ML11223A279

Transmittal of the Final Report for the Pilgrim Nuclear Power Station Plume and Ingestion Exercise That Was Conducted on November 16-17, 2010

ML11223A279
Person / Time
Site:	Pilgrim
Issue date:	02/01/2011
From:	Boyce D Federal Emergency Management Agency, US Dept of Homeland Security
To:	Dean B Region 1 Administrator
References
Download: ML11223A279 (115)

Text

U.S. Department of Homeland Security FEMA Region I 99 High St., 5'h Floor Boston, MA 02110-2320

~FEMA February 1,.2011 Bill Dean Regional Administrator U.S. NRC Region I 475 Allendale Road King of Prussia, PA 19406-1415

Dear Mr. Dean:

Enclosed find a copy of the Final Report for the Pilgrim Nuclear Power Station Plume and Ingestion Exercise that was conducted on November 16-17, 2010.

The Commonwealth of Massachusetts, State of Rhode Island, and local emergency response organizations successfully demonstrated their capabilities to implement off-site radiological emergency response plans and procedures based on the evaluation by the Regional Assistance Committee and a team of Federal evaluators. There were no deficiencies, three Areas Requiring Corrective Action (ARCA's), and one Planning Issue identified during the exercise. All ARCA's from the previous exercise were resolved.

State and local preparedness remains adequate to protect the health and safety of the public living in the vicinity of the Pilgrim Nuclear Power Station and provides reasonable assurance that appropriate measures can be taken off-site in the event of a radiological emergency.

www.fema.gov

Mr. Dean February 1, 2011 Page 2 If you have any questions or concerns, please contact Steve Colman, Regional Assistance Committee Chair at (617) 832-4731, or Taneeka Hollins, Pilgrim Site Specialist, at (617) 956-7523.

Sincerely, Don R. Boyce Regional Administrator DRB:th cc:

NRC Headquarters Document Control Desk Marc Dapas, Deputy Regional Administrator Brian McDermott, Director, NRC Division of Preparedness and Response James Wiggins, Director, NRC Office of Nuclear Security and Incident Response Robert Kahler, Chief, NRC Inspection and Regulatory Improvements Branch Nancy McNamara, NRC Region I Liaison Vanessa Quinn, Branch Chief, FEMA REP HQ Rebecca Fontenot, Regional Project Officer, FEMA REP HQ Enclosure

Pilgrim Nuclear Power Station After Action Report/

Improvement Plan Exercise Date - November 17, 2010 Radiological Emergency Preparedness (REP) Program aFEMA Published January 26, 2011

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Pilgrim Nuclear Power Station After Action Report/Improvement Plan Published January 26, 2011 Contents Executive Summary 5

Section 1: Exercise Overview 7

1.1 Exercise Details 7

1.2 Exercise Planning Team Leadership 7

1.3 Participating Organizations 8

Section 2: Exercise Design Summary 13 2.1 Exercise Purpose and Design 13 2.2 Exercise Objectives, Capabilities and Activities 14 2.3 Scenario Summary 14 Section 3: Analysis of Capabilities 15 3.1 Exercise Evaluation and Results 15 3.2 Summary Results of Exercise Evaluation 15 3.3 Criteria Evaluation Summaries 22 3.3.1 Massachusetts Jurisdictions 22 3.3.1.1 Massachusetts State Emergency Operations Center 22 3.3.1.2 MA 211 Center 24 3.3.1.3 MA Region II EOC 24 3.3.1.4 MA (PNPS) Emergency Operations Facility 24 3.3.1.5 MA (PNPS) Field Monitoring Team-i 25 3.3.1.6 MA (PNPS) Field Motoring Team-2 25 3.3.1.7 MA (PNPS) Joint Information Center 25 3.3.2 Risk Jurisdictions 25 3.3.2.1 Carver Local EOC 25 3.3.2.2 Duxbury Local EOC 26 3.3.2.3 Kingston MA Local EOC 27 3.3.2.4 Marshfield Local EOC 29 1

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Ihnprovemnent Plan Pilgrim Nuclear Power Station 3.3.2.5 Plymouth Local EOC 29 3.3.2.6 Bay Path Nursing Home 30 3.3.2.7 Bright Ideas Preschool 30 3.3.2.8 Berry Brook Preschool 30 3.3.2.9 Camp Clark 30 3.3.2.10 Discover Comer Daycare 31 3.3.2.11 Hedge Elementary School 31 3.3.2.12 Indian Brook Elementary School 31 3.3.2.13 Manomet Elementary School 31 3.3.2.14 Newfield House 32 3.3.2.15 Mt. Pleasant Elementary School 32 3.3.2.16 Pilgrim Childcare and Preschool 32 3.3.2.17 Pilgrim's Hope 32 3.3.2.18 West Elementary School 33 3.3.2.19 Sacred Heart High School 33 3.3.2.20 Sacred Heart Elementary School 33 3.3.2.21 Sacred Heart Early Childhood Center 33 3.3.2.22 Radius Health Care 34 3.3.2.23 Providence House 34 3.3.2.24 Plymouth North High School 34 3.3.2.25 Plymouth Community Intermediate School 34 3.3.2.26 Life Care Center 35 3.3.3 Support Jurisdictions 35 3.3.3.1 Braintree Local EOC 35 3.3.3.2 Bridgewater Local EOC 35 3.3.3.3 Taunton LocalEOC 35 3.3.3.4 American Medical Response Ambulance Company 36 3.3.3.5 Caritas Good Samaritan Medical Center 36 3.3.4 Rhode Island Jurisdictions 36 3.3.4.1 RI State Emergency Operations Center 36 3.3.4.2 RI Field Sampling Team-1 36 3.3.4.3 RI Field Sampling Team-2 37 2

Unclassified Radiological Emergency Preparedness Program (REP)

After-Action Report/inprovement Plan Pilgrim Nuclear Power Station 3.3.4.4 RI Field Sampling Team-3 39 3.3.4.5 RI Joint Information Center 40 Section 4: Conclusion 41 Appendix A: Improvement Plan 42 Appendix B: Exercise Timeline 45 Appendix C: Exercise Evaluators and Team Leaders 47 Appendix D: Exercise Plan 50 Appendix E: Ma Extent of Play 60 3

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After Action Report/linprovement Plan Pilgrim Nuclear.Power Station EXECUTIVE

SUMMARY

On November 16 & 17, 2010 a full-scale plume/ingestion exercise was conducted in the 10-miile plume and the 50-mile ingestion exposure pathway, emergency planning zone (EPZ) around the Pilgrim Nuclear Power Station (PNPS) by the Federal Emergency Manage: mn-t A genc,'

(FEMA), Region I. Out-of-sequence demonstrations of local schools, daycares, Medical Service (MS-I) Hospitals and special facilities were conducted on various dates from August through December, 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 April 2, 2008. The qualifying emergency preparedness exercise was conducted on March 3, 1982.

FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Massachusetts; the Massachusetts risk jurisdictions of Carver, Duxbury, Kingston, Marshfield, and Plymouth; the host jurisdictions of Bridgewater and Braintree; and the State of Rhode Island who were evaluated at this exercise. The various agencies, organizations, and units of government from these State and local jurisdictions who participated in this exercise are listed in Section III of this report.

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 biennial exercise and the evaluation of the following out-of-sequence activities:

" Duxbury schools and day care centers

" Kingston schools, day care centers, and special facilities 5

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reporl/ltnprovement Plan Pilgrim Nuclear Power Station

" Plymouth schools, day care centers, and special facilities

• Caritas Good Samaritan Medical Center-MS-:i Hospital The State and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. As.a result of this exercise, there were no Deficiencies identified, two Areas Requiring Corrective Action (ARCAs) in Massachusetts, and one ARCA and Planning Issue in Rhode Island. There were also four ARCA's in MA from the previous exercise which were successfully re-demonstrated.

6

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear-Power Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Pilgrim Nuclear Power Station Type of Exercise Ingestion Exercise Date November 17, 2010 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Taneeka Hollins Site Specialist FEMA Region One Tech Hazards Specialist 99 High Street, Fifth Floor Boston, Massachusetts, 02110 617-956-7523 Taneeka.Hollins@dhs.gov John Giarusso Tech Hazards Specialist/Planning Manager Massachusetts Emergency Management Agency Planning and Preparedness Division Manager 400 Worcester Road 7

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Framingham, Massachusetts, 01702 508-820-2040 John.Giarusso@state.ma.us Paul D'Abbraccio Rhode Island Exercise Planner Rhode Island Emergency Management. Agency State Radiological Safety Officer 645 New London Avenue Cranston, Rhode Island, 02920 401-751-1,516 PDAbbraccio@gov.state.ri.us Fran DeNicola Lead Planner MEMA MEMA State Planner 400 Worcester Rd Framingham, Massachusetts, 01702 508-820-2049 Fran.Denicola@state.ma.us 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Pilgrim Nuclear Power Station exercise:

State Jurisdictions Commonwealth of Massachusetts Mass Correction Institute-Plymouth Massachusetts Department of Agricultural Resources Massachusetts Department of Corrections (DOC)

Massachusetts Department of Environmental Protection Massachusetts Department of Fish and Game, Division of Fisheries and Wildlife 8

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Massachusetts Department of Mental Health (MDMH)

Massachusetts Department of Public Health (MDPH)

Massachusetts Department of Public Health (MDPH), Radiation Control Program Massachusetts Department of Transportation (Mass DOT)

Massachusetts Emergency Management Agency (MEMA)

Massachusetts Executive Office of Public Safety Massachusetts National Guard (MNG)

Massachusetts State Police (MSP)

Office of the Secretary of the Commonwealth of Massachusetts State of.Rhode Island Rhode Island Department of Environmental Management (DEM)

Rhode Island Department of Health Food Health Davison Rhode Island Department of Health, Water Quality Division Rhode Island Department of Health (RIDH)

Rhode Island Emergency Management Agency (RIEMA)

Rhode Island Governor's Office Rhode Island National Guard Rhode Island National Guard 13th - Civil Support Team Rhode Island State Police (RISP)

Risk Jurisdictions Carver Council on Aging Carver Department of Public Works Carver Emergency Management Agency Carver Emergency Medical Services Carver Fire Department Carver Police Department Carver School District Carver Selectman Carver Town Clerk's Office Duxbury Council on Aging Duxbury Emergency Management Duxbury Emergency Medical Services Duxbury Fire Department Duxbury Police Department 9

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reporl/Improvement Plan Pilgrim Nuclear Power Station Duxbury Public Information Duxbury Public Works Department Duxbury School Department Duxbury Selectmen Duxbury Shelters Duxbury Town Administrator Kingston Board of Selectmen Kingston Emergency Management Kingston Fire Kingston Police Kingston Streets, Trees and Parks Kingston, Silver Lake School District Marshfield Board of Health Marshfield Board of Selectmen Marshfield Council on Aging Marshfield Emergency Management Agency Marshfield Fire Marshfield Harbormaster Marshfield Police Marshfield Public Schools Marshfield Public Works Marshfield Sheriffs Department Marshfield Town Administrator Marshfield Transportation Plymouth Board.of Health Plymouth Board of Selectmen Plymouth Communications Plymouth County Sheriffs Department Plymouth Department of Public Works Plymouth Emergency Management Agency Plymouth Fire Department Plymouth Harbor Master Plymouth Police Department Plymouth Public Information 10

Unclassified Radiological Emnergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Plymouth Radiological Officer Plymouth School Department Plymouth Shelters Plymouth Special Needs Plymouth Special Populations Plymouth Town Manager Plymouth Transportation Support Jurisdictions Braintree Department of Public Works Braintree Emergency Management Agency Braintree Mayor's Office Braintree Police Department Braintree School District Bridgewater Fire Department Bridgewater Health Department Bridgewater Highway Department Bridgewater Police Department Bridgewater Selectmen Bridgewater State University American Medical Response (AMR) Company Caritas Good Samartian Medical Center Private Organizations Braintree American Red Cross (ARC)

Braintree Radio Amateur Civil Emergency Service (RACES).

Carver Radio Amateur Civil Emergency Service (RACES)

Duxbury Radio Amateur Civil Emergency Service (RACES)

Entergy, Pilgrim Nuclear Power Station Marshfield Radio Amateur Civil Emergency Service (RACES)

Mass 2-1-1 Massachusetts Bay Chapter American Red Cross (ARC)

Massasoit Radio Amateur Civil Emergency Service (RACES)

Plymouth Radio Amateur Civil Emergency Service (RACES)

United Way Federal Jurisdictions 11

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Federal Emergency Management Agency (FEMA)

Federal Radiological Monitoring & Assessment Center (FRMAC) Advance Party

-Federal. Radiological Monitoring & Assessment Center (FRMAC) Advisory Team United State Coast Guard (USCG) 12

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise Purpose and Design DESIGN:

The 2010 Pilgrim Graded Ingestion Exercise is a full-scale exercise (FSE) designed to establish a learning environment for players to exercise emergency response plans, policies, and procedures as they pertain to Nuclear Power Plant accidents. An FSE is a complex event that requires detailed planning. To conduct an effective exercise, subject matter experts (SMEs) and local representatives from numerous agencies havetaken part in the planning process and Will take part in exercise conduct and evaluation.

This Exercise Plan (ExPlan) was produced at the direction of the MEMA and RIEMA with the input, advice, and assistance of the EPTI The 2010 Pilgrim Graded Ingestion Exercise is evidence of the growing partnership between State and local jurisdictions for response to the' threats our Nation and communities face.

PURPOSE:

The purpose of this exercise is to evaluate player actions against current response plans and capabilities for a nuclear power plant-related incident, and to comply with the requirements of 44 CFR 350 and the guidelines of NUREG 0654/FEMA-REP-1. Exercise planners utilized the elements described in the 67 FR 20580 (April 25, 2002) and Interim Radiological Emergency Preparedness(REP) Program Manual (August 2002) to develop this exercise.

The objective of MEMA, RIEMA, and Entergy is to demonstrate reasonable assurance that the public can be protected during a nuclear power plant emergency.

13

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station 2.2 Exercise Objectives, Capabilities and Activities Target Capabilities:

The establishment of the National Preparedness Priorities have steered the focus of homeland security toward a capabilities-based planning approach. Capabilities-based planning focuses on planning under uncertainty, since the next danger or disaster can never be forecast with complete accuracy. Therefore, capabilities-based planning takes an all-hazards approach to planning and preparation which builds capabilities that can be applied to a wide variety of incidents. States and Urban Areas use capabilities-based planning to identify a baseline assessment of their homeland security efforts by comparing their current capabilities against the Target Capabilities List (TCL) and the critical tasks of the Universal Task List (UTL). This approach identifies gaps in current capabilities and focuses efforts on identifying and developing priority capabilities and tasks for the jurisdiction. These priority capabilities are articulated in the jurisdiction's homeland security strategy and Multi-Year Training-and Exercise Plan (TEP).

The capabilities listed below have been selected by the EPT planning team for demonstration during the exercise. These capabilities provide the foundation for development of the exercise objectives and scenario, as the purpose of this exercise is to measure and validate performance of these capabilities and their associated critical tasks. However, the UTL and TCL does not replace the NUR-EG-0654 evaluation criteria which are used to evaluate off-site response capabilities.

" Emergency Operations Center Management

" Emergency Public Information and Warning

" Weapons of Mass Destruction (WMD) and Hazardous Materials (HazMat) Response and Decontamination

" Emergency Triage and Pre-Hospital Treatment

• Citizen Evacuation and Shelter-in-Place 2.3 Scenario Summary The exercise scenario was developed to evaluate the response of the exercise participants to a radiological emergency.

The scenario is included in Appendix D, Exercise Plan.

14

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results 3.2 Summary Results of Exercise Evaluation 15

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Table 3.1 - Summary of Exercise Evaluation (4 pages)

-DATE2010-11-17

'W U

SITE: Pilgrim Nuclear Power Station, MA U

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

Demonstrated

-Einr'gen4Operations Managemet

--AIL

~

~I 4-'~~

.~

Mobilization lal M

M M

M M M M M M MM Facilities Ilbl Direction and Control 1ei M M M M M A M MT Communications Equipment Idl M M M M M M M M M M M Equip& Supplies to support operations lei MIM M M M M M M M M M Emergency Worker Exposure Control 2al M

Radiological Assessment and PARs 2bl M

M Decisions for the Plume Phase -PADs 2b2 M PADs for protection of special populations 2cl M

M Rad Assessment and Decision making for the Ingestion Exposure Pathway 2dl M

Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Implementati6n of emergency worker exposure control 3al I M M M" M M M M M Implementation ofKl decision 3bl M M M M M M M M M Implementation of protective actions for special populations -EOCs 3cl M

M M M M M Implementation of protective actions for Schools 3c2 M

M M M M Implementation of traffic and access control 3d]

M M M M M Impediments to evacuation are identified and resolved 3d2 M M M M M Implementation of ingestion pathway decisions - availability/use of info 3el M

Materials for Ingestion Pathway PADs are available 3c2 M

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

3171 M L Zl,,,.,

.and

ýA*,aly"sit.

2

'* P; Adequate Equipment for Plume Phase Field Measurements 4al M M Field Teams obtain sufficient information

.4a2 NM M M Field Tearns Manage Sample Collection Appropriately 4a3 M M Post plume phase field measurements and samplin;g 4bl M M Laboratory operations 4cl.-

,Activation o f the prompt alert and notification system 5al M

M M M M SActivation 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 A M.

M M M M M Emergency Worker Monitoring/Decontamination 6

Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6bl Temporary care of evacuees 6cl Transportation and treatment of contaminated injured individuals 6di 16

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 2/4)

'5 DATE: 2010-11-17 SITE: Pilgrim Nuclear Power Station, MA U

U U

U 0

M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not 0

Demonstrated E

.E W

0 (A(

Mobilization...

al M

M M M

,M M

M Facilities M

I M

Direction and Control

.1l M M_ M M

M Communications.Equipment "d]

M M M

, M M M M

Equip & Supplies to support operations

.lel M MM M

M.P M M M Emergency Worker Exposure Control 2a1

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

Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return:

Impleinientation of emergency worker exposure control 3al M,

I

.M M M I

M Implemnentation of KI decision 3bl M

Implementation of protective actions for special populations - EOCs 3cl M M M Implemenitation of protective actions for Schools 3c2 M

Implementation of traffic and access control....

3dl M M M

• M..

lmpediments.to evacuation-are identified and resolved.

3d2 M M,M.

Implementation of ingestion pathway decisions -_.availability/usc of info.

3el M

Materials for Ingestion Pathway PADs are available 3e2 M

Implementationi of relocation, re-entry, and return decisions 3fl Adequate Equipment for Plume Phase Field Measurements 4al.

Field-Teams obtain sufficient information 4a2"'

Field Teams Manage Sample Collection Appropriately

.4a3 Post plume phase field measurements and sampling.

4bl M A Laboratory operations 4cl Activation of the prompt alert and notification system 5al M

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

M M M M

Emergency Worker Monitoring/Decontamination 6

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

Mon / decon of emergency worker equipment 6b1 M

17

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportlnmprovement Plan

[Tefm rary care of evacuees T

Transportatioh'and treatme'ni of contaminated injured indi'*;iduals Pilgrim Nuclear Power Station 16d)]

M IM 18

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvemnent Plan Pilgrim Nuclear Power Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 3/4)'

DATE: 2010-11-17 r

0 SITE: Pilgrim Nuclear Power Station, MA M

00 M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not as Demonstrated Mobilization -al Facilities lbl Direction and Control Id Communications Equipment Idl Eqip & Supplies to support operations lel rotctv AciDecisiifinWMk in T-

'eW~

~'

-Ai' tEmergency Worker Exposure Control 2al Radiological Assessment and PARs 2bl Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations 2cl Rad Assessment and Decision making for the Ingestion Exposure Pathway 2d]

Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Implementation of emergency wotker exposure control 3al I finplementation of Kl decision 3b' M' M M M M M M M M M Implementation of protective actions for special populations - EOCs 3cl M

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

Impediments to evacuation are identified and resolved 3d2 Implementation of ingestion pathway decisions - availability/use of info 3e]

Materials for Ingestion Pathway PADs are-available 3e2 Implementation of relocation, re-entry, and return decisions.

3f1 Adequate Equipment for Plume Phase Field Measurements 4al Field Teams obtain sufficient information 4a2 Field Teams Manage Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling,4b Laboratory operations 4cl Activation of the prompt alert and notification system 5al Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emergency information and instructions for the public and the miedia 5b]

Emergency Worker Monitoring/Decontamination 6

Mon / decon of evacuees and emergency workers, and registration of evacuees. 6al Mon / decon of emergency worker equipment 6b]

Temporary care of evacuees 6cl Transportation and treatment of contaminated injured individuals 6d1 19

Unclassified Radiological Emergency Preparedness Program (REP)

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

DATE: 2010-11-17 G

SITE: Pilgrim Nuclear.Power Station, MA F 4 2

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

Demonstrated v

2,

Cn0 CO0c4A Mobilization lal Facilities lbi Direction and Control I cl Comintnications Equipment Idl Equip & Supplies to support operations lel

...~~~~~~~~~~~~~~~.

N..."i, 4 Emergency Worker Exposure Control 2al RadiologicalAssessment and PARs 2bl Decisions for the Plume Phase -PADs 2b2 PADs for protection of special populations..

2cl

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

Rad Assessment and Decision making concerning Relocation, Reentry, and 2el Return Implementation of emergency workerexposure control 3al Implementation of KI decision 3bl M M M M M M M M M M Implementation of protective actions for special populations - EOCs 3cl M

M M M

Implementation of p rotective actions for Schools 3c2 M M M M M M Ihplementation of traffic and access control 3di Impediments to evacuation are identified and resolved 3d2 Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation V relocation, re-entry, and retum decisions.

3f1 Adequate Equipment for Plume Phase Field Measurements 4a]

Field Teams obtain sufficient infonnation 4a2 Field Teams Manage Sample Collection Appropriately 4 4a3 Post plume phase field measiirenrents and sampling 4b]

Laboratory operations 4c]

Activation of the prompt alert and notification system 5al Activation of the prompt alert and notification system - Fast Breaker 5a2 Activation of the prompt alert and notification system - Exception areas 5a3 Emerg6ncy information and instructions for the public and the media 5bl SEmergency Worker Monitoring/Decontamination 6

Mon / decon of evacuees and emergency workers, and registration of evacuees 6al Mon / decon of emergency worker equipment 6bi Temporary care of evacuees 6cl Transportation and treatment of contaminated injured individuals 6dI 20

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim-Nuclear Power Station 21

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Rcport/lmprovement Plan Pilgrim Nuclear Power Station

.3.3 Criteria Evaluation Summaries 3.3.1 Massachusetts Jurisdictions 3.3.1.1 Massachusetts State Emergency Operations Center

a. M ET: La. 1, I.c.1, l.d.1, 1.e.1, 2.a. 1, 2.b.1, 2.b.2, 2.c.1, 2.e.1, 3.c.1, 3.d.1, 3.d.2, 3.e.1, 3.e.2, 3.f.l, 5.a..

b.

AREAS REQUIRING CORRECTIVE ACTION: 5.b.l.

ISSUE NO.: 48-10-5bl-A-01 CRITERION: OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E.5., 7., G.3.a, G.4.a.b.c)

CONDITION: At the General Emergency (GE) Emergency Classification Level (ECL), the Massachusetts Public Information staff at the MassachusettsEmergency Operations Center (EOC) failed to disseminate an appropriate News Release supporting the Pilgrim Emergency Action Directives authorized by the Massachusetts Emergency Management Agency Director at 1 245. and 1303 that correspond to Emergency Alert System (EAS) Messages Numbers 2 and 3, with a sense of urgency and without undo delay.

At 1248, EAS Message Number 2 was signed by the Massachusetts Emergency Management, Director and at 1303 that message was broadcast from the EOC Communications Room. This directed an evacuation of subareas 1,2,3,4 and 12 and Sheltering-In-Place for subareas 5,6,7,8,9,10 and 11. Because of the time constraints of the EAS system, detailed instructions and descriptions of subareas were not included. At 1304, EAS Message Number 3 was signed by the Director changing the above recommendations to an evacuation of subareas 1,2,3,4,5,6,11 and 12, thus adding subareas 5,6 and 11 to the evacuation directive and removing them from the Shelter-In-Place directive. This change was given to the Communications Room staff at 1309 and was encoded into the EAS system and transmitted at 1316.

The Massachusetts News Release that contained detailed information and the 22

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportlimprovement Plan Pilgrim Nuclear Power Station descriptions of the affected areas, plus further critical information for the public, was delayed at the EOC and not distributed to the JIC for release to the-media and the.

public, until 1400, 44 minutes after the EAS broadcast.

At 1304 and 1330 the State Public Information Officer (PIO) at the Joint Information Center (JIC) did conduct two verbal media briefings. While these briefings did provide supplemental information, they do not substitute for a written and widely distributed news release.

POSSIBLE CAUSE: The news release containing critical protective action" information was not wbritten, approved and released in a timely manner. A decision was made to include an embargo -of food in the 10 mile Emergency Planning Zone in the Emergency Action Directives and the subsequent decision to not authorize a News Release until embargo information was included delayed, undu~ly critical information on evacuation, sheltering, and the ingestion of potassium iodide.

REFERENCE:

NUREG-0654,-E.5, 6, 7 MAREP Rev. 14,"4.3.2 MAREP Rev. 12 Section 12.4 EFFECT: Critical information concerning the physical descriptions of the subareas, essential items the public should take with, them in an evacuation, instructions for sheltering in place, and the recommendation from the Commissioner of Public Health for the ingestion of potassium'iodide for the general public and institutionalized individuals was not done in a timely manner.

RECOMMENDATION: Ensure all staff at the EOC and JIC are aware of the time sensitive nature of critical information contained in-news releases following protective action recommendations and EAS activations. We recommend that this criterion be redemonstrated during the Vermont Yankee Combined Functional Drill (CFD l)on March 8-9, 2011.

c. DEFICIENCY: None

d.

PLAN ISSUES: None 23

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/hnprovement Plan Pilgrim Nuclear Power Station

e. NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.1.2 MA 211 Center

a.

MET: 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 3.3.1.3 MA Region II EOC

a.

M ET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.c.l, 3.a.1, 3.b.1, 3.c.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 3.3.1.4 MA (PNPS) Emergency Operations Facility

a.

M ET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.b.1, 2.d.1, 3.b.1, 4.a.2.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

PLAN ISSUES: None

e.

NOT DEMONSTRATED: None f

PROR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 24

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Inprovement Plan Pilgrim Nuclear Power Station 3.3.1.5 MA (PNPS) Field Monitoring Team-1

a. M ET: l.a.1, I.d.1, I.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.2, 4.a.3, 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 3.3.1.6 MA (PNPS) Field Motoring Team-2

a.

M ET: l.a.1, I.d.1, L.e.1, 3.a.1, 3.b.1, 4.a.1, 4.a.2, 4.a,3, 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 3.3.1.7 MA (PNPS) Joint Information Center

a.

MET: 1.a.1, 1.c.1, 1.d.1, L.e.1, 3.a.1, 3.b.1, 5.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 Risk Jurisdictions 3.3.2.1 Carver Local EOC

a.

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

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None 25

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station

f. PRIOR ISSUES -RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.2 Duxbury Local EOC

a.

M ET: 1.a.l,l.d.1,I.e.],3.a.l,3.bl,3.c.l,3.c.2,3.d.l,3.d.2,5.a.l,5.b.1.

b. AREAS REQUIRING CORRECTIVE ACTION: 1.c.l.

ISSUE NO.: 48-10-1cI-A-02 CRITERION: Key personnel with functional roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.

CONDITION: The Duxbury Emergency Management Director (EMD) injected a non-scenario event involving a bridge closure for an evacuation route to support evacuees from Sub-area 4 without prior coordination with the MEMA Controller and the impacted jurisdictions of Plymouth and Marshfield. The areas affected by the simulated closure of Powder Point Bridge are Duxbury Beach, Gurnet Point, Saquish Neck and Clark's Island. By the time the controller was aware of the inject, operations and the other jurisdictions had already been notified and, in his estimation, was too far gone to stop.

POSSIBLE CAUSE: The EMA's stated intent was to draw aftention to the complex arrangement whereby Duxbury historically responds to emergency events in the affected areas which are under the'jurisdiction of both Plymouth and Duxbury. The current arrangement is conducted under a Memorandum of Agreement between the jurisdictions. Controller training may not have adequately covered how to address scenario variances.

REFERENCE:

NUREG-0654, A..d and Pilgrim Exercise Plan, 2010-10-19 EFFECT: The unplanned action to simulate the closure of the bridge departed from the approved exercise scenario and resulted in additional work for the EOC staff that was involved with actions to support the ongoing exercise. Additionally, the neighboring jurisdictions of Plymouth and Marshfield were also distracted by calls to simulate siren activation and route alerting to notify residents of the bridge closure and to establish traffic control points. In summary, the action distracted from an 26

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvemnent Plan Pilgrim Nuclear Power Station otherwise effective operation; however, the Plymouth antd Marshfield response to the bridge closure inject were timely and effective.

RECOMMENDATION: Ensure the EMD is made aware of the proper discipline and controls necessary for an exercise and to assure future operations do not deviate from the scenario and extent of play. Should there be a need for similar events in future exercises, the input should be properly presented to MEMA and FEMA at the exercise planning conferences.

Control11r training should cover methods to address scenario variances.

c.

DEFICIENCY: None,

d. PLAN ISSUES: None

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: 1.c. 1.

ISSUE NO.: 48-08-1cl-A-01.

ISSUE: The Duxbury Selectmen and Emergency Management Director (EMD) failed to ensure that an observer of the exercise did not interfere with exercise activities as required by FEMA rules. An observer of the Duxbtiry Emergency Operations Center (EOC) was allowed to interact extensively with the Selectmen during the exercise and influenced decisions CORRECTIVE ACTION DEMONSTRATED: The EMD demonstrated strong direction and control measures throughout the event and there were no distractions created by visitors or observers.

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.3 Kingston MA Local EOC

a.

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d.

PLAN ISSUES: None 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Inprovement Plan Pilgrim Nuclear Power Station

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 3.a.1, 3.c.2.

ISSUE NO.: 48-08-3al-A-02 ISSUE: The Radiological Liaison Dosimetry Coordinator (RLDC) at the Kingston Emergency Operations Center (EOC) did not properly conduct a radiological briefing for emergency workers and did not provide dosimeters that were ready for use. The RLDC was given on the spot training, and the briefing was re-demonstrated to emergency workers within the EOC. The revised radiological briefing, although improved, still contained errors of omission. The Direct Reading Dosimeters provided were not set at zero. Within the EOC, the reading of dosimeters in 15 minute increments was sporadic.

CORRECTIVE ACTION DEMONSTRATED: The Radiological Officer/Dosimetry Coordinator (RODC) gave a thorough radiological briefing to the emergency workers and explained the procedures for recording and monitoring the dosimeters'. The RODC calibrated the dosimeters prior to issuing :and read the Dosimetry Instruction Briefing Card to the five Emergency Workers.

ISSUE NO.: 48-08-3c2-A-03 ISSUE: The Kingston Elementary School and the Kingston Intermediate School students and staff were not relocated to Bridgewater as a precautionary measure.

CORRECTIVE ACTION DEMONSTRATED: At the Kingston EOC, representatives for the Kingston School Superintendent's Office were presented and worked with the State School EOC representative to coordinate and notify allschools and day cares of current events. The two representatives for the Kingston School Superintendent's Office both had check off sheets/list and workedtogether as a team in keeping the other person informed as to the action and steps taken. As a result, all schools were informed, notified and relocated inma timely manner.

28

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear PowerStation

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.2.4 Marshfield Local EOC

a.

M ET: 1.a.1,1.c.1,1.d.1,1.e.1,3.a.1,3.b.1,3.c.1,3.c.2,3.d.1,3.d.2,5.a.1,5.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' 3.3.2.5 Plymouth Local EOC

a.

M ET:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None.

c. - DEFICIENCY: None

d. PLAN ISSUES; None e." NOT DEMONSTRATED: None)

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

ISSUE NO.: 48-08-5al-A-04 ISSUE: State notification to sound sirens at the Site Area Emergency was not acted upon in a timely manner at the Plymouth Emergency Operations Center (EOC).

Activation' directed to occur at, 1035. did not take place. (simulated), until 1050.

CORRECTIVE ACTION DEMONSTRATED: Through simulation, the Emergency Management Director successfully demonstrated actions to disseminate the appropriate information/instructions in a timely manner to the public through the voice-over component of the siren system. Per the direction of the Emergency Management Director, the Fire Department activated the voice-over systerm for Sirens 38 and 39 from Fire Station One. The voice-over system gave residents in Sub-Area Four advance notice of the emergency situation at Pilgrim Nuclear Power Station.

g.

PRIOR ISSUES - UNRESOLVED: None 29

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Ihnprovement Plan Pilgrim Nuclear Power Station 3.3.2.6. Bay Path Nursing Home

a.

MET: 3.b.1,3.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 3.3.2.7 Bright Ideas Preschool

a.

MET: 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 3.3.2.8 Berry Brook Preschool

a.

MET: 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 3.3.2.9 Camp Clark

a.

MET: 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 30

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Inprovement Plan Pilgrim Nuclear Power Station 3.3.2.10 Discover Corner Daycare

a.

MET: 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 3.3.2.11 Hedge Elementary School

a.

MET: 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 3.3.2.1.2 Indian Brook Elementary School

a.

MET: 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 3.3.2.13 Manomet Elementary School

a.

MET: 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 31

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Inprovement Plan Pilgrim Nuclear Power Station 3.3.2.14 Newfield.House

a.

MET: 3.b.1, 3.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

• 3.3.2.15 Mt. Pleasant Elementary School

a.

MET: 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 3.3.2.16 Pilgrim Childcare and Preschool

a. MET: 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 3.3.2.17 Pilgrim's Hope

a.

MET: 3.b.1, 3.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 32

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Imnprovement Plan PilgrimnNuclear Power Station 3.3.2.18 West Elementary School

a. MET: 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 3.3.2.19 Sacred Heart High School

a. MET: 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 3.3.2.20 Sacred Heart Elementary School

a.

MET: 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 3.3.2.21 Sacred Heart Early Childhood Center

a.

MET: 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 33

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3.2.22 Radius Health Care

a. M ET: 3.b.1, 3.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 3.3.2.23 Providence House

a.

M ET: 3.b.1, 3.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 3.3.2.24 Plymouth North High School

a.

MET: 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 3.3.2.25 Plymouth Community Intermediate School

a.

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

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None d.

e.

f.

g.

PLAN ISSUES: None NOT DEMONSTRATED: None PRIOR ISSUES - RESOLVED: None PRIOR ISSUES - UNRESOLVED: None 34

Unclassified Radiological Eniergenicy Preparedness Program (REP)

,After Action Report/Improveinent Plan Pilgrim Nuclear Power Station 3.3.2.26 Life Care Center

a.

MET: 3.b.1,3.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 3.3.3 Support Jurisdictions 3.3.3.1 Braintree Local EOC

a.

MET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.c.1, 3.d.1, 3.d.2, 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 3.3.3.2 Bridgewater Local EOC

a.

MET: 1.a.1, 1.c.1, l.d., 1.e.1, 3,c.1, 3.d.1, 3.d.2, 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 3.3.3.3 Taunton Local EOC

a. MET: 1.a.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/Inprovement Plan Pilgrim Nuclear Power Station

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 3.3.3.4 American Medical Response Ambulance Company

a.

MET: 6.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 3.3.3.5 Caritas Good Samaritan Medical Center

a. MET: 3.a.1, 6d.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 3.3.4 Rhode Island Jurisdictions 3.3.4.1 RI State Emergency Operations Center

a.

M ET: l.a.1, 1.b.1, 1.c.1, 1.d.1, 1.e.l, 2.d.1, 3.d.1, 3.e.1, 3.e.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/lmprovelnent Plan Pilgrim Nuclear Power Station 3.3.4.2 Ri Field Sampling Team-1

a.

M ET: 1.a.1, 1.d.1, 3.a.l,4.b.1.

b.

AREAS REQUIRING CORRECTIVE ACTION: None

c.

DEFICIENCY: None

d. PLAN ISSUES: l.el.

ISSUE NO.: 48-10-lel-P-04 CRITERION: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to sup~port emergencyoperafions.

CONDITION: Plan contains how to perform the operability check on the CDV-718 radiological instrument but do not require the. meter to be source checked. The specific Dosimetry Coordinator assigned to this exercise was aware of the need to source check the CDV-718, which was completed successfully., This inadequacy is applicable to all Rhode Island Field Sampling Teams.

POSSIBLE CAUSE: Procedure inadequacy

REFERENCE:

NUREG-0654, H.7,10; J.10,a, b, e, J.11; K.3.a Rhode Island Emergency Management Agency Radiological Emergency Plan, Appendix B-7, "RIEMA Dosimetry Coordinator" EFFECT: Dosimetry briefing may not contain instructions to source check CDV-718, if not completed successfully, meter may not be functional and provide erroneous readings.

RECOMMENDATION: Revise procedure to include instructions for source check of CDV-718

e.

NOT DEMONSTRATED: None

f.

PRIOR ISSUES - RESOLVED: None

g.

PRIOR ISSUES - UNRESOLVED: None 37

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/hnIprovement Plan Pilgrim Nuclear Power Station 3.3.4.3 R1 Field Sampling Team-2

a. M ET: l.a.1, l.d.1, Le.1, 3.a.-1..

b.

AREAS REQUIRING CORRECTIVE ACTION: 4.b. 1.

ISSUE NO.: 48-10-4bl-A-05 CRITERION: Field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making. (NUREG-0654, 1.8., J.11)

CONDITION: During the ingestion pathway exercise, the Rhode Island State Police for Field Sampling Team, 2 was unsure as to how and wh~ento perfornm a background radiation check at the sample location. -The State of Rhode Island Ingestion Pathway Plan, Appendix H,: 'Field Team Sampling Procedure'", states that a background check will be performed at each sample location prior to exiting the vehicle. If background is greater than 10 times that of the assembly point, the Feld Sampling. Team Coordinator must be contacted for further instructions before proceeding with sample collection. This survey was not initially performed. The Controller proceeded to explain the use Qf the CD V-71 8 survey meter and demonstrated its proper use. The State Police Officer then performed.a survey and correctly re-demonstrated the use of the meter.

The requirement to perform the background check was listed under the responsibility of the Field Sampling Team Leader. The Rhode Island State Police, 'in accordance with Appendix H of the Plan, served as the Field Sampling Team Leader for Field Sampling Team 2 during this exercise. The Officer stated that the only survey method for which training was received was. to open the window of the survey meter and hang the probe out the window. However, Appendix H, Table H-3, 'Beta-Gamma Exposure Rate Log', has blanks for waist level (window open and window closed readings) and ground level (window open and window closed readings).

Waist level readings are not necessary in post-plume evaluations. The State Police Officer was not aware of this log or the method to correctly complete this log.

POSSIBLE CAUSE: The Evaluator for Field Sampling Team 1 was told by the 38

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim-Nuclear Power Station Rhode Island State Police Officer that the training given on the-use of the survey.

meter, procedures, and radiological hazards was not adequate and that'the Officer was not comfdrtable with the assignment. In addition, the lack of training and experience to serve as the Field Sampling Team Leader and lack of familiarity with the 'Beta-Gamma Exposure Rate Log' compounded this problem:

REFERENCE:

NUREG-0654, 1.8., J.11 State of Rhode Island Radiological Emergency Response Plan for the Ingestion Exposure Pathway, Appendix H, 'Field Team Sampling Procedure' EFFECT: Without adequate survey results; erroneous readings, could have been provided, which would result in the Field Sampling Teams being locaited in a radiation area greater than allowed by the Field Sampling Team Coordinator. This cotuld result in exposures to *the team fiembers greater than anticipated, as well as an

• inaccurate estimation of offsite ýexposure leves-that cbuld be used. in making protective action decisions.

RECOMMENDATION: Ensure that adequate instrumentation, radiological hazard, and applicableprocedure train'inig is provided to personnel who are responsible for performing radiation surveys andwhb are responsible for serving as the Field Sampling Team Leader. Determine the use of the 'Beta-Gamma Exposure Rate Log' and ensure that only necessary readings are included on the form. Ensure that

-personnel responsible for performing radiation surveys are familiar with the use of thelog.

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/Improvemnent Plan Pilgrim Nuclear Power Station 3.3.4.4 RI Field Sampling Team-3

a.

MET: 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 3.3.4.5 RI Joint Information Center

a.

MET: 1.a.1, 1.b.1, 1.c.1, 1.d.1, L.e.], 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 40

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station SEC TION 4:CONCLUSION Ma'~'1u~ts Stati-bf Rli'debIý IsA-~ d, Nd c 16c.

TIO.

4:n

,,,a 0 r

• aiaiosec where noted in this report, demonstrated knowledge of their emergency response plans and procedures *and adecfuately implemented them.

As a result of this exercise, there were no Deficiencies. There were four Areas Requiring Corrective Action (ARCA) identified.

There were also four prior ARCAs open fiom the 2008 Plume Exercise. These ARCAs were redemonstrated correctly during the 2010 Plume and Post Plume Exercise, and closed 41

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvemnent Plan Pilgrim Nuclear Power Station APPENDIX A: IMPROVEMENT PLAN Issue Nu be :-4-0llA0:;.

Crtrin

.1 ISSUE: The Duxbury Emergenc'y Management Director (EMD) injected a i'on-scenario event involving a bridge closure for an evacuation route to support evacuees from Sub-area 4 without prior coordination with the MEMA Controller and the impacted jurisdictions of Plymouth and Marshfield. The areas affected by the simulated closure

.of Powder Point Bridge are Duxbury Beach, Gurnet Point, Saquish Neck and Clark's Island. By the time, the controller was aware of the inject, operations and the other jurisdictions had already been notified and, in his estimation, was too far gone to stop.

RECOMMENDATION: Ensure the EMD is made aware of the proper discipline and controls necessary for an exercise and to assure future operations do not deviate from the scenario and extent of play. Should there be a need for similar events in future exercises, the input should be properly presented to MEMA and FEMA at the exercise planning conferences.

Controller training should cover methods to addressscenario variances.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY:

PRIMARY RESPONSIBLE AGENCY:

CAPABI1LITY ELEMENT:

START DATE:.

AGENCY.POC:

ESTIMATED COMPLETION DATE:.

42

.Unclassified Radiological EmergencyPr! p redness Program (REP)

AfterAction ReportIlmprovernent Plan

.Pilgrimi Nuclear Power Station Issue

~

Nuibr

'805lA0 Ceitein:b ISSIJE: Atithe General Emergency,(GE) Emergency, Classification Level (ECL), the Massachusetts Public Information staff at tl~e Massachusetts EmergencyrOperaiifnS Center (EGC) fai1ed to d ifilinaite aniappropriate News Release supporting the Pilgrnm Emergency Actio6 bir'ecti'ves authorized by the Massachusetts E -'rg"n"y MainagemenYtAgency Director at, 1245 and 1303that correspond to Emergencyv Alert System (EAS)Messages Numbers 2 and 3, with a *sense of urgency andwithoui undo delay.

A0l 248, EAS Message Number 2 was signed by the Massachusetts Emergency Management Director ari8 atr13O3 that-message was broadcast from the EOC Coinmunicajions Room. This directed an evalcuatiin of' subareas 1,2,3,4 and 12 and Sheltering-In-Place for subareas 5,6,7,8,9,10 and 11. Because of the time constiraintrsof the EAS system, detailed instructions and descriptions of subareas were not included. At 1304, EAS Message Number 3 was signed byrthe Director changing the above recommenndtionS to an evacuation of subareas, 1,2,3,4,5,6,11 and 12, thus adding subareas 5,6 and 1.1 to the evacuatioain'directive and removinig them from the'Stheitet-"id-Place directive.

This change was given to the Communications Room staff at 1309 and was &ncoded into.thfiEAS 'sys' ise and transmitted at 1316.

The Massachusetts News Release that contained detailed infornation and the descriptions of the affected areas, plus further critical information for the public, was delayed at the EOC and not distributed to tihle JIG for release to the media and the public, until 1400, 44 minutes after the EAS broadcast.

At 1304 and 1330 the State Public Information Officer (PIO) at the Joint Information Center (JIC) did conduct two verbal media briefings. While these briefings did provide supplemental information, they do not substitute for a.,

written and widely-distributed news release...

RECOMMENDATION: Ensure all staff at the EOC and JIC are aware of the time oe rýs;it iVe I atureof c'fiti cadl information contained in news releases following protective action recon miendations and, EAS attivations:

e We recommnend that this criterion be redemonstrated during the Vernont Yankee Combined Functional-Drill (CFD.

1)on Marchr8-9, 2011.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY:

PRIMARY RESPONSIBLE AGENCY.:

CAPABILITY ELEMENT:

START DATE:

AGENCY POC:

ESTIMATED COMPLETION DATE:

Isu Numer 481-elP0 Criteron:

ISSUE: Plan contains how to perform the operability check on the CDV-718 radiological instrument but do not require the meter to be source checked. The specific Dosimetry Coordinator assigned to this exercise was aware of the need to source check the CDV-718, which was completed successfully. This inadequacy is applicable to all Rhode Island Field Sampling Teams.

RECOMMENDATION: Revise procedure to include instructions for source check of CDV-718 CORRECTIVE ACTEIN DESCRIPTION:

CAPABILITY:

PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT:

START DATE:

AGENCY POC:

ESTIMATED COMPLETION DATE:

43

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvemnent Plan Pilgrim Nuclear Power Station Issue Number: 48-10-4bl-A-05 Criterion: 01 ISSUE: During the ingestion pathway exercise, the Rhode Island State Police for Field Sampling Team.2 was unsure as to how and when to perform a background radiation check at the sample location. The State of Rhode Island Ingestion PNithCvay Plan, Appendix H, 'Field Team Sampling Procedure', states'that a background check will be performed at each sample location prior to exiting the Vehicle. If background is greater than 10 times that of the assembly point, the Field Sampling Team Coordinator must be contacted for further instructions before proceeding with sample collection. This survey was not initially performed. The Controller proceeded to explain the use of the CD V-718 survey meter and demonstrated its proper use. The State police Officer then perfonmed a survey and correctly re-demonstrated the use.of the meter.

The requirement to perform the background check was listed under theresponsibility of the Field Sampling Team.

Leader, The Rhode.Island State Police, in accordance with Appendix H of the Plan, served as the Field'Sampling Team Leader for Field Sampling Team 2 during this exercise. The Officer stated that the only survey method for which training was received was to Open the window of the survey meter and hang the probe out the windoW.

However, Appendix H, Table H-3, 'Beta-Gamma Exposure Rate Log', has blanks for waist level (window open and window closed readings) and ground level (window open and window closed readings). Waist level readings are not necessary in post-plume evaluations. The State Police Officer was not aware of this log oi the method to correctly complete this log.

RECOMMENDATION: Ensure that adequate instruimentation, radiological hazard, and applicable procedure training is provided to personnel who are responsible for performing radiation surveys and who are responsible for servingass the Field Sampling Team Leader. Determine the use of the 'Beta-Ganmna Exposure Rate Log' and ensure that only necessary readings are included on the form. Ensure that personnel responsible for performing radiation surveys are familiar with the use of the log.

CORRECTIVE ACTION.DESCRIPTION:

CAPABILITY:

PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT:

START DATE:

AGENCY POC:

ESTIMATED COMPLETIONDATE:

44

Unclassified Radiological Emergency.Preparedness Program (REP)

After Action Report/Improvement Plati Pilgrim Nuclear Power Station APPENDIX B: EXERCISE TIMELINE Table 1 - Exercise Timeline DATE: 2010-11-17, S*ITE: Pilgriml Nuclear.ý Power Statibh MA Facility De6lared Operational -

Declaration of Emergency: State Declaration of Emergency: Local.

Exercise Terminated Early Precautionary Actions: Close Parks and Early Precautionary Actions: School Transfe Eatly Precautionary Actions: Shelter Livestc EAS "Heads Up" Message or 1 st Protective ActionDecision I st Siren Activation I st EAS Message 45

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Table 1 - Exercise Timeline DATE: 2010-11-17, SITE: Pilgrim Nuclear Power Station, MA I "

46

Unclassified Radiological Emergency Preparedness Program (REP)

Pilgrim Nuclear Power Station After Action Report/Improvement Plan APPENDIX C: EXERCISE.EVALUATORS AND, TEAM LEADERS 47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station DATE: 2010-11-17, SITE: Pilgrim Nuclear Power Station, MA 0

`

-R GENQYY,.

Massachusetts State Emergency Operations Center Paul Anderson FEMA - R9 Johanna Berkey.

FEMA RIO Gary Bolender ICFI Reggie Rodgers ICFI Barbara Thomas FEMA - RI MA 21__ Conter Helen LaForge FEMA - RI MA Region II EOC

• Linda Gee FEMA R6 Roy Smith ICFI MA (PNPS) Emergency Operations Facility Reggie Rodgers ICFI MA (PNPS) Field Monitoring Team-I

• Mike Howe FEMA - HQ MA (PNPS) Field Motoring Team_-2 Jim Hickey ICFI MA (PNPS) Joint InformationCenter

• Don Carlton FEMA - RI RI State Emergency Operations Center Bridget AhIgrimr FEMA - HQ

• Robert Swartz FEMA - RI RI Field Sampling Team-1

• Marty Vyenielo FEMA - R3 RI Field Sampling Team-2 Jill Leatherman ICFI RI Field Sampling Team-3 Andrew Hower FEMA - R3 RI Joint Information Center Henry Christiansen ICFI Carver Local EOC

• Richard Echavarria FEMA - R9 Daryl Thome ICFI Duxbury Local EOC Mark Dalton ICFI

• David White ICFI Kingston MA Local EOC John Arszulowicz FEMA HQ

• Richard Kinard FEMA - R3 Rosemary Samsel ICFI Marshfield Local EOC Marcy Campbell ICFI

• Rebecca Fontenot FEMA - HQ Timothy Looby FEMA - RI Plymouth Local EOC Lisa Hamilton FEMA HQ Elizabeth Haney ICFI

• Melissa Savilonis FEMA - RI Bay Path Nursing Home

• Taneeka Hollins FEMA - RI Bright Ideas Preschool

• Taneeka Hollins FEMA - RI Berry Brook Preschool

• Taneeka Hollins FEMA - RI Camp Clark

• Taneeka Hollins FEMA - RI Discover Corner Daycare

• Taneeka Hollins FEMA - RI Hedge Elementary School

• Taneeka Hollins FEMA - RI Indian Brook Elementary School

• Taneeka Hollins FEMA - RI Manomet Elementary School

• Taneeka Hollins FEMA - RI Newfield House

• Taneeka Hollins FEMA - RI Mt. Pleasant Elementary School

• Taneeka Hollins FEMA - RI Pilgrim Childcare and Preschool

• Taneeka Hollins FEMA - RI Pilgrim's Hope

• Taneeka'Hollins FEMA - RI West Elementary School

• Taneeka Hollins FEMA - RI Sacred Heart High School

• Taneeka Hollins FEMA - RI Sacred Heart Elementary School

• Taneeka Hollins FEMA - RI Sacred Heart Early Childhood Center

• Taneeka Hollins FEMA - RI 48

Unclassified Radiological Emergency Preparedness Program (REP)

.After Action Report/hmprovement.Plan Pilgrim Nuclear Power Station I

49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station APPENDIX D: EXERCISE PLAN This appendix contains a summary of the simulated sequence of events used as the basis for invoking emergency response actions by OROs during the Pilgrim Nuclear Power Station plume/post plume exercise on November 16 & 17, 2010.

The scenario was approved by the Federal Emergency Management Agency (FEMA) Region I in September 2010Q. The summary presented in this appendix is a compilation of exercise scenario materials submitted -by the Pilgrim Nuclear Power Station...

Events at the plant site that are not pertinent to the ORO response have been omitted.

50

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportlhnprovement Plan Pilgrim Nuclear Power Station Pilgrim Nuclear Power Station November 1 6 th 2010 NRC/FEMA Evaluated Exercise - PlUme Portion NARRATIVE

SUMMARY

Initial Conditions It is November 1.6, 2010. The plant has been Trunning for an extended full power. runfor the last 300 days., The 'C' Salt Service Water (SSW) pump is red tagged for bearing repair. The 'A' Average Power Range Monitor (APRM) is bypassed and I&C is investigating.

It is a partly cloudy day with seasonal temperatures. The wind is from the Northeast (45 degrdees) at 5 to 10 MPH. Skies are expected to remain cloudy throughout the day.

The temperature is 42 degrees, Sequence of Events The Exercise event starts with an, earthquake sensed onsite.. The Seismic Recorder Operating alarm is received in the Control Room accompanied by several spurious, alarms. The operations crew will enter procedure PNPS 5.2.1 (Earthquake) to.initiate appropriate actions for determining the magnitude of the earthquake and expected walk downs of the plant for damage. The reactor remains at power.

Initial. reports from -t.he field will include a report from Security that ground motion was,

felt at the Bullet Resistant Enclosures (BREs), overhead lights in the Aux Bay are arcing and a flammable liquid locker outside the Emergency Diesel Generator (EDG),Building was tipped over and 2-3,gallons of oily liquid has spilled. A broken wire on-'B' Squib valve will result in a Squib valve continuity alarm on the Simulator CR 905 panel.

Results of the plant seismic monitoring system will show that the ground motion from the earthquake exceeded the Alert entry condition (operating-'basis earthquake) but not the Site Area Emergency e ntry condition (safe shutdown earthquake).,

The Shift Manager (SM) will declare an ALERT based on Emergency Action Level 7.4.2.2 (An Earthquake onsite which has been determined to be greater than Operating Basis Earthquake 0.08g).

When the Alert is declared, the emergency response organization (ERO) is notified by activation of the Computerized Automated Notification System (CANS), Offsite notifications of the Alert declaration wilLbe made to the Commonwealth and-local towns by activation of the Dedicated Notification Network (DNN) computerized system.;, When sufficient ERO staff arrives at the Technical, Support Center: (TSC.),-the Operations Support Center (OSC), the Emergency Operations Facility (EOF), and the Joint.

Information Center (JIC), each facility will be activated.

51

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Pilgrim Nuclear Power Station November 1 6 th 2010 NRC/FEMA Evaluated Exercise - Plume Portion NARRATIVE

SUMMARY

Sequence of Events (continued)

After the emergency response facilities are staffed and activated, a minor after-shock will cause an Emergency Diesel Generator (EDG) trouble alarm, and a Shutdown Transfer (SDT) alarm that the E-Lab will investigate. The EDG will have an 6il leak on a flanged connection that can be repaired. Operators will continue to request TSC/OSC support with on-going event related work activities and walk down inspections of plant equipment for sEismic-related damage., Plant field personnel will report that a hanger on the Turbine Closed Cooling Water (TBCCW) System has separated from its anchor and the public hydrant at the old gate house is leaking.'

Approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 5 minutes after the initiating event, another after-shock occurs that causes the Reactor Recirculation pumps to go to maximum speed and reactor power to exceed the automatic reactor scram signal but the reactorfails to scram on high reactor power. Operators will insert a manual scram but some of the control rods willnotfully insert.: An Anticipated Transient without scram (ATWS) event has occurred, Enough rods will insert.to lower-.reactor power to about 10 percenit and Standby Liquid Control (SBLC) will be manually:initiated to lower power.'In addition to SBLC initiation, Emergency Operating Procedure (EOP-02) will direct the crew to utilize procedure PNPS 5.3.23 for alternate rod insertion. Alternative, and parallel, success paths include individual CRD insertion, closing of. the CRD 25 valve, and multiple scrams., subsequent to bypassing Reactor Protection'System (RPS) and Alternate Rod Insertion (ARI) logics per PNPS*5.:3.23., Upon taking and completing-these actions, the crew will be,able to manually insert control rods to shutdown the reactor.

After the ATWVS event, the EOF.ý,E~mergencyDirector is expected to upgrade the event to a SITE AREA EMERGENCY (SAE)'based on Emergency Action Level 2.3.1.3 (Reactor Power greater than 3 percent andboron injection into the reactor pressure vessel intentionally initiated).

While stabilizing the plant'the Main Steam and Off-gas radiation monitors will alarm in response to reactor fuel cladding damage (gap activity) released into the reactor coolant from the power excursion sequence of events. The Main Steam Isolation Valves will be closed by operator action as per procedure PNPS 2.4.40.

Approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the Site Area Emergency is declared, a final after-shock will cause a steam leak to occur in the "B" valve room downstream of the HPCI Steam Line Outboard Isolation Valve MO-2301-5. A steam leakage area hi-temp alarm annunciates in the CR Simulator indicating the leak.

52 P n mm ID r-%f Q

Unclassified Radiological Emergency Preparedness Program (REP)

.After Action Report/Improvement Plan Pilgrim Nuclear Power Station Pilgrim NuclearPoWer Station

,November 16h 2010 NRC/FEMA EvaIuated Exercise-Plume Portion NARRATIVE

SUMMARY

Sequence of Events (continued)

Operators will enter EOP-04 (Secondary Containment Control) due to high area

.temperature. Radiation levels in the Reactor Building will increase significantly due to the steam leak into the Reactor Building atrfiosphere.,

Thereleased,airborne concentration in the Reactor-Building is being exhausted-through the Standby Gas Treatment,(SBGT) system to the Main Stackand released to the:

environment. Main Stack and SBGT discharge radiationmonitors Will. start to-respond, and will indicate a release of radioactivity to the off-site environment.

Radiation levels on the Main-Stack will rise as the secondary containment'steam leak-is exhausted.through the Standby GasTreatment System. The radiation levels-from the st6an J:Iaak.will ca.de the MainrStack readings to exceýd 10,000 cps forgre

'ater than 15 m inefs. The CR Simulator crew will enter EOP-05 "Rad Release Control', and an enimrgency RPV depoessurizatiohwill be required (EOP-17). -Howeveýr;:-rýadiation, levels onthe Main Stack will continue t 6'riseand exceed 'the,General Emergency threshold

.value of 240,000 counts per second (cps),

Whien Main Stack exceeds"24G0,000 cps,1.the EOF Emergency Directo'i is-expektied to upgrade'the. event to a GENERAL EMERGENCY (GE) based on Emergency Actibn Level 5.1.1.4 ý(Valid Main Stack process radiation monitor reading greater than 2.4E5" cps)';

At.the time of.declaring the General Emergency, the PNPS ERO will issue'FProtect ve Action Recommendations (PARs)t,.o the appropriate-G-mi n0nwealth of Massachusetts authorities, located at the Emergency Operations Facility (EOF). The PAR will be based on plant conditions that shouldi*nclude evacuating the 2 mile ring surrounding the plant and 5 miles downwind in the affected sub-areas in the Emergency Planning Zone (EPZ),; and sheltering all remaining sub-areas in the EPZ. This:should:include evacuating su.b-areas.1, 2, 3 and 12 and sheltering sub-areas 4, 5, 6,7,8, 9, 10 and 11.

In addition, a reminder is provided in the PAR that the Commonwealth of Massachusetts and local emergency authorities should consider the, administration of Potassium Iodide (KI) for the general public in accordance with each authority's emergency plan and procedures.

Termination

-After the General Emergency is declared, the exercise will be terminated when sufficient time has elapsed to allow appropriate objectives to be demonstrated or evaluated.

53

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Pilgrim Nuclear Power Station November 1 6th 2010 NRC/FEMA Evaluated Exercise - Plume Portion ABBREVIATED SCENARIO TIMELINE Details/Expected Actions

-Simulator operating crew is briefed on the initial conditions. Controllers must provide this information to players when they arrive at each facility, especially the lead facility players.

Controllers and players are in position.

Scenario begins..

The crew in the Control Room (Simulator) receives indications of an earthquak e.

Shift Manager (SM) declares an ALERT per EAL 7.4.2.2 (An Earthquake 6onsite which has been detetrnined to be greater than Operating Basis Earthquake - 0.08g) 00:25

-0825 ERO Mobilization The ERO should be mobilizing and activating Emergency Response Facilities. State and' local offsite notifications will be initiated and made.- During the ERO activation the plant may experience minor after-shocks.

01:20 0920 FacilityActivation TSC, OSC, and EOF should be activated.

On-call Emergency. Director takes over command and control of the emergency from the Shift Manager/Emergency Plant.

Operations Supervisor,.

02:05 1005 Another after-shock occurs that Operators notice that the reactor did not causes the Recirc pumps -to go to scram on high reactor power. Operators will max speed and reactor power to insert a manual scram but'some of the control exceed the automatic scram.signal rods will not fully insert.

.butifails to scram on high reactor power.

02:10 1010 Anticipated Transient Without Scram Emergency Operations Procedure (EOP-02)

(ATWS) with Rx Power about 10%.

will direct crew actions. Enough rods will insert to lower power to about 10%.

Simulator response will require crew to initiate Standby Liquid Control (SBLC).

10 Site Area Emergency (SAE)

After the ATWS event, the EOF will declare Declared the SAE based on EAL 2.3.1.3 (Reactor 54 1 Power >3% and boron injection required).

• Elapsed Times and Actual Clock Times are approximations.

,Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim.Nuclear Power Station Pilgrim Nuclear Power Station November 1 6 th 2010 NRCJFEMA Eval uated Exercise - Plume Portion ABBREVIATED SCENARIO TIMELINE.

Elapsed rA-ctu-al Time*-

Clock,,

(Hr:min)

[Tme*

02:3 5 1

Event Aain Steam, and Off-gas Radiation Aonitors alarm Details/Expected Actions Main *Steam* radiation*levels are trending upward due to fuel failure occurring with this after-stock and'th6 reactdr power excursion sequence. PNPS Pi'bdedure2'4.40'directs Main Steam Isolation: Valve (MSIV.) closure upon reaching High-High set point..Crew may i 61ate MSIVs before reaching 6set oint.

030 All Control Rods are inserted Tihe operator crew will be able to take alternate actions to manualiy in*sert control rods.. to shutdown the reactor.

04:05 12015-':

e final aft&r-shock is felt Indications will be observedat the dhsite TSC 1,"

h

""and OSC emergency response facilities.

04:07 1207 Steam Leak located in the "B" Valve Operators should d~temmine'thata steam leak Room has occurred in the "B" valve room located on.

the ground floor of the Reactor Building. The steam leak is associated With the failure of the HPCI Steam Line Outboard Isolation Valve.

t(MO-2301-5).

04:10 1210 High Main Stack, Radiation Levels.

Operato0s reqognize' High Main Stack Radiation.

04:25, 1225 Steam leak worsens and continues Main Stack radiation levels, start to~rise to degrade. EOP-5 entry conditions.

significantly. Main stack radiation levels are above 10,000 cps for greater then 15 minutes and continue to increase.

04:35

.1235 1General Emergency (GE) Declared: When Main Stack exceeds 2.4E5 cps, the (Main Stack Radiation monitors EOF will declare a GEbased on EAL 5.1.1.4 exceed. 2,4E5 cps)

(Valid Main Stack radiation monitor reading greater than 2.4E5 cps). Off-site Protective Action Recommendations should be formulated. and issued with the General Emergency declaration.

06:00 1400 Exercise Termination The Exercise is terminated when sufficient time has elapsed to allow appropriate objectives to be demonstrated or evaluated.

55 "Elapsed Times and Arti t I rlnrl' Tim--..-.---.-

- 1.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvemnent Plan Pilgrim Nuclear Power Station Pilgrim Nuclear Power Station 2010 Ingestion Pathway Evaluated Exercise SCOPE The scope of the 2010 Pilgrim Nuclear Power Station (PNPS) Ingestion Pathway EValuated ExcrciSe is focused on the activities of the State agencies responsible for determniing and implementing post-radio logical emergency measures.during the post-plume phase ofa simulated accident at the PNPS. The post-plume phase is the period beginning afler releases of radioactive material have been brought under control and the period of deposition of radioactivity has ceased. This phase of a radiological qmergency may take from weeks to marny months to complete depending on the severity and; extent of the release ofradioactive material to the environment. Fulfly demonstiating-this response is well beyond thie scope oftthis exercise. However, the Conino'nnWealth of Massachusetts and the State of Rhode Island and will demonstratebke;y :esponse actions and objectives based on the simulated deposition ofradioactive~hiatefifal resulting from the off-site release and assumed scenario time finame postilalted, throughout the exercise sequence of events.

The majior exercise events to.be demonstrated. will inclide protective action decision making and implementation of actions resulting in p rotection of the public from direct long-term exposure to deposited radioactive Materiial and ingestion of contaminated fbod and water. To allow the demonstration. of ithse-activities, simulated scenario times, information and data will be provided to 'exercise participants for the demonstration of the exercise objectives. 'The season assumed for the purposes of the exercise is fall with the date being November, 7 p,_010. The specific schedule of events and timing of exercise events is provided in the table presented below and the detailed sequence of events.

56

Pilgrim Nuclear Power Station 2010 Ingestion Pathway Evaluated Exercise EXERCISE EVENT PLAN

SUMMARY

Event Activity Description Date Time Locati6n(s)

Participants No./Simmulated Scenario Time.

Event 1/

Transition firom Plume Exposure To be conducted TBD State EOCs and (both states)

T*+2 hrs Phase Exercise and conduct following the.

PNPS EOF Designated FRMAC Advance Party Meeting completion of the:

Dose Plume Portion Assessment

• Establish Initial Conditions Exercise (T.time is Staff/Decision

• Assess Plume Data based on to be set-asidetfor Makers Cn available map(s)

'thcDDE /NNSA persoi"o Support hold/w, alkthrough Agency Staýffs the-Advance Party

" Meeting.)

Designated Controllers 0

0 ma

~0 a ~

a" a.

~0 a

m

~0

• T=Refers to the time when release to the environment hasbeen terminated and deposition of radioactive material is completely dispersed within die 50-mile area.

~0

• 0 a

• 0 0

0)

C Page 2 of 4

Pilgrim Nuclear Power Station 2010 Ingestion Pathway Evaluated Exercise Event Activity Description Date Time Location(s)

Participants No./Simulated Scenario Time Event 2 Post-Emergency Enviromnental Morning of Day TBD Designated (both states)

(Out of sequence)

Sample Collection alter Plume Portion Muster Point and e

Designated of the Exposure Predetermined Environmental Exercise Sampling Sampling Team Locations Coordinator Designated.

Environmental Sampling Teams Sampling Team

-00 Controllers Event 3/

Establish Environmental

,Morning of Day TBD State EOC,.

(both states)

T+5 hrs Sampling Plan based on

,after Plume Portion

• • Designated NARAC-provided Maps, of the Exercise EOC Personne Models. and Measurements EOC Controllers Event 41 Radiological Assessnient of Morning of Day TBD State EOC (both states)

T+48 hrs Enviro nental.Data-and PAD after Plume Portion State EOC Formulation for ReloOocation/Re-.

of the Exercise Personnel Entry/Returnmid Ingestion..

EOC Pathway Controllers C

C C

0s 0

CCC, C,~C C

C z

6

• T=Refers to the time whengrelease to the environment has b'een terminated and deposition of radioactive material is completely dispersed within the 50-mile area.

Page 3 of 4

Pilgrim Nuclear Power Station 2010 Ingestion Pathway Evaluated Exercise Event Activity Description Date Time.

Location(s)

Participants No./Simulated Scenario Time Event 5/

Table Top Decision Making and Afternoon of Day TBD State.of State EOC T+72 lurs Implementation of Relocation/

after Plume Portion Massadhusetts Personnel Re-Entry/Return of the Exercise EOC only EOC Controllers Event 6/

Table Top Decision Making and Afternoon of Day TBD`- State of State EOC T+72 hrs Implementation of Ingestion after Plume Portion Massachusetts Personnel Pathway Actions of the Exercise and Rhode Island EOC.

EOC Controllers a

0 01

-v -

CC. Cs

-~0 v-c-

'~0 005

.2 01

• T=Refers to the time when :release to the environment hasbeen terminated and deposition of radioactivematerial is completely dispersed within the 50->

mile area.

Cn (0

• P0 05 0

~0 0

0 Page 4 of 4

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/inprovement Plan Pilgrim Nuclear Power Station MASSACHUSETTS EVALUATION AREAS AND EXTENT OF PLAY' PILGRIM NUCLEAR POWER STATION EXERCISE November 16-17, 2010 Overview The following organizations/locations will demonstrate in 2010:

State Emergency Operations Center Massachusetts Emergency Management Agency Massachusetts Department of Public Health Massachusetts State Police Massachusetts Department of Transportation Massachusetts National Guard Massachusetts Department of Mental Health Massachusetts Department of Agricultural Resources Massachusetts MDPH Food Protection Program Massachusetts Department of Environmental Program Massachusetts Department of Fish & Game Office of the Secretary of the Commonwealth Mass 2-1-1 Call Center U.S. Coast Guard Pilgrim Nuclear Power Station Liaison American Red Cross Federal Emergency Management Agency Region I Federal Radiological and Monitoring Assessment Center Region II Emergency Operations Center Massachusetts Emergency Management Agency - Region II Massachusetts State Police Massachusetts Highway Department Massachusetts National Guard Pilgrim Nuclear Power Station Liaison American Red Cross RACES Operators Massachusetts Bay Transportation Authority (MBTA) Representative Department of Corrections - Bridgewater Plymouth County Sheriff Emergency Management Agency Emergency Operations Facility Pilgrim Nuclear Power Station Massachusetts Emergency Management Agency Massachusetts Department of Public Health 60 lBased on guidance from Section 11I.B-Evaluation Areas, "Interim Radiological Emergency Preparedness (REP) Program Manual" August 2002.

8, Unclassified Radiological Emerg6cý'

Preparedness Program (REP)

After Action ReportlImprovement Plan Pilgrim Nuclear Power Station Radiological Field Moniýoring and Sampling Teams Pilgrim Nuclear Power Station Massachusetts Department of Public Health/Radiation Control Program Joint Information Center Pilgrim Nuclear Power Station Massachusetts Emergency Management Agency EAS Radio Stations.

• WBZ 1030 AM Risk Jurisdictions Carver EOC Duxbury EOC Kingston EOC Marshfield EOC Plymouth EOC Support Jurisdictions Braintree Command Center Bridgewater EOC Taunton EOC Schools [NOTE: *Indicates KI Distribution Plan in placel Out of Sequence Kingston:

Sacred Heart Elementary School* (10/5/10)

Sacred Heart High School* (10/5/10)

Plymouth:

Plymouth Community Intennediate School*

Indian Brook ElementarySchool*

Manomet Elementary School*

Plymouth North High School*

Mt. Pleasant Elementary School*

West Elementary School*

Hedge Elementary School*

61

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/inprovement Plan Pilgrim Nuclear Power Station 04%

~

~R, Day Care Centers [NOTE: *Indicates KI Distribution Plan in placel Out of Seqiuence Duxbury:'

Berrybrook Preschool*(9/28/10)

Pilgrim Day Childcare*(9/22/10)

Discovery Comer Daycare* (9/27/10)

Kingston:

Sacred Heart Early Childhood Center* (10/5/10)

Plymouth:

Bright Ideas Preschool*(8/30/10)

Special Facilities: fNOTE: *KI Distribution Plan in place] Out of Sequence Duxbury:

Baypath/Duxbury Nursing Home*(9/17/10)

Kingston:

Providence House* (9/14/10)

Pilgrim's Hope (9/14/10)

Plymouth:

Newfield Nursing Home (8/17/10)

Chilton House Rest Home (8/17/10)

Life Care House of Plymouth* (TBD)

Radius Health Care* (8/12/10)

Camps: [NOTE:

• KI Distribution Plan in place} Out of Sequence Plymouth:

Camp Clark (8/11/10) 62 OTHER FACILITIES TO BE EXERCISED

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Ntclear Power Station Braintree Reception Center (7/2010)

Braintree TSA (Out of Sequence)

Radiological Emergency Worker Monitoring and Decontamination Station (REWMDS) (Successfully demonstrated August 2009)

Milton KI Dispensing Site (Successfully demonstrated November 2009)

MS-I Quincy Medical Center (Successfully demonstrated November 2009)

Good Samaritan Medical Center (December 2010)

Massachusetts State. Police at Middtleborough Troop B (11/09)

FACILITIES NOT TO BE EXERCISED Camps not to be exercised Carver:

Camp Clear ('12)

Duxbury:

Camp Wing Magic Mountain Summer Camp Camp Friendship Kingston:

Camp Norse('08)

Camp Mishannock('08)

Plymouth:

Wind in the Pines ('12)

Camp Bournedale ('11)

Cachalot Scout Reservation ('11)

Camp Squanto ('12)

Camp Massasoit ('11) 63

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvenment Plan Pilgrim Nuclear Power Station Carver:.

Erwin K. Washburn Primary School ('08)

Carver Middle School ('11)

Carver High School ('11)

Governor John Carver Elementary ('11)

Duxbur:

Chandler Elementary School* ('08)

Bay Farm Montessori Academy ('08)

Duxbury Bay Maritime School ('08)

Good Shepherd Christian Academy Alden Elementary ('12)

Duxbury Middle School ('12)

Duxbury High School ('12)

Kingston:

Kingston Elementary School* ('08)

Kingston Intermediate School* ('08)

Silver Lake Regional Middle School ('12)

Silver Lake Regional High School ('12)

Marshfield:

Governor Winslow School Plymouth:

Cold Spring Elementary School* ('08)

Federal Furnace Elementary School* ('08)

Plymouth South High School* ('08)

Plymouth South Middle School* ('08)

South Elementary School* ('08)

Nathaniel Morton School* ('08)

Day Cares not to be exercised Carver:

Kidstop Early Childhood Center ('08)

Captain Pal Preschool ('09)

KidsCount Nursery and Preschool ('09)

Old Colony Y ('11)

Duxbury:

Learn in Play Pre-School ('08) 64 Pied Piper Pre-School ('08)

Blue River Montessori ('08)

Elements Montessori ('11)

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgtrin Niclear Power Station Pilgrim Area Collaboratives Kingston:

Growth Unlimited PreSchool ('08)

Little People's Country Day Care ('11)

Wooded Acres Child Care ('11)

Crayon College, Inc. ('11)

South Shore Early Education: Kingston ('11)

Plymouth:

Methodist Nursery School ('08)

New Testament Christian Academy ('08)

Ponds Child Care Center* ('08)

South Shore Head Start* ('08)

Kinder College Nursery School ('08)

Kinder Care - Richards Street ('08)

Kinder Care - Pilgrim Hill Road ('08)

Bright Beginnings ('08)

Woodside School ('08)

Plymouth Family Network ('11)

Cedar Brook Children's Center ('11)

Cranberry Country Day Care ('11)

Crayon College, Inc. ('11)

Garden of Knowledge ('11)

Leaping Frog Preschool ('11)

Miss Joanne's Bright Beginnings ('12)

Pilgrim Academy ('12)

Pinewood School of Montessori ('12)

Rising Tide Public Charter School. ('12)

Room 2 Grow ('12)

Tiny Town Children's Center ('12)

Special Facilities not to be exercised Duxbury:

Group Facility at North Hill ('08)

Kinjston:

Rehabilitative and Skilled Nursing Residence at Silver Lake* ('08)

The Inn at Silver Lake ('08)

Jones River Guest House ('11)

The Residences at Silver Lake ('12)

Vinfen Evergreen House ('12) 65 Kingston A & B ('12) 16 Center Street ('12)

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Plymouth:

Plymouth Crossing Assisted Living ('08)

Sunrise Assisted Living ('08)

Baird Center ('08)

Community Connections, Inc ('08)

Golden Living Nursing Home* ('08)

Chilton House Rest Home ('08)

Life Care Center of Plymouth* ('08)

Stafford Hill Living(' 12)

High Point Treatment Center ('12)

Habilitation Assistance ('12)

Teamworks ('12)

,OTHER FACILITIES NOT TO BE EXERCISE' Myles Standish State Forest MCI Plymouth Bridgewater Reception Center Taunton Reception Center

• Brockton KI Dispensing Site Department of Corrections Bridgewater Complex Monitoring and Decontamination Massachusetts Environmental Radiation Laboratory (MERL) at Jamaica Plain, MA Jordan Hospital Carver TSA ('07)

Kingston TSA Plymouth TSA (Scusset Beach)

Marshfield TSA NOTE: "On the Spot" corrections approved for the below mentioned sub-elements, as per FEMA Region 1 MEMORANDUM dated, August 4, 2010.

Note: If during the exercise, a participant demonstrates sub-element.. d. 1, L.e. 1, 3.a. 1; 3.b. 1, 3.d.1, 3.d.2, 4.a.3, 4.b.1 or 5.b.1 unsatisfactorily, the FEMA Evaluator will inform the participant and the Controller. After an" on the spot" re-training by the state or local organization, the FEMA Evaluator will provideqge participant another opportunity to re-demonstrate the activity that same day.

I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrimn Nuclear Power Station EVALUATION AREA 1: Em*ergency Operations Manakement Sub-element l.a - Mobilization,.

Intent This sub-element. is derived fronm NUREG-O654, which provides, that Offsite Response Organizations (ORO) should have the capability to alert, notifi;, and mobilize emnergency, personnel and to activate and staff emergency facilities.

Criterion L.a.l: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely nan'er. ý(NUREG-0654j A. 4; D.3, 4;.E.1, 2;H.4)

Extent of Play Responsible OROs should demonstrate the capability to receive notification of aheergency situation from the licensee, verify the notification, and contact, alert, and mobilize key emergency personnel in a timely manner. Responsible OROs should demonsoati-ate thle activation offacilities for immediate use by mobilized personnel when they arrive to beg!n, emergency -,-.

operations. Activation offacilities should be completed in accordance with th~eplan and/or procedures. Pre-positioning of emergency personnel is appropriate, in accordance with the extent ofplay agreement, at those facilities located beyond a normal conrnuin*g idistihace from, the individual's duty location or residence. Further, pre-positioning of staff for.,ut-o Isequence demonstrations is appropriate in accordance with the extent ofplay agfeement:.,.,

All activities must be based on the ORO's plans and procedures' and completed ai they'tv Wuldu be in an actual emergency, unless otherwise indicated in the extent of play agreement.

Mass~achusetts Extent of Play Jv

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station 68

...Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan

,Pilgrim Nuclear Power. Station Sub-element 1. b - Facilities

Intent, This sub-element is de'ived fi-om NUREG-0654, which provides that Offsite Response Organizations (ORO) have facilities to support the emergency TeSpspnse..:

• Criterion 1.b.1: Facilities are'sufficient to support the emergency response. (NUREG-0654, H.3)

Extent of Play Facilities will only be specifically evaluated for this criterion if they are new ci have substantial changes in structure or mission. Responsible OROs should demonstrate theavailability of facilities that support the accomplishment of emergency' operations-Some of th' areaS'tb be considered are." adequate space, furnishings, lighting, restr6 nbs, ventilation, backup power and/or alternate facility (if required to support operations)' However, FEtMA ill evaluate all faciIities, as a baseline, during the first exercise under the new Evaluation Criteria.

Fdcilities must be set up based on the ORO's plans and procedures and demionsteated as they would be used in an actual emergenc'y, unless noted above or otherwise indicated in the extent of play agreement.

Massachusetts Extent of Play TheTaumintEOC has clianedf location due. to a iecent fire. This new locatin will-be evaluated t6:astab~lish of siijj~ortiiig em-erg'e~icy.,response '<ý,*.*

Sub-element 1.c - Direction and Control Intent This sub-element is derived from NUREG-0654, which provides that Offsite Respoinse Organizations (ORO) have the capability to control their overall response to an emergency.

Criterion 1.c.J: 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.l.d; A.2.a, b)

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

69 All activities associated with direction and control must be performed based on the ORO's plans and procedures and completed as they would be in an actual emergenrvy,7lp.v. nthprwi.-,/' m7,iod

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/lInprovemnent Plan Pilgrim Nuclear Power Station Massachusetts Extentof Play EPZ E'OC§ s :'If a towns Bare ee auCersonnelr den0ons4ate'continuiyof g ovefnit through a 4isglSSon!,nf logistics.,CI)5osin'iigof the local ]30AO anl re ocatiortoa,,

facilit o deChe EPZwil Ui Ua tO ARCA -D UXBUR Y -EOC Issue Number: 48-08-1.c.1-A-O1 Condition: The DuXbury Selectmen and Emergency Management Director (EMD) failed to ensure -that an observer of the exercise did not interfere with exercise activities as required by FEIvA rules. An observer of the Duxbuiy Emergency. Operations Center (EQC) was allowed to interact. extensively with the Selectmen during the exercise and influenced decisions..

Possible Cause: The role'of an observer (to view activities only and not to participate in discussions or'strategy sessions) was not fully -understood by the exercise participants and the observer.

Reference:

NUREG-0654, N.l.a, N.1.b, N.4 Effect: Following a discussion between the observer and the Duxbury Selectman, the Selectman instructed the EMD to have the school children from Duxbury schools take potassiunm iodide (K!I) while the students were already on, buses and being transferred to Braintree High School. Since the students were already being transported away from the area, and, since there had not been. ci release of radioactive material, the use of K! was unwarranted. Further, the buses could not be contacted 6fer leaving the Duxbyui schools until. they had reached Braintree High School.:' Therefore, the inplementation of this directive.could not be accomplished.

Recommendation: Ensure that all participants (including observers) understand their role during an exercise. The EMD should have the authority and responsibility to ensure that observers and evaluators do not interfere with the conduct of the exercise or influence decision-making.

Sub-element 1. d - Communications Equipment Intent This sub-element is derivedfr-om NUREG-0654, which provides that Offsite Response Organizations (ORO) should establish reliable ~oimary and backup communication systems to ensure communications with key emergency personnel at locations such as thefollowing.:

appropriate contiguous governments within the emergency planning zone (EPZ), Federal

Unclassified Radiological Emergency Prepa*edness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station emtegeIncy respo se organizations, the licei4ee_ and its facilities, emergency operations'.ehters (EOC), and field teams.

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

Extent of Play OROs will demonstrate that a primary and afleast one backup system arefidly functional at the beginning of an exercise. If a communications system or systems are not functional, but exercise peiformance. is not affected,, no exercise issue will be assessed. Comimnunications equipment and procedures for facilities and field units should be used as neededfor~the transmission and receipt of exercise messages. Allfacilities and field teams. should. have the capability to access aI least one communication system that is independent of the commercial telephone system. Responsible OROs should demonstrate the capability to manage the communication systems and ensuVre that all message traffic is handled without delays that might disrupt the conduct of enmergenicy operations.

OROs should ensure that~a coordinated communication link for fixed and mo'bil'e dial '

support facilities exists. The specific communications, capabilities of OROs should be commensurate with that specified in the response plan, and/or proceduresm Exercilse sceniarios could require the failure of a communications system and the use of an alternate system, as negotiated in the extent ofplay agreement.

All. activities associated with the 'management of communications c'apabilities must be denionstrated based on the. ORO's plans and procedures and completed as they Woyld be in an actual emergency, unless otherwise noted above gr in the'extent ofplay agreement.

Massachusetts Extent of Play Contactwit*t*ocations *ot playing will be simulated. Se~eExtent of Play. 0*:I-e fiofr fo1te liStingl of facilities that no see 1

NOTE: "On the Spot" corrections approved for the fore mentioned sub-element. That portion of the evaluation element relating to both the proper functionality of communications systems and the proper use of those systems.

Note: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant and the Controller. After an '..ontlthespot" re-training by the state or local organization, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day..

71

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Sub-element I. e - Equipment and Supplies to Support Operations Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) have emergency equipment and supplies adequate to support the emergency response.

Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI), and

• other supplies are sufficient to support emergency operations. (N.UREG-0654, H. 7,10; J.10.a, b, e, J.11; K.3.a)

Extent of Play Equipment within the facility (facilities) should be sufficient and consistent with the role assigned to' that facility in the ORO s plans and/o-r procedures in support of emergency operations. Use of maps and displays is encouraged.

All instruments should be inspected, inventoried, and operationally checked before each use.

Instruments should be calibrated.in accordance with -the manufacturer's recommendations.

Unmodfied CD V-700 series instruments and other. instruments without a manufacturer's recommendation should be calib.rated annually. Modied CDV-700 inst~uments should be calibrated in accordance with the recommendation of the modification manufict~urer. A label indicating such calibration should be on each instrument, or calibrated frequency can be verified by other means. Additionally, instruments being used to measure activity should have a range of readings sticker affixed to the side of the instrument.

Sufficient, quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers should be available for issuance to all.categories. of emergenczy workers that could be deployed from that facility. Appropriate direct-reading dosimetry should allow individual (s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans and procedures.

Dosimetry should be inspectedfor electrical leakage at least annually and replaced, if necessary. CDV-138s, due to their documented histo*y of electrical leakage problems, should be inspected for electrical leakage at least quarterly and replaced if necessary. This leakage testing will be verified during the exercise, through documentation submitted in the Annual Letter of Certification, and/or through a staff assistance visit.

Responsible OROs should demonstrate the capability'to maintain inventories of KI sufficient for use by emergency workers, as indicated on rosters,; 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 T2ume pathway EPZ.

Quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical insoection at storage location(s) or through documentation of current inventory submitted

Unclassified

-Radiological Emergency.Preparedness Program (REP)

.After Action Report/improvemen.r Plan Pilgrim Nuclear Power Station during the exercise,p rovided in the Annul, Letii'of CH-tfi-tion nbnii-sio,+dii'd/Y-16rvfid during a StaffAssistance 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 letterj.om a certified private or State laboratory indicating that the KI supply remains potent, in accordance with U., S. Pharmacopoeia standards.

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

All activities must be based bn the ORO 's plans andprocedures and completedas_ they would be in an actual emergency, unless noted above or otherwise indicatedin the extent ofp tay agreement.

Massachusetts Extent of Play or Ceview natn*o the fsReg.ionsJ IoffitcKNont-,

sFmeA %6'11eto\\

n *Id& )I, ethe Anii e*ah1LettcteOf' NOTE: "On the Spot" corrections approved for the fore mentioned sub-element. That.

portion of the evaluation element Wh'ee'players, are initially unable to show proper equipment, supplies, or documentation.

Note: If during the exercise, a participant demonstrates this sub-element unsatisfact rily, the,.

FEMA Evaluator will inform the participant and the Controller. After an,,.", on the, spoj re-training b'y the state.or local organization; the FEMA Evaliiator will provide the participant another opportunity to re-demonstrate the activity that same day.

E VAL UA TION AREA 2: Protective A ction Decision-Making Sub-element 2.a - Emergency Worker Exposure Control Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (OROs) 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 Npermitted to incur during an emergency.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station MUFI,"ý~ ~ ~

4 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.

Criterion 2.a. 1: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers includi.ng provisions to authorize radiation exposure in excess of administrative limits or protective action guides. (NUREG-0654, K.4, J.10. e,f)

Extent of Play OROs authorized to send emergency workers into the plume exposure pathway EPZ should demonstrate a capability to meet the criterion based on their emergency plans and procedures.

Responsible OROs should demonstrate the capability to niake decisions concerning the authorization ofexposure levels in excess ofpre-authorized levels and to the numn ber 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 'splan and/or procedures or projected thyroid dose compared with the established Protective Action Guides (PA Gs) for KI administration.

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

Massachusetts Extent of Play roeý,Iwacin'kiin d'ren ofistrated at the M" h

tttiECbaed upon ~

infofiý'ati~n~p'rovided frtditA V0FU.

Radiiti Con CntrolProgni1EOU btaff ii1 alyze utility, )ylte.....

and meteorologic-"'al" data

-r6idedat t ieEOF to make a eonctdlo to the Sate 0 fo er d IInn I -I 1k de iso I I,,JItc ýa to Sub-element 2.b. - RadiologicalAssessment and Protective Action Recommendations and Decisions for the Plume Phase oftthe Emergency Iutent This sub-element is derived fiom NUREG-0654, which provides that Offsite Response Organizations (ORO),have the capability to use all available data to independently project integrated dose and compare the estimated dose savings with the protective action guides.

OROs have the capability to choose, among a range ofprotective actions, those most appropriate in a given emergency situation. Off04s base these choices on PA Gsfirom the ORO's plans and procedures or EPA 400-R-92-001 and other criteria, such as, plant conditions, licensee protective action recommendations, coordination ofprotective action decisions with

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Imnprovemnent Plan Pilgrim Nuclear-Power Station othe&political juri.sdictions (e.g., other affected OROs), availability of appropriate in-place shelter, weather conditions, and situations that create higher than normal risk fiom evacuation.

C

-, Criterion 2. b.-1: Appropriate protective action recommendations are based on 'available ilifornhatioihi on planrt ohnditions, field moniioring-data, and-licenseeand ORO0dose projections, as well as knowledge of onsite and offsite environmental 'iohditions.

(NUREG-0654, L8, 10 and Supplement 3)

Extent of Play.-

During the initial stage of the emergency response, following notification ofplant conditio'ns that may warrant offsite protective actions, the ORO should demonstrate the capability to use appropriate means, described, in the plan an'd/or procedures, to develop pro tective action recommendations (PAR) for decision-makers based on available informatibn and,

recommendations f'rom the licensee andfield monitoring data' if available.

When release and meteorological data are provided by the licensee, the ORO also considers these data. The ORO should demonstraie a-eliable capability to independently validate dose pr.ojections. The lypes of calcu.lations to be demionstrated depenid on the dciatavailable-`and the need for assessments to support the PARs. appropriate to the scenario. In all cases, calculation ofprpgjected dose should be demonstrated. Projected doses should be related to quantities and units ofthe.PAG to which theywýll be compared. PARs should beprompti y transmitt d to decision,- makers in a prearranged format.

Differences greater than a factor of 10 between projected doses by the licensee and the ORO should be discussed with the licensee with-respect to the-input data and assumptions used, the use of dfferent models, or other possible reasons. Resolution of-these diff rences should be incorporated into' the PAR if timely and appropriate. The ORO should demnonstrate the capability to use any additional data to refine projected doses andexposure-rates and revise the associated PARs.

All activities must be based on the ORO's plans andprocedures and completed, as they would be in an actual emergency, unless noted above or otherwise indicated in the exient ofplay agreem ent.

,.I

/

Massachusetts Extent of Play

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Inprovenment Plan Pilgrim Nuclear Power Station Criterion 2. b. 2: A decision-making process in volhing consideration of appropriate factors and necessary coordination is used to make protective action decisions (PAD) for the generalpublic (including the recommendation for the use of KI, if ORO policy).

(NUREG-0654, J.9, 1O.fjim)

Extent of Play Offsite Response Organizations (ORO) should have the capability to make both initial and subsequent PADs.. They should demonstrate the capability to make initial PADs in a timely manner appropriate to the situation,. based on notification fiom the licensee, assessment ofplant status and releases, and PARs from the utility and ORO staff The dose assessment personnel niay provide additional PARs based on the subsequent dose projections, field monitoring data, or information on plant conditions. The decision-makers should demonstrate the capability to change protective actions as appropriate based on these projections.

If the ORO has determined that K! will be used as a protective measure for the general public under offsite plans, then the ORO should demonstrate the capability to make decisions on the distribution and administration of KI as a protective measure for the general public to supplement sheltering and evacuation. This decision should be based on the ORO s plan and/orprocedurms or projected thyroid dose comp5ared v9ith the established PA Gfor KI admini sitration. The K! decision-making process should involve' close coordination 'With. appropriate asssessviient ýnd decision-making staff If more than one ORO is involved in decision-making, OROs should communicate and coordinate PADs with affected OROs. OROs should demonstrate the capability to communicate the contents of decisions to the affectedjurisdictions.

All decision-making activities by ORO personnel must be performed based on the ORG's plans and procedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent ofplay agreement.

P)ýA]0he slons are demonstrated atetheMassachliusetts S.....EOC 13'ase u

idedry.t the EOF:_ME.*

Iýid 4dMDPI Radiation Control Pfrd.an antl f

e.

a anao a

in p.m Ieat e

toý makarecommendatio prtdt~it 76

Unclassified Radiological Ernergnricypr*paredness Program (REP)

After.Action Repor.htl provement Plan Pilgrim Nuclear Power Station suib-elemient 2.'C'. "ýPitýec'tiv'eA £ti~ionDecisi(iCons isidet~i'ati~n for the Protection of'Special Po..ula.ions..

Intent This sub-element is derivedfrom N[UREG-0654, which pi'ovides that Offsite Response Orgaqnizations. (OR0) should have the capability to determine protective action recommiendations, including evacuation, sheltering and use bfp otassium iodide (KI), if applicable, foi-spýciai population groups (e.g., hospitals, nursing homes, correctional facilities, schools, licensedd `c'are

..centers, mobility impaired individuals, and transportation dependent individuals). Focus is on..

those special population groups that are (orpoientially will be) affected by a radiological releas'e

from a nuclear power plant.

Criterion 2. c. 1: Protective action decisions are made, as appropriate, for special population groups.. (NUREG-0654, J.9, J.1 O.d,ee)

Extent of Phay Appl*a1icle OROs'should demonstrate the c'apabilib)to alert and notify all public school' systems/districts of emergency conditions that'are 6pe'cted to or may necessitate protectiv* actions for'st'udents. Contacts with public schbol syste's/districts must be actual.

In accordance with plans and/or procedures, 6s6Os and/or officials ofpublic' school systems/districts should demonstrate the capability to make prompt decisions on protective actions for students. Officials should demonstrate that the decision making processfor protective.actions considers (i.e., either accepts automatically or gives heavy weightto) protective action recommendations made by ORO personnel, the ECL at which these recommendations are. received, preplanned strategies for protective actionsfor that ECL, and the location ofstudents at the. time.(e.g.,, whether the students are still at home, en route to the school, orat the school).

Usually, it is appropriate to implement evacuation in. areas where doses are projected to exceed the lower end of the range of PA Gs, except for situations wherethere is a high-risk environment orwhere high-risk groups (e.g., the immobile or infirm.) are involved. In these cases, examples offactors that should be considered are. weather conditions, shelter availability, availability of transportation assets, risk of evacuation-vs. risk from the avoided dose, andprecautionamy..

school evacuations. In situations where an institutionalized population cannot be, evacuated, the administration of KI should be considered by the OROs.

All decision-making activities associated with pi-otective actions, including:consideration of avdilable reso urces; for special populationi groups must be based on the ORO's plans and prded~uies and comljleted as they would be in an actual emergency,' unless noted above-or.

otherwise indicated in the extent of play agreement..

MaSsachusetts Extent of Play

• Pmecl~eaclo'.*tcxlos~~mltdm tos~fr~~li~populatmQn goups;: are demon:rtefat.l~e'.

thýefj a.ppb-f 6f:gý(4" d

tfidd-10 Rad{~11Ti.

QMEAUNfl CPP

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/inprovement Plan Pilgrim Nuclear Power Station anaanneergticity fielda t a

naaeane iX1Te a drecommendation..

to the State E'OC for-theirconisideratio'n in makinig p*rite'tive a.ction decisions.~

Sub-element 2.d. -Radiolo4ical Assessment and Decision-Making for the Ingestion Exposure Pathway Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the means to assess the radiological consequences for the ingestion exposure pathway, relate them to the appropriate PA Gs, 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 ingestidn pathway for weeks or years..

Criierion 2.d.1: Radiological'consequencesfor'the ingestion pathway are assessed and appropriate protective action decisions are made based on the OROY'splanning criteria.

(NUREG-0654, J. 11)

.Extent of Play It is expected that the Offsite Response Organizations (ORO) will take precautionary actions to protect food and water supplies, or to minimize exposure to potentially contaminated water and food, in accordance with their respeciive plans :and procedures. Often such precautionaty actions are initiated by the OROs based on criteria related to thefacility'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 re/eas'e 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, OROs 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 PA Gs contained in the ORO's plan and/or procedures. (The plan and/or procedures may contain PA Gs 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 comparison of taking or not taking a given action on the resultant ingestion pathway dose commitments.

78..

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.

Unclassified RadiologicatEmergency.Preparedness Program (REP)

After-Action Report/Improvement Plan

.PilgimrnNuclear Power.Station should be comnvunicated and, to-~th~ "extentpriactic~aic -do*"dinjgted with niklg/Thb25fhg7H*l*TbaJ!,i~

4g g

OROs should use Federal resources, as identifed in the Federal Radiological Emergency Response Plan (FRERP-) and other resources ('e.g., conipadts, nuclear insurers, etc.), ifavailalile.. Evaluation of this 'criterion will take into. consideration the.level of Federal and other resources participating.

All activities must be based on the.ORO's plan*s and proc~edures and completed as they would be in an actual emergencyd unless noted above or otherwise indicated inathe extent of plafr agreement.

s a

i Massachusetts Extent of Play Sueivbelent.e ailgclAssmt WTdeasssa Fi'ndtDec~ion-MakenSFoncearningoA R

elcation, s-ng tta se sand detu is e

1*4i P'ci on t

cSM

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r 4

I.

...ll-

]Ii liet L4IdtIis erivo m

IEG 5

Iw II tht f ite eeso Organ IzatIon1 IIIIs I(I I 1) 1have th I

capabG 1ility too Iak Idecisýivtnst ton reloaion,.-

tr, l and retur dIIIcI, I CoI rm e s

tI t

o dsi 11ted1 C radioct-)

"11a s<-o

-a sevrea4cciet P itacl powe!roplannt.1 sap&tut;;Cn

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a...e sampfiocatons

-I

-of itknr xttih.Z c i sats of U

io oaoitio The crit6 her'ifood poduCtheGtORO s

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IatentoPyh i.n s

79 Sub lemnztin 2OO e

av RadilogcalpAssessmeto manedDecisions Makng Cocrnnrelocation,,

eenradrtr of the general public. Th7ese decisions dre essen tial for the protection of the public from the direct long-lermn exposure to deposited radioactive materials from a severe accident at a nuclear power plant.

-Criterion 2.e.]: Timely relocation, re-entry, and return decisions arle made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the ORO's plan and/or procedures. ('NUREG-O6S4, L10; Ml,)),

Extent of Play

-'79 Relocation: OROs should demonstrate the canabilitv to estimate integrated dose in contaminnapd

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station individuals in the general public who have not been evacuated but where projected doses are in excess of relocationPAGs, 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 PA Gs.

Determination of areas to be restricied should be based onfactors such as the mix of radionuclides in deposited materials, calculated exposure r ates vs' the PA Gs, and field samples of vegetation and soil analyses.

Re-entry:, Decisions should be made regarding the lodation of contrdl points andpolicies 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 con/trol procedures are. the assignment of O'r checking for, direct -reading and non-direct-readi'ng dosimetry for emergency workers; questions regarding the individual's bjectives and locati6s4'xpeited 'to be visited anid'associated t'e frames; availabihtyof maps and plots of radiation 5exposure i-rites; advice on-areas to 'avoid;-, and procedures forI exit including:

monitoring of individuals, vehicles, and equipmeht" decision criteria regarding decontamination,, and proper disposition of emergency worker dosimetry and maintenance of emergency worker radiation exposure records.

ResponsibleOROs should demonstrate the capability to develop a strategy for

'h' orized re-entiryof individuals into the restrtetd zone, based'on esitbhsheddeci.iion criteria. OROs should demoistrate the capability to modcfy those policiesfor secuiritypurposes (e.g., police patrols),

f6r in'idiheen'afe of essential se-gices !(e.g., firerpotecti6oh alnd utilitiei), and f6r other critical:

functions' Tehey 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 ageticies with roles to peiform in the restricted zone. OROs should demonstrate the capability to establish policies for prdvision of dosimetry.t all individuals allowed to re-en tei the restricted zoneý The extent that OROs need to develop policies on re-entry will be determined by scenario events.

Return: Decisions are to be based on environmental data andpolitical boundaries or physical/geologi'al features, which allow identification of the boundaries of areas to which members of the generad public may return. Return is permitted to the boundary of the restricted area that is based on the relocation PA G.

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 evacuatedto reoccupy their homes and businesses on an unrestricted basis) on measurements of radiation frob' ground deposition'" and the capability to identify services andfacilities that require restoration within afew 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,49 relocated persons.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear,Power Station r~A r

Massachusetts Extent of Play VEVA!LUA TION AREA 3-Protective Action implemeniadtion.

Sub-element 3. a - Implementation of Emerencv Worker Exposure Control Intent This sub-element is derived friom NUREG-0654, which pro ivdes that OROs should have the capability to provide for the following: distribution, use, collection, and processing of d'rect-'

reading dosimetry and permanent record dosimetiy; the reading of direct-reading dosinetry by emergency workers at appropriate frequencies; maintaining a radiation dose record fdr each emergency worker; and establishing a decision chain or authorization proc'duref6r emergency workers to incur radiation exposures in excess ofpi otective action guides, a itays applying the ALARA (As Low As is Reasonably Achievable) principle as appropriate.

Criterion 3. a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans andyý.-'

procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart.ý-"-""ý."'

(NUREG-0654, K.3. a,b) 81

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Extent of Play OROs should demonstrate the capability to provide appropriate direct-reading and permanent record dosimetry, dosimeter chargers, and, instructions on the use of dosimetry to.emergency workers. For evaluation p

ds.es: appropriate direct-reading dosimetiis defined as doshienT that allows individual(s) to read the admi'istrative reporting limits (that are pre'-established at a level low enough to cofisider subsequent calculation-of Total Effective Dose Equiyalent) and maximum exposure limits (for those emergency workers involved in life saving activities) contained in the ORO's plans and procedures.

Each emergency worker shou'ld have the basic knowledge of ra'diation exposure limits as specified in the ORO's jIan and/or procedures.. Procedures to monitor and record-dosimeter readings ahd-to manage radiological exposure contrdl should be demons'trated.

Duiring a plume phase exercise, emergency workers should demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. The emergency

• worker should report accumulated exposures during the exercise as indicated in the plans and procedures. OROs should demonstrate the actions described in the plan and/or procedures by determining whether to replace. the worker, to.authorize the worker to incur additional exposures or to take other actions. If scenario events do not require emeriggcy' workers to seek authorizations for additional exposure, evaluators should interview at least two emergency workers, to detern.mine their knowledge of whom to contact in the event *uthorizatioh is needed and at what exposure levels. Emergency w rkei;s may Useany available resburces (e.g., written procedures and/or co-workers) in providing' responses.

AlIthough it is desirable for all emergency workers to each have' a direct-readihg dosimeter, there may be situations WherTe team members will be in close proximity to each,other during the entire mission and.adequate control of exposure can be affected for all members /f the team by one dosimeter worn by the team leader, Emneigency workers who are assigned to low exposure rate a!eas, e.g., at reception centers, counting lab0ratories,................centers,

'and communications centers, mna have individual direct-reading dosimeters 6 they may be monitored by dosimeters strategically placed in 'the work'area. It should be'noted that, even in these situations, each tedm member must still have their own permanent record dosimeoty.

Individuals without specific radiological response missions, Such as farmers for animal care, essential utility service personnel, or other members of the public who must re-enter an evacuated area following or during the plume passage, should be limited to the lowest radiological exposure commensurate with completing their missions.

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

Massachusetts Extentof Play EIpz EoCs:

__imtr

%ill be isý,i.c 18 iiimm m iiof five 1ndlvjdi~i1i_ w'lid%611 bec won

'glosidmet each thPZiEO411 all ofLemos the

• t o

aeeFEus'EA ai&ipoi (oyol vi t h.,.tr,id as.ins. ure d*ish*. WEA*Evaluator...........,

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station NOTE: "On the Spot" corrections approved for the fore mentioned sub-element. That portion of the evaluation element dealiniWjwiih isguibfl~sitr@indbiieff2.g...Also to be included is the demonstration by emergencl worker knowledge of ra.diation, controL.

Note: If during the'exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will.inform the participant 'nd the Controller. After an " on the s6t" re-training by the state or local-organization, the FEMA Evaluator will provide theparticipant. :

another opportunity to re-demonstrate the activity that same'day.

ARCA-'KINGSTON-EOC Issue Number: 48-08-3.a.1-A-02 Condition: The Radiological Liaison Dosimetry Coordinator (RLDC) at the KIingston Emergency Operations Center (EOC) did not p1roperly conduct a radiological briefing for emergency workers and did not pr6vide doimeters that were ready for use. The RLDC was given on the Spot trairifigand the briefing was re-demonstrated to emergency workers within :the EOC. The revised radiological briefing, although improved, stilil oniained errors of onrission. The Direct Reading Dosimeters provided Were not set at zero. Within the EO'C,`the reading of dosimeters in 15 minute increments was sporadic.

Possible Cause: The RLDC may have been unfamiliar with the requirements for radiological briefings of emergency workers and with his responsibilities as a RLDC.

References:

NUREG-0654, K.3.a, b Town of Kingston Radiological Emergency Response Plan, Section iI;'

Part K, 3.a, 3.d, 3.e Effect: Emergency workers did not understand the proper use of the issued dosimetry or the administrative levels for call-in.

Recommendation: Procedures for the RLDC should be specific and detailed in briefing procedure and content, 4-the RLDC should be versed and trained in those procedures.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/hmprovernent Plan Pilgrim Nuclear Power Station Sub-element 3. b - Iniplementation of KI Decision Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to provide radioprotective drugs for emergency workers, institutionalized individuals, and, if in the plan and/or procedures, to the general public for whom immediate evacuation may not be feasible, very difficult, or significantly delayed While it is necessary for OROs to have the capability to provide. KI to emergency workers and institutionalized individuals, the-provision bf KJ to the general public is'an ORO option and is reflected in ORO 'splans and procedures. Provisions should include the availability of adequate quantities, stoirage, -and means ofthe distribution of radioprotective drugs.

Criterion3.b.I:KI and appropriateinstructions.

are, available should a decision to recommend: use of KI be made. Appropriate record keeping of the administration of KI for emergency workers and institutionalized individuals is-maintained. (NUREG-0654, J. 10. e)

Extent of Play Offsite Response Organizations (ORO) should demonstrate, the capability to make KI available to emergency workers, institutionalized individuals, and, where provided for in the ORO plan and/or procedures, to members of the general public. OROs should demonstrate the capability to accomplish distribution of KI conS'istent with'ideciSions made. Organizations should have the capability to develop and maintain lists of emergency workers and institutionalized individuals who have ingested K!, including documentaiion of the date(s) and time(s) they were instructed to ingest KL The ingestion of KI recommended by the designated'ORO health official i's voluntary.

For evaluation purposes, the actual ingestion of KT is not necessary. OROs should demonstrate the capability to formulate and disseminate appropriate instructions on the use of KIfor those advised to take it, If a recommendation is made for the general public to take KI,.appropriate information should be provided to the public by the means of notification specified in the ORO's plan and/or procedures.

Emergency workers should demonstrate the basic knowledge ofprocedures for the use of KI whether or not the scenario drives the use of K. This can be accomplished by an interview with the evaluator.

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

Massachusetts Extent of Play A*KaIj hi n awl&,ii'dietien6e1os1 pal si

'E*e ptr ImIergene (small Zip-Idck b)'vI11 b*Nc uedin the dosimetry ~a 1't0 o

wrer

Unclassified Radiological Ernergency Pearedness Program (REP)

After Action Report/lmproveement Plan Pilgrim Nuclear Power Station 45 e

.w.

~.Su

~t~Vi&e ou oc Fe~

F Ns-rI the

• 1 "IC K I d t.-"

1".

.1>

I 11 1 1 1:

1

)L LI t

NOTE:.-"On the Spot" corrections approved for themfore mentibnedsub-ele*hm"e t"-.'

Note: If during the exercise, a participant demonstrates this sub-elemenit un_-satisfactori Iy th-e" FEMA E valuator will inform the participant and theController. After. an," on the Spot" re-traihing,by the state; or local organization,:the FEM ' Eva uator will 'provide the paticipanti another opportunity to re-demonstrate the activity that same iday.

This ** ub-ele noent is derived from NUREG-0654, wh chO" pb ides that Offshte Respo*h

.e 2

Or ganizations (ORO) should have the capability to implement protective action decisioan:-s)!!

includiing evacuation and/or sheltering, for all specialpopulations. Focus is on those special P&pulato'ns that are (or potei.ically will be) affe&td by: a,adidlogical releds&frodma nular -

Criterion 3. c. 1: Protective action decisions are implemented for specdalpopulations.

other than schools within areas subject to protective actions. (NUREG-0654,.

... c..g)

"Emen'tof Ply' Ap'lidable"'OROs' should demonstrate the capability to alert and notify (e.g," provide protective action recommendations and emergency information and instructions) special populations (hospitals, nursing homes, correctional facilities, mobility impaired individuals, transportation d

4pezd't, e

_tc.).

OROs should dembnstrate-the capability to provide for the needs of special populations in accordance with the ORO 's plans'ahnd procedures.

Contact with special populations and reception facilities may be actual or simulated, as agreed to in the Extent of Play. Some contacts with transportation providers should be actual, as Snegotiated in the extent ofplay.1 All actual and simulated contacts shbuld be logged:

All implementing activities associated with protective actions for special populations must be based on the ORO'splans and procedures and completed as they would be in an.-adtual eme -gency, tinIsi no'ted above or otherwise.indicated in the extent of play agreement.

Massachusetts Extent of Play 8

5 tSeerancommunrcate.m;.

ime rougnMh, i execlse. N.-Bro'arica.til I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Criterion 3. c. 2: OROs/School officials implement protective actions for schools.

(NUREG-0654, J.1O.c, d, g)

Extent of Play Public school systems/districts shall demonstrate the ability to implement protective action decisions for students. The demonstration shall be made as follows.: At least one school in each affected school system or district, as appropriaA, needs to demonstrate the nimplementation of protective actions. The implementation of canceling the school day, dismissing early, or sheltering should be simulated by describing to evaluators the procedures that wouldbe followed. If evacuation is the implemented protective action, all activities to coordinate and

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim-Nuclear Power-Station M

E complete the evacuation of students to reception cenitrs, congregateocare centers, or host schooq*s may actually be demonstrated or accomplished through an iterview p1ocess. If acconplished through an interview process, appropriate, school per"sonnel including decision making officials (e.g., superintendent/principal, transportation dtrector/buis' disp&atcher), and at I leas tone.,

bus driveir (and the bus.driver.'s escort, ifapplicable).shouldbe available to demnonstrate knowledge of their role.(s) in the evacuation Of school chi-ldre.iýCommunication@s capabilities between schoolpofficials and the buses, if.requ'ired by the plan qild/6r: procedures, should be Veriffed.,...-

Officials of the school system(s) should demonstrate the capability to develop aiidprovide timely information to OROsfor use in messages to parents, the generalpublic, and the media on the status ofprotective actions for;schools.

The provisions of this criterion also apply to any private schools, private kindira.tens and day care centers that participate in REP exercises pursuant to the OR&O's plans ahd pi-ocedu res as negotiated in the-Extent of Play Agreemen.t.

All act~ities must be based on the ORO's-plans andprocedures and coniplefýddas they'would be in an actual-emergency, unless noted above or otherwise indicated in the extent ofpIy' agreement...

MAissachusetts Extent of Play R, i,11 II, f' Th"eM'EMA'`RR:g AR CA-KINGSTON 87 II Tc~ciia Viai mhiiv AEW2Q-'

1,1-A Ill i

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Repor/imnprovement Plan Pilgrim Nuclear Power Station hv

ý,i N's m, n Condition: The Kingston Elementary School and the Kingston Intermediate School stfidents and staff were not relocated to Bridgewater as a precautionary-measure.

Possible Cause: The Kingston Elementary School and the Kingston Intermediate School wer-e.not notified by the Sch ool Suirterintdent's officelthat students and

.staff were to be relocated to Bridgewater as a"-precautionary measure. TIhis information had been passed. from the Kingston Emergency Operations Center to the School Superintendent's office at about 0935.

References:

NUREG-0654, J.10.c School Department Standard Operating Procedure (KIN-06)

Effect: School students and staff could have been Subjected to exposu-e to.

radioactive material.

Recommendafion:KoProvide traininig~to School Superintendent's Offide,.taff.

regardinglie pro:isioni ofStandard Operating Procedure KIN-6,for precautionary relocationi of -chifdiren:-

Sub-element 3.d.' Implementation of Traffic and Access Control Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to implement protective actionplans, including relocation and restriction of access to evaIcuated/sheltered areas. This sub-element focuses on selecting, establishing"- and staffing of traffic and access control points and removal of impediments to the flow of evdcuation traffic.

Criterion 3. d. 1:,h Appropriate traffic and'access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654i J.1O.gj)

Extent of Play OROs should demonstrate the capability to select, establish, and staff appropriate traffic and access control points, consistent with protective action decisions (for example, evacuating, sheltering, and relocation), in a timely manner. OROs should demonstrate the capability to provide instructions to traffic and access control staff on actions to take when modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled 88

Unclassified, Radiological EmergcpicyPre' pid'dness Progra.

(REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Traffic and access, control :staff should demonstrate accurate knowledge of their roles and responsibilities. This, capability may be demonstrated by actual deployment oor by interview, in accordance with the extent ofplay agreement.

In instcnces where OROs lack authority necessary to control access by certaintpes of tr-affic (iail,,

water, and air.traffic), they should de>monstrate the capability to contact the State or,Federal

agencies with duthority to controlraccess.,

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

Massachusetts Extent of Play operatqions,ithifn' hemsjthl mJs d0111111s 'trugcations e

lua tt rA EOC~1~ca1.'hijjj

,adtne;Local Policerep IsntIve iarcipate III a

ý11(1Icso-c:sLtafai1ý21- )r~ traffic Conltrol. N"opefsdqr Cuipetd NOTE: "On the Spot" corrections approved for the fore mentioned sub-element. Appropriate traffic and access cohtrol estabhiishd. Accurate instructions are p'rovided to traffic and access control point personnel.

Note:. If during the exercise, a participant demonstrates this sub-element unsatisfacto r iiy, thed FEMA Evaluator will inform the participant and the Controller. After an " on tfie sip'c' r-training by the state-or local organization, the FEMA Evaluator will provide the'participanit another opportunity to re-demonstrate the activity that same day.

Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUJREG-0654, J.10.k)

Extent of Play OROs should demonstrate the capability, as requ red by the scenario, to identfy and take appropriate actions concerning impediments to Racuation. Actual dispatch of resources to deal with impediments, such as wreckers, need not be demonstrated; however, all contacts, actual or simulated, should be logged.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reporl/Improvement Plan Pilgrim Nuclear Power Station All activities must be based on the ORO's plans 6indprocedutres and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent of play agreement.

Massachusetts Extent of Play Eachi EPZ* L6ocalO*

iO':dla11demons~irate decii* s nal~ing~reg#aidmg, rer~outrng of tra~ffic f*,*ll &iga v"11 hc

'oh:...lla&

n c

NOTE. "On the Spot" corrections approved for the fore mentioned sub-element. Impediments to evacuation are identified and resolved.

-Note: If during.the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant and thIe Controller.. After an,." on the spot" re, training by the state or local organization, the FEMA Evaluator will provide the participant another opportunity, to re-demonstrate the activity thatsame day.-

I:

a Sub-element 3.e - Implementation of Ingestion Path way Decisions...

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 approximateSO-mile radius of the nuclear power plant. This sub-elenient focuses on those actions required for implemeiitation ofprotective actions.

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. NUREG-0654, J.9, 1-)

Extent of Play Applicable OROs should demonstrate the capability to secure and utilize current information on the locations of dairyfarms, 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.

OROs should use Federal resources as identified in the FRERP, and other resources (e.g.,

compacts, nuclear insurers, etc.), ifavailable. Evaluation of this criterion will take into consideration the level of Federal and other reso'gyes participating in the exercise.

Unclassified Radiological Emergency Preparedness Program (REP)

A.fter Ac.tioin.Reportn/!mprovyenent Plan Pilgrim Nuclear Power Station Massachusets Extentt of PIlay_

amza

on imlmnt neuma~apr o~tectiv ractions Hi~e* 2*s actual field play of imlni nato a ct'Iivities, \\\\Ill be u~~ 4 'F6Oe i

CtOHMIMniLation an coordination withaj forei f

Ibi'Lk andwatr' co6ntro4lsu withll th

,igestion pathway EPZ will be simiul'ated by,1)%

shoingý- evaluator th cotact 11st(s)'f farmers food

-producers, and proce~ssors tlhat wVouldb eu~sedlm a real emergency, Sinc the mýiforim'athon is, confidential, a c-opy will notbcI~bipo\\ ided to the evaýlulator. hioweve the evaluator wvill be shIownl either a hard copyor the data on acompu All appropria nd trstte co'ordi I tib>6h indcommiLctI(io w] b1e,2 Coldnlnadciiuicliis

\\ihF~a agen~cies pai icipahnin,-

th~4 ee~ie will be

>42 infooinStateEtinwthe otaties or non participaing2 Ldt Inf~into o

ete (fi sstl~ pratin;IditiuninoA S:tiii, Ail

-ý ýlftl'O[7i

-\\

protecf*tiv ctlons.to, te geerlpublic ;and tofrmrssdprc>ors,ýnlfo d~-hio Bt ro cln u re:, fo r f a nrm ersi, a i u tura l w o r kers, o d ~ c s o s n 1 0 odid t l w iý m

-stockpiled for dlstrnbutlon-as*.,iceedt.

Distribili 1ý \\IlICpovhice tý 1CMA

• ~iti~~lo D*epart

• ~~b'*mento isaG-Meýnd (11,trl hUtlOnS ietthod,)il1ý diLS:'scd', htatlI bioilIll 4'

4

'44-4" 4

Criterion 3.e.2: Appropriate measures, strategies, andKpre-printed insructional material are developedsfor implementing protective action, decisions frcontaminated water, f ood products, milk, and agricultural production. (

R

-4

, J.jj, !I)

Extent of Play Development. of measures and strategies for implementation of higestion, Pathway Zon~e !PZ:

protective actions should be demonstrated by formulation of protective action. inforn ',ation for the general public and food producers and processors. This includes either pre-distributed public intform a tion material in the IPZ or the capabilitytfofi theorapid distibutions wof appsoprian e pre-printed and/or camera-ready information and ins4tructions to p>re-terminedindividuals.and businesses.,OROs should demonstrate the capability t Io:. con'troQ!,'.restrict or prjeventdisti-,ib.ution of contaminatedrfood by commercial sectors. Exerciserplay shouldincludbe demonstration of communicatsve tions atd genalipublicean orfarmerions tfoo Jpces end tpotdective actions.

Actuafieldplay of implementation activities may be simulated For example, communications and coordination with agencies responsible for enforcing food controls within the IPZ should be

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Inprovement Plan Pilgrim Nuclear Power Station For example,. co~innunications and coordination with agencies responsible for enforcing food, controls within the IPZ should be demonstrated, but actual conmnunications with foodproducers and processors may be simulated All activities must be based on the ORO's plans andprocedures and completed as they would be in an actual emergency, unless noted above or otherwise indicated in the extent ofplay agreement.

Massach usettsExtent of Play ApI.*pi,O~ *eiimasre, strategie, ls:and pip, re1:nntd ean}eo*m te icatda elopedefto-e.,

• mpemntm*:~rte tioeacan 1ecs

01. rCon I

at a

Coi£6d pfodms `milk and ar.-*:!i~lwn rtodtictaoni at t*e uMsaf-sgsStitelEO s-tn~tare coo~laledS'e bsaprp ased on Sub-element 3.fj Implementation of Relocation, Re-entry, and Return Decisions Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response,,,

Organizations (ORO) should demonstrate the capability to implementplans, procedures, and decisions for relocation, re-entiy, 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 nuclearpowerplant.

Criterion 3.f 1: Decisions regarding controlled re-entry qf emergency workers and relocation and return of the public are 'coordinated with appropriate organizations and

" implemented. (NUREG-0654, M.1, 3)

Extent of Play Relocation: OROs should denonstrate 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 PA Gs. OROs 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) PA Gs.

Areas of consideration should include the capability to communicate with OROs regarding timing ofactions, 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., OROs should also demonstrate the capability to communicate instri-ions to the public regarding relocation decisions.

Un.classified Radiological Emergency-Preparedness.Program (REP)

After, Action Report/Inprovement Plan Pilgrim Nuclear Power Station Re-enthy: OROs should demohstrate/hlr,.capability to contro re-entiy and-extitX-ituals ho--,

need to temporarily re-enter the. restricted area, to protect tihem iif ri unnhces-A-?adiatibWt-.

exposure and for exit of vehicles and other equipment to control thý spread of contamination" outside the restricted area. Moihitoringnand decont inaiionfaciliie'swil establidsh'e a

appropriate.

Examples 9f control procedure subjects a 1e:

(1) the 1of r chednkgfoqi dect-readin'g (2

u.r'uest i

n aud nonudirect-reading dosimetiy for emergency workers, (2) questons regarding the individuals objectives and locations expected to be aied a

ssoczated time'dames; (3) maps.and plots of radiation exposure rates, (4) advice on areas to avoid," and procedures for exit, includin..

monitoring of individuals, vehicles, and equipment, decision criteiria regarding contamination; proper disposition ofemergency worker d6simetry, and niaintienance ofemer ency workr radiation exposure records.

Return: OR Os should demonstrate the capability to implement policies concerning eturn of membersofthe public atoaieds thatwere ev'acucted during the p6lume phase. ORO§. should, demonstrate the cqpability to identify and proritize services and fa6citites ithat require restoration within a few days, and to identify the procedures and resources fdr their iestortatin. Empleai sotf these se-vices and facilities are medical and social seivices, utilities, roads, schools, and intermediate ter.n housing for relocatedpersons..

Commnunications among OROs for relocation, ieeýnty, and return may bes m'lated," however all simulated or actual contacts should be documnted. These disciss~orsnaybO dcbmplished in agroup setting.

OROs should use Federal resources as identified in the FRERP, and.other resources (e.g.,:,

c'ompactsi nuclear insurers, etc.), if available. Evaluation of this criterion will take. into consideration the level of Federal and other resources participating insthe. exercise.,%.

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

Mass~achusetts Extent of Play 93

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station EVALUATION AREA 4: Field.Measurement And Analysis Sub-element 4.a - Plume Phase Field Measurements and Analises Intent This sub-element is derivedfrom NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to deploy field teams with th&eequipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654 indicates that OROs should have the~capabiliiy to.usefield teams within the plume emergency planning zone to measure airb6orneradioiodine in ihe presence of noble gases and to detect radioactive particulate material in the airborne plumne.

In the event of an ac'ident'at a nuclear power plant, the possible release of radioactive mat erial may pose a risk, to the Inearby population and efivironment. Although accident assessment methods are available to project the extent ahdamagnitude of a release, these Methods are subject to large uncertainties. During an accident, it is important to collect field radiological data in order to help characterize any radiological release. Adequate equipment-and procedures are essential to such field measuremdnt effoits.

Criterion 4.a.]: The field teams are equipped to peiform field measurements Of direct radiation exposure (cloud and ground shine) and to sample airborne radioiodine and

• articulates. (NUREG 0654, H.I OI. 7; 8, 9)

Extent of Play Field teams should be eqquipped with, all instr;uinentation and supplies necessary to accomplish their mission. This should include instrumentsc'apable of measuring gamma exposure rates and detecting the presence of beta radiation., These instruments shoiud be capable of measuring a range of activity and. exposure, including radiological protection/exposure control of team members and detection of activity on the air sample. collection medial -consistent with the intended use of the instrument and the ORO'splans and procedures. An appropriate radioactive check source should be used'to verify proper operational response for each low r-ange radiation measurement instrlument (less than 1 R/hr) and for high range instruments when *available. if a source is not availablefjdr a high range instrument, a procedure should exist to operIationally test the instrument before entering an area where only a high range instrument can make useful readings.

All instruments should be inspected, inventoried, and operationally checked before each use.

Instruments should be calibrated in accordance with the manufacturer's recommendations.

Unmodifed CD V-700 series instruments and other instruments wvithout a manufacturer's recommendation should be calibrated annually. Modified CDV-700 instruments should be calibrated in accordance with the reco'mmendation of the modification mahufacturer. A label indicating such calibration should be on each instrument, or calibratedfrequency can be verified by other means. Additionally, instruments being used to measure activity should have a range of readings sticker affixed to the side of the instruugnt.

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

Unclassified Radiological Emergency, Plýiaredness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station M assachusetts Extent,of Play j...

z.

I Masat hsetso Play ly

~

,~

I rthuW~eO>f0th11is, xercise, t%ýb MNA FedTm'.'i from thLý t 1:

th~capabi~ty h refp therelaseandtoconrolradaton xpoure ~N rEQO5,2 18 1J1O,,

V Extent of Play ResponsibleOffsite Response Organizations~ (ORO,) should demonstrate,,the~capability to brief teams on predicted plume location and direction, travel speed, and exposure. control procedures before deployment...

Field measurements are needed to help characterize the, release and to support the -adequacy of implemented protective actions or to be afactor in niodijfing protective actions., Teams should be directed t6 take measurements in such,locations, at such times to provide information",

stifficent to characterize the, plume and inipacts.

2.

If the responsibility to obtain peak measurements in the plume has been accepted by. licensee field monitoring teams, with concurrence from OROs, there is no requirement for these measurements to be repeated by State and local monitoring teams. If the licensee teams do nbt obtain~pealk measurements in the plume, it is the ORO's decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coordination of plume measurement.information among allfield teams (licensee, Federal, and ORO) is essential. Coordination concerning transfer of samples, including q chain-'of-custody form, to a radiological laboratory should be demonstrated.,

OROs should tise Federal resources as identified in the Federal Radiological Emergency

• Response Plan (FRERP), and otherjresources (e.g., compacts, utility, etc),. if available:

Evaluation of this Criterion will take into consideration the leVeflof Federal and other resources participating in the exercise.

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

Massachusetts Extent of

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station NIA T

,elde am',erson,nel we l pepal l

sampl eme*a asuv, y f6rms tand 0 chainofcstody,,

documents

as i'eyj,were I

beingtransfrre to

• a' lab Cfor analysis**

saApCeI>i ti will biiý:~

V+"~

C'riter ion 4.a.3: Ambient radiation measurements are made and recor ded at appropriate locations, and radioiodine and particulate samples are collected. Teams will moveto an appropriatelow background location to determine whether any, sigrificant (as specified in the plan and/or procedures) amount of radioactivity has-been collected on the sampling media. (NUREG-0654, L 9).

Extent of Play Field teams should demonstrate the capability to !report measurements and field data pertaining to the measurement of airborne radioiodine and particulates and ambient radiation to the field team coordinator dose assessment, or other appropriate authority. If samples have radioactivity significantly above backgrdund,- the appropriate authority should consider the need for expedited laboratory analyses of these samples. OROs should share data in a timely manner with all appropriate OROs. All methodology, including contamination control, instrumentation, preparation of samples, and a chain-of-custody form for transfer to a laboratory, will be in accordance with the ORO 'splan and/or procedures.

OROs should use Federal resources as identified in the FRERP, and other resources (e.g.;

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

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

Massachusetts Extent of Play Tw~o x2 Person MOA NIAT Field Teams wlib di!j.tched f5n.the uti]

with.the NIAT H*ndbo:ok Once diispatctied y

onl 5's I'"~te

,lo

Unclassified:

Radiological Emergency. Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station NOTE: "On the Spot" corrections approved for the fore mentioned sub-element. That..

portion of the evaluation element that demonstrates one complete sample.

Note:Ifduring the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA' Evaluato~r',.wall inform the, parti'clpant and the Controller'. After an "on' tlie' spot re-...

training.,by.th;e. sta Ite or.loc'a'l rgan'z'atibn, th-e FEMA Eva'luaýtor wit.lproviadeý tihe 'afti~iant..

anothe op uty, to t6-demonistrate theactivity that saime day.

Sub-element 4.b - Post Plume Phase Field Measureements and Sam pling Intent,,

Thi*s'sub-element is derivedfrom NUREG-0654 which pi ovides that OROs should have the capability to assess.,the actual orpotential magnitude and locations Of adiologica hazacrds in the JPZ.and for -

relocation, re-entry and return measures.

This sub-elementfocuses on the collection of environmental samples for laboratoy analyses that are essentialfordecisions on protection of th public from contaminatedfod. anidwater and dirct radiation fiom deposited materials.

'9. -

Criterion 4.b.: The field teams demonstrate the capability to make iap;priate,.

measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and rotoectveaictonh dectsion-making. (NUREG-0654, 18; J.i) 9/.

Extent of Play "l' t tk m.a"ur" The ORO's field team should demonstrate the cap auilityO take neasurnemet d'sca piIe'sitýt such times and locations as directed, to enable an adequate assessment of the ingestion pathway and. to support rýe-en t;y, relocation,' and retrn d:c&ions. When r:sdturcs a; es availa ble ulse of aerial surveys and in-situ gamma measuremenit s' approp rate..All

'eth*

-odology.i

ý-zc.*

dini'g contamination control, instrumentation, preparation of sanples, and a chino-bf-custo'dyf *m for transfer to a laboratory, will be.in accordance with the ORO's plan and/or procedures.

Ingestion pathway samples should be secured from agrilcural productisd "ndwater.-Saimples "in support of relocation and return should be secured from soil, vegetation, and" theý su*fjaes'in areas that received radioactive ground deposition.

OROs should use Federal resources as identified in the FRERP, and other resources (e.g.,

compacts, utility, nuclear insurers, etc.), if avai4-'le. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station All activities must be must be based on the ORO's plans and procedures-and completed as they would be in an actual emergency,- unless noted above.or otherwise indicated in the extent ofplay agreement. v.

7 Massachusetts Extent of Play 98

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/lmprovement Plan Pilgrim Nuclear.Power Station NOTE,: -:"On the..Sbotl, corrections approved, forthe f6re mhentioned sub-elemhenit.Tiar portion of the evaluation element thatrdeals with the pkopei collection and a siil!siof'fleldsaniples.

Note: If during the exercise, a participant demonstrates this sub-element unsatisfActorl'y, the FEMA Evaluator will inform the participant and. the Controller. After an" on the spot" re-trai-ning by the state ori local organization;the. FEMA Evaluator will provide the participant, another opportunity to re-demonstrate the activity that same. day.

Sub-element 4.c - LaboratoryOperations In ten t.""

5,.

This sub-elenient is derived from NUREG-0654, which provi.des 'that Offsite Reoniese' OrganizationS (ORO) should have the capability to perform laboratory analyses of radioactivity in air, liquid, and environmental samples, to support rotect*v"eaction decpsios-makrg, Criterion 4.c.l: The laboratory iscapable ofperfornung required radiological analyses to support protective action decisions. (NURE-654, C3";J.11)

Extent of Play The laboratory staff should demonstrate the capability. to.fqllow appropriate proceduresfor receiving samples, including logging of information, preventing contifamination of the ldbomratdry" pie'eenting buildup of background radiationcdue to stored sampies, pteverting cross coitamiriation of samples, preserving samples that may spoil (e.g., milk) and keepiig':track of sampl identity. nl addition, the laboratory staff should demonstrate the capability to prepare samples for'conducting measurements.

All instruments should be inspected,. inventoried, and operationally checked before each use.

Instruments should be calibrated in accordance with the maýufacturer's recommendations. Unmodified

.CDV-700'series instruments and other, instruments w athout aMntfacturer 'secomiendation should be Cdli&i-ated anniually. Mddified CD V-700 instruments should be-calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibratln, should be on each instrument, or calibratedf-equency can be verified by other means. Additionally, instruments being used to measure activity should have a range of readings sticker affixed to the side, of the instrument.

The laboratory should be appropriately equipped Jo pr-vipde analyses of media, as requesfed, on a timely basis, of sufficient quality, and.sensitivity.to support assessmentsa,!d decisions as anLiipated by.

the ORO 's plans and procedures. The laboratoiny (laboratories), instrument calibrations sh6uld be traceable to, standaddsprovided by the Nationa*istitute of Standards and Technology. LabIoratory 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

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station releases (e.g., tranisuranics or as a result of a terro)rist event) or if warranted by circumstances of the event. Analysis niay require resources beyond those of the ORO.

The laborato-y,stYaff should be qualified in radioanalytical techniques and contamination control procedures.

OROs should use Federal resources as identified in the FRERP, and other resources (e.g.,

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

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

Massa ch usetts'Exten t of Play shsact usy io e

de onta t

., § EVALUATIONAREA 5: Emergency, Notification and Public Information Sub-element 5.a - Activation of the Prompt.Alert and Notification Spstem Intent This sub-element is.derived from NUREG-0654, which provides that OROs should have the capability to provide prompt instructions to the public within the plume pathway EPZ. Specific.

provisions addre'ssed in this sub-element are derivedfrom the Nuclear Regulatoly Commission (NRC) regulations (10 CFR Part 50, Appendix E.IVD.), and FEMA-REP-1 0, "Guide for the Evaluation qfAlert and Notification systems for Nuclear Power Plants."

Criterion 5.a.1: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current FEMA REP guidance. (10 CFR Part 50, Appendix E.IV.D and NUREG-0654, E.5, 6,7)

Extent of Play Responsible Offsite Response Organizations (ORO) should demonstrate the capability to sequentially provide an alert signal followed by an initial instructional message to populated areas (permanent'resident and transient) throughout the 1 0-mile plume pathway EPZ. Following the decision to activate the alert and notification system, in accordance with the ORO 's plan and/or procedures, compltion of system activation should be accomplished in a timely manner (will not be. subject to speciic time requirements) forpi't_:AWy alerting/notification. The initial message should include the elements required by current FEMA REP guidance.

Unclassified Radiological EmergefidyPe

'-edness Program (REP)

AfterAction Report/Improvement Plan Pilgrim Nuclear Power Station Offsite Response Qrganizations (ORO,) w ith oide ralertihg`as'th ii1-i*i aiethbd oaM-f Y#g di:

notifying the public should demonstrate the capability to accomplish.the primnaiy route alerting following the decision to activate the alert and notification system, iii hniy m (1 ll' nabte hibjea' t6pcific tifne'rdquirements) in acco-dance with the ORO's plan and/or procedures. At least one route needs to be demonstrated and egaluited.-The*select'edd/te(s)fsh16idvaiyfroM exercise to exercise.. However, the most difficult route should be demonstrated at least once evey siyedi*'. }7)4ll bt and n ot~ea~it~ acti*,'iigs'al6ng the route'shbiild be sihm, "a6ed, ('ihat is, the:

message that wPouiild actually be used is readfor the evaluator; but not actually br6ad~ast,% as agreed upon in the extent *f playv Actual esting of the nrobilepublic addess system wil'be conducted at some agreed upon location. The initial message should include-the elements required by current FEMA REP guidance.

For exoercise purposes, tidIely is defiied as "the responsible OR 0 personnel/representatives demonstfate actions to disseminate' the: dapropriate inforiiation/instriuwtiorns' withh S'ense of ii 'ge'#c 1 an):d Without u~di&delciy. " If!~biysagO dissemination is to be identifiid as hot having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timel4.

Pr*ocedures to broadca'si the 'mes'ageshould befuliy-demionst'rated as they' ivoU'd in an actual emrenyupt te' asiio.,

r M

emergency up to the poit of transmission. Broadcast of then message(s)jo, 'test-messages is not req f

u Trea.*Jh' aler--%'igna! activa-ion 'tni be simulated. However, the-procedures*,sh duld be.:

demonstrated up to the"point of actual'dctivation.:

The icdpability of the p rimary n6tficdtion systerh to-b&oadcast an iistruetioral message on a 24-hour basis should be 'verified during'an interview".with appr6priate personnel from the primary notification sys'tem.

All activities for this criterion must be based on the ORO's plans and procedures and completed as they would be in an actual emergency, except as noted above or otherwise indilcated in the extent ofplay agreement.

Massa4chusetts E*teit of Play ME.. MA to.i,

?f6:a' fi. i

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/hmprovement Plan Pilgrim Nuclear Power Station V

~

"~4~,~2; r

~j4.

t?

AR CA-PLYMOUTH-EOC Issue Number: 48-08.-5.a. 1A-04.

Condition: Stateinotification to sound sirens at the Site Area Emergency was not acfed upon in a timely manner at the Plymouth'Emergency Operations Center (EUC). Activation directed to occur at 1035 did not take place (simulated) until

" 1050.

':7 Possible Cause: Notification advisory from the State was received by the EOC radio dispatcher at 1031, but the emergency.manager indicated he waited for receipt of a fax with a. signature authorization that-was never received. He ultimately difected the sirens activated based on. informiation on :the state web log.

Reference:

NUJREG-0654 E:5, E.6 and E.7, Effect: Sirens in adjacent.jurisdictions were sounded at 1035, 15 minutes earlier than in Plymouth. The objective of coordinaiing" synchronized sounding of the sirens was niotachieved. Likewise, :h* State*originated EAS message would have been'broadcast prior to the sounding ofthe'sirens in Plymouth.

Recommendation: Re-evaluate the policy that the emergency manager does not act on siren activation without a "written' directive from.the state.:

Criterion 5. a. 2: [RESER VED]

Criterion 5a.3:.Activities"associated with: FEMA""approved exception areas (where applicable) are completed within 45 minutes following the initial decision by authorized offsite em'ergency 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 CRO of afailure:ofthe priniarj, alert andnotification system. (NVUREG,0654, E.

6, Appendix 3.B.2.c)

Extent of Play Offsite Response Organizations (ORO) with FEMA -approved exception areas (identified in the approve'dAlert and Notification System Design Report) 5-10 miles from the nuclear power plant should demonstrate the capability to accomplish primary alerting and notification of the exception area(s) within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The 45-minute clock will begin when the OROs make the. decision to activate the alert and notification system for the first time for a specific, emergency.situation. The initial message shoul1l42t a minimum, include. a statement that an emergency exists at the plant and where to obtain additional information.

I

Unclassified Radiological Emergency P'ýeredness Program (REP)

AfterAction-Report/lmproyement Plan Pilgrim Nuclear Power Station For excepttibn:a'riag, at: east one route aneeds te ontFated idevaluatod.T...

selectedroiute(s)-shoultdavo.y p m exercise to exercise. However, the most difficultyroute should be demonstrated at least. once. every six years. Al/alert and notification -activities along the route should be..simulated (that is., the message that would actuallyb e useq is read for, the evaluator; but njot actually broadcast) as agreed upon in the extent offplay. Actual tesqtig of

ýfthe mobile-public address.system,.-jl be conducted at some agreed-upon location.

Backup, alert and notification of the public shouqld be completed within 45 minute following the detection by the ORO of afafilure of the primary alert and hotification system., Backup route alerting.only needs to.be demonstrated and evaluated, in accordance with ihe.bROs plan.

and/or procedures, and theextent of play agreement, if the exercise scenario calls forfailure of any portion of the primary system (s), or if any portion of the.primaiy system(s) abtualN fils to function; If demonstrated, only one route -needs to be selected.and demonstrated' All alert and notification activities along the. route should be simulated (that is, the message that would actually be usedis,read for the evaluator, b*ut not actually broadcast) aspagr'eýedqu9in the extent ofplay., Actual testing of the mobile public address system will be conducted at some agreed-upon location.

j J

All activities for this criterion mnust be based on -the ORO 'splans and procedures and completed as they would be in an actual emergency, except as noted above or otherwise indicated in the extentof play agreement,..

Massachusetts Extent of Play Sub-element 5.b - Emergency Information and Instructions for the Public and the Media Intent This, sub-element is derived from NUREG-0654. which provides that OffsiteResponseq, r- ý '.

I.

`

• ; i i* " \\ '.':

,n Organizations (ORO) should have. the capability to disseminate to the public, appropriate emergency information and.instructions,, including any recommendedprotectivýeacins./n addition, NUREG-0654 pr6yides that. OROs should ensure that the capability,es for providing information to the media. This includes the availability'ofaphysical ocadion for use by the media during an emergency. NUREG-0654 also provides that a system should be available for dealing with runmors. This system will hereafter be known as the public inquiry hotline.

Criterion 5.b.1:I OROs provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E.,,5 7; G.3.a, G.4.c)

Extent of Play:..

Subs quent,'emergency information and instructions should be provided t&* th Public and the media in a timely manner (will not be subject to specific time requiremen ts). For exercise purposes, timely is defined as "the responsible ORO personnel/representatives dembnstrate actionsm to disseminate the appropriate information/instructions; with. a se nse,pf.urgncy and without undue delay." If message disseminatiooW. to be identified as not hqving been.

accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station The ORO should ensure that emergency information and instructions are consistent with, protective action decisions made by appropriate officials.- The emnergency information should:

contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, information concerning pets, shelter-in-place instructions, informnation. co*cerning protective actions for, schools anid special populations, public inquhy telephone number, etc.) to assist the public in ca~ying out protective action decisions provided to them. The ORO should also be prepared to disclose and explain the Emergency Classication.Level (ECL) of the incident. At a mini'inlum, this information must be included in media briefings and/or media releases. OROs should demonstrate Mhe calpability to use language that is clear and understandable to the public within both, the plume and ingestion pathway E2PZs.. This includes demonstration of the capability t6 use familiar landmarks and boundaries to describe protective action areas.

The dmerge.ncy iformatign should he all-inclusive by including previously identified protective action areas.that are still valid, as well as new-areas. The OROs should deinonstrate the capability to ensuie that emergency information that is no longer.valid.is rescinded and not repeated by broadcast media. In addition, the OROs should demonstrate the capability to ensure that current. emergency information is repeated at pre-established interv'als in accordance with ihe plan and/or procedu.res.

OROs should demonstrate the capability to develop emergency infor'mation in a hon-English language when required by the plan and/or procedures.'

If ingestion pathway measures are exercised, OROs should demonstrate that a system exists for rapid dissemination of ingestion pathway information to pre-determined individuals and.

businesses ih acFbrdah

-Withe ORO 's plan and/or pr6ceduies.

OR"OS sh~ould dnbstrjte the. capabTiity to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. This would, include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the situation warrants. The OROs should demonstrate the capability to respond, appr!oppriately to inquiriesfirom the news media. All information presented-in media briefings arid n'iedia releases should be consistent 'with'protectiv'e action decisions and other emergency information provided to the public. Copies ofpertinent emergency information (e.g.,

EAS messages and media release) and media information kits should be available for dissemination to the-media.

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

All activities for this criterion must be'basedon the ORO'splans and procedures and completed, as they would be in an actual emergency, unlesQboted above or otherwise indicated in the extent ofplay agreement.

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Unclassified Radiological EmergencyPreparedness Program (REP)

-After Action Report/Improvenient Plan

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NOTE: "On the Spot" corrections approved for the fordmentioned sub-elements. That portion of the evaluation element dealing with "timely manne;" and emergency

- information being all-inclusive. Plaers'should have the opportuntP" to Yre-demiobnstrate this criterion in subsegueuit zdssaii.s..

Note: If during the exercise, a participant demonstrates this sub-element udnsatlsfiact'only, the FEMA Evaluator will informr the participant and.the Controller. After an" on thepot" re-tiaining by the state or local organization, the FEMA Evaluator will provide the participant anothe* opportunity to re-demonstrate the activity that same day.

EVALUA TION AREA 6: Support-Operation/Facilities Su'b-element 6. a - Mon itoring and Decontamination of Evacuees and Emergency Workers add Registration of Evacuees Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) have the capability to impoent radiological monitoring and,

decontamination of evacuees and emergency worMers, while minimizing contamination, of the facility, and registration of evacuees at reception centers.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reporl/Improvement Plan Pilgrim Nuclear Power Statioi Criterion 6. a.]: The reception center/emergency worker facility has appropriate space, iadeq'uate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers' (NUREG-0654, J.1 O.h; J.12;'

K. 5.a)

Extent of Play Radiological monitoring, decontamination, and registration facilities for evacuees/ emergency.

workers should be set up and demonstrated as they would be in an actual emerency or-as indicated, in the extent ofplay agreemerit. This would include adequate space for evacuees.'

vehicles. Expected demonstration should include 1/3 of the monitoring teams/portal monifoios required to monitor 20% of the population 'allocated to the facility within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Prior to using monitoring instrument(s), the monitor(s)'should, demonstrate the process of checking the instrument(s) for proper operation.

All-instruments should.be ins ected, inventoried, andbopeationally~checked before each use.

Instruments should be calibrated in accordance-with the mamifacturer's recommendations."

Unmodified CD V-700 series instruments and other instruments without a mani~faturer 's recommendation should be calibrated annually. Modified CDV-700 instruments should be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration should be on each instrument, or calibratedfrequency can be verified by other means. Additionally, instruments being used to measure adtivity should have a range of readings sticker affixed to the side of the instrument.

Staff responsible for the radiological monitoring of evacuees should demonstrate the capability to attain and sustain a monitoring productivity rate per hour needed to monitor the 20%

emergency planning zone (EPZ) population plan ning base within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />., This monitoring productivity rate per hour is the number of evacuees That can be mi6hitOredper hour by the total complement of monitors using an appropriate monitoring procedure. A minimum of six individuals.per monitoring station should be monitored,. using egquipment and procedures specified in the plan and/or prodedures, to allow demonstration of monito.ring, decontamination, and registration capabilities. The monitoring sequences for 1he first SUi simulated evacuees per monitoring team will be timed by the evaluators in order to determine whether the twelve-hour requirement can be meet. Monitoringgoftmergency workers does not have to meet the twelve-hour requirement. However, apprýýpriate monitoring procedures.'should be demonstrated for a minimum of two emergency workers.

Decontamination of evacuees/emergency workers may be simulated and conducted by interview.

The availability ofprovisions for separately showering should be demonstrated or explained The staff should demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs and appropriate means (e.g., partitions, roped-off areas) to separate clean from potentially contaminated areas. Provisions should also exist to separate contaminated and uncontaminated individuals, provide changes of clothing for individuals whose clothing is contaminated, and store contaminated clothing and personal belongings to prevent firther contamination of evacuees or facilities. In addit' fior any individual found to be contaminated, procedures should be discussed concerning.the )[andling ofpotential contamination of vehicles and personal belongings.

Unclassified Radiological Emergency Prieparedness Program (REP)

After Action Reportlimprovement Plan Pilgrim Nuclear Power Station M,.nitoringpersondneLshould explain the'use.ofaton. evels f6r-dOtermmn7g the ie*f7"d;'

for decontamination. They should also explain the procedures for, referring eyacuees who canwnot be adequately decontaminated for assessment and follow up in accordance with the ORO's plans and procedures. Contamination of the individual will be determined by controller inject and not simulated with any low-level:radiation source.

The capability to ýregister individuals uifpon completioh of the monitoring and deonitaminatiOn activities should be demonstrated. The registration activities dem7onstrated should include the es~tablishment of a registration recoidfor each individuazýlcoflsisting o th~e individuWl's'name, address,- results of monitoring, and time 'of decontamination, if any,.or as othlerwise designated in the plan. Audio recorders, camcorders', or written records are all acceptablý me6ns for registration.

All activities associated with this criterion must, be based on the ORO's plans and procedures and completed,. as they would be in-an actial emnergency, unless otherwise'indicated in the exten of play agreement.

Massachusetts Extent of Play

.I Successfully demonstrated 70.

Sub-element 6.b-Monitoring and Decontamination of Emergenc. Wo:k~r Equlpment Intent This sub-element is derivedfrom NUREG-0654, which provide~sthafiOff~ite Resvanp".ne Orgahizations'(ORO) have'the capability to impiemenicadiological ni'iorning an"d" decontamination of emergency worker equipment, including vehicles.

Criterion 6.b.1: The facility/ORO has adequate procedures and resources for the accomplishment ofmonitoring and decontamination of emergency worker equipment, including vehicles. (NUREG-0654, K.5.b).

Extent of Play The monitoring staff should demonstrate the capability to monitor equil5ienl, includin(g vehicles, for contamination in accordance with ihe Offsite ResPonse Obgahniati"s"(OR 0j plIaiS and.

a procedures. Specific attention should be given to eqiipment, including vediicles, th'at was in contact with individuals found to be contaminated:. The' monito ing staff shoutd-d'ho ns'iate the capability to make decisions on the need for deconi'amindtion of equipment, including vehicles, based on guidance levels and procedures stated in the plan and/or procedures.

The area to be used for monitoring and decontaminatio'n shouild beJet up ;s it would be in an actual emergency, with all route markings, instl-Q eiiatian, record keeping and contamination control measures in place. Monitoring procedures should be demonstrated for a minimum of one vehicle. It is generally not necessary to nmonitor the entire swuJace of vehicles. However, the capabilitv to monitor areas 7u7h o;-,_nrlits, cill'

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station should be demonstrated Interior suifaces of vehicles that were in contact with individuals found to be contahlinated should also be checked.

• Decontamination capabilities, and provisions for vehicles and equipment that cannot be decontaminated, may be simulatedand conducted by interview.

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

Massachusetts Extent of Play Tisb~1ntwas suic'essfuih~

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ýist209 Sub-element 6.c - Temporary Careoof Evacuees Intent This sub-element, is derivedfrom NUREG-0654, which provides that Offsite Response Organizations (ORO) demonstrate the capability to establish relocation centers in host areas.

Congregate care is normally provided in support of OROs by the American Red Cross (ARC) under existing letters of agreement,.

Criterion 6.c.1: -Managers of eon gegate care facilities demonstrate that the centers have resources. to provide services and accommodations consistent with American Red Cross planning guidelines. (Found in MASS CARE - Preparedness Operations, ARC 3031) Managers demonstrate the procedures to assure that evacuees have been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities. (NUREG-0654, J.10.h, J. 12)

Extent of Play Under this criterion, demonstration of co)igregate care centers may be conducted out of sequence with the exercise scenario. The evaluator should conduct a walk-through of the center to deternnine, through observation and inquiries, that the services and accommodcations are consistent with ARC 3031. In this simulation, it is not necessary to set up operations as they would be in an actual emergency. Alternatively, capabilities may be demonstrated by setting 'mp stations for various services and providing those services to simulated evacuees. Given the substantial differences between demonstration and simulation of this objective, exercise demonstration expectations should be clearly specified in extent-of-play agreements.

Congregate care staff should also demonstrate the capability to ensure that evacuees have been monitored for contamination, have been decontaminated as appropriate, and have been registered before entering the facility. This capability mayp(gietermined through an interview process.

If operations at the center are demonstrated, material that would be difficult or expensive to transport (e.g., cots, blankets, sundries, and large-scale food supplies) need not be physically 11 InIn

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Unclassified Radiological Emergency'Preparedness Program (REP)

After. Action Report/Inprovement Plan Pilgrim Nuclear Power Station available -at th facility: (facilities),., Ho eve{r iiIibiof such' ite iis. tioiihd j*rzfed bj providingtthe evaluator a list ofsouirces.*wiih locations and estimates af quantiities."..,

All. activitiesoassociatedJwith this criterion. must be basedon the ORQ 'splans andprioceduires and completed as, they~would be in an actual emnergency, unless noted above or otherwise indicated in

'the extent ofpldy. qgreement.,"..

Massachusetts Extent of Play Qo~ngregate.care centersw~w~i1~f~~tlactiated Se iter: surveys* ewil pfovided 't EMEAof6new, Sub-element 6. d - Transportation and Treatment. of Contaminated Injured Individuals Intent This sub-element -is derived from NUREG-0654, which provides that Offsite Reqsponse, Organizations (ORO) should have the capability to transpýort contamninated~injui ed individuals to medical facilities with the capability to Provide mediccdl serices..

Criterion 6.d.]: The facility/ORO,.has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contamzinated injured individualsi. (NUREG-0654, F.2 H.10, K.5.a, b; L1, Extent of Play Monitoring, decontamination, and contamination control efforts, Will not delay,. urgent medical care for the victim.

Offsite Response Organizations (OR0) should demonstrate the capability to transport contaminated injured individuals to medicalfacilities. An ambulance should be. used forthe response to the victim. However, to avoid taking an ambulance out of service for an extended time, aiiy vehicle (e.g., tar, truck, or van) may be 'Utilized to transport the victim to the medical facility. Normal communications between the ambulance/dispatcher and the receiving medical facility should be demonstrated. If a substitute vehicle is used for transport to the medical facility, this communication must occur prior to releasing the ambulance from the drill. This communication.would include reporting radiation monitoring results, if available. Additionally, the ambulance crew should demonstrate, by interview, knowledge of Where the ambulance and crew would be monitored and decontaminated, if required, or whom to contact for such information.

Monitoring of the victim may be peiformed prior to transport, done enroute, or deferred to the medicalfacility. Prior to using a monitoring instrument(s), the monitor(s) should demonstrate the process of checking the instrument(s) for proper operation. All monitoring activities should be completed as they would be in an actual emergency. Appropriate contamination control measures should be demonstrated prior to and1-Wing transport and at the receiving medical facility.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Pc.ver Station All instruments should be inspected, inventoried, and operationally checked before each use.

Instruments should be calibrated in accordance with the manufacturer's recommendations.

Unmodified CDV-700 series instruments and other instruments without a manufacturer's recommendation should be calibrated annually. Modified CD V-700 instruments should be calibrated iin accordance with the recommendation of the modification manufacturer. A label indicating such calibration should be on each instrument, or calibratedfrequency can be verified by other means. Additionally, instruments being used to measure activity should have a range of readings sticker affixed to the side of the instrument.

The medical faciliiy should demonstrate the capability to activate and set up a radiological emergency area for treatment. Equipment and supplies should be available for the treatment of contaminated injured individuals.

The medical facility should demonstrate the capability to make decisions on the need for decontamination of the individual, to follow appropriate decontamination procedures, and to maintain records of all survey measurements and samples taken. All procedures for the collection and analysis of samples and the decontamination of the individual should be demonstrated or described to the evaluator.

All activities associated with this criterion must be based on the ORO's plans and procedures and completed as they would be in an actual emergency; unless noted above or othei-wise indicated in the extent ofplay agreement..

Massachusetts Extent of Play

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