Text

U.S. Dept of Homeland Security/Final Report for the March 2, 2010, Radiological Emergency Preparedness (REP) Full Participation Plume Exposure Pathway Exercise for the Palisades Nuclear Power Plant/Letter
	ML101830320
Person / Time
Site:	Palisades
Issue date:	07/02/2010
From:	Velasquez A; US Dept of Homeland Security, Federal Emergency Management Agency
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML101830320 (78)
	v • d • e

U.S. Department of Homeland Security Region V 536 South Clark Street, Floor 6 Chicago, IL 60605 K FEMA NRC Headquarters Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 To Whom It May Concern:

Enclosed is one copy of the Final Report for the March 2, 2010 Radiological Emergency Preparedness (REP) Partial Participation Plume Exercise for the Palisades Nuclear Power Plant. Under separate cover, four copies of this report are being sent to the Michigan Department of State Police-Emergency Management & Homeland Security Division for distribution to the Counties of Allegan, Berrien and Van Buren, along with an additional copy for the State. The State of Michigan, the Counties of Allegan, Berrien and Van Buren and the operator, Entergy Corporation, participated in this exercise.

No Deficiencies were identified for any jurisdiction during this exercise.

There were no Areas Requiring Corrective Action (ARCA) identified for the State of Michigan during this exercise.

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

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

There was one ARCA identified during this exercise for Berrien County. The ARCA identified for Berrien County was Number 44-10-6al -A-02 under Criterion 6.a. 1 - 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. This ARCA was successfully redemonstrated during the exercise.

There was one prior ARCA for Berrien County identified during the September 15, 2009, D.C. Cook Nuclear Power Plant exercise. ARCA Number 15-09-3.b. l-A-01 Criterion 3b. I -

Potassium Iodine (KI) and appropriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals (not general public) is maintained. This ARCA was successfully redemonstrated during the exercise.

www.fema.gov

NRC Headquarters Document Control Desk Page 2 There were no ARCA identified for Van Buren County during this exercise.

There were no ARCA identified for Allegan County during this exercise.

There was one Plan Issue identified during the exercise for Allegan County. Plan Issue Number 44-10-6al-P The Allegan County Procedures for Public Reception/Decontamination Centers, dated February 2010, assigns the responsibility for evacuee vehicle exterior decontamination to the fire services within the County. This is found in the SOP for Station #8, Vehicle Decontamination Station, pages 3 1-35. However, it is Allegan County's understanding that the State of Michigan, Department of Environmental Quality, is responsible for this function.

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

Based on the results of the March 2, 2010, exercise, the offsite radiological emergency response plans and preparedness for the State of Michigan and affected local jurisdictions, site-specific to the Palisades Nuclear Power Plant can be implemented and are adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency.

Therefore, the Title 44 CFR, Part 350, approval of the offsite radiological emergency response plans and preparedness for the State of Michigan site-specific to Palisades Nuclear Power Plant, granted on July 6, 1982, remain in effect.

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

Sincerely, fr Andrew Velasquez III Regional Administrator Enclosure (1)

-AJI9 Palisades Nuclear Power Plant After Action Report/

Improvement Plan Exercise Date - March 02, 2010 Radiological Emergency Preparedness (REP) Program 1FEMA Published June 11, 2010

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After Action Report/improvement Plan Palisades Nuclear Power Plant Palisades Nuclear Power Plant After Action Report/Improvement Plan Published June 11, 2010 Contents Executive Summary 6

Section 1: Exercise Overview 12 1.1 Exercise Details 12 1.2 Exercise Planning Team Leadership 12 1.3 Participating Organizations 14 Section 2: Exercise Design Summary 17 2.1 Exercise Purpose and Design 17 2.2 Exercise Objectives, Capabilities and Activities 17 2.3 Scenario Summary 17 Section 3: Analysis of Capabilities 18 3.1 Exercise Evaluation and Results 18 3.2 Summary Results ofxExercise Evaluation 19 3.3 Criteria Eyaluation Summaries 29 3.3.1 Michigan'Jurisdictions 29 3.3.1.1 Initial Notification Point 29 3.3.1.2 State Emergency Operations Center 29 3.3.1.3 Joint Information Center 29 3.3.1.4 Michigan State Rumor Control Center 30 3.3.1.5 Technical Support Group 30 3.3.1.6 Field Team Center Cell 30 3.3.1.7 MDEQ FTC Traffic and Access Contol Dosimetry 31 Briefing - Palisades 3.3.1.8 Michigan State Police Traffic and Access Control 31 Point Demonstration - Palisades 3.3.1.9 State Liaison - Allegan County EOC - Palisades 31 3.3.1.10 State Liaison - Berrien County EOC - D.C. Cook and 31 Palisades 1

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After Action Report/Improvement Plan Palisades Nuclear Power Plant 3.3.1.11 State Liaison-Van Buren County EOC - Palisades 31 3.3.1.12 Michigan Department of Environmental Quality -

32 Emergency Worker Equipment/Vehicle Monitoring/Decontamination - Decatur FD 3.3.1.13 Michigan Department of Environmental Quality -

32 Emergency Worker Equipment/Vehicle Monitoring/Decontamination - North Berrien FD 3.3.1.14 Michigan Department of Environmental Quality -

32 Emergency Worker Monitoring/Decontamination -

Decatur FD 3.3.1.15 Michigan Department of Environmental Quality -

33 Evacuee Monitoring/Decontamination - Otsego High School - Allegan County 3.3.1.16 Michigan Department of Environmental Quality -

33 Evacuee/Vehicle Monitoring/Decontamination.- Paw Paw High School-Van' Buren County 3.3.1.17 Michigan Department of Enivironmental Quality -

33 Evacuee/Vehicle Monitoring/Decontamination -

Coloma High School-Berriefi'County 3.3.1.18 Michigan Department of Environmental Quality -

33 Evacuee Monitoring/econtamination - Paw Paw High School -Vaný Buren County 3.3.1.19 Michigan Department of Environmental Quality 7 34 Emergency Worker Monitoring/Decontamination -

North Berrien Fire Department 3.3.1.20, Mihilgan Department of Environmental Quality -

34 E*Krgency Worker Monitoring/Decontamination -

Graafschap Fire Department 3.3.1.21 EW Monitoring/Decontamination - Decatur Fire 34 Department - Palisades 3.3.2 Risk Jurisdictions 35 3.3.2.1 Van Buren County Initial Notification Point -

35 Palisades 3.3.2.2 Van Buren County EOC - Palisades 35 3.3.2.3 Van Buren County Traffic and Access Control 35 Dosimetry Briefing - Palisades 3.3.2.4 Van Buren County Traffic and Access Control Point 35 Demonstration - Palisades 3.3.2.5 Van Buren County Health Department - Dosimetry -

36 Palisades 3.3.2.6 Van Buren County Public Information Officer in the 36 JIC 2

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After Action Report/Improvement Plan Palisades Nuclear Power Plant 3.3.2.7 Emergency Alert System Radio Station WSJM -

36 Palisades 3.3.2.8 EV-2 Interview - South Haven Public Schools 36 3.3.2.9 Evacuee Vehicle 37 Monitoring/Decontamination/Registration - Paw Paw High School-Palisades 3.3.2.10 Emergency Worker Equipment/Vehicle Monitoring 37

/Decontamination - Decatur Fire Department 3.3.2.11 Evacuee Monitoring/Decontamination/Registration -

37 Paw Piw High School - Palisades 3.3.2.12 Congregate Carer Lawrence High School - Palisades 37 3.3.2.13 Berrien County Initial Notification Point 38 3.3.2.14 Berrien County Emergency Operations Center 38 3.3.2.15 Berrien County Traffic and Access Control Point 39 Dosimetry Briefing 3.3.2.16 Berrien County Traffic andfAccess Control Point 39 Demonstration - Palisades 3.3.2.17 Berrien County Public 'nformation Officer at the JIC 39 3.3.2.18 Congregate Care - Coloma High School - Palisades 40 3.3.2.19 Emergency Worker Equipment/Vehicle Monitoring 40

/Decontamination - North Berrien Fire Department 3.3.2.20 Evacuee Vehicle Monitoring/Decontamination -

40

,C'lofnm High School - Palisades 3.3.2.21 E*vacuee Monitoring/Decontamination/Registration -

40 Coloma High School - Palisades 3.3.2.22 Emergency Worker Monitoring/Decontamination -

41 North Berrien Fire Department 3.3.2.23 EV-2 Interview - Coloma Public Schools 42 3.3.2.24 Allegan County Initial Notification Point - Palisades 42 3.3.2.25 Allegan County Emergency Operations Center -

42 Palisades 3.3.2.26 Allegan County Traffic and Access Control 42 Dosimetry Briefing - Palisades 3.3.2.27 Allegan County Traffic and Access Control Point 43 Demonstration - Palisades 3.3.2.28 Allegan County Public Information Officer at the 43 JIC 3

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After Action Report/Improvement Plan P alisades Nuclear Power Plant 3.3.2.29 EW Monitoring/Decontamination - Graafschap Fire 43 Dept. - Palisades 3.3.2.30 Congregate Care - Otsego High School - Palisades 44 3.3.2.31 Evacuee Monitoring/Decontamination/Registration -

44 Otsego High School - Palisades 3.3.2.32 Evacuee Vehicle Monitoring/Decontamination -

44 Otsego High School - Palisades Section 4: Conclusion 46 Appendix A: Improvement Plan 47 A1ppendix B: Exercise Timeline 49 Appendix C: Exercise Evaluators and Team Leaders 51 Appendix D: Acronyms and Abbreviations 54 Appendix E: Exercise Plan 57 Appendix F: Scenario Details 70 4

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After Action Report/Improvement Plan Palisades Nuclear Power Plant EXECUTIVE

SUMMARY

On March 2, 2010, a Radiological Emergency Preparedness (REP) Partial Participation Plume Exposure Pathway Exercise evaluation was conducted by the U.S. Department of Homeland Security (DHS)/Federal Emergency Management Agency (FEMA) for the 10-mile Emergency Planning Zone (EPZ) around the Palisades Nuclear Power Plant (PNPP). The purpose of the exercise was to assess the level of State and local preparedness in responding to a radiological emergency. This exercise was held in accordance with DHS/FEMA's policies and guidance concerning the exercise of State and local Radiological Emergency Response Plans (RERPs) and procedures.

The most recent exercise at this site was conducted on September 16, 2008. The qualifying emergency preparedness exercise was conducted on December 9, 1980.

DHS/FEMA wishes to acknowledge the efforts of the many individuals who participated in this exercise. In the State of Michigan, the risk counties of Allegan, Berrien, and Van Buren participated along with State Government. " 7 Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility by volunteerinlgaf Iprovide vital emergency services to their communities.

Cooperation and teamworkoi*

the part of all the participants were evident during this exercise.

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

Protective Actions for Schools (EV-2) for the South Haven and Coloma School Districts

Monitoring and Decontamination of Evacuees and emergency workers

" Monitoring and Decontamination of emergency worker's equipment

" Public Registration

" Congregate Care Center Except where noted in this report, the State and local organizations demonstrated knowledge of and adequately implemented their emergency response plans and procedures.

No Deficiencies were identified for the State of Michigan or for Allegan, Berrien, and Van

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After Action Report/Improvement Plan Palisades Nuclear Power Plant Buren Counties during this exercise.

There was no Area Requiring Corrective Action (ARCA) identified for the State of Michigan during this exercise.

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

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

There was one ARCA identified during this exercise for Berrien County. The ARCA identified for Berrien County was Number 44-10-6al-A-02 under Criterion 6.a. 1 - 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. This ARCA was successfully redemonstrated during the exercise.

One prior ARCA for Berrien County ideiitified during the September 15, 2009, D.C. Cook Nuclear Power Plant exercise, Number 15-09-3.b. 1-A-01 Criterion 3.b; 1 - Potassium Iodine (KI) and appropriate instructions are available should a decision to recommend use of KI be made.

Appropriate record keeping of'e t.ic administration of KI for emergency workers and institutionalized individuals (Dot general public) is maintained. This ARCA was successfully redemonstrated during the exercise.

There were no ARCA identified for Van Buren County during this exercise.

There were no ARCA identified forAllegan County during this exercise.

There was one Plan Issue identified during the exercise for Allegan County. Plan Issue Number 44-10-6a I-P The Allegan County Procedures for Public Reception /Decontamination Centers, dated February 2010, assigns the responsibility for evacuee vehicle exterior decontamination to the fire services within the County. This is found in the SOP for Station #8, Vehicle Decontamination Station, pages 3 1-35. However, it is Allegan County's understanding that the State of Michigan, Department of Environmental Quality, is responsible for this function.

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After Action Report/Improvement Plan Palisades Nuclear Power Plant INTRODUCTION - EXERCISE BASIS On December 7, 1979, the President directed FEMA to assume the lead responsibility for all offsite nuclear planning and response. DHS/FEMA's activities are conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350 "Review and Approval of State and Local Radiological Emergency Plans and Preparedness", 351 "Radiological Emergency Planning. and Preparedness" and 352 "Commercial Nuclear Power Plants: Emergency Preparedness Planning."

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.

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

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

Taking the lead in offsite emergency planning and in the review and evaluation of RERPs and procedures developed by Statend local governments;

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

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

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

- U.S. Department of Agriculture;

- U.S. Department of Commerce;

- U.S. Department of Energy; 8

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

- U.S. Department of the Interior;

- U.S. Department of Transportation;

- U.S. Environmental Protection Agefncy;

- U.S. Food and Drug Administration; and

- U.S. Nuclear Regulatory Commission.

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

Formal submission of the RERPs for the Palisades Nuclear Power Plant to FEMA Region V by the State of Michigan and involved local jurisdictions occurred on December 9, 1980. Formal approval of these RERPs was granted by FEMA on July 6, 1982, under 44 CFR 350.

A REP Partial Participation Plume Exposure Pathway Exercise was conducted on March 2, 2010, and evaluated by DHS/FEMA to assess the capabilities of State and local offsite emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radio Iogical emergency involving the Palisades Nuclear Power Plant. The purpose of this exercise reiport is to present the exercise results and findings on the performance of the Offsite Response Organizations (ORO) during a simulated radiological emergency.

1, The findings presented in thlrepjort are based on the evaluations of the Federal evaluation team, with final determinations made by the DHS/FEMA Region V RAC Chairperson, and approved by the DHS/FEMA Headquarters.

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

NUREG-0654/FEMA-REP-1, Rev. 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"

November 1980;

FEMA-REP-14, "Radiological Emergency Preparedness Exercise Manual," September 1991; and 9

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

Section 1 of this report, entitled "Exercise Overview", presents information pertaining to the team that planned and coordinated the exercise. This section also provides listing of all participating jurisdictions and functional entities that were evaluated.

Section 2 of this report, entitled "Exercise Design Summary", contains the purpose and design of the exercise, a description of the plume pathway EPZ and presents basic information and data relevant to the exercise scenario.

Section 3 of this report, entitled "Analysis of Capabilities," presents detailed information on the demonstration of applicable exercise criteria at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format. This section also contains: (1) descriptions of all Deficiencies and ARCAs (if any) assessed duringthis exercise, recommended corrective actions, and the State and local governments' schedule o'fcorrective actions, if applicable, for each identified exercise issue; and (2) descriptionsof uniresolved ARCAs assessed during previous exercises and the status of the OROs' efforts to resolve them.

Section 4 of this report, entitled "Conclusion" presents the DHS/FEMA summary of overall exercise conduct and results s evaluated against the requirements of 44 CFR 350.

EMERGENCY PLANNING ZONE (EPZ) DESCRIPTION The Palisades Nuclear Power Plant is a single unit pressurized water reactor with a net capacity of 805 megawatts. The facility owned and operated by Entergy Nuclear Operations, Incorporated, commenced commercial operation in December 1971. Lake Michigan is the cooling water source for the plant.

The plant is located in northwestern Van Buren County, Michigan, on the shore of Lake Michigan, approximately five miles south-southwest of South Haven. The 10-mile EPZ of the Palisades Nuclear Power Plant encompasses parts of Allegan, Berrien, and Van Buren Counties, with the major portion of the zone falling within Van Buren County. The total plume pathway EPZ permanent population is 33,027 persons.

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After Action Report/Improvement Plan Palisades Nuclear Power Plant The EPZ is comprised of five Protective Action Areas (PAAs), numbered 1 to 5, with PAAs 1, 2, and 3 being located within Van Buren County only; PAA 4 is located within both Allegan and Van Buren Counties; and PAA 5 is located within both Berrien and Van Buren Counties. The permanent population of PAA 1 is 2,001. The permanent population of PAA 2 is 1,939. The permanent population of PAA 3 is 2,360. The permanent population of PAA 4 is 10,283. The permanent population of PAA 5 is 4,308.

Approximately 50 percent of the 10-mile EPZ lies within Lake Michigan. The lake attracts a large number of vacationers during the summer. The area includes various summer resorts, which offer camping facilities, light housekeeping cottages, tourist's attractions, and the Van Buren State Park. The City of South Haven, with a tourism based economy, is located five miles north of the plant. The population varies from summer to winter months.

Agricultural use of the land includes seasonal fresh fruit and vegetable farming and processing.

Peak agricultural use takes place during the spring, summer, and fall months.

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After Action Report/Improvement Plan Palisades Nuclear Power Plant SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Palisades Nuclear Power Plant Type of Exercise Plume Exercise Date March 02, 2010 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership William King Exercise RAC Chairperson DHS/FEMA Radiological Assistance Committee, Chairman 536 South Clark Street Chicago, Illinois, 60605 312-408-5575 William.King@dhs.gov Stephen Tulley Exercise Director DHS/FEMA Supervisory REP Team Leader 536 South Clark Street 12

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After Action Report/Improvement Plan Palisades Nuclear Power Plant Chicago, Illinois, 60605 312-408-4425 Stephen.Tulley@dhs.gov Edward Diaz Palisades Site Specialist/Exercise Coordinator DHS/FEMA Technical Hazards Program Specialist 536 South Clark Street Chicago, Illinois, 60605 312-408-5585 Edward.Diaz@dhs.gov Matt Blythe State Lead Controller Emergency Management & Homeland Security Division Michigan State Police Radiological Emergency Prepaiedness Trainer 4000 Collins Road 4

Lansing, Michigan, 489 10 i

517-333-5028 BlytheM@michigan.i o\\

Thomas Higinbotham State Liasion Emergency Management & Homeland Security Division Michigan State Police REP Local Support Unit Manager 4000 Collins Road Lansing, Michigan, 48910 517-333-5035 HiginboT@michigan.gov Norm Brott Lead Offsite Planner 13

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After Action Report/Improvement Plan Palisades Nuclear Power Plant Entergy Corporation Emergency Preparedness Specialist 27780 Blue Star Memorial Highway Covert, Michigan, 49043 269-764-2124 nbrott@entergy.com 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Palisades Nuclear Power Plant exercise:

State Jurisdictions Michigan Department of Environmental Quality Michigan Department of Health Michigan Department of Transportaption',.",

Michigan Departrment of Environmental Quality Michigan Emergency Management Homeland Security Division Michigan Governor Representitive Michigan State Attorney General's Office Michigan State Police Michigan Sta eiSpreme Court Risk Jurisdictions" Allegan Count7¶mergency Management Agency*

Allegan County Health Department Allegan County Hotline Representitive Allegan County Public Information Officer Allegan County RACES Personnel Allegan County Radiological Defense (RADEF)

Allegan County Sheriffs Department (911 operators)

Allegan County Sheriffs Department American Red Cross American Red Cross, Kalamazoo Chapter Area Agency on Aging Bangor Community Fire Department 14

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After Action Report/Improvement Plan Palisades Nuclear Power Plant Berrien County Chief Executive Berrien County Chief of Staff Berrien County Emergency Management Berrien County Health Department Berrien County Hotline Representitive Berrien County Public Information Officer Berrien County Public Safety Communications Dispatch Center Berrien County Sheriffs Department Berrien County Sheriffs Department Hazardous Materials Unit Black River Amateur Radio Club Coloma School District Communications Community Health Emergency Coordination Center Decatur Fire Department.

Decatur-Hamilton Fire Department Department of Human Services (DHS)

Fennville Fire Department Geographic Information System (GIS)

Graafshap Fire Department North Berrien Fire Department Gun Plain Fire Department Otsego Fire D nftent Paw Paw High School Otsego Public Schools Palisades Nuclear Power Plant Representitive Paw Paw Fire Department Paw Paw Police Department Plainwell Area Emergency Medical Services Plainwell Department of Public Safety RACES of Allegan County Radio Amatuer Civil Emergency Services (RACES)

Salvation Army State Fire Marshall Representitive Van Buren American Red Cross 15

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After Action Report/Improvement Plan Palisades Nuclear Power Plant Van Buren County Hotline Representitive Van Buren Health Department Van Buren Intermediate School District Van Buren Sheriffs Office WSJM Radio Station

iii*i!"

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After Action Report/improvement Plan Palisades Nuclear Power Plant SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise Purpose and Design The DHS/FEMA Region V Office evaluated the PNPP Radiological Emergency Preparedness (REP) Partial Participation Plume Exposure Pathway Exercise conducted on March 2, 2010, to assess the capabilities of local emergency preparedness organizations in implementing their Radiological Emergency Response Plans (RERP) and procedures to protect the public health and safety during a radiological emergency involvingthe Palisades Nuclear Power Plant. The purpose of this report is to present the results and findings on the performance of the Offsite Response Organizations (OROs) during a simulated radiological emergency.

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

2.3 Scenario Summary Appendix F "Scenario Details," cýntalns a summary of the Exercise Scenario, a simulated sequence of events that was ifused as: the basis for invoking emergency response actions by Offsite Response Organizations (OR*Qflin the Palisades Nuclear Power Plant REP Partial Participation Plume Exposure Pathway exercise on March 2, 2010.

This exercise scenario was submitted by the State of Michigan and Entergy Corporation and accepted by DHS/FEMA Region V on. January 29, 2010.

During the exercise, in addition to information and data provided through the PNPP onsite scenario, controllers from the State of Michigan provided "inject messages" containing scenario events and/or relevant data to those persons or locations who would normally receive notification of such events. These inject messages were the method used for invoking additional specific response actions by OROs.

The details of the scenario are included in Appendix F "Scenario Details."

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After Action Report/Improvement Plan Palisades Nuclear Power Plant SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained in this section are the results and findings of the evaluation of all jurisdictions and functional entities that participated in the March 2, 2010, REP Partial Participation Plume Exposure Pathway Exercise conducted to test the offsite emergency response capabilities of State and local governments in the EPZ surrounding the PNPP.

Each jurisdiction and functional entity was evaluated based on its demonstration of exercise criteria delineated in Federal Register Notice: Vol. 67, No. 80, dated April 25, 2002. Detailed information on the exercise criteria and the extent-of-play agreements used in this exercise are found in Appendix E "Exercise Plan" of this report.

Presented below are definitions of the terms used in this report relative to the criteria demonstration status:

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

- 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.

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. Listing of the demonstrated exercise criteria under which one or more.

ARCAs was/were assessed during the current exercise or ARCAs assessed during prior exercises remain unresolved. Included is a description of any ARCAs assessed during this exercise and the recommended corrective action to be demonstrated before or during the next biennial exercise.

P - Plan.Issue - An observed or identified inadequacy in the ORO's emergency plan or implementing procedures, rather than in the ORO's performance.

e N - Not Demonstrated - Exercise criteria that were not demonstrated as scheduled during this 18

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After Action Report/Improvement Plan Palisades Nuclear Power Plant exercise and the reason(s) they were not demonstrated.

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

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

3.2 Summary Results of Exercise Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of all exercise criteria from Federal Register Notice: Vol. 67, No.. 80, dated April 25, 2002, which were scheduled for demonstration during this exercise by all participating jurisdictions and functional entities. The criterion status box is blank if it was not scheduled for demonstration.

This subsection provides information on the evaluation of each participating jurisdiction' and functional entity in a jurisdiction-based, issues-only format.

The DHS has developed a standardizedye

>cfor numbering exercise issues. This system is used to achieve consistency, in numbering cxercise issues among DHS Regions and site-specific exercise reports within each Region. It also is used to expedite tracking of exercise issues on a nationwide basis.

The identifying number of Dýeii'iencies, ARCAs, and Plan Issues includes the following elements, with each element separated by a hyphen (-).

Plant Site Identifier - A two-digit number, corresponding to the Utility Billable Plant Site Code (44 for Palisades Nuclear Power Plant).

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

" Criterion Number - An alpha and two-digit number corresponding to the criteria numbers in the six Exercise Evaluation Areas described in Federal Register Notice, Vol. 67, No. 80, dated April 25, 2002, which amends FEMA-REP 14, Radiological Emergency Preparedness Exercise Manual.

" Issue Classification Identifier - (D = Deficiency, A = ARCA, P = Plan Issue).

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

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After Action Report/Inprovement Plan Palisades Nuclear Power Plant Table 3.1 - Summary of Exercise Evaluation (5 pages)

DATE: 2010-03-02 U U U SITE: Palisades Nuclear Power Plant, MI

-It M >

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

U C C

-.o.,.2 ° Demonstrated' c

E1 1

EmteYgncyOperations Mlanagemnt i

Mobilization lal M M M M M Facilities 1b1 Direction and Control lc]

M M Communications Equipment Idl M M M

_MM M

M Equip & Supplies to support operations lel M M M

Prote~ctv ACtion Deccisin Mlaking;,>j Emergency Worker Exposure Control.

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

M PADs for protection of special populations 2cl M

Rad Assessment and Decision making for the Ingestion Exposure Pathwa..

2d]

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Temporary care of evacuees 6c1 Transportation and treatment of contaminated injured individuals 6dl 20

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant Table 3.1 - Summary of Exercise Evaluation (Continued. page 2/5)

DATE: 2010-03-02 SITE: Palisades Nuclear Power Plant, MI M: Met, A: ARCA, D: Deficiendy, P: Plan Issue, N: Not Demonstrated z0 7

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Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 21

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant Emergency information and instructions for the public and the media 5b]

M Support OpertlornsFlacilltes Mon / decon of evacuees and emergency workers, and registration of evacuees 6a]

M M M M M M M Mon / decon of emergency worker equipment 6b1 M M Temporary care of evacuees 6c 1 Transportation and treatment of contaminated injured individuals 6d1 1 22

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Palisades Nuclear Power Plant Table 3.1 - Summary of Exercise Evaluation (Continued. page 3/5)

DATE: 2010-03-02 SITE: Palisades Nuclear Power Plant, MI M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated H

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Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions 3fl Adequate Equipment forPlume 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]

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Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the media 5bl M

23

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant Support Operations aciliti.s..

Mon / decon of evacuees and emergency workers, and registration of evacuees 6al M

M M

Mon / decon of emergency worker equipment 6b]

M Temporary care of evacuees 6cl M

Transportation and treatment of contaminated iniured individuals 16dl E 24

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant Table 3.1 - Summary of Exercise Evaluation (Continued. page 4/5)

DATE: 2010-03-02 SITE: Palisades Nuclear Power Plant, MI M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated z

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M Support OperatonsFaci t I

M M M Mon / decon of evacuees and emergency workers, and registration of evacuees 6al M M M 25

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Mon / decon of emergency worker equipment Temporary care of evacuees Transoortation and treatment of contaminated iniured individuals Palisades Nuclear Power Plant 6bI M

6cl M

6d I

I I

I 26

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant Table 3.1 - Summary of Exercise Evaluation (Continued. page 5/5)

DATE: 2010-03-02 SITE: Palisades Nuclear Power Plant, MI M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated UO 75 U

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27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant SuppoitO(eraton/Faulhtiesa f I Mon/ decon of evacuees and emergency workers, and registration of evacuees

-6al M

M P Mon / decon of emergency worker equipment 6b1 M

Temporary care of evacuees 6c]

M Transportation and treatment of contaminated injured individuals 6dl 28

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant 3.3 Criteria Evaluation Summaries 3.3.1 Michigan Jurisdictions 3.3.1.1 Initial Notification Point

a. MET: 1.a.1, 1.d.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 3.3.1.2 State Emergency Operations Center

a.

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

\\

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: Non&

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.1.3 Joint Information Center

a.

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: 5.b.1.

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

29

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant REASON UNRESOLVED: Two news releases did not recind agricultural advisory information when Protective Action Orders to evacuate were issued. Evacuation information contained in PAOs continued to advise shelering, if possible all livestock and to make sure that they have enough stored feed and well or stored water to last a few days.

3.3.1.4 Michigan State Rumor Control Center

a.

MET: 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: Nonei:,

3.3.1.5 Technical Support Group

a.

MET: 1.a. 1, 1.d. 1, 2.a. 1, 2.b.1./,

b. AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: Noii

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.6 Field Team Center Cell

a.

MET: 1.a. 1, I.d. 1, 1.e. 1, 2.a. 1, 2.b. 1, 2.b.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 30

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant 3.3.1.7 MDEQ FTC Traffic and Access Contol Dosimetry Briefing - Palisades 3.3.1.8 Michigan State Police Traffic and Access Control Point Demonstration - Palisades

a.

MET: 1.d.1,3.b.1,3.d.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 3.3.1.9 State Liaison - Allegan County EOC : Palisades

a.

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None

e.

NOTDEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None:

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.10 State Liaison - Berrien County EOC - D.C. Cook and Palisades

a.

MET: 2.a.1, 2.b.1 41,-15.b. 1.

b. AREAS REQUIRINi ORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.1.11 State Liaison - Van Buren County EOC - Palisades

a.

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None 31

Unclassified Radiological Emergency Preparedness Program (REP)

After Action leport/Improvement Plan Palisades Nuclear Power Plant

f.

PRIOR ISSUES-RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.1.12 Michigan Department of Environmental Quality - Emergency Worker Equipment/Vehicle Monitoring/Decontamination - Decatur FD

a.

MET: 1.d.1, 1.e.1, 3.a.l,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 3.3.1.13 Michigan Department of Environmental Quality - Emergency Worker Equipment/Vehicle Monitoring/Decontamination - North Berrien FD

a.

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None

e.

NOT DEMONSTRATED: Nonei

f. PRIOR ISSUES - RE'OLVED: None

g.

PRIOR ISSUES - Ii, RESOLVED: None 3.3.1.14 Michigan Department of Environmental Quality - Emergency Worker Monitoring/Decontamination - Decatur FD

a.

MET: 1.d.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 32

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant 3.3.1.15 Michigan Department of Environmental Quality - Evacuee Monitoring/Decontamination - Otsego High School - Allegan County

a.

MET: 1.d.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 3.3.1.16 Michigan Department of Environmental Quality - Evacuee/Vehicle Monitoring/Decontamination - Paw Paw High School-Van Buren County

a.

MET: 1.d.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 3.3.1.17 Michigan Department of Environmental Quality - Evacuee/Vehicle Monitoring/Decontamination - Coloma High School-Berrien County

a.

MET: 1.d.1, 1.e.1, 3.a.,l6.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 3.3.1.18 Michigan Department of Environmental Quality - Evacuee Monitoring/Decontamination - Paw Paw High School - Van Buren County

a.

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

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None 33

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant

d. PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.1.19 Michigan Department of Environmental Quality - Emergency Worker Monitoring/Decontamination - North Berrien Fire Department

a.

MET: 1.d.1, 1.e.l,3.a.l,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 3.3.1.20 Michigan Department of Environmental Quality - Emergency Worker Monitoring/Decontamination - Graafschap Fire Department

a.

MET: 1.d.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 3.3.1.21 EW Monitoring/Decontamination - Decatur Fire Department - Palisades

a.

MET: 1.d.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 34

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant 3.3.2 Risk Jurisdictions 3.3.2.1 Van Buren County Initial Notification Point - Palisades

a.

MET: 1.a.1, l.d.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 Van Buren County EOC - Palisades

a.

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

b.

AREAS REQUIRING CORRECTIVE ACTIQN: 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 Van Buren County Traffi and Access Control Dosimetry Briefing - Palisades

a.

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

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 3.3.2.4 Van Buren County Traffic and Access Control Point Demonstration - Palisades

a.

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None

e.

NOT DEMONSTRATED: None 35

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.5 Van Buren County Health Department - Dosimetry - Palisades 3.3.2.6 Van Buren County Public Information Officer in the JIC

a.

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

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.7 Emergency Alert System Radio Station WSJM - Palisades

a.

MET: 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 - IiNRESOLVED: None 3.3.2.8 EV-2 Interview - South Haven Public Schools

a.

MET: 1.d.1, 1.e.1, 3.a.1, 3.b.1, 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 36

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant 3.3.2.9 Evacuee Vehicle Monitoring/Decontamination/Registration.- Paw Paw High School-Palisades a.

b.

C.

d.

e.

f.

g.

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

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None PLAN ISSUES: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 3.3.2.10 Emergency Worker Equipment/Vehicle Monitoring /Decontamination - Decatur Fire Department

a.

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

b.

C.

d.

e.

f.

g.

AREAS REQUIRING CORRECTIVE ACTION: None DEFICIENCY: None PLAN ISSUES: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED:"Noneo*

PRIOR ISSUES - UNRESOLVED: None 3.3.2.11 Evacuee Monitoring/Decontamination/Registration - Paw Paw High School -

Palisades 7'

a.

MET: 1.d.1, L.e.1, 3.a.l, 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 3.3.2.12 Congregate Care - Lawrence High School - Palisades

a.

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None 37

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES-UNRESOLVED: None*

3.3.2.13 Berrien County Initial Notification Point

a. MET: 1.a.l 1l.d.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 3.3.2.14 Berrien County Emergency Operations Center

a.

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

ISSUE NO.: 15-09-3ibl-A-01 ISSUE: The decision to take KI was made by the State; however the implementation of that decision was. not carried out by the Berrien County EOC in a timely manner.

CORRECTIVE ACTION DEMONSTRATED: The Berrien County EOC staff demonstrated the ability to implement timely recommendations and instructions to Emergency Workers as they relate to KI. At 1116 hours0.0129 days 0.31 hours 0.00185 weeks 4.24638e-4 months , following the declaration by PNPP, the State of Michigan Chief Medical Executive issued a PAO for all emergency workers in Protective ActionAreas (PAAs) 1, 2, 3, 4 and 5 to ingest KI.

This PAO was announced at the EOC at 1131 hours0.0131 days 0.314 hours 0.00187 weeks 4.303455e-4 months . This PAO was distributed (simulated) to EWs at 1133 hours0.0131 days 0.315 hours 0.00187 weeks 4.311065e-4 months through the emergency services radio system.

Through interview it was determined that emergency workers in PAAs 1, 2, 3, 4 and 5 would take their KI and log on their individual record sheet the time of ingestion 38

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant (simulated) and they would each report to their supervisors that they complied with the State of Michigan's Chief Medical Executive recommendation. The status of emergency worker ingestion of KI would be reported to the appropriate representative in the Berrien County EOC. The only PAA applicable to Berrien County is PAA #5 for the PNPP 10-Mile EPZ.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.15 Berrien County Traffic and Access Control Point Dosimetry Briefing

a.

MET: 3.a.1, 3.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 3.3.2.16 Berrien County Traffic and Access Control Point Demonstration - Palisades

a.

M ET: 1.d.1, l.e.1, 3.a.1, 3.b.1,3:.d.l-.1ý'

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 3.3.2.17 Berrien County Public Information Officer at the JIC

a.

MET: L.a.1, l.d.l,.e.l, 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 39

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant 3.3.2.18 Congregate Care - Coloma High School - Palisades

a. MET: 1.d.1,6.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 3.3.2.19 Emergency Worker Equipment/Vehicle Monitoring /Decontamination - North Berrien Fire Department

a.

MET: 1.d.1, 1.e. 1, 3.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 3.3.2.20 Evacuee Vehicle Monitoring/Decontamination - Coloma High School - Palisades

a.

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

b. AREAS REQUIRING ORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.21 Evacuee Monitoring/Decontamination/Registration - Coloma High School -

Palisades

a.

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

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

ISSUE NO.: 44-10-6al-A-02 CRITERION: Reception center/emergency worker facility has appropriate space, 40

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant 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: A radiation technician performed an improper hand survey demonstration of a contaminated (simulated) evacuee at the out-of-sequence demonstration of evacuee monitoring and decontamination. The technician used a CD V-700 probe with a pancake probe and moved the probe too fast (8-10 inches per minute, estimated) and at a distance of several inches from the body.

POSSIBLE CAUSE: The technician did not properly apply the training that had been issued.

REFERENCE:

NUREG-0654, J.10.h., K.5.b EFFECT: Evacuees with areas of contamination on their bodies could have been released from the facility and couldIhav i

-spread contamination to other individuals.

CORRECTIVE ACTION DEMONSTRATED: The demonstration was stopped and the individual was refrained and instructed by the Controller. A re-demonstration of the Radiation. suvywas-performed and demonstrated successfully.

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 Emergency Worker Monitoring/Decontamination - North Berrien Fire Department

a.

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

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None

e.

NOT DEMONSTRATED: None 41

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.23 EV-2 Interview - Coloma Public Schools

a. MET: 1.d. 1, 1.e. 1, 3.a. 1, 3.b. 1, 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 3.3.2.24 Allegan County Initial Notification Point - Palisades

a.

MET: 1.a. 1, 1.d. 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 3.3.2.25 Allegan County Emergency Operations Center - Palisades

a. M ET: 1.a.1, 1.c.1, It'd.1, L.e.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 3.3.2.26 Allegan County Traffic and Access Control Dosimetry Briefing - Palisades

a.

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

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None 42

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.27 Allegan County Traffic and Access Control Point Demonstration - Palisades

a.

MET: 1.d.1, 1.e.1, 3.a.1, 3.b.1, 3.d.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 Allegan County Public Information Officer at the JIC

a.

MET: La.1,.d.1, L.e.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 3.3.2.29 EW Monitoring/Decontamination - Graafschap Fire Dept. - Palisades

a.

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 43

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan' Palisades Nuclear Power Plant 3.3.2.30 Congregate Care - Otsego High School - Palisades

a.

MET: 1.d.1, 6.c.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 3.3.2.31 Evacuee Monitoring/Decontamination/Registration - Otsego High School -

Palisades

a. MET: 1.d.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: Nonec

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.32 Evacuee Vehicle Monitoring/Decontamination - Otsego High School - Palisades a..

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: No ne

d. PLAN ISSUES: 6.a.1.

ISSUE NO.: 44-10-6a1-P-03 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 Allegan County Procedures for Public Reception/Decontamination Centers, dated February 2010, assigns the responsibility for evacuee vehicle exterior decontamination to the fire services within the County.

This is found in the SOP for Station #8, Vehicle Decontamination Station, pages 31-44

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant 35.

However, it is Allegan County's understanding that the State of Michigan, Department of Environmental Quality, is responsible for this function.

POSSIBLE CAUSE: Previous versions of Allegan County's SOPs for Public Reception/Decontamination Centers did not require Allegan County to decontaminate evauees' vehicles. Either this change has not yet been incorporated into Allegan County planning, or the Allegan County's SOPs need to be modified to indicate that the State of Michigan is responsible for evacuee vehicle decontamination.

REFERENCE:

NUREG 0654 Sec. J.12 (Requires setting standards for decontamination)

EFFECT: Vehicles belonging to the evacuating public that could have otherwise been washed and decontaminated t (lthie Reception/Decontamination Center are now impounded in a contaminate&dparking area.

RECOMMENDATION: Allegan County prepare to implement Station #8 SOP of it's new procedure, or; State of MichiganJimplement Station #8 SOP in Allegan County.

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 45

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant SECTION 4: CONCLUSION Based on the results of the March 2, 2010, exercise, the offsite radiological emergency response plans and preparedness for the State of Michigan and affected local jurisdictions, site-specific to the Palisades Nuclear Power Plant, can be implemented and are adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency at the site. Therefore, the Title 44 CFR, Part 350, approval of the offsite radiological emergency response plans and. preparedness for the State of Michigan site-specific to the Palisades Nuclear Power Plant, remain in effect.

46

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant APPENDIX A: IMPROVEMENT PLAN Isu Numer Is1-alP0 Cr iteron ISSUE: The Allegan County Procedures for Public Reception/Decontamination Centers, dated February 2010, assigns the responsibility for evacuee vehicle exterior decontamination to the fire services within the County. This is found in the SOP for Station #8, Vehicle Decontamination Station, pages 31-35.

However, it is Allegan County's understanding that the State of Michigan, Department of Environmental Quality, is responsible for this function.

RECOMMENDATION: Allegan County prepare to implement Station #8 SOP of it's new procedure, or; State of Michigan implement Station #8 SOP in Allegan County.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY:

PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT:

START DATE:-"

AGENCY POC:

.. COMPLETION DATE:

47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant Isu Nu be 440 Ib--

Cr iter ISSUE: Two News Releases were issued with incorrect and/or incomplete information. One contained the wrong emergency classification level. Both did not include all of the information that was contained in the Agricultural Advisories.

RECOMMENDATION: Ensure that all information contained in the news release is accurate prior release.

Additionally, provide the media with copies of Executive Orders, Agricultural Advisories, and other pertinent documents upon receipt at the JIC to ensure that the media has complete and accurate infonnation.

SCHEDULE OF CORRECTIVE ACTIONS: The EMHSD will review JIC SOPs and conduct training with State JIC staff to address lack of attention to detail in proofreading the news releases prior to release to the media. The criterion will be demonstrated for correction at the 2009 D.C. Cook REP exercise.

CORRECTIVE ACTION NOT DEMONSTRATED:

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

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

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY:

jPRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT:

START DATE:

AGENCY POC:

COMPLETION DATE:

48

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant APPENDIX B: EXERCISE TIMELINE Table 1, on the following page, presents the times at which key events and activities occurred during the Palisades Nuclear Power Plant REP Partial Participation Plume Exposure Pathway exercise conducted on March 2, 2010. Also included are times notifications were made to the

,participating jurisdictions/functional entities.

49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant Table 1 -

DATE: 2010-03-02, SITE:

Exercise Timeline Palisades Nuclear Power Plant,. MI Unusual Event N/A N/A N/A N/A N/A N/A Alert 0812 0825 N/A 0825 0825 0825 Site Area Emergency 0920 0926 0926 0928 0928 0928 General Emergency 1105 1103 1115 1115 1118 1118 Simulated Rad. Release Started

.1103 1115 1125' 1115 1116 1116 Simulated Rad. Release N/A N/A N/A N/A N/A N/A Terminated Facility Declared Operational 0919 0940 0915 0937 0935 Declaration State of Emergency - State 0951 1015 N/A N/A N/A Declaration of Local Disaster - County N/A N/A 0930 0935 0951 Exercise Terminated 1330 1 350 1330 0330 1335 1 st Precautionary Action Decision: School N/A,

N/A 0932 1001 1036 Evacuations 2nd Precautionary Action Decision: MDOT 1125 N/A N/A N/A N/A Traffic Restrictions Protective Action Areas 1-3 Rail and Highway and 5-Mile Radius Water and Air Ist Agricultural Advisory: All Dairy and v0935 N/A N/A N/A N/A Livestock Sheltered and Placed on Stored Feed and Well Water Protective Action Areas l'and 5.....

1 st Agricultural Advisory Amendment: Added 1031 N/A N/A N/A N/A Protective Action Area 3 to the Attached Map 2nd.Agricultural Advisory: Agrie1t111t ia]

1125 N/A N/A N/A N/A Embargo Protective Action Area,*N*4 -3 3rd Agricultural Advisory: Agric'ultu*al Embargo 1130 N/A N/A N/A N/A Protective Action Areas 4 and 5 4th Agricultural Advisory: Agricultural Embargo 1310 N/A N/A N/A N/A Protective Action Areas 1-5 1 st Protective Action Order: Evacuation of 1115 N/A N/A N/A N/A Protective Action Areas 1-3 and Lake 5-Mile Radius I st Siren Activation N/A N/A 1123 N/A

. N/A 1st EAS Message N/A N/A 1131 N/A N/A 2nd Protective Action Order: Evacuation of 1307 N/A 1315 N/A N/A Protective Action Areas 1-5 and Lake 10-Mile Radius 2nd Siren Activation N/A

N/A 1315 N/A N/A 2nd EAS Message N/A N/A 1327 N/A N/A KI Administration Decision 1: Emergency 1116 N/A N/A N/A N/A Workers Located Protective Action Areas 1-5 KI Administration Decision 2: Institutionalized

.1120 N/A N/A N/A N/A Population and Caretakers Under 40 Protective Action Areas 1, 3, and 5 KI Administration Decision 3: Institutionalized 1125 N/A N/A N/A N/A Population and Caretakers Under 40 Protective Areas 2 and 4 50

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS The following is a list of the personnel that evaluated the Palisades Nuclear Power Plant REP Partial Participation Plume Exposure Pathway Exercise on March 2, 2010. The list includes the evaluation team leadership and all evaluators. The organization each evaluator represents is indicated.by the following abbreviations:

DHS/FEMA Dept of Homeland Security/Federal Emergency Management Agency ICF Consulting Title Name Organization Radiological Assistance Committee, Chairman William E. King DHS/FEMA Exercise Director Stephen Tulley DHS/FEMA Senior Specialist Gary Naskrent DHS/FEMA Site Specialist Edward Diaz DHS/FEMA Team Leader - Michigan James King DHS/FEMA Team Leader - Van Buren County Bridget Ahlgrim DHS/FEMA Team Leader - Berrien County Carolyn Sturghill DHS/FEMA Team Leader - Allegan Coun, Ed Golinski DHS/FEMA 51

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant DATE: 2010-03-02, SITE: Palisades Nuclear Power Plant, Ml LOCATIO EVALUATOR AGENCY i Initial Notification Point Marcy Campbell ICF State Emergency Operations Center Todd Gemskie DHS/FEMA Kimberly Wood ICF Joint Information Center Robert Duggleby ICF Michigan State Rumor Control Center Paul Nied ICF Technical Support Group Marcy Campbell ICF Field Team Center Cell Robert Walker ICF MDEQ FTC Traffic and Access Contol Dosimetry Briefing - Palisades Michigan State Police Traffic and Access Control Point Daniel Prevo ICF Demonstration - Palisades State Liaison - Allegan County EOC - Palisades Louis Sosler ICF State Liaison - Berrien County EOC - D.C. Cook and Palisades Richard Grundstrom ICF State Liaison - Van Buren County EOC - Palisades Edward Diaz DHS/FEMA Michigan Department of Environmental Quality - Emergency Worker Robert Walker ICF Equipment/Vehicle Monitoring/Decontamination - Decatur FD Michigan Department of Environmental Quality - Emergency Worker Lynn Steffensen ICF Equipment/Vehicle Monitoring/Decontamination - North Berrien' FD Michigan Department of Environmental Quality - Emergency Worker Paul Ringheiser Jr ICF Monitoring/Decontamination - Decatur FD 11 Michigan Department of Environmental Quality - Evacuee :.

Michael Meshenberg ICF Monitoring/Decontamination - Otsego High School - Allegahn.County Michigan Department of Environmental Quality - Evacuee/Vehicle Daniel Prevo ICF Monitoring/Decontamination - Paw Paw High School-Van Buren County Michigan Department of EnvironmentallQuality - Evacuee/Vehicle Robert Duggleby ICF Monitoring/Decontamination - Colom&aHigh School-Berrien County Michigan Department of Environmental Quahiy - Evacuee Todd Davidson ICF Monitoring/Decontamination -,P aWw-x High School - Van Buren County Michigan Department of Environmental Quality - Emergency Worker Robert Duggleby ICF Monitoring/Decontamination - North Berrien Fire Department Michigan Department of Environmental Quality - Emergency Worker DeeEll Fifield ICF Monitoring/Decontamination - Graafschap Fire Department EW Monitoring/Decontamination - Decatur Fire Department -

David Ortman DHS/FEMA Palisades Van Buren County Initial Notification Point - Palisades Robert Vork ICF Van Buren County EOC - Palisades Edward Diaz DHS/FEMA Paul Ringheiser Jr ICF Robert Vork ICF Van Buren County Traffic and Access Control Dosimetry Briefing -

Robert Vork ICF Palisades Van Buren County Traffic and Access Control Point Demonstration -

David Ortman DHS/FEMA Palisades Van Buren County Health Department - Dosimetry - Palisades Van Buren County Public Information Officer in the JIC Paul Nied ICF

.Emergency Alert System Radio Station WSJM - Palisades Lynn Steffensen ICF EV-2 Interview - South Haven Public Schools Michael Meshenberg ICF Evacuee Vehicle Monitoring/Decontamination/Registration - Paw Paw Robert Vork ICF

.High School-Palisades 52

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant Emergency Worker Equipment/Vehicle Monitoring /Decontamination Kimberly Wood ICF

- Decatur Fire Department Evacuee Monitoring/Decontamination/Registration - Paw Paw High Lynn Steffensen ICF School - Palisades Congregate Care - Lawrence High School - Palisades DeeEll Fifield ICF Berrien County Initial Notification Point Richard Grundstrom ICF Berrien County Emergency Operations Center Clinton Crackel DHS/FEMA Delwyn Kinsley DHS/FEMA Berrien County Traffic and Access Control Point Dosimetry Briefing Clinton Crackel DHS/FEMA Berrien County Traffic and Access Control Point Demonstration-Wes Ryals ICF Palisades Berrien County Public Information Officer at the JIC Paul Nied ICF Congregate Care - Coloma High School - Palisades Thomas Gahan ICF Emergency Worker Equipment/Vehicle Monitoring /Decontamination Sonia Eischen ICF

- North Berrien Fire Department Evacuee Vehicle Monitoring/Decontamination - Coloma High School Louis Sosler ICF

- Palisades Evacuee Monitoring/Decontamination/Registration - Coloma High Wes Ryals ICF School - Palisades Emergency Worker Monitoring/Decontamination - North Berrien Fire Daniel Prevo ICF Department EV-2 Interview - Coloma Public Schools Sonia Eischen ICF Allegan County Initial Notification Point - Palisades Louis Sosler ICF Allegan County Emergency Operations Center - Palihades Todd Davidson ICF Thomas Gahan ICF Allegan County Traffic and Access Control Dosimetry Briefing -

Louis Sosler ICF Palisades Allegan County Traffic and Access Control Pboini/Demonstration -

DeeEll Fifield ICF Palisades Allegan County Public Informatioff Officeratfthe JIC Paul Nied ICF EW Monitoring/Decontamination iraafschap Fire Dept. - Palisades Bruce Swiren ICF Congregate Care - Otsego High School - Palisades Karl Fippenger ICF Evacuee Monitoring/Decontamination/Registration - Otsego High Karl Fippenger ICF School - Palisades Evacuee Vehicle Monitoring/Decontamination - Otsego High School - Bruce Swiren ICF Palisades L_ý

'TeanviLeadcJýr 53

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant APPENDIX D: ACRONYMS AND ABBREVIATIONS ACCC Allegan County Communications Center ACEMD Allegan County Emergency Management Director ACP Access Control Point AFC Adult Foster Care ALARA As Low As Reasonably Achievable ARC American Red Cross ARCA Area Requiring Corrective Action ARES Amateur Radio Emergency Service BCRC Berrien County Road Commission CCC Congregate Care Center CD Central Dispatch CDE Committed Dose Equivalent CEO Chief Executive Officer DFD Decatur Fire Department DO Duty Officer DPD Domestic Preparedness*Director DRD Direct-Reading Dosimeter EAS Emergency AlertSysteiý EBS Emergency Broadcast System ECL Emergency Classification Level EMA Emergency Management Agency EMC Emergency Management Coordinator EMD Emergency Management Director EMS Emergency Medical Services EOC Emergency Operations Center EOP Emergency Operations Plan EPA Environmental Protection Agency EPD Electron Personal Dosimeter EPZ Emergency Planning Zone EW Emergency Workers EWD Emergency Worker Decontamination FAA Federal Aviation Administration FEMA Federal Emergency Management Agency FMT Field Monitoring Teams 54

Unclassified Radiological Emergency Preparedness Program (REP).

After Action Report/Improvement Plan Palisades Nuclear Power Plant FRA Federal Railroad Administration FS Fire Services FTC Field Team Center FTCC Field Team Center Coordinator GE General Emergency GIS Geographic Information Systems GR Governor's Representative HD Health Department HF High Frequency HP Health Physicist HPL Health Physics Liaison HPS Health Physics Support HSAS Homeland Security Advisory System HSO Health Services Officer IM Incident Manager ISD Intermediate School District JIC Joint Information Center LE Law Enforcement LEIN Law Enforcement Information Network LIS Land Information System.--

MARS Military Affiliated RadibSystern MSP Michigan State Police

NPP Nuclear Power Plant.

Y ORG Offsite Resp6nse,Organization PAG Protective Aýtiorf'Guideline PAO Protective Action Order PAR Protective Action Recommendation PIO Public Information Officer PM Portal Monitor PNPP Palisades Nuclear Power Plant PPFD Paw Paw Fire Department PW Public Works RACES' Radio Amateur Civil Emergency Services RAP Radiological Assistance Program RC Red Cross REP Radiological Emergency Preparedness RESA Regional Educational Service Agency RO Radiological Officer SAE Site Area Emergency SHP State Health Physicist 55

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant SHPS South Haven Public Schools SLO State Liaison Officer SOP Standard Operating Procedure SS School Services SSC Social Services Chief TACP Traffic Access Control Points TEDE Total Effective Dose Equivalent TLD Thermo Luminescent Dosimeter UHF Ultra High Frequency VBCRDO Van Buren County Radiological Defense Officer VBISD Van Buren Intermediate School District VHF Very High Frequency

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56

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant APPENDIX E: EXERCISE PLAN This appendix lists the exercise criteria, which were scheduled for demonstration in the Palisades Nuclear Power Plant Radiological Emergency Preparedness Partial Participation Plume Exposure Pathway Exercise on March 2, 2010, and the offsite extent-of-play agreement accepted by DHS/FEMA Region V on January 29, 2010. The exercise criteria, contained in the FEMA "Radiological Emergency Preparedness Exercise Evaluation Methodology; Notice," as published in the Federal Register Notice/Vol. 67, dated April 25, 2002, represent a functional translation of the planning standards and evaluation criteria of NUREG-0654/FEMA-REP-1, Revl, "Criteria for the Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," November 1980. Because the exercise criteria are intended for use at all nuclear power plant sites, and because of variations among offsite plans and procedures, an extent-of-play agreement is prepared by the State and accepted by DHS/FEMA to provide evaluators with guidance on expected actual demonstration of the criteria.

Exercise Criteria Listed on the following pages are the specific, hdioi6gical emergency preparedness criteria that were scheduled for demonstration during this exercise.

57

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant STATE OF MICHIGAN, AND ALLEGAN, BERRIEN AND VAN BUREN COUNTIES EXTENT OF PLAY AGREEMENT FOR THE PALISADES NUCLEAR POWER PLANT REP EXERCISE March 02, 2010 EVALUATION AREA 1 - EMERGENCY OPERATIONS MANAGEMENT Criterion 1.a.l: OROs use effective procedures to alert, notify and mobilize emergency personnel and activate facilities in a timely manner.

o State of Michi2an

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

2. State personnel reporting to the county EOC's will be pre-positioned and will report when mobilized by the SEOC.

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

4. State personnel involved in out of sequence demonstrations will be pre-positioned.

0 Alleman County

1. The Allegan County EOC will be fully activated. Personnel will be mobilized in accordance with procedures.

2. Allegan County personnrel reporting to the JIC will be pre-positioned and will begin participationiup ionotification by the JIC Controller.

3. All personnel'imlved in out of sequence demonstrations will be pre-positioned.

o Berrien County,

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

2. Berrien County JIC personnel will be pre-positioned and will begin participation upon notification by the JIC Controller.

3. All personnel involved in out of sequence demonstrations will be pre-positioned.

o Van Buren County

1. The Van Buren County EOC will be fully activated. Personnel will be mobilized in accordance with procedures.

2. Van Buren County JIC personnel will be pre-positioned and will begin participation upon notification by the JIC Controller.

3. All personnel involved in out of sequence demonstrations will be pre-positioned.

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

o State of Michi2an The State Emergency Operations Center (SEOC) is maintained in operational readiness and set up will not be demonstrated.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant o

Allegan County Allegan County EOC is maintained in operational readiness.

o Berrien County Berrien County EOC is maintained in operational readiness.

o Van Buren County Van Buren County EOC will be set up prior to the start of the exercise.

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

o State of Michilan. Allegan, Berrien & Van Buren Counties This criterion will be demonstrated at the SEOC, county EOC's and JIC.

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

o State of Michi2an, Allesanm-Berrien & Van Buren Counties This criterion will be dem6hsti*atfdby the SEOC, county EOC's, JIC and the Public Reception/Decon Centers, Emergency Worker Decon. Centers and.Access Control.

If both the primary and backýup systems fail, this objective may be demonstrated by successful use of alternate method of communication.

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

o State of Michigan, Alle2an, Berrien & Van Buren Counties

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

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

3. Potassium iodide. and dosimetry are stored at each county's emergency management office and at the MSP/EMHSD office in Lansing. Van Buren County stores 25 bottles at the emergency management office and the remaining at the County Emergency Operations Center (EOC).

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

5. Documentation related to KI shelf life extension is maintained by MSP/EMHSD and will be provided to FEMA at the Pre-Exercise Briefing along with instrument calibration data.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant EVALUATION AREA 2-PROTECTIVE ACTION DECISION MAKING 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.

o State of Michigan

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

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

Note: This criterion may be re-demonstrated as approved on a case-by-case basis by the Chair of the Radiological Preparedness CoordinatingCommittee.

o Allegan, Berrien & Van Buren Counties This criterion does not apply to the counties and will not be demonstrated by the counties.

Criterion 2.b.l: Appropriate protective action recommendations are based on available information on plant conditio.s, field monitoring data and licensee and ORG dose projections, as well as kno wledge, of on-site and off-site environmental conditions.

o State of Michi:a:n

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

2. Dose assessment evaluation will be conducted in the SEOC and/or FTC cell as appropriate.

Note: This criterion may be re-demonstrated as approved on a case-by-case basis by the Chair of the Radiological Preparedness Coordinating Committee.

o Allegan, Berrien & Van Buren Counties This criterion does not apply to the counties and will not be demonstrated by the counties.

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant o State of Michi2an This criterion will be demonstrated by the Incident Management Group in the SEOC in conjunction with applicable support staff. i.e., Technical Support Group and MDCH.

Note: This criterion may be re-demonstrated as approved on a case-by-case basis by the Chair of the Radiological Preparedness Coordinating Committee.

o Allegan, Berrien & Van Buren Counties This criterion does not apply to the counties and will not be demonstrated by the counties.

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

o State of Michi2an This criterion will be demonstrated by the Incident Management Group in the SEOC in conjunction with applicable suppoil staff through the decision to recommend the use of KI to institutionalized persons.

o Allegan, Berrien & Van Buren Counties

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

2. *Equipment lissnd rosters will be available in the county EOCs.

o Berrien, Van Buren and Allelan Counties The School Services Representatives in the Berrien and Van Buren County EOCs will make phone contact with affected school districts if schools are in session. No scenario information will be discussed during these calls.

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

This criterion will not be demonstrated during this exercise.

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

This criterion will not be demonstrated during this exercise.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant EVALUATION AREA 3-PROTECTIVE ACTION IMPLEMENTATION Criterion 3.a.l: The OROs issue appropriate dosimetry and procedures, and mdnage radiological exposure to emergency workers in accordance with the plan and procedures.

Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriateexposure record or chart.

o State of Michigan The State of Michigan will demonstrate this criterion at out of sequence activities utilizing State personnel.

o Allegan, Berrien & Van Buren Counties

Allegan, Berrien and Van Buren Counties will demonstrate this criterion out of sequence at the reception center and decontamination centers. Berrien and Van Buren County will demonstrate this criterion at the access control point when emergency workers are issued dosimeters' for use. Allegan County will demonstrate this criterion for the ACP via interview at theýEOC.

Note: This criterion may be re-demonstrated immediately for credit, at the discretion of

.the evaluator.

7,,

Criterion 3.b.1: KI and appirpriate instructions are available should a decision to recommend use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals (not the general public) is maintained.

o State of Michiga*n The State will onilydemonstrate decision-making and directives to implement appropriate Protective Action Orders.

Note: Advanced distribution of KI to the general public has been instituted by Michigan Department of Community Health (MDCH). Orders for ingestion decision making will be implemented through the SEOC according to MDCH procedures.

o Alleman, Berrien & Van Buren Counties

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

ingest it.

2. KI will be distributed to emergency workers inAllegan, Berrien and Van Buren Counties along with their dosimetry.

3. ARCA Issue 15-09-3bl-A-1 The decision to take KI was made by the State; however the implementation of that decision was not carried out by the Berrien County EOC in a timely manner.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant Criterion 3.c.1: Protective action decisions are implemented for special population groups within areas subject to protective actions.

o State of Michigan This criterion will not be demonstrated by the state.

o Alleman, Berrien & Van Buren Counties

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

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

3. Allegan, Berrien and Van Buren Counties will contact a maximum of four providers of transportation services, whichmay include public transit authorities, school systems for buses, ambulances'ervices,:or fire/rescue services. There will be no discussion of scenario informationlduring these calls.

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

o State of Michigan This criterion will not be demonstrated by the state.

o Alleman Berrien &*Van Buren Counties

1. This criterion will be demonstrated in Allegan, Berrien and Van Buren County EOCs as driven by the scenario. If schools are not in session, the FEMA evaluator will conduct an interview with the schools representative in the county EOCs.

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

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

o State of Michigan

1. This criterion will be demonstrated by the SEOC through the opening or closing of air, rail and water ways.

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant o

Alleman, Berrien & Van Buren Counties

1. Decisions related to traffic and access control will be demonstrated in Allegan, Berrien and Van Buren County EOCs. Allegan, Berrien and Van Buren County ACP demonstration locations will be determined during the exercise at a time agreed upon by the FEMA evaluator, the EMHSD Controller, and the county emergency management coordinator. Van Buren and Berrien Counties will dispatch one vehicle for the ACP evaluation. Allegan County will demonstrate this Criterion via interview with an Officer at the EOC.

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

Note: This criterion may be re-demonstrated immediately for credit, at the discretion of the evaluator.

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

o State of Michi$!an This criterion will not be demonstrated by theIstate.

o Alle2an, Berrien & Van Buren Counties This will be demonstrated through' discussions at the county EOCs. Messages will be injected by EMHSD Controllers to drive these demonstrations. Personnel will deal with the impediments by diseussing the need for equipment, discussing its estimated time of arrival, etc. If the impediment posed involves road closures that would have been known to exercise participants during the course of normal operations, this information will beprovided to the players as part of the initial conditions for the exercise. All contacts;,actual or simulated will be logged.

Note: This criterion may be re-demonstrated immediately for credit, at the discretion of the evaluator.

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

This criterion will not be demonstrated during this exercise.

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

This criterion will not be demonstrated during this exercise.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant Criterion 3.f.1: Decisions regarding controlled re-entry of emergency workers and relocation and return of the public are coordinated with appropriate organizations and implemented.

This criterion will not be demonstrated during this exercise.

EVALUATION AREA 4 - FIELD MEASUREMENT AND ANALYSIS 0 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.

This criterion will not be demonstrated during this exercise.

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

This criterion will not be demonstrated during this exercise.

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

This criterion will not be dem6nstrated during this exercise.

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.

This criterion will be not be demonstrated during this exercise.

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

This criterion will not be demonstrated during this exercise.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant EVALUATION AREA 5 - EMERGENCY NOTIFICATION AND PUBLIC INFORMATION 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.

o State of Michigan The State will provide information to each county for release in the Emergency Alert System messages.

o Van Buren County The Van Buren County Sheriff Department is the primary activation point for the public warning sirens. Van Buren Count*yalso activates the Emergency Alert System. An interview with WSJM personnel will be conducted by FEMA following transmittal of EAS messages.

o Allegan & Berrien Counties Allegan and Berrien Counties willI provide, as needed, information to. Van Buren County for inclusion in EAS messages..

Note: This criterion may be-re-demonstrated as approved on a case-by-case basis by the Chair of the Radiological 1P'rearedness Coordinating Committee.

Criterion 5.a.2: [RESERVED]

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

The Palisades EPZ does not contain any FEMA approved exception areas. This criterion will not be demonstrated during this exercise.

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant o

State of Michigan, Allegan, Berrien & Van Buren Counties

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

2. A public inquiry hotline will be operated by Entergy personnel based at the JIC during the exercise. Trending is performed by the Public Inquiry Coordinator, who identifies trends and ensures appropriate information is provided to the public inquiry operators and the JIC for inclusion in media briefings.

3. ARCA Issue 44-08-5bl-A-1 Two news releases were issued with incorrect and/or incomplete information.

One contained the wrong emergency classification level Both did not include all of the information that was contained in the Agricultural Advisories.

Note: This criterion may be re-demonstrated as approved on a case-by-case basis by the Chair of the Radiological Preparedness Coordinating Committee.

EVALUATION AREA 6 - SUPPORT OPERATIONS/FACILITIES 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/ork'emergency workers.

o State of Michip an State HP personne: _ill provide assistance as requested during these demonstrations.

o Allegan County

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

2. Public reception centers will demonstrate 1/3 of the monitoring teams required to monitor 20% of the population allocated to that facility within a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time period.

Each team will monitor six individuals.

o Van Buren County

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

2. Public reception centers will demonstrate 1/3 of the monitoring teams required to monitor 20% of the population allocated to that facility within a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time period.

Each team will monitor six individuals.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant o Berrien County

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

2. Public reception centers will demonstrate 1/3 of the monitoring teams required to monitor 20% of the population allocated to that facility within a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months time period.

Each team will monitor six individuals.

Note: This criterion may be re-demonstrated immediately for credit, at the discretion of the evaluator.

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

o State of Michigan State HP personnel will provide assistafnce as requested during these demonstrations' at local EWD.

o Alle2an, Berrien and Van Buren Counties

1. Allegan, Berrien and Van Buren Counties will each fully demonstrate an emergency worker/equipment decontamination center out of sequence with the exercise.

2. Emergency velhicles, ill be monitored and decontaminated as appropriate.

Note: This criterion may biee-demonstrated immediately for credit, at the discretion of the evaluator.

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

o Alleman, Berrien & Van Buren Counties Allegan, Berrien and Van Buren Counties will each fully demonstrate a congregate care center out of sequence with the exercise. This facility will be set up in advance of the demonstration. Personnel manning the center will not go through alert, mobilization, activation, or shift changes.

Note: This criterion may be re-demonstrated immediately for credit, at the discretion of the evaluator.

68

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant 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.

o A date for this criterion demonstration will be determined Note: This criterion may be re-demonstrated immediately for credit, at the discretion of the evaluator.

69

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant APPENDIX F: SCENARIO DETAILS This appendix contains a summary of the Exercise Scenario, a simulated sequence of events, that was used as the basis for invoking emergency response actions by Offsite Response Organizations (OROs) in the Palisades Nuclear Power Plant REP Partial Participation Plume Exposure Pathway exercise on March 2,2010.

Results of a technical review of the scenario, submitted by the State of Michigan and Entergy Corporation on January 4, 2010, indicated that the scenario was adequate to support demonstration of Department of Homeland Security's requirements, as well as criteria selected by the Offsite Response Organizations provided in the State's January 4, 2010, extent-of-play submission.

This exercise scenario was accepted by DHS/FEMA Region V on December 23, 2009.

During the exercise, in addition to information and data provided through the PNNP onsite scenario, controllers from the State of Michigan gave "inject messages" containing scenario events and/or relevant data to those persons or locations who would normally receive notification of such events. The inject messages were the method used for invoking additional specific response actions by OROs.

DHS/FEMA concurred with the offsite scenario and extent-pf-play submission for the State of Michigan, Allegan, Berrien, and Van Buren Counties for the Mairh 2, 2010 Biennial Radiological Emergency Preparedness Exercise for the Palisades Nuclear PoweriPlant.

PALISADES ONSITE EXERCISE SCENARIO The plant is operating at 100% power, equilibrium xenon, 736ppm boron, ASI on target and has been for the last 10 months. High.Pressure Safety *nje-tion P-66B is Out of Service (OOS) for pump oil change.

Technical Specification (T.S.) LCO 13.5.2 has been in effect since 0600 with a return to Operations by 1200 on 3/02/2010 - same :day. The plant is currently in Action Level 2 for PCS Activity due to suspected minor fuel failure(s).'

A 150 gallon per minute (gpm) Primary Coolant System (PCS) leak will occur. The operating crew will enter ONP-23.1, "Primary Coolant Leak" to quantify leak rate and perform mitigating actions. The Operating Crew will trip the Reactor and enter EOP-1.0, "Standard Post-Trip Actions" followed by a transition to EOP-4.0, "Loss of Coolant Accident Recovery." An ALERT will be declared in the Fission Products Barriers Category (FA1) for potential loss (#2) of Primary Coolant barrier. When Safety Injection occurs Service Water P-7C motor/breaker will fail clearing and locking out 1-D bus. Emergency Diesel Generator (EDG) 1-2 will start, however, the output breaker for EDG 1-2 will not close (Auto or Manual) onto the ID Bus due to bus overcurrent/lockout. This will result in HPSI P-66A loss of power and no operating HPSI pumps. As a result of loss of HPSI, the operating crew will transition to EOP-9.0 "Functional Recovery Procedure." The ERO will take actions to determine fault on 1-D bus (P-7C breaker) as well as refill HPSI P-66B pump oil reservoirs and restore it to service. The loss of 1-D bus results in minimal Containment Cooling (loss of 2 Service Water Pumps and loss of 3 Containment Air Coolers) during the Small Break LOCA resulting in a more observable Containment Barrier failure later.

70

Unclassified Radiological Emergency Preparedness Program (REP)*

After Action Report/Improvement Plan Palisades Nuclear Power Plant Approximately 5 minutes after the Safety Injection, Primary Coolant Pump (PCP) P-50D (P-50B will fail if P-50D has already been secured @ 1300#) experiences a locked rotor and its breaker fails to open resulting in a loss of "Rear" Switchyard Bus. Pieces of the catastrophically failed P-50D impeller will migrate into the reactor core inducing fuel cladding failures that reveal themselves later in the event.

Containment RadiationMonitors (RIA-1805 through RIA-1808) and Containment High Range Radiation Monitors (RIA-2321 and 2322) will begin to gradually rise soon after P-50D locked rotor event. The plant will be in a Natural Circulation (NC) condition.

Approximately 65 minutes after the Alert declaration and approximately 50 minutes after the P-50D locked rotor, the Containment High Range Radiation Monitors RIA-2321 and 2322 gradual rise will promptly jump to -2500 R/hr. A SITE AREA EMERGENCY (SAE) will be declared in the Fission Products Barriers Category (FS 1) for either potential loss (#2) or loss (#2) of Primary Coolant barrier and loss (#5) of fuel clad barrier.

Approximately 100 minutes after the SAE declaration the Containment Main Airlock will catastrophically fail as evidenced by Containment Pressure indications sucddenly dropping to about atmospheric pressure.

A GENERAL EMERGENCY (GE) will be declared in the Fission Products Barriers Category (loss of all 3 barriers) when the Containment Pressure drops and on-site and off-site dose teams report rising dose levels. Additionally, Component Cooling Water rooimand Turbine Building Area Monitors will begin to alarm. An INITIAL PAR will be made based upon the Minimum PAR for a General Emergency to Evacuate Areas 1, 2 and 3.

Approximately 2 hrs. after the declaration of the GE, the cladding fault will worsen into multiple fuel element failures sufficient to ci-eaa significant radiation level in the containment. Containment High Range Radiation Monitors rise to -20,000 R/hr. This will cause an UPGRADE PAR to be developed for the entire EPZ based on Major Core Damage with a release in progress (Areas 1, 2, 3, 4, and 5).

The exercise will be terminated upon satisfying all the objectives for the DRILL.

-0745 Crew reports to Simulator Control Room to begin turnover.

-0800 Crew assumes responsibility for the watch.

-0805 Crew conducts reactivity briefing (Provide crew with reactivity briefing sheets).

-0806 A 150 gpm PCS leak will occur - exceeds ALERT criteria for FAl. Crew will trip the reactor. All 3 Charging pumps will be in service with lowering Pressurizer level.

Containment Gas Radiation Monitor RIA-1817 and Containment Sump fillrate rise.

-0810 Crew completes verbal communication of reactor trip response actions. The crew transitions to EOP-4.0, "LOCA Recovery", secures 'A' and 'D' PCPs; commences Emergency Boration and PCS cooldown.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant NLT 0821 The Shift Manager will declare an ALERT for PCS leak > 50 gpm in the Fission Product Barrier category (FA1, potential loss PCS #2).

-0823 Safety Injection (SI) actuates on Low Pressurizer Pressure; loss of 1-E Bus and LCC-77; TSC and OSC lose power. Service Water P-7C trips immediately on start signal and locks out 1 -D bus resulting in a loss of Safeguards Equipment powered from the 1 -D Bus.

This will result in HPSI P-66A loss of power and no operating HPSI pumps.

-0826 SM makes appropriate plant announcements and sounds Emergency Siren.

-0828 5 minutes after the Safety Injection Actuation Signal Primary Coolant Pump P-50D (or PCP P-50B if P-50D already secured) experiences a locked rotor and its breaker fails to open resulting in the loss of "Rear" Switchyard Bus (Station Transformer transferred to the Startup Transformer on the trip). The plant is in a Natural Circulation (NC) condition.

0828 Containment radiation levels begin to rise to 20R/hr over an approximate one (1) hour period as indicated on RIA-2321 and 1RIA-2322. They will promptly jumpto exceed 2000 R/hr at the end of that period. *1/2. \\*

0833 Control Room transitions to EOQP-9.0 "Functional Recovery Procedure" due to sustained loss of both HPSI pumps. :

-0835 Control Room briefs and dispatches an Auxiliary Operator (AO) to the Switchyard to investigate "Retr'-'Bus failure.

-0840 Control Room ti ask for Tech Support Center (TSC) assistance to restore HPSI P-66B as well as troubleshoot cause of 1-D bus lockout.

-0845 "E" Bus and LC77 are restored. Power is restored to the TSC and OSC.

-0858 Containment Isolation Signal actuates based on Containment High Radiation (2 out of 4 Containment Area Rad Monitors RIA-1805, 1806, 1807, 1808 > 10 R/hr)

-0910 TSC/OSC announce they are operational.

-0910 AO dispatched to the Switchyard reports back conditions.

-0915 EOF announces that they are operational. EOF Director assumes Command and Control.

-0916 Containment High Range Radiation Monitors RIA-2321 and 2322 will promptly jump to

-2500 R/hr - exceeds SAE criteria for FS1.

NLT 0931 Emergency Director (ED) or Site Emergency director (SED) declares a SITE AREA EMERGENCY (SAE) due to FS1, Loss of Fuel Cladding Barrier #5 (> 2000 R/hr) and Loss or Potential Loss of PCS Barrier #2 (PCS < 25F subcooled or PCS Leak Rate > 50 gpm).

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Palisades Nuclear Power Plant

-1056 The Containment Main Airlock catastrophically fails as evidenced by a noise heard in the Control Room (and by anyone in the vicinity, including the TSC) and Containment Pressure indications suddenly drop to about atmospheric pressure - exceeds GE criteria for FG1. (Message #6)

NLT 1111 ED declares a General Emergency. Initial PAR will be to evacuate Areas 1, 2, and 3 with the wind from 285'. The EOF Director calls the State Emergency Management Director in Lansing.

-1258 Containment High Range Radiation Monitors RIA-2321 and 2322 will promptly jump to

-20,000 R/hr indicating > 20% core damage. Met conditions change causing dose estimates to exceed PAGs at 5 miles. This will cause an Upgrade PAR to bedeveloped for the entire EPZ based on dose assessment indicating PAGs exceeded at 5 miles (Areas 1, 2, 3, 4, and 5). The PAG between 5 and 10 miles is exceeded for thyroid dose based on dose assessment.

-1313 EOF Director notifies the State Emergency Management Director of the Upgrade PAR.

--1330 Terminate/Critique 73

Unclassified Radiological Emergency Preparedness Program (REP)

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ML101830320

Text

SUMMARY

SUMMARY

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REFERENCE:

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