ML13262A046

FEMA, Submittal of Final Report for the Vermont Yankee Plume and Post Plume Biennial Exercise, Conducted on June 5, 2013

ML13262A046
Person / Time
Site:	Seabrook
Issue date:	09/04/2013
From:	Colman S US Dept of Homeland Security, Federal Emergency Management Agency
To:	Bill Dean NRC Region 1
References
Download: ML13262A046 (233)

Text

U.S. Department of Homeland Security FEMA Rceion I 99 High St. 5For

..Boston, NIA 02110-2320 September 4, 20 13 Mr. Bill Dean Regional Administrator Nuclear Regulatory Commission, Region I 475 Allendale Road King of Prussia. PA 19406-1415

Dear Mr. Dean:

Enclosed is a copy of the Final Report for the Vermont Yankee Plume mid Post Plume Biennial Exercise, conducted on June 5th. 2013.

The Commonwealth of Massachusetts, State of New Hampshire, State of Vermont and local emergency response organizations successfully demonstrated their capabilities to implement their off-site radiological emergency response plans and procedures based on the evaluation of this exercise by a team of Federal evaluators with final determinations made by the Regional Assistance Committee (RAC) Chair.

There were four Areas Requiring Corrective Action (ARCA) as a result of this exercise, two of which were successfully re-demonstrated during the exercise and closed. There were no deficiencies. The two open ARCAs as a result of this exercise occurred at the Vermont State Police Rockingham Dispatch Center and New 1lampshire State Emergency Operations Center.

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

U.S. Deparlment of Homeland Security FEMA Region I

91) High St.. 5"1' Floor Boston. MA 02110-23220 Mr. Bill Deai September 4, 2013 Pane 2 If you have any questions regarding this matter, please contact Ryan Jones of my staff at (617) 8312-4718.

Sincerely,

/Steve L. Colman RAC Chair FEMA, Region I cc: NRC I.eadquarters Document Control Desk Nancy McNamara, Liaison Officer, NRC Region I Enclosure www.fema.gov

Vermont Yankee Power Station After Action Report/

Improvement Plan Exercise Date - June 05, 2013 Radiological Emergency Preparedness (REP) Program

.F..A Published September 04, 2013

Unclassified Radiological Emergency Preparedness Program (REP)

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Vermont Yankee Power Station After Action Report/Improvement Plan Published September 04, 2013 Contents Executive Summary 5 Section 1: Exercise Overview 6 1.1 Exercise Details 6 1.2 Exercise Planning Team Leadership 6 1.3 Participating Organizations 9 Section 2: Exercise Design Summary 15 2.1 Exercise Purpose and Design 15 2.2 Exercise Objectives, Capabilities and Activities 15 2.3 Scenario Summary 15 Section 3: Analysis of Capabilities 16 3.1 Exercise Evaluation and Results 16 3.2 Summary Results of Exercise Evaluation 16 3.3 Criteria Evaluation Summaries 29 3.3.1 Massachusetts Jurisdictions 29 3.3.1.1 Massachusetts State Emergency Operations Center 29 3.3.1.2 MA 211 Call Center 29 3.3.1.3 MA Warning Point - Shelburne 29 3.3.1.4 MA (VY) Emergency Operations Facility 30 3.3.1.5 MA (VY) Joint Information Center 30 3.3.1.6 MA Region III/W EOC 31 3.3.2 Risk Jurisdictions 32 3.3.2.1 Bernardston Local EOC 32 3.3.2.2 Colrain Local EOC 32 3.3.2.3 Gill Local EOC 32 3.3.2.4 Greenfield Local EOC 33 3.3.2.5 Leyden Local EOC 33 1

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 3.3.2.6 Northfield Local EOC 33 3.3.2.7 Warwick Local EOC 34 3.3.3 New Hampshire Jurisdictions 34 3.3.3.1 NH State Emergency Operations Center 34 3.3.3.2 NH 911 Call Center 35 3.3.3.3 NH (VY) Joint Information Center 35 3.3.3.4 NH State Police Troop C, Keene 36 3.3.3.5 NH (VY) Field Monitoring Team-i 37 3.3.3.6 NH (VY) Field Monitoring Team-2 38 3.3.3.7 NH State Warning Point 39 3.3.3.8 NH (VY) Emergency Operations Facility 40 3.3.3.9 NH Cheshire County Sheriffs Dispatch 40 3.3.3.10 WKNE Radio Station 40 3.3.4 Risk Jurisdictions 41 3.3.4.1 Chesterfield Local EOC 41 3.3.4.2 Hinsdale Local EOC 43 3.3.4.3 Richmond Local EOC 43 3.3.4.4 Swanzey Local EOC 43 3.3.4.5 Winchester Local EOC 44 3.3.4.6 DD's Totley Crew 46 3.3.4.7 Immaculate Heart of Mary 46 3.3.4.8 Nanny's Day Care 46 3.3.4.9 Little Imaginative Learners 47 3.3.4.10 Village Children Center 47 3.3.5 Support Jurisdictions 47 3.3.5.1 Southwestern New Hampshire District Fire Mutual 47 Aid Local Warning Point 3.3.5.2 Keene Local EOC 48 3.3.5.3 Keene Reception Center 48 3.3.5.4 First Student Bus Company 49 3.3.6 Vermont Jurisdictions 50 3.3.6.1 Vermont State Emergency Operations Center 50 2

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 3.3.6.2 Vermont EOF 51 3.3.6.3 Vermont Joint Information Center 53 3.3.6.4 VT Plume Tracking Team-i 54 3.3.6.5 VT Plume Tracking Team-2 56 3.3.6.6 Vermont Rockingham State Police 56 3.3.6.7 Vermont Alternate Warning Point 59 3.3.6.8 Vermont 211 Call Center 59 3.3.7 Risk Jurisdictions 61 3.3.7.1 Brattleboro Local EOC 61 3.3.7.2 Dummerston Local EOC 63 3.3.7.3 Guilford Local EOC 64 3.3.7.4 Halifax Local EOC 64 3.3.7.5 Vernon Local EOC 64 3.3.7.6 Academy School 65 3.3.7.7 WSESU Superintendent 65 3.3.7.8 Barbara Gantt 65 3.3.7.9 Brattleboro Union High and Middle School 65 3.3.7.10 ESS/Canal St School 66 3.3.7.11 Doris' Day Care 66 3.3.7.12 Family Garden 66 3.3.7.13 Happy Hands 67 3.3.7.14 Judy's Family Child Care 67 3.3.7.15 Meenama's Learning Center and Child Care 67 3.3.7.16 Miss Martha's homecare 68 3.3.7.17 Vernon Elementary 68 3.3.7.18 Teddy Bear Child Care 68 3.3.7.19 Winston Prouty Early Learning Center 69 Section 4: Conclusion 70 Appendix A: Improvement Plan 71 Appendix B: Exercise Timeline 77 Appendix C: Exercise Evaluators and Team Leaders 83 Appendix D: Exercise Plan 87 3

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After Action Report/Improvement Plan Vermont Yankee Power Station EXECUTIVE

SUMMARY

On June 5th, 2013, the Federal Emergency Management Agency (FEMA), Region I, evaluated an exercise in the plume exposure pathway Emergency Planning Zone (EPZ) around the Vermont Yankee Nuclear Power Station. The purpose of the exercise was to assess the level of state and local preparedness in responding to a radiological emergency. The 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 prior exercise at this site was conducted on May 3rd-4th, 2011 (plume and post plume exposure pathway).

FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Massachusetts, the State of New Hampshire, the State of Vermont, local communities, and private and volunteer organizations that 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. Others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities. All participants demonstrated cooperation and teamwork during this exercise.

Interviews and out-of-sequence demonstrations for schools, other special facilities, and reception, monitoring, and decontamination centers (as outlined in this report) were conducted within 60 days of the exercise. The state and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Deficiencies. There were four Areas Requiring Corrective Action (ARCA), two of which were redemonstrated during the exercise and closed.

There were eight new planning issues.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Vermont Yankee Power Station Type of Exercise Plume Exercise Date June 05, 2013 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Radiological Emergency 1.2 Exercise Planning Team Leadership Donald Carlton Planning Team Member FEMA Region I Tech Hazards Specialist 99 High Street, 5th Floor Boston, Massachusetts, 02110 617-956-7563 donald.carlton@dhs.fema.gov Ingrid Bruns Planning Team Member FEMA Region I Senior Tech Hazards Specialist 99 High Street, 5th Floor 6

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Boston, Massachusetts, 02110 617-956-7641 ingrid.bruns@dhs.gov Ryan Jones Planning Team Member FEMA Region I Tech Hazards Specialist 99 High St Boston, Massachusetts, 02110 671-832-4718 ryan.jones2@fema.dhs.gov Erica Bornemann Planning Team Member Vermont Division of Emergency Management and Homeland Security Planning Section Chief 103 South Main Street Waterbury, Vermont, 05671 800-347-0488 erica.bornemann@state.vt.us John Angil II Planning Team Member Vermont Division of Emergency Management and Homeland Security Radiological Emergency Response Plan Program Manager 230 Main Street Brattleboro, Vermont, 05301 802-251-2172 jangil@dps.state.vt.us Diane Becker Planning Team Member 7

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Division of Homeland Security & Emergency Management, New Hampshire Department of Safety Chief, Technological Hazards Section 110 Smokey Bear Blvd Concord, New Hampshire, 03301 603-271-2231 diane.becker@dos.nh.gov Dave Rodham Planning Team Member Massachusetts Emergency Management Agency Planner 400 Worcester Road Framingham , Massachusetts, 01702 978-328-1505 dave.rodham@state.ma.us Michael McKenney Planning Team Member Entergy Vermont Yankee Emergency Preparedness Manager Vermont Yankee Nuclear Power Station Vernon, Vermont, 05354 802-258-4183 mmckenn@entergy.com Charles H. Dissinger, Jr.

Planning Team Member Entergy Vermont Yankee Senior Emergency Planner Vermont Yankee Nuclear Power Station Vernon, Vermont, 05354 802-258-4134 8

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station cdissin@entergy.com 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Vermont Yankee Power Station exercise:

State Jurisdictions STATE OF VERMONT Vermont 211 Call Center Vermont Agency for Agriculture, Food & Markets Vermont Agency of Natural Resources Vermont Agency of Transportation Vermont Center for Geographic Information Vermont Department of Education Vermont Department of Environmental Conservation Vermont Department of Health Vermont Department of Labor Vermont Division of Fire Safety Vermont Department Emergency Management Vermont Homeland Security Vermont National Guard Vermont Public Safety Vermont State Police STATE OF NEW HAMPSHIRE New Hampshire Department of Agriculture, Market & Food New Hampshire Department of Health and Human Sevices, Child Support Division New Hampshire Department of Health and Human Services, Emergecny Services Unit New Hampshire Department of Health and Human Services, Human Resources New Hampshire Department of Health and Human Services, Spill Response and Complaint New Hampshire Department of Resource and Economic Development New Hampshire Department of Transportion 9

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station New Hampshire Division of Fire Standards and Training and Emergency Medical Services New Hampshire Divsion of State Police New Hampshire E-911 New Hampshire Fire Marshal's Office New Hampshire Fish and Game Department New Hampshire Homeland Security and Emergency Management COMMONWEALTH OF MASSACHUSETTS Massachusetts 211 Call Center Massachusetts Department of Conservation and Recreation Massachusetts Department of Public Health Massachusetts Department of Mental Health Massachusetts Department of Transportation Massachusetts Emergency Management Headquarters (Framingham)

Massachusetts Emergency Management Region III/IV (Agawam)

Massachusetts Environmental Police Massachusetts Executive Office of Health and Human Services Massachusetts National Guard Massachusetts State Police Office of the Secretary of State for the Commonwealth of Massachusetts Risk Jurisdictions STATE OF VERMONT Brattleboro Finance Department Brattleboro Fire Department Brattleboro Police Department Brattleboro Public Works Department Dummerston Communications Unit Dummerston Elementary School Dummerston Emergency Management Dummerston Health Department Dummerston Highway Department Dummerston Board of Selectmen Guilford Constable Guilford Emergency Management 10

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Guilford Highway Department Guilford Board of Selectmen Guilford Volunteer Fire Company Halifax Clerk;s Office Halifax Constable Halifax Elementary School Halifax Emergency Medical Services Halifax Fire Department Halifax Garage Halifax Board of Selectmen Vernon Clerk's Office Vernon Fire Department Vernon Police Department Vernon Board of Selectmen West Dummerston Fire Department Windham County Community Emergency Response Team Windham Southeast Supervisory Union Schools STATE OF NEW HAMPSHIRE Chesterfield Fire Department Chesterfield Highway Department Chesterfield Office of Emergency Management Chesterfield Police Department Chesterfield School District Chesterfield Board of Selectmen Hinsdale Fire Department Hinsdale Highway Department Hinsdale Police Department Hinsdale Board of Selectmen Richmond Emergency Management Richmond Fire Department Richmond Police Department Richmond Rescue Squad Richmond Board of Selectmen Spofford Fire Department 11

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemiont Yankee Power Station Swanzey Communcations Unit Swanzey Emergency Management Swanzey Fire Department Swanzey Police Department Swanzey Public Works Department Swanzey Board of Selectmen Winchester Highway Department Winchester Office of Emergency Management Winchester Police Department Winchester Board of Selectmen Winchester Volunteer Fire Department COMMONWEALTH OF MASSACHUSETTS Agawam Office of Emergency Management Bernardston Board of Health Bernardston Fire Department Bemardson Highway Department Bernardson Police Department Bernardston Board of Selectmen Colrain Ambulance Association Colrain Board of Health Colrain Fire Department Colrain Highway Department Colrain Police Department Colrain Board of Selectmen Franklin County Amateur Radio Club Franklin County Amateur Radio Emergency Services Gill Board of Health Gill Fire Department Gill Highway Department Gill Police Department Gill Board of Selectmen Greenfield Emergency Management Greenfield Police Department Greenfield Health Department 12

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power'Station Greenfield Fire Department and Dispatch Greenfield Department of Public Works Greenfield Mayor's Office Leyden Police Department Leyden Fire Department Leyden Highway Department Leyden Board of Selectmen Northfield Emergency Management Northfield Highway Department Northfield Police Department Northfield Public Health Department Northfield Board of Selectmen Pioneer Valley Regional School District Warwick Elementary School Warwick Emergency Mangement Warwick Fire Department Warwick Highway Department Warwick Police Department Warwic Board of Selectmen Support Jurisdictions STATE OF NEW HAMPSHIRE Cheshire County Sheriffs Office Keene Fire Department Keene Police Department Keene Public Works Department COMMONWEALTH OF MASSACHUSETTS American Red Cross Private Organizations American Red Cross, Massachusetts Bay American Red Cross, Springfield, Massachusetts Public Utility Commison Radio Amatuer Civil Emergency Services Radio Station WKNE United Way of Massachusetts 13

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Vermont Yankee Nuclear Power Plant Federal Jurisdictions Federal Emergency Management Agency United States Food and Drug Administration Unites States Nuclear Regulatory Commission 14

Unclassified Radiological Emergency Preparedness Program (REP)

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

SUMMARY

2.1 Exercise Purpose and Design The purpose of this report is to present the results and findings on the performance of the offsite response organizations (OROs) during a simulated radiological emergency.

FEMA Region I evaluated the June 5, 2013 exercise to assess the capabilities of state and local emergency preparedness organizations in implementing their Radiological Emergency Response Plans (RERPs) and procedures to protect the public health and safety during a radiological emergency involving Vermont Yankee Power Station.

2.2 Exercise Objectives, Capabilities and Activities The exercise objectives, capabilities, and activities are noted in the extent of play agreement, included in Appendix D, Exercise Plan.

2.3 Scenario Summary The exercise scenario was developed to evaluate the response of the exercise participants to a radiological emergency.

The scenario is included in Appendix D, Exercise Plan.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Vermont Yankee Power Station SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results This section contains the results for each location evaluated during this exercise.

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

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

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

A - ARCAs assessed or unresolved ARCAs from previous exercises D - Deficiency assessed P - Plan Issues N - Not Demonstrated Note: Blank fields indicate criterion was not evaluated at that location.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Table 3.1 - Summary of Exercise Evaluation (6 pages)

.2 DATE: 20 13-06-05 "

SITE: Vermont Yankee Power Station, VT 2 C))

M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not 2 1 Demonstrated C_

> F-' >

> H >

H F- >

> [-- >

> H 2

Eme gency Operations Management Mobilization lal M M M M AIM M M M Facilities IbI Direction and Control lcl M M P M M M Communications Equipment Idl M M M M M P M M M M M Equipment and Supplies to Support Operations lei M M M M M M M M M Prdtecfive Action Decision Making%'.

Emergency Worker Exposure Control 2al M Dose Assessment & PARs & PADs for the Emergency Event 2b1 M M Dose Assessment & PARs & PADs for the Emergency Event 2b2 M PADs for the Protection of persons with disabilities and access/functional 2cl M needs Radiological Assessment and Decision-making for the Ingestion Exposure 2dl Pathway Radiological Assessment & Decision-making Concerning Post-Plume Phase 2e]

Relocation, Reentry, and Return Protective Action lImplementation  :'". ....  :

Implementation of Emergency Worker Exposure Control 3al M M M M P M M Implementation of KI Decision for Institutionalized Individuals and the Public 3bl M Implementation of Protective Actions for persons with disabilities and 3cl M M M access/functional needs Implementation of Protective Actions for persons with disabilities and 3c2 M M M M access/functional needs Implementation of Traffic and Access Control 3d] M M M Implementation of Traffic and Access Control 3d2 M M M Implementation of Ingestion Pathway Decisions 3el Implementation of Ingestion Pathway Decisions 3e2 Implementation of Post-Plume Phase Relocation, Reentry, and Return 3f1 Decisions Field Me'asuirememtitnd Analysis .

RESERVED 4a1 M Plume Phase Field Measurement and Analyses 4a2 M Plume Phase Field Measurement and Analyses 4a3 P M Post Plume Phase Field Measurements and Sampling 4b]

Laboratory Operations 4c I Emergency Notification and Public Info ' "

Activation of the Prompt Alert and Notification System 5al M P M M RESERVED 5a2 Activation of the Prompt Alert and Notification System 5a3 Activation of the Prompt Alert and Notification System 5a4 Emergency Information and Instructions for the Public and the Media 5b] M M P M M M S9upp4Operations/Facilities ..

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Monitoring, Decontamination, and Registration of Evacuees 6a 1 Monitoring and Decontamination of Emergency Workers and their Equipment 6bl atId Vehicles Temporary h Care of Evacuees 6ca Transportation and Treatment of Contaminated Injured Individuals 6d]

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 2/6)

DATE: 2013-06-05 SITE: Vermont Yankee Power Station, VT M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not OW- -

Demonstrated n > V > C >

Emergency Operations Management Mobilization ]al M M M M N M M Facilities Ib 1 Direction and Control Icl M M A M M I M Communications Equipment Idl M M M M M M M M M M M Equipment and Supplies to Support Operations lel M M M MI M M M M M M Protective Action Decisiori Making Emergency Worker Exposure Control 2al M Dose Assessment & PARs & PADs for the Emergency Event 2b I M M Dose Assessment & PARs & PADs for the Emergency Event 2b2 M PADs for the Protection of persons with disabilities and access/functional 2cl M needs Radiological Assessment and Decision-making for the Ingestion Exposure 2dI Pathway Radiological Assessment & Decision-making Concerning Post-Plume Phase 2el Relocation, Reentry, and Return Protective Action Implementation*...

Implementation of Emergency Worker Exposure Control 3al M M M P M M M Implementation of K) Decision for Institutionalized Individuals and the Public 3b]

Implementation of Protective Actions for persons with disabilities and 3c M access/functional needs M M Implementation of Protective Actions for persons with disabilities and 3c2 M M access/functional needs Implementation of Traffic and Access Control 3dl M M M M Implementation of Traffic and Access Control 3d2 M M M M Implementation of Ingestion Pathway Decisions 3el Implementation of Ingestion Pathway Decisions 3e2 Implementation of Post-Plume Phase Relocation, Reentry, and Return 3fl Decisions Field Measurement and.Analysis . . . .

RESERVED 4al Plume Phase Field Measurement and Analyses 4a2 M Plume Phase Field Measurement and Analyses 4a3 M M Post Plume Phase Field Measurements and Sampling 4bl Laboratory Operations 4c I Enierge~cyNotificationand iublic'Info . .. **... .

Activation of the Prompt Alert and Notification System 5al M M M M RESERVED 5a2 Activation of the Prompt Alert and Notification System 5a3 Activation of the Prompt Alert and Notification System 5a4 Emergency Information and Instructions for the Public and the Media 5b] M M M M M Support Operations/Facilities Monitoring, Decontamination, and Registration of Evacuees 6al 19

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Monitoring and Decontamination of Emergency Workers and their Equipment 6bl and Vehicles Temporary Care of Evacuees 6cl Transportation and Treatment of Contaminated Injured Individuals 6d]

20

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 3/6) 2 DATE: 2013-06-05 SITE: Vermont Yankee Power Station, VT =

M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not ") - U Demonstrated -_ -

Emergency Operations Management Mobilization ]al M M M M M M M M Facilities IbI Direction and Control 1cl M M IMM M MM M M Communications Equipment Idl M M M M M M M M M M Equipment and Supplies to Support Operations lel M M M M M M M M M M Protective Action Decision Making Emergency Worker Exposure Control 2al M Dose Assessment & PARs & PADs for the Emergency Event 2bl Dose Assessment & PARs & PADs for the Emergency Event 2b2 M PADs for the Protection of persons with disabilities and access/functional 2cl M needs Radiological Assessment and Decision-making for the Ingestion Exposure 22dl Pathway Radiological Assessment & Decision-making Concerning Post-Plume Phase 2el Relocation, Reentry, and Return Protective Action Implementation . .

Implementation of Emergency Worker Exposure Control 3al M M M M M M-Implementation of KI Decision for Institutionalized Individuals and the Public 3bl Implementation of Protective Actions for persons with disabilities and 3cl M M M M M access/functional needs Implementation of Protective Actions for persons with disabilities and 3c2 M M M M M access/functional needs Implementation of Traffic and Access Control 3d] M M M M M N M Implementation of Traffic and Access Control 3d2 M M M M M Implementation of Ingestion Pathway Decisions 3el Implementation of Ingestion Pathway Decisions 3e2 Implementation of Post-Plume Phase Relocation, Reentry, and Return 3fl Decisions Field Measurement and Analysis "  :

RESERVED 4al Plume Phase Field Measurement and Analyses 4a2 Plume Phase Field Measurement and Analyses 4a3 Post Plume Phase Field Measurements and Sampling 4bl Laboratory Operations 4cl Eimergency Notification and Public Info Activation of the Prompt Alert and Notification System 5al M M M M M M M RESERVED 5a2 Activation of the Prompt Alert and Notification System 5a3 Activation of the Prompt Alert and Notification System 5a4 Emergency Information and Instnictions for the Public and the Media 5bl P M M M M M M M Support Operations/Facilities.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Monitoring, Decontamination, and Registration of Evacuees 6al M Monitoring and Decontamination of Emergency Workers and their Equipment 6bl M and Vehicles M Temporary Care of Evacuees 6c 1 Transportation and Treatment of Contaminated Injured Individuals 6dl 22

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 4/6)

DATE: 2013-06-05 o 0

0 00 U SITE: Vermont Yankee Power Station, VT C) U > U WU W0

~- >-0

> 0z W M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not * > > o7 c w a Demonstrated -

Emergency Operations Management Mobilization lal M M M M M M M M M M Facilities 1b]

Direction and Control Icl MI P M M M MIM M M M Communications Equipment Idl M M M.M M M M M M M M Equipment and Supplies to Support Operations lel M M M M M M MIM M M Protective Action Decision Making Emergency Worker Exposure Control 2al Dose Assessment & PARs & PADs for the Emergency Event 2bI M Dose Assessment & PARs & PADs for the Emergency Event 2b2 PADs for the Protection of persons with disabilities and access/functional 2cl needs Radiological Assessment and Decision-making for the Ingestion Exposure 2d]

Pathway Radiological Assessment & Decision-making Concerning Post-Plume Phase 2el Relocation. Reentry, and Return Protective Action lmplementation Implementation of Emergency Worker Exposure Control 3al M M M M M M M M M M Implementation of KI Decision for Institutionalized Individuals and the Public 3bl Implementation of Protective Actions for persons with disabilities and 3cl M M M M M M M access/functional needs Implementation of Protective Actions for persons with disabilities and 3c2 M M M M M M M access/functional needs Implementation of Traffic and Access Control 3dl M M M M M M M M Implementation of Traffic and Access Control 3d2 M M M M M M M M Itnplementation of Ingestion Pathway Decisions 3e1 Implementation of Ingestion Pathway Decisions 3e2 Implementation of Post-Plume Phase Relocation, Reentry, and Return 3f1 Decisions Field Measurement and Analysis RESERVED 4al Plume Phase Field Measurement and Analyses 4a2 M Plume Phase Field Measurement and Analyses 4a3 Post Plume Phase Field Measurements and Sampling 4b1 Laboratory Operations 4c I Emergency Notification and Public Info Activation of the Prompt Alert and Notification System 5al N M M M M M M M RESERVED 5a2 Activation of the Prompt Alert and Notification System 5a3 Activation of the Prompt Alert and Notification System 5a4 Emergency Information and Instructions for the Public and the Media 5b] M M M M M M M M Support Operations/Facilities Monitoring, Decontamination, and Registration of Evacuees 6al Monitoring and Decontamination of Emergency Workers and their Equipment 6b1 and Vehicles 23

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Temporary Care of Evacuees 6c I Transnortation and Treatment of Contaminated Iniured Individuals 24

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemont Yankee Power Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 5/6)

SITE: Vermont DATE:Yankee2013-06-05 Power Station, VT -* "- a, E

= M. U M: Met, A: ARCA, D: Deficiency, P: Plan Issue, N: Not = . -r > -M Mobilization lal M _

Facilities 1b1 Direction and Control Ict Communications Equipment Id1 Equipment and Supplies to Support Operations lel Protective Action Decision Making . . . . . ..

Emergency Worker Exposure Control 2al Dose Assessment & PARs & PADs for the Emergency Event 2bl Dose Assessment & PARs & PADs for the Emergency Event 2b2 PADs for the Protection of persons with disabilities and access/functional needs 2cl Radiological Assessment and Decision-making for the Ingestion Exposure 2dl Pathway Radiological Assessment & Decision-making Concerning Post-Plume Phase 2el Relocation, Reentry, and Return Protective Action Implementation Implementation of Emergency Worker Exposure Control 3al Implementation of KI Decision for Institutionalized Individuals and the Pttblic 3bl M M M M M M M M M Implementation of Protective Actions for persons with disabilities and 3cl access/functional needs Implementation of Protective Actions for persons with disabilities and 3c2 M M M M M M M M M M access/functional needs Implementation of Traffic and Access Control 3d1 Implementation of Traffic and Access Control 3d2 Implementation of Ingestion Pathway Decisions 3el Implementation of Ingestion Pathway Decisions 3e2 Implementation of Post-Plume Phase Relocation, Reentry, and Return Decisions 3fl Field Measurement and Analysis RESERVED 4a 1 Plume Phase Field Measurement and Analyses 4a2 Plume Phase Field Measurement and Analyses 4a3 Post Plume Phase Field Measurements and Sampling 4b]

Laboratory Operations 4c I Emergency Notification and Public Info...

Activation of the Prompt Alert and Notification System 5a]

RESERVED 5a2 Activation of the Prompt Alert and Notification System 5a3 Activation of the Prompt Alert and Notification System 5a4 Emergency Information and Instructions for the Public and the Media 5bl Support Operations/Facilities " ""

Monitoring, Decontamination, and Registration of Evacuees 6al 25

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Monitoring and Decontamination of Emergency Workers and their Equipment 6b]

and Vehicles Temporary Care of Evacuees 6c l Transportation and Treatment of Contaminated Injured Individuals 6dl 26

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 6/6)

DATE: 2013-06-05 E > 0 _j SITE: Vermont Yankee Power Station, VT > .

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

Demonstrated o 5->

Emergency Operations Management Mobilization lal M Facilities IbI Direction and Control Icl M Communications Equipment 1dI M Equipment and Supplies to Support Operations lel M Protecti"Ve Action Decision Making Emergency Worker Exposure Control 2a I Dose Assessment & PARs & PADs for the Emergency Event 2b]

Dose Assessment & PARs & PADs for the Emergency Event 2b2 PADs for the Protection of persons with disabilities and access/functional needs 2c]

Radiological Assessment and Decision-making for the Ingestion Exposure 2dl Pathway Radiological Assessment & Decision-making Concerning Post-Plume Phase 2el Relocation, Reentry, and Return Protective Action imlrinsentation ............ ' " .

Implementation of Emergency Worker Exposure Control 3a IM Implementation of KI Decision for Institutionalized Individuals and the Public 3b] M M M M I M Implementation of Protective Actions for persons with disabilities and 3cl M access/functional needs Implementation of Protective Actions for persons with disabilities and 3c2 MM MMM MM M M M access/functional needs Implementation of Traffic and Access Control 3dl Implementation of Traffic and Access Control 3d2 Implementation of Ingestion Pathway Decisions 3el Implementation of Ingestion Pathway Decisions 3e2 Implementation of Post-Plume Phase Relocation, Reentry, and Return Decisions 3f1 Field Measurement and Analysis . .. .... ,.

RESERVED 4al Plume Phase Field Measurement and Analyses 4a2 Plume Phase Field Measurement and Analyses 4a3 Post Plume Phase Field Measurements and Sampling 4b]

Laboratory Operations 4c I Emergency.Notification. and Public Info . ..

Activation of the Prompt Alert and Notification System 5al RESERVED 5a2 Activation of the Prompt Alert and Notification System 5a3 Activation of the Prompt Alert and Notification System 5a4 Emergency Information and Instructions for the Public and the Media 5bl Support Operations/Facilities Monitoring. Decontamination, and Registration of Evacuees 6al 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Monitoring and Decontamination of Emergency Workers and their Equipment 6b]

and Vehicles Temporary Care of Evacuees 6cl Transportation and Treatment of Contaminated Injured Individuals 6dl 28

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 3.3 Criteria Evaluation Summaries 3.3.1 Massachusetts Jurisdictions 3.3.1.1 Massachusetts State Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.2 MA 211 Call Center In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.3 MA Warning Point - Shelburne In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None 29

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.4 MA (VY) Emergency Operations Facility In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.c.1, 1.d.1, L.e.1,2.b.1, 3.a.l,4.a.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.5 MA (VY) Joint Information Center In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: l.c.l.

ISSUE NO.: 67-13-1cl-P-12 CRITERION: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.

CONDITION: Although the Joint Information Center (JIC) is within the Emergency Planning Zone (EPZ), there are not clear written plans for the evacuation of the JIC.

This issue applies to all three states in the EPZ.

POSSIBLE CAUSE: Although there has been significant discussion among the states about evacuating the JIC, the ideas have not yet been finalized into a viable plan.

REFERENCE:

NUREG 0654/FEMA REP 1 II.G.3.a: Each principal organization shall designate the points of contact and physical locations for use by news media during an emergency.

30

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemiont Yankee Power Station EFFECT: JIC personnel and the media (general public) could be left in an evacuated town in the plume, compromising their health and safety.

RECOMMENDATION: Representatives from the three states and Vermont Yankee Nuclear Power Station should develop a procedure for evacuating the JIC by January 31, 2014. The procedure should cover the following questions:

- When should the media be told to leave the primary JIC, and by whom?

- What is the trigger to evacuate the JIC staff? If they leave during a radiological release, do they go to a monitoring/decontamination center before leaving the area?

- Is the JIC evacuated at same time and on same roads with general public evacuation, and if so, how long will it take?

- What resources are available at the alternate JIC (phones, Internet connections, etc.)? What do the states need to take with them from the primary JIC?

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.6 MA Region III/IV EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: 5.a.I.

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 31

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 3.3.2 Risk Jurisdictions 3.3.2.1 Bernardston Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.2 Colrain Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.3 Gill Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 32

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 3.3.2.4 Greenfield Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.5 Leyden Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.6 Northfield Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 33

Unclassified Radiological Emergency Preparedness Program (REP)

After Actiotý Report/Improvement Plan Vermont Yankee Power Station 3.3.2.7 Warwick Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3 New Hampshire Jurisdictions 3.3.3.1 NH State Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows:

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

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

ISSUE NO.: 67-13-1cl-A-01 CRITERION: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible.

CONDITION: The State of New Hampshire Emergency Operations Center (EOC) placed conflicting weather information in blocks 7 and 8 of their Form 301B EOC Report Numbers 5-8, causing confusion for stakeholders who received them.

For example, Form 301B #005 reported in Block #7 ("Present Meteorological Conditions") a wind speed of 4.18 mph from a wind direction of 216.7 degrees.

Form 301B #006 reported in Block #7 a wind speed of 4.20 mph from a direction of 148.6 degrees and in Block #8 ("Extended Weather Forecast"), reported the Emergency Classification Level rather than the extended weather forecast. Form 301B #007 again reported in Block #7 a wind direction from 148.6 degrees, but Block #8 reported the wind from the southwest.

34

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station POSSIBLE CAUSE: The provision of inconsistent information was possibly caused by a lack of proofreading of the 301B forms before they were posted to webEOC and disseminated to stakeholders.

REFERENCE:

NUREG 0654/FEMA REP-1, A.l.d; A.2.a, b; A.3; C.4, 6 EFFECT: The conflicting information on the forms caused some stakeholders to doubt the validity of the information that they were presented.

RECOMMENDATION: All 301B forms should be more carefully reviewed to ensure accuracy prior to release from the State EOC and distribution to stakeholders.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.2 NH 911 Call Center In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 1.d.1, 1.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 3.3.3.3 NH (VY) Joint Information Center In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None 35

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.4 NH State Police Troop C, Keene In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 3.a.1.

ISSUE NO.: 67-13-3a1-P-08 CRITERION: The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. Appropriate record-keeping of the administration of KI for emergency workers is maintained.

CONDITION: The General Emergency notification was received by Troop C at 1210. At the direction of the Law Enforcement Liason at the New Hampshire (NH)

State Emergency Operations Center (SEOC), the Troop C Assistant Commander directed Troop C personnel to establish and operate assigned Traffic Control Points (TCPs) and Access Control Points (ACPs) at 1210. He did not receive information that a radiological release was in progress. With no information on the status of a release, unless instructions to the contrary were received, the troopers in the field would have coninued to read their dosimetery every 30 minutes instead of every 15 minutes.

POSSIBLE CAUSE: The Assistant Troop C Commander asked the Law Enforcement Liaison at the SEOC at 1330 if she had any information on a release in progress, but the Liaison did not have that information.

36

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station

REFERENCE:

NUREG-0654/FEMA-REP-1: J.10.e; K.3.a, b; K.4 State of New Hampshire, State Emergency Operations Plan, Incident Annex Radiological Emergency Response for Nuclear Facilities. Page 31, II.N. 1.

Attachment A, Implementation Procedures for State Agencies. Page 73, ESF #13 Public Safety and Law Enforcement (Operations Section)

EFFECT: If a radiological release had been in progress without the Troop C's knowledge from the time the TCPs and ACPs were established (1210) until the time the exercise was terminated (1330), the troopers operating the TCPs and ACPs may have been exposed to higher levels of radiation.

RECOMMENDATION: The SEOC Law Enforcement Liaison procedures and job aids should specify that the Troop C Commander should be notified of a radiological release as soon as possible. Other relevant procedures should ensure that the Law Enforcement Liaison receives any information about a radiological release.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.5 NH (VY) Field Monitoring Team-1 In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: L.a. 1.

f. PRIOR ISSUES - RESOLVED: 4.a.3.

ISSUE NO.: 67-11-4a3-P-16 ISSUE: The New Hampshire Field Monitoring Team (NHFMT) equipment includes 37

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemiont Yankee Power Station a SAIC RADeCO Model H809C air sampler. A tag on the air sampler indicates the run time to collect a ten cubic foot air sample at a flow rate of one cubic foot per minute corrected for different temperatures and air pressures. When one of the air samplers was run in the field the flow rate meter was indicating 0.7 cubic foot per minutes and when the operability check was performed on another air sampler the flow rate was almost 1.5 cubic feet per minute. The DPHS Field Team Manual, Chapter Four, Operating Procedures, Section 4.4 Air Sampling, step 9, instructs the team to enter 10 cubic feet as the volume on entry H on form 300V.

CORRECTIVE ACTION DEMONSTRATED: New Hampshire Field Monitoring Teams now use F&J Model DF-AB-406-Li Air Samplers. These samplers are programed to draw a 10 cubic foot sample. Regardless of the flow rate that is achieved, the sampler integrates the volume and stops at the total volume programmed. The equipment and procedure change resolves issue 67-11-4a3-P-16.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.6 NH (VY) Field Monitoring Team-2 In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 4.a.3.

ISSUE NO.: 67-11-4a3-A-15 ISSUE: On multiple occasions the New Hampshire Field Monitoring Teams (NHFMT) demonstrated inadequate knowledge, skill and training related to monitoring and sampling equipment and measurement procedures. On one occasion one of the NHFMT members entered the background exposure rate of the CDV 718A in block I "Background count rate cpm" of the Offsite Sample Log (Form 300V, Vol.

8/Rev. 13). In this case the background of the instrument (Eberline RM-14) used to count air sample filters and cartridges should have been entered. Another member of 38

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station the NHFMT had difficulty establishing the background of the correct instrument after the team was redirected to establish an appropriate background measurement. The individual had the RM-14 turned on but was not seeing any response by the dial. The field team member was then instructed to scale the instrument down from the X 100 setting to X 1 such that a response could be seen and background recorded. At this time, another monitoring team member held both the filter and subsequently the silver zeolite cartridge in his hand while the other member counted the sample.

Toward the end of the exercise, all three radiation detection instruments were brought to the back of the vehicle and the NHFMT members were asked to describe the purposes of each instrument. The FMT I and 2 expressed a fair understating of the CDV 718A, but had difficulty describing what the RM- 14 was used for and had no understanding of the PIC-6B Ion Chamber's use as it pertained to their activities.

CORRECTIVE ACTION DEMONSTRATED: The New Hampshire Field Monitoring Teams demonstrated their ability to perform field measurements and analyses during the June 5, 2013 Vermont Yankee Nuclear Power Station Plume Exercise.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.7 NH State Warning Point In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 39

Unclassified Radiological Emergency Preparedness Program (REP)

After Actiori Report/Improvement Plan 'Vermont Yankee Power Station 3.3.3.8 NH (VY) Emergency Operations Facility In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.9 NH Cheshire County Sheriffs Dispatch In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.10 WKNE Radio Station In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 5.a.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 5.b.1.

ISSUE NO.: 67-13-5bl-P-09 CRITERION: OROs provide accurate emergency information and instructions to the public and news media in a timely manner.

CONDITION: Emergency Public Information (EPI) Message No. 3, the 40

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan ..... Vermont Yankee Power Station supplemental EPI Message to Emergency Alert System (EAS) Message No. 2 (evacuation of Hinsdale and shelter remaining New Hampshire (NH) towns in the Emergency Planning Zone (EPZ)) was not received at the WKNE Radio Station.

Several attempts by WKNE staff to obtain a facsimile copy of EPI Message No. 3 were unsuccessful.

POSSIBLE CAUSE: Section Xiv of Attachment # A to the Radiological Emergency Response for Nuclear Facilities, Implementing Procedures for State Agencies -

ESF#2 (pages 59-63), assigned responsibilities to the State Public Information Officer (PIO). A key responsibility was "Ensure EPI messages forwarded to...Wkne..." (page 61). It did not stipulate "received." That reponsibility should lie with the State PIO in the State EOC.

REFERENCE:

NUREG-0654: E.5,7; G.3.a; G.4.a,c EFFECT: The inability of WKNE to receive and broadcast EPI Message No. 3 following the EAS notification of the decision at the General Emergency to evacuate and shelter in place NH EPZ Towns may have placed those populations at a higher risk than if they had heard the message in a timely manner.

RECOMMENDATION: It is recommended that the SEOC revise that portion of the above reference to clearly assign responsibility to ensure each EPI (and EAS)

Message is both forwarded and received by WKNE.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.4 Risk Jurisdictions 3.3.4.1 Chesterfield Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: 3.a.1.

41

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station ISSUE NO.: 67-13-3al-A-10 CRITERION: The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. Appropriate record-keeping of the administration of KI for emergency workers is maintained.

CONDITION: The Radiological Officer for the town of Chesterfield, NH did not conduct a proper radiological briefing by not following all of the information requirements in the position procedures.

POSSIBLE CAUSE: The Radiological Officer may not have reviewed the procedures prior to delivering the briefing.

REFERENCE:

New Hampshire - Implementing Procedures for EPZ Communities (Attachment B); sections VI, F2, H; Town of Chesterfield, NH, Radiological Emergency Response for Nuclear Facilities Plan, December 2012,Section I Plan 8, 9.3, Figure 9, Attachment K - RADEF Officer; RADEF Job Aid EFFECT: By not following the printed script, one could miss important information that an emergency worker may need to ensure his or her own safety.

CORRECTIVE ACTION DEMONSTRATED: This criteria was re-demonstrated; The controller re-trained the Radiological Officer and the Radiological Officer correctly demonstrated the briefing to an emergency worker.

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 42

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 3.3.4.2 Hinsdale Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.4.3 Richmond Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

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

ISSUE NO.: 67-11-lcl-P-18 ISSUE: The Richmond EOC used outdated plans and procedures (REV 13).

CORRECTIVE ACTION DEMONSTRATED: The EMD, Chairman, and Fire Chief were well-trained and knowledgeable of the Town plans and implementing procedures for their positions. Each position had a binder with current position checklists and copies of the Town of Richmond NH Radiological Emergency Response for Nuclear Facilities Plan dated March, 2013 were available (and used) for reference and review. This resolves previous PLAN ISSUE NO.: 67-11-Icl-P-18.

g. PRIOR ISSUES - UNRESOLVED: None 43

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 3.3.4.4 Swanzey Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 3.d.1.

ISSUE NO.: 67-11-3dl-P-19 ISSUE: Swanzey Traffic Control procedures (Section 3.7 of Vol. 17/Rev 14) are inaccurate and conflicting.

CORRECTIVE ACTION DEMONSTRATED: This issue was corrected during the June 5, 2013 exercise.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.4.5 Winchester Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: 3.a.1.

ISSUE NO.: 67-13-3al-A-1 1 CRITERION: The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. Appropriate record-keeping of the administration of KI for emergency workers is maintained.

CONDITION: During the issuance of the 0-200mR Direct-reading Dosimeter (DRD) 44

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station to an Emergency Worker, the dosimeter was not properly zeroed and recorded properly on the Form 305A - Dosimetry - KI Report Form. The dosimeter read 3mR at issuance, and was recorded as 0.

POSSIBLE CAUSE: The Emergency Worker did not verify the dosimeter reading as required by the procedures.

REFERENCE:

NUREG Criterion K.3.a - "Each organization shall make provisions for distribution of dosimeters, both self-reading and permanent record devices."

REP Program Manual Dated April 2012, Criterion 1.e. 1 - "Direct-reading dosimeters must be zeroed or operationally checked prior to issuance."

Radiological Emergency Response for Nuclear Facilities, Attachment #B Implementing Procedures for EPZ Communities dated April 2011, Pages 78 and 79, Paragraph 3.3-3.5, the dosimeter has to be recharged (zeroed) and entered in the BEFORE block of the form.

EFFECT: The purpose of exposure control and use of dosimetry is to protect emergency workers (EWs) by restricting their exposure to radioactive materials.

Exposure is based on the total risk to exposed individuals to help determine Total Dose Equivalent (TEDE). The non-zeroed dosimeter could have added to the TEDE erroneously for that individual. Recording of incorrect readings and determination of a possible higher threshold exposure level may have led the supervisor to exclude the EW from further activity in the EPZ.

CORRECTIVE ACTION DEMONSTRATED: The RADEF Officer was informed of the error in following the procedures. He then asked the controller to re-demonstrate the entire dosimeter issuance process. The RADEF Officer tried to re-zero the dosimeter in question two times and was unsuccessful. The faulty dosimeter was replaced with a new, properly zeroed 0-200mR dosimeter and the 305A form was re-done and the emergency worker verified the reading as required. This corrected the previous issue and the activities described in the demonstration criterion were carried out in accordance with the plans, procedures, and extent-of-play.

45

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemiont Yankee Power Station

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.4.6 DD's Totley Crew In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.4.7 Immaculate Heart of Mary In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.4.8 Nanny's Day Care In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None 46

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power-Station

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.4.9 Little Imaginative Learners In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.4.10 Village Children Center In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.5 Support Jurisdictions 3.3.5.1 Southwestern New Hampshire District Fire Mutual Aid Local Warning Point In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None 47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.5.2 Keene Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.5.3 Keene Reception Center In summary, the status of DHS/FEMA criteria for this location is as follows:

a. M ET: 1.a.1, 1.c.1, 1.d.1, 1.e.1, 3.a.1, 6.a.1, 6.b.1.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: 3.d.1.

f. PRIOR ISSUES - RESOLVED: 6.a.1, 6.b.1.

ISSUE NO.: 67-05-6a1-A-17 ISSUE: Dosimetry briefings provided to male and female emergency workers at the Keene reception Center did not provide additional information about female workers making a declaration if they were or not pregnant.

CORRECTIVE ACTION DEMONSTRATED: The dosimetry briefing was complete during the April 26, 2013 Keene Reception Center exercise.

ISSUE NO.: 67-05-6aI-A- 18 48

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station ISSUE: After many attempts to check all the sensors, the portal monitor was not working properly. The portal monitor, TSA model TPM 703, ID# 703012, was declared inoperable.

CORRECTIVE ACTION DEMONSTRATED: This issue was resolved during the Keene Reception Center Graded Exercise held on April 26th, 2013.

ISSUE NO.: 67-05-6a1-A-19 ISSUE: A guide was stationed at the entrance doors handing each evacuee a public letter describing the process and that each person should shower within the next two or three days. This letter should have been a State form 102A. However, those forms were in short supply, so the guide issued State form 103A as well. State form 103A was to be distributed by the secondary monitoring team when an evacuee was determined to be contaminated above the 300 cpm level established by the plans.

CORRECTIVE ACTION DEMONSTRATED: The appropriate forms were distributed during the April 26, 2013 Keene Reception Center exercise.

ISSUE NO.: 67-05-6b1-A-20 ISSUE: Vehicles in which contaminated individuals traveled may not be checked for contamination or decontaminated if necessary.

CORRECTIVE ACTION DEMONSTRATED: This issue was resolved during the April 26, 2013 Keene Reception Center exercise through demonstration of a proper vehicle monitoring process.

g. PRIOR ISSUES - UNRESOLVED: None 49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 3.3.5.4 First Student Bus Company In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.6 Vermont Jurisdictions 3.3.6.1 Vermont State Emergency Operations Center In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 2.b.2.

ISSUE NO.: 67-11-2b2-P-02 ISSUE: At the Site Area Emergency the Vermont State EOC Manager, upon advice from the Senior State EOC Staff, reached a decision to initiate a precautionary evacuation at 1041. This was 14 minutes prior to the Emergency Alert System (EAS) activation at 1056. The Vermont Risk Communities in the Emergency Planning Zone (EPZ) responsible for local traffic and access control were given from 6 - 12 minutes notice prior to release of the EAS message to EAS radio broadcasters. This timing may not have allowed sufficient time to ensure all required personnel were mobilized, briefed and equipped and had adequate time to travel to and set up at local Traffic and Access Control Points (TACPs) as required by their local plans and procedures. Arrangements for dealing with potential impediments to evacuation were also not implemented prior to the onset of the evacuation.

50

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station CORRECTIVE ACTION DEMONSTRATED: During the Vermont Yankee Exercise on June 5, 2013 the Decision Makers Group at the Vermont State EOC demonstrated attention to the need for time and resources to set up the Traffic and Access Control Points to support the evacuation decision. They asked the representatives from State Police and the Department of Transportation for their input and if there were any issues associated with the Traffic Management Plan.

Earlier in the exercise the Town of Vernon had made the decision to evacuate. The State Police supported that decision with access control points on Interstate 91. The remaining 5 towns in the 10 mile emergency planning zone were informed over the radio of the evacuation decisions about 40 minutes prior to the release of the EAS message to the general public. This would provide them with time to implement local traffic control points. The State Police person responsible for implementing Traffic and Access Control Points on Interstate 91 described how the resources to support the evacuation would be staged using two shifts per day with 30 Troopers.

Inter-state traffic flow was coordinated with the Massachusetts State Police.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.6.2 Vermont EOF In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 3.b.1.

ISSUE NO.: 67-11-3bl-P-03 ISSUE: State of Vermont staff located at the Emergency Operations Facility (EOF) did not demonstrate the capability to maintain documentation of which Vermont individuals located in the EOF ingested Potassium Iodide (KI). After ingesting KI once authorization was received the staff did not record the ingestion on any records or make notification of administration.

51

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station CORRECTIVE ACTION DEMONSTRATED: A new document was implemented for the documentation of Potassium Iodide (KI) ingestion by emergency workers, including those in the Emergency Operations Facility. This document, the Emergency Worker Information Sheet and Radiation Exposure Record, provides an area for the documentation of KI ingestion including the date, time and dosage taken.

During this exercise once KI ingestion was authorized the Vermont EOF staff documented their ingestion in accordance with this document. The Vermont Emergency Management Liaison verified that KI had been ingested and documented on the Emergency Worker Information Sheet and Radiation Exposure Record.

ISSUE NO.: 67-11-3b1-P-04 ISSUE: Procedural guidance in the Radiological Plume Tracking Teams, Plume Tracking Team Director, IP- 1 states "Ensure that team members have self administered KI at least thirty (30) minutes before arrival near a potential plume or actual radiological plume. During the exercise the Dose Assessment staff and the Radiological Health Advisor instructed the Plume Tracking Team Director (PTTD) to dispatch the teams to obtain radiological measurements and air samples due to the release that had occurred. This was to be done even though 30 minutes had not passed since the ingestion of KI by the Plume Tracking Teams had occurred.

CORRECTIVE ACTION DEMONSTRATED: The requirement in the Radiological Plume Tracking Team Director Implementing Procedure IP- 1 that states "Ensure that team members have self administered KI at least thirty (30) minutes before arrival near a potential plume or actual radiological plume" has been deleted. The statement in the Radiological Advisor Implementing Procedure remains unchanged and will be policy used for determining Potassium Iodide use for emergency workers in Vermont. This procedure states that during a General Emergency the Radiological Health Advisor should consider "Ensuring emergency workers are instructed to ingest KI prior to exposure to the plume, where best performance is provided with KI dosing 30 minutes before exposure and KI dosing up to three hours after exposure to the plume". The Plume Tracking Team Director was interviewed about this change and stated that he understood the policy as stated above.

52

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station

g. PRIOR ISSUES - UNRESOLVED: None 3.3.6.3 Vermont Joint Information Center In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: 1.c. 1.

ISSUE NO.: 67-11-Icl-P-05 ISSUE: The Vermont Yankee Joint Information Center (JIC) plan does not include detailed information in several important areas.

The plans for the Vermont JIC staff consist of 6 pages of checklists; 2 pages each for 3 positions. The majority of information in these checklists is redundant and basic.

There is no infornation that addresses the tasks and responsibilities that are traditionally accomplished by the JIC.

The plan does not contain specific instructions for how to evacuate and relocate the JIC if necessary, even though it is located within the 10-mile Emergency Planning Zone (EPZ). During the exercise, the town was evacuated and the Vermont JIC staff had discussions regarding their safety and on when they were supposed to evacuate.

The plan states that the JIC is "not a hardened facility and may have to be evacuated if downwind from radiological release." However, there is no direction for the staff other than, "If conditions mandate an evacuation of the Joint Information Center, follow evacuation instructions and relocate to pre-determined location. Simply transport selves and computers." While other portions of the VT plan states the location of the alternate facility, there is no information on where the evacuation instructions will come from, at what point the decision will be made and who will make the decision. There is also no information on whether the staff should report to 53

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station a monitoring/decontamination center upon leaving the EPZ.

There is no plans regarding distribution, reading or recording of dosimeters. The JIC checklists state that personnel should "obtain dosimeter if not contained in 'go kit"'.

There is no information on where additional dosimeters should be obtained.

There was no procedural guidance as to what JIC personnel are to do in the event their dosimeters showed a received dose. The informational card located in the dosimetry kits indicated that at a reading of 1 R, persons should contact their agency.

However, staff was unsure what that meant and whom to contact. Upon questioning, the staff called the State Emergency Operations Center (EOC), who stated they were unsure and to try Department of Health. Upon calling the Department of Health, who was also unsure of direction to give, the JIC staff was then given the name and number of a person at the EOF. At this point, more than 30 minutes later, she added the name to the informational white board in the work room, and stated she was told that if she had an "immediate concern" that she should contact this person.

Lastly, the VT plan dated February 17, 2011, Logistics Section Chief Attachment lists "Radiological Instruments Potassium Iodide and Other Supplies". However, under "If there is a need for additional Potassium Iodide, the following is a list of likely sources: "- no list follows this statement. Plans also do not designate a spokesperson.

REASON UNRESOLVED: The currently available PUBLIC INFORMATION OFFICE (SSF-14)-JIC REPRESENTATIVE- ALL HAZARDS IMPLEMENTING PROCEDURE has not been revised and was dated April 2011. For this reason, prior planning issue No. 67-1 1-1clP-05 has not been resolved.

3.3.6.4 VT Plume Tracking Team-1 In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None 54

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station

c. DEFICIENCY: None

d. PLAN ISSUES: 4.a.3.

ISSUE NO.: 67-13-4a3-P-05 CRITERION: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will move to an appropriate low-background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media.

CONDITION: When collecting an air sample in the field, the sample flow rate for the Vermont Plume Tracking Team 1 air sampler was 25 % lower than when the operational check was performed.

POSSIBLE CAUSE: TheVermont Plume Tracking Team procedure required an operational check of their air sampler and calculation of a sample run time based on required detection sensitivity. During the pre-operational check the flow rate was 2 cubic feet per minute (cfm). During air sample collection in the field, the flow rate was 1.5 cfm. The sample run time was not modified to compensate for the lower flow rate. The procedure does not require the team check the flow rate each time they collect a sample to ensure that it is not different than the operational check flow rate.

REFERENCE:

NUREG 0654,1.9 Radiological Emergency Response Procedure, Radiological Plume Tracking Teams, Plume Tracking Team Members, IP-2 EFFECT: If the flow rate is different than during the operational check, the run time must be modified to ensure an appropriate run time and volume of air is collected. If the field flow rate is different, the iodine airborne activity calculation will be incorrect. The volume of air collected must allow field detection capability of 1E-7 microcuries/cc of radioactive iodine.

RECOMMENDATION: Revise the Plume Tracking Team procedure to require the 55

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station team to check the air sampler flow rate each time they start an air sample. If the flow rate is different than previously determined, include direction to calculate a new sample run time or contact the Plume Tracking Team Director.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.6.5 VT Plume Tracking Team-2 In summary, the status of DHS/FEMA criteria for this location is as follows:

a. M ET: 1.a. 1, 1.d. 1, 1.e. 1, 3.a. 1, 4.a.1, 4.a.3.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 4.a. 1.

ISSUE NO.: 67-11-4al-P-07 ISSUE: The Vermont Plume Tracking Team procedure does not include a method for source checking the Ludlum Model 14C high range detector prior to entering a radiation field where the high range detector must be used.

CORRECTIVE ACTION DEMONSTRATED: The Ludlum Model 14C is no longer used by the Vermont Plume Tracking Teams and has been replaced by the Thermo Scientific RadEye B20-ER with an operational range up to 10 Roentgen/hr. The Plume Tracking Teams have an appropriate procedure for operational check of the RadEye B20-ER using a Cesium-137 checksource. This resolves the prior issue number: 67-11-4a1-P-07.

g. PRIOR ISSUES - UNRESOLVED: None 56

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Vermont Yankee Power Station 3.3.6.6 Vermont Rockingham State Police In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: None

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

ISSUE NO.: 67-13-1al-A-02 CRITERION: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner.

CONDITION: The Dispatcher at the Rockingham State Warning Point marked the second Vermont Yankee Power Station (VYPS) Emergency Notification Form as an Unusual Event (UE) Emergency Classification Level (ECL) instead of an Alert ECL.

No authentication call back to VYPS was observed. Also, while a fax was sent by VYPS, no comparison against the completed form was made. This resulted in an inaccurate classification message being sent out.

The message indicating an UE was sent near simultaneously with other notifications indicating an Alert.

POSSIBLE CAUSE: Equipment problems with getting the initial notifications out caused some frustration at this location. This may have caused distraction, contributing to providing the incorrect information.

REFERENCE:

NUREG- 0654/FEMA-REP-1, Rev. 1, F.L.e, Emergency Communications EFFECT: The inaccurate message at the Alert had the potential to delay activation of the State and local Emergency Operations Centers. Within the exercise, it resulted in some confusion as to the current Emergency Classification Level.

RECOMMENDATION: Review with Dispatchers the need to authenticate messages and to review completed messages against the messages faxed by VYPS.

57

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan .... .Vermont Yankee Power Station

c. DEFICIENCY: None

d. PLAN ISSUES: l.d.1.

ISSUE NO.: 67-13-ldl-P-03 CRITERION: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations.

CONDITION: There were problems with the equipment and procedures for the Department of Public Safety Voice Mail System. At 0836, the Dispatcher attempted to record an Unusual Event (UE) Emergency Classification Level (ECL) message on the Voice Mail System. The password appeared to be wrong. According to the Dispatcher, the steps in the procedures were wrong or inadequate. The Dispatcher was locked out of the Voice Mail System and the System Administrator had to be contacted to reset the system. At 0851, the Dispatcher tried again to record a message, but the message did not save on the system. The Dispatcher appeared to select Vermont Emergency Management staff and Vermont Yankee (VY) state groups, individually, and send out a page. The Dispatcher stated the system was not allowing selection of multiple groups. Despite these challenges, VEM staff followed established plans, policies and procedures that detailed built-in planning redundancies and transferred notification responsibilities to the designated alternate site in Derby.

POSSIBLE CAUSE: The cause appeared to be an equipment malfunction or an outdated or inadequate procedure.

REFERENCE:

NUREG- 0654/FEMA-REP-1, Rev. 1, F. .e, Emergency Communications and H.4, Emergency facilities and Equipment EFFECT: The failure of the Voice Mail System resulted in delayed notification of emergency response personnel and delayed activation of emergency response facilities.

58

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station RECOMMENDATION: Investigate the cause of the failure. Revise the procedures to ensure the problem does not recur.

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.6.7 Vermont Alternate Warning Point In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.6.8 Vermont 211 Call Center In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 5.b.1.

ISSUE NO.: 67-13-5bl-P-04 CRITERION: OROs provide accurate emergency information and instructions to the public and news media in a timely manner.

CONDITION: The conflicting terms "reception centers" and "host schools" were both used interchangeably during the exercise. At 1049 the 211 Call Center personnel received notification from the Vermont State Emergency Operations Center (SEOC) that a "precautionary transfer of school children" had been 59

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/hi*provement Plan Vermont Yankee Power Station implemented for all schools within the Emergency Planning Zone (EPZ). However, the notification did not include the destination locations for the school children.

From 1049 until 1131, call center personnel told callers that school students were being transferred to "reception centers". At 1131, the SEOC notified the call center that school students were being transferred to "host schools". From 1131 until the conclusion of the exercise, call center personnel told callers that school students were being transferred to (designated) "host schools". Section 12A(1)(b)of the State of Vermont Emergency Operations Plan, Incident Annex 9A, Vermont Radiological Emergency Response Plan states that school children are transferred to the "Bellows Falls Union High School Reception Center, or other previously identified location, as appropriate." However, page 12 of the PIB states that "school children inside the EPZ will be moved to host facilities outside the EPZ." The area of concern is that the use of the conflicting terms of "reception centers" and "host schools" (or facilities) may cause confusion for parents or guardians of school children about the destination of those school children in the event of an evacuation.

POSSIBLE CAUSE: The terminology "host school" and "reception center" in the plans is not consistent.

REFERENCE:

Section 12A(l)(b)of the State of Vermont Emergency Operations Plan, Incident Annex 9A, Vermont Radiological Emergency Response Plan states that school children are transferred to the "Bellows Falls Union High School Reception Center, or other previously identified location, as appropriate." However, page 12 of the PIB states that "school children inside the EPZ will be moved to host facilities outside the EPZ."

EFFECT: Conflicting terminology may cause confusion for parents or guardians of school children about the destination of those school children in the event of an evacuation.

RECOMMENDATION: Update plans so that terminology is consistent. Provide training so staff understand the difference between a host school and a reception center.

60

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7 Risk Jurisdictions 3.3.7.1 Brattleboro Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: 3.a.1, 5.a.l.

ISSUE NO.: 67-13-3al-P-06 CRITERION: The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. Appropriate record-keeping of the administration of KI for emergency workers is maintained.

CONDITION: The current version of the Town of Brattleboro Implementing Procedure 8, Supply Unit/ Radiological Officer provides for the use of CDV-715 and CDV-700 survey meters to monitor radiological conditions inside and outside of the Brattleboro Emergency Operations Center. The procedures provide instruction for establishing a background reading but do not provide for a threshold value to trigger an action, or explain the purpose of taking readings.

POSSIBLE CAUSE: Incomplete procedures.

REFERENCE:

NUREG-0654/FEMA-REP-1, J.10.e; K.3.a, b; K.4 EFFECT: Potential for confusion for Emergency Workers located at the Brattleboro Emergency Operations Center.

61

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Vermont Yankee Power Station RECOMMENDATION: Revise the procedures to clearly explain the purpose of using survey meters at a local emergency operations center, and include all relevant information necessary for Emergency Workers. Provide additional training on the purpose of monitoring.

ISSUE NO.: 67-13-5al-P-07 CRITERION: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current REP guidance.

CONDITION: During the exercise, there was confusion over who had primary responsibility for sounding the sirens in the Town of Brattleboro. The Town sounded the sirens during the exercise even though the State did not expect them to do so.

POSSIBLE CAUSE: There appeared to be conflicting information in the Town and State plans regarding activation of the sirens. There may have been miscommunication between the State Emergency Operations Center (EOC) and local EOC regarding siren sounding.

REFERENCE:

NUREG-0654/FEMA-REP-1, E.5, 6, 7 Vermont State and Local Radiological Emergency Response Plans EFFECT: Confusion over the responsibility for sounding sirens could lead to incorrect siren sounding, causing confusion for the general public.

RECOMMENDATION: Review call down procedures to include a call down to verify coordination efforts between the State of Vermont and the Town of Brattleboro in the proper sequence of alert and notification. Ensure plans are clear on who has primary responsibility for sounding sirens.

62

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 3.c.2.

ISSUE NO.: 67-11-3c2-A-09 ISSUE: Windham Southeast Supervisory Union representatives did not stay informed about certain important exercise details, such as the wind direction and evacuation decisions.

In addition, lack of communication of school decisions to the rest of the EOC caused disorder surrounding those decisions. As a result, the Joint Information Center (JIC) issued confusing information concerning the evacuation of schoolchildren. This caused questions as to why parents (i.e., the general public) were told to go to reception centers in opposite directions to where school children were sent.

Clarifying information on the actual location of school children was not confirmed until 1300, several hours after the initial media briefing at 0954 concerning the evacuation of school children.

CORRECTIVE ACTION DEMONSTRATED: The School Superintendent's Representative (SSR) at the Brattleboro EOC was fully engaged in implementing Protective Action Decisions (PADs) for schools. He used the school radio system and telephone to communicate with the School Superintendent, the bus contractor, the State EOC, and verbally with the EOC staff.

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7.2 Dummerston Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None 63

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7.3 Guilford Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7.4 Halifax Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7.5 Vernon Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 64

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee"PowerStation 3.3.7.6 Academy School In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7.7 WSESU Superintendent In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: 3.c.2.

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7.8 Barbara Gantt In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 65

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan 'Vermont Yankee Power Station 3.3.7.9 Brattleboro Union High and Middle School In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7.10 ESS/Canal St School In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7.11 Doris' Day Care In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 66

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemlont Yankee Power Station 3.3.7.12 Family Garden In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7.13 Happy Hands In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7.14 Judy's Family Child Care In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 67

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 3.3.7.15 Meenama's Learning Center and Child Care In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7.16 Miss Martha's homecare In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7.17 Vernon Elementary In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 68

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 3.3.7.18 Teddy Bear Child Care In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.7.19 Winston Prouty Early Learning Center In summary, the status of DHS/FEMA criteria for this location is as follows:

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

b. AREAS REQUIRING CORRECTIVE ACTION: None

c. DEFICIENCY: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 69

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/hmprovement Plan Vermont Yankee Power Station SECTION 4: CONCLUSION The state and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them. There were no Deficiencies. There were four Areas Requiring Corrective Action (ARCA), two of which were redemonstrated during the exercise and closed. There were eight new planning issues.

70

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station APPENDIX A: IMPROVEMENT PLAN IIsu Numer 671-a -- 6C itein a ISSUE: The current version of the Town of Brattleboro implementing Procedure 8, Supply Unit/ Radiological Officer provides for the use of CDV-715 and CDV-700 survey meters to monitor radiological conditions inside and outside of the Brattleboro Emergency Operations Center. The procedures provide instruction for establishing a background reading but do not provide for a threshold value to trigger an action, or explain the purpose of taking readings.

RECOMMENDATION: Revise the procedures to clearly explain the purpose of using survey meters at a local emergency operations center, and include all relevant information necessary for Emergency Workers. Provide additional training on the purpose of monitoring.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

I' NuIsu br 671-a- 7C itein a ISSUE: During the exercise, there was confusion over who had primary responsibility for sounding the sirens in the Town of Brattleboro. The Town sounded the sirens during the exercise even though the State did not expect them to do so.

RECOMMENDATION: Review call down procedures to include a call down to verify coordination efforts between the State of Vermont and the Town of Brattleboro in the proper sequence of alert and notification. Ensure plans are clear on who has primary responsibility for sounding sirens.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

71

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station liss Numer 671-elP1 Crtrin l ISSUE: Although the Joint Information Center (JIG) is within the Emergency Planning Zone (EPZ), there are not clear written plans for the evacuation of the JIC. This issue applies to all three states in the EPZ.

RECOMMENDATION: Representatives from the three states and Vennont Yankee Nuclear Power Station should develop a procedure for evacuating the JIC by January 31, 2014. The procedure should cover the following questions:

- When should the media be told to leave the primary JIC, and by whom?

- What is the trigger to evacuate the JIC staff? If they leave during a radiological release, do they go to a monitoring/decontamination center before leaving the area?

- Is the JIC evacuated at same time and on same roads with general public evacuation, and if so, how long will it take?

- What resources are available at the alternate JIC (phones., Internet connections, etc.)? What do the states need to take with them from the primary JIC?

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

I. NuIsu br 671- Il--1C iein I d ISSUE: The State of New Hampshire Emergency Operations Center (EOC) placed conflicting weather information in blocks 7 and 8 of their Form 301B EOC Report Numbers 5-8, causing confusion for stakeholders who received them.

For example, Form 301B #005 reported in Block #7 ("Present Meteorological Conditions") a wind speed of 4.18 mph from a wind direction of 216.7 degrees. Form 301B #006 reported in Block #7 a wind speed of 4.20 mph from a direction of 148.6 degrees and in Block #8 ("Extended Weather Forecast"), reported the Emergency Classification Level rather than the extended weather forecast. Form 301B #007 again reported in Block #7 a wind direction from 148.6 degrees, but Block #8 reported the wind from the southwest.

RECOMMENDATION: All 301B fonns should be more carefully reviewed to ensure accuracy prior to release from the State EOC and distribution to stakeholders.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

72

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan . Vermont Yankee 'Power Station I Isu Nu br riein *133]P0 a ISSUE: The General Emergency notification was received by Troop C at 1210. At the direction of the Law Enforcement Liason at the New Hampshire (NH) State Emergency Operations Center (SEOC), the Troop C Assistant Commander directed Troop C personnel to establish and operate assigned Traffic Control Points (TCPs) and Access Control Points (ACPs) at 1210. He did not receive information that a radiological release was in progress. With no information on the status of a release, unless instructions to the contrary were received, the troopers in the field would have coninued to read their dosimetery every 30 minutes instead of every 15 minutes.

RECOMMENDATION: The SEOC Law Enforcement Liaison procedures and job aids should specify that the Troop C Commander should be notified of a radiological release as soon as possible. Other relevant procedures should ensure that the Law Enforcement Liaison receives any information about a radiological release.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

IIsu Nu br 671- al--2C itein ISSUE: The Dispatcher at the Rockingham State Warning Point marked the second Vermont Yankee Power . :.

Station (VYPS) Emergency Notification Form as an Unusual Event (UE) Emergency Classification Level (ECL) instead of an Alert ECL. No authentication call back to VYPS was observed. Also, while a fax was sent by VYPS,.

no comparison against the completed form was made. This resulted in an inaccurate classification message being-sent out.

The message indicating an UE was sent near simultaneously with other notifications indicating an Alert.

RECOMMENDATION: Review with Dispatchers the need to authenticate messages and to review completed messages against the messages faxed by VYPS.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

73

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Issue Numer 6713Id-3Cieon 'Id ISSUE: There were problems with the equipment and procedures for the Department of Public Safety Voice Mail System. At 0836, the Dispatcher attempted to record an Unusual Event (UE) Emergency Classification Level (ECL) message on the Voice Mail System. The password appeared to be wrong. According to the Dispatcher, the steps in the procedures were wrong or inadequate. The Dispatcher was locked out of the Voice Mail System and the System Administrator had to be contacted to reset the system. At 0851, the Dispatcher tried again to record a message, but the message did not save on the system. The Dispatcher appeared to select Vermont Emergency Management staff and Vermont Yankee (VY) state groups, individually, and send out a page. The Dispatcher stated the system was not allowing selection of multiple groups. Despite these challenges, VEM staff followed established plans, policies and procedures that detailed built-in planning redundancies and transferred notification responsibilities to the designated alternate site in Derby.

RECOMMENDATION: Investigate the cause of the failure. Revise the procedures to ensure the problem does not recur.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: P RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

II ssu br 671-b.P0 Nu C itein ISSUE: The conflicting terms "reception centers" and "host schools" were both used interchangeably during the exercise. At 1049 the 211 Call Center personnel received notification from the Vermont State Emergency Operations Center (SEOC) that a "precautionary transfer of school children" had been implemented for all schools within the Emergency Planning Zone (EPZ). However, the notification did not include the destination locations for the school children. From 1049 until 1131, call center personnel told callers that school students were being transferred to "reception centers". At 1131, the SEOC notified the call center that school students were being transferred to "host schools". From 1131 until the conclusion of the exercise, call center personnel told callers that school students were being transferred to (designated) "host schools". Section 12A(l)(b)of the State of Vermont Emergency Operations Plan, Incident Annex 9A, Vermont Radiological Emergency Response Plan states that school children are transferred to the "Bellows Falls Union High School Reception Center, or other previously identified location, as appropriate." However, page 12 of the PIB states that "school children inside the EPZ will be moved to host facilities outside the EPZ." The area of concern is that the use of the conflicting terms of "reception centers" and "host schools" (or facilities) may cause confusion for parents or guardians of school children about the destination of those school children in the event of an evacuation.

RECOMMENDATION: Update plans so that terminology is consistent. Provide training so staff understand the difference between a host school and a reception center.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

74

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station I

IIssu Nu b r:67-1 I ',l- ,i o I 1' ISSUE: The Vermont Yankee Joint Information Center (JIG) plan does not include detailed information in several important areas.

The plans for the Vermont JIC staff consist of 6 pages of checklists; 2 pages each for 3 positions. The majority of information in these checklists is redundant and basic. There is no information that addresses the tasks and responsibilities that are traditionally accomplished by the JIC.

The plan does not contain specific instructions for how to evacuate and relocate the JIC if necessary, even though it is located within the 10-mile Emergency Planning Zone (EPZ). During the exercise, the town was evacuated and the Vermont JIC staff had discussions regarding their safety and on when they were supposed to evacuate. The plan states that the JIC is "not a hardened facility and may have to be evacuated if downwind from radiological release."

However, there is no direction for the staff other than, "If conditions mandate an evacuation of the Joint Information Center, follow evacuation instructions and relocate to pre-determined location. Simply transport selves and computers." While other portions of the VT plan states the location of the alternate facility, there is no information on where the evacuation instructions will come from, at what point the decision will be made and who will make the decision. There is also no information on whether the staff should report to a monitoring/decontamination center upon leaving the EPZ.

There is no plans regarding distribution, reading or recording of dosimeters. The JIC checklists state that personnel should "obtain dosimeter if not contained in 'go kit"'. There is no information on where additional dosimeters should be obtained.

There was no procedural guidance as to what JIC personnel are to do in the event their dosimeters showed a received dose. The infornational card located in the dosimetry kits indicated that at a reading of I R, persons should contact their agency. However, 'staff was unsure what that meant and whom to contact. Upon questioning, the staff called the State Emergency Operations Center (EOC), who stated they were unsure and to try Department of Health. Upon calling the Department-of.Health, who was also unsure of direction to give, the JIC staff was then given the name and number of a person at the EOF. At this point, more than 30 minutes later, she added the name to the informaational white board in the work room, and stated she was told that if she had an "immediate concern" that she should contact this person.

Lastly, the VT plan dated February 17, 2011, Logistics Section Chief Attachment lists "Radiological Instruments Potassium Iodide and Other Supplies". However, under "If there is a need for additional Potassium Iodide, the following is a list of likely sources: "- no list follows this statement. Plans also do not designate aspokesperson.

RECOMMENDATION: Create a more detailed JIC plan and checklist. Utilize the JIC staff to assist in writing the plan. The plan could address the following:

-Who, by title, makes the determination to evacuate personnel at the JlC, and what criteria determine when personnel will be evacuated.

-Information regarding personnel reporting to a monitoring/decontamination facility, if necessary.

-A list of available quantities and locations of dosimetry and KI either listed in plan or referred to in the plan.

-Who, by title, is the designated spokesperson and alternates.

-Information on who, by title, JIC staff are to contact in the event of a dosimetry reading, and ensure staff and dosimetry contact person are trained on the plan.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

75

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station I IsueN mbr 671-a 3P0 Crtrin 4a3 ISSUE: When collecting an air sample in the field, the sample flow rate for the Vermont Plume Tracking Team 1 air sampler was 25 % lower than when the operational check was performed.

RECOMMENDATION: Revise the Plume Tracking Team procedure to require the team to check the air sampler flow rate each time they start an air sample. If the flow rate is different than previously determined, include direction to calculate a new sample run time or contact the Plume Tracking Team Director.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

Issu Nubr 6-3SblP0 Crtrin 5 ISSUE: Emergency Public Information (EPI) Message No. 3, the supplemental EPI Message to Emergency Alert System (EAS) Message No. 2 (evacuation of Hinsdale and shelter remaining New Hampshire (NH) towns in the Emergency Planning Zone (EPZ)) was not received at the WKNE Radio Station. Several attempts by WKNE staff to obtain a facsimile copy of EPI Message No. 3 were unsuccessful.

RECOMMENDATION: It is recommended that the SEOC revise that portion of the above reference to clearly assign responsibility to ensure each EPI (and EAS) Message is both forwarded and received by WKNE.

CORRECTIVE ACTION DESCRIPTION:

CAPABILITY: PRIMARY RESPONSIBLE AGENCY:

CAPABILITY ELEMENT: START DATE:

AGENCY POC: ESTIMATED COMPLETION DATE:

76

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station APPENDIX B: EXERCISE TIMELINE Table 1 - Exercise Timeline DATE: 2013-06-05, SITE: Vermont Yankee Power Station, VT

{.....' * ~ C..=

U 0 Emergency Classification Level or

" Event : 12

... .. 2 : . [- :.*.F , * - , - ." " . "- . "

> > > I___

Unusual Event 0831 0826 0831 0832 0920 Alert 0857 0858 0913 0857 0855 0955 Site Area Emergency 1049 1059 1048 1049 1049 1054 General Emergency 1157 1201 1152 1157 1157 1210 Simulated Rad. Release Started 1157 1141 1145 1157 1157 1210 Simulated Rad. Release Terminated Facility Declared Operational 0910 0932 0940 0920 0930 1024 Declaration of State of Emergency 0855 0930 0925 0855 0930 0944 Early Precautionary Actions: Close Parks 1015 1046 1029 I015 1006 1046 Early Precautionary Actions: School Transfer 1015 1046 1029. 1015 1006 1046 Early Precautionary Actions: Shelter Live Stock 1015 1046 1029 1015 1006 1158 1st Protective Action Decision: 1108 1123 1123 1108 1114 1st Siren Activation 1120 1120 1123 1120 1120 1120 I st EAS or EBS Message 1123 1123 1123 1123 1123 1123 2nd Protective Action Decision: 1206 1159 1152 1206 1158 2nd Siren Activation 1218 1204 1152 1218 1204 1204 2nd EAS or EBS Message 1221 1207 1152 1221 1204 1207 KI Administration Decision: 1201 1201 1214 1201 1205 1236 3rd Siren Activation 1204 1218 3rd Protective Action Decision 1201 1221 3rd EAS or EBS Message 1207 77

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Table 1 - Exercise Timeline DATE: 2013-06-05, SITE: Vermont Yankee Power Station, VT UU Emergen*y Classification Level or *.). . ,

U Event .W ....- o 0 0>

> z Unusual Event 0814 0845 0845 0831 0836 Alert 0905 0912 0903 0855 0857 0901 Site Area Emergency 1104 1049 1044 1049 1049 General Emergency 1146 1212 1210 1157 1153 Simulated Rad. Release Started 1157 1212 1210 1157 1153 Simulated Rad. Release 1337 1335 Terminated Facility Declared Operational 0930 0955 0905 0919 1000 Declaration of State of Emergency 0855 0844 0928 0942 0942 Early Precautionary Actions: Close Parks 1006 1015 0944 1135 Early Precautionary Actions: School Transfer 1020 1043 1028 1040 1135 Early Precautionary Actions: Shelter Live Stock 1130 .1043 1043 1040 1135 1st Protective Action Decision: . 1015 1108 1104 1st Siren Activation 1120 1120 1030 1120 1120 I st EAS or EBS Message 1123 1123 1030 1123 1123 2nd Protective Action Decision: 1154 1130 1206 1206 2nd Siren Activation 1204 1218 1204 1218 1218 2nd EAS or EBS Message 1207 1221 1207 1221 1221 KI Administration Decision: 1205 1212 1219 1320 1200 3rd Siren Activation 1205 3rd Protective Action Decision 1218 3rd EAS or EBS Message 1221 1 78

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power'Station Table 1 - Exercise Timeline DATE: 2013-06-05, SITE: Vermont Yankee Power Station, VT Emergency Classification Level or .* . .

Event Z. ".

.:.:_ .*--, ,. o

- ~ 0 E,

U N

Unusual Event 0825 0849 0850 0844 0841 0842 Alert 0857 0908 0914 0904 0905 0905 Site Area Emergency 1052 1059 1052 1055 1054 1055 General Emergency 1141 1201 1201 1202 1203 1203 Simulated Rad. Release Started 1201 1202 1203 1203 Simulated Rad. Release Terminated _____

Facility Declared Operational 1035 0940 0910 0947 0936 Declaration of State of Emergency 1026 0942 0959 0954 0942 Early Precautionary Actions: Close Parks ______1040 0955 0958 0952 Early Precautionary Actions: School Transfer ______1114 1127. *. 1114 Early Precautionary Actions: Shelter Live Stock 1040 1040 1045 1042 1st Protective Action Decision: ________1114 1117 1114 1st Siren Activation 1120 1120 1120 1120 1st EAS or EBS Message 1123 1123 .1123- 1123 2nd Protective Action Decision: 1209 1210 1215 1211 2nd Siren Activation 12 18 1218 12018 1218 2nd EAS or EBS Message 1026 0941221 1221 1221 1221 KI Administration Decision: SchoolTran r1328 1328 1329 1330 3rd Siren Activation Acton:_SelerivStck104 140__145_04 3rd Protective Action Decision 1209__210__215_1211 3rd EAS or EBS Message 79

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Table 1 - Exercise Timeline DATE: 2013-06-05, SITE: Vermont Yankee Power Station, VT Emergency Classificatibn.Level or >

Event .

Unusual Event 0840 0831 0826 0831 Alert 0905 0855 0858 0857 0855 Site Area Emergency 1053 1052 1050 1054 1049 1055 General Emergency 1202 1202 1158 1201 1153 1155 Simulated Rad. Release Started 1200 1202 1158 1141 1153 1155 Simulated Rad. Release 1334 1335 1300 Terminated I Facility Declared Operational 0917 0948 0920 0932 1000 0920 Declaration of State of Emergency 0950 0942 1010 0930 1146 1010 Early Precautionary Actions: Close Parks 0946 1016 0953 0951 Early Precautionary Actions: School Transfer 1115 0946 0951 1046 0953 0951 Early Precautionary Actions: Shelter Live Stock 1053 0951 1046 , 0953. 0951 1st Protective Action Decision: 111 1I11 1123 .1104 1105 1st Siren Activation 1120 1120 1120 1120 1120 1120 1st EAS or EBS Message 1123 1123 1123 1123 1i23 1123 2nd Protective Action Decision: 1208 1208 1205 1159 1206 1155 2nd Siren Activation 1218 1218 1218 1204 1218 1218 2ndEAS or EBS Message 1221 1221 1221 1207. 1221 1221 KI Administration Decision: 1327 1328 1205 1201 1146 1155 3rd Siren Activation 1259 3rd Protective Action Decision 1305 3rd EAS or EBS Message 80

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Table 1 - Exercise Timeline DATE: 2013-06-05, SITE: Vermont Yankee Power Station, VT Emergency Classification Lev el or .  : " . C..o Event u U1  :.0?g:::: Z Unusual Event 0839 0838 0837 0838 0843 0838 Alert 0907 0905 0914 0908 0904 0905 Site Area Emergency 1059 1107 1102 1058 1058 1037 General Emergency 1205 1203 1212 1215 1203 1202 Simulated Rad. Release Started 1 146 1146 1217 1215 1204 1202 Simulated Rad. Release 1405 Terminated Facility Declared Operational 0906 0857 0905 0905 0857 0935 Declaration of State of Emergency 1010 1146 1150 1022 1010 1021 Early Precautionary Actions: Close Parks 0951 0951 1004 0959 0951 0954 Early Precautionary Actions: School Transfer 0951 0951 1004 0959 0951 0954 Early Precautionary Actions: Shelter Live Stock 0951 0951 1004 0959 0951 0954 1st Protective Action Decision: -*0951 1206 1st Siren Activation 1120 1120 1120 1120 1120 1120 I1st EAS or EBS Message 1123 1123 1123 1123 1123 1123 2nd Protective Action Decision: 1217 1220 1146 1215 1203 2nd Siren Activation 1218 1218 1218 1218 1218 1218 Ind EAS or EBS Message 1221 122112121 12121 KI Administration Decision: 1207 1112 1146 1215 1211 1206 3rd Siren Activation 3rd Protective Action Decision 3rd EAS or EBS Message 81

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Table 1 - Exercise Timeline DATE: 2013-06-05, SITE: Vermont Yankee Power Station, VT 7;

Uu Emergency Classifi~ation Level or Event Unusual Event 0837 Alert 0903 Site Area Emergency 1059 General Emergency 1205 Simulated Rad. Release Started 1205 Simulated Rad. Release Terminated Facility Declared Operational 0920 Declaration of State of Emergency 1143 Early Precautionary Actions: Close Parks 095!

Early Precautionary Actions: School Transfer 0951 Early Precautionary Actions: Shelter Live Stock 0951 1st Protective Action Decision:

.1st Siren Activation 1120 1st EAS or EBS Message 1123 2nd Protective Action Decision: 1214 2nd Siren Activation 1214 2nd EAS or EBS Message 1214 KI Administration Decision: 1205 3rd Siren Activation 3rd Protective Action Decision 3rd EAS or EBS Message 82

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station APPENDIX C: EXERCISE EVALUATORS AND TEAM LEADERS 83

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station DATE: 2013-06-05, SITE: Vermont Yankee Power Station, VT LOCATION EVALUATOR AGENCY Vermont State Emergency Operations Center John Flynn ICF Reggie Rodgers ICFI

• Melissa Savilonis FEMA - RI Dennis Wilford ICFI Vermont EOF *Johanna Berkey FEMA RIX Alan Bevan ICFI Vermont Joint Information Center *Henry Christiansen ICFI VT Plume Tracking Team-I *Marcy Campbell ICFI VT Plume Tracking Team-2 *Marcy Campbell ICFI Kent Tosch ICFI Vermont Rockingham State Police *Terry Blackmon ICFI Vermont Alternate Warning Point *Samuel Nelson ICFI Vermont 211 Call Center *Cheryl Weaver ICFI NH State Emergency Operations Center James Hickey ICFI

• Barbara Thomas FEMA RI Carl Wentzell ICFI NH 911 Call Center Lynn Steffensen ICFI NH (VY) Joint Information Center *John Rice FEMA RI NH State Police Troop C, Keene *David Petta ICFI Rosemary Samsel ICFI NH (VY) Field Monitoring Team-1 *Michael Howe FEMA HQ NH (VY) Field Monitoring Team-2 John Zeidler ICFI NH State Warning Point Lynn Steffensen ICFI NH (VY) Emergency Operations Facility *Joseph Keller ICFI Timothy Pflieger FEMA RVI NH Cheshire County Sheriffs Dispatch Frank Cordaro ICFI WKNE Radio Station *David Petta ICFI Massachusetts State Emergency Operations Center Deborah Blunt ICFI Ronald Bonner ICF1 Gary Goldberg ICFI

• Taneeka Hollins FEMA RI MA 211 Call Center *Danny Loomis ICFI MA Warning Point - Shelburne Thomas Gahan ICFI MA (VY) Emergency Operations Facility *Jill Leatherman ICFI Brad McRee ICFI MA (VY) Joint Information Center *Bridget Ahlgrim FEMA HO MA Region III/IV EOC *Patricia Foster FEMA RI Wes Ryals ICFI Brattleboro Local EOC *Brad DeKorte FEMA RVI Robert Lemeshka ICFI Dummerston Local EOC *Paul Anderson FEMA RIX Terry Blackmon ICFI Guilford Local EOC *Lisa Hamilton FEMA HQ David Kayen ICFI Halifax Local EOC *Linda Gee FEMA RVI Michael Petullo ICFI Vernon Local EOC *Brian Hasemann FEMA RII Richard Watts ICFI 84

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan " Vermont Yankee Power'Station

• Chesterfield Local EOC Clayton Spangenberg ICFI

• Robert Swartz FEMA RI Hinsdale Local EOC LaShawn Halsey FEMA HQ

• Bruce Swiren ICFI Richmond Local EOC Brenda Rembert ICFI

• Roy Smith ICFI Swanzey Local EOC *Helen LaForge FEMA RI John McGough FEMA - RI Winchester Local EOC Gregg Dawkins ]CF

• Ryan Jones FEMA - RI Thomas Reynolds ICFI Bernardston Local EOC Richard Fournier ICFI

• Patricia Mason FEMA RII Colrain Local EOC *Larry Broockerd FEMA HQ Thomas Gahan ICFI Gill Local EOC Ronald Biernacki ICFI

• Paul Ringheiser ICFI Greenfield Local EOC George Allen US FDA

• David Jacobson ICFI Leyden Local EOC Clark Duffy ICFI

• Bill Webb FEMA RX Northfield Local EOC *Mark Dalton ICFI Robert O'Sullivan FEMA - RI Warwick Local EOC Brian Collins FEMA - RI

• Paul Nied ICFI Academy School *Robert Swartz FEMA RI WSESU Superintendent *Robert Swartz FEMA RI Barbara Gantt *Robert Swartz FEMA RI Brattleboro Union High and Middle School *Robert Swartz- FEMA RI ESS/Canal St School *Robert Swartz FEMA RI Doris' Day Care *Robert Swartz FEMA RI Family Garden *Robert Swartz FEMA RI Happy Hands *Robert Swartz FEMA RI Judy's Family Child Care *Robert Swartz FEMA RI Meenama's Learning Center and Child Care *Robert Swartz FEMA RI Miss Martha's homecare *Robert Swartz FEMA RI Vernon Elementary *Robert Swartz FEMA RI Teddy Bear Child Care *Robert Swartz FEMA RI Winston Prouty Early Learning Center *Robert Swartz FEMA RI DD's Totley Crew *Robert Swartz FEMA RI Immaculate Heart of Mary *Robert Swartz FEMA RI Nanny's Day Care *Robert Swartz FEMA RI Little Imaginative Learners *Robert Swartz FEMA RI Village Children Center *Robert Swartz FEMA RI Southwestern New Hampshire District Fire Mutual Aid Local *Laura Forrest FEMA RII Warning Point Keene Local EOC *Laura Forrest FEMA RiI Keene Reception Center *Ingrid Bruns FEMA RI 85

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 86

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station APPENDIX D: EXERCISE PLAN 87

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station VERMONT EVALUATION AREAS AND EXTENT OF PLAY FOR THE VERMONT YANKEE POWER STATION EXERCISE June 5, 2013 Based on guidance from Section llI.C -Exercise Demonstration, "Radiological Emergency Preparedness (REP) Program Manual", April 2012. 88 1

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station ASSESSMENT AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element 1.a - Mobilization Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to alert, notify, and mobilize emergency personnel, and activate and staff emergency facilities.

Criterion1.a.1: OROs use effective procedures to alert,notify, and mobilize emergency personnel and activatefacilities in a timely manner. (NUREG-0654/

FEMA-REP-1, A.1.a, e; A.3, 4; C.1,4, 6; D.4; E.1, 2; H.3, 4)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplishedduring a biennialexercise, an actual event, out-of-sequence evaluation or by means of drills conducted at any time.

Responsible OROs must demonstrate the capability to receive notification of an incident from the licensee; verify the notification; and contact, alert, and mobilize key emergency personnel in a timely manner and demonstrate the ability to maintain and staff 24-hour operations. Twenty-four-hour operations can be demonstrated during the exercise via rosters or shift changes or otherwise in an actual activation. Local responders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management organizations of an incident in a timely manner, when they receive information from the licensee or alternate sources. Responsible OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. Activation of facilities and staff, including those associated with the Incident Command System, must be completed in accordance with ORO plans/procedures. The location and contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP after these facilities have been activated.

Pre-positioning of emergency personnel is appropriate, in accordance with the Extent-of-Play Agreement, at those facilities located beyond a normal commuting distance from the individual's duty location or residence. This includes the staggered release of resources from an assembly area. Additionally, pre-positioning of staff for out-of-sequence demonstrations may be used in accordance with the Extent-of-Play Agreement.

The REP program does not evaluate Incident Command Post tactical operations (e.g., Law Enforcement hostile action suppression techniques), only coordination among the incident command, the utility, and all appropriate OROs, pursuant to plans/procedures.

Initial law enforcement, fire service, HAZMAT, and emergency medical response to the NPP site may impact the ability to staff REP functions. The ability to identify and request additional resources or identify compensatory measures must be demonstrated. Exercises must also address the role of mutual aid in the incident, as appropriate. An integral part of the response to an HAB scenario at an NPP may also be within the auspices of the Federal Government (e.g., FBI, NRC, or DHS). Protocols for requesting Federal, state, local, and tribal law enforcement support must be dc9onstrated, as appropriate. Any resources must be on the ORO's mobilization list so they can be contacted during an incident, if needed.

2

Unclassified Radiological Emergency Preparedness Program (PEP)

After Action Report/Improvement Plan Vermont Yankee Power Station All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play Rosters for 2nd shift personnel will be available for all facilities/locations staffed on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis.

Real time notification of emergency response staff will be demonstrated during this exercise with the following exceptions:

The Nuclear Engineer will be in Brattleboro or Vernon in the normal course of his duties and will deploy to the EOF when he is paged out.

If there are any responders to other facilities that would have more than a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or more drive, it will be suggested that they go to a location within an hour's drive of that facility and await the page before deploying.

If there are any responders to other facilities that would have more than a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or more drive, they will go to a designated mobilization staging area and await the notification before deploying. The rule for arrival at a facility sooner than actual travel time is ten minutes for each hour of actual travel time. e.g. A responder living 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> away could arriveten minutes after being notified.

90 3

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power'Station Sub-element 1.b - Facilities Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have facilities to support the emergency response.

Criterion 1.b.1: Facilitiesare sufficient to support the emergency response. (NUREG-0654/FEMA-REP-I, H.3; G.3.a; J.1O.h; J.12; K.S.b)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a biennialexercise, an actual event, staff assistance visits, or by out-of-sequence evaluations.

Responsible OROs must demonstrate, no less than once every eight years, the availability of facilities to support accomplishment of emergency operations (this includes all alternate and backup.facilities).

Evaluations are typically performed for EOCs and JICs, as well as other facilities such as reception/relocation centers. Some of the areas evaluated within the facilities are adequate space,

.furnishings, lighting, restrooms, ventilation, backup power, and/or alternate facility, if required to support operations. Radio stations, laboratories, initial warning points and hospitals are not evaluated under 1.b.1.

In addition, facilities will be evaluated for this criterion during the first biennial exercise after any new or

....s.ubstantial changes.in structure, equipment, or mission that affect key capabilities, as outlined in respective emergency plans/procedures. A substantial change is one that has a direct effect or impact on

emergency response operations performed in those facilities. Examples of substantial changes include:

modifying the size or configuration of an emergency operations center, adding more function to a center, or changing the equipment available for use in a center.

All activities must be based on the ORO's plans/procedures and completed as they would be inan actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play There are no new or substantially changed facilities to be evaluated under this criterion.

91 4

Unclassified Radiological Emergency Preparedness Program (REP)

After Aciion Report/Improvement Plan Vermont Yankee Power Station Sub-element 1.c - Direction and Control Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to control their overall response to an emergency.

Criterion 1.c.1: Key personnelwith leadershiprolesfor the ORO provide direction and control to that part of the overall response effortfor which they areresponsible. (NUREG-0654/FEMA- REP-1, A.1.d; A.2.a, b; A.3; C.4, 6)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplishedin a biennialor tabletop exercise.

Leadership personnel must demonstrate the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed through periodic briefings and/or other means, coordinating with other OROs, and ensuring completion of requirements and requests.) Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources. Any resources identified through LOA/MOUs must be on the ORO's mobilization list so they may be contacted during an incident, if needed.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play State EOC- Communications with the Governor and his staff will be simulated where necessary.

EPZ Town EOCs- If any towns are directed to evacuate, EOC personnel will simulate closing and transfer of their operation to their alternate EOC location and demonstrate continuity of government through a discussion. All appropriate communications with the State EOC and the State Transportation Staging Area will continue to be demonstrated at the town EOC.

A Planning Issue was identified regarding the JIC plan in 2011. A revised JIC plan will be provided to evaluators taking into account the recommendations made and will resolve this planning issue.

92 5

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Vermont Yankee Power Station Sub-element 1.d - Communications Equipment Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs establish and operate reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as contiguous governments within the EPZ, Federal emergency response organizations, the licensee and its facilities, EOCs, Incident Command Posts, and FMTs.

CriterionI.d.1: At least two communication systems are available, at least one operates properly,and communication links are establishedand maintained with appropriatelocations. Communications capabilitiesare managed in support of emergency operations.(NUREG-0654/FEMA-REP-1, F.1, 2)

Assessment/Extent of Play Assessment of this Demonstration Criterionis accomplished initially in a baseline evaluation and subsequently in periodic testing and drills. System familiarity and use must be demonstrated as applicable in biennialor tabletop exercise, or if their use would be required,during an actual event.

OROs must demonstrate that a primary system, and at least one backup system for fixed facilities, is fully functional at all times. Communications systems are maintained and tested on a recurring basis throughout the assessment period and system status is available to all operators. Periodic test results and.

corrective actions are maintained on a real time basis. If a communications system or systems are not functional, but exercise performance is not affected, no exercise issue will be assessed.

Communications equipment and procedures for facilities and field units are used as needed for transmission and receipt of exercise messages. All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

Exercise scenarios may require the failure of a communication system and use of an alternate system, as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play All facilities (State EOC, SWPs, JIC, Town EOCs, and EOF) will demonstrate that a primary and at least one backup system are fully functional. For all above facilities, contact with locations or organizations that are not participating in the exercise or are demonstrating out of sequence will be simulated by placing an entry in the log at the appropriate time(s) in the exercise unless otherwise noted.

93 The following chart represents the primary and secondary communications between the State EOC and the listed facility:

6

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station FACILITY PRIMARY BACK UP Joint Information Commercial Phone FAX, Disaster LAN Center Emergency Operations EPZ Radio 45.52. MHz & Commercial Phone, RACES Radio & Disaster LAN Facility (VT) FAX, & FMT Freq.

Brattleboro EPZ Radio 45.52. MHz Commercial Phone, RACES Radio, Disaster LAN, FAX Dummerston EPZ Radio 45.52. MHz Commercial Phone, RACES Radio, Disaster LAN, FAX Guilford EPZ Radio 45.52. MHz Commercial Phone, RACES Radio, Disaster LAN, FAX Halifax EPZ Radio 45.52. MHz Commercial Phone, RACES Radio, Disaster LAN, FAX Vernon EPZ Radio 45.52. MHz Commercial Phone, RACES Radio, Disaster LAN, FAX Public Inquiry, 211* Commercial Phone FAX, Disaster LAN Rockingham SWP Commercial Phone FAX, Disaster LAN I Derby ASWP I Commercial Phone FAX, Disaster LAN Note: United Way "211" provides the public multiple ways to reach them with a question or comment.

The Public Inquiry line "800-736-5530" is forwarded to 211 in an emergency, the public can dial "211" and any persons who call E-"911" with an emergency related, but not life threatening question or comment will be referred to "211".

94 7

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Sub-element i.e - Equipment and Supplies to Support Operations Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have emergency equipment and supplies adequate to support the emergency response.

Criterion 1.e.1: Equipment,maps, displays, monitoringinstruments, dosimetry, potassium iodide (KI) and other supplies are sufficient to support emergency operations(NUREG-0654/FEMA-REP-1, H.7, 10; 1.7, 8, 9; I.10.a, b, e; J.11, 12; K.3.a; K.5.b)

Assessment/Extent of Play Assessment of this DemonstrationCriterion is accomplishedprimarily through a baseline evaluation and subsequent periodic inspections.

A particular facility's equipment and supplies must be sufficient and consistent with that facility's assigned role in the ORO's emergency operations plans. Use of maps and other displays is encouraged. For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available, or their availability described.

Specific equipment and supplies that must be demonstrated under this criterion include KI inventories, dosimetry, and monitoring equipment, as follows:

KI: Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by:

(1) emergency workers; (2) institutionalized individuals, as indicated in capacity lists for facilities; and (3) where stipulated by the plans/procedures, members of the general public (including transients) within the plume pathway EPZ. In addition, OROs must demonstrate provisions to make KI available tospecialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures). The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI, as well as a mechanism for identifying emergency workers that have declined KI in advance. Consider carefully the placement of emergency workers that have declined KI in advance.

ORO quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical inspection at the storage location(s) or through documentation of current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. Available supplies of KI must be within the expiration date indicated on KI bottles or blister packs. As an alternative, the ORO may produce a letter from a certified private or state laboratory indicating that the KI supply remains potent, in accordance with U.S. Pharmacopoeia standards.9,4F Dosimetry: Sufficient quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers must be available for issuance to all emergency workers who will be dispatched to perform an ORO mission. In addition, OROs must dejggnstrate provisions to make dosimetry available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures).

8

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures.

Direct-reading dosimeters must be zeroed or operationally checked prior to issuance. The dosimeters must be inspected for electrical leakage at least annually and replaced when necessary. Civil Defense Victoreen Model 138s (CD V-138s) (0-200 mR), due to their documented history of electrical leakage problems, must be inspected for electrical leakage at least quarterly and replaced when necessary. This leakage testing will be verified during the exercise, through documentation submitted in the ALC and/or through an SAV.

Operational checks and testing of electronic dosimeters must be in accordance with the manufacturer's instructions and be verified during the exercise, through documentation submitted in the ALC and/or through an SAV.

Monitoring Instruments: All instruments must be inspected, inventoried, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations.

Unmodified CDV-700 series instruments and other instruments without a manufacturer's recommendation must be calibrated annually. Modified CDV-700 instruments must be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration must be on each instrument or calibrated frequency can be verified by other means. In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source.

For FMTs, the instruments must be capable of measuring gamma exposure rates and detecting beta radiation. These instruments must be capable of measuring a range of activity and exposure, including radiological protection/exposure control of team members and detection of activity on air sample collection media, consistent with the intended use of the instrument and the ORO's plans/procedures. An appropriate radioactive check source must be used to verify proper operational response for each low-range radiation measurement instrument (less than 1R/hr) and for high-range instruments when available.

If a source is not available for a high-range instrument, a procedure must exist to operationally test the instrument before entering an area where only a high-range instrument can make useful readings.

In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the ContaminationMonitoring Standardfor a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play FEMA will provide copies of the Annual Letter of Certification to evaluators, as appropriate. Instrument data will be an attachment to the Annual Letter of Certification.

Pursuant to the VTRERP, facilities participating in this exercise will demonstrate the equipment, maps, displays, dosimetry, potassium iodide (KI) and other supplies available to them. Some procedures state that if kit boxes are sealed and have an inventory form attached, the teams do not need to perform an inventory prior to deployment. Instrument calibration certificates are on file at both Vermont Emergency Management Offices and can be viewed by FEMA evaluators.

96 9

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station ASSESSMENT AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.a - Emergency Worker Exposure Control Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place, as specified in the ORO's plans/procedures, to authorize emergency worker exposure limits to be exceeded for specific missions.

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

Criterion 2.a.i: OROs use a decision-making process, consideringrelevantfactors and appropriate coordination,to ensure that an exposure control system,. including the use of KI, is in place for emergency workers, including provisions to authorize radiationexposure in excess of administrativelimits or protective action guides. (NUREG-0654/FEMA-REP-i, C.6; L.10. e, f; K.4)

Assessment/Extent of Play Assessment of this Demonstration Criterionmust be assessedconcurrently with a licensee exercise and may be demonstrated in a biennialor tabletop exercise.

OROs authorized to send emergency workers into the plume exposure pathway EPZ must demonstrate a capability to comply with emergency worker exposure limits based on their emergency plans/procedures.

Participating OROs must also demonstrate the capability to make decisions concerning authorization of exposure levels in excess of pre-authorized levels and the number of emergency workers receiving radiation doses above pre-authorized levels. This would include providing KI and dosimetry in a timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating actions, in accordance with respective plans/procedures.

As appropriate, OROs must demonstrate the capability to make decisions on the distribution and administration of KI as a protective measure for emergency workers, based on their plans/procedures or projected thyroid dose compared with the established PAGs for KI administration.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play There will be no exceptions to this sub-element in the Vermont extent of play.

97 10

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Sub-element 2.b. - Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to independently project integrated dose from projected or actual dose rates and compare these estimates to the PAGs.

OROs must have the capability to choose, among a range of protective actions, those most appropriate in a given emergency. OROs base these choices on PAGs from their plans/procedures or EPA's Manual of Protective Action Guides and ProtectiveActions for Nuclear Incidents and other criteria, such as plant conditions, licensee PARs, coordination of PADs with other political jurisdictions (e.g., other affected OROs and incident command), availability of in-place shelter, weather conditions, and situations, to include HAB incidents, the threat posed by the specific hostile action, the affiliated response, and the effect of an evacuation on the threat response effort, that create higher than normal risk from general population evacuation.

Criterion2.b.1: Appropriateprotective action recommendations(PARs) are based on available information on plant conditions,field monitoring data,and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmentalconditions.

(NUREG-0654/FEMA-REP-1, 1.10 and Supplement 3)

Assessment/Extent of Play Assessment of this DemonstrationCriterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise.

During the initial stage of the emergency response, following notification of plant conditions that may warrant offsite protective actions, the ORO must demonstrate the capability to use appropriate means, described in the plans/procedures, to develop PARs for decision-makers based on available information and recommendations provided by the licensee as well as field monitoring data, if available. The ORO must also consider any release and meteorological data provided by the licensee.

The ORO must demonstrate a reliable capability to independently validate dose projections. The types of calculations to be demonstrated depend on the data available and the need for assessments to support the PARs must be appropriate to the scenario. In all cases, calculation of projected dose must be demonstrated. Projected doses must be related to quantities and units of the PAG to which they will be compared. PARs must be promptly transmitted to decision-makers in a pre-arranged format.

When the licensee and ORO projected doses differ by more than a factor of 10, the ORO and licensee must determine the source of the difference by discussing input data and assumptions, using different models, or exploring possible reasons. Resolution of these differences must be incorporated into the PARs if timely and appropriate. The ORO must demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated Ibs.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemiont Yankee Power Station Vermont Extent of Play There will be no exceptions to this sub-element in the Vermont extent of play.

Criterion2.b.2: A decision-makingprocess involving considerationof appropriatefactors and necessary coordinationis used to make protective action decisions (PADs) for the generalpublic (including the recommendationfor the use of KI, if ORO policy). (NUREG-0654/FEMA- REP-1,A.3; C.4, 6; D.4; i.9; J.iO.f, m)

Assessment/Extent of Play Assessment of this Demonstration Criterionmust be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise.

OROs must have the capability to make both initial and subsequent PADs. OROs must demonstrate the capability to make initial PADs in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO authorities (e.g., incident command), and PARs from the utility and ORO staff. In addition, a subsequent or alternate PAD may be appropriateif various conditions (e.g., an HAB incident, weather, release timing and magnitude) pose undue risk to an evacuation, or if evacuation may disrupt the efforts to respond to a hostile action.

OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a PAD if local law enforcement, fire service, HAZMAT, and emergency medical resources are utilized to augment response to the NPP site or other key infrastructure.

Dose assessment personnel may provide additional PARs based on the subsequent dose projections, field monitoring data, or information on plant conditions. In addition, incident command must provide input regarding considerations for subsequent PARs based on the magnitude of the ongoing threat, the response, and/or site conditions. The decision-makers must demonstrate the capability to change protective actions based on the combination of all these factors.

If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must demonstrate the capability to make decisions on the distribution and administration of KI to supplement sheltering and evacuation. This decision must be based on the ORO's plans/procedures or projected thyroid dose compared with the established PAG for KI administration. The KI decision-making process must involve close coordination with appropriate assessment and decision-making staff.

If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate PADs with each other. In addition, decisions must be coordinated/communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play 99 There will be no exceptions to this sub-element in the Vermont extent of play.

12

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station A Planning issue was identified in the implementation of traffic and access control in 2011. The VT SEOC will successfully demonstrate this criterion to resolve this planning issue.

Sub-element 2.c - PAD Consideration for the Protection of Persons with Disabilities and Access/Functional Needs Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to determine PADs, including evacuation, sheltering, and use of KI, if applicable, for groups of persons with disabilities and access/functional needs (e.g., hospitals, nursing homes, correctional facilities, schools, licensed daycare centers, mobility-impaired individuals, and transportation-dependent individuals). The focus is on those groups of persons with disabilities and access/functional needs that are, or potentially will be, affected by a radiological release from an NPP.

Criterion2.c.1: Protective action decisions aremade, as appropriate,for groups of persons with disabilitiesand access/functionalneeds. (NUREG-0654/FEMA-REP-1,D.4;J.9; J.1O.d, e)

Assessment/Extent of Play Assessment of this Demonstration Criterionmust be accomplishedconcurrently with a licensee exercise and may be demonstratedin a biennial or tabletop exercise that would include the use of plant conditions transmittedfrom the licensee.

Usually it is appropriate to implement evacuation in areas where doses are projected to exceed the lower end of the range of PAGs, except for incidents where there is a high-risk environmental condition or where high-risk groups (e.g., the immobile or infirm) are involved. In these cases, factors that must be considered include weather conditions, shelter availability, availability of transportation assets, risk of evacuation versus risk from the avoided dose, and precautionary school evacuations. In addition, decisions must be coordinated/communicated with the incident command. In situations where an institutionalized population cannot be evacuated, the ORO must consider use of KI.

Applicable OROs must demonstrate the capability to alert and notify all public school systems/districts of emergency conditions that are expected to or may necessitate protective actions for students.

Demonstration requires that the OROs actually contact public school systems/districts during the exercise.

In accordance with plans/procedures, OROs and/or officials of public school systems/districts must demonstrate the capability to make prompt decisions on protective actions for students. The decision-making process, including any preplanned strategies for protective actions for that ECL, must consider the location of students at the time (e.g., whether the students are still at home, en route to school, or at school).

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play There will be no exceptions to this sub-element in tMt1)ermont extent of play.

13

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan .Vermont Yankee Power Station Sub-element 2.d. - Radiological Assessment and Decision Making for the Ingestion Exposure Pathway Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the means to assess the radiological consequences for the ingestion exposure pathway, relate them to the appropriate PAGs, and make timely, appropriate PADs to mitigate exposure from the pathway.

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

Criterion 2.d.1: Radiologicalconsequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO's planning criteria.(NUREG-0654/FEMA-REP-1, A.3; C.1, 4; D.4; J.9,11)

Assessment/Extent of Play Assessment of this Demonstration Criterionmust be accomplished concurrently with a licensee exercise and may be demonstratedin a.biennialor tabletop exercise that would include the use of plant conditions transmittedfrom the licensee.

OROs are expected to take precautionary actions to protect food and water supplies, or to minimize exposure to potentially contaminated water and food, in accordance with their respective plans/procedures. Often OROs initiate such actions based on criteria related to the facility's ECLs. Such actions may include recommendations to place milk animals on stored feed and use protected water supplies.

The ORO must use its procedures to assess the radiological consequences of a release on the food and water supplies, such as the development of a sampling plan. The ORO's assessment must include evaluation of the radiological analyses of representative samples of water, food, and other ingestible substances of local interest from potentially impacted areas; characterization of the releases from the facility; and the extent of areas potentially impacted by the release. During this assessment, OROs must consider use of agricultural and watershed data within the 50-mile EPZ. The radiological impacts on the food and water must then be compared to the appropriate ingestion PAGs contained in the ORO's plans/procedures. The plans/procedures contain PAGs based on specific dose commitment criteria or on criteria as recommended by current Food and Drug Administration (FDA) guidance. Timely and appropriate recommendations must be provided to the ORO decision-makers group for implementation decisions.

OROs may also include a comparison of taking or not taking a given action on the resultant ingestion pathway dose commitments.

101 The ORO must demonstrate timely decisions to minimize radiological impacts from the ingestion pathway, based on the given assessments and other information. Any such decisions must be communicated and, to the extent practical, coordinated with neighboring OROs.

14

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station OROs will use Federal resources, as identified in the Nuclear/Radiological Incident Annex of the NRF and other resources (e.g., compacts or nuclear insurers), as necessary. Evaluation of this criterion will take into consideration the level of Federal and other participating resources.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play This criterion was successfully demonstrated in 2011.

102 15

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Sub-element 2.e. - Radiological Assessment and Decision Making Concerning Post- Plume Phase Relocation, Reentry, and Return Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to make decisions on post-plume phase relocation,reentry,and return of the general public. These decisions are essential for protection of the public from direct long-term exposure to deposited radioactive materials from a severe incident at an NPP.

Criterion2.e.1: Timely post-plume phase relocation, reentry, and return decisions are made and coordinatedas appropriate,based on assessments of the radiologicalconditions and criteriain the ORO's plan and/orprocedures. (NUREG-0654/FEMA-REP-1, 1.10; J.9; K.3.a; M.1)

Assessment/Extent of Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennialortabletop exercise that would include the use of plant conditions transmittedfrom the licensee.

Relocation: OROs must demonstrate the capability to estimate integrated dose in contaminated areas and.

compare these estimates with PAGs; apply decision criteria for relocation of those individuals in the general public who have not been evacuated, but where actual or projected doses are in excess of relocation PAGs; and control access to evacuated and restricted areas. OROs will make decisions for relocating members of the evacuated public who lived in areas that now have residual radiation levels in excess of the PAGs. Determination of areas to be restricted must be based on factors such as the mix of radionuclides in deposited materials, calculated exposure rates versus the PAGs, and analyses of vegetation and soil field samples.

Reentry: Decisions must be made on location of control points and policies regarding access and exposure control for emergency workers and members of the general public who need to temporarily enter the evacuated area to perform specific tasks or missions.

Examples of control procedures are the assignment of, or checking for, direct-reading and permanent record dosimetry for emergency workers; questions regarding an individual's objectives, locations expected to be visited, and associated timeframes; availability of maps and plots of radiation exposure rates; and advice on areas to avoid. Control procedures also include monitoring of individuals, vehicles, and equipment; the implementation of decision criteria regarding decontamination; and proper disposition of emergency worker dosimetry and maintenance of emergency worker radiation exposure records.

Responsible OROs must demonstrate the capability to develop a strategy for authorized reentry of individuals into the restricted zone(s), based on esta4ohed decision criteria. OROs must demonstrate the capability to modify those policies for security purposes (e.g., police patrols), maintenance of essential services (e.g., fire protection and utilities), and other critical functions. They must demonstrate the capability to use decision-making criteria in allowing access to the restricted zone by the public for various 16

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemront Yankee Power Station reasons, such as to maintain property (e.g., to care for farm animals or secure machinery for storage) or retrieve important possessions. Coordinated policies for access and exposure control must be developed among all agencies with roles to perform in the restricted zone(s). OROs must demonstrate the capability to establish policies for provision of dosimetry to all individuals allowed to reenter the restricted zone(s).

The extent to which OROs need to develop policies on reentry will be determined by scenario events.

Return: OROs must demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase (i.e., permitting populations that were previously evacuated to reoccupy their homes and businesses on an unrestricted basis). OROs must base decisions on environmental data and political boundaries or physical/ geological features, which allow identification of the boundaries of areas to which members of the general public may return. Return is permitted to the boundary of the restricted area(s) that is based on the relocation PAG.

Other factors that the ORO must consider in decision-making include conditions that permit cancellation of the ECL and relaxation of associated restrictive measures. OROs must base return recommendations on measurements of radiation from ground deposition. OROs must have the capability to identify services and facilities that require restoration within a few days and to identify the procedures and resources for their restoration. Examples of these services and facilities are medical and social services, utilities, roads, schools, and intermediate-term housing for relocated persons.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play This criterion was successfully demonstrated in 2011.

104 17

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee'Power Station ASSESSMENT AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.a - Implementation of Emergency Worker Exposure Control Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for each emergency worker; establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of the PAGs, and the capability to provide KI for emergency workers, always applying the "as low as is reasonably achievable" principle as appropriate.

Criterion3.a.1: The OROs issue appropriatedosimetry, K1,and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures.Emergency workers periodicallyand at the end of each mission read their dosimeters and record the readingson the appropriateexposure recordor chart.OROs maintain appropriaterecord-keeping of the administration of KI to emergency workers. (NUREG-0654/FEMA-REP-1, J.1O.e; K.3.a, b; K.4)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplishedduring a biennial or tabletop exercise.

Other means may include drills, seminars or training activities that would fully demonstrate technical proficiency.

OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent record dosimetry, dosimeter chargers, KI, and instructions on the use of these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows an individual(s) to read the administrative reporting limits that are pre-established at a level low enough to consider subsequent calculation of TEDE and maximum exposure limits, for those emergency workers involved in lifesaving activities, contained in the ORO's plans/procedures.

Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control.

During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. The emergency worker must report accumulated exposures during the exercise as indicated in the plans/procedures. OROs must demonstrate the actions described in the plans/procedures by determining whether to replace the worker, authorize the worker to incur additional exposures, or take other actions. If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge of whom to contact in case authorization is needed, and at what exposure levels. Workers may use any available resources (e.g., written procedures and/or coworkers) in providing responses. 105 Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission. In such 18

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemiont Yankee Power Station cases, adequate control of exposure can be achieved for all team members using one direct-reading dosimeter worn by the team leader. Emergency workers assigned to low-exposure rate fixed facilities (e.g., EOCs and communications center within the EPZ, reception centers, and counting laboratories) may have individual direct-reading dosimeters or they may be monitored using group dosimetry (i.e., direct-reading dosimeters strategically placed in the work area). Each team member must still have his or her own permanent record dosimetry. Individuals authorized by the ORO to reenter an evacuated area during the plume (emergency) phase, must be limited to the lowest radiological exposure commensurate with completing their missions.

OROs may have administrative limits lower than EPA-400-R-92-O01 dose limits for emergency workers performing various services (e.g., life saving, protection of valuable property, all activities). OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where life saving and/or protection of valuable property may require an urgent response.

OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. Ingestion of KI recommended by the designated ORO health official is voluntary. For evaluation purposes, the actual ingestion of KI shall not be performed. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it. Emergency workers must demonstrate basic knowledge of procedures for using KI whether or not the scenario drives the implementation of KI use. This can be accomplished by an interview with the evaluator.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play Each of the following facilities will provide a minimum of 2 emergency workers at random to discuss the turn back values according to their procedures with the FEMA evaluator.

Brattleboro EOC Dummerston EOC Guilford EOC Halifax EOC Vernon EOC EOF JIC Staff at the above facilities will demonstrate actions described in their plans to determine whether to replace an exposed worker or get authorization for the worker to incur additional exposure. In addition, turn-in of dosimetry will be demonstrated.

NOTE: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant. After an "on the spot" re-training by the State, the FEMA Evaluator will provide the participant another opportunity to rlsG*monstrate the activity that same day.

19

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Sub-element 3.b - Implementation of KI Decision for Institutionalized Individuals and the General Public Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide KI for institutionalized individuals, and, if in the plans/procedures, to the general public for whom immediate evacuation may not be feasible, very difficult, or significantly delayed. While it is necessary for OROs to have the capability to provide KI to institutionalized individuals, providing KI to the general public is an ORO option and must be reflected as such in ORO plans/procedures.

Provisions must include the availability of adequate quantities, storage, and means of distributing KI.

Criterion3.b. 1: KI and appropriateinstructionsare availableif a decision to recommend use of KI is made. Appropriaterecord-keepingof the administrationof Kifor institutionalizedindividuals is maintained.(NUREG-0654/FEMA-REP-1, L 10. e, f)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplishedduring a biennialor tabletop exercise..

Other means may include drills, seminars or trainingactivities that would fully demonstrate technical proficiency.

OROs must demonstrate the capability to make KI available to institutionalized individuals, and, where provided for in their plans/procedures, to members of the general public. OROs must demonstrate the capability to accomplish distribution of KI consistent with decisions made. OROs must have the capability.

to develop and maintain lists of institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest KI. Ingestion of KI recommended by the designated ORO health official is voluntary. For evaluation purposes, the actual ingestion of KI shall not be performed. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it.

If a recommendation is made for the general public to take KI, appropriate information must be provided to the public by the means of notification specified in the ORO's plans/procedures.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play Actual distribution and ingestion of KI will not occur. Radiological Officers and Dosimeter Coordinators will show the FEMA evaluator the supply of pills and explain that they would place the foil wrapped pill in each Emergency Worker packet. KI is pre-distributed to the members of the general public residing or working in the EPZ communities. Plume Tracking Teams and Post Plume Radiological sampling Teams have KI in their kits but will not open or ingest it.

A Planning issue was identified in 2011 at the EOF regarding the documentation of the ingestion of KI by emergency workers at the facility. This criterion will be successfully demonstrated with correct documentation to resolve this planning issue.

107 20

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemiont Yankee Power Station Sub-element 3.c - Implementation of Protective Actions for Persons with Disabilities and Access/Functional Needs Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement PADs, including evacuation and/or sheltering, for all persons with disabilities and access/functional*needs. The focus is on those persons with disabilities and access/functional needs that are (or potentially will be) affected by a radiological release from an NPP.

.Criterion3.c.1: Protective action decisions are implementedfor persons with disabilitiesand access/functionalneeds other than schools within areassubject to protective actions. (NUREG-.

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

Assessment/Extent of Play Assessment of.this Demonstration Criterionmay be accomplishedduring a biennialexercise, an actual event, or by~means of drills conducted at any time.

Applicable OROs must demonstrate the capability to alert and notify (i.e., provide PARs and emergency information and instructions to) persons with disabilities and access/functional needs, including hospitals/medical facilities, nursing homes, correctional facilities, and mobility-impaired and transportation-dependent individuals. OROs must demonstrate the capability to provide for persons with disabilities and access/functional needs in accordance with plans/procedures.

Contact with persons with disabilities and access/functional needs and reception facilities may be actual or simulated, as agreed to in the extent of play. Some contacts with transportation providers must be actually contacted, as negotiated in the extent of play. All actual and simulated contacts must be logged.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play This criterion was successfully demonstrated in 2011.

108 21

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Criterion3.c.2: OROs/School officials implement protective actionsfor schools. (NUREG-0654/FEMA-REP-1, J.1O.c, d, e, g)

Assessment/Extent of Play Assessment of this DemonstrationCriterionmay be accomplished during a biennial,or tabletop exercise, an actualevent, staff assistance visit, or by means of drills conducted at any time.

School systems/districts (these include public and private schools, kindergartens, pre-schools, and licensed daycare centers) must demonstrate the ability to implement PADs for students. The demonstration must be made as follows: Each school system/district within the 10 mile EPZ must demonstrate implementation of protective actions. At least one school per affected system/district must participate in the demonstration. Canceling the school day, dismissing early, or sheltering in place must be simulated by describing to evaluators the procedures that would be followed. If evacuation is the implemented protective action, all activities to coordinate and complete the evacuation of students to reception centers, congregate care centers, or host schools may actually be demonstrated or accomplished through an interview process.

If accomplished through an interview, appropriate school personnel including decision-making officials (e.g., schools' superintendent/principals and transportation director/bus dispatchers), and at least one bus driver (and the bus driver's escort, if applicable) must be available to demonstrate knowledge of their role(s) in the evacuation of school children. Communications capabilities between school officials and the buses, if required by the plans/procedures, must be verified.

Officials of the school system(s) must demonstrate the capability to develop and provide timely information to OROs for use in messages to parents, the general public, and the media on the status of protective actions for schools.

If a school facility has emergency plans as a condition of licensing, those plans may be submitted to FEMA review in place of demonstration or interview pursuant to the ORO's plans/procedures as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play Brattleboro EOC, AREAS REQUIRING CORRECTIVE ACTION: 3.c.2., ISSUE NO.: 67-11-3c2-A-09., CONDITION:

Windham Southeast Supervisory Union representatives did not stay informed about certain important exercise details, such as the wind direction and evacuation decisions. Unresolved, to be evaluated in 2013.

Additional training and coordination has occurred and this will be successfully demonstrated in the next exercise.

109 22

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Sub-element 3.d. - Implementation of Traffic and Access Control Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement protective action plans/procedures, including relocation and restriction of access to evacuated/sheltered areas. This Sub-element focuses on selecting, establishing, and staffing of traffic and access control points, and removal of impediments to the flow of evacuation traffic.

Criterion3.d.1: Appropriatetraffic and access control is established.Accurate instructionsare provided to traffic and access control personnel. (NUREG-0654/FEMA-REP-1, A.3; C.1,4; J.1O.g, j)

Assessment/Extent of Play Assessment of this DemonstrationCriterion may be accomplished during a biennialexercise, an actual event, staff assistance visit, or by means of drills conducted at any time.

OROs must demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with current conditions and PADs (e.g., evacuating, sheltering, and relocation) in a timely manner. OROs must demonstrate the capability to provide instructions to traffic and access control staff on actions to take when modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled.

Traffic and access control staff must demonstrate accurate knowledge of their roles and responsibilities, including verifying emergency worker identification and access authorization to the affected areas, as per the Extent-of-Play Agreement. These capabilities may be demonstrated by actual deployment or by interview, in accordance with the Extent-of-Play Agreement.

In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic), they must demonstrate the capability to contact the state or Federal agencies that have the needed authority, as agreed upon in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play EPZ EOCs and the SEOC will discuss their traffic and access control procedures with their respective FEMA Evaluators. Coordination will be demonstrated through discussion and phone calls which will be logged but no personnel or equipment will be dispatched.

110 23

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Criterion3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654/FEMA- REP-1, J.1O.k)

Assessment/Extent of Play Assessment of this DemonstrationCriterionmay be accomplished during a biennialexercise, on actual event, staff assistance visit, or by means of drills conducted at any time.

OROs must demonstrate the capability, as required by the scenario, to identify and take appropriate actions concerning impediments to evacuation. Actual dispatch of resources to deal with impediments, such as wreckers, need not be demonstrated; however, all contacts, actual or simulated, must be logged.

The impediment must occur during the evacuation and be on an evacuation route such that re-routing of traffic is. required, triggering decision-making and coordination with the JIC to communicate the alternate route to evacuees leaving the area.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play Each affected EOC staff (the six towns, the IFO and the state EOC) will demonstrate decision making regarding rerouting of traffic following a traffic impediment, in response to a controller inject. No personnel or equipment will be deployed to the simulated scene but the EOC staff will demonstrate decision making and coordination with appropriate agencies and other EOCs as needed.

111 24

Unclassified Radiological Emergency Preparedness Program (REP)

"Atter Action Report/Improvement Plan Ver'm<ont Yankee Power Station Sub-element 3.e - Implementation of Ingestion Pathway Decisions Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement protective actions, based on criteria recommended by current FDA guidance, for the ingestion exposure pathway EPZ (i.e., the area within an approximate 50-mile radius of the NPP). This Sub-element focuses on those actions required for implementation of protective actions.

Criterion3.e.1: The ORO demonstrates the availabilityand appropriateuse of adequateinformation regardingwater,food supplies, milk, and agriculturalproduction within the ingestion exposure pathway emergency planning zone for implementation of protective actions. NUREG-0654/FEMA-REP-1, A.3; C.1, 4;J.i1)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplished during a biennial exercise, an actual event, or by means of drills conducted at any time.

Applicable OROs must demonstrate the capability to secure and use current information on the locations of dairy farms, meat and poultry producers, fisheries, fruit growers, vegetable growers, grain producers, food processing plants, and water supply intake points to implement protective actions within the EPZ.

OROs use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex, and other resources (e.g., compacts, nuclear insurers), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play This criterion was successfully demonstrated in 2011.

112 25

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemiont Yankee Power Station Criterion3.e.2: Appropriatemeasures,strategies,and pre-printedinstructionalmaterialare developed for implementing protective action decisionsfor contaminatedwater,food products, milk, and agriculturalproduction. (NUREG-0654/FEMA-REP-1, G.1, J.9, 11)

Assessment/Extent of Play Assessment of this DemonstrationCriterionmay be accomplished during a biennial exercise, an actual event, or by means of drills conducted at any time.

OROs must demonstrate the development of measures and strategies for implementation of ingestion exposure pathway EPZ protective actions by formulating protective action information for the general public and food producers and processors. Demonstration of this criterion includes either pre-distributed public information material in the ingestion exposure pathway EPZ or the capability for rapid reproduction and distribution of appropriate reproduction-ready information and instructions to pre- determined individuals and businesses.

OROs must also demonstrate the capability to control, restrict, or prevent distribution of contaminated.

food by commercial sectors. Exercise play must include demonstration of communications and coordination among organizations to implement protective actions. Field play of implementation activities may be simulated. For example, communications and coordination with agencies responsible for enforcing food controls within the ingestion exposure pathway EPZ must be demonstrated, but actual communications with food producers and processors may be simulated.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play This criterion was successfully demonstrated in 2011.

113 26

Unclassified Radiological Emergency Preparedness Program (REP)

After Actioni Report/Improvernent Plan Vermont Yankee Power Station Sub-element 3.f- Implementation of Post-Plume Phase Relocation, Reentry, and Return Decisions Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement plans, procedures, and decisions for post-plume phase relocation, reentry, and return.

Implementation of these decisions is essential for protecting the public from direct long-term exposure to deposited radioactive materials from a severe incident at a commercial NPP.

Criterion3.f.1: Decisions regardingcontrolled reentry of emergency workers and relocationand return of the public during the post-plume phase are coordinatedwith appropriateorganizationsand implemented. (NUREG-0654/FEMA-REP-1, E.7; J.1O.j; J.12; K.5.b; M.1, 3)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a biennial, or tabletop exercise, or by means of drills conducted at any time.

Relocation: OROs must demonstrate the capability to coordinate and implement decisions concerning relocation of individuals located in radiologically contaminated areas who were not previously evacuated.

Such individuals must be relocated to an area(s) where radiological contamination will not expose the general public to doses that exceed the relocation PAGs. OROs must also demonstrate the capability to provide for short- or long-term relocation of evacuees who lived in an area(s) that has residual radiation levels above the (first-, second-, and 50-year) PAGs.

Areas of consideration must include the capability of OROs to communicate with other OROs regarding timing of actions, notification of the population of procedures for relocation, and notification of, and advice for, evacuated individuals who will be converted to relocation status in situations where they will not be able to return to their homes due to high levels of contamination. OROs must also demonstrate the capability to communicate instructions to the public regarding relocation decisions and intermediate-term housing for relocated persons.

Reentry: OROs must demonstrate the capability to control reentry and exit of individuals who are authorized by the ORO to temporarily reenter the restricted area during the post-plume (i.e., intermediate or late) phase to protect them from unnecessary radiation exposure. OROs must also demonstrate the capability to control exit of vehicles and other equipment to control the spread of contamination outside the restricted area(s). Individuals without specific radiological response missions, such as farmers for animal care, essential utility service personnel, or other members of the public who must reenter an evacuated area during the post-emergency phase must be limited to the lowest radiological exposure commensurate with completing their missions. Monitp4ing and decontamination facilities will be established as appropriate.

27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Examples of control procedures are: (1) assignment of, or checking for, direct-reading and permanent record dosimetry for emergency workers; (2) questions regarding the individuals' objective(s), location(s) expected to be visited, and associated timeframes; (3) maps and plots of radiation exposure rates; (4) advice on areas to avoid; (5) procedures for exit, including monitoring of individuals, vehicles, and equipment; (6) decision criteria regarding contamination; (7) proper disposition of emergency worker dosimetry, and (8) maintenance of emergency worker radiation exposure records.

Return: OROs must demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase. OROs must demonstrate the capability to identify and prioritize services and facilities that require restoration within a few days, and to identify procedures and resources for their restoration. Examples of these services and facilities are medical and social services, utilities, roads, and schools.

Communication among OROs for relocation, reentry, and return may be simulated. All simulated or actual contacts must be documented. These discussions may be accomplished in a group setting.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex, and other resources (e.g., compacts or nuclear insurers), as necessary, if available. Evaluation of this criterion will take into consideration the level of Federal and other r~esources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play This criterion was successfully demonstrated in 2011.

115 28

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station ASSESSMENT AREA 4: FIELD MEASUREMENTS AND ANALYSES Sub-element 4.a - Plume Phase Field Measurements and Analyses Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to deploy FMTs with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654/FEMA-REP-1 indicates that OROs must have the capability to use FMTs within the plume exposure pathway EPZ to detect airborne radioiodine in the presence of noble gases and radioactive particulate material in the airborne plume. In an incident at an NPP, the possible release of radioactive material may pose a risk to the nearby population and environment. Although incident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties. During an incident, it is important to collect field radiological data to help characterize any radiological release. Adequate equipment and procedures are essential to such field measurement efforts.

Criterion 4.a. 1: [RESERVED]

Criterion 4.o.2: Field teams (2 or more) are managed to obtain sufficient information to help characterize the release and to control radiationexposure. (NUREG-0654/FEMA-REP-1, C.1; H.12; 1.7, 8, 11; J.LO.a)

Assessment/Extent of Play Assessment of this DemonstrationCriterion may be accomplished during a biennialexercise. Other means may include drills that would fully demonstrate technical proficiency.

Responsible OROs must demonstrate the capability to brief FMTs on predicted plume location and direction, plume travel speed, and exposure control procedures before deployment. During an HAB incident, the Field Team management must keep the incident command informed of field monitoring teams' activities and location. Coordination with FMTs and field monitoring may be demonstrated as out-of-sequence demonstrations, as negotiated in the Extent-of-Play Agreement.

Field measurements are needed to help characterize the release and support the adequacy of implemented protective actions, or to be a factor in modifying protective actions. Teams must be directed to take measurements at such locations and times as necessary to provide sufficient information to characterize the plume and its impacts.

If the responsibility for obtaining peak measurements in the plume has been accepted by licensee field monitoring teams, with concurrence from OROs, there is no requirement for these measurements to be repeated by ORO monitoring teams. If the licensee FMTs do not obtain peak measurements in the plume, it is the ORO's decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coordination of plume measurement information among all FMTs (licensee, Federal, and ORO) is essential. Coordination concerrlilptransfer of samples, including a chain-of- custody form(s), to a radiological laboratory(ies) must be demonstrated.

29

Unclassified Radiological Emergency Preparedness Program (REP)

After Action ReporUimprovement Plan Vermont Yankee Power'Station OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee), as necessary. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play Coordination of the transfer of samples to a lab will be simulated and discussed in an interview with the FEMA Evaluator.

By agreement with Vermont Yankee, Vermont plume tracking teams will define the edge of the plume occurring in Vermont or other designated area while VY tracking teams will determine the center line of the plume.

VT Plume Tracking Team #2, PLAN ISSUES: 4.a.1., ISSUE NO.: 67-11-4a1-P-07 Lack of proper procedure for field check of Ludlum 14C.

Proper procedures have been incorporated and will be demonstrated successfully in the upcoming exercise.

117 30

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report!Improvenment Plan Vermont Yankee Power Station Criterion4.a.3: Ambient radiationmeasurements ore made and recordedat appropriatelocations, and radioiodineand particulatesamples are collected. Teams will move to an appropriatelow background location to determine whether any significant(as specified in the plan and/orprocedures)amount of radioactivityhas been collected on the sampling media. (NUREG-0654/FEMA-REP-1, C.1; H.12:1.8, 9; J.10.a)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise. Other means may include drills that would fully demonstrate technicalproficiency.

Two or more FMTs must demonstrate the capability to make and report measurements of ambient radiation to the field team coordinator, dose assessment team, or other appropriate authority. FMTs must also demonstrate the capability to obtain an air sample for measurement of airborne radioiodine and particulates, and to provide the appropriate authority with field data pertaining to measurement. If samples have radioactivity significantly above background, the authority must consider the need for expedited laboratory analyses of these samples.

OROs must share data in a timely manner with all other appropriate OROs. All methodology, including contamination control, instrumentation, preparation of samples, and a chain-of-custody form(s) for transfer to a laboratory(ies), will be in accordance with the ORO's plans/procedures.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play A minimum of two field teams will each pick up a minimum of two complete samples each consisting of an ambient radiation measurement and an air sample.

Charcoal filter cartridges may simulate use of Silver Zeolite filter media. Simulated cartridges will be prepared for transportation to the Lab for analysis.

Field data may be provided by Controllers to the Accident Assessment (Plume Tracking) Team to facilitate the accident assessment process during the exercise.

By agreement with Vermont Yankee, Vermont plume tracking teams will define the edge of the plume occurring in Vermont or other designated area while VY tracking teams will determine the center line of the plume.

NOTE: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant. After an "on the spot" re-training by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

118 31

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Sub-element 4.b - Post-Plume Phase Field Measurements and Sampling Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to assess the actual or potential magnitude and locations of radiological hazards to determine the ingestion exposure pathway EPZ and to support relocation, reentry, and return decisions. This Sub-element focuses on collecting environmental samples for laboratory analyses that are essential for decisions on protecting the public from contaminated food and water and direct radiation from deposited materials.

Criterion4.b.i: The field teams (2 or more) demonstrate the capability to make appropriate measurements and to collect appropriatesamples (e.g., food crops, milk, water, vegetation, and soil) to support adequateassessments andprotective action decision making.

(NUREG-0654/FEMA-REP-1, C.1; 1.8; J.11)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplished during a biennial or tabletop exercise.

Other means may include drills, seminars or trainingactivities that would fully demonstrate technical proficiency.

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

The FMTs and/or other sampling personnel must secure ingestion pathway samples from agricultural products and water. Samples in support of relocation and return must be secured from soil, vegetation, and other surfaces in areas that received radioactive ground deposition.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play This criterion was successfully demonstrated in 2011.

119 32

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Sub-element 4.c - Laboratory Operations Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to perform laboratory analyses of radioactivity in air, liquid, and environmental samples to support protective action decision making.

Criterion4.c.1: The laboratoryis capable of performing requiredradiologicalanalyses to support protective action decisions. (NUREG-0654/FEMA-REP-1, C.1, 3; J.11)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplished during a biennial, tabletop exercise, or.an actualevent. Other means may include drills, seminars or training activities that would fully demonstrate technicalproficiency.

The laboratorystaff must demonstrate the capability to follow appropriate procedures for receiving samples, including logging information, preventing contamination of the laboratory(ies), preventing buildup of background radiation due to stored samples, preventing cross contamination of samples, preserving samples that may spoil (e.g., milk), and keeping track of sample identity. In addition, the laboratory staff must demonstrate the capability to prepare samples for conducting measurements.

The laboratory(ies) must be appropriately equipped to provide, upon request, timely analyses of media of sufficient quality and sensitivity to support assessments and decisions anticipated in the ORO's plans/procedures. The laboratory instrument calibrations must be traceable to standards provided by the National Institute of Standards and Technology. Laboratory methods used to analyze typical radionuclides released in a reactor incident must be as described in the plans/procedures. New or revised methods may be used to analyze atypical radionuclide releases (e.g., transuranics or as a result of a terrorist incident) or if warranted by incident circumstances. Analysis may require resources beyond those of the ORO.

The laboratory staff must be qualified in radioanalytical techniques and contamination control procedures.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play 120 4.c.1 will be demonstrated ???

33

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Inprovement Plan - Vermont Yankee Power Station ASSESSMENT AREA 5: EMERGENCY NOTIFICATION AND PUBLIC INFORMATION Sub-element 5.a - Activation of the Prompt Alert and Notification System Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide prompt instructions to the public within the plume exposure pathway EPZ. Specific provisions addressed in this Sub-element are derived from the Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants, FEMA-REP-10 (November 1985).

Exhibit 111-4: Evaluation Standards for Alert and Notification Systems T Withina Demonstration Criterion: Ina Timely . Within 45 Reasonable Manner minutes Time .

Primary Alert and Notification _

5.a.1: ...covering essentially 100% of the 10-mile EPZ X ___

5.a.4: ...for FEMA-approved exception areas X Backup Alert and Notification for All Incidents 5.a.3: ...covering the 10-mile EPZ X Criterion 5.0.1: Activities associatedwith primaryalertingand notification of the public are completed in a timely mannerfollowing the initialdecision by authorized offsite emergency officials to notify the public of an emergency situation. The initialinstructionalmessage to the public must include as a minimum the elements requiredby currentREP guidance. (NUREG-0654/FEMA-REP-1, E.5, 6, 7)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplishedduring a biennialexercise, drills, or operationaltesting of equipment that would fully demonstrate capability.

Responsible OROs must demonstrate the capability to sequentially provide an alert signal followed by an initial instructional message to populated areas (permanent resident and transient) throughout the 10-mile plume EPZ. Following the decision to activate the alert and notification system, OROs must complete system activation for primary alert/notification and disseminate the information/instructions in a timely manner. For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." If message dissemination is identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

Procedures to broadcast the message must be fully demonstrated as they would in an actual emergency up to the point of transmission. Broadcast of the message(s) or test message(s) is not required. The procedures must be demonstrated up to the point of actual activation. The alert signal activation should be simulated, not performed. Evaluations of EAS broadcast stations may also be accomplished through SAVs. 121 34

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station The capability of the primary notification system to broadcast an instructional message on a 24-hour basis must be verified during an interview With appropriate personnel from the primary notification system, including verification of provisions for backup power or an alternate station.

The initial message must include at a minimum the following elements:

" Identification of the ORO responsible and the official with authority for providing the alert signal and instructional message;

• Identification of the commercial NPP and a statement that an emergency exists there;

• Reference to REP-specific emergency information (e.g., brochures, calendars, and/or information in telephone books) for use by the general public during an emergency; and

• A closing statement asking that the affected and potentially affected population stay tuned for additional information, or that the population tune to another station for additional information.

If route alerting is demonstrated as a primary method of alert and notification, it must be done in accordance with the ORO's plans/procedures and the Extent-of-Play Agreement. OROs must demonstrate the capability to accomplish the primary route alerting in a timely manner (not subject to specific time requirements). At least one route needs to be demonstrated and evaluated. The selected route(s) must vary from exercise to exercise. However, the most. difficult route(s) must be demonstrated no less than once every 8 years. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast) as negotiated in the extent of play. Actual testing of the mobile public address system will be conducted at an agreed-upon location.

OROs may demonstrate any means of primary alert and notification included in their plans/procedures as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play Actions to demonstrate performance of the notifications of the public will be performed up to the point of actual transmission of the EAS message. In the initial notification the National Weather Service will be contacted and a "Test" message will actually be transmitted. The IFO and the five town EOCs will report receipt (or non receipt) of the test message. The three states (VT, NH, & MA) will coordinate each public notification.

The simulated activation of the sirens for all three (3) States by the Commonwealth of Massachusetts will be demonstrated. Brattleboro and Vernon may demonstrate actions necessary to sound the sirens but will not activate the sirens.

All States will coordinate activities for the activation of the NOAA tone-alert radios throughout the EPZ.

Activation of the NOAA tone-alert radios by the State of Vermont will be demonstrated using a test message.

The simulated activation of the Code Red notification system for all 3 States by the State of New Hampshire will be demonstrated. 122 35

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee:Power Station Criterion5.a.2: [RESERVED]

Criterion5.a.3: Backup alert and notification of the public is completed within a reasonabletime following the detection by the ORO of a failure of the primaryalert and notificationsystem. (NUREG-0654/FEMA-REP-1, E.6, Appendix 3.B.2.c)

Assessment/Extent of Play Assessment of this DemonstrationCriterion may be accomplished during a biennialexercise, drills, or operationaltesting of equipment that would fully demonstratecapability.

If the exercise scenario calls for failure of any portion of the primary system(s) or if any portion of the primary system(s) actually fails to function during the exercise, OROs must demonstrate backup means of alert and notification. Backup means of alert and notification will differ from facility to facility.

Backup alert and notification procedures that would be implemented in multiple stages must be structured such that the population closest to the plant (e.g., within 2 miles) is alerted and notified first. The

• populations farther away and downwind of any potential radiological release would be covered*

sequentially (e.g., 2 to 5 miles, followed by downwind 5 to 10 miles, and finally the remaining population as directed by authorities). Topography, population density, existing ORO resources, and timing will be

• considered in judging the acceptability of backup means of alert and notification.

Although circumstances may not allow this for all situations, FEMA and the NRC recommend that OROs and operators attempt to establish backup means that will reach those in the plume exposure EPZ within a reasonable time of failure of the primary alert and notification system, with a recommended goal of 45 minutes. The backup alert message must, at a minimum, include (1) a statement that an emergency exists at the plant and (2) instructions regarding where to obtain additional information.

If backup route alerting is demonstrated, only one route needs to be selected and demonstrated. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast), as negotiated in the extent of play. Actual testing of the mobile public address system will be conducted at an agreed-upon location.

OROs may demonstrate any means of backup alert and notification included in their plans/procedures as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play Actual route alerting will not be conducted during exercise play. This criteria will be demonstrated during out of sequence meetings with the FEMA evaluators.

Brattleboro EOC- PLAN ISSUES: 5.a.3., ISSUE NO.: 67-11-5a3-P-10, Back-up Route Alerting in excess of 45 minutes. 123

- This planning issue will be resolved via an out-of-sequence meeting with the FEMA evaluator to successfully demonstrate the criteria.

36

Unclassified Radiological Emergency Preparedness Program (REP)

Aftee Action Report/Improvenient Plan Verniont Yankee Power Station Dummerston EOC, PLAN ISSUES: 5.a.3., ISSUE NO.: 67-11-5a3-P-08, Back-up Route Alerting in excess of 45 minutes.

- This planning issue will be resolved via an out-of-sequence meeting with the FEMA evaluator to successfully demonstrate the criteria.

Vernon EOC, PLAN ISSUES: 5.a.3., ISSUE NO.: 67-11-5a3-P-12, Back=up Route Alerting took in excess of 45 minutes.

- This planning issue will be resolved via an out-of-sequence meeting with the FEMA evaluator to successfully demonstrate the criteria.

124 37

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Criterion5.a.4: Activities associatedwith FEMA-approved exception areas(where applicable)are completed within 45 minutes following the initialdecision by authorized offsite emergency officials to notify the public of an emergency situation. (NUREG-0654/FEMA-REP-1, E.6; Appendix 3.B.2.c)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplishedduring a biennialexercise, drills, or operationaltesting of equipment that would fully demonstrate capability.

OROs with .FEMA-approved exception areas (identified in the approved Alert and Notification System Design Report), 5 to 10 miles from the NPP, must demonstrate the capability to accomplish primary alerting and notification of the exception area(s). FEMA and the NRC recommend that OROs and operators establish means that will reach those in approved exception areas within 45 minutes once the initial decision is made by authorized offsite emergency officials to notify the public of an incident. The exception.

area alert message must, at a minimum, include (1) a statement that an emergency exists at the plant and (2) instructions regarding whereto obtain additional information.

For exception area alerting, at least one route must be demonstrated and evaluated. The selected route(s) must vary from exercise.toexercise. However, the most difficult route(s) must be demonstrated no less than once every 8 years. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcasted) as negotiated in the extent of play. Actual testing of the mobile public address system will be conducted at an.

agreed-upon location. For exception areas alerted by air/water craft, actual routes will be negotiatedin .

the extent of play, but must be demonstrated no less than once every 8 years.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play Actual route alerting will not be conducted during exercise play. This criteria will be demonstrated during out of sequence meetings with the FEMA evaluators.

125 38

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemiont Yankee Power Station Sub-element 5.b - Subsequent Emergency Information and Instructions for the Public and the Media Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to disseminate appropriate emergency information and instructions, including any recommended protective actions, to the public. In addition, NUREG-0654/FEMA-REP-1 requires OROs to ensure that the capability exists for providing information to the media. This includes the availability of a physical location for use by the media during an emergency. NUREG-0654/FEMA-REP-1 also provides that a system must be available for dealing with rumors. This system will hereafter be known as the "public inquiry hotline."

Criterion5.b.1: OROs provide accuratesubsequent emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654/FEMA-REP-i, E.5, 7; G.3.a, G.4.a, c)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplished during a biennial exercise, or drills.

The responsible ORO personnel/representatives must demonstrate actions to provide emergency information and instructions to the public and media in a timely manner following the initial alert and notification (not subject to specific time requirements). For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." If message dissemination is identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

Message elements: The ORO must ensure that emergency information and instructions are consistent with PADs made by appropriate officials. The emergency information must contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, shelter-in-place instructions, information concerning protective actions for schools and persons with disabilities and access/functional needs, and public inquiry hotline telephone number) to assist the public in carrying out the PADs provided. The ORO must also be prepared to disclose and explain the ECL of the incident. At a minimum, this information must be included in media briefings and/or media releases. OROs must demonstrate the capability to use language that is clear and understandable to the public within both the plume and ingestion exposure pathway EPZs. This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas.

The emergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5.a.1 and previously identified protective action areas that are still valid, as well as new areas. The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. In addition, the OROs must demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures. OROs must Jl~onstrate the capability to develop emergency information in a non-English language when required by the plans/procedures.

39

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station If ingestion pathway measures are exercised, OROs must demonstrate that a system exists for rapid dissemination of ingestion pathway information to pre-determined individuals and businesses in accordance with the ORO's plans/procedures.

Media information: OROs must demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the incident warrants. The OROs must demonstrate the capability to respond appropriately to inquiries from the news media. All information presented in media briefings and releases must be consistent with PADs and other emergency information provided to the public. Copies of pertinent emergency information (e.g., EAS messages and media releases) and media information kits must be available for dissemination to the media.

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

HAB considerations: The dissemination of information dealing with specific aspects of NPP security capabilities, actual or perceived adversarial (terrorist) force or threat, and tactical law enforcement response must be coordinated/communicated with appropriate security authorities, e.g., law enforcement and NPP security agencies, in accordance with ORO plans/procedures.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play State EOC- Control cell personnel will make calls simulating members of the public and media personnel.

The Public Information staff will demonstrate receiving calls on the public information line. They will demonstrate identifying and properly handling rumortrends.

Joint Information Center- Controllers will act as media representatives. Information generated as a result of incoming calls to the Public Information staff at the state EOC will be included in a news briefing. At least one rumor trend will be included.

EPZ EOCs- Control cell personnel will make calls to each town EOC simulating members of the public. Each EOC will demonstrate determining which call(s) may be handled by the town EOC (inquiries about town response actions) and which call(s) must be referred to the Information Officer staff at the State EOC.

NOTE: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant. After an "on the spot" re-training by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

127 40

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station ASSESSMENT AREA 6: SUPPORT OPERATIONS/FACILITIES Sub-element 6.a - Monitoring, Decontamination, and Registration of Evacuees Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement radiological monitoring and decontamination of evacuees, while minimizing contamination of the facility. OROs must also have the capability to identify and register evacuees at reception centers.

Criterion 6.a.1: The reception centerfacility has appropriatespace, adequateresources, and trained personnel to provide monitoring, decontamination,and registrationof evacuees. (NUREG-0654/FEMA-REP-1, A.3; C.4; J.1O.h; J.12)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplishedduring a biennial exercise, an actual event, drills, or SAV.

Radiological monitoring, decontamination, and registration facilities for evacuees must be set up and demonstrated as they would be in an actual emergency or as indicated in the Extent-of-Play Agreement.

OROs conducting this demonstration must have one-third of the resources (e.g., monitoring teams/instrumentation/portal monitors) available at the facility(ies) as necessary to monitor 20 percent of the population within a 12-hour period. This would include adequate space for evacuees' vehicles.

Availability of resources can be demonstrated with valid documentation (e.g., MOU/LOA, etc.) reflecting how necessary equipment would be procured for the location. Plans/procedures must indicate provisions for service animals.

Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. Staff responsible for the radiological monitoring of evacuees must demonstrate the capability to attain and sustain, within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a monitoring productivity rate per hour needed to monitor the 20 percent EPZ population planning base. The monitoring productivity rate per hour is the number of evacuees that can be monitored, per hour, by the total complement of monitors using an appropriate procedure. For demonstration of monitoring, decontamination, and registration capabilities, a minimum of six evacuees must be monitored per station using equipment and procedures specified in the plans/procedures. The monitoring sequences for the first six simulated evacuees per monitoring team will be timed by the evaluators to determine whether the 12-hour requirement can be met.

OROs must demonstrate the capability to register evacuees upon completion of the monitoring and decontamination activities. The activities for recording radiological monitoring and, if necessary, decontamination must include establishing a registration record consisting of the evacuee's name, address, results of monitoring, and time of decontamination (if any), or as otherwise designated in the plan and/or procedures. Audio recorders, camcorders, or written records are all acceptable means for registration.

Monitoring activities shall not be simulated. Monitotfi3 personnel must explain use of trigger/action levels for determining the need for decontamination. They must also explain the procedures for referring any evacuees who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures. Contamination of the evacuee(s) will be determined by controller inject and not 41

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee'Power Station simulated with any low-level radiation source. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Decontamination of evacuees may be simulated and conducted by interview. Provisions for separate showering and same-sex decontamination must be demonstrated or explained. The staff must demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated evacuees, provide changes of clothing for those with contaminated clothing; and store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities. In addition, for any evacuee found to be contaminated, procedures must be discussed concerning handling of potential contamination of vehicles and personal belongings. Waste water from decontamination operations does not need to be collected.

Individuals who have completed monitoring (and decontamination, if needed) must have means (e.g.,

hand stamp, sticker, bracelet, form, etc) indicating that they, and their service animals and vehicles, where applicable, have been monitored, cleared, and found to have no contamination or contamination below the trigger/action level.

In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored. These individuals do not require confirmation that their vehicle is free from contamination prior to entering the congregate care areas.

However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles monitored and decontaminated (if applicable) and do require confirmation that their vehicle is free from contamination prior to entering the congregate care areas.

Vermont Extent of Play Criterion 6.a.1 was demonstrated in 2008 and will not be demonstrated in 2013.

129 42

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Sub-element 6.b - Monitoring and Decontamination of Emergency Workers and their Equipment and Vehicles Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement radiological monitoring and decontamination of emergency workers and their equipment, inclusive of vehicles.

Criterion 6.b.1: The facility/ORO has adequate procedures and resourcesto accomplish monitoring and decontaminationof emergency workers and their equipment and vehicles. (NUREG-0654/FEMA-REP-I, K.5.a, b)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplished during a biennial exercise, drills, an actual event, or SAV.

The monitoring staff must demonstrate the capability to monitor emergency worker personnel and their equipment and vehicles for contamination in accordancewith the ORO's plans/procedures.

Specific attention must be given to equipment, including any vehicles that were in contact with contamination. The monitoring staff must demonstrate the capability to make decisions on the need for decontamination of personnel, equipment, and vehicles based on trigger/action levels and procedures stated in the ORO plans/procedures. Monitoring of emergency workers does not have to meet the 12-hour requirement. However, appropriate monitoring procedures must be demonstrated for a minimum of two emergency workers and their equipment and vehicles. Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation.

The area to be used for monitoring and decontamination must be set up as it would be in an actual emergency, with all route markings, instrumentation, record keeping, and contamination control measures in place. Monitoring procedures must be demonstrated for a minimum of one vehicle. It is generally not necessary to monitor the entire surface of vehicles. However, the capability to monitor areas such as radiator grills, bumpers, wheel wells, tires, and door handles must be demonstrated. Interior surfaces of vehicles that were in contact with contaminated individuals must also be checked.

Decontamination of emergency workers may be simulated and conducted via interview. Provisions for separate showering and same-sex decontamination must be demonstrated or explained. The staff must demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated individuals where applicable; provide changes of clothing for those with contaminated clothing; and store contaminated clothing and personal belongings to prevent further contamination of emergency workers or facilities.

OROs must demonstrate the capability to register emergency workers upon completion of the monitoring and decontamination activities. The activities for reqqging radiological monitoring and, if necessary, decontamination must include establishing a registration record consisting of the emergency worker's name, address, results of monitoring, and time of decontamination (if any), or as otherwise designated in 43

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power'Station the plan and/or procedures. Audio recorders, camcorders, or written records are all acceptable means for registration.

Monitoring activities shall not be simulated. Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. They must also explain the procedures for referring any emergency workers who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures. Contamination of the individual(s) willbe determined by controller inject and not simulated with any low-level radiation source.

Decontamination capabilities and provisions for vehicles and equipment that cannot be successfully decontaminated may be simulated and conducted by interview. Waste water from decontamination operations does not need to be collected.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play Criterion 6.b.1 was demonstrated in 2007 and will not be demonstrated in 2013.

131 44

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yahkee Power Station Sub-element 6.c - Temporary Care of Evacuees Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires OROs to have thecapability to establish relocation centers in host/support jurisdictions. The American Red Cross normally provides congregate care in support of OROs under existing letters of agreement.

Criterion6.c.i: Managers of congregatecare facilities demonstrate that the centers have resources to provide services and accommodationsconsistent with American Red Cross planning guidelines.

Managersdemonstrate the procedures to assure that evacuees have been monitoredfor contamination andhave been decontaminatedas appropriatepriorto entering congregatecarefacilities. (NUREG-0654/FEMA-REP-1, J.1O.h, J.12)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplished during a biennial exercise; drills, an.

actual event, or SAV.

The evaluator must conduct a walk-through of the center to determine, through observation and inquiries, that the services and accommodations are consistent with applicable guidance.

For planningpurposes, OROs must plan for a sufficient number of congregate care centers in host/support jurisdictions to accommodate a minimum of 20 96of the EPZ population. In this simulation, it is percent95F not necessary to set up operations as they would be in an actual emergency. Alternatively, capabilities may be demonstrated by setting up stations for various services and providing those services to simulated evacuees. Given the substantial differences between demonstration and simulation of this criterion, exercise demonstration expectations must be clearly specified in Extent-of-Play Agreements.

Congregate care staff must also demonstrate the capability to ensure that evacuees, service animals, and vehicles have been monitored for contamination, decontaminated as appropriate, and registered before entering the facility.

Individuals arriving at congregate care facilities must have means (e.g., hand stamp, sticker, bracelet, form, etc.) indicating that they, and their service animals and vehicles, where applicable, have been monitored, cleared, and found to have no contamination or contamination below the trigger/action level.

In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored. These individuals do not need confirmation that their vehicle is free from contamination prior to entering the congregate care areas.

However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles monitored and decontaminated (if applicable) and do need confirmation that their vehicle is free from contamination prior to entering the co1L*pgate care areas. This capability may be determined through an interview process.

45

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station If operations at the center are demonstrated, material that would be difficult or expensive to transport (e.g., cots, blankets, sundries, and large-scale food supplies) need not be physically available at the facility(ies). However, availability of such items must be verified by providing the evaluator a list of sources with locations and estimates of quantities.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Vermont Extent of Play Congregate care centers will not be activated. Current shelter surveys will be provided to FEMA for review. Based on FEMA's survey review, a tour of selected (some, all, or none) congregate care facilities that support the Bellows Falls reception center, will be conducted if needed with a controller and an American Red Cross representative out of sequence.

133 46

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan " Vermont Yankee Power Station Sub-element 6.d -Transportation and Treatment of Contaminated Injured Individuals Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

Criterion6.d.1: The facility/ORO has the appropriatespace, adequateresources,and trainedpersonnel to provide transport,monitoring, decontamination,and medical services to contaminatedinjured individuals. (NUREG-0654/FEMA-REP-1, F.2; H.IO; K.5.a, b; L.1, 4)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplishedduring a biennialexercise, an actual event, or drills.

Monitoring, decontamination, and contamination control efforts must not delay urgent medical care for the victim.

OROs must demonstrate the capability to transport contaminated injured individuals to medical facilities.

An ambulance must be used for response to the victim. However, to avoid taking an ambulance out of service for an extended time, OROs may use any vehicle (e.g., car, truck, or van) to transport the victim to the medical facility. Normal communications between the ambulance/dispatcher and the receiving medical facility must be demonstrated. If a substitute vehicle is used for transport to the medical facility, this communication must occur before releasing the ambulance from the drill. This communication would include reporting radiation monitoring results, if available. In addition, the ambulance crew must demonstrate, by interview, knowledge of where the ambulance and crew would be monitored and decontaminated, if. required, or whom to contact for such information.

Monitoring of the victim may be performed before transport or en route, or may be deferred to the medical facility. Before using monitoring instruments, the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. All monitoring activities must be completed as they would be in an actual emergency. Appropriate contamination control measures must be demonstrated before and during transport and at the receiving medical facility.

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

The medical facility must demonstrate the capability to make decisions on the need for decontamination of the individual, follow appropriate decontamination procedures, and maintain records of all survey measurements and samples taken. All procedures for collection and analysis of samples and decontamination of the individual must be demonstrated or described to the evaluator. Waste water from decontamination operations must be handled according to facility plans/procedures.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

134 Vermont Extent of Play Criterion 6.d.1 was successfully demonstrated in 2008 and will not be demonstrated in 2013.

47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 135 48

Unclassified Radiological Emergency Preparedness Program (REP)

'After Action Report/Improvement Plan Vermont Yankee Power Station COMMONWEALTH OF MASSACHUSETTS EVALUATION AREAS AND EXTENT OF PLAY VERMONT YANKEE NUCLEAR POWER STATION EXERCISE JUNE 5, 2013 Overview The following locations and organizations will demonstrate in 2013:

State Emergency Operations Center Massachusetts Emergency Management Agency (MEMA)

Massachusetts Department of Public Health (MDPH)

Massachusetts State Police (MSP)

Massachusetts Department of Transportation (MassDOT)

Massachusetts National Guard American Red Cross of Massachusetts Bay (ARC)

Federal Emergency Management Agency Region I (FEMA)

Mass-211 Operations Center Region III!IV Emergency Operations Center Massachusetts Emergency Management Agency Massachusetts State Police Troop B Massachusetts Department of Transportation (MassDOT) District 2 Department of Conservation & Recreation, District 9 Fire Warden (DCR)

Massachusetts Department of Fish and Game Office of Law Enforcement (MDFG - OLE)

American Red Cross of Pioneer Valley Radio Amateur Civil Emergency Service Operators (RACES)

Vermont Yankee Emergency Operations Facility Massachusetts Emergency Management Agency Massachusetts Department of Public Health Vermont Yankee Joint Information Center Massachusetts Emergency Management Agency Radiological Field Monitoring and Sampling Teams Massachusetts Department of Public Health - Nuclear Incident Advisory Team (NIAT)

Risk Jurisdictions Bernardston EOC Colrain EOC 136 Gill EOC Greenfield EOC 49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Leyden EOC Northfield EOC Warwick EOC Shelburne Control Dispatch Center EAS Radio Station WBZ 1030 AM The following organizations/locations have demonstrated this cycle and will not demonstrate in 2013:

Mohawk Trail Regional School District Colrain Central School Linden Hill School Northfield/Mount Hermon School Giving Tree Preschool Pioneer Valley School District Superintendent's Office Bernardston Elementary School Pearl Rhode Elementary School Northfield Elementary School Pioneer Valley Regional High School Warwick Community School Gill-Montague Regional School District Full Circle School Gill Elementary School Camps Camp Lion Northfield Bible Conference Inc.

Camp Keewanee Transportation Provider F. M. Kusimeskus, Inc.

First Student Bus Company MDPH Laboratory Jamaica Plain Massachusetts Department of Transportation District 2, Deerfield Maintenance Division Massachusetts Department of Conservation & Recreation District 9 - Fire Warden HQ, Rte. 2, Erving, MA37 Northfield State Forest, Western Section - Northfield Northfield State Forest, Eastern Section (Warwick State Forest) - Warwick 50

Unclassified Radiological Emergency Preparedness Program (REP)

AfterAction Report/Improvement Plan Vermont Yankee Power Station Mt. Grace State Forest - Warwick Leyden State Forest - Leyden Erving State Forest - Erving MS-I Hospital Franklin Medical Center Massachusetts State Police Troop B at Headquarters, Northampton, MA, Reception Center Greenfield Community College Radiological Monitoring & Decontamination Station Greenfield Community College Host Facility Turners Falls High School KI Dispensing Center Northampton KI Dispensing Site NOTE: "On the Spot" corrections approved for the below mentioned sub-elements, as per FEMA Region I MEMORANDUM dated, February 27, 2012.

Note: If during the exercise, a participant demonstrates sub-element l.d. 1, L.e. 1, 3.a. 1, 3.b. 1, 3.d. 1, 3.d.2, 4.a.3, 4.b. I or 5.b. 1, 6.a. I and 6.b. I unsatisfactorily, the FEMA Evaluator will inform the participant and the Controller. After an "on the spot" re-training by the state or local organization, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

138 51

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station ASSESSMENT AREA 1: Emergencvi OperationsManagement Sub-element L.a - Mobilization Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to alert, notify, and mobilize emergency personnel, and activate and staff emergency facilities.

Criterion 1.a.1: OROs use effective proceduresto alert, notify, and mobilize emergency personnel and activatefacilities in a timely manner. (NUREG-0654/

FEMA-REP-1, A.l.a, e; A.3, 4; C.1,4, 6; D.4; E.1, 2; H.3., 4)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplishedduring a biennialexercise, an actual event, out-of-sequence evaluation or by means of drills conducted at any time.

Responsible OROs must demonstrate the capability to receive notification of an incident from the licensee; verify the notification; and contact, alert, and mobilize key emergency personnel in a timely manner and demonstrate the ability to maintain and staff 24-hour operations. Twenty-four-hour operations can be demonstrated during the:exercise via rosters or shift changes or otherwise in an actual activation. Local responders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management organizations of an incident in a timely manner, when they receive information from the licensee or alternate sources. Responsible OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival.

Activation of facilities and staff, including those associated with the Incident Command System, must be completed in accordance with ORO plans/procedures. The location and contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP after these facilities have been activated.

Pre-positioning of emergency personnel is appropriate, in accordance with the Extent-of-Play Agreement, at those facilities located beyond a normal commuting distance from the individual's duty location or residence. This includes the staggered release of resources from an assembly area. Additionally, prepositioning of staff for out-of-sequence demonstrations may be used in accordance with the Extent-of-Play Agreement.

The REP program does not evaluate Incident Command Post tactical operations (e.g., Law Enforcement hostile action suppression techniques), only coordination among the incident command, the utility, and all appropriate OROs, pursuant to plans/procedures.

Initial law enforcement, fire service, HAZMAT, and emergency medical response to the NPP site may impact the ability to staff REP functions. The ability to identify and request additional resources or identify compensatory measures must be demonstrated. Exercises must also address the role of mutual aid in the incident, as appropriate. An integral part of the response to an HAB scenario at an NPP may also be within the auspices of the Federal Government (e.g., FBI, NRC, or DHS). Protocols for requesting Federal, state, local, and tribal law enforcement support must be demonstrated, as appropriate. Any resources must be on the ORO's mobilization list so they can be contacted during an incident, if needed.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specifiefY39 the Extent-of-Play Agreement.

52

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Massachusetts Extent of Play State EOC: MEMA SEOC emriergency.staff, including the Massachusetts Emergency Management Team staff (MA Department of'Public Health, MassDOT, MA State Police, MA National Guard, American Red Cross and FEMA Liaison), and the MASS 211 Liaison will be prestaged in the SEOC.. and upon notificatiohn will report to the Operations Room, using a ten-minute per hour

.ravel tinme. TheIMASS 211 Call Ceniiterill be activa'ld for a nuclear poer plan eventat Vermont Yankee. The notification process will be completed and call down rosters will be shown to the FEMA Evaluator.  :

iRegionrI/IV EOC: MEMA Region.11I1/ *and emergency volurit*e staff will be prestaged outside of the EOC, and upon notification, will report to the Operations Room using a ten-minute per hour travel time.

EOF: MEMA and MDPH emergency staffw7ll1be prestaged, the area of the EOF, and upon notification, will report to the EOF using a ten-minute per hour travel time.

Joint InformationiCenter: MEMA staff will be prestaged in the area of the JIC, and upon notification, will report to.the JIC,.using a en-minutep er hour travel time..

EPZ Local EO~s: LEOG emergency response staff will be prestaged outside the EOC. :Once notified to report, they will use a compressed reporting time of 10 minutes/hour of normal travel.

NIATF*ield Momitoring Team Personnel: NIAT Field Team emergency response staff will be prestaged, and upon notification will report to the assigned location.

" "z; " ,' * * ... . ,." :. * ': . ..i~ .':,,".

Sub-element 1. b - Facilities Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have facilities to support the emergency response.

Criterion 1.b. 1: Facilitiesare sufficient to support the emergencly response.

(NUREG-0654/FEMA-REP-1, H.3; G.3.a; J. 10.h; J..12; K.5.b)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplished during a biennial exercise, an actual event, staff assistance visits, or by out-of-sequence evaluations.

Responsible OROs must demonstrate, no less than once every eight years, the availability of facilities to support accomplishment of emergency operations (this includes all alternate and backup facilities).

Evaluations are typically performed for EOCs and JlCs, as well as other facilities such as reception/relocation centers. Some of the areas evalueaW1 within the facilities are adequate space, furnishings, lighting, restrooms, ventilation, backup power, and/or alternate facility, if required to support operations. Radio stations, laboratories, initial warning points and hospitals are not evaluated under L.b. 1.

53

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vertilont Yankee Power Station In addition, facilities will be evaluated for this criterion during the first biennial exercise after any new or substantial changes in structure, equipment, or mission that affect key capabilities, as outlined in respective emergency plans/procedures. A substantial change is one that has a direct effect or impact on emergency response operations performed in those facilities. Examples of substantial changes include:

modifying the size or configuration of an emergency operations center, adding more function to a center, or changing the equipment available for use in a center.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play

.Thereare no ne or ren. ed EOCs. ,..k.. ..

Sub-element 1.c - Direction and Control Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to control their overall response to an emergency Criterion1.c.l: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible. (NUREG-0654/FEMAREP-1, A.l.d; A.2.a, b; A.3; C.4, 6)

AssessmentlExtent of Play Assessment of this Demonstration Criterionmay be accomplished in a biennial or tabletop exercise.

Leadership personnel must demonstrate the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed through periodic briefings and/or other means, coordinating with other OROs, and ensuring completion of requirements and requests.) Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources. Any resources identified through LOA/MOUs must be on the ORO's mobilization list so they may be contacted during an incident, if needed.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play EPZ EOCs: If any towns are directed to evacuate, EOC personnel will demonstrate continuity of government through a discussion of logistics. Closing of the local EOC and relocation to a facility outside the EPZ will be simulated through discussion.

141 54

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan ........ Vemiont Yankee Power Station Sub-element 1.d - CommunicationsEquipment Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs establish and operate reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as contiguous governments within the EPZ, Federal emergency response organizations, the licensee and its facilities, EOCs, Incident Command Posts, and FMTs.

Criterion l.d. 1: At least two communication systems areavailable,at least one operates properly, and communication links are establishedand maintainedwith appropriate locations. Communications capabilitiesare managed in support of emergency operations.

(NUREG-0654/FEMA-REP-1, F.1, 2)

Assessment/Extent of Play Assessment of this Demonstration Criterion is accomplishedinitially in a baseline evaluation and subsequently in periodic testing and drills. System familiarit, and use must be demonstratedas applicable in biennialor tabletop exercise, or if their use would be required,during an actual event OROs must demonstrate that a primary system, and at least one backup system for fixed facilities, is fully functional at all times. Communications systems are maintained and tested on a recurring basis throughout the assessment period and system status is available to all operators. Periodic test results and corrective actions are maintained on a real time basis. If a communications system or systems are not functional, but exercise performance is not affected, no exercise issue will be assessed.

Communications equipment and procedures for facilities and field units are used as needed for transmission and receipt of exercise messages. All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

Exercise scenarios may require the failure of a communication system and use of an alternate system, as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play el " .ý 4._" _.." ;,' .. .: . . I. lated Contact with locations not payingwill be simulated.

Note: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant and the Controller. After an " on the spot" re-training by the state or local organization, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that s4i*2 day.

55

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Sub-element 1.e - Equipment and Supplies to Support Operations Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have emergency equipment and supplies adequate to support the emergency response.

Criterion L.e. 1: Equipment, maps, displays, monitoring instruments, dosimetry, potassium iodide (KI) and other supplies are sufficient to supportemergency operations(NUREG-0654/FEMA-REP-), H. 7, 10; L 7, 8, 9; J.I0.a, b, e; J.11, 12; K.3.a; K.5.b)

Assessment/Extent of Play Assessment of this Demonstration Criterion is accomplishedprimarily through a baseline evaluation and subsequentperiodic inspections.

A particular facility's equipment and supplies must be sufficient and consistent with that facility's assigned role. in the ORO's emergency operations plans. Use of maps and other displays is encouraged.

For non-facility-based operations, the equipment and supplies must be sufficient and consistent with-the assigned operational role. At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available, or their availability described.

Specific equipment and supplies that must be demonstrated under this criterion include KI inventories, dosimetry, and monitoring equipment, as follows:

KI: Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (1) emergency workers; (2) institutionalized individuals, as indicated in capacity lists for facilities; and (3) where stipulated by the plans/procedures, members of the general public (including transients).

within the plume pathway EPZ. In addition, OROs must demonstrate provisions to make KI available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures). The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI, as well as a mechanism for identifying emergency workers that have declined KI in advance. Consider carefully the placement of emergency workers that have declined KI in advance.

ORO quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical inspection at the storage location(s) or through documentation of current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. Available supplies of KI must be within the expiration date indicated on KI bottles or blister packs. As an alternative, the ORO may produce a letter from a certified private or state laboratory indicating that the KI supply remains potent, in accordance with U.S. Pharmacopoeia standards.

Dosimetry: Sufficient quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers must be available for issuance to all emergency workers who will be dispatched to perform an ORO mission. In addition, OROs must demonstrate provisions to make dosimetry available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures).

Appropriate direct-reading dosimetry must allow ani vidual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures.

Direct-reading dosimeters must be zeroed or operationally checked prior to issuance. The dosimeters must 56

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station be inspected for electrical leakage at least annually and replaced when necessary. Civil Defense Victoreen Model 138s (CD V-138s) (0-200 mR), due to their documented history of electrical leakage problems, must be inspected for electrical leakage at least quarterly and replaced when necessary. This leakage testing will be verified during the exercise, through documentation submitted in the ALC and/or through an SAV.

Operational checks and testing of electronic dosimeters must be in accordance with the manufacturer's instructions and be verified during the exercise, through documentation submitted in the ALC and/or through an SAV.

Monitoring Instruments: All instruments must be inspected, inventoried, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations.

Unmodified CDV-700 series instruments and other instruments without a manufacturer's recommendation must be calibrated annually. Modified CDV-700 instruments must be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration must be on each instrument or calibrated frequency can be verified by other means. In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source.

For FMTs, the instruments must be capable of measuring gamma exposure rates and detecting beta radiation. These instruments must be capable of measuring a range of activity and exposure, including radiological protection/exposure control of team members and detection of activity on air sample , -

collection media, consistent with the intended use of the instrument and the ORO's plans/procedures.. An appropriate radioactive check source must be used to verify proper operational response for each lowrange radiation measurement instrument (less than I R/hr) and for high-range instruments when available. If a source is not available for a high-range instrument, a procedure must exist to operationally test the instrument before entering an area where only a high-range instrument can make useful readings.

In areas where portalmonitors are used, the OROs must set up and operationally check the monitor(s).

The monitor(s) must conform to the standards set forth in the ContaminationMonitoringStandardfor a PortalMonitor Usedfor Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement Massachusetts Extent of Play Participating facilities will demonstrate that equipment, maps, displays, dosimetry, KI and other supplies are adequate and sufficient to support the emergency response.

MA NIAT Field Teams will be dispatched from the Greenfield Fire Department located on 512 Main Street, Greenfield, MA. in accordance with section D.4 of the NIAT Handbook.

FEMA will provide copies of the Annual Letter of Certification to evaluators, as appropriate.

• .  :* . ** .1, ..:1 57

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan - Vermont Yankee Power Station Note: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inforni the participant and the Controller. After an " on the spot" re-training by the state or local organization, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

ASSESSMENT AREA 2: ProtectiveAction Decision-Making Sub-element 2.a - Emergencl' Worker Exposure Control Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place, as specified in the ORO's plans/procedures, to authorize emergency worker exposure limits to be exceeded for specific missions.

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

Criterion2.a. 1: OROs use a decision-makingprocess, consideringrelevantfactors and appropriate coordination,to ensurethat an exposure control system, including the use of K1, is in placefor emergency workers, includingprovisionsto authorizeradiationecposure in excess of administrativelimits or protective action guides. (NUREG-0654/FEMA-REP-1, C.6; J.10. e,f, K.A4)

Assessment/Extent of Play Assessment of this DemonstrationCriterionmust be assessedconcurrentl/ with a licensee exercise and may be demonstratedin a biennialor tabletop exercise.

OROs authorized to send emergency workers into the plume exposure pathway EPZ must demonstrate a capability to comply with emergency worker exposure limits based on their emergency plans/procedures.

Participating OROs must also demonstrate the capability to make decisions concerning authorization of exposure levels in excess of pre-authorized levels and the number of emergency workers receiving radiation doses above pre-authorized levels. This would include providing KI and dosimetry in a timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating actions, in accordance with respective plans/procedures.

As appropriate, OROs must demonstrate the capability to make decisions on the distribution and administration of KI as a protective measure for emergency workers, based on their plans/procedures or projected thyroid dose compared with the established PAGs for KI administration.

All activities must be based on the ORO's plans/prclures 4 and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Vermont Yankee Power Station Massachusetts Extent of Play Protective action decisions are demonstrated at the Massachusetts State EOC based upon information provided from the EOF.

Radiation Control Program EOF staff will analyze utility, field team and meteorological data provided at the EOF to make a recommendation to the State EOC for their consideration in making protective action decisions.

Sub-element 2.b. - RadiologicalAssessment and ProtectiveAction Recommendations and Decisions for the Plume Phase of the Emergency Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to independently project integrated dose from projected or actual dose rates and compare these estimates to the PAGs.

OROs must have the capability to choose, among a range of protective actions, those most appropriate in a given emergency. OROs base these choices on PAGs from their plans/procedures or EPA's Manualof ProtectiveAction Guides and ProtectiveActionsfor NuclearIncidents and other criteria, such as plant conditions, licensee PARs, coordination of PADs with other political jurisdictions (e.g., other affected OROs and incident comninand), availability of in-place shelter, weather conditions, and situations, to include I1AB incidents, the threat posed by the specific hostile action, the affiliated response, and the effect of an evacuation on the threat response effort, that create higher than normal risk from general population evacuation.

Criterion2.b. 1: Appropriateprotective action recommendations(PARs) are based on available informationon plant conditions,field monitoring data,and licensee and ORO dose projections,as well as knowledge of onsite and offsite environmental conditions.

(NUREG-O654IFEMA-REP-1, 1.10 and Supplement 3)

Assessment/Extent of Play Assessment of this Demonstration Criterionmust be accomplishedconcurrently with a licensee exercise andmay be demonstratedin a biennialor tabletop exercise.

During the initial stage of the emergency response, following notification of plant conditions that may warrant offsite protective actions, the ORO must demonstrate the capability to use appropriate means, described in the plans/procedures, to develop PARs for decision-makers based on available information and recommendations provided by the licensee as well as field monitoring data, if available. The ORO must also consider any release and meteorological data provided by the licensee.

The ORO must demonstrate a reliable capability to independently validate dose projections. The types of calculations to be demonstrated depend on the data available and the need for assessments to support the PARs must be appropriate to the scenario. In all cases, calculation of projected dose must be demonstrated. Projected doses must be related to quantities and units of the PAG to which they will be compared. PARs must be promptly transmitted to decision-makers in a pre-arranged format.

When the licensee and ORO projected doses differ k4 6iore than a factor of 10, the ORO and licensee must determine the source of the difference by discussing input data and assumptions, using different models, or exploring possible reasons. Resolution of these differences must be incorporated into the 59

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/l]mprovement Plan Verhiont Yankee Power Station PARs if timely and appropriate. The.ORO must demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated PARs.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play This evaluation area will be demonstrated in accordance with the NIAT Handbook in the context of the exercise scenario.

The State EOC decision making team will evaluate the protective action recommendations of the NIAT accident assessment team and develop appropriate protective action decisions.

Protective action recommendations will be made in accordance with the MARERP and NIAT Handbook.

Criterion 2.b. 2: A decision-makingprocess involving consideration of appropriatefactors and necessary coordinationis used to make protective action decisions (PAD)for the generalpublic (including the recommendationfor the use of Kl, if OROpolic,). (NUREG-0654, J.9, 1O.f. mn Assessment/Extent of Play Assessment of this Demonstration Criterionmust be accomplishedconcurrently with a licensee exercise and many be demonstratedin a biennialor tabletop exercise.

OROs must have the capability to make both initial and subsequent PADs. OROs must demonstrate the capability to make initial PADs in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO authorities (e.g., incident command), and PARs from the utility and ORO staff. In addition, a subsequent or alternate PAD may be appropriate if various conditions (e.g., an HAB incident, weather, release timing and magnitude) pose undue risk to an evacuation, or if evacuation may disrupt the efforts to respond to a hostile action.

OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a PAD if local law enforcement, fire service, HAZMAT, and emergency medical resources are utilized to augment response to the NPP site or other key infrastructure.

Dose assessment personnel may provide additional PARs based on the subsequent dose projections, field monitoring data, or information on plant conditions. In addition, incident command must provide input regarding considerations for subsequent PARs based on the magnitude of the ongoing threat, the response, and/or site conditions. The decision-makers must demonstrate the capability to change protective actions based on the combination of all these factors.

If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must demonstrate the capability to make decisions on the distribution and administration of KI to supplement sheltering and eAiO'uation. This decision must be based on the ORO's plans/procedures or projected thyroid dose compared with the established PAG for KI administration. The KI decision-making process must involve close coordination with appropriate assessment and decision-making staff.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate PADs with each other. In addition, decisions must be coordinated/communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play Protective action decisions are demonstrated at the Massachusetts State EOC based upon information provided by the EOF. MEMA and MDPH Radiation Control Program staff will analyze utility, field team and meteorological data provided at the EOF to make a recommendation to the State EOC for their consideration in making protective action decisions.

Sub-element 2.c - PAD Considerationfor the Protectionof Persons with Disabilitiesand Access/FunctionalNeeds Intent This Sub-element is derived from NUREG-0654/FEMA-REP- 1, which requires that OROs have the capability to determine PADs, including evacuation, sheltering, and use of KI, if applicable, for groups of persons with disabilities and access/functional needs (e.g., hospitals, nursing homes, correctional facilities, schools, licensed daycare centers, mobility-impaired individuals, and transportation-dependent individuals). The focus is on those groups of persons with disabilities and access/functional needs that are, or potentially will be, affected by a radiological release from an NPP.

Criterion 2. I: Protective action decisions are made, as appropriate,for groups ofpersons with disabilities and access/functionalneeds. (NUREG-0654/FEM*4-REP-I.D.4;J.9; J.IO.d, e)

Assessment/Extent of Play Assessment of this DemonstrationCriterion must be accomplishedconcurrently with a licensee exercise andmay be demonstratedin a biennialor tabletop exercise that would include the use ofplant conditions transmittedfi'om the licensee.

Usually it is appropriate to implement evacuation in areas where doses are projected to exceed the lower end of the range of PAGs, except for incidents where there is a high-risk environmental condition or where high-risk groups (e.g., the immobile or infirm) are involved. In these cases, factors that must be considered include weather conditions, shelter availability, availability of transportation assets, risk of evacuation versus risk from the avoided dose, and precautionary school evacuations. In addition, decisions must be coordinated/communicated with the incident command. In situations where an institutionalized population cannot be evacuated, the ORO must consider use of KI.

Applicable OROs must demonstrate the capability to alert and notify all public school systems/districts of emergency conditions that are expected to or may necessitate protective actions for students.

Demonstration requires that the OROs actually contact public school systems/districts during the exercise.

4 In accordance with plans/procedures, OROs and/ort*) &ials of public school systems/districts must demonstrate the capability to make prompt decisions on protective actions for students. The decision-61

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemsont Yankee Power Station making process, including any preplanned strategies for protective actions for that ECL, must consider the location of students at the time (e.g., whether the students are still at home, en route to school, or at school).

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play Protective action decisions, including those for special population groups, are demonstrated at the Massachusetts State EOC based upon information provided by MEMA and MDPH Radiation Control Program staff at the EOF. MEMA and MDPH Radiation Control Program staff will analyze utility, field team and meteorological data provided at the EOF to make a recommendation to the State EOC for their consideration in making protective action decisions.

Sub-element 2.d. -Radioloeical Assessment andDecision-Making for the Ingestion Exposure Pathway Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the means to assess the radiological consequences for the ingestion exposure pathway, relate them to the appropriate PAGs, and make timely, appropriate PADs to mitigate exposure from the pathway.

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

Criterion 2.d 1: Radiological consequencesfor the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO's planning criteria.(NUREG-0654/FEMA-REP-I, A.3; C.1, 4: D.4; J.9,11)

Assessment/Extent of Play Assessment ofthis DemonstrationCriterionmust be accomplishedconcurrently with a licensee exercise andmay be demonstratedin a biennialor tabletop exercise that would include the use ofplant conditions transmittedfirom the licensee.

OROs are expected to take precautionary actions to protect food and water supplies, or to minimize exposure to potentially contaminated water and food, in accordance with their respective plans/procedures. Often OROs initiate such actions based on criteria related to the facility's ECLs. Such actions may include recommendations to place milk animals on stored feed and use protected water supplies.

The ORO must use its procedures to assess the radiological consequences of a release on the food and water supplies, such as the development of a sampling plan. The ORO's assessment must include evaluation of the radiological analyses of representative samples of water, food, and other ingestible substances of local interest from potentially impactj*-eas; characterization of the releases from the facility; and the extent of areas potentially impacted by the release. During this assessment, OROs must consider use of agricultural and watershed data within the 50-mile EPZ. The radiological impacts on the food and water must then be compared to the appropriate ingestion PAGs contained in the ORO's 62

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermiont Yankee Power Station plans/procedures. The plans/procedures contain PAGs based on specific dose commitment criteria or on criteria as recommended by current Food and Drug Administration (FDA) guidance. Timely and appropriate recommendations must be provided to the ORO decision-makers group for implementation decisions. OROs may also include a comparison of taking or not taking a given action on the resultant ingestion pathway dose commitments.

The ORO must demonstrate timely decisions to minimize radiological impacts from the ingestion pathway, based on the given assessments and other information. Any such decisions must be communicated and, to the extent practical, coordinated with neighboring OROs.

OROs will use Federal resources, as identified in the Nuclear/Radiological Incident Annex of the NRF and other resources (e.g., compacts or nuclear insurers), as necessary. Evaluation of this criterion will take into consideration the level of Federal and other participating resources.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement..

Massachusetts Extent of Play Thissub-element will not be evaluated"in this exercise.'

Sub-element 2.e. - RadiologlicalAssessment and Decision-MakingConcerningRelocation, Post Plume relocation, Re-entry, and Return Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to make decisions on post-plume phase relocation,reentr.y, and return of the general public.

These decisions are essential for protection of the public from direct long-term exposure to deposited radioactive materials from a severe incident at an NPP.

Criterion2e. 1: Timely post-plumephase relocation,reentry, and return decisions are made and coordinated as appropriate,based on assessments of the radiologicalconditions and criteriain the ORO's plan and/or procedures.(NUREG-0654/FEMA-REP-1,1.10; J.9; K.3.a; M.I)

Assessment/Extent of Play Assessment of this Demonstration Criterionmust be accomplishedconcurrently with a licensee exercise and may be demonstratedin a biennialor tabletop exercise that would include the use of.plant conditions transmittedfromn the licensee.

Relocation: OROs must demonstrate the capability to estimate integrated dose in contaminated areas and compare these estimates with PAGs; apply decision criteria for relocation of those individuals in the general public who have not been evacuated, but where actual or projected doses are in excess of relocation PAGs; and control access to evacuated and restricted areas. OROs will make decisions for relocating members of the evacuated public who lived in areas that now have residual radiation levels in excess of the PAGs. Determination of areas to be restricted must be based on factors such as the mix of radionuclides in deposited materials, calculated exposure rates versus the PAGs, and analyses of vegetation and soil field samples.

Reentry: Decisions must be made on location of co 1ftl points and policies regarding access and exposure control for emergency workers and members of the general public who need to temporarily enter the evacuated area to perform specific tasks or missions.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Examples of control procedures are the assignment of, or checking for, direct-reading and permanent record dosimetry for emergency workers; questions regarding an individual's objectives, locations expected to be visited, and associated timeframes; availability of maps and plots of radiation exposure rates; and advice on areas to avoid. Control procedures also include monitoring of individuals, vehicles, and equipment; the implementation of decision criteria regarding decontamination; and proper disposition of emergency worker dosimetry and maintenance of emergency worker radiation exposure records.

Responsible OROs must demonstrate the capability to develop a strategy for authorized reentry of individuals into the restricted zone(s), based on established decision criteria. OROs must demonstrate the capability to modify those policies for security purposes (e.g., police patrols), maintenance of essential services (e.g., fire protection and utilities), and other critical functions. They must demonstrate the capability to use decision-making criteria in allowing access to the restricted zone by the public for various reasons, such as to maintain property (e.g., to care for farm animals or secure machinery for storage) or retrieve important possessions. Coordinated policies for access and exposure control must be developed among all agencies with roles to perform in the restricted zone(s). OROs must demonstrate the capability to establish policies for provision of dosimetry to all individuals allowed to reenter the restricted zone(s). The extent to which OROs need to develop policies on reentry will be determined by scenario events.

Return: OROs must demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase (i.e., permitting populations that were previously evacuated to reoccupy their homes and businesses on an unrestricted basis). OROs must base decisions on enviromnental data and political boundaries or physical/ geological features, which allow identification of the boundaries of areasto which members of the general public may return. Return is permitted to the boundary of the restricted area(s) that is based on the relocation PAG.

Other factors that the ORO must consider in decision-making include conditions that permit cancellation of the ECL and relaxation of associated restrictive measures. OROs must base return recommendations on measurements of radiation from ground deposition. OROs must have the capability to identify services and facilities that require restoration within a few days and to identify the procedures and resources for their restoration. Examples of these services and facilities are medical and social services, utilities, roads, schools, and intermediate-term housing for relocated persons.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play

ýThis sub-element will not be evaluated in this exercise .:AI...

151 64

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station ASSESSMENT E VAL UA TION AREA 3: ProtectiveAction Implementation Sub-element 3.a - Implementation of Emergenct, Worker Exposure Control Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for each emergency worker; establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of the PAGs, and the capability to provide KI for emergency workers, always applying the "as low as is reasonably achievable" principle as appropriate.

Criterion3.a.1: The OROs issue appropriatedosimetry,KI, andprocedures,and manageradiological exposure to emergency workers in accordancewith the plans/procedures.Emergency workers periodically and at the end of each mission readtheir dosimetersand recordthe readings on the appropriateexposure recordor chart.OROs maintainappropriaterecord-keeping of the administrationof Kl to emergenc, workers. (NUREG-0654/FEM4-REP-1,J.1O.e; K.3.a., b; K.4)

Assessment/Extent of Play Assessment of this DemonstrationCriterionmay be accomplishedduring a biennialor tabletop exercise.

Other means ma' include drills, seminars or training activities that wouldfully demonstratetechnical proficiency.

OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent record dosimetry, dosimeter chargers, KI, and instructions on the use of these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows an individual(s) to read the administrative reporting limits that are pre-established at a level low enough to consider subsequent calculation of TEDE and maximum exposure limits, for those emergency workers involved in lifesaving activities, contained in the ORO's plans/procedures.

Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control.

During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. The emergency worker must report accumulated exposures during the exercise as indicated in the plans/procedures. OROs must demonstrate the actions described in the plans/procedures by determining whether to replace the worker, authorize the worker to incur additional exposures, or take other actions. If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge of whom to contact in case authorization is needed, and at what exposure levels.

Workers may use any available resources (e.g., written procedures and/or coworkers) in providing responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close pro~* ty to each other during the entire mission. In such cases, adequate control of exposure can be achieved or all team members using one direct-reading dosimeter worn by the team leader. Emergency workers assigned to low-exposure rate fixed facilities 65

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station (e.g., EOCs and communications center within the EPZ, reception centers, and counting laboratories) may have individual direct-reading dosimeters or they may be monitored using group dosimetry (i.e., direct-reading dosimeters strategically placed in the work area). Each team member must still have his or her own permanent record dosimetry. Individuals authorized by the ORO to reenter an evacuated area during the plume (emergency) phase, must be limited to the lowest radiological exposure commensurate with completing their missions.

OROs may have administrative limits lower than EPA-400-R-92-001 dose limits for emergency workers performing various services (e.g., life saving, protection of valuable property, all activities). OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where life saving and/or protection of valuable property may require an urgent response.

OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. Ingestion of KI recommended by the designated ORO health official is voluntary. For evaluation purposes, the actual ingestion of KI shall not be performed. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it. Emergency workers must demonstrate basic knowledge of procedures for using KI whether or not the scenario drives the implementation of KI use. This can be accomplished by an interview with the evaluator.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play EPZ EOCs: Dosimetry packets will be issued to a minimum of two individuals who will be working inside each EPZ EOC. Actual distribution and ingestion of KI will not occur. Empty KI tablet containers (small :zip-lock bags) will be included in the dosimetry packets for emergency workers. Knowledge of emergency worker exposure control and the use of dosimetry will be demonstrated through an interview with those individuals issued dosimetry and the FEMA Evaluator.

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

Sub-element 3.b - Implementation of KI Decision for InstitutionalizedIndividuals and the General Public 153 Intent 66

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station This Sub-element is derived from NUREG-0654/FEMA-REP- 1, which requires that OROs have the capability to provide KI for institutionalized individuals, and, if in the plans/procedures, to the general public for whom immediate evacuation may not be feasible, very difficult, or significantly delayed. While it is necessary for OROs to have the capability to provide KI to institutionalized individuals, providing KI to the general public is an ORO option and must be reflected as such in ORO plans/procedures.

Provisions must include the availability of adequate quantities, storage, and means of distributing KI.

Criterion3.b. 1: KI and appropriateinstructionsare availableif a decision to recommend use of K1 is made. Appropriaterecord-keepingofthe administrationof Klfor institutionalizedindividualsis maintained.(NUREG-0654/FEMA-REP-1,J.10.e,fl Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplishedduring a biennialor tabletop exercise.

Other means may include drills, seminars or trainingactivities that wouldfidly demonstrate technical proficiency.

OROs must demonstrate the capability to make KI available to institutionalized individuals, and, where provided for in their plans/procedures, to members of the general public. OROs must demonstrate the capability to accomplish distribution of KI consistent with decisions made. OROs must have the capability to develop and maintain lists of institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest KI. Ingestion of KI recommended by the designated ORO health official is voluntary. For evaluation purposes, the actual ingestion of KI shall not be performed. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it.

If a recommendation is made for the general public to take KI, appropriate information must be provided to the public by the means of notification specified in the ORO's plans/procedures.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play There are no institutionalized persons in the EPZ.

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

Sub-element 3.c - Implementation of ProtectiveActions for Persons with Disabilitiesand A ccess/FunctionalNeeds Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement PADs, including evacuation and/or sheltering, for all persons with disabilities and access/functional needs. The focus is on those persons with disabilities and access/functional needs that are (or potentially will be) affected by a radiological 54ease from an NPP.

67

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power'Station Criterion3.c.1: Protectiveaction decisions are implementedfor persons with disabilitiesand access/functionalneeds other than schools within areas subject to protective actions. (NUREG-0654/FEMA-REP-1, J.1O.c, d, e, g)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplishedduring a biennial exercise, an actual event, or by means of drills conducted at ani' time.

Applicable OROs must demonstrate the capability to alert and notify (i.e., provide PARs and emergency information and instructions to) persons with disabilities and access/functional needs, including hospitals/medical facilities, nursing homes, correctional facilities, and mobility-impaired and transportation-dependent individuals. OROs must demonstrate the capability to provide for persons with disabilities and access/functional needs in accordance with plans/procedures.

Contact with persons with disabilities and access/functional needs and reception facilities may be actual or simulated, as agreed to in the extent of play. Some contacts with transportation providers.must be actually contacted, as negotiated in the extent of play. All actual and simulated contacts must be logged.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play Bernardston EOC: EOC staff will simulate contacting persons on their special nee.ds lists by logging the calls at the appropriate time. The list of special needs individuals Will be shown to the FEMA Evaluator; however, the information is confidential and copies will NOT be provided.

No vehicles for alerting persons with special needs or providing transportation to the transportation dependent will be mobilized.

Colrain EOC: EOC staff will simulate contacting persons on their special needs lists by logging the calls at the appropriate time.. The list of special needs individuals will be shown to the FEMA Evaluator; however, the information is confidential and copies will NOT be provided.

No vehicles for alerting persons with special needs or providing transportation to the transportation dependent will be mobilized.

Gill EOC: EOC staff will simulate contacting persons on their special needs lists bylogging the calls at the appropriate time. The list of special needs individuals will be shown to the FEMA Evaluator, however, the information is confidential and .copies will NOT be provided.

No vehicles for alerting persons with special needs or providing transportation to the transportation dependent will be mobilized.

Greenfield EOC: EOC staff will simulate contacting persons on their special needs lists by logging the calls at the appropriate time. The list of special needs individuals will be shown to the FEMA Evaluator; however, the information is confidenjigand copies will NOT.:be provided.,

No vehicles for alerting persons with special needs or providing transportation to the.transportation dependent will be mobilized.

68

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Impiovement Plan Vermont Yankee Power Station The capability to correctly operate a TTY will be demonstrated in Greenfield by sending and receiving a test message to/from a TTY at the SEOC in Framingham.

Leyden EOC: EOC staff will simulate contacting persons on their special needs lists by logging the calls at the appropriate time. The list of special needs individuals will be shown to the FEMA Evaluator; however, the information is confidential and copies will NOT be provided.

No vehicles for alerting persons with special needs or providing transportation to the transportation dependent will be mobilized.

Northfield EOC: EOC staff will simulate contacting persons on their special needs lists by logging the calls at the appropriate time. The list of special needs individuals will be shown to the FEMA Evaluator; however, the information is confidential and copies will NOT be provided.

No vehicles for alerting persons with special needs or providing transportation. to the transportation dependent will be mobilized.

Warwick EOC: N/A p

• No vehicles for alerting persons with special needs or providing transportation to the transportation dependent willbe mobilized.

Criterion3.c.2: OROs/School officials implement protective actionsfor schools. (NUREG-0654, J.10.c. d, e, g)

Assessment/Extent of Play Assessment of this DemonstrationCriterion may be accomplishedduring a biennial,or tabletop exercise, an actual event, staff assistancevisit, or by means of drills conducted at any tine.

School systems/districts (these include public and private schools, kindergartens, pre-schools, and licensed daycare centers) must demonstrate the ability to implement PADs for students. The demonstration must be made as follows: Each school system/district within the 10 mile EPZ must demonstrate implementation of protective actions. At least one school per affected system/district must participate in the demonstration. Canceling the school day, dismissing early, or sheltering in place must be simulated by describing to evaluators the procedures that would be followed. If evacuation is the implemented protective action, all activities to coordinate and complete the evacuation of students to reception centers, congregate care centers, or host schools may actually be demonstrated or accomplished through an interview process.

If accomplished through an interview, appropriate school personnel including decision-making officials (e.g., schools' superintendent/principals and transportation director/bus dispatchers), and at least one bus driver (.and the bus driver's escort, if applicable) must be available to demonstrate knowledge of their role(s) in the evacuation of school children. Communications capabilities between school officials and the buses, if required by the plans/procedures, must be verified.

Officials of the school system(s) must demonstrate the capability to develop and provide timely information to OROs for use in messages to parents X

• general public, and the media on the status of protective actions for schools.

69

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan .. Vermont Yankee Power Station If a school facility has emergency plans as a condition of licensing, those plans may be submitted to FEMA review in place of demonstration or interview pursuant to the ORO's plans/procedures as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play EPZ EOCs: Initial notification will be made to all public school Superintendent's Offices. All further calls to schools will be simulated.

Sub-element 3.d. - Implementation of Traffic and Access Control Intent This Sub-element is derived from NUREG-0654/FEMA-REP- 1, which requires that OROs have the capability to implement protective action plans/procedures, including relocation and restriction of access to evacuated/sheltered areas. This Sub-element focuses on selecting, establishing, and staffing of traffic and access control points, and removal of impediments to the flow of evacuation traffic.

Criterion3.d.1: Appropriatetraffic andaccess controlis establishedL Accurate instructionsareprovidedto traffic and access controlpersonnel. (ANUREG-0654/FEMA-REP-1, A.3; C.1.4; J.1 O.g.j)

Assessment/Extent of Play Assessment of this DemonstrationCriterionmay be accomplishedduring a biennialexercise, an actual event, staff assistance visit, or by means ofdrills conducted at any)time.

OROs must demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with current conditions and PADs (e.g., evacuating, sheltering, and relocation) in a timely manner. OROs must demonstrate the capability to provide instructions to traffic and access control staff on actions to take when modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled.

Traffic and access control staff must demonstrate accurate knowledge of their roles and responsibilities, including verifying emergency worker identification and access authorization to the affected areas, as per the Extent-of-Play Agreement. These capabilities may be demonstrated by actual deployment or by interview, in accordance with the Extent-of-Play Agreement.

In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic), they must demonstrate the capability to contact the state or Federal agencies that have the needed authority, as agreed upon in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

157 Massachusetts Extent of Play 70

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station SEOC: Massachusetts State Police and Massachusetts Department of Transportation Liaisons will demonstrate coordination of traffic and access control, but no personnel or equipment will actually be deployed. The demonstration will include interstate coordination of traffic and access control, if appropriate.

Region III/IV EOC: The Massachusetts State Police Liaison will demonstrate coordination of traffic and access control through discussion and communication, but no personnel or equipment will be deployed to field locations.

EPZ EOCs: EPZEOCs will demonstrate the ability to direct and monitor traffic control operations within their jurisdictions through discussions and communications with the evaluator. The EOC local highway representative will participate in a discussion of procedures and resources available*

for traffic control. No personnel or equipment will be deployed to field locations.

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

FEMA Evaluator will inform the participant and the Controller. After an " on the spot" re-training by the State or local organization, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

Criterion3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654, J.10.

ok)

Assessment/Extent of Play Assessment of this DemonstrationCriterionmay be accomplishedduringa biennialexercise, an actual event, staff assistancevisit, or ib'means of drills conducted at any time.

OROs must demonstrate the capability, as required by the scenario, to identify and take appropriate actions concerning impediments to evacuation. Actual dispatch of resources to deal with impediments, such as wreckers, need not be demonstrated; however, all contacts, actual or simulated, must be logged.

The impediment must occur during the evacuation and be on an evacuation route such that re-routing of traffic is required, triggering decision-making and coordination with the JIC to communicate the alternate route to evacuees leaving the area.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play Each EPZ Local EOC will demonstrate decision making regarding rerouting of traffic following a traffic impediment. No personnel or equipment will be deployed to the accident scene.

158 71

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Note: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant and the Controller. After an " on the spot" re-training by the state or local organization, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

Sub-element 3.e - Implementation of Ingestion Pathway' Decisions Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement protective actions, based on criteria recommended by current FDA guidance, for the ingestion exposure pathway EPZ (i.e., the area within an approximate 50-mile radius of the NPP).

This Sub-element focuses on those actions required for implementation of protective actions.

Criterion3.e.1: The ORO demonstrates the availabilio,and appropriateuse of adequate information regarding water, food supplies, milk, and agriculturalproduction within the ingestion exposure pathway emergency planning zone for implementation of protective actions. NUREG-0654/FEMA-REP-1, A.3; C.I, 4; J.Hl)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplishedduring a biennialexercise, an actual event, or by means of drills conducted at any time.

Applicable OROs must demonstrate the capability to secure and use current information on the locations of dairy farms, meat and poultry producers, fisheries, fruit growers, vegetable growers, grain producers, food processing plants, and water supply intake points to implement protective actions within the EPZ.

OROs use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex, and other resources (e.g., compacts, nuclear insurers), if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play Tis be evaluated:in this exercise:..

a*susb-elementwllno . .. . .

Criterion3.e.2: Appropriatemeasures, strategies,and pre-printedinstructionalmaterialare developedfor implementingprotective action decisionsfor contaminatedwaterfoodproducts.,milk, andagricultural production. (NUREG-0654/FEMA-REP-1,G. 1, J.9, 11)

Assessment/Extent of Play Assessment of this DemonstrationCriterion may be accomplishedduring a biennialexercise, an actual event, or by means of drills conducted at ani, time.

OROs must demonstrate the development of measures and strategies for implementation of ingestion exposure pathway EPZ protective actions by formulating protective action information for the general public and food producers and processors. Demonst*[n of this criterion includes either pre-distributed public information material in the ingestion exposure pathway EPZ or the capability for rapid reproduction and distribution of appropriate reproduction-ready information and instructions to pre-determined individuals and businesses.

72

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station OROs must also demonstrate the capability to control, restrict, or prevent distribution of contaminated food by commercial sectors. Exercise play must include demonstration of communications and coordination among organizations to implement protective actions. Field play of implementation activities may be simulated. For example, communications and coordination with agencies responsible for enforcing food controls within the ingestion exposure pathway EPZ must be demonstrated, but actual comnmunications with food producers and processors may be simulated.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play

, . * ... * .. * ..; .. * * . . ! . .......... :......*.I, ,.. . .. . ................ .* . o. - .. . . . .

,This stub-eemeiit will not be evaluated in this exercise..

Sub-element 3.f- Implementation of Post Plume PhaseRelocation, Re-entry, and Return Decisions Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement plans, procedures, and decisions for post-plume phase relocation,reentry, and return. Implementation of these decisions is essential for protecting the public from direct long-term exposure to deposited radioactive materials from a severe incident at a commercial NPP.

Criterion3.f 1: Decisions regardingcontrolled reentry of emergenc, workers and relocation and return of the public during the post-plume phase arecoordinatedwith appropriateorganizationsand implemented (NUREG-0654/FEMAI-REP-1, E. 7: J.1 0.j; J.12; K.5.b; M.1, 3)

Assessment/Extent of Play Assessment of this DemonstrationCriterionmay be accomplishedduring a biennial,or tabletop exercise, or by means of drills conductedat anm time.

Relocation: OROs must demonstrate the capability to coordinate and implement decisions concerning relocation of individuals located in radiologically contaminated areas who were not previously evacuated.

Such individuals must be relocated to an area(s) where radiological contamination will not expose the general public to doses that exceed the relocation PAGs. OROs must also demonstrate the capability to provide for short- or long-term relocation of evacuees who lived in an area(s) that has residual radiation levels above the (first-, second-, and 50-year) PAGs.

Areas of consideration must include the capability of OROs to communicate with other OROs regarding timing of actions, notification of the population of procedures for relocation, and notification of, and advice for, evacuated individuals who will be converted to relocation status in situations where they will not be able to return to their homes due to high levels of contamination. OROs must also demonstrate the capability to communicate instructions to the public regarding relocation decisions and intermediate-term housing for relocated persons.

160 Reentry: OROs must demonstrate the capability to control reentry and exit of individuals who are authorized by the ORO to temporarily reenter the restricted area during the post-plume (i.e., intermediate or late) phase to protect them from unnecessary radiation exposure. OROs must also demonstrate the 73

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/lmprovement Plan Vermont Yankee Power Station capability to control exit of vehicles and other equipment to control the spread of contamination outside the restricted area(s). Individuals without specific radiological response missions, such as farmers for animal care, essential utility service personnel, or other members of the public who must reenter an evacuated area during the post-emergency phase must be limited to the lowest radiological exposure commensurate with completing their missions. Monitoring and decontamination facilities will be established as appropriate.

Examples of control procedures are: (1) assignment of, or checking for, direct-reading and penrmanent record dosimetry for emergency workers; (2) questions regarding the individuals' objective(s), location(s) expected to be visited, and associated timeframes; (3) maps and plots of radiation exposure rates; (4) advice on areas to avoid; (5) procedures for exit, including monitoring of individuals, vehicles, and equipment; (6) decision criteria regarding contamination; (7) proper disposition of emergency worker dosimetry, and (8) maintenance of emergency worker radiation exposure records.

Return: OROs must demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase. OROs must demonstrate the capability to identify and prioritize services and facilities that require restoration within a few days, and to identify procedures and resources for their restoration. Examples of these services and facilities are medical and social services, utilities, roads, and schools.

Communication among OROs for relocation, reentry, and return may be simulated. All simulated or actual contacts must be documented. These discussions may be accomplished in a group setting.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex, and other resources (e.g., compacts or nuclear insurers), as necessary, if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play s sUl-el ement:w*i not bevaluated in this exercise..

161 74

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station ASSESSMENT AREA 4: Field MeasurementAnd Analyses Sub-element 4.a - Plume Phase FieldMeasurements and Analyses Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (ORO) should have the capability to deploy field teams with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654 indicates that OROs should have the capability to use field teams within the plume emergency planning zone to measure airborne radioiodine in the presence of noble gases and to detect radioactive particulate material in the airborne plume.

In the event of an accident at a nuclear power plant, the possible release of radioactive material may pose a risk to the nearby population and environment. Although accident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties. During an accident, it is important to collect field radiological data in order to help characterize any radiological release. Adequate equipment and procedures are essential to such field measurement efforts.

Criterion4.a. ]:[RESER VED]

Criterion 4.a.2: Field teams (2 or more) are managed to obtain sufficient information to help characterizethe release and to control radiation erposure. (NUREG-0654/FEMA-REP-1, C. 1; H.12; L.7,8, 11; J.lO.a)

Assessment/Extent of Play Assessment of this DemonstrationCriterion may be accomplishedduring a biennialexercise. Other means may include drills that wouldful/v demonstratetechnicalproficiency.

Responsible OROs must demonstrate the capability to brief FMTs on predicted plume location and direction, plume travel speed, and exposure control procedures before deployment. During an HAB incident, the Field Team management must keep the incident command informed of field monitoring teams' activities and location. Coordination with FMTs and field monitoring may be demonstrated as out-of-sequence demonstrations, as negotiated in the Extent-of-Play Agreement.

Field measurements are needed to help characterize the release and support the adequacy of implemented protective actions, or to be a factor in modifying protective actions. Teams must be directed to take measurements at such locations and times as necessary to provide sufficient information to characterize the plume and its impacts.

If the responsibility for obtaining peak measurements in the plume has been accepted by licensee field monitoring teams, with concurrence from OROs, there is no requirement for these measurements to be repeated by ORO monitoring teams. If the licensee FMTs do not obtain peak measurements in the plume, it is the ORO's decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coordination of plume measurement information among all FMTs (licensee, Federal, and ORO) is essential. Coordination conceding transfer of samples, including a chain-of-custody form(s), to a radiological laboratory(ies) must be demonstrated.

75

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee), as necessary. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play NIAT Field Teams are managed by theField Team Coordinator who is located at the utility EOF.

He will brief and dispatch two teams to0 sampling locations in accordance with the NIAT Handbook, Section D.4, as dictated by scenario play.

NIAT Field Team personnel will prepare sample media, survey forms, and chain of custody documents as if they were being transferred to the lab for analysis. Actual transport of samples will be simulated.

This sub-element.will be not evaluated as it was successfully demonstrated in the 2012 Seabrook exercise.

. ...i.,:, . "... .... .. .......* ... . ........

Criterion4.a.3: Ambient radiationmeasurements aremade and recordedat appropriatelocations,and radioiodineandparticulatesamples are collected. Teams will move to an appropriatelow background location to determine whether any significant(as specified in the plan and/orprocedures)amount of radioactiviot has been collected on the sampling media. (NUREG-0654/FEMA-REP-1,C.1; H.12: 1.8, 9; J.1O.aa)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplishedduringa biennialexercise. Other means may include drills that would fully demonstrate technicalproficiency.

Two or more FMTs must demonstrate the capability to make and report measurements of ambient radiation to the field team coordinator, dose assessment team, or other appropriate authority. FMTs must also demonstrate the capability to obtain an air sample for measurement of airborne radioiodine and particulates, and to provide the appropriate authority with field data pertaining to measurement. If samples have radioactivity significantly above background, the authority must consider the need for expedited laboratory analyses of these samples.

OROs must share data in a timely manner with all other appropriate OROs. All methodology, including contamination control, instrumentation, preparation of samples, and a chain-of-custody form(s) for transfer to a laboratory(ies), will be in accordance with the ORO's plans/procedures.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

163 Massachusetts Extent of Play 76

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Two MA NIAT Field Teams willbe dispatched from the EOF in accordance with the NMAT Handbook. Once, dispatched, only disposable gloves will be used for actual exercise play.

Charcoal cartridges will be used instead of silver zeolite.

The NIAT Field Teams will collect one complete sample (monitoring and air sample) as specified by the procedures in Section D.4 of the NIAT Handbook.

This sub-element will be not evaluated as it was successfully demonstrated in the 2012 Seabrook exercise Note: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant and the Controller. After an " on the spot" re-training by the state or local organization, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

Sub-element 4.b - Post Plume Phase Field Measurements and Sampling Intent This Sub-element is derived from NUREG-0654/FEMA-REP- 1, which requires that OROs have the capability to assess the actual or potential magnitude and locations of radiological hazards to determine the ingestion exposure pathway EPZ and to support relocation, reentry, and return decisions. This Sub-element focuses on collecting environmental samples for laboratory analyses that are essential for decisions on protecting the public from contaminated food and water and direct radiation from deposited materials.

Criterion4.b. 1: Thefield teams (2 or more) demonstratethe capability to make appropriatemeasurements andto collect appropriatesamples (e.g.,food crops. milk, water, vegetation, and soil) to supportadequate assessments andprotective action decision making.

(NUREG-0654/FEMA-REP-1, C. 1; L.8; J. 11)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplishedduringa biennialor tabletop exercise.

Other means may include drills, seminars or trainingactivities that wouldfully demonstratetechnical proficiency.

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

The FMTs and/or other sampling personnel must secure ingestion pathway samples from agricultural products and water. Samples in support of relocation and return must be secured from soil, vegetation, and other surfaces in areas that received radioactive1i4und deposition.

77

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play iThls sul51eeent wifinote jevaluatedmiithis exercise.

Sub-element 4.c - Laboratory,Operations Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to perform laboratory analyses of radioactivity in air, liquid, and environmental samples to support protective action decision making.

Criterion4.c. 1: The laboratoryis capable ofperforming requiredradiologicalanalyses to support protectiveaction decisions. (NUREG-0654/FEMA-REP-1, C. 1, 3; J. 11)

Assessment/Extent of Play Assessment of this DemonstrationCriterion may be accomplishedduring a biennial, tabletop exercise, or an actualevent. Other means may include drills, seminars or trainingactivities that wouldfully demonstrate technicalproficiency.

The laboratory staff must demonstrate the capability to follow appropriate procedures for receiving samples, including logging information, preventing contamination of the laboratory(ies), preventing buildup of background radiation due to stored samples, preventing cross contamination of samples, preserving samples that may spoil (e.g., milk), and keeping track of sample identity. In addition, the laboratory staff must demonstrate the capability to prepare samples for conducting measurements.

The laboratory(ies) must be appropriately equipped to provide, upon request, timely analyses of media of sufficient quality and sensitivity to support assessments and decisions anticipated in the ORO's plans/procedures. The laboratory instrument calibrations must be traceable to standards provided by the National Institute of Standards and Technology. Laboratory methods used to analyze typical radionuclides released in a reactor incident must be as described in the plans/procedures. New or revised methods may be used to analyze atypical radionuclide releases (e.g., transuranics or as a result of a terrorist incident) or if warranted by incident circumstances. Analysis may require resources beyond those of the ORO.

The laboratory staff must be qualified in radioanalytical techniques and contamination control procedures.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

165 All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

78

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Massachusetts Extent of Play

,This sub-elemrent Will not be evaluated in this exercise.

166 79

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Impiovement Plan Vermont Yankee'Power'Station ASSESSMENT AREA 5: Emergency Notification and Public Information Sub-element 5.a -Activation of the PromptAlert and Notification System Intent This Sub-element is derived from NUREG-0654/FEMA-REP- 1, which requires that OROs have the capability to provide prompt instructions to the public within the plume exposure pathway EPZ. Specific provisions addressed in this Sub-element are derived from the Guidefor the Evaluation ofAlert and NotificationSystems for NuclearPower Plants,FEMA-REP- 10 (November 1985).

Exhibit 111-4: Evaluation Standards for Alert and Notification Systems

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Demonstration S.,ner Criterion: :a :i* . nnea Withi minutes 45 Reasonable Time Primary Alert and Notification 1m E....

5.a.1: ... covering essentially 100% of the 1 0_mile Epz X[

5.a.4: .for FEMA-approved exception areas X Backup Alert and Notification for All Incidents 5.a.3: ... covering the 10-mile EPZ X 5.a.]: Activities associatedwith primary alertingand notification of the public are completed in

.Criterion a timely mannerfollowing the initialdecision bk'authorizedoffsite emergency officials to notify the public of an emergenc, situation. The initialinstructionalmessage to thepublic must include as a mininum the elements requiredby currentREPguidance. (NUREG-O654/FEMA-REP-1, E.5, 6, 7)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplishedduring a biennialexercise, drills, or operationaltesting of equipment that would fully demonstrate capability.

Responsible OROs must demonstrate the capability to sequentially provide an alert signal followed by an initial instructional message to populated areas (permanent resident and transient) throughout the 10-mile plume EPZ. Following the decision to activate the alert and notification system, OROs must complete system activation for primary alert/notification and disseminate the information/instructions in a timely manner. For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." If message dissemination is identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

Procedures to broadcast the message must be fully demonstrated as they would in an actual emergency up to the point of transmission. Broadcast of the message(s) or test message(s) is not required. The procedures must be demonstrated up to the point of actual activation. The alert signal activation should be simulated, not performed. Evaluations of EAS broadcast stations may also be accomplished through SAVs.

The capability of the primary notification system to broadcast an instructional message on a 24-hour basis must be verified during an interview with appropriate personnel from the primary notification system, including verification of provisions for backup power or an alternate station.

167 80

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station The initial message must include at a minimum the following elements:

• Identification of the ORO responsible and the official with authority for providing the alert signal and instructional message;

" Identification of the commercial NPP and a statement that an emergency exists there;

" Reference to REP-specific emergency information (e.g., brochures, calendars, and/or information in telephone books) for use by the general public during an emergency; and

" A closing statement asking that the affected and potentially affected population stay tuned for additional information, or that the population tune to another station for additional information.

If route alerting is demonstrated as a primary method of alert and notification, it must be done in accordance with the ORO's plans/procedures and the Extent-of-Play Agreement. OROs must demonstrate the capability to accomplish the primary route alerting in a timely manner (not subject to specific time requirements). At least one route needs to be demonstrated and evaluated. The selected route(s) must vary from exercise to exercise. However, the most difficult route(s) must be demonstrated no less than once every 8 years. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast) as negotiated in the extent of play. Actual testing of the mobile public address system will be conducted at an agreed-upon location.

OROs may demonstrate any means of primary alert and notification included in their plans/procedures as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play Actions to demonstrate performance of initial notification of the public will be performed up to the point of actual transmission of the Emergency Alert System (EAS) message. The State Primary EAS Station of WBZ will be contacted and notified that activations of the EAS System will be handled out of the SEOC. Actual activation of the Emergency Alert System will be will be simulated by SEOC staff.

All States will coordinate activities for the activation of the NOAA tone-alert radios throughout the EPZ. Activation of the NOAA tone-alert radios by the State of Vermont will be demonstrated using a test message.

The simulated activation of the Rapid Emergency Notification Telephone System (RENTS) for all 3 States by the State of New Hampshire will be demonstrated.

The MA SEOC will demonstrate the actions necessary to perform the siren activation for all 3 States up to the point of actually sounding the sirens. Siren sounding will be simulated.

Criterion5.a.2: [RESERVED]

81

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Criterion5.a.3: Backup alertand notification ofthe publicis completed within a reasonable time following the detection ky the ORO of afailureof the primarj' alertand notification system. (NUREG-0654/FEMA-REP-1,E.6, Appendix 3. B.2.c)

Assessment/Extent of Play Assessment of this DemonstrationCriterionmay be accomplishedduring a biennialexercise, drills, or operationaltesting of equipment that would fdlyv demonstrate capability.

If the exercise scenario calls for failure of any portion of the primary system(s) or if any portion of the primary system(s) actually fails to function during the exercise, OROs must demonstrate backup means of alert and notification. Backup means of alert and notification will differ from facility to facility.

Backup alert and notification procedures that would be implemented in multiple stages must be structured such that the population closest to the plant (e.g., within 2 miles) is alerted and notified first. The populations farther away and downwind of any potential radiological release would be covered sequentially (e.g., 2 to 5 miles, followed by downwind 5 to 10 miles, and finally the remaining population as directed by authorities). Topography, population density, existing ORO resources, and timing will be considered in judging the acceptability of backup means of alert and notification.

Although circumstances may not allow this for all situations, FEMA and the NRC recommend that OROs and operators attempt to establish backup means that will reach those in the plume exposure EPZ within a reasonable time of failure of the primary alert and notification system, with a recommended goal of 45 minutes. The backup alert message must, at a minimum, include (1) a statement that an emergency exists at the plant and (2) instructions regarding where to obtain additional information.

If backup route alerting is demonstrated, only one route needs to be selected and demonstrated. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast), as negotiated in the extent of play. Actual testing of the mobile public address system will be conducted at an agreed-upon location.

OROs may demonstrate any means of backup alert and notification included in their plans/procedures as negotiated in the Extent-of-Play Agreement.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play

• -7 7*'*. ... ": ..... . ..

". v*,:* :Z * "W"* ..... 7... : 7 * . ' ; ,

• Th!is. siub.-el!ement wfillnotbe evaluate din this' exercise.

Criterion5.a.4: Activ'ities associatedwith FEMA-approvedexception areas (where applicable)are completed within 45 minutesfollowing the initialdecision by authorizedoffsite emergency officials to notifi, the public of an emergenc, situation. (NUREG-0654/FEMA-REP-1, E.6; Appendix 3.B.2.c) 169 Assessment/Extent of Play 82

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Assessment of this DemonstrationCriterionmay be accomplishedduring a biennial exercise, drills, or operationaltesting of equipment that would fully demonstratecapability.

OROs with FEMA-approved exception areas (identified in the approved Alert andNotification System Design Report), 5 to 10 miles from the NPP, must demonstrate the capability to accomplish primary alerting and notification of the exception area(s). FEMA and the NRC recommend that OROs and operators establish means that will reach those in approved exception areas within 45 minutes once the initial decision is made by authorized offsite emergency officials to notify the public of an incident. The exception area alert message must, at a minimum, include (1) a statement that an emergency exists at the plant and (2) instructions regarding where to obtain additional information.

For exception area alerting, at least one route must be demonstrated and evaluated. The selected route(s) must vary from exercise to exercise. However, the most difficult route(s) must be demonstrated no less than once every 8 years. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcasted) as negotiated in the extent of play. Actual testing of the mobile public address system will be conducted at an agreed-upon location. For exception areas alerted by air/water craft, actual routes will be negotiated in the extent of play, but must be demonstrated no less than once every 8 years.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement..

Massachusetts Extent of Play This su-elemnent will not be evaluated in th:Is exercise.

Sub-element 5.b - Subsequent Emergenci,Information and Instructions for the Public and the Media Intent This Sub-element is derived from NUREG-0654/FEMA-REP- 1, which requires that OROs have the capability to disseminate appropriate emergency information and instructions, including any recommended protective actions, to the public. In addition, NUREG-0654/FEMA-REP- 1 requires OROs to ensure that the capability exists for providing information to the media. This includes the availability of a physical location for use by the media during an emergency. NUREG-0654/FEMA-REP- 1 also provides that a system must be available for dealing with rumors. This system will hereafter be known as the "public inquiry hotline."

Criterion5.b.]: OROs provide accurate subsequent emergency information and instructionsto the public and the news media in a timely manner. (NUREG-0654/FEMA-REP-J, E.5, 7; G.3.a, G.4.a, c)

Assessment/Extent of Play Assessment of this DemonstrationCriterionmay be accomplishedduring a biennialexercise, or drills. 170 The responsible ORO personnel/representatives must demonstrate actions to provide emergency information and instructions to the public and media in a timely manner following the initial alert 83

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station and notification (not subject to specific time requirements). For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." If message dissemination is identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

Message elements: The ORO must ensure that emergency information and instructions are consistent with PADs made by appropriate officials. The emergency information must contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, shelter-in-place instructions, information concerning protective actions for schools and persons with disabilities and access/functional needs, and public inquiry hotline telephone number) to assist the public in carrying out the PADs provided. The ORO must also be prepared to disclose and explain the ECL of the incident. At a minimum, this information must be included in media briefings and/or media releases. OROs must demonstrate the capability to use language that is clear and understandable to the public within both the plume and ingestion exposure pathway EPZs. This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas.

The emergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5.a. 1 and previously identified protective action areas that are still valid, as well as new areas. The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media.

In addition, the OROs must demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures.

OROs must demonstrate the capability to develop emergency information in a non-English language when required by the plans/procedures.

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

Media information: OROs must demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the incident warrants. The OROs must demonstrate the capability to respond appropriately to inquiries from the news media. All information presented in media briefings and releases must be consistent with PADs and other emergency information provided to the public.

Copies of pertinent emergency information (e.g., EAS messages and media releases) and media information kits must be available for dissemination to the media.

Public inquiry: OROs must demonstrate that an effective system is in place for dealing with calls received via the public inquiry hotline. Hotline staff must demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate information source.

Information from the hotline staff, including information that corrects false or inaccurate information when trends are noted, must be included, as appropriate, in emergency information provided to the public, media briefings, and/or media releases.

HAB considerations: The dissemination of information dealing with specific aspects of NPP security capabilities, actual or perceived adversarial (terrorist) force or threat, and tactical law enforcement response must be coordinated/communicated with appropriate security authorities, e.g., law enforcement and NPP security ageppits, in accordance with ORO plans/procedures.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

84

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Massachusetts Extent of Play Joint Information Center: Rumor trends generated as a result of public inquiry calls to the Mass-211 Public Information Line will be included in news briefings by the MEMA PIO.

State EOC: Simulation Cell personnel will make calls simulating members of the public to the Mass-21 I Public Information Line.. This process will commence after the initial siren activation. Information on rumor trends recognized at the Mass-21 1 Public Information Line will be forwarded to the Public Affairs Office at the SEOC.

Mass-21 1 Operations Center: Staff from Mass-21 1 will demonstrate the ability to handle inquiry calls. Information on rumor trends recognized will be forwarded to the Public Affairs Office at the SEOC.

EPZ Towns: Simulation Cell personnel at the SEOC.will make calls to the local EOCs simulating members of the public with inquiries. Each local EOC will demonstrate the ability to properly handle these inquiries.

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

172 85

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station ASSESSMENT AREA 6: Support Operation/Facilities Sub-element 6.a - Monitoring.DecontaminationandRegistration of Evacuees Intent This Sub-element is derived from NUREG-0654/FEMA-REP- 1, which requires that OROs have the capability to implement radiological monitoring and decontamination of evacuees, while, minimizing contamination of the facility. OROs must also have the capability to identify and register evacuees at reception centers.

Criterion 6.a.1: The reception centerfacility has appropriatespace, adequate resources, and trainedpersonnelto provide monitoring,decontamination,and registrationof evacuees.

(NUREG-0654/FEMA -REP-1, A.3; C.4; J.lO.h; J.12)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomplishedduring a biennialexercise, an actual event, drills, or SA V.

Radiological monitoring, decontamination, and registration facilities for evacuees must be set up and demonstrated as they would be in an actual emergency or as indicated in the Extent-of-Play Agreement. OROs conducting this demonstration must have one-third of the resources (e.g.,

monitoring teams/instrumentation/portal monitors) available at the facility(ies) as necessary to monitor 20 percent of the population within a 12-hour period. This would include adequate space for evacuees' vehicles. Availability of resources can be demonstrated with valid documentation (e.g., MOU/LOA, etc.) reflecting how necessary equipment would be procured for the location.

Plans/procedures must indicate provisions for service animals.

Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. Staff responsible for the radiological monitoring of evacuees must demonstrate the capability to attain and sustain, within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a monitoring productivity rate per hour needed to monitor the 20 percent EPZ population planning base. The monitoring productivity rate per hour is the number of evacuees that can be monitored, per hour, by the total complement of monitors using an appropriate procedure. For demonstration of monitoring, decontamination, and registration capabilities, a minimum of six evacuees must be monitored per station using equipment and procedures specified in the plans/procedures. The monitoring sequences for the first six simulated evacuees per monitoring team will be timed by the evaluators to determine whether the 12-hour requirement can be met.

OROs must demonstrate the capability to register evacuees upon completion of the monitoring and decontamination activities. The activities for recording radiological monitoring and, if necessary, decontamination must include establishing a registration record consisting of the evacuee's name, address, results of monitoring, and time of decontamination (if any), or as otherwise designated in the plan and/or procedures. Audio recorders, camcorders, or written records are all acceptable means for registration.

Monitoring activities shall not be simulated. Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. They must also explain the procedures for referring any evacuees who cannot be adequately decontaminated for assessment and follow-up in accordance with the OROl 70ans/procedures. Contamination of the evacuee(s) will be determined by controller inject and not simulated with any low-level radiation source. All activities must be based on the ORO's 86

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Verimiont Yankee Power Station plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Decontamination of evacuees may be simulated and conducted by interview. Provisions for separate showering and same-sex decontamination must be demonstrated or explained. The staff must demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated evacuees, provide changes of clothing for those with contaminated clothing; and store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities. In addition, for any evacuee found to be contaminated, procedures must be discussed concerning handling of potential contamination of vehicles and personal belongings. Waste water from decontamination operations does not need to be collected.

Individuals who have completed monitoring (and decontamination, if needed) must have means (e.g.,

hand stamp, sticker, bracelet, form, etc) indicating that they, and their service animals and vehicles, where applicable, have been monitored, cleared, and found to have no contamination or contamination below the trigger/action level.

In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored. These individuals do not require confirmation that their vehicle is free from contamination prior to entering the congregate care areas.

However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles monitored and decontaminated (if applicable) and do require confirmation that their vehicle is free from contamination prior to entering the congregate care areas.

Massachusetts Extent of Play

!T~h,,e Greenfield ~on.un~ty  !!ege.

. cep.opn Center has been demnonstrated tis'~ cycle.

Sub-element 6.b - Monitoringand Decontaminationof Emergency Worker Equipment Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement radiological monitoring and decontamination of emergency workers and their equipment, inclusive of vehicles.

Criterion6.b. 1: The facility/ORO has adequateproceduresand resourcesto accomplish monitoringand decontaminationof emergenc, workers and their equipment and vehicles.

(NUREG-0654/FEMA-REP-1., K.5.a, b)

Assessment/Extent of Play 174 Assessment of this DemonstrationCriterionmay be accomplishedduring a biennialexercise, drills, an actual event, or SA V.

87

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station The monitoring staff must demonstrate the capability to monitor emergency worker personnel and their equipment and vehicles for contamination in accordance with the ORO's plans/procedures.

Specific attention must be given to equipment, including any vehicles that were in contact with contamination. The monitoring staff must demonstrate the capability to make decisions on the need for decontamination of personnel, equipment, and vehicles based on trigger/action levels and procedures stated in the ORO plans/procedures. Monitoring of emergency workers does not have to meet the 12-hour requirement. However, appropriate monitoring procedures must be demonstrated for a minimum of two emergency workers and their equipment and vehicles. Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation.

The area to be used for monitoring and decontamination must be set up as it would be in an actual emergency, with all route markings, instrumentation, record keeping, and contamination control measures in place. Monitoring procedures must be demonstrated for a minimum of one vehicle. It is generally not necessary to monitor the entire surface of vehicles. However, the capability to monitor areas such as radiator grills, bumpers, wheel wells, tires, and door handles must be demonstrated. Interior surfaces of vehicles that were in contact with contaminated individuals must also be checked.

Decontamination of emergency workers may be simulated and conducted via interview. Provisions for separate showering and same-sex decontamination must be demonstrated or explained. The staff must demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated individuals where applicable; provide changes of clothing for those with contaminated clothing; and store contaminated clothing and personal belongings to prevent further contamination of emergency workers or facilities.

OROs must demonstrate the capability to register emergency workers upon completion of the monitoring and decontamination activities. The activities for recording radiological monitoring and, if necessary, decontamination must include establishing a registration record consisting of the emergency worker's name, address, results of monitoring, and time of decontamination (if any), or as otherwise designated in the plan and/or procedures. Audio recorders, camcorders, or written records are all acceptable means for registration.

Monitoring activities shall not be simulated. Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. They must also explain the procedures for referring any emergency workers who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures. Contamination of the individual(s) will be determined by controller inject and not simulated with any low-level radiation source.

Decontamination capabilities and provisions for vehicles and equipment that cannot be successfully decontaminated may be simulated and conducted by interview. Waste water from decontamination operations does not need to be collected.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otk~t~vise specified in the Extent-of-Play Agreement.

88

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Massachusetts Extent of Play The en*field Community College Reception Cenier has been demonstrated, this'scycle.

Sub-element 6.c - Temporary Care of Evacuees Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires OROs to have the capability to establish relocation centers in host/support jurisdictions. The American Red Cross normally provides congregate care in support of OROs under existing letters of agreement.

Criterion6.c 1: Managersof congregate carefacilitiesdemonstratethat the centers have resources to provide services and accommodations consistent with American Red Cross planningguidelines. Managers demonstrate theprocedures to assurethat evacuees have been monitoredfor contaminationand have been decontaminatedas appropriatepriorto entering congregatecarefacilities. (NUREG-0654/FEMA-REP-1,J.10.h, J.12)

Assessment/Extent of Play Assessment of this.DemonstrationCriterionmay be accomplishedduring a biennialexercise, drills, an actual event, or SA V.

The evaluator must conduct a walk-through of the center to determine, through observation and inquiries, that the services and accommodations are consistent with applicable guidance.

For planning purposes, OROs must plan for a sufficient number of congregate care centers in host/support jurisdictions to accommodate a minimum of 20hercent of the EPZ population. In this simulation, it is not necessary to set up operations as they would be in an actual emergency. Alternatively, capabilities may be demonstrated by setting up stations for various services and providing those services to simulated evacuees. Given the substantial differences between demonstration and simulation of this criterion, exercise demonstration expectations must be clearly specified in Extent-of-Play Agreements.

Congregate care staff must also demonstrate the capability to ensure that evacuees, service animals, and vehicles have been monitored for contamination, decontaminated as appropriate, and registered before entering the facility.

Individuals arriving at congregate care facilities must have means (e.g., hand stamp, sticker, bracelet, form, etc.) indicating that they, and their service animals and vehicles, where applicable, have been monitored, cleared, and found to have no contamination or contamination below the trigger/action level.

In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored. These individuals do not need confirmation that their vehicle is free from contamination prior to entering the congregate care areas.

176 However, those individuals who are found to be contaminated and are then decontaminated will have 89

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station their vehicles monitored and decontaminated (if applicable) and do need confirmation that their vehicle is free from contamination prior to entering the congregate care areas. This capability may be determined through an interview process.

If operations at the center are demonstrated, material that would be difficult or expensive to transport (e.g., cots, blankets, sundries, and large-scale food supplies) need not be physically available at the facility(ies). However, availability of such items must be verified by providing the evaluator a list of sources with locations and estimates of quantities.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play

.......... . ..... .....-. ~. -. .: ** : ...L * .* :.. " ... . .. '*

TIS will not be demrnonstrat4ed .

Sub-element 6.d - Transportationand Treatment of ContaminatedIniuredIndividuals Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

medical services.

Criterion 6.d 1: The facilio,/OROhas the appropriatespace, adequate resources,and trained personnelto provide transport,monitoring, decontamination,and medical services to contaminatedinjured individuals. (NUREG-0654/FEMA-REP-1, F.2; H.1O; K.5.a, b; L.1, 4)

Assessment/Extent of Play Assessment of this Demonstration Criterionmay be accomnplished duringa biennialexercise, an actual event, or drills.

Monitoring, decontamination, and contamination control efforts must not delay urgent medical care for the victim.

OROs must demonstrate the capability to transport contaminated injured individuals to medical facilities.

An ambulance must be used for response to the victim. However, to avoid taking an ambulance out of service for an extended time, OROs may use any vehicle (e.g., car, truck, or van) to transport the victim to the medical facility. Normal communications between the ambulance/dispatcher and the receiving medical facility must be demonstrated. If a substitute vehicle is used for transport to the medical facility, this communication must occur before releasing the ambulance from the drill. This communication would include reporting radiation monitoring results, if available. In addition, the ambulance crew must demonstrate, by interview, knowledge of where the ambulance and crew would be monitored and decontaminated, if required, or whom to contact for such information.

177 Monitoring of the victim may be perforned before transport or en route, or may be deferred to the medical facility. Before using monitoring instruments, the monitor(s) must demonstrate the 90

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station process of checking the instrument(s) for proper operation. All monitoring activities must be completed as they would be in an actual emergency. Appropriate contamination control measures must be demonstrated before and during transport and at the receiving medical facility.

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

The medical facility must demonstrate the capability to make decisions on the need for decontamination of the individual, follow appropriate decontamination procedures, and maintain records of all survey measurements and samples taken. All procedures for collection and analysis of samples and decontamination of the individual must be demonstrated or described to the evaluator. Waste water from decontamination operations must be handled according to facility plans/procedures.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Massachusetts *~~~.

Extent of Play......

.The Franklin Medical Center was.demonstrated on December *:2010.

178 91

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station VERMONT YANKEE EXERCISE CYCLE 2013 Extent of Play State of New Hampshire 179 92

Unclassified Radiological Emergency Preparedness Program (REP)

After Action'Report/Improvement Plan Vermont Yankee Power Station This page left intentionally blank TABL* JF CONTENTS VERMONT YANKEE EXERCISE CYCLE ........................................ .............................................. 7ý T A BLE O F C O N TEN TS ....................................................................... ........................................................ .93 Overview 93

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan . Vermont Yankee Power Station-Exercise C ycle Set C alendar and Players .............................................................................................. 96 In Sequence Evaluations ........................... 97.......................

97 Host EOC .......... ................................................ 97 Lo c a l E O C s ......................... ................... .......................... ........................................... 9 7 State EOC ...................... ... ... ... .. .. .. .. . ................. 97 Em ergency O perations Facility (EO F) .............................................................................................. 97 Joint Inform ation C enter (JIC ) ...... . .. .................. 97.........................

97 Field Monitoring Teams ................................................. 97 O ut of Sequence Evaluations 977.......................

R isk D ay C a re s ........................................................................................ . . 98 M-S 1 Ho sp ita l: ........................................................................ ........................................... 9 8 Nursing/Long-Term C are Facility (R isk) ............................................................................................ 98 Nursing/Long-Term C are Facilities (Host) ................................. ............... ............................................ 98 EPZ Schools .............................................................................................. 98 State Transportation Staging A rea (STSA )............................................................................................. 98 Core Capabilities ........... ................................................ 98 11EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMEN ............................................ 99 S ub-e le m ent 1 .a - Mo b ilization ................................................................................................................. 99 EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMEN .......................................... 101 S ub-elem ent 1.b - Facilities ........................... .................................... 101 EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMEN ...................... 1...................

101 S ub-elem ent 1.c - Direction and C ontrol ................................................................................................ 102 EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT1 .......................................... 102 Sub-elem ent 1.d - Com m unications Eguipm ent 2.........................

102:

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMEN11 .......................................... 103 Sub-element 1.e - Eguipment and Supplies to Support Operations ...................... .103 EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING................... ... 105.

Sub-element 2.a - Emergency Worker Exposure Control .................................................................. 105 EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKINGý ............................................. 106 Sub-element 2.b: Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emerqencyv............................... ......... 106 EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING1 ............................................ 110 Sub-element 2.c - Protective Action Decisions Consideration for the Protection of Persons with Disabilities and Access/Functional Needs ........................................... 110 11EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION11 ............................................. III Sub-element 3.a - Implementation of Emergency Worker Exposure Control .................................. 11 EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION .......... ................. 113 Sub-element 3.b - Implementation of KI Decision for Institutionalized Individuals and the General P u b lic ................................................................................................................. ................. 1 13 11EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION!l .......................................... 114 Sub-element 3.c - Implementation of Protective Actions for Persons with Disabilities and A ccess/F unctiona l Needs ............................................................................................... 114 IEVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATIONI ............................................. 115 Sub-element 3.c - Implementation of Protective Actions for Persons with Disabilities and Access/Functional Needs ................................. .......................................... 115 1EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION1 ............................................ 116 Sub-element 3d. - Implementation of Traffic and Access Control .................................................... 116 IEVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSES11 ............................................... 118 Sub-element 4.a - Plume Phase Field Measurements and Analyses .............................................. 118 11EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS11 ................................................. 119 Sub-element 4.a - Plume Phase Field Measurements and Analyses .......... 1...........................

120 11EVALUATION AREA 5: EMERGENCY N 'I ICATION & PUBLIC INFORMATION@ ................... 121 Sub-element 5.a - Activation of the Prompt Alert and Notification System ...................................... 121 Sub-element 5.a - Activation of the Prompt Alert and Notification System ...................................... 122 11EVALUATION AREA 5:EMERGENCY NOTIFICATION & PUBLIC INFORMATION ...................... 123 94

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Sub-element 5.b - Subsequent Emergency Information and Instructions for the Public and the A i rl L* 1 1)1

... ir- ................................................................... . . . . . . . . . . ........................................................ .........

ME

• 1[EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES] ................................ 125 Sub-element 6.a - Monitoring, Decontamination, and Reqistration of Evacuees ........................... 125 EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES11 ......................................................... 127 Sub-element 6.b - Monitorinq and Decontamination of Emerqency Workers and their Equipment and Vehicles ...................................... ............................ 127 1[EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES ............ ................ 129 Sub-element 6.c - Temporary Care of Evacuees ............................................................ 129 F[EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES]1 ......................... 130 Sub-element 6.d - Transportation and Treatment of Contaminated Iniured Individuals ................. 130 A ttachm ent A - Non-Participating Facilities ........................................................................................ 131 Residential Cam pgrounds .......................................................................... Error! Bookm ark not defined.

Daycare Centers ................ .. .. ...................................... 131 Lo n g -T e rm C a re F a c ilitie s ........................................................................................................................ 13 1 S c h o o ls 131.........................

13 1 American Red Cross Congregate Care Facilities. ............................ ... 46 Overview This is the proposed 2013 Extent of Play (EOP) Criteria for the New Hampshire (N.H.) off-Site Response Organization (ORO) involved in the Plume Exercise Cycle for the Vermont Yankee Nuclear Po eStation (VY). No changes have been made to any criterion except as noted direcl'yin the document.

95

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station This EOP covers all components and activities of the exercise cycle starting with a planning workshop on December 5, 2012 and culminating with the Graded Exercise on June 5, 2013. Various "out of sequence" activities and exercises will/have been scheduled, but the criteria utilized will be incorporated into the EOP and noted throughout the document as appropriate.

This document does NOT identify all exercise areas to be discussed/exercised by the State and other ORO components. The scenarios developed for and utilized throughout will incorporate sufficient injects to provide opportunities for all players to participate in response activities mindful of an all-hazard approach. Only items identified in this EOP will be subject to evaluation.

This is a NEW HAMPSHIRE ONLY document. The EOP's from other participating states will be combined with this document by FEMA to form a comprehensive EOP for this exercise cycle.

Exercise Cycle Set Calendar and Players N.H. Only Date Place Participants Type December 5, 2012 TBD State/Local Emergency Planning Workshop Response Organizations (Unified Command and General Staff, ESF 1,2,3,6,7,8,10,11,12,13; Local Liaison; RHTA, AA, EOF 1 83 Personnel, FMT, Vermont Yankee Personnel); JIC Personnel, Host and EPZ EOC and Response Organizations January 9, 2013 TBD State/Local Emergency Tabletop Exercise 96

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Response Organizations (Unified Command and General Staff, ESF 1,2,3,6,7,8,10,11,12,13; Local Liaison; RHTA, AA, EOF Personnel, FMT, Vermont Yankee Personnel); JIC Personnel, Host and EPZ EOC

• nri PR~nrnn* CtrnaniTatinne February 13, 2013 SEOC,JIC, EOF, State/Local Emergency CFE#1*

LEOC Response Organizations (Unified Command and General Staff, ESF 1,2,3,6,7,8,10,11,12,13; Local Liaison; RHTA, AA, EOF Personnel, FMT, Vermont Yankee Personnel); JIC Personnel, Host and EPZ EOC and Response Organizations May 8, 2013 SEOC,JIC, EOF, State/Local Emergency CFE#2 LEOC Response Organizations (Unified Command and General Staff, ESF 1,2,3,6,7,8,10,11,12,13; Local Liaison; RHTA, AA, EOF Personnel, FMT, Vermont Yankee Personnel); JIC Personnel, Host and EPZ EOC and Response Organizations June 5, 2013 SEOC, JIC, EOF, State/Local Emergency Graded Exercise LEOC Response Organizations (Unified Command and General Staff, ESF 1,2,3,6,7,8,10,11,12,13; Local Liaison; RHTA, AA, EOF Personnel, FMT, Vermont Yankee Personnel); JIC Personnel, Host and EPZ EOC and Response Organizations AA = Accident Assessment CFE = Combined Functional Exercise EOF = Emergency Operations Facility EOC = Local Emergency OperationsCenter ESF = Emergency Support Function FMT = Field Monitoring Team JIC = Joint Information Center RHTA = Rad. Health Technical Advisor SEOC = State Emergency Operations Center In Sequence Evaluations Host EOC - Keene Local EOCs - Chesterfield, Hinsdale, Richmond, Swanzey, Winchester State EOC (including Accident Assessment) - Concord Emergency Operations Facility (EOF)

Joint Information Center (JIC)

Field Monitoring Teams - Monitoring Teams (MT1 & MT2)

Equipment Checklist - Day Prior to Exercise Southwest N.H. Fire Mutual Aid District N.H. Primary State Warning Point SP - Troop C; DOT - District 4 184 Out of Sequence (OOS) Evaluations Residential Camps TBD 97

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power'Station Camp Spofford - Chesterfield Camp Takodah - Richmond Camp Wiyaka - Richmond Risk Day Cares (4) TBD Village Children's Center - Chesterfield Nanny's Day Care - Hinsdale Pooh's Corner Preschool - Hinsdale Ashuelot Head Start - Winchester M-S 1 Hospital:

Cheshire Medical Center- Keene, N.H. September 19, 2012 Nursing/Long-Term Care Facility (Risk) TBD None in 2013 Cycle Nursing/Long-Term Care Facilities (Host) (2) TBD Westwood Care & Rehabilitation - Keene Pheasantwood Care & Rehabilitation - Peterborough EPZ Schools TBD Immaculate Heart of Mary School - Richmond State Transportation Staging Area (STSA) June 12, 2013 First Student Terminal - Swanzey, N.H.

Keene Reception Center April 26, 2013 Keene High School - Keene ARC Congregate Care Facilities TBD Jaffrey-Rindge Middle School Facilities not expected to participate in this exercise cycle are also identified in Attachment A

• Evaluation Areas are based upon guidance from Section III - C. Exercise Demonstration, "REP ProgramManual, April 2012"

• Special Disclaimer: Due to exercise scenario time constraints, some responses and/or activities associated with certain classification levels may be significantly compressed or exaggerated such as reception center personnel arrival time, transportation asset scheduling, etc.

Core Capabilities Critical Transportation Environmental Response/Health and Safety Health and Social Services Housing Mass Care Services On-Scene Security and Protection Operational Communications Operational Coordination Planning Public and Private Services and Resources Public Health and Medical Services Public Information and Warning Supply Chain Integrity and Security 185 98

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENTH Sub-element 1.a - Mobilization Criterion 1.a.1: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654/FEMA-REP-1, A.I.a, e; A.3, 4; C.1,4, 6; D.4; E.1, 2; H.3, 4)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to alert, notify, and mobilize emergency personnel, and activate and staff emergency facilities.

ASSESSMENT/EXTENT OF PLAY Responsible OROs must demonstrate the capability to receive notification of an incident from the licensee; verify the notification; and contact, alert, and mobilize key emergency personnel in a timely manner and demonstrate the ability to maintain and staff 24-hour operations. Twenty-four-hour operations can be demonstrated during the exercise via rosters or shift changes or otherwise in an actual activation. Local responders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management organizations of an incident in a timely manner, when they receive information from the licensee or alternate sources. Responsible OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. Activation of facilities and staff, including those associated with the lrident Command System must be completed in accordance with ORO plans/procedures. The location and contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP after these facilities have been activated.

99

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Pre-positioning of emergency personnel is appropriate, in accordance with the Extent-of-Play Agreement, at those facilities located beyond a normal commuting distance from the individual's duty location or residence. This includes the staggered release of resources from an assembly area. Additionally, prepositioning of staff for out-of-sequence demonstrations may be used in accordance with the Extent-of-Play Agreement. The REP program does not evaluate Incident Command Post tactical operations (e.g., Law Enforcement hostile action suppression techniques), only coordination among the incident command, the utility, and all appropriate OROs, pursuant to plans/procedures.

Initial law enforcement, fire service, HAZMAT, and emergency medical response to the NPP site may impact the ability to staff REP functions. The ability to identify and request additional resources or identify compensatory measures must be demonstrated. Exercises must also address the role of mutual aid in the incident, as appropriate. An integral part of the response to an HAB scenario at an NPP may also be within the auspices of the Federal Government (e.g.,

FBI, NRC, or DHS). Protocols for requesting Federal, state, local, and tribal law enforcement support must be demonstrated, as appropriate. Any resources must be on the ORO's mobilization list so they can be contacted during an incident, if needed. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

Emergency facilities will be alerted in accordance with the NHRERP. Those .facilities that are *to partic!pate-in the exercise will mobilize accordingly. N.H. will respond at a 10-minute per hour ratio.

Rostersforptky personnel relief shifts will be available in each participatingfacility. Those facilities thait are not participatingwill acknowledge receipt of notification, but will take no fitrther action. Controllers will simulate facilities not participatingin the exercise. The Followingfacilities are expected to Mobilize and participate in this exercise: NH State EOC, EOF, JIC, Hinsdale EOC. Winchester EOC, Chesterfield EOC, Richmond EOC, Swanzev, EOC, Keene EOC (Host Communit,) Field Monitoring Teams, Troop C NHSP, NHDOT District4 (etensions of ESF#1 and ESF#13 in the SEOC). The State.

Transportation Staging Area (STSA), School, Reception Center and Resident Camps will identify mobilizationprocedures through out of sequence interviews.

187 100

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan ' Vermont Yankee Power Station IIEVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT Sub-element I.b - Facilities Criterion 1 .b.1: Facilities are sufficient to support the emergency response.

(NUREG-0654/FEMA-REP-1, H.3; G.3.a; J.10.h; J.12; K.5.b)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have facilities to support the emergency response.

ASSESSMENT/EXTENT OF PLAY Responsible OROs must demonstrate, no less than once every eight years, the availability of facilities to support accomplishment of emergency operations (this includes all alternate and backup facilities). Evaluations are typically performed for EOCs and JICs, as well as other facilities such as reception/relocation centers. Some of the areas evaluated within the facilities are adequate space, furnishings, lighting, restrooms, ventilation, backup power, and/or alternate facility, if required to support operations. Radio stations, laboratories, initial warning points and hospitals are not evaluated under 1.b.1.

In addition, facilities will be evaluated for this criterion during the first biennial exercise after any new or substantial changes in structure, equipment, or mission that affect key capabilitiesi as outlined in respective emergency plans/procedures. A substantial change is one that has a direct effect or impact on emergency response operations performed in those facilities.

Examples of substantial changes include: modifying the size or configuration of an emergency operations center, adding more function to a center or changing the equipment available for use in a center.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

There are currently no new Facilities in the New Hampshire Portion of the Vermont Yankee Emergency Planning Zone, however the State Transportation Staging Area (STSA) at the First Student Bus Terminal in Swanzey has been re-designedand will require re-evaluation. The Reception Center at Keene High School will demonstrate capabilities out of sequence. The school and campgrounds will be visited and demonstrate their capabilitiesthrough visitation and interview out of sequence.

188

[EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT]

101

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Sub-element 1.c - Direction and Control Criterion 1.c.1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible. (NUREG-0654/FEMAREP-1, A.1.d; A.2.a, b; A.3; C.4, 6)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to control their overall response to an emergency.

EXTENT OF PLAY Leadership personnel must demonstrate the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed through periodic briefings and/or other means, coordinating with other OROs, and ensuring completion of requirements and requests.) Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources. Any resources identified through LOA/MOUs must be on the ORO's mobilization list so they may be contacted during an incident, ifneeded.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

Participatingstate and local facilities will demonstrate their abilihy to direct and control emergency operations in accordance with the NHRERP..

• SEOC - Communicationswith the Governor and his staff will be simulated where necessaily.

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMEN Sub-element 1.d - Comm unicatiorA8quipment 102

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Criterion 1.d.1: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations. Communications capabilities are managed in support of emergency operations.

(NUREG-0654/FEMA-REP-1, F.1, 2)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs establish and operate reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as contiguous governments within the EPZ, Federal emergency response organizations, the licensee and its facilities, EOCs, Incident Command Posts, and FMTs.

ASSESSMENT/EXTENT OF PLAY OROs must demonstrate that a primary system, and at least one backup system for fixed facilities, is fully functional at all times. Communications systems are maintained and tested on a recurring basis throughout the assessment period and system status is available to all operators. Periodic test results and corrective actions are maintained on a real time basis. If a communications system or systems are not functional, but exercise performance is not affected, no exercise issue will be assessed.

Communications equipment and procedures for facilities and field units are used as needed for transmission and receipt of exercise messages. All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of.the commercial telephone system. Responsible OROs must demonstrate the capability to manage the communication. systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists. Exercise scenarios 'nay require the failure of a communication system and use of an alternate system, as negotiated in the Extent-of-Play Agreement. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

Pursuantto the NHRERP,facilities participatingin this exercise will demonstrate their primaria and back up communications systems. Other communications systems and capabilitiesmay also be utilized.

Contact with locations not participatingwill be simulated.

NOTE: If during the exercise, a participant demonstrates the portion of this sub-element that deals with performance unsatisfactorily, the FEMA Evaluator will inform the participant. After an "on the spot" re-training by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day. Actual communication equipment cannot be re-demonstrated.

EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENj Sub-element 1.e - Equipment and Supplies to Support Operations Criterion I.e.1: Equipmentif9aps, displays, monitoring instruments, dosimetry, potassium iodide (KI) and other supplies are sufficient to 103

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station support emergency operations (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)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have emergency equipment and supplies adequate to support the emergency response.

ASSESSMENT/EXTENT OF PLAY A particular facility's equipment and supplies must be sufficient and consistent with that facility's assigned role in the ORO's emergency operations plans. Use of maps and other displays is encouraged. For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available, or their availability described.

Specific equipment and supplies that must be demonstrated under this criterion include KI inventories, dosimetry, and monitoring equipment, as follows:

KI: Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (1) emergency workers; (2) institutionalized individuals, as indicated in capacity lists for facilities; and (3) where stipulated by the plans/procedures, members of the general public (including transients) within the plume pathway EPZ. In addition, OROs must demonstrate provisions to make KI available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures). The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI, as well as a mechanism for identifying emergency workers that have declined KI in advance. Consider carefully the placement of emergency workers that have declined KI in advance.

ORO quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical inspection at the storage location(s) or through documentation of current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV.

Available supplies of KI must be within the expiration date indicated on KI bottles or blister packs. As an alternative, the ORO may produce a letter from a certified private or state laboratory indicating that the KI supply remains potent, in accordance with U.S. Pharmacopoeia standards.

Dosimetry: Sufficient quantities of appropriate direct-reading and permanent record dosimetry and dosimeter chargers must be available for issuance to all emergency workers who will be dispatched to perform an ORO mission. In addition, OROs must demonstrate provisions to make dosimetry available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures).

Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures.

Direct-reading dosimeters must be zeroed or operationally checked prior to issuance. The dosimeters must be inspected for electrical leakage at least annually and replaced when necessary. Civil Defense Victoreen Model 138s (CD V-138s) (0-200 mR), due to their documented history of electrical leakage problems, must be inspected for electrical leakage at least quarterly and replaced when necessary. This leakage testing will be verified during the exercise, through documentation submitted in the ALC and/or through an SAV. Operational checks and testing of electronic dosimeters must be in accordance with the manufacturer's instructions and be verified during the exercise, through documentation submitted in the ALC and/or through an SAV. 191 Monitoring Instruments: All instruments must be inspected, inventoried, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. Unmodified CDV-700 series instruments and other instruments without a 104

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station manufacturer's recommendation must be calibrated annually. Modified CDV-700 instruments must be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration must be on each instrument or calibrated frequency can be verified by other means. In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source.

For FMTs, the instruments must be capable of measuring gamma exposure rates and detecting beta radiation. These instruments must be capable of measuring a range of activity and exposure, including radiological protection/exposure control of team members and detection of activity on air sample collection media, consistent with the intended use of the instrument and the ORO's plans/procedures. An appropriate radioactive check source must be used to verify proper operational response for each low-range radiation measurement instrument (less than 1R/hr) and for high-range instruments when available. If a source is not available for a high-range instrument, a procedure must exist to operationally test the instrument before entering an area where only a high-range instrument can make useful readings.

In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standardfor a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

FEA4A will provide copies of the Annual Letter of Certification to evaluators,as appropriate. Instrimnent data will be an attachment to the Annual Letter of Certification. Pursuant to the NHRERP, facilities participating in this exercise will demonstrate their equipment, immaps, displays, dosimetry, potassium iodide (KI) and other supplies are adequate and sufficient to support the emergency response. DPHS responders traveling to the VY EOF who alreadyhave proper dosimetry with them at the tinme may forego stopping at SP, Troop C.

NOTE: If during the exercise, a participant demonstrates the portion of this criterion that deals with performance unsatisfactorily, the FEMA Evaluator will inform the participant. After an "on the spot" re-training by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day. Actual equipment cannot be re-demonstrated.

IEVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKINGJ Sub-element 2.a - Emergency Worker Exposure Control Criterion 2.a.1: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers, inclIging provisions to authorize radiation exposure in excess of administrative limits or protective action guides.

(NUREG-0654/FEMA-REP-1, C.6; J.10. e, f; K.4) 105

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place, as specified in the ORO's plans/procedures, to authorize emergency worker exposure limits to be exceeded for specific missions. Radiation exposure limits for emergency workers are the recommended accumulated dose limits or exposure rates that emergency workers may be permitted to incur during an emergency. These limits include any pre-established administrative reporting limits (that take into consideration TEDE or organ-specific limits) identified in the ORO's plans/procedures.

ASSESSMENT/EXTENT OF PLAY OROs authorized to send emergency workers into the plume exposure pathway EPZ must demonstrate a capability to comply with emergency worker exposure limits based on their emergency plans/procedures. Participating OROs must also demonstrate the capability to make decisions concerning authorization of exposure levels in excess of pre-authorized levels and the number of emergency workers receiving radiation doses above pre-authorized levels. This would include providing KI and dosimetry in a timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating actions, in accordance with respective plans/procedures.

As appropriate, OROs must demonstrate the capability to make decisions on the distribution and administration of KI as a protective measure for emergency workers, based on, their plans/procedures or projected thyroid dose compared with the established PAGs for. KI administration. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

77is Evaluation Area will be demonstrated in accordance with the NHRERP. Protective action decision-making occurs at the New HanipshireSEOC. T7w State decision-making team coordinates their activity with Venuont and Massachusetts. Recommended protective actions are transmitted to each municipal EOCfroiu the SEOC.

EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING1 Sub-element 2.b: Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency Criterion 2.b.1: Appropriate protective action recommendations (PARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA-REP-1, 1.10 and ej:pplement 3)

INTENT 106

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to independently project integrated dose from projected or actual dose rates and compare these estimates to the PAGs.

OROs must have the capability to choose, among a range of protective actions, those most appropriate in a given emergency. OROs base these choices on PAGs from their plans/procedures or EPA's Manual of Protective Action Guides and Protective Actions for Nuclear Incidents and other criteria, such as plant conditions, licensee PARs, coordination of PADs with other political jurisdictions (e.g., other affected OROs and incident command), availability of in-place shelter, weather conditions, and situations, to include HAB incidents, the threat posed by the specific hostile action, the affiliated response, and the effect of an evacuation on the threat response effort, that create higher than normal risk from general population evacuation.

ASSESSMENT/EXTENT OF PLAY During the initial stage of the emergency response, following notification of plant conditions that may warrant offsite protective actions, the ORO must demonstrate the capability to use appropriate means, described in the plans/procedures, to develop PARs for decision-makers based on available information and recommendations provided by the licensee as well as field monitoring data, if available. The ORO must also consider any release and meteorological data provided by the licensee.

The ORO must demonstrate a reliable capability to independently validate dose projections. The types of calculations to be demonstrated depend on the data available and ;the need for assessments to support the PARs must be appropriate to the scenario. In all cases, calculation of projected dose must be demonstrated. Projected doses must be related to quantities and units of the PAG to which they will be compared. PARs must be promptly transmitted to decision-makers in

• a pre-arranged format.

When the licensee and ORO projected doses differ by more than a factor of 10, the ORO and licensee must determine the source of the difference by discussing input data and assumptions, using different models, or exploring possible reasons. Resolution of these differences must be incorporated into the PARs if timely and appropriate. The ORO must demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated PARs.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

This Evaluation Area will be demonstratedin accordancewith the NHRERP at the State EOC and EOF in the context of the exercise scenario. Appropriateaccident assessment models will be selected and used. The state decision-making team will evaluate the recommendations of the accident assessment team and develop appropriateprotective action decisions. Protective action recommendations will be made in accordance with the NHRERP.

194 107

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station IEVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKINGI Sub-element 2.b - Radiological Assessment and Protective Action Recommendations and Decisions for the Plume Phase of the Emergency Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make protective action decisions (PADs) for the general public (including the recommendation for the use of KI, if ORO policy). (NUREG-0654/FEMAREP - 1,A.3; C.4, 6; D.4; J.9; J.10.f, m)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to independently project integrated dose from projected or actual dose rates and compare these estimates to the PAGs.

OROs must have the capability to chooslamong a range of protective actions, those most appropriate in a given emergency. OROs base these choices on PAGs from their plans/procedures or EPA's Manual of Protective Action Guides and Protective Actions for Nuclear Incidents and other 108

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station criteria, such as plant conditions, licensee PARs, coordination of PADs with other political jurisdictions (e.g., other affected OROs and incident command), availability of in-place shelter, weather conditions, and situations, to include HAB incidents, the threat posed by the specific hostile action, the affiliated response, and the effect of an evacuation on the threat response effort, that create higher than normal risk from general population evacuation.

ASSESSMENT/EXTENT OF PLAY OROs must have the capability to make both initial and subsequent PADs. OROs must demonstrate the capability to make initial PADs in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO authorities (e.g., incident command), and PARs from the utility and ORO staff. In addition, a subsequent or alternate PAD may be appropriate if various conditions (e.g., an HAB incident, weather, release timing and magnitude) pose undue risk to an evacuation, or if evacuation may disrupt the efforts to respond to a hostile action.

OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a PAD if local law enforcement, fire service, HAZMAT, and emergency medical resources are utilized to augment response to the NPP site or other key infrastructure.

Dose assessment personnel may provide additional PARs based on the subsequent dose projections, field monitoring data, :or information on plant conditions. In addition, incident command must provide input regarding considerations for subsequent PARs based on the magnitude of the ongoing threat, the response, and/or site conditions. The decision-makers must demonstrate the capability to change protective actions based on the combination of all these factors.

If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must demonstrate the capability to make decisions on the distribution and administration of KI to supplement sheltering and evacuation. This decision must be based on the ORO's plans/procedures or projected thyroid dose compared with the established PAG for KI administration. The KI decision-making process must involve close coordination with appropriate assessment and decision-making staff.

If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate PADs with each other. In addition, decisions must be coordinated/communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

Protective action decisions are made and demonstrated at the NH SEOC based upon information provided to and by NH DPHS/RadHealth personnel. The SEOC Accident Assessment team analyzes utiliti,, field team and meteorological data to make recommendations to the SEOC decision-makersfor consideration in making protective action recommendations and decisions.

Municipal organizations will be notified and respond in accordance with their plans and procedures to implement the recommended protective actions. The New Hampshire decision-making team will discuss its decisions with the Vermont and Massachusetts decision-making teams and coordinate the joint public notification process.

196 109

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station IEVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING1 Sub-element 2.c - Protective Action Decisions Consideration for the Protection of Persons with Disabilities and Access/Functional Needs Criterion 2.c.1: Protective action decisions are made, as appropriate, for groups of persons with disabilities and access/functional needs.

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

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to determine PADs, including evacuation, sheltering, and use of KI, if applicable, for groups of persons with disabilities and access/functional needs (e.g., hospitals, nursing homes, correctional facilities, schools, licensed daycare centers, mobility-impaired individuals, and transportation-dependent individuals). The focus is on those groups of persons with disabilities and access/functional needs that are, or potentially will be, affected by a radiological release from an NPP.

ASSESSMENT/EXTENT OF PLAY Usually it is appropriate to implement evacuation in areas where doses are projected to exceed the lower end of the range of PAGs, except for incidents where there is a high-risk environmental condition or where high- ~roups (e.g., the immobile or infirm) are involved. In these cases, factors that must be con=red include weather conditions, shelter availability, availability of transportation assets, risk of evacuation versus risk from the avoided dose, and precautionary school evacuations. In addition, decisions must be coordinated/communicated 110

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan - Vermont Yankee Power Station -

with the incident command. In situations where an institutionalized population cannot be evacuated, the ORO must consider use of KI. Applicable OROs must demonstrate the capability to alert and notify all public school systems/districts of emergency conditions that are expected to or may necessitate protective actions for students. Demonstration requires that the OROs actually contact public school systems/districts during the exercise.

In accordance with plans/procedures, OROs and/or officials of public school systems/districts must demonstrate the capability to make prompt decisions on protective actions for students.

The decision-making process, including any preplanned strategies for protective actions for that ECL, must consider the location of students at the time (e.g., whether the students are still at home, en route to school, or at school). All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

The ability and resources to implement protective actionsfor schools will be demonstratedin accordance with the NHRERP at the State and municipal EOCs. School Administrative Units located within the Vermont Yankee EPZ are: SA U 92 - Hinsdale, SA U 94 - Winchester and SA U 29 - Chesterfield All public schools within the VY EPZ were evaluated in 2009 and therefore do not need to be evaluated until 2015. Immaculate Heart of Mart will be interviewed OOS EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.a - Implementation of Emergency Worker Exposure Control Criterion 3.a.1: The OROs issue appropriate dosimetry,KI, and procedures, and manageradiological exposure to emergency workers in accordance with the plans/procedures. Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to emergency workers. (NUREG-0654/FEMA-REP-1,J.1O.e; K.3.a, b; K.4)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimetry and permanent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for each emergency worker; establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of the PAGs, and the capability to provide KI for emergency workers, always applying the "as low as is reasonably achievable" principle as appropriate.

ASSESSMENTIEXTENT OF PLAY OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent record dosimetry, dosimeter chargers, KI, and instructions on the uspqA' these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows an individual(s) to read the administrative reporting limits that are pre-established at a level low enough to consider 111

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemiont Yankee Power Station subsequent calculation of TEDE and maximum exposure limits, for those emergency workers involved in lifesaving activities, contained in the ORO's plans/procedures.

Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control.

During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. The emergency worker must report accumulated exposures during the exercise as indicated in the plans/procedures. OROs must demonstrate the actions described in the plans/procedures by determining whether to replace the worker, authorize the worker to incur additional exposures, or take other actions. If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge of whom to contact in case authorization is needed, and at what exposure levels.

Workers may use any available resources (e.g., written procedures and/or coworkers) in providing responses.

Although it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission. In such cases, adequate control of exposure can be achieved for all team members using one direct-reading dosimeter worn by the team leader. Emergency workers assigned to low-exposure rate fixed facilities (e.g., EOCs and communications center within the EPZ, reception centers, and counting laboratories) may have individual direct-reading dosimeters or they may be monitored using group dosimetry (i.e., direct reading dosimeters strategically placed in the work area). Each team member must still have his or her own permanent record dosimetry. Individuals authorized by the ORO to reenter an evacuated area during the plume (emergency) phase, must be limited to the lowest radiological exposure commensurate with completing their missions.

OROs may have administrative limits lower than EPA-400-R-92-001 dose limits for emergency workers performing various services (e.g., life saving, protection of valuable property, all activities). OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where life saving and/or protection of valuable property may require an urgent response.

OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. Ingestion of KI recommended by the designated ORO health official is voluntary. For evaluation purposes, the actual ingestion of KI shall not be performed. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it.

Emergency workers must demonstrate basic knowledge of procedures for using KI whether or not the scenario drives the implementation of KI use. This can be accomplished by an interview with the evaluator.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

Tie RADEF Officer in each facility will issue appropriatedosimetny in accordance with the NHRERP.

Tize following facilities will demonstrate their ability to meet these criteria: LOCAL EOCs--Hinsdale, Winchester, Chesterfield, Richmond and 1 -twanzey; Field Teams; Troop C; and Department of Transportation,Division 4. The RADEF Officer in each facility will issue dosimetry to at least three (3) participants in accordance with procedures identified in the NHRERP. Emergenctj Worker Exposure 112

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan" Vermont Yankee Power Station Control for the State TransportationStaging Area will be done out-of-sequence. The capability to issue KI to emergency workers will be demonstrated at appropriate state and municipal facilities. The RADEF officer at each faciliot (including Troop C and Field Teams) will talk through the issuing process. Two (2) emergency workers will be interviewed at each site about their knowledge and proceduresfor the use of KI.

No KI will be ingested.

NOTE: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant.After an "on-the-spot"retraining by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

1EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION.

Sub-element 3.b - Implementation of KI Decision for Institutionalized Individuals and the General Public.

Criterion 3.b.1: KI and appropriate instructions are available if a

decision to recommend use of KI is made. Appropriate record-keeping of the administration of KI for institutionalized individuals is maintained. (NUREG-0654/FEMA-REP-1, J.10.e, f)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide KI for institutionalized individuals, and, if in the plans/procedures, to the general public for whom immediate evacuation may not be feasible, very difficult, or significantly delayed. While it is necessary for OROs to have the capability to provide KI to institutionalized individuals, providing KI to the general public is an ORO option and must be reflected as such in ORO plans/procedures. Provisions must include the availability of adequate quantities, storage, and means of distributing KI.

ASSESSMENT/EXTENT OF PLAY OROs must demonstrate the capability to make KI available to institutionalized individuals, and, where provided for in their plans/procedures, to members of the general public. OROs must demonstrate the capability to accomplish distribution of KI consistent with decisions made.

OROs must have the capability to develop and maintain lists of institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest KI. Ingestion of KI recommended by the designated ORO health official is voluntary. For evaluation purposes, the actual ingestion of KI shall not be performed. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it.

If a recommendation is made for the general public to take KI, appropriate information must be provided to the public by the means of notification specified in the ORO's plans/procedures.

All activities must be based on the ORG ans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

113

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station New Hampshire Extent of Play:

Quantities of KI are stored at each risk municipality EOC, EPZ nursing home, and hospitals. The general public may secure KI through application to the NH DPHS.

NOTE.: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant. After an "on-the-spot"retraining by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

11EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.c - Implementation of Protective Actions for Persons with Disabilities and Access/Functional Needs.

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

persons with disabilities and access/functional needs other thaný schools within areas subject to protective actions. (NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement PADs, including evacuation and/or sheltering, for all persons with disabilities and access/functional needs. The focus is on those persons with disabilities and access/functional needs that are (or potentially will be) affected by a radiological release from an NPP.

ASSESSMENT/EXTENT OF PLAY Applicable OROs must demonstrate the capability to alert and notify (i.e., provide PARs and emergency information and instructions to) persons with disabilities and access/functional needs, including hospitals/medical facilities, nursing homes, correctional facilities, and mobility-impaired and transportation-dependent individuals. OROs must demonstrate the capability to provide for persons with disabilities and access/functional needs in accordance with plans/procedures.

Contact with persons with disabilities and access/functional needs and reception facilities may be actual or simulated, as agreed to in the extent of play. Some contacts with transportation providers must be actually contacted, as negotiated in the extent of play. All actual and simulated contacts must be logged.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

EPZ EOCs will contact licensed and regi2,eOd childcare centers and nursing home according to their procedures. Further contact with special facilities by the EOCs will be simulated and default numbers will be used to determine transportation requirements. Patients/residents will not be involved. No 114

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station vehicles will be dispatchedfor precautionarn transfer or evacuation. An up-to-date list of individuals in EPZ colninniities requiring special assistance with transportation will be available to the FEMA evaluator; however, the information is confidential and copies will not be provided to the evaluator. All calls will be simulated and logged. State EOC notification to for transportationassets to STSA will be simulated.

An out of sequence demonstration/discussion of the Staging Area will take place to demonstrate the ability to distribute transportation resources to support the risk municipalities in New Hampshire.

Transportationassets will not be dispatched.

IEVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.c - Implementation of Protective Actions for Persons with Disabilities and Access/Functional Needs Criterion 3.c.2: OROs/School officials implement protective actions for schools. (NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement PADs, including evacuation and/or sheltering, for all persons with disabilities and access/functional needs. The focus is on those persons with disabilities and access/functional needs that are (or potentially will be) affected by a radiological release from an NPP.

ASSESSMENTIEXTENT OF PLAY School systems/districts (these include public and private schools, kindergartens, pre-schools, and licensed daycare centers) must demonstrate the ability to implement PADs for students.

The demonstration must be made as follows: Each school system/district within the 10 mile EPZ must demonstrate implementation of protective actions. At least one school per affected system/district must participate in the demonstration. Canceling the school day, dismissing early, or sheltering in place must be simulated by describing to evaluators the procedures that would be followed. If evacuation is the implemented protective action, all activities to coordinate and complete the evacuation of students to reception centers, congregate care centers, or host schools may actually be demonstrated or accomplished through an interview process.

If accomplished through an interview, appropriate school personnel including decision-making officials (e.g., schools' superintendent/principals and transportation director/bus dispatchers),

and at least one bus driver (and the bus driver's escort, if applicable) must be available to demonstrate knowledge of their role(s) in the evacuation of school children. Communications capabilities between school officials and the buses, if required by the plans/procedures, must be verified.

Officials of the school system(s) must demonstrate the capability to develop and provide timely information to OROs for use in messages to parents, the general public, and the media on the status of protective actions for schools. If a school facility has emergency plans as a condition of licensing, those plans may be submitted to FEMA review in place of demonstration or interview pursuant to the ORO's plans/procedures as negotiated in the Extent-of-Play Agreement.

All activities must be based on the OR(Q)lans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

115

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vernont Yankee Power Station New Hampshire Extent of Play:

EPZ EOCs will initially contact schools, licensed and registeredchildcare centers and any nursing hoImes according to their procedures. Students and patients/residentswill not be involved. Furthercontact with schools/daycares by the EOCs will be simulated. Default numbers will be used to determine transportationrequirements. No vehicles will be dispatchedfor precautionarytransfer or evacuation.

Protective Action Decisions are made at the SEOC. Immaculate Heart of Mary School and campgrounds will be interviewed out of sequence.

1EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION1 Sub-element 3.d. - Implementation of Traffic and Access Control Criterion 3.d.1: Appropriate traffic and access control is established.

Accurate instructions are provided to traffic and access control personnel. (NUREG-0654/FEMA-REP-1, A.3; C.1, 4; J.10.g, j)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement protective, action plans/procedures, including relocation and restriction of access to evacuated/sheltered areas. This Sub-element focuses on selecting, establishing, and staffing of traffic and access control points, and removal of impediments to the flow of evacuation traffic.

ASSESSMENT/EXTENT OF-PLAY OROs must demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with current conditions and PADs (e.g., evacuating, sheltering, and relocation) in a timely manner. OROs must demonstrate the capability to provide instructions to traffic and access control staff on actions to take when modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled.

Traffic and access control staff must demonstrate accurate knowledge of their roles and responsibilities, including verifying emergency worker identification and access authorization to the affected areas, as per the Extent-of-Play Agreement. These capabilities may be demonstrated by actual deployment or by interview, in accordance with the Extent-of-Play Agreement.

In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic), they must demonstrate the capability to contact the state or Federal agencies that have the needed authority, as agreed upon in the Extent-of-Play Agreement. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

Municipal police will be asked to describe their traffic control plan for theirjurisdiction at the inunicipal EOC. State Police Troop C and DOT District 4 personnel will not be involved for evaluation of this criteriaduring the graded exercise on June 5.

203 116

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station EVALUATION AREA 3: PROTECTIVE ACTION IMPLEMENTATION Sub-element 3.d. - Implementation of Traffic and Access Control Criterion 3.d.2: Impediments to evacuation are identified and resolved.

(NUREG-0654/FEMA REP-1, J.10., k.)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement protective action plans/procedures, including relocation and restriction of access to evacuated/sheltered areas. This Sub-element focuses on selecting, establishing, and staffing of traffic and access control points, and removal of impediments to the flow of evacuation traffic.

ASSESSMENT/EXTENT OF PLAY OROs must demonstrate the capability, as required by the scenario, to identify and take appropriate actions concerning impediments to evacuation. Actual dispatch of resources to deal with impediments, such as wreckers, need not be demonstrated; however, all contacts, actual or simulated, must be logged. The impediment must occur during the evacuation and be on an evacuation route such that re-routing of traffic is required, triggering decision-making and coordination with the JIC to communicate the alternate route to evacuees leaving the area.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

Each EPZ EOC will demonstrate re-routing of traffic following a traffic impediment through an interview with the FEMA evaluator. No personnel or actual equipmient will be deployed to field locations.

NOTE: If during the exercise, a participantdemonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant. After an "on-the-spot"retraining by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

204 117

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station F[EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSES]

Sub-element 4.a - Plume Phase Field Measurements and Analyses Criterion 4.a.2: Field teams (2 or more) are managed to obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654/FEMA-REP-1, C.1; H.12; 1.7, 8, 11; J.1O.a)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to deploy FMTs with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654/FEMA-REP-1 indicates that OROs must have the capability to use FMTs within the plume exposure pathway EPZ to detect. airborne radioiodine in the presence of noble gases and radioactive particulate material in the airborne plume. In an incident at an NPP, the possible release of radioactive material may pose a risk to the nearby population and environment. Although incident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties. During an incident, it is important to collect field radiological data to help. characterize any radiological release. Adequate equipment and procedures are essential to such field measurement efforts.

ASSESSMENT/EXTENT OF PLAY Responsible OROs must demonstrate the capability to brief FMTs on predicted plume location and direction, plume travel speed, and exposure control procedures before deployment. During an HAB incident, the Field Team management must keep the incident command informed of field monitoring teams' activities and location. Coordination with FMTs and field monitoring may be demonstrated as out-of-sequence demonstrations, as negotiated in the Extent-of-Play Agreement.

Field measurements are needed to help characterize the release and support the adequacy of implemented protective actions, or to be a factor in modifying protective actions. Teams must be directed to take measurements at such locations and times as necessary to provide sufficient information to characterize the plume and its impacts.

If the responsibility for obtaining peak measurements in the plume has been accepted by licensee field monitoring teams, with concurrence from OROs, there is no requirement for these measurements to be repeated by ORO monitoring teams. If the licensee FMTs do not obtain peak measurements in the plume, it is the ORO's decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coordination of plume measurement information among all FMTs (licensee, Federal, and ORO) is essential.

Coordination concerning transfer of samples, including a chain-of-custody form(s), to a radiological laboratory(ies) must be demonstrated.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee), as necessary. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

205 118

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vemiont Yankee Power Station New Hampshire Extent of Play:

For the purposes of this exercise, at least two NH DPHS radiological monitoring teams will be dispatched from the DPHS radiological chemistny laboratonr in Concord. Charcoal cartridges will be used in place of silver-zeolite. The .field data from the sample collection will be communicated to the DPHS Monitoring Team Coordinator(MTC). Sample transfer process will be talked through to its final deliveny to the DPHS radiological chemistry lab. TDe Monitoring Teams will not be picking up their dosimetry front Troop C but ratherpick it up from the DPHS Radiological Lab prior to proceeding to the EPZ.

The monitoring teams will collect tzvo complete samples, at a minimum before the exercise terminates.

For the purposes of this exercise, two NH DPHS radiologicalmonitoring teams will be dispatched out of sequence. The teams will arrive at the DPHS office at 08:00 to obtain kits. The kits will be sealed with dated custody tape. If tle custody tape is intact, the teams will take the kits as is without need to inventonr. Each teamlWill source-check their instruments, receive a briefing from the Rad Lab Supervisor and do a radio check, then deploy to the EPZ. A FEMA evaluator will observe the team's activities at the DPHS office and return to the SEOC after the teams have departed for the EPZ. FEMA field team evaluators will meet up with the field teams in the EPZ. Drill/exercise cartridges will be prepared for transportation to the EOF (or the DPHS radiologicalchemistry laboratory)for analysis.

The monitoring teanm data will be reported to the Accident Assessment Team via the MTC.

The Monitoring Teams will do the equipment cheeks oit-of-sequence at the Radiological Health Lab at 29 Hazen Drive the day before the gradedexercise.:

IEVALUATION AREA 4: FIELD 1ASUREMENT AND ANALYSISI 119

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Sub-element 4.a - Plume Phase Field Measurements and Analyses Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations and radioiodine and particulate samples are collected. Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654/FEMA-REP-1, C.1; H.12: 1.8, 9; J.10.a)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to deploy FMTs with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate deposition on the ground from an airborne plume. In addition, NUREG-0654/FEMA-REP-1 indicates that OROs must have the capability to use FMTs within the plume exposure pathway EPZ to detect airborne radioiodine in the presence of noble gases and radioactive particulate material in the airborne plume. In an incident at an NPP, the possible release of radioactive material may pose a risk to the nearby population and environment. Although incident assessment methods are available to project the extent and magnitude of a release, these methods are subject to large uncertainties. During an incident, it is important to collect field radiological data to help characterize any radiological release..Adequate equipment and procedures are essential to such field measurement efforts.

ASSESSMENT/EXTENT OF PLAY Two or .more FMTs must demonstrate the capability to make and report measurements of ambient radiation to the field team coordinator, dose assessment team, or other appropriate authority. FMTs must also demonstrate the capability to obtain an air sample for measurement of airborne radioiodine and particulates, and to provide the appropriate authority with field.data pertaining to measurement. If samples have radioactivity significantly above background, the authority must consider the need for expedited laboratory analyses of these samples. OROs must share data in a timely manner with all other appropriate OROs. All methodology, including contamination control, instrumentation, preparation of samples, and a chain-of-custody form(s) for transfer to a laboratory(ies), will be in accordance with the ORO's plans/procedures. OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee), as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

A minimum of two field teams will each pick up a minimum of two complete samples each consisting of an ambient radiationmeasurement and an air sample. Charcoalfilter cartridges may simulate use of silver zeolite filter media. Simulated cartridges will be preparedfor transportationto the Lab for analysis.

Field data may be provided (OOS, if necessary) by Controllers to the Accident Assessment (Plume Tracking) Team to facilitate the accident assessmentprocess during the exercise.

NOTE: If during the exercise, a participantdemonstrates that portion of the evaluation element that demonstrates one complete sample unsatisfactorily,the FEMA Evaluatorwill inform the participant.

After an "on the spot" re-training by the State, the FEMA Evaluator will provide the participant anotheropportunity to re-demonstratethe activity that same day.

207 120

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yainkee Power Station EVALUATION AREA 5: EMERGENCY NOTIFICATION & PUBLICI INFORMATION Sub-element 5.a - Activation of the Prompt Alert and Notification System Criterion 5.a.1: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current REP guidance. (NUREG-0654/FEMA-REP-1, E.5, 6, 7)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide prompt instructions to the public within the plume exposure pathway EPZ.

Specific provisions addressed in this Sub-element are derived from the Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants, FEMA-REP-10 (November 1985).:..

ASSESSMENT/EXTENT OF PLAY Responsible OROs must demonstrate the capability to sequentially provide anm alert signal followed by an initial instructional message to populated areas (permanent resident and transient) throughout the 10-mile plume EPZ. Following the decision to activate the alert and notification system, OROs must complete system activation for primary alert/notification and disseminate the information/instructions in a timely manner. For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." If message dissemination is identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

Procedures to broadcast the message must be fully demonstrated as they would in an actual emergency up to the point of transmission. Broadcast of the message(s) or test message(s) is not required. The procedures must be demonstrated up to the point of actual activation. The alert signal activation should be simulated, not performed. Evaluations of EAS broadcast stations may also be accomplished through SAVs. The capability of the primary notification system to broadcast an instructional message on a 24-hour basis must be verified during an interview with appropriate personnel from the primary notification system, including verification of provisions for backup power or an alternate station.

The initial message must include at a minimum the following elements:

L1Identification of the ORO responsible and the official with authority for providing the alert signal and instructional message; D Identification of the commercial NPP and a statement that an emergency exists there; 0] Reference to REP-specific emergency information (e.g., brochures, calendars, and/or information in telephone books) for use by the general public during an emergency; and n A closing statement asking that the affected and potentially affected population stay tuned for additional information, or that the population tune to another station for additional information.

If route alerting is demonstrated as a primary method of alert and notification, it must be done in accordance with the ORO's plans/procedures and the Extent-of-Play Agreement. OROs must demonstrate the capability to accomplish the primary route alerting in a timely manner (not subject to specific time requirements). At least one route needs to be demonstrated and evaluated. The selected route(s) mus~tvary from exercise to exercise. However, the most difficult route(s) must be demonstrated f46'fss than once every 8 years. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used 121

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station is read for the evaluator, but not actually broadcast) as negotiated in the extent of play. Actual testing of the mobile public address system will be conducted at an agreed-upon location.

OROs may demonstrate any means of primary alert and notification included in their plans/procedures as negotiated in the Extent-of-Play Agreement. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

Actions to demonstrate performance of the notifications of tile public will be peifornmed up to the point of actual transnmission of the EAS message. In the initial notification the National Weather Set-vice will be contacted by Verniont Emergency Management and a "Test" message will be transmitted. The three states (VT, NH, & MA) will coordinate public notification.

The simulated activation of the sirensfor all three (3) States by the Commonwealth of Massachusetts will be demonstrated. All States will coordinate activities for the activation of the NOAA tone-alert radios throughout the EPZ. Activation of the NOAA tone-alert radios by the State of Vermont will be demonstrated using a test message.

The simulated activation of the Code Red notification system for all 3 States by SWNHFA4A in Keene, New Hampshirewill be demonstrated.

EVALUATION AREA 5:EMERGENCY NOTIFICATION & PUBLIC INFORMATION Sub-element 5.a - Activation of the Prompt Alert and Notification System 122

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Criterion 5.a.3: Backup alert and notification of the public is completed within a reasonable time following the detection by the ORO of a failure of the primary alert and notification system. (NUREG-0654/FEMA-REP-1, E.6, Appendix 3.B.2.c)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide prompt instructions to the public within the plume exposure pathway EPZ. Specific provisions addressed in this Sub-element are derived from the Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants, FEMA-REP-10 (November 1985).

ASSESSMENT/EXTENT OF PLAY If the exercise scenario calls for failure of any portion of the primary system(s) or if any portion of the primary system(s) actually fails to function during the exercise, OROs must demonstrate backup means of alert and notification. Backup means of alert and notification will differ from facility to facility.

Backup alert and notification procedures that would be implemented in multiple stages must be structured such that the population closest to the plant (e.g., within 2 miles) is alerted and notified first. The populations farther away and downwind of any potential radiological release would be covered sequentially (e.g., 2 to 5 miles, followed by downwind 5 to 10 miles, and finally the remaining population as directed by authorities). Topography, population density, existing ORO resources, and timing will be considered in judging the acceptability of backup means of alert and notification.

Although circumstances.may not allow this for all situations, FEMA and the NRC recommend that OROs and operators attempt to establish backup means that will reach those in the plume exposure EPZ within a reasonable time of failure of the primary alert and notification system, with a recommended goal of 45 minutes. The backup alert message must, at a minimum, include (1) a statement that an emergency exists at the plant and (2) instructions regarding where to obtain additional information. If backup route alerting is demonstrated, only one route needs to be selected and demonstrated. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast), as negotiated in the extent of play. Actual testing of the mobile public address system will be conducted at an agreed-upon location.

OROs may demonstrate any means of backup alert and notification included in their plans/procedures as negotiated in the Extent-of-Play Agreement. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

A request has currently been submitted to utilize Code Red as the back-up notification method for the EPZ. Route alerting,will not be demonstratedin New Hampshire.

IEVALUATION AREA 5:EMERGENCY NOTIFICATION & PUBLIC INFORMATION Sub-element 5.b - Subsequent Emergency Information and Instructions for the Public and the Media Criterion 5.b.1: OROs provide accurate subsequent emergency information and instructions to the public and the news media in a timely manner. (NUREG-06,*OPEMA-REP-1, E.5, 7; G.3.a, G.4.a, c) 123

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to disseminate appropriate emergency information and instructions, including any recommended protective actions, to the public. In addition, NUREG-0654/FEMA-REP-1 requires OROs to ensure that the capability exists for providing information to the media. This includes the availability of a physical location for use by the media during an emergency. NUREG-0654/FEMA-REP-1 also provides that a system must be available for dealing with rumors. This system will hereafter be known as the "public inquiry hotline."

ASSESSMENTIEXTENT OF PLAY The responsible ORO personnel/representatives must demonstrate actions to provide emergency information and instructions to the public and media in.a timely manner following the initial alert and notification (not subject to specific time requirements). For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." If message dissemination is identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

Message elements: The ORO must ensure that emergency information and instructions are consistent with PADs made by appropriate officials. The emergency information must contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, shelter-in-place instructions, information concerning protective actions for schools and persons with disabilities and access/functional needs, and public inquiry hotline telephone number) to assist the public in carrying out the PADs provided. The ORO must also be prepared to disclose and explain the ECL of the incident. At a minimum, this information must be included in media briefings and/or media releases. OROs must demonstrate the capability to use language that is clear and understandable to the public within both the plume and ingestion exposure pathway EPZs. This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas. The emergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5.a.1 and previously identified protective action areas that are still valid, as well as new areas. The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. In addition, the OROs must demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures. OROs must demonstrate the capability to develop emergency information in a non-English language when required by the plans/procedures. If ingestion pathway measures are exercised, OROs must demonstrate that a system exists for rapid dissemination of ingestion pathway information to pre-determined individuals and businesses in accordance with the ORO's plans/procedures.

Media information: OROs must demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the incident warrants. The OROs must demonstrate the capability to respond appropriately to inquiries from the news media. All information presented in media briefings and releases must be consistent with PADs and other emergency information provided to the public. Copies of pertinent emergency information (e.g., EAS messages and media releases) and media information kits must be available for dissemination to the media.

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

211 HAB considerations: The dissemination of information dealing with specific aspects of NPP security capabilities, actual or perceived adversarial (terrorist) force or threat, and tactical law enforcement response must be coordinated/communicated with appropriate security authorities, 124

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station e.g., law enforcement and NPP security agencies, in accordance with ORO plans/procedures.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

The primary responsibilityfor briefing the mnedia with respect to offsite activities in New Hampshire lies with the State. The SEOC and the Joint Information Center (JIQ are the facilities where this process takes place. The JIC is the facility that is jointly operated among the states, the utilihy and federal response agencies. Controllers at these facilities will simulate media inquiries. New Hampshire will coordinate media information with Vermont, Massachusettsand Vermont Yankee personnel at the JIC.

New Hampshire EPZ municipalities do not have representativesat the JIC. EPZ municipal officials muay respond to questions about local emergency response but are encouragedto refer press inquiries to tile 1IC.

A controller message will be generated for each conununithy to initiate a response and referral to media inquiries made to local officials.

A Public Inqluiry line is established at the State PSAP 911 to provide inembers of the public with a supplemental source of emergency information. A control cell will provide incoming calls. Calls to the public inquity center will occur when a Site Area Emergency and/or General Emergency emergency classification level (ECL) is reached during the course of the exercise. Public Inquiry personnel will provide callers with information and screen calls for trends.. Municipalities will refer calls that address issues beyond the local jurisdiction to the Public Inquiry Center. A controller message will be generated for each Municipal EOC to initiate a response and referral to the Public Inquinr Center.

During an Actual Emergency WKNE repeats New' Hampshire Emergency Public Information Messages every fifteen minutes until they are changed by the state. The repetition or broadcast of any exercise messages will be simulatedfor the purposes of this exercise.

NOTE: If during the exercise, a participantdemonstrates the portion of the evaluation element dealing with "timely manner"and emergency information being all-inclusive unsatisfactorily,the FEMA Evaluator will inform the participant.After an "on the spot" re-training by the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day. *Players should have the opportunity to re-demonstrate the criterion in subsequent messages.

11EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES Sub-element 6.a - Monitoring, Decontamination, and Registration of Evacuees Criterion 6.a.1: The reception center facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees. (NUREG-0654/FEMA-REP-1, A.3; C.4; J.10.h; J.12)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement radiologicglronitoring and decontamination of evacuees, while minimizing contamination of the facility. OROs must also have the capability to identify and register evacuees at reception centers.

125

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station ASSESSMENT/EXTENT OF PLAY Radiological monitoring, decontamination, and registration facilities for evacuees must be set.up and demonstrated as they would be in an actual emergency or as indicated in the Extent-of-Play Agreement. OROs conducting this demonstration must have one-third of the resources (e.g.,

monitoring teams/instrumentation/portal monitors) available at the facility(ies) as necessary to monitor 20 percent of the population within a 12-hour period. This would include adequate space for evacuees' vehicles. Availability of resources can be demonstrated with valid documentation (e.g., MOU/LOA, etc.) reflecting how necessary equipment would be procured for the location. Plans/procedures must indicate provisions for service animals.

Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. Staff responsible for the radiological monitoring of.

evacuees must demonstrate the capability to attain and sustain, within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a monitoring productivity rate per hour needed to monitor the 20 percent EPZ population planning base. The monitoring productivity rate per hour is the number of evacuees that can be monitored, per hour, by the total complement of monitors using an appropriate procedure. For demonstration of monitoring, decontamination, and registration capabilities, a minimum of six evacuees must be monitored per station using equipment and procedures specified in the plans/procedures. The monitoring sequences for the first six simulated evacuees per monitoring team will be timed by the evaluators to determine whether the 12-hour requirement can be met.

OROs must demonstrate the capability to register evacuees upon completion of the monitoring and decontamination activities. The activities for recording radiological monitoring and, if necessary, decontamination must include establishing a registration record consisting of the:

evacuee's name, address, results of monitoring, and time of decontamination (if any),. or as otherwise designated in the plan and/or procedures. Audio recorders, camcorders, or written records.are all acceptable means for registration.

Monitoring activities shall not be simulated. Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. They must also explain the procedures for referring any evacuees who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures. Contamination of the evacuee(s) will be determined by controller inject and not simulated with any low-level radiation source. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Decontamination of evacuees may be simulated and conducted by interview. Provisions for separate showering and same-sex decontamination must be demonstrated or explained. The staff must demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated evacuees, provide changes of clothing for those with contaminated clothing; and store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities. In addition, for any evacuee found to be contaminated, procedures must be discussed concerning handling of potential contamination of vehicles and personal belongings. Waste water from decontamination operations does not need to be collected.

Individuals who have completed monitoring (and decontamination, if needed) must have means (e.g., hand stamp, sticker, bracelet, form, etc) indicating that they, and their service animals and vehicles, where applicable, have been monitored, cleared, and found to have no contamination or contamination below the trigger/action level.

In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored. These 2ib&iiduals do not require confirmation that their vehicle is free from contamination prior to entering the congregate care areas. However, those individuals who are found to be contaminated and are then decontaminated will have their 126

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/lrIprovement Plan Vermont Yankee Power Station vehicles monitored and decontaminated (if applicable) and do require confirmation that their vehicle is free from contamination prior to entering the congregate care areas.

New Hampshire Extent of Play:

The Keene High School Reception Center will be set up as a reception, monitoring/decontamination facilihj with capabilities demonstrated out-of-sequence. The facility will exhibit appropriatespace and personnel for two (2) registrationstations, one (1) special registration area, two (2) messaging and one (1) exiting station. Monitoring/decontaminationactivities will be established and demonstrated for at least eight (8) evacuees and two (2) emergency workers. Adequate space will be identified for evacuee's vehicles. No vehicles will be activated.

NOTE: If during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the participant.After an "on the spot" re-trainingby the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

1EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES Sub-element 6.b - Monitoring and Decontamination of Emergency Workers and their Equipment and Vehicles Criterion 6.b.1: The facility/ORO has adequate procedures and resources to accomplish monitoring and decontamination of emergency workers and their equipment and vehicles. (NUREG-0654/FEMA-REP-1, K.5.a, b)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement radiological monitoring and decontamination of emergency workers and their equipment, inclusive of vehicles.

ASSESSMENT/EXTENT OF PLAY The monitoring staff must demonstrate the capability to monitor emergency worker personnel and their equipment and vehicles for contamination in accordance with the ORO's plans/procedures. Specific attention m2t~e given to equipment, including any vehicles that were in contact with contamination. The monitoring staff must demonstrate the capability to make decisions on the need for decontamination of personnel, equipment, and vehicles based on trigger/action levels and procedures stated in the ORO plans/procedures. Monitoring of 127

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station emergency workers does not have to meet the 12-hour requirement. However, appropriate monitoring procedures must be demonstrated for a minimum of two emergency workers and their equipment and vehicles. Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation.

The area to be used for monitoring and decontamination must be set up as it would be in an actual emergency, with all route markings, instrumentation, record keeping, and contamination control measures in place. Monitoring procedures must be demonstrated for a minimum of one vehicle. It is generally not necessary to monitor the entire surface of vehicles. However, the capability to monitor areas such as radiator grills, bumpers, wheel wells, tires, and door handles must be demonstrated. Interior surfaces of vehicles that were in contact with contaminated individuals must also be checked.

Decontamination of emergency workers may be simulated and conducted via interview.

Provisions for separate showering and same-sex decontamination must be demonstrated or explained. The staff must demonstrate provisions for limiting the spread of contamination.

Provisions could include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated individuals where applicable; provide changes of clothing for those with contaminated clothing; and store contaminated clothing and personal belongings to prevent further contamination of emergency workers or facilities.

OROs must demonstrate the capability to register emergency workers upon completion of the monitoring and decontamination activities. The activities for recording radiological monitoring and, if necessary, decontamination must include establishing a registration record consisting of the emergency worker's name, address, results of monitoring, and time of decontamination (if any), or as otherwise designated in the plan and/or procedures. Audio recorders, camcorders, or written records are all acceptable means for registration.

Monitoring activities shall not be simulated. Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. They must also explain the procedures for referring any emergency workers who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures. Contamination of the individual(s) will be determined by controller inject and not simulated with any low-level radiation source. Decontamination capabilities and provisions for vehicles and equipment that cannot be successfully decontaminated may be simulated and conducted by interview. Waste water from decontamination operations does not need to be collected.

All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

Monitoring and Decontamination Stations will be set up and demonstrated at the Keene High School Reception Center out-of-sequence. One (1) portal monitor will be demonstrated. A minimunm often (10) individuals (eight (8) representingevacuees and two (2) representingemergency workers) will go through primary monitoring with controller injects establishing the number of individuals presenting themselves as decontaminated and proceeding through secondany monitoring and decontamination. There will be a mininumn of one female and one male. During these activities monitoring and decontamination equipment, instrunmentation,record keeping and routing will be demonstratedappropriately. Monitoring procedures will be demonstrated on at least one (1) vehicle. Decontamination capabilitiesand provisions

• forvehicles and equipment that cannot be decontaminated may be sinmulated and conducted by interview by the Evaluator.

NOTE: If during the exercise, a participa4fl lemonstrates this sub-element unsatisfactorily, the FEMA Evaluatorwill inform the participant.After an "on the spot"re-trainingby the State, the FEMA Evaluator will provide the participant another opportunity to re-demonstrate the activity that same day.

128

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 1EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES!

Sub-element 6.c - Temporary Care of Evacuees Criterion 6.c.1: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines. Managers demonstrate the procedures to assure that evacuees have been monitored for contamination and have been decontaminated as appropriate prior to entering congregate care facilities. (NUREG-0654/FEMA-REP-1, J.10.h, J.12)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires OROs to have the capability to establish relocation centers in host/support jurisdictions. The American Red Cross normally provides congregate care in support of OROs under existing letters of agreement.

ASSESSMENT/EXTENT OF PLAY The evaluator must conduct a walk-through of the center to determine, through observation and inquiries, that the services and accommodations are consistent with applicable guidance. For planning purposes, OROs must plan for a sufficient number of congregate care centers in host/support jurisdictions to accommodate a minimum of 20 percent95F of the EPZ population. In this simulation, it is not necessary to set up operations as they would be in an actual emergency.

Alternatively, capabilities may be demonstrated by setting up stations for various services and providing those services to simulated evacuees. Given the substantial differences between demonstration and simulation of this criterion, exercise demonstration expectations must be clearly specified in Extent-of-Play Agreements. Congregate care staff must also demonstrate the capability to ensure that evacuees, seýýi' animals, and vehicles have been monitored for contamination, decontaminated as appropriate, and registered before entering the facility.

Individuals arriving at congregate care facilities must have means (e.g., hand stamp, sticker, bracelet, form, etc.) indicating that they, and their service animals and vehicles, where applicable, 129

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yafikee Power Station have been monitored, cleared, and found to have no contamination or contamination below the trigger/action level.

In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored. These individuals do not need confirmation that their vehicle is free from contamination prior to entering the congregate care areas.

However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles monitored and decontaminated (if applicable) and do need confirmation that their vehicle is free from contamination prior to entering the congregate care areas. This capability may be determined through an interview process. If operations at the center are demonstrated, material that would be difficult or expensive to transport (e.g., cots, blankets, sundries, and large-scale food supplies) need not be physically available at the facility(ies). However, availability of such items must be verified by providing the evaluator a list of sources with locations and estimates of quantities.All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

Congregate-carecenters will not be activated. Currentshelter surv'ey, if they exist, can be provided to FEMA for review. Based on FEA'L4's survey review, a tour of selected (some, all, or none) congregate-carefacilities that support the Keene reception centers will be conducted with a controller and an ESF 6 or American Red Cross representative independently and out ofsequence..

1EVALUATION AREA 6: SUPPORT OPERATION/FACILITIES1 Sub-element 6.d - Transportation and Treatment of Contaminated Injured Individuals Criterion 6.d.1: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals. (NUREG-0654/FEMA-REP-1, F.2, H.10., K.5.a.b., L.1., 4.)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to transport contaminated injured individuals to medical facilities with the capability to provide medical services.

ASSESSMENT/EXTENT OF PLAY Monitoring, decontamination, and contamination control efforts must not delay urgent medical care for the victim.

OROs must demonstrate the capability to transport contaminated injured individuals to medical facilities. An ambulance must be used for response to the victim. However, to avoid taking an ambulance out of service for an extended time, OROs may use any vehicle (e.g., car, truck, or van) to transport the victim to the medical facility. Normal communications between the ambulance/dispatcher and the receiving medical facility must be demonstrated. If a substitute vehicle is used for transport to the medical facility, this communication must occur before releasing the ambulance from the drill. This communication would include reporting radiation monitoring results, if available. In addition, the ambulance crew must demonstrate, by interview, knowledge of where the ambulance and crew would be monitored and decontaminated, if required, or whom to contact for such information.

217 Monitoring of the victim may be performed before transport or en route, or may be deferred to the medical facility. Before using monitoring instruments, the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. All monitoring activities must be 130

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/improvement Plan Vermont Yankee Power Station completed as they would be in an actual emergency. Appropriate contamination control measures must be demonstrated before and during transport and at the receiving medical facility. The medical facility must demonstrate the capability to activate and set up a radiological emergency area for treatment. Equipment and supplies must be available for treatment of contaminated injured individuals.

The medical facility must demonstrate the capability to make decisions on the need for decontamination of the individual, follow appropriate decontamination procedures, and maintain records of all survey measurements and samples taken. All procedures for collection and analysis of samples and decontamination of the individual must be demonstrated or described to the evaluator. Waste water from decontamination operations must be handled according to facility plans/procedures. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

New Hampshire Extent of Play:

This EvaluationArea will be demonstratedout ofsequence at Cheshire Medical Center in Keene as an MIS-1 Facility. Demonstrating ambulanceser'ices will be those normalli,associatedwith the hospital.

This was successful/y demonstratedin Sept. 2012.

Attachment A - Non-Participating Facilities Daycare Centers The Little Imaginative Learners Daycare - Hinsdale Elizabeth Murdough Child Care - Hinsdale Happy Times Day Care - Hinsdale Julie's Day Care - Hinsdale Lil Chick Day Care - Richmond Winchester Learning Center - Winchester DD's Totley Crew - Winchester Long-Term Care Facilities Host (Dependent Upon FEMA)

Langdon Place of Keene - Keene Crestwood Care & Rehabilitation - Milford The Elms Care & Rehabilitation Center - Milford Risk Applewood Care & Rehabilitation - Winchester Schools (all evaluated in 2009)

Chesterfield School - Chesterfield Hinsdale Elementary School - Hinsdale Hinsdale High School - Hinsdale Winchester Elementary School - Winchester Shelters See attached. list.. 218 131

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 219 132

Unclassified Radiological Emergency Preparedness Program (PEP)

After Action Report/Improvement Plan Vermont Yankee Power Station State ,of New Hampshire.*Vermont Yankee. .

Type Role Facility Name TOWN Due Next 2007 2009 2011 Camp Spofford (Faith Based)

CG/CSC Risk campspofford.org Chesterfield CG/CSC Risk Camp Takodah (YMCA/NH) camptakodah.org Richmond CG/CSC Risk Camp Wiyaka (YMCA/Ma) Richmond Daycare Risk Village Children's Center. Chesterfield Done Daycare Risk The Little Imaginative Learners Daycare Hinsdale Daycare Risk Elizabeth Murdough Child Care Hinsdale Daycare Risk Happy Times Day Care Hinsdale Daycare Risk Julie's Day Care Hinsdale 5-May Daycare Risk Nanny's Day Care Hinsdale Done Pooh's Corner Preschool (Closed for Daycare Risk Summer)(open Sept to May) Hinsdale Daycare Risk Lil Chick Day Care Richmond Daycare.. Risk Ashuelot Head Start (Open Sept. to May Only) Winchester Done Daycar'e Risk Winchester Learning Center Winchester 5-May Daycare. Risk DD's Totley Crew Winchester Cheshire Medical Center/Dartmouth-Hitchcock 26-MS I Keene Keene 5-Dec Oct Oý Langdon Place of Keene Retirement &

NursH Host Rehabilitation Center Keene NursH Host Westwood Care & Rehabilitation Center Keene NursH Host Crestwood Care & Rehabilitation Center Milford NursH Host The Elms Care & Rehabilitation Center Milford NursH Host Pheasantwood Care & Rehabilitation Center: Peterborough NursH Risk Applewood Care & Rehabilitation Winchester 5-May 21-PubS Risk Chesterfield School Chesterfield May 21-PubS Risk Hinsdale Elementary School Hinsdale May 21-PubS Risk Hinsdale High School Hinsdale May 21-PubS Risk Winchester Elementary School Winchester May PubS Risk Inumaculate Heart of Mary School Richmond Recp Ctr Keene High School Drill / Tour Keene. 24-Apr Recp Ctr Keene High School Graded Exercise Keene 2-Jul 21-STSA First Student, Inc. Swanzey May Yellow Highlighting indicates facilities to be evaluated.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee PowerStation American Red Cross Congregate Care Facilities I Post Evacuation Impact Physi.

Shelter Name Capacity Capacity Physical Street Address 1 Town State Allenstown Elementary 180 90 30 South Main St. Allenstown NH Andover Elementary School 300 150 20 School Street Andover NH Boscawen Town Hall 51 25 14 High St. Boscawen NH 32 WHITE ROCK HILL Bow High School 1050 525 RD. Bow NH Bradford Area Community Center 200 100 64 East Main St Bradford NH Canterbury Elementary School 240 120 15 Baptist Road Canterbury NH Canterbury Fire Department 0 15 26 Baptist Road Canterbury NH Chichester Fire and Rescue 61 30 22 Main Street Chichester NH Concord High School 535 267 170 Warren Street Concord NH Green Street Community Center 315 157 37 Green Street Concord NH Dublin High School 431 215 18 Lehmann Way Dublin NH Dunbarton Elementary 100 50 18 Robert Rogers Road Dunbarton NH Epsom Central School 157 78 282 Blackhall Road Epsom NH Fitzwilliam VFW 142 71 Route 12 N Fitzwilliam NH Franklin High School 233 116 115 Central Street Franklin NH Franklin Middle School 22-P2 146 200 Sanbum Street Franklin NH Gilsum Fire Department 22 11 5 church St Gilsum NH Gilsum Elementary School 159 79 640 Route 10 Gilsum NH 134

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Goshen Town Offices 54 27 54 Mill Village Rd Goshen NH Grantharn Town Hall 175 87 300 Route 10 South Grantham NH Grantham Village School 55 27 75 Learning Drive Grantham NH Wells Memorial Elementary School 47 0 705 Chesham Rd Harrisville NH Hooksett Underhill School* 242 121 2 SHERWOOD DR Hooksett NH Hooksett Municipal Building 450 225 35 MAIN ST Hooksett NH Hooksett Memorial School 665 332 5 Memorial Drive Hooksett NH David Cawley Middle School 687 343 89 WHITEHALL RD Hooksett NH Hopkinton High School 420 210 297 Park Ave. Hopkinton NH Jaffrey-Rindge Middle School 330 0 1 Conant Way Jaffrey NH Jaffrey Bible Center 260 130 133 Turnpike Road Jaffrey NH Monadnock Bible Conference 272 0 257 Dublin Road Jaffrey NH Keene Recreation Center 656 328 312 Washington St Keene NH Loudon Fire Station 2 74 0 56 Clough Hill Rd Loudon NH Loudon Safety Building 250 0 8 Cooper St Loudon NH Nelson Elementary School 28 14 441 Granite Lake Road Nelson NH Nelson Fire Department 8 4 55 Old Stoddard Road Nelson NH Kearsarge School District 96 48 64 Cougar Court New London NH Kearsarge Regional Middle School 150 75 32 Gile Pond Rd North Sutton NH Pittsfield Elementary School 154 77 34 Bow Street Pittsfield. NH Rindge Recreation Department 75 37 283 Wellington Road Rindge .... NH ROXBURY TOWN HALL 78 0 3 Middleton Rd Roxbury. NH Salisbury Elementary School 126 63 6 Whittemore Road Salisbury NH James Faulkner 148 74 200 School St Stoddard NH Sullivan Congregational Church 62 31 1 Church St. Sullivan NH Cutler Elementary School 80 40 31 S Winchester St Swanzey NH Monadnock Middle and High School 270 135 600 Old Homestead HWY Swanzey NH Troy Elementary School 347 173 44 School St Troy NH Walpole Fire Station 60 30 278 Main St. Walpole NH Camp Morgan 98 49 339 Millen Pond Road Washington NH Westmoreland School 265 132 40 Glebe Rd. Westmoreland NH Winchester Community Center (ELMM) 100 50 21 Durkee Street Winchester NH Thomas Hall 105 52 25 S Main Street NH TOTALS 11,355 5,159 ]

2010 Number to be sheltered = 20% *21,200 4,240 Yellow highlighting indicates facility willing to be evaluated per ARC. Other facilities have NOT been evaluated and may be required to be also.

222 135

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station 223 136

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station ENTERGY NUCLEAR VERMONT YANKEE Rev. 0 EMERGENCY PREPAREDNESS EXERCISE Page 5.2-1 June 5, 2013 5.2 EXERCISE SEQUENCE OF EVENTS The exercise begins at 08:00 with the simulator running at 100% power. The Control Room crew and Engineering have been monitoring a slowly rising trend in the Drywell leak rate. HPCI is tagged out and in the middle of a planned two day maintenance evolution.

Just after 08:00, a CBI employee using a portable torch kit to do some fabrication work inside the Containment Access Building inadvertently causes a flashback to the acetylene cylinder. Everyone evacuates the building, and an explosion occurs at 08:05. No injuries or fires result from the explosion. However, there is damage to the south roll-up door. Drywell leakage continues to slowly increase. The simulator Control Room crew should declare an UNUSUAL EVENT by 08:20 based on AP 3125 EAL HU2.2, "Explosion within the Protected Area resulting in visible damage to permanent structure or equipment". The Emergency Response Organization Notification System (ERONS) will contact the on-duty team. Security personnel activate the pagers using Attachment 9.7 of OP 3547, "Security Actions during an Emergency". The simulator Control Room crew should notify the Commonwealth of Massachusetts, State of New Hampshire, and State of Vermont in accordance with OP 3540, "Control Room Actions during an Emergency", within 15 minutes of declaration. The Unusual Event classification and state notification each provide an NRC performance indicator opportunity.

Unusual Event Command Cards Card Clock Time Description SCR-01 Before Start Use of Gaitronics and initial plant conditions SCR-02 Before Start Initial resources and who is involved in exercise SCR-03 Before Start NRC contact, met data, and communications SEC-01 Before Start Security actions MCR-01 Before Start Use of Gaitronics and Ring Down Circuits MCR-02 08:00 EXERCISE START Control Room announcement SEC-02 08:05 Acetylene tank explosion SCR-04 08:07 CAB damage and no injuries or fire SCR-05 08:20 Declare UE HU2.2 SCR-06 08:21 Notify Security of event SCR-07 08:22 Activate ERON SCR-08 08:25 Activate Alternate ERON if necessary MCR-03 08:26 Control Roo24'innouncement for UE SCR-09 08:35 Notify states of UE HU2.2

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plat ... Vermont Yankee PowerStation Rev. 0 Page 5.2-2 With Drywell pressure increasing, the simulator Control Room crew should insert a manual SCRAM prior to exceeding 2.5 psig at approximately 08:50. The reactor will SCRAM automatically if they do not. All control rods successfully insert, but the Start-Up Transformers fail to transfer resulting in a loss of normal power. Both Emergency Diesel Generators start and accept loads. The simulator Control Room crew should enter EOP-1, "RPV Control", and EOP-3, "Primary Containment Control", in response to plant conditions and begin reactor cool down.

The simulator Control Room crew should declare an ALERT by 09:05 based on AP 3125, "Emergency Plan Classification and Action Level Scheme", Emergency Action Level (EAL) FAI.1, "Any loss or any potential loss of Fuel Clad or RCS (Table F-1)". "Primary Containment pressure greater than 2.5 psig due to Reactor Coolant System leakage" (RCS Loss B.2.) is the affected barrier. They should then notify the Commonwealth of Massachusetts, State of New Hampshire, and State of Vermont in accordance with OP 3540, "Control Room Actions During an Emergency", within 15 minutes of declaration. The Alert classification and state notification each provide an NRC performance indicator opportunity.

Alert Command Cards Card Clock Time Description SCR-10 08:50 Simulator indications if necessary SCR-1 1 After 08:50 "B"Recirculation discharge valve will not close SCR-12 09:05 Declare ALERT FAI.1 SCR-1 3 09:06 Notify Security of event SCR-14 09:07 Activate ERON SCR-15 09:10 Activate Alternate ERON if necessary MCR-04 09:11 Control Room announcement for ALERT SCR-16 09:20 Notify states of ALERT FA1.1 A fire begins on Reactor Building 252' at approximately 09:20. Smoke is reported in that area around 09:25. The Fire Brigade musters, assesses the situation, and takes action to extinguish any fire that is present. The Fire Brigade Leader will inform the simulator Control Room that the source of the smoke appears to be a cable tray on the northwest side of 252'. He also states that it will take time to investigate the extent of the fire. The sprinkler system is not successful in controlling the blaze, so it spreads to other cable trays before the Fire Brigade can begin mitigation. At 09:40, alarms associated with various safety related systems begin annunciating in the simulator Control Room. Bus 4 fails at 10:00 resulting in a loss of Core Spray and RHR equipment. The Fire Brigade Leader will contact the simulator Control Room at 10:05 to report that the fire is out, but there is visible damage to numerous cables in severhaays. Failure of the safety relief valves prevents the simulator Control Room crew from depressurizing the reactor vessel.

Water level drops below the top of active fuel around 10:20 despite all efforts.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Reportf/lmprovement Plan Vermont Yankee Pov'er Station Rev. 0 Page 5.2-3 The Emergency Operations Facility (EOF) should declare a SITE AREA EMERGENCY by 10:35 based on AP 3125, "Emergency Plan Classification and Action Level Scheme", Emergency Action Level (EAL) FSI.1, "Loss or potential loss of any two barriers (Table F-I)". The potential affected barriers are "Reactor Pressure Vessel level cannot be restored and maintained greater than top of active fuel or cannot be determined" (Fuel Clad Potential Loss A.l. and RCS Loss A.1 .),

"Primary Containment pressure greater than 2.5 psig due to Reactor Coolant System leakage" (RCS Loss B.2.), and "Drywell High Radiation Monitor RM-1 6 1A/B greater than 10 R/hr" (RCS Loss C.4.). They should then notify the Commonwealth of Massachusetts, State of New Hampshire, and State of Vermont in accordance with OP 3540, "Control Room Actions During an Emergency", within 15 minutes of declaration. The Site Area Emergency classification and state notification each provide an NRC performance indicator opportunity.

Site Area Emeraencv Command Cards Card Clock Time Description SCR-17 09:25 Smoke on Reactor Building 252' north MCR-05 09:26 Control Room announcement for FIRE SCR-18 09:35 Fire Brigade Leader initial report on the fire SEC-03 Before 09:35 Perform accountability SCR-19 After 09:40 SRVs will not open electronically ALL-01 10:00 Some AC power is lost in the OSC and TSC SCR-20 10:05 Fire is out, but cables are damaged MCR-06 10:06 Control Room announcement for end of FIRE SEC-04 Before 10:07 Simulate evacuation and accountability MCR-07 Before 10:07 CR area radiation readings for the entire exercise ALL-02 Before 10:07 IT verification of ERFIS data points OSC-01 Before 10:07 OSC area radiation readings for the entire exercise TSC-01 Before 10:07 TSC activation, communications, and ERDS TSC-02 Before 10:07 TSC area radiation readings for the entire exercise EOF-01 Before 10:07 Obtaining weather information via NWS SCR-21 10:20 RPV water level is below TAF EOF-02 10:35 Declare SAE FSI.1 MCR-08 10:36 Control Room announcement for SAE EOF-03 10:50 Notify states*f SAE FS1.1

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Rev. 0 Page 5.2-4 Primary containment hydrogen and radiation levels begin to increase at about 10:40.

Standby Gas Treatment System Valve 16-19-7A drifts open at 11:40, and a weld fails downstream releasing radioactive steam onto Reactor Building 303' elevation.

Stack radiation monitors begin to increase at 11:50 indicating a release is in progress.

The Emergency Operations Facility (EOF) should declare a GENERAL EMERGENCY by 11:55 based on AP 3125, "Emergency Plan Classification and Action Level Scheme", Emergency Action Level (EAL) FG1.1, "Loss of any two barriers AND loss or potential loss of third barrier (Table F-I)". The potential affected barriers are "Reactor Pressure Vessel level cannot be restored and maintained greater than top of active fuel or cannot be determined" (Fuel Clad Potential Loss A.1. and RCS Loss A.1.), "Drywell High Radiation Monitor RM-1 6 1A/B greater than 1,500 R/hr" (Fuel Clad Loss C.4.), "RPV water level cannot be restored and maintained greater than -19 inches (MSCRWL)" (Fuel Clad Loss A.1 .),

"Primary Containment pressure greater than 2.5 psig due to Reactor Coolant System leakage" (RCS Loss B.2.), "Drywell High Radiation Monitor RM-16-19-1A/B greater than 10 R/hr" (RCS Loss C.4.), "SAG entry required" (Primary Containment Potential Loss A.1 .), "Primary Containment pressure rise followed by a rapid unexplained drop in Primary Containment pressure" (Primary Containment Loss B.),1 and "Unisolable primary system discharge outside Primary Containment resulting in Secondary Containment area radiation or temperature above any Maximum Safe Operating Limit in Table 0 of EOP-4" (Primary Containment Loss C.5.). A Protective Action Recommendation (PAR) should also be issued to evacuate the towns of Brattleboro, Guilford, Vernon, and Hinsdale. The Emergency Operations Facility (EOF) should then notify the Commonwealth of Massachusetts, State of New Hampshire, and State of Vermont in accordance with OP 3540, "Control Room Actions During an Emergency", within 15 minutes of declaration.

The General Emergency classification, PAR, and state notification each provide an NRC performance indicator opportunity.

General Emergency Command Cards Card Clock Time Description JIC-01 11:30 Alternate JIC activation will be simulated SCR-22 11:40 Rapid drop in Primary Containment pressure OSC-02 After 11:40 Personnel are not contaminated OSC-03 After 11:40 No fire present EOF-04 11:55 Declare GE FGI.1 MCR-09 11:56 Control RocM-'nnouncement for GE SCR-23 12:00 Stack radiation readings EOF-05 12:10 Issue GE PAR based on plant conditions 111) - 11r% kl^+if%, ý+ý#- ^f 1ý-C CfI4 ol -4 DAO

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Vermont Yankee Power Station Rev. 0 Page 5.2-5 The Standby Gas Treatment System is slightly degraded by steam intrusion allowing a larger than predicted amount of radioactive material to be released to the environment. The Site Boundary team will detect dose rates of 285 mR/hr in Sector Q at approximately 12:15. Off-site teams further downwind will confirm the release.

A Repair and Corrective Action Team should be dispatched to open RHR 27A and/or 27B to restore cooling water flow to the reactor. RHR 27A is seized in the closed position, but the team will be successful in opening RHR 27B be replacing the control power fuse at approximately 13:15. Another Corrective Action Repair Team should be dispatched to close SGTS Valve 16-19-7A stopping the radiological release. The valve closes at 13:45.

The exercise is terminated when exercise objectives have been verified as met by Lead Facility Drill Controllers and authorized by the E-Plan Manager. All Emergency Response Facilities will restore their facilities to a ready condition and initiate critiques.

All Emergency Response Facilities are expected to use the fleet standardized critique process per the requirements of EN-EP-308, "Emergency Planning Critiques".

Termination Command Cards Card Clock Time- Description OSC-04 13:15 RHR 27B is open OSC-05 13:45 SGTS Valve 16-19-7A is closed MCR-10 14:00 Plant / PSB Exercise Termination announcement EOF-07 14:00 EOF / JIC Exercise Termination announcement 228

Unclassified Radiological Emergency Preparedness Program (REP)

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