ML17306A073
| ML17306A073 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 10/25/2017 |
| From: | US Dept of Homeland Security, Federal Emergency Management Agency |
| To: | Office of Nuclear Reactor Regulation, Office of Nuclear Security and Incident Response |
| Shared Package | |
| ML17306A067 | List: |
| References | |
| Download: ML17306A073 (62) | |
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Calvert Cliffs Nuclear Power Plant After Action Report/
ltnproverbent Plan (Delaware)
Exercise Date-September 12-14, 2017
. Radiological Emergency Preparedness.(REP) Program
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Published October25, 2017
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!e Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Calvert Cliffs Nuclear Power Plant After Action Report/Improvement Plan Published October25, 2017 EXECUTIVE
SUMMARY
1
- 5 SECTION 1: EXERCISE OVERVIEW........................... ;......................................................... 6 1.1 Exercise Details...........................................................................,................... :.................... 6 1.2 Exercise Planning Team Leadership................................................................................. 6 1.3 Participating Organizations..... :......................................................................................... 8 SECTION 2: EXERCISE DESIGN
SUMMARY
.................................................................... 10 2.1 Exercise Purpose and Design........................................................................................... 10 2.2 Exercise Objectives, Capabilities and Activities............................................................. 13 2.3 Scenario Summary....................................................................... :.............. :..................... 14 SECTION 3: ANALYSIS OF CAPABILITIES..................................................... :................. 17 3.1 Exercise Evaluation and Results...................................................................................... 17 3.2 Summary Results of Exercise Evaluation............................................ :.......................... 17 3.3 Criteria Evaluation Summaries....................................................................................... 21 3.3.1 State Jurisdictions......................................................................................................... 21 3.3.2 Risk Jurisdictions........................................................................................ _.................. 23 3.3.3 Private Jurisdictions...................................................................................................... 24 SECTION 4: CONCLUSION.................................................................................................... 25 APPENDIX A: EXERCISE TIMELINE.................................................................................. 26 APPENDIX B: EXERCISE EVALUATORS AND TEAM LEADERS................................ 27 APPENDIX C: ACRONYMS AND ABBREVIATIONS........................................................ 28 APPENDIX D: EXTENT OF PLAY AGREEMENT.............................................................. 32 3
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant This page is intentionally blank.
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Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant EXECUTIVE
SUMMARY
From September 12-14, 2017, a full-scale Post Plume and Ingestion Pathway exercise was demonstrated for the Delaware portion of the 50 Mile Emergency Planning Zone (EPZ) around the Calvert Cliffs Nuclear Power Plant (CCNPP) and evaluated by the Federal Emergency Management Agency (FEMA), Region III. The station is located at 1650 Calvert Cliffs Pkwy, Lusby, MD. FEMA RlII also evaluated the Plume Exposure exercise conducted in Maryland on September 12, 2017. The previous Ingestion Pathway exercise for CCNPP was evaluated on October 20-22, 2009.
Out-of-Sequence demonstrations were conducted on September 13 and 18, 2017. 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 CCNPP. 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 or Level 2 findings and there were no Planning issues. There were no outstanding Performance and Planning Issues from previous exer.cises.
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 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 Planning Issue is: "An observed or identified inadequacy in the ORO's emergency plan/implementing procedures, rather than that of the ORO's performance."
FEMA wishes to acknowledge the efforts of many individuals in the State of Delaware, the risk jurisdictions of Kent County and Sussex County, and the support county of New Castle.
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.
Cooper~tion and teamwork of all the participants was evident during the exercise.
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Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant SECTION 1: EXERCISE OVERVIEW 1.1 Exercise Details Exercise Name CALVEX2017 Type of Exercise Post Plume Exercise Date September 12-14, 2017 Program Department of Homeland Security/FEMA Radiological Emergency Preparedriess Program Scenario Type Post Plume, Ingestion Pathway 1.2 Exercise Planning Team Leadership FEDERAL POC(s):
Nicholas Buls Emergency Management Specialist (Site Specialist, Delaware)
FEMA, Region III One Independence Mall 615 Chestnut Street 6th Floor Philadelphia PA 19106 nicholas. buls@fema.dhs.gov (202) 355-8134 (c)
Patricia Gardner Emergency Management Specialist (Site Specialist Maryland)
FEMA, Region III One Independence Mall 615 Chestnut Street 6th Floor Philadelphia PA 19106 Patricia.Gardner2@fema.dhs.gov (202) 329-7573(c) 6
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan STATE POC(s):
Wilbert Hayes Lead Radiological Emergency Preparedness Planner Delaware Emergency Management Agency 165 Brick Store Landing Road
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Smyrna, DE 19977 Wilbert.hayes@state.de.us 302-659-2350 (w)
Stephen F. Stasolla (Lead Controller)
Consultant stasolla@comcast.net 215-428-1017 (w) 267-994-6104 (c) 7 Calvert Cliffs Nuclear Power Plant
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the CAL VEX 201 7 exercise:
State Jurisdictions 1.3.l State of Delaware 1.3.1.1 State EOC Delaware Emergency Management Agency (DEMA)
Delaware Department of Agriculture (DDA)
Delaware Department of Health and Social Services (DHSS)
Department of Services for Children Youth and Families (DSCYF)
Delaware State Police (DSP)
Delaware Department of Transportation (DelDOT)
Delaware Department of Education (DOE)
Delaware National Guard (DNG)
Delaware Natural Resource Police (DNR)
Delaware Natural Resource and Environmental Conservation (DNREC)
Delaware State Housing Authority (DSHA)
American Red Cross (ARC) DELMARVA Chapter _
Public Services Electric and Gas (PSE&G)
DELMARVA Power and Light Delaware Co-op 1.3.1.2 State Technical Assessment Center (TAC)
Delaware Division of Public Health (DPH)
Delaware Department of Agriculture (DDA) e Delaware Department of Natural Resources and Environmental Control (DNREC)
Delaware Emergency Management Agency (DEMA)
Delaware National Guard (DNG)
U.S. Department of Agriculture (USDA)
Public Services Electric and Gas (PSE&G) 1.3.1.3 State Field Sampling Team 1 Delaware National Guard 1.3.1.4 State Field Sampling Team 2 Delaware National Guard 8
Unclassified Radiological Emergency Preparedness Program (REP)
. Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 1.3.2 Risk Jurisdktions 1.3.2.1 Kent County EOC Kent County Department of Public Safety, Division of Emergency Management 1.3.2.2 Sussex County EOC Sussex County Office of Emergency Management 1.3.3 Out of Sequence Exercise September 19, 2017 1.3.3.l State Contracted Laboratory Teledyne-Brown Laboratories 9
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 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 (CPR) Parts 350, 351and352. These regulations are a key element in the Radiological Emergency Preparedness (REP) Program that was established following the Three Mile Island Nuclear Station accident in March 1979.
44 CPR 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 off site 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 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 December 7, 2015 (Federal Register, Vol. 81; No. 57, March 24, 2016); 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. Department of Energy,
- U.S. Department of Health and Human Services,
- U.S. Department of Transportation,
- 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 Regional Assistance Committee (RAC), which is chaired by FEMA. A REP Post-Plume Exercise was conducted during the week of September 11, 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 10
Unclassified Radiological Emergency Preparedness Program (REP)
. Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Calvert Cliffs Nuclear Power Plant (CCNPP). The purpose ofthis exercise report is to present the exercise 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 evaluation team, with final determination~ made by the FEMA Region III 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:
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; 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, of this report entitled "Exercise Design Summary", and includes the "Exercise Purpose and Design", "Exercise Objectives, Capabilities, and Activities", and the "Scenario Summary".
Section 3 of this report, entitled "Analysis of Capabilities, presents detailed "Exercise Evaluation and Results" information on the demonstration for each jurisdiction or functional entity evaluated in a jurisdiction-based, issue-only format (Criteria Evaluation Summaries). This section also contains:
The appendices, present supplementary information:
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 used in this report.
Appendix D - Method of Operation and Extent of Play 11
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Emergency Planning Zone
Description:
A. Plume Emergency Planning Zone Description CCNPP is located near Maryland Highway 2-4 in Calvert County, Maryland, on the west bank of the Chesapeake Bay near Lusby, Maryland. The coordinates of the site are 38°25'39.7" North and 76°26'45" West. The site is owned and operated by Exelon Energy and covers an area of approximately 2,108 acres.
Seventy percent of the area remains forested and relatively undisturbed by CCNPP activities. There are several endangered plant and insect species within the boundaries of the site. Two pressurized water reactors each generate an electrical output of 825 MW units that provide power to around 400,000 residential customers. Unit 1 began commercial operation during May 197 5 and Unit 2 in April 1977. On e
March 23, 2002, the license was renewed, thereby extending the life of the plant by 20 years.
Nearby communities include: Calvert Beach and Long Beach, approximately 3 miles to the northwest; Cove Point, approximately 4 1/2 miles to the southeast; Chesapeake Ranch Estates, approximately 6 miles to the south-southwest; and the Patuxent Naval Air Test Center, approximately 10 miles to the south. Camp Bay Breeze, a summer camp, is located 2 miles southeast of the site.
The topography of the vicinity around the plant defines several small watersheds. The watershed containing the plant and auxiliary structures drains into the Chesapeake Bay. Chesapeake Bay has an average depth of 30 feet and receives the majority of its fresh water, sediment, and nutrients from the Susquehanna River.
A majority fraction of the land in the area surrounding the site is devoted to agricultural and forest use, such as farming of tobacco, corn, soybeans, and hay. Dairy farming is of minor importance. The waters adjacent to the site are used for commercial fishing, primarily for shellfish such as clams, oysters, and crabs.
There are approximately 54,602 people in the 10-mile EPZ. There are approximately 9,563 transients within the EPZ during peak seasonal activities, e.g., daytime, during the summer. No major populated cities (greater than 25,000) exist within the 10-mile EPZ.
B. Ingestion Pathway Emergency Planning Zone The Ingestion Pathway Emergency Planning Zone (EPZ) is approximately 7,850 square miles in area, which is equivalent to a 50-mile radius around the plant site. The States of Maryland, Delaware, Virginia, and the District of Columbia have jurisdictions within the Ingestion Pathway EPZ. The largest city within the Ingestion Pathway EPZ is Washington, D.C., with a population of 681,170, approximately 42 miles from the plant site. According to the U.S. Census Bureau 2014 five year estimates, the State of Delaware has a population of approximately 73,452 residents residing within the Calvert Cliffs Ingestion Pathway EPZ.
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Unclassified Radiological Emergency Preparedness Program (REP)
. Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 2.2 Exercise Objectives, Capabilities and Activities The objective of the 2017 Calvert Cliffs Nuclear Power Plant (CCNPP) Post-Plume Exercise, CAL VEX 201 7, 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 50 mile Ingestion Pathway Emergency Planning Zone (EPZ).
To demonstrate the ability to communicate between multiple State jurisdictions and levels of government and provide timely, accurate, and sufficiently detailed information to the public, the emergency management agencies use a variety of resources, including radios, telephones, the Internet, and the media. Media information was prepared but not actually released..
An essential capability of the Radiological Emergency Preparedness Program (REPP) is the ability of the State and risk and support counties to mobilize personnel and resources to support protective actions for the Ingestion Pathway EPZ, including relocation and the interdiction of contaminated food.
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Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 2.3 Scenario Summary Event Event Event Responsible Recipient Time Description Controller Player(s)
Day 1 (Plume Phase) - September 12, 2017 0945 Start of Exercise (START EX)
All All 1
0945 Media reports of Alert at CCNPP DEMA DEMAPIO 2
1015' Site Area Emergency notification MEMA DEMA 3
1145 General Emergency notification MEMA DEMA(TBD) 4 1215 Maryland Protective Actions MEMA DEMA(TBD)
(plume) 5 1220 Dose Projections (MD)
DEMA TAC 6
1230 Request for Federal Assistance DEMA DEMA (MD)
Command 7
1300 Precautionary Actions &
DEMA DEMA Field Monitoring Results (MD)
Command 8
1315 CCNPP Plant Status DEMA DEMA Command 9
1330 Dose Projections (NARAC)
DEMA TAC 10 1345 CCNPP Plant Status DEMA DEMA Command 11 1400 MD PAD Status DEMA DEMA Command 12 ONGOING Development of DE Precautionary DEMA TAC Actions (TAC) 13 ONGOING Development of Initial Sampling DEMA TAC and Assessment Plan (TAC) 14 1500 CCNPP Status DEMA DEMA Command 15 1530 DNG field monitoring data DEMA TAC 16 1600 End of Exercise All All 14
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Event Event Event Responsible Recipient Time Description Controller Player(s)
Day 2 (Post Plume) - September 13, 2017 0900 Start of Exercise (START EX)
All All 1
0900 Briefing I Initial Conditions DEMA All Presentation of Precautionary 2
0915 Actions and Sampling Plan (TAC TAC TAC to Command)
NARAC Projections DOE I AMS Flyover 3
0930 Initial field samples (TurboFRMAC analysis)
TAC TAC Field Monitoring Results 4
1000 Request from Governor (inject)
DEMA DEMA Command 5
1200 Presentation of relocation PAR's (approx.)
(TAC to Command)
TAC TAC 6
1230 Development of Relocation Plan TAC TAC (Command)
NARAC Ingestion Products 7
1300 Ingestion Pathway Samples TAC TAC (TurboFRMAC Analysis) 8 1315 Public Inquiry Calls Sim Cell DEMAPIO 9
1330 Resource Request Sussex County Sussex OEM Controller 1600 End Ex All All 15
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nnclear Power Plant Event Event Event Responsible Recipient Time Description Controller Player(s)
Day 3 (Post Plume) - September 14, 2017 0900 Start ofExerQise (START EX)
All All 1
0900 Briefing I Initial Conditions DEMA All 2
0915 Reentry Requests DEMA DEMA Controller Operations 3
1000 Presentation of ingestion pathway TAC TAC PAR' s (TAC to Command) 4 1030 Development of Ingestion TAC TAC Pathway Plan (Command) 5 1245 Return (inject)
TAC TAC 6
1300 Development of Recovery/Return DEMA Plan DEMA Controller Command 1600 End Ex All All 16
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant SECTION 3: ANALYSIS OF CAPABILITIES 3.1 Exercise Evaluation and Results Contained in this section are the results and fmdings of the evaluations of all jurisdictions and*
locations that participated in the September 12-14, 2017, Post-Plume Radiological Emergency Preparedness (REP) Exercise, and the Out of Sequence Exercise evaluations conducted on September 13 and 19, 2017. The exercise was conducted to demonstrate the ability of the Offsite Response Organizations of State and local government to *protect the health and safety of the public in the 50 mile Emergency Planning Zone surrounding the Calvert Cliffs Nuclear Power Plant.
Eachjlirisdiction 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 is contained in this report.
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. All evaluated criteria met the required demonstration(s). 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.
(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 e
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 17
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plan~
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.
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Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant
- _~'. Locaii:<%\\ ',
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DEMAEOC DEMAEOC DEMAEOC DEMAEOC DEMAEOC DEMAEOC DEMAEOC DEMAEOC DEMAEOC DEMAEOC DEEOCTAC DEEOCTAC DEEOCTAC DEEOCTAC DEEOCTAC DEEOCTAC DEEOCTAC DEEOCTAC DEEOCTAC SFST# 1 SFST # 1 SFST# 1 SFST# 1 SFST#2 SFST# 2 SFST# 2 SFST# 2 KCoEOC KCoEOC KCoEOC KCoEOC KCoEOC KCoEOC KCoEOC SCoEOC SCoEOC SCoEOC SCoEOC SCoEOC SCoEOC SCoEOC Tables 3.1 - Summary of Exercise Evaluation Table 3.1 - Exercise Evaluation - Criteria Met Date: September 12-14, 2017 Site: Calvert Cliffs Nuclear Power Plant Direction and Control Communications Equipment and Supplies to Support Operations Radiological Consequences for the Ingestion Pathway are assessed Timely P ADs for the Post-Plume phase are made and coordinated Appropriate Traffic and Access Control is established Availability and appropriate use of agricultural information Appropriate measures, strategies, pre-printed materials for P ADs Post-Plume decisions for reentry, relocation, and return are coordinated Emergency Information & Instructions for the Public/Media Direction and Control Communications Equipment and Supplies to Support Operations OROs use a decision making process to ensure exposure control Radiological Consequences for the ingestion pathway are assessed Timely P ADs for the Post-Plume phase are made and coordinated Appropriate Traffic and Access Control is established Availability and appropriate use of agricultural information Appropriate measures, strategies, pre-printed materials for P ADs Communications Equipment and Supplies to Support Operations Implementation of Emergency Worker Exposure Control Field Teams make appropriate measurements and collect samples Communications Equipment and Supplies to Support Operations Implementation of Emergency Worker Exposure Control Field Teams make appropriate measurements and collect samples Direction and Control Communications Equipment and Supplies to Support Operations Availability and appropriate use of agricultural information Appropriate measures, strategies, pre-printed materials for P ADs Post-plume decisions for reentry, relocation, and return are coordinated Emergency Information & Instructions for the Public/Media Facilities lcl ldl lel 2dl 2el 3dl 3el 3e2 3fl Sbl lcl ldl lel 2al 2dl 2el 3dl 3el 3e2 ldl lel 3al 4bl ldl lel 3al 4bl lcl ldl lel 3el 3e2 3fl 5.b.1 l.b.l Direction and Control lcl Communications ldl Equipment and Supplies to Support Operations lel Availability and appropriate use of agricultural information 3el Appropriate measures, strategies, pre-printed materials for PADs 3e2 Post-plume decisions for reentry, relocation, and return are coordinated 3fl 19
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant SCoEOC Sbl TB LAB lel TB LAB 3al TB LAB ses 4cl 20
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 3.3 Criteria Evaluation Summaries 3.3.1 State Jurisdictions 3.3.1.1 State of Delaware Emergency Operations Center In summary, the status ofDHS/FEMA criteria for the State jurisdiction is as follows:
- a. MET: Le.I, Ld.I, Le.I, 2.d.I, 2.e.I, 3.d.I, 3e.I, 3.e.2, 3.f.I,5.b.I
- b. LEVEL I 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 Technical Assessment Center In summary, the status ofDHS/FEMA criteria for the State jurisdiction is as follows:
- a. MET: Le.I, Ld.l, 2.a.I, 2.d.I, 2.e.I, 3.d.I, 3.e.I, 3.e.2
- b. LEVEL I FINDINGS: NONE
- c. LEVEL i FINDINGS: NONE
- d. PLAN ISSUES: NONE
- e. PRIOR ISSUES: RESOLVED: NONE
- f.
PRIOR ISS:cJES: UNRESOLVED: NONE 3.3.1.3 State Field Sampling Team 1 In summary, the status ofDHS/FEMA criteria for the State jurisdiction is as follows:
- a. MET: Ld.I, Le.I, 3.a.I, 4.b.I
- b. LEVEL I FINDINGS: NONE
- c. LEVEL 2 FINDINGS: NONE 21
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant
- d. PLAN ISSUES: NONE
- e. PRIOR ISSUES: RESOLVED: NONE
- f.
PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.4 State Field Sampling Team 2 In summary, the status of DHS/FEMA criteria for the State jurisdiction is as follows:
- a. MET: l.d.l, l.e.l, 3.a.l, 4.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 22
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 3.3.2 Risk Jurisdictions 3.3.2.1 Kent County Emergency Operations Center In summary, the status of DHS/FEMA criteria for this Risk location is as follows:
- a. MET: l.c.l, l.d.l, l.e.l, 3.e.l, 3.e.2, 3.f., 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 3.3.2.2 Sussex County Emergency Operations Center In summary, the status ofDHS/FEMA criteria for this Risk location is as follows:
- a. MET: l.b.l, l.c.l, l.d.l, l.e.l, 3.e'.1, 3.e.2, 3.f., 5.b.l
- b. LEVEL 1 FINDINGS: NONE
- c. LEVEL 2 FINDINGS: NONE
- d. PLAN ISSUES: NONE
- e. PRIOR ISSUES: RESOLVED: NONE 1*
- f.
PRIOR ISSUES: UNRESOLVED: NONE 23
Unclassified Radiological Emergency Preparedness Program (REP)
Action ReporUimprovement Plan Calvert Cliffs Nuclear Power Plant 3.3.3 Private Jurisdictions 3.3.3.1 Teledyne-Brown Laboratories In summary, the status of DHS/FEMA criteria for the Private jurisdiction is as follows:
- a. MET: l.e.l, 3.a.l, 4.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 24
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant SECTION 4: CONCLUSION The State of Delaware 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 Calvert Cliffs Nuclear Power Plant Post-Plume exercise evaluated on September 12-14, 2017, and the Out of Sequence Exercise conducted on September 19, 2017.
Federal Emergency Management Agency (FEMA) evaluators provided analyses of Forty-Five evaluation criteria. These analyses resulted in a determination of no Level 1 Findings, Level 2 Findings, or 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.
An After Action Implementation Plan (IP) will not be developed as part of this report.
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Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant APPENDIX A: EXERCISE TIMELINE This table contains the CCNPP Plume Exercise Timeline. Delaware was not required to participate in the Plume phase, but activated the SEOC and TAC in accordance with plans and procedures for adjacent state nuclear power plant incidents.
Plume Phase ECL Timeline Table: September 12, 2017 Calvert Cliffs Nuclear Power Plant
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!Radiation Release Facility Declared Operational Governor's Declaration of State of Emergency Exercise Terminated Pirst Protective Action Decision Describe:
Siren Sounding EAS Broadcast time Additional Precautionary Actions Describe:
Second Protective Action Decision Describe:
Siren Sounding EAS Message Broadcast KI Decision - NO Emergency Workers KI Decision - NO General Public 0811 1019 1142 1142 NA 26 Delaware SEOC NA 1037 1156 1156 NA 1245 NA NA NA NA NA NA NA NA NA NA NA Delaware TAC NA 1037 1156 1156 NA 1245 NA NA NA NA NA NA NA NA NA NA NA
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant APPENDIX B: EXERCISE EVALUATORS AND TEAM LEADERS The following is the list of Evaluators and Team Leaders for the Calvert Cliffs Nuclear Power Plant Radiological Emergency Preparedness Post-Plume Exercise evaluated from September 12-14, and the Out of Sequence Exercise conducted on September 19, 2017.. The following constitutes the managing staff for the Exercise Evaluation:
- Thomas Scardino, DHS/FEMA, Regional Assistance Committee (RAC) Chairman
- Nicholas J. Buis, DHS/FEMA, Project Officer and Site Specialist DATE: 12-14 September, 2017; Out of Sequence 19 September, 2017 SITE: Calvert Cliffs Nuclear Power Plant l~'.::U/Nf;ii~'.;, </'\\_;::~:; :J:;;~J,c:>:oA'.flbN:~J ~'<*.::ci:i:t~.::o": **,{;;
1
- ;:;:>*:* _*{* ::k:-1: ;.~::rgz\\MJ;?~MF'.~*:*k'}B ;:,;;;;:;:~ -.J~:~:~:'::'?)AQ§N.Glfff:;.2::;~::0i:~~ff'.i Delaware State Emergency Operations Center William McDougall FEMA Region 3 Delaware State Technical Assessment Center Cheryl Weaver ICF State Field Sampling Team 1 Carol Shepard ICF State Field Sampling Team 2 Marcy Campbell ICF Kent County Emergency Operations Center Paul Ringheiser ICF
/
Sussex County Emergency Operations Center Megean Brown FEMA Region 3 Out of Sequence Exercise September 19, 2017 Teledyne-Brown Laboratories Marcy Campbell ICF Hf;~;~::;i{~:. '. '.*. -':... ;.*, *. LOC'AT:Ib:N" '. :\\ ; *... 7:;~:* ;;. *...,.. *.. ;
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Delaware State Emergency Operations Center William McDougall FEMA Region 3 Delaware State Emergency Operations Center Nicholas Buls FEMA Region 3 Delaware Technical Assessment Center Cheryl Weaver ICF State Field Sampling Team 1 Carol Shepard ICF State Field Sampling Team 2 Marcy Campbell ICF Kent County Emergency Operations Center Paul Ringheiser ICF Sussex County Emergency Operations Center Megean Brown FEMA Region 3 Out Of Sequence Exercise September 19, 2017 Teledyne-Brown Laboratories Marcy Campbell ICF 27
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant APPENDIX C: ACRONYMS AND ABBREVIATIONS Acronym Description ACP Access Control Point ALARA As Low As Reasonably Achievable ARC American Red Cross ARES Amateur Radio Emergency Services CAD Computer Aided Display CCNPP Calvert Cliffs Nuclear Power Plant CDE Committed Dose Equivalent CERT Community Emergency Response Team co Communication Officer CPM Counts Per Minute CST Civil Support Team DAC Dose Assessment Coordinator DAD Digital Alarming Dosimetry DAS Director of Auxillary Services DDA Delaware Department of Agriculture DHSS Department of Health and Social Services DEANG Delaware Air National Guard DEEOCTAC Technical Assessment Center at State EOC DEMASEOC Delaware Emergency Management Agency State Emergency operations Center DelDOT Delaware Department of Transportation DNG Delaware National Guard DNREC Delaware Department of Natural Resourses and Environmental Control DPH Delaware Department of Public Health DRF Dosimetry Record Form DRC Disaster Recovery Center DSP Delaware State Police EAL Emergency Action Level EAS Emergency Alert System EC Emergency Coordinator ECL Emergency Classification Level ECO Exposure Control Officer EMC Emergency Management Coordinator EMD Emergency Management Director EMnet Emergency Management Network EMS Emergency Medical Services EOC Emergency Operations Center 28
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant EOF Emergency Operations Facility EOP Extent of Play EPA Environmental Protection Agency EPT Exercise Planning Team EPZ Emergency Planning Zone ER Emergency Room ERM Emergency Response Manager ERV Emergency Response Vehicle ESC Emergency Services Coordinator ESF Emergency Support Function ETA Estimated Time of Arrival EW Emergency Workers FD Fire Department FEMA Federal Emergency Management Agency PST Field Sampling Team FRMAC Federal Radiological Monitoring Assessment Center FSE Full Scale Exercise FTC Field Team Coordinator GE General Emergency GIS Geographic Information Systems GPS Global Positioning System HAN Health Alert Network HazMat Hazardous Materials HF High Frequency HSEEP Homeland Security Exercise and Evaluation Program IPZ Ingestion Pathway Zone IWP Initial Warning Point JIC Joint Information Center KCoEOC Kent County EOC KI Potassium Iodide LCD Liquid Crystal Display LHD Local Health Department MDDT Mobile Data Display Terminal MDE Maryland Department of Environment MDT Mobile Data Terminals MEMA Maryland Emergency Management Agency MHz Megahertz MIDAS Meteorological Information Dose Assessment System MS-1 Medical Services Hospital MSEL Master Scenario Events List 29
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant NA WAS National Warning System NCCEOC New Castle County EOC OSD Optically Stimulated Dosimeter PA Public Affairs PAD Protective Action Decision PAG Protective Action Guidelines PAR Protective Action Recommendation PARA Primary Area Route Alerting PAZ Protective Action Zone PD Police Department PDAFN Persons with Disabilities/ Access and Funtional Needs PED Personal Electronic Dosimeter PIO Public Information Officer PPE Personal Protective Equipment PRA Primary Route Alerting PRD Permanent Record Dosimeter RAC Regional Assistance Committee RACES Radio Amateur Civil Emergency Services RAO Radiation Assessment Officer RDO Radiation Defense Officer REA Radiation Emergency Area REC Radiation Exposure Control REP Radiological Emergency Plan RERP Radiological Emergency Response Plan RHP Radiological Health Program RML Radiological Mobile Laboratory RO Radiological Officer ROO Radiological Operations Officer RTF Radiological Task Force SA Staging Area SAC Staging Area Coordinator SAE Site Area Emergency SAIC Science Applications International Corporation SAM Staging Area Manager SCBA Self-Contained Breathing Apparatus SCoEOC Sussex County Emergency Operations Center SEOC State Emergency Operations Center SERS State Emergency Radio System SFST State Field Sampling Team STAC/DELDOT/DSP State Traffic and Access Control, Delaware Dept. of Transportation, Delaware State Police so State Official 30
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant SOP Standard 0 erating Procedure SRO School Resources Officer sso Social Services Officer TAC Technical Assessment Center TCP Traffic Control Point TEDE Total Effective Dose Equivalent TO Trans ortation Officer UEM Utility Emergency Manager VHF Very High Frequency VMS Variable Message Sign VOIP Voice Over Internet Protocol*
31
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant APPENDIX D: METHOD OF OPERATION AND EXTENT OF PLAY AGREEMENT The Calvert Cliffs Nuclear Power Plant Post-Plume Exercise Extent-of-Play was negotiated and agreed upon by FEMA Region III, Delaware Emergency Management Agency (DEMA), and the Emergency Management Agencies of the Risk Counties.
32
I Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Extent Of Play INTRODUCTION The purpose of this' document is to establish those exercise evaluation areas and corresponding Extent-of-Play parameters expected to be demonstrated by the State of Delaware during the Calvert Cliffs Nuclear Power Plant evaluated ingestion pathway exercise to be conducted on September 12, 13 and 14, 2017. The State of Delaware will participate in plume phase activities but these will not be part of the evaluation, with the exception of the demonstration of communication with the State of Maryland.
As it is difficult to fully demonstrate both plume and ingestion objectives for both States with a single scenario, the scenarios for the Plume and Ingestion portions of the exercise will be disconnected.
Also, the scenario for the ingestion portion of the exercise will be adjusted to allow the participating States (Maryland and Delaware) to fully demonstrate their respective exercise objectives. The parameters of these scenarios will not necessarily coincide. A simulated plume scenario will be produced to drive activities for the ingestion portion of the exercise.
This exercise is being conducted in close cooperation with the State of Maryland. They will submit a separate set of evaluation objectives to FEMA Region III for consideration.
. These evaluation areas have been developed through reviews of past exercises, associated plans and procedures, the proposed exercise scenario, applicable FEMA guidance documents, and extensive discussions with FEMA representatives.
All demonstrations will be conducted in accordance with established plans and procedures, except as indicated for specific exercise evaluation areas described herein. By agreement between the State of Delaware and FEMA Region 3, protective actions will be limited to the 50 mile emergency planning zone regardless of the extent of the radiological impact of the scenario data.
There were no exercise issues that will require corrective action by the State of Delaware during this exercise.
33
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan The following locations will be activated for this exercise:
State Emergency Operations Center (EOC) State Technical Assessment Center (TAC)
Delaware National Guard (DNG) Ingestion Sampling Teams County Jurisdictions Kent Cotinty EOC Sussex CountyEOC Other Locations NIA Out of Sequence Demonstrations Calvert Cliffs Nuclear Power Plant Some demonstrations will be conducted out-of-sequence. These demonstrations have been noted in the applicable evaluation area(s) and are summarized below.
Criterion 1.d.l, 1.e.1, 3.a.1, 4.b.1 Post Plume Sampling Demonstration - State ingestion sampling team September 13, 2017 Location - DNG Headquarters and field locations Criterion 1.e.1, 3.a.1, 4.c.1 Laboratory Operations Teledyne-Brown September 19, 2017 34
Action Report/Improvement Plan Unclassified Radiological Emergency Preparedness Program (REP).
Calvert Cliffs Nuclear Power Plant INGESTION PATHWAY EXERCISE CRITERIA AND EXTENT-OF-PLAY The Ingestion Pathway portion of the Calvert Cliffs exercise for the State of Delaware will be conducted on September 13 and 14, 2017. There will not be a demonstration of Plume Phase criteria for this exercise. These criteria will be demonstrated at an evaluated exercise at the Salem Hope Creek Nuclear Generating Station in May 2018.
Communication with the State of Maryland will be demonstrated on September 12th during the plume portion of the exercise.
The following extent of play outlines the Evaluation Areas and the expected activities for objectives related to the Ingestion Pathway.
The last evaluated ingestion pathway exercise that the State of Delaware participated in was in conjunction with the Salem Hope Creek site in 2010. There were no exercise issues noted during that exercise that will require corrective action by the State of Delaware during this exercise.
35
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Extent of Play by Evaluation Area The following evaluation areas, sub-elements and evaluation criterion are consistent with FEMA's exercise evaluation methods as reflected in the REP Program Manual. Generic extent of play text from the REP Manual is quoted verbatim for each evaluation criterion and has been placed in italics. All activities will be demonstrated in accordance with established plans and procedures, except as indicated in the State of Delaware Extent of Play for each evaluation criterion.
EVALUATION AREA 1: EMERGENCY OPERATIONS MANAGEMENT.
Sub-element 1.b - Facilities Criterion 1.b.1: Facilities are sufficient to support the emergency response.
(NUREG-0654, H)
Intent This sub-element is derived from NUREG-0654, which provides that OROs have facilities to support the emergency response.
Assessment/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 eight years, the availability of facilities to support accomplishment of emergency operations. This includes all alternate and backup facilities. Evaluations are typically performed for EOCs and J!Cs, as well as other facilities such as reception/relocation centers. Some of the areas evaluated within the facilities are adequate space, farnishings, lighting, restrooms, ventilation, access to 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 outlined in respective emergency plans/procedures. A substantial change is one that has a direct effect or impact on emergency response operations performed in those facilities.
Examples of substantial changes include modifying the size or configuration of an emergency operations center, adding more function to a center, or changing the equipment available for use in a center.
36
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 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 of Delaware 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.
Locations Evaluated Sussex County BOC Outstanding Issues None Sub-element 1.c - Direction and Control:
Criterion 1.c.1: Key personnel with leadership roles for the ORO provide Direction and Control to *that part of the overall response effort for which they are responsible.
(NUREG-0654, A.1.d.,2.a.,b.)
Intent This sub-element is derived from NUREG-0654, which provides that OROs have the capability to control their overall response to an emergency.
Assessment/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/supplement resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources. Any resources identified through LOA/MO Us must be on the ORO 's mobilization list so they may be contacted during an incident if needed.
All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of Play Agreement.
37
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant State of Delaware Extent of Play:
All activities will be performed in accordance with the ORO's plans/procedures and completed as they would be in an actual emergency.
Locations evaluated:
State BOC, Kent County EOC, Sussex County EOC, Technical Assessment Center Outstanding Issues None Sub-element 1.d - Communications Equipment 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, F.1., 2.)
Intent This Sub-element is derived from NUREG-0654/FEMAREP-1, which requires that OROs establish and operate reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as contiguous governments within the EPZ, Federal emergency response organizations, the licensee and its facilities, EOCs, Incident Command Posts, and FMTs.
Assessment/Extent-Of-Play 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 exercise or, if their use would be required, during an actual event.
OROs must demonstrate that a primary system and at least one backup system are 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, FMI's, and incident command must have the capability to access at least one communication system that is independent of the 38
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 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. 0 ROs must ensure that a coordinated communication 'link for fixed and mobile medical support jacilities exists. Exercise scenarios may require the failure of a communication system and use of an alternate system, as negotiated in the Extent-of-Play Agreement.
All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of Play Agreement.
. State of Delaware Extent-of-Play All activities will be performed in accordance with the ORO's plans/procedures and completed as they would be in an actual emergency, except as indicated below.
Communication capability with a contiguous ORO (State of Maryland) will be demonstrated using the primary communication method (or backup if primary fails) on September 12, 2017 during the plume portion of the exercise. One or more phone calls between the States of Delaware and Maryland will occur.
Locations Evaluated State EOC, Kent County EOC, Sussex County EOC State Ingestion Sampling Teams Outstanding Issues None Sub-element 1.e - Equipment and Supplies to Support Operations Criterion 1.e.1: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations.. (NUREG-0654, H.,
J.10.a.b.e.f.j.k., 11, K.3.a.)
Intent This sub-element is derived from NUREG-0654, which provides that OROs have emergency equipment and supplies adequate to support the emergency response. -
Assessment/Extent-Of-Play Assessment of this Demonstration Criterion is accomplished primarily through a baseline evaluation and subsequent periodic inspections.
39
Unclassified RadiologicaJ Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 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 Kl inventories, dosimetry, and monitoring equipment, as follows:
KI: Responsible OROs must demonstrate the capability to maintain inventories of Kl 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 Kl 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 Kl, as well as a mechanism for identifj;ing emergency workers that have declined Kl in advance. Consider carefully the placement of emergency workers that have declined Kl in advance.
ORO quantities of dosimetry and Kl 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 Kl must be within the expiration date indicated on Kl bottles or blister packs. As an alternative, the ORO may produce a letter from a certified private or State laboratory indicating that the Kl supply remains potent in accordance with US.
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 specia}ized 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 J 38s (CD V-J 38s) (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.
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Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Operational checks and testing of electronic dosimeters must be in accordance with the manufacturer's instructions and be verified during the exercise, through documentation submitted in the ALC and/or through an SAV.
Monitoring Instruments: All instruments must be inspected, inventoried, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. Unmodified CDV-700 series instruments and other instruments without a manufacturer's recommendation must be calibrated annually.
Modified CDV-700 instruments must be calibrated in accordance with the recommendation of the modification manufacturer. A label indicating such calibration must be on each instrument or calibrated frequency can be verified by other means. In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it is response checked using a standard test source.
For FMTs, the instruments must be capable of measuring gamma exposure rates and detecting beta radiation. These instruments must be capable of measuring a range of activity and exposure, including radiological protection/ exposure control of team members and detection of activity on air sample collection media, consistent with the intended use of the instrument and the ORO 's plans/ procedures. An appropriate radioactive check source must be used to verify proper operational response for each low range radiation measurement instrument (less than 1 Rlhr) 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/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 of this Manual.
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 of Delaware 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, except as indicated below.
41
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Radiological Equipment verification is included with the Annual Letter of Certification (ALC) or information is available at the State BOC. This information will be available for the evaluator(s).
Sussex County is not a plume risk county and does not have radiological equipment.
For a radiological response in Sussex County the State plan provides for equipment and trained personnel to dispatch to the impacted area. DEMA Command will discuss this with an evaluator at the State EOC at a mutually agreeable time to satisfy this criteria.
Evaluation of dosimetry and Potassium Iodide (KI) supplies will be demonstrated at the May 2018 biennial exercise for the Salem Hope Creek site.
Locations Evaluated State EOC, Kent County EOC, Sussex County BOC State Ingestion Sampling Teams Outstanding Issues:
None 42
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant EVALUATION AREA 2: PROTECTIVE ACTION DECISION-MAKING Sub-element 2.a -Emergency Worker Exposure Control Criterion 2.a.1: OROs use a decision-making process, considering relevant factors and appropriate coordination, to insure 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, K.4.)
Intent This sub-element is derived from NUREG-0654, which provides that an ORO have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place as specified in the ORO's plans and procedures to authorize emergency worker exposure limits to be exceeded for specific missions.
Radiation exposure limits for emergency workers are the recommended accumulated dose limits or exposure rates that emergency workers may be permitted to incur during an emergency. These limits include any pre-established administrative reporting limits (that take into consideration Total Effective Dose Equivalent or organ-specific limits) identified in the ORO's plans and procedures.
Assessment/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 plµns/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 Kl 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 Kl as a protective measure for emergency workers, based on their plans/procedures or projected thyroid dose compared with the established PA Gs for Kl administration.
43
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 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 of Delaware Extent-of-Play All activities will be performed in accordance with the ORO's plans/procedures and completed as they would be in an actual emergency.
Location Evaluated State Technical Assessment Center Outstanding Issues None Sub-element 2.d - Radiological Assessment & Decision Making for Ingestion Exposure Criterion 2.d.l: Radiological consequences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO planning criteria.
(NUREG-06451.8. J.11.)
Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (OROs) have the means to assess the radiological consequences for the ingestion exposure pathway, relate them to the appropriate PA Gs, and make timely, appropriate protective action decisions to mitigate exposure from the ingestion pathway.
During an accident at a nuclear power plant, a release of radioactive material may contaminate water supplies and agricultural products in the surrounding areas. Any such contfilnination would likely occur during the plume-phase oftlie accident and, dependiJ!g on the nature of the release, could impact the ingestion pathway for weeks or years.
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 that would include the use of plant conditions 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/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 44
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 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 PA Gs 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) guidanc.e. 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 exposure pathway dose commitments.
The ORO must demonstrate timely decisions to minimize radiological impacts from the ingestion exposure 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 will use Federal resources, as identified in the Nuclear/Radiological Incident Annex of the NRF and other resources (e.g., compacts or nuclear insurers), as necessary.
Evaluation of this criterion will take into consideration the level of Federal and other participating resources.
All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.
State of Delaware Extent of Play All activities will be performed in accordance with the ORO's plans/procedures and completed as they would be in an actual emergency.
By agreement between the State of Delaware and FEMA Region 3, protective actions will be limited to the 50 mile emergency planning zone regardless of the extent of the radiological impact of the scenario data.
Location Evaluated State EOC, Technical Assessment C_enter 45
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Outstanding Issues None Sub-element 2.e. - Radiological Assessment & Decision Making for Radiological Assessment and Decision Making for Relocation, Return, & Re-entry Criterion 2.e.1: Timely relocation, re-entry, and return decisions are made and coor~inated as appropriate, based on assessments of the radiological conditions and criteria in the ORO's plans and procedures. (NUREG-0654, A.1.b. 1.10.,M)
Intent This sub-element is derived from NUREG-0654, which provides that bffsite Response Organizations (OROs) have the capability to make decisions on relocation, reentry, and return of the general public. These decisions are essential for the protection of the public from the direct long-term exposure to deposited radioactive materials from a severe accident at a nuclear power plant.
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 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 PAGs; and control access to evacuated and restricted areas. OROs will make decisions for relocating members of the evacuated public who lived in areas that now have residual radiation levels in excess of the PA Gs. Determination of areas to be restricted must be based on factors such as e
the mix ofradionuclides in deposited materials, calculated exposure rates versus the PAGs, and analyses of vegetation and soil field samples.
Reentry: Decisions must be made on location of control points and policies regarding access and exposure control for emergency workers and members of the general public who.need to temporarily enter the evacuated area to perform specific tasks or missions.
Examples of control procedures are the assignment of, or checking for, direct-reading and permanent record dosimetry for emergency workers; questions regarding an individual's objectives, locations expected to be visited, and associated time.frames; availability of maps and plots of radiation exposure rates; and advice on areas to avoid. Control procedures also 46
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant include monitoring of individuals, vehicles, and equipment; the implementation of decision criteria regarding decontamination; and proper disposition of emergency worker dosimetry and maintenance of emergency worker radiation exposure records.
Responsible OROs must demonstrate the capability to develop a strategy for authorized reentry of individuals into the restricted zone(s) based on established decision criteria. OROs must demonstrate the capability to modify those policies for security purposes (e.g., police patrols), maintenance of essential services (e.g., fire protection and utilities), and other critical functions. They must demonstrate the capability to use decision-making criteria in allowing access to the restricted zone by the public for various reasons, such as to maintain property (e.g., to care for farm animals or secure machinery for storage) or retrieve important possessions.
Coordinated policies for access and exposure control must be developed among all agencies with roles to perform in the restricted zone(s). OROs must demonstrate the capability to establish policies for provision of dosimetry to all individuals allowed to reenter the restricted zone(s). The extent to which OROs need to develop policies on reentry will be determined by scenario events.
Return: OROs must demonstrate the capability to implement policies concerning return of members of the public to areas that were evacuated during the plume phase (i.e., permitting populations that were previously evacuated to reoccupy their homes and businesses on an unrestricted basis). OROs must base decisions on 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. OR Os must base return recommendations on measurements of radiation from ground deposition. OROs must have the capability to identify services and facilities that require restoration within a few days and to identify the procedures and resources for their restoration.
Examples of these services and facilities are medical and social services, utilities, roads, schools, and intermediate-term housing for relocated persons.
All activities must be based on the ORO 's plans/procedures and completed as they would be in an aciual emergency, unless noted above or otherwise specified in the Extent-of Play Agreement.
State of Delaware Extent of Play All activities will be performed in accordance with the ORO's plans/procedures and completed as they would be in an actual emergency, except as indicated below.
47
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant An inject will be provided by a controller at the Technical Assessment Center to drive return assessment.
By agreement between the State of Delaware and FEMA Region 3, protective actions will be limited to the 50 mile emergency planning zone regardless of the extent of the radiological impact of the scenario data.
Locations Evaluated State EOC, Technical Assessment Center
- outstanding Issues None 48
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant EVALUATION AREA 3: PROTECTIVE 1\\.CTION IMPLEMENTATION Sub-element 3.a - Implementation of Emergency Worker Exposure Control Criterion 3.a.1: The OROs issue appropriate dosimetry and procedures, and manage radiological exposure to emergency workers in accordance with the plans and 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. (NUREG-0654, K.3.)
Intent This sub-element is derived from NUREG-0654, which provides that OROs should have the
- capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimeters and permanent record dosimeters; provide for direct-reading dosimeters to be read at appropriate frequencies by emergency workers; maintain a radiation dose record for each emergency worker; and provide for establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of protective action guides, always applying the ALARA (As Low As is Reasonably Achievable) principle as appropriate.
Assessment/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, Kl, 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/procedures.
Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO 's plans/ procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control.
During a plun:ze phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached The emergency worker must report accumulated exposures during the exercise as indicated in the plans/ procedures. OR Os 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 49
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 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 e
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 EPA400-R-92-00J 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.
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 of Delaware Extent of Play All activities will be performed in accordance with the ORO's plans/procedures and completed as they would be in an actual emergency.
Locations Evaluated State Ingestion Sampling Teams so
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Outstanding Issues None Sub-element 3.d. - Implementation of Traffic and Access Control Intent This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement protective action plans/procedures, including relocation and restriction of access to evacuated/sheltered areas. This Sub-element focuses on selecting, establishing, and staffing of traffic and access control points, and removal of impediments to the flow of evacuation traffic.
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)
ASSESSl\\tlENT/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, as agreed. upon in the Extent-of-Play Agreement. All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of Play Agreement.
State of Delaware Extent of Play All activities will be performed in accordance with the ORO's plans/procedures and completed as they would be in an actual emergency, except as indicated below.
51
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Locations Evaluated StateEOC Outstanding Issues None 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.
Intent This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to implement protective actions, based on criteria recommended by current Food and Drug Administration guidance, for the ingestion pathway zone (IPZ), the area within an approximate 50-mile radius of the nuclear power plant. This sub-element focuses on those actions required for implementation of protective actions.
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 secure and use current information on the locations of dairy farms, meat and poultry producers, fisheries, fruit growers, vegetable growers, grain producers, food processing plants, and water supply intake points to implement protective actions within the EPZ OROs use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, nuclear.
insurers) if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.
All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play
- Agreement.
State of Delaware Extent of Play All activities Will be performed in accordance with the ORO's plans/procedures and completed as they would be in an actual emergency 52
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plali Locations Evaluated State EOC, Kent County EOC, Sussex County EOC Technical Assessment Center Outstanding Issues None Sub-element 3.e - Implementation of Ingestion Pathway Decisions Calvert Cliffs Nuclear Power Plant 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.
Intent This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to implement protective actions, based on criteria recommended by current Food and Drug Administration guidance, for the ingestion pathway zone (IPZ), the area within an approximate 50-mile radius of the nuclear power plant. This sub-element focuses on those actions required for implementation of protective actions.,
Assessment/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 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 predetermined 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 ageneies responsible for enforcing food controls within the ingestion exposure pathway EPZ must be demonstrated, but actual communications with food producers and processors may be simulated All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of Play Agreement.
53
Unclassified Radiological Emergency. Preparedness Program (REP)
A.ction Report/Improvement Plan Calvert Cliffs Nuclear Power Plant State of Delaware Extent of Play All activities will be performed in accordance with the ORO's plans/procedures and completed as they would be in an actual emergency.
By agreement between the State of Delaware and FEMA Region 3, protective actions will be limited to the 50 mile emergency planning zone regardless of the extent of the radiological impact of the scenario data.
Locations Evaluated State BOC, Kent County BOC, Sussex County.BOC Technical Assessment Center Outstanding Issues None Sub-Element 3.f-Implementation of Relocation, Reentry, and Return Decisions Criterion 3.f.1: Decisions regarding controlled Reentry of emergency workers and relocation and return of the public are coordinated with appropriate organizations and implemented. (NUREG-0654, M.1, 3)
Intent This sub-element is derived from NUREG-0654, which provides that Off site Response Organizations _(OROs) should demonstrate the capability to implement plans, procedures, and decisions for relocation, Reentry, and return. Implementation of these decisions is **essential for the protection of the public from the direct long-term exposure to deposited radioactive materials from a severe accident at a commercial nuclear power plant.
Assessment/Extent-Of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial, or tabletop exercise, or by means of drills conducted at any time.
Relocation: OROs must demonstrate the capability to coordinate and implement decisions concerning relocation of individuals located in radiologically contaminated areas who were not previously evacuated. Such individuals must be relocated to an area(s) where radiological contamination will not expose the general public to doses that exceed the relocation PA Gs.
OROs must also demonstrate the capability to provide for short-or long-term relocation of evacuees who lived in an area(s) that has residual radiation levels above the (first-, second-,
and 50-year) PAGs.
54
Unclassified
- Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Areas of consideration must include the capability ofOROs to communicate with other OROs regarding timing of actions, notification of the population of procedures for relocation, and notification of and advice for, evacuated individuals who will be converted to relocation status in situations where they will not be able to return to their homes due to high levels of contamination. OROs must also demonstrate the capability to communicate instructions to the public regarding relocation decisions and intermediate term housing for relocated persons.
Reentry: OROs must demonstrate the capability to control reentry and exit of individuals who are authorized by the ORO to temporarily reenter the restricted area during the post-plume (i.e., intermediate or late) phase to protect them from unnecessary radiation exposure. OROs must also demonstrate the capability to control exit of vehicles and other equipment to control the spread of contamination outside the restricted area(s). Individuals without specific radiological response missions, such as farmers for animal care, essential utility service personnel, or other members of the public who must reenter an evacuated area during the post-emergency phase must be limited to the lowest.radiological exposure commensurate with completing their missions. 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 individua./s, 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. OR Os must demonstrate the capability to identify and prioritize services and facilities that require restoration within a few days, and to identify procedures and resources for their restoration.
Examples of these services and facilities are medical and social services, utilities, roads, and schools.
Communication among OROs for relocation, reentry, and return may be simulated All simulated or actual contacts must be documented These discussions may be accomplished in a group setting.
OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other necessary resources (e.g., compacts or nuclear insurers) as necessary and if available. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.
All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency,. unless noted above or otherwise specified in the Extent-of Play Agreement.
55
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant State of Delaware Extent of Play All activities will be performed in accordance with the ORO's plans/procedures and completed as they would be in an actual emergency, except as indicated below.
A controller inject(s) will be provided to participants to initiate a request for reentry to the restricted area By agreement between the State of Delaware and FEMA Region 3, protective actions will be limited to the 50 mile emergency planning zone regardless of the extent of the radiological impact of the scenario data.
e Locations Evaluated State EOC, Kent County EOC, Sussex County EOC Technical Assessment Center Outstanding Issues None 56
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant EVALUATION AREA 4: FIELD MEASUREMENT AND ANALYSIS Sub-element 4.b - Post Plume Phase, Field Measurements & Sampling Criterion 4.b.l: The field teams demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g., food crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making.
Intent This sub-element is derived from NUREG-0654, which provides that OROs should have the capability to assess the actual or potential magnitude and locations of radiological hazards in the IPZ and for relocation, Reentry and return measures. This
- sub-element focuses on the collection of environmental samples for laboratory analyses that are essential for decisions on protection of the public from contaminated food and water and direct radiation from deposited materials.
Assessment/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.
The ORO 's FMI's must demonstrate the capability to take measurements and samples at such times and locations as directed to enable an adequate assessment of the ingestion exposure 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 FMI's and/or other sampling personnel must secure ingestion exposure pathway samples from agricultural products and water. Samples in support of relocation and return must be secured from soil, vegetation, and other surfaces in areas that received radioactive ground deposition.
OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers) as needed. Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.
All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.
57
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant State of Delaware 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 except as indicated below.
Two sampling teams will be evaluated. They will be demonstrated out of sequence on September 13, 2017.
Communications from the EOC to the sampling teams will be simulated. Sampling location( s) will be determined in advance and may not coincide with the footprint of the plume. The teams will collect one or more samples based on the crops in the field at the time [soil, water, milk, leafy vegetation, crops]. Teams will split up the sample types (both teams do not need to collect e
all sample types). Sample transport to the analysis lab will be simulated.
Milk sampling will not be demonstrated at a farm but will be done by interview - a field team member(s) will explain the process of sampling to the evaluator.
Ifrequired by the Technical Assessment Center, sampling team will demonstrate donning anti-contamination equipment, but will not wear them during sample collection or other field activities. Booties and gloves will be worn as per Delaware SOP's and as directed by the Technical Assessment Center. An inventory list will be available with protective equipment.
Locations Evaluated State Ingestion Sampling Teams Outstanding Issues None Sub-element 4.c - Laboratory Operations Criterion 4.c.1: The laboratory is capable of performing required radiological analyses to support protective action decisions.
Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (OROs) should have the capability to perform laboratory analyses of radioactivity in air, liquid, and environmental samples to support protective action decision-making..
Extent-Of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial, tabletop 58
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant exercise, or an actual event. 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.
The laboratory staff must be qualified in radioanalytical techniques and contamination control procedures. OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers) as needed Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.
All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.
State of Delaware Extent of Play All activities will be performed in accordance with the ORO' s plans/procedures and completed as they would be in an actual emergency except as indicated below.
Laboratory operations will be evaluated out of sequence at the Teledyne-Brown facility.
Location Evaluated Teledyne-Brown Outstanding Issues None 59
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant EVALUATION AREA 5 - EMERGENCY INFORMATION AND PUBLIC NOTIFICATION Sub-element 5.b - Emergency Information and Instructions for the Public and the Media Criterion 5.b.l: ORO's provide accurate emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654, E.5.7.
G.3.a., G.4.a.,b.,c.)
Intent This sub-element is derived from NUREG-0654, which provides that Offsite Response Organizations (OROs) should have the capability to disseminate to the public appropriate emergency information and instructions, including any recommended protective actions. In addition, NUREG-0654 provides that OROs should 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 also provides that a system should be available for dealing with rumors. This system will hereafter be known as the public inquiry hotline.
Assessment/Extent-Of-Play Assessment of this Demonstration Criterion may be accomplished during a biennial exercise, or drills. The responsible ORO personnel/representatives must demonstrate actions to provide emergency information and instructions to the public and media in a timely manner following the initial alert and notification (not subject to specific time requirements). For exercise purposes, timely is defined as "with a sense of urgency and without undue delay. " If message dissemination is identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.
Message elements: The ORO must ensure that emergency information and instructions are e
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/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.
60
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant The emergency information must be all-inclusive by including the fo'ur items specified under exercise Demonstration Criterion 5. a. I and previously identified protective action areas that are still valid, as well as new areas. Information about any rerouting of evacuation routes due to impediments should also be included The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. In addition, the OROs must demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures.
OROs must demonstrate the capability to develop emergency information in a non-English language when required by the plans/procedures.
If ingestion exposure pathway measures are exercised, OROs must demonstrate that a system exists for rapid dissemination of ingestion exposure pathway information to predetermined individuals and businesses in accordance with the ORO 's plans/procedures.
State of Delaware Extent of Play All activities will be performed in accordance with the ORO's plans/procedures and completed as they would be in an actual emergency.
Location Evaluated State EOC, Kent County EOC, Sussex County EOC Outstanding Issues None 61
Unclassified Radiological Emergency Preparedness Program (REP)
Action Report/Improvement Plan Addresses of Locations to be Evaluated State State Emergency Operations Center (EOC)
State Technical Assessment Center (TAC) 165 Brick Store Landing Rd Smyrna, DE 19977 Delaware National Guard (DNG) Field Teams - DNG HQ 1 Regiment Rd Wilmington, DE 19808 Lum's Pond (Field Sampling Team Demonstrations) 33 55 Red Lion Road Bear, DE 19701 Counties Kent County EOC 911 Public Safety Blvd Dover, DE 19901 Sussex County EOC 21911 Rudder Lane Georgetown, DE 19947 Private Teledyne-Brown Laboratories 2508 Quality Lane Knoxville, TN 3 7931 62 Calvert Cliffs Nuclear Power Plant
(