ML102360317

Transmittal of Final Report for Radiological Emergency Preparedness Ingestion Exercise Held on May 19-20, 2010

ML102360317
Person / Time
Site:	Salem, Hope Creek
Issue date:	08/16/2010
From:	Welch R US Dept of Homeland Security, Federal Emergency Management Agency
To:	Document Control Desk, Office of Nuclear Security and Incident Response
References
Download: ML102360317 (52)

Text

U.S. Department of Homeland Security One Independence Mall, Sixth Floor 615 Chestnut Street Philadelphia, PA 19106-4404

~FEMA AUG 1 6 2010 Nuclear Regulatory Commission Headquarters Office of Nuclear Security and Incident Response Document Control Desk U.S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Enclosed is the final report for the Salem/Hope Creek Nuclear Generating Stations (S/HCNGS)

Radiological Emergency Preparedness Ingestion Exercise that was held on May 19-20, 2010.

Based on the results of the exercise, the offsite radiological emergency response plans and preparedness for the State of Delaware and the affected local jurisdictions, site-specific to S/HCNGS are adequate to protect the public health and safety in the event of a radiological emergency at the Site.

If you have any questions, please contact Darrell Hammons at (215) 931-5546.

Sincerely, obert P. Welch Acting Regional Administrator Enclosure U ~5iUC~O I www.fema.gov

Salem/Hope Creek Nuclear Generating Stations After Action Report/

Improvement Plan Exercise Date - May 19, 2010 Radiological Emergency Preparedness (REP) Program Q FEMA Published August 09, 2010

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After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Salem/Hope Creek Nuclear Generating Stations After Action Report/Improvement Plan Contents Executive Summary 3

Section 1: Exercise Overview 5

1.1 Exercise Details 5

1.2 Exercise Planning Team Leadership 5

1.3 Participating Organizations 7

Section 2: Exercise Design Summary 8

2.1 Exercise Purpose and Design 8

2.2 Exercise Objectives, Capabilities and Activities 10 2.3 Scenario Summary 10 Section 3: Analysis of Capabilities 12 3.1 Exercise Evaluation and Results 12 3.2 Summary Results of Exercise Evaluation 12 3.3 Criteria Evaluation Summaries 14 3.3.1 Delaware Jurisdictions 14 3.3.1.1 Delaware Emergency Operations Center 14 3.3.1.2 Delaware Emergency Operations Center, Technical 14 Assessment Center 3.3.1.3 State. Field Sampling Team A 16 3.3.1.4 State Laboratory 16

.3.3.2 Risk Jurisdictions 17 3.3.2.1 Kent County Emergency Operations Center (I) 17 3.3.2.2 New Castle County Emergency Operations Center 17 (I) 3.3.2.13 Sussex County Emergency Operations Center (I) 17 Section 4: Conclusion 18 Appendix A: Exercise Timeline 19 Appendix B: Exercise Evaluators and Team Leaders 20 Appendix C: Exercise Plan 21 1

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After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations EXECUTIVE

SUMMARY

On May 19-20, 2010, an ingestion exercise was evaluated in the 50-mile exposure pathway, emergency planning zone (EPZ) around the Salem/Hope Creek Nuclear Generating Stations (S/HCNGS) by the Federal Emergency Management Agency (FEMA), Region III. On May 18, 2010, a full-scale exercise was evaluated in the 10-mile plume exposure pathway, emergency planning zone (EPZ) around the Salem/Hope Creek Nuclear Generating Stations (S/HCNGS) by the Federal Emergency Management Agency (FEMA), Region III. Out-of-sequence demonstrations were conducted on May 5-6, 2010. The purpose of the exercise and the out-of-sequence demonstrations was to assess the level of State and local preparedness in responding to a radiological emergency. The exercise and out-of-sequence demonstrations were held in accordance with FEMA's policies and guidance concerning the exercise of State and local radiological emergency response plans (RERP) and procedures.

The most recent prior full-scale exercise at this site was conducted on May 20, 2008.

FEMA wishes to acknowledge the efforts of the many individuals in the State of Delaware and the risk jurisdictions of Kent, New Castle and Sussex Counties who were evaluated at this exercise.

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

Cooperation and teamwork of all the participants were evident during this exercise.

This report contains the final evaluation of the Ingestion exercise and the evaluation of the.

following out-of-sequence activities:

The State of Delaware uses Teledyne Brown Laboratory in Knoxville, Tennessee as their primary laboratory for Ingestion Pathway Radiological analysis, a drill was conducted on May 27, 2010.

The State and local organizations demonstrated knowledge of their emergency response plans and procedures and adequately implemented them.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations demonstrated during the exercise. One new planning issue was identified and it was successfully resolved.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Salem/Hope Creek Nuclear Generating Stations Type of Exercise Ingestion Exercise Date May 19, 2010 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Janet Chomiszak Offsite Emergency Planner DEMA Planner IV 165 Brick Store Landing Road Smyrna, Delaware, 19977 302-659-2229 janet.chomiszak@state.de.us Tina Lai Project Officer FEMA RIIl Technological Hazards Program Specialist 615 Chestnut Street, 6th Floor 5

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportlimprovement Plan Salem/Hope Creek Nuclear Generating Stations Philadelphia, Pennsylvania, 19106 215-931-5680 tina.lai@dhs.gov Richard Kinard Backup Project Officer FEMA RIII Sr. Technological Hazards Program Specialist 615 Chestnut Street, 6th Floor Philadelphia, Pennsylvania, 19106 215-931-5558 richard.kinard@dhs.gov Martin Vyenielo Technical Team Leader FEMA Technological Hazards Program Specialist 615 Chestnut Street, 6th Floor Philadelphia, Pennsylvania, 19106 215-931-5670 martin.vyenielo@dhs.gov Reggie Rogers Scenario Reviewer ICF Consulting Technical Evaluator 9300 Lee Highway Fairfax, Virginia, 22031 860-992-3040 rodgersgroup@juno.com Steve Stasolla Scenario Developer 6

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations DEMA Offsite Emergency Planner 165 Brick Store Landing Road Smyrna, Delaware, 19977 302-659-3362 stasolla@comcast.net 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Salem/Hope Creek Nuclear Generating Stations exercise:

State Jurisdictions Delaware Emergency Management Agency Risk Jurisdictions Kent County Emergency Operation Center New Castle County Emergency Operation Center Support Jurisdictions Sussex County Emergency Operation Center 7

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations SECTION 2: EXERCISE DESIGN

SUMMARY

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

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

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

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

• Taking the lead in offsite emergency planning and in the review and evaluation of Radiological Emergency Response Plans (RERPs) and procedures developed by State and local governments;

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

- Responding to requests by the U.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between the NRC and FEMA dated June 17, 1993 (Federal Register, Vol. 58, No. 176, September 14, 1993); and 9 Coordinating the activities of the following Federal agencies with responsibilities in the radiological emergency planning process:

- U.S. Department of Commerce,

- U.S. Nuclear Regulatory Commission,

- U.S. Environmental Protection Agency, 8

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After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations

- U.S. Department of Energy,

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

- U.S. Department of Transportation,

- U.S. Department of Agriculture,

- U.S. Department of the Interior, and

- U.S. Food and Drug Administration.

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

A REP exercise was conducted on May 19-20, 2010, to assess the capabilities of State and local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving Salem/Hope Creek Nuclear Generating Stations (S/HCNGS). The purpose of this exercise report is to present the exercise results and findings on the performance of the off-site response organizations (OROs) during a simulated radiological emergency.

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

/

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

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

• 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 Guidance Memoranda MS-l, "Medical Services," November 1986;

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

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After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations

- 66 FR 47546, "FEMA Radiological Emergency Preparedness: Alert and Notification,"

September 12, 2001; and

- 67 FR 20580, "FEMA Radiological Emergency Preparedness: Exercise Evaluation Methodology," April 25, 2002.

Section 3 of this report, entitled "Analysis of Capabilities" presents basic information and data relevant to the exercise. This section of the report contains a Table 3.1 Summary of Exercise Evaluation and Summary Results of Exercise Evaluation. This section also contains the detailed information on the demonstration of applicable exercise evaluation areas at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format.

Section 4 of this report, entitled "Conclusion" This section also contains a summary of: (1) all Deficiencies and Areas Requiring Corrective Action (ARCAs) assessed during this exercise, recommended corrective actions, and the Tribal, State, and local governments' schedule of corrective actions for each identified exercise issue and (2) ARCAs assessed during previous exercises and resolved at this exercise, including the corrective action demonstrated, as well as ARCAs assessed during previous exercises and scheduled for demonstration at this exercise which remain unresolved.

The final section of the report is comprised of the appendices, which present the following supplementary information: Exercise Timeline, Exercise Evaluators and Team Leaders, and the Exercise Plan.

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations 2.3 Scenario Summary Summary of current conditions (8 am, May 19, 2010)

" Salem Nuclear Generating Station (SNGS) Unit 2 is shutdown and in a stable condition.

" The plume has dissipated and is no longer impacting the area.

" The Emergency Classification Level (ECL) remains at General Emergency.

" Salem Unit 1 and Hope Creek NGS continue to operate at full power.

" The evacuation for the State of Delaware has been fully implemented. The sheltering in place protective action was lifted overnight.

" Commercial and recreational access to the river remains restricted.

" Sampling teams from the State and the Department of Energy RAP teams are in the field monitoring ambient radiation levels and taking environment samples. Samples are being analyzed by DOE mobile labs, Teledyne-Browne and the State of Pennsylvania. High priority sample locations have been analyzed.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations 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 May 19-20, 2010 Ingestion Radiological Emergency Preparedness (REP) exercise. The exercise was held to test the offsite emergency response capabilities of local governments in the 50-mile Emergency Planning Zone (EPZ) surrounding the Salem/Hope Creek Nuclear Generating Stations. Each jurisdiction and functional entity was evaluated on the basis of its demonstration of the exercise evaluation area criteria contained in the REP Exercise Evaluation Methodology. Detailed information on the exercise evaluation area criteria are in the extent-of-play agreement used in this exercise.

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

3.2 Summary Results of Exercise Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of the exercise evaluation area criteria from the REP Exercise Evaluation Methodology that were scheduled for demonstration during this exercise by all participating jurisdictions and functional entities.

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

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

A ARCA(s) assessed D Deficiency P Plan Issue N Not Demonstrated 12

Unclassified Radiological Emergency Preparedness Program (REP)

Salem/Hope Creek Nuclear Generating Stations After Action Report/Improvement Plan Table 3.1 - Summary of Exercise Evaluation DATE: 2010-05-19 0 <

SITE: Salem/Hope Creek Nuclear Generating Stations, NJ U

0 U M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated W ;

w U U UX Emergency Operations Management Mobilization lal Facilities IbI M

Direction and Control Icl M

M M

M Communications Equipment Idl M

M Equip & Supplies to support operations lel M

M M

M M M

Protective Action Decision Making Emergency Worker Exposure Control 2al M

Radiological Assessment and PARs 2b 1 Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2c 1 Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl M

M Rad Assessment and Decision making concerning Relocation, Reentry, and Return 2e 1 M

M Protective Action Implementation Implementation of emergency worker exposure control 3al M M Implementation of KI decision 3b1 M

Implementation of protective actions for special populations - EOCs 3c 1 Implementation of protective actions for Schools 3c2 Implementation of traffic and access control 3d 1 Impediments to evacuation are identified and resolved 3d2 Implementation of ingestion pathway decisions - availability/use of info 3el M

M M

M Materials for Ingestion Pathway PADs are available 3e2 M

M M

M Implementation of relocation, re-entry, and return decisions.

3f1 M

M M

M Field Measurement and Analysis Adequate Equipment for Plume Phase Field Measurements 4al Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling 4b 1 M

Laboratory operations 4c1 M

Emergency Notification and Public Info Activation of the prompt alert and notification system 5a]

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

M Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6bI Temporary care of evacuees 6c 1 Transportation and treatment of contaminated injured individuals 6d I 13

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations 3.3 Criteria Evaluation Summaries 3.3.1 Delaware Jurisdictions 3.3.1.1 Delaware Emergency Operations Center

a.

MET: 1.c.1, 1.e.1, 2.d.1, 2.e.1, 3.e.1, 3.e.2, 3.f.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 3.3.1.2 Delaware Emergency Operations Center, Technical Assessment Center

a.

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

b. AREAS REQUIRING CORRECTIVE ACTION: 2.d.1.

ISSUE NO.: 02-10-2d1-A-02 CRITERION: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO planning criteria.

CONDITION: The precautionary protective action recommendation (PAR) for the temporary embargo of food products was not demonstrated using the National Atmospheric Release Advisory Center (NARAC) model projections of where the Food and Drug Administration Derived Intervention Levels (FDA DIL) would be exceeded and, in accordance with the extent of play agreement.

POSSIBLE CAUSE: At 0930 on Exercise Day 2, the Exercise Controller tasked the Technical Assessment Center (TAC-EOC) at the State EOC with preparing a Sampling Plan by 1100. This could have distracted the TAC-EOC from following their procedures and addressing the precautionary PAR for the temporary embargo of food products prior to sampling for deposition. They presented their Sampling Plan at 1130 based on the NARAC model projections of deposition. The exercise timeline was changed to Exercise Day 7. The temporary embargo of food products in the impacted area was not addressed.

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After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations

REFERENCE:

NUREG-0654, J.9, J. 11 SOP 303, Rev 5, October 2009 EFFECT: Delaying the temporary embargo of food products for days or weeks until samples are collected and analyzed would allow contaminated food produce to enter the food supply.

CORRECTIVE ACTION DEMONSTRATED: Corrective Action Demonstrated: At 1145 the TAC-EOC was tasked by the Director of the Delaware Emergency Management Agency (DEMA) with developing a temporary embargo of food products in the affected area. At 1205 the TAC-EOC presented their PAR that included putting milk and meat producing animals on stored feed and covered water, sheltering milk producing animals, delaying the distribution, sale or consumption of food products until monitoring can be accomplished, and uarantine of all food producing animals in the impacted area. The impacted area was shown on an attached map. At 1213 the Director of DEMA approved the PAR.

c.

DEFICIENCY: None

d. PLAN ISSUES: 2.d.1.

ISSUE NO.: 02-10-2dl-P-01 CRITERION: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO planning criteria.

CONDITION: The DE Radiological Emergency Plan Section 4, Rev. 7 "Concept of Operations" has some inconsistencies with the DE Radiological Emergency Standard Operating Procedures (SOPs). These inconsistencies are within the Ingestion Pathway Sections.

POSSIBLE CAUSE: Plan has not been updated in parallel with SOPs.

REFERENCE:

NUREG-0654, J.9, J. 11, DE REP Plan Section 4, Rev.7 15

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations EFFECT: Depending on whether the Plan or procedure is followed, significantly different Ingestion Pathway Relocation dose projections could result. This could extend the size of the restricted zone, which impacts the individuals that would be relocated.

CORRECTIVE ACTION DEMONSTRATED: DEMA Revised SOPs, Rev. 12, July 2010.

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.3 State Field Sampling Team A

a.

MET: 1.d.1, 1.e.1, 3.a.l, 3.b.1, 4.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 3.3.1.4 State Laboratory

a.

MET: L.e.l,3.a.l,4.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 16

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations 3.3.2 Risk Jurisdictions 3.3.2.1 Kent County Emergency Operations Center (I)

a.

MET: 1.c.1, 1.e.1,3.e.1, 3.e.2,3.f.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 3.3.2.2 New Castle County Emergency Operations Center (I)

a.

MET: 1.c.1, 1.e.l, 3.e.1,3.e.2,3.f.1.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.3 Sussex County Emergency Operations Center (I)

a.

MET: 1.b.1, 1.c.1, 1.d.1, 1.e.1, 3.e.1, 3.e.2, 3.fl.

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 17

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations SECTION 4: CONCLUSION The State of Delaware and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans andprocedures and adequately implemented them.

One Area Requiring Corrective Action (ARCA) was identified and was successfully re-demonstrated during the exercise. One new planning issue was identified and it was successfully resolved.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations APPENDIX A: EXERCISE TIMELINE Exercise Timeline not applicable to the Ingestion Exercise.

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Unclassified Radiological Emergency Preparedness Program (REP)

Salem/Hope Creek Nuclear Generating Stations After Action Report/Improvement Plan APPENDIX B: EXERCISE EVALUATORS AND TEAM LEADERS DATE: 2010-05-19, SITE: Salem/Hope Creek Nuclear Generating Stations, NJ LOCATION EVALUATOR AGENCY Delaware Emergency Operations Center Marcy Campbell ICF Roger Jobe ICF

• Richard Kinard FEMA RIII Bruce Swiren ICF Delaware Emergency Operations Center, Technical Assessment Reggie Rogers ICF Center

• Martin Vyenielo FEMA RII1 State Field Sampling Team A Stephen Chambers ICF State Laboratory

• Andrew Hower FEMA RIII Martin Vyenielo FEMA RIII Kent County Emergency Operations Center (I)

• Daniel Lerch FEMA RIII Kenneth Wierman FEMA HQ NP/REP New Castle County Emergency Operations Center (I)

Michael Shuler FEMA RII1

• Joseph Suders FEMA RIII Sussex County Emergency Operations Center (I)

• Andrew Hower FEMA RIII Richard Smith ICF Roy Smith ICF

• Team Leader 20

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations APPENDIX C: EXERCISE PLAN 21

Unclassified Radiological Emergency Preparedness Program (REP)

Salem/Hope Creek Nuclear Generating Stations After Action Report/Improvement Plan STATE OF DELAWARE EXERCISE CRITERIA AND EXTENT-OF-PLAY Salem Exercise May 2010 Revision 3 March 1, 2010 Approved Director, Delaware Emergency Management Agency / Date Real Life Emergencies Take Priority over Exercise Play 22

Unclassified Radiological Emergency Preparedness Program (REP)

Salem/Hope Creek Nuclear Generating Stations After Action Report/Improvement Plan Extent of Play - State of Delaware Salem Exercise - May 2010 TABLE OF CONTENTS IN T R O D U C T IO N.........................................................................................

.. 3 EVALUATION AREAS AND EXTENT OF PLAY Ingestion Exercise................. 5 23 Page 2 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 INTRODUCTION The purpose of this document is to establish those exercise evaluation areas and corresponding Extent-of-Play parameters expected to be demonstrated during the Salem Nuclear Power Plant graded exercise to be conducted on Mag 18, 19, and 20, 2010. The plume portion of the exercise will be conducted on May 18t and the Ingestion Pathway portion will be conducted on May 1 9th and 2 0 th.

As it is difficult to fully demonstrate both plume and ingestion objectives for both States with a single scenario, the scenarios for the Plume and Ingestion portions of the exercise will be disconnected. Also, the scenario for the ingestion portion of the exercise will be adjusted to allow the participating States (New Jersey and Delaware) to fully demonstrate their respective exercise objectives.

A simulated plume scenario will be produced to drive activities for the ingestion portion of the exercise.

As the objectives for the plume and ingestion portions are being demonstrated separately, the objectives and Extent of Play for the Ingestion Pathway portion of the exercise have been developed as a separate section of this document.

This exercise is being conducted in close cooperation with the State of New Jersey. The New Jersey Office of Emergency Management (NJOEM) will submit a separate set of evaluation objectives to FEMA Region II for consideration.

These evaluation areas have been developed through reviews of past exercises, associated plans and procedures, the proposed exercise scenario, applicable FEMA guidance documents, and extensive discussions with FEMA representatives.

All demonstrations will be conducted in accordance with established plans and procedures, except as indicated for specific exercise evaluation areas described herein.

There were no exercise issues for either the plume or ingestion phase that will require corrective action by the State of Delaware during this exercise.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 The following locations will be activated for this exercise State State Emergency Operations Center (EOC)

State Technical Assessment Center (TAC)

Emergency Operations Facility (EOF)

Emergency News Center (ENC)

Delaware National Guard (DNG) Field Teams County Jurisdictions New Castle County EOC Kent County EOC Sussex County EOC (Ingestion only)

Other Locations Teledyne-Brown (laboratory analysis) - Knoxville, TN 25 Page 4 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 INGESTION PATHWAY EXERCISE CRITERIA AND EXTENT-OF-PLAY The Ingestion Pathway portion of the Salem Exercise will be conducted on May 19 and 20, 2010.

The following extent of play outlines the Evaluation Areas and the expected activities for objectives related to the Plume Pathway. All activities will be demonstrated in accordance with established plans and procedures, except as indicated in the State of Delaware Extent of Play for each evaluation criterion.

The last evaluated ingestion pathway exercise that the State of Delaware participated in was in conjunction with the Calvert Cliffs site in 2003. There were no exercise issues noted during that exercise that will require corrective action by the State of Delaware during this exercise.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 Extent of Play by Evaluation Area The following evaluation areas, sub-elements and evaluation criterion are consistent with FEMA's exercise evaluation methods as reflected in the Interim REP Program Manual dated August 2002. Generic extent of play text from the REP Manual is quoted verbatim for each evaluation criterion and has been placed in italics. All activities will be demonstrated in accordance with established plans and procedures, except as indicated in the State of Delaware Extent of Play for each evaluation criterion.

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.b - Facilities Criterion 1.b.1: Facilities are sufficient to support the emergency response. (NUREG-0654, H)

Intent This sub-element is derived from NUREG-0654, which provides that OROs have facilities to support the emergency response.

Extent-Of-Play Facilities will only be specifically evaluated for this criterion if they are new or have substantial changes in structure or mission. Responsible ORO's should demonstrate the availability of facilities that support the accomplishment of emergency operations. Some of the areas to be considered are:

adequate space, fumishings, lighting, restrooms, ventilation, backup power and/or altemate facility (if required to support operations).

State of Delaware Extent of Play All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency.

Locations Evaluated Sussex County EOC - Baseline Outstanding Issues None 27 Page 6 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 EVALUATION AREA 1:- EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.c - Direction and Control:

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

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

Intent This sub-element is derived from NUREG-0654, which provides that OROs have the capability to control their overall response to an emergency.

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

State of Delaware Extent of Play:

All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency.

Locations evaluated:

State EOC, New Castle County EOC, Kent County EOC, Sussex County EOC Outstanding Issues None 28 Page 7 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.d - Communications Equipment Criterion 1.d.1: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations. (NUREG-0654, F.I., 2.)

Intent This sub-element is derived from NUREG-0654, which provides that OROs should establish reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as the following: appropriate contiguous governments within the emergency planning zone (EPZ), Federal emergency response organizations, the licensee and its facilities, emergency operations centers (EOC), and field teams.

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

The specific communications capabilities of OROs should be commensurate with that specified in the response plan and/or procedures. Exercise scenarios could require the failure of a communications system and the use of an alternate system.

State of Delaware Extent-of-Play All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency.

29 Page 8 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

Salem/Hope Creek Nuclear Generating Stations After Action Report/Improvement Plan Extent of Play - State of Delaware Salem Exercise - May 2010 Locations Evaluated Sussex County EOC State Ingestion Sampling Teams Outstanding Issues None 30 Page 9 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.e - Equipment and Supplies to Support Operations Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG-0654, H.,

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

Intent This sub-element is derived from NUREG-0654, which provides that OROs have emergency equipment and supplies adequate to support the emergency response.

Extent-Of-Play Equipment within the facility(ies) should be sufficient and consistent with the role assigned to that facility in the ORO's plans and/or procedures in support of emergency operations.

Use of maps and displays is encouraged.

All instruments, including air sampling flow meters (field teams only), should be inspected, inventoried, and operationally checked before each use. They should be calibrated in accordance with the manufacturer's recommendations (or at least annually for the unmodified CDV-700 series or if there are no manufacturer's recommendations for a specific instrument; modified CDV-700 instruments should be calibrated in accordance with the recommendation of the modification manufacturer.). A label indicating such calibration should be on each instrument or verifiable by other means. Note: Field team equipment is evaluated under 4. a. 1; radiological laboratory equipment under 4. c. 1; reception center and emergency worker facilities' equipment is evaluated under 6.a. 1; and ambulance and medical facilities' equipment is evaluated under 6.d. 1.

Sufficient quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers should be available for issuance to all categories of emergency workers that could be deployed from that facility. Appropriate direct-reading dosimeters should allow individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans and procedures. Dosimeters should be inspected for electrical leakage at least annually and replaced, if necessary. CDV-138s, due to their documented history of electrical leakage problems, should be inspected for electrical

-leakage at least quarterly and replaced if necessary. This leakage testing will be verified during the exercise, through documentation submitted in the Annual Letter of Certification, and/or through a staff assistance visit.

Responsible OROs should demonstrate the capability to maintain inventories of KI sufficient for use by emergency workers, as indicated 9g rosters; institutionalized individuals, as indicated in capacity lists for facilities; and, where stipulated by the plan and/or procedures, members of the general public (including transients) within the plume pathway EPZ.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 Quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical inspection at storage location(s) or through documentation of current inventory submitted during the exercise, provided in the Annual Letter of Certification submission, and/or verified during a Staff Assistance Visit. Available supplies of KI should be within the expiration date indicated on KI bottles or blister packs. As an alternative, the ORO may produce a letter from FEMA indicating that the KI supply remains potent, in accordance with Food and Drug Administration (FDA) guidance. FEMA issues these letters based upon the findings of the certified independent laboratory that performed the analysis at the ORO's request and expense.

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

State of Delaware Extent-of-Play All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency, except as indicated below.

Radiological Equipment verification is included with the Annual Letter of Certification (ALC) or information is available at all evaluated locations. Additionally, this information will be available for the evaluator(s).

Locations Evaluated State EOC New Castle County EOC Kent County EOC Sussex County EOC State Ingestion Sampling Teams Outstanding Issues:

None 32 Page 11 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.a - Emergency Worker Exposure Control Criterion 2.a.1: OROs use a decision-making process, considering relevant factors and appropriate coordination, to insure that an exposure control system, including the use of KI, is in place for emergency workers including provisions to authorize radiation exposure in excess of administrative limits or protective action guides.

(NUREG-0654, K.4.)

Intent This sub-element is derived from NUREG-0654, which provides that an ORO have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place as specified in the ORO's plans and procedures to authorize emergency worker exposure limits to be exceeded for specific missions.

Radiation exposure limits for emergency workers are the recommended accumulated dose limits or exposure rates that emergency workers may be permitted to incur during an emergency. These limits include any pre-established administrative reporting limits (that take into consideration Total Effective Dose Equivalent or organ-specific limits) identified in the ORO's plans and procedures.

Extent-Of-Play OROs authorized to send emergency workers into the plume exposure pathway EPZ should demonstrate a capability to meet the criterion based on their emergency plans and procedures. Responsible OROs should demonstrate the capability to make decisions conceming the authorization of exposure levels in excess of pre-authorized levels and to the number of emergency workers receiving radiation dose above pre-authorized levels. As appropriate, OROs should demonstrate the capability to make decisions on the distribution and administration of KI, as a protective measure, based on the ORO's plan and/or procedures or projected thyroid dose compared with the established protective action guides (PAGs) for KI administration.

State of Delaware Extent-of-Play All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency except as indicated below.

The taking of KI by emergency workers will be simulated.

33 Page 12 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 Location Evaluated State EOC Technical Assessment Center Outstanding Issues None 34 Page 13 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.d - Radiological Assessment & Decision Making for Ingestion Exposure Criterion 2.d.1: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO planning criteria. (NUREG-0645 1.8. J.11.)

Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (OROs) have the means to assess the radiological consequences for the ingestion exposure pathway, relate them to the appropriate PAGs, and make timely, appropriate protective action decisions to mitigate exposure from the ingestion pathway.

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

Extent-Of-Play It is expected that the Offsite Response Organizations (ORO's) will take precautionary actions to protect food and water supplies, or to minimize exposure to potentially contaminated water and food, in accordance with their respective plans and procedures.

Often such precautionary actions are initiated by the ORO's based on criteria related to the facility's Emergency Classification Levels (ECL). Such actions may include recommendations to place milk animals on stored feed and to use protected water supplies.

The ORO should use its procedures (for example, development of a sampling plan) to assess the radiological consequences of a release on the food and water supplies. The ORO's assessment should include the evaluation of the radiological analyses of representative samples of water, food, and other ingestible substances of local interest from potentially impacted areas, the characterization of the releases from the facility, and the extent of areas potentially impacted by the release. During this assessment, ORO's should consider the use of agricultural and watershed data within the 50-mile EPZ. The radiological impacts on the food and water should then be compared to the appropriate ingestion PAGs contained in the ORO's plan and/or procedures. (The plan and/or procedures may contain PAGs based on specific dose commitment criteria or based on criteria as recommended by current Food and Drug Administration guidance.) Timely and appropriate recommendations should be provided to the ORO decision-makers group for implementation decisions. As time permits, the ORO may also include a cc3parison of taking or not taking a given action on the resultant ingestion pathway dose commitments.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek NuclearGenerating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 The ORO should demonstrate timely decisions to minimize radiological impacts from the ingestion pathway, based on the given assessments and other information available. Any

.such decisions should be communicated and, to the extent practical, coordinated with neighboring and local ORO's. ORO's should use Federal resources, as identified in the Federal Radiological Emergency Response Plan (FRERP), and other resources (e.g.,

compacts, nuclear insurers, etc.), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating.

State of Delaware Extent of Play All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency.

Location Evaluated State EOC, Technical Assessment Center Outstanding Issues None 36 Page 15 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.e. - Radiological Assessment & Decision Making for Radiological Assessment and Decision Making for Relocation, Return, & Re-entry Criterion 2.e.1: Timely relocation, re-entry, and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the ORO's plans and procedures. (NUREG-0654, A. l.b. I.1O.,M)

Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (OROs) have the capability to make decisions on relocation, Reentry, and return of the general public. These decisions are essential for the protection of the public from the direct long-term exposure to deposited radioactive materials from a severe accident at a nuclear power plant.

Extent-Of-Play Relocation: ORO's should demonstrate the capability to estimate integrated dose in contaminated areas and to compare these estimates with PAGs, apply decision criteria for relocation of those individuals in the general public who have not been evacuated but where projected doses are in excess of relocation PAGs, and control access to evacuated and restricted areas. Decisions are made for relocating members of the evacuated public who lived in areas that now have residual radiation levels in excess of the PAGs. Determination of areas to be restricted should be based on factors such as the mix of radionuclides in deposited materials, calculated exposure rates vs. the PAGs, and field samples of vegetation and soil analyses.

Reentry: Decisions should be made regarding the location of control points and policies regarding access and exposure control for emergency workers and members of the general public who need to temporarily enter the evacuated area to perform specific tasks or missions. Examples of control procedures are: the assignment of, or checking for, direct-reading and non-direct-reading dosimetry for emergency workers; questions regarding the individual's objectives and locations expected to be visited and associated time frames; availability of maps and plots of radiation exposure rates; advice on areas to avoid; and procedures for exit including: monitoring of individuals, vehicles, and equipment; decision criteria regarding decontamination; and proper disposition of emergency worker dosimetry and maintenance of emergency worker radiation exposure records. Responsible ORO's should demonstrate the capability to develop a strategy for authorized Reentry of individuals into the restricted zone, based on established decision criteria.

37 ORO's should demonstrate the capability to modify those policies for security purposes (e.g., police patrols), for maintenance of essential services (e.g., fire protection and Page 16 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 utilities), and for other critical functions. They should demonstrate the capability to use decision making criteria in allowing access to the restricted zone by the public for various reasons, such as to maintain property (e.g., to care for farm animals or secure machinery for storage), or to retrieve important possessions. Coordinated policies for access and exposure control should be developed among all agencies with roles to perform in the restricted zone. ORO's should demonstrate the capability to establish policies for provision of dosimetry to all individuals allowed to re-enter the restricted zone. The extent that ORO's need to develop policies on Reentry will be determined by scenario events.

Return: Decisions are to be based on environmental data and political boundaries or physical/geological features, which allow identification of the boundaries of areas to which members of the general public may return. Return is permitted to the boundary of the restricted area that is based on the relocation PAG. Other factors that the ORO should consider are, for example: conditions that permit the cancellation of the Emergency Classification Level and the relaxation of associated restrictive measures; basing return recommendations (i.e., permitting populations that were previously evacuated to reoccupy their homes and businesses on an unrestricted basis) on measurements of radiation from ground deposition; and the capability to identify services and facilities that require restoration within a few days and to identify the procedures and resources for their restoration. Examples of these services and facilities are: medical and social services, utilities, roads, schools, and intermediate term housing for relocated persons.

State of Delaware Extent of Play All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency.

Locations Evaluated State EOC, Technical Assessment Center Outstanding Issues None 38 Page 17 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.e - Implementation of Ingestion Pathway Decisions Criterion 3.e.1 The ORO demonstrates the availability and appropriate use of adequate information regarding water, food, supplies, milk, and agricultural production within the ingestion exposure pathway emergency-planning zone for implementation of protective actions.

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

Extent-Of-Play Applicable ORO's should demonstrate the capability to secure and utilize current information on the locations of dairy farms, meat and poultry producers, fisheries, fruit growers, vegetable growers, grain producers, food processing plants, and water supply intake points to implement protective actions within the ingestion pathway EPZ. ORO's should use Federal resources as identified in the FRERP, and other resources (e.g.,

compacts, nuclear insurers, etc.), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

State of Delaware Extent of Play All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency.

Locations Evaluated Technical Assessment Center, State EOC, New Castle County EOC, Kent County EOC, Sussex County EOC Outstanding Issues None 39 Page 18 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.e - Implementation of Ingestion Pathway Decisions 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.

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

Extent-Of-Play Development of measures and strategies for implementation of IPZ protective actions should be demonstrated by formulation of protective action information for the general public and food producers and processors. This includes either pre-distributed public information material in the IPZ or the capability for the rapid reproduction and distribution of appropriate reproduction-ready information and instructions to pre-determined individuals and businesses. ORO's should demonstrate the capability to control, restrict or prevent distribution of contaminated food by commercial sectors.

Exercise play should include demonstration of communications and coordination between organizations to implement protective actions. Actual field play of implementation activities may be simulated. For example, communications and coordination with agencies responsible for enforcing food controls within the IPZ should be demonstrated, but actual communications with food producers and processors may be simulated.

State of Delaware Extent of Play All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency.

Locations Evaluated State EOC, New Castle County EOC, Kent County EOC, Sussex County EOC Outstanding Issues 40 None Page 19 of 27

Unclassified RadiologicalEmergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-Element 3.f-lmplementation of Relocation, Reentry, and Return Decisions Criterion 3.f.1: Decisions regarding controlled Reentry of emergency workers and relocation and return of the public are coordinated with appropriate organizations and implemented. (NUREG-0654, M.1, 3)

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

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

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

Reentry: ORO's should demonstrate the capability to control Reentry and exit of individuals who need to temporarily re-enter the restricted area, to protect them from unnecessary radiation exposure and for exit of vehicles and other equipment to control the spread of contamination outside the restricted area. Monitoring and decontamination facilities will be established as appropriate. Examples of control procedure subjects are: (1) The assignment of, or checking for, direct-reading and non-direct-reading dosimetry for emergency workers; (2) questions regarding the individuals' objectives and locations expected to be visited and associated timeframes; (3) maps and plots of radiation exposure rates; (4) advice on areas to avoid; and procedures for exit, including monitoring of individuals, vehicles, and equipment, decisio411criteria regarding contamination, proper disposition of emergency worker dosimetry, and maintenance of emergency worker radiation exposure records.

Page 20 of 27

Unclassified Radiological Emefgency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 Return: ORO's should demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase. ORO's should demonstrate the capability to identify and prioritize services and facilities that require restoration within a few days, and to identify the procedures and resources for their restoration. Examples of these services and facilities are medical and social services, utilities, roads, schools, and intermediate term housing for relocated persons.

Communications among ORO's for relocation, Reentry, and return may be simulated; however all simulated or actual contacts should be documented. These discussions may be accomplished in a group setting. ORO's should use Federal resources as identified in the FRERP, and other resources (e.g., compacts, nuclear insurers, etc.), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

State of Delaware Extent of Play All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency.

Locations Evaluated State EOC Technical Assessment Center New Castle County EOC Kent County EOC Sussex County EOC Outstanding Issues None 42 Page 21 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS Sub-element 4.b - Post Plume Phase, Field Measurements & Sampling Criterion 4.b.1 The field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making.

Intent This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to assess the actual or potential magnitude and locations of radiological hazards in the IPZ and for relocation, Reentry and return measures. This sub-element focuses on the collection of environmental samples for laboratory analyses that are essential for decisions on protection of the public from contaminated food and water and direct radiation from deposited materials.

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

Ingestion pathway samples should be secured from agricultural products and water.

Samples in support of relocation and return should be secured from soil, vegetation, and other surfaces in areas that received radioactive ground deposition. ORO's should use Federal resources as identified in the FRERP, and other resources (for example, compacts, utility, nuclear insurers, etc.), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

State of Delaware Extent of Play All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency except as indicated below.

A single sampling team will be evaluated by FEMA. This will be demonstrated out-of-sequence on May 19, 2010.

43 Page 22 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 Communications from the EOC to the sampling team will be simulated. Sampling location(s) will be determined in advance and may not coincide with the footprint of the plume. The team will collect one or more samples based on the crops in the field at the time [soil, water, milk, leafy vegetation, crops]. Sample transport to the analysis lab will be simulated.

If required sampling team will demonstrate donning anti-contamination equipment, but will not wear them during sample collection.

Locations Evaluated State Ingestion Sampling Team Outstanding Issues None 44 Page 23 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS Sub-element 4.c - Laboratory Operations Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions.

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

Extent-Of-Play The laboratory staff should demonstrate the capability to follow appropriate procedures for receiving samples, including logging of information, preventing contamination of the laboratory, preventing buildup of background radiation due to stored samples, preventing cross contamination of samples, preserving samples that may spoil (for example, milk),

and keeping track of sample identity. In addition, the laboratory staff should demonstrate the capability to prepare samples for conducting measurements. The laboratory should be appropriately equipped to provide analyses of media, as requested, on a timely basis, of sufficient quality and sensitivity to support assessments and decisions as anticipated by the ORO's plans and procedures. The laboratory (laboratories) instrument calibrations should be traceable to standards provided by the National Institute of Standards and Technology. Laboratory methods used to analyze typical radionuclides released in a reactor incident should be as described in the plans and procedures. New or revised methods may be used to analyze atypical radionuclide releases (for example, transuranics or as a result of a terrorist event) or if warranted by circumstances of the event. Analysis may require resources beyond those of the ORO. The laboratory staff should be qualified in radioanalytical techniques and contamination control procedures.

ORO's should use Federal resources as identified in the FRERP, and other resources (for example, compacts, utility, nuclear insurers, etc.), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

State of Delaware Extent of Play All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency.

45 Page 24 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

Salem/Hope Creek Nuclear Generating Stations After Action Report/Improvement Plan Extent of Play - State of Delaware Salem Exercise - May 2010 Location Evaluated Teledyne-Brown Outstanding Issues None 46 Page 25 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 EVALUATION AREA 5 - EMERGENCY INFORMATION AND PUBLIC NOTIFICATION Sub-element5.b - Emergency Information and Instructions for the Public and the Media Criterion 5.b.1: ORO's provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E.5.7. G.3.a.,

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

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

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

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

Page 26 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Salem/Hope Creek Nuclear Generating Stations Extent of Play - State of Delaware Salem Exercise - May 2010 The emergency information should be all-inclusive by including previously identified protective action areas that are still valid, as well as new areas. The ORO's should demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. In addition, the ORO's should demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plan and/or procedures. ORO's should demonstrate the capability to develop emergency information in a non-English language when required by the plan and/or procedures.

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

ORO's should demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public.

This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the situation warrants. The ORO's should demonstrate the capability to respond appropriately to inquiries from the news media. All information presented in media briefings and media releases should be consistent with protective action decisions and other emergency information provided to the public.

Copies of pertinent emergency information (for example, Emergency Alert System [EAS]

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

State of Delaware Extent of Play All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency.

Location Evaluated State EOC Outstanding Issues None 48 Page 27 of 27

Unclassified Radiological Emergency Preparedness Program (REP)

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