ML13037A382

Transmittal of Final Exercise Report for the August 7, 2012 Partial Plume Exposure Pathway Exercise of the Offsite Radiological Emergency Response Plans Site-Specific to the Brunswick Nuclear Plant

ML13037A382
Person / Time
Site:	Brunswick
Issue date:	12/28/2012
From:	May M US Dept of Homeland Security, Federal Emergency Management Agency
To:	Mccree V Region 2 Administrator
References
Download: ML13037A382 (62)

Text

309~3 Chamnblee-Tudkcr Reiad Admina. Georgia 30~341 December 28, 2012 Victor M. McCree Regional Administrator - RII US Nuclear Regulatory Commission One Marquis Tower 245 Peachtree Center Avenue, Suite 1200 Atlanta, Georgia 30303

Dear Mr. McCree:

Enclosed is a copy of the final after action report for the August 7, 2012, partial plume exposure pathway exercise of the offsite radiological emergency response plans site-specific to the Brunswick Nuclear Plant. This report addresses the evaluation of the plans and preparedness for the State of North Carolina and the affected risk counties of Brunswick and New Hanover. The Federal Emergency Management Agency Region IV staff prepared the final after action report. Copies of this report will be forwarded to the State of North Carolina, FEMA Headquarters and NRC Headquarters.

During the exercise no Deficiencies or Area's Requiring Corrective Action (ARCA) were noted.

Two previous ACRAs (08-10-5.b. I-A-02 and 08-10-5.b. 1-A-03) identified during the 2010 exercise concerning the Risk County PIO's in the Joint Information Center were resolved.

Officials and representatives from the State of North Carolina, Brunswick and New Hanover Counties, the Nuclear Regulatory Commission, FEMA, U.S. Coast Guard (USCG), National Weather Service (NWS) and Duke Energy as well as numerous volunteers participated in this exercise. Based on the results of this exercise and the review of the North Carolina Annual Letter of Certification for 2011, the offsite radiological emergency response plans and preparedness for the State of North Carolina and the affected local jurisdictions site-specific to the Brunswick Nuclear Plant can be implemented and are adequate to provide reasonable assurance that appropriate measures can be taken offsite to protect the health and safety of the public in the event of a radiological emergency at the site. The Title 44 CFR, Part 350, approval of the offsite radiological emergency response plans and preparedness' for the State of North Carolina offsite radiological emergency response plans and preparedness, site-specific to the Brunswick Nuclear Plant, granted on March 17, 1982 will remain in effect.

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Should you have any questions, please contact Conrad Burnside at 770/220-5486.

Major P. May Regional Administrator Enclosure cc: Ms. Vanessa E. Quinn, Branch Chief Federal Emergency Management Agency Headquarters Radiological Emergency Preparedness Branch - NP-TH-RP 1800 South Bell Street Arl~

Z Virginia 20598-3025 C Headquarters Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001

Brunswick Nuclear Plant After Action Report/

Improvement Plan Exercise Date - August 07, 2012 Radiological Emergency Preparedness (REP) Program

• FEMA Published December 20, 2012

Brunswick Nuclear Plant After Action Report/

Improvement Plan Exercise Date - August 07, 2012 Radiological Emergency Preparedness (REP) Program W90:FEMA Published September 1 , 2012

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After Action Report/Improvement Plan Brunswick Nuclear Plant Brunswick Nuclear Plant After Action Report/Improvement Plan Published September 10, 2012 Contents Executive Summary 3 Section 1: Exercise Overview 5 1.1 Exercise Details 5 1.2 Exercise Planning Team Leadership 5

.1.3 Participating Organizations 7 Section 2: Exercise Design Summary 10 2.1 Exercise Purpose and Design 10 2.2 Exercise Objectives, Capabilities and Activities 12 2.3 Scenario Summary 16 Section 3: Analysis of Capabilities 21 3.1 Exercise Evaluation and Results 21 3.2 Summary Results of Exercise Evaluation 21 3.3 Criteria Evaluation Summaries 23 3.3.1 North Carolina Jurisdictions 23 3.3.1.1 State of North Carolina 23 3.3.1.2 Emergency Operation Facility Brunswick 28 3.3.1.3 North Carolina Joint Information Center 29 3.3.1.4 Brunswick County 31 3.3.1.5 New Hanover County 37 Section 4: Conclusion 41 Appendix A: Exercise Timeline 42 Appendix B: Exercise Evaluators and Team Leaders 43 Appendix C: Acronyms and Abbreviations 44 Appendix D: Extent of Play Agreement 47 1

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After Action Report/Improvement Plan Brunswick Nuclear Plant EXECUTIVE

SUMMARY

On August 7, 2012, the Department of Homeland Security (DHS)/Federal Emergency Management Agency (FEMA) Region IV Radiological Emergency Preparedness (REP) Program staff evaluated a plume exposure pathway exercise in the EPZ for the Brunswick Nuclear Plant (BNP). BNP is operated by Duke Energy and is located in southeastern Brunswick County, North Carolina near the City of Southport. The 10-mile EPZ is divided into 13 emergency response planning zones and affects both the Counties of Brunswick and New Hanover.

FEMA's overall objective of the exercise was to assess the level of State and local preparedness in responding to a radiological emergency at BNP. The purpose of this report is to analyze exercise results, identify strengths to be maintained and built upon, identify potential areas for improvement, and support development of corrective actions.

This exercise was held in accordance with FEMA's policies and guidance concerning the exercise of State and local radiological emergency response plans (RERP) and procedures. The evaluation team conducted this exercise using Homeland Security Exercise and Evaluation Program (HSEEP) methodology. The previous Federal evaluated exercise was conducted on August 31, 2010. The qualifying emergency preparedness exercise was conducted August 17-19, 1981.

The evaluation of out of sequence (OOS) activities during the weeks of May 14 and July 16, 2012 are included in this report. The activities included: traffic control points; back up route alerting; protective actions for schools; reception and congregate care centers; emergency worker and equipment monitoring and decontamination; marine waterway warning; and a Medical Services Drill.

Officials and representatives from the State of North Carolina, Brunswick and New Hanover Counties, U.S. Coast Guard (USCG), National Weather Service (NWS) and Duke Energy as well as numerous volunteers participated in this exercise. These organizations demonstrated knowledge of their emergency response plans and procedures and successfully implemented them. During the exercise no deficiencies or Area's Requiring Corrective Action (ARCA) were noted. Two previous ACRAs (08-10-5.b. l-A-02 and 08-10-5.b. l-A-03) identified during the 2010 exercise concerning the Risk County PIO's in the Joint Information Center were resolved.

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I After Action Report/Improvement Plan Brunswick Nuclear Plant FEMA has provided an Improvement Plan (IP) to the State of North Carolina that details the Strengths and Areas for Improvement observed during the exercise. The IP was published under a separate cover and classified For Official Use Only (FOUO) in compliance with HSEEP standards.

FEMA wishes to acknowledge the efforts and hard work of the many individuals who participated in the success of this exercise. The professionalism and teamwork of the participants was evident throughout all the phases of the exercise.

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After Action Report/Improvement Plan Brunswick Nuclear Plant SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Brunswick Nuclear Plant Type of Exercise Plume Exercise Date August 07, 2012 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Kevin Keyes Evaluator Supervisor DHS/FEMA RIV North Section Chief 3003 Chamblee-Tucker Road Atlanta, Georgia, 30341 770-220-5378 kevin.keyes@dhs.gov Robert Spence Lead Evaluator DHS/FEMA RIV Brunswick Site Specialist 3003 Chamblee-Tucker Road 5

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Atlanta, Georgia, 30341 770-220-3177 robert.spence@dhs.gov I

Carolyn Freitag Lead Controller NC Department of Public Safety, Division of Emergency Management State Exercise Planner 1636 Gold Star Drive I Raleigh, North Carolina, 27607 919-825-2267 Carolyn.Freitag@ncdps.gov I

Brian Falconer Lead Controller NC Department of Public Safety, Division of Emergency Management State Exercise Officer 1636 Gold Star Drive Raleigh, North Carolina, 27607 919-825-2264 I Brian.Falconer@ncdps.gov I

Kent Crocker Exercise Planner I Duke Energy Supervisor Emergency Preparedness P.O. Box 10429 BNP 04 Southport, North Carolina, 28461 910-457-3165 Kent. Crocker@pgnmail.com 6

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After Action Report/Improvement Plan Brunswick Nuclear Plant Mike Kinney Scenario Developer Duke Energy Emergency Preparedness P.O. Box 10429 BNP 04 Southport, North Carolina, 28461 910-620-7266 Michael. Kinney@pgnmail.com Heather Heigl Exercise Planner Brunswick County Emergency Services Emergency Management Planner PO Box 249 Bolivia, North Carolina, 28422 910-253-2562 hheigl@brunswickes.com Steven Still Exercise Planner New Hanover County Emergency Management Senior Emergency Management Specialist 230 Government Center Drive, Ste. 115 Wilmington, North Carolina, 28403 910-798-6907 SStill@nhcgov.com 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Brunswick Nuclear Plant exercise:

State Jurisdictions 7

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After Action Report/Improvement Plan Brunswick Nuclear Plant Department of Public Safety (DPS), Division of Emergency Management Department of Health and Human Services, Division of Health Service Regulation, Radiation Protection Section (RPS)

Department of Environment and Natural Resources (DENR), Division of Marine Fisheries, Marine Patrol l Department of Environment and Natural Resources (DENR), Wildlife Resources Commission, Law Enforcement Department of Public Safety (DPS), State Highway Patrol Risk Jurisdictions Brunswick County Emergency Services Brunswick County Emergency Medical Services (EMS)

• Brunswick County Sheriffs Office I Brunswick County Health Department Brunswick County Board of Commissioners, Administration, Public Information Office Brunswick County Schools Brunswick County Social Services Southport Police Department Shallotte Fire Department Boiling Spring Lakes Fire Department New Hanover County Emergency Management New Hanover County Public Safety Communications Center (911)

New Hanover County Public Information Office New Hanover County Fire Rescue Department New Hanover County Sheriffs Office New Hanover County Health Department New Hanover County Department of Social Services City of Wilmington Police Department n City of Wilmington Fire Department Town of Kure Beach Private Organizations American Red Cross (ARC), Cape Fear Chapter The Salvation Army i Duke Energy I

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After Action Report/Improvement Plan Brunswick Nuclear Plant Dosher Memorial Hospital New Hanover Regional Medical Center Radio Amateur Civil Emergency Services (RACES)/ Amateur Radio Emergency Services (ARES)

Federal Jurisdictions Department of Homeland Security, FEMA RIV Nuclear Regulatory Commission, Region II Department of Homeland Security, U.S. Coast Guard, Sector North Carolina Department of Commerce, National Oceanic and Atmospheric Administration (NOAA), National Weather Service Wilmington Department of the Defense, Military Ocean Terminal Sunny Point (MOTSU) 9

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SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise Purpose and Design DHS/FEMA administers the REP Program pursuant to the regulations found in Title 44 Code of Federal Regulation (CFR) parts 350, 351 and 352. 44 CFR 350 codifies 16 planning standards that form the basis for radiological emergency response planning for licensee, State, tribal and local governments impacted by the EPZs established for each nuclear power plant site in the United States. 44 CFR 350 sets forth the mechanisms for the formal review and approval of State, Tribal and local government RERPs and procedures by DHS/FEMA. On March 15, 1981 the State of North Carolina formally submitted the RERP for the BNP to FEMA Region IV.

Formal approval of the RERP was granted by FEMA on March 17, 1982 in accordance with 44 CFR 350.

I One of the REP program cornerstones established by these regulations is the biennial exercise of offsite response capabilities. During these exercises State, Tribal and local governments demonstrate their abilities to implement their plans and procedures to protect the health and safety of the public in the event of a radiological emergency at the nuclear plant. A REP exercise was evaluated on August 7, 2012, and included evaluations of the out of sequence activities during the weeks of May 14 and July 16, 2012. The results of this exercise together with review of the RERPs and procedures and verification of the periodic requirements set forth in NUREG-0654/FEMA-REP- 1 through the Annual Letter of Certification and staff assistance visit enables FEMA to provide a statement with the transmission of this final After Action Report/ Improvement Plan (AAR/IP) to the NRC that State, Tribal and local plans and preparedness are (1) adequate to protect the health and safety of the public living in the vicinity of the nuclear power facility by providing reasonable assurance that appropriate protective measures can be taken offsite in the event of a radiological emergency; and (2) they are capable of being implemented. 3 The purpose of this exercise was to assess the level of State and local preparedness in responding to a radiological emergency at the BNP. The overall goal was to affirm that reasonable assurance exists and that the health and safety of the public can be protected, through successful demonstration of all the Emergency Preparedness Evaluation Areas - elements and sub-elements

- that are required to be demonstrated, as specified by the REP Program Manual (April 2012) and the approved Extent of Play Agreement (EOPA). This partial participation exercise was held in accordance with FEMA's policies and guidance concerning the exercise of State and local 10 I

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After Action Report/Improvement Plan Brunswick Nuclear Plant radiological emergency response plans and procedures.

The Design incorporated capabilities-based planning which allows the exercise planning teams to develop exercise objectives and observe exercise outcomes through a framework of specific action items that are derived from the HSEEP Target Capabilities List (TCL). The REP Assessment Areas, Sub-elements, and Demonstration Criteria have been aligned with HSEEP target capabilities, activities, and tasks. FEMA Region IV has identified a set of Target Capabilities correlating to the REP Demonstration Criteria so that regional REP exercise evaluations using HSEEP exercise documents may occur.

The HSEEP evaluation methodology is an analytical process used to assess the demonstration of capabilities during exercises. According to this methodology, exercise evaluation incorporates three distinct levels of analysis: task-level analysis, activity-level analysis, and capability-level analysis.

1. Task-Level Analysis Tasks are specific, discrete actions that individuals or groups must successfully perform or address during entities in analyzing shortcomings or strengths related to these individual actions.

This analysis can also help entities target plans, equipment, and training resources to improve specific task performance.

Each task is accompanied by performance measures designed to assist an exercise evaluator in assessing relevant individual or group performance pertaining to the task.

2. Activity-Level Analysis Activities are groups of similar tasks that, when carried out according to plans and procedures, allow an entity to demonstrate an associated capability from the TLC and the Universal Task List.

When conducting activity-level analysis, exercise evaluators seek to determine whether all activities have been performed successfully and in accordance with plans, policies, procedures and agreements. Through this analysis, exercise evaluators gain valuable insight into broad thematic successes or challenges in performing related tasks.

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After Action Report/Improvement Plan Brunswick Nuclear Plant Awareness of such themes is key to improving the performance of individual tasks, and thus demonstrating the associated capability. Such analysis is also vital in assessing the effectiveness with which individuals worked together at the discipline or organizational level, and how well team members communicated across organizational boundaries during an exercise.

3. Capability-Level Analysis Capabilities are combinations of elements (e.g., personnel, planning, organization and leadership, equipment and systems, training, exerciseg, assessments and corrective actions) that provide the means to achieve a measurable outcome.

Capability-level analysis involves assessing an entity's ability to demonstrate its priority capabilities necessary to successfully prevent, protect against, respond to, or recover from the threat or hazard simulated in the exercise scenario. When conducting capability-level analysis, exercise evaluators examine whether an entity's performance of specific tasks and activities was sufficient to demonstrate the desired capability outcome. Capability-level analysis is designed to assist managers and executives in developing operating plans and budgets, communicating with political officials, setting long-range training and planning goals, and developing interagency and/or inter-jurisdictional agreements.

I 2.2 Exercise Objectives, Capabilities and Activities The objectives developed to meet the REP Program requirements and based on the negotiated I Extent of Play Agreement are as follows (these objectives encompass the REP Program evaluation area criteria):

Objective 1: Demonstrate the ability to provide Emergency Operations Center management including Direction and Control through the Counties and State Emergency Operations Centers Multi-agency Coordination Center System (MACCS).

Objective 2: Demonstrate the ability to provide protective action decision-making for State and County emergency workers and public through exercise play and discussions of plans and i procedures.

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After Action Report/Improvement Plan Brunswick Nuclear Plant Objective 3: Demonstrate the ability to implement protective actions for State and Counties' emergency workers and public through exercise play and discussions of plans and procedures.

Objective 4: Demonstrate the ability to activate the Prompt Alert and Notification System utilizing the Primary Notification System/Emergency Alert System (PNS/EAS)through exercise play.

Objective 5: Demonstrate the effectiveness of plans, policies and procedures in the Joint Information Center for joint (public and private sectors) emergency information communications.

Objective 6: Demonstrate the ability to conduct independent dose assessment, management of field teams, and mobile or fixed laboratory analysis in response to a radiological release.

Capabilities-based planning allows for exercise planning teams to develop exercise objectives and observe exercise outcomes through a framework of specific action items that are derived from the HSEEP TCL. The REP Assessment Areas, Sub-elements, and Demonstration Criteria have been aligned with HSEEP target capabilities, activities, and tasks. FEMA Region IV has identified a set of Target Capabilities correlating to the REP Demonstration Criteria so that regional REP exercise evaluations using HSEEP exercise documents may occur. These capabilities are listed below with the applicable criterion and activities identified in Appendix D:

EOPA.

1. Emergency Operations Center (EOC) Management: Emergency Operations Center (EOC) management is the capability to provide multi-agency coordination (MAC) for incident management by activating and operating an EOC for a pre-planned or no-notice event. EOC management includes: EOC activation, notification, staffing, and deactivation; management, direction, control, and coordination of response and recovery activities; coordination of efforts among neighboring governments at each level and among local, regional, State, and Federal EOCs; coordination of public information and warning; and maintenance of the information and communication necessary for coordinating response and recovery activities.

2. Emergency Public Information and Warning: Develop, coordinate, and disseminate accurate alerts and emergency information to the media and the public prior to an impending emergency and activate warning systems to-notify those most at-risk in the event of an emergency. By 13

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After Action Report/Improvement Plan Brunswick Nuclear Plant refining its ability to disseminate accurate, consistent, timely, and easy-to understand information about emergency response and recovery processes, a jurisdiction can contribute to the well-being of the community during and after an emergency.

3. Citizen Evacuation and Shelter in Place (SIP): Citizen Evacuation and SIP is the capability I to prepare for, ensure communication of, and immediately execute the safe and effective sheltering-in-place of an at-risk population (and companion animals), and/or the organized and managed evacuation of the at-risk population (and companion animals) to areas of safe refuge in response to a potentially or actually dangerous environment. In addition, this capability involves the safe reentry of the population where feasible.

4. Public Safety and Security Response: Public Safety and Security Response is the capability I to reduce the impact and consequences of an incident or major event by securing the affected area, including crime/incident scene preservation issues as appropriate, safely diverting the public from hazards, providing security support to other response operations and properties, and sustaining operations from response through recovery. Public Safety and Security Response requires coordination among officials from law enforcement (LE), fire, and emergency medical services (EMS).

5. Hazardous Materials Response and Decontamination(HAZMAT): HAZMAT Response and Decontamination is the capability to assess and manage the consequences either of a hazardous materials release, accidental or as part of a terrorist attack. It includes testing and identifying all likely hazardous substances onsite; ensuring that responders have protective clothing and equipment; conducting rescue operations to remove affected victims from the hazardous environment; conducting geographical survey searches of suspected sources or contamination spreads and establishing isolation perimeters; mitigating the effects of hazardous materials, decontaminating on-site victims, responders, and equipment; coordinating off-site I

decontamination with relevant agencies, and notifying environmental, health, and law enforcement agencies having jurisdiction for the incident to begin implementation of their standard evidence collection and investigation procedures.

6. Mass Care: Mass Care is the capability to provide immediate shelter, feeding centers, basic first aid, bulk distribution of needed items, and related services to persons affected by a large-I scale incident, including special needs populations. Special needs populations include individuals with physical or mental disabilities who require medical attention or personal care beyond basic 14

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After Action Report/Improvement Plan Brunswick Nuclear Plant first aid. Other special-needs populations include non-English speaking populations that may need to have information presented in other languages. The mass care capability also provides for pet care/handling through local government and appropriate animal-related organizations.

Mass care is usually performed by nongovernmental organizations (NGOs), such as the American Red Cross, or by local government-sponsored volunteer efforts, such as Citizen Corps.

Special-needs populations are generally the responsibility of local government, with medical needs addressed by the medical community and/or its alternate care facilities. State and Federal entities also play a role in public and environmental health by ensuring safe conditions, safe food, potable water, sanitation, clean air, etc.

7. Public Health Laboratory Testing: The Public Health Laboratory Testing capability is the ongoing surveillance, rapid detection, confirmatory testing, data reporting, investigative support, and laboratory networking to address potential exposure, or known exposure, to all-hazards which include chemical, radiochemical, and biological agents in all matrices including clinical specimens, food and environmental samples, (e.g., water, air, soil). All-hazard threats include those deliberately released with criminal intent, as well as those that may be present as a result of unintentional or natural occurrences.

Additionally, each objective is linked to one or more capabilities. Based upon the identified exercise objectives, the evaluated capabilities were:

Objective 1: Capability - EOC Management Objective 2: Capability - EOC Management Capability - Emergency Public Information and Warning Objective 3: Capability - EOC Management Capability - Emergency Public Safety and Security Response Capability - Citizen Evacuation and Shelter-in-Place Capability - Hazardous Materials Response and Decontamination Capability - Mass Care (Sheltering, Feeding, Related Services)

Objective 4: Capability - Emergency Public Information and Warning Objective 5: Capability - Emergency Public Information and Warning 15

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After Action Report/Improvement Plan Brunswick Nuclear Plant Objective 6: Capability - Hazardous Materials Response and Decontamination 2.3 Scenario Summary The exercise was conducted with the Brunswick Plant Simulator in the interactive mode. Times given are approximate and were for planning purposes only. Actual times did vary due to dynamic response of the simulator.

Initial Conditions U The drill begins with both units at 100% power. I Unit I Initial Plant Conditions:

The plant is at 100% power on day 380 of a continuous run. There is no work activities or planned events affecting generation in the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. No significant Limiting Condition of Operation (LCO) items at this time. Risk condition Green.

Equipment Out of Service: None I

Protected Equipment: None Unit 2 Initial Plant Conditions: U The plant is at 100% power on day 380 of a continuous run. There are no work activities or I planned events affecting generation in the next 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. No significant LCO items at this time.

Risk condition Green.

Equipment Out of Service:

2-MUD-2A-XFER-PMP under clearance for routine lube check.

Protected Equipment: I 2-MUD-2B-XFER-PMP 2-MUD-2C-XFER-PMP 16

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After Action Report/Improvement Plan Brunswick Nuclear Plant Meteorological Information:

Forecast: Winds are out of the north, north east and steady. No precipitation is anticipated for the next few days. Wind Direction is from 10-20 degrees at the start of the exercise.

Wind Speed 2-3 mph Temperature High: 90 Low: 70 Conditions at time of release:

Wind Direction from: 45 degrees Wind Speed: 4 mph Temperature: 86 degrees Stability Class: B Time Event:

0730: The initial plant conditions and shift briefing will be provided to the CR crew. During this time, the crew will be informed of equipment out of service and other irregularities.

0800: Crew takes watch:

0810: Annunciator 2-UA-22 3-2, Diesel Generator (DG)4 FUEL TANK LEVEL LOW alarm in Control Room. Investigation finds failed level switch FO-LS-2288.

0820: Annunciator 2-UA-13 4-10, Startup Auxiliary Transformer (SAT) WINDING Y GRD CURRENT, will alarm. Operators dispatched to investigate Balance of Plant (BOP) buses 2C and 2D will find no flags or abnormal indications. If sent to check the SAT, no abnormal indications will be evident. I&C will determine that the ground alarm is valid and that the ground will need to be located. Ground identification will include having to de-energize the SAT non-segregated bus.

0820: Initiating Condition for UNUSUAL EVENT The ground conditions previously alarmed for the SAT worsen. The crew will receive 17

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After Action Report/Improvement Plan Brunswick Nuclear Plant annunciator 2-UA-19 2-9, SAT DIFF RELAY TRIP. This occurs concurrently with a trip and lockout of the SAT and a Unit 2 Transformer Bus lockout. This is a Loss of Off-Site Power to Unit 2. All equipment will respond as expected. Diesel Generator 3 (DG-3) reenergizes Bus E3. Diesel Generator 4 (DG-4) re-energized Bus E4.

Entry into Abnormal Operation Procedure (AOP)-36.1, Loss of Any 41 60v Buses Or 480v E-Buses.

I 0840: UNUSUAL EVENT declared SEC declares an UNUSUAL EVENT based on EAL SU 1.1: i Loss of all offsite AC power to Emergency 4 KV Buses El (E3) and E2(E4) for >15 min. i NOTE: SEC may decide to activate Emergency Facilities.

0915: Initiating Condition for ALERT DG-4 will trip due to low lube oil pressure resulting from an oil leak.

0925: ALERT declared I

SEC declares an ALERT based on EAL SA 1.1:

AC power capability to Emergency 4 KV Buses E1 (E3) and E2(E4) reduced to a single power source for > 15 minutes such that any additional single failure would result in loss of all AC power to emergency buses.

0950: Emergency Facilities activated (if not activated at Unusual Event) Maintenance personnel responding to the Diesel Generator #4 oil leak will determine that the leak can be repaired and the oil system refilled within 5 to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

1010: Initiating Condition for Site Area Emergency DG-3 trips due to a sensed differential over-current condition. Local investigation will reveal a tripped Device 87 and a tripped Device 86DP lockout relay.

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After Action Report/Improvement Plan Brunswick Nuclear Plant Operations will not be able to execute a cross-tie of Bus El to Bus E3 until I&C has determined that the E-Bus is not faulted. DG-3 will remain inoperable for the remainder of the exercise.

Entry into OAOP-36.2, Station blackout. Crew begins an immediate 100°F/hr cool down of UNIT

2. Unit 1 preparing to go to hot shutdown.

1020: Site Area Emergency declared SEC declares a SITE AREA EMERGENCY based on EAL SS 1. 1:

Loss of all offsite and all onsite AC power to Emergency 4 KV Buses El (E3) and E2 (E4) for >

15 minutes.

1025: Start Severe Accident Mitigation Alternatives (SAMA) Diesel Generators. 2-SAMADIESEL- 1 and 2-SAMA-DIESEL-2 are started to re-energize Battery Charges 2A- 1 /2A-2, and 2B-1 /2B-2 in accordance with AOP-36.2 As the crew executes AOP-36.2, all equipment with the exception of the High Pressure Injection Cooling (HPCI) will operate as designed. Reactor water level will lower toward Top of Active Fuel (TAF) due to boil off of available coolant inventory.

1040: Sirens in 10 mile EPZ sounding. Siren NHO1 fails to sound.

1050: Initiating Condition for General Emergency UAT feeder to Busses 2C and 2D remains unavailable.

Maintenance reports parts unavailable for restoration of DG-3. Administrative and Logistics Manager (ALM) and Materials and Contract Services (M&CS) attempting to find source for parts.

Maintenance reports work continuing on DG-4, but have been unable to improve on original projection for repair and refilling of the lube oil system.

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After Action Report/Improvement Plan Brunswick Nuclear Plant 1100: General Emergency declared SEC declares a GENERAL EMERGENCY based on EAL SG 1.1:

Loss of all/ offsite and all/ onsite AC power to Emergency 4 KV Buses El(E3) and E2(E4) AND EITHER: Re-energizalion of at least one emergency bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely OR RPV level cannot be restored and maintained > TAF or cannot be determined.

PAR: Evacuate: ABCDE i Shelter: FGHJKLMN KI: No Based on wind from 45 degrees 1115: As reactor water level lowers < TAF, fuel damage will begin to take place. The level of fuel damage will progressively increase as level continues to lower.

1130: A Reactor Core Isolation Cooling (RCIC) steam line break occurs. When the crew or personnel in the reactor building identify the RCIC steam leak, isolation of the system from the I control board will be attempted but unsuccessful.

I This will provide a fission product release path to the environment via the Main Stack.

The Drywell High Range Radiation Monitors indicated radiation levels exceeding 20,000 R/HR.

1230: Environmental Monitoring Team confirms off site dose rates.

1300: When all field actions have been completed and actions have been completed which have allowed evaluation for the required objectives, the exercise will be terminated.

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After Action Report/Improvement Plan Brunswick Nuclear Plant SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results This section contains the results and findings of the evaluation of all jurisdictions and functional entities that participated in the August 7, 2012 partial participation plume phase exercise and OOS activities. Exercise criteria are listed by number and the demonstration status of those criteria are indicated by the use of the following terms:

" Met (No Deficiency or ARCA(s) assessed and no unresolved ARCA(s) from prior exercise)

" ARCA(s) assessed or unresolved ARCA(s) from previous exercises

• Deficiency assessed "Plan Issues

• Not Demonstrated 3.2 Summary Results of Exercise Evaluation See section 3.3 Criteria Evaluation Summaries for the associated HSEEP Capability Summaries for each jurisdiction.

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Table 3.1 - Summary of Exercise Evaluation DATE: 2012-08-07 I

SITE: Brunswick Nuclear Plant, NC U M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not Demonstrated U 0 z iu U0 0 U U =

z 9Q z I Emergency Operations Management Alert and Mobilization Facilities Direction and Control lal IbN Icl M

M M

M *M M

M M

I Communications Equipment Equipment and Supplies to Support Operations Protective Action Decision Making ldl lel M

M M M

M M

M I Emergency Worker Exposure Control 2al M M M Dose Assessment & PARs & PADs for the Emergency Event Dose Assessment & PARs & PADs for the Emergency Event 2bl 2b2 M

M M M M

M M

I PADs for the Protection of persons with disabilities and access/functional needs 2c] M M Radiological Assessment and Decision-making for the Ingestion Exposure Pathway Radiological Assessment & Decision-making Concerning Post-Plume Phase Relocation, Reentry, and Return 2dl 2e] I Protective Action Implementation Implementation of Emergency Worker Exposure Control Implementation of KI Decision for Institutionalized Individuals and the Public 3al 3bl M M M M

M M

I Implementation of Protective Actions for persons with disabilities and access/functional needs 3cl M M Implementation of Protective Actions for persons with disabilities and access/functional needs Implementation of Traffic and Access Control 3c2 3d] M M

M M I

Implementation of Traffic and Access Control 3d2 M M M Implementation of Ingestion Pathway Decisions Implementation of Ingestion Pathway Decisions Implementation of Post-Plume Phase Relocation, Reentry, and Return Decisions 3el 3e2 3fl I

Field Measurement and Analysis RESERVED Plume Phase Field Measurement and Analyses 4al 4a2 M I

Plume Phase Field Measurement and Analyses 4a3 Post Plume Phase Field Measurements and Sampling Laboratory Operations 4b0 4c I I

Emergency Notification and Public Info Activation of the Prompt Alert and Notification System RESERVED Activation of the Prompt Alert and Notification System 5al 5a2 M M M I

5a3 M M M Activation of the Prompt Alert and Notification System Emergency Information and Instructions for the Public and the Media Support Operations/Facilities 5a4 5bt M M M M I Monitoring, Decontamination, and Registration of Evacuees I

6al M Monitoring and Decontamination of Emergency Workers and their Equipment and Vehicles 6bl M Temporary Care of Evacuees 6c1 M Transportation and Treatment of Contaminated Injured Individuals 6dI M I

22

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant 3.3 Criteria Evaluation Summaries 3.3.1 North Carolina Jurisdictions 3.3.1.1 State of North Carolina Emergency Operations Management Capability Summary: State Emergency Operations Center(SEOC)

The North Carolina State Emergency Response Team (SERT) operating from the SEOC effectively demonstrated the capability of the SERT to respond to a radiological incident involving the BNP.

The SEOC is a new facility and therefore required an evaluation for this exercise. The SEOC is co-located with NC State Highway Patrol (NCSHP), NC Department of Transportation (NCDOT) and the NC Army National Guard (NCANG). The 43,000 square foot SEOC consisted of a 3,275 square foot Situation Room, Command Room, and several surrounding break out rooms to accommodate the various Emergency Support Functions (ESFs). Backup electrical power for the entire building is provided by a generator that is owned and maintained by the NCANG. SPARTA is NC version of WebEOC and is the primary means of communication. Backup communications consisted of the SSS, Decision Line, satellite telephone, 800 MHz radios, and facismile. There were no communication failures during the exercise. There is more than adequate space, furnishings, lighting, cafeteria, ventilation and restrooms located throughout the structure to support 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> operations.

The SERT Leader efficiently directed his staff throughout the exercise. The SERT members were knowledgeable of their responsibilities and successfully coordinated necessary actions with the risk counties of Brunswick and New Hanover, the BNP emergency operations facility (EOF),

the NCEM Eastern Branch Office, and other agencies throughout the exercise. Periodic status briefings and Decision Line conference calls fully involved the various agencies and professionally addressed the concerns and recommendations of the county emergency management directors while achieving concurrence on key decisions. All personnel were knowledgeable of their responsibilities and successfully performed their assigned actions. The new SEOC facility and equipment enhance and complement their dedication and desire to ensure public safety.

23

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant Emergency Operations Management Capability Summary: Eastern Branch Office The primary operating location for the SERT is the SEOC in Raleigh. SERT activity may also be i conducted through Regional Coordination Centers (RCC) located in each of the three North Carolina Emergency Management (NCEM) Branch Offices. The Eastern Branch Office (EBO) located at 3802 NC Highway 58 North, Suite B., NC successfully demonstrated the capability to alert, notify, and mobilize emergency response personnel and manage resources in response to an incident at Brunswick Nuclear Plant (BNP).

In accordance with the extent of play the RCC Director/EBO Manager, Planning Chief, Logistic I Chief/Mission Area Coordinator (MAC), administrative support, and planner where prepositioned at the EBO. Area Coordinators were alert and mobilized real time and tasked to 3 report to Brunswick and New Hanover Counties, the Joint Information Center (JIC) and the EBO.

During the exercise the EBO Manager demonstrated the ability to provide direction and control of the staff and the emergency, by providing plant status updates as situational awareness briefings and asking the staff for position specific updates.

Redundant communications systems and equipment were tested and employed during the exercise. The Selected Signal System (SSS) serves as primary communications for an emergency at the BPN. SPARTA, commercial telephone lines, 800 MHz radios (Viper), cell phones, fax, laptop computers were utilized during the exercise. The Radio Emergency Civil Emergency Services (RACES) and Amateur Radio Emergency Services (ARES) radio operators were not available for this exercise, but the equipment was available to provide additional communications capability, if necessary. 3 The EBO is equipped with computers, printers, copiers/fax/scanners, flat screens monitors, i overhead projector, a SMART Board and enough audio visual equipment to support an emergency at BPN, also observed were position specific Standard Operating Guides (SOG) for all the EBO positions.

24

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant Emergency Public Information & Warning Capability Summary: State Emergency Operations Center The North Carolina SERT, operating out of the SEOC efficaciously demonstrated the ability to alert the public of an impending emergency and provided accurate, timely, and easy to understand information and instructions relating to that emergency. The SERT coordinated the sounding of the alert siren system within the 10 mile EPZ of the BNP with the risk Counties of Brunswick and New Hanover. The alert sirens were sounded on two separate occasions during the exercise once when the BNP declared an emergency classification level (ECL) of Site Area Emergency (SAE)and once when the plant status had degraded and caused the BNP to declare an ECL of General Emergency (GE). The sounding of the sirens were immediately followed by transmission of prescript emergency alert system (EAS) messages sent over local radio and television stations by utilizing EMnet, a network software using TCP/IP protocol. This alert and notification system was backed up by a separate alert and notification system, the National Oceanic and Atmospheric Administration Radio (NOAA) system. This system broadcasts a tone alert and information and instructional messages over the NOAA radio.

The EAS messages used in this exercise were different than the preapproved messages in the State of North Carolina Radiological Response Plan. The exercise messages lacked the required information as required by FEMA. Both messages were missing the official with authority for providing the alert signal and instructional message. However, the official messages in EMNet and the plan do contain the FEMA required data. The SERT provided eleven news releases which were clear, concise and consistent with the protective action decisions (PADs) made.

Emergency Public Information and Warning Capability Summary: Waterway Warning The demonstration for Alert, Notification and Evacuation of the Atlantic Ocean, Intra-Coastal Waterway, and the Cape Fear River, as well as other sounds, bays and tributaries within a ten mile radius of the BNP was performed by representatives of the United States Coast Guard (USCG); North Carolina Wildlife Resources Commission (NCWRC), Division of Enforcement; and North Carolina Marine Patrol, Enforcement Section. The demonstration was done Out of Sequence (OOS) and in conjunction with a command table top exercise. Brunswick County Emergency Services (BCES) established a Mobile Command Post in the parking lot of the BNP Visitor's Center to support the flow of communications among the different agencies and their 25

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Brunswick Nuclear Plant boats. All personnel were well versed in their mission requirements and fully demonstrated the ability to perform the roles assigned to them. The level of professionalism and mutual support displayed by the officers involved was commendable.

I Emergency Public Information & Warning Capability Summary: National Weather Service (NWS)

The NWS staff demonstrated the capability to coordinate, verify and disseminate EAS messages 3 to the public and activate warning systems in the event of an emergency. Emergency notification messages were received and authenticated prior to being transmitted to user specified locations using Advanced Weather Interactive Processing System (AWIPS) Format Launcher software and tone alert radio. The staff discussed redundant transmission, communication and power generation systems in place in the event of a power failure, in addition to authentication 3 procedures after receipt of Emergency notification messages.

I NWS staff received two emergency notification messages during the exercise. Message #1 was received at 1059 indicating a SAE ECL. Message #4, declaring a GE, evacuating Zones A, B, C, D, and E, and SIP for zones F, G, H, J, K, L, M, and N, was received at 1400. Both EAS I messages were prepared as they would be in an actual emergency with only the transmission being simulated.

Hazmat Response and Decontamination Capability Summary: North Carolina Dose Assessment North Carolina Department of Health and Human Services (DHHS), Division of Health Services I Regulation, Radiation Protection Section (RPS) dose assessment personnel assigned to the SERT in the SEOC, were effectively alerted and notified, via facsimile, telephone, and WebEOC in a timely manner by the State Warning Point (SWP). Dose assessment personnel were pre-positioned in the SEOC at the commencement of the exercise per the EOPA. 3 The dose assessment personnel occupied adequate facilities, possessed equipment, maps, displays, and other supplies sufficient to support emergency operations. Each position was equipped with a computer and appropriate software for their position; e.g. Emergency Response data System (ERDS), WebEOC, Radiological Assessment System for Consequence 3 26

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant Analysis(RASCAL). The dose assessment staff successfully established, maintained, and managed primary and auxiliary communications capabilities between Brunswick Nuclear Plant (BNP) and dose assessment personnel. Primary communications systems included internet-based systems such as WebEOC and ERDS, facsimile, landline telephone, cellular telephone, and radio.

The RPS Director demonstrated effective direction and control over the dose assessment group composed of an RPS-SERT Coordinator, Dose Assessment Leader, Dose Assessment Assistant, SERT Power Plant Liaison, Field Team Coordinator, SERT Communicator, and Staff Assistant.

The RPS-SERT Coordinator effectively coordinated all functions within the dose assessment group, including field team management, dose projections, and requests for Federal and Southern Mutual Radiological Assistance Plan (SMRAP) radiological assistance.

The SERT Power Plant Liaison worked closely with the Utility and NRC Liaisons, obtained current plant status from the EOF Liaison, and exerted relentless effort to obtain ERDS data that was initially not available.

The Dose Assessment Leader and Dose Assessment Assistant worked closely with the SERT Power Plant Liaison to obtain sufficient data to make dose projections. The EOF Liaison promptly provided BNP dose projections and other pertinent information to the dose assessment group via facsimile and landline telephone.

The RPS Director developed Protective Action Recommendations (PARs) for the general public considering meteorological data, field team radiological data, BNP dose projections, and RPS dose projections using RASCAL version 4.2 software. The RPS Director provided timely and appropriate PARs to the Governor's Authorized Representative (GAR) following the BNP ECL escalation to GE. The RPS Director used a decision-making process, considered relevant factors and appropriate coordination to ensure that an exposure control system, including the use of KI, was in place for emergency workers. Per procedure, the RPS Director, with the concurrence of the Public Health Director, recommended ingestion of KI by emergency workers when a field team detected elevated radiation levels beyond the boundary of BNP. All field monitoring data for the dose assessment evaluation was provided as described in RPS plans and procedures.

Public Safety and Security Response Capability Summary:

27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant Troopers of the North Carolina State Highway Patrol (NCSHP) successfully demonstrated the ability to establish traffic control points (TCPs) and security road blocks (SRBs) in the event of an emergency at the BNP. This evaluation was conducted out of sequence through interview and discussion. Interviews with the Troopers provided ample evidence that they were well prepared to perform this task. The Troopers carefully explained their notification procedures, dosimetry issue and use, and the differences between operating a TCP versus a SRB. Procedures are clearly in place to ensure personnel are able to provide assistance to evacuees and facilitate the evacuation process by maintaining a smooth traffic flow to designated reception centers. They were well trained on personal radiological protective measures and described how they would respond to impediments in traffic flow.

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

a. M ET: l.a.1, 1.b.1, 1.c.1, 1.d.l, 1.e.1, 2.a.1, 2.b.1, 2.b.2, 3.a.1, 3.d.I., 3.d.2, 4.a.2, 5.a.1, 5.a.3, 5.b. I.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.2 Emergency Operation Facility Brunswick Emergency Operations Management Capability Summary:

Representatives from the NCEM and RPS were dispatched to the onsite Emergency Operation Facility (EOF). These liaison positions were effectively staffed by knowledgeable individuals, who provided information to their counterparts at the SEOC and Brunswick and New Hanover Counties.

Information about the plant conditions was readily available and used. Plant key condition indicators were displayed on 3 large screens at the front of the EOF and the emergency response director held frequent briefings regarding their actions to solve the problems with the plant. The NCEM liaison was in direct communication with the SEOC and the counties both informing them of the changing situation at the plant and giving them advance notice of changes to the 28

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant ECL when they were announced in the EOF. The NCEM liaison also discussed actions with the counties and the state prior to the decision to implement them, such as water way warning and the closing of the State parks. She also gave status updates of the State and local activities during the EOF briefings. The RPS liaison in the EOF operations room obtained the information they needed and communicated with the SEOC.

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

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.3 North Carolina Joint Information Center Emergency Public Information & Warning Capability Summary:

Representatives from the State of North Carolina, Brunswick County and New Hanover County located at the Brunswick Nuclear Plant (BNP) Joint Information Center (JIC) successfully demonstrated the Emergency Public Information and Warning capability by providing emergency information and instructions to the media and public. The State and county representatives performed their roles in accordance with their published plans and procedures.

The BNP JIC is located at the Brunswick County Community College and is designed as the focal point for the distribution of news releases and presentation of press briefings by the utility and jurisdictions. BNP staff activated the JIC during the Alert Emergency Classification Level (ECL). For this exercise, in accordance with the EOPA, the Offsite Response Organizations (OROs) JIC staff and equipment were prepositioned and each responded after notification by their respected agencies. BNP's Company Spokesperson has the overall responsibility for the management of the JIC.

State and County JIC representatives confirmed that all news releases were prepared, coordinated and approved according to respective procedures. All releases conformed to protective action decisions and precautionary measures instituted by the jurisdictions. A total of 29

Unclassified i Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant 34 press releases were received, prepared and/or distributed from the JIC during the exercise.

Three media briefings were also conducted during the exercise. Prior to each briefing the spokespersons gathered to discuss and coordinate their message for the briefing. They discussed who would say what, and in which order the briefing would be conducted. The spokespersons answered all questions asked of them and were able to discuss what actions had been taken by their organizations.

The JIC was well equipped with redundant communications systems that included landline phones, facsimiles, laptop computers and internet connectivity at each of the work stations.

Additional communications were augmented by cellular phones, handheld 800 MHz radios, intranet WebEOC and ProgressNet, an operations and resource tracking data management system. The primary and backup communications systems were fully functional at the commencement of the exercise and there were no failures during the exercise. Media Monitoring consisted of television, radio and internet monitoring. Utility and state staff monitored the i televisions that were set to national and local media outlets to ensure that accurate information would be disseminated. These televisions are linked to video recorders so transmissions can be recorded if necessary.

The Citizen Hotline (public Inquiry/Rumor Control) was located in the JIC along with the BNP's I Public Inquiry staff. Rumors and/or trends of misinformation were reported to the JIC staff for correction in press briefings and/or news releases. The State Citizen Hotline fielded 21 calls and the utility Public Inquiry staff received more than 20 calls. Both provided information on a false rumor, which was corrected during the press briefings. The rumor concerned information regarding a "boom" being heard along with smoke being seen at the plant.

In the 2010 BNP exercise, the PIOs of Brunswick and New Hanover County were not familiar i with their roles in the JIC and failed to issue any news releases prior to the activation of the JIC and were assigned ARCAs for those areas requiring corrective action. The two unresolved i ARCAs from the 2010 BNP, ARCA 08-10-5.b. l-A-02, Brunswick County, and ARCA 08 5.b. 1-A-03, New Hanover County, were successfully demonstrated through observations during i this exercise, in accordance with the scheduled corrective action and are therefore, resolved as reflected below. 3 ARCA 08-10-5.b. 1-A-02-Resolved; The Brunswick County Public Information Officer (PIO) in the JIC was not familiar with his responsibilities and did not publish any news releases. Rumor i 30

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant control information detailing public inquiries was gathered at the EOC. However, this data was not requested or used by the spokesperson in the JIC Brunswick County successfully demonstrated this criterion on August 7, 2012 during the 2012 BNP REP Exercise as indicated above, thus resolving this ARCA.

ARCA 08-10-5.b. 1-A-03-Resolved; The New Hanover County PIO in the JIC was not familiar with his responsibilities and did not publish any news releases. The PIO did not corroborate with the EPIC regarding rumor control.

New Hanover County successfully demonstrated this criterion on August 7, 2012 during the 2012 BNP REP Exercise as indicated above, thus resolving this ARCA.

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

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.4 Brunswick County Emergency Operations Management Capability Summary:

Brunswick County successfully demonstrated the capability to effectively manage the EOC.

Notification and mobilization of staff was conducted using the First Call Network. The First Call Network is a computer based program which calls and sends texts to multiple contact numbers of responders in the system. A report is then generated that provides results of who received the message. Through utilization of this program, EOC staff was mobilize in an efficient and effective manner. The system can also be used to contact farmers in the EPZ to provide them protective actions that should be taken for livestock and crops. The primary communications in the EOC were new for this exercise. The hard line telephones found at each work station were replaced with new Voice Over Internet Protocol (VOIP) phone lines. Even though this was the first time they were used in the EOC, they proved to be a cost effective asset 31

Unclassified Radiological Emergency Preparedness Program (REP) i After Action Report/Improvement Plan Brunswick Nuclear Plant n that provided more flexibility while directing and transferring calls. The dedicated decision line was still used as the primary method of communication with the utility, State, and other risk county. The EOC was well equipped to support operations. Maps, signs, and displays were used throughout the drill to make decisions and maintain situational awareness.

The EOC Manager did an excellent job of directing EOC Operations. He provided frequent staff briefings and facilitated round table updates. He maintained a forward leaning posture throughout the exercise and ensured the staff had assets in place to support degrading incident conditions. Relevant factors were carefully considered prior to making protective action decisions; plans and procedures were followed throughout the exercise. Coordination with involved entities was conducted'on a regular basis. The EOC manager took it upon himself to use the exercise as a training opportunity for staff on the use of a paper messaging system by

.disabling WebEOC. His reasoning is that WebEOC may not always be available and the staff should be proficient using both methods. 3 Implementation of protective action decisions and preplanned action items were accomplished in i accordance with plans and procedures. The EOC Manager instructed EOC staff to prepare for an evacuation and they were knowledgeable enough with their responsibilities to execute them without the need for further guidance. The waterways were cleared, schools were relocated, traffic control points were coordinated and set up, functional needs populations were relocated, and shelters were established. This was all done through close coordination amongst EOC staff.

For example, Public Safety did not begin relocating functional needs populations until Human 3

Services advised them that the special needs shelters were activated and ready to receive people. 3 Every implementation of the plan was well thought out and coordinated. All staff in the Brunswick County EOC was familiar with the plans and their responsibilities and well prepared to respond to an incident.

Emergency Public Information & Warning Capability Summary:

The primary means of notification to the public is through a fixed siren system located throughout the EPZ. Brunswick County serves as the lead county for the BNP and will normally activate the system. However, New Hanover County has the ability to activate the siren system if necessary. Additionally, EAS messages are transmitted to the local LP- 1 and LP-2 radio stations through the State of North Carolina warning point using EMNET. The activation of the weather m 32

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant radio system through the NWS Wilmington serves as an additional mechanism for notification.

The sirens were sounded at the SAE and GE. Brunswick County activated the system in a timely manner following a joint decision with State and New Hanover County. During this exercise and lAW with the EOPA, there was a simulated siren failure and backup route alerting (BRA)was implemented. The Fire Liaison and the EMAD discussed the procedures for implementing and determining which route would need to be run. The evaluation of BRA was done OOS and is detailed below.

All new releases are complied and released by the County PIO in the JIC. Public Inquiry Control was effective in the EOC. All calls were directed to a phone bank which was manned by.

volunteers. The volunteers were familiar with the process for directing calls to the appropriate EOC staff. They were also able to answer many of the questions which were asked of them by using the informational brochures which were distributed by the utility.

Emergency Public Information & Warning Capability Summary: Backup Route Alerting A representative from the Boiling Springs Lake Volunteer Fire Department was interviewed on back-up route alerting procedures for Brunswick County. He had a clear understanding of how he would receive and process a request for back-up route alerting. He was knowledgeable of the local area, his duties and of radiological exposure control procedures.

Public Safety and Security Response Capability Summary:

Two officers with the Brunswick County Sherriff's Office and the Southport Police Chief were interviewed regarding TCPs OOS from the exercise. They were well aware of procedures for the issuance of equipment and reporting to assigned locations. The equipment and communications maintained by the TCP officers is sufficient to perform operations. All officers were familiar with the use of DRDs, PRDs and KI. They also knew the administrative reporting values and turn back limits. Both agencies were familiar with the pre-identified TCPs in the plan and were well versed on their relationship to the evacuation routes and shelters. Resources required for the removal of impediments are predetermined and available to the officers if needed. During the interview it was observed that there is good coordination between these agencies. They were familiar with each other's resources and were ready to work together to accomplish the mission.

33

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant Citizen Evacuation and Shelter in Place Capability Summary:

Brunswick County successfully demonstrated this capability to safeguard students and faculty in I the event of an emergency at the Brunswick Nuclear Plant. The evaluation was conducted out of sequence on July 18th, 2012 through discussion with the following personnel; Assistant Director m of Brunswick County Emergency Services; Director of Brunswick County Transportation; Principal and Assistant Principal of South Brunswick High School; and the Director of Operations for Brunswick County School System. The County representatives were well versed and understood the District's crisis evacuation plan and BCSOG-106 which covers the schools actions in a REP emergency. The plans cover all County endangered schools to include the populations of private schools and day care centers in the emergency planning zone area.

Brunswick County's preparedness was evident during the discussion and should be commended. 3 Hazardous Materials Response and Decontamination Capability Summary: Reception and Congregate Care Center(RCCC) 3 Brunswick County successfully demonstrated the ability to assess radiological hazards through radiological monitoring and establishing contamination control. The county managed radiological exposure by providing radiological safety briefings, implementing radiation exposure limits and issuing personal dosimetry to all emergency workers. Spread of radiological contamination was minimized by activating the West Brunswick High School RCCC, which monitored and decontaminated evacuees and their vehicles as required. The emergency workers demonstrated good survey monitoring techniques and worked well as a team. The information I flow between the Emergency Workers (EWs) concerning the recorded status and condition of the contaminated individuals was excellent. Each EW gave clear and concise directions to the surveyed individuals. All agencies involved in the monitoring and decontamination team exhibited outstanding team work, effective communication skills, a strong understanding of 3 exposure control, and demonstrated thorough monitoring and decontamination techniques.

I HAZMAT Response and Decontamination Capability Summary: Emergency Worker Decontamination (EWD) I 34

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant Brunswick County personnel successfully demonstrated the capability to assess and manage the consequences of a hazardous materials release, decontaminate on-site responders and equipment; and coordinating off-site decontamination with relevant agencies. The Radiological Officer gave a good safety and radiological briefing to the entire monitoring and decontamination team. She reminded each worker of their dosimetry requirements, exposure limits, KI requirements, and time requirements for reading and reporting their DRD results. The vehicle monitoring and decontamination teams exhibited good team work, communications, and good monitoring and decontamination practices. Two emergency workers successfully donned and doffed their PPE.

The PPE were donned in a fashion to provide ample protection from contamination to critical areas of the body. EW equipment was affixed properly to PPE and EW's demonstrated proper usage. Doffing procedures were followed with supervisor assistance resulting in a successful exit from the hot zone.

Hazmat Decontamination and Response Capability Summary: Medical Services Drill Brunswick County Emergency Management Services staff successfully demonstrated their ability to respond to an accident victim with radiological contamination and transport that patient during this Medical Services Drill. After receiving a call for assistance the Brunswick County Emergency Medical Services team dispatched appropriate emergency medical service resources, provided appropriate contamination control, and notified the Dosher Memorial Hospital on the status of the contaminated injured patient, and then transported the patient to the hospital.

Dosher Memorial Hospital demonstrated their ability to receive a contaminated injured patient and properly performing necessary decontamination, contamination control actions, and medical treatment. The exterior Radiation Emergency Area (REA) was established in a timely manner and appropriately marked to limit entry to authorized personnel. The REA surface areas were covered sufficiently to provide excellent contamination control from the exterior ambulance parking area to the emergency room vestibule. Medical staff successfully and consistently demonstrated effective personnel monitoring, equipment survey, and personal protective equipment donning and doffing procedures.

Mass Care (Sheltering, Feeding, and Related Services) Capability Summary:

Brunswick County was prepared to provide evacuees immediate shelter, security, food, water, 35

Unclassified Radiological Emergency Preparedness Program (REP) i After Action Report/Improvement Plan Brunswick Nuclear Plant sleeping space, sanitation facilities, and medical care. The shelter for evacuees from the 10 mile emergency planning zone within the county would be established at the GE ECL. Preparation to open the shelters would be initiated at the SAE ECL. The Cape Fear Chapter of the American Red Cross (ARC) was responsible for the coordination of all government and non-government agencies involved with sheltering. West Brunswick High School is an ARC certified shelter with a capacity for 1,230 evacuees. The high school campus has adequate space, sufficient resources, and utilities to support the assigned mission. Cross contamination of the shelter was prevented by use of green colored armbands distributed by the monitoring and decontamination staff. Only evacuees with armbands who had processed through the monitoring station and 3 reception desk were allowed inside the shelter facility. In accordance with county plans, KI is stored with the County Health Department and would be moved to the shelter and distributed by the Health Department when ordered to do so.

In summary, the status of DHS/FEMA criteria for this location is as follows: 3

a. M ET: 1.a. 1, 1.c. 1, 1.d. 1, L.e. 1, 2.a. 1, 2.b. 1, 2.b.2, 2.c. 1, 3.a. 1, 3.b. 1, 3.c. 1, 3.c.2, 3.d. 1, 3.d.2, 5.a. 1, 5.a.3, 5.b. 1, 6.a. 1, 6.b. 1, 6.c. 1, 6.d.1. i

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 5.b.1.1 ISSUE NO.: 08-10-5b1-A-02 i ISSUE: The Brunswick County PIO in the JIC was not familiar with his responsibilities and did not publish any news releases. Rumor control information detailing public inquiries was gathered at the EOC. However, this data was not requested or used by the spokesperson in the JIC 3 CORRECTIVE ACTION DEMONSTRATED: Brunswick County successfully 3 demonstrated this criterion on August 7, 2012 during the 2012 BNP REP Exercise as indicated above, thus resolving this ARCA. 3

g. PRIOR ISSUES - UNRESOLVED: None I

363

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant 3.3.1.5 New Hanover County Emergency Operations Management Capability Summary:

New Hanover County Emergency Management personnel and Emergency Operations Center (EOC) staff successfully demonstrated the capability to provide multi-agency coordination for incident management by activating and operating an EOC. Emergency support personnel were prepositioned in the EOC as per the extent of play agreement. The Emergency Management Director (EMD) explained how staff would normally be alerted and mobilized using the primary automatic calling system and a manual call down system. These systems and methods could efficiently alert, notify, and mobilize emergency personnel and facilities in New Hanover County.

The Selective Signaling System (SSS) and the Decision Line telephone were the primary means of communications between New Hanover County and Brunswick'County, State agencies and the utility. Other communications systems, included; commercial telephones, radios, and computer based software systems like WebEOC.

The EMD exhibited good direction and control of the EOC Staff and in coordinating PADs with Brunswick and State agencies in implementing the protective actions. The EMD used a tasking/checklist tied into the WebEOC system to effectively delegate actions to EOC agencies and coordinate actions with Brunswick County. Briefings were held at appropriate times and the EMD polled the staff to review actions that they had been working, to review plans and checklists for future actions, and to insure they were coordinating with other agencies. The EMD and the EOC Staff displayed excellent coordination with agencies outside of the EOC. The Progress Energy liaison representative consistently provided sound explanations of the emergency notification form ensuring a thorough understanding of the emergency situation and plant status. The EMD successfully adhered to the plans and procedures and made timely decisions throughout the exercise.

Actual issuance of dosimetry was not conducted during this exercise. Dosimetry issuance was observed during out-of-sequence activities. All dosimetry and KI was satisfactorily inventoried and inspected during a Site Assistance Visit. During this portion of the exercise New Hanover County Sheriff s Office and North Carolina Highway Patrol personnel did demonstrate and discuss the proper methods and practices to manage radiological exposure to emergency workers 37

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Brunswick Nuclear Plant and issue KI and track the administration of KI to emergency workers. These representatives also discussed management of traffic control points, including handling any impediments.

Representatives from the New Hanover County Emergency Management, Schools, Public Health, and Department of Social Services described actions they would take to protect the health and safety of school students and staff, citizens with functional needs and transportation dependent individuals. All of these agencies could coordinate resources to easily handle the 23 special needs individuals who required assistance and the one school located in the 10-mile EPZ.

There were no hospitals, nursing homes or day care centers in the EPZ.

Emergency Public Information & Warning Capability Summary:

The primary means for alerting the public in New Hanover County was the Duke Energy fixed siren system. Activation control panels were located in the County EOC and 911 Center. The sirens could also be activated by control panels located in Brunswick County and the EOF.

Brunswick is the lead county and has the primary responsibility for the system activation with New Hanover serving as a backup if Brunswick fails to activate the system in a timely manner.

This system was successfully demonstrated during two siren activations using a silent test and receiving feedback reports that verified siren activation. Tone Alert Radios operated by the National Weather Service would also be used to automatically alert the public and broadcast emergency instructions. Emergency vehicles with sirens and public address systems would be used if any or all of the siren system failed. New Hanover County emergency personnel satisfactorily demonstrated or discussed how these systems could be activated and what actions they would take if any part of the system failed. The County PIO and members of the Emergency Public Information Center demonstrated the ability to provide instructional messages to the public in a timely manner and handle public inquiries.

Emergency Public Information & Warning Capability Summary: Back up Alerting and Notification This capability was demonstrated through discussion with a representative New Hanover County I Fire Rescue Station 19. The Lieutenant clearly understood his responsibilities and duties in the event of a siren failure in New Hanover County. His professionalism and candor was evident 38

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant during this interview to include his knowledge of the dosimetry and radiological exposure control measures.

Public Safety and Security Response Capability Summary:

New Hanover County Sheriff Office Deputies were interviewed on their responsibilities regarding Traffic Control Points and Security Road Blocks. Each was knowledgeable of traffic access control and emergency worker exposure control. They described the process of clearing traffic impediments; explained the responsibilities of the positions, demonstrated equipment usage and the exposure limits required while in the EPZ. The Deputies also discussed procedures for issuing and the ingestion of Potassium Iodide (KI). Both Deputies successfully discussed the aspects of Traffic Control Points and Security Road Blocks for New Hanover County.

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

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

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

ISSUE NO.: 08-10-5bl-A-03 ISSUE: The New Hanover County PIO in the JIC was not familiar with his responsibilities and did not publish any news releases. The PIO did not corroborate with the EPIC regarding rumor control.

CORRECTIVE ACTION DEMONSTRATED: New Hanover County successfully demonstrated this criterion on August 7, 2012 during the 2012 BNP REP Exercise as indicated above, thus resolving this ARCA.

39

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant

g. PRIOR ISSUES - UNRESOLVED: None I

I I

I 40

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant SECTION 4: CONCLUSION Officials and representatives from the State of North Carolina; the risk counties of Brunswick and New Hanover, and Duke Energy as well as numerous volunteers participated in the exercise.

The cooperation and teamwork of the participants was apparent throughout the exercise. FEMA wishes to acknowledge the efforts of the many individuals who participated and made the exercise a success.

FEMA would also like to acknowledge the exceptional efforts of the many individuals who planned, prepared for and participated in this exercise. Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others. Still others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities.

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

During this exercise, two Area's Requiring Corrective Action (ARCA's) from the 2010 exercise evaluation were resolved.

1.(08-10-5.b. 1-A-02) Emergency Public Information and Warning: The Brunswick county representative in the JIC was not prepared to act as media spokesperson. Once the JIC was activated the county PIO did not publish or release any news releases. Criterion Not Met: 5.b. 1.

2.(08-10-5.b. l-A-03) Emergency Public Information and Warning: The New Hanover county representative in the JIC was not prepared to act as media spokesperson. Once the JIC was activated the county PIO did not publish or release any news releases. Criterion Not Met: 5.b. 1.

The clearance of these ARCA's required the hard work of many and FEMA acknowledges all parties that helped to implement the Corrective Action Program (CAP) adapted by the State of North Carolina. The role of the BNP Task Force in scheduling and conducting the necessary improvements was instrumental in the success of the CAP and ultimately the exercise.

41

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Brunswick Nuclear Plant I

APPENDIX A: EXERCISE TIMELINE I Table 1 - Exercise Timeline DATE: 2012-08-07, SITE: Brunswick Nuclear Plant, NC I

7z Emergency Classification Level or "

I Event "U

[-

U Z tZ U U~

Z I

I Unusual Event 0836 0856 0836 N/A 0854 0858 Alert 0927 0941 0927 0944 0941 0945 Site Area Emergency 1030 1043 1030 1034 1038 1036 General Emergency 1341 1357 1341 1350 1345 1351 Simulated Rad. Release Started Simulated Rad. Release Terminated 1341 Ongoing 1357 Ongoing 1341 Ongoing N/A N/A 1345 Ongoing 1351 Ongoing I

Facility Declared Operational State Assumes Direction and Control Declaration of State of Emergency: State 0944 1135 1045 0911 N/A N/A 1043 1135 1045 0927 1135 N/A 0950 1135 N/A I

Declaration of State of Emergency: Brunswick I

1040 N/A 1050 1040 N/A County Declaration of State of Emergency: New 1050 N/A 1050 N/A 1050 Hanover County Exercise Terminated Early Precautionary Actions: Waterway Clearing, Livestock on Stored Feed and Water, Close Parks 1425 1030 1409 N/A 1430 N/A 1425 1030 1428 1030 I I st Protective Action Decision: Stay Tuned 1st Siren Activation 1st EAS Message 1055 1057 1100 N/A N/A N/A N/A 1057 1100 1055 1057 1100 1055 1057 1100 I

I 1st NWS Message 1105 N/A 1105 1105 1105 2nd Protective Action Decision: Evacuate Zones: 1405 N/A 1405 1405 1405 A, B, C, D, E. Shelter in Place Zones: F, G, H, J, K, L, M, N 2nd Siren Activation 2nd EAS Message 2nd NWS Message 1410 1415 1420 N/A N/A N/A 1410 1415 1420 1410 1415 1420 1410 1415 1420 I

KI Administration Decision: Field Teams 1216 N/A N/A N/A N/A KI Administration Decision: Emergency Workers 1241 N/A 1300 1242 1245 I KI Administration Decision: General Public 1430 N/A N/A N/A N/A I

42

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant APPENDIX B: EXERCISE EVALUATORS AND TEAM LEADERS DATE: 2012-08-07, SITE: Brunswick Nuclear Plant, NC LOCATION ' EVALUATOR ,' AGENCY State of North Carolina Walt Cushman FEMA-NP-

• Michael Dolder TH-REP John Fill FEMA-NP-Alex Sera TH-REP Ronald Shaw FEMA RIV John Wills FEMA-NP-TH-REP FEMA-NP-TH REP ICFI Emergency Operation Facility Brunswick *Larry Robertson FEMA-NP-TH-REP North Carolina Joint Information Center *John Ackermann FEMA Odis Spencer FEMA-NP-TH-REP Brunswick County *Matthew Bradley FEMA-NP-Michael Dolder TH-REP Willis Larrabee FEMA-NP-Lorenzo Lewis TH-REP Gerald Mclemore ICFI Robert Spence FEMA-NP-TH-REP FEMA RIV FEMA-NP-TH-REP New Hanover County Joe Harworth FEMA-NP-

• Robert Nash TH-REP Robert Speuice FEMA-NP-TH-REP FEMA-NP-TH-REP

• Team Leader 43

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Brunswick Nuclear Plant I

APPENDIX C: ACRONYMS AND I ABBREVIATIONS I

-rn Mening ARC ARCA American Red Cross Area Requiring Corrective Action I

ARES Amateur Radio Emergency Services AWIPS BCES Advanced Weather Interactive Processing System Brunswick County Emergency Services i

BNP CFR Brunswick Nuclear Plant Code of Federal Regulations I CPM Counts Per Minute DHS DRD Department of Homeland Security Direct-Reading Dosimeter I

EAL Emergency Action Level EAS EBO Emergency Alert System Eastern Branch Office I

EEG EMS Exercise Evaluation Guide Emergency Medical Services I EOC Emergency Operations Center EOF EOPA Emergency Operations Facility Extent of Play Agreement I

EPIC Emergency Public Information Center EPZ ERDS Emergency Planning Zone Emergency Response Data System I

ESF EW Emergency Support Function Emergency Worker I

FEMA Federal Emergency Management Agency FMT FOUO Field Monitoring Team For Official Use Only U

FTL GE Field Team Leader General Emergency I HSEEP Homeland Security Exercise and Evaluation Program IP IPAWS Improvement Plan Integrated Public Alert and Warning System I

JIC Joint Information Center MHz MOTSU Mega Hertz Military Ocean Terminal Sunny Point I

44 I

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant mR milliroentgen mR/h milliroentgen per hour NAWAS National Warning System NCEM North Carolina Emergency Management NHCEM New Hanover County Emergency Management NIMS National Incident Management System NOUE Notification of Unusual Event NRC Nuclear Regulatory Commission NWS National Weather Service 00S Out-of-Sequence ORO Offsite Response Organization PAD Protective Action Decision PAG Protective Action Guide PAR Protective Action Recommendation P1O Public Information Officer PPE Personal Protective Equipment PRD Permanent Recoid Dosimetry PSCC Public Safety Communications Center R Roentgen R/h Roentgen(s) per hour RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Services RASCAL Radiological Assessment System for Consequence Analysis REM Roentgen Equivalent Man REMO Radiation Emergency Management Organization REP Radiological Emergency Preparedness RERP Radiological Emergency Response Plan RPS Radiation Protection Section SAE Site Area Emergency SEOC State Emergency Operations Center SERT State Emergency Response Team SMRAP Southern Mutual Radiological Assistance Plan SOG Standard Operating Guide SOP Standard Operating Procedure SRD Self-Reading Dosimeter SSS Selective Signaling System TCL Target Capabilities List TCP Traffic Control Point TEDE Total Effective Dose Equivalent TLD Thermoluminescent dosimeter 45

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant USCG United States Coast Guard VIPER Voice Interoperability Plan for Emergency Responders 46

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant APPENDIX D: EXTENT OF PLAY AGREEMENT EXTENT OF PLAY AGREEMENT BRUNSWICK NUCLEAR PLANT RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE August 7. 2012 Demonstrating Reasonable Assurance: The Assessment Areas, derived from the NUREG-0654/FEMA-REP-1 (April 2012) Planning Standards and Evaluation Criteria, reflect current FEMA policy and guidance on the activities that OROs are expected to be able to perform to maintain reasonable assurance that the health and safety of the public can be protected in the event of an incident at an NPP. The REP Assessment Areas, Sub-elements, and Demonstration Criteria have been aligned with HSEEP target capabilities, activities, and tasks. FEMA Region IV has identified a set of Target Capabilities correlating to the REP Demonstration Criteria so that regional REP exercise evaluations using HSEEP exercise documents may occur. These capabilities are listed below with the applicable criterion identified within.

All selected activities will be demonstrated fully in accordance with respective plans.

This Extent of Play agreement is written by exception. If it is not listed as an exception it will be demonstrated as described in the plans and standard operating guides or procedures.

FEMA and the State of North Carolina have agreed that any issue or discrepancy arising during exercise play be allowed correction immediately, at all player locations, if it isn't disruptive to exercise play and if it is mutually agreeable to both the controller and evaluator.

CAPABILITY: Emergency Operations Management. (State and County EOCs, EOF). Definition: Emergency Operations Center (EOC) management is the capability to provide multi-agency coordination (MAC) for incident management by activating and operating an EOC for a pre-planned or no-notice event. EOC management includes: EOC activation, notification, staffing, and deactivation; management, direction, control, and coordination of response and recovery activities; coordination of efforts among neighboring governments at each level and among local, regional, State, and Federal EOCs; coordination of public information and warning; and maintenance of the information and communication necessary for coordinating response and recovery activities.

Participants:

NC SERT, Brunswick and New Hanover Counties.

Activity 1: Activate EOC. (Definition: In response to activation, perform incident notifications, recall essential personnel, and stand-up EOC systems to provide an operational EOC in accordance with State and local policies, procedures, and directives). (Criterion L.a.l: NUREG-0654/ FEMA-REP-1, 47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant I

A.!.a, e; A.3, 4; C.1,4, 6; D.4; E.1, 2; H.3, 4), (Criterion 1.b.1: NUREG-0654/FEMA-REP-1, H.3; G.3.a; J. 1.0.h; J.12; K.5.b), (Criterion 1.d.l: NUREG-0654/FEMA-REP-1, F.1, 2), (Criterion 1.e.l: NUREG-0654/FEMA-REP-1, H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.1 1, 12; K.3.a; K.5.b).

Exceptions: I

• Exercise participants are allowed to pre-position for this exercise.

o County Alert rosters have been verified during FEMA SAV (5/12/12).

o The Lead State evaluator will verify SEOC staffing rosters.

o Players will discuss alert and notification procedures with the evaluators.

" The SERT will be operating out of a new SEOC. This facility will be base lined during this exercise. Communications and equipment in the SEOC will have a courtesy review and not evaluated.

I

• Dosimetry and KI inventories have been verified during the FEMA SAV (5/12/12).

Activity 2: Direct EOC Operations. (Definition: Following activation of the EOC system, staff and organize the EOC, to include providing Protective Action Decision Making in accordance with the State and local policies, procedures, and directives). (Criterion 1.c.1: NUREG-0654/FEMA-REP-1, A. 1.d; A.2.a, b; A.3; C.4, 6), (Criterion 2.a.l: NUREG-0654/FEMA-REP-1, C.6; J.10. e, f; K.4),

(Criterion 2.b.2: NUREG-0654/FEMA-REP-1,A.3; C.4, 6; D.4; J.9; J.10.f, in),

(Criterion 2.c.1: NUREG-0654/FEMA-REP-1,D.4; J.9; J.10.d, e).

Exceptions: i

• Brunswick County is the lead-coordinating county until the state is requested to assume direction and control. Following the silent testing of sirens and issuance of the first PAD recommendations to the public, Brunswick County will request the State assume direction and control.

• Radiation Protection Section will analyze technical data and make recommendations to the SERT Leader who in turn will make recommendations to the Brunswick & New Hanover EOCs Activity 3: Support and Coordinate Response. (Definition: Once requested, provide resource, technical, and policy support to the Incident Command by coordinating the actions of off-site agencies, organizations, and jurisdictions, to include implementing MAAs, requesting higher-level assistance, and Protective Action Implementation). (Criterion 2.b.l: NUREG-0654/FEMA-REP-1, 1.10 and 48

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant Supplement 3), (Criterion 3.a.l: NUREG-0654/FEMA-REP-1, J.10.e; K.3.a, b; K.4), (Criterion 3.b.1: NUREG-0654/FEMA-REP-1, J.10.e, f), (Criterion 3.c.1:

NUREG-0654/FEMA-REP- 1, J. lO.c, d, e, g), (Criterion 3.c.2: NUREG-0654/FEMA-REP-l, J.10.c, d, e, g), (Criterion 3.d.M: NUREG-0654/FEMA-REP-1, A.3; C. 1,4; J. 1O.g, j), (Criterion 3.d.2: NUREG-0654/FEMA-REP- 1, J. 10. k).

Exceptions:

" If Counties are in direction and control then the decision to take KI is made by the County Health Director. If the State is in direction and control then the decision to take KI is made by the State Health Director in consultation with the State Pharmacist, Radiation Protection Section and County Health Directors.

" County PAD Implementation for Special Populations will be evaluated through discussion with the Federal Evaluator. No actual evacuation or relocation will take place.

" In accordance with current HIPAA laws, a current list of Special Needs Populations will be available for review by the Federal Evaluator.

• No distribution of actual or simulated KI will be accomplished. Procedures will be demonstrated through discussion with the Federal Evaluator.

CAPABILITY: Emergency Public Information and Warning. (State and Counties)

Definition: Develop, coordinate, and disseminate accurate alerts and emergency information to the media and the public prior to an impending emergency and activate warning systems to notify those most at-risk in the event of an emergency. By refining its ability to disseminate accurate, consistent, timely, and easy-to understand information about emergency response and recovery processes, a jurisdiction can contribute to the well-being of the community during and after an emergency.

Participants:

NC SERT (SEOC, JIC), Brunswick and New Hanover Counties.

Activity 1: Activate Emergency Public information, Alert/Warning and Notification Plans. (Definition: Activate key personnel, facilities, and procedures). (Criterion 1.a.l: NUREG-0654/ FEMA-REP-1, A.l.a, e; A.3, 4; C.1,4, 6; D.4; E.1, 2; H.3, 4), (Criterion 1.e.1: NUREG-0654/FEMA-REP-1, H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.1 1, 12; K.3.a; K.5.b) (Criterion 3.a.l: NUREG-0654/FEMA-REP-1, J.10.e; K.3.a, b; K.4), (Criterion 5.a.l: NUREG-49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant I

0654/FEMA-REP-1, E.5, 6, 7), (Criterion 5.a.3: NUREG-0654/FEMA-REP-1, E.6, Appendix 3.B.2.c).

Exceptions:

• Actual Waterway clearance activities will not be demonstrated (No boats in i water). Evaluation will be through a combination of interviews and a communications drill scheduled during the table top exercise on July 17th.

The COMEX will include a minimum demonstration of communication capabilities with Incident Command and three boats at predetermined launch locations.

• Staff working in the JIC will pre-position in Brunswick County and will be called to report to the JIC at the appropriate time. Players will discuss alert and notification procedures with the evaluators.

• NWS-Wilmington will NOT ACTIVATE EAS or NOAA weather radio systems. System activation will be evaluated through discussion with the evaluator.

I Activity 2: Issue Emergency Warnings. (Definition: Upon receiving Protective I Action Decisions, issue emergency public warnings through established warning systems). (Criterion 5.a.l: NUREG-0654/FEMA-REP-1, E.5, 6, 7), (Criterion 5.a.3: NUREG-0654/FEMA-REP-1, E.6, Appendix 3.B.2.c), (Criterion 5.b.l: l NUREG-0654/FEMA-REP-1, E.5, 7; G.3.a, G.4.a, c).

Exceptions:

" Brunswick County will coordinate and conduct the countdown for siren activation. A silent test of the sirens will be demonstrated, no actual sounding of the sirens will take place.

i

" If a siren has failed, back-up alerting procedures will be discussed with the Federal Evaluator for the failed zone. If no siren fails during the silent test, the State controller will inject a pre-determined zone (siren failure simulated).

" Both counties will demonstrate their back-up Alert Notification Systems (reverse 911). This demonstration will be evaluated for traininguse only.

• EAS activation will be simulated; system activation procedures will be evaluated through discussion with the evaluator.

50

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant

" Brunswick County will address an Area Requiring Corrective Action (ARCA 08-10-5.b. I-A-02)

" New Hanover County will address an Area Requiring Corrective Action (ARCA 08-10-5.b. l-A-03)

Activity 3: Manage Emergency Public Information and Warnings.

(Definition: In response to need for public notification, provide overall management and coordination of Emergency Public Information and Warning capability). (Criterion 5.a.l: NUREG-0654/FEMA-REP-l, E.5, 6, 7), (Criterion 5.b.l: NUREG-0654/FEMA-REP-1, E.5, 7; G.3.a, G.4.a, c).

Exceptions:

" Brunswick County will address an Area Requiring Corrective Action (ARCA 08-10-5.b. 1-A-02)

" New Hanover County will address an Area Requiring Corrective Action (ARCA 08-10-5.b.l-A-03)

Activity 4: Provide Public Inquiry Control. (Definition: Track inquiries for rumors). (Criterion 5.b.l: NUREG-0654/FEMA-REP-1, E.5, 7; G.3.a, G.4.a, c).

Exceptions:

• State rumor control functions will be demonstrated in the JIC.

• County rumor control will be JAW with their plans and procedures.

CAPABILITY: Citizen Evacuation and Shelter in Place (Schools). Definition:

Citizen Evacuation and shelter-in-place is the capability to prepare for, ensure communication of, and immediately execute the safe and effective sheltering-in-place of an at-risk population (and companion animals), and/or the organized and managed evacuation of the at-risk population (and companion animals) to areas of safe refuge in response to a potentially or actually dangerous environment. In addition, this capability involves the safe reentry of the population where feasible.

Participants:

Brunswick County Activity 1: Direct Evacuation and/or In Place Protection. (Definition: In response to a hazardous condition for a locality, direct, manage, and coordinate evacuation and/or in-place sheltering procedures for both the general population 51

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant I

and those requiring evacuation assistance throughout incident). (Criterion 3.c.2:

NUREG-0654/FEMA-REP-1, J. 1O.c, d, e, g)

Exceptions:

" Out of Sequence - Date and Time: Wednesday, 18 July, 2012 10:00AM, Location: I Brunswick County EOC 3325 Old Ocean Highway, Building C, Bolivia, NC 28422

• School evacuation procedures will be evaluated through discussion with key school staff members from South Brunswick High School.

" School bus drivers are not emergency workers. Local law enforcement agencies are responsible for escorting buses during an evacuation. These agencies will be interviewed during the TCP evaluations concerning these requirements.

I CAPABILITY: Public Safety and Security Response (TCPs). Definition: Public Safety and Security Response is the capability to reduce the impact and consequences of an incident or major event by securing the affected area, including crime/incident scene preservation issues as appropriate, safely diverting the public from hazards, providing security support to other response operations and properties, and sustaining operations from response through recovery. Public Safety and Security Response requires coordination among officials from law enforcement (LE), fire, and emergency medical services (EMS). I

Participants:

NC SERT, Brunswick and New Hanover Counties.

Activity 1: Activate Public Safety/Security Response (Definition: Upon notification, mobilize and deploy to begin operations). (Criterion 1.d.1:

NUREG-0654/FEMA-REP- 1, F. 1, 2), (Criterion 1.e.l: NUREG-0654/FEMA-REP-1, H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.1 1, 12; K.3.a; K.5.b), (Criterion 3.a.l:

NUREG-0654/FEMA-REP-1, J. 10.e; K.3.a, b; K.4).

I Exceptions: I

• Out of Sequence - Date and Time: Tuesday, 17 July, 2012 10:00AM, Location:

Brunswick County EOC 3325 Old Ocean Highway, Building C, Bolivia, NC 28422 I

• Evaluation will be through discussion with Representatives from the NC State Highway Patrol, New Hanover County Sheriff's Office, Brunswick County Sheriffss Office and Southport Police Department.

Activity 2: Control Traffic, Crowd, and Scene. (Definition: Direct/redirect traffic and pedestrians out of the affected area(s). Assess, coordinate, and 52

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant establish force protection and perimeter zones, maintain a visible and effective security presence to deter criminal conduct and maintain law and order).

(Criterion 3.d.l: NUREG-0654/FEMA-REP- 1, A.3; C. 1,4; J. 10.g, j), (Criterion 3.d.2: NUREG-0654/FEMA-REP- 1, J. 10.k).

Exceptions:

• Out of Sequence - Date and Time: Tuesday, July 17, 2012 10:00AM, Location:

Brunswick County EOC 3325 Old Ocean Highway, Building C, Bolivia, NC 28422

" Evaluation will be through discussion with Representatives from the NC State Highway Patrol, New Hanover County Sheriff s Office, Brunswick County Sheriff s Office and Southport Police Department.

CAPABILITY: HAZMAT Decontamination and Response. Dose Assessment, FMTs, FMT Control, Reception Centers, Emergency Worker Decontamination, MSD). (Definition: HAZMAT Response and Decontamination is the capability to assess and manage the consequences either of a hazardous materials release, accidental or as part of a terrorist attack. It includes testing and identifying all likely hazardous substances onsite; ensuring that responders have protective clothing and equipment; conducting rescue operations to remove affected victims from the hazardous environment; conducting geographical survey searches of suspected sources or contamination spreads and establishing isolation perimeters; mitigating the effects of hazardous materials, decontaminating on-site victims, responders, and equipment; coordinating off-site decontamination with relevant agencies, and notifying environmental, health, and law enforcement agencies having jurisdiction for the incident to begin implementation of their standard evidence collection and investigation procedures.

Participants:

Radiation Protection Section, Brunswick County, Dosher Memorial Hospital.

Activity 1: Site Management and Control. (Definition: In response to activation, mobilize and arrive at the incident scene and initiate response operations to manage and secure the physical layout of the incident). (Criterion 1.a.l: NUREG-0654/FEMA-REP-1, A.l.a, e; A.3, 4; C.1,4, 6; D.4; E.1, 2; H.3, 4), (Criterion 1.c.l: NUREG-0654/FEMA-REP-1, A.l.d; A.2.a, b; A.3; C.4, 6),

(Criterion 1.d.1: NUREG-0654/FEMA-REP-1, F.1, 2), (Criterion 1.e.l:

NUREG-0654/FEMA-REP-1, H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b), (Criterion 3.a.l: NUREG-0654/FEMA-REP-1, J.10.e; K.3.a, b; K.4),

(Criterion 3.b.l: NUREG-0654/FEMA-REP- 1, J. 10.e, f).

Exceptions:

53

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant I

" Brunswick County RCCC/ EWD Operations: Out of Sequence - Date and Time:

Tuesday, July 19, 2012 10:00AM, Location: West Brunswick High School, 550 Whiteville Road, Shallotte, NC 28470.

" Brunswick County: Availability of KI was verified during the Staff Assistance Visit on 5/12/12.

Activity 2: Hazard Assessment Risk Evaluation. (Definition: Assess the hazards present, evaluate the level of risk to both responders and the public, and develop an Incident Action Plan (IAP) to address the response problem).

(Criterion 2.a.l: NUREG-0654/FEMA-REP-1, C.6; J.10. e, f, K.4), (Criterion 2.b.2: NUREG-0654/FEMA-REP-1,A.3; C.4, 6; D.4; J.9; J. 10.f, m), (Criterion 2.c.l: NUREG-0654/FEMA-REP-1,D.4; J.9; J.10.d, e), (Criterion 4.a.2:

(NUREG-0654/FEMA-REP-1, C.1; H.12; 1.7, 8, 11; J.10.a), (Criterion 4.a.3:

(NUREG-0654/FEMA-REP-1, C.1; H.12: 1.8, 9; J.l0.a).

Exceptions:

• Radiation Protection Section field activities will consist of two Radiation Protection field survey teams. The teams will be deployed from the North Carolina Army National Guard facility located at the Wilmington International Airport. This evaluation will be for training only.

Activity 3: Decontamination and Recovery Operations. (Definition: Upon I arrival on-scene and with the requisite equipment, initiate response operations to reduce the level of contamination on-scene, minimize the potential for secondary contamination beyond the incident scene, and ensure an effective transition to clean-up and recovery operations). (Criterion 6.a.l: (NUREG-0654/FEMA-REP-I 1, A.3; C.4; J.10.h; J.12), (Criterion 6.b.l: (NUREG-0654/FEMA-REP- 1, K.5.a, b), (Criterion 6.d.l: (NUREG-0654/FEMA-REP-1, F.2; H.10; K.5.a, b; L.1, 4). I Exceptions:

0 Brunswick County RCCC/EWD Operations: Out of Sequence - Date and Time:

Tuesday, July 19, 2012 10:00AM, Location: West Brunswick High School, 550 Whiteville Road, Shallotte, NC 28470. (Agencies: Shallotte Fire Department and Brunswick Count EMS).

I o RCCC - Six individuals per monitoring station will be demonstrated. Setup LAW plans, process 6 individuals, 2 contaminated (Imale & 1 Female).

Actual general population decontamination will be simulated and evaluated by interview.

" EWD - Two emergency workers will be monitored. One emergency worker will be decontaminated.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Brunswick Nuclear Plant o EWD - Two vehicles will be monitored and one will be decontaminated using water.

0 Medical Services Drill: Out of Sequence - Date and Time: Wednesday, July 18, 2012, 5:00PM, Dosher Memorial Hospital, Southport, NC. (Agencies: Dosher Memorial Hospital and Brunswick County EMS).

CAPABILITY: Mass Care. (Congregate Care). Definition: Mass Care is the capability to provide immediate shelter, feeding centers, basic first aid, bulk distribution of needed items, and related services to persons affected by a large-scale incident, including special needs populations. Special needs populations include individuals with physical or mental disabilities who require medical attention or personal care beyond basic first aid. Other special-needs populations include non-English speaking populations that may need to have information presented in other languages. The mass care capability also provides for pet care/handling through local government and appropriate animal-related organizations. Mass care is usually performed by nongovernmental organizations (NGOs), such as the American Red Cross, or by local government-spons'ored volunteer efforts, such as Citizen Corps. Special-needs populations are generally the responsibility of local government, with medical needs addressed by the medical community and/or its alternate care facilities. State and Federal entities also play a role in public and environmental health by ensuring safe conditions, safe food, potable water, sanitation, clean air, etc.

Participants:

Brunswick County, American Red Cross Activity 1: Establish Shelter Operations. (Definition: Staff and equip shelter in preparation to receive displaced persons and/or companion animals). (Criterion 6.c.1: NUREG-0654/FEMA-REP- 1, J. 10.h, J. 12).

Exceptions:

• Out of Sequence - Date and Time: Tuesday, 19 July, 2012 10:00AM, Location: West Brunswick High School, 550 Whiteville Road, Shallotte, NC 28470.

CAPABILITY: Public Health Laboratory Testing (Mobile or Fixed laboratory)

Definition: The Public Health Laboratory Testing capability is the ongoing surveillance, rapid detection, confirmatory testing, data reporting, investigative support, and laboratory networking to address potential exposure, or known exposure, to all-hazards which include chemical, radiochemical, and biological agents in allmatrices including clinical specimens, food and environmental samples, (e.g., water, air, soil). All-hazard threats include those deliberately released with criminal intent, as well as those that may be present as a result of unintentional or natural occurrences.

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Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Brunswick Nuclear Plant I

Participants:

Radiation Protection Section I Activity 1: Direct Public Health Laboratory Testing. (Definition: Direct and coordinate local, State, and Federal public health, food testing, veterinary diagnostic, and environmental testing laboratory efforts to a radiological incident). (Criterion 1.e.l: NUREG-0654/FEMA-REP-1, H.7, 10; 1.7, 8, 9; J.10.a, b, e; J. 11, 12; K.3.a; K.5.b), (Criterion 3.a.l: NUREG-0654/FEMA-REP-1, J.10.e; K.3.a, b; K.4), (Criterion 4.c.1: (NUREG-0654/FEMA-REP-1, C.1, 3; J.11).

Exceptions: I

" Radiation Protection Section's mobile laboratory and other field activities will be conducted from the NC National Guard Facility at the Wilmington International Airport.

• Mobile Lab - The Radiation Protection Section will demonstrate the use of the High Purity Germanium (HPGe) Gamma Spectrometer to resolve Area Requiring Corrective Action (ARCA 08-10-4.c.1-A-03) from the McGuire exercise. All other activities will be for training only. I II I

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Unclassified Radiological Emergency Preparedness Program (REP)

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