Text

After Action Report/Improvement Plan for the October 4, 2011, Radiological Emergency Preparedness (REP) Exercise
	ML12072A160
Person / Time
Site:	Kewaunee
Issue date:	02/28/2012
From:	Velasquez A; US Dept of Homeland Security, Federal Emergency Management Agency
To:	; Office of Nuclear Reactor Regulation
References
	Download: ML12072A160 (102)
	v • d • e

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

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

Enclosed is one copy of the After Action Report/Improvement Plan for the October 4, 2011, Radiological Emergency Preparedness (REP) Exercise for the Kewaunee Power Station. Under separate cover, four copies of this report are being sent to the State of Wisconsin for distribution to Kewaunee and Manitowoc Counties, along with an additional copy for the State. The State of Wisconsin, Kewaunee and Manitowoc Counties, and the utility owner/operator, Dominion, Kewaunee Inc. participated in this exercise.

The Final Report was prepared by the staff of the U.S. Department of Homeland Security/Federal Emergency Management Agency (DHS/FEMA) Region V, Radiological Emergency Preparedness Program.

No Deficiencies were identified for any jurisdiction during this exercise.

Two ARCAs from previous exercises were not successfully demonstrated during this exercise:

The State of Wisconsin, ARCA #1 (49-10-lel-A-01) was identified under Criterion 1.e. 1 which was issued in 2010 during the Point Beach REP Exercise. Acceptable ranges of operation were not posted on the calibration stickers on the Bicron Micro-Rem meters or the Ludlum Model 12 count rate meters used in the Mobile Radiological Laboratory or the Sample Receiving Area. Nor was the Field response manager contacted for assistance because there was no means to ensure the instrument was operating properly. This ARCA remains unresolved.

The following actions will be taken in response to ARCA #49-10-1el-A-01 issued against the State of Wisconsin, Mobile Radiological Laboratory. Acceptable ranges of operation, in the proper units, will be documented on each Ludlum Model 12 and Bicron pUL www.fema.gov

NRC Micro-Rem meter used by field teams or Forward Operations/Mobile Laboratory personnel (FOC/ML). In addition, the two Ludlum Model 375/2 area monitors and one Ludlum Model 177 count rate meter located in the FOC/ML will be in calibration. An acceptable range of operations, in the proper units, will also be documented on each of these instruments.

This ARCA (#49-10-1 el-A-01) will be re-demonstrated at the April 2012 Point Beach Nuclear Plant exercise.

The State of Wisconsin, ARCA #2 (49-10-5bl-A-02) was identified under Criterion 5.b. 1 which was issued in 2010 during the Point Beach REP Exercise. Exercise Release #3 was marked "For Immediate Release," and was issued to the JIC and Counties at 1012 hours0.0117 days 0.281 hours 0.00167 weeks 3.85066e-4 months , but the Hotline staff was not operational until 1040 hours0.012 days 0.289 hours 0.00172 weeks 3.9572e-4 months . The State EOC PIO anticipated that the JIC would announce the establishment of the Hotline but apparently did not anticipate the distribution of the release by the County PIOs. Until the JIC and Hotline become operational, the State and County EOC PIOs provide incident related public information to the media and respond to public inquiries directly. The State EOC PIO apparently anticipated that coordination with the JIC implied full coordination with Counties, but when combined with actual communications systems malfunctions during the transition of responsibilities, the coordination was incomplete.

This issue was given during Point Beach in 2010 and could not be re-demonstrated during the Kewaunee 2011 due to the hotlines being at different locations for Point Beach and Kewaunee. This will be re-demonstrated during Point Beach 2012.

The State of Wisconsin has added an item to the Public Information Officer Check List instructing them to contact the Public Information Hotline prior to distributing media releases stating or indicating that the hotline is operational. An additional checkpoint has also been added to the Operations Check List, which includes requesting the State Public Information Officer to contact the utility Public Information Hotline to ensure that they are operational prior to writing a media release stating they are operational.

This ARCA (#49-10-5b1-A-02) will be re-demonstrated at the April 2012 Point Beach Nuclear Plant exercise.

Two ARCAs from previous exercises were successfully re-demonstrated during this exercise:

Peterson FEB 2 8 2012 Page #3 Incident Response Plan Volume 2, FOC/MRL Operations Manual. Using a completed Field Team Dispatch Briefing Checklist; the Field Team Coordinator performed a pre-deployment brief to all Field Team and FOC/MRL support staff prior to Field Team deployment. This ARCA was successfully demonstrated during this exercise.

The State of Wisconsin ARCA #4, for the State of Wisconsin (33-09-5bl-A-05) identified under Criterion 5.b. 1 which was issued during 2009 Kewaunee REP exercise -

The Virginia Call Center did not receive JIC News Releases, EAS and Special News Broadcast messages regarding protective action decision for the public. After receiving and reviewing, documentation and by evaluator's observations, it has been determined that there was adequate support that communications between the Virginia Call Center and the JIC was much improved. This ARCA was successfully demonstrated during this exercise.

There were five Planning Issues associated with this exercise:

The State of Wisconsin, Planning Issue #1 (33-11-lel-P-01) identified under Criterion i.e. 1, the State of Wisconsin Radiological Incident Response Plan (RIRP) and Manitowoc County Emergency Operations Plan and supporting SOPs, checklists and forms identify the Permanent Record Dosimeters (PRDs) issued to emergency workers as TLDs (Thermo-Luminescent Dosimeters). However, Landauer/Luxel + Optically Stimulated Luminescent Dosimeters (OSLDs) were issued at the Manitowoc County Highway Department Reception Center. The table in Volume IV, Section 2.3.1, of the State Radiological Incident Response Plan (RIRP), includes a Dosimeter Issuance Policy table that lists Minimum Recommended dosimeter types by Response Staff Type and includes a column that is titled TLD or OSL which indicates that either TLDs or OSLDs may be issued. The table in Volume IV, Section 2.3.1, of the RIRP also indicates that the issuance of 0-20 R DRDs is NA (meaning Not Applicable) to all Response Staff Types.

However, 0-20 R DRDs were issued to the emergency workers who staffed the Personnel and Vehicle Monitoring/Decontamination Stations at the Reception Center (including the following Response Staff Types: Vehicle Monitoring, Vehicle Decontamination, Personnel Monitoring, Portal Monitoring, Resurvey Monitoring, Personnel Decontamination, Decontamination Exit Monitoring, and Monitoring Station Recording).

The State of Wisconsin, Planning Issue #2 (33-11-6al-P-02) identified under Criterion 3.c.2, the facility has one shower stall that would be used for whole-body

NRC FEB Page 218 2012

4 Personnel Monitoring, Portal Monitoring, Resurvey Monitoring, Personnel Decontamination, Decontamination Exit Monitoring, and Monitoring Station Recording).

The State of Wisconsin, Planning Issue #2 (33-11-6al-P-02) was identified under Criterion 3.c.2, the facility has one shower stall that would be used for whole-body Evacuee/Emergency Worker Decontamination. The stall is not large enough to provide privacy for staging a clean towel and body covering (Tyvek suit), disrobing and placing contaminated clothing in a receptacle, showering, drying with the clean towel, and donning the clean garment. These activities could be viewed by the Decontamination Team Recorder, who would hand a clean towel to the evacuee/emergency worker for drying and a Tyvek suit body covering for donning, as well as by the Entrance and Exit Monitors.

When queried by the Evaluator, the Appleton Hazmat Team personnel who operated the station stated that the Team has no female personnel Who are trained Monitors or Recorders.

The floor diagram on page ATT 1-21 of the Manitowoc County Emergency Operations Plan (Attachment 1, Manitowoc County Reception Center Personnel Decontamination) does not accurately reflect the actual configuration of the personnel decontamination facility. The diagram shows a Hand Washing Sink located outside the Decontamination Station Room (combination Locker Room/Shower in the diagram) past the Frisking Stations. During this exercise, the sink used for hand washing by Evacuees/Emergency Workers was located inside (rather than outside) the combination Locker Room/Shower in a separate toilet/wash room. The combination locker/shower room portion of the diagram does not accurately reflect that actual configuration of the room(s).

Manitowoc County, Planning Issue #3 (33-11-3c2-P-03) was identified under Criterion 3.c.2. The Manitowoc County Executive at the Emergency Operations Center (EOC) directed the Mishicot Superintendent to evacuate schools in the School District of Mishicot at the Site Area Emergency, Emergency Classification Level (ECL). Staff at the Manitowoc EOC did not receive confirmation that the School District of Mishicot had successfully evacuated their schools.

Procedures for staff at the Manitowoc EOC (Manitowoc County Emergency Operations Plan, Annex I, Part 2) do not match the specific procedures for school staff (Manitowoc County Emergency Operations Plan, Annex I, Part 2, Attachment 7, Nuclear Emergency Evacuation Plan for the School District of Mishicot). The Mishicot Superintendent is

NRC FEB 28 012 Page #5 required to inform the Human Services representative at the EOC when evacuation is complete, but the EOC procedures do not require any staff, including the County Executive, Emergency Management Director, or Human Services representative to confirm when evacuation is complete.

The State of Wisconsin, Planning Issue #4 (33-11-4al-P-04) was identified under Criterion 4.a. 1. The instructions in the Wisconsin Department of Health Services Radiological Incident Response Plan for response check of the Fluke Victoreen 451 B Ion Chamber Survey Meter did not match the requirements posted on the calibration sticker for the instrument or the instructions posted with the check source jig in the mobile laboratory.

According to Wisconsin Department of Health Services Radiological Incident Response Plan, Volume 3, Page 21, the instructions to source check the Victoreen 451 B were Turn the meter over and slide back the plastic cover. This exposes the Beta window. With the assistance of FOC staff, obtain the check source jig. Ensure the check source is set snugly within the square insert, and place the meter into the jig such that the Beta window is flush with the check source.

The calibration sticker on the side of the Victoreen 451 B clearly indicated that the response check should be conducted with the cover on the instrument closed. The instructions posted with the check source jig in the mobile laboratory also indicated that the response check should be conducted with the cover on the beta window closed.

The State of Wisconsin, Planning Issue #5 (33-11-4al-P-05) was identified under Criterion 4.a. 1. Restricted Area Field Team 2 did not record background measurements in a clean area for either the Fluke Victoreen 451 B Ion Chamber Survey Meter or the Ludlum Model 12 Rate meter with Model 44-9 Probe. During interview, team members were unable to recall what the original or baseline background readings had been.

There are no instructions in the Wisconsin Department of Health Services Radiological Incident Response Plan to record baseline instrument readings.

According to the procedures for the Ludlum Geiger Counters and Pancake Detectors (Wisconsin Department of Health Services Radiological Incident Response Plan, Volume 3, Page 21) the operator should Step the meter down to the lowest scale and observe background reading with slowest response setting. Make sure the RESET button returns needle to zero and that the background readings are less than 500 cpm However, there are

NRC FEB 28 2012 Page #6 no instructions to record the background reading. The procedures for the Victoreen 451 B do not address background readings.

The five Planning Issues identified in the After Action Report/Improvement Plan will be addressed in this year's 'Plan Submittal.' ISSUE NOs 33-1 1-4al-P-04, 33-11-4al-P-05, and 33-1 1-lel-P-0l will be addressed in the State of Wisconsin Radiological Incident Response Plan (RIRP). ISSUE NOs 33-11-6a1-P-02 and 33-11-3c2-P-03 will be addressed in the Manitowoc County Emergency Response Plan. (Please see Attachment 1 for a description of these Planning Issues.) [Note: After discussions between FEMA and WEM, it was determined that FEMA will not have had sufficient time to review the Plan submittals prior to the Point Beach Nuclear Plant 2012 exercise. Consequently, the demonstration of the exercise criteria associated with these issues will differ from the plans the evaluators may be using.]

Based on the results of the October 4, 2011, exercise, the offsite radiological emergency response plans and preparedness for the State of Wisconsin and affected local jurisdictions, site-specific to the Kewaunee Power Station, can be implemented and are adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency at the site.

Therefore, the Title 44 CFR, Part 350, approval of the offsite radiological emergency response plans and preparedness for the State of Wisconsin site-specific to the Kewaunee Power Station, granted on June 15, 1985, remains in effect.

NRC Page #7 Copies of this Report were transmitted to DHS/FEMA National Office, Nuclear Regulatory Commission Region III and the State of Wisconsin.

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

Sincerely, Andrew Velasquez III Regional Administrator Enclosure (1)

Kewaunee Power Station After Action Report/

Improvement Plan Exercise Date - October 04, 2011.

Radiological Emergency Preparedness (REP) Program

( FE A Published February27, 2012

Unclassified ,

Radiological Emergenc Preparedness Program (REP)

Atter Action Report/Improvement Plan Kewaunce Power Station I-1~

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power. Station Kewaunee Power Station After Action Report/Improvement Plan Published February27, 2012 Contents Executive Summary 5 Section 1: Exercise Overview 14 1.1. Exercise Details 14 1.2 Exercise Planning Team Leadership 14 1.3 Participating Organizations 15 Section 2: Exercise Design Summary 18 2.1 Exercise Purpose and Design 18 2.2 Exercise Objectives, Capabilities and Activities 18 2.3 Scenario Summary 18 Section 3: Analysis of Capabilities 19 3.1 Exercise Evaluation and Results 19 3.2 Summary Results of Exercise Evaluation 19 3.3 Criteria Evaluation Summaries 26 3.3.1 Wisconsin Jurisdictions 26 3.3.1.1 State of Wisconsin - State Warning Center #1 - Inital 26 Warning Point 3.3.1.2 State of Wisconsin - State Warning Center #2 - 26 Initial Warning Point 3.3.1.3 State of Wisconsin - Emergency Operations Center 27 3.3.1.4 State of Wisconsin - State Emergency Operations 28 Center - Radiological Coordinator 3.3.1.5 State of Wisconsin - Forward Operating Center 29 3.3.1.6 State of Wisconsin - Forward Operations Center - 30 Mobile Radiological Laboratory 3.3.1.7 State of Wisconsin - Restricted Area Field Team 1 31 3.3.1.8 State of Wisconsin - Restricted Area Field Team 2 32 3.3.1.9 State of Wisconsin - Joint Information Center - 35 Media Center 1

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Kewaunee Power Station 3.3.1.10. State of Wisconsin - Kewaunee County. Emergency 36 Operations Center - State Liaison 3.3.1.11. State of Wisconsin - Manitowoc County Emergency 37 i Operations Center - State Liaison 3.3.1.12 State of Wisconsin - Highway Department - 37 Evacuee/Emergency Worker Monitoring and Decontamination 3.3.1.13 State of Wisconsin - Highway Department - 42 Evacuee/Emergency Worker Monitoring and Decontamination of Equipment and Vehicles 3.3.1.14 State of Wisconsin - Holy Family Medical Center - 42 Medical Service - Facility 3.3.2 Risk Jurisdictions , 43 3.3.2.1 Kewaunee County - Sheriffs Dispatch Center - . 43 Initial Warning Point 3.3.2.2 Kewaunee County - Emergency Operations Center 44 3.3.2.3 Kewaunee County - Sheriffs Department - Traffic 44 Control Point 3.3.2.4 Manitowoc County - Joint Information Center - 45 Public Information Officer 3.3.2.5 Kewaunee County - Joint Information Center - 45 Public Information Officer 3.3.2.6 Kewaunee County - Emergency Alert System - 46 WSRG l 3.3.2.7 Kewaunee County - Kewaunee School District - 46 Evacuation School 3.3.2.8 Kewaunee County - Annex Building - Dosimetry 47 Distribution Point 3.3.2.9 Kewaunee County - Route Alerting - Exception Area 48 3.3.2.10 Manitowoc County - Sheriffs Dispatch Center - 48 Initial Warning Point 3.3.2.11 Manitowoc County - Emergency Operations Center 49 3.3.2.12 Manitowoc County - Sheriffs Department - 50 Dosimetry Distribution Point i 3.3.2.13 Manitowoc County - Sheriffs Department - Traffic 51 Control Point 3.3.2.14 Manitowoc County - Lakeshore Aviation - Route 51 Alerting 3.3.2.15 Manitowoc County - Emergency Alert System - 52 WCUB/WLTU 2

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station 3.3.2.16 Manitowoc County - Michicot School District - 52 Evacuation School 3.3.2.17 Manitowoc County - Highway Department - 53 Dosimetry Distribution Point 3.3.2.18'Manitowoc County - Highway Department - 54 Evacuee/Emergency Worker Registration 3.3.2.19 Manitowoc County - Lakeshore Technical College - 54 Congregate Care Center 3.3.2.20 Manitowoc County Manitowoc County Fire 55 Department/EMS - Medical Service - Transportation Section 4: Conclusion 56 Appendix A: Improvement Plan 61 Appendix B: Exercise Timeline 67 Appendix C: Exercise Evaluators and Team Leaders 68 Appendix D: Acronyms and Abbreviations 71 Appendix E: Exercise Plan 74 3

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I After Action Report/Improvement Plan Kewaunee Power Station I

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After Action Report/Inprovement Plan Kewaunee Power Station EXECUTIVE

SUMMARY

On October 4, 2011, a Radiological Emergency Preparedness (REP) Full Participation Plume Exposure Pathway Exercise was scheduled for the 10-mile Emergency Planning Zone (EPZ) around the Kewaunee Power Station (KPS) by the U.S. Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA) Region V. The purpose of this exercise was to assess the level of State and local preparedness in responding to a radiological emergency.

The most recent exercise at this site was conducted on June 23, 2009. The qualifying emergency preparedness exercise was conducted on January 21, 1981.

DHS/FEMA would like to acknowledge the efforts of the many individuals who participated in the exercise. In particular,the State of Wisconsin and the risk counties of Kewaunee and Manitowoc.

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

Cooperation and teamwork on the part of all participants was evident during the exercise.

This After Action Report/Improvement Plan (AAR/IP)contains the evaluation of the biennial exercise and the following out-of-sequence activities:

State of Wisconsin:

Evacuee/Emergency Worker Monitoring/Decontamination Evacuee/Emergency Worker Equipment Monitoring/Decontamination including vehicles Medical Services (MS-i) - Hospital Facility Manitowoc County:

Dosimetry Distribution - Reception Center Registration - Reception Center Congregate Care Center 5

Unclassified Radiological Emergency Preparedness Program (REP)

After Action. Report/Improvement Plan Kewaunee Power Station EV2 - Host School Interview - Luxemburg School-District Medical Services (MS-1) - Transportation Kewaunee County:

There were no out-of-sequence activities conducted in Kewaunee County.

There were no Deficiencies identified for any jurisdiction during this exercise. -

There:were no new Areas Requiring Corrective Action (ARCAs) identified and unresolved, during this exercise.

There were no Planning Issues from a previous exercise identified.

Two ARCAs from previous exercises were not successfully demonstrated during this exercise:

The State of Wisconsin, ARCA #3 (49-10-lel-A-01).identified under Criterion !.e. 1 which was issued in 2010 during the Point Beach REP Exercise - Acceptable ranges of operation. were not posted on the calibration stickers on the Bicron Micro-Rem meters or. the LudlumModel 12 count rate meters used in the Mobile Radiological Laboratory or the Sample Receiving Area nor was the Field response manager contacted for assistance because there wasno means to ensure the instrument was operating properly. This ARCA remains unresolved.

The State of Wisconsin, ARCA #4.(49-10-5b l-A-02) identified under Criterion 5.b.1 which was issued in..2010 during the Point Beach REP Exercise- Exercise Release #3 was marked "For Immediate Release," and was issued to the JIC and Counties at 1012 hours0.0117 days 0.281 hours 0.00167 weeks 3.85066e-4 months , but the Hotline staff was not operational until 1040 hours0.012 days 0.289 hours 0.00172 weeks 3.9572e-4 months . The State EOC PIO anticipated that the JIC would announce the establishment of the Hotline but apparently. did not anticipate the distribution of the release by the County PIOs. Until the JIC and Hotline become operational, the State and County EOC PIOs provide incident related public information to the media and respond to public inquiries directly. The State EOC PIO apparently anticipated that coordination with the JIC implied full coordination with Counties, but when combined with actual communications systems malfunctions during the transition of responsibilities, the coordination was incomplete.

This issue was given during Point Beach in 2010 and could not be re-demonstrated during the Kewaunee 2011 due to the hotlines being at different locations for Point Beach and Kewaunee.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station This will be re-demonstrated during Point Beach 2012.

Two ARCAs from a previous exercise were successfully re-demonstrated during this exercise:

The State of Wisconsin ARCA # 1, for the State of Wisconsin (49-10-1 c l-A-04) identified under Criterion 1.c. 1 which was issued in 2010 during the Point Beach REP exercise - Field Operation Center briefings were not performed by the Field Response Manager as defined in Section 4.1 of the Wisconsin Department of Health Radiological Incident Response Plan Volume 2, FOC/MRL Operations Manual. Using a completed Field Team Dispatch Briefing Checklist; the Field Team Coordinator performed a pre-deployment brief to all Field Team and FOC/MRL support staff prior to Field Team deployment. This ARCA was successfully demonstrated, during this exercise.

The State of Wisconsin ARCA #2, for the State of Wisconsin (33-09-5b l-A-05) identified under Criterion 5'b.1 which was issued during 2009 Kewaunee REP exercise - The Virginia Call Center did not receive JIC News Releases, EAS and Special News Broadcast messages regarding protective action decision for the public. After receiving and reviewing documentation and by evaluat6r's :observations, it'has 'been determined that there was adequate support that communications between the Virginia Call Center and the JIC was much improved. This ARCA was successfully demonstrated during this exercise.

There were five Planning Issues associated with this exercise:

The State of Wisconsin, Planning Issue #1 (33-11-lel-P-01) identified under Criterion 1.e.1, the State of Wisconsin Radiological Incident Response Plan-(RIRP) and ManitowocCdunty Emergency Operations Plan and supporting SOPs, checklists and forms identify the'Permanent Record Dosimeters (PRDs)issued to emergency workers as TLDs (Thermo'-Luminescent Dosimeters). However, Landauer/Luxel + Optically Stimulated Luminescent Dosimeters (OSLDs) were issued at the Manitowoc County. Highway Department Reception Center. The table in Volume'IV, Section 2.3.1, of the State Radiological Incident Response Plan (RIRP),.

includes a Dosimeter Issuance Policy table that lists Minimum Recommended dosimeter types by Response Staff Type and includes a column that is titled TLD or OSL which indicates that either TLDs or OSLDs may be issued. The table in Volume IV, Section 2.3.1, of the RIRP also indicates that the issuance of 0-20 R DRDs is NA (meaning Not Applicable) to all Response Staff Types.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station However, 0-20 R DRDs were issued to the emergency workers who staffed the Personnel and Vehicle Monitoring/Decontamination Stations at the Reception Center (including the following Response Staff Types: Vehicle Monitoring, Vehicle Decontamination, Personnel Monitoring, Portal Monitoring, Resurvey Monitoring, Personnel Decontamination, Decontamination Exit Monitoring, and Monitoring Station Recording).

The State of Wisconsin, Planning Issue #2 (33-11-6al-P-02) identified under Criterion 3.c.2, the facility has one shower ýstall that would be used for whole-body Evacuee/Emergency Worker.

Decontamination. The stall is not large enough to provide privacy for staging a clean towel and body covering (Tyvek suit), disrobing and. placing contaminated clothing in a receptacle, showering, drying with the clean towel, and donning the clean garment. These activities could be viewed by the Decontamination Team Recorder, who would hand a clean towel to the evacuee/emergency worker for drying and a Tyvek suit body covering for donning, as well as by the Entrance and Exit Monitors. When queried by the Evaluator, the Appleton Hazmat Team personnel who operated the station stated that the Team has no female personnel who are trained Monitors or Recorders. *.

The floor diagram on page ATT 1-21 of the *Manitowoc County Emergency Operations Plan (Attachment 1, Manitowoc County Reception Center Personnel Decontamination), does not accurately. reflect the actual configuration of the personnel decontamination facility. The diagram shows a Hand Washing Sink located outside theDecontamination Station Room (combination 3 Locker Room/Shower in the diagram) past the Frisking Stations. During this exercise, the sink used for hand washing by Evacuees/Emergency Workers was located inside (rather than outside) the combination Locker Room/Shower in a separate toilet/wash room. The combination locker/shower room portion of the diagram does not accurately reflect that actual .configuration of the room(s).

Manitowoc County, Planning Issue #3 (33-1 1-3c2-P-03) identified-under Criterion 3.c.2, the Manitowoc County Executive at the Emergency Operations Center (EOC) directed the Mishicot Superintendent to evacuate schools in the School District of Mishicot at the Site Area Emergency, Emergency Classification Level (ECL). Staff at the Manitowoc. EOC did -notreceive confirmation that the School District of Mishicot. had successfully evacuated their schools.

Procedures for staff at the Manitowoc EOC (Manitowoc County Emergency Operations Plan, Annex I, Part 2) do not match the specific procedures for school staff (Manitowoc County 8

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station Emergency Operations Plan, Annex I, Part 2, Attachment 7, Nuclear Emergency Evacuation Plan for the School District of Mishicot). The Mishicot Superintendent is required to inform the Human Services representative at the EOC when evacuation is complete, but the EOC procedures do not require any staff, including the County Executive, Emergency Management Director, or Human Services representative to confirm when evacuation is complete.

The State of Wisconsin, Planning Issue #4 (33-11-4a 1-P-04) identified under Criterion 4.a. 1, the instructions in the Wisconsin Department of Health Services Radiological Incident Response Plan for response check of the Fluke Victoreen 451B Ion Chamber Survey Meter did not match.

the requirements posted on the calibration sticker for the instrument or the instructions posted with the check source jig in the mobile laboratory..

According to Wisconsin Department of Health. Services Radiological Incident Response.Plan, Volume 3, Page 21, .the instructions to source check the Victoreen 451B were Turn the meter over and slideback the plastic cover. This exposes.the Beta window..With the assistance of FOC staff, obtain the check source jig. Ensure the check source is set snugly within the square insert, and place the meter into the jig such that the Beta window is flush with the check source. The calibration sticker on. the side of the Victoreen 451 B clearly indicated that the response check:

should be conducted with the cover on the instrument closed. The iristructions posted with the check sourcejig in the mobile laboratory also indicated that the response check should be conducted with the cover on the beta window closed.

The State ofWisconsin, Planning Issue #5 (33-11-4al-P-05) identified under Criterion4*a. 1, Restricted Area Field Team 2 did not record background measureiments in a clean area for either the Fluke Victoreen 451 B Ion Chamber Survey Meter or the Ludlum Model 12 Rate meter with Model 44-9 Probe. During interview, team members were unable to recall what the original or baselinebackground readings had been. There are no instructions in the Wisconsin Department of Health Services Radiological Incident Response Plan to record baseline instrument readings.

According to the procedures for the Ludlum Geiger Counters and Pancake Detectors (Wisconsin Department of Health Services Radiological Incident Response Plan, Volume 3, Page 21) the operator should -Step the meter down to the lowest scale and observe background reading with slowest response setting. Make sure the RESET button returns needle to zero and that the background readings .are less than 500 cpm However, there are no instructions to record the 9.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station background reading. The procedures for the Victoreen 451B do not address background readings.

Based on the results of the October 4, 2011 exercise, the offsite radiological emergency response plans and preparedness for the State of Wisconsin and affected local jurisdictions, site-specific to the Kewaunee Power Station, can be implemented and are adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency at the site.

Therefore, the Title 44 CFR, Part 350, approval of the offsite radiological emergency response plans and preparedness for the State of Wisconsin site-specific to Kewaunee Power Station, granted on June 15, 1985, remains in effect.

INTRODUCTION - EXERCISE BASIS On December 7, 1979, the President directed FEMA to assume the lead responsibility for all off-site nuclear planning and response. DHS/FEMA's activities are conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351, and 352. These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the Three I Mile Island Nuclear Station accident in March 1979.

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

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

Taking the lead in off-site emergency planning; and in the review and evaluation of RERPs and procedures developed by State and local governments;

Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans .and procedures conducted by I State and local governments; 10

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station

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

and

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

- U.S. Department of Agriculture;

- U.S. Department of Commerce;

- U.S. Department of Energy;.

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

- U.S. Department of the Interior;

- U.S. Department of Transportation;

- U.S. Environmental Protection Agency;

- U.S. Food and Drug Administration; and.

- U.S. Nuclear Regulatory Commission.

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

Formal submission of the RERPs for the Kewaunee Power Station to FEMA Region V by the.

State of Wisconsin and involved local jurisdictions occurred on April 4, 1984......"

Formal approval of these RERPs was granted by FEMA to the State of.Wisconsin during June 14, .1985, under 44 CFR 350.

A REP Full Participation Plume Exposure Pathway Exercise was conducted on October 4, 2011, by DHS/FEMA Region.V to assess the capabilities of State emergency.preparedness "

organizations in implementing their RERPs and procedures to protect the public health and.

safety during a radiological emergency involving the Kewaunee Power Station. The purpose of this exercise report is to present the exercise results and findings on the performance of the offsite response organizations (OROs) during a simulated radiological emergency.

The findings presented in this AAR/IAP are based on the evaluations of the Federal evaluator 11

Unclassified Radiological Emergency Preparedness Program (REP)

I

-After Action Report/Improvement Plan Kewaunee Power Station team, with final determinations made by the DHS/FEMA Region V RAC Chairperson, and approved by the DHS/FEMA Headquarters."

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

NUREG-0654/FEMAREP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear

Power Plants, November 1980;

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

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

2002.

Section 3 of this report, entitled "Exercise Overview," presents basic-information and data, relevant to the exercise. This section of the report contains a description of the plume pathway EPZ, a listing of all participating jurisdictions and functional entities which were.evaluated, and a tabular presentation of the time of actual occurrence of key exercise events and activities.

Section 4 of this report, entitled "Exercise Evaluation and Results," presents detailed information on the demonstration of applicable exercise criteria at each jurisdiction or functional entity evaluated in a jurisdiction-based, issues-only format. This section also contains: descriptions of all Deficiencies,ARCAs and Planning Issues assessed during this exercise, recommended corrective actions and descriptions of unresolved ARCAs/Planning Issues assessed during previous exercises and the status of the OROs' efforts to resolve them.

I EMERGENCY PLANNING ZONE (EPZ) DESCRIPTION The Kewaunee Power Station occupies a 900-acre site that is located on the Lake Michigan shore, in the town of Carlton, nine miles south of Kewaunee, Wisconsin, and 35 miles southeast of Green Bay, Wisconsin. The plant began commercial operation on June 16, 1974. 3 12

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station The Kewaunee Power Station, which is owned and operated by Dominion Energy Kewaunee, Inc., has one Westinghouse Electric pressurized water nuclear reactor that generates about 560 megawatts of electrical power. In an average year, the plant generates about 2.26 billion kilowatt-hours of electricity, which is sufficient to supply the yearly energy needs of the Green Bay metropolitan area plus the remaining homes and farms in Brown, Kewaunee, -Door, Marinette, Oconto, and Winnebago Counties. These counties have a population of about one-half million people.

The nearest population centers of 25,000 people or more are, according to the 2010 census, Manitowoc 13 miles south-southwest of the site, with approximately 33,736 people; Green Bay 35 miles northwest of the site, with approximately 104,057 people; Appleton 43 miles west of the site, with approximately 72,623 people; and Sheboygan 36 miles southwest of the sitee, with approximately 49,288 people.

There are no other population centers with populations greater than 25,000 people that lie within 50-miles "ofthesite. The town of Two Rivers, which is, located 10-miles south of the site; had a 201 0 census'population of 11,712. The total population' located within the 10-mile plume pathway EPZ'was approximately: 11,691ipeople..

The following radiological emergency planning Sub-areas are included within the 10- mile EPZ:

5, ION, 1ONW, 1OW,.1OSW and lOS.

13

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station I

SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Kewaunee Power Station Type of Exercise U Plume Exercise Date October 04, 2011 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness I Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership William King Chairman DHS/FEMA Radiological Assistance Committee 3 536 S. Clark Street.

Chicago, Illinois, 60605 312-408-5575 3 william.king5 @fema.dhs.gov I

Dwaine Warren Exercise Director DHS/FEMA REP Supervisor Team Lead 536 S. Clark Street 14 3

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station Chicago, Illinois, 60605 312-408-5342 Dwaine.warren@fema.dhs.gov Gary Naskrent Assistant Exercise Director DHS/FEMA REP Supervisor Team Lead 536 S. Clark Street Chicago, Illinois, 60605 312-408-5214 gary.naskrent@fema.dhs.gov James King Site Specialist DHS/FEMA Technological Hazards Specialist 536 S. Clark Street Chicago, Illinois, 60605 312-408-5596 james.king@fema.dhs.gov 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Kewaunee Power Station exercise:

State Jurisdictions Amercian Red Cross Appleton Fire Department - Hazmat Team Department of Human Services Governor's Authorized Representative Kenosha County Health Department Public Service Commission of Wisconsin 15

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/hmprovement Plan Kewaunee Power Station University of Wisconsin Extension Wisconsin Department of Agriculture, Trade and Consumer Protection Wisconsin Department of Children and Family Services Wisconsin Department of Commerce Wisconsin Department of Corrections ,

Wisconsin Department of Criminal Investigation Wisconsin Department. of Health Services Wisconsin National Guard Wisconsin Emergency Management Wisconsin National Guard, Civil Support Team Wisconsin National Guard Joint Operations Center Wisconsin Department of Military Affairs Wisconsin Department of Natural Resources - Drinking Water Supply Wisconsin Department of Transportation Wisconsin State Highway Patrol Wisconsin Public Service Commission Risk Jurisdictions Amateur Radio Emergency Services American Red Cross, Badger Chapter Department of Health and Services, Radiation Protection Section (lead agency)

Kewaunee County Board Kewaunee County Fire/Rescue Kewaunee County Health Department Kewaunee County Highway/Public Works Department Kewaunee County Law Enforcement Kewaunee County Sheriffs Department Kewaunee County Sheriff Liaison Manitowoc County Fire Department - Hazmat Team Manitowoc Fire Department/ Emergency Medical Service Manitowoc County Health Department Manitowoc County Highway Department Manitowoc County Sheriffs Department Mishicot High School Principal Mishicot School District Grounds and Transportation Coordinator 16

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station Mishicot School District Superintendent Mishicot School District Mishicot School District Bus Driver Valders Area School District Valders Area School District Superintendent Private Organizations Kewaunee Power Station Liaison Lakeshore Aviation LLC Federal Jurisdictions Department of Energy Radiological Assistance Program Team FEMA Region V State Liaison Nuclear Regulatory Comission State Liaison 17

Unclassified Radiological Emergency Preparedness Program (REP)

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

SUMMARY

2.1 Exercise Purpose and Design The DHS/FEMA Region V Office evalutated the Kewaunee Power Station (KPS) Radiological Emergency Preparedness (REP) Full Participation Plume Exposure Pathway Exercise conducted on October 4, 2011, to assess the capabilities of local emergency preparedness organizations in implementing their Radiological Emergency Response Plans (RERP) and procedures to protect the public health and safety during a radiological emergency involving KPS. The purpose of this report is to present the results and findings on the performance of the Offsite Response Organizations (OROs) during a simulated radiological emergency.

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

2.3 Scenario Summary Appendix F, "Exercise Scope", contains a summary of the Exercise Scenario, a simulated sequence of events, that was used as the basis for invoking emergency response actions by OROs in the KPS REP Full Participation Plume Exposure Pathway Exercise on October 4, 2011.

This exercise scenario was submitted by the State of Wisconsin and Dominion Energy Kewaunee Inc. and accepted by DHS/FEMA Region V on September 19, 2011.

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

The details of the scenario are included in Appendix F "Exercise Scope".

18

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained inmthis section are the results and findings of the evaluation of all jurisdictions and, functional entities that participated in the October 4;2011, Full Participation Plume Exposure Pathway Exercise to test offsite emergency response capabilities of State and local governments within the 10-mile EPZ surrounding the Kewaunee Power Station.

Each jurisdiction and functional entity Was evaluated based on its demonstration of exercise criteria delineated in Federal Register Notice/vol. 67, no. 80, dated April 25, 2002. Detailed information on the exercise criteria and the extent-of-play agreement used in this exercise are found in Section 3 of this report.

3.2 Summary Results of Exercise Evaluation The matrix in Table 2, on the following page(s), presents the status of all exercise criteria from the Federal Register Notice Volume 67, Number 80, dated April 25, 2002, which were scheduled for demonstration during this exercise by all participating jurisdictions and functional entities.

Exercise criteria are listed by number and the, demonstration status of those criteria are indicated by the following letters:

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

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

N - Not Demonstrated (Reason explained in section 4.2)

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

B - Not scheduled for demonstration.

19

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station Table 3.1 Summary of Exercise Evaluation (3 pages)

I C

DATE: 2011-10-04 J E SITE: Kewaunee Power Station, WI M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated Lrg~i-y Operatiumns anagoiw/iP /

Mobilization lal M M M M M M M M Facilities lb]

Direction and Control Icl M M M _ MM M Communications Equipment Idl M M M M M M M M M .MM Equip & Supplies to support operations lel M _MA M MM MIMI P Potec)tive Actiou Decision Making Emergency Worker Exposure Control 2al M M M Radiological Assessment and PARs 2b] M M Decisions for the Plume Phase - PADs 2b2 M M PADs for protection of special populations 2cl M Rad Assessment and Decision making for Ingestion Pathway 2d] I Rad Assess/Decision making concerning Relocation, Reentry, and Return 2el1

,ýr ie -- -..

Implementation of emergency worker exposure control 3al M M M M Implementation of KI decision 3b] M M M M Implementation of protective actions for special populations - EOCs 3cl Implementation of protective actions for Schools 3c2 Implementation of traffic and access control 3dl Impediments to evacuation are identified and resolved 3d2 Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available 3e2 Implementation of relocation, re-entry, and return decisions 3fl Adequate Equipment for Plume Phase Field Measurements 4al M P Field Teams obtain sufficient information 4a2 M Field Teams Manage Sample Collection Appropriately 4a3 __m M Post plume phase field measurements and sampling 4bI Laboratory operations 4c1 _ M Atargenction ofiathermn and t nbdc lnf ication system. -,M M Activation of the prompt alert and notification system - F B 5aI 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] A M M M Mon/Decon of evacuees and EWs and registration of evacuees 6al _ P Mon/Decon of EW worker equipment 6b I 20 I

I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station Temporary care of evacuees 16cd1 I I I I I Transnortation and treatment of contatninated injured individuals 21

Unclassified Radiological Emergency Preparedness Program (REP)

I

, After Action Report/Improvement Plan Kewaunee Power Station I

Table 311 - Summary of Exercise Evaluation.(Continued. page 2/3) 0 U DATE:2011-10-04 SITE: Kewaunee Power Station, WI a t-C I M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated U 0 0

, I I

Mobilization lal ]M M Facilities Direction and Control IbI IcI M I

Communications Equipment Idl M MIMMM M M M M M Equip & Supplies to support operations Protec~tve Action Decision ak..:

lel M M M M M M M I

Emergency Worker Exposure Control 2a]

Radiological Assessment and PARs Decisions for the Plume Phase - PADs PADs for protection of special populations 2b]

2b2 2cl M

M 1

Rad Assessment and Decision making for Ingestion Pathway Rad Assess/Decision making concerning Relocation, Reentry, and Return 2dl 2e] I Implementation of emergency worker exposure control 3a1 M M M M M M M Implementation of KI decision Implementation of protective actions for special populations - EOCs 3b]

3cl M M M M

M M I

Implementation of protective actions for Schools 3c2 M M Implementation of traffic and access control Impediments to evacuation are identified and resolved 3d]

3d2 M M M

I Implementation of ingestion pathway decisions - availability/use of info 3el Materials for Ingestion Pathway PADs are available Implementation of relocation, re-entry, and return decisions Field M asurementaa n .. . . . . .-.

3e2 3fl I

Adequate Equipment for Plume Phase Field Measurements Field Teams obtain sufficient information Field Teams Manage Sample Collection Appropriately 4al 4a2 4a3 I

Post plume phase field measurements and sampling 4b1 Laboratory operations Lmergenc .. fication.and Public. nfoi.3/4s/ ..

4c]

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

5bl M M M Support Operations/Faclhities 3/4:v.

Mon/Decon of evacuees and EWs and registration of evacuees Mon/Decon of EW worker equipment 6al 6b]

M M

I 22 I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station Temporary care of evacuees 6 , I -I1 Transportation and treatment of contaminated injured individuals 23

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Inprovement Plan Kewaunee Power Station I

Table 3.1 - Summary of Exercise Evaluation (Continued. page 3/3)

<)

a)

U H I

U DATE: 2011-10-04.

SITE: Kewaunee Power Station, WI U cAt a)

U U

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

U I?

a)

U C

a) a)

C-a) 0 I

V) z*

z z z I Etuegaieny6 vtin Nlanaement A I Mobilization Facilities lal Ibi M M I

Direction and Control 1I1 M Communications Equipment Equip & Supplies to support operations

'ProtectiVe ActaonDecisionMakingLK&I: A Idl lel M M M M M M M M M M M M M M M M M M I Emergency Worker Exposure Control Radiological Assessment and PARs Decisions for the Plume Phase - PADs 2al 2bl 2b2 M

M I

PADs for protection of special populations 2cl M Rad Assessment and Decision making for Ingestion Pathway Rad Assess/Decision making concerning Relocation, Reentry, and Return 2d]

2el I

Lrnplementation of emergency worker exposure control Irmplementation of KI decision 3al 3b]

M M M M M M M M M M M

M I

Implementation of protective actions for special populations - EOCs 3d M Implementation of protective actions for Schools Implementation of traffic and access control Impediments to evacuation are identified and resolved 3c2 3d]

3d2 P

M M

I Implementation of ingestion pathway decisions - availability/use of info Materials for Ingestion Pathway PADs are available Irnplementation of relocation, re-entry, and return decisions 3e1 3e2 3fl I

Field Nleasurmet'~id Anhalysis.A,.

I Adequate Equipment for Plume Phase Field Measurements 4a]

Field Teams obtain sufficient information 4a2 Field Teams Manage'Sample Collection Appropriately 4a3 Post plume phase field measurements and sampling Laboratory operations Emergency Notificaion andPublcno Info .... , ..

4b1 4c I I Activation of the prompt alert and notification system Activation of the prompt alert and notification system - Fast Breaker Activation of the prompt alert and notification system - Exception areas 5a]

5a2 5a3 M M M I

E*mergency information and instructions for the public and the media Support Operations/Faciliiein,;.J .. ,

Mon/Decon of evacuees and EWs and registration of evacuees 5bl 6al M

- 5 "

M I

[Mon/Decon of EW worker equipment 6b I 24 I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan I. Kewaunee Power Station Temporary care of evacuees 6c1 M Transportation and treatment of contaminated injured individuals 6dlI I IM 25

Unclassified Radiological Emergency PreparednessProgram (REP)

I After Action Report/Improvement Plan Kewaunee Power Station 3.3 Criteria Evaluation Summaries 3.3.1 Wisconsin Jurisdictions

3.3.1.1 State of Wisconsin - State Warning Center #1 - Inital Warning Point I The State of Wisconsin Initial Warning Point #1 (IWP#1) demonstrated the. Target Capibility to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. The State of Wisconsin IWP#1 is located in the Wisconsin State Patrol Headquarters secured facility in Deforest, Wisconsin. The Dispatch Center is staffed by Wisconsin State Patrol personnel, .24-hours a day, seven days a week.

In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None "

g. PRIOR ISSUES - UNRESOLVED: None.

3.3.1.2 State of Wisconsin - State Warning Center #2 - Initial Warning Point The State of Wisconsin Initial Warning Point #2 (IWP#2) demonstrated the Target Capibilitiy to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. The State of Wisconsin IWP#2 is located in the Wisconsin Department of Military Affairs, Wisconsin Emergency Managemet reception area in Madison, Wisconsin. The IWP#2 is only staffed during normal business hours.

In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None 26

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station f, PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.3 State of Wisconsin - Emergency Operations Center The State of Wisconsin Emergency Operations Center (SEOC) demonstrated the Target Capability of Emergency Operations Center Management including the use of effective procedures to alert, notify and mobilize emergency personnel and activate facilities in a timely manner.. The SEOC provided sufficient multi-agency coordination in response~to the simulated incident at the Kewaunee Power Station (KPS) by promptly activating and operating for the duration of the exercise. The SEOC was managed efficiently and effectively, completed a full activation and notification, and was staffed to a fully operational level. The SEOC provided timely and effective management and direction and control through the use of briefings information posted on SEOC monitors and on eSponder to track, organize and maintain a chronological record of events. The SEOC coordinated with the risk counties and. other state agencies to synchronize decision making and dissemination of public information regarding the situation at the KPS.

In summary, the status of DHS/FEMA criteria for, this location is as follows:

a. MET: L.a. 1, l.c.1, 1.d.1, L.eýl, 2.a. 1, 2.b.1, 2.b.2. .

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

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

ISSUE NO.: 49-10-5bl-A-02 ISSUE: State Message #5/Exercise Release #3 issued by the State EOC contained untimely instructions by directing the public to contact the Public Inquiry Hotline at its designated telephone number substantially prior to when the Hotline was operational. Exercise Release #3 was marked "For Immediate Release,"' and was issued to the JIC and Counties at 1012 hours0.0117 days 0.281 hours 0.00167 weeks 3.85066e-4 months , but the Hotline staff was not operational until 1040 hours0.012 days 0.289 hours 0.00172 weeks 3.9572e-4 months . The County PIOs distributed Exercise Release #3 in accordance with their respective procedures and the "For Immediate Release" 27

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Kewaunee Power Station markings. Callers would have received the following pre-recorded message:"Thank you for calling the FPL Point Beach Nuclear Plant Emergency Hotline. At this time, the Emergency Hotline has not been activated..." Callers were provided telephone numbers for, and instructed to call, either the Point Beach Manager of Communications or the Supervisor of the Point Beach Energy Center. This can be confirmed by calling the Point Beach Hotline.

REASON UNRESOLVED: This ARCA was part of the Point Beach Exercise 2010.

The call centers are operated in different locations, this ARCA will be re-demonstrated during the Point Beach Exercise in 2012.

3.3.1.4 State of Wisconsin - State Emergency Operations Center - Radiological Coordinator lI The State of Wisconsin Radiological Coordinator (SRC) demonstrated the Target Capibilities of direction and control to that part of the overall response effort for the Kewaunee Power Station (KPS) Radiological Emergency Preparedness Exercise on October 4, 201 1. The SRC workroom was located across the hallway from the State Emergency Operations Center (SEOC) in Madison, Wisconsin.

The SRC effectively demonstrated the ability to carry out essential functions of the SRC response effort; he kept staff informed through periodic briefings, coordinated with other organizations and ensured completion of requirements and requests. Throughout the exercise, the SRC updated SRC staff, the Wisconsin Emergency Manager (WEM) and the SEOC on plant status, Protective Action Recommendations (PAR) and SRC activities.

In summary, the status of DHS/FEMA criteria for this location is as follows: I

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None I

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 28

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station 3.3.1.5 State of Wisconsin - Forward Operating Center The State of Wisconsin Forward Operation Center (FOC) demonstrated the Target Capability to provide accurate and timely information to the FOC staff and supporting members of the Mobil Radiological Lab (MRL), sample receipt station, two evaluated Restricted Area Field Teams (RAFT's), and three unevaluated RAFT's.

During the course of the exercise both evaluated RAFT'S (H901 and H902) were instructed to take a set of air sample in locations within the plume path. Communication between the FTC and the RAFT's was adequate to ensure a representative sample was obtained and that team*

exposure levels were minimized. All samples were directed to a transfer location in the field and delivered to the sample receipt station at the FPC/MRL.

All activities described in the demonstration criterion were carried out in accordance with the plan, procedures and extent-of-play agreement.

Iný summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET:' Lc. 1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED:, L c. 1.

ISSUE NO.: 49-10-icl-A-04 ISSUE: Field Operation Center briefings were not performed by the Field Response Manager as defined in Section 4.1 of the Wisconsin Department of Health and Services, Radiological Incident Response Plan Volume 2, FOC / MRL Operations manual.

CORRECTIVE ACTION DEMONSTRATED: Using a completed Field Team Dispatch Briefing Checklist; the Field Team Controllei perfoi-med an pre-deployment brief to all Field Team and FOC/MRL support staff prior to Field Team deployment.

This briefing included all information element expected for radiological emergency.

29

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Kewaunee Power Station worker knowledge and safety.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.6 State of Wisconsin - Forward Operations Center - Mobile Radiological Laboratory the Field Response Manager (FRM) demonstrated the Target Capability to setup and operate the Forward Operations Center/Mobile Radiological Laboratory (FOC/MRL). The State Radiological Coordinator (SRC) informed the FRM that the Kewaunee Power Station (KPS) had declared an Alert at 0747 hours0.00865 days 0.208 hours 0.00124 weeks 2.842335e-4 months . The SRC ordered the FRM to activate the Forward Command Center/Mobile Radiological Laboratory (FOC/MRL) and supporting Restricted Area Field Teams (RAFT's).

In accordance with the extent-of-play agreement all exercise participating were pre-positioned at the Best Western Hotel in Manitowoc, Wisconsin RAFT assignments and results were tracked and documented using the "FQC Field Team Data Reporting Record" form. This form is designed to capture the RAFT identifier, -time, sample location, ambient radiation readings, Direct-Reading Dosimeter (DRD) readings, and Iodine air cartridge field measurements. As this data was obtained by the FTC from, the field it was uploaded into an e-Sponder (web based system to log events and post messages) data sheet that could be viewed by the SRC.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: l.a.l, .l.d.l 2.a.1, 3.a.1, 3.b.1, 4.a.2, 4.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: No e.1.

ISSUE NO.: 49-10-lel-A-01 ISSUE: Acceptable ranges of operation were not posted on the calibration stickers on 30

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station the Bicron Micro-Rem meters or the Ludlum Model 12 count rate meters used at the Mobile Radiological Laboratory or the Sample Receiving Area nor was the Field Response Manager contacted for assistance because there was no means. to ensure the instrument was operating properly.

REASON UNRESOLVED: As occurred in the previous exercise, accurate ranges of operation were not posted on the calibration stickers on the BicronMicro-Rem meter.

Also, the Ludlum Model 12 count rate meter had an operational source check range on the calibration sticker but the value was 4 mR/hr; instead of a value with units of counts per minute that would be expected for a count rate meter.

Additionally, three permanently mounted instruments in FOC/MRL vehicle were past their calibration due date. Two Model 375/2 area monitors and one model 177 count rate meter showed a calibration date of September 10, 2010; exceeding the instrument calibration limit by almost one month. Calibration stickers were not posted on the perrmanently mounted instruments but calibration logs were available in the MRL that provided check source ranges.

Becauseof this existing conditionARCA issue number 49 lel-A-02 cannot be cleared.

3.3.1.7 State of Wisconsin - Restricted Area Field Team 1 in summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR.ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 31

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Kewaunee Power Station 3.3.1.8 State of Wisconsin - Restricted Area Field Team 2 In summary, the status of DHS/FEMA criteria for this location is as follows: l

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

b. AREAS REQUIRING CORRECTIVE ACTION: None I

c. DEFICIENCY: None

d. PLAN ISSUES: 4.a.1.

ISSUE NO.: 33-11-4al-P-04 n CRITERION: Field teams are equipped to perform field measurements of direct

,radiation exposure (cloud & ground shine) and to sample airborne radioiodine and I particulates (NUREG-0654, H. 10., 1.8., 9., 11.)

CONDITION: The instructions in the Wisconsin Department of Health Services Radiological Incident Response Plan for response check of the Fluke Victoreen 451 B Ion Chamber Survey Meter did not match the requirements posted on the calibration sticker for the instrument or the instructions posted with the check source jig in the mobile laboratory.

POSSIBLE CAUSE: According to Wisconsin Department of Health Services Radiological Incident Response Plan, Volume 3, Page 21, the instructions to source check the Victoreen 451 B were "Turn the meter over and slide back the plastic cover.

This exposes the Beta window. With the assistance of FOC staff, obtain the check source jig. Ensure the check source is set snugly within the square insert, and place the meter into the jig such that the Beta window is flush with the check source." The I calibration sticker on the side of the Victoreen 451B clearly indicated that the response check should be conducted with the cover on the instrument closed. The instructions posted with the check source jig in the mobile laboratory also indicated that the response check should be conducted with the cover on the beta window I closed.

REFERENCE:

Wisconsin Department of Health Services Radiological Incident I Response Plan, Volume 3, Page 21 I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station EFFECT: Both Restricted Area Field Teams conducted the instrument response check on their respective Victoreen 451B with the beta window closed, obtaining the desired reading on the instrument and verifying the instrument response against the check source.

Had either team attempted to conduct the response check with the beta window cover in the open position, an inappropriate reading would have been obtained. The team would then have incorrectly determined that their instrument was out of calibration and declared it unserviceable.

RECOMMENDATION: Edit Wisconsin Department of Health Services Radiological Incident Response Plan, Volume 3, Page 21, and Volume 2, Page 32.

From: Turn the meter over and slide back the plastic cover. This exposes the Beta window.

To" Turn thermeter over and assure that the plastic cover is slid forward. The source check must be conducted with the Beta window closed.

ISSUE NO.: 33-11-4al-P-05 CRITERION: Field teams are equipped to perform field measurements of direct radiation exposure (cloud. & ground shine) and to sample airborne radioiodine and particulates (NUREG-0654, H. 10. 1.8., 9., 11.).

CONDITION: Restricted Area Field Team 2 did not record background measurements in a clean area for either the Fluke Victoreen 451 B Ion Chamber Survey Meter or the Ludlum Model 12 Ratemeter with Model 44-9 Probe. During interview, team members were unable to recall what the original or'baseline background readings had been.

POSSIBLE CAUSE: There are no instructions in the Wisconsin Department of Health Services Radiological Incident Response Plan to record baseline instrument 33

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station readings.

According to-the procedures for the Ludlum Geiger Counters and Pancake Detectors (Wisconsin Department of Health Services Radiological Incident Response Plan, Volume 3, Page 21) the operator should "Step the meter down to the lowest scale and observe background reading with slowest response setting. Make sure the RESET button returns needle to zero ,and that the background readings are less than 500 cpm." However, .there are no instructions to record the background reading. The procedures for the Victoreen 451 B do not address background readings.

REFERENCE:

Wisconsin Department of Health Services Radiological Incident Response Plan I Pre-Dispatch Field Team/Kit Evaluation Checklist, Revised 7/28/11.

EFFECT: Restricted Area Field Teams could find themselves in a contaminated environment with. no initial instrument' readings to reference.

The Wisconsin Radiological Incident Response Plan (RIRP) defines contamination as levels of radioactive material that result in a reading of 100 counts per minute (cpm) above background when taken at the -appropriate frisking distance with a GM counter equipped with a "pancake" detector. Without an initial background reading, Restricted Area Field Teams may be unable to determineif they' or their equipment were contaminated.

RECOMMENDATION: Add a location on the Pre-Dispatch Field Team/Kit Evaluation Checklist to record background readings. This may prove helpful to the Field Teams and to persons performing assessment to calculate dose conversion factors.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 34

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station 3.3.1.9 State of Wisconsin - Joint Information Center - Media Center Wisconsin Emergency Management (WEM) and both Kewaunee and Manitowoc counties demonstrated the-Target Capibilities to staff and operate the Joint Information Center (JIC).

State and local responders were notified by locally initiated systems to dispatch public information officers (PIOs) and administrative staff to the.licensee-leased JIC at 3060 Voyager Drive, Green Bay, Wisconsin at the "Alert" emergency classification level (ECL). WEM personnel were pre-positioned to facilitate timely arrival. WEM staff included a Lead Spokesperson, a Lead PIO, a Radiation Protection PIO, and two support staff members. A contract public information consultant assisted both county PIOs as necessary. In each case, deployed personnel were functionally consistent with the requirements of their respective plans.

Upon arrival, representatives from each jurisdiction immediately established contact with their home agencies, effectively demonstrating activation of the state and local elements of the JIC.

Similarly, the staff achieved operational capability shortly before the 0918 hours0.0106 days 0.255 hours 0.00152 weeks 3.49299e-4 months pre-briefing before the first media briefing without formalizing their status.

In summary, the status of DH S/FEMA criteria for this location is as follows:

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

ISSUE NO.: 33-09-5bl-A-05 ISSUE: The Virginia Call Center did not receive JIC News Releases, EAS and Special News Broadcast messages regarding protective action decisions for the public.

CORRECTIVE ACTION DEMONSTRATED: Responses to questions provided by the Public Inquiry Hotline suggest that communication between the JICand the 35

Unclassifled Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Kewaunee Power Station Virginia Call.Center had improved. This was confirmed in the post-exercise discussion by the participant responsible for maintaining the log of inquiries and response when she stated the information exchange was "much better" than the previous exercise. It should be noted, however, that the activities at the Virginia Call Center were not directly observed by the FEMA evaluation team.

After receiving the logs from the Virginia.Call Center it has been determined that there was adequate support .that there was a good communication link form the JIC to the call center and therefore the ARCA is has been successfully re-demonstrated during this exercise.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.10 State of Wisconsin - Kewaunee County Emergency Operations Center - State 3 Liaison The State of Wisconsin Liaison to the Kewaunee County Emergency Operations Center I demonstrated the Target Capability by providing efficient multi-agency coordination during the KPS, REP Exercise by promptly mobilizing to the County-EOC, providing expert assistance and coordinating direct communications with the Stateof Wisconsin,,EOC. The State;Liaison provided effective management, direction and control through the use of briefings and information provided from the SEOC. Additionally, the State Liaison coordinated with. other jurisdictions and counties to facilitate information sharing between state and local agencies synchronize decision-making and ensure that a consistent message was relayed to public.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: !.c.1, 1.d.1, 1.e.1, 5.a.l, 5.b.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None I 36

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station 3.3.1.11 State of Wisconsin - Manitowoc County Emergency Operations Center - State Liaison The State of Wisconsin Liaison to the Manitowoc County Emergency Operations Center demonstrated the Target Capability by providing efficient multi-agency coordination during the KPS, REP Exercise by promptly mobilizing to the County EOC, providing expert assistance and coordinating direct communications with the State of Wisconsin EOC. The State' Liaison provided effective management, direction and control through the use of briefings and information provided from the SEOC. Additionally, the State Liaison coordinated with other jurisdictions and counties to facilitate information .sharing between state and local agencies synchronize decision-making and ensure that a consistent message was relayed to public.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. 'MET: 1.c.l, i.d., L.e.1, 5.a.1, 5.b. 1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES9:None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVEDNone

g. PRIORISSUES - UNRESOLVED: None 3.3.1.12 State of Wisconsin -Highway Department - Evacuee/Emergency Worker Monitoring and Decontamination The State of Wisconsin demonstrated the Target Capability to provide direction and control for evacuee monitoring and decontamination in accordance with plans. and procedures. During the evaluation, the Wissconsin Department of Health Services representative reported to the evacuee monitoring and decontamination station.

One member of the Wisconsin Department of Health Services (DHS) was sent 'to the Emergency Worker Decontamination Center at the Manitowoc County Highway Department acting in an advisory capacity supporting direction and control and performing activities as requested by the Survey and Decontamination Commander. The DHS representative's primary functions included performing operational checks on portal monitors and CD V-700 hand held radiological survey meters, inspecting the facility layout to ensure cones and barrier tape was properly placed providing advice during the setup of the segregation of-clean and potentially 37

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station contaminated areas, observing radiological monitoring and decontamination personnel to ensure proper techniques were used, and to offer advice on how to apply the As Low As Reasonably Achievable (ALARA) principles to all facility personnel In. summary,.the status of DHS/FEMA criteria for this location is as follows:

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

b.: AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLANISSUES: L.e.1,6.a.1.

ISSUENO.:.33-11-lel-P-01.

CRITERION: Equipment, maps, displays, dosimetry, potassiumiodide (KI), and other supplies are sufficient to support emergency operations.

CONDITION: The State of Wisconsin Radiological Incident Response Plan (RIRP) and Manitowoc County Emergency Operations Plan and supporting SOP's, checklists and forms identify the Permanent Record Dosimeters- (PRD's) issued to emergency workers as TLDs (ThermoLuminescent Dosimeters). However, Landauer Luxel+ Optically Stimulated Luminescent Dosimeters (OSLD's) Were issued at the Manitowoc County Highway Department Reception Center. The table in Volume IV, Section 2.3. 1, of !the State Radiological Incident Response Plan (RIRP), includes a Dosimeter Issuance Policy table that lists "Minimum Recommended" dosimeter types by Response Staff Type and includes a column that is titled "TLD or OSL" -

which indicates that.either TLD's. or OSLD's may beissued.

The table in Volume IV, Section 2.3.1, of the RIRP also indicates. that the issuance of 0-20 R DRD's is '"NA" (meaning "Not Applicable") to all Response Staff Types. 3 However, 0-20 R DRD's were issued to the emergency workers who staffed the Personnel and Vehicle Monitoring/Decontamination Stations at the Reception Center (including the following Response Staff Types: Vehicle Monitoring, Vehicle Decontamination, Personnel Monitoring, Portal Monitoring, Resurvey Monitoring, Personnel Decontamination, Decontamination Exit Monitoring, and Monitoring Station Recording).

38

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station POSSIBLE CAUSE: The table in Volume IV, Section 2.3.1, of the State Radiological Incident Response Plan (RIRP), includes a Dosimeter Issuance Policy table that lists "Minimum Recommended" dosimeter types by Response Staff Type and includes a column that is titled "TLD or OSL" - which indicates that The table in Volume IV, Section 2.3.1, of the State Radiological Incident Response Plan (RIRP),

includes a Dosimeter Issuance Policy table. that lists "Minimum Recommended" dosimeter types by Response Staff Type and includes a column that is titled "TLD or OSL" which indicates that either TLD's or OSLD's may be issued.

The table in Volume IV, Section 2.3.1, of the RIRP also indicates that the issuance of 0-20 R DRD's is "NA" (meaning "Not Applicable") to all Response Staff Types.

However, 0-20 R DRD's were issued to the emergency workers who staffed the Personnel and Vehicle Monitoring/Decontamination Stations at the Reception Center (including the following Response Staff Types: Vehicle Monitoring, Vehicle Decontamination, Personnel Monitoring, Portal Monitoring, Resurvey Monitoring, Personnel Decontamination, Decontamination Exit Monitoring, and Monitoring Station Recording).

REFERENCE:

NUREG 0654 -,FEMA-REP 1-REV 1.-K23.b EFFECT: The confusion of dosimeter type can mislead emergency worker on

. improper use of dosimeter.

RECOMMENDATION: Revise plans, procedures, checklists and forms to reflect the type or types of permanent record dosimetry that is currently used. For example, the

.; generic, term' "Permanent Record Dosimeter" and associated acronym "PRD" could replace references to "ThermoLumiriescent Dosimeter" and "TLD." Where appropriate, identify the specific make and model, such as Landauer ThermoLuminescent Dosimeter (TLD) or Landauer Luxel+ Optically Stimulated Luminescent Dosimeter (OSLD). The TLD's and OSLD's may also be referred to generically as "Luminescent Dosimeters" and by the acronym "LD."

The RIRP table (Volume IV, Section 2.3.1) should be revised to replace the "NA" designations in the 0-20 R column by a more appropriate designation (e.g., "Yes" -

39

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Kewaunee Power Station which reflects what was actually issued; or "Optional" - which would allow, but not require, the issuance of the 0-20 R DRD's to the designated Response Staff Types). 3 ISSUE NO.: 33-11-6al-P-02 I CRITERION: Reception center/emergency worker facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees and/or emergency workers. (NUREG-0654, J.10.h., 3 K.5.b).

CONDITION: The facility has one shower stall that would be used for whole-body.1 Evacuee/Emergency Worker Decontamination. The stall is-not large enough to provide privacy for staging a clean towel and body covering (Tyvek suit), disrobing '

and placing contaminated clothing in a receptacle, showering, drying with the clean towel, and donning the clean garment. These activities could be viewed by the 3 Decontamination Team Recorder, who would hand a clean towel to the evacuee/emergency worker for. drying and a Tyvek suit body covering for donning, as well as by the Entrance and Exit Monitors.

When queried by the Evaluator,, the Appleton Hazmat Team personnel who operated 3 the station stated that the Team has no female personnel who are trained Monitors or Recorders.. 3 The floor diagram on page ATT 1-21 of the Manitowoc County Emergency

Operations Plan (Attachment 1 - Manitowoc County Reception Center Personnel Decontamination) does not accurately reflect the actual configuration of the personnel decontamination facility. The diagram shows a Hand Washing Sink 3 located outside the Decontamination Station Room (combination Locker Room/Shower in the diagram) past the "Frisking Stations." During this exercise, the I sink used for hand washing by Evacuees/Emergency Workers was located inside (rather than outside) the combination Locker Room/Shower in a separate toilet/wash room. The combination locker/shower room portion of the diagram does not accurately reflect that actual configuration of the room(s).

40

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station POSSIBLE CAUSE: There is confusion on where to place members of the opposite sex if decontamination showers are not available at the same time and it is unclear what would be done to accommodate people of the opposite sex if needed.

REFERENCE:

Manitowoc County Emergency Operations Plan (5/2010), Floor Diagram, page ATT 1-21.

EFFECT: Memebers of the opposite sex having to share the same facility to shower and change could result in a person being over exposed or their right to privacy be violated.

RECOMMENDATION: In order to avoid delays and other issues when processing female contaminated individuals, the Decontamination Station should be staffed by fully trained female workers to advise, assist and monitor female evacuees and emergency workers during processing. If feasible, a separate (temporaiy or permanent) shower fficilityý for and staffed by females should be made available. If space is sufficient, a removable, free-standing partition or drape' might be used to provide privacy by screening both the shower stall and niche beside the stall where a small table and waste receptacle could be positioned to stage clean items (towel/Tyvec suit') and dispose of dirty items (contaminated clothing).

The diagram on page ATT 1-21 of the County Plan should be revised to show the actual configuration of functional elements. Providing an enlarged insert or separate diagram for the Decontamination Station' would aid in depicting the actual location

'and configuration of such functional elements as the toilet/wash room, shower, benches, equipmentstaging,;(clean and dirty) waste receptacles, tables, chairs, and demarcation lines/step-off pads.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 41

Unclassified Radiological Emergency Preparedness Program (REP) 3 After Action Report/Improvement Plan Kewauree Power Station I

3.3.1.13 State of Wisconsin - Highway Department - Evacuee/Emergency Worker Monitoring and Decontamination of Equipment and Vehicles The State of Wisconsin successfully demonstrated the Target Capibility of key personnel with leadership roles to provide direction and control to that part of the response effort for which they were responsible during out-of-sequence activities for the Kewaunee Power Station (KPS).

Manitowoc County Reception Center, Manitowoc County Highway Department.

The Manitowoc County Reception Center M/D personnel were.issued standardized Dosimetry 3 Kits provided by Manitowoc County Emergency Management. The M/D staff was briefed in groups of six individuals at the RC's Dosimetry Distribution Point located in the.Highway Department bay prior to assuming their monitoring and decontamination duties. Each kit l contained one Arrow Tech Model 138 0-200 mR Direct-Reading Dosimeter (DRD), one Arrow Tech 0-20 R DRD, and one Landauer Thermo-Luminescent Dosimeter I(TLD). They were also issued a Dosimeter Record Form for recording their initial, periodic and final DRD readings.

In summary, the status of DHS/FEMA criteria for this locationis ais follows: -

a. MET: 1.d.1, 1.e.l, 3.a.1, 3.b.1, 6.a.l, 6.b.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 3.3.1.14 State of Wisconsin - Holy Family Medical Center - Medical Service - Facility i The State of Wisconsin (Holy Family Medical Center) demonstrated the Target Capability that they,have proper space; resources and trained personnel to monitor decontaminate and provide medical services to contaminated injured individuals. They aligned the ambulance stretcher aside a hospital stretcher. The patient was carefully transferred across the REA control line to the hospital stretcher. The patient was then wheeled into the decontamination room by the hot zone nurse and EMS responder working at the hospital. They also demonstrated their ability to issue i appropriate dosimetry and manage radiological exposure to emergency workers. The Wisconsin Department of Health Services Medical Radiation Technician (MRT) will monitor the 3 ambulance, ambulance bay and attendants. They would check in when all outside monitoring 42 i I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station activities were complete.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.d.1, 1.e.1,3.a.l,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 3.3.2 Risk Jurisdictions 3.3.2.1 Kewaunee County - Sheriff's Dispatch Center - Initial Warning Point Kewaunee County demonstrated the Target Capability of Emergency Operations Center Management at the Initial Warning Point, located in the Kewaunee County Sheriff s Dispatch Center. The dispatchers demonstrated the ability to alert, notify, and mobilize emergency personnel in a timely manner. The dispatchers were familiar with the nuclear incident notification procedures, demonstrated the redundant communication systems available at the Dispatch Center, and used both primary and backup systems effectively during this exercise.

In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED:, None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 43

Unclassified I Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station 3.3.2.2 Kewaunee County - Emergency Operations Center I

Kewaunee County demonstrated the Target Capability of Emergency Operations Center Management including the use of effective procedures to alert, notify and mobilize emergency personnel and activate facilities in a timely manner. The Kewaunee County EOC demonstrated sufficient multi-agency coordination to respond to an incident at the Kewaunee Power Station through timely activation and efficient operations throughout the exercise. The EOC was managed efficiently and effectively, completed a full notification and activation, and was staffed to an operational levdl. The Emergency Management Director and County Board Chair provided effective management, direction and control throughout the exercise. The Kewaunee County EOC coordinated decision-making with the SEOC, JIC and other jurisdictions and ensured that a clearand-consistent message was communicated to the public.

In summary, the status of DHS/FEMA criteria for this location is as follows: I a., MET: l.a.1, 1.c.l, l.d.1, 1.e.1, 2.b.2, 2.c.1, 3.a.1 3.b.1; 3.c.., 3.c.2, 3.d.1, 3.d.2,-5.a.1, 5.b. 1. 3 b: AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.3 Kewaunee County - Sheriffs Department - Traffic Control Point U Kewaunee County demonstrated the Target Capability of Emergency Public Safety and Security Response through interview which included thedistribution of dosimetry, emergency worker radiological exposure management, and the capability to implement Traffic and Access Control 3 Points (TACPs) within the 10-mile Emergency Planning Zone. During the interview, the Deputy demonstrated thorough knowledge of the provisions of the Emergency Operations Plan related to the establishment of TACPs in addition to the use of appropriate dosimetry procedures,documentation and communications equipment including portable radios, cell phones and mobile data terminals.

I In summary, the status of DHS/FEMA criteria for this location is as follows:

44 I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None,

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.4 Manitowoc County - Joint Information Center - Public Information Officer Manitowoc County demonstrated the Target Capability of Providing Emergency Public Information through the County Public Information Officers (PIOs) at the Joint Information Center (JIC). Manitowoc County PIOs coordinated with their counterparts in the JIC and County EOC to provide timely, accurate and useful information to the public. The JIC facility is well designed and serves as an efficient facility. The Telephone Response Center-had access to prescripted FAQs, media advisories and special news broadcasts, enhancing their ability to deliver accurate information and maintain good situational awareness. Wisconsin Emergency Management (WEM) staff provided leadership to the state and local components of the JIC.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 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 Kewaunee County - Joint Information Center - Public Information Officer Kewaunee County demonstrated the Target Capability of Providing Emergency Public Information through the County Public Information Officers (PIOs) at the Joint Information Center (JIC). Kewaunee County PIOs coordinated with their counterparts in the JIC and County EOC to provide timely, accurate and useful information to the public. The JIC facility is well designed and serves as an efficient facility. The Telephone Response Center had access to prescripted FAQs, media advisories and special news broadcasts, enhancing their ability to

45

I p

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station deliver accurate information and maintain good situational awareness. Wisconsin Emergency Management (WEM) staff provided leadership to the state and local components of the JIC.

In summary, the status of DHS/FEMA criteria for this location is as follows: I

a. MET: 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 p 3.3.2.6 Kewaunee County - Emergency Alert System - WSRG Kewaunee County demonstrated the Target Capability of Emergency Public Information and Warning associated with primary alerting and notification of the public was completedin a timely~manner. Following the decision by County emergency management officials to notify the public of an emergency situation at the Kewaunee Power Station, Radio Station WSRG personnel demonstrated a thorough understanding of their equipment, the EAS process, and executed their duties in a timely and professional. manner..

In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None I

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None 3

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.7 Kewaunee County - Kewaunee School District - Evacuation School I Kewaunee County demonstrated the Target Capability of Citizen Evacuation and Shelter-in-Place for school children through telephone interview. The Kewaunee County School District representative described plans and procedures to safely evacuate students from the Kewaunee County Power Station EPZ and reunite them with their families. The school district demonstrated 46

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station sufficient personnel, current contact information, emergency worker dosimetry, and; communications capabilities to notify families and guardians regarding how to reunite with evacuated students.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.d.1, L.e.1, 3.a.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 Kewaunee County - Annex Building - Dosimetry Distribution Point Kewaunee County demonstrated the Target Capability of Critical Resource Logistics and' Distribution through the establishment of a Dosimetry Distribution Point at the Kewaunee County Courthouse Annex in Algoma. The Public Health Nurse demonstrated the proper. use of direct-reading-and Thermoluminescent dosimeters, calibration equipment and communications systems. The nurse conducted a thorough briefing, regarding the use of and record keeping requirements for personal dosimetry kits including the proper procedures and documentation of the use of potassium iodide.

In summary, the status of DHS/FEMA criteriafor this location is a's follows:

a. MET: 1.d.1, L.e.1,3.a.1,3.b.l1.

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 47

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/improvement Plan Kewaunee Power Station 3.3.2.9 Kewaunee County - Route Alerting - Exception Area Kewaunee County demonstrated the Target Capability of Emergency Public Safety and Security U Response.through interview which included the distribution of dosimetry, emergency worker radiological exposure management, and the capability to perform Supplementary Route Alerting by aircraft within the 10-mile Emergency Planning Zone. A Kewaunee County Sheriff's Officer was dispatched by the Law Enforcement Officer in the Kewaunee County EOC to perform the 3 route alerting, along the one (and only) exception area in Kewaunee County.

lI In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.10 Manitowoc County - Sheriffs Dispatch Center - Initial Warning Point, Manitowoc County demonstrated the Target Capability of Emergency Operations-Center Management at the Initial Warning Point, located in the Manitowoc County Sheriff s Dispatch Center. The dispatchers demonstrated the ability to alert, notify, and mobilize emergency personnel in a timely manner. The dispatchers were familiar with the nuclear incident notification procedures, demonstrated the redundant communication systems available at the Dispatch Center, and used both primary and backup systems effectively during this exercise.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.a.,, 1.d.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 48

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station 3.3.2.11 Manitowoc County - Emergency Operations Center Manitowoc County demonstrated the Target Capability of Emergency Operations Center Management including the use of effective procedures to alert, notify and mobilize- emergency personnel and activate facilities in atimely manner. The Manitowoc County EOC demonstrated sufficient multi-agency coordination to respond to an incident at the Kewaunee Power Station through timely activation and efficient operations throughout the exercise. The EOC was managed efficiently and effectively, completed a full notification, and activation, and was staffed to an operational level. The Emergency Management Director and County Board Chair provided effective management, direction and control throughout the exercise. The Manitowoc County EOC coordinated decision-making with the SEOC, JIC and 'other-jurisdictions and ensured that a clear and consistent message was communicated to the public.

In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None d.. PLAN ISSUES: 3.1c.2.

ISSUE'NO.: 33-1 1:-3c2-P-03 CRITERION: OlOs/school officials decide upon and implement protective actions for'schools (NUREG-0654, J.101c.d.g.) ..

CONDITION: The Manitowoc County Executive at the Emergency Operations Center (EOC) directed the Mishicot Superintendent to evacuate schools in the School District of Mishicot at the Site Area Emergency Emergency Classification Level (ECL). Staff at the Manitowoc EOC did not receive confirmation that the School District of Mishicot had successfully evacuated their schools.

POSSIBLE CAUSE: Procedures for staff at the Manitowoc EOC (Manitowoc County Emergency Operations Plan, Annex I, Part 2) do not match the specific procedures for school staff (Manitowoc County Emergency Operations Plan, Annex I, Part 2, Attachment 7, Nuclear Emergency Evacuation Plan for the School District 49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station of Mishicot). The Mishicot Superintendent is required to inform the Human Services representative at the EOC when evacuation is complete, but the EOC procedures do not require any staff, including the County Executive, Emergency Management Director, or Human Services representative to confirm when evacuation is complete.

REFERENCE:

Manitowoc County Emergency Operations Plan (EOP), Annex I, Part 2, Attachment 7, Nuclear Emergency Evacuation Plan for the School District of Mishicot, Part B, Evacuation Procedures; Manitowoc County EOP, Annex I, Part 2, Human Services Nuclear Power Plant Incident Checklist, County Executive Nuclear Power Plant Incident Checklist, and Emergency Management Director Nuclear Power Plant Checklist; NUREG-0654/FEMA REP-1, J.l0.c, d, g. Criterion 3c.2' EFFECT: Lack of confirmation of evacuation status of schools could lead to confusion and delays in family reunification during a real event. Without confirmed

.informationregarding the location of students, misinformation regarding students' locations could accidentally be given to the public.

RECOMMENDATION: Include a task in the Manitowoc EOP for the appropriate representative at the Manitowoc EOC to confirm that school evacuation has been completed'and incorporate into the Manitowoc County Plan.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None "

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.12 Manitowoc County - Sheriffs Department - Dosimetry Distribution Point Manitowoc County demonstrated the Target Capability of Critical Resource Logistics and Distribution through the establishment of a Dosimetry Distribution Point at the Manitowoc County Sheriffs Department located in Manitowoc. The Public Health Nurse demonstrated the proper useof direct-reading and thermo-luminescent dosimeters, calibration equipment and communications systems.. The nurse conducted a thorough briefing regarding the use of and record keeping requirements for personal dosimetry kits including the proper procedures and documentation of the use of potassium iodide.

In summary, the status of DHS/FEMA criteria for this location is as follows:

50

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.13 Manitowoc County - Sheriff's Department -, Traffic Control Point Mgnitowoc County demonstrated the Target Capability of Emergency Public Safety and Security Response through interview which included the distribution of dosimetry, emergency worker radiological exposure management, and the capability to implement Traffic Control Points (TCPs) within the 10-mile Emergency Planning Zone.. During the interview, the Deputy demonstrated thorough knowledge of the provisions of the. Emergency Operations Plan related to the establishment of TCPs in addition.to the u~se of appropriate dosimetry procedures, documentation and communications equipment including portable radios, cell phones and mobile data terminals.-,

In summary, the status of DHS/FEMA criteria for this location-is as follows: .

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.1.4 Manitowoc County - Lakeshore Aviation - Route Alerting Manitowoc County demonstrated the Target Capability of Emergency Public Safety and Security Response through interview which included the distribution of dosimetry, emergency worker radiological exposure management, and the capability to perform Supplementary Route Alerting by aircraft within the 10-mile Emergency Planning Zone. A Manitowoc County Sheriff s Depuity was dispatched by the Law Enforcement Officer in the Manitowoc County EOC to meet with the private pilot and assist him with the notification along the supplimentail route via 51

Unclassified I After Action Report/Improvement Plan Radiological Emergency Preparedness Program (REP)

Kewaunee Power Station I aircraft in Manitowoc County.

In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None .

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.15 Manitowoc County - Emergency Alert System - WCUB/WLTU Manitowoc County demonstrated the Target Capability of Emergency Public Information and Warning associated with primary alerting and notification of the public was completed in a timely manner. Following the decision by County emergency management officials to notify.the public of an emergency situation at the Kewaunee Power Station, Radio Station WCUBiWLTU personnel demonstrated a thorough understanding of their equipment, the EAS process, and executed their duties in a timely and professional manner.

In summary, the status of DHS/FEMA criteria for this location is as follows: I

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

b. AREAS REQUIRING CORRECTIVE ACTION: None " -

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None I

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.16 Manitowoc County - Michicot School District - Evacuation School I Manitowoc County demonstrated the Target Capability of Citizen Evacuation and Shelter-in-Place for school children through telephone interview. The Michicot School District U representative described plans and procedures to safely evacuate students from the Kewaunee County Power Station EPZ and reunite them with their families. The school district demonstrated sufficient personnel, current contact information, emergency worker dosimetry, and 52

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station communications capabilities to notify families and guardians regarding how to reunite with, evacuated students.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET:- 1.d.1, 1.e.l, 3.a.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 Manitowoc County - Highway Department - Dosimetry Distribution Point to y demonstrated the Target Capability of Critical Resource Logisti cs. and Manitowoc County deosrtdteTre aaiiyo rtclRsuc oIsisan Distribution through the establishment of a Dosimetry Distribution Point at the Manitowoc.,

County Highway Department in Manitowoc Wisconsin' The Public Health Nurse demonstrated the proper use of direct-reading 'and thermo-luminescent dosimeters, calibration equipment and communications systems. The nurse conducted a thorough briefing regarding the use'of and' record keeping requirements :for personal dosimetry kits including the proper procedures and documentation of the use of potassium i6dide.

In summary, the status of DHS/FEMA criteria for this lo~ation is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 53

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Kewaunee Power Station 3.3.2.18 Manitowoc County - Highway Department - Evacuee/Emergency Worker Registration Kewaunee County demonstrated the target capability to establish adequate facilities, resources and trained personnel for monitoring and, if necessary, decontaminating evacuees and emergency workers during an out-of-sequence activity at the Kewaunee County Reception Center, Luxemburg Intermediate School in Luxemburg, Wisconsin:

In summary, -the status of DHS/FEMA criteria for this location is as follows:

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

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 Manitowoc County - Lakeshore Technical College - Congregate Care Center Manitowoc County and the American Red Cross Lakeland Disaster Chapter (ARC) successfully I demonstrated the Target Capability of communications equipment to support emergency operations during an out-of-sequence demonstration. The demonstration was conducted at the Lakeshore Technical College Congregate Care Center in Cleveland, Wisconsin.

American Red Cross (ARC) successfully demonstrated that they had the resources to provide services and accommodations consistent with American Red Cross planning guidelines, and had procedures to assure that evacuees had been monitored for contamination, and had been decontaminated as appropriate prior to entering the congregate care facility In summary, the status of DHS/FEMA criteria for this location is as follows: I

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

b. AREAS REQUIRING CORRECTIVE ACTION: None *

c. DEFICIENCY: None

d. PLAN ISSUES: None 54

Unclassified Radiological Emergenc' Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.20 Manitowoc County - Manitowoc County Fire Department/EMS - Medical Service -

Transportation The State of Wisconsin and the Manitowoc County Fire Departmrnt demonstrated the Target Capability that they have the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals. Manitowoc County Fire Department demonstrated the capability to transport.

contaminated, injured individuals.

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: l.d.1, .e.1,3.a.1, 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 55

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Kewaunee Power Station SECTION 4: CONCLUSION There were no Deficiencies identified for any jurisdiction during this exercise.

I There were no new Areas Requiring Corrective Action (ARCA)/Planning. Issues identified and unresolved during this exercise.

Twvo ARCAs from previous exercises were not successfully demonstrated during this exercise:

The State of Wisconsin, ARCA # 1 (49-10-1 e l-A-01) identified under Criterion 1.e. 1 which was issued in 2010 during the Point Beach REP Exercise - Acceptable ranges of operation were not posted on the calibration stickers on the Bicron Micro-Rem meters or the Ludlum Model 12 count rate meters used in the Mobile Radiological Laboratory or the Sample Receiving Area nor n was the Field response manager contacted for assistance because there was no means to ensure the instrument was operating properly. This ARCA remains unresolved. n The State of Wisconsin, ARCA #2 (49-10-5b 1-A-02) identified under Criterion 5.b. 1 which was issued in 2010 during the Point Beach REP Exercise - Exercise Release #3 was marked "For Immediate Release," and was issued to the JIC and Counties at 1012 hours0.0117 days 0.281 hours 0.00167 weeks 3.85066e-4 months , but the Hotline staff was not operational until 1040 hours0.012 days 0.289 hours 0.00172 weeks 3.9572e-4 months .. The State EOC PIO anticipated that the JIC would. n announce the establishment of the Hotline but apparently did not anticipate the distributionof the release by the County PIOs. Unftil the JIC and Hotline become operational, the State and County EOC PIs provide incident related public information to the media and respond to public inquiries directly. The, State EOC PIO apparently anticipated that coordination with the JIC implied full coordination with Counties, but when combined with actual cOmmunications systems malfunctions during the transition of responsibilities, the coordination was incomplete.

This issue was given during Point Beach in 2010 and could not be re-demonstrated during the Kewaunee 2011 due to the hotlines being at different locations for Point Beach and Kewaunee.

This will be re-demonstrated during Point Beach 2012.

Two ARCAs from previous exercsises were successfully re-demonstrated during this exercise:

The State of Wisconsin ARCA #3, for the State of Wisconsin (49-10-1 c 1-A-04) identified under Criterion 1.c. 1 which was issued in 2010 during the Point Beach REP exercise - Field Operation n Center briefings were not performed by the Field Response Manager as defined in Section 4.1 of 56

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station the Wisconsin Department of Health Radiological Incident Response Plan Volume 2, FOC/MRL Operations Manual. Using a completed Field Team Dispatch Briefing Checklist; the Field Team Coordinator performed a pre-deployment brief to all Field Team and FOC/MRL support staff prior to Field Team deployment. This ARCA was successfully demonstrated during this exercise.

The State of Wisconsin ARCA #4, for the State of Wisconsin (33-09-5b 1-A-05) identified under Criterion 5.b. 1 which was issued during 2009 Kewaunee REP exercise - The Virginia Call Center did not receive JIC News Releases, EAS and Special News Broadcast messages regarding protective action decision for the public. After receiving and reviewing documentation and by evaluator's observations, it has been determined that there was adequate support that communications between the Virginia Call Center and the JIC was much improved. This ARCA was successfully demonstrated during this exercise.

There were five Planning Issues associated with this exercise:

The State of Wisconsin, Planning Issue #1 (33-11-1 el-P-0l) identified under Criterion L.e. 1, the State of Wisconsin Radiological Incident Response Plan (RIRP) and Manitowoc County Emergency Operations Plan and supporting SOPs, checklists and forms identify the Permanent Record Dosimeters (PRDs) issued to emergency workers as TLDs (Thermo-Luminescent Dosimeters). However, Landauer/Luxel + Optically Stimulated Luminescent Dosimeters (OSLDs) were issued at the Manitowoc County Highway Department Reception Center. The table in Volume IV, Section 2.3.J, of the State Radiological Incident Response Plan (RIRP),

includes a Dosimeter Issuance Policy table that lists Minimum Recommended dosimeter types by Response Staff Type and includes a column that is titled TLD or OSL which indicates that either TLDs orOSLIs may be issued. The table in Volume IV, Section 2.3.1, of the RIRP also indicates that the issuance of 0-20 R DRDs is NA (meaning Not Applicable) to all Response Staff Types.

However, 0-20 R DRDs were issued to the emergency workers who staffed the Personnel and Vehicle Monitoring/Decontamination Stations at the Reception Center (including the following Response Staff Types: Vehicle Monitoring, Vehicle Decontamination, Personnel Monitoring, Portal Monitoring, Resurvey Monitoring, Personnel Decontamination, Decontamination Exit Monitoring, and Monitoring Station Recording).

The State of Wisconsin, Planming Issue #2 (33-1 i -6a l-P-02) identified under Criterion 3.c.2, the 57

Unclassified Radiological Emergency Preparedness Program (REP)

I

'After Action Report/lInprovenment Plan Kewaunee Power Station facility has one shower stall that would be used for whole-body Evacuee/Emergency Worker Decontamination. The stall is not large enough to provide privacy for staging a clean towel and body covering (Tyvek suit), disrobing and placing contaminated clothing in a receptacle, showering, drying with the clean towel, and donning the clean garment. These activities could be viewed by the Decontamination Team Recorder, who would hand a clean towel to the -

evacuee/emergency worker for drying and a Tyvek suit body covering for donning, as Well as by the Entrance and Exit Monitors. i When queried by the Evaluator,. the Appleton Hazmat Team personnel who operated the station stated that the Team has no female personnel who are trained Monitorsl or Recorders.

The floor diagram on page ATT 1-21 of the Manitowoc County. Emergency Operations Plan (Attachment 1, Manitowoc County. Reception Center Personnel Decontamination) does not accurately reflect the actual configuration of the personnel decontamination facility. The diagram shows a Hand Washing Sink located outside the Decontamination Station Room (combination Locker Room/Shower in the diagram) past the Frisking Stations. During this exercise, the sink used for hand washing-by Evacuees/Emergency Workers was located inside (rather than outside) the combination Locker Room/Shower in a separate toilet/wash room. The combination locker/shower room portion of the diagram does not accurately reflect that actual configuration I of the room(s)., ... ,,

Manitowoc County., Planning Issue #3 (33-11-3c2-P-03) identified under Criterion 3.c.2, the Manitowoc County Executive at the Emergency Operations Center (EOC) directed the.Mishicot Superintendent to evacuate schools in the School District of Mishicot at the Site Area Emergency, Emergency'Classification Level (ECL). Staff at the Manitowoc EOC did not receive confirmation that the School District of Mishicot had successfully evacuated their schools.

Procedures for staff at the Manitowoc EOC (Manitowoc County Emergency Operations Plan, Annex I, Part 2) do not match the specific procedures for school staff (Manitowoc County Emergency Operations. Plan, Annex I, Part 2, Attachment 7, Nuclear Emergency Evacuation Plan for the School District of Mishicot). The Mishicot Superintendent is required to inform the Human Services representative at the EOC when evacuation is complete, but the EOC procedures do not require any staff, including the County Executive, Emergency Management l Director, or Human Services representative to confirm when evacuation is complete.

58

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Kewaunee Power Station The State of Wisconsin, Planning Issue #4 (33-11-4al-P-04) identified under Criterion 4.a. 1, the instructions in the Wisconsin Department of Health Services Radiological Incident Response Plan for response check of the Fluke Victoreen 451 B Ion Chamber Survey Meter did not match the requirements posted on the calibration sticker for the instrument or the instructions posted, with the check source jig in the mobile laboratory.

According to Wisconsin Department of Health Services Radiological Incident Response Plan,:

Volume 3, Page 21, the instructions to source check the Victoreen 451B were Turn the meter over and slide back the plastic cover. This exposes the Beta window. With the assistance of FOC staff, obtain the check source jig. Ensure the check source is .set snugly within the square insert, and place. the meter. into the jig such that the Beta window is flush with the check source.

The calibration sticker on the side of the Victoreen 451B Bclearly indicated that the.response check should be conducted with the cover on the instrument closed. The instructions posted. with

the check source jig in the mobile laboratory also indicated that the response check should be conducted with the cover on the beta' window closed.

The State of Wisconsin, Planning Issue.#5 (33-1 i-4a1-P-05) identified under Criterion 4.a.1, Restricted Area,Field Team 2 did not record background measurements in a clean area for either the Fluke. Victoreen 451 B Ion Chamber Survey Meter or the Ludlum Model 12 Rate meter with' Model 44-9 Probe. During interview, team members were unable to recall what the original or baseline background readings had been.

There are no instructions in the Wisconsin Department of Health Services Radiological Incident Response Plan to record baseline instrument readings.

According to the procedures for the Ludlum Geiger Counters' and Pancake Detectors (Wisconsin Department of Health Services Radiological Incident Response Plan, Volume 3, Page 21) the operator should Step the meter down to the lowest scale and observe background reading with slowest response setting. Make sure the RESET button returns needle to zero and that the background readings are less than 500 cpm However, there are no instructions to'record the background reading. The procedures for the Victoreen 451B do not address background '

readings.

.Two ARCAs from previous exercises were not successfully demonstrated during this exercise:

Based on the results of the October 4, 2011 exercise, the offsite radiological emergency response plans and preparedness for the State of Wisconsin and affected local jurisdictions, site-specific to 59

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station the Kewaunee PowerStation, .can be implemented and are adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect thehealth and safety of the public in the event of a radiological emergency a4t the site.

Therefore, the Title 44 CFR, Part 350, approval of the offsite radiological emergency response plans and 15reparedness for the State of Wisconsin site-specific to Kewaunee Power Station, granted on June 15, 1985, remains in effect.

6 I

I 60I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station APPENDIX A: IMPROVEMENT PLAN Isu Num er 33*1c-!-13Ciein c ISSUE: The Manitowoc County Executive at the Emergency Operations Center (EOC) directed the Mishicot Superintendent to evacuate schools in the School District of Mishicot at the Site Area Emergency Emergency Classification Level (ECL). Staff at the Manitowoc EOC did not receive confirmation that the School District of Mishicot had successfully evacuated their schools.

RECOMMENDATION: Include a task in the Manitowoc EOP for the appropriate representative at the:

Manitowoc EOC to confirm that school evacuation has been completed and incorporate into the Manitowoc County Plan.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

61

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Kewaunee Power Station

!Issue Numbe: . i i ISSUE: State Message #5/Exercise Release #3 issued by the State EOC contained untimely instructions by directing the public to contact the Public Inquiry Hotline at its designated telephone number substantially prior to when the Hotline was operational. Exercise Release.#3 was marked "For Immediate Release," and was issued to the I

JIC and Counties at 1012 hours0.0117 days 0.281 hours 0.00167 weeks 3.85066e-4 months , but the Hotline staff was not operational until 1040 hours0.012 days 0.289 hours 0.00172 weeks 3.9572e-4 months ., The County PIOs distributed Exercise Release #3 in accordance with their respective procedures and the "For Immediate Release" markings. Callers would have received the following pre-recorded message: "Thank you for calling the FPL Point Beach Nuclear Plant Emergency Hotline. At this time, the Emergency Hotline has not been activated..." Callers were provided telephone numbers for, and instructed to call, either the Point Beach Manager of Communications or the Supervisor of the Point Beach Energy Center. This can be confirmed by calling the Point Beach Hotline.

RECOMMENDATION: The State EOC PIO should verify with the JIC that the Public Infornation Hotline is staffed and operational before issuing a news releasel directing the public to contact the Hotline regarding questions I

and concerns. Additionally, the State EOC PIO should ensure that County EOC PIOs are provided appropriate ý,

handling instructions for any public infornantion documents marked "For Immediate Release." Public Information Officer plans, procedures, guides and checklists should be reviewed and updated, as appropriate, to incorporate the verification process.

i CORRECTIVE ACTION DESCRIPTION: The following actions will be taken in response to ARCA #49-1.0-5bl-A-02 issued against the State of Wisconsin, Emergency Operations Center - Public Informatidn Officer'.

State message #5, Exercise Release #3,.issued by the .State EOC contained untimely instructions by directing.'the public to contact the Public Inquiry Hotline at its designated telephone number substantially prior to ivhen t,he Hotline Wvas operational. Exercise Release #3'was marked "For Immediate Release," and was issued to the JIC and Counties at '1012 hours0.0117 days 0.281 hours 0.00167 weeks 3.85066e-4 months , but the hotline staff was not operational until 1040 hours0.012 days 0.289 hours 0.00172 weeks 3.9572e-4 months . The.County PIOs distributed Exercise Release #3 in accordance with their respective procedures and the "For 'Immediate Release" marking.

Callers .would have received the following pre-recorded message: "Thank you for calling the FPL Point Beach I

Nuclear Plant Emergency Hotline. At this time,the Emergency Hotline has not been activated..." Callers were provided telephone numbers for, and instructed to call, either the Point Beach Manager of Commtinications.or the' Supervisor of the Point Beach Energy Center. This can be confirmed by calling the Point Beach Hotline..

The State of Wisconsin will add an additional.item to the Operatio ns Check List, which will include requesting the State Public Information Officer contact the utility Public Information Hotline to ensure that they are opetational prior to writing a media release stating they are operational... .. -

This ARCA (#49-10-5bl-A-02) will be re-demonstrated at the October 2011 Kewaunee Power Station exercise.

CAPABILITY: " PRIMARY RESPONSIBLE AGENCY:

Emergency Public Information and Warning Wisconsin Emergency Management Public Information Officer I CAPABILITY ELEMENT: START DATE:

Organization and Leadership AGENCY POC:

William Clare 608-242-3220 2011-01-24 ESTIMATED COMPLETION DATE:

2011-1'0-04 I

I I

I 62 I

I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station I I t.1 C ite io :l .

ISSUE: Acceptable ranges of operation were not posted on the calibration stickers on the Bicron Micro-Remn meters or the Ludlum Model 12 count rate meters used at the Mobile Radiological Laboratory or the Sample Receiving Area nor was the Field Response Manager contacted for assistance because there was no .means to ensure the instrument was operating properly.

RECOMMENDATION: Install calibration labels indicating acceptable ranges of operation during the calibration process and train personnel on the proper procedure for performing operability checks in accordance with procedures.

CORRECTIVE ACTION DESCRIPTION: The following actions will be taken in response to ARCA #49-10-1 el-A-01 issued against the State of Wisconsin, Mobile Radiological Laboratory' -Acceptable ranges of operation were not posted on the calibration stickers on the Bicron Micro-Rem meters orthe Ludlum Model 12 count rate meters used at the Mobile Radiological Laboratory or the Sample Receiving Area nor was the Field ResponseManager contacted for assistance because there was no means to ensure the instrument was operating properly.

Although the State of Wisconsin does not have an immediate solution for the Bicron Micro-Rem meterissue, the Wisconsin Department of Health Services - Radiation Protection Section is in the process of conducting research.

and discussing approaches taken by other states for a solution that will satisfy all stakeholders. It is anticipated that this research can be conducted within the next 30 days. The .State of Wisconsin will send FEMA a subsequent ' ý letter describing the solution. Regarding the Ludlum meters, these theters Will be sent back to the manufacture for calibration and an appropriate calibration sticker.

This ARCA (#49-10-1 eI-A-01) will be re'demonstrated at the October 2011 Kewaunee Power Station exercise.

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:.

Laboratory; Testing Wisconsin Department of Health'Services - Radiation' Protection Section CAPABILITY ELEMENT: START.DATE:.

Systemns and Eguipmefit 2011-01-24 AGENCY POC: ESTIMATED COMPLETION DATE:

Paul Schmidt 608&267-4792 : 2011-1004 2011-10-'0 63

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan . Kewaunee Power Station I

IsuNubr 3311I~e.P0 Crtrong ISSUE: The State of Wisconsin Radiological Incident Response Plan (RIRP) and Manitowoc County Emergency Operations Plan and supporting SOP's, checklists and forms identify the Permanent Record Dosimeters (PRD's) issued to emergency workers as TLDs (ThermoLuminescent Dosimeters). However, Landauer Luxel+ Optically I

Stimu!ated Luminescent Dosimeters (OSLD's) were issued at the Manitowoc County Highway Department Reception Center. The table in Volume IV, Section 2.3.1, of the State Radiological Incident Response Plan (RIRP),

includes a Dosimeter Issuance Policy table that lists "Minimum Recommended" dosimeter types by Response Staff Type and includes a column that is titled "TLD or OSL" - which indicates that either TLD's or OSLD's may be

,I issued.

The table in Volume IV, Section 2.3.1, of the RIRP also indicates that the issuance of 0-20 R DRD's is "NA" (meaning."Not Applicable") to all Response Staff Types. However, 0-20 R DRD's were issued to the emergency I

workers who staffed the Personnel and Vehicle Monitoring/Decontamination Stations at the Reception Center (including the following Response Staff.Types: ,Vehicle Monitoring, Vehicle Decontamination, Personnel.

Monitoring, Portal Monitoring, Resurvey Monitoring, Personnel Decontamination, Decontamination Exit, Monitoring, and Monitoring Station Recording).

I RECOMMENDATION: Revise plans, procedures, checklists and forms to reflect the type or types of' permanent record dosimetry that is currently used. For example, the generic term "Pennanent Record Dosimeter.'

and associated acronym "PRD" could replace references to "ThermoLuminescent Dosimeter" and "TLD." Wlhere appropriate, identify the specific make and model, such as Landauer ThermoLuminescent Dosimeter (TLD) or I

Landauer.Luxel+ Optically Stimulated Luminescent Dosimeter (OSLD). The TLD's and OSLD's may also be referred to generically as "Luminescent Dosimeters" and by the acronym "LD."

The RIRP tableý (Volume IV, Section 2.3.1) should be revised to replace the ".NA" designations in the 0-20 R I

column by a more appropriate designation (e.g., "Yes" - which reflects what was actually issued; or "Optional" -

which would allow, but not require, the issuance of the 0-20 R DRD's to the designated Response Staff Types).

CORRECTIVE ACTION DESCRIPTION: ' I

, /

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

I CAPABILITY ELEMENT:

AGENCY POC:

START DATE:

ESTIMATED COMPLETION DATE:- I I

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station 110I Cri rit I I ISSUE: The facility has one shower stall that would be used for whole-body Evacuee/Emergency Worker Decontamination.. The stall is not large enough to provide privacy for staging a clean towel and body covering (Tyvek suit), disrobing and placing contaminated clothing in a receptacle, showering, drying with the clean towel, and donning the clean garment. These activities could be viewed by the Decontamination Team Recorder, who would hand a clean towel to the evacuee/emergency worker for drying and a Tyvek suit body covering for donning, as wellas by the Entrance and Exit Monitors.

When queried by the Evaluator, the Appleton Hazmat Team personnel who operated the station stated that the, Team has no female personnel who are trained Monitors or Recorders.

The floor diagram on page ATT 1-21 of the Manitowoc County Emergency Operations Plan (Attachment 1 -

Manitowoc County Reception Center Personnel Decontamination) does not accurately reflect the actual configuration of the personnel decontamination facility. The diagram shows a Hand Washing Sink located outside the Decontamination Station Room (combination Locker Room/Shower in the diagram) past the "Frisking Stations." During this exercise, the sink.used for hand washing by Evacuees/Emergency 'Workers was located-.._

inside (rather than outside) the combination Locker Room/Shower in a separate toilet/wash room. The combination locker/shower room portion of the diagram does not accurately reflect that actual configuration of the room(s)..

RECOMMENDATION: In order to avoid delays and other issues when processing female contaminated individuals, the Decontamination Station should be staffed by fully trained female workers to advise, assist and monitor female evacuees and emergency workers during processing. If feasible, a separate (temporary or permanent) shower facility for and staffed by females should be made available. If space is sufficient, a removable, free-standing partition or drape might be used to provide privacy by screening both the shower stall and niche beside the stall where a small table andwaste receptacle could be positioned to stage clean items (towel/Tyvec suit) and dispose of dirty items (contaminated clothing).

The diagram on page ATT 1-21 of the County Plan should be revised to show the actual configuration of functional elements. Providing an enlarged insert or separate diagram for the Decontamination Station would aid in depicting the actual location and configuration of such functional elements as the toilet/wash room, shower, benches, equipment staging, (clean and dirty) waste receptacles, tables, chairs, and demarcation lines/step-off pads.

CORRECTIVE -ACTION DESCRIPTION:. ... ..

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE-65

' Unclassified Radiological Emergency Preparedness Program.(REP)

I After Action Report/Improvement Plan Kewaunee Power Station IIsu Nu br 331-a -P0 riein ISSUE: The instructions in the Wisconsin Department of Health Services Radiological Incident Response Plan for response check of the Fluke Victoreen 451B IonChamber Survey Meter did not match the requirements posted on the calibration sticker for the instrument or the instructions posted with the check source jig in the mobile laboratory.

RECOMMENDATION: Edit Wisconsin Department of Health Services Radiological Incident Response Plan, Volume 3, Page 21, and Volume 2, Page 32.

From: Turn the meter over and slide back the plastic cover. This exposes the Beta window.

To: Turn the meter over and assure that the plastic cover is slid forward. The source check must be conducted with the Beta window closed.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

Issu Numer 3314lP5 Crtrin 4l.

ISSUE: Restricted Area Field Team 2 did not record background measurements in a clean area for either the Fluke&Victoreen 45 1B Ion Chamber Survey.Meter or the Ludlum Model 12 Ratemeter with Model 44-9 Probe..

During~interview, team members were unable to recall what the original or baseline background readings had been.

RECOMMENDATION: Add a location on the Pre-Dispatch, Field Team/Kit Evaluation Checklist to record background readings. -This may prove helpful to the Field Teams and to persons .performing-assessment to calculate dose conversion factors.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY:, PRIMARY RESPONSIBLE AGENCY:-

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

I I

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Unclassified Radiological Emergency Preparedness. Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station APPENDIX B: EXERCISE TIMELINE' Table. 1, on the following page, presents the times at whichkey events. and activities occurred during the Kewaunee Power Station Radiological Emergency Preparedness (REP) Full Participation Plume Exposure Pathway Exercise conducted on October 4, 2011. Included are times that notifications were made to the participating jurisdictions and functional entities.

Table 1 - Exercise Timeline -

DATE: 2011-10-04, SITE: Kewaunee Power Station, WI Emtergency Clas09sificaton Le9eor...45 Unusual Event Alert.~ 0747 0756 4 93 0811'. "00 S,ite Area Emrergency 09-27 0943 0929 0959' 0946 0.945 General Emergency 1039 1050 104-1 1059 1052 1055, Simulated Rad. Release Started 1039 1039 1035 1059 -1039 1059 Simulated Rad. Release Terminated Facility Declared Operational 0904 0925 0919 0850 Declaration of State of Emergency 1112 1120 1055 1055 Exercise Terminated 1242 1242 .1230 1245 1247 Early Precautionary Actions: (Evacuate State 1105 1139 1110 1114 Parks and Hunting)

Early Precautionary (Evacuate Schools) 1016 1000 0958 1007 1000 1007 Advisory Message General Information Message 0920 " 0857 0856 Protective Action Recommendation 1046. 1114 1053 1055 1st Protective Action Decision: . 1101 1057-1st Siren Activation 1105 1105 I st EAS or EBS Message 1110 1107 KI Administration Decision: 1107 1046 1101 1057 67

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Kewaunee Power Station APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS The following is a list of the personnel that evaluated the Perry Nuclear Power Plant REP Partial Participation Plume Exp6sure Pathway Exercise on September 28, 2010. The list includes the evaluation team leadership and all evaluators. The organization each evaluator represents is indicated by the following abbreviations:

DHS/FEMA - Department of Homeland Security/Federal Emergency Management. Agency.

ICF - ICF Consulting . -

Title, Name, Organization Radiological Assistance Committee, Chairman - William E., King - DHS/FEMA "

Exercise Director - Dwaine Warren - DHS/FEMA Site Specialist - James King - DHS/FEMA .

Team Leader - State of Wisconsin - David Ortman - DHS/FEMA Team Leader - Kewaunee County- Edward Golinski - DHS/FEMA, Team Leader - Manitowoc Kerris Bates - DHS/FEMA .

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station DATE: 20'11-10-04, SITE: Kewaunee Power Station, WI LOCATON EVALUATOR . AGENCY State of Wisconsin - State Warning Center #1 - Inital Warning Point Richard Echavarria FEMA RIX State of Wisconsin - State Warning Center #2 - Initial Warning Point Alberto Sifuentes FEMA RIX State of Wisconsin - Emergency Operations Center Richard Echavarria FEMA RIX Alberto Sifuentes FEMA RIX State of Wisconsin - State Emergency Operations Center - Marcy Campbell ICFI Radiological Coordinator State of Wisconsin - Forward Operating Center . David Seebart ICFI State ofWisconsin - Forward Operations Center - Mobile Radiological David Seebart ICFI Laboratory .

State of Wisconsin - Restricted Area Field Team 1 Paul Ward FEMA HQ State of Wisconsin - Restricted Area Field Team 2 Michael Howe,, FEMA HQ State of Wisconsin - Joint Information Center - Media Center John Simpson FEMA RV State of Wisconsin - Kewaunee County Emergency Operations, Center Edward Golinski FEMA RV

- State Liaison State of Wisconsin - Manitowoc County Emergency Operations Kerris Bates FEMA RV Center - State Liaison State of Wisconsin - Highway Department - Evacuee/Emergency Carl Bebrich FEMA Worker Monitoring and Decontamination State of Wisconsin - Highway Department - Evacuee/Emergency Karl Rabenhorst FEMA RV Worker Monitoring and Decontamination of Equipment and Vehicles State of Wisconsin - Holy Family Medical Center - Medical Service - Christopher Bellone FEMA RV Facility Kewaunee County - Sheriffs Dispatch Center - Initial Warning Point John Arszulowicz FEMA-IQ Kewaunee County - Emergency Operations Center John Arszulowicz FEMA HQ David Jeremy FEMA HQ James King FEMA RV John Simpson FEMA RV Kewaunee County - Sheriffs Department - Traffic Control Point Lisa Rink FEMA R4 Manitowoc County - Joint Information Center - Public Information John Simpson FEMA RV Officer Kewaunee County - Joint Information Center - Public Information John Simpson FEMA RV Officer Kewaunee County - Emergency Alert System - WSRG Paul Anderson FEMA RIX Kewaunee County - Kewaunee School District - Evacuation School Paul Anderson FEMA RIX Kewaunee County - Annex Building - Dosimetry Distribution Point Carl Bebrich FEMA Kewaunee County - Route Alerting - Exception Area Richard Grundstrom ICFI Manitowoc County - Sheriffs Dispatch Center - Initial Warning Point Todd Gemskie FEMA Manitowoc County - Emergency Operations Center Ingrid Bruns FEMA RI Todd Gemskie FEMA Elena Joyner FEMA RIX Manitowoc County - Sheriffs Department - Dosimetry Distribution Carolyn Sturghill FEMA RV Point Manitowoc County - Sheriffs Department - Traffic Control Point Rebecca Fontenot FEMA HQ Manitowoc County - Lakeshore Aviation - Route Alerting Karl Rabenhorst FEMA RV Manitowoc County - Emergency Alert System - WCUB/WLTU Christopher Bellone FEMA RV Manitowoc County - Michicot School District - Evacuation School Clinton Crackel FEMA RV Manitowoc County - Highway Department - Dosimetry Distribution Rebecca Fontenot FEMA HQ Point 69

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station Manitowoc County - Highway Department - Evacuee/Emergency Carolyn Sturghill FEMA RV Worker Registration_

Manitowoc County - Lakeshore Technical College - Congregate Care Elena Joyner FEMA RIX Center Manitowoc County - Manitowoc County Fire Department/EMS - Clinton Crackel FEMA RV Medical Service - Transportation

.. ....... ....... m L e.. Ta> :, ** ..

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station APPENDIX D: ACRONYMS-AND ABBREVIATIONS ARC American Red Cross CBC County Board Chair CCC Congregate Care Center CEO Chief Elected Official CLAR Customer Location Alternative Routing CO Communications Officer CTH County Trunk Highway DC Data Coordinator DCO Dosimetry Control Officer DDP Dosimetry Distribution Point DO Duty Officer DRD Direct Reading Dosimeters EAS Emergency Alert System ECL Emergency Classification Level ED Emergency Department EM Emergency Manager EMA Emergency Management Agency EMD Emergency Management Director EMS Emergency Medical Service EOC Emergency Operations Center EOF Emergency Operations Facility EOP Emergency Operations Plan EPZ Emergency Planning Zone ERDS Emergency Response Data System ESF Emergency Support Function EW Emergency Workers FEMA Federal Emergency Management Agency FOC Forward Operations Center FRM Field Response Manger FT Field Teams FTC Field Team Coordinator GCS Glasgow Coma Scale GE General Emergency GIS [Geographic Information System 71

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Kewaunee Power Station I

HSD Human Services Director HTL IAP Health Team Leader Incident Action Plan U

IFR Instrument Flight Rule IWP Initial Warning Point I JDC Joint Dispatch Center JIC JPIC Joint Information Center Joint Public Information Center I

KCHD Kewaunee County Highway Department KCHS KEOC Kewaunee County Human Services Kewaunee Emergency Operations Center I

KPS LSC Kewaunee Power Station Laboratory Services Coordinator I MCHD Manitowoc County Highway Department MCRC MEOC Manitowoc County Reception Center Manitowoc Emergency Operations Center I

MFD Manitowoc Fire Department MRL NARS Mobil Radiological Laboratory Nuclear Accident Reporting System I

NO NRC Network Operations Nuclear Regulatory Commission I OSL Optically Stimulated Luminescent PAD PAG Protective Action Decisions Protective Action Guidelines I

PAR Protective Action Recommendation Pio PPE Public Information Officers Personal Protective Equipment I

PRD RACES Permanent Record Dosimeter Radio Amateur Civil Emergency Services I

RAFT Restricted Area Field Team RCM RD Reception Center Manager Regional Director I

REA REP Radiological Emergency Area Radiological Emergency Preparedness I RIRP Radiological Incident Response Plan RO RPS Radiological Officer Radiation Protection Section I

RSO Radiation Safety Officer SAE SEOC Site Area Emergency State Emergency Operations Center I

72 I

I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan KewauneePower Station SMS Short Message Service SRC State Radiological Coordinator TCP Traffic Control. Point TLD Thermoluminescent Luminescent Dosimeter USCG United States Coast Guard VFR Visual Flight Rules VMTS Vehicle Monitoring Team Supervisor WEM Wisconsin Emergency Management WSP Wisconsin State Police 73

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station APPENDIX E: EXERCISE PLAN The KPS REP Plume Exposure Pathway exercise was 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 have taken part in the planning process and will take part in exercise conduct and evaluation.

This ExPlan was produced at the direction of the DHS/FEMA with the input, advice, and" assistance of the EPT. The KPS REP Plume Exposure Pathway exercise is evidence of the growing partnership between State and local jurisdictions: for response to the threats our Nation and communities face.

This one day exercise is a full participation Plume Exposure Pathway exercise., Ingestion.

Pathway Exercise activities are not required and will not occur. Several emergency facilities will be activated for the exercise; State of Wisconisin Emergency Operations Center (EOC) located in Madison, Wisconsin; Manitowoc County EOC located in Manitowoc, Wisconsin; Kewaunee County EOC located in Algoma, Wisconsin; and the Joint Information Center (JIC) Call Center both colocated in Green Bay, Wisconsin. The Reception Centers and Congregate Care Centers are located in various locations within Kewaunee and Manitowoc counties. Additionally, Holy Family Memorial Hospital located in Manitowoc, Wisconsin will participate in a Medical Services (MS-1) drill with field operations support from Kewaunee County.

74

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station DOMINION GENERATION KEWAUNEE POWER STATION OCTOBER 4,2011 GRADED EXERCISE EXERCISE SCOPE The purpose of this emergency exercise is to activate and evaluate major poitions of the Kewaunee Emergency Plan, associated implementing procedures, and selected portions of the Corporate Emergency Response Plan in accordance with 10CFR50.47 (b)(14), and to support the implementation of state and local governments emergency response plans.

This graded exercise will be held in conjunction with the State of Wisconsin, Kewaunee County and Manitowoc County emergency response personnel. The exercise will demonstrate that the ,

individuals and agencies assigned responsibilities in a radiological emergency are capable of coordinating and assessing necessary protective Measures to ensure the health and safety of the public in the event of an accident at Kewaunee Power Station.-

The exercise will demonstrate responses to the emergency classes, commensurate with the stated exercise objectives, established by NLTREG-0654 FEMA-REP- 1, Criteria for Preparation. and Evalhition of Radiological Emergency Response Plans andPreparedness'iin-Support of Nuclear Power Plants. Free play is encouraged and controllers will be allowed to interface with the, participants to provide information as directed by the exercise manual. The controllers will not alter the participants!. responses unless the exercise lags behind schedule, emergency response personnel takeliappropriate actions to car them t0the nexteveft or action is taken that would correct the expected simulated response earlier than scheduled by the scenario.

The focus items of this exercise are:

Safety

Drill Control

Communication with State and County EOCs The exercise will fulfill the following exercise and drill requirements:

Biennial Exercise

RP Drill The content of this exercise has been evaluated and is considered to provide a meaningful opportunity for the participants to gain proficiency. Therefore, drill participation will be awarded for qualifying positions. Also, objectives 2, 3 and 4 for Classification, Notification and Protective Action Recommendations will be evaluated to support the NRC Performance Indicator, Drill and 75

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station I

I Exercise Performance.

At no time will the exercise be permitted to interfere with personnel safety or the safe operation of I

the station. Station management may, at their discretion, suspend the exercise or any portion thereof for any period of time necessary to ensure this goal. Exercise participants will not have prior.

knowledge of the simulated incident.

I I

I 76 I

I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station DOMINION GENERATION KEWAUNEE POWER STATION OCTOBER 4,2011 GRADED EXERCISE OBJECTIVES The purpose of this exercise is to demonstrate the adequacy of the Kewaunee Power Station Emergency Plan, the Corporate Emergency Response Plan and associated implementing procedures.

The objectives of this exercise are to demonstrate by actual performance a number of key emergency preparedness functions as they relate to the Kewaunee Power Station Emergency Plan.

The simulated accident will involve: emergency classification, notifications of company and off-site organizations, simulated actions to correct the emergency condition and initiation of accident assessment and protective actions as necessary to cope with the event. The event will include a simulated off-site radiological release to support a plume exposure pathway exercise.

As applicable to the exercise scenario events, the Kewaunee Power Station, Dominion Corporate, State, and County response facilities will be activated. Each facility Staff will demonstrate functions described in the implementing procedures. Emergency response functions impractical to demonstrate will be simulated.

The attached objectives will be demonstrated as applicable to the schedule provisions of the Kewaunee Six Year Plan. A matrix, identifying the objectives, the Dominion Generation Emergency Response Facilities/Groups and facilities in which demonstrations will occur, is provided. The Control Room Simulator will be used in lieu of the actual Station Control Room.

77

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station I

DOMINION: GENERATION KEWAUNEE-POWER STATION OCTOBER 4,2011 GRADED EXERCISE OBJECTIVES The following objectives establish the scope, the extent of play, and extent of evaluation for this exercise. Also, these objectives ensure that required events are included in the exercise scenario. 5 Demonstrate the ability to conduct a drill or exercise with a strong focus on industrial and personnel safety.

Extent of Play All participants and controllers will employ safe working practices and observe for unsafe working conditions during the conduct of the exercise.

Extent of Evaluation This objective will be evaluated, including participant self-evaluation.

Demonstrate the ability to analyze station Conditions, assess Emergency Action Level (EAL) parameters; and correctly classify the emergency.

Extent of Play The CR Simulator and emergency response organizations will use EAL Charts and appropriate operational procedures to assess plant conditions and event occurrences to determine appropriate emergency classifications.

Anticipated classifications for this exercise are based, on conditions that' were established through control room simulator development activities. It should be noted that although these conditions were verified to be reproducible, variables exist that may alter the expected plant conditions resulting in a classification different than anticipated by the scenario. Off-

-site agency response will be guided by their procedures and May not follow the timeline and narrative description of the event. Any differences between off-site response and the pre-scripted timeline will be evaluated during the critique process.

The Shift Manager or Emergency Director may, under some conditions, classify events based on judgment per the EAL Charts. If conditions exist requiring classification under a specific EAL Chart conditions, then the classification should be made in accordance with that set of conditions rather than '"judgment". U Extent of Evaluation 7

78I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station This objective will be evaluated, including participant self-evaluation. In addition, this objective will be used for NRC drill and exercise performance indicator.

79

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station I

3 Demonstrate the ability to develop appropriate off-site Protective Action Recommendations. (PARs) based on assessment of plant conditions and off-site dose projections and/or measurements..

Extent of Play As appropriate, the Emergency Director in the TSC or the Emergency Response Manager in the EOF will implementtEPIP EP-AD-19.

The TSC and EOF organizations will monitor plant conditions and perform off-site dose projections to support formulation of PARs. Responsibility for PAR development is transferred from the TSC to the EOF following activation of the EOF. This scenario calls for a radioactive release, so dose projections may be directed in anticipation of potential [

degrading conditions. When the scenario events progress to a General Emergency a PAR will be issued.

Extent of Evaluation This objective will be evaluated, including participant self-evaluation. I n addition, this objective will be used for NRC drill and exercise performance indicator.

4 Demonstrate the ability to notify the State and local governments and the NRC within established time constraints. I As appropriate to the communications process, the CR Simulator and EOF will provide up-to-date information to the federal, state and local governments within the required time limits.

a. State and Local Government Communications.

An Emergency Communicator will perform initial and follow-up communications in accordance with EPIP-AD-07.

The Emergency Director will retain the responsibility for state and local government communications until the EOF is activated. Following EOF activation, responsibility for communications will be transferred to the Emergency Response Manager.

Use of backup communications systems will be performed only if primary communications fail.

b. NRC Communications An Emergency Communicator will perform initial and follow-up communications in accordance with EPIP-AD-07. The communicator will transmit information over I

80

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station the ENS phone line. The NRC will provide a simulated Headquarters Operations Officer to receive the initial and continuing communications. The responsibility for NRC communications remains with the CR staff during a security event. NRC communications will include prompt notification of a security event if applicable.

Health Physics Network communications will be performed in accordance with EPIP-EOE-04. If requested by NRC, the communicator will transmit information over the HPN phone line. The NRC will provide a simulated response officer to receive initial and continuing communications, over HPN., The responsibility for Health Physics Network communications will be with the EOF staff.

81

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station I

The Emergency Response Data System will be activated. Use of backup communications systems will be demonstrated only if primary communications fail. .

Extent of Evaluation This objective will be evaluated, including participant self-evaluation. In addition, this objective will be used for NRC drill and exercise performance indicator.

5. Demonstrate the ability to perform off-site dose assessment. Extent of Play As appropriate, the TSC and EOF Health Physics staffs will perform dose assessment through the implementation of EPIP-ENV-03 and associated dose assessment procedures.

U Field monitoring teams will be dispatched per EPIP-EN V- 03 and as indicated procedures to support the dose assessment effort.. As appropriate, BOP' staffs will direct these teams.

Event, conditions may require .state environmental monitoring teams' respond.-- State Field Monitoring Teams are expected to be mobilized for this exercise and May be pre-staged in consideration of travel time..

Extent of Evaluation' This objective will be evaluated, including participant Self-evaluation.

6. Demonstrate the ability to notify, mobilize, and sustain the Kewaunee Power Station and Corporate Emergency Response Organizations.

Extent of Play I The CR Simulator staff and Station Security will notify and mobilize the station emergency response organization.

If required, the process for obtaining logistical and technical support for emergency response personnel will be simulated.

Extent of Evaluation This objective will be evaluated, including participant self-evaluation.

7. Demonstrate the ability to conduct assembly and accountability of personnel within the Protected Area.

Extent of Play I

82

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station The Station Security staff will perform accountability ih accordance with EPIP-SEC-03.

On site personnel will be directed to report to their ERO dutystations or to one of five assembly areas. Non-participants will be released to return to work following initial accountability.

Extent of Evaluation This objective will be evaluated, including participant self-evaluation.

83

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station Demonstrate the ability to assemble, dispatch, and control on-site emergency teams to perform response activities.

Extent of Play As appropriate, the CR Simulator and Operations Support Facility staffs will brief, dispatch and control teams in response to scenario events within the Station Protected Area. The CR Simulator staff will initiate applicable procedures in response to scenario events.

Extent of Evaluation This objective will be evaluated, including participant self-evaluation.

9. Demonstrate the ability to assess conditions and implement appropriate protective measures for emergency response personnel, including site access control, contamination control, exposure control, use of protective devices and, as appropriate, the process for authorizing the use of potassium iodide (M).

Extent of Play Assessing conditions and implementing appropriate protective measures will be performed

-through an interface among the CR Simulator, Technical Support Center, Security, and EOF emergency response organizations. In conjunction with off-site agencies, the staff will monitor and authorize protective measures for site access, contamination control, and exposure control.

Extent of Evaluation.

This objective will be evaluated. The evaluation will include participant self-evaluation.

10 As appropriate, demonstrate the ability of Health Physics and Chemistry to conduct monitoring activities, including exposure rate surveys, sample collection, and sample analysis.

Extent of Play As required, radiological monitoring, sampling and analysis for in-plant, on-site and/or off-site activities will be initiated in accordance with EPTP-ENV-04 series and other appropriate plant procedures. Sampling activities will be requested as appropriate for scenario events.

As appropriate, facility monitoring will be performed in accordance with EPEP-ENV-04 series procedures.

84

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station Extent of Evaluation This objective will be evaluated, including participant self-evaluation.

85

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station I

11. Demonstrate the ability to effectively activate the emergency response facilities and associated. emergency response processes. 3 Extent of Play Activation of facilities and emergency response processes by the CRS, EOF, TSC, OSF, ICSC, SBF, and JIC will bee.performed in accordance with the appropriate procedures. As appropriate, activation of emergency response processes will be performed by Security, TSC, EOF, and JIC staffs. 5 Extent of Evaluation This objective will be evaluated, including participant self-evaluation. U

12. Demonstrate that a layout and equipment support emergency response activities in each facility.

3 Extent of Play .

The CR Simulator, EOF, TSC, OSF, ICSC, JIC, SBF, and Security staffs will perform their required tasks by using the facilities and associated equipment Extent of Evaluation This objective will be evaluated, including participant self-evaluation. 3

13. Demonstrate the ability to establish and maintain effective communications. Extent of Play I The CR Simulator, EOF, TSC, OSF, ICSC, JIC, SBF, and Security staffs will communicate using the appropriate equipment and proper communications techniques.

Use of backup communications systems will be performed only if primary communications Extent of Evaluation This objective will be evaluated, including participant self-evaluation. 3

14. Demonstrate the ability to maintain command and control of the emergency response effort.I Extent of Play 86

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station The Emergency Director will perform initial on-site emergency response command and control from the CR Simulator. The Emergency. Director will demonstrate command and control of the emergency from the Control Room Simulator and the TSC. The OSF

'Coordinator will demonstrate command and control of the OSF. The Emergency Response Manager will demonstrate command and control of the emergency response effort' associated with the EOF upon activation of that facility. The Corporate Response Manager will demonstrate command and control of the emergency response effort associated with the ICSC upon activation of that facility.

87

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station The Emergency Director will ensure personnel withinthe Protected Area are informed of emergency event status. If announcements are made, they should be preceded and terminated with the phrase: "This is a drill."

The OSF Coordinator will ensure OSF staff conducts accountability and performs damage control functions in accordance with procedure.

The CR Simulator, TSC, and EOF staffs will transfer appropriate command and control functions.

a The CR Simulator functions that transfer to the TSC include:

(1) Notifications to the state, local governments, and NRC.

(2) Developing and transmitting PARs to the state.

(3) Determining the emergency classification.

(4) Authorizing emergency exposures.

b The TSC functions that will transfer to the EOF are:

(1) Notifications to the state and local governments and to the NRC via the Health Physics Network.

(2) Developing and transmitting PARs to the state.

Extent of Evaluation This objective will be evaluated, including participant self-evaluation.

15. Demonstrate the ability to coordinate preparation, review and release of timely and accurate information to the public.

Extent of Play The ICSC and JIC staffs will coordinate, develop, and Issue press releases. As appropriate, the EOF will review press releases for technical accuracy.

The Corporate External Affairs Manager will be cognizant of all press releases and make them available to the media in the JIC following ICSC activation.

Extent of Evaluation This objective will be evaluated, including participant self-evaluation.

16. Demonstrate the ability to establish and operate rumor control, functions. Extent of Play Public Affairs will establish an emergency hotline. Questions requiring response will be called in to the Virginia Call Center.

88

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/lmprovement Plan Kewaunee Power Station Extent of Evaluation This objective will be evaluated, including participant self-evaluation.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station

17. Demonstrate the ability to provide basic life support and to package and transport a contaminated injured person to an off-site medical facility.

Extent of Play This objective will not be demonstrated.

Extent of Evaluation This objective will not be performed or evaluated during this exercise.

18. Demonstrate the ability to respond to, control and mitigate the consequences of a fire. Extent of Play This objective will not be, demonstrated.

Extent of Evaluation This objective will not be performed or evaluated during this exercise.

D Demonstrate the ability to establish a Recovery Organization and to develop a

- Recovery Plan.

Extent of Play This objective will not be demonstrated.

Extent of Evaluation This objective will not be performed or evaluated during this exercise.

20. Demonstrate the ability to effectively coordinate and conduct an exercise. Extent of Play The exercise controllers, evaluators and phone cell will initiate and control the exercise in accordance with the exercise manual and supporting material.

Extent of Evaluation This objective will be evaluated, including participant self-evaluation.

21. Demonstrate the ability to conduct a self-critique and to identify areas for improvement.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station Extent of Play The CR Simulator, EOF, TSC, OSF, ICSC, JIC, SBF, and Security will conduct a self-critique to identify weaknesses and improvement items.

Extent of Evaluation This objective will be evaluated, including participant self-evaluation.

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' Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Kewaunee Power Station I

The following is a summary of the anticipated PI Opportunities to be evaluated during the i

events of the scenario:

Note: Anticipated classifications for this exercise are based on conditions that were established I

through control room simulator development activities. It should be noted that although these conditions were verified to be reproducible, variables exist that may alter the expected simulated plant conditions resulting in a classification different than anticipated by the scenario. If this I

situation occurs, it will be evaluated during the critique process to determine if the unanticipated classification was valid for simulated plant conditions and whether it will be included with DEP PI statistics. I Note: The Shift Manager or Emergency Director may, at any time, classify events based on judgment per the EAL Matrixes. If existing conditions require classification under a specific EAL then the classification should accordingly.

Opportunity Recognition and Declaration Inhal Notification Tota I Opportunities I Alert Declaration EAL SA2.1 2 I SAE Declaration EAL SS1.1 1 2 GE Declaration PAR Declaration with GE EAL FG1 1 2

2 I Total ]_48 I

1 I

I I

92 1

I

Unclassified Radiological Emergency Preparedness Program (REP)

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SUMMARY

SUMMARY

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