Plan (RERP). Inconsistencies included the following items:

The video specifies that permanent record dosimeier§ (PRDs) should be'werf oufside.th*e~clothinig. ThebDouglas' Township RERP specifies that "Dosimeters (PRDs,' and as appropriate, DRDs) are to be worn in the pocket of an outer garment."

The video states that emergency workers given missions outdoors will be issued a 0-200 R direct-reading dosimeter (DRD). The Douglass Township RERP states that workers who have outdoor assignments will receive a Category A Standard Issue of dosimetry, which includes a 0-20 R DRD,but no 0-200 R. DRD.0-200 R DRDs must be obtained from Berks County....

RECOMMENDATION: The radiological briefing video and the RERP should be aligned, or additional radiological briefing should be provided to address these discrepancies.

CORRECTIVE ACTION DESCRIPTION: The video was updated and copies provided to PEMA during the week prior to the exercise. It was not distributed to all participants at the time of the biennial exercise.

Participants were expected, through pre-exercise training, to address the discrepancy. A copy of the updated video (11/2009) was provided to FEMA just prior to the exercise with an explanation that exercise participants would receive it in the near future, though not in time for the exercise. The updated video has since been mass produced and is now available for distribution to all participants. The video was updated to correct prior planing issue number 35-07-3al-P-01 "Discrepancies exist between:"the dosimetry information on the emergency worker r~adiological briefin* videotane and the Risk Townshin Radtiolo~ical-Emer~encv Resnonse Plans".

CAPABILITY: ,. PRIMARY RESPONSIBLE AGENCY:

Responder Safety and Health Berks County Emergency Management Agency CAPABILITY ELEMENT:: START DATE:

Planning 2009-11-17.

AGENCY POC: COMPLETION DATE:

Berks County Emergency Management Planning 2010-11-17 Manager 610-236-8211 . . ,__,"..__,__._______________'____"______.

lisu b r 3_;0Nu-e'--0 Citein ISSUE: The Chester County Hazardous Materials Team demonstrated operational checks of (2) Ludlum Model 3 Survey Meters with 44-9 Pancake Probes (S/N: 203947 & S/N 205818). During the demonstration it was observed that the instruments did not have a sticker affixed to it with the range of readings for a source check.

RECOMMENDATION: The source check of range reading stickers should be affixed to survey instruments at the time of calibration.

CORRECTIVE ACTION DESCRIPTION: Operational checks wereperformed were performed with the use of specific range readings as prescribed in the documentation provided with each of the Ludlum Model 3 Survey Meters from their previous calibration testing. However, it is agreed that affixed stickers would expedite operational checks and minimize error. Range reading stickers will be affixed to survey instruments during the next calibration cycle.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Responder Safety and Health Chester County Emergency Managment Agency CAPABILITY ELEMENT: START DATE:

Planning 2009-11-17 AGENCY POC: COMPLETION DATE:

Deputy Director Emergency Managment 610-344-5000 2010-11-17 111

6 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Repcrt/Improvement Plan Limerick Generating Station

-1 ISSUE: The Chester County hazardous Materials Team demonstrated, operational checks of (2) Ludlum Model 3 Survey Meters with 44-9 Pancake Probes (S/N: 203947 & S/N the 205818). During the range of readings fordemonstration a source check.it was observed that the instruments did not have a sticker affixed to it with RECOMMENDATION: The source check of range reading stickers should be affixed to survey instruments at the time of calibration.

CORRECTIVE ACTION DESCRIPTION: Operational checks were performed were performed with the use of specific range readings as prescribed in the documentation provided with each of the Ludlum Model 3 Survey Meters from their previous calibration testing. However, it is agreed that affixed stickers would expedite operational checks and minimize error. Range reading stickers will be affixed to survey instruments during the next calibration cycle.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Critical Resource Logistics and Distribution Chester County Emergency Management Agency CAPABILITY ELEMENT: 2 START DATE:

Planning . " 2009-11-17 AGENCY POC: COMPLETION DATE:

Deputy Director, Chester County Emergency 2010-11-17 Management 610-344-5000 ... ..

S illsUw ISSUE: The location of the Charlesiown Township Emergency Operations Center (EOC) was incorrectly cited in the Radiological Emergency Response. Plan for Incidents at the Limerick Generating Station (LGS) Annex E to the Township Emergency Operations Plan utilized by the Charlestown Emergency Management EOC Staff during the Exercise.

RECOMMENDATION: The Charlestown Township Radiological Emergency Response Plan should be revised. Prior todistribution, the Plans should be reviewed by the County, Township, and Licensee.

New address: 1580 Charlestown Road, Phoenixville, PA 19460 CORRECTIVE ACTION DESCRIPTION: Plan changes were implemented and two copies of.the revised plans (County and Municipal) were provided to FEMA during the Limerick re-demonstrations on December 14, 2009.

A review by FEMA of the revised Charlestown Township, Radiological Emergency plan indicates the location of the Charlestown Emergency Operations Center was and continues to be listed as 4030 Whitehorse Road, DeVault, PA in the Charlestown Radiological Emergency Response Plan Revision 2 page 15 and Attachment K, Appendix K-I.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY: 0]

Emergency Public Information and Warning Chester County, Emergency Management Agency CAPABILITY ELEMENT: START DATE:

Planning 2009-11-17 AGENCY POC: COMPLETION DATE:

Deputy Director, Chester County Emergency 2010-11-17 Management 310-644-5000 112 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station ISSUE: The South Coventry Township Emergency-Manager did not complete stqps4identified in the South Coventry Township Radiological Response Plan because the "recommendation"*of evacuation did not prompt steps to be completed.

RECOMMENDATION: Revise SCTRERP, section I. P..1d (b) on page.48 to read "If evacuation is:directed or recommended..."

CORRECTIVE ACTION DESCRIPTION: Plan changes are under review to ensure the term recommendation" is incorporated in all 16 municipal plans. This change will~be implemented during the next planning cycle prior to the end of 2010. - ,

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Emergency Operations Center Management Chester County Emergency Management Agency CAPABILITY ELEMENT: START DATE:

Planning 2009-11-17 AGENCY POC: COMPLETION DATE:

Deputy Director, Chester County Emergency 2010-11-17 Management 610-644-5000 "' _- " " _ _ _____ _

ISSUE: The Radiological Equipment Distributii*nsheetip'ovided with dosimetry at the Douglass Township was incomplete and inaccurate. It was dated July"2007 for distrbiution, but did not have any information about when the direct-reading dosimeters (DRDs) were last-leak tested. Additionally, the sheet d6es not include the serial numbers of the permanent record dosimeters (PRDs)..

The Radiological Equipment Distribution .sheet indicated that the box contained 44 Model DCA-622 (0-20 R).

DRDs and 18 Model CD V-742 (0-200 R) DRDs. An' inspection .othe inventory indicated that included 39 Model DCA-622 (0-20 R) DRDs; 5 Arrow-Tech Model 730, (0-20 R) DRDs 4 Model CD V-730 (0-20 R) DRDs, and 14 CD V7742 (0-200 R) DRDs. In summary, the box contained four fewer 0-200 R DRDs than indicated on the inventory list and four more 0-20 R DRDs than indicated on the inventory list..

RECOMMENDATION: Inventories should be checked against the Radiological Equipment Distribution sheet by a second person.

PEMA Response: Schedule of Corrective Actions; The Douglass Township dosimetry inventory has been checked and adjusted as appropriate to be consistent with the Radiological Equipment Distribution Sheet.

CORRECTIVE ACTION DESCRIPTION: Montgomery County officials will review and correct any inventory and documentation discrepancies. In late 2009, Montgomery County officials began working with Douglass Township Administration to replace the current Emergency Management Coordinator (EMC). A candidate has been identified by Douglass Township in the first quarter of 2010. After the new EMC is officially appointed by the Commonwealth of Pennsylvania, a full plan review will be completed and any discrepancies corrected.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Emergency Operations Center Management Montgomery County Emergency Management Agency CAPABILITY ELEMENT: START DATE:

Planning 2007-08-07 AGENCY POC: COMPLETION DATE:

Radiological Planner/Trainer 610-631-6524 2010-11-17 113

Unclassified Ridio!cgical Emergency Preparedness Program (REP)

After Action Report/improvement Plan Limerick Generating Station ISSUE: The Lower Salford Township plan states that TCPs/ACPs will be manned at the Site Area Emergency classification by township personnel. The Police/Public Works checklist did not contain this information in their checklists.

RECOMMENDATION: Incorporate the specific TCPs/ACPs from the Lower Salford Township Plan, Attachment D, into the Police/Public Works checklists for the Site Area Emergency classification.

CORRECTIVE ACTION DESCRIPTION: Traffic Control Point /Access Control Point (TCP/ACP) personnel are traditionally briefed for possible deployment to their assigned locations at the Site Area Emergency classification. The Lower Salford Plan and associated checklist(s) will be reviewed and corrected as appropriate.

CAPABILITY:. PRIMARY RESPONSIBLE AGENCY:

Emergency Public Safety and Security Response Montgomery County Emergency Management Agency 0 CAPABILITY ELEMENT: START DATE:

Planning 2009-11-17 AGENCY POC: COMPLETION DATE:

Radiological Planner/Trainer 610-631-6524 2010-11-17 Isu br Nu rtro :32 ISSUE: The Western Montgomery County Area Vocational/Technical School, which is located within the Spring-I0-c--1, Ford Area School District, serves students from the Spring-Ford, Upper Perkiomen, and Pottsgrove School Districts. Questions were, raised regarding whetheror*not Spring-Ford relocated al!the V'ocational/Technical School studen0; rowhether each district handled the yelo.cation.of their..awn student population attending the.

school.

RECOMMENDATION: The three school districts and the Administration of the Vocational/Technical School, in consultation with the Montgomery.County Authority, jointlyresolve the approach for relocating Vocational/Technical School students and update their plans accordingly.

CORRECTIVE ACTION DESCRIPTION: Montgomery County will consult with the affected schools to ensure plans are updated to provide clarity for all concerns. The Montgomery County Office of Emergency Management will recommend the movement of all students from the Western Center for Technical Studies (WCTS) to the Upper Perkiomen High School as the Upper Perkiomen High School is located outside the 10 mile Emergency Planning Zone (EPZ). Currently, the Radiological Emergency Response Plan (RERP) for Western Center for Technical Studies lists Upper Perkiomen School District as a host school. Additionally, transportation for evacuation of WCTS students will be provided by Montgomery County Office of Emergency Management via the Towamencin TSA. Reference will be made in each school district RERP stating the same.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Citizen Evacuation and Shelter-in-Place Montgomery County Office of Emergency Management 0 CAPABILITY ELEMENT: START DATE:

Planning 2009-11-17 AGENCY POC: COMPLETION DATE:

Radiological Planner/ Trainer 610-631-6524 2010-11-17 114

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station ISSUE: The County Plan contained a.map showing the route to be taken from.Spring-Ford School District to the Montgomery County Community College; however there were no directions regarding where on the college campus the students from each school would be sheltered. Without clear plan guidance, management of the relocation activities, and pick-up of evacuated students on the college campus would be difficult.

RECOMMENDATION: Update the School District Plan to provide specific informationregarding relocation of students once they arrive at the Montgomery County Community College.

CORRECTIVE ACTION DESCRIPTION: Montgomery County Community College (MCCC) has multiple locations on campus for re-located students. Montgomery County officials will meet with Community College administrators to determine the appropriate method(s) for resolving this issue. The Spring-Ford Area School District RERP will be reviewed and recommendations will be made concerning assignments for building relocation to MCCC based upon recommendation from MCCC personnel. A meeting will be held between Spring-Ford Area School District and MCCC to determine what facilities on their campus would be best utilized to meet their need(s) to include the following buildings. Parkhouse'Hall, Science Center, Fine Arts Center and.Physical Education Center.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Citizen Evacuation and Shelter-in-Place Montgomery County Office of Emergency Management CAPABILITY ELEMENT: START DATE:

Planning . .20,09-11-17 AGENCY POC: .COMPLETION 'DATE:

Radiological Planner/ Trainer 610-631-6524 2010-11-17 Isse N nibr: 5-0-3c-Pr1I1 ISSUE: The Western Montgomery County Area Vocational/Technical School, which is located within the Spring-Ford Area School District, serves students. from-the Spring-Ford, Upper Perkiomen, and Pottsgrove School Districts. Questions were raised regarding whether or not Spring-Ford relocated all the Vocational/Technical School students, or whether each district handled the relocation of their own student population attending the school.

RECOMMENDATION: The three school districts and the Administration of the Vocational/Technical School, in consultation with the Montgomery County Authority, jointly resolve the approach for relocating Vocational/Technical School students and update their plans accordingly.

CORRECTIVE ACTION DESCRIPTION: Montgomery County will consult with the affected schools to ensure plans are. updated to provide clarity for all concerns. The Montgomery County Office of Emergency Management will recommend the movement of all students from the Western Center for Technical Studies (WCTS) to the Upper Perkiomen High School as the Upper Perkiomen High School is located outside the 10 mile Emergency Planning Zone (EPZ). Currently, the Radiological Emergency Response Plan (RERP) for Western Center for Technical Studies lists Upper Perkiomen School District as a host school. Additionally, transportation for evacuation of WCTSstudents will be provided by Montgomery County Office of Emergency Management via the Towamencin TSA. Reference will be made in each school district RERP stating the same.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Citizen Evacuation and Shelter-in-Place Montgomery County Office of Emergency Managment CAPABILITY ELEMENT: START DATE:

Planning 2009-11-17 AGENCY POC: COMPLETION DATE:

Radiological Planner/ Trainer 610-631-6524 2010-11-17 115

0

'Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

'U A;3 ISSUE: Newer housing developments and other recent construction has caused route alert maps to be out of date.

RECOMMENDATION: Upper Frederick Township should review and update all route alerting maps to reflect the most recent changes, to ensure new residential housing areas and roads are reflected on the maps. Then, the fire companies should actually drive the routes and determine if existing routes are too. long and may need to be further divided to ensure the 45-minute requirement can be met.

CORRECTIVE ACTION DESCRIPTION: Agreed. Route alerting maps should be reviewed periodically, amended as needed, and analyzed to determine the level of resources needed to ensure timeliness of public notifications in the event of a siren failure. In 2010 Montgomery County Office of Emergency management will begin a Geographic Information System (GIS) project to update all route alert maps within the Emergency Planning Zone (EPZ), This project will include the creation of a GIS tool/ template that will enable for creation of new route alert maps as dictated by a new development and creation of new roadways.. As a result of the project, new route alert maps will be distributed to all EPZ municipalities by the third quarter of 2010.

CAPABILITY: . . . - PRIMARY RESPONSIBLE AGENCY: 0 Emergency Public Information and Warning . - Montgomery County Office of Emergency Management CAPABILITY ELEMENT: START DATE:

Planning 2009-11-17 AGENCY POC: .. COMPLETION DATE:

Radiological Planner/ Trainer 610-631-6524 .2010-11-17

.... 1 ISSUE: The Western Montgomery County Area Vocational/Technical School, which is located within the Spring-Ford Area School District, serves students from the Spring-Ford, Upper Perkiomen, and Pottsgrove School Districts. Questions were raised regarding whether or not Spring-Ford relocated all the Vocational/Technical School students, or whether each' district handled the relocation of their own student population attending the school.

RECOMMENDATION: The three school districts and the Administration of the Vocational/Technical School, in consultation with the Montgomery County Authority, jointly resolve the approach for relocating Vocational/Technical School students and update their plans accordingly.

CORRECTIVE ACTION DESCRIPTION: Montgomery County will consult with theaffected schools to ensure plans are updated to provide clarity for all concerns. The Montgomery County Office of Emergency Management will recommend the movement of all students from the Western Center for Technical Studies (WCTS) to the Upper Perkiomen High School as the Upper Perkiomen High School is located outside the 10 mile Emergency Planning Zone (EPZ). Currently, the Radiological Emergency Response Plan (RERP) for Western Center for Technical Studies lists Upper Perkiomen School District as a host school. Additionally, transportation for evacuation of WCTS students will be provided by Montgomery County Office of Emergency Management via the Towamencin TSA. Reference will be made in each school district RERP stating the same.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Citizen Evacuation and Shelter-in-Place Montgomery County Office of Emergency Management CAPABILITY ELEMENT: START DATE:

Planning 2009-11-17 AGENCY POC: COMPLETION DATE:

Radiological Planner/ Trainer 610-631-6524 2010-11-17 116 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station ISSUE: Newer housing developments and other recent construction has caused route alert maps to be out of date.

RECOMMENDATION: Upper.Pottsgrove Township should review and update all route alerting maps to reflect the most recent changes, to ensure new residential housing areas and roads are reflected on the maps. Then, the fire companies should actually drive the routes and determine if existing routes are too long and may need to be further divided to ensure the 45-minute requirement can be met.

CORRECTIVE ACTION DESCRIPTION: Agreed. Route alerting maps should be reviewed periodically, amended as needed, and analyzed to determine the level of resources needed to ensure timeliness of public notifications in the event of a siren failure. In 2010 Montgomery County Office of Emergency management will begin a Geographic Information System (GIS) project to update all route alert maps within the Emergency Planning Zone (EPZ), This project will include the creation of a GIS tool/ template that will enable for creation of new route alert maps as dictated by a new development and creation of new roadways. As a result of the project, new route alert mans will be distributed to all EPZ municinalities bv the third auarter of 20 10.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Emergency Public Information and Warning Montgomery,:County Office of Emergency Management CAPABILITY ELEMENT: START DATE:

Planning 2009-11-17 AGENCY POC: COMPLETION DATE:

Radiological Planner/ Trainer 610-632-6524 2010-11-17 II7-ISSUE: Discrepancies exist between the dosimetry information on the emergency worker radiological briefing videotape and the Risk Township Radiological Emergency. Response Plans.

RECOMMENDATION: Revise the radiological briefing videotape and Dosimetry-KI Report Form to reflect current information.

Schedule of Corrective Actions: The Commonwealth Emergency Operations Plan and the Commonwealth Nuclear Power Plant Incident Annex (Annex E) are currently underg6ing revision including aspects related to dosimetry, forms, exposure limits, etc. The commonwealth and contributing stakeholders (REP counties and utilities) will work to address the apparent discrepancies. The videotape was not produced by the commonwealth. Future use and proposed modifications to the videotape and referenced materials are currently under review. In the interim, clarification statements have been provided to supplement the emergency worker radiological briefing (rad briefing). Modifications to the rad briefing will be available for inspection during the nextannual plan review.

CORRECTIVE ACTION DESCRIPTION: REASON UNRESOLVED: Planning issue 35-07-3.a.l-P-01 has partially been corrected by PEMA by issuance of a new videotape to the Risk Counties to be used by them to brief Emergency Workers on emergency worker exposure control. In addition, Pennsylvania Annex E, Radiological Emergency Preparedness Response to Nuclear Power Plant Incidents, Change 4 dated March 2002, to the State Emergency Operations Plan is currently undergoing a major revision. PEMA has provided interim guidance in a memo dated April 6, 2009 to be used until all necessary changes have been made and incorporated into Annex E. Until all of the changes are made and incorporated into Annex E, this issue will remain unresolved.

CORRECTIVE ACTION DESCRIPTION: When the issue was presented in 2007 the recommendation was to "Revise the radiological briefing videotape and Dosimetry-KI Report Form to reflect current information." Both of these items have been addressed. Additionally, other electronic and specific 3-part hardcopy forms were updated and provided to the various participating agencies to ensure continuity of plans. It is also true that Annex E of the State Emergency Operation Plan is currently undergoing a major revision and that PEMA had issued the interim guidance dated April 6, 2009. The interim guidance coupled with the updated video and forms should insure that such discrepancies, as stated in the issue above, are resolved.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

Responder Safety and Health Pennsylvania Emergency Management Agency CAPABILITY ELEMENT: START DATE:

Planning 2007-08-07 AGENCY POC: COMPLETION DATE:

Chief, Technological Hazards Division 717-651-2723 2010-11-17 117

0

'Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

~

Issue Nu ~br3'I-a--2C

~~I itro:3 ISSUE: Local jarisdictions'(boroughs and townships) do not maintain 0-200 R Direct Reading Dosimeters (DRDs); all 0-200 R DRDs are maintained at the County EOC.

RECOMMENDATION: Plans should address coordination of 0-200 R DRD issuance to avoid delays in life-saving situations. This issue is being assigned to the Commonwealth of Pennsylvania because it affected several counties. The Commonwealth will review its policies, guidance, and information to provide clear direction to its counties on the coordination of 0-200 R DRD issuance to avoid delays in life-saving situations.

CORRECTIVE ACTION DESCRIPTION: This issue should be credited to the Commonwealth as this issue can not be specific to any one county as the policy, guidance, and information developed by the Commonwealth applies to all Pennsylvania risk counties. The Commonwealth will review its policies, guidance, and information to provide clear direction to its countieson the coordination of 0-200 R DRD issuance to avoid delays in life-saving situations. (This was originally assigned to Berks County item "3.3.2.14 Berks County, Douglass Township EOC", 35-09-3al-P-02). It was reassigned to the Commonwealth of Pennsylvania.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY: 0 Emergency Public Safety and Security Response Pennsylvania Emergency Management Agency CAPABILITY ELEMENT: START DATE:

Planning 2009-11-17 AGENCY POC: COMPLETION DATE:

Chief, Technological hazards Division 717-651-2723 2010-11-17 118 0

Unclassified Radiological EmergencyPreparedness Program (REP)

After Action Report/Improvement Plan Limerick.Generating Station APPENDIX B: EXERCISE TIMELINE Table 1, on the following page, presents the times at which key events and activities occurred during the LGS exercise on November 17, 2009. Also included are times notifications were made to the participating jurisdictions/functional entities.

Table 1 - Exercise Timeline DATE: 2009-11-17, SITE:. Limerick Generatinq Station, PA Unusual Event 1534 1545 NA NA 1545 1545 1 NA Alert 1657 1709 1715 NA 1709 1709 1722 Site Area Emergency 1839 1846 1850 1839 1846 1848 1853 General Emergency 1957 2006 2010 2021 2006 2014 2021 Simulated Rad. Release Started 1957 2006 2017 2031 1952 2014 Simulated Rad. Release Ongoing NA NA NA NA NA Terminated Facility Declared Operational 1721 1721 1858 1721 1657 1745 Governor's Declaration of State of Emergency 1910 1931 1953 1910 1920 Local Declaration of State of Emergency NA Exercise Terminated 2146 2150 2141 2146 2148 2132 Precautionary Actions:

Restrict airspace 2006 2006 2141 2006 2130 Restrict rail traffic 1910 1910 1910 1910 2026 Restrict water traffic 1956 1956 1956 1956 1956 Shelter livestock, place on stored feed 1906 1953 1953 1906 1906 1st A&N Decision Time/Reason: 1905 1905 1905 1905 1905 1927 1st Siren Activation 1915 1915 1st EAS Message 1918 2nd A&N Decision Time/Reason:: 2040 2040 2040 2040 2040 2054 2nd Siren Activation 2050 2050 2nd EAS Message 2053 KI Administration Decision:

Emergency Workers advised to take KI 2036 2040 2040 2040 2036 2048 Action taken at location KI Administration Decision:

General Public advised to take KI 2036 2040 2040 2040 2036 2036 Action taken at location 119

0 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Table 1 - Exercise Timeline

-DATE: 2009-1.1-17, SITE: Limerick Generatinq Station, PA Unusual Event 1534 NA NA NA 1633 NA NA Alert 1657 1722 1724 1722 1709 1730 1801 Site Area Emergency 1839 1850 1852 1851 1848 1856 1858 General Emergency 1957 2016 2015 2015 2014 2021 2021 0

Simulated Rad. Release Started 1957 2014 Simulated Rad. Release Ongoing NA Terminated Facility Declared Operational 1830 1745 1839 1556 1828 1818 Governor's Declaration of State of Emergency 1918 Local Declaration of State of Emergency NA Exercise Terminated 2052 2149 2146 2147 2157 2147 Precautionary Actions:

Restrict airspace 2036 Restrict rail traffic 1947 Restrict water traffic 1956 Shelter livestock, place on stored feed 1906 I st A&N Decision Time/Reason: 1930 1913 1911 1905 1927 NR 1st Siren Activation 1915 Ist EAS Message 2nd A&N Decision Time/Reason:: 2048 2049 2046 2040 .2051 2059 2nd Siren Activation 2050 2nd EAS Message KI Administration Decision: 2048 Emergency Workers advised to take KI 2049 2046 2036 2051 2059 Action taken at location KI Administration Decision: 2048 General Public advised to take KI 2049 2046 2036 2051 2036 Action taken at location I 120 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Table 1 - Exercise Timeline DATE: 2009-11-17, -SITE: Limerick Generatinc Station, PA Unusual Event 1534 NA NA NA NA 1545 NA Alert 1657 1730 1735 1758 1759 1709 1718 Site Area Emergency 1839 1858 1857 1858 1856 1848 1903 General Emergency 1957 2021 2022 2002 2022 2014 2020 Simulated Rad. Release Started 1957 2006 Simulated Rad. Release Ongoing NA' Terminated Facility Declared Operational 1830 1740 1825 1822 1740 1745 Governor's Declaration of State of Emergency 1945 Local Declaration of State of Emergency 1930 Exercise Terminated 2149 2147 2138 2147 2148 2150 Precautionary Actions:

Restrict airspace 1952 Restrict rail traffic 1952 Restrict water traffic 1956.

Shelter livestock, place on stored feed 1906 1st A&N Decision Time/Reason: NR NR 1925 NR 1905 1913 1st Siren Activation 1915 1st EAS Message 2nd A&N Decision Time/Reason::. 2054 2054 2053 2051 2040 NR 2nd Siren Activation 2050 2nd EAS Message KI Administration Decision:

Emergency Workers advised to take KI 2054 2054 2053 2051 2036 2052 Action taken at location KI Administration Decision:

General Public advised to take KI 2054 2054 2053 2051 2036 2'052 Action taken at location 121

0 Unclassified Radiological Emergency Preparedness Program (REP)

After-Action ReportJImprovement Plan Limerick Generating Station Table 1 - Exercise Timeline DATE: 2009-11-17, SITE: Limerick Generatinq Station, PA Unusual Event 1534 1 NA NA NA NA 1545 1720 Alert 1657 1717 1718 1718 1718 1757 1758 Site Area Emergency 1839 1902 1903 1903 1903 1852 1855 General Emergency 1957 2019 2021 2021 2021 2018 2020 0 Simulated Rad. Release Started 1957 2036 2036 Simulated Rad. Release Ongoing NA NA Terminated Facility Declared Operational 1748 1743 1744 1740 1726 1825 Governor's Declaration of State of Emergency 1921 1923 Local Declaration of State of Emergency 2038 NA Exercise Terminated 2150 2151 2116 2140 2115 2130 Precautionary Actions:

Restrict airspace 2036 2036 Restrict rail traffic 1947 1947 Restrict water traffic 1958 1958 Shelter livestock, place on stored feed 1924 1924 I st A&N Decision Time/Reason: 1915 1925 1918 1913 1905 2036 1st Siren Activation 1st EAS Message 2nd A&N Decision Time/Reason:: NR NR NR 2041 2049 2049 2nd Siren Activation 2nd EAS Message KI Administration Decision:

Emergency Workers advised to take KI 2054 2057 2045 NR 2036 NR Action taken at location KI Administration Decision:

General Public advised to take KI 2054 2057 2045 2041 2036 NR Action taken at location 122 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS 123

0 Unclassified RadiologicalEmergency Preparedness Program (REP)

After Action Repor'JImprovement Plan Limerick Generating Station DATE: 2009-11-17, SITE: Limerick Generating Station, PA LOCATION - EV~ALUAT~OR & GENCY~

Pennsylvania Emergency Operation Center *Barton Freeman FEMA Rill Tina Lai REP Albert Lookabaugh FEMA RIII Carl McCoy REP Michael Shuler ICF ICF FEMARIII REP Pennsylvania Joint Information*Center Carl McCoy ICF Pennsylvania Accident Assessment Center, State Emergency *Reggie Rogers ICF Operations Center-Bureau of Radiation Protection .....

Pennsylvania Bureau of Radiation Protection Activities,' Exelon Emergency Operating Facility, Coatesville 41 Pennsylvania State Traffic and'Access Control Points, State-Police Paul Cromier ICF Barracks Skippack Pennsylvania Bureau of Radiationp'rotection, Radiological Rapid Response .Vehicle PA State Field Monitoring Team A, South East Region "

PA State Field Monitoring Team B, South East Region Berks County Emergency Operation Center Marcy Campbell ICF Quirano lannazzo ICF Daniel Lerch FEMA RII Roy Smith REP ICF Berks County Reception Center, Morgantown Crossing Richard Watts ICF Berks County Reception Center, Robeson Township Building Gary Snodgrass ICF Berks County Monitoring and Decontamination Center,Governor Daryl Thome ICF Mifflin Senior High School Berks County Mass Care Center, Governor Mifflin Senior High Robert Duggleby' ICF School Berks County Monitoring and Decontamination Station, Muhlenberg Stephen Chambers' ICF Senior High School Berks County Mass Care Center, Muhlenberg Senior High. School Clark Duffy ICF Berks County Monitoring and Decontamiratiion Center, Schuylkill Keith Earnshaw ICF Valley School Complex Berks County Mass Care Center, Schuylkill Valley School Complex Earl Shollenberger ICF Berks County Monitoring and Decontamination Station, Wilson Larry Harrington. ICF 40 Central Junior High School Berks County Mass Care Center, Wilson Senior High School John Zeidler ICF Berks County, Boyertown Borough/Colebrookdale Township Tana Alert ICF Emergency Operations Center Daniel Prevo ICF Berks County, Colebrookdale Township Traffic and Access Control Daniel Prevo. ICF Berks County, Douglass Township Emergency Operations Center Ernest Boaze ICF Elizabeth Haney ICF Berks County,. Douglass Township Traffic and Access Control Elizabeth Haney ICF Berks County, Union Township Emergency Operations Center Michael Burns ICF Tracey Green ICF Berks County, Union Township Back-up Route Alerting A Michael Burriss ICF Berks County, Union Township Back-up Route Alerting B William Palmer ICF Berks County, Union Township Back-up Route Alerting C Bruce Swiren ICF 124 0

,Unclassified Radiological Emergency, Preparedness Program (REP)

After Action Report/]mprovement Plan Limerick Generating Station Berks County, Washington Township Emergency Operations Center Eric Carter. ICF David Kayen. ICF Chester County Emergency Operations Center Henry Christiansen ICF Gary Goldberg ICF Lawrence Visniesky ICF Martin Vyenielo FEMA Chester County Emergency Worker Monitoring and Decontamination Karl Flippinger ICF Station, Valley Forge Intermediate School Joseph Keller ICF Chester County Reception Center, Downingtown High School Karl Flippinger ICF Chester County Monitoring and Decontamination Center, Downington Karl Flippinger . ICF High School Donald Jacobson ICF Chester County Mass Care Center, Avon Grove High School Barton Freeman FEMA RIIl REP Chester County Mass Care Center, Fred Engle Middle School Barton Freeman. FEMA RII REP Chester County Mass Care Center, Gordon Middle School . Barton Freeman FEMA RIII REP Chester County, Charlestown Emergency Operations Center Jon Christiansen ICF John Willis' ICF Chester County, East Coventry Township Emergency Operations Frank Cordaro ICF Center John Flynn ICF-Chester County, East Coventry Township Traffic and Access Control John Flynn ICF Chester County, South Coventry Township Emergency Operations Steve Denron " ICF Center Nicholas DePierro ICF Michael Petullo ICF Chester County, Schuylkill Township Emergency Operations Center Mark Dalton ICF Thomas Gahan . ICF Chester County, Schuylkill Township Back-up Route Alerting:A Gregg Dawkins ICF Chester County, Schuylkill Township Back-up Route Alerting B Nicholas DePierro ICF Chester County, Schuylkill Township Back-up Route Alerting C Martin Vyenielo FEMA Chester County, Schuylkill Township Traffic and Access Control Thomas Gahan ICF Gary Goldberg ICF Chester County, West Pikeland Emergency Operations Center Rosemary Samsel. ICF William Vocke ICF' Chester County, West Pikeland Township Traffic and Access Control William Vocke ICF Chester County, West Vincent Township Emergency Operations Glen Kinnear ICF Center Carl Wentzell ICF Chester County, West Vincent Township Traffic and Access Control Carl Wentzell ICF Montgomery County Emergency Operations Center. Alejandro Fernandez ICF Robert Host ICF William O'Brien ICF Bart Ray ICF Clayton Spangenberg ICF Montgomery County Emergency Worker Monitoring and Ronald Bonner ICF Decontamination Station, Upper Perkiomen High School Montgomery County, Douglass Township Emergency Operations Barton Freeman FEMA RIIl Center REP Montgomery County, Lower Providence Township Emergency Bernie Hannah ICF Operations Center Marynette Herndon ICF Montgomery County, Lower Providence Township Traffic .and Access Bernie Hannah ICF Control Montgomery County, Lower Salford Township Traffic and Access Jill Leatherman . ICF Control 125

0 Unclassified Radio'ogical Emergency Preparedness Program (REP)

After Action Report/improvement Plan Limerick Generating Station Montgomery County, Lower Salford Township Emergency Operations Jill Leatherman ICF Center Lynn Steffensen ICF Montgomery County, Pottstown Borough Emergency Operations James Greer -ICF Center Robert Lemeshka ICF Montgomery County, Pottstown Borough Traffic and Access Control James Greer ICF Montgomery County, Upper Frederick Township' Emergency ..Richard Wessman ICF Operations Center David White ICF Montgomery County, Upper Pottsgrove Township Emergency Richard McPeak ICF Operation Center Patrick Taylor ICF Montgomery County, Upper Pottsgrove Township Back-up Route ' Kent Tosch ICF Alerting Montgomery County, Upper Pottsgrove Township Traffic and Access Richard McPeak ICF Control ... ...

Berks County, Boyertown Area School District *Nancy Johnson ICF Berks County, Boyertown Area District, Boyertown Elementary Earl Shollenberger ICF School Berks County,' Boyertown Area School District, Boyertown Senior ' Richard Watts ' ICF High School Berks County, Boyertown Area School District, Boyertown Junior Robert Duggleby ICF High School West Berks County, Boyertown Area School District, New.Hanover/Upper Nicholas DePierro ICF Frederick Elementary School Berks County, Boyertown Area School District, Washington Larry Harrington ICF Elementary School Berks County, Daniel Boone Area School District Gary Snodgrass ' ICF Berks County, Daniel Boone Area District, Monocacy Elementary Keith Earnshaw ICF Center Berks County, Daniel Boone Area School District, Daniel Boone High Gary Snodgrass ICF School Chester County, Downingtown Area School District Joseph Keller ICF Chester County, Downingtown Area School District, Downingtown John Willis ICF High School East Chester County, Downingtown Area School District, Downingtown Joseph Keller ICF High School West Chester County, Downingtown Area School District, Lionville Middle Lawrence Visniesky ICF School Chester County, Downingtown Area School District, Shamona Creek John Flynn ICF Elementary School Chester County, Downingtown Area School District, Uwchlan Hills Thomas Gahan. ICF Elementary School Chester County, Great Valley School District, Great Valley Middle Donald Jacobson ICF School Chester County, Great Valley School District, KD Markley Michael Petullo ICF Elementary School Chester County, Owen J. Roberts School District Gary Goldberg ICF Chester County, Owen J. Roberts School District, East Coventry Gary Goldberg . ICF Elementary School Chester County, Owen J. Roberts School District, East Vincent Carl Wentzell ICF Elementary School Chester County, Owen J. Roberts School District, Owen J. Roberts Karl Flippinger ICF High School Chester County, Phoenixville Area School District William Vocke ICF 126

,Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Chester County, Phoenixville Area School District, Phoenixville Area William Vocke, ICF High School Chester County, Phoenixville Area School District, Kindergarten Mark Dalton ICF Center Montgomery County, Methacton School District, Jill. Leatherman ICF Montgomery County, Methacton School District, Methacton High Jill Leatherman ICF School Montgomery County, Methacton School District, Arcola Intermediate Jill Leatherman . ICF School Montgomery County, Methacton School District, Eagleville Kent Tosch ICF-Elementary School Montgomery County, Perkiomen Valley School District Bruce Swiren ICF Montgomery County, Perkiomen Valley District, Schwenksville Bruce Swiren ICF Elementary School Montgomery County, Perkiomen Valley School District, Perkiomen James Greer ICF Valley Elementary South Montgomery County, Perkiomen Valley School District, Perkiomen Bernie Hannah* ICF Valley High School Montgomery County, Pottsgrove School District Marynette Herndon ICF.

Montgomery County, Pottsgrove School District, Lower Pottsgrove Robert Lemeshka ICF.

Elementary School - .

Montgomery County, Pottsgrove School District, West Pottsgrove Marynette Herndon - ICF Elementary School Montgomery County, Pottstown Area School District David White ICF Montgomery County, Pottstown Area School District, Edgewood David White. ICF Elementary School Montgomery County, Pottstown Area School District, Franklin . John Zeidler ICF Elementary School _ ,

Montgomery County, Pottstown Area School District, Lincoln Stephen Chambers ICF Elementary School Montgomery County, Pottstown Area School District, Pottstown Clark Duffy ICF Middle School Montgomery County, Souderton Area School District Patrick Taylor ICF Montgomery County, Souderton Valley Area School District, Indian Patrick Taylor ICF Valley Middle School .

Montgomery County, Spring-Ford Area School District Richard Wessman ICF Montgomery County, Spring-Ford Area School District, 5th, 6th, &7th William O'Brien ICF Grade Center Montgomery County, Spring-Ford Area School District, Limerick Richard McPeak ICF Elementary School Montgomery County, Spring-Ford Area School District, Spring-Ford David Kayen ICF Area High School Montgomery County, Spring-Ford Area School District, Evans Ronald Bonner ICF Elementary School Montgomery County, Spring-Ford Area School District, Upper Roger Jobe ICF Providence Elementary School Montgomery County, Spring-Ford Area School District, Royersford Richard Wessman ICF Elementary School Montgomery County, Upper Perkiomen School District Clayton Spangenberg ICF Montgomery County, Upper Perkiomen School Distirct, Upper William Palmer ICF Perkiomen High School 127.

Unclassified Radiological Emergency PreparednessProgram (REP)

After Action Report/Improvement Plan Limerick Generating Station Montgomery County, Upper Perkiomen School District, Marlborough Quirano lannazzo ICF Elementary School Bucks County Emergency Operations Center ."*Joseph Suders FEMA Rill Bucks County Mass Care Center, Bucks County Community College Robert Neff FEMA Rill

• __"___________"_ _ "__ "REP Bucks County Mass Care Center, Central Bucks West High School Robert Neff FEMA Rill REP Bucks County Mass Care Center, Cenitral Bucks East Complex Robert Neff FEMA R111 REP Bucks County Mass Care Center, Delaware Valley College Barton Freeman FEMA RIII REP Bucks County Mass Care Center, New Hope-Solebury Jr./Sr. High Robert Neff FEMA RII School REP Bucks County Mass Care Center, Palisades JrSr High :School *Barton Freeman FEMA RIII REP 0 Bucks County Mass Care Center, Pennridge Central Junior High Barton Freeman FEMA RIII School REP Bucks County Mass Care Center, Pennridge Lower High School Barton Freeman FEMA Rill REP Bucks County Mass Care Center, Pennridge South Jr. High School Robert Neff FEMA RiII REP Bucks County Mass Care Center, Pennridge Upper High School Barton Freeman FEMA Rill REP Bucks County Mass Care Center, Unami' Jr. High School RobertNeff FEMA Rill REP Lehigh County Emergency Operations Center *Robert Neff FEMA Ri1 REP Lehigh County Mass Care Center, DeSales University Barton Freeman FEMA RII REP Lehigh County Mass Care Center, Eyer Jr. High School Robert Neff FEMA Rill REP Lehigh County Mass Care Center, Orefield Middle School Robeht Neff FEMA RIJI REP Lehigh County Mass Care Center, Salisbury Middle School Barton Freeman FEMA R1II REP Lehigh County Mass Care Center, South Mountain Middle School Robert Neff FEMA Ri1I REP Lehigh County Mass Care Center, Springhouse Middle School Barton Freeman FEMA Ril REP Lehigh County Mass Care Center, Troxell Jr. High School Barton Freeman FEMA RiII REP Chester County, Great Valley School District Michael Petullo ICF Chester County, Great Valley School District, Great Valley High Daniel Prevo ICF School Exelon Joint Information Center Paul Nied ICF

• Team Le:ader -_______________

128 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Limerick Generating Station

-APPENDIX D: ACRONYMS AND ABBREVIATIONS ACP Access Control Point AP Assistant Principal ARC American Red Cross ARCA Area Requiring Corrective Action ARES Amateur Radio Emergency Services BARTA Berks Area Reading Transportation Authority BASD Boyertown Area School District BC Berks County BCEMA Berks County Emergency Management Agency BJHSW Boyertown Junior High School West CAD Computer Aided Dispatch CCEMA Chester County Emergency Management Agency CCEOC Chester County Emergency Operations Center CCEPRS Chester County Emergency Preparedness Radio System CTEMC Charlestown Township Emergency Management Coordinator CTEOC Charlestown Township Emergency Operations Center DBASD Daniel Boone Area School District DBHS Daniel Boone High School DEHS Downingtown East High School DRD Direct Reading Dosimeter DSD Downingtown School District EAL Emergency Action Level EAS Emergency Alert System ECES East Coventry Elementary School ECL Emergency Classification Level ECS Emergency Communications System EES Evans Elementary School EM EOC Manager EMA Emergency Management Agency EMC Emergency Management Coordinator EMS Emergency Medical Services EMT Emergency Medical Technician EOC Emergency Operations Center EOP Emergency Operations Plan 129

9 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Limerick Generating Station EPA Environmental Protection Agency EPZ Emergency Planning Zone ERT Emergency Response Team ESF Emergency Support Function EW Emergency Workers EWDC Emergency Worker Decon Center EWFC East Whiteland Fire Company EWTVFA East Whiteland Township Volunteer Fire Association FEMA Federal Emergency ManagementAgency FES Franklin Elementary School GE General Emergency 6 GIS Global Information System GVHS Great Valley High School GVSD Great Valley School District HES Hereford Elementary School HMO Hazardous Materials Officer ICS Incident Command System JIC Joint Information Center LGS Limerick Generating Station MCCF Montgomery County Correctional Facility MCEOC Montgomery County Emergency Operations Center MCEPR Montgomery County Emergency Preparedness Radio MCEPRS Montgomery County Emergency Preparedness Radio System MDC Mobile Data Computer MES Marlborough Elementary School MS Middle School PAD Protective Action Decision PAG Protective Action Guideline PBPD Pottstown Borough Police Department PDA Personal Digital Assistant is PEIRS Pennsylvania Emergency Incident Reporting System PEMA Pennsylvania Emergency Management Agency PIO Public Information Officer PKC Phoenixville Kindergarten Center PML PEMA Media Liaison PRD Permanent Record Dosimeter PSO Public Safety Officer PSP Pennsylvania State Police RACES Radio Amateur Civil Emergency Services RCC Rumor Control Center 130 a

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station REM Roentgen Equivalent Man REP Radiological Emergency Preparedness REPP Radiological Emergency Preparedness Plan RERP Radiological Emergency Response Plan RO Radiological Officer RSO Radiation Safety Officer RTRC Robeson Township Reception Center SAE Site Area Emergency,.

SCEOC South Coventry Emergency Operations Center SCT South Coventry Township SCTRERP South Coventry Township Radiological Emergency Response Plan SEOC State Emergency Operations Center SEVAN Statewide Emergency Voice Activation Network SNP Special Needs Population SOG Standard Operating Guideline SRO School Resource Officer ST Schuylkill Township STT Schuylkill Township Transportation TC Transportation Coordinator TCP Traffic Control Point TEDE Total!Effective Dose Equivalent UHES Uwcllan Hills Elementary School UPHS Uppetr Perkiomen High School UPMS UppeIr Perkiomen Middle School UPS Uninterrupted Power Supply UPSD Uppe r Perkiomen School District VMS Variable Message Signs 131

Unclassified Radiological Emergency Preparedness Program (REP)

Afler Action Report/Improvement Plan Limerick Generating Station APPENDIX E: EXERCISE PLAN 0

132 0

Unclassified Radiological Emergency, Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

1. Limerick Generating Station (LGS).

The facility normally uses off-watch section personnel to participate in the exercise. The plant's simulated events, radiation readings, and emergency classifications will trigger offsite exercise actions. A pre-approved exercise scenario will be used. LGS will notify the State EOC, the Bureau of Radiation Protection and Risk Counties of emergency classifications.

2. Bureau of Radiation Protection (BRP)

BRP personnel will be present at the State EOC, the nuclear facility EOF and field locations; BRP will not be evaluated during this exercise.

3. PEMA Operations at State EOC This "Method of Operation" Document includes activities for the Full-Scale Plume Exercise (November 17, 2009), and the "Out of Sequence" Activities (November 17, 2009).

A. Plume Exercise - November 17, 2009 PEMA Bureau of Operations and Training staff, augmented by designated PEMA personnel from the Fire Commissioner's Office, the Bureau of Administration, Technical Services, Plans, plus Emergency Preparedness Liaison Officers (EPLOs) with accompanying response team members from designated state departments/agencies, including representatives from the USDA State Emergency Board will comprise initial operations at the State Emergency Operations Center (EOC). The State EOC will not be evaluated during this exercise.

B. Plume Exercise - "Out of Sequence" Activities - November 17, 2009.

PEMA Bureau of Operations and Training staff, augmented by designated PEMA personnel will disseminate exercise related messages to the participating Counties for dissemination to the participating School Districts during the morning of November 17, 2009. The State Emergency Operations Center (EOC) and County EOCs will NOT be evaluated during the "Out of Sequence" component. PEMA personnel will serve as "observers" at the identified School Districts.

133

-Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station C. "Out of Sequence" Activities - November 18, 2009.

PEMA personnel will serve as "Observers" at the various field exercise locations during the evening "Out-of-Sequence" component November 18, 2009. An exercise coordinator will remain in the State EOC. The State Emergency Operations Center (EOC) and Counties will NOT be evaluated during the evening "Out of Sequence" component.

The Pennsylvania State Police (PSP) demonstration will take place at PSP Skippack Barracks, 2047C Bridge Road,: Schwenksville, Montgomery County. The PSP briefing will be performed out of sequence in a demonstration window of 10:00 a.m. to 12:00 a.m. on November 18, 2009..

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

5. Counties Designated to Participate The threerisk counties (Berks,- Chester, and Montgomery), in coordination with PEMA, will demonstrate the capability to mobilize, appropriate staff, activate their respective Emergency Operations Centers and implement emergency response operations to include sheltering and/or evacuation. County government will provide direction and coordination to risk municipalities. The two support counties (Bucks and Lehigh) will participate in their assigned support roles. Actual sheltering or evacuation of the general public will be simulated.

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

7. Controllers A lead controller will be present in the State EOC. Controllers will be present at the emergency worker monitoring/decontaminating stations and the mass care monitoring/

decontamination centers (November 18, 2009). Controllers are not players. Controllers will provide pre-approved injects and information to the players, as appropriate, regarding radiological readings during the monitoring of personnel. Live radioactive sources will not be used. Exception: individuals tasked with the setup ofportal monitoring equipment will 134 a

'Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station use a standardI micro curie Cesium 13 7 sourcefor the purpose of conducting operational tests. Additionally, appropriatetest sources will be available and used to verify the operation of the monitoring /survey instrumentsper manufacturer'srecommendations.

8. PEMA Observers PEMA staff, qualified county emergency management personnel, and/or nuclear power plant personnel will be assigned, if required, to key locations for the purpose of observing, noting response actions and conditions, and recording observations for future use.

Observers will not take an active part in the proceedings, but will interact with staff members to the extent necessary to fulfill their observer responsibilities. Coaching of players by observers is not permitted except to provide training to participants awaiting a re-demonstration. (Refer to paragraph 13) :

9. FEMA Evaluators Federal evaluators will be present at the risk and support county EOCs and identified risk municipal EOCs, and at appropriate field locations' to evaluate player response. to the actual and simulated events in the exercise scenario.: FEMA will evaluate one-third of the risk municipalities in Berks, Chester, and Montgomery Counties.

Out of Sequence Period (November 17, 2009): Federal evaluators will be present at the identified "out-of-sequence" demonstration sites per Attachment A, Section 1.1 These include the identified Public School Districts.

Plume Phase Exercise (November 17, 2009): Federal evaluators will be.present at the

• identified risk and support county EOC's to evaluate player response to the actual and simulated events in the exercise scenario. Additionally, one-third of the risk municipalities will be federally evaluated.

Out of Sequence Period (November 18, 2009): Federal evaluators will be present at identified Reception Centers, Emergency Worker Monitoring and Decontamination Stations and Mass Care Centers-and Mass Care Monitoring and Decontamination Centers, as identified in Attachment A,Section I.B. 1, I.B.2 and I.B.3. Note: 21 Mass Care Centers (as indicated)will receive a federally evaluatedwalk-down during the week of October 5 h. Additionally, Mass Care Monitoringand DecontaminationCenters are either co-located with Reception Centers or Mass Care Centers as indicatedin Attachment A.

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

demonstrated.

135

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station The "demonstration windows" for this exercise are:

A. Plume Phase Exercise The out-of-sequence MS-'I hospital demonstration was, federally evaluated at Lehigh Valley Hospital, Lehigh County, June 10, 2009.

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

11:00 a.m. on November 17, 2009.

The out-of-sequence demonstration of reception centers, mass care centers (as indicated), monitoring'/ decontaminati6n centers and emergency worker stations will be conducted from 7:00 - 9:30 p.m. on November 18,'2009. Locations are specified within Attachment A,Section I.

Note: 21 mass care centers, (11 in Bucks, 7 in Lehigh and 3 in Chester) will receive "walk-down" baseline evaluations during the week of October 5th. These 21 mass care centers will not be evaluated duiring the evening of N`vember 18th as they are not co-located with monitoring decontamination centers. Mass care centers in Berks County (4) will be evaluated on the evening of Nov'ember 18th.

The out-of-sequence interview of Pennsylvania State Police traffic control / access control points will be from 10:00 a.m. - 12:00 noon. November 18, 2009.

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

County and municipal EOC operations will be conducted'on November 17, 2009.

(Please refer to the Extent of Play Demonstration Tables, Attachment A)

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

11. Stand-down All jurisdictions will request approval on a jurisdiction by jurisdiction basis prior to stand-down.

a. Upon completion of all requirements and after having informed the FEMA evaluator that all evaluation areas have been demonstrated and/or completed, the risk municipality EOCs may request approval from their county EOC to stand-down their portion of the exercise.

136 a

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

b. Support counties may likewiserequest approvalto stand-down upon completion of all evaluated objectives from the state EOC.

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

12. General Concepts An emergency plan is drafted to address the generally expected conditions of an emergency. Not everything in th6 emergency plan maybe applicable for a given scenario.

The main purpose of an emergency plan is to assemble sufficient expertise and officials so as to properly react to the events as they occur. The responders should not be so tied to a plan that they cannot take actions that are more protective of the public. Therefore, if, by not following the plan, the responders protect the public equally as well as provided in the plan, it should be noted for possible modification of the plan, but not classified as a negative incident. Furthermore, if, by following the plan there is a failure to protect the public health and safety, it should be noted so th at the plan can be modified and the appropriate negative assessment 'applied..

13. Re-demonstrations.

Any activity that is not satisfactorily demonstrated may be re-demonstrated by the participants during the.exercise, provided it does not negatively interfere with the exercise.

Refresher training maybe provided by the players, observers, and/or controllers.

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

137

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station EXTENT OF PLAY AGREEMENT EVALUATION AREA 1 Emergency Operations Management Sub-element L.a - Mobilization INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to alert, notify, and mobilize emergency personnel and to activate and staff emergency facilities:

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

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

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

PEMA NegotiatedExtent of Play:

Pre-positioningof state emergency personnel (LiaisonOfficers) at the Emergency Operations Facility (EOF),the Utility Joint Information Center (JIC)and Risk and Support Counties is appropriatedue to the commuting distancefrom the individual's duty location or residence.

Risk municipalities will conduct call-outs to demonstrate the mobilization of key personnel.

• Actual calls (orpager notifications)will be made to the municipalEOCpersonnel

,for the Plume Phase exercise per plans andprocedures.

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

138 0

Unclassified RadiologicalEmergency Preparedness Program (REP)

After Action Report/Improvement Plan .. - Limerick Generating Station 9 All out-of-sequence players and equipment 'willibepre-positioned (School District personnel,PennsylvaniaState Police A CP, Reception Centers, Emergency Worker Monitoring and DecontaminationStations and Monitoringand DecontaminationCenters).

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

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

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

(NUREG-0654, H.3)

EXTENT OF PLAY Facilities will only be specifically evaluated for this criterion if they are new or have substantial changes in structure or mission. Responsible OROs!should demonstrate the availability of facilities that support the accomplishment of emergency operations. Some of the areas to be considered are: adequate space, furnishings, lighting, restrooms, ventilation, backup. power and/or alternate facility (if required. to support operations.).

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

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

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

(NUREG-0654, A.l.d; A.2.a, b) 139

Unclassified Radiological Emergency Preparedness Program (REP)

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

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

PEMA NegotiatedExtent of Play: None Sub-element 1.d - Communications Equipment INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should establish reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as the following:

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

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

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

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

140 a

Unclassified Radiological Emergency Preparedness Program (REP)

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

PEMA NegotiatedExtent of Play:

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

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

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

Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency-operations. (NUREG-0654, H.7,10; J.10.a, b, e, J.11; K.3.a)

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

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

Instruments should be calibrated in accordance with the manufacturer's recommendations.

Unmodified CDV-700 series instruments and other instruments without a manufacturer's recommendation should be calibrated annually. Modified CDV-700 instruments should be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration should be on each instrument, or calibrated frequency can be verified by other means. Additionally, instruments being used to measure activity should have a range of reading sticker affixed to the side of the instrument. The above considerations should be included in 4.a. 1 for field team equipment; 4.c. 1 for radiological laboratory equipment (does not 141

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Limerick Generating Station apply to analytical equipment; reception center and emergency worker facilities' equipment under 6.a. 1; and ambulance and medical facilities' equipment under 6.d. 1.

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

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

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

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

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

private or State laboratory indicating that the KI supply remains potent, in accordance with U.S.

Pharmacopoeia standards.

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

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

PEMA NegotiatedExtent of Play:

In Pennsylvania CDV-700s are calibratedevery 4-years. Support counties do not have DRDs, or KI, but those responsiblefor reception centers and/ or monitoringand decontamination centers will have PRDs.

142 4

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Evaluation,of K1 quantities.will be verified.using inventory sheets. K[ will not be. removedfrom storage locationsand boxes /packages will not be opened. KI questions will be addressed through interviews.

Leakage testing verification and K1 extension letters (as appropriate)will be available to the evaluator.

All DRDs "read" in units of Roentgens. The commonwealth, counties and municipalities do not use directreading dosimeters which "read" in units of milli-Roentgens.

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

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

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

(NUREG-0654, K.4, J.10. e, f)

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

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

143

Unclassified Radiological Emergency Preparedness Pregram (REP)

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

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

PEMA NegotiatedExtent of Play: None Sub-element 2.b. - Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations. (ORO) have the capability to use all available data to independently project integrated dose and compare the estimated dose savinigs.with the protective action guides. OROs have the capability to choose, among a range of protective actions, those most appropriate in a given emergency situation. OROs base these choices on PAGs from the ORO's plans and procedures or EPA 400-R-92-001 and other criteria, such as, plant conditions, licensee protective action recommendations, coordination of protective action decisions with other political .

jurisdictions (for example, other affected OROs), availability of appropriate in-place shelter, weather conditions, and situations that create higher than normal risk from evacuation.

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

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

When the licensee provides release and meteorological data, the ORO also considers these data.

The ORO should demonstrate a reliable capability to independently validate dose projections. The types of calculations to be demonstrated depend on the data available and the need for assessments to support the PARs appropriate to the scenario. In all cases, calculation of projected dose should be demonstrated. Projected doses should be related to quantities and units of the PAGs to which 144 a

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station they will be compared. PARs should be promptly transmitted to decision-makers in a prearranged format.

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

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

PEMA NegotiatedExtent of Play:

This criterionwill not be evaluated during this exercise.

Criterion 2.b.2: A de'cision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PAD) for the general public (including the recommendation for the use of K1, if ORO policy). (NUREG-0654, J.9; i0o.f,m)

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

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

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

145

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Limerick Generating Station If more-than one ORO is involved in decision-making, OROS should communicate and coordinate PADs with affected OROs. OROs should demonstrate the capability to communicate the contents of decisions to the affected jurisdictions.

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

PEMA Negotiated Extent of Play: None Sub-element 2.c - Protective Action Decisions Consideration for the Protection of Special Populations INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to determine protective action recommendations, including evacuation, sheltering and use of potassium iodide (KI), if applicable,-for special population groups (for example, hospitals, nursing homes, correctional facilities, schools, licensed day care centers, mobility impaired individuals, and transportation dependent individuals). Focus is on those special population groups that are (or potentially will be) affected by a radiological release from a nuclear power plant.

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

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

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

In accordance with plans and/or procedures, OROs and/or officials of pubic school systems/districts should demonstrate the capability to make prompt decisions on protective actions for students. Officials should demonstrate that the decision making process for protective actions considers (that is, either accepts automatically or gives heavy weight to) protective action 146 0

Unclassified Radiological Emergency Preparedness Program(REP)

After Action Report/Improvement Plan Limerick Generating Station recommendations made by ORO personnel, the ECL at which these recommendations are received, preplanned strategies for protective actions.for.that ECL, and the location of students at the time (for example, whether the students are still at home, en route to the school, or at the school).

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

PEMA Negotiated Extent of Play:.None.

Sub-element 2.d. - Radiological Assessment and Decision-Making for the Ingestion Exposure Pathway This sub-element will not be evaluated duringthis exercise.

Sub-element 2.e. - Radiological Assessment and Decision-Making Concerning Relocation, Re-entry, and Return This sub-element will not be evaluatedduring this exercise.

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

Criterion 3.a.l: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans and procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. (NUREG-0654, K.3.a,b) 147

0 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station EXTENT OF PLAY OROs should demonstrate the capability to provide appropriate direct-reading and permanent record dosimetry, dosimeter chargers, and instructions on the use of dosimetry to emergency workers. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows individual(s) to read the administrative reporting limits (that are pre-established at a level low enough to consider .subsequent calculation of Total Effective Dose Equivalent) and maximum exposure limits (for those emergency workers involved in life saving activities) contained in the 1 1 ORO's plans and procedures.

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

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

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

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

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

PEMA Negotiated Extent of Play:

148 0

Unclassified Radiological Emergency Preparedness' Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Radiological briefings will be providedto addressexposure limits andprocedures'to replace those approachinglimits and how permission to exceed limits is obtainedfrom the municipalityand county. Emergency workers will also be briefed on when to take KI andon whose authority.

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

OROs shouldalso demonstratethe use ofall applicabledosimetryforms to emergency workers.

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

In Pennsylvania, emergency workers outside of the EPZ do not have turnback values.

Emergency workers who are. assigned to lovy exposure rate areas, e.g., at reception centers, counting laboratories, emergency operations centers, and communications centers, may have individual direct-reading dosimeters.or they may be monitored by dosimeters strategically placed in the work area. In Pennsylvania this.will be,accomplished through the use of an area kit. The area kit process is explained in State, County and Municipal Plans.

Standard issue of dosimetry and potassium iodide for each category of emergency worker is as follows:

Category A: 1 PRD, I DRD, and I unitofK!

Category B: 1 PRD and 1 unit of KI Category C: 1 PRD (no KI).

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

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

Sub-element 3.b - Implementation of KI Decision INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to provide radioprotective drugs for emergency workers, institutionalized individuals, and, if in the plan and/or procedures, to the general public for whom immediate evacuation may not be feasible, very difficult, or significantly delayed. While it is necessary for OROs to have the capability to provide KI to emergency workers and institutionalized 149

0 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station individuals, the provision of KI to the general public is an ORO optionand is reflected in ORO's plans and procedures. Provisions should include the availability of adequate quantities, storage, and means of the distribution of radioprotective drugs.

Criterion 3.b.l: KI and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals is maintained.

(NUREG-0654, J. 10. e)

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

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

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

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

PEMA NegotiatedExtent of Play:

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

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

Personnelassigned to operate Monitoring /Decontamination centers and stations are not issued DRDs or KI since the centers/stationsare locatedoutside the EPZ. Each will be issued a 150

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station simulated PRD with mock.serial numbers.. For;purposesof demonstration, a maximum of six PRDs will be issued.

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

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

EXTENT OF PLAY Applicable OROs should demonstrate the capability to alert and notify (for example, provide protective action recommendations and emergency information and instructions), special populations (hospitals, nursing homes, correctional facilities, mobility impaired individuals, transportation dependent, etc.). OROs should demonstrate the capability to provide for the needs of special populations in accordance with the ORO's plans and procedures.

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

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

PEMA NegotiatedExtent of Play:

The names, locations and contact informationof identified individuals with identified special needs are maintainedon a list at their respective municipalEOC (based upon residential jurisdiction). Copies of these lists will not be provided to the evaluators; however, evaluators will be allowed to inspect the lists during the exercise. NOTE. Berks County maintains a countywide special needs listfor individuals requiringassistance. This list may be viewed at the county as it will not be disseminatedfor exercisepurposes.

Initial contact, by the County, with specialpopulations (hospitals,nursing homes and county correctionalfacilities) will be actual. All subsequent calls will be simulated. Actual contacts 151

Unclassified Radiological Emergency Preparedness. Program (REP)

After Action Report/Improvement Plan Limerick Generating Station (up to two per risk county) will be made with transportationprovidersper theirplan. All actual and simulatedcontacts should be logged.

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

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

EXTENT OF PLAY Public school systems/districts shall demonstrate the ability to implement protective action decisions for students. The demonstration shall be made as follows: At least one school in each affected school system or district, as appropriate, needs to demonstrate the implementation of protective actions. The implementation of canceling the school day, dismissing early, or sheltering should be simulated by describing to evaluators the procedures that would be followed. If evacuation is the implemented protective action, all activities to coordinate and complete the evacuation of Students to reception centers, congregate care centers, or host schools may actually be demonstrated or accomplished through an interview process: If accomplished through an interview process, appropriate school personnel including decision making officials (e.g., superintendent/principal, transportation director/bus dispatcher), and at least one bus driver (and the bus driver's escort, if applicable) should be available to demonstrate knowledge of their role(s) in the evacuation of school children. Communications capabilities between school officials and the buses, if required by the plan and/or procedures, should be verified.

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

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

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

PEMA Negotiated Extent of Play:

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

The role of the bus driver may be conducted through an interview with school or transportation officials (or designee) if a bus driver is not available. Actual demonstration of the bus route is 152

Unclassified Radiologica! Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station not requiredand will not be demonstrated. Maps or route descriptions will be availablefor illustrationpurposes.

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

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

However, OROs will be preparedto show evaluators lists of thesefacilities that thy would contact in the event of an emergency in accordancewith plans andprocedures. Any simulatedcontacts should be logged.

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

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

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

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

accordance with the extent of play.

In instances where OROs lack authority necessary to control access by certain types of traffic (rail, water, and air traffic), they should demonstrate the capability to contact the State or Federal agencies with authority to control accessý 153

0 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station All activities must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

PEMA NegotiatedExtent of Play:

Municipal Traffic and Access 'controlwill be demonstratedby interview at the applicable EOC of jurisdiction. The traffic/accesscontrol personnel will not be deployed to the traffic / access controlpoint(s). If thedesignatedassignment is a location within the EPZ,a radiological briefing will be provided to the assignedindividuals; Criterion 3.d.2: Impediments'to evacuation are identified and resolved. (NUREG-0654, J.10.k)

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

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

PEMA Negotiated Extent of Play:

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

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

Sub-element 3.f - Implementation of Relocation, Re-entry, and Return Decisions This sub-element will not be evaluated during this exercise.

EVALUATION AREA 4 Field Measurement And Analysis Sub-element 4.a - Plume Phase Field Measurements and Analyses 154

Unclassified Radiological Emergency Preparedness.Program (REP)

After Action Report/improvement Plan Limerick.Generating, Station INTENT This sub-element derives from NUREG-0654, which provides that OROs should have the capability to deploy field teams with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654 indicates that OROs should have the capability to use field teams within the plume emergency planning zone to measure airborne radioiodine in the presence of noble gases and to measure radioactive particulate material in the airborne plume. In the event of an accident at a nuclear power plant; the possible release of radioactive material may pose a risk to the nearby population and environment. Although accident assessment methods are available to project the ,extent and.magnitude. of a release, these methods are subject to large uncertainties. During an accident, it is important to collect field radiological data in order to help characterize any radiological release. Adequate equipment and procedures are essential to such field measurement efforts.

Criterion 4.a.l: The field teams are equipped to perform field measurements of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and particulates. (NUREG-0654, H.10; 1.7, 8, 9).

EXTENT OF PLAY Field teams should be equipped with all instrumentati6n and supplies necessary to accomplish their mission. This should include instruments capable of measuring gamma exposure rates and detecting the presence of beta radiation. These instruments should be capable of measuring a range of activity and exposure, including radiological protection/exposure control of team members and detection of activity on the air sample collection media, consistent with the intended use of the instrument and the ORO's plans and procedures. An appropriate radioactive check source should be used to verify proper operational response for each low range radiation measurement instrument (less than 1 R/hr) and for high range instruments when available. If a source is not available for a high range instrument, a procedure should exist to operationally test the instrument before entering an area where only a high range instrument can make useful readings.

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

PEMA NegotiatedExtent of Play:

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

155

Unclassified Radiological Emergency, Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Criterion 4.a.2: Field-teams are managed to obtain sufficient information to help characterize the release and to control radiation exposure. ,(NUREG-0654, H.12; 1.8., 11; J.10.a).

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

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

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

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

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

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

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

EXTENT OF PLAY 156

Unclassified Radiological. Emergency Preparedness Program (REP)

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

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

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

PEMA Negotiated Extent of Play:

This sub-element will not be evaluatedduring this exercise.

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

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

Criterion 4.b.l: The field teams demonstrate the capability to make appropriate-measurements and to collect appropriate samples (e.g., food crops, milk,'water, vegetation, and soil) to support adequate assessments and protective action decision-making. (NUREG-0654, 1.8; J.11)

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

157

Unclassified Radiological Emergency Preparedness Program (REP)

After-Action Report/Improvement Plan Limerick Generating Station Ingestion pathway samples should be secured from agricultural products and water. Samples in support of relocation and return should be secured from soil, vegetation, and other surfaces in areas that received radioactive ground deposition.

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

compacts, utility, nuclear insurers, etc.), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

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

PEMA NEGOTIATED EXTENT OFPLAY:

This sub-element will not be demonstratedduring this exercise.

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

Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654, C.3; J.11)

EXTENT OF PLAY The laboratory staff should demonstrate the capability to follow appropriate procedures for receiving samples, including logging of information, preventing contamination of the laboratory, preventing buildup of background radiation due to stored samples, preventing cross contamination of samples, preserving samples that may spoil (e.g., milk), and keeping track of sample identity. In addition, the laboratory staff should demonstrate the capability to prepare samples for conducting measurements.

The laboratory should be appropriately equipped to provide analyses of media, as requested, on a timely basis, of sufficient quality and sensitivity to support assessments and decisions as anticipated by the ORO's plans and procedures. The laboratory (laboratories) instrument calibrations should be traceable to standards provided by the National Institute of Standards and Technology. Laboratory methods used to analyze typical radionuclides released in a reactor. incident should be as described in the plans and procedures. New or revised methods may be used to analyze atypical radionuclide releases (e.g.,

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

158 0

'Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station The laboratory staff should be qualified in radioanalytical techniques and contamination control procedures.

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

compacts, utility, nuclear insurers, etc.), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

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

PEMA NEGOTIA TED EXTENT OFPLAY:

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

EVALUATION AREA 5 Emergency Notification and Public Information Sub-element 5.a - Activation of the Prompt Alert and Notification System INTENT This sub-element derives from NUREG-0654, which provides that OROs should have the capability to provide prompt instructions to the public within the plume pathway EPZ. Specific provisions addressed in this sub-element are derived from the Nuclear Regulatory Commission (NRC) regulations (10 CFR Part 50, Appendix E.1V.D.), and FEMA-REP-10, "Guide for the Evaluation of Alert and Notification systems for Nuclear Power Plants."

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

EXTENT OF PLAY Responsible Offsite Response Organizations (ORO) should demonstrate the capability to sequentially provide an alert signal followed by an initial instructional message to populated areas (permanent resident and transient) throughout the I0-mile plume pathway EPZ. Following the decision to activate the alert and notification system, in accordance with the ORO's plan and/or procedures, completion of system activation should be accomplished in a timely manner (will not 159

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station be subject to specific -time requirements) for primary alerting/notification. The initial message should include the elements required by current FEMA REP guidance.

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

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

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

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

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

PEMA NegotiatedExtent of Play:

The Commonwealth of Pennsylvaniahas implemented a Statewide EAS Control system in cooperation with the PennsylvaniaAssociation of Broadcastersper the State Emergency Communications Committee andPennsylvaniaEmergency Alert System State EAS Plan (April 1, 2004). The State EOC (PEMA) is the initiatingpointfor the activation of the EAS. Risk Counties have the control equipmentfor activation of sirens. Coordinationwill occur between the State EOC and the affected counties with respect to the Alert and Notification System (ANS) process. Sirens will be coordinatedand the sounding simulated at the appropriatetime with the simulatedactivation of EAS takingplace approximately 3 minutesfollowing the simulated 160 0

Unclassified Radiological Emergency PreparednessProgram (REP)

After Action Report/Improvement Plan Limerick Generating Station activation of the sirens. Regular Broadcastingwill not be interruptedon the EAS Stations.

Broadcast of the message(s) or test message(s). is NOT requiredand NOT requested. Counties may elect to simulate county specific supplemental messages to their electronic local media.

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

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

Each evaluatedmunicipalityper risk county will demonstrate, by interview, route alertingof the hearing impairedresidents within theirjurisdiction. Hearingimpairednotification teams will not be deployed.

Criterion 5.a.2: [RESERVED]

Criterion 5.a.3: Activities associated with FEMA approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation.

• Backup alert and notification of the public'is completed within 45 minutes following the detection. by the ORO of a failure of the primary alert and notification system.

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

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

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

161

Unclassified Radiological Emergency Preparedness Program (REP)

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

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

PEMA Negotiated Extent of Play:

Back-up alert notification of the public due to,a simulatedsirenfailure will be demonstrated. (Refer to Attachment A, Section 1. 4.) County liaisons will give an inject to the county coordinator,upon confirmation that sirens were sounded,that a particularsiren hasfailed in the municipalities scheduled to demonstrate back-up route alerting. Notice of the sirenfailure will then be communicated to the appropriatemunicipalitiessothey can demonstrate their 45-minute pre-identified back-up route -alertrun as per Attachment A, Section 'LA. 4. Pennsylvaniadoes not have any "exception areas.

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

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

EXTENT OF PLAY Subsequent emergency information and instructions should be provided to the public and the media in a timely manner (will not be subject to specific time requirements). For exercise 162 0

Unclassified Radiological Emergency Preparedness Program (REP)

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

The ORO should ensure that emergency information and instructions are consistent with "

protective action decisions made by appropriate officials. The emergency information should contain all necessary and applicable instructions (for example, evacuation instructions,'

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

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

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

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

OROs should demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the situation warrants. The OROs should demonstrate the capability to '

respond appropriately to inquiries from the. news media. .All information presented in media briefings and media releases should be consistent with protective action decisions and other emergency information provided to the public. Copies of pertinent emergency information (e.g.,

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

163

Unclassified Radiological Emergency Preparedness Program (REP)

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

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

PEMA Negotiated Extent of Play: .

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

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

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

Criterion 6.a.l: The reception center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers.

(NUREG-0654, J.10.h; J.12; K.5.a)

EXTENT OF PLAY 164

Unclassified Radiological Emergency Preparedness Program (REP)

Afier Action Report/Improvement Plan Limerick Generating Station Radiological monitoring, decontamination, and registration facilities for evacuees/ emergency workers should be set up and demonstrated as they would be in an actual emergency or as indicated in the extent of play agreement. This would include adequate space for evacuees' vehicles. Expected demonstration should include 1/3 of the monitoring teams/portal monitors required to monitor 20% of the population allocated to the facility within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Before using monitoring instrument(s), the monitor(s) should demonstrate the process of checking the instrument(s) for proper operation.

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

emergency planning zone (EPZ) population planning base within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This monitoring productivity rate per hour is the number of evacuees that can be monitored per hour by the total complement of monitors using an appropriate monitoring procedure. A minimum of six individuals per monitoring station should be monitored, using equipment and procedures specified in the plan and/or procedures, to allow demonstration of monitoring, decontamination, and registration capabilities. The monitoring sequences for the first six. simulated evacuees per monitoring team will be timed by the evaluators in order to determine whether the twelve-hour requirement can be meet. Monitoring of emergency workers. does not have to meet the twelve-hour requirement. However, appropriate monitoring procedures should be demonstrated for a minimum of two emergency workers.

Decontamination of evacuees/emergency workers maybe:simulated and conducted by interview.

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

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

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

165

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station All activities associated with this criterion must be based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless otherwise indicated in the extent of play agreement.;

PEMA NegotiatedExtent of Play:

Radiologicalmonitoringdemonstration sites shouldpossess a rosterof the monitoringpersonnel requiredto process 20% of the population allocatedto the facility within a 12 hourperiod Waterfrom decontaminationactivities may go directly to a storm drain or other sewer or drain system or area normally designatedfor wastewater that has been usedfor bathing or washing of vehicles and or equipment.

Radiologicalmonitoringof the public may be co-located at eitherreception centers or mass care centers depending on the county plan.

At each reception center (stand alone - non-monitoring/decontaminationactivity sites) a' minimum of three volunteer evacuees will be processed, briefed, issued the appropriatestrip map or directions;and instructedto proceed to a.mass care center designatedfor demonstration of monitoring,decontamination,and registration. A. sample of the:appropriatestrip maps or directions will be made availablefor the demonstration. Note. Co-locatedfacilities do not require strip maps or written directions.

Mass care centers and mass care monitoring/decontaminationcenters will be demonstrated per Attachment A during the out-of-sequence window. The counties will provide space at designatedmass care centersfor operation of monitoring/decontaminationcenters. Schematics of these monitoring/decontaminationcenters will be available to show the organizationand layout within thefacility and space managementfor monitoring and decontamination.

Procedureswill be demonstratedto show the separation of contaminatedand non-contaminated (clean) individuals to minimize cross contamination.

At the evacuee monitorinje/decontaminationcenters (if using hand-held meters). a minimum of six (6) volunteer evacuees will be monitored(or one volunteer evacuee may be monitoredsix times). Centers using portalmonitors will not be requiredto demonstratethe timing aspect of processing six individuals- three (3) will suffice.

Suitable radiologicalmonitoring instruments will be issued to and demonstratedby the initial monitoring team(s). A monitoringteam consists of one monitor and one recorderequipped with one survey instrument. Those individualsfound to be free of "contamination", based upon scenario injects, will be directed to the mass care registrationpointforfurtherprocessing.

Note: Actual radiologicalsources will not be attached to or hidden upon the volunteer evacuees.

166 60

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station One of the simulated evacuees, based upon controllerinjects, will not be able to be decontaminated. Discussions concerningthe processingof contaminatedpersonnel will include capabilitiesand written proceduresfor showeringfemales.-separatefrommales. Showering will be simulated, water will not be used. Note: Ifportalmonitors are used, the.PortalMonitor*

Extent of Play described below shall be used.

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

PortalMonitor Use: Risk and Support counties may, during this exercise, utilize portal monitors to monitor simulated evacuees and/ or emergency workers. The monitoring /

decontaminationteam requirements will be based on the portalmonitor capabilitiesas applicablebased on the procedure/guidelines, and the recommendations of the manufacturer.

Note: PEMA guidance shall apply.... .

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

Category "C "Dosimetry applies. Simulatedpersonalrecorddosimeters (PRDs) will be worn.

Radiation readings/ contamination datafor the evacuees and vehicle will be provided by the controlleras appropriate.basedupon information containedin the scenariopackage. Set-up of thefacility will be performed the same asfor an actual emergency.with all route markings and contaminationcontrol measures in place including step-offfpad,(if used). Long runs ofplastic covered with paper will not be demonstrated,but the materialsmay be available and explained (as appropriate). Positioningof afire apparatuson-site mayý be simulatedif otherwise required.

Note: Re-demonstrations may be performed as appropriateand time permitting.

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

Criterion 6.b.l: The facility/ORO has adequate procedures and resources for the accomplishment of monitoring and decontamination of emergency worker equipment, including vehicles. (NUREG-0654, K.5.b) 167

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station EXTENT OF PLAY The monitoring staff should demonstrate the capability to monitor equipment, including vehicles, for contamination in accordance with the Offsite Response Organizations (ORO) plans and procedures. Specific attention should .be given to equipment, including vehicles, that was in contact with individuals found to be contaminated. The monitoring staff should demonstrate the capability to make decisions on the need for decontamination of equipment, including vehicles, based on guidance levels and procedures stated in the plan and/or procedures.

The area to be used for monitoring and decontamination should be set up as it would be in an actual emergency, with all route markings, instrumentation, record keeping and contamination control measures in place. Monitoring procedures should be demonstrated for a minimum of one vehicle. It is generally notnecessary to monitor theentire surface of vehicles. However, the capability to monitor areas such as radiator grills, bumpers, wheel wells, tires, and door handles should be demonstrated. Interior surfaces of vehicles that were in contact with individuals found to be contaminated should also be checked.

Decontamination capabilities, and provisions for vehicles and equipment -thatcannot be decontaminated, may be simulated and conducted by interview..

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

PEMA Negotiated Extent of Play:

Emergency worker stationpersonnel will consist of a minimum of one monitor and one recorder and sufficient personnel to demonstrate monitoringofat least one vehicle. Schematics of these monitoring/decontaminationstations will be available to show orgaaizationand space management within thefacility. The evaluatorwill request that decontaminationprocedures be explainedafter the vehicle which has simulatedcontamination has been monitored. One radiologicalsurvey meter will be issued to each monitoring/decontaminationteam. One vehicle and/orpiece of equipment will not be able to be decontaminated. Simulated radiation contaminationdata will be included in the scenariopackage, and injected by a controller. Set-up of thefacility will be performed as closely as possible to thatfor an actual emergency with all route markings in place including clearly defined exit areas,per contaminationcontrol proceduresand/or step-offpads (if used); with the exception of long runs ofplastic covered with paper which will not be demonstrated,but the materialsmay be availableand explained (as appropriate.).

168

Unclassified Radiological Emergency PreparednessProgram (REP)

Afier Action Report/Improvement Plan Limerick Generating Station Decontaminationcapabilities,andprovisionsfor vehicles and equipment that can not be decontaminated,will be simulatedand conducted by interview.."

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

Sub-element 6.c- Temporary Care of Evacuees INTENT This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) demonstrate the capability to establish relocation centers in: host areas. The American Red Cross (ARC) normally provides congregate care in support of OROs under existing letters of agreement.

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

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

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

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

169

0 Unclassified Radiological Emergency Preparedness Program (REP)

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

PEMA NegotiatedExtent of Play:

Counties demonstratingthe operationof mass care centers during the out-of-sequence window (Berks County) will providefloorplans of the mass care centers to show organizationwithin the facility and space management during a realemergency. Mass care center locations are listed in the demonstration tables "Demonstrationof Mass Care Centers (AttachmentA, Section B. 3) ".

Personnel,at a minimum, will consist of one managerand one assistantfor each mass care center opened during the out-of-sequence window. The responsibleAmerican Red Cross chapter will show the source and quantities, by jobfunctional description,to be providedto mass care centers to support the 24-hour operation. The responsibleRed Cross Chapter(s)will be visited, or telephonically contacted during business hours on November:18, 2009, by an exercise evaluator,or interviewed at the mass care center(as appropriate)during the out-of-sequence evaluation to provide information regardingthe 24-hour operation. Schematics of these mass care centers will be available,during the demonstrationwindow; to, show organizationwithin the facility andspace allocationfor the registrationandsheltering the evacuatingpublic. Necessary signs, directional arrowsandforms will be available and used to demonstrate registration,at a minimum, of three evacuees requiringemergency housing. Evacuees will be shown the location where they would be housed in an actualsituation. Bedding, cots,food, etc. normally associatedwith mass care will not be moved to the site, but the sources of those items should be explainedto FEMA evaluators. This out-of-sequence demonstration window will be from 7:00 PM- 9.30 PMon November 18, 2009.

Thosefacilities identifiedfor the FEMA walk-down evaluations will be supportedby a participatingrepresentativefrom the appropriateRed Cross Chapter(s).An interview process will be conducted to determinefacility compliance of the above stated requirements.

American Red Cross risk and support county chapters:

Berks County Chapter 701 Centre Avenue Reading PA 19601-2507 Adrian Grieve (610) 375-4383 Greater Lehigh Valley Chapter 2200 Avenue A Bethlehem PA 18017-2181 Nina Johnson (610) 865-4400 x227 170 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station (Montgomery, Chester & Bucks Counties)

Southeast Pennsylvania Chapter 23 rd & Chestnut Streets Philadelphia PA 19103 Clifton Salas (215) 299-4889 Lower Bucks County Chapter 1909 New Rodgers Road Levittown PA 19056 Steve Huizar (215) 946-4870 x 105 Sub-element 6.d - Transportation and Treatment of Contaminated Injured Individuals This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO's) should have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

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

EXTENT OF PLAY Monitoring, decontamination, and contamination control efforts will not delay urgent medical care for the victim.

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

Monitoring of the victim may be performed prior to transport, done enroute, or deferred to the medical facility. Prior to using a monitoring instrument(s), the monitor(s) should demonstrate the process of checking the instrument(s) for proper operation. All monitoring activities should be completed, as they would be in an actual emergency. Appropriate contamination control 171

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station measures should be demonstrated prior to:and during transport and at the receiving medical facility.

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

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

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

Sub-element 6.d - Transportation and Treatment of Contaminated Injured Individuals This sub-element will be evaluated at Lehigh Yalley Hospital, Lehigh County on June 10, 2009.

172

Unclassified Radiological.EEmergency-Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station ATTACHMENTA Limerick Generating Station Extent of Play Demonstration Tables.

I. Plume Phase Exercise A. Activities - November 17, 2009.

1, Risk Public.School Districts with schools located within the EPZ and.

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

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

• Asterisks'items indicate buildings not in EPZ students may live in the EPZ 0 "Bold" indicated those facilities that are scheduled for federal evaluation.

COUNTY SCHOOL DISTRICT SCHOOLS (approx. 1 /3rd evaluated) Evaluated Berks Boyertown Area (10) 1. Boyertown Elementary 2009 (5)

2. Boyertown Senior HS 2009

3. Colebrookdale Elementary 2007

4. Earl Elementary

• 2005

5. Gilbertsville Elementary 2007

6. Boyertown JHS East 2007

7. Boyertown JHS West 2009

8. New Hanover/UpperFrederick 2009 Elementary 2009

9. Pine Forge Elementary 2007

10. Washington Elementary

• 2009 Daniel Boone Area (6) 1. DanielBoone HS

• 2009 (3)

2. Daniel Boone MS

• 2007

3. Amity Intermediate Center 2007

4. Monocacy Elementary Center 2009

5. Birdsboro Elementary

• 2005 173

0 Urclassifiea Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Chester Downingtown Area (7) .1. Pickering Valley Elementary 2005/07

2. Lionville Elementary

• 2007

3. Shamona Creek Elementary

• 2009

4. Uwchlan Hills Elementary

• 2009 (5)

5. Lionville MS

• 2009

6. Downingtown HS East

• 2009

7. Downingtown HS West

• 2009 Great Valley (4) 1'. Charlestown Elementary 2005/07

2. KD Markley Elementary

• 2009

3. Great Valley MS

• 2009 (3)

4. Great Valley HS

• 2009 Owen J. Roberts (7)', 1. Owen J Roberts HS 2009 (3) 0

2. Owen J Roberts MS 2007

3. East Coventry Elementary 2009

4. East Vincent Elementary 2009 5:.N*orth.Coyentry Elementary 2007

6. French Creek Elementary 2005

7. West Vincent Elementary (new)

Phoenixville Area (7) .L PhoenixvilleSenior HS 2009 (2)

2. Phoenixville MS 2007

3. East Pikeland Elementary 2005

.4. Samuel K Barkley Elementary 2007

.5- French Creek Learning Center 2005 6; Schuylkill Elementary 2007

7. Kindergarten Center 2009 Montgomery Methacto'nArea (7) 1. Arcola Intermediate .2009 (3)

2. Arrowhead Elementary 2007

3. Audubon Elementary 2007

4. Eagleville Elementary

• 2009

5. Methacton Senior HS

• 2009

6. Woodland Elementary . 2005

7. Worcester Elementary Perkiomen Valley (7) 1. Perkiomen Valley Elementary (3) 0 South 2009

2. Evergreen Elementary 2007

3. Perkiomen Valley HS 2009

4. Perkiomen Valley MS - East 2005

5. Perkiomen Valley MS - West 2007

6. Skippack Elementary 2007

7. Schwenksville Elementary 2009 174

I'.

• '*'1¸

-Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan . Limerick Generating Station Pottsgrove (5) 1. Lower Pottsgrove Elementary 2009 (2)

2. Pottsgrove HS 2005

3. Pottsgrove MS 2007

4. Ringing Rocks Elementary 2W

5. West Pottsgrove Elementary 2007

_ *2009 Pottstown Area (7)., -1. EB Barth Elementary 2007. (4)

2. Edgewood Elementary 2009

.3. FranklinElementary 2009

4. Lincoln Elementary 2009

5. Pottstown HS 2005

64. Pottstown MS.. 2009

.7. Rupert Elementary 2007 Souderton Area (3).-, 4,1 Indian Valley MS

• 2009 (1)

, .2.Salford Hills Elementary 2005

3. Souderton Area Senior HS

• 2007 Spring-Ford Area (10),' 1. Brooke Elementary 2007 (6)

2. Evans Elementary. 2009 S..,..13., Limerick Elementary. 2009

. 4. Oaks Elementary 2007 5.- Royersford Elementary 2009

6. Spring-City Elementary 2007

7. Ufper ProvidenceElementary 2009 8&5', 6"', & 7"hGrade Center 2009

, 9. 8 th Grade Center (old MS) 2005

_ _,_ _ _ 0. Spring-FordArea HS 2009 Upper Perkiomen (4) 1. Hereford Elementary

• 2007 (2)

2. MarlboroughElementary 2009

3. Upper Perkiomen HS

• 2009

-___4. Upper Perkiomen MS

• 2005 Western Center Technical Western Center Technical Studies 2005 Studies (1)

2. County Emergency Operations Center (EOCs)

Time: Per Exercise Scenario DEMONSTRATION FOR EOC MOBILIZATION FOR COUNTIES COUNTY DATE Time Berks November 17, 2009 Exercise Scenario Bucks November 17, 2009 Exercise Scenario Chester November 17, 2009 Exercise Scenario Montgomery November 17, 2009 Exercise Scenario 175

0 Uriclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Lehigh November t17, 2009 Exercise Scenario

3. Municipal Emergency Operations Center (EOCs)

Time: Per Exercise Scenario-DEMONSTRATION FOR EOC MOBILIZATION FOR MUNICIPALITIES RISK COUNTY MUNICIPALITY DATE Berks (7/3) Amity Township November 17, 2009

• Boyertown Borough/ Colebrookdale November 17, 2009 Township 40 Douglass Township November 17, 2009 Earl Township November 17, 2009 Union Township (new EOC) November 17, 2009 Washington Township (new EOC) November 17, 2009 Chester (15/6) Charlestown Township November 17, 2009 East Coventry Township November 17, 2009 East Nantmeal Townsh'p November 17, 2009 East Pikeland Township November 17, 2009 East Vincent Township November. 17, 2009 North Coventry Township November 17, 2009 Phoenixville Borough November 17, 2009 Schuylkill Township November 17, 2009 South Coventry Township November 17, 2009 Spring City Borough November 17, 2009 Upper Uwchlan Township November 17, 2009 Uwchlan Township November 17, 2009 Warwick Township November 17, 2009 West Pikeland Township November 17, 2009 West Vincent Township November 17, 2009 Montgomery (20/ 5) Collegeville Borough November 17, 2009 Douglass Township November 17, 2009

• Green Lane Borough/ Marborough November 17, 2009 Township Limerick Township November 17, 2009 Lower Frederick Township November 17, 2009 Lower Pottsgrove Township November 17, 2009 Lower Providence Township November 17, 2009 Lower Salford Township November 17, 2009 New Hanover Township November 17, 2009 Perkiomen Township November 17, 2009 Pottstown Borough November 17, 2009 176 0

'Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Royersford Borough November 17, 2009 Schwenksville Borough November 17, 2009 Skippack Township November 17, 2009 Trappe Borough November 17, 2009 Upper FrederickTownship' November 17, 2009 Upper PottsgroveTownship November 17, 2009 Upper Providence Township November 17, 2009 Upper Salford Township November 17, 2009 West Pottsgrove Township November 17, 2009

• Joint EOC

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

Back-up Route Alerting COUNTY MUNICIPALITY/SIREN/ROUTE DATE Berks Union Twp / #38 / 36-A November 17, 2009 Chester Schuylkill Twp / #95 / 68-D November 17, 2009.

Montgomery Upper Pottsgrove'Twp / #30 / 79-D November 17, 2009

5. Traffic and Access Control Points

a. The Pennsylvania State Police will brief at the PSP Skippack Barracks, 2047C Bridge Road, Schwenksville, Montgomery County. Members attending the briefing will NOT actually deploy to the TCP/ACPs.

b. The PSP briefing will be performed out of sequence in a demonstration window of 10:00 a.m. to 12:00 a.m. on November 18, 2009.

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

d. Municipal and county staffs will be prepared to brief the FEMA evaluator on actions to be taken should there be an impediment to evacuation on a designated route. This will be demonstrated between 7:00 p.m. - 9:30 p.m. on November 17, 2009.

177

0

.Ur~classified RadiologicalEmergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station These municipal/regional police forces are (by county):

Berks , Chester Montgomery Amity Township East Coventry Township Marborough Township Boyertown Borough East Vincent Township Collegeville Borough Colebrookdale Township North Coventry Douglass Township Township Douglass Township Phoenixville Borough Green Lane Borough Schuylkill Township West Pottsgrove Township Spring City Borough Limerick Township Upper Uwchlan Upper Pottsgrove Township Township West Pikeland Lower Providence Township Township West VincentTownship Lower Salford Township Uwchlan Township New Hanover Township East Pikeland Township Pottstown Borough Royersford Borough Schwenksville Borough

_Upper Providence Township B. Activities - November 18, 2009

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

Demonstration of ReceDtion Centers COUNTY DATE TIME Berks November 18, 2009 7:00 p.m. - 9:30 p.m.

• Bucks Exempted (6-year cycle) N/A

• Chester November 18, 2009 7:00 p.m. - 9:30 p.m.

• Montgomery Exempted (6-year cycle) N/A 0

• Lehigh Exempted (6-year cycle) N/A Reception Centers Locations COUNTY LOCATION Quantity Berks (4) Morgantown Crossings (new) 2 Robeson Township Building

• Bucks (2) Exempted (6-year cycle) na

• Chester (3) Alt. Demo Location for Downingtown High School 1

@ Chester EMA

• Montgomery (2) Exempted (6-year cycle) na 178 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station

• Lehigh (2) Exempted (6-year. cycle). na

2. Mass Care Centers: OnlyBerks County (*)conducts monitoring/decontamination center activities at their mass care centers.

DEMONSTRATION of Mass Care Centers /Host'School/

COUNTY DATE - TIME

• Berks (7/4) November 18,ý 2009 7:00 p.m. - 9:30 p.m.

Bucks (32) Week of October 5th . Walk-Down Schedule Chester (12). Week of October 5th "Walk-Down Schedule Montgomery (8) EXempted (6-yeai cycle) N/A Lehigh (15) Week of.October-5th' Walk-Down Schedule Mass Care Center Locations COUNTY . LOCATION Quantity

• Berks (7) Schuylkill. Valley School Complex 4 Governor Mifflin Sehior HS Wilson Senior HS

______Muhlenberg Senior HS Lehigh (15) 1. DeSales.University 7

2. South Mountain MS

3. Salisbury MS Tuesday 4. Eyer Junior HS October 6th 5. Springhouse HS

6. Orefield MS

7. Troxell Junior HS Bucks (32) 1. Palisades MS 11

2. Pennridge Upper HS

3. Pennridge Lower HS

4. Pennridge South Junior HS

5. Pennridge Central Junior HS Wednesday 6. Central Bucks West HS October 7t 7. Delaware Valley College

8. Unami Junior HS Bucks (cont.) 1. Central Bucks East Complex

2. New Hope-Solebury Jr/Sr HS Thursday 3. Bucks County Community College October 8 th

• • Valley Forge Intermediate School (EWMD)

Chester (12) ** Downingtown HS West (Public MD Center)

4. Gordon MS

5. Avon GroveHS 3

6. Fred Engle MS 179

0 Unclassiied Radiological.Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Montgomery (8) Exempted (6-year cycle)

All Evaluations completed 2005 & 2007 N/A

• • indicates two Mon/Decon location site' visits in support of alternate demonstration location @ Chester Co-EMA.

3. Emergency worker monitoring/decontamination stations for each risk county.

Emergency Worker Monitoring / Decontamination Station COUNTY LOCATION DATE Berks (2) Exempted (6-year cycle) N/A Chester (3) Alt. Demo Location for Valley Forge. Intermediate November 18, 2009 School @ Chester EMA 0 Montgomery (3) Upper Perkiomen High School November 18, 2009 0

180 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station TABLE, 1 FEDERAL EVALUATION PROCESS MATRIX Evaluation Area Consolidate Frequency Out-of- Credit Staff Sequence- Assistance of Exercise Visit Scenario

1. Emergency Operations 1, 2, 3, 4, 5, Management 14, 17, 30 Mobilization Eveiy NO YES NO

.... .. ...... _. Exercise Facilities Once if NO YES YES new Direction and Control Every NO NO NO Exercise Communications Equipment Once if new' YES YES YES Equipment and Supplies to Every YES YES YES, Support Operations Exercise

2. Protective Action 5, 7, 9, 14, 15, Decision-making 16, 17, 26, 28 Emergency Worker Exposure Every YES YES YES Control Exercise Radiological Assessment & Every NO NO NO Protective Action Exercise Recommendations & Decisions for the Plume Phase of the Emergency Protective Action Decisions for Every NO NO NO the Protection of Exercise Special Populations Radiological Assessment & Once in 6 NO NO NO Decision-making for the yrs.

Ingestion Exposure Pathway2 Radiological Assessment & Once in 6 NO NO NO Decision-making Concerning 2 yrs.

Relocation, Re-entry, and Return

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

Implementation of Protective Once in 6 YES YES YES 181

0 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Limerick Generating Station Evaluation Area Consolidate Frequency Out-of- Credit Staff Sequence Assistance of Exercise Visit Scenario Actions for Special Populations yrs.3 Implementation of Traffic and 1 per YES YES YES Access Control 4 Organizatio n per exercise Implementation of Ingestion Once in 6 NO NO NO Pathway Decisions S.

Implementation of Relocation, Once in 6 NO NO NO Re-entry, and Return decisions yrs.

4. Field Measurement and 6, 8, 24, 25 Analysis Plume Phase Field Measurements Every Full YES YES NO

& Analysis Participatio n Exercise Post Plume Phase Field Once in 6 YES YES NO Measurements and Sampling yrs.

Laboratory Operations Once in 6 YES YES NO yrs.

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

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

6. Support 18, 19, 20, Operations/Facilities 21, 22 Monitoring & Decontamination Once in 6 YES NO NO of Evacuees3 and Emergency yrs.

Workers

& Registration of Evacuees Monitoring & Decontamination Once in 6 YES NO NO of Emergency 3 Worker yrs.

Equipment Temporary Care of Evacuees 6 Once in 6 YES YES YES 182 0

- Unclassified Radiological'Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Evaluation Area Consolidate. Frequency Out-of- Credit Staff Sequence Assistance of Exercise Visit Scenario yrs.

Transportation and Treatment of Every 2 YES YES NO Contaminated Injured Individuals years 183

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Will be evaluated if new orchanged substantially.

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

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

4 Physical deployment of resources is not necessary.

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

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

184 0

Uncla3sified Radiological Emergency PreparednessProgram (REP)

After Action Report/Improvement Plan Limerick-Generating Station LIMERICK EXERCISE 2007 Listing of Prior Issues No. ISSUE NUMBER FACILITY EVALUATED. CRITERIA P-01 35-07-3.a. l-P-01 Commonwealth of Pennsylvania 3.a. 1 P-02 35-07-6.a.l-P-02 Berks Co - M/D Ctr, Antietam Jr/Sr HS 6.a. 1 P-03 35-07-6.a.l-P-03 Berks Co - M/D Ctr, Antietam Jr/Sr HS 6.a. I P-04 35-07-6.a. l-P-04 Berks Co - M/D Ctr,!Kutztown Area Sr HS 6.a. I P-05 35-07-6.a. 1-P-05 Berks Co - M/D Ctr, Kutztown Area Sr HS 6.a. 1 P-06 35-07-i.e. l-P-06 Montgomery.Co-- Douglass *Township EOC i.e. 1 P-07 35-07-i.e.l-P-07 Montgomery Co - Royersford EOC L.e. I P-08 35-07-3.a. l-P-08 Montgomery Co - Royersford Route Alerting 3.a. 1 P-09 35-07-6.a. 1-P-09 Lehigh Co - Reception Ctr, Southern Lehigh HS 6.a. 1 P-10 35-07-3.c.2-P-10 , Berks Co - Daniel Boone Area School District 3.c.2 P-i1 35-07-3.c.2-P-1 1 Berks Co -Daniel Boone Area School District, .3.c.2 Amity Intermediate Center.....

P-12 35-07-3.c.2-P-12 Berks Co -Daniel Boone Area School District, 3.c.2 Daniel Boone MS " I . .

P-13 35-07-3.c.2-P-13 Chester Co - Owen J. Roberts SD, North Coventry 3.c.2 Elementary School P-14 35-07-3.c.2-P-14 Montgomery Co - Pottsgrove SD, Pottsgrove MS 3.c.2 P-15 35-07-3.c.2-P-15 Montgomery Co - Pottsgrove SD 3.c.2 P-16 35-07-3.c.2-P-16 Montgomery Co - Pottsgrove SD, Rupert elementary 3.c.2 School P-17 35-07-3.c.2-P-17 Montgomery Co - Pottsgrove SD, Rupert elementary 3.c.2 School I-1 LIMX88-06R Commonwealth of Pennsylvania (Ingestion) 4.b. I 1-2 LIMX88-07R Commonwealth of Pennsylvania (Ingestion) 4.b. 1 1-3 L1MX88-08R Commonwealth of Pennsylvania (Ingestion) 4.b. 1 185

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station APPENDIX 5:

Planning Issues This appendix contains the planning issues, assessed during the August 7, 2007, exercise for the Limerick Generating Station (LGS) and those outstanding from earlier exercises. Planning issues are items identified in an exercise or drill that do not involve participant performance, but rather involve inadequacies in the plan or procedures. Planning issues are required to be corrected through the revision and update of the appropriate State and local radiological emergency response plans (RERPs) and/or procedures in accordance with the following schedule:

• Within 120 days of the date of the exercise/drill when the planning issue is directly related to protection of the public health and safety.

• During the annual plan review and update (reported in the Annual Letter of Certification) when the Planning Issue does not directly affect .the public health and safety. However, when the date for the annual plan review and update is imminent and the responsible organization does not have sufficient time to make the necessary revisions in the plans and/or procedures, the revised portion of the plans and/or procedures should be submitted in the subsequent annual plan review and. update and .reported in the Annual Letter of Certification.

Any requirement for additional training of responders:to' radiological. emergencies necessitated by the revision and update of the plans and/or procedures must be completed within the timeframes described above in order for the planning issue to be considered resolved.

Commonwealth of Pennsylvania Issue Number: 35-07-3.a.1-P-01 Condition: Discrepancies exist between the dosimetry information on the emergency worker radiological briefing videotape and the Risk Township Radiological Emergency Response Plans.

Possible Cause: The emergency worker radiological briefing videotape states that 0-200 R Direct Reading Dosimeters (DRD) are no longer used. Workers are advised to disregard the 0-200 R DRD section of the Dosimetry-KI Report Form.

The Township Radiological Emergency Response Plans include the following information, "A supply of 0-200 Roentgen DRDs has been established at the county and each risk municipality. These would be issued in the extremely unlikely event of a life-saving mission requirement in a known, high radiation area."

186 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Limerick Generating Station The videotape also includes a briefing on emergency worker exposure limits. The tape covers the requirement-to obtain approval from the County Radiological Officer prior to exceeding 5 Rem. The Dosimetry-KI Report Form that was provided to emergency workers in a township states,:'Do not exceed 25 R cumulative total", but does not provide instructions for the 5 R limit.

References:

• Emergency Worker Radiologicalbriefing tape (provided .by the Pennsylvania Emergency Management Agency);

• Colebrookdale Township Radiological Emergency Response Plan, section G.6, Municipal Emergency Workers;

• Dosimetry-KI Report Form, PEMA BOP-REP-3 (4/97).

Effect: Emergency Workers maynot be aware that they need a 0-200 R dosimeter to monitor their exposure when -responding to life-saving activities in high exposure. rate, areas. .

Recommendation: Revise the radiological briefing videotape and Dosimetry-KI Report Form to reflect current information.

Schedule of CorrectiVe Actions:. The Commonwealth Emergency Operations Plan and the Commonwealth Nuclear Power Plant Incident Annex (Annex E) are currently undergoing revision including aspects related to dosimetry, forms, exposure limits, etc. The commonwealth and contributing stakeholders (REP counties and utilities) will work to address the apparent discrepancies. The videotape was not produced by the commonwealth. Future use and proposed modifications to the videotape and referenced materials are currently under review. In the interim, clarification statements have been provided to supplement the emergency worker radiological briefing (radiological briefing). Modifications to the radiological briefing will be available for inspection during the next annual plan review.

Berks County Monitoring/Decontamination Center (Antietam Junior & Senior High School)

Issue Number: 35-07-6.a.l-P-02 Condition: The Berks County Radiological Emergency Response Plan, SOP #13 for Antietam Senior High School Mass Care Center (MCC) for the mass care monitoring and decontamination center was not sufficient to enable effective contamination control.

187

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Possible Cause: Schematics did not provide demarcation between clean and contaminated areas. Specifically, this included hallways for male and female transit to locker rooms for decontamination, and within the locker rooms. The locker room schematics did not include specific areas for step-off pads, monitoring locations, and radioactive waste receptacles. Additionally, radioactive material signs, directional signs, and informational signs for evacuees, as well as stanchions and rope to delineate walkways were not available.

The Mass Care Decontamination Station Traffic Flow schematic did not indicate a location for initial vehicle monitoring or vehicle decontamination location.

Currently, the Berks County Radiological Emergency Response Plan, Annex E, Appendix 13 specifies personnel and vehicle contamination limits with regard to loose and fixed contamination, including specification of the probe to be used for contamination monitoring. SOP # 13 is not consistent with the Berks County Plan in that personnel and vehicle contamination limits do not specify loose and fixed contamination, and does not specify the probe to be used for contamination monitoring.

The vehicle contamination limit of 1,000 counts per minute (cpm), without reference to loose or fixed, could result in an evacuee becoming contaminated at levels above the 300 cpm individual contamination limit. For example, a vehicle is monitored at 900 cpm and determined to be clean. If this is loose contamination, then an evacuee could then re-enter the vehicle and become contaminated above the individual limit of 300 cpm.

References:

• NUREG-0654, J.10.h; J.12; K.5.a; 0 Berks County Radiological Emergency Response Plan, SOP # 13, Antietam SH MCC;

• FEMA REP-22, Contamination Monitoring Guidance for Portable Instruments Used for Radiological Emergency Response to Nuclear Power Plant Accidents; 0 Berks County Radiological Emergency Response Plan, Annex E, Appendix 13, Attachment B, Tab 1.

Effect: Without adequate schematics, facility setup for mass care monitoring and decontamination could not be consistently established. This could lead to cross-contamination or re-contamination of evacuees.

Recommendation: Develop updated facility schematics within SOP #13 to reflect demarcation between clean and contaminated areas, including hallways for 188

Unclassified Radiological Emergency. Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station male and female transit 'to locker rooms for decontamination, within the locker rooms, and initialvehicle monitoring and decontamination locations.

Change vehicle contamination criteria within SOP # 13 to be consistent with the Berks County Radiological Emergency Response Plan, Annex E, Appendix 13.

Schedule of Corrective Actions: Berks County RERP, SOP # 13 has been revised to provide clarification through the inclusion of enhanced schematics and clarification of vehicle contaminationcriteria. Plans and procedures will be available for inspection during the next annual plan review.

Berks County Monitoring/Decontamination Center (Antietam Junior & Senior High School)

Issue Number: 35-07-6.a.1-P-03 Condition: The Berks County Radiological Emergency Response Plan, SOP #13 for Antietam Senior High School Mass Care Center (MCC) did not include direction or guidance to perform radiological monitoring instrument operational checks... .

Possible Cause: 'Procedures are not included -in plan.

References:

• NUREG-0654, J.10.h; J.12; K.5.a;

• Berks County Radiological Emergency Response Plan, SOP #13, Antietam SH MCC.

Effect: Without this guidance, participants may not have an understanding of how to perform an instrument operability check.

Recommendation: Add a comprehensive instrument operability checklist to SOP

1. 13.

Schedule of Corrective Actions: Appendix 15 "Survey Meter Operation Sheet" has been added to SOP #13. Plans and procedures will be available for inspection during the next annual plan review.

Berks County Monitoring/Decontamination Center (Kutztown Area Senior High School)

Issue Number: 35-07-6.a.1-P-04 189

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Condition: The Berks County Radiological Emergency Response Plan, SOP #9 for Kutztown Senior High School Mass Care Center (MCC) for the mass care monitoring and decontamination center was not sufficient to enable effective contamination control.

Possible Cause: Schematics did not provide demarcation between clean and contaminated areas. Specifically, this included hallways for male and female transit to locker rooms for decontaimination, and within the locker rooms. The locker room schematics did not include specific areas for step-off pads, monitoring locations, and radioactive~waste receptacles. Additionally, radioactive

'material signs, directional signs, and informational signs for evacuees, as well as stanchions and rope to delineate walkways were not available.

The Mass Care Decontamination Station Traffic Flow schematic did not indicate a location for initial vehicle monitoring or vehicle decontamination location.

Currently, the Berks County Radiological Emergency Response Plan, Annex E, Appendix 13 specifies personnel and vehicle contamination limits with regard to

-. loose and fixed contaminations including specification of the probe to be used for contamination monitoring. SOP #9 is not consistent with the Berks County Plan in that personnel and vehicle contamination limits do not specify loose and fixed contamination, and does not specify the probe to be used for contamination monitoring. Neither document is in compliance. with FEMA REP-22, Table 3.

The-vehicle contamination limit of 1,000 cpm, without reference to loose or fixed, could result in an evacuee becoming contaminated at levels above the 300 cpm individual contamination limit. For example, a vehicle is monitored at 900 cpm and determined to be clean. If this is loose contamination,, then an evacuee could then re-enter the vehicle and become contaminated above the individual limit of 300 cpm.

References:

• NUREG-0654, J.10.h; J.12; K.5.a; 0 Berks County Radiological Emergency Response Plan, SOP #9, Kutztown SH MCC;

• FEMA REP-22, Contamination Monitoring Guidance for Portable Instruments Used for Radiological Emergency Response to Nuclear Power Plant Accidents; 0 Berks County Radiological Emergency Response Plan, Annex E, Appendix 13, Attachment B, Tab 1.

190

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Limerick Generating Station Effect: Without adequate schematics, facility setup for mass, care monitoring and decontamination could not :be consistently established.. This could lead to cross-contamination or re-contamination ofevacuees. -

Recommendation: Develop updated facility schematics within SOP #9 to reflect demarcation between clean and contaminated .areas, including. hallways for male and female transit to locker rooms for decontamination, within the. locker rooms, and initial vehicle monitoring and decontamination locations.

Change vehicle contamination criteria within SOP #9 to be consistent with the Berks County Radiological Emergency. Response. Plan, Annex, E, Appendix 13.

Schedule of Corrective Actions: Berks County RERP, SOP #9 has been revised to provide clarification through the~inclusion of enhanced schematics and clarification of vehicle contamination criteria. Plans .and.procedures will be available for inspection during the next annual plan review.

Berks County Monitoring/Decontamination Center (Kutztown Area Senior-High School)

Issue Number: 35-07-6.a.1-P-05 Condition: The Berks County Radiological Emergency Response Plan, SOP #9 for Kutztown Senior High School Mass Care Center (MCC) did not include direction or guidance to perform radiological monitoring instrument operational checks.

Possible Cause: Procedures are not included, in. plan.

References:

NUREG-0654, J.10.h; J.12; K.5.a; Berks County Radiological Emergency Response Plan, SOP #9, Kutztown Senior High School MCC.

Effect: Without this guidance, participants may not have an understanding of how to perform an instrument operability check.

Recommendation: Add a comprehensive instrument operability checklist to SOP

1. 9.

Schedule of Corrective Actions: Appendix 15 "Survey Meter Operation Sheet" has been added to SOP #9. Plans and procedures will be available for inspection during the next annual plan review.

Douglas Township Emergency Operations Center 191

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Issue Number: 35-07-1.e.1-P-06 Condition: The Radiological Equipment Distribution sheet provided with dosimetry at the Douglass Township was incomplete and inaccurate. It was dated July 2007.for distribution, but did not have any information about when the direct-reading dosimeters (DRDs),were last leak tested. Additionally, the sheet does not include the serial numbers of the permanent record dosimeters (PRDs).

The Radiological Equipment Distribution sheet indicated that the box contained 44 Model DCA-622 (0-20 R) DRDs and 18 Model CD V-742 (0-200 R) DRDs.

An inspection of the inventory indicated that included 39 Model DCA-622 (0-20 R) DRDs; 5 Arrow-Tech Model 730, (0-20 R),DRDS 4 Model CD V-730 (0-20 R)

DRDs, and 14 CD V-742 (0-200QR) DRDs. In summary, the box contained four fewer 0-200 R DRDs than indicated on the inventory list and four more 0-20 R DRDs than indicated on the inventory list.

Possible Cause: The individual DRDs do not have stickers indicating when they were last .leak tested, making it difficult to document that they have been leak tested, without additional documentation. The inaccurate inventory list is possible due to the similarities in appearance of the Model CD V-742 (0-200 R) DRD and the Model CD V-730 (0-20R) DRD..,

Reference:

0 Douglass County Radiological Emergency Response Plan (RERP),

Attachment K, Emergency Worker Dosimetry-KI List.

Effect: The potential use of DRDs that haven't been. leak tested could. increase the likelihood that DRDs would give erroneous readings and an over-estimation of someone's actual exposure. This could limit the availability of emergency workers who would be removed from their mission beforetheir exposure limit had been reached.

Recommendation: Inventories should be checked against the Radiological 0 Equipment Distribution sheet by a second person.

Schedule of Corrective Actions: The Douglass Township dosimetry inventory has been checked and adjusted as appropriate to be consistent with the Radiological Equipment Distribution Sheet.

Royersford Borough Emergency Operations Center Issue Number: 35-07-1.e.1-P-07 192

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Condition: The informational chart displayed on the Emergency Operations Center (EOC) wall was out of date. Specifically the Montgomery County rumor control number was incorrect.

Possible Cause: Failure of the Emergenicy Coordinator to update information and cross reference information found. on the Exelon fact sheet for Limerick Generating Station (LGS) and the Royersford Borough Annex E.

References:

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

Effect: Residents calling the RoyersfordEOC for information would be referred to an un-workingnumber,. instead of the correct number of 610-631-9700. This would result in delaysin the public obtaining information, which may or may not be critical.

Recommendation: Update written materials frequently and cross-reference the.

informationwith other information documents related to LGS. Examples would be the Royersford Borough Annex E, Monftgomery County Annex E, and LGS yearly information data" which is circulated to thepublic annually.

Schedule of Corrective Actions:*As:o.f 8/9/07,;all Royersford EOC information charts and materials have been reviewed and updated. Outdated information materials have been discarded and/or replaced as appropriate.

Royersford Borough Route Alerting Issue Number: 35-07-3.a.1-P-08 Condition: Attachment K to the Royersford RERP lists pre-distributed dosimetry, KI, and Area Kits being available at a number of locations in the Borough (Fire Companies, Police Station, Public Works, etc.). No such equipment was available at the Friendship Fire Company Station. According to the Friendship Fire Company Chief, this equipment for all of the listed locations has been consolidated in the Royersford EOC.

Possible Cause: Emergency Plan is not up to date.

Reference:

• NUREG-0654, H. 11.

Effect: There was no observed consequence from the erroneous information in the Montgomery County Emergency Plan, since this particular aspect of the plan did not appear to be consulted during the exercise. Based on interview, exercise 193

0 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station participants knew that all of the dosimetry, KI and Area Kits had been consolidated at the Royersford EOC.

Recommendation: The emergency plan should be updated to correct this discrepancy.

Schedule of Corrective Actions: Attachment K was reviewed and determined to be consistent with the EOC's understanding and intent. The term "pre-distribution" is recognized as equipment and materials that are "pre-distributed" to the local EOC. All participating organizations (municipal based fire companies, EMS units, Police, Public Works) understand they are to.receive their distribution from their local EOC. The information in Attachment K will be further examined and clarified, if deemed appropriate, during the next.annual plan review.

Lehigh County Reception Center (Southern Lehigh High School)

Issue Number: 35-07-6.a.1-P-09 Condition: There were no procedures for the reception center staff to follow.

Possible Cause: No procedures exist or not present at the reception center.

Reference:

NUREG-0654, J. 12.

Effect: Reception center staff did not know the scope of their responsibilities.

They also did not know where to call when they were posed with a question they did not know how to answer. As they did not have procedures, they may be been performing tasks that were to have been done by other personnel in the decontamination/monitoring/mass care/reception center facility.

. i Recommendation: Develop procedures for the reception center.

Schedule of Corrective Actions: Reception Center procedures were presented for inspection and use during the Lehigh County Radiological Officer briefing re-demonstration conducted on 9/25/07.

Berks County Schools - Daniel Boone Area School District Issue Number: 35-07-3.c.2-P-10 Condition: The Daniel Boone Area School District Radiological Emergency Response Plan, in Attachment 1, page 2, states that Amity Intermediate School requires zero buses for evacuation.

194

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Possible Cause: The Daniel Boone Area School District Radiological Emergency Response Plan has not been updated to reflect the estimated school population.

Reference:

NUREG-0654, J.l0.d.

Effect: Sufficient buses may not arrive in a timely fashion to evacuate the school population if the numbers in Table 1 would be used to determine bus counts rather than the school census called in by the school principal to the district Superintendent.

Recommendation: Update the Daniel Boone Area School District Radiological Emergency Response Plan.

Schedule of Corrective Actions: The Daniel Boone Area School District RERP is currently under review and will be updated by January 1, 2008 to reflect the appropriate number of buses to support the Amity Intermediate School population. Plans and procedures will be available for inspection during the next annual plan review.

Berks County Schools - Daniel Boone Area School District, Amity Intermediate Center Issue Number: 35-07-3.c.2-P-11 Condition: The Amity Intermediate Center Plan is not up to date in numerous places. Attachment 1, page 2, indicates the school requires zero buses for evacuation. The principal indicated he would need approximately 15 buses to evacuate the school (estimated b/c he is still enrolling students for the upcoming year). The plan's Transportation Summary is from the 1998/1999 School year and Amity is not on the list at all.

In Tab 12, the maps for evacuation are illegible (text is VERY small and blurry).

There are also no highlighted streets, indicating a route or turn-by-turn directions and there is no date on the map.

The "Notice of Movement" flyer reads that the school has been evacuated to the Daniel Boone Junior/Senior High School with the correct phone number. There is no longer a Daniel Boone Jr/Sr High School - it is only a Daniel Boone Sr. High School. There is also no address nor directions to the facility. The 'Notice of Movement' flyer is placed on the school doors indicating to parents where the students may be picked up.

195

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station In Tabs 1 and 2, the Phone list and the Emergency Contact list, are both from the 2003/2004 school year.

Possible Cause:, The School implementation plans have not been updated on a regular basis.

References:

NUREG-0654, J.10.d, g.

Effect: The effects: of the plan not being updated are numerous and include buses not arrive ina timely fashion to evacuate the students and staff; staff and bus drivers may be unfamiliar with the evacuation route, and without readable maps, arrival at the Host Community could be delayed; parents arriving at Amity School may be unaware that the Daniel Boone Jr/Sr HighSchool was recently renamed the Daniel Boone Sr. High School; They may not know where the Daniel Boone Sr. High School is located and this may cause concern or panic among the parents. Staff may have changed phone numbers~or changed entirely and are not on the list. If the correct:phone numbers are not inthe plan, then they cannot be reached in a timely manner.

Recommendation: Update the school plans. -

Schedule of Corrective Actions: The Daniel Boone Area School District RERP is currently under review and will be updated by January. 1, 2008 to address all of the above enumerated effects as appropriate. Plans and procedures will be available for inspection during the next annual plan review.,

Berks County Schools - Daniel Boone Area School District, Daniel Boone Middle School Issue Number: 35-07-3.c.2-P-12 Condition: The Radiological Emergency Response Plan atDaniel Boone Middle School is from 2003 and does not include the fact that the school is now considered a risk school by theDaniel Boone Area School District.

Possible Cause: Daniel Boone Middle School has moved to a new school building since 2003. The new building is technically located outside the 10-mile EPZ, but is in close proximity to two other schools that are inside the 10-mile EPZ. The school district has opted to consider Daniel Boone Middle School as a risk school to avoid the confusion of having two risk schools located very close to a non-risk school. The Radiological Emergency Response Plan at the middle school has not been updated to reflect the change in status of the new middle school as a risk school from its previous designation as a non-risk school.

196 0

Unclassified Radiological, Emergency Preparedness Program (REP)

After Action Report/Improvement Plan ..Limerick Generating Station

Reference:

NUREG-0654, J. 10.d.

Effect: The school staff may have improperly identified' the protective actions for the students at Daniel Boone Middle School or reported an inaccurate number for students requiring transport had school been in session. The condition did not produce a problem during this drill because no students were present at the school. t' Recommendation: The plan and implementing procedures should be revised to account for the status of Daniel, Boone Middle School as a risk school that would require evacuation.

Schedule of,Corrective Actions: Berks County EMA provided notice and instruction to Daniel Boone School;District to ensure replacement of the outdated 2003 RERF plan with the updated 2007 RERF plan for the Daniel Boone Middle School. The 2007 plan recognizes Daniel. Boone Middle School as a risk school.

The Commonwealth appreciates Berks County EMA's assistance in addressing this issue with Daniel Boone School District.

Additionally, the Daniel Boone Area SchoolDistrict RERP is currently under review and will be updated by January 1, 2008 to ensure all necessary plan changes are addressed. Plans and procedures willbe available for inspection during the next annual plan review.

Chester County Schools - Owen J. Roberts School District, North Coventry Elementary School Issue Number: 35-07-3.c.2-P-13 Condition: The use of KI by adult school staff is not addressed in the school emergency procedures. There was no form for identifying the school staff who, at the last moment, decided to ingest a KI tablet.

Possible Cause: North Coventry Elementary school maintains 672 doses of KI.

The school indicated that this was enough for both students and staff. Information was available for the students that did and did not have prior permission to take KI. However, there was no literature of dosage recommendation or potential side affects for distribution -tothe adult members of the school staff.

References:

0 NUREG-0654, J. 10.e, f.

197

0 Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Effect: Staff members deciding to ingest KI, would do so without understanding the medical risks from ingesting KI and may experience a negative reaction.

Recommendation: Provide information cards to adult staff members. Provide a log sheet or card that each individual must sign stating that they are accepting KI from the school district, and that they have been given information on the risks of ingesting KI.

Schedule of Corrective Actions: Pennsylvania Department of Health KI information was provided to Owen J. Roberts School District via Chester County EMA. The commonwealth appreciates Chester County EMA's assistance in addressing this issue with Owen J. Roberts School .District. Plans and procedures will be-available-for inspection during the next annual plan review.

Montgomery County Schools -- Pottsgrove School District, Pottsgrove Middle School Issue Number: 35-07-3.c.2-P-14 .

Condition: The Pottsgrove Middle:School does not address Potassium Iodide (KI) in the Radiological Emergency Response Plan.

Possible Cause: The Plan has not been updated to address implementation of KI.

References:

. *NUREG-0654, J.l0.c, d, g.

Effect: The Principal described a process in place in the event KI is authorized for use. Staff might not understand the process during an emergency event without a procedure in place.

Recommendation: The Pottsgrove Middle School should address KI use in their Radiological Emergency Response Plan.

Schedule of Corrective Actions: Pennsylvania Department of Health KI information was provided to Pottsgrove School District via Montgomery County EMA. The commonwealth appreciates Montgomery County EMA's assistance in addressing this issue with Pottsgrove School District. Plans and procedures will be available for inspection during the next annual plan review.

Montgomery County Schools - Pottstown School District Issue Number: 35-07-3.c.2-P-15 198 0

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Condition: The school plans used by the Pottstown do notinclude any instructions regarding KI deployment."

Possible Cause: The Plan has not been updated to include instructions on KI deployment.

References:

• NUREG-0654, J.1O.c, d, g.

Effect: Inappropriate implementation of a protective action, Recommendation:,The Pottstown School District should include instructions for KI deployment in its Radiological Emergency Response Plan-.t :

Schedule of Corrective Actions: Pennsylvania Department of Health KI information was provided to Pottstown School District via Montgomery County EMA. The commonwealth appreciates MontgOmery County EMA's assistance in addressing this issue with Pottstown School District. Plans and procedures will be available for.inspectionduring the next annual plan review.

Montgomery County Schools, Pottstown School District - Rupert Elementary School Issue Number: 35-07-3.c.2-P-16 Condition: There are not enough Potassium Iodide (KI) tablets at the nurse's station for the approximately 300 students in the school.

Possible Cause: Only one 200 count bottle of 65mg KI tablets for the children and 42 sealed 130 mg KI tablets (3 blister packs of 14 tablets each) for adults were in the locked cabinet in the nurse's station for the 300 students and 13 teachers and adults normally at the school.

Reference:

• NUREG-0654, J.10.e.

Effect: Some-children would not have received a KI tablet.

Recommendation: Obtain a sufficient supply of 65 mg KI tablets.

Schedule of Corrective Actions: Montgomery County EMA delivered KI. to the Rupert Elementary School on 9/21/07 to ensure a sufficient supply of KI is available for students and staff. The commonwealth appreciates Montgomery County's efforts in facilitating the delivery of KI to the Rupert Elementary School.

199

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Limerick Generating Station Montgomery County Schools, Pottstown School District - Rupert Elementary School Issue Number: 35-07-3.c.2-P-17 Condition: While the Principal is away from the school during normal class time, if an emergency is declared, a "Principal on Call" is available to report to the school and implement the procedures. During the "After School" program, from 3:30 until 5:30 each afternoon, the "Principal on Call" is not available for response. Further, the principal is not required to be at the school during The After School program as this is beyond his normal working hours.

Possible Cause: Rupert Elementary School has not identified any procedure for "After School" programs in its Radiological Emergency Plan.

References:

0 NUREG-0645, J 10, c, d, g.

Effect: There is no one available to implement protective actions during the "After School" program hours.

Recommendation: Designate and train backup personnel in the school for implementation and link the procedures such that off-hour activity information is known if needed.

Schedule of Corrective Actions: Montgomery County EMA is assisting Pottstown School District in a full plan review and update. Plans and procedures will be revised by school district officials, as appropriate, to address coverage and responsibilities of both in-session and out-of-session requirements. The commonwealth appreciates Montgomery County EMA's assistance and guidance in working with the Pottstown School District. Plans and procedures will be available for inspection during the next annual plan review.

200 0

i Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/]mprovement Plan Limerick Generating Station This page is intentionally blank.

201