ML16210A375

After Action Report / Improvement Plan for Radiological Emergency Preparedness Plume Exercise Held on 04/27/2016

ML16210A375
Person / Time
Site:	Peach Bottom
Issue date:	07/26/2016
From:	Tierney M US Dept of Homeland Security, Federal Emergency Management Agency
To:	Document Control Desk, Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response
References
Download: ML16210A375 (165)

Text

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Nuclear Regulatory Commission Headquarters Office of Nuclear Security and Incident Response Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 To Whom It May Concern:

U.S. Dcpa11ment of Homeland Security One Independence Mall, Sixth Floor 615 Chestnut Street Philadelphia, PA 19106-4404 FEMA Enclosed is the final After Action Report/Improvement Plan for the Peach Bottom Atomic Power Station Radiological Emergency Preparedness Plume Exercise held on April 27, 2016. This report also includes the Medical Services Drills for Union Hospital and Upper Chesapeake Hospital evaluated on March 24, 2016 and March 31, 2016 and Out of Sequence demonstrations also evaluated in March.

There were no Level 1 Findings or Planning Issues identified during the exercise. There was one Level 2 Finding identified that was successfully re-demonstrated during the exercise.

Based on the results of the exercise and a review of the off site radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards ofNUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CFR.350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise.

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

Enclosure Sincerely, Mary Ann Tierney Regional Administrator

Peach Bottom Atomic Power Station After Action Report/

Improvement Plan Exercise Date -April 27, 2016 Radiological Emergency Preparedness (REP) Program Published July 15, 2016

Unclassified Radiological Emergency Preparedness Program (REP)

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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

..................................................................... 13 2.1 Exercise Purpose and Design............................................................................................ 13 2.2 Exercise Objectives, Capabilities and Activities............................................................. 17 2.3 Scenario Summary............................................................................................................. 17 SECTION 3: ANALYSIS OF CAP ABILITIES....................................................................... 18 3.1 Exercise Evaluation and Results...................................................................................... 18 3.2 Summary Results of Exercise Evaluation........................................................................ 18 3.3 Criteria Evaluation Summaries......................................................................................... 32 3.3.1 State Jurisdictions......................................................................................................... 32 3.3.2 Risk Jurisdictions.......................................................................................................... 35 3.3.3 Private Jurisdictions...................................................................................................... 49 SECTION 4: CONCLUSION..................................................................................................... 52 APPENDIX A: EXERCISE TIMELINE.................................................................................. 53 APPENDIX B: EXERCISE EVALUATORS AND TEAM LEADERS................................. 55 APPENDIX C: ACRONYMS AND ABBREVIATIONS........................................................ 61 APPENDIX D: EXTENT OF PLAY......................................................................................... 65 3

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station EXECUTIVE

SUMMARY

On April 27, 2016, a full-scale Plume Exposure Pathway exercise was demonstrated and evaluated for the 10 Mile Emergency Planning Zone (EPZ) around the Peach Bottom Atomic Power Station (PBAPS) by the Federal Emergency Management Agency (FEMA), Region III. The previous full-scale exercise at this site was evaluated on April 7, 2014.

e Out-of-Sequence demonstrations were conducted on March 2, 7-9, 24, 29, 30, and 31, 2016. The purpose of the Exercise and Out-of-Sequence demonstrations was to assess the capabilities of State, counties, and local jurisdictions to implement Radiological Emergency Plans and Procedures (RERP) to protect the property and lives of residents and transients in the event of an emergency at PBAPS. The findings in this report are based on the evaluations of the Federal evaluation team, with final determinations made by the FEMA, Region III Regional Assistance Committee (RAC)

Chairperson, and approved by FEMA Headquarters. These reports are provided to the Nuclear Regulatory Commission (NRC) and participating states. State and local governments utilize the findings contained in these reports for the purposes of planning, training, and improving emergency preparedness.

The evaluation of this Exercise determined that there were no Level 1 Findings, one Level 2 Finding that was successfully re-demonstrated, and no Plan Issues. All prior Performance and Planning Issues were resolved during the previous exercise. A Level 1 Finding is defined by the FEMA Radiological Emergency Preparedness Program Manual as follows: An observed or identified inadequacy of organizational performance in an exercise that could cause a determination that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in the event of a radiological emergency to protect the health and safety of the public living in the vicinity of a Nuclear Power Plant (NPP). A Level 2 Finding is defined as: An observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety. Finally, a e

Planning Issue is: An observed or identified inadequacy in the ORO's emergency plap/implementing procedures, rather than that of the ORO's performance.

FEMA wishes to acknowledge the efforts of many individuals in the Commonwealth of Pennsylvania and the risk jurisdictions; Chester, Lancaster, and York Counties. FEMA also wishes to acknowledge the State of Maryland and the risk jurisdictions of Harford and Cecil Counties.

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

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name Peach Bottom Atomic Power Station Plume Type of Exercise Radiological Emergency Exercise Date April 27, 2016 Program Department of Homeland Security/FEMA Radiological Emergency Preparedness Program Scenario Type Plume Exposure Pathway 1.2 Exercise Planning Team Leadership Federal POC(s):

Michael E. Shuler, Sr., Project Officer & Site Specialist NP/REPP, Region III U.S. Department of Homeland Security Federal Emergency Management Agency 615 Chestnut Street One Independence Mall Philadelphia, Pennsylvania 19106-4404 215-931-5526 michael. shuler@dhs.gov Thomas Scardino Radiological Assistance Committee, Chair DRS/Federal Emergency Management Agency One Independence Mall 615 Chestnut Street Philadelphia, Pennsylvania, 19106 215-931-5546 thomas.scardino@fema.dhs.gov 6

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan State POC(s):

Laurin Fleming, Lead Controller/Site Specialist Emergency Management Specialist Bureau of Strategic Operational Planning Pennsylvania Emergency Management Agency 1310 Elmerton A venue Harrisburg, Pennsylvania 1711 0 717-65 1-2119 laufleming@pa.gov Reed Correll, REP Planner Maryland Emergency Management Agency 5401 Rue Saint Lo Drive Reisterstown, MD 2113 6 443-379-3065 reed.correll@maryland.gov Tony Przychodzien Peach Bottom Atomic Power Station Chester County Office of Emergency Management 601 Westtown Road, Suite 102 Box 2747 West Chester, PA 19380-0990 tprzychodzien@chesco.org Randall Gockley Lancaster County Emergency Management Agency Coordinator PO Box 219 Manheim, Pennsylvania, 17545 800-808-5236 rgockley@lancema.us Jim Welty York County Office of Emergency Management Deputy Director 120 Davies Road York, Pennsylvania, 17402 717-840-2916 jwwelty@ycdes.org 7

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Shen Kreiser Exercise Planning Team York County Office of Emergency Management Nuclear Planner/Trainer 120 Davies Drive York, Pennsylvania, 17402 717-840-2981 shkreiser@ycdes.og Richard Brooks Cecil County Emergency Director Emergency Director 107 Chesapeake BL VD Suite# 108 Elkton, MD 21921 (410) 996-5350 richard.brooks@ccdps.org Richard Ayers Harford County Emergency Management Services Director, Emergency Services 2220 Ady Road Forest Hill, Maryland, 21050 410-638-3047 raayers@harfordpublicsafety.org Jerry Beaver Exelon Nuclear Senior Offsite Emergency Preparedness Specialist P.O. Box 480 Middletown, Pennsylvania, 17057 717-948-8700 Jerry.Beaver@exeloncorp.com Glenn Fehring Exelon Nuclear Senior Emergency Preparedness Specialist PO Box 388 Forked River, New Jersey, 08087 732-240-8174 glenn.fehring@exeloncorp.com 8

Peach Bottom Atomic Power Station

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the Peach Bottom Atomic Power Station exercise:

State Jurisdictions State of Maryland Maryland Army National Guard Maryland Association of Soil Conservation Districts Maryland Department of Agriculture Maryland Department of Environment Maryland Department of General Services Maryland Department of Health and Mental Hygiene Maryland Department of Human Resources Maryland Department of Information Technologies Maryland Department of Transportation Maryland Emergency Management Agency Maryland Institute for Emergency Services Systems Maryland Joint Operations Center Maryland Natural Resources Police Maryland Public Service Commission Maryland Social Services Maryland State Highway Administration Maryland State Police Maryland Technology Assistance Program Cecil County Airville Volunteer Fire Company Baltimore County Government Bel Air Police Department Cecil County Department of Emergency Services Cecil County Department of Social Services Cecil County Emergency Management Cecil County Health Department Cecil County Public Schools Cecil County Sheriffs Office Cecil County Soil Conservation District Harford County Baltimore County Baltimore Gas and Electric Bel Air Police Department 9

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Harford County Administrator Harford County Communications Harford County Community College Harford County Community Services Harford County Department Public Works, Roads Harford County Department Public Works, Water & Sewer Harford County Emergency Services Harford County Health Department Harford County Human Resources Harford County Local Emergency Planning Committee Harford County Mental Health Harford County Parks and Recreation Harford County Public Schools Transportation Harford County Sheriffs Office Havre De Grace Police Department Commonwealth of Pennsylvania Pennsylvania Department of Administration Pennsylvania Department of Aging Pennsylvania Department of Agriculture Pennsylvania Department of Conservation and Natural Resources Pennsylvania Department of Corrections Pennsylvania Department of Education Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection Pennsylvania Department of Fish and Boat Pennsylvania Department of General Services Administration Pennsylvania Department of Health Pennsylvania Department of Infrastructure Pennsylvania Department of Military and Veteran's Affairs Pennsylvania Department of Public Welfare Pennsylvania Department of Transportation Pennsylvania Emergency Management Agency Pennsylvania Game Commission Pennsylvania Liquor Control Board Pennsylvania Public Utility Commission Pennsylvania State Police Pennsylvania Turnpike Commission Chester County Chester County Department of Emergency Services Chester County Department of Emergency Services, 911 Center Chester County Department of Emergency Services, Facilities Department 10

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Chester County Department of Emergency Services, Technical Division Chester County FIRST/Private Sector Chester County Health Department Chester County Sheriffs Office Oxford Area School District Oxford Area High School Chester County Amateur Radio Emergency Services Union Fire Company #1 West Nottingham Township Emergency Operations Center West Nottingham Township Police Department Lancaster County York County Lancaster County Board of Commissioners Lancaster County Chief Clerk Lancaster County Commissioners Lancaster County Geographical Information System Lancaster County Public Safety Training Center Lancaster County Sheriff Lancaster County-Wide Communications Lancaster County South Central Task Force Penn Manor School District Marticville Middle School Solanco Area School District Solanco High School Clermont Elementary School Providence Elementary School Rawlinsville Fire Department York Adams Disaster, Crisis, Outreach and Referral Team York Adams Transportation Authority York City Bureau of Health York County 911 York County Commissioners York County Department of Emergency Services York County HazMat Team York County Office of Emergency Management York County Parks and Recreation York County Penn State Extension York County Sheriffs Office York Skywarn Quarryville Borough Emergency Management Agency Quarryville Fire Department 11

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Quarryville Law Enforcement Private Organizations American Red Cross Blue Ridge News Delmarva Power Exelon Nuclear Knowledge Center, Inc.

Penn State Cooperative Extension Peach Bottom Atomic Power Station Radio Amateur Communications Emergency Services Wellspan York Hospital WXCYRadio Union Hospital Darlington Volunteer Fire Company Upper Chesapeake Memorial Hospital Rising Sun Emergency Medical Services AMTRAK Baltimore Gas and Electric The Aegis Federal Organizations United States Coast Guard United States Department of Agriculture 12

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise Purpose and Design On December 7, 1979, the President directed the Federal Emergency Management Agency (FEMA) to assume the lead responsibility for all off-site nuclear planning and response.

FEMA's activities were conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351 and 352. These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that were established following the Three Mile Island Nuclear Station accident in March 1979.

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

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

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

c.

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

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

- U.S. Department of Commerce,

- U.S. Nuclear Regulatory Commission,

- U.S. Environmental Protection Agency,

- U.S. Departmerlt of Energy,

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

- U.S. Department of Transportation, 13

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After Action Report/Improvement Plan Peach Bottom Atomic Power Station

- U.S. Department of Agriculture,

- U.S. Department of the Interior, and

- U.S. Food and Drug Administration.

Representatives of these agencies serve on the Region III Radiological Assistance Committee (RAC), which is chaired by FEMA. A REP Plume Exposure Pathway Exercise was evaluated April 27, 2016, and Medical Services drills were conducted March 24, 2016

& March 31, 2016 to assess the capabilities of State and local emergency preparedness organizations in implementing their RERPs and procedures to protect the public health and safety during a radiological emergency involving Peach Bottom Atomic Power Station. The purpose of this exercise report is to present the results and findings on the performance of the off-site response organizations (OROs) during a simulated radiological emergency.

The findings presented in this report are based on the evaluations of the Federal evaluator team, with final determinations made by the FEMA Region III Radiological Assistance Committee (RAC) Chairperson and approved by FEMA Headquarters. These reports are provided to the NRC and participating States. State and local governments utilize the findings contained in these reports for the purposes of planning, training, and improving emergency response capabilities.

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

A.

NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, November 1980; B.

Radiological Emergency Preparedness Program Manual, January 2016 Section 1 of this report, entitled ""Exercise Overview"", presents the Exercise Planning Team and the Participating Organizations.

Section 2 ofthis report entitled "Exercise Design Summary", and includes the Purpose and Design, Exercise Objectives, Capabilities, and Activities, and the Scenario Summary.

Section 3 of this report, entitled "Analysis of Capabilities", presents detailed Drill Evaluation and Results information on the demonstration for each jurisdiction or functional entity evaluated in a jurisdiction-based, issue-only format (Criteria Evaluation Summaries).

Section 4 of this report, entitled "Conclusion", is a description of the Regions overall assessment of the capabilities of the participating organizations. It also presents information on planning issues if any were identified. The Appendices, present supplementary information:

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Appendix A - Exercise Timeline. A table that depicts the times when an event or notifications were noted at participating agencies and locations.

Appendix B - Exercise Evaluators and Team leaders. A table listing the evaluator names, organizations, and responsibilities of the evaluators and management.

Appendix C - Acronyms and Abbreviations. An alphabetized table defining the formal names Emergency Planning Zone Description The following is a basic description of the plume exposure Emergency Planning Zone (EPZ): Exelon Nuclear owns and operates the Peach Bottom Atomic Power Station (PBAPS). The station consists of one 40-megawatt (MW), high-temperature, gas-cooled reactor (Unit 1), decommissioned in October 1974, and two operating boiling water reactors (Units 2 and 3) rated at 1,065 MW per unit. The operating licenses for the facility were granted in October 1973 (Unit 2) and July 1974 (Unit 3); commercial operation began at the site in July 1974 (Unit 2) and December 1974 (Unit 3).

The coordinates of the plant site are 39°45'32" north (latitude) by 76°16'9" west (longitude). The site consists of 620 acres located on the west shore of Conowingo Pond, a reservoir formed by the backwater of the Conowingo Dam on the Susquehanna River. The site is primarily in Peach Bottom Township, York County, Pennsylvania; a small portion of the property lies in Lancaster County in southeastern Pennsylvania near the mouth of Rock Run Creek. The minimum exclusion distance (distance from the center point of the reactor vessel to the site area boundary) specified for the PBAPS is 2,700 feet. Exelon Nuclear owns all the land within the exclusion area; there are no private residences on site.

The plant is located about 38 miles north-northeast of Baltimore, Maryland; 45 miles southeast of Harrisburg, Pennsylvania; and 20 miles south-southeast of Lancaster, Pennsylvania. The nearest communities are Delta, Pennsylvania, and Cardiff, Maryland, which are located approximately four and five miles west-southwest of the site, respectively. There are 97 sirens providing coverage for the 10-mile EPZ; 65 are in Pennsylvania. Soils of the Manor-Glenelg Association predominate in the site area. These soils, which are generally underlain by schist or phyllite, are shallow to moderately deep and are found on moderate to very steep slopes. The general topography of the site is hilly, with elevations ranging from 110 feet to over 460 feet above mean sea level (MSL); the plant is 116 feet above MSL.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station The site is characterized by broad ridge tops and steep hillsides along the river. The climate in this area of York County is mild but humid. Prevailing winds are from the west.

The average rainfall is approximately 40.5 inches, and the average annual temperature is 52.8° Fahrenheit. The area in the immediate vicinity of the plant is mostly agricultural.

There are no commercial airports within a 10-mile radius. The closest major airport is in Harrisburg, about 50 miles northwest of the site. A smaller airport servicing commuter and private aircraft is located in Lancaster, about 25 miles north of the site. No public highways pass through the plant, and no major arterial highways pass near it. Access to the plant is by two roads: one, from the nearby town of Delta, leads to the decommissioned Unit 1 area and Information Center; the other passes north of Delta and enters the plant area near Units 2 and 3.

The 10-rnile EPZ for PBAPS, with a total risk population of approximately 57,645, covers the following jurisdictions:

Commonwealth of Pennsylvania Risk Counties:

Chester County West Nottingham Township Lancaster County Drumore Township East Drumore Township Fulton Township Little Britain Township Martic Township Providence Township Quarryville Borough York County Delta Borough Fawn Grove Borough Fawn Township Lower Chanceford Township Peach Bottom Township State of Maryland Cecil County Harford County 16

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 2.2 Exercise Objectives, Capabilities and Activities The objective of the Peach Bottom Atomic Power Station 2016 Plume Exercise was to demonstrate the capabilities of State and local emergency management agencies to mobilize emergency management and emergency response personnel, to activate emergency operations centers and support facilities, and to protect the health, lives, and property of the citizens residing within the 10 mile Emergency Planning Zone (EPZ).

To demonstrate the ability to communicate between multiple levels of government and provide timely, accurate, and sufficiently detailed information to the public, emergency management agencies used a variety of resources including radios, telephones, the Internet, the media, the Emergency Alert System (EAS), and the utility Alert and Notification System sirens (ANS). All of these communications resources were employed and evaluated. The EAS and ANS was simulated and media information was prepared but not actually released.

An essential capability of the Radiological Emergency Preparedness Program (REPP) is to evacuate, monitor and decontaminate if necessary, and provide temporary care and shelter to displaced residents from the EPZ. The ability of the counties to mobilize personnel and resources to establish reception, monitoring and decontamination, and mass care centers was demonstrated.

The protection of school children is also a vital mission of the REPP. School districts and selected schools demonstrated the capability to communicate and coordinate the collection, evacuation, transportation and shelter of students attending schools within the EPZ.

Provisions for students who live within the EPZ but attend school outside were also evaluated."

2.3 Scenario Summary NOTE: All information below is scenario simulated. The times for the events are approximate as the NRC licensees operations crew on the reactor training simulator will be provided opportunity for free play.

An Alert is declared by 1625 due to a potential loss of the reactor coolant barrier.

At 1700, a wind shift occurs with a wind direction from 85 degrees. A Site Area Emergency is declared by 1736 due to the potential or loss of two barriers.

At 1810, a wind shift occurs with a wind direction from 65 degrees. Drywell radiation monitors ramp to 980 R/hour due to fuel failure from the uncovered reactor fuel.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station A General Emergency is declared by 1830 for the potential or loss of the third barrier. The Commonwealth of Pennsylvania and the State of Maryland will make protective action decisions based Protective Action Recommendations (P ARs) from the Licensee and State officials.

At 1915, a wind shift occurs with a wind direction from 30 degrees. The updated PAR adds the South downwind sector for evacuation out to five miles.

At 2030, the exercise is terminated.

SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained in this section are the results and findings of the evaluations of all jurisdictions and locations that participated in the April 27, 2016, biennial Plume Exposure Pathway EPZ Radiological Emergency Preparedness (REP) Exercise, and the Out of Sequence Exercise evaluations conducted in March 2, 7, 8, 9, 16, 24, 29, 30, 31 2016; and Medical Services Drills conducted March 24 & 31, 2016. The exercise was conducted to demonstrate the ability of the Off site Response Organizations of State and local government to protect the health and safety of the public in the 10 mile Emergency Planning Zone surrounding the Peach Bottom Atomic Power Station.

Each jurisdiction and functional entity was evaluated on the basis of its demonstration of the Exercise Evaluation Area Criteria contained in the REP Exercise Evaluation Methodology.

Detailed information on the exercise evaluation area criteria and the Extent of Play Agreement can be found in the Exercise Plan.

3.2 Summary Results of Exercise Evaluation The matrix presented in Table 3.1, on the following pages, presents the status of the exercise evaluation area criteria from the REP Program Manual that was scheduled for demonstration during this exercise by all participating jurisdictions and functional entities. Exercise evaluation area criteria are listed by number and the demonstration status of the criteria is indicated by the use of the following letters:

(D) Demonstrated Strength: an observed action, behavior, procedure, and/or practice that is worthy of special notice and positive recognition, Note: this is already a common practice that many Regions employ when identifying demonstrated strengths.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station (Ll) Level 1 Finding: an observed or identified inadequacy or organizational performance in an exercise that could cause a determination that offsite emergency preparedness is not adequate to provide reasonable assurance that appropriate protective measures can be taken in event of a radiological emergency to protect the health and safety of the public living in the vicinity of a Nuclear Power Plant (NPP).

(L2) Level 2 Finding: an observed or identified inadequacy of organizational performance in an exercise that is not considered, by itself, to adversely impact public health and safety.

(P) Plan Issue: an observed or identified inadequacy of organizational in the offsite response organizations' (OROs) emergency plan/implementation procedures, rather than that of the ORO"s performance.

(N) Not Demonstrated: term applied to the status of a REP exercise Evaluation Area Criterion indicating that the ORO, for a justifiable reason, did not demonstrate the Evaluation Area Criterion, as required in the extent-of-play agreement or at the two -year or eight-year interval required in the FEMA REP Program Manual.

(M) Met: status of a REP exercise Evaluation Area Criterion indicating that the participating ORO demonstrated all demonstration criteria for the Evaluation Area Criterion to the level required in the extent of-of-play agreement with no Findings assessed in the current exercise and no unresolved prior Findings.

Tables 3.2 - Summary of Exercise Evaluation T bl 3 2 E

a e. a -

xerc1se E f

b Cl

.fi va ua wn 1y ass1 1catwn Date: 4/27/2016 Site: Peach Bottom Atomic Power Station Location Criteria Title Criteria Classification Chester County Emergency Implementation of Emergency Worker 3al L2 Operations Center Exposure Control Table 3.lc - Exercise Evaluation - Criteria Met Date: 4/27/2016 Site: Peach Bottom Atomic Power Station Location Criteria Title Criteria Chester County Emergency Emergency Information &

Sbl Operations Center Instructions for the Public/Media Chester County Emergency Activation of the Back-up ANS 5a3 Operations Center Chester County Emergency Activation of the Prompt Alert &

Sal Operations Center Notification System Chester County Emergency Equipment and Supplies to Support lel Operations Center Operations 19

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Chester County Emergency Implementation of P ADs for Schools 3c2 Operations Center Chester County Emergency Impediments to Evacuation 3d2 Operations Center Chester County Emergency Implementation of Traffic & Access 3dl Operations Center Control Chester County Emergency Communications Equipment ldl Operations Center Chester County Emergency Direction and Control lcl Operations Center Chester County Emergency Implementation of Emergency 3al Operations Center Worker Exposure Control Chester County Emergency Implementation of P ADs for disabilities & access/functional needs 3cl Operations Center people Chester County Emergency Mobilization lal Operations Center Chester County Emergency Implementation of KI PAD for 3bl Operations Center Institutionalized Individuals/Public Cecil County Back up Route Alerting Communications Equipment ldl Cecil County Back up Route Alerting Equipment and Supplies to Support lel Operations Cecil County Back up Route Alerting Activation of the Back-up ANS 5a3 Cecil County Back up Route Alerting Implementation of Emergency 3al Worker Exposure Control Cecil County Emergency Operations Equipment and Supplies to Support lel Center Operations Cecil County Emergency Operation Communications Equipment ldl Center Cecil County Emergency Operations Mobilization lal Center Cecil County Emergency Operations Implementation of P ADs for Schools 3c2 Center Cecil County Emergency Operations Implementation of PADs for disabilities & access/functional needs 3cl Center people Cecil County Emergency Operations Implementation of KI PAD for 3bl Center Institutionalized Individuals/Public Cecil County Emergency Operations Emergency Information &

Sbl Center Instructions for the Public/Media Cecil County Emergency Operations Direction and Control lcl Center Cecil County Emergency Operations Activation of the Back-up ANS 5a3 Center Cecil County Emergency Operations Implementation of Traffic & Access 3dl Center Control 20

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Cecil County Emergency Operations Activation of the Prompt Alert &

Sal Center Notification System Cecil County Emergency Operations Implementation of Emergency 3al Center Worker Exposure Control Cecil County Emergency Operations P ADs for disabilities &

2cl Center access/functional needs people Cecil County Emergency Operations Emergency Worker Exposure Control 2al Center Decisions Cecil County Emergency Operations Impediments to Evacuation 3d2 Center Cecil County Emergency Worker Monitoring/Decontamination of Monitoring & Decontamination Emergency 6bl Station Perryville High School Workers/EquipmentN ehicles Cecil County Emergency Worker Implementation of Emergency Monitoring & Decontamination 3al Station Perryville High School Worker Exposure Control Cecil County Emergency Worker Equipment and Supplies to Support Monitoring & Decontamination lel Station Perryville High School Operations Cecil County Mass Care Center Temporary Care of Evacuees 6cl Rising Sun High School Cecil County Mass Care Center Equipment and Supplies to Support lel Rising Sun High School Operations Cecil County Public School District Implementation of P ADs for Schools 3c2 Cecil County Public School District Implementation of PADs for Schools 3c2 Conowingo Elementary School Cecil County Reception Center Monitoring, Decontamination, &

6a1 Rising Sun High School Registration of Evacuees Cecil County Reception Center Implementation of Emergency 3al Rising Sun High School Worker Exposure Control Cecil County Reception Center Equipment and Supplies to Support lel Rising Sun High School Operations Cecil County Reception Center Communications Equipment ldl Rising Sun High School Cecil County Rising Sun Emergency Transportation/Treatment of 6dl Medical Service Ambulance Contaminated Injured Individuals Cecil County Rising Sun Emergency Implementation of Emergency 3al Medical Service Ambulance Worker Exposure Control Cecil County Rising Sun Emergency Equipment and Supplies to Support lel Medical Service Ambulance Operations Cecil County Traffic & Access Impediments to Evacuation 3d2 Control Point Cecil County Traffic & Access Implementation of Traffic & Access 3dl Control Point Control Cecil County Traffic & Access Implementation of Emergency 3al Control Point Worker Exposure Control 21

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Cecil County Traffic & Access Equipment and Supplies to Support lel Control Point Operations Cecil County Traffic & Access Communications Equipment ldl Control Point Cecil County Union Hospital Equipment and Supplies to Support lel Operations Cecil County Union Hospital Transportation/Treatment of 6dl Contaminated Injured Individuals Cecil County Union Hospital Equipment and Supplies to Support lel Operations Chester County Oxford Area School Implementation of PADs for Schools 3c2 District Chester County area School District Implementation of PADs for Schools 3c2 Oxford Area High School Chester County West Nottingham Activation of the Back-up ANS 5a3 Township back-Up Route Alerting Chester County West Nottingham Implementation of Emergency 3al Township back-Up Route Alerting Worker Exposure Control Chester County West Nottingham Equipment and Supplies to Support lel Township back-Up Route Alerting Operations Chester County West Nottingham Communications Equipment ldl Township back-Up Route Alerting Chester County West Nottingham Township Emergency Operations Mobilization lal Center Chester County West Nottingham Implementation of P ADs for Township Emergency Operations disabilities & access/functional needs 3cl Center people Chester County West Nottingham Township Emergency Operations Activation of the Back-up ANS 5a3 Center Chester County West Nottingham Implementation of Traffic & Access Township Emergency Operations Control 3dl Center Chester County Emergency Operation Impediments to Evacuation 3d2 Center Chester County West Nottingham Township Emergency Operations Direction and Control lcl Center Chester County West Nottingham Township Emergency Operations Communications Equipment ldl Center Chester County West Nottingham Implementation of KI PAD for Township Emergency Operations Institutionalized Individuals/Public 3bl Center 22

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Chester County West Nottingham Equipment and Supplies to Support Township Emergency Operations lei Center Operations Chester County West Nottingham Implementation of Emergency Township Emergency Operations 3al Center Worker Exposure Control Exelon Joint Information Center Emergency Information &

5bl Instructions for the Public/Media Exelon Joint Information Center Communications Equipment ldl Harford County Back Up Route Activation of the Back-up ANS 5a3 Alerting Harford County Back Up Route Equipment and Supplies to Support lel Alerting Operations Harford County Back Up Route Communications Equipment ldl Alerting Harford County Back Up Route Implementation of Emergency 3al Alerting Worker Exposure Control Harford County Congregate Care Temporary Care of Evacuees 6cl Center Patterson Mill High School Harford County Congregate Care Equipment and Supplies to Support lel Center Patterson Mill High School Operations Harford County Darlington Transportation/Treatment of 6dl Emergency Medical Services Contaminated Injured Individuals Harford County Congregate Care Implementation of Emergency 3al Center Patterson Mill High School Worker Exposure Control Harford County Darlington Equipment and Supplies to Support lel Emergency Medical Services Operations Harford County Emergency Monitoring/Decontamination of Monitoring Decontamination Station Emergency 6bl Fallston High School Workers/Equipment/Vehicles Harford County Emergency Implementation of Emergency Monitoring Decontamination Station Worker Exposure Control 3al Fallston High School Harford County Emergency Equipment and Supplies to Support Monitoring Decontamination Station lel Fallston High School Operations Harford County Emergency Monitoring Decontamination Station Communications Equipment ldl Fallston High School Harford County Emergency Monitoring Decontamination Station Direction and Control lcl Fallston High School Harford County Emergency Implementation of PADs for disabilities & access/functional needs 3cl Operations Center people 23

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Harford County Emergency Implementation of KI PAD for 3bl Operations Center Institutionalized Individuals/Public Harford County Emergency Implementation of Emergency 3a1 Operations Center Worker Exposure Control Harford County Emergency Activation of the Back-up ANS 5a3 Operations Center Harford County Emergency Activation of the Prompt Alert &

Sal Operations Center Notification System Harford County Emergency Emergency Information &

5bl Operations Center Instructions for the Public/Media Harford County Emergency Impediments to Evacuation 3d2 Operations Center Harford County Emergency Implementation of Traffic & Access 3dl Operations Center Control Harford County Emergency Accident Assessment and P ARs for 2bl Operations Center the Emergency Event Harford County Emergency Communications Equipment ldl Operations Center Harford County Emergency Command and Control lcl Operations Center Harford County Emergency Mobilization lal Operations Center Harford County Emergency Implementation of PADs for Schools 3c2 Operations Center Harford County Emergency Emergency Worker Exposure Control 2al Operations Center Decisions Harford County Emergency Facilities lbl Operations Center Harford County Emergency Equipment and Supplies to Support lel Operations Center Operations Harford County Public School Implementation of P ADs for Schools 3c2 District Harford County Public School North Implementation of P ADs for Schools 3c2 Harford Elementary School Harford County Access & Control Implementation of Traffic & Access 3d1 Point Control Harford County Access & Control Implementation of Emergency 3al Point Worker Exposure Control Harford County Access & Control Equipment and Supplies to Support lel Point Operations Harford County Access & Control Communications Equipment ldl Point Harford County Access & Control Impediments to Evacuation 3d2 Point Harford County Emergency Implementation of PADs for Schools 3c2 Operations Center 24

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Harford County Public School Implementation of PADs for Schools 3c2 District Harford County Public School District North Harford Elementary Implementation of PADs for Schools 3c2 School Harford County Public School implementation of PADs for Schools 3c2 District North Harford High School Harford County Public School Implementation of PADs for Schools 3c2 District North Harford Middle School Harford County Union Medical Transportation/Treatment of 6dl Center Contaminated Injured Individuals Harford County Union Medical Implementation of Emergency 3al Center Worker Exposure Control Harford County Union Medical Equipment and Supplies to Support lel Center Operations Lancaster County Martic Township Communications Equipment ldl Back-Up Route Alerting Lancaster County Martic Township Equipment and Supplies to Support lel Back-Up Route Alerting Operations Lancaster County Martic Township Implementation of Emergency 3al Back-Up Route Alerting Worker Exposure Control Lancaster County Martic Township Activation of the Back-up ANS 5a3 Back-Up Route Alerting Lancaster County Martic Township Mobilization lal Emergency Operations Center Lancaster County Martic Township Command and Control lcl Emergency Operations Center Lancaster County Martic Township Implementation of Emergency 3al Emergency Operations Center Worker Exposure Control Lancaster County Martic Township Communications Equipment ldl Emergency Operations Center Lancaster County Martic Township Implementation of KI PAD for 3bl Emergency Operations Center Institutionalized Individuals/Public Lancaster County Martic Township Implementation of PADs for disabilities & access/functional needs 3cl Emergency Operations Center people Lancaster County Martic Township Implementation of Traffic & Access 3dl Emergency Operations Center Control Lancaster County Martic Township Impediments to Evacuation 3d2 Emergency Operations Center Lancaster County Providence Township Emergency Operations Command & Control lcl Center Lancaster County Providence Township Emergency Operations Communications Equipment ldl Center 25

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Lancaster County Providence Equipment and Supplies to Support Township Emergency Operations Operations lel Center Lancaster County Providence Implementation of Emergency Township Emergency Operations Worker Exposure Control 3al Center Lancaster County Providence Implementation of KI PAD for Township Emergency Operations Institutionalized Individuals/Public 3bl Center Lancaster County Providence Implementation of PADs for Township Emergency Operations disabilities & access/functional needs 3cl Center people Lancaster County Providence Implementation of Traffic & Access Township Emergency Operations Control 3dl Center Lancaster County Providence Township Emergency Operations Impediments to Evacuation 3d2 Center Lancaster County Emergency Worker Monitoring & Decontamination Communications Equipment ldl Station Lampeter Strasburg Lancaster County Emergency Worker Monitoring/Decontamination of Monitoring & Decontamination Emergency 6bl Station Lampeter Strasburg Workers/Equipment/Vehicles Lancaster County Emergency Worker Implementation of Emergency Monitoring & Decontamination 3al Station Lampeter Strasburg Worker Exposure Control Lancaster County Emergency Worker Equipment and Supplies to Support Monitoring & Decontamination Operations lel Station Lampeter Strasburg Lancaster County Emergency Worker Monitoring & Decontamination Command & Control lcl Station Lampeter Strasburg Lancaster County Emergency Communications Equipment ldl Operation Center Lancaster County Emergency Command & Control lcl Operation Center Lancaster County Emergency Activation of the Prompt Alert &

Sal Operation Center Notification System Lancaster County Emergency Mobilization lal Operation Center Lancaster County Emergency Activation of the Back-up ANS 5a3 Operation Center Lancaster County Emergency Emergency Information &

Sbl Operation Center Instructions for the Public/Media 26

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Lancaster County Emergency Implementation of Emergency 3al Operation Center Worker Exposure Control Lancaster County Emergency Implementation of KI PAD for 3bl Operation Center Institutionalized Individuals/Public Lancaster County Emergency Implementation of PADs for disabilities & access/functional needs 3cl Operation Center people Lancaster County Emergency Implementation of PADs for Schools 3c2 Operation Center Lancaster County Emergency Impediments to Evacuation 3d2 Operation Center Lancaster County Emergency lmplementation of Traffic & Access 3dl Operation Center Control Lancaster County Emergency Equipment and Supplies to Support lel Operation Center Operations Lancaster County Mass Care Center Implementation of KI PAD for 3bl Lampeter Strasberg School Complex Institutionalized Individuals/Pub! ic Lancaster County Mass Care Center Implementation of Emergency 3al Lampeter Strasberg School Complex Worker Exposure Control Lancaster County Mass Care Center Equipment and Supplies to Support lel Lampeter Strasberg School Complex Operations Lancaster County Mass Care Center Communications Equipment ldl Lampeter Strasberg School Complex Lancaster County Mass Care Center Monitoring, Decontamination, &

6al Lampeter Strasberg School Complex Registration of Evacuees Lancaster County Mass Care Center Temporary Care of Evacuees 6cl Lampeter Strasberg School Complex Lancaster County Monitoring &

Equipment and Supplies to Support Decontamination Center Lampeter Operations lel Strasberg School Complex C Lancaster County Monitoring &

Equipment and Supplies to Support Decontamination Center Lampeter Operations 3al Strasberg School Complex C Lancaster County Monitoring &

Decontamination Center Lampeter Temporary Care of Evacuees 6cl Strasberg School Complex C Lancaster County Martic Township Implementation of PADs for disabilities & access/functional needs 3cl Emergency Operations Center people Lancaster County Martic Township Impediments to Evacuation 3d2 Emergency Operations Center Lancaster County Martic Township Implementation of Traffic & Access 3dl Emergency Operations Center Control Lancaster County Solanco School Implementation of PADs for Schools 3c2 District Claremont Elementary School 27

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Lancaster County Solanco School Implementation of P ADs for Schools 3c2 District Solanco High School Lancaster County Solanco School District Providence Elementary Implementation of P ADs for Schools 3c2 School Lancaster County Solanco School Implementation of PADs for Schools 3c2 District Lancaster County Penn Manor School Implementation of PADs for Schools 3c2 District Lancaster County Penn Manor School Implementation of PADs for Schools 3c2 District Marticville Middle School Maryland Accident Assessment State Emergency Operation Center Mobilization Jal Maryland Department of the Environment Maryland Accident Assessment State Emergency Operation Center Direction and Control lcl Maryland Department of the Environment Maryland Accident Assessment State Emergency Operation Center Communications Equipment ldl Maryland Department of the Environment Maryland Accident Assessment State Emergency Operation Center Equipment and Supplies to Support lel Maryland Department of the Operations Environment Maryland Accident Assessment State Emergency Operation Center Emergency Worker Exposure Control 2al Maryland Department of the Decisions Environment Maryland Accident Assessment State Emergency Operation Center Accident Assessment and P ARs for 2bl Maryland Department of the the Emergency Event Environment Maryland Accident Assessment State Emergency Operation Center PAD decision-making process and 2b2 Maryland Department of the coordination for the General Public Environment Maryland Accident Assessment State Emergency Operation Center Accident Assessment and PARs for 4a2 Maryland Department of the the Emergency Event Environment Maryland Emergency Operations Communications Equipment ldl Center 28

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Maryland Emergency Operations Mobilization lal Center Maryland Emergency Operations PADs for disabilities &

2cl Center access/functional needs people Maryland Emergency Operations Facilities lbl Center Maryland Emergency Operations Direction and Control lei Center Maryland Emergency Operations Equipment and Supplies to Support lel Center Operations Maryland Emergency Operations PAD decision-making process and 2b2 Center coordination for the General Public Maryland Emergency Operations Activation of the Prompt Alert &

Sal Center Notification System Maryland Emergency Operations Implementation of Traffic & Access 3dl Center Control Maryland Emergency Operations Implementation of KI PAD for 3bl Center Institutionalized Individuals/Public Maryland Emergency Operations Implementation of PADs for disabilities & access/functional needs 3cl Center people Maryland Emergency Operations Implementation of PADs for Schools 3c2 Center Maryland Emergency Operations Implementation of Traffic & Access 3d2 Center Control Maryland Emergency Operations Emergency Information &

5bl Center Instructions for the Public/Media Maryland State Field Monitoring Plume Phase Field Measurement, 4a3 TeamA Handling, & Analyses Maryland State Field Monitoring Mobilization lal TeamA Maryland State Field Monitoring Implementation of Emergency 3al TeamA Worker Exposure Control Maryland State Field Monitoring Equipment and Supplies to Support lel TeamA Operations Maryland State Field Monitoring Communications Equipment ldl TeamA Maryland State Field Monitoring Plume Phase Field Measurement, 4a3 TeamB Handling, & Analyses Maryland State Field Monitoring Mobilization lal TeamB Maryland State Field Monitoring Implementation of Emergency 3al TeamB Worker Exposure Control Maryland State Field Monitoring Equipment and Supplies to Support lel TeamB Operations 29

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Maryland State Field Monitoring Communications Equipment ldl TeamB Pennsylvania Accident Assessment Center State Emergency Operations Accident Assessment and P ARs for 2bl Center Bureau of Radiation the Emergency Event Protection Pennsylvania Accident Assessment Center State Emergency Operations Emergency Worker Exposure Control 2al Center Bureau of Radiation Decisions Protection Pennsylvania Accident Assessment Center State Emergency Operations Communications Equipment ldl Center Bureau of Radiation Protection Pennsylvania Accident Assessment Center State Emergency Operations Equipment and Supplies to Support lel Center Bureau of Radiation Operations Protection Pennsylvania Accident Assessment Center State Emergency Operations Direction and Control lcl Center Bureau of Radiation Protection Pennsylvania Accident Assessment Center State Emergency Operations Mobilization lal Center Bureau of Radiation Protection Commonwealth of Pennsylvania State Communications Equipment ldl Emergency Operation Center Commonwealth of Pennsylvania State Mobilization lal Emergency Operation Center Commonwealth of Pennsylvania State PADs for disabilities &

2cl Emergency Operation Center access/functional needs people Commonwealth of Pennsylvania State Direction and Control lcl Emergency Operation Center Commonwealth of Pennsylvania State Equipment and Supplies to Support lel Emergency Operation Center Operations Commonwealth of Pennsylvania State PAD decision-making process and 2b2 Emergency Operation Center coordination for the General Public Commonwealth of Pennsylvania State Emergency Worker Exposure Control 2al Emergency Operation Center Decisions Commonwealth of Pennsylvania State Activation of the Prompt Alert &

5al Emergency Operation Center Notification System Commonwealth of Pennsylvania State Implementation of Traffic & Access 3dl Emergency Operation Center Control Commonwealth of Pennsylvania State Implementation ofKJ PAD for 3bl Emergency Operation Center Institutionalized Individuals/Public 30

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station PA TIC/Rumor Control Communications Equipment ldl PA TIC/Rumor Control Emergency Information &

Sbl Instructions for the Public/Media PA T ACP State Police Barracks Impediments to Evacuation 3d2 Lancaster Pennsylvania Traffic & Access Implementation of Traffic & Access Control Point State Police Barracks 3dl Lancaster Control Pennsylvania Traffic & Access Control Point State Police Barracks Communications Equipment ldl Lancaster Pennsylvania Traffic & Access Implementation of Emergency Control Point State Police Barracks 3al Lancaster Worker Exposure Control Pennsylvania Traffic & Access Equipment and Supplies to Support Control Point State Police Barracks lel Lancaster Operations York County Emergency Operations Direction and Control lcl Center York County Red Lion Area School Implementation of P ADs for Schools 3c2 District York County Red Lion Area School Implementation of PADs for Schools 3c2 District 31

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 3.3 Criteria Evaluation Summaries 3.3.1 State Jurisdictions 3.3.1.1 Maryland Accident Center, Maryland Department of the Environment In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.2 Maryland Emergency Operations Center In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.3 State Field Monitoring Team A In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE 32

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.4 Maryland State Field Monitoring Team B In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.5 Pennsylvania Accident Assessment Center, Bureau of Radiation Protection In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.6 Pennsylvania Emergency Operations Center In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:

a. MET: l.a.1, l.c.1, l.d.1, l.e.1, 2.a.1, 2.b.2, 3.b.1, 3.d.1, 5.a.1 33

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.7 Pennsylvania Joint Information Center/Rumor Control In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.8 Pennsylvania State Traffic and Access Control Points, State Police Barrack Lancaster In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:

a. MET: l.d.1, l.e.1, 3.a.1, 3.d.3.5.2, 5.b.1

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 34

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 3.3.2 Risk Jurisdictions 3.3.2.1 Cecil County Back-up Route Alerting In summary, the status of DHS/FEMA criteria for the Risk location is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.2 Cecil County Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk location is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.3 Cecil County Emergency Worker Emergency Worker Monitoring and Decontamination Station In summary, the status of DHS/FEMA criteria for the Risk location is as follows:

a. MET: 1.e.1, 3.a.l, 6.b.1

b. LEVEL 1 FINDINGS: NONE 35

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.4 Cecil County Mass Care Center, Rising Sun High School In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.5 Cecil County Public School District In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.6 Cecil County Public School District, Conowingo Elementary School In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

36

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.7 Cecil County Reception Center, Rising Sun High School In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: l.d.l, l.e.1, 3.a.1, 6.a.1

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.8 Cecil County Traffic and Access Control Point In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: l.d. l, l.e.1, 3.a.1, 3.d.1, 3.d.2, 6.c.1

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 37

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 3.3.2.9 Chester County, Oxford Area School District In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.10 Chester County, Oxford Area School District, Oxford Area High School In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.11 Chester County, West Nottingham Township Back-up Route Alerting In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE 38

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

e. PRJOR ISSUES: RESOLVED: NONE

f.

PRJOR ISSUES: UNRESOLVED: NONE 3.3.2.12 Chester County, West Nottingham Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRJOR ISSUES: RESOLVED: NONE

f.

PRJOR ISSUES: UNRESOLVED: NONE 3.3.2.13 Chester County Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: 3.a.1

d. PLAN ISSUES: NONE

e. PRJOR ISSUES: RESOLVED: NONE ISSUE FOR CRITERION: 3.a.1 CONDITION: During the required Emergency Worker (EW) radiological briefing the Chester County Radiological Officer (RO) did not adequately deliver the briefing to two Chester County Sheriffs Office deputies serving as emergency workers.

POSSIBLE CAUSE: The RO did not adhere to the recommended procedures and provided disparate information to the emergency workers.

39

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

REFERENCE:

NUREG-0654/FEMA-REP-1, K.3.a, b; K.4 EFFECT: The information briefed by the RO could have resulted in a misunderstanding of exposure control and dosimetry.

CORRECTIVE ACTION DEMONSTRATED: The briefing was successfully re-demonstrated by an alternate RO.

3.3.2.14 Harford County Back-up Route Alerting In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: l.d.l, l.e.l, 3.a.l, 5.a3

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.15 Harford County Congregate Care Center, Patterson Mill High School

a. MET: l.e. l, 6.c. l

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.16 Harford County Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

40

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.17 Harford County Emergency Worker Monitoring and Decontamination Station, Fallston In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 1.d.1, 1.c.l, 1.e.l, 3.a.l, 6.b.l

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.18 Harford County Public School District In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.21

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE 41

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.19 Harford County Public School District, North Harford Elementary School In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.20 Harford County Public School District, North Harford High School In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.21 Harford County Public School District, North Harford Middle School In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE 42

I*

i Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.22 Harford County Traffic and Access Control Point In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 1.d.1, 1.e.l, 3.d.l, 3.d.2, 6.b.l

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.23 Lancaster County, Martic Township Backup Route Alerting In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 1.d.l, 1.e.l, 3.a.1, 5.a3

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.24 Lancaster County, Martic Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE 43

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.25 Lancaster County, Penn Manor School District In summary, the status ofDHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.26 Lancaster County, Penn Manor School District, Marticville Middle School In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.27 Lancaster County, Providence Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

44

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.28 Lancaster County, Solanco School District In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.29 Lancaster County, Solanco School District, Clermont Elementary School In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 45

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 3.3.2.30 Lancaster County Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.31 Lancaster County Emergency Worker Monitoring and Decontamination Station, Lampeter In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: l.c.1, l.d.1, l.e.1, 3.a.l, 6.b.l

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.32 Lancaster County Mass Care Center, Lampeter/Strasburg School Complex In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: l.d.1, l.e.l, 3.a.1, 3.b.1, 6.a.1, 6.c.1

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE 46

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.33 Lancaster County Monitoring and Decontamination Center, Lampeter/Strasburg School In summary, the status ofDHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: Le.I, 3.a.1, 6.a.l

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.34 York County, Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: Lal, Lc.1, Ld.l, Le.I, 3.a.l, 3.b.l, 3.c.l, 3.c.2, 3.d.l, 3.d.2, 5.a.l, 5.a.3, 5.b.1

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.35 York County, Lower Chanceford Back-up Route Alerting In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: Ld.1, Le.I, 3.a.l, 5.a.3 47

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.36 York County, Lower Chanceford Township Emergency Operations Center In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.37 York County, Red Lion Area School District In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 48

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 3.3.2.38 York County, Red Lion Area School District, Windsor Manor Elementary School In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.39 York County, Red Lion School District, Red Lion Senior High School In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 3.c.2

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.3 Private Jurisdictions 3.3.3.1 Cecil County, Rising Sun Emergency Medical Services In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 1.e.l, 3.a.1, 6.d.l

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE 49

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.3.2 Cecil County, Union Hospital In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: l.e.l, 3.a.l, 6.d.1

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.3.3 Exelon Joint Information Center In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

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

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.3.4 Harford County, Darlington Volunteer Fire Company In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: l.e.l, 3.a.l, 6.d.1 50

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 3.3.3.5 Harford County, Upper Chesapeake Medical Center In summary, the status of DHS/FEMA criteria for the Risk jurisdiction is as follows:

a. MET: 1.e.1, 3.a.1, 6.d.1

b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE

e. PRIOR ISSUES: RESOLVED: NONE

f.

PRIOR ISSUES: UNRESOLVED: NONE 51

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station SECTION 4: CONCLUSION The Commonwealth of Pennsylvania and the State of Maryland and local jurisdictions, except where noted in this report demonstrated knowledge of their Radiological Emergency Response Plans (RERP) and procedures were adequately implemented during the Peach Bottom Atomic Power Station Plume exercise evaluated on April 27, 2016.

Federal Emergency Management Agency (FEMA) evaluators provided analyses of six evaluation criteria. These analyses resulted in a determination of no Level 1 Findings, (1) One Level 2 Finding (successfully re-demonstrated), and no New Plan Issues.

Based on the results of the exercise and a review of the off site radiological emergency response plans and procedures submitted, FEMA Region III has determined they are adequate (meet the planning and preparedness standards ofNUREG-0654/FEMA-REP-1, Revision 1, November 1980, as referenced in 44 CFR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise.

The Rising Sun Emergency Medical Services (EMS) and the Darlington Volunteer Fire Company successfully demonstrated that necessary equipment and supplies were available to support the treatment of an injured/contaminated victim. EMS personnel prioritized life-saving medical practices over contamination concerns, implemented protective measures through the use of Personal Protective Equipment (PPE), regular glove changes, and control of cross contamination. Appropriate patient assessments were demonstrated as well as regular and ongoing communications with Upper Chesapeake and Union Hospital.

The Upper Chesapeake and Union Hospital successfully demonstrated the mobilization of staff, staffing assignments, issue of dosimetry and monitoring equipment, and effective use of Personal Protective Equipment (PPE) during the exercise. The hospital staff effectively responded to communications from the Ambulance, initiated the set-up and management of a Radiation Emergency Area (REA), and accepted and successfully treated an injured/contaminated victim while administering life-threatening medical attention over contamination concerns. In addition, the medical facility provided security control of the facility including the drop off bay for the patient and overall protective measures for contamination control and prevention of cross contamination.

An After Action Implementation Plan (IP) will not be developed as part of this report.

52

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station APPENDIX A: EXERCISE TIMELINE This section contains the Exercise Timeline. A table that depicts the times when an event or notifications were noted at participating agencies and locations.

Time That Notification Was Received at the Listed Location Emergency AAMD Cecil Harford Classification Time Utility State of Maryland (MDE)

County County level or Event Declared EOC EOC EOC Unusual Event Alert 16 14 1628 1630 1630 1630 Site Area Emergency 1730 1740 1744 1743 1743 General Emergency 1819 1841 1841 1841 1841 Simulated Radiation NIA 1807 1823 1807 1807 Relea e Started Simulated Radiation NIA On-going On-going On-going On-going Release Terminated Facility Declared Operational 1700 1725 1700 1700 Governor's Declaration of 1900 1850 1900 1900 State of Emergency Exercise Terminated 2003 2045 2007 2007 First Precautionary/Protective Actions:

1756 1805 1756 1756 Describe school activities cancelled Parks closed 1757 1805 1757 1757 An imals placed on stored feed, water &

1800 1805 1805 1805 Rai I, feed & water, Air restriction l Om 1800 1805 1805 1805 restrictions 5mi/5,000 Decision 1805 1805 18 15 1815 Siren Sounding 1815 1815 1815 18 15 EAS Broadcast time 1818 18 18 1818 1818 Second Precautionary/ Protective 1846 1850 1850 1850 Actions: Describe 0- 10 mi, Evacuation Air Restrictions l 0 mi les l 0,000 feet 1850 1850 1850 1850 Decision 1850 1850 1850 1850 Siren Sounding 1900 1900 1900 1900 EAS Message Broadcast 1903 1903 1903 1903 Decision to take Kl:

1814 1805 18 14 1814 EWs 53

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Time That Notification Was Received at the Listed Location Chester West Lancaster Martic Providence Time PA/AA Exelon Nottingham Emergency Utility Commonwealth PAJIC (BRP)

JlC County Township County Township Township Classification PA EOC EOC EOC EOC EOC Level or Event Declared EOC Unusual Event Alert 1614 1635 1635 1624 1650 1622 1640 1622 1634 1724 Site Area Emergency 1730 1745 1745 1739 1800 1739 1750 1801 1805 1808 General Emergency 1819 184 1 1841 1832 1845 1841 1841 1841 1847 1847 Simulated Radiation 1804 1807 1807 1820 1808 1808 1841 1841 1848 1847 Release Started Simulated Radiation On-going On-going On-going On-going On-going On-going On-going On-going On-going On-going Release Terminated

!Facility Declared Operational 1635 1635 1605 1730 1637 1705 1713 1652 1730 Governor's Declaration of 1814 1814 1814 1822 1823 1827 1814 1814 1900 State of Emergency Exercise Terminated 20 14 2014 20 10 1945 1959 2015 2000 2000 194 1 First Precautionary/Protective 1805 1805 1800 1800 1805 1846 1805 1805 1805 Actions: Describe Livestock on stored feed and 1805 1805 1800 1800 1805 1846 1805 1805 1805 Water 10 mi le waterway restriction; 1805 1805 1800 1800 1805 1846 1805 1805 1805 Air 5 mile 5000/ TCP 1805 1805 1800 1835 1805 1846 1805 1805 1805 ACP 10 mile rail 1805 1805 1800 1835 1805 1846 1805 1805 1 Of\\C Siren Sounding 18 15 1815 1815 1822 1815 1815 1815 18 15 1805 EAS Broadcast time 1818 1818 1818 1822 1818 1818 1818 1818 1808 Second Precautionary/

1850 1850 1844 1900 1850 1852 1850 1850 1907 Protective Actions: Describe Expand air 10 mile 10,000 1850 1850 1844 1900 1850 1852 1850 1850 1907 360 IO mile, KI for all 1850 1850 1844 1900 1850 1852 1850 1850 1907 Received Evac farms 1850 1850 1849 1900 1850 1852 1850 1850 1907 S~en Sounding 1900 1900 1900 1900 1900 1900 1900 1900 1903 EAS Message Broadcast 1903 1903 1903 1900 1903 1903 1903 1903 1907 Decision to take KI:

1903 1903 1903 1900 1903 1903 1903 1903 1903 EWs Decision to take KI:

1903 1903 1903 1900 1903 190 1 1903 1910 19 10 Public 54

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station APPENDIX B: EXERCISE EV ALU A TORS AND TEAM LEADERS LOCATION TEAM LEADER AGENCY Cecil County Back-up Route Alerting John Rice FEMA Region 1 Cecil County Emergency Operations Center John Rice FEMA Region 1 Cecil County Emergency Worker Emergency Worker Martin Vyenielo FEMA Region 3 Monitoring and Decontamination St Cecil County Mass Care Center, Rising Sun High Michael Shuler FE~Region#

School Cecil County Public School District Martin Vyenielo FEMA Region 3 Cecil County Public School District, Conowingo Michael Shuler FEMA Region 3 Elementary School Cecil County Reception Center, Rising Sun High School Martin Vyenielo FEMA Region 3 Cecil County Traffic and Access Control Point John Rice FEMA Region 1 Cecil County, Rising Sun Emergency Medical Services Barton Freeman FMA Region 3 Cecil County, Union Hospital John Price FEMA Region 3 Chester County Emergency Operations Center Lee Torres FEMA Region 3 Chester County, Oxford Area School District Michael Shuler FEMA Region 3 Chester County, Oxford Area School District, Oxford Michael Shuler FEMA Region 3 Area High School Chester County, West Nottingham Township Back-up Lee Torres FEMA Region 3 Route Alerting Chester County, West Nottingham Township Lee Torres FEMA Region 3 Emergency Operations Center Exelon Joint Information Center Joseph Suders FEMA Region 3 Harford County Back-up Route Alerting Barton Freeman FEMA Region 3 Harford County Congregate Care Center, Patterson Mill John Price FEMA Region 3 High School Harford County Emergency Operations Center Barton Freeman FEMA Region 3 Harford County Emergency Worker Monitoring and Martin Vyenielo FEMA Region 3 Decontamination Station, Fallston Harford County Public School District Barton Freeman FEMA Region 3 Harford County Public School District, North Harford Barton Freeman FEMA Region 3 Elementary School Harford County Public School District, North Harford Barton Freeman FEMA Region 3 High School Harford County Public School District, North Harford Barton Freeman FEMA Region 3 Middle School Harford County Reception Center, Fallston High School Michael Shuler FEMA Region 3 Harford County Traffic and Access Control Point Barton Freeman FEMA Region 3 55

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Harford County, Darlington Emergency Medical Martin Vyenielo FEMA Region 3 Services Harford County, Upper Chesapeake Medical Center Joseph Suders FEMA Region 3 Lancaster County Emergency Operations Center Tina Lai-Thomas FEMA Region 3 Lancaster County Emergency Worker Monitoring and Tina Lai-Thomas FEMA Region 3 Decontamination Station, Lampeter Lancaster County Mass Care Center, Tina Lai-Thomas FEMA Region 3 Lampeter/Strasburg School Complex Lancaster County Monitoring and Decontamination Tina Lai-Thomas FEMA Region 3 Center, Lampeter/Strasburg School Lancaster County Reception Center, Lancaster County Tina Lai-Thomas FEMA Region 3 Career and Technology Center Lancaster County, Martic Township Backup Route Tina Lai-Thomas FEMA Region 3 Alerting Lancaster County, Martic Township Emergency Tina Lai-Thomas FEMA Region 3 Operations Center Lancaster County, Penn Manor School District Michael Shuler FEMA Region 3 Lancaster County, Penn Manor School District, Robert Neff FEMA Region 3 Marticville Middle School Lancaster County, Providence Township Emergency Tina Lai-Thomas FEMA Region 3 Operations Center Lancaster County, Solanco School District Michael Shuler FEMA Region 3 Lancaster County, Solanco School District, Clermont Michael Shuler FEMA Region 3 Elementary School Lancaster County, Solanco School District, Providence Michael Shuler FEMA Region 3 Elementary School Lancaster County, Solanco School District, Solanco Michael Shuler FEMA Region 3 High School Maryland Accident Assessment Center, Maryland Martin Vyenielo FEMA Region 3 Department of the Environment Maryland Emergency News Center John Price FEMA Region 3 Maryland Emergency Operations Center John Price FEMA Region 3 Maryland State Field Monitoring Team A Martin Vyenielo FEMA Region 3 Maryland State Field Monitoring Team B Martin Vyenielo FEMA Region 3 Pennsylvania Accident Assessment Center, St Martin Vyenielo FEMA Region 3 Emergency Ops Center-Bureau of Radiation Protection Pennsylvania Emergency Operations Center Joseph Suders FEMA Region 3 Pennsylvania Joint Information Center/Rumor Control Joseph Suders FEMA Region 3 Pennsylvania State Traffic and Access Control Points, Michael Shuler FEMA Region 3 State Pol Barrack Lancaster York County Reception Center Red Lion High School Michael Shuler FEMA Region 3 York County, Emergency Operations Center Thomas Murray FEMA Region 3 York County, Lower Chanceford Back-up Route Thomas Murray FEMA Region 3 Alerting 56

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station York County, Lower Chanceford Township Emergency Thomas Murray FEMA Region 3 Operations Center York County, Red Lion Area School District Joseph Suders FEMA Region 3 York County, Red Lion School District, Red Lion Joseph Suders FEMA Region 3 Senior High School York County, South Eastern School District Michael Shuler FEMA Region 3 York County, South Eastern School District, Fawn Michael Shuler FEMA Region 3 Elementary York County, South Eastern School District, South East Michael Shuler FEMA Region 3 Middle School - East Cecil County Back-up Route Alerting Brenda Rembert ICF Cecil County Emergency Operations Center Timothy Pflieger DHS-FEMA Cecil County Emergency Operations Center Kenneth Wierman FEMAHQ Cecil County Emergency Operations Center John Rice FEMA Region 1 Cecil County Emergency Operations Center Brian Clark ICF Cecil County Emergency Operations Center William McDougall FEMA Region 3 Cecil County Emergency Worker Emergency Worker Martin Vyenielo FEMA Region 3 Monitoring and Decontamination St Cecil County Emergency Worker Emergency Worker Michael Shuler FEMA Region 3 Monitoring and Decontamination St Cecil County Mass Care Center, Rising Sun High Michael Shuler FEMA Region 3 School Cecil County Public School District Martin Vyenielo FEMA Region 3 Cecil County Public School District, Conowingo Martin Vyenielo FEMA Region 3 Elementary School Cecil County Reception Center, Rising Sun High School Martin Vyenielo FEMA Region 3 Cecil County Traffic and Access Control Point Bruce Swiren ICF Cecil County, Rising Sun Emergency Medical Services Barton Freeman FEMA Region 3 Cecil County, Union Hospital John Price FEMA Region 3 Chester County Emergency Operations Center Dennis Branson FEMAR7 Chester County Emergency Operations Center Barbara Thomas FEMA Region 1 Chester County Emergency Operations Center Lee Torres FEMA Region 3 Chester County Emergency Operations Center Jon Christiansen ICF Chester County, Oxford Area School District Michael Shuler FEMA Region 3 Chester County, Oxford Area School District, Oxford Michael Shuler FEMA Region 3 Area High School Chester County, West Nottingham Township Back-up Frank Cordaro ICF Route Alerting Chester County, West Nottingham Township Miriam Weston FEMA Region 2 Emergency Operations Center Chester County, West Nottingham Township Michael Burriss ICF Emergency Operations Center Exelon Joint Information Center Roger Kowieski ICF 57

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Harford County Back-up Route Alerting Rosemary Samsel ICF Harford County Congregate Care Center, Patterson Mill John Price FEMA Region 3 High School Harford County Emergency Operations Center Andrew Chancellor FEMAR7 Harford County Emergency Operations Center Barton Freeman FEMA Region 3 Harford County Emergency Operations Center Rebecca Thomson ICF Harford County Emergency Operations Center Ronald Bonner ICF Harford County Emergency Worker Monitoring and Martin Vyenielo FEMA Region 3 Decontamination Station, Fallston Harford County Public School District Ronald Bonner ICF Harford County Public School District, North Harford Roger Winkelmann ICF Elementary School Harford County Public School District, North Harford Rosemary Samsel ICF High School Harford County Public School District, North Harford Brian Clark ICF Middle School Harford County Reception Center, Fallston High School Michael Shuler FEMA Region 3 Harford County Traffic and Access Control Point Gary Goldberg ICF Harford County, Darlington Emergency Medical Martin Vyenielo FEMA Region 3 Services Harford County, Upper Chesapeake Medical Center Joseph Suders FEMA Region 3 Lancaster County Emergency Operations Center Judy Dodgen FEMAR7 Lancaster County Emergency Operations Center Brad DeKorte FEMA Region 6 Lancaster County Emergency Operations Center David Petta ICF Lancaster County Emergency Operations Center Tina Lai-Thomas FEMA Region 3 Lancaster County Emergency Worker Monitoring and Robert Neff FEMA Region 3 Decontamination Station, Lampeter Lancaster County Mass Care Center, Robert Neff FEMA Region 3 Lampeter/Strasburg School Complex Lancaster County Mass Care Center, William McDougall FEMA Region 3 Lampeter/Strasburg School Complex Lancaster County Monitoring and Decontamination Robert Neff FEMA Region 3 Center, Lampeter/Strasburg School Lancaster County Monitoring and Decontamination William McDougall FEMA Region 3 Center, Lampeter/Strasburg School Lancaster County, Martic Township Backup Route Mark Dalton ICF Alerting Lancaster County, Martic Township Emergency Kathy Duran FEMA Region 3 Operations Center Lancaster County, Martic Township Emergency Kerry Holmes FEMA Region 3 Operations Center Lancaster County, Penn Manor School District Robert Neff FEMA Region 3 Lancaster County, Penn Manor School District, Robert Neff FEMA Region 3 Marticville Middle School 58

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Lancaster County, Providence Township Emergency Robert Swartz FEMA Region I Operations Center Lancaster County, Providence Township Emergency Laurel Ryan FEMA Region 9 Operations Center Lancaster County, Solanco School District Michael Shuler FEMA Region 3 Lancaster County, Solanco School District, Clermont Michael Shuler FEMA Region 3 Elementary School Lancaster County, Solanco School District, Providence Michael Shuler FEMA Region 3 Elementary School Lancaster County, Solanco School District, Solanco Michael Shuler FEMA Region 3 High School Maryland Accident Assessment Center, Maryland Kent Tosch ICF Department of the Environment Maryland Accident Assessment Center, Maryland Roger Winkelmann ICF Department of the Environment Maryland Emergency Operations Center Paul Anderson FEMA Region 10 Maryland Emergency Operations Center Dulcie Allen FEMA Region I 0 Maryland Emergency Operations Center John Price FEMA Region 3 Maryland Emergency Operations Center Roy Smith ICF Maryland Emergency Operations Center Ryan Jones ICF Maryland State Field Monitoring Team A Deborah Blunt ICF Maryland State Field Monitoring Team B John Wiecjorek ICF Pennsylvania Accident Assessment Center, State Martin Vyenielo FEMA Region 3 Emergency Ops Center-Bureau of Radiation Protection Pennsylvania Emergency Operations Center Craig Fiore FEMAHQ Pennsylvania Emergency Operations Center Joseph Suders FEMA Region 3 Pennsylvania Emergency Operations Center Jill Leatherman ICF Pennsylvania Emergency Operations Center Rufus Mobley FEMA HQ Pennsylvania Emergency Operations Center Steve Ward FEMA Region 3 Pennsylvania Joint Information Center/Rumor Control Paul Nied ICF Pennsylvania State Traffic and Access Control Points, Robert Neff FEMA Region 3 State Pol Barrack Lancaster York County, Emergency Operations Center Taneeka Hollins FEMA Region 1 York County, Emergency Operations Center Cristina Schulingkamp EPA Region 3 York County, Emergency Operations Center Linda Gee Yark County, Emergency Operations Center Thomas Murray FEMA Region 3 York County, Lower Chanceford Back-up Route Kevin Reed ICF Alerting York County, Lower Chanceford Township Emergency Helen Laforge FEMA Region 1 Operations Center York County, Lower Chanceford Township Emergency Lisa Rink FEMAHQ Operations Center York County, Red Lion Area School District Joseph Suders FEMA Region 3 59

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station York County, Red Lion Area School District, Windsor Joseph Suders FEMA Region 3 Manor Elementary School York County, Red Lion School District, Red Lion Joseph Suders FEMA Region 3 Senior High School York County, South Eastern School District Joseph *suders FEMA Region 3 York County, South Eastern School District, Fawn Joseph Suders FEMA Region 3 Elementary York County, South Eastern School District, South East Joseph Suders FEMA Region 3 Middle School - East 60

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station APPENDIX C: ACRONYMS AND ABBREVIATIONS Acronym Meaning AAC Accident Assessment Center ACP Access Control Points ALARA As Low As Reasonably Achievable ARC American Red Cross ARCA Area Requiring Corrective Action ARD Automatic Ring Down ARES Amateur Radio Emergency Services CCC Congregate Care Center CFC Community Fire Company CFD Community Fire Department CMARC Central Maryland Area Radio Communications co Communications Operator CP Command Post DFTR Dedicated Field Team Response DRD Direct Reading Dosimeters DS District Superintendent EAS Emergency Alert System ECC Emergency Communications Center ECL Emergency Classification Level EMA Emergency Management Agency EMC Emergency Management Coordinator EMD Emergency Management Director EMS Emergency Medical Services ENF Emergency Notification Form ENR Emergency Notification Report EOC Emergency Operations Center EOF Emergency Operations Facility EOP Emergency Operations Plan EPA Environmental Protection Agency EPD Electronic Personal Dosimeter EPI Emergency Public Information EPLO Emergency Preparedness Liaison Officer EPZ Emergency Planning Zone ERC Emergency Response Coordinator 61

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station ERO Emergency Response Organization ERT Emergency Response Teams ESF Emergency Support Functions EW Emergency Workers FD Fire Department FEMA Federal Emergency Management Agency FTC Field Team Coordinator FTEOC Fulton Township Emergency Operation Center FTL Field Team Leader GE General Emergency GIS Geographical Information System GM Geiger Muller GPS Global Positioning System HAB Hostile Action Based HCC Hartford Community College HCEMA Hartford County Emergency Management Agency HCEOC Harford County Emergency Operations Center HCHD Harford County Health Department HCHT Harford County Hazmat Team HCS Hartford Christian School HCSO Harford County Sheriffs Office HCTHS Hartford County Technical High School HM Hazardous Materials HO Health Officer HR Human Resources HS High School IC Incident Commander ICP Incident Command Post res Incident Command System JIC Joint Information Center LBTEOC Little Britain Township Emergency Operations Center LCEOC Lancaster County Emergency Operations Center LCRO Lancaster County Radiological Officer LEMA Lancaster Emergency Management Agency LEOC Lancaster Emergency Operations Center LGIA Large Group Instructional Area 62

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station MCC Mass Care Center MDT Mobile Data Terminal MEMA Maryland Emergency Management Agency MJOC Maryland Joint Operations Center MNRP Maryland Natural Resources Police MS Middle School MSEL Master Scenario Events List MSP Maryland State Police NARS Nuclear Accident Reporting System OASD Oxford Area School District ORO Offsite Response Organization OSL Optically Stimulated Luminescent PAD Protective Action Decision PAG Protective Action Guide PAR Protective Action Recommendation PBAPS Peach Bottom Atomic Power Station PBNPS Peach Bottom Nuclear Power Station PEMA Pennsylvania Emergency Management Agency PIC Public Information Center PIO Public Information Officer PM Portal Monitor PMHS Penn Manor High School PMSD Penn Manor School District PPE Personal Protection Equipment PRD Permanent Record Dosimeters PSP Pennsylvania State Police PVES Pleasant View Elementary School RACES Radio Amateur Civil Emergency Service RAD Radiological Assessment Director RC Reception Center REA Radiation Emergency Area REP Radiological Emergency Preparedness REPE Radiological Emergency Preparedness Exercise RERP Radiological Emergency Response Plan RHP Radiation Health Protection RLAJHS Red Lion Area Junior High School RLASD Red Lion Area School District 63

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station RLASHS Red Lion Area Senior High School RO Radiological Officer RS EMS Rising Sun Emergency Medical Services RSO Radiation Safety Officer SAE Site Area Emergency sco State Coordinating Officer SEMSW South Eastern Middle School West SEOC State Emergency Operations Center SESD South Eastern School District SES DO South Eastern School District Office SEVAN State Emergency Voice Activation Network SFMT State Field Monitoring Team SFP Spent Fuel Pool SHA State Highway Administration SME Subject Matter Expert SNB Special News Bulletins SOP Standard Operating Procedures sso Senior State Official TCP Traffic Control Points TEDE Total Effective Dose Equivalent TLD Thermo Luminescent Dosimeter UR1 Unified RASCAL Interface VP Vice Principal WNT West Nottingham Township YCEOC York County Emergency Operations Center 64

I

• Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station APPENDIX D: EXTENTS OF PLAY The 2016 Peach Bottom Atomic Power Station, Extents of Play Radiological Emergency Preparedness Exercise was negotiated and agreed upon by FEMA Region III, PEMA, MEMA, and the emergency management agencies of the Risk and Support Counties.

Commonwealth of Pennsylvania Extent of Play 2016 RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE 65

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station METHOD OF OPERATION I.

Peach Bottom Atomic Power Station (PBAPS)

The facility normally uses off-watch section personnel to participate in the exercise. The plant's simulated events, radiation readings, and emergency classifications will trigger offsite exercise actions. A pre-approved exercise scenario will be used. PBAPS will notify the State Emergency Operations Center (SEOC), the Bureau of Radiation Protection (BRP) and Risk Counties of emergency classifications.

II.

Bureau of Radiation Protection (BRP)

Personnel from the Pennsylvania Bureau of Radiation Protection (BRP) will be present and participate in the following aspects of the exercise during the Plume Exercise:

State EOC Exelon Emergency Operations Facility (EOF)

Field Sampling Teams & Command Vehicle BRP personnel field teams and R3V will NOT be evaluated during this exercise but BRP assessment will be evaluated as part of the PEMA SEOC evaluation. In the event the scenario has no radiological release, a report of Background Radiation by the Field Monitoring Team would be considered a successful demonstration of the criterion.

PEMA Operations at SEOC This "Method of Operation" Document includes activities for the Full-Scale Plume Exercise (April 27, 2016), and the "Out-of-Sequence" Activities (Various).

A.

Plume Exercise - April 27, 2016 PEMA Staff and Emergency Preparedness Liaison Officers (EPLOs) from designated state departments I agencies will comprise initial operations at the SEOC. The SEOC will be evaluated during this exercise.

B.

Plume Exercise - "Out-of-Sequence" Activities - March 7-9, 2016 The PEMA staff will disseminate exercise related messages to the participating Counties for dissemination to the participating School Districts during the demonstration windows on March 7-9, 2016. The State EOC and County EOCs will participate, but will not be 66

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station C.

evaluated during the "Out of Sequence" component. PEMA personnel will serve as "observers" at the identified School Districts.

Plume Exercise - "Out-of-Sequence" Activities - March 16, 2016 The Pennsylvania State Police (PSP) demonstration will take place at PSP York Barracks, located at 110 Trooper Court, York, Pennsylvania The PSP briefing will be performed out-of-sequence in a demonstration window of 9:30 a.m. to 11 :30 a.m. on March 16, 2016.

PEMA personnel will serve as "Observers" at the field exercise locations during the evening "out-of-sequence" component at 7:00 p.m. - 9:30 p.m. on March 7, 2016. The SEOC and Counties will not be evaluated during the evening "out-of-sequence" component.

IV.

PEMA Area Office Operations

v.

VI.

The PEMA Area Offices (Harrisburg-Central Area and Hamburg-Eastern Area) will not be activated nor evaluated during this exercise. Selected staff of the Area Offices will serve as Liaison Officers to Risk Counties as assigned. Liaison Officers are exercise participants.

Counties Designated to Participate The three risk counties (Chester, Lancaster and York), in coordination with PEMA, will demonstrate the capability to mobilize appropriate staff, activate their respective Emergency Operations Centers and implement emergency response operations to include sheltering and/or evacuation. County government will provide direction and coordination to risk municipalities. Actual sheltering or evacuation of the general public will be simulated.

Local Emergency Management All affected local municipalities, along with supporting agencies, will participate in the plume exercise. On a rotating basis, local municipalities will be federally evaluated as coordinated by PEMA and their associated county (once per 8 year cycle). They will demonstrate mobilization of staff, activation of their Emergency Operation Center, and implementation of emergency response operations. Some municipalities may be evaluated on Back-up Route Alerting or TCP I ACP operations. See Attachment A Sections 1.A.2, 1.A.3, and 1.A.4 for those locations being federally evaluated.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station VII.

PEMA Liaison Officers Liaison officers will be present at the participating risk county EOCs, the Exelon EOF, and Exelon JIC to provide assistance, guidance, and support. These liaison officers will participate as players in the exercise.

VIII.

Controllers Controllers are not players. Controllers will provide pre-approved injects and information to the players, as appropriate, regarding radiological readings during the monitoring of personnel.

A lead controller will be present in the State EOC during the Plume Phase Exercise (April 27, 2016) and not forthe out of sequence School exercises (March 7-9, 2016).

A controller will be present at each of the emergency worker monitoring I decontaminating stations and public monitoring and decontamination centers that are scheduled for evaluation on the evening of March 7, 2016 at 7:00 p.m. - 9:30 p.m. The controller for these locations is provided by the Utility.

Live radioactive sources will not be used. Exception: individuals tasked with the setup of portal monitoring equipment (if used) will use a standard 1 micro curie Cesium 137 source for the purpose of conducting operational tests. Additionally, appropriate test sources will be available and used to verify the operation of the monitoring I survey instruments per manufacturers' recommendations.

IX.

PEMA Observers PEMA staff, qualified county emergency management personnel, and/or nuclear power plant personnel will be assigned, if required, to key locations for the purpose of observing, noting response actions and conditions, and recording observations for future use. Observers will not take an active part in the proceedings, but will interact with staff members to the extent necessary to fulfill their observer responsibilities. Coaching of players by observers is not permitted except to provide training to participants awaiting a re-demonstration. (Refer to paragraph XIV)

X.

FEMA Evaluators Federal evaluators will be present at the risk and support county EOCs, identified risk municipal EOCs, and at appropriate field locations to evaluate player response to the actual and simulated events in the exercise scenario. FEMA will evaluate about one-68

I I

I XI.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station third of the risk municipalities in Chester, Lancaster and York Counties as identified in this document. The exercise will follow REP Program Manuel (July 2015)

Plume Phase Exercise (April 27, 2016): Federal evaluators will be present at the SEOC and identified risk and support county EOC's to evaluate player response to the actual and simulated events in the exercise scenario. Additionally, one-fourth of the risk municipalities will be federally evaluated. As required, a "floating-evaluator" will be made available for the purpose of evaluating any ORO locations not scheduled to have a federal evaluator, but having a prior issue (Attachment A,Section I.A. I and I.A.2).

Out-of-Sequence - Schools (March 7-9, 2016): Federal evaluators will be present at the identified "out-of-sequence" demonstration sites per Attachment A,Section I.B.1. These include the identified Public School Districts.

Out-of-Sequence - Pennsylvania State Police (March 16, 2016): PSP demonstration will take place at PSP Lancaster Barracks, located at 2099 Lincoln Highway East, Lancaster, Pennsylvania. The PSP briefing will be performed "out-of-sequence" in a demonstration window of 9:30 a.m. to 11:30 a.m.

Out-of-Sequence -Reception Center, Public and Emergency Worker Monitoring and Decontamination Stations, Mass Care Locations (March 7, 2016): Federal evaluators will be present for demonstrations conducted at Reception Centers, Mass Care Centers, and Monitoring I Decontamination Centers (for the public) and Stations (for Emergency Workers) as identified in Attachment A, Sections I.B.3, I.B.4 and I.B.5.

Demonstration Windows In order to provide for more effective demonstrations, as well as, to permit the release of volunteers from exercise play at a reasonable hour, periods ohime (Demonstration Windows) have been designated during which specified actions will be accomplished I demonstrated.

The "demonstration windows" for this exercise are:

A.

Plume Phase Exercise The following out-of-sequence MS-1 hospital demonstrations ware federally evaluated: Ephrata Community Hospital on April 23, 2015, York Hospital on May 28, 2015, and Brandywine Hospital on August 11, 2015 There will not be an evaluation of BRP field teams and R3V for this exercise.

69

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station County and municipal EOC operations will be conducted on the evening of April 27, 2016. (Please refer to the Extent of Play Demonstration Tables, Attachment A, Sections l.A.1 and l.A.2).

The out-of-sequence exercise window for school demonstrations will follow the schedule found in the Demonstration Tables, Attachment A,Section I.B.1 The out-of-sequence interview of PSP traffic control I access control points will be from 9:30 a.m. -11:30 a.m. on March 16, 2016.

The out-of-sequence demonstrations for Reception Centers, Mass Care Centers, and Monitoring I Decontamination Centers (for the public) and Stations (for Emergency Workers) will be conducted from 7:00 p.m. - 9:30 p.m. on March 7, 2016 per Attachment A, Sections I.B.3, l.B.4 and I.B.5.

All demonstrations will commence promptly and, barring any complications, not continue beyond the time of the designated demonstration window.

B.

Post Plume Exercise A post-plume phase exercise is not scheduled during this evaluation.

XII.

Stand-Down All jurisdictions will request approval on a jurisdiction by jurisdiction basis prior to stand-down.

A.

Upon completion of all requirements and confirming with the federal evaluator that all evaluation areas have been demonstrated and/or completed, the risk municipality EOCs may request approval from their county EOC to "stand-down".

B.

Support counties may likewise request approval from the State EOC to terminate the exercise upon completion of all evaluated objectives.

The risk county EOCs will remain operational until the exercise is officially terminated by the State in consultation with the federal evaluator. The SEOC will issue an Exercise Termination Message. If county exercise components are demonstrated and completed, portions of the EOC may be able to stand down.

70

XIII.

XIV.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station General Concepts An emergency plan is drafted to address the generally expected conditions of an emergency. Not everything in the emergency plan may be applicable for a given scenario. The main purpose of an emergency plan is to assemble sufficient expertise and officials so as to properly react to the events as they occur. The responders should not be so tied to a plan that they cannot take actions that are more protective of the public.

Therefore, if, by not following the plan, the responders protect the public equally as well as provided in the plan, it should be noted for possible modification of the plan, but not classified as a negative incident. Furthermore, if, by following the plan there is a failure to protect the public health and safety, it should be noted so that the plan can be modified and the appropriate negative assessment corrected.

Re-demonstrations Any activity that is not satisfactorily demonstrated may be re-demonstrated by the participants during the exercise, provided it does not negatively interfere with the exercise. Refresher training may be provided by the players, observers, and/or controllers. Evaluators are not permitted to provide refresher training. Re-demonstrations will be negotiated between the players, observers, controllers, and evaluators. PEMA may advise the Regional Assistance Committee (RAC) Chair prior to initiating any re-demonstrations. It is permissible to extend the demonstration window, within reason, to accommodate the re-demonstration. Activities corrected from a re-demonstration will be so noted.

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

EVALUATION AREA 1: Emergency Operations Management Sub-element 1.a - Mobilization INTENT This Sub-element is derived from NUREG-0654 I FEMA-REP-1, which requires that OROs have the capability to alert, notify, and mobilize emergency personnel, and activate and staff emergency facilities.

71

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Criterion 1.a.1: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654 I FEMA-REP-1, A.1.a, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; H.3, 4)

Assessment I Extent-of-Play Assessment of the Demonstration Criterion may be accomplished during a biennial exercise, 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 I 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 System 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 I 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 identified through LOA I MOUs must be on the ORO's mobilization list so they can be contacted during an incident, if needed.

72

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station PEMA Negotiated Extent-of-Play:

In all instances, the demonstration of a shift change is NOT required. Twenty-four hour staffing will be demonstrated by means of a roster or staffing chart.

All out-of-sequence players and equipment will be pre-positioned (School District personnel, PSP, TCP/ACP, Reception Centers, Emergency Worker Monitoring and Decontamination Stations, and Monitoring and Decontamination Centers).

Individuals working in state facilities and county EOCs may be pre-positioned for the plume phase.

Pre-positioning of state emergency personnel (Liaison Officers) at the EOF, the Utility JIC and at Risk Counties is appropriate due to the commuting distance from the individual's duty location or residence.

Other locations including municipal EOCs will NOT pre-stage for the Plume Phase exercise but will wait for actual notification per plans and procedures before staffing their duty locations.

BRP Field Teams and R3V are NOT evaluated for this exercise.

Sub-element 1.b - Facilities INTENT This sub-element derives from NUREG- 0654, which provides that Offsite Response Organizations (ORO) have facilities to support the emergency response.

Criterion 1.b.l: Facilities are sufficient to support the emergency response. (NUREG-0654 I FEMA-REP-1, H.3; G.3.a; J.10.h; J.12; K.5.b)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, SA Vs, or by out-of-sequence evaluations.

Responsible OROs must demonstrate, no less than once every 8 years, the availability of fixed facilities that support accomplishment of emergency operations (this includes all alternate and backup facilities). Evaluations are performed for EOCs and JICs, as well as, other fixed facilities such as reception I 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 capabilities, as 73

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station outlined in respective emergency plans I 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.

PEMA Negotiated Extent-of-Play:

Municipalities will demonstrate this criteria during each federal evaluation they receive (generally once per 8 year cycle) and counties will demonstrate this criteria once in each 8 year cycle unless new or substantial improvements occur.

Sub-element 1.c - Direction and Control INTENT This Sub-element is derived from NUREG-0654 I FEMA-REP-1, which requires that OROs have the capability to control their overall response to an emergency.

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 I FEMA-REP-1, A.1.d; A.2.a, b; A.3; C.4, 6)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion may 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 I supplement resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources. Any resources identified through LOA I MOUs must be on the ORO's mobilization list so they may be contacted during an incident, if needed.

PEMA Negotiated Extent-of-Play:

None 74

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Sub-element 1.d - Communications Equipment INTENT This Sub-element is derived from NUREG-0654 I 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 Field Monitoring Teams (FMTs).

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 I FEMA-REP-1, F.1, 2)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion is accomplished initially in a baseline evaluation and subsequently in periodic testing and drills. System familiarity and use must be demonstrated as applicable in biennial or tabletop exercises, 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.

75

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station PEMA Negotiated Extent-of-Play:

The plant will communicate to the risk counties and SEOC utilizing the Dedicated Automatic Ring Down Telephone System (ARD) (Primary) and the commercial telephone system (Secondary). If the plant cannot contact the SEOC, the Power Plant will contact the York County EOC and York County EOC will fulfill the role of primary contact until such time as communications with the SEOC can be made.

Risk counties will communicate with the SEOC via the commercial telephone system (Primary),

email (Secondary) and other systems.

Risk counties will communicate with their risk municipalities via public safety radio frequencies (EMA Radio), commercial telephone, fax, email, or Amateur Radio Communications (ACS I ARES I RACES) or other available means.

BRP Field Teams will demonstrate two or more forms of communications (Field Teams and R3V NOT evaluated for this exercise).

Sub-element 1.e - Equipment and Supplies to Support Operations INTENT This sub-element derives from NUREG-0654 I 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, monitoring instruments, dosimetry, potassium iodide (KI) and other supplies are sufficient to support emergency operations.

(NUREG-0654 I FEMA-REP-1, H.7, 10; 1.7, 8, 9; J.10.a, b, c; J.11, 12; K.3.a; K.5.b)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion is accomplished primarily 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.

76

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 I 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 I procedures. The plans I procedures must include the forms to be used for documenting emergency worker ingestion of Kl, as well as, a mechanism for identifying 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 I 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 I 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.

77

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 I 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 I procedures. An appropriate radioactive check source must be used to verify proper operational response for each low-range radiation measurement instrument (less than IR/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 Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

Mutual Aid Resources: If the incoming resources arrive with their own equipment (i.e.,

monitors and I or dosimetry) they will be evaluated by REP Program standards. FEMA will not inventory equipment that is not part of the REP Program. If an agency has a defined role in the REP Plan, they are subject to the planning process and standards, as well as the guidance ofthis Manual.

PEMA Negotiated Extent-of-Play:

Radiological Survey Instruments are calibrated per manufactures' recommendations. Neither CDV-700 nor CDV-138 instruments are in use in the area.

Evaluation of DRD and KI quantities will be verified using inventory sheets. DRDs or KI will not be removed from storage locations and boxes I packages will not be opened, however, lot numbers and expiration dates should be visible for inspection. KI questions will be addressed through interviews.

78

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Annual Direct Reading Dosimeter leakage testing verification or KI extension letters (as appropriate) will be available to the evaluator.

Pennsylvania Support Counties do not have DRDs or KI but those responsible for reception centers, and I or monitoring and decontamination centers will have PRDs.

All DRDs "read" in units of Roentgens. The Commonwealth counties and municipalities do not use DRDs which read in milli-Roentgens.

Reception Centers shall be evaluated on their ability to use maps or other documentation to direct evacuating persons to the correct Monitoring I Decontamination Centers and/or Mass Care Centers (as Applicable). If Reception Centers are co-located with Monitoring I Decontamination Centers and Mass Care Centers the use of maps or documents to provide direction does not apply.

BRP Field Teams and R3V will NOT be evaluated for this exercise.

ASSESSMENT AREA 2; Precautionary and I or Protective Action Decision Making Sub-element 2.a - Emergency Worker Exposure Control INTENT This Sub-element is derived from NUREG-0654 I 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 I procedures, to authorize emergency worker exposure limits to be exceeded for specific missions.

Radiation exposure limits for emergency workers are the recommended accumulated dose limits or exposure rates that emergency workers may be permitted to incur during an emergency.

These limits include any pre-established administrative reporting limits (that take into consideration total effective dose equivalent (TEDE) or organ-specific limits) identified in the ORO's plans I procedures.

Criterion 2.a.1: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers, including provisions to authorize radiation exposure in excess of administrative limits or protective action guides. (NUREG-0654 I FEMA-REP-1, C.6; f; K.3.a; K.4) 79

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Assessment I Extent-of-Play Assessment of this Demonstration Criterion must be assessed concurrently with a licensee exercise and may be demonstrated in a biennial or 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 I 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 I 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.

PEMA Negotiated Extent-of-Play:

Radiological briefings (which may be supported by video) will be provided to address exposure limits, procedures to replace those personnel approaching exposure limits and how permission to exceed limits is obtained from the municipality and county. Emergency workers will also be briefed on when to take KI and on whose authority. Distribution of KI to emergency workers will be simulated. The Commonwealth, under direction of the Department of Health, will authorize use of KI when radiological conditions warrant its use. If the scenario has no potential for a radiological release, the decision on the distribution and administration of KI as a protective measure for emergency workers and the authorization process for emergency workers to exceed pre-authorized levels can be addressed through an interview.

The completion of a "Dosimetry-KI Report Form" will be demonstrated.

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 I 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 PA Gs.

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 I procedures or EPA' s Manual of Protective Action Guides and Protective Actions for Nuclear Incidents and other criteria, such as plant conditions, licensee P ARs, coordination of P ADs 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.

Criterion 2.b.l: 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-0654IFEMA-REP-1,1.10 and Supplement 3)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion 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 I procedures, to develop P ARs 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 P ARs 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 P AG to which they will be compared. P ARs 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.

81

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station PEMA Negotiated Extent-of-Play:

BRP will validate plant dose projections and coordinate resolution of differences if more than a factor of 10. If the scenario has no radiological release, or potential of a radiological release, the decision-making process used to make P ADs can be addressed through an interview (Note: BRP not evaluated for this exercise).

Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make precautionary and I or protective action decisions for the general public (including the recommendation for the use of KI, if ORO policy).

(NUREG-0654 I FEMA-REP-1, A.3; C.4, 6; D.4; J.9; J.10.e, f, m)

Assessment/Extent-of-Play Assessment of this Demonstration Criterion must 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 precautionary and I or protective action decisions. OROs must demonstrate the capability to make initial precautionary and I or protective action decisions 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 P ARs from the utility and ORO staff. In addition, a subsequent or alternate precautiop_ary and I or protective action decision 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, HAZMA T, 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 P ARs 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 I 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 I procedures or projected thyroid dose compared with the established P AG for KI administration. The KI decision-making process must involve close coordination with appropriate assessment and decision-making staff.

82

Unclassified Radiological.Emergency Preparedness Program (REP)

After. Action Report/Improvement Plan Peach Bottom Atomic Power Station If more than one ORO is involved in decision making, all appropriate OR Os must communicate and coordinate P ADs 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.

~

PEMA Negotiated Extent-of-Play:

The Commonwealth, in developing a PAD, will base the decision upon plant recommendation and condition, confirmation and advice ofBRP, environmental data, impediments, and other factors that may impact the decision. If the scenario has no radiological release, or potential of a radiological release, the decision-making process used to make P ADs can be addressed through an interview.

The Commonwealth will include Maryland and it's affected counties in the decision making process but they may make a decision independent of ours.

Sub-element 2.c - Precautionary and I or Protective Action Decisions Consideration for the Protection of Persons with Disabilities and Access I Functional Needs INTENT This Sub-element is derived from NUREG-0654 I FEMA-REP-1, which requires that OROs have the capability to determine precautionary and I or protective action decisions, including evacuation, sheltering, and use of KI, if applicable, for groups of persons with disabilities and access I 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 I functional needs that are, or potentially will be, affected by a radiological release from an NPP.

Criterion 2.c.1: Protective action decisions are made, as appropriate, for groups of persons with disabilities and access I functional needs. (NUREG-0654 I FEMA-REP-1, D.4; J.9; J.10.d, e)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise that would include the use of plant conditions transmitted from the licensee.

Usually it is appropriate to implement evacuation in areas where doses are projected to exceed the lower end of the range of PA Gs, except for incidents when~ there is a high-risk 83

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan

,Peach Bottom Atomic Power Station 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 I communicated with the Incident Command. In situations where an institutionalized population cannot be evacuated, the ORO must consider use of KL Applicable OROs must demonstrate the capability to alert and notify all public school systems I 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 I districts during the exercise.

The OROs must demonstrate how the decision-making process takes those with disabilities and access I functional needs (e.g. nursing homes, correctional facilities, licensed day cares, mobility-impaired individuals, and transportation-dependent individuals) into account.

In accordance with plans I procedures, OROs and/or officials of public school systems I 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 Emergency Classification Level (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).

Since other agencies place requirements on hospitals to prepare for contaminated patients, the REP program has no need to evaluate hospitals in-the EPZ that need to evacuate, or the facilities that are receiving these evacuees, nor does the ORO have the responsibility to provide training or dosimetry to these hospitals I facilities. Additionally, hospital evacuation plans do not need to be reviewed or tested by the REP program.

PEMA Negotiated Extent-of-Play:

If the scenario has no radiological release, or potential of a radiological release, the decision-making process used to make protective action recommendations can be addressed through an interview.

Sub-element 2.d. - Radiological Assessment and Decision-Making for the Ingestion Exposure Pathway INTENT This Sub-element id derived from NUREG0654/FEMA-REP-1, which requires that OROs have the means to assess the radiological consequences for the ingestion exposure pathway, relate 84

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station them to the appropriate P AGs, and make timely, appropriate P ADs to mitigate exposure from the pathway.

During an incident at the 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 to years.

Criterion 2.d.l: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are based on the ORO's planning criteria.

(NUREG0654/FMEA-REP-1, A.3; C.1, 4; D.4; J.9, 11)

Assessment I Extent of Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise that would include the use of plant condition transmitted from 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 I 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 analysis ofrepresentative 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 30-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 I procedures. The plans I procedures contain PA Gs 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 OFO 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. These decisions include tracking agricultural products entering and leaving the EPZ. Demonstration of 85

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomi'~ Power Station plans and procedures which use traffic access control points to track agricultural products entering and leaving the EPZ may be conducted through interview.

ORO will use Federal resources, as identified in the Nuclear I Radiological Incident Annexes of the National Response Plan 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.

PEMA Negotiated Extent-of-Play:

This sub-element will not be evaluated during this exercise.

Sub-element 2.e. - Radiological Assessment and Decision-Making Concerning Relocation, Re-entry, and Return Intent This sub-element is derived from NUREG0654 I FEMA-REP-l, 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.

Criterion 2.e.1; Timely post-plume phase relocation, reentry, and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the ORO's plan and I or procedures. (NUREG0654IFEMA-REP-1.1-10; J.9; K.3; M.1)

Assessment I Extent of Play Assessment of the Demonstrated Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a biennial or tabletop exercise that would include the use of plant conditions transmitted from the licensee.

Relocation; OROs must demonstrate the capability to estimate integrated dose in contaminated areas and compare these estimates with PA Gs; 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 PA Gs; 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 PA Gs. Determination of areas to be 86

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station restricted must be based on factors such as the mix of radionuclides in deposited materials, calculated exposure rates versus the PA Gs, 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, location 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 populating 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 I 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. OR Os 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.

87

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station This sub-element will not be evaluated during this exercise.

EVALUATION AREA 3 Protective Action Implementation Sub-element 3.a - Implementation of Emergency Worker Exposure Control INTENT This Sub-element is derived from NUREG-0654 I FEMA-REP-1, which requires that O:ROs 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 (ALARA) principle as appropriate.

Criterion 3.a.1: The OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans I 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 I FEMA-REP-1, K.3.a, b; K.4)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during 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 ofTEDE and maximum exposure limits, for those emergency workers involved in lifesaving activities, contained in the ORO's plans I procedures.

88

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Each emergency worker must have basic knowledge of radiati()n exposure limits as specified in the ORO's plans I 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 tum-back values are reached. The emergency worker must report accumulated exposures during the exercise as indicated in the plans I

- procedures. OROs must demonstrate the actions described in the plans I 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., lifesaving, 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 lifesaving 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 89

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station using KI whether or not the scenario drives the implementation of KI use. This can be accomplished by an interview with the evaluator.

PEMA Negotiated Extent-of-Play:

Radiological briefings will be provided to address exposure limits, procedures to replace personnel approaching limits, and how permission to exceed limits is obtained from the municipality and county. Emergency workers will al.so be briefed on when to take KI and on whose authority.

Distribution of KI will be simulated. OROs should also demonstrate the use of all applicable dosimetry forms. The completion of a "Dosimetry-KI Report Form" will be demonstrated.

At any time, players may ask other players or supervisors to clarify radiological information.

Evaluation of emergency worker KI quantities will be verified using inventory sheets. KI will not be removed from storage locations and boxes will not be opened. KI questions will be addressed through interviews. Personnel assigned to operate Monitoring I Decontamination centers and stations are not issued DRDs or KI since the centers I stations are located outside the EPZ. Simulated PRDs with mock serial numbers may be used to simulate issue.

Emergency worker~ who are assigned to low exposure rate areas, e.g., at counting laboratories, emergency operations centers, and communications centers, may have individual permanent record dosimeters or they may be monitored by dosimeters strategically placed in the work area.

In Pennsylvania this will be accomplished through the use of an area kit. The area kit process is explained in State, County and Municipal Plans.

Standard issue of dosimetry and KI for each category of emergency worker is as follows:

Category A: 1PRD,1 DRD, and 1 unit of KI Category B: 1 PRD and 1 unit of KI (Area Kit includes 2 DRDs)

Category C: 1 PRD In Pennsylvania, emergency workers outside of the EPZ do not have tum-back values.

All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP), will make the dosimetry equipment (and KI) available for inspection by the Federal Evaluator. In order to demonstrate an understanding of the use of the dosimetry equipment, KI and associated forms; the location need only remove and distribute I issue a maximum of six (6) units of dosimetry from their inventory. Simulation PRDs with mock serial numbers and simulated KI may be issued. The location will demonstrate filling out a minimum of two (2) Dosimetry I KI Report Form.

90

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station BRP Field Teams and R3V will not be evaluated during this exercise.

Sub-element 3.b - Implementation of KI Decision for Institutionalized Individuals and the General. Public INTENT This Sub-element is derived from NUREG-0654 I FEMA-REP-1, which requires that OROs have the capability to provide KI for institutionalized individuals, and, if in the plans I 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 I procedures. Provisions must include the availability of adequate quantities, storage, and means of distributing KI.

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 and the general public is maintained. (NUREG-0654 I FEMA-REP-1, J.10.e, f)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during 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 make KI available to institutionalized individuals, and, where provided for in their plans I 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 I procedures.

91

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station PEMA Negotiated Extent-of-Play:

Within Pennsylvania, the Pennsylvania Department of Health is responsible for distribution of KI to the general public located within the EPZ. Pre-distribution is accomplished on an annual basis. Pennsylvania does not distribute KI at reception centers.

Evaluation of emergency worker KI quantities will be verified using inventory sheets. KI will not be removed from storage locations and boxes will not be opened. KI questions will be addressed through interviews.

Personnel assigned to operate Monitoring I Decontamination centers and stations are not issued PRDs or KI since the centers I stations are located outside the EPZ. Simulated PRDs with mock serial numbers may be used to simulate issue (Maximum of 6 issued). KI may be simulated for issue.

Sub-element 3.c - Implementation of Precautionary and I or Protective Actions for Persons with Disabilities and Access I Functional Needs INTENT This Sub-element is derived from NUREG-0654 / FEMA-REP-1, which requires that OROs have the capability to implement precautionary and I or protective action decisions, including evacuation and I or sheltering, for all persons with disabilities and access I functional needs. The focus is on those persons with disabilities and access I functional needs that are (or potentially will be) affected by a radiological release from an NPP.

Criterion 3.c.1: Precautionary and I or Protective Action Decisions are implemented for persons with disabilities and access I functional needs other than schools within areas subject to protective actions.

(NUREG-0654 I FEMA-REP-1, J.10.c, d, e, g)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion may 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 alert and notify (i.e., provide P ARs and emergency information and instructions to) persons with disabilities and access I functional needs, including hospitals I medical facilities, licensed day cares, nursing homes, correctional facilities, and mobility-impaired and transportation-dependent individuals. OROs must 92

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station demonstrate the capability to provide for persons with disabilities and access I functional needs in accordance with plans I procedures.

Contact with persons with disabilities and access I 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.

Since other agencies place requirements on hospitals to prepare for contaminated patients, the REP Program has no need to evaluate hospitals in the EPZ that need to evacuate, or the facilities that are receiving these evacuees, nor does the ORO have the responsibility to provide training or dosimetry to these hospitals I facilities. Additionally, hospital evacuation plans do not need to be reviewed or tested by the REP program.

PEMA Negotiated Extent-of-Play:

The names, locations and contact information of identified individuals with identified disabilities and access I functional needs are maintained on a list at their respective muniCipal EOC (based upon residential jurisdiction). Copies of these lists will not be provided to the evaluators; however, evaluators will be allowed to inspect the lists during the exercise.

Evaluators may ask, by interview, about the transportation plans concerning transportation staging, source of vehicles, radiological protection of the drivers I emergency workers, and routes or assignments of vehicles for transportation of persons with disabilities and access I functional needs. No buses or drivers will be mobilized.

Initial contact with special populations and reception facilities will be actual (hospitals, nursing homes and correctional facilities). All subsequent calls will be simulated. Actual contacts (up to two per Risk County) will be made with transportation providers as per plan. All actual and simulated contacts should be logged.

Criterion 3.c.2: OROs I School officials implement protective actions for schools.

(NU~G-0654 I FEMA-REP-1, J.10.c, d, e, g)

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

School systems I districts (these include public and private schools, kindergartens, and preschools) must demonstrate the ability to implement precautionary and I or protective action decisions for students. The demonstration must be made as follows: each school system I 93

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station district within the I 0 mile EPZ must demonstrate implementation of protective actions; at least one school per affected system I district must participate in the demonstration; and 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 I principals and transportation director I 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 I 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 I procedures as negotiated in the Extent-of-Play Agreement.

Additionally, hospital evacuation plans do not need to be reviewed or tested by the REP program.

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

PEMA Negotiated Extent-of-Play:

School Students will not be involved during the exercise. Actions and activities associated with the demonstration of Criterion 3.c.2 will be limited to the School District Administration key personnel and the County. Evacuation of students will be conducted through an interview process with School District personnel or the building principal.

The role of the bus driver may be conducted through an interview with school or transportation officials (or designee) if a bus driver is not available. Actual demonstration of the bus route is not required and will not be demonstrated. Maps or route descriptions will be available for illustration purposes.

94

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Risk County school plans do not require communications between the school and vehicles. Bus drivers are not considered emergency workers and therefore do not require dosimetry.

Private schools, private kindergartens, and day care centers do not participate in REP exercises.

However, OROs will be prepared to show evaluators lists of these facilities that they will contact in the event of an emergency in accordance with plans and procedures. Any simulated contacts will be logged.

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 I procedures, including relocation and restriction of access to evacuated I 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.

I Criterion 3.d.l: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel. (NUREG-0654 I FEMA-REP-1, A.3; C.1, 4; J.10.g, j)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, 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 P ADs (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.

95

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station PEMA Negotiated Extent-of-Play:

Municipal Traffic and Access control will be demonstrated by interview at the applicable EOC of jurisdiction. The traffic I access control personnel will not be deployed to the traffic I access control point(s). If the designated assignment is a location within the EPZ, a radiological briefing will be provided to the assigned individuals. Reception Centers shall provide a traffic control plan for the location being evaluated.

Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654 I FEMA-REP-1, J.10.k)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, 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. In demonstrating this capability, the impediment must remain in place during the evacuation long enough that re-routing of traffic is required and must also result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

When, due to specifics of the scenario or jurisdiction, the impediment cannot be located on an evacuation route, it must be located so as to impact the evacuation. When not possible, actual dispatch of resources need not be physically demonstrated; however, all contact, actual and simulated, must be logged.

PEMA Negotiated Extent-of-Play:

County EOCs will demonstrate the ability to identify and take appropriate actions concerning impediments to evacuation by inject or interview. Actual dispatch of resources to deal with impediments, such as tow trucks, need not be demonstrated; however, simulated contacts will be logged. If the scenario does not lead to evacuation the criteria shall be deemed complete if the ORO can describe to the evaluator the actions they would take to overcome a major traffic impediment during an evacuation and how such actions would be communicated to the public and affected OROs. (Risk Counties only) 96

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Sub-element 3.e - Implementation of Ingestion Pathway Decisions Intent This Sub-element is derived from NUREG0654 I 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.

Criterion 3.e.1: The ORO demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk, and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective actions. (NUGEG0654 I FEMA-REP-1, A.3; C.1, 4; J.11 Assessment I Extent of Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, and 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 location 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 I 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.

PEMA Negotiated Extent-of-Play:

This sub-element will not be evaluated during this exercise Criterion 3.e.2; Appropriate measures, strategies, and preprinted instructional materials are developed for implementing protective action decisions for contaminated water, food products, milk, and agricultural production. (NUREG0654 I FEMA-REP-1, G.1, J.9, 11)

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

97

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 instruction 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 communication 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.

PEMA Negotiated Extent-of-Play:

This sub-element will not be evaluated during this exercise Sub-element 3.f - Implementation of Post-Plume Phase Relocation, Re-entry, and Return Decisions Intent This Sub-element is derived from NUREG0654 I 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.

Criterion 3.f.1: Decisions regarding controlled reentry, relocation, and return of individuals during the post-plume phase are coordinated with appropriate organizations and implemented. (NUREG0654 I FEMA-REP-1, E.7; J.lOj; J.12; K.5.b; M.1, 3)

Assessment I 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 98

~.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station contamination will not expose the general public to doses that exceed the relocation P AGs.

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) P AGs.

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 home 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; OR Os 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. OR Os 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 the evacuated area during the post-emergency phase must be limited to the lowest radiological exposure commensurate with completing their missions. Monitoring and deco.ntamination facilities will be established as appropriate.

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 I Radiological Incident Annex, and other resources (e.g., compacts or nuclear insurers), as necessary, if available.

99

)

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

PEMA Negotiated Extent-of-Play:

This sub-element will not be evaluated during this exercise EVALUATION AREA 4 Field Measurement and Analysis 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 I 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 a 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.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.10.a)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial, or tabletop exercise. Other means may include drills that would fully demonstrate technical proficiency.

Responsible OR Os 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 100

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Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station FMTs' 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 FMTs, 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.

OROs will use Federal resources as identified in the NRF Nuclear I 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.

PEMA Negotiated Extent-of-Play:

Field Team Control will be performed near the 10 mile EPZ using the DEP Radiological Rapid Response Vehicle (R3V). Field Team control is expected to initially be out-of-sequence with the plume timeline. During the exercise the field teams will be directed to take measurements in locations to provide information sufficient to characterize the plume and impacts. In addition to field team measurements, remote detectors will be deployed by the field teams near the expected plume pathway. These detectors will automatically transmit data to the R3V. These detectors will be used to keep field teams dose ALARA. BRP Field Teams and R3V will NOT be evaluated for this exercise.

In the event the scenario has no radiological release, a report of background radiation by the FMT will signify successful demonstration of the criterion.

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 I FEMA-REP-1, C.l; H.12: 1.8, 9; J.10.a) 101

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Assessment I Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise.

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

technical proficiency.

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.

Coordination concerning transfer of samples, including a chain-of-custody form(s), to a radiological laboratory(ies) must be demonstrated.

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 I procedures.

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

PEMA Negotiated Extent-of-Play:

Measurements will be made by Department of Environmental Protection (DEP) Bureau of Radiological Protection (BRP), in accordance with State Radiological Annex E, Appendix 6 and the BRP Standard Implementing Procedures (IPs). Two mobile monitoring teams from BRP will demonstrate ambient radiation monitoring and radioiodine and particulate sampling. Field Teams will be equipped with appropriate dosimetry and KI. Both teams will participate but not be evaluated by FEMA. Each team will be directed to monitoring location and perform actual radiation measurements at each location. Measurements may consist of truck installed radiation monitor or hand-held radiation instruments. The team will explain by interview the procedures they follow for air sampling. Teams will take air samples as directed at various locations, if conditions are appropriate for radio iodine sampling and relay information to the R3 V. In place of silver zeolite cartridges, charcoal cartridges will be used for the exercise. All measurements will be forwarded to the R3V immediately upon obtaining data. BRP Field Teams and R3V will NOT be evaluated for this exercise.

Sub-element 4.b - Post Plume Phase Field Measurements and Sampling This sub-element will not be evaluated during this exercise.

102

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Sub-element 4.c - Laboratory Operations This sub-element will not be evaluated during this exercise.

EVALUATION 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 I 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).

Criterion 5.a.1: Activities associated with primary alerting and noti~cation 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 I FEMA-REP-1, E.5, 6, 7)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, drills, or operational testing 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 I notification and disseminate the information I 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 103

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station signal activation should be simulated, not performed. Evaluations of EAS broadcast stations

• may also be accomplished through SA Vs.

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; 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 I 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 I procedures as negotiated in the Extent-of-Play Agreement.

PEMA Negotiated Extent-of-Play:

The Commonwealth of Pennsylvania has implemented a Statewide EAS Control system in cooperation with the Pennsylvania Association of Broadcasters per the State Emergency Communications Committee and Pennsylvania Emergency Alert System State EAS Plan (September 23, 2010 and revised on November 2, 2011). The SEOC (PEMA) is the initiating point for the activation of the EAS. Risk Counties have the control equipment for activation of sirens. Coordination will occur between the SEOC and the affected counties with respect to the Alert and Notification System (ANS) process as to when the sirens and EAS messages will occur. Sirens will be coordinated and the sounding simulated at the appropriate time with the simulated activation of EAS taking place approximately 3 minutes following the simulated activation of the sirens. Regular Broadcasting will not be interrupted on the EAS Stations. All 104

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station subsequent actions to broadcast stations will be simulated. Broadcast of the message( s) or test message(s) is not required and not requested. Counties may elect to provide Subsequent News Bulletins or County-Specific EAS messages to their EAS stations.

Following the decision to activate the alert and notification system, in accordance* with the ORO's plan and/or procedures, ANS activation should be accomplished in a timely manner for primary alerting I notification. This action will not be subject to specific time requirements.

All actions to broadcast stations will be simulated. Systems that use automatic sending technology may be demonstrated by explanation during an interview.

Each evaluated municipality per Risk County will demonstrate, by interview, route alerting of the hearing impaired residents within their jurisdiction. Hearing impaired notification teams will not be deployed.

Criterion 5.a.2: [RESERVED]

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)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, drills, or operational testing of equipment that would fully 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, 105

Unclassified Radiological Emerg~ncy Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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.

PEMA Negotiated Extent-of-Play:

Plans specify that route alerting is used as a back up to the sirens. County Liaisons will provide an inject to the risk counties that a siren has failed. The county will demonstrate contacting one municipal EOC in regards to the failed siren in that municipality. The municipal EOC will then dispatch a route alert team to cover one route alert sector affected by the failed siren. All other routes will be simulated. Route Alert Teams should finish their route in about 45 minutes from time of siren failure.

OR Os may utilize IP AW s or other public alerting systems in accordance with their plans but use of such systems will not negate the need to provide for demonstration of route alerting by the ORO.

Sub-element 5.b -Emergency Information and Instructions for the Public and the Media INTENT This Sub-element is derived from NUREG-0654 I 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 I 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 I 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".

Criterion 5.b.l: OROs provide accurate subsequent emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654 I FEMA-REP-1, E.5, 7; G.3.a, G.4.a, c) 106

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Assessment I Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, or drills.

The responsible ORO personnel I 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 P ADs 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 I functional needs, and public inquiry hotline telephone number) to assist the public in carrying out the P ADs 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 ~.a.I 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 I procedures.

OROs must demonstrate the capability to develop emergency information in a non-English language when required by the plans I procedures.

If ingestion pathway measures are exercised, OR Os 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 I 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 107

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station media briefings and distribute media releases as the inddent 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 P ADs 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 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 I communicated with appropriate security authorities, (e.g., law enforcement and NPP security agencies) in accordance with ORO plans I procedures.

PEMA Negotiated Extent-of-Play:

Subsequent emergency information and instructions should be provided to the public and the media in a timely manner. This will not be subject to specific time requirements. One media briefing will be demonstrated in each risk county.

Risk Counties will receive and handle "Public Inquiry" messages via their individual "Public Inquiry" processes (in compliance with NIMS terminology, Rumor Control is now considered to be "Public Inquiry"). Counties will receive approximately ten (10) public inquiry calls from the State Exercise Cell assigned this responsibility. Counties will be expected to receive and log the calls, identify any trends and take appropriate actions to include follow-up message development, distributions and/or briefings.

EVALUATION AREA 6 Support Operation I Facilities Sub-element 6.a - Monitoring, Decontamination, and Registration of Evacuees INTENT This Sub-element is derived from NUREG-0654 I FEMA-REP-1, which requires that OROs have the capability to implement radiological monitoring and decontamination of evacuees, 108

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 center facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees. (NUREG-0654 I FEMA-REP-1, A.3; C.4; J.10.h; J.12)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, 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 I instrumentation I 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 ofresources can be demonstrated with valid documentation (e.g., MOU I LOA, etc.) reflecting how necessary equipment would be procured for the location. Plans I procedures must indicate provisions for service anim'als.

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 I 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, camcorder~, or written records are all acceptable means for registration.

Monitoring activities shall not be simulated. Monitoring personnel must explain use of trigger I action levels for determining the need for decontamination. They must also explain the 109

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station procedures for referring any evacuees who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans I procedures.

Decontamination of evacuees may be simulated and conducted by interview. Provisions for separate showering and same-sex monitoring 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 I action level or have been placed in a secure area until they can be monitored and decontaminated, if necessary.

In accordance with plans I procedures, individuals found to be ~lean after monitoring do not need to have their vehicle monitored. These individuals do notrequire 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 held in a secure area or monitored and decontaminated (if applicable) arid do require confirmation that their vehicle is being held in a secure area or free from contamination prior to entering the congregate care areas.

PEMA Negotiated Extent-of-Play:

Radiological monitoring demonstration sites should possess a roster of the monitoring personnel, as well as, providing a means by which mass care or others could verify that the person has been monitored and has been deemed uncontaminated. The Radiological Monitoring station(s) should be prepared to monitor 20 percent of the risk population within a 12-hour period as allocated to that location. In some cases Reception Centers, Monitoring and Decontaminations Centers, and/or Mass Care centers may be collocated.

At each reception center, a minimum of three volunteer evacuees will be processed, briefed, issued the appropriate strip map or directions, and instructed to proceed to a mass care center designated for demonstration of monitoring, decontamination, and registration. A sample of the 110

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station appropriate strip maps or directions will be made available for the demonstration unless collocated with mass care and monitoring I decontamination. As negotiated with FEMA, this criterion will be demonstrated but not be evaluated because registration is not done at the reception center.

One mass care center and one mass care monitoring I decontamination center will be demonstrated per support county during the out-of-sequence window. The support counties will provide space at designa~ed mass care centers or reception centers for operation of monitoring I decontamination centers. Schematics of these monitoring I decontamination centers will be available to show the organization within the facility and space management for monitoring and

• decontamination. Procedures will be demonstrated to evidence the separation of contaminated and non-contaminated (clean) individuals.

At the evacuee monitoring I decontamination center, a minimum of six (6) volunteer evacuees will be monitored (or one volunteer evacuee may be monitored six times). Suitable radiological monitoring instruments will be issued to and demonstrated by the initial monitoring team(s). A monitoring team consists of one monitor and one recorder equipped with one survey instrument.

Those individuals found to be free of "contamination", based upon scenario injects, will be directed to the mass care registration point for further processing. Note: Actual radiological sources will not be attached to or hidden upon the volunteer evacuees but sources may be used by operators to verify proper equipment calibration. Note: If portal monitors are used, the Portal Monitor Extent-of-Play described below shall be used.

One of the simulated evacuees, based upon controller injects, will not be able to be decontaminated. Discussions concerning the processing of contaminated personnel will include capabilities and written procedures for showering females separate from males. Showering will be simulated, water will not be used. Note: If portal monitors are used, the Portal Monitor Extent-of-Play described below shall be used.

Monitoring I decontamination centers are not issued DRDs or KI since the centers and stations are outside the EPZ. Category "C" Dosimetry applies. Permanent Record Dosimeters (PRD's) may be simulated.

Radiation readings I contamination data for the evacuees and vehicle will be provided by the controller as appropriate based upon information contained in the scenario package. Set-up of the facility will be performed the same as for an actual emergency with all route markings and contamination control measures in place including step-off pads. Long runs of plastic covered with paper will not be demonstrated, but the materials shall be available and explained.

Positioning of a fire apparatus on-site may be simulat~d if otherwise required.

Participants should be able to describe how vehicles are identified for radiological screening and plans or layouts should show the locations and movements of vehicles.

111

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Water from decontamination activities may go directly to a storm drain or other sewer or drain system or area normally designated for wastewater that has been used for bathing or washing of vehicles and or equipment.

Portal Monitor Use: Risk and Support counties may, during this exercise, utilize portal monitors to monitor simulated evacuees and/or emergency workers. The monitoring I decontamination team requirements will be based on the portal monitor capabilities as applicable based on the procedure I guidelines, and the recommendations of the manufacturer.

PEMA guidance shall apply. Note that most Portal Monitors are verified to be calibrated by an operator passing through the Portal Monitor with a radioactive source at head, mid, and ankle heights. For locations utilizing multiple portal monitors only one working portal monitor needs to be demonstrated.

Sub-element 6.b - Monitoring and Decontamination of Emergency Workers and their Equipment and Vehicles INTENT This Sub-element is derived from NUREG-0654 I 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 I ORO has adequate procedures and resources to accomplish monitoring and decontamination of emergency workers and their equipment and vehicles.

(NUREG-0654 I FEMA-REP-1, K.5.a, b)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, drills, or SAV.

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 I 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 I action levels and procedures stated in the ORO plans I procedures. Monitoring of emergency workers does not have to meet the 12-hour requirement. However, appropriate monitoring procedures must be 112

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 he 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 monitoring 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.

Monitoring activities shall not be simulated. Monitoring personnel must explain use of trigger I 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 I procedures.

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.

PEMA Negotiated Extent-of-Play:

At the emergency worker monitoring I decontamination stations schematics of these monitoring I decontamination stations will be available to show organization and space management. One emergency worker will be monitored. Discussions concerning processing of contaminated personnel will include capabilities and written procedures for showering females separate from males. Showering will be simulated, water will not be used. Suitable radiological monitoring instruments will be issued to the initial monitoring team. If portal monitors are used, the Portal Monitor Extent-of-Play described below shall be used.

Emergency worker station personnel will consist of a minimum of one monitor and one recorder and sufficient personnel to demonstrate monitoring of at least one vehicle. The evaluator will 113

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station request that vehicle decontamination procedures be explained after the vehicle (with simulated contamination) has been monitored. One radiological survey meter, wiffbe issued to each vehicle monitoring I decontamination team. One vehicle and/or piece of equipment will not be able to be decontaminated. Simulated radiation contamination data will be included in the scenario package, and injected by a controller. Set-up of the facility will be performed as closely as possible to that for an actual emergency with all route markings in place.

Decontamination capabilities and provisions for vehicles and/or equipment that cannot be decontaminated will be simulated and conducted by interview. Water will NOT be used.

Radiation readings I contamination data for the emergency worker and vehicle will be provided by the controll~r as appropriate based upon information contained in the scenario package. Set-up of the facility will be performyd the same as for an actual emergency with all route markings and contamination control measures in place including step-off pads. Long runs of plastic covered with paper will not be demonstrated, but the materials shall be available and explained.

Positioning of a fire apparatus on-site may be simulated if otherwise required.

Portal Monitor Use: Risk and Support counties may, during this exercise, utilize portal monitors to monitor simulated emergency workers. The monitoring I decontaniination team requirements will be based on the portal monitor capabilities as applicable based on the procedure I guidelines, and the recommendations of the manufacturer. Note: PEMA guidance shall apply. Note that most Portal Monitors are verified to be calibrated by an operator passing through the Portal Monitor with a radioactive source at head, mid, and ankle heights. For locations utilizing multiple portal monitors only one working portal monitor needs to be demonstrated.

Emergency Worker monitoring and decontamination station personnel are not issued DRDs or KI since the centers and stations are outside the EPZ. Category "C" Dosimetry applies.

Permanent Record Dosimeters (PRD's) may be simulated. Water from decontamination activities may go directly to a storm drain or other sewer or drain system or area normally designated for wastewater that has been used for bathing or washing of vehicles and or equipment.

Sub-element 6.c - Temporary Care of Evacuees INTENT This Sub-element is derived from NUREG-0654 I FEMA-REP-1, which requires OROs to have the capability to establish relocation centers in host I support jurisdictions. The American Red Cross normally provides congregate care in support of OR Os under existing letters of agreement.

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 114

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 I FEMA-REP-1, J.10.h, J.12)

Assessment I ~xtent-of-Play Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, drills, 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 I support jurisdictions based on their all-hazard sheltering experience and what is historically relevant for that particular area. 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 expeetations 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 I action level.

In accordance with plans I 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 does 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

'115

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station, 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.

PEMA Negotiated Extent-of-Play:

Each of the risk or support counties with mass care-centers will demonstrate the operation of one mass care center during the out-of-sequence window. Floor plans with flow diagramsbfthe mass care centers will be available to show organization within the facility and space management during a real emergency. Mass care center locations are listed in the demonstration tables "Demonstration of Mass Care Centers (Attachment A,Section I.B.4)".

Personnel, at a minimum, will consist of one manager and one assistant for each mass care center opened during the out-of-sequence window. The evaluator will expect to see sources and quantities of equipment and supplies, as well as, a staffing chart by job title for 24-hour staffing. Schematics of these mass care centers will be available, during the demonstration window, to show organization within the facility and space allocation for the registration and sheltering the evacuating public.

Necessary signs, directional arrows and forms will be available and used to demonstrate registration, at a minimum, of three evacuees requiring emergency housing. Evacuees will be shown the location where they would be housed in an actual situation. Bedding, cots, food, etc.

normally associated with mass care will not be moved to the site, but the sources of those items should be explained to FEMA evaluators.

AMERICAN RED CROSS SUPPORT COUNTY CHAPTERS For Lancaster and York Counties:

American Red Cross of Central Pennsylvania 1804 North Sixth Street Harrisburg, Pennsylvania 17102 Chris Weidenhammer, Regional Disaster Program Officer, 717-234-3101 Chris. Weidenhammer@redcross.org For Chester County:

American Red Cross of Southeastern Pennsylvania 23rd & Chestnut Streets Philadelphia, Pennsylvania 19103 Leo Pratte, Regional Disaster Program Officer, 215-299-4822, Leo.Pratte@redcross.org 116'

I Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Sub-element 6.d - Transportation and Treatment of Contaminated Injured Individuals INTENT This Sub-element is derived from NUREG-0654 I FEMA-REP-l, which requires that OROs have the capability to transport contaminated injured individuals to medical facilities with' the capability to provide medical services.

Criterion 6.d.l: The facility I ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to contaminated injured individuals. (NUREG-0654 I FEMA-REP-1, F.2; H.10; K.5.a, b; L.1, 4)

Assessment I Extent-of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, an actual event, or drills. FEMA has determined that these capabilities have been enhanced and consistently demonstrated as adequate; therefore, offsite medical services drills need only be evaluated biennially. FEMA will, at the request of the involved ORO, continue to evaluate the

.drills on an annual basis. If more than two medical facilities and transportation providers are designated as primary or backup, they are also evaluated biennially.

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. It is allowable for an ambulance to demonstrate up to the point of departure for the medical facility and then have a non-specialized vehicle transport the "victim(s)" to the medical facility. This option is used in areas where removing an ambulance from service to drive a great distance (over an hour) for a drill would not be in the best interests of the community.

Normal communications between the ambulance I 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.

117

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Monitoring of the victim may be performed before transport or en route, or may be deferred to the medical facility. Contaminated injured individuals transported to medical facilities are monitored as soon as possible to assure that everyone (ambulance and medical facility) is aware of the medical and radiological status of the individual(s). However, if an ambulance defers monitoring to the medical facility, then the ambulance crew presumes that the patient(s) is contaminated and demonstrate appropriate contamination controls until the patient(s) is monitored. 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. Medical facilities are expected to have at least one trained physician and one trained nurse to perform and supervise treatment of contaminated injured individuals. 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 I procedures.

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

PEMA Negotiated Extent-of-Play:

This sub-element evaluated at Ephrata Community Hospital on April 23, 2015, York Hospital on May 28, 2015, and at Brandywine Hospital on August 11, 2015 118

I.

Unclassified Radiologi cal Emergency Preparedness Program (REP)

After Action Report/Improve mentPlan Peach Bottom Atomic Power Station ATTAC HMENT A-DEMONSTRATION TABLES Peach Bottom Atomic Power Station 2016 nt-of-Play Demonstration Tables Exte Plume Phase Exercise A.

Activities - Apri 127, 2016 beginning after 4 p.m.

1.

County EOCs Time: Pe r Exercise Scenario DEMON STRATION FOR EOC MOBILIZATION FOR COUNTIES Chester Lancaster York

2.

Municip alEOCs Time: Pe r Exercise Scenario DEMON RISK COUNTY Chester Lancaster York

• Joint EOC 0 - Location require STRATION FOR EOC MOBILIZATION FOR MUNICIPALITIES MUNICIPALITY West Nottin ham Townshi Drumore Township East Drumore Twp I Providence Twp I Quarryville Borough Fulton Township Little Britain Township Martic Townshi

• Delta I Peach Bottom Townshi sO

• Fawn Grove Twp I Fawn Borough Lower Chanceford Townshi s Base Line Evaluation 119

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station B.

3.

Back-up Route Alerting One back-up route alerting demonstration by one municipality in each risk county (During scenario Exercise)

Back-up Route Alerting COUNTY MUNCIP ALITY Chester West Nottingham Township Lancaster Martic Township York Lower Chanceford Township

4.

Municipal I Region Police Forces

a.

Each municipal I regional police force with a TCP assigned in its plan will demonstrate all preparation duties including TCP responsibilities and radiological briefing. Dispatch of persons to the TCP site will not occur during the exercise.

b.

Municipal and county staffs will be prepared to brief the FEMA evaluator on actions to be taken should there be an impediment to evacuation on a designated route. This will be demonstrated as part of the municipal or county demonstrations.

These municipal I regional police forces are (by county): NI A Chester Lancaster York NIA NIA NIA Out-of-Sequence Activities

1.

School Districts Risk Public School Districts with schools located within the EPZ and those districts situated outside the EPZ, but with students living within the EPZ, will participate and be evaluated by FEMA. Each identified District Administration Office will be evaluated. When a school system is comprised of multiple buildings (High School, Middle School, Elementary School), the affected buildings (those with students from the EPZ) will be evaluated on a rotational basis to coincide with the eight-year exercise cycle.

Time: Out-of-Sequence 120

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station County School District Date I Time Lancaster Penn Manor March 7-9 AM Lancaster Solanco March 7 -1 PM Chester Oxford March8-9AM York Red Lion March9-9AM York South Eastern March9-l PM Schools and School Districts COUNTY SCHOOL DISTRICT SCHOOLS (approx. 113rd evaluated)

Evaluated Chester Oxford Area ( 5)

1. Jordan Bank I Elementary School

• 2008/14

2. Nottingham Elementary School*

2008/14

3. Elk Ridge School

• 2002/10

4. Penn's Grove Middle School*

2006/12

5. Oxford Area HS*

2010/16 Lancaster Penn Manor (3)

1. Martic Elementary 2006112

2. Penn Manor High School

• 2008/14

3. Marticville Middle School

• 2010/16 Solanco (6)

1. Solanco High School 2010/16

2. Swift Middle School 2008/14

3. Smith Middle School 2006/12

4. Quarryville Elementary School 2008/14

5. Clermont Elementary School 2010/16

6. Providence Elementary School

• 2010/16 York South Eastern SD (5)

1. Fawn Elementary 2010/16

2. Delta I Peach Bottom Elementary 2006/12

3. SE Middle School (was East) 2010/16

4. SE Intermediate School (was Middle 2008/14 West)

5. Kennard Dale High School 2008/14 Red Lion (4)

1. Red Lion Sr High

• 2010/16

2. Red Lion Jr High

• 2008/14

3. Clearview Elementary

• 2006/12

4. Larry J. Macaluso Elementary*

NEW/2012

5. Pleasant View Elementary*

NEW/14

6. Windsor Manor Elementary*

NEW/16 Asterisks (*) items indicate buildings not in EPZ - students may live in the EPZ 121

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

2.

Traffic and Access Control Points

a.

PSP from all three county troop locations will be briefed at the PSP Lancaster Barracks, 2099 Lincoln Highway East Lancaster, Pennsylvania. Members attending the briefing will not actually deploy to the TCP I ACPs.

b.

The PSP briefing will be performed out-of-sequence in a demonstration window of 9:30 a.m. -12:00 noon on March 16, 2016.

3.

Reception Centers COUNTY Chester (1)

• Lancaster York (2)

Reception Centers Locations None LOCATION Octorara Middle School Lancaster County Career & Technology Center Red Lion Sr. High School Southern School Complex MS EVALUATED 2006/10 2006/12 2006/12 2011 (TMI)

NOTE: All counties have requested exemption from demonstration for the 2016 exercise.

The asterisks (*) indicate monitoring I decontamination center activities at the respective reception centers.

4.

Mass Care Centers Mass Care Center Locations March 7, 2016 - 7:00 p.m. to 9:30 p.m.

COUNTY LOCATION EVALUATED Chester (1)

Octorara High School 2010 Lancaster (3)

• Penn Manor High School 2006/12

• Manheim TownshiQ School Com12lex:

2007111 (TMI)

Manheim Township MS Manheim Township HS

• Laml!eter Strasburg School Coml!lex:

2010/16 Lampeter Strasburg High School Lampeter Strasburg Martin Mylin Middle School Lampeter Strasburg Hans Herr Elementary School Mass Care overflow capacity facilities include:

122

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Mass Care Center Locations March 7, 2016 - 7:00 p.m. to 9:30 p.m.

COUNTY LOCATION EVALUATED Hempfield Sr. High School 2013 (TMI)

Franklin & Marshall College Walk-Down -3/18 Manor Middle School Walk-Down -3/18 Conestoga Valley HS 2011 (TMI)

Conestoga Valley MS 2011 (TMI)

Garden Spot High & Middle School Complex Walk-Down -3/18 Warwick HS 2011 (TMI)

Warwick MS 2011 (TMI)

Cocalico HS 2011 (TMI)

Cocalico MS 2011 (TMI)

York (2)

• Red Lion School Complex:

2006/12 Red Lion Sr High School Red Lion Jr High School

• Southern School Complex:

2005/11 (TMI)

Southern Middle School Susquehannock High School Mass Care overflow capacity facilities:

Spring Grove High & Intermediate School Walk-Down -2012 Complex Spring Grove Middle School Walk-Down -2012 York County 4-H (people w/pets)

Walk-Down -2012 Dallastown High & Middle School Complex Walk-Down -2012 Additional Mass Care overflow capacity facilities:

Southwestern High & Markle Intermediate School Walk-Down -2012 Complex Red Lion Fire Company Walk-Down -2012 NOTE: Chester and York counties have asked for exemption for the 2016 exercise The asterisks (*) indicate monitoring I decontamination center activities at their mass care centers.

5.

Emergency Worker Monitoring*; Decontamination Station Emergency Worker Monitoring I Decontamination Station March 7, 2016 - 7:00 p.m. to 9:30 p.m.

COUNTY I

LOCATION I EVALUATED 123

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Chester (1)

Penns Grove Middle School 2006/12 Lancaster (1)

Lampeter Strasburg Field House 2012/16 York (1)

Brogue Ambulance Company 2006/12 Emergency worker monitoring I decontamination station(s) for the risk county.

NOTE: Chester and York counties have asked for exemption for the 2016 exercise 124

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station STATE OF MARYLAND METHOD OF OPERATION AND EXTENT OF PLAY 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 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.

Criterion 1.a.1: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-06541 FEMA-REP-1, A.I.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 accomplished during a full-scale or functional exercise, an actual event, 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 OR Os 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.

125

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station The REP program does not evaluate Incident Command System tactical operations, only coordination among the incident command, the utility, and all appropriate OROs, pursuant to plans/procedures.

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.

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 identified through LOA/MOUs must be on the ORO's mobilization list so they can be contacted during an incident, if needed.

State Negotiated Extent of Play:

During the plume phase exercise activities on April 27, 2016 the emergency workers will pre-stage at various locations to reduce the amount of travel time. MEMA will mobilize only key State agencies at the Maryland EOC. All other facilities will activate according to plans. Key State Agencies are: MEMA, Maryland Military Department/National Guard, Maryland Department of the Environment, Maryland Department of Health and Mental Hygiene, Maryland Department of Natural Resources, Maryland Department of Agriculture, Maryland Department of Transportation, Maryland State Police, Maw land Department of Education and the Maryland Institute for Emergency Medical Services Systems. The Maryland Department of the Environment field monitoring teams will pre-stage.

Risk and Support Jurisdictions Negotiated Extent of Play:

The County Agencies involved are Harford County Department of Emergency Services and Cecil County Department of Emergency Services. In all instances, the demonstration of a shift change is not required. Twenty-four hour staffing will be demonstrated by means of a roster or staffing chart.

All out-of-sequence players and equipment will be pre-positioned (Congregate Care, Reception Centers, Emergency Worker Monitoring and Decontamination Stations and Monitoring and Decontamination Centers). Cecil County MS-1 Union Hospital in Cecil County will not pre-126

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station stage its players. However, the Rising Sun EMS staff will pre-stage at the location that will begin the MS-1 portion of the exercise. Harford County MS-1 Upper Chesapeake Medical Center will not pre-stage its players. However, the Darlington Volunteer Fire Company will pre-stage at the location that will begin the MS-1 portion of the exercise.

Outstanding Issues:

None Sub-element 1.b - Facilities Intent This sub-element derives from NUREG-0654, which provides that Offsite Response Organizations (ORO) have facilities to support the emergency response.

Criterion l.b. l: Facilities are sufficient to support the emergency response. (NUREG-0654, H.3). Play Facilities will only be specifically evaluated for this criterion if they are new or have substantial changes in structure or mission. Responsible OROs should demonstrate the availability of facilities that support the accomplishment of emergency operations. Some of the areas to be considered are: adequate space, furnishings, lighting, restrooms, ventilation, backup power and/or alternate facility (ifrequired to support operations).

State Negotiated Extent of Play:

All State locations have been evaluated for the current 8-year cycle.

Risk and Support Jurisdictions Negotiated Extent of Play:

Cecil County EOC evaluations have been completed for their 8-year cycle. Harford County has a new EOC which will be evaluated on April 27th during the drill. The following locations will be evaluated during the out of sequence demonstrations. Harford County Fallston High School (Reception Center IE-Worker Monitoring) Patterson Mill High School (Congregate Care) Cecil County Rising Sun High School (Reception Center I Congregate Care) Perryville High School (E-Worker Monitoring)

Outstanding Issues:

None 127

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic 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 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/FEMA-REP-1, A.1.d; A.2.a, b; A.3; C.4, 6)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished in a full scale, functional, 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.

State Negotiated Extent of Play:

All activities will be in accordance with plans and procedures.

Risk and Support Jurisdictions Negotiated Extent of Play:

All activities will be in accordance with plans and procedures.

Outstanding Issues:

None 128

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic 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 commµnication 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 1.d.l: At least two communication systems are available, at least one operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations. (NUREG-0654/F'EJVIA-REP-1, F'.1, 2)

Assessment/Extent of Play Assessment of this Demonstration Criterion is accomplished initially in a baseline evaluation and subsequently in periodic testing and drills. System familiarity and use must be demonstrated as applicable in full scale, functional and tabletop exercises, 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.

129

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station State Negotiated Extent of Play:

This element will be demonstrated during the April 27, 2016 exercise in accordance with plans.

Failure of communications equipment will not be provided in the scenario but may be discussed with appropriate personnel Risk and Support Jurisdictions Negotiated Extent of Play:

This element will be demonstrated during the April 27, 2016 exercise in accordance with plans.

Failure of communications equipment will not be provided in the scenario but may be discussed with appropriate personnel.

Outstanding Issues:

None 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 1.e.1: Equipment, maps, displays, monitoring instruments, 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; J.10.a, h, e; J.11, 12; K.3.a; K.5.h)

Assessment/Extent of Play Assessment of this Demonstration Criterion is accomplished primarily 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:

130

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Kl: 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.

Mutual Aid Resources: If the incoming resources arrive with their own equipment (i.e., monitors and/or dosimetry), they will be evaluated by REP Program standards. FEMA will not inventory 131

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station equipment that is not part of the REP Program. If an agency has a defined role in the REP Plan, they are subject to the planning process and standards, as well as the guidance of this Manual.

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 measlirement instrument (less than IR/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 Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

State Negotiated Extent of Play:

All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency. Electrical leakage information is included with the Annual Letter of certification. Electronic dosimetry, used at most locations, does not require electrical leakage testing. Actual self-reading dosimetry will be issued however permanent dosimetry may be simulated. Quantities of dosimetry and KI available at storage locations(s) have been confirmed by documentation of current inventory submitted the Annual Letter of Certification submission.

KI tablets for emergency workers will be simulated. Actual distribution of KI will not be demonstrated.

Risk and Support Jurisdictions Negotiated Extent of Play:

132

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station All activities will be based on the ORO's plans and procedures and completed as they would be in an actual emergency. Electrical leakage information is included with the Annual Letter of certification. Electronic dosimetry, used at most locations, does not require electrical leakage testing. Actual self-reading dosimetry will be issued however permanent dosimetry may be simulated. Quantities of dosimetry and KI available at storage locations(s) have been confirmed by documentation of current inventory submitted the Annual Letter of Certification submission.

KI tablets for emergency workers will be simulated. Actual distribution of KI will not be demonstrated.

Outstanding Issues:

None ASSESSMENT AREA 2: PRECAUTIONARY AND/OR 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.1: OROs use a decision-making process, considering relevant/actors 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 radiation exposure in excess of administrative limits or protective action guides. (NUREG-0654/FEMA-REP-1, C.6; J.10. e,f; K.3.a; K.4)

Assessment/Extent of Play Assessment of this Demonstration Criterion must be assessed concurrently with a licensee exercise and may be demonstrated in a full scale, functional or tabletop exercise.

133

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 PA Gs for KI administration.

State Negotiated Extent of Play:

• All activities will be conducted in accordance with plans Risk and Support Jurisdictions Negotiated Extent of Play:

All activities will be conducted in accordance with plans Outstanding Issues:

None Sub-element 2.b. - Radiological Assessment and Precautionary and/or 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 PA Gs. 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 PA Gs 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 P ARs, coordination of Precautionary and/or Protective Action Decisions 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 134

Unclassified

• Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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.

Criterion 2.b.l: 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 of/site environmental conditions. (NUREG-0654/FEMA-REP-1, LJO and Supplement 3)

Assessment/Extent of Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a full-scale, functional 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 P AR,s 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 P ARs 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 P AG to which they will be compared. P ARs 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.

State Negotiated Extent of Play:

All activities will be conducted in accordance with MDE plans and procedures. The MDE Decision Maker does not travel to the Exelon Nuclear Coatesville EOF. He/She will remain local to the MDE or MEMA facility.

135

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Risk and Support Jurisdictions Negotiated Extent of Play:

All activities will be conducted in accordance with respective plans and procedures.

Outstanding Issues:

None Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make precautionary and/or protective action decisions for the general public (including the recommendation for the use of KI, if ORO policy). (NUREG-0654/FEMA-REP-1,A.3; C.4, 6; D.4; J.9; J.10.f, m)

Assessment/Extent of Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a full-scale, functional or tabletop exercise.

OROs must have the capability to make both initial and subsequent Precautionary and/or Protective Action Decisions. OROs must demonstrate the capability to make initial Precautionary and/or Protective Action Decision 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 P ARs from the utility and ORO staff. In addition, a subsequent or alternate Precautionary and/or Protective Action Decision 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 Precautionary and/or Protective Action Decision if local law enforcement, fire service, HAZMA T, and emergency medical resources are used to augment response to the NPP site or other key infrastructure.

Dose assessment personnel may provide additional P ARs 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 P ARs 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 136

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 P AG 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 OR Os must communicate and coordinate P ADs 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.

The OROs must demonstrate how the decision-making process takes those with disabilities and access/functional needs (e.g., nursing homes, correctional facilities, licensed day cares, mobility-impaired individuals, and transportation-dependent individuals) into account.

State Negotiated Extent of Play:

This activity will be conducted in accordance with plans. Maryland counties have the authority to initiate or expand a PAD. If a recommendation is made for the general public to take Kl, appropriate information will be provided to the public by the means of notification specified in the plan and/or procedures. The Maryland Department of Health and Mental Hygiene with input from MDE will decide whether or not to issue KI to the public based on plant conditions or a calculation to determine if protective thyroid dose (CDE Thyroid) exceeds projected dose during a General Emergency. This decision is coordinated my MEMA thtough the MDE Accident Assessment Center.

Risk and Support Jurisdictions Negotiated Extent of Play:

Same as State Outstanding Issues:

None Sub-element 2.c - Precautionary and/or Protective Action Decisions 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 Precautionary and/or Protective Action Decisions including evacuation, sheltering, and use of Kl, if applicable, for groups of persons with disabilities and access/functional needs (e.g., hospitals, nursing homes, correctional facilities, schools, licensed 137

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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.c.1: Precautionary and/or 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)

Assessment/Extent of Play Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a full-scale, functional or tabletop exercise that would include the use of plant conditions transmitted from 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).

State Negotiated Extent of Play:

All decision-making activities associated with protective actions, including consideration of available resources, for special population groups will be based on the ORO's plans and.

procedures and completed, as they would be in an actual emergency. List of any special populations will be available for review. School protective actions will be demonstrated as an out-of-sequence activity. Private schools, private kindergartens and day care centers will not 138

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station participate in the exercise however; OROs will have lists of any facilities located within the jurisdiction available for review.

Risk and Support Jurisdictions Negotiated Extent of Play:

All decision-making activities associated with protective actions, including consideration of available resources, for special population groups will be based on the ORO's plans and procedures and completed, as they would be in an actual emergency. List of any special populations will be available for review. School protective actions will be demonstrated as an out-of-sequence activity. Private schools, private kindergartens and day care centers will not participate in the exercise however; OROs will have lists of any facilities located within the jurisdiction available for review.

Outstanding Issues:

None 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 P AGs, and make timely, appropriate P ADs 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.l: Radiological consequences/or 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 Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a full-scale, functional or tabletop exercise that would include the use of plant conditions transmitted from the licensee.

139

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 PA Gs 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. These decisions include tracking agricultural products entering and leaving the EPZ. Demonstration of plans and procedures which use traffic access control points to track agricultural products entering and leaving the EPZ may be conducted through interview.

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

State Negotiated Extent of Play:

Not demonstrated Risk and Support Jurisdictions Negotiated Extent of Play:

Not demonstrated Outstanding Issues:

NIA 140

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic 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.

Criterion 2.e.1: Timely post-plume phase relocation, reentry, and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the ORO's plan and/or procedures. (NUREG-0654/FEMA-REP-1, LlO; 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 full-scale, functional or tabletop exercise that would include the use of plant conditions transmitted from the licensee.

Relocation: OROs must demonstrate the capability to estimate integrated dose in contaminated areas and compare these estimates with PA Gs; 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 PA Gs; 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 PA Gs. 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 PA Gs, 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.

141

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 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.

State Negotiated Extent of Play:

Not demonstrated Risk and Support Jurisdictions Negotiated Extent of Play:

Not demonstrated Outstanding Issues:

NIA ASSESSMENT AREA 3: PROTECTIVE ACTION IMPLEMENTATION 142

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 achievablell principle as appropriate.

Criterion 3.a.1: 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. OR Os maintain appropriate record-keeping of the administration of KI to emergency workers. (NUREG-0654/FEMA-REP-1, J.10.e; K.3.a, b; K..4)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional 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.

143

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and tum-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., lifesaving, 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 lifesaving 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.

State Negotiated Extent of Play:

At the MDE Accident Assessment Center, dosimetry will be used by the Field Team workers.

Risk and Support Jurisdictions Negotiated Extent of Play:

144

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station At Cecil and Harford Counties, personnel performing route alerting will receive radiological briefings, dosimetry, simulated KI and forms at the County EOC during the April 27, 2016 plume phase activities. Radiological briefings will be provided to address exposure limits and procedures to replace those approaching limits and how permission to exceed limits is obtained from the county. Emergency workers will also be briefed on when to take KI and on whose authority. Distribution of KI will be simulated. Forms should also be demonstrated to emergency workers. Forms used by emergency workers to track dosimetry and KI should be filled out completely and, when appropriate, serial numbers should be entered on forms for dosimetry.

In Harford County and Cecil County, personnel working at evacuee or emergency worker monitoring and decontamination facility will receive dosimetry and forms from their officer in charge while on site. A minimum of six (6) dosimetry kits will be demonstrated for each county.

This will be demonstrated out of sequence on March 29, 2016 from 19: 00- 21 : 00. Emergency workers who are assigned to low exposure rate areas, e.g., at reception centers, counting laboratories, emergency operations centers and communications centers, may have individual direct-reading dosimeters or they may be monitored by dosimeters strategically placed in the work area.

Cecil County will conduct radiological briefings and distribute KI, dosimeters, and forms at Rising Sun EMS. A radiological officer will be at Rising Sun EMS to carry out these duties and a second officer will be at the EOC to conduct briefings and distribute equipment as necessary as well. At Union Hospital in Cecil County, personnel working at the hospital will follow procedural guidance regarding use of dosimetry and KI. The Rising Sun EMS will receive their player briefing and dosimetry at the Cecil County staging area, Rising Sun EMS.

At any time, players may ask other players or supervisors to clarify radiological information. All locations that have dosimetry equipment indicated within their Radiological Emergency Response Plan (RERP), will make the dosimetry equipment (and KI) available for inspection by the Federal Evaluator. Simulation PRDs with mock serial numbers may be used.

Outstanding Issues:

None 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 145

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 Kl.

Criterion 3.b.l: Kl and appropriate instructions are available if a decision to recommend use of Kl is made. Appropriate record-keeping of the administration of KI for institutionalized individuals and the general public is maintained. (NUREG-0654/FEMA-REP-1, J.10.e,j)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional or tabletop exercise. Other means may include drills, seminars or training activities 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. OR Os 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.

State Negotiated Extent of Play:

This activity will be conducted in accordance with plans and procedures. KI has been pre-distributed to the general public. However, availability and dissemination of KI for the general population will be demonstrated for the evaluator during this exercise up to the point of actual distribution at the Reception/Monitoring & Decontamination Centers/Congregate Care Centers.

KI for the Emergency Workers will be evaluated through inventory sheets and/or inspection. KI will not be removed from the storage locations. KI questions will be addressed through interviews or submitted in the Annual Letter of Certification. Simulated KI may be used. The quantity of KI available for Emergency Workers will be made known to evaluators through inspection or inventory sheets.

146

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Risk and Support Jurisdictions Negotiated Extent of Play:

• Same as State Outstanding Issues:

None Sub-element 3.c - Implementation of Precautionary and/or 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 P ADs, 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.

Criterion 3.c.1: Precautionary and/or Protective action decisions are implemented for persons with disabilities and access/functional needs other than schools within areas subject to protective actions. (NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, 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 P ARs 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 actual, as negotiated in the extent of play. All actual and simulated contacts must be logged.

147

Unclassified Radiological Emergency Preparedness Program (REP)*

After Action Report/Improvement Plan Peach Bottom Atomic Power Station State Negotiated Extent of Play:

NIA Risk and Support Jurisdictions Negotiated Extent of Play:

All activities will be conducted in accordance with plans and procedures. The names, locations and contact information of identified individuals with identified special needs are maintained at each County EOC. Copies of these lists will not be provided to the evaluators; however, evaluators will be allowed to inspect the lists during the exercise.

Contact with special populations and reception facilities will be simulated (hospitals, nursing homes and correctional facilities). Actual contacts (up to two per Risk County) will be made with transportation providers as per plan. All actual and simulated contacts should be logged. AN interview will be conducted at each EOC with the organization that provides transportation on the April 27th Drill.

Outstanding Issues:

None Criterion 3.c.2: OROs/School officials implement precautionary and/or protective actions for schools. (NUREG-0654/FEMA-REP-1, J.10.c, d, e, g)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or tabletop exercise, an actual event, or by means of drills conducted at any time.

Public school systems/districts must demonstrate the ability to implement P ADs 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 148

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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.

The provisions of this criterion also apply to any private schools, private kindergartens, and licensed daycare centers that participate in REP exercises pursuant to the ORO's plans/procedures as negotiated in the Extent-of-Play Agreement.

State Negotiated Extent of Play:

NIA Risk and Support Jurisdictions Negotiated Extent of Play:

This activity will be conducted in accordance with plans and procedures on March 2, 2016 in Cecil County and April 27, 2016 in Harford County. In Harford and Cecil Counties, the interview of the School Principal will be done at each school. In Harford, School District personnel will be at the District office.

School Students will not be involved during the exercise. Actions and activities associated with the demonstration of Criterion 3.c.2 will be limited to the School District Administration key personnel and the County. Evacuation of students will be conducted through an interview process with School District personnel or the building principal.

The role of the bus driver may be conducted through an interview with school or transportation officials (or designee). Buses and drivers will not participate. Maps or route descriptions will be available for illustration purposes. Risk County school plans do not require communications between the school and vehicles. Bus drivers are not considered emergency workers and therefore do not require dosimetry. Potassium Iodide may be available at the school (pre-distributed) for the bus driver.

The School Services Officer is staged at the County EOC and will be coordinating activities with the Principal, including notifications. Private schools and kindergartens will not participate. Lists of these facilities will be provided and procedures for contacting them will be described.

Licensed Day Care Facilities will be listed in the County EOC and the following information will be available for each:

- Name of Facility or Operator Name

- Facility Contact Name (if different from Operator Name) 149

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station

- Facility Address

- Contact Phone Number These Day Care Facilit~es will not be contacted.

Outstanding Issues:

Sub-element 3.d. - Implementation of Traffic and Access Control Intent This Sub-element is derived from NUREG-0654/FEMA-REP-l, 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.

Criterion 3.d.l: 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)

Assessment/Extent of Play Assessment ofthis Demonstration Criterion may be accomplished during a full-scale or functional exercise, an actual event, or by means of drills conducted at any time.

OR Os must demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with current conditions and P ADs (e.g., evacuating, sheltering, and relocatipn) 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.

150

I I

I Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic 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.

State Negotiated Extent of Play:

This activity will be conducted in accordance with plans and procedures. Rail, water or air traffic will be coordinated through PEMA and implemented by the State. Actual contact with federal agencies (where required) will be simulated Risk and Support Jurisdictions Negotiated Extent of Play:

This activity will be conducted in accordance with plans and procedures. This element will also be evaluated during the April 27, 2016 plume phase activities in Harford and Cecil Counties.

Traffic and Access control will be demonstrated by interview at the County EOC. The traffic I access control personnel will not be deployed to the traffic I access control point(s). If the designated assignment is a location within the EPZ, a radiological briefing will be provided to the assigned individuals.

Outstanding Issues:

None Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NUREG-0654/FEMA-REP-1, J.10.k)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, an actual event, or by means of drills conducted at any time.

OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. In demonstrating this capability, the impediment must remain in place during the evacuation long enough that re-routing of traffic is required and must also result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees. When, due to specifics of the scenario or jurisdiction, the impediment cannot be located on an evacuation route, it must be located so as to impact the evacuation. When not possible, actual dispatch of resources need not be physically demonstrated; however, all contacts, actual or simulated, must be logged.

State Negotiated Extent of Play:

151

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station NIA Risk and Support Jurisdictions Negotiated Extent of Play:

This activity will be demonstrated in accordance with plans and procedures. This element will also be evaluated during the April 27, 2016 plume phase activities in Harford and Cecil Counties.

OROs should 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 tow trucks, need not be demonstrated; however, simulated contacts will be logged.

Outstanding Issues:

None 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.

Criterion 3.e.1: The ORO demonstrates the availability and appropriate use of adequate information regarding water, food supplies, milk, and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective actions. NUREG-0654/FEMA-REP-1, A.3; C.1, 4; J.11)

Assessment/Extent of Play Assessment ofthis Demonstration Criterion may be accomplished during a full-scale or functional 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 152

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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.

State Negotiated Extent of Play:

Not evaluated during this exercise Risk and Support Jurisdictions Negotiated Extent of Play:

Not evaluated during this exercise Outstanding Issues:

NIA Criterion 3.e.2: Appropriate measures, strategies, and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk, and agricultural production. (NUREG-0654/FEMA-REP-1, G.1, J.9, 11)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional 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.

153

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station State Negotiated Extent of Play:

Not evaluated during this exercise Risk and Support Jurisdictions Negotiated Extent of Play:

Not evaluated during this exercise Outstanding Issues:

NIA 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.

Criterion 3.f.l: Decisions regarding controlled reentry, relocation, and return of individuals during the post-plume phase are coordinated with appropriate organizations and implemented.

(NUREG-0654/FEMA-REP-1, E.7; J.10.j; J.12; KS.b; M.1, 3)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or tabletop exercise, an actual event, 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 P AGs.

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) PA Gs.

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 154

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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 contamiriation. 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. OR Os 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. Monitoring and decontamination facilities will be established as appropriate.

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

State Negotiated Extent of Play:

Not evaluated during this exercise 155

Unclassified Radiological Emergency Preparedness Program (REP)

I After Action Report/Improvement Plan Peach Bottom Atomic Power Station Risk and Support Jurisdictions Negotiated Extent of Play:

Not evaluated during this exercise Outstanding Issues:

NIA ASSESSMENT AREA 4: FIELD MEASUREMENTS AND ANALYSIS 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 ORO.shave 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.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; L7, 8, 11; J.10.a)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or tabletop exercise. Other means may include drills, seminars or training activities that would fully deruonstrate technical proficiency.

Responsible OR Os 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 156

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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.

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

State Negotiated Extent of Play:

These activities will be based on the ORO's plans and procedures and completed, as they would be in an actual emergency. At least six readings will be obtained by each team at a survey point location. IA W agreements with Exelon State and Local organizations, State and local teams will not measure plume centerline radiation levels. Airborne radioactivity samples will be counted in the field. Chain of custody procedures to deliver samples for additional analysis will be described to the evaluator. Federal participation is not scheduled for this exercise. Contact with Federal resources will be simulated.

Risk and Support Jurisdictions Negotiated Extent of Play:

County field teams do not perform survey, air sampling or air sampling analysis. Harford and Cecil Counties do not dispatch field teams.

Outstanding Issues:

None 157

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station 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)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or tabletop exercise. Other means may include drills, seminars or training activities that would fully demonstrate technical proficiency.

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.

• Coordination concerning transfer of samples, including a chain-of-custody form(s), to a radiological laboratory(ies) must be demonstrated. 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 must use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee). Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

State Negotiated Extent of Play:

These activities will be based on the ORO's plans and procedures and completed, as they would be in an actual emergency. At least six readings will be obtained by each team at a survey point location. IA W agreements with Exelon State and Local organizations, State and local teams will not measure plume centerline radiation levels. Airborne radioactivity samples will be counted in the field. Chain of custody procedures to deliver samples for additional analysis will be described to the evaluator. Federal participation is not scheduled for this exercise. Contact with Federal resources will be simulated Risk and Support Jurisdictions Negotiated Extent of Play:

County field teams do not perform survey, air sampling or air sampling analysis. Harford and Cecil counties do not dispatch field teams.

158

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Outstanding Issues:

None Sub-element 4.b - Post-Plume Phase Field Measurements and Sampling Intent This Sub-element is derived from NUREG-0654/FEMA-REP-l, 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.

Criterion 4.b.l: The field teams (2 or more) demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision making. (NUREG-0654/FEMA-REP-1, C.1; 1.8; J.11)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or tabletop exercise. Other means may include drills, seminars or training activities 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 must use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers). Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

159

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station State Negotiated Extent of Play:

Not evaluated during this exercise Risk and Support Jurisdictions Negotiated Extent of Play:

Not evaluated during this exercise Outstanding Issues:

NIA 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.

Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654/FEMA-REP-1, C.1, 3; J.11)

Assessment/Extent of Play Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or tabletop exercise. Other means may include drills, seminars or training activities that would fully demonstrate technical proficiency.

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.

160

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station The laboratory staff must be qualified in radio-analytical techniques and contamination control procedures.

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

State Negotiated Extent of Play:

Not evaluated during this exercise Risk and Support Jurisdictions Negotiated Extent of Play:

Not evaluated during this exercise Outstanding Issues:

NIA 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-l, 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).

161

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station ATTACHMENT B - FEDERAL EVALUATION PROCESS MA TRIX Evaluation Area Consolidate Frequency Out-of-Credit Staff Sequence Assistance of Visit Exercise Scenario

1. Emergency Operations 1, 2, 3, 4, 5, Management 14, 17, 30 Mobilization Every Exercise NO YES NO Facilities Once ifnew1 NO YES YES Direction and Control Every Exercise NO NO NO Communications Equipment Article I. Once YES YES YES per 8 yr. cycle Equipment and Supplies to Every Exercise YES YES YES Support Operations

2. Protective Action 5, 7, 9, 14, 15, Decision-Making 16, 17, 26, 28 Emergency Worker Exposure Every Exercise YES YES YES Control Radiological Assessment &

Every Exercise NO NO NO Protective Action Recommendations & Decisions for the Plume Phase of the Emergency Protective Action Decisions for Every Exercise NO NO NO the Protection of Special Populations Radiological Assessment &

Once in 6 yrs.

NO NO NO Decision-making for the Ingestion Exposure Pathway2 Radiological Assessment &

Once in 6 yrs.

NO NO NO Decision-making Concerning Relocation, Re-entry, and Retum2

3. Protective Action 5, 14, 15, 16, Implementation 17,27,29 Implementation of Emergency Every Exercise YES YES NO Worker Exposure Control Implementation of Kl Decision Once in 8 yrs.

YES NO NO 162

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Evaluation Area Consolidate Frequency Out-of-Credit Staff Sequence Assistance of Visit Exercise Scenario Implementation of Protective Once in 8 yrs.3 YES YES YES Actions for Special Populations Implementation of Traffic and 1 per YES YES YES Access Control4 Organization per exercise Implementation of Ingestion Once in 8 yrs.

NO NO NO Pathway Decisions Implementation of Relocation, Once in 8 yrs.

NO NO NO Re-entry, and Return decisions

4. Field Measurement and 6,8,24,25 Analysis Plume Phase Field Measurements Every Full YES YES NO

& Analysis Participation Exercise Post Plume Phase Field Once in 8 yrs.

YES YES NO Measurements and Sampling Laboratory Operations Once in 8 yrs.

YES YES NO

5. Emergency Notification and 10, 11, 12, 13 Public Information Activation of the Prompt Alert 10 Every exercise NO

.NO NO and Notification System Activation of the Prompt Alert 10 Separate Drill NO NO NO and Notification System (Fast once in 8 yrs.

Breaking)

Emergency Information &

Every exercise NO NO NO Instructions for the Public and the Media

6. Support 18, 19, 20, Operations I Facilities 21, 22 Monitoring & Decontamination Once in 8 yrs.

YES NO NO of Evacuees and Emergency Workers3

& Registration of Evacuees Monitoring & Decontamination Once in 8 yrs.

YES NO NO 163

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Peach Bottom Atomic Power Station Evaluation Area Consolidate Frequency Out-of-Credit Staff Sequence Assistance of Visit Exercise Scenario of Emergency Worker Equipment3 Temporary Care ofEvacuees6 Once in 8 yrs.

YES YES YES Transportation and Treatment of Every 2 years YES YES NO Contaminated Injured Individuals

• 1 Will be evaluated if new or changed substantially.

2 The plume phase and the post-plume phase (ingestion, relocation, re-entry and return) can be demonstrated separately.

3 All facilities must be evaluated once during the eight-year exercise cycle.

4 Physical deployment of resources is not necessary.

5 Facilities managed by the American Red Cross (ARC), under the ARC I FEMA MOU, will be evaluated once when designated or when substantial changes occur; all other facilities not managed by the ARC must be evaluated once in the eight-year exercise cycle.

6 Each State within the 10-mile EPZ of a commercial nuclear power site shall fully participate in an exercise jointly with the licensee and appropriate local governments at least every two years. Each State with multiple sites within its boundaries shall fully participate in a joint exercise at some site on a rotational basis at least every two years. When not fully participating in an exercise at a site, the State shall partially participate at that site to support the full participation of the local governments.

164