ML17346A757

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After Action Report/Improvement Plan for the Ingestion Pathway Exercise Held September 12-14, 2017
ML17346A757
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 12/01/2017
From:
US Dept of Homeland Security, Federal Emergency Management Agency
To:
Office of Nuclear Reactor Regulation
Shared Package
ML17346A795 List:
References
Download: ML17346A757 (98)
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Text

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Calvert Cliffs Nricle.ar Power* Plant After Action Report/

Exercise Date-. September 12-14, 2017 Radiological Emergency Preparedness Program Published December 11 2017

Unclassified Radiological Emergency_Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant

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  • Un~lassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant TABLE OF CONTENTS EXECUTIVE

SUMMARY

......................................................................................................................... -5 SECTION 1: EXERCISE OVERVIEW.:..........................................................,............,..................,........ 7 1.1 Exercise *Details....................... *.......................................................................................................... 7 1.2 Exercise Planning Team Leadership..................... :................. :.................... ;.................................... 7.

1.3 Participating Organizations............. '.....,...................................................................................-.......... 8 SECTION 2: EXERCISE DESIGN

SUMMARY

... :.......................................................... :........... :......... 13

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  • 2.1 Exercise Purpose and Design:.....-............. ~......................................... :... :**************************************** 13
  • 2.2 Exercise Objectives, Capabilities and Activities.............................. ~.............................................. 16 2.3 Scenario Summary*************************************:**..............................................,................................... 16 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:................................................ :.................. *................................... 27 3.3.1 State Jurisdictions..........................*............................... ~..............................*........... :.................... 27 3.3.2 Risk Jurisdictions...................................................................... :........................................ :...... 31 3.3.3 Support Jurisdictions................................................ :......... :................... :..................... *....... ;.. *.. 36.

3.3.3 Private Jurisdictions...................................-.......... :.... ;.........................,..................................... 42

  • SECTION 4: DEMONSTRATED STRENGTHS................................................ :............................ :...... 44 4: 1 State Jurisdictions...................................................................................... :**,****;************************** 44 SECTION 5: CONCLUSION......................................... :......................................................................... 46 APPENDIX A: EXERCISE TIMELINE.................................................................................................. 47 APPENDIX B: EXERCISE EVALUATORS AND TEAM LEADERS.................................. ;.............. 48 APPENDIX C: ACRONYMS AND.ABBREVIATIONS..... ~...................... :............................. _...... _....... 53 APPENDIX D: EXERCISE PLAN...................................... _........................................................,............ 54 3

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Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant EXECUTIVE

SUMMARY

From September 12-14, 2017, a full-scale Plume and Ingestion Pathway*exercise was demonstrated for the 50 Mile Emergency Planning Zo11-e (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 RIII also evaluated the Ingestion Pathway

  • exercise conducted in Delaware on September 13th and 14th, 2017. The previous Ingestion Pathway exercise for CCNPP was evaluated on October 20-22, 2009. One out-of-sequence demonstration was evaluated on August 14, 2017. The most recent Plume*full-scale exercise at this site was evaluated in September 2015. There were two Level 2 Findings, and one planning issue as a result of the FEMA-evaluated 2015 CCNPP exercise. The Planning Issue was successfully corrected prior to the September 12, 2017 e~ercise evaluation.

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*

fmdings in this report are based on the evaluations of the Federal evalu~tiori. team, with final determinations made by the FEMA, Region III Regional Assistance Co:mniittee (RAC) Chairperson, and approved by FEMA Headquarters. Th~~e 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 there were two Level 2 Findings, one of which was successfully redemonstrated on September 13, 2017, and the other redemonstrated on December 1, 2017. There were three planning issues identified, which were also closed on December 1, 2017. A Level 1 Finding ~s. defined by the FEMA Radiological Emergency Preparedness Program Manual as.

follows: "An observed or identified in.adequacy 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 the many individuals in the State of Maryland, the risk jurisdictions of Calvert County, Dorchester County and St. Mary's County, and the 23 ingestion pathway counties that were evaluated during this exercise. Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned responsibility for others.

Still, others have willingly sought this responsibility by volunteering to provide vital emergency services 5

Unclassified

  • Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant to their communities. Cooperation and teamwork of all the participants were evident during this

. exercise. This report contains the final evaluation of the biennial exercise and the evaluation cif the out-of-sequence activities.

The State and local organizations, except w;b.ere noted in this report, demonstrated knowledge of their emergency response plans and procedures and adequately implemented them.

6

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant SECTION Jl: EXERCISE OVERVIEW 1.1 Exercise Details Exercise N a~e CALVEX17 Type of Exercise

  • Plume and Ingestion Pathway Exercise Exercise Date September 12-14, 2017 Program Department of Homeland Security/FEMA Radiological Emerge;ncy Preparedness Program Scenario Type Radiological release that exceeds protective action guidelines beyond. lOmiles.

1.2 Exercise Planning Team Leadership Patricia M. Gardner Technological Hazards Specialist FEMA Region III One Independence Mall, 6th Floor 615 ChestnutStreet Philadelphia, PA, 19106 (202) 329~ 7573 Patricia. Gardner2@fenia.dhs.gov Reed Correll Preparedness Planner IV Maryland Emergency Management Agency 5401 Rue Saint Lo Drive Reisterstown, MD, 2113 6 (410) 517-3612 reed.correll@maryland.gov Rick Woods Sr. Emergency Preparedness Analyst Calvert Cliffs Nuclear Power Plant 1650 Calvert Cliffs Parkway Lusby, MD, 20678 (410) 495-3866 rick.woods@exeloncorp.com 7

Unclassified Radiological Emergency Preparedne~s Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 1.3 Participating Organizations Agencies and organizations of the following jurisdictions participated in the exercise:

State Jurisdictions Maryland Department of Agriculture Maryland Department of Education Maryland Department of General Services Maryland Department of Health Maryiand Department of Health and Mental Hygiene Maryland Department oflnformation and Technology Maryland Department of Juvenile Services

Pennsylvania Department of Environmental Protection Pennsylvania Department of Radiation Protection/Bureau of Radiation Protection Pennsylvania Emergency Management Agency Virginia Department of Emergency Management Virginia Department of Health Washington, District of Columbia Department of Health Washington, District of Columbia Homeland Security and Emergency Management West Virginia Department of Homeland Security and Emergency Management Risk-Area Jurisdictions Calvert County 911 Communications Control Center Calvert County Communications and Media Relations Calvert County Department of Agriculture Calvert County Department of the Environment Calvert County Department of Natural Resources Calvert County Department of Public Health 8

1*

Unclassified After Action Report/Improvement Plan

~adiological Emergency Preparedness Program Cl!I Calvert County Department of Public Safety Calvert County Department of Social Services Calvert Cliffs Nuclear Power Plant 0

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Calvert County Department of Technology Servic~s/Geographical Information Systems Office Calvert County Emergency Operations Center 9

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Calvert County Fire/Rescue/EMS Calvert County General Services Calvert County Public Schools Calvert County Public Works Department Calvert County Radiological Officer Calvert County Sheriffs Office Calvert Memorial Hospital Cambridge Police Department Commissioners of St. Mary's County Patuxent High School Dorchester County Board of Education

  • Dorchester County Emergency Services Dorchester County Department of Natural Resources*

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Dorchester County Department of Public Works Dorchester County Department of Social Services Dorchester County Emergency Medical Services Dorchester County Farm Service Agency ll e>

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Dorchester County Health Department Dorchester County Highway Department Dorchester County Planning and Zoning Dorchester County Public Information Office Dorchester County Sheriffs Office Department of Natural Resource Marine Police Eastern Shore Health Center MedStar St. Mary's Hospital Resource Fire Company St. Mary's County Administrator St. Mary's County Aging & Human Services St. Mary's County Communications 911 St. Mary's County Department of Agriculture St. Mary's County Department of Public Works & Transp9rtation St. Mary's County Department of Social Services St. Mary's County External Affairs St. Mary's County Hazmat 9

Unclassified Radiological Emergency Preparedness Program After Action Report'lmprovement Plan St. Mary's County Health Department.

St. Mary's County Metropolitan Commission St. Mary's County Recreation and Parks St. Mary's County Rescue Chief St. Mary's County School St. Mary's County Sheriffs Office e

Green Holly Elementary School Mutual Elementary e

Town of Leonardtown Taylors Island Fire Company University of Maryland Shore Regional Hospital Ingestion Pathway Participants Ann Arundel County e

Ann Arundel County Department of Health Ann Arundel Office of Emergency Management u

Arlington County Office of Emergency Management Arlington County Public Health Office

  • . Baltimore City Health Dep~ent e

Baltimore City Police Department Baltimore County Fire and Emergency Medical Services e

Baltimore County Health and Human Services Baltimore County Police Department Beaver County Emergency Services Caroline County Emergency Services e

Carroll County Emergency Management Carroll County Health Department e

Cecil County Department of Emergency Services e

Charles County Department of Emergency Services Charles County Department of Health

Fairfax County Health Department Fairfax County Office of Emergency Management Fairfax County Public Affairs 10 Calvert Cliffs Nuclear Power Plant.

Unclassified

  • Radiological Emergency Preparedness Program After Action Report/Improvement Plan Falls*Church Health Department Falls Church Police. Department Frederick County Department of Emergency Management II Frederick County Department of Health Hancock County Homeland. Security Harford County Department of Emergency Services _

s Harford County Department of Health Howard County Health Department

Kent County Health Department Kent County Office of Emergency Services Calvert Cliffs Nuclear Power Plant Montgomery: County Office Emergency Management and Homeland. Security Prince Georges County ll Prince Georges County Office of Emergency Management

~ Queen Anne County Department of Emergency Services e

Queen Anne County* Department of Health fl Queen Anne County Extension Somerset County Emergency Services c

Somerset County Health Department

  • 0 Talbot County Department of Emergency Services Talbot County Health Department o

Washington County Emergency Management o

Washington County Health Department Wicomico County Department of Emergency Services e. Wicomico County Department of Health 11 Worchester County Emergency Services ll Worchester County Government Worchester County Health Department PrivateN olunteer Organizations s

American*Red Cross Exelon Corporation e

Radio Amateur Civil Emergency Services (RACES}*

~ University of Maryland Department of Environmental Science and Technology*

WSMD Radio, Star 98.3 Federal Jurisdictj_on Federal Emergency Management Agency (FEMA) 11

Unclassified

United States Department of Agriculture United States Department of Energy - Federal Radiological Monitoring and Assessment Center (DOE-FRMAC) e United States Department of Homeland Security

  • United States Nuclear Regulatory Commission 12

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan.

Calvert Cliffs Nuclear Power Plant SECTION 2: EXERCISE DESIGN

SUMMARY

2.1 Exercise Purpose and D.esign On December 7, 1979, the President directed the Federal Emergency Management Agency (FEMA) to.

assume the lead re~ponsibility for all off-site nuclear planning and response. FEMA' s activities were conducted pursuant to 44 Code of Federal Regulations (CFR) Parts 350, 351 and 352. These regulations are a key element in the Radiological Emergency Preparedness (REP) Progr3ll1: that was established following the Three Mile Island Nuclear Station accident in March 1979.

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

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

B. Determining whether such plans and procedures can be implemented on the basis of observation and evaluation of exercises of the plans and procedures conducted by State and local governments; C. Responding to r~quests by the "Q.S. Nuclear Regulatory Commission (NRC) pursuant to the Memorandum of Understanding between theNRC 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.

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Unclassified Radiological Emergency Preparedriess Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Representatives of these agencies serve on the FEMA Region III Regional Assistance Committee

. (RAC), which is chaired by FEMA. A REP Exercise was conducted during the week of September 11, 2017; (in addition to one Out of Sequence exercise) 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 CCNPP. The purpose of this 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 evaluator team, with.

final determinations 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.

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Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Emergency Plannmg Zone

Description:

Plume Emergency Planning Zone Description CCNPP is located near Marylarid Highway 2-4 in Calvert County, Marylarid, on the west bank of the Chesapeake Bay near Lusby, Marylarid.-,The coordinates of the site are 38°25"39.7' North arid 76°26"45' West. The site is owned arid operated by Constellation Energy.Group arid cqvers ari area of approximately 2, i 08 acres. Seventy percent of the area remains forested and relatively undisturbed by CCNPP ~ctivities. There are several endarigered plarit arid insect species withm the boundaries of the site. Two pressurized water reactors each generate ari electrical output of 825 MW units that provide power to around 400,000 residential customers. Unit I begari commercial operation during May 1975 arid _Unit 2. in April 1977. On March 23, 2002, the license was renewed, thereby extending the life of the plarit by 20 years.

Nearby communities include: Calvert Beach arid Long Beach, approximately 3 miles to the northwest; Cove* Point, approximately 4 *1/2 miles to the southeast; Chesapeake Rarich Estates, approximately 6 miles to the south-southwest; arid 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 plarit defines several small watersheds. The watershed containing the plant arid auxiliary structures drains into the Chesapeake Bay. Chesapeake Bay has ari average depth of 30 feet arid receives the majority of its fresh water, sediment, and nutrients from the Susquehanna River.

A majority fraction of the larid in the area surrounding the site is devoted to agricultural arid forest use, such as farming of tobacco, com, soybearis, arid hay. Dairy farming is of minor importarice. The waters adjacent to the site are used for commercial fishing, primarily for shellfish such as clams, oysters, and crabs;

  • There are approximately 50,058 people in the 10-mile EPZ, 13,307 in the 5-mile EPZ, arid 2,329 iJ:i the 2;..mile EPZ. There are approximately 9,563 trarisients within.the EPZ during peak seasonal activities, e.g., _daytime, during the summer. No major populated cities (greater thari 25,000) exist within the 10-.

mileEPZ.

Ingestion Pathway Emergency Planning Zone*

'The Ingestion Pathway EPZ is approximately 7,850 square miles in area, which is equivalent to a 50-mile radius around the plarit site. The States ofMarylarid, Delaware, Virginia, arid 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 plarit site. According to the U.S. Census Bureau 2014 five )'."ear estimates, the State of Delaware has a population of approximately 73,452 residents residing within the Calvert Cliffs Ingestion Pathway EPZ.

15

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan.

Calvert Cliffs Nuclear Power Plant

. 2.2 Exercise Objectives, Capabilities and.Activities The* objective of CAL VEX 2017, was to demonstrate the capabilities of State and local emergency management agencies to mobilize emergency managemenf and emergency resporise personnel, to activate emergency operations centers and support faciliti~s, and to protect the health, lives, and property of the citizens residing within the 50 mile Ingestion Pathway 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 inf orm,ation was prepared but not actually released.

An essential capability of the REP Program is the ability of the State and risk and support countie.s to mobilize personnel and resources to support protective actions for the Ingestion Pathway EPZ, including

  • relocation and the interdiction of contaminated food.

2.3 Scenario Summary NOTE: AU information below is simulated The times for the events are approximate as the NRC

  • licensees operations crew on the reactor training simulator will be provided opportunity for free play.

On September 12, 2017 an Alert is declared by 0811 due to a potential loss of the reactor cool~t barrier~

At 1019 a Site Area Emergency is declared due.to the potential or los~ of two barriers.

At 1130 the steam generator tube ruptures outside containment and pot9ntial loss of fuel dadding

.* exists. At 1142 a General Emergency is q.eclared for the potential or loss of the third barrier. The State of Maryland wiUmake protective action decisions based Protective Action Recommendations (PARs) from the Licensee and State officials.

At 1234, this portion of the exercise is terminated.

On September 13, 2017 field san;ipling teams assessed water, soil, dairy and leafy vegetables for radiation contamination and pre-selected schools responded to the events from September 12 as if they were occurring on that day.

On September 14, 2017 radiation data was presented to communities surrounding CCNPP out to 50 miles and implementation of P ARs and P ADs were discussed.

16

Unclassified Radiological Emergency Preparedness Program

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Emergency Information & Instructions for the AnnCtyEOC(I)

PubliciMedia 5bl Availability & use of Commodity & Resource BalCoEOC(I)

Information 3el Preprinted Materials for Implementing P ADs for BalCoEOC(I)

Commodities & Resources 3e2 Implementation of Relocation/Reentry/Return BalCoEOC(I)

Decisions 3fl Emergency Information & Instructions for the BalCoEOC(I)

Public/Media 5bl CalCoPS MES Implementation of PADs for Schools 3c2 CalCo PS PHS Implementation of PADs for Schools 3c2 CalCo TACP Equipment and Supplies to Support Operations lel Implementation_ of Emergency Worker Exposure CalCo TACP

  • Control 3al CalCo TACP Implementation of Traffic & Access Control 3dl

.CalCoEOC Impediments to Evacuation 3d2 CalCoEOC Implementation of Traffic & Access Control 3dl CalCoEOC Implementation of P ADs for Schools 3c2 Implementation of P ADs for disabilities &

CalCoEOC access/functional needs people 3cl Implementation of KI PAD for Institutionalized CalCoEOC Individuals/Public

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CalCoEOC Control 3al CalCoEOC

  • Mobilization 1al Emergency Information & Instructions for the CalCoEOC Public/Media 5bl CalCoEOC Direction and Control lcl CalCoEOC Activation of the B.ack-up ANS 5a3 '

CalCoEOC Communications Equipment ldl CaiCoEOC Equipment and Supplies to Support Operations lel CalCoEOC Activation of the Prompt Alert & Notification System Sal P ADs for disabilities & access/functional needs CalCoEOC people 2cl PAD decision-making process and coordination for CalCoEOC the General Public 2b2 CalCoEOC Emergency.Worker Exposure Control Decisions 2al Availability & use of Commodity & Resource CalCoEOC (I)

  • Information 3el 19

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 2017 Calvert. Cliffs Nuclear Power Plant Exercise

~Bte:ma Preprinted Materials for Implementing P ADs for

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Commodities & Resources 3e2 Implementation of Relocation/Reentry/Return CalCoEOC (I)

Decisions 3fl Emergency Information & Instructions for the CalCoEOC (I)

Public/Media 5bl Availability & use of Commodity & Resource CarCo MD EOC (I)

Information 3el Preprinted Materials for Implementing P ADs for CarCo MD EOC (I)

Commodities & Resources 3e2

. Implementation of~elocation/Reentry/Return CarCo MD EOC (I)

Decisions 3fl Emergency Information & Instructions for the CarCo MD EOC (I)

Public/Media 5bl Availability & use of Commodity & Resource CBEOC(I)

Information 3el Preprinted Materials for Implementing P ADs for CBEOC(I)

Commodities & Resources 3e2 Implementation of Relocation/Reentry/Return CBEOC(I)

Decisions 3fl Emergency Information & Instructions for the CBEOC(I)

Public/Media 5bl Availability & use of Commodity & Resource ChrlsCo EOC (I)

Information 3el Preprinted Materials for Implementing P ADs for ChrlsCo EOC (I)

Commodities & Resources 3e2 Implementation of Relocation/Reentry/Return.

ChrlsCo EOC (I)

Decisions

  • 3fl Emergency Iriformation & Instructions for the ChrlsCo EOC (I)

Public/Media 5bl A vaiiability & use of Commodity & Resource CrlC EOC (I)

Information 3el Preprinted Materials for Implementing P ADs for CrlC EOC (I)

Commodities & Resources 3e2 Implementation of Relocation/Reentry/Return CrlC EOC (I)

Decisions 3fl Emergency Information & Instructions for the CrlCEOC (I)

Public/Media 5bl DEFSTB Equipment and Supplies to Support Operations lel Availability & use of Commodity & Resource DoC EOC (I)

Information 3el 20

Unclassified After Action Report/Improvement Plan Radiological Emergency Preparedness Program Calvert Cliffs Nuclear Power Plant SECTION 3: ANALYSIS OF CAP AQILITIES.

3.1 Exercise Evaluation. and Results Contained in this section are the results and findings of the evaluations of all jurisdictions and locations that participated in the September 12-14, 2017, Post-Plume.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 ORO of State and local government to protect the health and safety of the public in the *so mile EPZ surrounding the CCNPP.

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

Detailed information on the exercise evaluation area criteria 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 functi~nal 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 foHowing letters:

Ji (D) Demonstrat~d 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 i 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 tak~n in event of a -.

radiological emergency to protect the health and safety of the public living in the vicitiity*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 OROs emergency plan/implementation.procedures, rather than that of the OROs performance.

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

17

Unclassified Radiological Emergency Preparedness Program Mter Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant (M) Met: status of a REP exercise Evaluation Area Criterion indicating that the participating ORO demonstrated all demonstration criteria for the Evaluation Area Criterion to the level required in the extent of..:of-play agreement with no Findings assessed in the current exercise and no unresolved prior Findings.

Tables 3.1 - Summary of Exercise Evaluation Table 3.la - Exercise Evaluation by Classification.

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Information Preprinted Materials for Implementing P ADs for AACo BOC (I)

Commodities & Resources Implementation of Relocation/Reentry /Return AACo BOC 0)

Decisions Emergency Information & Instructions for the AACo BOC (I)

Public/Media AnnCtyEOC(I)

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Public/Media 5bl DoCoBuRA Communications Equipment ldl DoCoBuRA Equipment and Supplies to Support Operations lel Implementation of Emergency Worker Exposure DoCoBuRA Control 3al DoCoBuRA Activation of the Back-up ANS 5a3 DoCoEOC Communications.Equipment ldl DoCoEOC Equipment and Supplies to Support Operations lel DoCoEOC Emergency Worker Exposure Control Decisions 2al PAD decision-making process and coordination for DoCoEOC the General Public 2b2 P ADs for disabilities & access/functional needs DoCoEOC people 2cl DoCoEOC Activation of the Prompt Alert & Notification System 5al Implementation of Emergency Worker Exposure DoCoEOC Control 3al Implementation of KI PAD for Institutionalized DoCoEOC Individuals/Public 3bl Implementation of P ADs for disabilities &

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  • DoCoEOC Public/Media 5bl DoCoEOC Activation of the Back-up ANS 5a3 DoCoEOC Mobilization lal DoCoTACP Equipment and Supplies to Support Operations lel Implementation of Emergency Worker Exposure DoCo TACP Control 3al DoCo TACP Implementation of Traffic & Access Control 3dl Availability & use of Commodity & Resource FarFxCoEOC(I)

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Unclassified Radiological Emergency Preparedness Program Calvert Cliffs Nuclear Power Plant After Action Report/Improvement Plan 3.3 Criteria Evaluation Summari~s 3.3.1 State Jurisdictions 3.3.1.l Maryland State Emergency Operations Center

a. MET: l.c.l, l.d.1, l.e.l, 2.d.. l, 2.e.l, 3.d.l, 3e.1, 3.e,2, 3.f.l, 5.b.l
b. LEVEL 1 FINDINGS: NONE c.. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE.
e. PRIOR ISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.2 Maryland State Emergency Operations Center Joint Information Center

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

b. LEVEL 1 FINDINGS; NONE

. *c. LEVEL 2 FINDINGS: NONE

d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.3 Maryland Accident Assessment Center, Baltimore
a. MET: l.c.l, l.a.l, l.d.1, l.e.l, 2.a.l, 2.b.l, 2.b.2, 4.a.2 b, LEVEL 1 FINDINGS; NONE
c. LEVE;L 2 FINDINGS: NONE
d. PLAN ISSUES:

ISSUE FOR CRITERION: 461 I

\\

CONDITION: There is crucial information that needs to be provided by the State of Maryland to the contract General Engineering Laboratories (GEL) for ingestion sampling analyses.

POSSIBLE CAPSE: With the closmg of the Maryland Dep~ent of Environment Laboratory, a contract laboratory (GEL) was chosen to count the ingestion sampling media. However, there are important counting parameters that need to be supplied to GEL that cannot be found in the agreement or procedure.

27

Unclassified Radiological Emergency Preparedness Program..

After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant

REFERENCE:

NUREG-0654/FEMA-REPl, C.3, J.11 and EP-601, :'Laboratory Procedures for Radiological Emergencies" EFFECT: If requirements and counting parameters are n~t specified to the contract labm;atory, it could result in a delay in receiving, preparing, analyzing, and reporting ingestion sampling data, which is used to make.protective action decisions for the public.

RECOMMENDATION:

Include the following items in the Memorandum of Agreement, procedure, or by other written documents and provide them to the contract laQorato.ry:

1.
2.
3.
4.
5.

.6.

7.

Sample retention time, if samples are to be retained greater than 30 days; If meat and fish samples sh~uld be counted whole or prepared with only the edible portions; If soil samples should be dried or quick counted as wet samples; Units to be reported for each sample media, as compared to ingestion calculation spreadshee~s; List of radionuclides to be included in the sample report and their respective Minimum Detectable Activities, to reduce sample turn.:around time;

  • Chain-of.:.custody form_or method that will be used when*sending sarp.ples to GEL; Comparison of sampling volumes for each media type with amount of material that is needed for: counting, to potentially reduce sampling time
  • and shipment volume.

CORRECTIVE ACTION DEMONSTRATED: The Procedure MDE-601 Laboratory Procedures for R~diol~gical Emergencies Sample Processing and Preparation Sample Analysis Reporting Results was updated to address the items above.

~: PRIOR ISSUES: RESOLVED : NONE

f. PRIOR ISSUES: UNRESOLVED: NONE 3.~.1.4 Maryland Accident Assessment Center, Barstow I
a. MET: l.c.l, l.a.l, l.d.l; l.e.1, 2.a.1, 2.b.l, 2.b.2

._/

b. LEVEL l FINDINGS: NONE
c. LEVEL 2 FINDINGS ISSUE FOR CRITERION: 4.a.2 28

I_

Unclassified Radiological Emergency Preparedness Program After Action Report!Improvement'Plan

  • Calvert Cliffs Nuclear Power Plant
  • . CONDITION: Field Monitoring Teams Alpha and Bravo were not provided the entire Protective Action Decision (PAD) by the Field Monitoring Team.. Leader_ to ingest Potassium Iodide.

POSSIBLE CAUSE: The Fiel~ Monitoring Team Leader failed to communicate the com.plete Protective Action Decision to Field Monitoring Teams Alpha & Bravo, which included the message that emergency workers should ingest Potassium Iodide.

j

REFERENCE:

NUREG-0654/FEMA-REP-l, rev 1, C.l; H.12; I.7, 8, 11; J.lOa EFFECT: The field monitoring teams could potentially have been exposed radioactivel-131 while completing radiological surveys as part of their sampling acp.vitiys.

REDEMONSTRATION:_ Following retraining of the communication and coordination of the PAD the Field Team Leader properly communicated with the Field Monit()ring

  • Team in the field and confirmed receipt of the proper information. This step is now included in the Field Monitoring Team Leader Checklist or procedure reducing.the probability of missing this critical action again.
d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.5 Maryland Department of the Environment Field Monitoring Team A
a. MET: l.a.l, l.d.1? l.e.l, 3.a.l, 4.a.3
b. LEVEL 1 FINDINGS; NONE
c. LEVEL 2 FINDINGS: 4.a.3 ISSUE FOR CRITERION: 4.a.3 CONDITION: Monitoring Team A did not adequately demonstrate'the capability to take an air ~ample using the RADECO Air Sampler during the plume phase.

POSSIBLE CAUSE: The Maryland State Field Monitoring Team A did not receive sufficient training to be knowledgeable in the procedure to take an air sample, or the written procedures in the plans were not sufficient to allow team members to correctly

\\

take an air sample.

REFERENCE:

NUREG-0654/FEMA-REP-l, C.1; H.12: I.8, 9; J.10.a EFFECT: FMT A would not have been able to take an air sample that could be relied upon, and the amount of time required to take and_process an air sample would have delayed.necessary field monitoring.

29

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan_.

Calvert Cliffs Nuclear Power Plant CORRECTIVE ACTION DEMONSTRATED: Following retraining the air sampling was. redemonstrated on September 13, and FMT A successfully demonstrated the capability take an air sample.

- d. PLAN ISSUES:

ISSUE FOR CRITERION: 4a3 CONDITION: There is no Memorandum of Understanding or Agreement in place to perform plume phase air sample analysis.

POS~IBLE CAUSE: With the closing of the Maryland State Lab and the proposed use of contract laboratories for post-plume phase sample* analyses, there is no written provision for counting plume phase air samples.

REFERENCE:

NUREG.:.0654/FEMA-REPl, H.12 and EP~601, "Laboratory Procedures for Radiological Emergencies" EFFECT: Without *an agreement in place to count air samples, there may be delays in verifying plume data that was used in making protective action decisions for the public.

RECOMMENDATIONS:

1. Include process for counting plume phase air samples in EP~601._
2. Obtain a Memorandum of Understanding or Agreement if using local laboratories for air sample analyses.
3. If using a contract laboratory, include this sample media in the Agreement and ensure.

that correct filter and cartridge geometries are available for analysis.

CORRECTIVE ACTION DEMONSTRATED: EP-601 was updated to include the process for counting plume phase air samples and their analyses.

.e: PRIOR ISSUES: RESOLVED : NONE

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.1.6 Maryland Department of the Environment Field Monitoring Team B
  • r
a. MET: l.a.l;- l.d.l, l.e.l, 3.a.1, 4.a.3
b. LEVEL 1 FINDINGS; NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE

-*e: PRIOR ISSUES: RESOLVED : NONE

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan 1

Calvert Cliffs Nuclear Power Plant

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.1. 7 Maryland Department of the Environment Field Sampling Team
a. MET: l.d.l, l.e.l, 3.a.1,,4.b.l
b. LEVEL 1 FINDINGS; NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN-ISSUES:

ISSUE FOR CRITERION: lel CONDITION: There is no procedural guidance or protocol for source checking the ThermoScientific RadEye B20-ER survey meter.

i POSSIBLE CAUSE: This instrument is relatively new to field operations and has not been added to the procedure or given a source check tag with a range o.facceptable

  • readings.

REFERENCE:

NUREG-0654/FEMA-REPl, H.10 and EP-302, "~bient Radiation Monitoring and Air Sampling".

EFFECT: There is no guidance for source checking the Ra.dEye survey instrument,.

which was used in the field ingestion sampling to measure exposure rate. Therefore, the.

instrument was not source checked prior to use. Possible malfunctions with the meter might not be detected without an accurate source check.

RECOMMENDATION:

1.

Include applicable instructions for the RadEye in EP-302.

2.

Make a source check tag for the RadEye with instructions for sourc~ checking the meter, including a range of acceptable readings, with the manufacturer supplied Lu-176 source.

3.

Train field team members on the RadEye *sou.tee check protocols.

CORRECTED ACTION DEMONSTRATED: Instructions were added to the RadEYE inEP-302.

e: PRIOR ISSUES: RESOLVED : NONE

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2 Ris}{ Jurisdictions 3.3.2. 1 Calvert County Emergency Operations Center 1-31

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant *

a. MET: l.c.l, 5.a.3, l.d.1, 1.eJ, 2.a;l, 2.b.2, 2.c.l, 5.a.l, 3.a.l, 3.b.l, 3.c.l, 3.c.2, 3.d.l, 3.d.2, 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 Calvert County Traffic and Access Control
a. MET: Le.l, 3.a.l, 3.d.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. 3
  • Calvert County Public Schools, Mutual Elementary School
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 4 Calvert County Public Schools, Patuxent High School
a. MET: 3.c~2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE cl. PLAN ISSUES: NONE e: PRIORISSUES: RESOLVED: NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 32.

Unclassified

  • Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nnclear Power Plant 3.3.2. 5 Dorchester C~mnty Emergency Operations Center
a. MET: l.c.l, 5.a.3, l.d.l, l.e.l, 2.a.l, 2.b.2, 2.c.l, 5.a.l, 3.a.l, 3.b.t, 3.c.l, 3.c.2, 3.d.l, 3.d.2; 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. 6 Dorche.ster County Back-up Route Alerting
a. MET: l.d.l, l.e.l, 3.a.l, 5.a.3
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 7 Dorchester County Monitoring and Decontamination Center, Dorchester County Career and Technology Center a; MET: 6.a.1, 6.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED :

ISSUE NO: 11-15-6al-L2-1 CRITERION: Monitoring, Decontamination, & Registration of Evacuees CONDITION: The process used in vehicle monitoring and decontamination allowed for cross-contamination. Contaminated vehicles were directed to drive down through the clean area.

POSSIBLE CAUSE: The designated vehicle monitoring team was unfamiliar with the facility procedures* for processing contaminated vehicles.

33

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant

REFERENCE:

NUREG-0654/FEMA-REP-1: K.5.a, b.

EFFECT: Contaminated vehicles could be allowed.to exit the decontamination area and cross-contaminate other vehicles and personnel.

CORRECTIVE ACTION DEMONSTRATED: A revised the site plan diagram with designated paths for clean and contaminated vehicles and proper vehicle decontamination procedures were demonstrated by monitoring and decontamination staff for evacuee and emergency worker vehicles during a redemonstration exercise on August 14, 2017..

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 8 Dorchester County Reception Center, Dorchester County Career and Technology Center
a. MET: 6.a.l.; 6.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE

.e: PRIOR ISSUES: RESOLVED :

ISSUE NO: 11-15-6al-L2-2 CRITERION: Monitoring, Decontamination, & Registration of Evacuees CONDITION: The Dorchester County Career and Technology Center Reception Center Manager did not report to the County Emergency Management pertinent information on the results of monitoring. A person was not designated as the manager.

POSSIBLE.CAUSE: The Reception Center Manager position was not assigned at the initial activation and/or no one was trained to assume the responsibility.

REFERENCE:

NUREG-0654/FEMA-REP-1: A.3; C.4; J.10.h; J.12 EFFECT: Without someone assigned to report pertinent information to the County Emergency Management, the support that the location provides to the public (monitoring/decontamination and medical treatment) could be delayed.

CORRECTIVE ACTION DEMONSTRATED~ The designated individual identified in the plan as a reception center manager was 34

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant retrained in the role. The reception center operations were demonstrated during a redemonstration exercise on August 14, 2017.

f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 9 Dorchester County Traffic and* Access Control
a. MET: Le.I, 3.a.1, 3.d.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 3.3.2.10 St. Mary's County Emergency Operations Center
a. MET: 1.c.l, 5.a.3, l.d.l, l.e.1,2.a.1, 2.b.2, 2.c.l, 5.a.1, 3.a.l, 3.b._1, 3.c.l, 3.c.2, 3.d.l, 3.d.2, 5.b.l, La.I
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.11 St. Mary's County Public Schools, Green Holly Elementary School
a. MET: 3.c.2
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2.12 St.. Mary's County Traffic and Access Control
a. MET: Le.I, 3.a.l, 3.d.l
b. LEVEL 1 FINDINGS: NONE 35

Unclassified_

Radiological Emergency Preparedness Program

_ After Action Report/Improvement Plan

c. LEVEL 2 FINDINGS: NONE

. d. PLAN ISSUES: NONE e: PRJOR ISSUES: RESOLVED : NONE

f. PRIOR ISSUES: UNRESOLVED: NONE*

3.3.3 Support Jurisdictions 3.3.2. 13 Annapolis City Einergericy Operations Center (I)

a. MET: 3.e.l, 3.e.2, 3.f.l, ~.b.l _
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRJOR ISSUES: RESOLVED : NONE
f. PRJORISSUES: UNRESOLVED: NONE Calvert Cliffs Nuclear Power. Plant 3.3.2. 14 Anne Arundel County Emergency Operations Center (I)
a. MET: 3_.e.l, 3.e.2, 3.f.l, 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRJOR ISSUES: RESOLVED : NONE
f. PRJOR ISSUES: UNRESOLVED: NONE 3.3.2. 15 Arlington County Emergency Operations Center (I)
a. MET: 3.e.l, 3.e.2, 3.f.1, 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN.ISSUES: NONE e: PRJOR ISSUES: RESOLVED : NONE
f. PRJOR IS SUBS: UNRESOLVED: NONE 3.3.2.-16 1 Baltimore County Emergency Operations Center (I) 36

Unclassified

. Radiological_Emergency Preparedness Program After Action Reportf.lmprovement Plan Calvert Cliffs Nuclear Power Plaut

a. MET: 3.e.l, 3.e.2,J.f.l, 5.b.1 *
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: TJNRESOLVED: NONE 3.3.2. 17 Caroline County MD Emergency Op.erations Center (I)
a. MET: 3.e.l,'3.e.2, 3.f.l; 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. 18 Carroll County Emergency Operations Center (I)
a. MET: 3.e.l, 3.e.2, 3.f.l, 5;b.1
b. LEVEL l FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE a: PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE

. 3.3~2. 19 Cecil County Emergency Operations Cente~ (I)

a. MET: 3.e.l, 3.e.2, 3.f.1, 5.b.1
b. LEVEL 1 FINDiNGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE.

e: PRIOR ISSUES: RESOLVED : NONE

f. PRIOR ISSUES: UNRESOLVED: NONE
  • 37

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 3.3.2. 20 Charles County Emergency Operations Center (I)

a. MET: 3.e.l, 3.e.2, 3.f.1, 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 21 City of Alexandria Emergency Operations Center (I)
a. MET: 3.e.1, 3.e.2, 3.f.1, 5~b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRJOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 22 City of Baltimore Emergency Operations Center (I)
a. MET: 3.e.l, 3.e.2, 3.f.1, 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRIORISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 23 Fairfax Co Emergency Operations Center (I) *
a. MET: 3.e.l, 3.e.2, 3.f.1, 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE 38

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant

f. PRlOR ISSUES: lJNRESOLVED: NONE 3.3.2. 24 Falls Church Emergency Operations Center (I)
a. MET: 3.e.l, 3.e.2, 3.r.'l, 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
  • d. PLAN ISSUES: NONE e: PRlOR ISSUES: RESOLVED : NONE
f. PRlOR ISSUES: UNRESOLVED: NONE *
  • 3.3.2. 25 Frederick County Emergency Operations Center (I)
a. MET: 3.e.1, 3.e.2, 3.f.1, 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRlOR ISSUES: RESOLVED : NONE
f. PRlOR ISSUES: UNRESOLVED: NONE 3.3.2. 26 Harford County Emergency Operations Center (I)
a. MET: 3.e.l, 3.e.2, 3.f.1, 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL.2 FINDINGS:. NONE
d. PLAN ISSUES: NONE e: PRlOR ISSUES: RESOLVED : NONE
f. PRlOR ISSUES: UNRESOLVED: NONE.

3.3.2. 27 Howard County Emergency Operations Center (I)

a. MET: 3.e.l, 3.e:2, 3.f.l, 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE 39

I Unclassified Radiological Emergency Preparedness Program

  • After Action Report/Improvement Plan e: PRIOR ISSUES: RESOLVED :NONE*
f. PRIOR ISSUES: UNRESOLVED: NONE CalvertCiiffs Nuclear P~wer,Plant 3.3.2. 28 Kent, MD, County Emergency Operations Center (I)
a. MET: 3.e,1, 3.e.2, 3.f.l, 5.b.1
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: J>RIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 29 Montgomery County Emergency Operations Center (I)
  • a. MET: 3.e.l, 3.e.2, 3.f.1, 5.b_.1
b. LEVEL 1 FINDINGS: NONE *
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSBES: NONE e: PRIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 30 Prince Georges _County Emergency Operations Center (I)
a. MET: 3.e.1, 3.e.2, 3.f.1, 5.b.l
b. LEVEL 1 FINDINGS: NONE.
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 31 Queen Anne's County Emergency Operations Center (I)
a. MET: 3.e.l~ 3.e.2, 3.f.l; 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE 40

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant

d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 32 Somerset County Emergency Operations Center (I)
a. MET: 3.e.l, 3,e.2, 3.f.1, 5.b.l *
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE.-
f. PRIOR ISSUES: UNRESOLVED: NONE*

3.3.2. 33 Talbot County Emergency Operations Center (I)

a. MET: 3.e.l, 3.e.2, 3.f.l, 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. 34 Washington County Emergency Operations Center (I) a.'"MET: 3.e.l, 3.e.2, 3.f.1, 5.b.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRIOR ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 3.3.2. 35 Washington, DC Homeland Security Emergency Management Agency EOC (I)
a. MET: 3.e.l, 3.e.2, 3.f.1, 5.b.l 41

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant

b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE

.. d. PLAN ISSUES: NONE e: PRJOR ISSUES: RESOLVED :.NONE

f. PlUORISSUES: UNRESOLVED: NONE 3.3.2. 36 Wicomico County Emergency Operations Center.(I)
a. MET: 3:e.l, 3.e.2, 3.f.1, 5.b.l.
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE

. d. PLAN ISSUES: NONE e: PRJOR ISSUES: RESOLVED : NONE

f. PRJOR ISSUES: UNRESOLVED: NONE 3.3.2~ 37 Worcester County Emergency Operations Center (I)
a. MET: 3.e.l, 3.e.2, 3.f.l, 5.b.1

. b. LEVEL 1 FINDINGS: NONE

c. LEVEL 2 FINDINGS: NONE*
d. PLAN ISSUES: NONE e: PRJOR ISSUES: RESOLVED : NONE
f. PRJOR ISSUES: UNRESOLVED: NONE 3.3.3 Private Jurisdictions 3.3.4. 1, GEL Laboratories LLC
a. MET: l.e.1, 3;a.l, 4.c.l
b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE e: PRJOR ISSUES: RESOLVED : NONE
f. PRJOR ISSUES: UNRESOLVED: NONE 42

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan 3.3.4. Z Star 98.3 Radio Station a: MET: l.d.l, 5.a.l

b. LEVEL 1 FINDINGS: NONE
c. LEVEL 2 FINDINGS: NONE
d. PLAN ISSUES: NONE
  • e: PRIOR-ISSUES: RESOLVED : NONE
f. PRIOR ISSUES: UNRESOLVED: NONE 43 Calvert Cliffs Nuclear Power Plant

/

After Action Report/Improvement Plan Unclassified Radiological-Emergency Preparedness Program Calvert Cliffs Nuclear Power Plant SECTION 4: DEMONSTRATED STRENGTHS 4.1 State Jurisdictions 4.1.1 The MEMA utilizes an Operational Tempo Board, which is broadcast on the monitors to allow all SEOC staff to view. This Ops-Tempo Board also enforces key decision-making times and allo:ws the SEOC Commander to facilitate briefings. MEMA also.

broadcast coordination calls with Risk Jurisdictions throughout the SEOC. This provided situational awareness to all SEOC Command and Support staff.

4.1.2 During CALVEXl 7, MEMA was managing several events simultaneously.

MEMA staff were processing EMAC requests for Hurricanes Irma and Harvey, activated an Opioid Task Force, and executed the, Plume Phase portion of CAL VEXl 7 in_the SEOC., The ability to manage several incidents simultaneously demonstrated that Maryland's public safety officials are well versed in all-hazards emergency management practices and has th~

staffing level needed to handle multiple incidents at the same time.

4.1.3.

During CAL VEXl 7, MEMA deployed a new, geospatial mapping tool titled OSPREY. The system brings together data from multiple automated sources in near real-time and presents it visually. OSPREY was activated to show the Calvert Cliffs EPZ with overlays of wind direction, and special care facilities such as nursing homes.
  • 4.2 Risk Jurisdictions 4.2.1 At the Calvert County BOC, early precautionary relocation was timely as all was completed almost 1-hour prior t<? the decision to evacuate in zones 1, 2, 4, and 5. This ensured the students and staff were out of the emergency area and the buses/drivers were then available to assist in the evacuation if required.

4.2.2 St. Mary's County has retained their former Emergency Communications Center (ECC), which is within a two mi1,rnte drive of the newer one (used since 2000), and kept it up-to-date, including using it for one day a month as a test, so they have full backup for their "ECC.

4.2.3 St. Mary's County uses an emergency worker exposure control video briefing for just-in-time refresher training. The video is very clear and concise, and can be accessed from any location.

4.2.4 St. Mary's County BOC uses their BOC to the fullest extent to include the four walls of the BOC. The walls were recently painted with a magnetic paint (allowing the use

  • . of magnetic signs to show different positions/ECL levels, etc.). After an exercise, activation, or other event, photos of the information contained on the walls may be used for additional follow up or to assist with any after action items/reports:

4.2.5 Throughout the exercise, the Dorchester County EMD coordinated and facilitated local decision making with enthusiasm, ensuring BOC staff had good situational awareness.

She allowed staff the freedom to fulfill their responsibilities with a minimum amount of guidance and sought their input a~Jlppropriate.

44

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 4.2.6 Dorchester County EOC staff coordinated emergency response activities efficiently and effectively. Communications between each agency and their ability to plan ahead utilizing their checklist were excellent. Knowledge of roles and responsibilities among

  • leadership on through administrative staff appeared co~esive.

45

Unclassified*

Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant SECTION 5: CONCLUSION

  • The State of Maryland and local jurisdictions, except where noted in this report demonstrated knowledge of their Radiological Emergency Response plans and procedures. The plans and procedures were adequately implemented during the Calvert Cliffs Nuclear Power Plant Post-Plume exe!cise evaluated on September 12-14, 2017, and the Out of Sequence Exercise conducted onAugust 14, 2017 and December 1, 2017.

FEMA evaluators provided analyses of 206 evaluatfon criteria. These analyses resulted in a determination of no Level 1 Findings, two Level 2 Findings, and three 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 CPR 350.5) and there is reasonable assurance they can be implemented, as demonstrated during this exercise.

46

Unclassified

. Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant

  • APPENDIX A: EXERCISE TIMELINE September 12-14, 2017 Calvert Cliffs Nuclear Power Plant Unusual Event Alert 0811 0819 0819 0823 0822 0824 0819
0819, Site Area Emergency 1019 1030 1019 1028 1019 1026 1025 1025 General Emergency 1142 1152 1143 1144 1144 1148 1148 1146 Simulated Radiation Release Started 0937 1015 0937 1011 1009 1015 Simulated Radiation Release Terminated On-going On-going On-going On-going On-going On-going. On-going Facility Declared Operational 0845 1010 0918 0913 0856 0825 0830 Governor's Declaration of State of Emergency 1042 1115 1115 1123 Exercise Terminated 1234 1230 1235 1222 1238 1234 1239 First Precautionary/Protective Actions: Describe:

Agriculture: farm animals on store feed.and covered water 10*rniies of the plant. Risk schools in Calvert and St. Mary's Counties relocate to host school. Water 1050 1050 1057 1037 1016 1050 1050 Restrictions: Bay.Bridge south to point lookout all waterways. Close all parks and recreation areas in Calvert and St. Mary's Counties. No KI for EW's.

  • Siren Sounding 1100 1100 1100 1100 1100 1100 1100 EAS Broadcast time 1103 1103 1103 1103 1103 1103 1103 Second Precautionary/ Protective Actions: Describe Evac Zones 1,2,4,5; Shelter Zones 3,6,7 1210 1210 1235 1207 1210 1210 1210 Agriculture _50 miles; Restrict Air space* 10 miles 360 Siren Sounding 1220 1220 1220 1220 1220 1220 1220 EAS Message Broadcast 1223 1223 1223 1223 1223 1223 1223 Decision to take KI: EWs, General Public 1210 1210 1235 1202 1210 1210 1210
  • Zones 1,2,4,5 47

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant APPENDIX B: EXERCISE EVALUATORS AND TEAM LEADERS September 12-14, 2017 Calvert Cliffs Nuclear Power Plant Annapolis City Emergency Operations Center (I)

Anne Arundel County Emergency Operations Center (I)

Arlington County Emergency Operations Center (I)

Baltimore County Emergency Operations Center (I)

Calvert County Emergency Operations Center Calvert County Emergency Operations Center (I)

Calvert County Public Schools, Mutu~l Elementary School Calvert County Public Schools, Patuxent High School Calvert County Traffic and Access Control Caroline County MD Emergency Operations Center (I)

Carroll* County Emergency Operations Center (I)

  • Cecil County Emergency Operations Center (I)

Charles County Emergency Operations Center (I)

City of Alexandria Emergency Operations Center (I)

City of Baltimore Emergency Operations Center (I)

Delaware Field Sampling Team Delaware State Emergency Operations Center &

Joint Information Center Delaware Technical Assessment Center Dorchester County Back-up Route Alerting Dorchester County Emergency Operations Center Dorchester County Emergency Operations Center Dorchester County Monitoring and Decontamination Center, Dorchester Co1IDty Caree Dorche.ster County Reception Center, Dorchester County Career and Technology Cent Dorchester County Traffic and Access Control Fairfax Co Emergency Operations Center (I)

Falls Church Emergency Operations Center (I)

Frederick County Emergency Operations Center (I) 48 AGENCY '. ' '

John Price FEMARlll John Price

.FEMARlll John Price*

FEMARlll' John Price FEMARlll Patricia Gardner FEMARlll Patricia Gardner FEMARlll Barton Freeman FEMARIII

  • Barton Freeman FEMARlll Patricia Gardner FEMARlll John Price FEMARlll John Price FEMARlll Patricia Gardner FEJvIA Rlll Patricia Gardner FEMARlll Patricia Gardner FEMARlll John Price FEMARlll Cheryl Weaver Contractor William McDougall FEMARlll Cheryl Weaver Contractor Lisa Rink Region.04 Patricia Gardner
  • FEMARlll Lisa Rink Region 04 Patricia Gardner FEMARlll Patricia Gardner FEMARlll Lisa Rink FEMARlV Patricia Gardner FEMARlll Patricia Gardner
  • FEMARlll
  • Patricia Gardner FEMARIII

Unclassified Radiological Emergency Preparedness Program.

After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant GEL Laboratories LLC Michael Shuler FEMARIII.

Harford County Emergency Operations Center (I)

John Price FEMARIII Howard County Emergency Operations Center (I)

John Price_.

FEMARIII Kent County, DE, Emergency Operations Center (I)

William McDougall FEMARIII Kent, MD, County Emergency Operations Center John Price FEMARIII (I)

Maryland Accident Assessment Center, Maryland Kenneth Wierman FEMAHQ Department of the Environment Maryland Emergency Op~rations Center John Price FEMARIII

  • Maryland Ingestion Field Sampling Team i Michael Shuler
  • FEMARIII Maryland Ingestion Field Sampling Team 2
  • Michael Shuler FEMARIII

Maryland State Field Monitoring Team A Kenneth Wierman FEMAHQ Maryland State Field Monitoring Team B Kenneth Wierman FEMAHQ Montgomery County Emergency Operations Center

  • Patricia Gardner FEMARIII (I)

Prince Georges County Emergency Operations Patricia Gardner FEMARIII Center (I)

Queen Anne's County Emergency Operations

  • Jolin Price FEMARIII Center (I)

Somerset County Emergency Operations Center (I)

John Price FEMARIII St. Mary's County Emergency Operations Center Patricia Gardner

  • FEMARIII St. Mary's County Emergency Operations Center.

Tina Lai-Thomas FEMARIII

'e I

St. Mary's County Public Schools, Gree~ Holly Barton Freeman

  • FEMARIII Elementary School St. Mary's County Traffic and Access Control Rebecca Thomson Contractor Star 98.3 Radio Station John Price FEMARIII Sussex County, DE, Emergency Operations Center
  • William McDougall FEMARIII (I)

Talbot County Emergency Operations Center (I)

John Price FEMARIII Teledyne Brown Laboratories Nicholas Buls FEMARIII Washington County Emergency Operations Center Patricia Gardner FEMARIII (I) 49

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Washington, DC Homeland Security Emergency Management Agency EOC (I)

Wicomico County Emergency Operations Center (i)"

Worcester County Emergency Operations Center (I)

LOCA'ftON.*

Annapolis City Emergency Operations Center (I)

Anne Arundel County Emergency Operations Center (I)

Arlington County Emergency Operations Center (I)

Baltimore County Emerge;ncy Operations Center (I)

Calvert County Emergency Operations Center Calvert County Emergency Operations Center Calvert County Emergency Operations Center Calvert County Emergency Operations Center Calvert County Emergency Operations Center (I)

Calvert County Public Schools, Mutual Elementary School Calvert County Public Schools, Patuxent High School Calvert County Traffic and Access Control Caroline County MD Emergency Operations Center (I)

Carroll County Emergency Operations Center (I)

Cecil County Emergency Operations Center (I)

Charles County Emergency Operations Center (I)

City of Alexandria Emergency Operations Center (I)

City of Baltimore Emergency Operations Center (I)

Dorchester County Back-up Route Alerting Dorchester County Emergency Operations Center Dorchester County Emergency Operations Center Dorchester County Emergency Operations Center Dorchester County Emergency Operations Center Dorchester County Tra:f:fi,c ap_d Access Control Fairfax Co Emergency Operations Center (I)

Falls Church Emergency Operations Center (I)

Frederick County Emergency Operations Center (I)

GEL Laboratories LLC Harford County Emergency Operations Center (I)

Howard County Emergency Operations Center (I) 50 Calvert Cliffs Nuclear Power Plant Patricia Gardner FEMARIII Patricia Gardner FEMARIII.

John Price FEMARJII EVAL'UA'F()R

.AGENCY

.*,... B c.*,'.:' "*'*

Roy Smith Contractor Roy Smith Contractor Barbara Thomas FEMARJ Tina Lai-Thomas :

FBMARIII Patricia Gardner FEMARIII Alonzo McSwain FEMAHQ Lynn Steffensen Contractor Roy Smith

  • Contractor John Rice FEMARI

. Lynn Steffensen Contractor Barton Fre~man FEMARIII Alonzo McSwain FEMAHQ Barton Freeman FEMARIII Richard Smjth Contractor

. Taneeka Hollins FEMARI Kathy Duran FEMARIII Barbara Thomas FEMARI Tina Lai-Thomas FEMARIII Marcy Campbell Contractor Lisa Rink FEMARIV Deborah Blunt Contractor Michael Meshenberg Contractor Paul Nied Contractor Deborah Blunt Contractor Ronald Bonner Contractor Ronald Bonner Contractor Michael Meshenberg Contractor Jill Leatherman Contractor Taneeka Hollins FEMARI Richard Sinith Contractor

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Kent, MD, County Emergency Operations Center (I)

Gary Goldberg Contractor Maryland Accident Assessment Center, Maryland Department of Kenneth Wierman FEMAHQ the Environment

  • Maryland Accident Assessment Center, Maryland Department of BradMcRee Contractor

. the Environment Maryland Emergency Operations Center Barbara Thomas FEMARl Maryland Emergency Operations Center John Price FEMARlII Maryland Emergency Operations Center Michael Shuler FEMARlII Maryland Emergency Operations Center Richard Smith Contractor Maryland Ingestion Field Sampling Team 1 Deborah Blunt Contractor

. Maryland Ingestion Field Sampling Team 2 Jill Leatherman Contractor Maryland Joint Information Center, Barstow John Rice FEMAR1 Maryland St Accident Assessment Center/MD Dept of Kenneth Wierman FEMAHQ -

Environ/Ingstn Pthwy Coard Cnt Maryland St Accident Assessment Center/MD Dept of

  • Michael Shuler FEMARlII Environ/Ingstn Pthwy Coard Cnt Maryland State Accident Assessmep.t Center, Emergency Taneeka Hollins FEMARl Operatiqns Facility Barstow Maryland State Accident Assessment Center, Emergency Michael Shuler FEMARlll Operations Facility Barstow Maryland State Emergency Operations Center/Joint Information John Zeidler Contractor Center (Ingestion)

Ml;IIYland State Field Monitoring Team A Gary Goldberg Contractor Maryland State Field Monitoring Team B Jill Leatherman Contractor Montgomery County Emergency Operations Center (I)

Alonzo McSwain FEMAHQ Prince Georges County Emergency Operations Center (I)

Alonzo McSwain FEMAHQ Queen Anne's County Emergency Operations Center (I)

Gary Goldberg Contractor Somerset CoUJ?-ty Emergency Operations Center (I)

Rebecca Thomson Contractor St. Mary's County Emergency Operations Center John Rice FEMARl St. Mary's County Emergency Operations Center Kathy Duran FEMARlII St. Mary's County Emergency Operations Center Tina Lai-Thomas FEMARlII St. Mary's County Emergency Operations Center Rebecca Thomson Contractor St. Mary's County Emergency Operations Center Ronald Bonner Contractor St. Mary's County Public Schools, Green Holly Elementary John °Zeidler Contractor School. *.

St. Mary's County_ Traffic and Access Control Kathy Duran FEMARlII Star 98.3 Radio Station Barton Freeman FEMARlII Talbot County Emergency Operations Center (I)

Barton Freeman FEMARlII Washington CoUrity Emergency Operations Center (I)

Michael Meshenberg Contractor 51

Unclassified Radiological Emergency Preparedness Program After Action Report!Improvem_en_t_P~Ia_n __________________

C_al_ve_r_t C_I_iff:_s._N_u_cle_a_r_Po_w_e_r _PI_an_*

t Washington~ DC Homeland Security 'Emergency Management Agency EOC (I)

Lisa Rink FEMARIV Wicomico County Emergency Operations Center (I)

J>aul Nied Contractor

+-----------<1--------~----i Worcester County Emergency Operations Center (I) *

  • Rebecca Thomson Contractor 52

Unclassified Radiolo();ical Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant APPENDIX C: ACRONYMS AND ABBREVIATIONS CCNPP Calvert Cliffs Nuclear. Power Plant CFR Code of Federal Regulations DOE-United States Department of Energy~ Federal Radiological Monitoring and FRMAC*

Assessment Center EPA United States Environmental Protection Agency EPZ Emergency Planning Zone FEMA Federal Emergency Management Agency NRC Nuclear Regulatory Commission RAC Radiological Assistance Committee RACES Radio Amateur Civil Emergency Services REP Radiological Emergency Prepare~ness RERP Radiological Emergency Response Plans ORO Offsite Response Org~zations PAR Protective Action Recommendation NPP

.Nuclear Power Plant PAD Protective Action Decision ECC Emergency Communications Center EOP Extent of Play 53

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan*

Calvert Cliffs Nuclea,r Power Plant APPENDIX D: EXERCISE PLAN Method of Operations and Extent of Play (EOP)

Sub-element I.a. - Mobilization Criterion l.a. l: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654/FEMA-REP-1, A.La, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; G.3.a; H.3, 4)

INTENT This Sub-element is derived from NUREG-0654/FEMAREP-1, which requires that OROs have the capability to alert, notify, and mobilize emergency personnel, and activate and staff emergency facilities.

EXTENT OF PLAY

. Responsible_ ORO's must demonstrate the capability to receive notification of an incident from the licensee; verify the notification, contact, alert, and mobilize key emergency personnel in a timely manner, and demonstrate the ability to maintain and staff24-hour operations. 24-hour operatic.ms can be demonstrated during the exercise via rosters or shift changes or otherwise in an actual activation. Local and/or Tribal responders must demonstrate the ability to receive and/or-initiate notification to the licensees or other respective emergency management organizations of an incident in a timely manner when they receive information from the licensee or alternate sources.

Responsible ORO's must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. Activation of facilities and staff, including those associated with the ICS, must be completed in accordance with ORO plans/procedures. The location and contact information for facilities included in the incident command must be available to ail appropriate responding agencies and the Nudear Power Plant (NPP) after these facilities have been.

activated.

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

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

Initial law enforcement, fire service, HAZMAT, and emergency medical response to the NPP site may impact the ability to staff REP functions. The ability to identify and request additional 54.

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant resources or identify compensatory measures must be demonstrated. Exercises must also address the role of mutual aid in the incident, as appropriate. An integral part of the response to a hostile action-based (HAB) scenario at an NPP may also be within the auspices of the Federal government ( e.g., Federal Bureau oflnvestigation (FBI), NRC, or DRS). Protocols for requesting Federal, State, local, and Tribal law enforcement support must be demonstrated, as appropriate. Any resources must'be on the ORO's mobilization list so they can be contacted during an incident when 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.

State of Maryland/ Local Jurisdiction Extent of Play:

  • During the plume phase exercise activities on September 12, 2017 responders will p:i;e-stage at various locations to reduce the amount of travel time. Pre-staging within the facility i_s permitted but centers should not initiate activation untilnotification to mobilize and respond has been received. MEMA will mobilize only key State agencies at the Maryland BOC. Key State Agencies are: MEMA, Maryland Military Department/National Guard, Maryland Department of the Environment, Maryland Department of Health and Mental Hygiene, Maryland Departri:lent of Natural Resources, Maryland Department of Agriculture, Maryland Department of Transportation, Maryland State Police, Maryland Department of Education.and the Maryland Institute for Emergency Medical Services Systems.
1. The Maryland Depmifuent of the Environment field monitoring teams (FMT) will pre-stage.
2. 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> rosters will be available for key players at each EOC.
3. Out of sequence locations for Reception Center Monitoring and Decontamination and Emergency Worker monitoring are pre-staged and set up prior to the evaluation.
4. Day Two assessment and Day Three table top exercise will all pe pre-staged.

Locations evaluated:

State EOC (SEOC) e SEOC JIC e

State AAC (Baltimore and Prince Frederick) e CCNPP JIC s

Calvert County o

St. Mary's County Dorchester County State Field Monitoring Teams Outstanding Issues: None 55

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Sub-element l.c - Direction and Control Criterion l.c.1: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible. (NUREG-0654/FEMA-REP-1, A.l.d; A.2.a, b; A.3; C.4, 6)

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

EXTENT OF PLAY Leadership personnel must demonstrate the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed through periodic briefings and/or other means, coordinating with other OROs, and ensuring completion of requirements and.

requests.) Leadership must demonstrate the* ability to prioritize resource tasking and

.replace/supplemenf resources ( e.g., through Memorandum of Understanding's (MOU) or other agreements) when faced with competing demands for finite resources. Any resources identified through LOA/MOUs must be on the ORO's mobilization list so they may be contacted during an incident, when 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.

State of Maryland/ Local Jurisdiction Extent of Play:

All activities associated with direction and control will be performed based on the ORO's plans and procedures and completed, as they would be in an actual emergency.

Locations evaluated:

SEPTEMBER 12, 2017 State EOC State AAC (Baltimore and Prince Frederick)

CCNPP JIC Calvert County St. Mary's County e

Dorchester County SEPTEMBER 13, 2017 MDEAACJPCC Outstanding Issues: None 56

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Sub-element l.d - Communications Equipment Criterion l.d. l: At least two communication systems are available, at least one operates properly, and comn~unication links are established and maintained with appropriate locations..

Communications capabilities are managed in support of emergency operations. (NUREG-0654, F.l., 2.)

INTENT:

This sub-element is derived from NUREG-0654, which provides that OROs should establish reliable primary and backup communication systems to ensure communications with key elllergency personnel at locations such as the following:. appropriate contiguous governments within the emergency planning zone (EPZ), Federal emergency response organizations, the licensee and its facilities, emergency operations centers (EOC), and field teams.

EXTENT OF PLAY OROs must demonstrate that a primary system ?Uld 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.

Locations evaluated:

SEOC SEOCITC State AAC (Baltimore and Prince Frederick)

I)

CCNPP JIC

  • . Radio Station (Star 98.3)

State Field Monitoring Teams State Field Sampling Teams 111 Calvert County St. Mary's County Dorchester County

~ Dorchester County (Back Up Route Alerting)

Outstanding Issues: None Sub-element l.e - Equipment and Supplies to Support Operations.

Criterion 1.e.l: Equipment, maps, displays, dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG0654/FEMA-REP-1, H.7, 10; I.7, 8, 9;

. J.10.a.b.e; J.11, 12; K.3.a; K.5.b) 57

Unclassified Radiological Em_ergency Preparedness Program

. After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant INTENT This sub-element is derived from NUREG-0654 REP-1, which requires that OROs have emergency equipment and supplies adequate to support the emergency response.

EXTENT OF PLAY Assessment of this Demonstration Criterion is accomplished primarily through a baseline evaluation and subsequent periodic inspections. A particular facility's equipment and supplies must be sufficient and consistent with that facility's assigned role in the ORO's emergency operations plans. Use of maps and other displays is encouraged. For non-facility:..based operations, the equipment *and supplies must be sufficient and consistent with the assigned operational role. At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be ayailable, or their availability described.

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

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

ORO quantities of dosimetry and KI available and storage locations(s) will be confirmed by physical inspection at the storage locations(s) or through documentation of current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV.

Available supplies of KI must be within the expiration date indicated on KI bottles or blister packs. As an alternative, the ORO may produce a letter from certified private or State laboratory indicating that the KI supply remains potent in accordance with U.S. Pharmacopoeia standards.

Dosi1lletry: Sufficient quantities of appropriate direct-reading and *permanent record dosimetry and dosimeter chargers must be available for issuance to all emergency workers who. will be dispatched to perform an ORO mission. In addition, OROs must demonstrate provisions to make dosimetry available to specialized response teams ( e.g. civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HazMat, or other ancillary groups) as identified in plans/procedures.

58

Unclassified Radiological Emergency.Preparedness Program After Action Reportlimprovement Plan Calvert Cliffs Nuclear Power Plant Appropriate direct-reading dosimetry must alJow an individual(s) to read the administrative reporting limits *and maximum e~posure limits contained in the ORO's plans/procedures.

Direct-reading dosimeters must be zeroed or operationally checked prior to issuance. The

. dosimeters must be inspected for electrical leakage at least annually and replaced when necessary. Civil Defense Victoreen Model 138s (CD V-138s) (0-200 mR), due to their..

documented history of electrical leakage problems, must be inspected for electrical leakage at least quarterly and replaced when necessary. This leakage testing will be verified during the

,exercise through documentation submitted in the ALC and/or through an SAV.

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

Monitoring Instruments: All instruments must be inspected, inventoried, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recornrnendations. Unmodified CDV-700 series instruments and other instruments without a manufacturer's recornrnendation inust be calibrated amiually. Modified CDV-700 instruments must be calibrated in accordance with tlie recornrnendation of the.modification manufacturer. A label indicating such calibration must be on each instrument or cafi.brated frequency can be verified by other means. Iri 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, tlie 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 contr_ol of team members and detection of activity on air sample collection niedia, 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 lR/hr) and for a high-range instruments whe~ available. Should a source not be 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 O_ROs must set up and operationally check the monitor(s). The monitor(s) must confirm 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 recornrnendations.

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

I 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: Should an agency have a defined role 59

Unclassified Radiolcigical Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant in the REP Plan, they are subject to the planning prncess and standards, as well as the guidance of this ManuaJ..

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

State of Maryland/ Local Jurisdiction Extent of Play:

All activities must be based on the ORO's plans and procedures and completed as they would be in an i:lCtual emergency, unless noted above *or otherwise indicated in the extent of play agreement.

Locations evaluated:

SEOC (i.e. maps and displays)

  • sEocnc State ACC (~altimore and Prince Frederick)

Calvert County St. Mary's County Dorchester County Dorchester County (Route Alerting)

Outstanding Issues: None Sub-element 2.a - Emergency Worker Exposure Control Criterion 2.a. l: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure controi system,including the use of KI, is in place for emergency workers, including prnvisions to authorize radiation exposure in exc.ess of administrative limits or protective action guides. (NUREG-0654/FEMA-REP~l, C.6; f; K.3.a; K.4)

INTENT

. This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place, as specified in the ORO's plans/procedures, to authorize emergency worker exposure limits to be exceeded ~or 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 r~porting limits (that talce into consideration TEDE or organ-specific limits) identified in the ORO's_plans/procedures.

EXTENT OF PLAY 60

Unclassified Radiological Emergency Preparedness Program After.Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Assessment of this Demonstration Criterion must be assessed concurrentl)'." with a licensee exercise and may be demonstrated in_a full scale, functional or tabletop exercise.

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

. emergency plans/procedures.

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

As* appropriate, OR Os must demonstrate the capability to make decisions on the distribution and adminis1!ation of KI as a protective measure for emergency workers~ based on their plans/procedures or projected thyroid dose compared with.the established Protective Action Guide's (PAG) for KI administration.

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

State ~fMaryland Local Jurisdiction Extent of Play:

All activities are based on the ORO's plans and procedures and completed as they would be in an actual emergency. KI tablets for emergency workers will be simulated. (i.e. tic tacs or other.

simulated substitute). Distribution of simulated KI will be demonstrated. Actual distribution of KI will not be demonstrated. Actual self-reading dosimeters and permanent recording *dosimeters will be issued.

Locations evaluated:

I)

  • AAC (Baltimore and Prince Frederick)
  • 11 Calvert County *

(l St. Mary's County Dorchester County Outstanding Issues: None.

Sub-element 2.b - Radiological Assessment, Protective Action Recommendations, and Precautionary and/or Protective Action Decisions for the Plume Phase of the Emergency Criterion 2.b.1: Appropriate protective action recommendations (PARs) are based on available inforn;iation on plant conditions, field monitoring data, and licensee and ORO dose pro}ections, as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA-REP-1, 1.10 and Supplement 3) 61

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to independently project integrated dose from projected or actual dose rates and compare these estimates to the PA Gs.

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

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

During the imtial stage of the *emergency response, following notification of plant conditions that may warrant offsite protective actions, the ORO must demonstrate the capability to use appropriate means, described in the plans/procedures, to develop P ARs for decision-makers based on available info]Jll.ation and recommendations provided by tl?.e license.e as well as field monitoring data, when available. The ORO must also consider any release and meteorological data provided by the licensee.

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

Whei:i the licensee and ORO projected doses*dif:f:er by more than a, factor of 10, the ORO and licensee must determine the source of the difference by discussing input data and assumptions, using different models, or exploring possible reasons. Resolution of these differences must be incorporated into the P ARs when timely and appropriate. The ORO must demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated P ARs.

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 62

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant State of Maryland Negotiated Extent of Play:

All activities are based. on the ORO~s plans and procedures and completed as they would be in an actual emergency, NO release scenarios may require asse*ssment of "what if' conditions or controller inject after the exercise to demonstrate dose projection capabilities.

Locations evaluated:

SEOC ID State AAC (Baltimore and Prince Frederick)

Outstandirtg Issues: None

. Criterion 2.b.2: A decision-making process involving consideration of appropriate factors and necessary coordirtation is used to make precautionary and/or protective action decisions for the general public (including the recommendation for the use of KI, if ORO policy). (NUREG-0654/FEMA-REP-1; A.3; C.4, 6; D.4; J.9; J.10.e, f;* m)

EXTENT OF PLAY Assessment ofthis Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated irt a full-scale, functional or tabletop exercise.*

OROs must have the capability to make both initial and subsequent P ADs. OROs must demonstrate the capability to make* initial P ADs in ~ timely manner appropriate to the incident,.

based on information from the licensee, assessment of plant status and potential or actual releases, other available information related to the incident, input from.appropriate ORO authorities ( e.g., incident command), and P ARs from the utility and ORO staff. In addition, a subsequent or alternate PAD may be appropriate should various conditions (e.g., an HAB incident, weather, release timing and magnitude) pose undue risk to an evacuation, or should evacuation disrupt the efforts to respond to a hostile aytion.

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

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

63

~-----~-----

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Should the ORO determine that KI will be used as.a protective measure for the general public under offsite plans/procedures, then it must demonstrate the capability to make decisions on the

~istribution and administration of KI to supplement sheltering and evacuation. This decision must be based on the ORO's plans/procedures or projected thyroid dose compared with the established P AG for KI administration. The KI decision-making process must involve close coordination with appropriate assessment and decision-making staff.

Should more than one ORO be involved in decision making, all appropriate OROs must communicate and coordinate P ADs with each other. In addition, decisions must be.

coordinated/communicated with jncident command. OROs must demonstrate the capability to

  • communicate the results of decisions to all the affected locations.

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

State of Maryland Negotiated Extent of Play:

All activiti_es are based on the ORO's plans and procedures and completed as they would be in an actual emergency. Actual KI will not be transported. KI will be avaiJable for inspection at the respective storage location. (Note-this may be demonstrated during the out.:.of-sequence evaluations)

Locations evaluated: KI Storage Locations:

Calvert County Health Department Dorchester County Dorchester County EOC Dorchester County Health Department St. Mary's County St. Mary's County EOC SEOC StateAAC Outstanding Issues: None Sub-element 2.c - Precautionary and/or Protective Action Decision Consideration for the Protection of Persons with Disabilities and Access/Functional Needs Criterion 2.c.1: Precautionary and/or protective action decisions are made, as appropriate, for groups of persons with disabilities and access/functional needs. (NUREG-065~/FEMA-REP-1, D.4; J.9; J.10.d, e)

INTENT 64

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to determine precautionary and /or protective action decisions, including evacuation, sheltering, and use of KI, when applicable, for groups of persons with disabilities and access/functional needs (e.g., ]J.ospitals, nursing homes, correctional facilities, schools, licensed day cares, mobility-impaired individuals, and transportation-dependent individuals).

  • The focus is on those groups of persons with disabilities and access/functional needs that are or potentially will be affected by a radiological release from an NPP.

EXTENT OF PLAY Assessment of this Demonstra~ion Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a full-scale, functional or tabletop exercise that would include the use of plant conditions transmitted from the licensee. Usually it is appropriate to

. implement evacuation in areas where doses are proJected to exceed the lower end of the range of*

PAGs, except' for incidents where there is a high-risk environmental condition or where high-risk groups ( e.g., the immobile or i;nfirm) are involved. fu these cases, factors that must be considered include weather conditions, shelter availability, availability of transportation assets, risk of evacuation versus risk :from the avoided dose, and precautionary school evacuations. In addition, decisions must be coordinated and communicated with the incident command. In situations where an institutionalized population cannot be evacuated, the ORO must consider use.of KI.

Applicable OR Os must demonstrate the capability to alert and notify all public school

  • systems/districts of emergency conditions that are expected to or may ne.cessitate protective actions for students. Demonstration requires that the OROs actually contact public school systems/districts during the exercise.

In accordance with plans/procedures, OROs and/or officials of public school systems/districts must demonstrate the capability to make prompt decisions on protective actions for students. The decision-making process, including any preplanned strategies for protective actions for that ECL,.

must consider the location of students at the time ( e.g., whether the students are still at home, en-route to school, or at school).

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

State of Maryland Negotiated Extent of Play:

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

65

After-Action Report/Improvement Plan Locations evaluated:

Calvert County*

St. Mary's County e

Dorchester County

. Outstanding Issues: None Unclassified Radiological Emergency Preparedness Program Calvert Cliffs Nuclear Po'l'\\'er Plant Sll;b-element 2.d. -. Radiological Assessment and Decision Malting for the Ingestion Exposure Pathway Criterion 2.d. l: Radiological consequences for the ingestion pathway are assessed and appropriate protective action deci~ions are made based on the ORO's planning criteria.

(NUREG-0654/FEMA-REP-1, A.3; C.1, 4; D.4; J.9, 11)

INTENT This Sub-element is derived from NUREQ-0654/FEMA-REP-1, which requires that OROs have the means to assess the radiological consequences for the ingestion exposure pathway, relate them to the appropriate P AGs, and make timely, appropriate P ADs to mitigate exposure from the pathway.

During an incident.at an NPP, a release of radioactive material may contaminate water supplies and agricultural products in the surrounding areas. Any such contamination would likely occur

  • ciuring"the plume phase of the incident and, depending on tp.e nature of the release, could impact the ingestion pathway for weeks or years.

EXTENT OF PLAY Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a full-scale; functional or tabletop exercise that would.*

include the use of plant conditions transmitt~d from the licensee.

OROs are expected to take precautionary actions to prote.ct food and water supplies, or to

  • minimize exposure to potentially contaminated. water and food, in accordance with their.

respective plans/procedures. Often OROs initiate such actions based on criteria related to the facility's ECLs. Such actions may include recommendations to place milk animals on stored feed and use protected water suppiies. 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 oflocal 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 66

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant to the appropriate ingestion PA Gs conta1ned in the ORO' s plans/procedures. The plans/procedures contain PA Gs based on specific dose commitment criteria or on criteria as recommended by current Food and Drug Administration (FDA} guidance*. Timely and appropriate recommendations must be provided to the ORO decision-makers group for implementatj.on decisions. OROs may also include a comparison of taking or not taking a given action on th,e resultant ingestion pathway dose commitments.

The ORO must demonstra~e timely decisions to minimize radiological impacts from the ingestion pathway, based on the given assessments and other information. Any such decisions must be communicat_ed and; to the extent practical, coordinated with neighboring OROs.

OROs must use Federal resources~ as identified in the Nuclear/Radiological Incident Annex of the NRF and other resources (e.g., compacts or nuclear insurers). Evaluation ofthis criterion will take into consideration the level ofFede~al 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 Maryland Negotiated Extent of Play:

This will be demonstrated on day two of the exercise in accordance with MDE plans and procedures.

Locations evaluated:

MDE Ingestion Pathway Coordinating Committee (IPCC) at State AAC Outstanding Issues: None Sub-element 2.e. - Radiologic~ Assessment and Decision Making Concerning Post-Plume Phase Relocation, Reentry, and Return Criterion 2.e. l: Timely post-plume phase relocation, reentry, and return decisions are made and coordinated as appropriate, based on assessments of the radiological conditions and criteria in the ORO's plan and/or procedures. (NUREG-0654/FEMA-REP-1, 1.10; J.9; K.3.a; M. l)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-l, which requires that OROs have the capability to make decisions on post-plume phase relocation, reentry, and return of the general public. These deGisions are essential for protection of the public from direct long-term exposure to deposited radioactive materials from a severe incident at an NPP.

EXTENT OF PLAY 67

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Assessment of this Demonstration Criterion must be accomplished concurrently with a licensee exercise and may be demonstrated in a full-scale, functional or tabletop e'?(ercise that would include the use of plant conditions transmitted froni the licensee.

  • Relocation: OROs must demonstrate the capability to estimate integrated dose in contaminated areas and compare these ~stimates with PA Gs; apply decision criteria for relocation of those individuals in the general public who have not be.en evacuated, but where actual or projected doses are in excess of relocation PA Gs; and control access to evacuated and restricted areas.

OROs will make de.cisions for relocating members of the evacuated public who lived in areas that now have residual radiation levels in excess of the PAGs. Determination of areas to be restricted must be based on factors such as the mix of radionuclides in deposited materials, calculated exposure rates versus the PAGs, and analyses of vegetation and soil field samples.

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

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

Responsible OROs must demonstrate the capability to develop a strategy for authorized reentry of individuals into the restricted zone(s), based on 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 niust demonstrate the capability to use decision-making criteria in allowing access to the restricted zone by the public for various reas01;is, such as to ;maintain property ( e.g., to care for farm animals or secure machinery forstorage) 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 are determined by scenario events.

Return: OROs must demonstrate the capability to implement policies concerning return ~f members of the public to areas that were evacuated during the plume phase (i.e., peri:nitting 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.

68

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant members of the general public may return. Return is permitted to the boundary of the restricted area(s) that is based @n 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-t~rm housiug.

for relocated persons.

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

State of Maryland Negotiated Extent of Play:

This will be demonstrated on day two of the exercise in accordance with MDE plans and procedures.

Location evaluated:

MDE IPCC at State AAC Outstanding Issues: None Sub-element 3.a - Implementation of Emergency Worker Exposure Control Criterion 3.a. l: The OR Os jssue appropriate dosimetry, KI, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures.

Emergency workers periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposurerecord or chart. OROs maintain appropriate record-keeping of the administration of KI to eme~gency workers. (NUREG-0654/FEMA-REP-1, K.3:a, b; K.4)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide for the following: distribution, use, collection, and processing of direct-reading dosimetry and pern;ianent record dosimetry; reading of direct-reading dosimetry by emergency workers at appropriate frequencies; maintaining a radiation dose record for each emergency worker; establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of the PA Gs, and the capability to provide KI for emergency workers, always applying the "as_ low as is reasonably achievable" principle as appropriate.

EXTENT OF PLAY 69

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Clif{s Nuclear Power Plant Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional or tabletop exercise. Other means may include drills, seminars or training activities that would fully demonstrate technical profic;;iency.

OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent record dosimetry, dosimeter chargers, KI, and instructions on the use of these items. For evaluation purposes, appropriate

  • direct-reading dosimetry is defined as dosimetry that allows an individual(s) to read the administrative reporting limits that are pre-established at a level low enough to consider subsequent calculation of TEDE and maximum exposure limits, for those emergency workers involved in lifesaving activities, contained in the ORO's plans/procedures.

Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/procedures. When supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exp~sure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure controL During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. The emergency worker must report ac;:cumulated exposures during the exercise as indicated in the plans/procedures. OROs must demonstrate the actions. described in the plans/procedures by determining whether to replace the worker, authorize the worker to incur additional exposures, or take other actions. Should exercise play not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge of who in 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-read.ing dosimeters strategically placed in the work area). Each team member must still have his or her own permanent record dosimetry. Individuals authorized by the ORO to reenter an ~vacuated area during the plume ( emergency) phase, inust be limited to the lowest radiological exposure commensurate with completing their missions.

OROs may have administrative limits lower than EPA-400/R-17/001 dose limits for emergency workers performing various services (e.g., lifesaving, protection of valuable property, all activities). OROs must ensure that the process.used to seek authorization for exceeding dose 70

Unclassified Radiological Emergency Preparedness Program.

After Action ReporUimprovement Plan Calvert Cliffs Nuclear Power Plant 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 de~isions _made.. OROs must have the capability to develop 8?-d 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 base~ on the ORO' s plans/procedures and completed as the>.7: would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreeµient.

State of Maryland Negotiated Extent of Play:

All activities ate based on the ORO' s plans* and procedures and *completed as they would be in an actual emergency. Dosimetry electrical leakage checks will be submitted with the ALC.

Electronic dosimetry may be substituted for SRD' s at some state or local jurisdictions.

Locations evaluated:

State Field Monitoring Team*

State Field Sampling Team

~ Calvert County

  • St; Mary's County.

Dorchester County GI Dorchester County (Back Up Route Alerting)

TCP/ACP (All Risk Counties)

Outstanding Issues: None Sub-element 3.b-Implementation of KI Decision for Institutionalized Individuals and the Genei:al Public Criterion 3.b.1: KI and appropriate instructions are available if a decision to recommend use of KI is made. Appropriate record-keeping of the administration of KI.for institutionalized individuals is maintained (NUREG-0654/FEMA-REP-1, J.10.e, and f)

INTENT 71

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant The Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have

  • the capability to provide KI for institutionalized individuals, and, when in the plans/procedures, to the general public for whom immediate evacuation may not be feasible, very difficult,* or significantly delayed. While it is necessary for OROs to have the capability to provide KI to institutionalized individuals, providing KI to the general public is an ORO option and must be reflected as such in ORO plans/procedures. Provisions must include the availability of adequate quantities, storage, and means of distributing KI.

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

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

OROs must have the capability to develop and maintain lists of institutionalized individuals who

  • have ingested KI, including documentation of the date(s) and time(s) they were instruded to ingest KL 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.

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

All activities must be based on the ORO's plans/procedures and complet~d as they would be in

. an actual emergency, unless rioted above or otherwise specified in the Extent-of-Play Agreement.

State of Maryland Negotiated Extent of Play:

All activities are based on the ORO's plans and procedures and completed as they would be in an actual emergency. There are no special facilities within the Dorchester County 10-mile Emergency Planning Zone.

Locations evaluated:

Calvert County Dorchester County St. Mary's County Outstanding Issues: None Sub-element 3.c-Implementation of Precautionary and/or Protective Actions for Persons with Disabilities and Access/Functional Needs 72

  • Unclassified

. Radiological Emergency Preparedness Program

  • After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant
  • criterion 3.c.l: Precautionary and/or protective action decisions are implemented for persons with disabilities and access/functional needs other than schools within areas subject to protective actions. (NUREG-0654/FEMA-REP-.l,.J.10.c, d, e, g)
  • INTENT This Sub-element is derived from NUREG-0654/FEMA-REP~l, which requires that OROs have the capability to implement precautionary and/or protective action decisions, including evacuation and/or sheltering, for all persons with disabilities and access/functional-needs. The focus is on those persons with disabilities and* access/functional needs that are ( or potentially will be) affected by a radiological release from an NPP.

EXTENT OF PLAY Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, an actual event, or by means of drills Gonducted at any time.

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

Contact with persons wi~h disabilities and access/functional needs and reception facilities may be real or snnulated, as agreed to in the extent of play. Some contacts with transportation providers must be real, as negotiated in the extent of play. All actqal and simulated contacts must be logged.

All activities must be based on the ORO's plans/procedures and completed as they would be in

  • an actual emergency, unless noted above or otherwise* specifie4 in the E~tent-'of-Play Agreement.

State of Maryland Negotiated Extent of Play:

Lists of any special populations are verified at the BOC but not provided to the evaluator. Lists of all special facilities are provided at evaluation. Contact with any special facility will be simulated or discussed at the BOC. Some facilities (- 10%) may be contacted.

Locations evaluated:

Calvert County Dorchester County St. Mary's County Outstanding Issues: None 73

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Criterion 3.c.2: OR.Os/School officials implement'precautionary and/or protective actions for*

schools. (NUREG~0654/FEMA-REP-1; J.l'O.c, d, e, g}

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

Public school systems/districts must demonstrate the ability to implement P ADs for stµdents.

The demonstration must be made as follows: Each school system/district within the 10 mile EPZ must. demonstrate implementation of protective actions. At least one school per affected system/district must participate in the demonstration. Canceling the school day, dismissing early, or sheltering in place must be simulated by describing to evaluators the procedures that would be followed. When evacuation is the implemented protective action, all activities t.o coordinate and complete the evacuation of students to reception centers, congregate care centers,* or host schools may actually be demonstrated or accomplished through an interview process.

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

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

status of protective actions for schools.

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

Calvert and St Mary's counties will demonstrate protective actions for schools from the respective county EOCs. On September 13, 2017, day two of the exercise, one school

. administrator will describe the required actions taken in the school building. There are no risk schools in Dorchester County. Protective actions for school children that live inside the IO-mile EPZ but attend school outside the 10-mile EPZ will be demonstrated by actions taken in the EOC.

during the actual exercise. OROs will have lists of any facilities located within the jurisdiction available for review.

74

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Locations evaluated:

September 12; 2017 e

Calvert County EOC St Mary's County EOC September 13, 2017 Patuxent High School (Calvert)

Mutual Elementary School (Calvert)

Green Holly Elementary School (SMC)

Outstanding Issues: None Sub-element 3.d - Implementation of Traffic and Access Control 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)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-:I, 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.

EXTENT OF PLAY Assessment of this Demonstration Criterion may be accomplished during a full-scale or

functional exercise, an actual event, or by means of drills conducted at any time.

OROs must demonstrate the capability to 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 mariner. 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.

75

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant In instances where OR Os 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 Maryland Negotiated Extent of Play:

Traffic and Access control points will be established administratively in the EOC based on scenario conditions. Access control points will be established near the EOC (parking lot) and not at an actual field location. Communications with the TCP/ACP will occur as they would in an a~tual emergency. Air and water *controls wtll be coordinated (simulated) from the SEOC. There are no railways in the 10-mile EPZ.

Locations evaluated:

Calvert County St. Mary's County Dorchester. County SEOC (Air/ Water)

Outstanding Issues: None.

Criterion 3.d.2: Impediments to evacuation are identified and resolved. (NlJREG-0654/FEMA-REP-l, J.10.k)

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

OROs must demonstrate the capability, as required by the scenario, to identify and take appropriate actions concerning impediments tci evacuation. Actual dispatch of resources to deal with impedim~nts, such as wreckers, need not be demonstrated; however; all contacts, actual or simulated, must be logged. The impediment must occur during the evacuation and be on an evacuation route such that re-routing of traffic is required, triggering decision-making and coordination with the JIC to communicate the alternate route to evacuees leaving the area.

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

State of Maryland Negotiated Extent of Play:

76

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant All activities are based on the ORO's plans and procedures and completed, as they would be in an actual emergency, unless specified above or indicated in the extent of play agreement. Actual..

equipment will not be dispatched. Should evacuation not be included as one of the protective action then actions to resolve impediments (should an evacuation order be given) will be described to the evaluator inpluding the conduct of a radiological briefing.

  • Locations evaluated:

Outstanding Issues:. None Sub-element 3.e - Implementation of Ingestion Pathway Decisions Criterion 3.e. l: The ORO demonstrates the availability and appropriate use of adequate info~ation regarding water, food supplies, milk, and agricultural production within the ingestion exposure pathway emergency planning zone for implementation of protective actions.

NUREG-0654/FEMA-REP-1, A.J; C.l, 4; J.11)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement protective actions, based on criteria recommended bycurrent FDA guidance, for the ingestion exposure pathway EPZ (i.e., the area within an approximate 50~mile radius of the NPP). This Sub-element focuses on those act1ons required for implemen~ation of protective actions.

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

Applicable OR.Os 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 protectlve

  • 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),

when available. Evaluation ofthis 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/11rocedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

State of Maryland/Commonwealth of Virginia and Local Agencies Negotiated Extent of Play:*

This will be demonstrated on day three at the table top exercise in accordance with the plans, policies, and procedures or at one of the regional training table top events happening in May or the dress rehearsal in July.

77

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Locations evaluated:

Annapolis City, MD

  • Anne Arundel County II Arlington County, VA
  • Baltimore City
  • Baltimore County
  • Calvert County
  • Caroline County
  • Carroll County

.. Cecil County

  • Charles County
  • City of Alexandria, VA District of Columbia Dorchester County Falls Church, VA
  • Fairfax County, VA
  • Frederick County*
  • Harford County
  • Howard County
  • Kent County, MD

/

Lancaster County Montgomery County

  • Prince Georges Co.unty
  • Queen Anne's County
  • Somerset County
  • St. Mary's County
  • Talbot County
  • Wicomico County
  • Worcester County Outstanding Issues: None
  • Criterion 3;e.2: Appropriate measures, strategies, and pre-printed instructional material are developed for implementing protective action decisions for contaminated water, food products, milk, and agricultural production. (NUREG-0654/FEMA-REP-1, G.1, J.9, 11).

EXTENT OF PLAY 78

I*

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, an actual event, or by means of drills conducted at any time.

OROs must demonstrate the development of measures and strategies for implementation of ingestion exposure pathway EPZ protective actions by formulating protective action information for the general public and food producers and processors. Demonstration of this criterion I

includes either pre-distributed public information material in the ingestion exposure pathway EPZ or the capability for rapid reproduction and distr1bution of appropriate reproduction-ready information and instructions to pre-determined individuals and businesses.

OROs must also demonstrate the capability to control, restrict, or prevent distribution of contaminated food by commercial sectors. Exercise play must include demonstration of communications and coordination among organizations to implement protective actions. Field play of implementation activities may be simulated. For example, communications and

  • coordination with agencies responsible for enforcing food controls within the ingestion exposure pathway EPZ must be demonstrated, but actual communications with food producers and processors may be simulated.

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

State of Maryland Negotiated*/Commonwealth of Virginia and Local Extent of Play:

This wiil be demonstrated on day three of the table top exercise ih accordance with the plans, policies, and procedures.

Locations evaluated:

  • Annapolis City, MD II!

Anne Arundel County

  • Arlington County, VA

"

  • Baltimore City f)

Baltimore County C)

Calvert County 5

Caroline County

  • Carroll County
  • Cecil County
  • Charles County
  • City of Alexandria, VA

" District of Columbia

  • Dorchester County
  • Falls Church, VA
  • Fairfax County, VA 79

Unclassified Radiological Emergency Preparedne_ss Program After Action Repor1ilmprovement Plan Calvert Cliffs Nuclear Power Plant

  • Frederick County
  • Harford County.
  • Howard County
  • Kent County, MD Lancaster County Montgomery County
  • Prince Georges County
  • Queen Anne's County
  • Somerset County
  • St. Mary's County
  • Talbot County
  • Wicomico County
  • Worcester County Outstanding Issues: None Suh-element 3.f-Implementation of Post-Plume Phase Relocation, Reentry, and Return

~

Decisions Criterion 3.f 1 : Decisions regarding controlled reentry of emergency workers and relocation and return of the public during the post-plume phase are coordinated with appropriate organizations and implemented. (NUREG-0654/FEMA-REP-1, E.7; J.10.j; J.12; K.5.b; M.1, 3)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement plans, procedures, and decisions for post-plume.phase relocation, re~ntry, and return. Implementation of these decisions is essential for protecting the public from direct long-term exposure to deJ?osited radioactive materials from a severe incident at a commercial NPP.

  • EXTENT OF PLAY Assessment of this Demonstration Criterion may be accomplished during a full-scale*, functional, or tabletop exercise, an actual event, or by means of drills conducted at any time.

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

  • previously evacuated. Such individuals must be relocated to an area(s) where radiologic~l.

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) P AGs.

80

Unclassified Radiological Emergency Preparedness Program After 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. OR Os must also demonstrate the capability to control exit of vehicles and other equipment to. control the spread of contamination outside the restricted area(s). Individuals without specific radiological response missions, such as farmers for arum.al care, essential utility service personnel, or other members of the public who must reenter an evacuated area during the post-emergency phase must be limited to the lowest radiological exposure commensurate with completing their missions. Monitoring and decontamination facilities will be established as appropriate.

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

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

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

. setting.

OROs must use Federal resources as identified in the NRF Nuclear/Radiological Incident Armex, and other resources (e.g., compacts or nuclear insurers), when 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 Maryland /Commonwealth of Virginia and Local Negotiated Extent of Play:

81

Unclassified Radiological Emergency Prepa,edness_ Program After Action Report/Improvement Plan*

Calvert Cliffs Nuclear Power Plant This will be demonstrated on Day Three of the table fop exercise in accordance with the plans, policies, and procedures.

Locations evaluated:

  • Annapolis City, MD
  • Anne Arundel County
  • Arlington County, VA
  • Baltimore City
  • Baltimore County
  • Calvert County
  • Caroline County Carroll County
  • Cecil County *
  • Charles County
  • City of Alexandria, VA
  • District of Columbia
  • Dorchester County

" Falls Church, VA

  • Fairfax County, VA
  • Frederick County
  • Harford County
  • Howard County
  • Kent County, MD
  • Lancaster County
  • Montgomery County
  • Prince Georges County
  • Queen Anne's *county
  • Somerset County
  • St. Mary's County
  • Talbot County
  • Wicomico County
  • Worcester County Outstanding Issues: None Sub-element 4.a - Plume Phase Field Measurements and Analyses 82

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Criterion 4.a.2: Field teams (2 or more) are managed to. obtain sufficient information to help characterize the release and to control radiation exposure. (NUREG-0654/FEMA-REP-1, C.1; H.12; I.7, 8, 11; J.10.a)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to deploy FMTs with the equipment, methods, and expertise necessary to determine the location of airborne radiation and particulate disposition on the ground from an airborne plume. In addition, NUREG-0654/FEMA-REP-1 indicates that OR.Os must have the capability to use FMTs within the plume exposure pathway EPZ to detect airborne radioiodine in the presence of µoble gases and radioactive particulate material in the airborne plume. In an.

incidentat an NPP, the possible release of radioactive material may pose a risk to the nearby population and environment. Although incident assessment methods are available to project the extent and magnitude ofa release, these m~thods are subject to large uncertainties. During an incident, it is important to collect field radiological data to help characterize any radiological release. Adequate equipment and procedures are essential to such field measurement efforts.

EXTENT OF PLAY Assessment of this Demonstration Criterion niay be accomplished during a full-s~ale, functional,

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

Responsible OROs must demonstrate the capability to briefFMTs on predicted plume location and direction, plume travel speed, and exposure control procedures before deployment. During

  • an HAB incident, the Field Team management must keep the incideri.t*command informed of field monitoring teams' activities and location. Coordination with FMTs and field monitoring may be demonstrated as out-of-sequence demonstrations, as negotiated in the Extent-of-Play Agreement.

Field measurements are needed to help characterize the release and support the adequacy of implemented protective actions, or to be* a factor in modifying protective actions. Teams must be directed to take measurements at such locations and times as 11ecessary to provide sufficient information to characterize the plume and its impacts.

Should the responsibility for obtaining peak measurements in the plume be accepted by licensee field monitoring teams, with concurrence from OROs, there is no requirement for these measurements to be repeated by ORO monitoring teams. _Should the licensee FMTs not obtain peak measurements in the plume, it is the ORO's decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coordination of plume measurement information among all FM.Ts (licensee, Federal, and ORO) is essential.

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

83

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant OROs must use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources ( e.g., compacts or the licensee). Evaluation of this criterion will take into consideration the level of Federal and other resources participating in the exercise.

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 Maryland Negotiated Extent of Play:

These activities are based on the ORO's plans and procedures and completed, as they would be in an achml emergency. At least six readi11gs will be obtained by each team at a survey point l_ocation. In accordance with, '(IA W) agreements with Exelon Generation and State ~d Local organizations, State teams will not measure plume centerline radiation_levels. Airborne radioactivity s_amples will be counted in the field. Chain of custody procedures to deliver samples for additional analysis will be described to the evaluator.

Location evaluated:

State AAC (Baltimore and Prince Frederick)

Outstanding Issues: None Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected. Teams will move to an_ appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount of radioactivity has been collected on the sampling media. (NUREG-0654/FEMA-REP-1, C.l; H.12: I.8, 9; J.10.a)

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

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

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

84 I

. Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan.

Calvert Cliffs Nuclear Power Plant OROs must use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts or the licensee). Evaluation of this criterion wiUtake into consideration the level of Federal and other resources participating 1h 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 Maryland Negotiated Extent of Play:

These activities are based on the ORO's plans and procedures and completed, as they would be in an actual emergency. Only the State teams* will demonstrate this objective.

One sample will be obtained in an area that exhibits above ambient background radiation levels (plume edge) when applicable. Scenario data/ location may not result in access to plume dose.

  • Delivery of samples for additional analysis will not be demonstrated. Chain of custody procedures will be describ_ed to the evaluator.

Locations evaluated:

(2) State MDE Field Monitoring Teams (plume)

Outstanding Issues: None

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

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to assess the actual or potential magnitude and locations of radiological hazards to determine the ingestion exposure pathway EPZ and to support relocation, reentry, and return decisions. This Sub-element focuses on collecting environmental samples for laboratory analyses that are essential for decisions on protecting the public from contaminated food and water and direct radiation from deposited materials.

EXTENT OF PLAY Assessment of this Demonstration Criterion may be accomplished during a full-scale,.:functional, or tabletop exercise. Other means may include drills~ seminars or training activities th~t would fully demonstrate technical proficiency.

The ORO's FMTs must demonstrate the capability to take measurements and samples, at such times and locations as directed, to enable an adequate assessment of the ingestion pathway and to 85

  • Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant 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, p~eparation of samples, and chain-of-custody form(s) for transfer to a laboratory (ies), are in accordance with the ORO's plans/procedures.

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

OROs must use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers). Evaluation ofthis 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 Maryland Negotiated Extent of Play:

This will be demonstrated on September 13, 2017, day two of exercise during *the field sample teams drill in accordance with the plans, policies, and procedures. Maryland will conduct four (4) samples in the following areas:

  • Soil;
  • Water;
  • Vegetables; and
  • Milk.

Locations evaluated:

AAC {Baltimore)

Outstanding Issues: None Sub-element 4.c - Laboratory Operations CrJterion 4.c. l: The laboratory_ is capable of performing required radiological analyses to support protective action decisions. (NUREG-0654/FEMA-REP-l, C.l, 3; J.11)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs hav~

the capability to perform laboratory analyses of radioactivity in air, liquid, and environmental_

samples to support protec_tive action decision making.

EXENT OF PLAY 86

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Assessment of this Demonstration Criterion may be accomplished during a full-scale, functional, or tabletop exercise. Other means niay include drills, seminars or training activities that would fuliy 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 ke~ping 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 trace.able to standards provided by the National Institute of _Standards and Technology. Laboratory methods used to analyz;e 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., transuranic or as a result of a terrorist incident) or when warranted by incident circumstan~es. Analysis may require resources beyond those of the ORO.

The laborntory staff must be qualified in radio-analytical techniques and contamination control procedures.

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

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 Maryland Negotiated Extent of Play:.

The state has acquired the services of a contracted laboratory; a demonstration will be completed at another date and time which has been agreed upon by FEMA.

Location evaluated:

GEL Labs (Charleston, SC)

Outstanding Issues:

Sub-element 5.a-Activation of the Prompt Alert and Notification System Criterion 5.a. l: Activities associated with primary aierting and notificadon of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initial instruptional message to the 87

Unclassified Radiological Emergency Preparedni;ss Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant public must include as a minimum the elements required by current REP guidance. (NUREG-0654/FEMA-;LIBP-1, E.5, 6, 7)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to provide prompt instructions to the public within the plume exposure pathway EPZ.

EXTENT OF PLAY Assessment of this Demonstration Criterion may be accomplished during a full-scale or

  • functional exercise, drills, or operational testing of equipmen! that would fully demonstrate capability.

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

Procedures to b.roadcast the message must be fully demonstrated as they would in an actual emergency up to the point of transmission. Broadcast of the message(s) or test message(s) is not required. Thy procedures must be demonstrated up to the point of actual activation. The alert.

signal activation should be simulated, not performed. Evaluations of Emergency Alert System (EAS) broadcast stations may also be accomplished through Site Assistance V1sits.

The capability of the primary notification system to broadcast an instructional message on a 24-hour basis must be verified during an interview with appropriate personnel from the primary notification system, including verification of provisions for backup power or an alternate station.

The initial message must include at a minimum the following elements: alert signal and irtstructional message; -specific emergency information ( e.g., brochures, calendars, and/or information in telephone books) for use by the general public during an emergency; and tuned for additional information, or that the population tune to another station for additional information.

Should route alerting be demonstrated as a prim~ method of alert and notification, it must be done in accordance with the ORO's plans/procedures and the Extent-of-Play Agreement. OROs must demonstrate the capability to accomplish the primary route alerting in a timely manner (not subject to specific time requirements). At least one route needs to be demonstrated and evaluated. The selected route(s) must vary from exercise to exercise. However, the most difficult 88 e:

i

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant route(s) must be demonstrated no less than once every 8 years. All alert and notification activities along the route(s) must be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast) as negotiated in the extent of play. Actual testing of the mobile public address system will be conducted at an agreed-upon location.

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

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

State of Maryland Negotiated E~tent of Play:

These activities are based on the ORO's plans and procedures and completed, as they would be in an actual emergency. Contact with one EAS station will be demonstrated. Actual siren

.sounding and EAS demonstration will be simulated.

-Note-MEMA will initiate EAS messaging for the respective local jurisdictions and will describe the process of using EMnet to the evaluator, however, the MJOC will draft a hard copy of the message which will be faxed directly to the EAS station (Star 98.3).

Calvert and St. Mary's County coordinate activation with the same EAS station. One county (Calvert) will make contact with the EAS station with a message for both counties. The County may activate EAS as a back-up should conditions warrant. The method receipt will be verified by a FEMA evaluator however, the actual message will not be broadcasted.

Locations evaluated:

Ill SEOC I!)

Calvert County I)

St. Mary's County I)

Dorchester County

© Star 98.3 Radio Station Outstanding Issues: None Criterion 5.a.3: Backup alert and notification of the public is completed within a reasonable time following the detection by the ORO of a failure of the primary alert and notification system.

(NUREG-0654/FEMA-REP-1, E.6)

EXTENT OF PLAY Offsite Response Organizations (ORO) with FEMA-approved exception areas (identified in the approved Alert and Notification System Design Report) 5-10 miles from the nuclear power plant 89

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant should demonstrate the capability to accomplish primary alerting and notification of the exception area(s) within 45 minutes following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The 45-minute clock will begin when the OROs make the decision to activate the alert and notification system for the first time for a specific emergency. The initial message should, at a minimum, include: a statement that an emergency exists at the plant and where to obtain additional information.

For exception area alerting, at least one route needs to be demonstrated and evaluated. The selected route(s) should vary from exercise to exercise. However, the most difficult route should be demonstrated at least once every six years. All alert and notification activities along the route

, should be simulated (that is, the message that would actually be used is read for the evaluator, but not actually broadcast) as agreed upon in the extent of play. Actual testing of the mobile

-public address systen,i will be conducted at some agreed-upon_location.

Backup alert and notification of the public should be completed within 45 minutes following the detection by the ORO of a failure of the primary alert and notification system. Backup route alerting only needs to be demonstrated and evaluated, in accordance with the ORO's plan and/or procedµres and the extent of play agreement, should the exercise scenario call for failure of any portion of the primary system(s), or should any portion of the primary sys_tem(s) actually fail to function. Only one route needs to be selected and demonstrated, when applicable. All alert and notification*activities along the route should be simulated (that is; the message that would actually be used is read for the. evaluator, but not actually broadcast) as agreed upon in the extent of play. Actual testing of the mobile public address system will be conducted at some agreed-upon location.

All activities for this criterion must be based on the ORO's plans and procedures and completed as they would be in an actual e:µiergency, except as noted above or otherwise indicated in the extent of play agreement.

State of Maryland Negotiated Extent of Play:

These activities are based on the ORO's plans and procedures and completed, as they_ would be in an actual emergency. Siren activation (simulated) is coordinated so that one county activates*

sirens for the other two riskjurisd:ictions.

Calvert County/ St Mary's County Back up alerting for Calvert and St. Mary's Counties will be initiated using an electronic notification technology. Alerting will be demonstrated to a specific evaluation group following a siren failure identified by scenario inject. Alerting of the evaluation group should be accomplished in a reasonable amount of time with a recommended goal of 45minutes. FEMA will provide a list for the evaluation group with Name, Cell Number, email address, Text ( cell phone provider) to* and verify that the alerting message was received.

90

~

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nnclear Power Plant Dorchester County The designated route alerting player will be located at the staging area. Timing of the back-up route should only begin after the designated participant receives notificatio"n of the failed siren from the County EOC. One back-up route alerting route will be demonstrated in Dorchester County.

Locations evaluated:

Calvert County e

St. Mary's County e

Dorchester County Dorchester County (Back Up Route Alerting)

Outstanding Issues: None Sub-element 5.b-Subsequent Emergency Information and Instructions for the Public and the Media Criterion 5.b.l: OROs provide accurate subsequent emergency information and instructions to the public and the news media in a timely manner. (NUREG-0654/FEMA-REP-l, E.5, 7; G.3.a, G.4.a, c)

INTENT This Sub-element is deriyed from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to disseminate appropriate emergency information and instructions, including any recommended protective actions, to the public. In addition, NUREG-0654/FEMA-REP-1 requires OROs to ensure that the capability exists for providing* information to the media. This includes the availability of a physical location for use by the media during an emergency.

NUREG-0654/FEMA-REP-1 also provides that a system must be available for dealing with rumors. This system will hereafter be knovvn as the public inquiry hotline.

EXTENT OF PLAY

.Assessment of this Demonstration Criterion may be accomplished during a full~scale or functional 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. Should message dissemination be 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..

91

Unclassified Radiological Emergency Preparedness Program Calvert Cliffs Nuclear Power Plant After Action Report/Improvement Plan Message elements: The ORO must ensure that emergency information ~d instructions are consistent with P ADs made by appropriate officials. The emergency inftjrmation must contain all necessary and applicable instructions ( e.g., evacuation instructions, evacuation routes, reception I

center locations, what to take when evac-qating, shelter-in-place instructions, information concerning protective actions for schoolsland persons with disabilities and access/functional.

needs, and public inquiry hotline teJephone number) to assist the public in carrying-out the P ADs provided. The ORO must also be prepared to disclose and explain the ECL of the incident. At a minimum, this information must be included in media briefings and/or media releases. OROs

. must demonstrate the capability to use language that is clear and understandable to the public within both the plume.and ingestion exposure pathway EPZs. This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas.

The emergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5.a. l and previously identified protective action areas that are still valid, as well as new areas. The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media.

In addition, the OROs must demonstrate the capability to ensure that current emergency

  • information is repeated at pre-established intervals in accordance with the plans/procedures.

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

Should ingestion pathway measures be exercised, OROs must demonstrate that a system exfsts for rapid dissemination of ingestion pathway information to pre-determined individuals and businesses in accordance with the ORO's plans/procedures.

Media information: OROs must demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the incident warrants. The OROs must demonstrate the capability to respond appropriately to inquiries from the news*media. All information presented in media briefings and release1;l must be consistent with P ADs and other emergency information provided to the public. Copies of pertinent emergency information (e.g.; EAS messages and media.releases) and media information kits must be available for dissemination to the media.

Public inquiry: OROs must demonstrate that an effective system is in place for dealing with calls

  • received via the public inquiry hotline. Hotline staff must demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate information source.

Information from the hotline staff, including information that corrects false or inaccurate information when trends are noted, must be included, as appropriate, in emergency information provided to the public, media briefings, and/or media releases.

HAB considerations: The dissemination of information dealing with specific aspects ofNPP security capabilities, actual or perceived adversarial (terrorist) force or threat, and tactical law 92

Unclassified Radiological Emergency Preparedness Program,

After Action Report/Improvement Plan Calvert Cliffs Nuclear* Power Plant enforcement response must be coordinated and communicated with appropriate security authorities, e.g., law enforcement and NPP security agencies, in accordance* with ORO plans/procedures.

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

State of Maryland Negotiated Extent of Play:

These activities wiU be based ori the ORO's plans and procedures and completed, as they would be in an actual emergency. One media briefing will be conducted by the SEOC Lead PIO on Day

3. Public inquiry calls will be initiated at a Site Area Emergency classification. Each location will receive at least six calls. Special News Broadcasts will be developed at appropriate centers but actual broadcast of these messages will not take place.

Locations evaluated:

  • Public Inquiry Control: This will be demonstrated on Day One (1) of the exercise for the State and risk jurisdictions.
  • Calvert County
  • St. Mary's County
  • Dorchester County Media Briefings: One Media Briefing will be given on D~y Three (3) by the SEOC Lead PIO on behalf of the.ingestion counties.
  • Annapolis City, MD
  • Anne Arundel*County
  • Arlingtqn Couno/, VA ll Baltimore City
  • Baltimore County
  • Calvert County
  • Caroline County Carroll County
  • Cecil County.

ll Charles County

  • City of Alexandria, VA
  • District of Columbia
  • Dorchester County
  • Falls Church, VA.

e Fairfax County, VA 93

)

Unclassified Radiological Emergency Prepare_dness Program After Action Rcport!Improvemcnt Plan Calvert Cliffs Nuclear Power Plant Frederick County Harford County Howard County Kent County, MD Lancaster County Montgomery County

  • Prince Georges County
  • Queen Anne's County
  • Somerset County
  • St. Mary's County.

.. Talbot Cqunty

  • Wicomico County 0

Worcester County Outstanding Issues: None Sub-element 6.a - Monitormg, Decontamination, and Registration of Evacuees Criterion 6.a.1: The reception center facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees.

(NUREG-0654/FEMA-REP~l, A.3; C.4; J.10.h; J.12)

INTENT This Sub-element is derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement radiological monitoring and decontamination of evacuees, while minimizing contamination of the facility. OROs must also have the capability to identify and register evacuees at reception centers.

EXTENT OF PLAY Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, drills, or SA V..

Radiological monitoring, decontamination, and registration facilities for evacuees_ must be set up and demonstrated as they would be in an actual emergency or as indicated in the Extent-of-Play Agreement. OROs conducting_this demonstration must have one-third of the resources (e.g.,

monitoring teams/instrumentation/portal monitors) available at the facility (ies) as necessary to monitor 20 percent of the population within a 12-hour period. This would include adequate space for evacuees 'vehicles. Availability of resources can be demonstrated with valid documentation

( e.g., MOU/LOA, etc.) reflecting how necessary equipment would be procured for the location.

Plans/procedures must indicate provisions for service animals.

94 I

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant Before using monitoring instrument(s), the monitor(s) must demonstrate the process of.checking the instrument(s) for proper operation. Staff responsible for the radiological monitoring of

  • evacuees must demonstrate the capability to attain and sustain, within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a monitoring productivity rate per hour needed to monitor the 20 percent EPZ population planning base. The monitoring productivity rate per hour is the number of evacuees that can be monitored, per hour, by the total complement of monitors using an appropriate procedure. For demonstration of monitoring, decontamination, and registration capabilities, a minimum of six evacuees must be monitored per station using equipment and procedures specified in the plans/procedures. The

. monitoring sequences for the first six simulated evacuees per monitoring team will be timed by the evaluators to determine whether the 12-hour requirement can be met.

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

. acceptable means for registration.

Monitoring activities shall not be simulated. Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. They must also explain the procedures for referring any evacuees who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures. Contamination of the evacuee(s) will be determined by controller inject and.not simulated with any low-level radiation source. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

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

Individuals who have completed moni.toring ( and decontamination, when needed) must have means ( e.g., hand stamp, sticker, bracelet, form, etc.) indicating that they, and their service animals and vehicles, where applicable, have been monitored, cleared, and found to have no contcµnination or contamination below the trigger/action level.

95

Unclassified Radiological Emergency Preparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored. These individuals do not require confirmation that their vehicle is free from.contamination prior to entering the congregate care areas.

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

State of Maryland Negotiated Extent of Play:

This element will be evaluated as an ouf-of-sequence activity These activities are based on the ORO's plans and prpcedures and completed, as they would be in an actual emergency. Atleast 6 evacuees will be monitored with one simulated contaminated.

One vehicle will be monitored. Estimated monitoring rates and teams required for demonstration are listed below. The number of teams is based on 10% of the population arriving at the reception center with some contamination.

Portal monitors can process ( 4 persons/min) 240 persons/hour Hand-held monitors process 12 persons/hour Dorchester County Total Population Est.*

300 Est. @ Reception 20 Time to monitor population (no contaminations) using 1 portal monitor> 10 minutes Time to monitor population (10% contaminations) using hand-held instruments 30 minutes/ team Teams required for ~and-held monitoring in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

  • Teams required for exercise demonstration (1/3)

Locations evaluated:

Dorchester County-Dorchester Career and Technology Center (co-located with emergency worker)

Facilities will be staffed and set up and operational prior to the evaluation.

Outstanding Issues:

Refer to Appendix B.

Sub-element 6.b-Monitoring and Decontamination of Emergency Workers and their Equipment and Vehicles Criterion 6.b. l: The facility/ORO has adequate procedures and resources to accomplish monitoring and decontamination of emergency workers and their equipment vehicles. (NUREG-0654/FEMA-REP-I; K.5.a, b)

INTENT 96

Unclassified

  • Calvert Cliffs Nuclear Power Plant This Sub-elementis derived from NUREG-0654/FEMA-REP-1, which requires that OROs have the capability to implement radiological monitoring and decontamination of emergency workers

_ arid their equipment, inclu~ive of vehicles.

EXTENT OF PLAY

_ Assessment of this Demonstration Criterion may be accomplished during a full-scale or functional exercise, drills, or SA V.

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

Specific attention must be given to equipment, including any vehicles that were in contact with contamination. The monitoring staff must demonstrate the capability to make decisions on the need for decontamination of personnel, equipment, and vehicles based on trigger/action levels and procedures stated in the ORO plans/procedures. Monitoring of emergency workers does not have to meet the 12-hour requirement. However, appropriate monitoring procedures must be

  • demonstrated for a minimum of two emergency workers and their equipment and vehicies.

Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrum~nt(s) for proper operation.

The area to be used for monitoring and decontamination must be set up as it would be in an actual emergency, with all route markings, instrumentation, record keeping, and contamination control measures in place. Monitoring procedures must be demonstrated for a minimum of one

  • vehicle. It is generally not necessary to monitor the entire surface of vehicles. However, the capability to monitor areas such as radiator grills, bumpers, wheel wells, tires, and door handles must be demonstrated. Interior surfaces of vehicles that were in contact with contaminated individuals must also be checked.

Decontamination of emergency workers may be simulated and conducted via interview.

Provisions for separate showering and same-sex monitoring must be demonstrated or explained.

_ The staff must demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to*

separate contaminated-and uncontaminated individuals where applicable; provide changes of clothing for those with contaminated clothing; and store contaminated clothing and personal belongings to prevent further contamination of emergency workers or facilities.

Monitoring activities shall not be simulated. Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. They must also explain the procedru;es for referring any emergency workers who cannot be adequately decontaminated for _

assessment and follow-up in accordance with the ORO's plans/procedures. Contamination of the 97

Unclassified

. Radiological Ernergencyl'reparedness Program After Action Report/Improvement Plan Calvert Cliffs Nuclear Power Plant individual(s) will be determined by controller inject and not simulated with any low-level radiation source.

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

All activities must be based on the ORQ's plans/procedures and completed as they would be in

  • an actual emergency, unless noted above or otherwise specified in the ~xtent-of-Play Agreement.

State of Maryland Negotiated Extent of Play:

This element will be evaluated as an out-of-sequence activity These activities are based oil the ORO's plans and procedures an1 completed, as they would be in an actual emergency. Facilities will be staffed set up and operational prior to the evaluation.

Location-evaluated:

Dorchester County-Dorches~er Career and Technology Center ( co_-located with evacuees) 98

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