ML20079J887

FEMA - After Action Report Final Browns Ferry, Radiological Emergency Preparedness Exercise June 26, 2019

ML20079J887
Person / Time
Site:	Browns Ferry
Issue date:	03/10/2020
From:	US Dept of Homeland Security, Federal Emergency Management Agency
To:	Office of Nuclear Reactor Regulation, NRC/RGN-II
Shared Package
ML20079J986	List: ML20079J887 ML20079J890
References
Download: ML20079J887 (216)

Text

- ---- - -- ---- ----------------- ----- - -

I I

I Ii, ,1 i Final Browns Ferry Nuclear Power Plant I Radiological Emergency Preparedness Exercise I Exercise Date: june 26, 2019 I March 10, 2020 I

I

I I 'i j' I

• ,~;:,L, :*: . ._ ~~::* -_-,* , . : -. :.,Ce ..

1 After Action Report I Final Browns Ferry Nuclear Power Plant Radiological Emergency Preparedness Exercise I Exercise Date: June 26, 2019 I March 10, 2020 I

I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

I I

I I

I I

I This page is intentionally blank I

I I

I I

I I

I I

2 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Table of Contents I Page Table of Contents ... .- ......................................................................................................................... 3 I Executive Summary ......................................................................................................................... 5 Section 1: Exercise Overview ......................................................................................................... 7 I 1.1 1.2 Exercise Details ....................................................................................................... 7 Exercise Planning Team Leadership ....................................................................... 7 I 1.3 Participating Organizations ..................................................................................... 8 Section 2: Exercise Design Summary ........................................................................................... 13 2.1 Exercise Purpose and Design ................................................................................. 13 I 2.2 2.3 Exercise Core Capabilities and Objectives ............................................................ 13 Exercise Scenario Summary .................................................................................. 16 I Section 3: Analysis of Capabilities ............................................................................................... 19 3 .1 Exercise Evaluation and Results ............................................................................ 19 3.2 Summary Results of Exercise Evaluation .............................................................. 19 I 3 .3 Jurisdictional Summary Results of Exercise Evaluation ....................................... 21 3.3.1 State of Alabama ........................................................................................ 21 I 3 .3 .1.1 State Emergency Operations Center .............................................. 21 3.3.1.2 State Radiological Monitoring and Assessment Center ................ 24 I 3.3.2 Lauderdale County ..................................................................................... 26 3 .3 .2.1 Emergency Operations Center ....................................................... 26 3.3.2.2 Congregate Care Operations .......................................................... 31 I 3.3.3 Lawrence County ....................................................................................... 32

3. 3. 3.1 Emergency Operations Center ....................................................... 32 I 3.3.4 3.3.3.2 Reception Center and Emergency Worker Decontamination ........ 37 Limestone County ...................................................................................... 38 i 3.3.4.1 Emergency Operations Center ....................................................... 38 3.3.4.2 Reception Center and Emergency Worker Decontamination ....... .42 3.3.5 Morgan County .......................................................................................... 45 I 3.3.5.1 Emergency Operations Center ...................................................... .45 3.3.5.2 Reception Center and Emergency Worker Decontamination ....... .49 3.3.5.3 Medical Service Drill: Lifeguard Ambulance Emergency I Medical Service ............................................................................. 51 3.3.5.4 Medical Service Drill: Decatur Morgan Hospital -Decatur Campus .......................................................................................... 52 I 3.3.6 Madison County ......................................................................................... 53 3.3.6.1 Emergency Operations Center ....................................................... 53 I

3 I

Radiological Emergency Preparedness Program

• I After Action Report 2019 Browns Ferry Nuclear Power Plant I

3.3.6.2 She~ter Operations ......................................................................... 55 3.3. 7 Joint Operations ......................................................................................... 56 3.3. 7 .1 Joint Information Center ................................................................ 56 I

3.3.8 Support Organizations ............................................................................... 58 3.3.8.1 National Weather Service .............................................................. 58 I

Section 4: Conclusion ....................... ,........................................................................................... 59 Appendix A: Exercise Timeline ................................................................................................... 61 I

Appendix B: Exercise Evaluators and Team Leaders .................................................................. 63 Appendix C: Alabama Exercise Extent of Play Agreement.. ....................................................... 67 I I

I I

I I

I I

I I

I I

I 4

I

I Radiological Emergency Preparedness Program I After Action Report *2019 Browns Ferry Nuclear Power Plant Executive Summary I On June 26, 2019, the U.S. Department of Homeland Security/Federal Emergency Management Agency Region IV, Radiological Emergency Preparedness Program staff evaluated a full I participation plume exposure pathway exercise for the Browns Ferry Nuclear Power Plant.

• The Browns Ferry Nuclear Power Plant, operated by the Tennessee Valley Authority, is located I in Limestone County, Alabama, approximately 10 miles northwest of Decatur, Alabama. The 10-mile emergency planning zone is divided into 20 emergency response sectors and encompasses parts of Lauderdale, Lawrence, Limestone, and Morgan Counties.

I Federal Emergency Management Agency's overall objective of the exercise was to. assess the level of State and local preparedness in coordinating and responding to a radiological emergency I at the Browns Ferry Nuclear Power Plant. The purpose of this report is to analyze exercise results, identify strengths to be maintained and built upon, identify potential areas for improvement, and support development of corrective actions.

I This exercise was held in accordance with Federal Emergency Management Agency's policies I

• and guidance concerning the exercise of State and local radiological emergency response plans and procedures. The evaluation team conducted this exercise using Homeland Security Exercise and Evaluation Program methodology. The previous Federal evaluated exercise was conducted I

• on June 28, 2017. The qualifying joint emergency preparedness exercise was conducted on November 1, 1989.

• I The evaluation of out of sequence activities conducted May 7-17, 2019 is included in this report.

The activities included: traffic control point demonstrations and interviews, backup route alerting demonstrations, waterway warning demonstrations, emergency worker decontamination, I reception centers, congregate care, mass care, implementation of potassium iodide for the institutionalized and the public, implementation of protective action decisions for persons with disabilities and access/functional needs, and Emergency Alert System activation through the I local National Weather Service.

Officials and representatives from the State of Alabama; the risk counties of Lauderdale, I Lawrence, Limestone, and Morgan; the host county of Madison; National Weather Service; Tennessee Valley Authority; and numerous volunteers and other agencies participated in this exercise.

I These organizations demonstrated knowledge of their emergency response plans and procedures and successfully implemented them. The jurisdictions met the joint exercise objectives and I successfully demonstrated the corresponding Core Capabilities identified in Section 2.2 of this report. During the exercise no level 1 or level 2 findings were identified.

I I

5 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

The Federal Emergency Management Agency will provide an Improvement Plan to the State of Alabama that details the Strengths and Areas for Improvement observed during the exercise and explain the above improvement items in more depth. The Improvement Plan is published under I a separate cover and classified "For Official Use Only" in compliance with Homeland Security Exercise and Evaluation Program standards.

I I

I I

I I

I I

I I

I I

I I

I 6

I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Section 1: Exercise Overview I 1.1 Exercise Details I Exercise Name 2019 Browns Ferry Nuclear Power Plant Radiological Emergency Preparedness Exercise I Type of Exercise Full-Scale Exercise I Exercise Date June 26, 2019 I Exercise Off-Scenario/Out-of-Sequence Dates May 7-17, 2019 I Program U.S. Department of Homeland Security, Federal Emergency Management Agency, Radiological Emergency Preparedness Program I Mission

Response

I Locations Various, see Appendix C, extent-of-play agreement for exercise locations.

I Sponsors I Alabama Emergency Management Agency and Tennessee Valley Authority Scenario Type I Plume-Phase Radiological Emergency Preparedness Exercise 1.2 Exercise Planning Team Leadership I Robert Spence South Section Chief I Federal Emergency Management Agency, Region IV 3003 Chamblee-Tucker Road Atlanta, Georgia 30341 I robert. spence@fema.dhs.gov I

I 7

I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Glenda Bryson Emergency Management Specialist Federal Emergency Management Agency, Region IV I 3003 Chamblee-Tucker Road Atlanta, Georgia 30341 glenda.bryson@fema.dhs.gov I

Quinton Dailey Lead Radiological Emergency Preparedness Planner I

Alabama Emergency Management Agency PO Drawer 2106 Clanton, Alabama 35046 I

quinton.dailey@ema.alabama.gov Alicia Reed I

Lead Exercise Officer Alabama Emergency Management Agency PO Drawer 2106 I

Clanton, Alabama 35046 alicia.reed@ema.alabama.gov I Kevin Hicks Director, Emergency Planning and Environmental Monitoring Alabama Department of Public Health, Office of Radiation Control I

201 Monroe Street, Suite 700 Montgomery, Alabama 36104 kevin.hicks@adph.state.al. us I

1.3 Participating Organizations I Agencies and organizations of the following jurisdictions participated in the 2019 Browns Ferry Nuclear Power Plant exercise. I State Jurisdictions:

Alabama Department of Forestry I

Alabama Department of Human Resources Alabama Department of Public Health Alabama Emergency Management Agency I

Alabama Law Enforcement Agency I

I I

8 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Risk Jurisdictions:

I Limestone County Athens Marine Patrol I Athens City Fire Department Athens City School District Athens Limestone Rescue Squad I Athens Police Department Limestone Council on Aging Limestone County Amateur Radio I Limestone County Commission Limestone County Health Department Limestone County Emergency Management Agency I Limestone County Emergency Medical Services Limestone County Mayor Office Limestone County School District I Limestone County Sheriffs Office Limestone County 911 Office Oak Grove Thach Volunteer Fire Department I Ardmore Volunteer Fire Department Morgan County I Brindlee Mountain Fire Department .

Decatur Council Decatur City Mayor I Decatur Fire Decatur Police Department Decatur Schools I Falkville Fire Falkville Health Care Falkville Police I Hartselle Fire Hartselle Police Department I Hartselle Schools Morgan County Emergency Management Agency Morgan County Emergency Communication Morgan County Commissioner I Morgan County Department of Human Resources Morgan County Extension Service I Morgan County Health Department Morgan County Rescue Squad Morgan County Schools I Morgan County Sheriffs Office Morgan County Volunteer Fire Association I

I I 9

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Priceville Fire and Rescue Department Priceville Police Department Somerville Police I Trinity Fire Department Trinity Police I

Lawrence County Courtland Police Department Hillsboro Police Department I Lawrence County Board of Education Lawrence County Department of Human Resources Lawrence County Emergency Management Agency I

Lawrence County Emergency Medical Services Lawrence County Health Department Lawrence County Rescue Squad I

Lawrence County Sheriffs Office Lawrence County Volunteer Fire Fighters Moulton Fire Department I

Moulton Police Department Lauderdale County I

City of Florence Florence-Lauderdale County Emergency Management Agency Florence-Lauderdale 911 I

Florence Police Department Lauderdale County Commission Lauderdale County Health Department I

Lauderdale County Sheriffs Office Lauderdale County Department of Human Resources I Host Jurisdictions:

Madison County I

Huntsville Fire and Rescue Department Huntsville-Madison County Emergency Management Agency Huntsville Police Department I

Private Organizations: I American Red Cross Amateur Radio Emergency Service Baptist Disaster I

Decatur Morgan Hospital First Response Ambulance Service I Hospice of the Valley I

10 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Industrial Emergency Association I Lifeguard Ambulance Emergency Medical Service North Central Alabama Regional Council of Governments Salvation Army I Samaritan EMS Shoals Ambulance Voluntary Organizations Active in Disaster I Decatur Amateur Radio Club Civil Air Patrol 134th Squadron I Federal Agencies:

Federal Emergency Management Agency, Region IV I National Weather Service Tennessee Valley Authority U.S. Nuclear Regulatory Commission, Region IV I

I I

I I

I I

I I

I 11 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

I I

I I

I I

I This page is intentionally blank I

I I

I I

I I

I I

12 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Section 2: Exercise Design Summary I 2.1 Exercise Purpose and Design I The Federal Emergency Management Agency administers the Radiological Emergency Preparedness Program pursuant to the regulations found in Title 44 Code of Federal Regulations parts 350, 351, 352, 353 and 354. Title 44 Code of Federal Regulations part I 350 codifies sixteen planning standards that form the basis for radiological emergency response planning for state, tribal, and local governments impacted by the emergency planning zones established for each nuclear power plant site in the United States.

I Nuclear Regulatory Commission regulations also codify the sixteen planning standards for the licensee. Title 44 Code of Federal Regulations part 350 sets forth the mechanisms for the formal review and approval of state, tribal, and local government radiological I emergency response plans and procedures by the Federal Emergency Management Agency. One of the Radiological Emergency Preparedness Program cornerstones established by these regulations is the biennial exercise of offsite response capabilities.

I During these exercises, affected state, tribal, and local governments demonstrate their abilities to implement their plans and procedures to protect the health and safety of the public in the event of a radiological emergency at the nuclear plant.

I The results of this exercise, together with review of the radiological emergency response I plans, and verification of the periodic requirements set forth in NUREG-0654/FEMA-REP-1, along with supplements through the annual letter of certification and staff assistance visits, enabled the Federal Emergency Management Agency to provide a statement with the transmission of this final after action report to the United States I Nuclear Regulatory Commission, that the affected state, tribal, and local plans and preparedness are: (1) adequate to protect the health and safety of the public living in the I vicinity of the nuclear power facility by providing reasonable assurance that appropriate protective measures can be taken offsite in the event of a radiological emergency; and (2) capable of being implemented.

I The State of Alabama formally submitted the Radiological Emergency Response Plans for the Browns Ferry Nuclear Power Plant to the Federal Emergency Management Agency, Region rv on May 15, 1985. The Federal Emergency Management Agency I approved the plans pursuant to 44 Code of Federal Regulations 350 on July 6, 1990. The qualifying joint emergency preparedness exercise was conducted on November 1, 1989.

I 2.2 Exercise Core Capabilities and Objectives I Capabilities-based planning allows for exercise planning teams to develop exercise objectives and observe exercise outcomes through a framework of specific action items.

Using the Homeland Security Exercise and Evaluation Program methodology, the I exercise objectives meet the Radiological Emergency Preparedness Program requirements and encompass the program's emergency preparedness evaluation areas.

The critical tasks to be demonstrated were negotiated with the State of Alabama and the I

13 I

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

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

counties of Lawrence, Limestone, Lauderdale, Morgan, and Madison. The core capabilities demonstrated during this exercise were:

I

• Operational Coordination: Establish and maintain a unified and coordinated operational structure and process that appropriately integrates all critical stakeholders and supports the execution of Core Capabilities.

I

• Operational Communications: Ensure the capacity for timely communications in support of security, situational awareness, and operations by any and all means I

available, among and between affected communities in the impact area and all response forces. I

• Situational Assessment: Provide all decision makers with decision-relevant information regarding the nature and extent of hazards, any cascading effects, and status of response.

I

• Public Information and Warning: Deliver coordinated, prompt, reliable, and actionable information to the whole community through the use of clear, consistent, I

accessible, and culturally and linguistically appropriate methods to effectively relay information regarding any threat or hazard and, as appropriate, the actions being taken, and the assistance being made available.

I

• Environmental Response/Health and Safety: Ensure the availability of guidance and resources to address all hazards including hazardous materials, acts of terrorism, I

and natural disasters in support of the responder operations and the affected communities. I

• On Scene Security, Protection and Law Enforcement: Ensure a safe and secure environment through law enforcement and related security and protection operations I for people and communities located within the affected areas and also for response personnel performing lifesaving and life-sustaining operations.

I

• Critical Transportation: Provide transportation (including infrastructure access and accessible transportation services) for response priority objectives, including the evacuation of people and animals, and the delivery of vital response personnel, I

equipment, and services into the affected areas.

• Mass Care: Provide life-sustaining services to the affected population with a focus I

on hydration, feeding, and sheltering to those who have the most need, as well as support for reunifying families. I I

I 14 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant

• Public Health, Healthcare, and Emergency Medical Services: Provide lifesaving I medical treatment via Emergency Medical Services and related operations and avoid additional disease and injury by providing targeted public health, medical and behavioral health support, and products to all affected populations.

I The State of Alabama objectives for this exercise were as follows:

I

• Objective 1: Establish and maintain a unified and coordinated operational structure that integrates all State partners and critical stakeholders.

I

• Objective 2: Provide timely, accurate, and appropriately formatted information products to facilitate situational awareness and support to decision making.

I

• Objective 3: Ensure the capacity for timely communications in support of security, situational awareness, and operations available, among and between affected communities in the impact area and all response forces.

I

• Objective 4: Deliver coordinated, prompt, reliable, and actionable information I through clear, consistent, accessible, and culturally and linguistically appropriate methods to effectively relay threat information, appropriate actions, and available assistance.

I

• Objective 5: Conduct appropriate measures to ensure the protection of the health and safety of the public, workers, and the environment in support of responder operations I and the impacted communities.

• Objective 6: Ensure a safe and secure environment across the impacted area through I law enforcement, protection, and security related operations for communities and response personnel engaged in lifesaving and life-sustaining operations.

I

• Objective 7: Provide life-sustaining and human services to the impacted population.

e Objective 8: Provide lifesaving medical treatment and related operations while I avoiding additional disease and injury by providing targeted public health, medical, and behavioral health support, and products to all affected populations.

I I

I I

15 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

2.3 Exercise Scenario Summary The following is a summary of the licensee's formal scenario submitted to FEMA on I May 8, 2019 and approved on May 30, 2019. The Scenario and supporting documents were adequate for the demonstration of the exercise objectives and associated technical criteria identified in the extent of play agreement.

I Time Utility Declares Key Events Time OROs Notified I

0800 Exercise begins 0825 0921 Utility declares an Alert Radiological release occurs 0840 I 0936 Utility declares Site Area Emergency 0951 Utility declares a General Emergency I Protective Action Recommendation to evacuate zones A2, B2, F2, and G2; shelter in place zone AS; monitor and prepare all other zones; and consider issuance of I

KI in accordance with the state plan. 1119 1104 Wind shifts to being from 209 degrees, requiring a change in utility's Protective Action Recommendation.

I Protective Action Recommendation to evacuate zones I A2, B2, F2, and G2; shelter in place zones AS and BS; monitor and prepare all other zones; and consider issuance of potassium iodide in accordance with the I 1145 state plan. 1200 Utility notifies offsite response organizations of upgraded Protective Action Recommendation. I Protective Action Recommendation to evacuate zones A2, B2, F2, G2, AS and BS; monitor and prepare all I other zones; and consider issuance of potassium iodide 1250 1300 in accordance with the state plan.

Exercise terminated 1250 1300 I

Summary: Exercise begins at 0800 CDT I

At 0810 there will be a report of acetylene gas in in the 4KV Electric Board Room lA.

Conditions exist to declare an Alert emergency classification level based on emergency action level "HAS."

I Utility is expected to declare Alert emergency classification level by 0825, with utility notification to offsite response organizations of the Alert by 0840.

I I

16 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant At 0905 the main turbine vibrations begin to rise. At 0915 the main turbine vibrations I reach value requiring turbine to be tripped. This in turn requires operators to scram the reactor. Three control rods fail to insert. Fuel clad damage will also occur.

I At 0916 a reactor water cleanup system isolation valve fails to close.

At 0921 the reactor water cleanup develops a leak outside of containment resulting in I radiation levels in the area to exceed maximum safe levels. Conditions exist to declare a Site Area Emergency based on emergency action level "FSl." A radiological release begins at this time.

I Utility is expected to declare a Site Area Emergency by 0936, with utility notification to offsite response organizations of the Site Area Emergency by 0951.

I At 1049 a chemistryanalysis shows coolant sample with 314 µCi/gm dose equivalent iodine-131. Conditions exist to declare a General Emergency based on emergency action I level "FG 1."

Utility is expected to declare a General Emergency by 1104, with utility notification to I offsite response organizations of the General Emergency by 1119. Expected.Protective Action Recommendation from the utility will be to evacuate zones A2, B2, F2, and G2; shelter in place zone AS; monitor and prepare all other zones; and consider issuance of I potassium iodide in accordance with the state plan.

At 1145 the wind shifts to being from 209 degrees, requiring a change in utility I Protective Action Recommendation.

By 1200 the utility is expected to notify offsite response organizations of new Protective I Action Recommendations. Expected Protective Action Recommendation from the utility will be to evacuate zones A2, B2, F2, and G2; shelter in place zones AS and BS; monitor and prepare all other zones; and consider issuance of potassium iodide in accordance with I the state plan.

I By 1250 the utility is expected to notify offsite response organizations of upgraded Protective Action Recommendations. Expected Protective Action Recommendation from the utility will be to evacuate zones A2, B2, F2, G2, AS and B5; monitor and prepare all I other zones; and consider issuance of potassium iodide in accordance with the state plan.

Note: The timing for this upgraded Protective Action Recommendation for staged evacuation is based on an inject given to the utility emergency director that evacuation of I the 2-mile zones began at 1110-not on the time the OROs actually began the evacuation.

I I

17 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

The exercise will terminate at approximately 1300 after all objectives have been completed.

I Meteorological conditions at the beginning of the General Emergency reflect a wind direction 171 degrees, wind speed of 4 miles per hour, and stability class of "Delta". At 1145 the wind shifts to being from 209 degrees. These conditions remain constant I

throughout the remainder of the exercise.

This scenario provides for a small release of radioactive material. Protective action I

guides will not be exceeded off site. Maximum projected offsite doses will be less than ten percent of the protective action guides for total effective dose equivalent and committed dose equivalent to the thyroid. However, the release is large enough for the I

plume to be detected and characterized by field monitoring teams. Plant conditions will be sufficient for the utility to declare a General Emergency and for offsite response organizations to make protective action decisions.

I I

I I

I I

I I

I I

I I

18 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Section 3: Analysis of Capabilities I 3.1 Exercise Evaluation and Results I This section contains the results and findings of the evaluation of all jurisdictions and functional entities that participated in the June 26, 2019 plume-exposure-pathway exercise and out-of-sequence activities of May 7-17, 2019.

I Each jurisdiction and functional entity was evaluated based on the demonstration of core I I capabilities, capability targets and critical tasks and the underlying radiological emergency preparedness criteria as delineated in the Federal Emergency Management Agency Radiological Emergency Preparedness Program Manual dated January 2016.

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

• M: Met (no unresolved level 1 or level 2 findings assessed and no unresolved I

• findings from prior exercises) 1: Level 1 finding assessed I

• 2: Level 2 finding assessed or an unresolved level 2 finding(s) from a prior exercise

• P: Plan issue I

• N: Not demonstrated 3.2 Summary Results of Exercise Evaluation I The Homeland Security Exercise and Evaluation Program evaluation methodology is an analytical process used to assess the demonstration of specific capabilities during an I exercise. A capability provides a means to perform one or more critical tasks under specified conditions and to specific performance standards. Core capabilities form the foundation of the Federal Emergency Management Agency Region IV Radiological I Emergency Preparedness Program evaluations. The core capability summaries below provide an overall combined assessment of state and local jurisdictions based upon their collective demonstrated performance as it relates to the specific core capability. Each I jurisdiction's standalone capability summaries are listed in Section 3.3 of this report.

1. Operational Coordination: Key leadership personnel from the participating I agencies established and maintained a unified and coordinated operational structure.

This enabled the unified command to provide effective and responsive direction and control over the incident. The decision-making process integrated critical I stakeholders, enabling protective actions and subsequent decisions to be implemented in a timely manner. The activated facilities contained ample working space, equipment, and communications capabilities to allow responders to perform their I respective roles.

I 19 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

2. Operational Communications: Multiple communications systems were demonstrated throughout the exercise. Primary and secondary systems along with web-based incident management software aided the multiple jurisdictions in Alabama I to maintain a unified operational response. These systems ensured the capacity for timely communications in support of a coordinated response.

I

3. Situational Assessment: Alabama Department of Public Health Office of Radiation Control dose assessment personnel assessed radiological and plant conditions to prepare decision-relevant information for the decision makers. The State Health I

Officer issued appropriate Emergency Health Orders based on the information he was provided.

I

4. Public Information and Warning: Alert and notification of the public was made using simulated siren activation and emergency alert system messages. This was followed by supplemental news releases and formal media briefings in the joint I

information center. Through these processes, public information staff prepared and delivered coordinated, prompt, and reliable information and instructions to the public and media.

I

5. Environmental Response/Health and Safety: Alabama Department of Public Health Office of Radiation Control provided appropriate staff and resources to I

support the response. They demonstrated the positioning and management of field monitoring teams and provided appropriate instructions for emergency worker exposure control. Emergency workers in_ Lawrence, Limestone, and Morgan I

Counties demonstrated the ability to perform radiological monitoring and decontamination of evacuees at their reception centers. I

6. On Scene Security, Protection and Law Enforcement: The local law enforcement agencies of Lawrence, Lauderdale, Limestone, Morgan, and Madison Counties effectively demonstrated the ability to establish traffic and access control points in I

support of the Browns Ferry Nuclear Power Plant. Their coordinated support of the precautionary and protective action decisions by the local emergency management directors was in compliance with established procedures.

I

7. Critical Transportation: School board officials in Lawrence, Lauderdale, Limestone, and Morgan Counties demonstrated the ability to implement protective I

actions for schools located within the 10-mile emergency planning zone of the Browns Ferry Nuclear Plant. The officials explained through interview the process and procedures for safeguarding students, staff, and faculty at these schools.

I

8. Mass Care: Limestone, Lauderdale, and Madison Counties demonstrated the ability I to provide services and accommodations for evacuees during out-of-sequence activities. These activities included evacuee reception and registration of evacuees at designated facilities. Representatives from the Department of Human Resources and I volunteers from the American Red Cross aided in the demonstrations.

20

I. Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant 3.3 Jurisdictional Summary Results of Exercise Evaluation I 3.3.1 State of Alabama I 3.3.1.1 State Emergency Operations Center Operational Coordination Capability Summary:

I The Alabama Emergency Management Agency personnel successfully demonstrated the capability to establish and maintain a unified and coordinated operational structure. The I decision-making and coordination process integrated all critical stakeholders and supported the execution of this core capability.

I The state warning point, which is staffed by the Alabama Emergency Management Agency on a 24-hour basis and housed next to the state emergency operations center, demonstrated effective procedures to alert, notify, and mobilize the Alabama Emergency I Management Agency state emergency operations center staff and other state agency staff necessary to activate the state emergency operations center in a timely manner. The Browns Ferry Nuclear Power Plant control room/central emergency coordination center I notified the state warning point of each escalating Emergency Classification Level. The calls came into the state warning point over the Tennessee Valley Authority Emergency Communications Notification System, which is a dedicated telephone system linking the I control room/central emergency coordination center with critical state, county and local agencies. The communication specialist answering the call recorded the information from the utility onto the Browns Ferry Nuclear Radiological Emergency Preparedness I Notification Form or utilized a faxed copy from the utility if received in time. Copies of all Browns Ferry Nuclear Radiological Emergency Preparedness Notification Forms were s'canned into an emergency management software system and copied and distributed to I key state emergency operations center personnel throughout the exercise. Alabama Emergency Management Agency's state emergency operations center staff already in the building were told to report to the state emergency operations center via intercom. All I other state agency staff were notified via commercial telephone by communications specialists in the state warning point to report to the state emergency operations center, as I identified in the contact lists in the standard operating guide. The operations chief activated the state emergency operations center to a level 3, partial activation at the onset of Alert.

I The state emergency operations center, along with the state warning point had multiple communications systems to support emergency operations. The primary communications I system between the State, and counties is the Tennessee Valley Authority emergency communications notification system. The emergency communications notification system is a dedicated and secure phone system, located in the state warning point, used I by the utility and state to convey notifications of emergency classification levels and associated information. Backup to this system is commercial telephone, fax, cellphone, and an emergency management software system. The state warning point also contains a I

21 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant National Warning System phone line for state agencies and the counties, an 800-I megahertz Statewide Radio Network, and a SouthernLinc two-way radio system for key state and county employees. All primary and some backup systems were used in this I exercise. There were no communications failures.

The Alabama State Emergency Operations Center had adequate space to support the I emergency response with partners from state government, non-profit organizations and other entities. Equipment displays used within the Alabama State Emergency Operations Center were: multiple electronic and paper maps; multiple television displays (displayed I local broadcasts, weather, news, and an electronic map); projectors; a speaker's podium with a smart-board; multiple computer workstations; network synchronized clocks; and multiple printers. All of which were operational and sufficient to support operations. I The Alabama Emergency Management Agency's operations section chief provided direction and control and oversaw the coordination process during the response effort for I

each emergency classification level escalation. Working at the direction of the operations section chief, the moderator announced updates and conducted just in time training of emergency classification levels for new personnel.

I The Alabama Office of Radiation Control requested three state coordination group calls via landline to the state warning point over the course of the exercise. The Alabama I

Emergency Management Agency's technological hazards planner scheduled and facilitated each of the three-state coordination group protective action recommendation coordination calls. In each case, the technological hazards planner facilitated I

concurrence from each critical stakeholder once the Alabama Office of Radiation Control provided the protective action recommendation. The Office of Radiation Control consistently briefed the current situation for each call prior to announcing the I

recommended public health orders. A total of four public health orders were recommended. These actions were accomplished in accordance with established plans and procedures.

I There were adequate staff and resources in the state emergency operations center to support access and traffic control, as well as to assist in identifying and removing I

impediments to evacuation. The Alabama Law Enforcement Agency and the Alabama Department of Transportation, part of the emergency services branch, were responsible for these support actions. During the exercise, there were no requests for traffic and I

access control, or evacuation impediment assistance, to the state emergency operations center. By interview, it was explained that local and county resources would be utilized first, with assistance provided by state law enforcement and transportation liaisons at the I

county emergency operations center for any unmet local needs. The county liaisons from these state agencies would mobilize and deploy state resources from the closest regional, area, or district facilities to support local operations. Only if additional state resources

• I were needed would the state emergency operations center representatives be contacted to request support statewide from their respective agencies. I I

22 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant For this capability the following Radiological Emergency Preparedness criteria were MET:

I 1.a.l, 1.c.l, 1.d.l, 1.e.l, 3.d.l, 3.d.2.

a. Level 1 Finding: None I b. Level 2 Finding: None

c. Not Demonstrated: None I d. Prior Level 2 Findings - Resolved: None

e. Prior Level 2 Findings - Unresolved: None I Public Information and Warning Capability Summary:

I The ability to provide emergency information and instructions to the public and news media in a timely manner was demonstrated at the state emergency operations center by the Alabama Emergency Management Agency external affairs staff.

I The primary method for alerting and notifying the public is through a series of fixed sirens located throughout the 10-mile emergency planning zone followed by the I broadcast of Emergency Alert System messages over local radio, television, and weather radios. Madison County coordinated the activation of sirens with the risk counties and directed the National Weather Service in Huntsville to disseminate the appropriate I Emergency Alert System messages to the public through television and radio outlets.

The Alabama Emergency Management Agency's external affairs specialist in the state emergency operations center or joint information center prepared joint news bulletins, I from templates in their procedures, to support the emergency alert system messaging or provide necessary information to the public in lieu of an emergency alert system message. These messages are jointly approved and disseminated by Alabama Emergency I Management Agency and Alabama Office of Radiation Control at the state emergency operations center, or at the joint information center once that facility is activated.

I During this exercise, four joint news bulletins were developed by the state. The first two originated at the state emergency operations center and the last two at the joint information center in Decatur. They were prepared by the external affairs staff, I coordinated with the Alabama Office of Radiation Control representative, and then approved by the operations chief. Accurate emergency information was included in each I news release and was consistent with the precautionary actions and protective action decisions.

I I

I 23 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant For this capability the following Radiological Emergency Preparedness criteria were MET:

I 5.b.l.

I

a. Level 1 Finding: None

b. Level 2 Finding: None I

c. Not Demonstrated: None

d. Prior Level 2 Findings-Resolved: None I

e. Prior Level 2 Findings - Unresolved: None 3.3.1.2 State Radiological Monitoring and Assessment Center I

Situational Assessment Core Capability Summary:

I Personnel staffing the State Radiological Monitoring and Assessment Centers in Montgomery and in Decatur successfully demonstrated the ability to assess radiological and plant conditions and to make appropriate protective action recommendations and I

decisions in response to a radiological incident at the Browns Ferry Nuclear Power Plant.

Alabama Department of Public Health staff initially coordinated the state's technical I

response to the emergency by activating the State Radiological Monitoring and Assessment Center in Montgomery and by contacting and deploying personnel to staff the State Radiological Monitoring and Assessment Center in Decatur and three I

radiological field monitoring teams. Once the State Radiological Monitoring and Assessment Center in Decatur was activated, responsibility for the response was*

transferred to that center. Staff gathered and maintained current informa(ion on plant I

conditions and performed timely dose projection calculations.

After consulting his staff, the State Radiological Monitoring and Assessment Center I

director made appropriate protective action decisions under the authority designated to him by the state health officer. The director issued four emergency health orders during the exercise. Immediately prior to issuing orders, the director participated in state group I

coordination calls with state emergency operations center staff, representatives of other state agencies, and representatives from the affected counties. The director briefed call participants on forthcoming orders during the calls.

I Per the extent-of-play agreement, staff members were pre-positioned near the two centers and responded promptly after receiving messages from Office of Radiation Control I

leadership to respond. Both centers were well equipped to support the response and multiple methods of communication were available and used. I For this capability the following Radiological Emergency Preparedness criteria were MET:

l.a.l, l.c.1, l.d.l, l.e.l, 2.a.1, 2.b.l, 2.b.2. I I

24 I

I Radiological Emergency Preparedness Program I After Action Report

a. Level 1 Finding: None 2019 Browns Ferry Nuclear Power Plant I b. Level 2 Finding: None

c. Not Demonstrated: None I d. Prior Level 2 Findings-Resolved: None

e. Prior Level 2 Findings - Unresolved: None I Environmental Response/Health and Safety Core Capability Summary:

I Alabama Department of Public Health personnel successfully demonstrated the ability to staff and manage radiological field monitoring teams to locate and characterize a radioactive plume in response to an incident at the Browns Ferry Nuclear Power Plant.

I Radiological field monitoring teams were initially managed by the field monitoring team coordinator at the State Radiological Monitoring and Assessment Center in Montgomery.

I Team members inventoried, prepared, and checked all equipment, dosimetry, potassium iodide, and radiological survey instruments prior to field deployment. Each team was equipped with sufficient supplies and equipment to perform field monitoring and .air I sampling. Redundant communication systems ensured that the teams had the ability to communicate with the field monitoring team coordinators.

I The *coordinator in Montgomery briefed team members before they left the staging area on plant status, meteorological conditions, use of dosimetry, administrative exposure limits, and the use of potassium iodide. He then provided initial deployment orders.

I Following the turnover of responsibilities from the State Radiological Monitoring and Assessment Center in Montgomery to the center in Decatur, the field monitoring team coordinator in Decatur assumed responsibility for managing the teams.

I Throughout the exercise, the coordinator continuously monitored the changing meteorological conditions. The coordinator identified when survey results indicated that I the plume was above the teams' locations and directed the team farther downwind to accurately assess the radiological release. The state coordinator worked closely with the I utility field team coordinator to optimize field team resources.

Field team members were knowledgeable of their procedures and promptly reported monitoring and sampling results to the coordinator. The coordinator promptly informed team members about changing plant conditions, meteorological conditions, and emergency health orders.

I In accordance with the extent-of-play agreement, field team personnel members were pre-positioned near the radiological field monitoring team staging area and responded I promptly after receiving messages from Office of Radiation Control leadership to respond.

I 25 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant For this capability the following Radiological Emergency Preparedness criteria were MET:

I l.a.1, l.d.l, l.e.l, 2.a.1, 2.b.l, 3.a.l, 4.a.2, 4.a.3.

I

a. Level 1 Finding: None

b. Level 2 Finding: None I

c. Not Demonstrated: None

d. Prior Level 2 Findings - Resolved: None I

e. Prior Level 2 Findings - Unresolved: None Public Information and Warning. Capability Summary I

Office of Radiation Control public information officers prepared four emergency health orders for the State Radiological Monitoring and Assessment Center director who had I

been designated the authority to issue them by the state health officer. The public information officers also prepared three joint Alabama Department of Public Health/Alabama Emergency Management Agency media releases. The releases described actions being taken I by the state and provided further details on actions for the public to take in response to the emergency health orders. All media releases were coordinated with and approved by the Alabama Emergency Management Agency prior to dissemination to the public and media. I For this capability the following Radiological Emergency Preparedness criteria were MET:

5.b.l. I

a. Level 1 Finding: None

b. Level 2 Finding: None I

c. Not Demonstrated: None

d. Prior Level 2 Findings - Resolved: None I

e. Prior Level 2 Findings - Unresolved: None I

3.3.2 Lauderdale County 3.3.2.1 Emergency Operations Center I

Operational Coordination Capability Summary: I The Florence-Lauderdale County Emergency Management Agency staff demonstrated the ability to establish and maintain a unified and coordinated operational structure that appropriately integrated all critical stakeholders. The director and staff coordinated and I

maintained communications with the risk and host counties and the state. Protective actions were implemented to protect county residents. I I

26 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant The Florence-Lauderdale County Emergency Operations Center staff was pre-staged per I the extent of play agreement. As such it was determined by interview with the Florence-Lauderdale County Emergency Management Agency Planner and E911 Center staff that effective plans and procedures were in place and available for the E911 Center to alert, I notify, and mobilize emergency personnel and activate the emergency operations center in a timely manner.

I Multiple communications systems were available and operational. Communication links were established and maintained with appropriate locations. Primary communications for emergency classification levels was over the Tennessee Valley Authority Emergency I Communications Notification System. This system functioned properly in the Florence-Lauderdale County Emergency Operations Center. The Southern Linc radio-telephone system functioned as the back up to this system and also operated properly. Additionally, I the facility was equipped with emergency services and amateur radio equipment, landline telephones, computers, and cellular telephones. All were observed to operate properly during the exercise and no failures were noted. Equipment, maps, displays, and other I supplies were sufficient and appropriate to support emergency operations.

The Florence-Lauderdale County Emergency Management Agency Director, deputy I director, and emergency management planner demonstrated good direction and control of the emergency operations center in response to a simulated radiological incident. One county commissioner and the mayor participated in the exercise. Support organizations I received continuous information on the situation as it developed. The emergency operations center staff received a constant up-to-date flow of information from the director, deputy director, and emergency management planner. The director and deputy I director coordinated with the state and other affected counties when tasking missions and followed up with each agency to ensure actions were being worked and completed.

I Appropriate and timely protective action decisions were made. Discussions among the risk counties and state concerning protective actions were coordinated and then concurred upon. The deputy director and emergency management director provided frequent I briefings to staff to keep them informed of emergency information and protective actions.

At the Alert emergency classification level two "Emergency Management Agency I Radiological Trailers", stored on county property in the City of Florence, equipped with dosimeters and chargers, thermoluminescent dosimeters and appropriate forms were simulated to have been deployed to the emergency worker station located at Lauderdale I County High School and to the general public station at Brooks High School. By interview it was confirmed that the emergency operations center staff's role would be to I make sure Alabama Health Department Emergency Health Orders were relayed to these sites so that appropriate actions could be taken. The two trailer's equipment was provided and maintained by the Alabama Emergency Management Agency. Staff at the I two locations would issue, train, track, and manage protective action implementation.

I 27 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Lauderdale County does not have any institutionalized individuals, special facilities, or persons with disabilities and access/functional needs within areas subject to protective actions. I Appropriate procedures for traffic and access control staffing, alerting citizens, assisting in evacuations, and clearing or re-routing traffic around impediments were all described I to the evaluator during the exercise.

For this capability the following Radiological Emergency Preparedness criteria were MET:

I l.a.l, l.c.l, l.d.1, l.e.1, 2.a.l, 2.b.2, 2.c.1, 3.a.l, 3.b.l, 3.c.l, 3.d.l, 3.d.2.

a. Level 1 Finding: None I

b. Level 2 Finding: None

c. Not Demonstrated: None I

d. Prior Level 2 Findings - Resolved: None

e. Prior Level 2 Findings - Unresolved: None I

Public Information and Warning Capability Summary: I Florence-Lauderdale County Emergency Management Agency personnel demonstrated the ability to deliver coordinated, prompt, and actionable information to the public.

Primary notification was made using fixed sirens followed by emergency alert system I

messages, and/or special news broadcasts that relayed accurate emergency information.

Following each emergency classification level change or emergency health order, the I

affected counties participated in a conference call to discuss which emergency alert system messages and/or special news broadcasts were appropriate. Once concurrence was achieved, Madison County Emergency Management Agency personnel were I

responsible for coordinating the activation of the sirens by the counties and the broadcast of the appropriate messages with the National Weather Service-Huntsville. All siren activations were simulated for the exercise; however, staff demonstrated knowledge of I

the system and their ability to activate it. Backup route alerting would be initiated in the event of siren failure and was discussed through interview. I The emergency alert system messages and special news broadcasts agreed on during the exercise were appropriate and provided the public with accurate and timely information.

The use of pre-scripted messages enhanced the county's ability to provide the public with I

coordinated and consistent information and instructions.

I I

I 28 I

I

• Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant For this capability the following Radiological Emergency Preparedness criteria were MET:

I l.a.l, l.d.l, l.e.l, 3.d.2, 5.a.l, 5.a.3, 5.b.l.

a. Level 1 Finding: None I b. Level 2 Finding: None

c. Not Demonstrated: None I d. Prior Level 2 Findings -Resolved: None

e. Prior Level 2 Findings - Unresolved: None I Environmental Response, Health and Safety Capability Summary:

I Implementation of a potassium iodide decision for institutionalized individuals and the general public was evaluated during out-of-sequence activities on May 7, 2019 with the Lauderdale County Health Department and the Alabama Department of Public Health.

I The Lauderdale County Health Department, upon issuance of a health order by the State Health Officer to ingest potassium iodide, the Health Department would deploy nurses, support staff, potassium iodide quantities, and go-kits to the county reception center.

I Potassium iodide would be issued to the general public from the county reception center.

Potassium iodide is not pre-distributed to residents of the 10-mile emergency planning zone prior to an incident.

I At the reception center members of the general public would be directed to a potassium iodide station staffed by the Lauderdale County Health Department. At this station individuals would sign a potassium iodide consent form, receive instructions for when to take potassium iodide, information about side effects, and be issued the appropriate dosage. Additional quantities of potassium iodide could be requested from the Alabama I Department of Public Health if needed. Lauderdale County's potassium iodide quantities were made available for inspection. Expiration dates and quantities were found to be sufficient to meet the needs of the expected population.

I For this capability the following Radiological Emergency Preparedness criteria were MET:

3.b.l I a. Level 1 Finding: None I b. Level 2 Finding: None

c. Not Demonstrated: None I d. Prior Level 2 Findings - Resolved: None

e. Prior Level 2 Findings - Unresolved: None I On-Scene Security, Protection, and Law Enforcement Capability Summary:

I 29 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Lauderdale County demonstrated the ability to implement traffic control points by interview during an out of sequence demonstration on May 14, 2019. Florence-Lauderdale County Emergency Management and Lauderdale County Sheriff's Office I staffs were interviewed on activities related to on-scene security, protection, and law enforcement. Sheriffs interviewed discussed their ability to establish traffic and access control, identify and resolve impediments to evacuation, and manage radiological I exposure to emergency workers, and provide accurate instructions to traffic and access control I

Communication systems used between Florence-Lauderdale County Emergency Management Agency and Lauderdale County Sheriff's Office are cell phone, radio, and sheriff's dispatch. Communication checks are conducted daily. Law enforcement I

officers assigned to establish the pre-determined traffic control points are provided a safety briefing by the radiation safety officer, issued personal protection equipment, radiation kits, and dosimetry. They also receive just in time training on radiological I

exposure control limits, dosimetry usage and placement, administrative limits and tum back values, dose and potassium iodide record management. Lauderdale County Sheriff's Office staff interviewed described methods for the removal of road impediments I

and requests for assistance to remove impediments. They are aware of locations for reception centers and emergency worker monitoring stations. I Lauderdale County conducted waterway warning during an out of sequence demonstration on May 14, 2019. Lauderdale County Emergency Management, Rogersville Police Department, and Alabama State Police launched a boat on the I

Tennessee and Elk River, covering the waterway area for which they are responsible within the IO-mile Emergency Planning Zone of the Browns Ferry Nuclear Plant. I Florence-Lauderdale County Emergency Management Agency alerted the Rogersville Police Department and Alabama State Police to place a boat into the water at the Elk River Bridge and Highway 72 launch point. The necessary equipment for running the I

river was maintained on the boat. Personnel were issued radiation kits with direct-reading dosimeters, thermoluminescent dosimeters, potassium iodide, and administrative I I limit cards. They were equipped with cell phones and radios and maintained constant communication with the Lauderdale County Emergency Operations Center throughout the demonstration. Waterway warning and clearance was initiated in accordance with plans and procedures. The boat proceeded from the launch and navigated to two I

designated checkpoints before returning to the launch. During navigation to and at the designated checkpoints, with the use of a bull horn, a scripted message was read to alert boaters of an incident, to leave the area immediately, and to tune in to local radio for I

further guidance. A dosimeter check was conducted, and readings recorded. Emergency management personnel noted that direct-reading dosimeters should be checked every 15-30 minutes. Waterway warning and clearance was completed in 33 minutes, well within I

the 45-minute goal.

I I

30 I

Radiological Emergency Preparedness Program After Action Report 2019 Browns Ferry Nuclear Power Plant Lauderdale County fully demonstrated their ability to alert the public and clear the Tennessee and Elk River of waterway activities in a timely manner in accordance with their plans and procedures.

I For this capability, the following Radiological Emergency Preparedness criteria were MET: l.a.l, l.d.l, l.e.l, 3.a.1, 3.d.l., 3.d.2.

I a. Level 1 Finding: None

b. Level 2 Finding: None I c. Not Demonstrated: None

d. Prior Level 2 Findings - Resolved: None I e. Prior Level 2 Findings - Unresolved: None 3.3.2.2 Congregate Care Operations I Mass Care Capability Summary:

I Lauderdale County demonstrated the capability to provide services and accommodations to evacuees by establishing a congregate care facility and ensuring evacuees have been monitored and decontaminated prior to entering the congregate care facility. Florence-I Lauderdale Emergency Management Agency, Lauderdale County Department of Human Resources, and American Red Cross personnel established a congregate care facility, at Florence High School, located at 1201 Bradshaw Drive, Florence, Alabama, during an I out of sequence demonstration on May 17, 2019.

Lauderdale County Department of Human Resources staff ensured all evacuees wore I green bands indicating they had been monitored and, if necessary, decontaminated, and were cleared to enter the facility. Evacuee registration and evacuation records, issued by the Department of Public Health at the reception center, were reviewed. Staff was I knowledgeable of the necessary forms to allow an evacuee into the congregate care facilities and to instruct evacuees to return to the reception center if forms were missing or incomplete. American Red Cross personnel demonstrated the ability to provide I services and accommodations for evacuees at the Florence High School. Meals, health services, and spiritual care would be provided at the shelter, as well as the opportunity for I evacuees to provide personal contact information for the American Red Cross Safe and Well website to aid reunification efforts. Security for the facility was provided by the Florence Police Department and the Florence High School resource safety officer.

I I

I 31 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant For this capability the following Radiological Emergency Preparedness criteria were MET:

I 6.c.1.

I

a. Level 1 Finding: None

b. Level 2 Finding: None I

c. Not Demonstrated: None

d. Prior Level 2 Findings - Resolved: None I

e. Prior Level 2 Findings - Unresolved: None 3.3.3 Lawrence County I 3.3.3.1 Emergency Operations Center I

Operational Coordination Capability Summary:

Lawrence County Emergency Management Agency leaders and staff successfully I

demonstrated the ability establish and maintain a coordinated operational structure in response to a radiological emergency at the Browns Ferry Nuclear Power Plant. The emergency management director demonstrated the capability to receive initial notification I

of an Alert declaration from the Alabama Emergency Management Agency State warning point, and mobilize staff using an automated mass communication system. The director activated the county emergency operation center at the appropriate activation level in a I

timely manner.

The emergency operations center was well equipped to support response operations. The I

emergency communication notification system was the primary means of receiving

,emergency information and coordinating protective action decisions among emergency planning zone counties, the state and other related agencies. Secondary communication I

capabilities were available to include cellular phones and extensive amateur radio capabilities. Multiple digital and static displays were used to show emergency information concerning the radiological emergency. Work stations were arranged I

according to the Incident Command System structure and staff were provide with plans, Browns Ferry emergency information calendars, and laptops to support their operations.

The emergency operations center was well equipped.

I The director and the radiological emergency preparedness planner worked well together.

The director conducted regular staff updates and briefings to ensure his staff's situational I

awareness concerning current emergency operations and plant status. The director also incorporated the Franldin and Colbert County emergency management directors into his structure to ensure the emergency operations center could operate around the clock I

during an emergency event. A Lawrence County Commissioner showed his support by being present during the exercise. I I

32 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant The radiological.officer conducted a radiological safety briefing which included I information and instructions, provided emergency workers with appropriate dosimetry who would be dispatched to conduct missions in Lawrence County's portion of the Browns Ferry emergency planning zone. A county sheriffs representative successfully

• I demonstrated by interview that proper coordination with other agencies concerning the establishment of traffic and access control points. Coordination between county and state agencies was adequate concerning traffic impediments. Once the controller supplied an

• 1 inject concerning an impediment on one of the evacuation routes the decisionmakers were timely in their decisions regarding setting up routes around the impediment if it would take too long to clear it,* and ensured the public would be notified of the detour.

I For this capability the following Radiological Emergency Preparedness criteria were MET:

l.aJ, l.c.1, l.d.l, l.e.l, 2.a.l, 2.b.2, 2.c.l, 3.a.l, 3.b.l, 3.d.l, 3.d.2 I a. Level 1 Finding: None I b. Level 2 Finding: None

c. Not Demonstrated: None I d. Prior Level 2 Findings - Resolved: Norte

e. Prior Level 2 Findings - Unresolved: None I Public. Information and Warning Capability Summary:

The Lawrence County emergency management director successfully demonstrated the I abiHty to notify the public in a timely and accurate mann.er.

• The primary method of notifying the public was the prompt notification system which consisted of thirty-four fixed sirens, supplemented by tone alert radios located in local schools and husinesses.

I The touch screen siren activation system, located in the county emergency operations center, was activated by the county radiological emergency preparedness planner after each protective action decision and as directed by the Alabama Emergency *Management I Agency. A back-up siren system activation point was located at the Moulton Fire Department. Activation of the system was timely, and no failures were observed. Siren I activation occurred simultaneously with emergency alert system activation. Siren Activation and Emergency alert system messages were coordinated via coordination with other 10-mile emergency planning zone agencies on the emergency communication I notification system. The messages provided in the emergency alert systeni notification had all four federal emergency management agency requirements necessary.

I During a simulated siren failure, the decision-makers coordinated the process of alerting the public in the area that would have been covered by the failed siren. A pre-planned route was used, and the emergency workers simulated traversing the route in question.

I I

33 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Throughout the exercise the decision-makers in the county emergency operations center I

worked closely together to ensure the proper emergency alert system messages and news releases were disseminated. Pre-scripted messages were coordinated and chosen by the decision-makers over the. emergency communication notification system line and I

developed further over the public information coordination line. Messages were then sent to the joint information center by the public information officer, where they were I released. A total of five messages and three press releases were sent to the joint information center for release. A Lawrence County special news broadcast was coordinated at the county emergency operations center between the county director, the I county radiological emergency preparedness planner, and the public information officer.

Once approved by the county leadership, the special news broadcast would have been provided to the public through media outlets to include the local radio station next door to I the emergency operations center. Lawrence county released one message for its county residents.

I Lawrence County conducted backup route alerting during an out of sequence demonstration on May 14, 2019. Following a simulated siren failure, Lawrence County Emergency Management staff initiated backup route alerting procedures. The Lawrence I

County Sheriffs Office assigned staff to report to the emergency operations center for a safety briefing by the radiation safety officer and to be issued personal protection equipment, radiation kits, and dosimetry. They also received just in time training on I

radiological exposure control limits, dosimetry usage and placement, administrative limits and turn back values, dose and potassium iodide record management. Officers were equipped with cell phones and radios to maintain communication. The Lawrence I

County Sheriffs Office vehicle left the emergency operations center and ran a pre-determined route to fully cover the area of siren failure. A scripted message was read over public address system to alert residents of an incident and to tune to local radio for I

further guidance. Backup route alerting was successfully completed in 21 minutes.

For this capability the following Radiological Emergency Preparedness criteria were MET:

I l.a.l, l.d.l, l.e.l, 3.d.2, 5.a.l, 5.a.3, 5.b.1

a. Level 1 Finding: None I

b. Level 2 Finding: None

c. Not Demonstrated: None I

d. Prior Level 2 Findings -Resolved: None

e. Prior Level 2 Findings - Unresolved: None I

I I

I 34 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Environmental Response, Health and Safety Capability Summary:

I Implementation of a potassium iodide decision for institutionalized individuals and the general public was evaluated during out-of-sequence activities on May 7, 2019 with the I Lawrence County Health Department and.the Alabama Department of Public Health.

The Lawrence County Health Department, upon issuance of a health order"by the State Health Officer to ingest potassium iodide, the Health Department would deploy nurses, I support staff, potassium iodide quantities, and go-kits to the county reception center.

Potassium iodide would be issued to the general public from the county reception center.

Potassium iodide is not pre-distributed to residents of the 10-rnile emergency planning I zone prior to an incident. .

At the reception center members of the general public would be directed to a potassium I iodide station staffed by the Lawrence County Health Department. At this station individuals would sign a potassium iodide consent form, receive instructions for when to take potassium iodide, information about side effects, and be issued the appropriate I dosage. Additional quantities of potassium iodide could be requested from the Alabama Department of Public Health if needed. Distribution and administration of potassium iodide to institutionalized individuals at locations other than the reception center would I require additional coordination with the Lawrence County Emergency Operations Center.

Lawrence County's potassium iodide quantities were made available for inspection.

Expiration dates and quantities were found to be sufficient to meet the needs of the I* expected population.

For this capability, the following Radiological Emergency Preparedness criteria were I MET: 3.b.l.

a. Level 1 Finding: None I b. Level 2 Finding: None

c. Not Demonstrated: None I d. Prior Level 2 Findings-Resolved: None

e. Prior Level 2 Findings - Unresolved: None I On-Scene Security, Protection, and Law Enforcement Capability Summary:

I Lawrence County demonstrated the ability to implement traffic control points by interview during an out of sequence demonstration on May 14, 2019. Lawrence County I Emergency Management and Lawrence County Sheriffs Office staffs were interviewed on activities related to on-scene security, protection, and law enforcement. Sheriff' s deputies interviewed discussed their ability to establish traffic and access control, identify I and resolve impediments to evacuation, and manage radiological exposure to emergency workers, and provide accurate instructions to the public at traffic and access control points.

I 35 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Communication systems used by the Lawrence County Sheriffs Office included cell phone, radio, and patrol vehicle laptops. Communication checks are conducted daily. I Law enforcement officers assigned to establish the pre-determined traffic control points .

were provided a safety briefing by the radiation safety officer, issued personal protection equipment, radiation kits, and dosimetry. They also received just in time training on I radiological exposure control limits, dosimetry usage and placement, administrative limits and turn back values, dose and potassium iodide record management. Lawrence County Sheriff's Office staff interviewed described methods for the removal of road I impediments and requests for assistance to remove impediments. They are aware of locations for reception centers and emergency worker monitoring stations.

I Lawrence County conducted waterway warning during an out of sequence demonstration on May 14, 2019. Lawrence County Emergency Management and Lawrence County Sheriffs Office launched a boat on Wheeler Lake, covering the waterway area for which I

they are responsible within the IO-mile Emergency Planning Zone of the Browns Ferry Nuclear Plant. I Lawrence County Emergency Management Agency alerted the Lawrence County Sheriffs Office to place a boat into the water at the Wheeler Lake boat ramp. The necessary equipment for running the river was maintained on the boat. Personnel were I

issued radiation kits with dosimeters, thermoluminescent dosimeters, potassium iodide, and administrative limit cards. They were equipped with cell phones and radios and maintained communication. Waterway warning and clearance was initiated in I

accordance with plans and procedures. The boat navigated from the Wheeler Lake boat ramp towards Morgan County, back to Spring Creek, and turned around at Mallard. With the use of a bull horn, a pre-scripted message was read over public address system to alert I

boaters of an incident, to leave the area immediately, and to tune to local ~adio for further guidance. It was noted by emergency management personnel that dosimeters should be checked every 15-30 minutes. Waterway warning and clearance was completed in 16 I

minutes, well within the 45-minute goal.

For this capability, the following Radiological Emergency Preparedness criteria were I

MET: I.a.I, l.d.l, Le.I, 3.a.l, 3.d.l., 3.d.2.

a. Level I.Finding: None.

I

b. Level 2 Finding: None

c. Not Demonstrated: None I

d. Prior Level 2 Findings -Resolved: None

e. Prior Level 2 Findings - Unresolved: None I

I I

36 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant 3.3.3.2 Reception Center and Emergency Worker Decontamination I Environmental Response, Health and Safety Capability Summary:

I Lawrence County and the State of Alabama demonstrated the monitoring and decontamination of evacuees, emergency workers, and their vehicles. The demonstration was held at the Moulton Recreation Center on May 14, 2019. Participants in the I demonstration included the Lawrence County Emergency Management Agency, Moulton Fire Department, Alabama Department of Health, and Department of Human Resources.

I Prior to set up of the vehicle monitoring and decontamination station and reception center, a safety and radiological briefing was provided to all emergency workers.

Dosimetry was issued and radiation survey equipment checked for calibration and I operability. Appropriate types and quantities of supplies were available for the demonstration; additional supplies, radiation survey equipment, or staff could be requested through Lawrence County Emergency Management, Alabama Department of I Health, and Alabama Emergency Management Agency. Emergency workers wore appropriate protective clothing, with donning and doffing observed. They also demonstrated a thorough understanding of survey instrument operation, dosimetry use, I administrative radiation exposure limits, exposure record-keeping, and contamination action levels. Dosimetry was read every 15-30 minutes during the demonstration.

Equipment, displays, signs, and other supplies were sufficient to support emergency I operations.

The vehicle monitoring and decontamination station was set up in the parking lot of the I reception center at Moulton Recreation Center. Moulton Fire Department and Alabama Department of Health personnel completed record forms of all incoming vehicles and ,

used handheld survey instruments for monitoring. Vehicles were surveyed in a I methodical fashion, with a focus on critical areas most likely to be contaminated. Two vehicles were processed through this station, one found to be clean and one found to be contaminated. The clean vehicle received a green 'clean' tag to be placed on the dash I and was parked in a designated clean area. The second vehicle found to be contaminated was given a red 'dirty' tag and parked in a designated impound area, to be I decontaminated later as resources allowed.

The reception center facility was well laid out, and all available resources were used to I minimize the chance for cross contamination. Moulton Fire Department and Alabama Department of Health personnel used portal monitors and handheld survey instruments to monitor evacuees for contamination and directed decontamination efforts as needed.

I Proper survey and contamination-control techniques were used throughout the demonstration. If found free of contamination, an evacuee was provided a green wrist band and directed to register with the Department of Human Resources. If contaminated, I an evacuee was escorted to the appropriate shower facility for further monitoring and decontamination. Appropriate decontamination supplies and instructions were provided to evacuees, as well as disposable replacement clothing.

I 37 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

A total of 6 evacuees were processed during this demonstration. 4 were found to be free of contamination and 2 were found to be contaminated. Additionally, 3 emergency I workers were processed during this demonstration. 2 were found to be free of contamination and one was found to be contaminated. Calculating the population of the 10-mile emergency planning zone sectors assigned to this reception center against the I 20% planning base, it was determined the reception center workers had approximately 55 seconds to complete monitoring of a single person. The demonstrated monitoring methods resulted in an average evacuee survey time of 21 seconds per person, which met I

the monitoring productivity rate outlined in the Radiological Emergency Preparedness Program Manual. With the available equipment and personnel, twenty percent of the evacuating public could be monitored within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

I For this capability the following Radiological Emergency Preparedness criteria were MET:

l.e.l, 3.a.l, 6.a.l, 6.b.l.

I

a. Level 1 Finding: None

b. Level 2 Finding: None I

c. Not Demonstrated: None I

d. Priot Level 2 Findings - Resolved: None

e. Prior Level 2 Findings - Unresolved: None I 3.3.4 Limestone County 3.3.4.1 Emergency Operations Center I

Operational Coordination Capability Summary: I Limestone County emergency management staff successfully demonstrated the ability to respond to a radiological emergency and ensure the safety of the public and county emergency workers. The emergency management director notified emergency operations I

center staff and activated the facility in a timely manner.

The director effectively demonstrated direction and control of the many different support I

agencies in the emergency operations center. She implemented all protective action decisions and health orders made by Alabama Department of Public Health. When the protective action decision was made to restrict access into the two-mile emergency I

planning zone the emergency management director's proactive planning of pre-positioning the sheriff deputies at the traffic control points helped for a speedy execution of the health order. Periodic briefings kept the staff informed of emergency conditions I

and effectively maintained internal coordination.

I I

38 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Communication capabilities were managed in support of emergency operations.

I Limestone County emergency operations center had redundant systems for communication to include a dedicated phone line for communication with Browns Ferry Nuclear Power Plant. Additional means of communications included email, text I messaging, an emergency management software system facsimile machines, and 800-megahertz voice radio.

I Limestone County emergency operation center had enough equipment, maps, displays, dosimetry, potassium iodide (KI) and other supplies to support emergency operations.

I Emergency management, law enforcement, and rescue squad staff were knowledgeable of radiological exposure control measures. The Limestone Council on Aging representative performed effective planning to evacuate persons identified with I access/functional needs. The school representatives demonstrated, through interview, the ability to evacuate school children and staff. Law enforcement representatives provided details on traffic control points, clearing impediments, and the county's role in waterway I warning. Staff members were knowledgeable, and effectively used county plan checklists to ensure the safety of the public and emergency workers.

I For this capability the following Radiological Emergency Preparedness criteria were MET:

1.a.1, 1.c.1, 1.d.1, 1.e.1, 2.a.l, 2.b.2, 2.c.l, 3.a.l, 3.b.1, 3.c.1, 3.d.l, 3.d.2.

I a. Level 1 Finding: None

b. Level 2 Finding: None I c. Not Demonstrated: None

d. Prior Level 2 Findings - Resolved: None I e. Prior Level 2 Findings - Unresolved: None Public Information and Warning Capability Summary:

I The Limestone County Public Information Officer demonstrated the ability to deliver I coordinated, prompt, reliable, and actionable information to Limestone County residents through the use of clear, consistent, and accessible means. The Limestone County operations officer, along with representatives from the other risk counties, coordinated I the selection of pre-scripted messages used for special news bulletins and Emergency Alert System messages. Madison County was responsible for coordinating the broadcast of each selected messages with the National Weather Service. County-specific messages I were emailed to radio and TV stations for further distribution.

I I

39 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

The primary means to alert and notify citizens was the primary notification system consisting of fixed sirens and the broadcast of Emergency Alert System messages. In addition, Limestone County communications room activated tone alert radios to notify I schools and businesses. Backup route alerting would be initiated in the event of siren failure.

I The first protective action decision was to restrict access for a two-mile radius around the Browns Ferry Nuclear Power Plant and to issue a public warning for the counties. The restricted access affected zones A2 and B2 in Limestone County. When the state and I

counties concurred that a protective action decision was to be made that would affect the public, Madison County coordinated the sounding of sirens and the issuance of Emergency Alert System messages. Emergency Alert System messages were issued by I

the National Weather Service. A time was concurred upon at which sirens were sounded, tone alert radios were activated, and Emergency Alert System messages were issued simultaneous!y.

I Limestone County demonstrated backup route alerting during an out of sequence demonstration on May 15, 2019. Participants included personnel from the Limestone I

County Emergency Management and Limestone Sheriff's Department. Following a simulated siren failure, Limestone County Emergency Management initiated backup route alerting procedures. The Limestone Sheriff's Department assigned staff to report to I

the emergency operations center for a safety briefing by the radiation safety officer and to be issued personal protection equipment, radiation kits, and dosimetry. They also received just in time training on radiological exposure control limits, dosimetry usage and I

placement, administrative limits and turn back values, dose and potassium iodide record management. Officers were equipped with cell phones and radios to maintain communication. The Limestone Sheriffs Department vehicle left the emergency I

operations center and ran a pre-determined route to fully cover the area of siren failures.

A scripted message was read over public address system to alert residents of an incident and to tune to local radio and refer to emergency information calendars for further I

guidance. Backup route alerting was successfully completed in 13 minutes.

For this capability the following Radiological Emergency Preparedness criteria were MET:

I 1.a.1, 1.d.1, 1.e.l, 3.d.2, 5.a.1, 5.a.3, 5.b.1.

a. Level 1 Finding: None I

b. Level 2 Finding: None

c. Not Demonstrated: None I

d. Prior Level 2 Findings - Resolved: None

e. Prior Level 2 Findings - Unresolved: None I

I I

40 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Environmental Response, Health and Safety CapabiUty Summary I Implementation of a potassium iodide decision for institutionalized individuals and the general public was evaluated during out-of-sequence activities on May 9, 2019 with the I Limestone County Health Department and the Alabama Department of Public Health.

The Limestone County Health Department, upon issuance of a health order by the State Health Officer to ingest potassium iodide, would deploy nurses, support staff, potassium I iodide quantities, and go-kits to the county reception center. Potassium iodide would be issued to the general public from the county reception center. Potassium iodide is not pre-distributed to residents of the 10-mile emergency planning zone prior to an incident.

I At the reception center members of the general public would be directed to a potassium iodide station staffed by the Limestone County Health Department. At this station I individuals would sign a potassium iodide consent form, receive instructions for when to take potassium iodide, information about side effects, and be issued the appropriate dosage. Additional quantities of potassium iodide could be requested from the Alabama I Department of Public Health if needed. Distribution and administration of potassium iodide to institutionalized individuals at locations other than the reception center would require additional coordination with the Limestone County Emergency Operations I Center. Limestone County's potassium iodide quantities were made available for inspection. Expiration dates and quantities were found to be sufficient to meet the needs of the expected population.

I For this capability, the following Radiological Emergency Preparedness criteria were MET: 3.b.l.

I a. Level 1 Finding: None I b. Level 2 Finding: None

c. Not Demonstrated: None I d. Prior Level 2 Findings-Resolved: None

e. Prior Level 2 Findings - Unresolved: None I On-Scene Security, Protection, and Law Enforcement Capability Summary:

I Limestone County demonstrated by interview the implementation of traffic and access control and dealing with impediments to evacuation during an out of sequence event on May 15, 2019. The interview was conducted at the Limestone County Emergency I Management Agency. Participants in the interview included the Limestone Emergency Management Agency staff (Director?), Limestone Sheriff's Department, and Oak Grove Thach Volunteer Fire Department.

I I

41 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

The Limestone Sheriff's Department discussed their ability to establish traffic and access control, identify and resolve impediments to evacuation, manage radiological exposure to emergency workers, and provide accurate information to the public. Communication I systems used by the Limestone Sheriff's Department include radio, VHF radio, patrol vehicle laptops, and cellular phone. Communication checks are conducted daily.

I Upon notification from the Limestone Emergency Management Agency to initiate traffic control points, the Limestone Sheriff's Department staff assigned to establish traffic control points would receive just-in-time training as needed, a briefing of the incident, I

documentation, and dosimetry. All necessary equipment used in establishing traffic control points is maintained by the Limestone Sheriff's Department. Additional traffic control point equipment needs would be coordinated with the Department of I

Transportation, local county agencies, and the emergency operations center. Limestone Emergency Management Agency and Limestone Sheriff's Department demonstrated the ability to issue dosimetry and the management of radiological exposure to emergency I

workers. Potassium iodide would be distributed in accordance with plans and procedures. Deputies were knowledgeable of radiological exposure control limits, dosimetry usage and placement, administrative limits and turn back values, dose and I

potassium iodide record management. Impediments to evacuation would be cleared immediately or, if necessary, alternate routes would be identified and communicated to the public.

I For this capability, the following Radiological Emergency Preparedness criteria were MET: l.d.l, l.e.l, 3.a.l, 3.d.l., 3.d.2.

I

a. Level 1 Finding: None I

b. Level 2 Finding: None

c. Not Demonstrated: None I

d. Prior Level 2 Findings -Resolved: None

e. Prior Level 2 Findings - Unresolved: None I 3.3.4.2 Reception Center and Emergency Worker Decontamination Environmental Response/Health and Safety Capability Summary:

I Limestone County demonstrated the monitoring and decontamination of evacuees, emergency workers, and their vehicles. The demonstration was held at Ardmore High I

School in Ardmore, Alabama, on May 15, 2019. Agencies participating in this demonstration were the Alabama Department of Public Health, Limestone Emergency I Management Agency, Ardmore Volunteer Fire Department, and Oak Grove-Thach Volunteer Fire/Rescue Department.

I I'

42 I

I Radiological Emergency Preparedness Program

.I After Action Report 2019 Browns Ferry Nuclear Power Plant Prior to set up of the vehicle monitoring and decontamination station and reception I center, a safety a_nd radiological briefing was provided to all emergency workers by the Alabama Department of Public Health. Dosimetry was issued and radiation survey equipment checked for calibration and operability. Appropriate types and quantities of I supplies were available for the demonstration; additional supplies, radiation survey equipment, or staff could be requested through Limestone County Emergency Management, Alabama Department of Health, and Alabama Emergency Management I Agency. Workers wore appropriate protective clothing, with donning and doffing observed, and demonstrated a thorough understanding of survey instrument operation, dosimetry use, administrative radiation exposure limits, exposure record-keeping, and I contamination action levels. Dosimetry was read every 30 minutes during the demonstration. Equipment, displays, signs, and other supplies were sufficient to support emergency operations.

I- The vehicle monitoring and decontamination station was set up in the parking lot of the reception center at Ardmore High School. Ardwore Volunteer Fire Department, Oak I Grove-Thach Volunteer Fire/Rescue Department, and Alabama Department of Health personnel completed record forms of all incoming vehicles and used handheld survey instruments for monitoring. Vehicles were surveyed-in.a methodical fashion, with a I focus on critical areas most likely to be contaminated. Two vehicles were processed through this station, one found to be clean.and one found to be contaminated. The clean vehicle received a green 'clean' tag to be placed ort the rearview mirror and was parked I in a designated clean area. The second vehiclefoundto be contaminated was given a red

'dirty' tag and diverted to a decontamination wash station. Decontamination was attempted using soap, hard bristle brushes, and water hose rinse. After decontamination I the vehicle was re-monitored and found to be clean.*. The red tag was replaced with a green tag and the vehicle was parked in the designated clean area.

I The reception center facility was well laid out within the gymnasium of Ardmore High School. All available resources were used to minimize the chance for cross contamination. Ardmore Volunteer Fire Department and Alabama Department of Health I personnel used portal monitors and handheld survey instruments to monitor evacuees for contamination and directed decontamination efforts as needed. Proper survey and

- contamination-control techniques were* used throughout the demonstration. - If found free I of contamination, an evacuee was provided a green wrist band and directed to register with the Department of Human Resources. If contaminated, an evacuee was escorted to I the appropriate shower facility for further monitoring and decontamination. Appropriate decontamination supplies and instructions were provided to evacuees, as well as disposable replacement clothing.

I A total of 6 evacuees processed during this demonstration. 4 were found to be free of

• contamination and 2 were found to be contaminated. Calculating the population of the I 10-mile emergency planning zone sectors assigned to this reception center against the 20% planning base, it was determined the reception center workers had approximately 27 seconds to complete monitoring of a single person. The demonstrated monitoring I

43 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I.

methods resulted in an average evacuee survey time of 15 seconds per person, meeting the monitoring productivity rate standard as outlined in the Radiological Emergency Preparedness Program Manual. With the available equipment and personnel, twenty I percent of the evacuating public could be monitored within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

For this capability the following Radiological Emergency Preparedness criteria were MET: I l.e.l, 3.a.l, 6.a.l, 6.b.1

a. Level 1 Finding: None I

b. Level 2 Fm.ding: None

c. Not Demonstrated: None I

d. Prior Level 2 Findings -Resolved: None

e. Prior Level 2 Findings - Unresolved: None I

Mass Care I Limestone County demonstrated the capabilityto*provide services and accommodations

• to evacuees by establishing a mass care shelter and ensuring evacuees have been monitored and decontaminated prior to entering the shelter. The demonstration was held I

at the Ardmore High School in Ardmore, Alabama on May 15, 2019. Participants in the demonstration included the Ardmore Fire Department, Oak Grove Thach Volunteer Fire Department, Limestone County Emergency Management Agency, Alabama Department I

of Public Health, Office of Radiation Control, Limestone County Department of Health, Department of Human Resources and the American Red Cross. Department of Human Resources and Health Department Nurses conducted the initial registration and I

. administration of potassium iodide.

The mass care shelter was in a second gymnasium on the Ardmore High School campus, I

in a building just west of the reception center. Once an evacuee completed registration at the reception center, they were directed to the mass care shelter. Signage and directions were posted to assist evacuees to go from the reception center to the mass care shelter.

I Three American Red Cross Volunteers staffed the mass care shelter. Once at the shelter, evacuees were requested to display their clean green wrist bands and their potassium iodide ingestion consent forms.

I Evacuees registering with the American Red Cross were provided services and accommodations at the mass care shelter. Evacuees were asked whether they needed I

medical attention, had special dietary needs, or requests for special accommodations.

The shelter had areas designated for children and those with special needs, and also had I WIFI capability. Meals, health services, and spiritual care would be provided at the shelter. A Spanish language translator was available, and each American Red Cross volunteer had cellular applications for any other language communication: issues. I I

44 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant For this capability the following Radiological Emergency Preparedness criteria were MET:

I 6.c.1.

a. Level 1 Finding: None I b. Level 2 Finding: None

c. Not Demonstrated: None I d. Prior Level 2 Findings-Resolved: None

e. Prior Level 2 Findings - Unresolved: None I 3.3.5 Morgan County I 3.3.5.1 Emergency Operations Center Operational Coordination Capability Summary:

I Morgan County Emergency Management Agency staff and the emergency operations center personnel successfully demonstrated the ability to manage an emergency I operations center. The staff was effectively notified and activated to staff the emergency operations center. The director demonstrated good direction and control in coordinating response activities.

I The emergency operations center staff was successfully alerted and mobilized. The staff had access to an appropriate amount of equipment, supplies, and maps to support their I needs. Redundant communication systems ensured the emergency operations center had the ability to communicate with other agencies. All systems were fully functional and demonstrated during the exercise. They used an Alabama Emergency Agency emergency I management software system , a Tennessee Valley Authority emergency management software system, and an internal Morgan County incident reporting system to successfully communicate and document all events .. The Decatur Amateur Radio Club I provided amateur radio resources.

I The Morgan County director and emergency operations center coordinator maintained good situational awareness of the emergency. They used the utility liaison to keep the staff informed and up to date on the utility's status. During briefings, they would poll the I various agencies as to their current actions and had the them review what "ifs" for potential future actions.

I The director coordinated the development of protective action decisions with the state and the other risk counties. Morgan County Emergency Operations Center staff did an excellent job of identifying the affected access and functional needs population in the I emergency planning zone. Once identified these individuals were notified for movement with the department of transportation.

I 45 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

For this capability the following Radiological Emergency Preparedness criteria were MET:

l.a.1, l.c.l, l.d.1, l.e.l, 2.a.l, 2.b.2, 2.c.1, 3.a.1, 3.b.1, 3.d.l, 3.d.2.

I

a. Level 1 Finding: None

b. Level 2 Finding: None I

c. Not Demonstrated: None

d. Prior Level 2 Findings - Resolved: None I

e. Prior Level 2 Findings - Unresolved: None Public Information and Warning Core Capability Summary:

I The Morgan County Emergency Management Agency successfully demonstrated the ability to furnish pertinent, accurate, and timely information to the public during a I

simulated emergency at the Browns Ferry Nuclear Power Plant. The primary means of alerting the public to an emergency in Morgan County was a system of strategically placed sirens. When the risk counties of Morgan, Lawrence, Lauderdale, and Limestone I

reached a decision concurrent with the host county of Madison that a public notice should be issued, the sirens were sounded simultaneously by each county. This sounding was followed immediately by the broadcast of an emergency alert system broadcast informing I

the public of the ongoing situation and any recommended protective actions. This action was completed using pre-scripted, pre-approved messages, which were transmitted to the national weather service for broadcast.

I A discussion was conducted with the Morgan County Emergency Operations Center Coordinator and the Morgan County Sheriff's Office representative concerning the I

procedure to be followed in the event of a siren failure. A procedure was described

• indicating the operation of patrol vehicles in the area of the failed siren while a verbal message was broadcast over the public address system. It was noted that instructional I

booklets and sufficient maps were available for officers that may be tasked with this assignment. I During this exercise the activation of sirens (simulated) and the broadcast of follow-up information to the public was demonstrated five times in Morgan County. On each occasion the action was approved by the Morgan County Emergency Management I

Director in coordination with the emergency operations center coordinator; the sounding was coordinated with the other counties and adequate information was included in the broadcast message. Broadcasts were monitored and accuracy of information transmitted I

was verified on each occasion.

I Morgan County made use of two public information officers; one from the Morgan County Sheriffs' Office and one from the Decatur Police Department. The public information officers compiled a total of eleven special news broadcasts, Emergency Alert I System messages, health orders, and county specific press releases during this exercise.

I 46 1,

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Each of these were approved by the emergency management director. Each message I identified the issuing entity; identified the nuclear facility involved in the emergency; referred the public to previously published emergency information; and directed the public to stay tuned to local news outlets for further information.

I For this capability the following Radiological Emergency Preparedness criteria were MET:

l.a.1, l.d.l, l.e.l, 3.d.2, 5.a.l, 5.a.3, 5.b.l.

I a. Level 1 Finding: None

b. Level 2 Finding: None I c. Not Demonstrated: None I d. Prior Level 2 Findings - Resolved: None

e. Prior Level 2 Findings - Unresolved: None I Environmental Response, Health and Safety Capability Summary:

Implementation of a potassium iodide decision for institutionalized individuals and the I general public was evaluated during out-of-sequence activities on May 9, 2019 with the Morgan County Health Department and the Alabama Department of Public Health. The Morgan County Health Department, upon issuance of a health order by the State Health I Officer to ingest potassium iodide, would deploy nurses, support staff, potassium iodide quantities, and go-kits to the county reception center. Potassium iodide would be issued.

to the general public from the county reception ceriter. Potassium iodide is not pre-I distributed to residents of the 10-mile emergency planning- zone prior to an incident.

At the reception center members of the general public would be directed to a potassium I iodide station staffed by the Morgan County Health Department. At this station individuals would sign a potassium iodide consent form, receive instructions for when to take potassium iodide, information about side effects, and be issued the appropriate I dosage. Additional quantities of potassium iodide could be requested from the Alabama Department of Public Health if needed. Distribution and administration of potassium iodide to institutionalized individuals at locations other than the reception center would I require additional coordination with the Morgan County Emergency Operations Center.

Morgan County's potassium iodide quantities were made available for .inspection.

I Expiration dates and quantities were found to be sufficient to meet the needs of the expected population.

I For this capability, the following Radiological Emergency Preparedness criteria were MET: 3.b.l.

I a. Level 1 Finding: None

b. Level 2 Finding: None I

47 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

c. Not Demonstrated: None

d. Prior Level 2 Findings - Resolved: None I

e. Prior Level 2 Findings - Unresolved: None On-Scene Security, Protection, and Law Enforcement Capability Summary: I Morgan County Emergency Management Agency staff and Decatur Police Department officers demonstrated by interview the implementation of traffic and access control and I impediments to evacuation during an out of sequence event on May 9, 2019. The interview was conducted at the Morgan County Emergency Operations Center in Decatur, Alabama.

I The Decatur Police Department officers discussed their ability to establish pre-determined traffic control points and issue dosimetry, procedures to obtain potassium I

iodide, and manage radiological exposure to their officers during an event at the Browns Ferry Nuclear Power Plant. Communication systems used by the Decatur Police Department included radio, patrol vehicle laptops, and cellular phone. Communication I

checks are conducted daily. Upon notification from the Morgan County Emergency Management Agency to initiate.traffic*controlpoints, the Decatur Police Department staff assigned to establish traffic control points would receive just-in-time training as needed, a I

briefing of the incident, documentation, and dosimetry.

Decatur Police Department officers demonstrated knowledge of radiological exposure I

control , dosimetry usage and placement, administrative exposure limits and turn back values, dose and potassium iodide record management. Potassium iodide is distributed in accordance with plans and procedures. Appropriate traffic and access control I

establishment was also discussed. They demonstrated knowledge of initiating orders to

• set up traffic control points, the reasons for establishment of traffic control points, their pre-identified locations, and the equipment necessary to set them up. Impediments to I

.evacuation would be cleared immediately by the assigned personnel. If impediment removal was outside of their ability, assistance would be requested and coordinated through the county emergency operations center. Alternate evacuation routes would be I

identified and communicated to the public.

For this capability, the following Radiological Emergency Preparedness criteria were I

MET: I.a.I, 1.d.l, 1.e.1, 3.a.l, 3.d.1., 3.d.2.

a. Level 1 Finding: None I

b. Level 2 Finding: None

c. Not Demonstrated: None I

d. Prior Level 2 Findings-Resolved: None I

e. Prior Level 2 Findings - Unresolved: None I

48 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I 3.3.5.2 Reception Center and Emergency Worker Decontamination Environmental Response, Health and Safety Capability Summary:

I Morgan County demonstrated the monitoring and decontamination of evacuees, emergency workers, and their vehicles. The demonstration was held at Priceville Junior I High School in Decatur, Alabama, on May 16, 2019. Organizations participating in this demonstration included the Priceville Fire and Rescue Department, Trinity Fire Department, Brindlee Mountain Fire Department, Morgan County Rescue, Samaritan I EMS, Hartselle Police Department, Morgan County Sheriff Department, Decatur Amateur Radio Club, Civil Air Patrol 1341h Squadron, Morgan County Department of Human Resources, Industrial Emergency Association, Morgan County Emergency I Management Agency, and Alabama Department of Public Health. The Brindlee Mountain Fire Department Chief oversaw the emergency response at this location and the Industrial Emergency Association representative served as the radiation safety officer.

I Prior to set up of the vehicle monitoring and decontamination station and reception center, a safety and radiological briefing was provided to all emergency workers by the I Alabama Department of Public Health. Dosimetry was issued and radiation survey equipment was source-checked, calibration confirmed, and placed into operation.

Appropriate types and quantities of supplies were available for the demonstration; I additional supplies, radiation survey equipment, or staff could be requested through Morgan County Emergency Management, Alabama Department of Public Health, and Alabama Emergency Management Agency. Workers wore appropriate protective I clothing, with donning and doffing observed, and demonstrated an understanding of survey instrument operation, dosimetry use, administrative radiation exposure limits, exposure record-keeping, and contamination action levels. Dosimetry was read every 30 I minutes during the demonstration. Equipment, displays, signs, and other supplies were sufficient to support emergency operations.

I The vehicle monitoring and decontamination station was set up in the parking lot of the reception center at Priceville Junior High School. Vehicles were directed to go through i an initial wash station, slowly drive through a portal monitor, and then proceeded to a vehicle monitoring station. Priceville Fire and Rescue Department and Alabama Department of Public Health personnel completed record forms of all incoming vehicles I and used handheld survey instruments for monitoring. Vehicles were surveyed in a methodical fashion, with a focus on critical areas most likely to be contaminated. Two vehicles were processed through this station, one found to be clean and one found to be I contaminated. The clean vehicle received a green 'clean' tag to be placed on the dash and was parked in a designated clean area. The second vehicle found to be contaminated was decontaminated a second time and re-monitored. The vehicle was found to be clean I upon re-monitoring and was given a green 'clean' tag and parked in the designated clean I

49 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

area. If it had been found dirty, a red 'dirty' tag would have been placed in the vehicle and parked in a designated dirty lot. The vehicle monitoring and decontamination team communicated effectively with one another and were attentive to minimizing potential I cross contamination.

The Priceville Junior High School gymnasium floorplan and the location of showers did I not make school an ideal location for the reception center. The reception center was laid out as effectively as possible, but there were still several unavoidable points of potential cross contamination. Emergency workers used all available resources to minimize the I

chance for cross contamination. Staff were assigned to man these points and were observed frequently surveying their assigned point, changing out the floor covering, and wiping the points clean. Emergency workers staffing the reception center used portal I

monitors and handheld survey instruments to monitor evacuees for contamination and directed decontamination efforts as needed. Proper survey and contamination-control techniques were demonstrated. If found free of contamination, an evacuee was provided I

a green wrist band and directed to register with the Department of Human Resources. If contaminated, an evacuee was escorted to the appropriate shower facility for further monitoring and decontamination. Appropriate decontamination supplies and instructions I

were provided to evacuees, as well as disposable replacement clothing.

A total of 10 evacuees processed during this demonstration. 5 were found to be free of I

contamination and 5 were found to be contaminated. 2 emotional support animals were carried through initial screening with their owners, who were found to be clean and did not require decontamination. Morgan County demonstrated the capability to I

communicate with evacuees at the reception center in American Sign Language, or other foreign languages, through the use of a virtual ~idea translation service. I Calculating the population of the 10-mile emergency planning zone sectors assigned to this reception center against the 20% planning base, it was determined the reception center workers had approximately 52 seconds to complete monitoring of a single person.

I The demonstrated monitoring methods results in an average evacuee survey time of averaged 30 seconds per person, meeting the monitoring productivity rate standard as outlined in the Radiological Emergency Preparedness Program Manual. With the I

available equipment and personnel, twenty percent of the evacuating public could be monitored within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. I For this capability the following Radiological Emergency Preparedness criteria were MET:

l.e.l, 3.a.l, 6.a.l. I

a. Level 1 Finding: None

b. Level 2 Finding: None I

c. Not Demonstrated: None

d. Prior Level 2 Findings - Resolved: None I

I 50 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant

e. Prior Level 2 Findings - Unresolved: None I 3.3.5.3 Medical Service Drill: Lifeguard Ambulance Emergency Medical Service I Public Health, Healthcare & Emergency Medical Services The Lifeguard Ambulance Emergency Medical Service staffs demonstrated they had I sufficient medical resources, equipment, supplies, and trained personnel to provide medical services and transportation of a contaminated injured patient, to support a radiological incident at the Browns Ferry Nuclear Power Plant. All exercise objectives I were successfully met during a medical services drill on July 18, 2019.

The Lifeguard Ambulance Emergency Medical Service demonstrated contamination I control by properly cocooning the patient, frequent glove changes and the proper disposal of waste materials. Proper use of dosimetry equipment was demonstrated by frequent monitoring of self-reading dosimeters.

I During this exercise they transported and provided medical care for a contaminated patient. The patient was transported from the Liberty Baptist Church in Hartselle, I Alabama, a simulated accident site, to the Decatur Morgan Hospital - Decatur Campus.

They conducted a communications check with the hospital upon departure, while en route and upon arrival to demonstrate the communications capability. The hospital staff was I provided with patient medical information, the expected arrival times and the possibility of contamination from the accident site. They provided enough information for the hospital to properly prepare for a contaminated injured patient.

!1 Transfer of the patient from the ambulance crew to the hospital staff was effortless and followed by a briefing on the patients' status to the decontamination room staff.

I For this capability the following Radiological Emergency Preparedness criteria were MET:

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

I a. Level 1 Finding: None I b. Level 2 Finding: None

c. Not Demonstrated: None I d. Prior Level 2 Findings - Resolved: None

e. Prior Level 2 Findings - Unresolved: None I

I I

51 I

• Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

3.3.5.4 Medical Service Drill: Decatur Morgan Hospital - Decatur Campus Public Health, Healthcare & Emergency Medical Services I The Decatur Morgan Hospital- Decatur Campus in Decatur, Alabama, demonstrated the capability to provide monitoring, decontamination, and medical services to a I

contaminated, injured individual during a medical services drill on July 18, 2019.

Hospital staff received notifications of a simulated event at the Browns Ferry Nuclear I

Power Plant and escalating emergency classification levels from the Morgan County Emergency Management Agency. Upon each escalation, additional hospital personnel were activated and increasing preparations made for the hospital and staff receive I

potentially contaminated, injured individuals. Hospital staff effectively prepared the receiving area and treatment room to accommodate a contaminated individual. Security personnel secured the facility to minimize the potential spread of contamination.

I Hospital staff were provided with a radiological safety briefing and issued dosimetry.

Survey meters were placed into operation in accordance with procedure. I Upon patient transfer from the ambulance to the hospital, the patient's medical condition was assessed. Once determining the patient's injuries to be non-life threatening, the hospital staff decontaminated the patient and treated injuries in accordance with their I

plans and procedures. Decontamination procedure reference charts, posters, and plans were used to their advantage. Great care was taken to prevent the spread of contamination to other areas of the hospital.

I Hospital staff followed appropriate protocols to control the spread of contamination, including frequently changing gloves, using ground covers to provide clean work areas, I

frequently surveying the decontamination room and equipment, and properly handling and disposing of potentially contaminated materials. Donning and doffing was demonstrated in accordance with procedure. The Decatur Morgan Hospital staff I

demonstrated good teamwork, excellent communication, and attention to detail.

For this capability the following Radiological Emergency Preparedness criteria were MET:

I l.e.l, 3.a.l, 6.d.l.

a. Level 1 Finding: None I

b. Level 2 Finding: None

c. Not Demonstrated: None I

d. Prior Level 2 Findings - Resolved: None

e. Prior Level 2 Findings - Unresolved: None I

I I

52 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant 3.3.6 Madison County I 3.3.6.1 Emergency Operations Center I Operational Coordination Capability Summary:

The Huntsville-Madison County Emergency Management Director and his staff I successfully demonstrated the ability to respond to a radiological emergency at the Browns Ferry Nuclear Power Plant. Madison County is a host county, with the primary mission of supporting evacuees from the risk counties. Emergency management staff I participated at the emergency operations center throughout the exercise, with other county support available through notification using a manual call-down roster.

Throughout the exercise the director effectively gathered pertinent emergency I information, analyzed it, and made appropriate decisions with effective direction and control. His proactive planning led to effective discussion and decision-making to receive any evacuating population from the emergency planning zone. Periodic staff I briefings kept his staff informed of emergency conditions and plant status, and the staff periodically briefed director to maintain effective internal coordination.

I The emergency operations center had multiple communication systems, to include computer Internet access, electronic mail, commercial land lines, cell phones, and other hand-held electronic devices. Backup communications also included facsimile machines, I 700/800 megahertz radios, and local government frequency radios. Three electronic incident management systems were used to maintain situational awareness and track assistance requests. Status calls and discussions among the risk counties and state I concerning protective actions were coordinated using a dedicated notification and conference line. Sufficient equipment and supplies were available.

I The radiological officer was knowledgeable of appropriate dosimetry, potassium iodide, and procedures to ensure that emergency workers were knowledgeable about radiological exposure control. The county health department was prepared to make potassium iodide I available to the general public at the reception center if activated.

I The Huntsville-Madison County emergency operations center supervisor discussed the requirements to establish appropriate traffic access and control points for reception centers in Madison County. The assistant director stated that if Limestone and or Morgan I counties requested Madison County open the county reception centers, then traffic access and control points would be established.

I The Huntsville-Madison County emergency operations center supervisor stated that an impediment to traffic flow to a reception center would be reported to the law enforcement representative in the emergency operations center to coordinate resources to remove the I

I 53 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

impediment or reroute traffic around the impediment. The county emergency operations supervisor stated the Madison County Emergency Management Director would notify Limestone and Morgan Counties of the new route to the reception center, and the I counties would disseminate the information to the evacuees from their counties.

For this capability the following Radiological Emergency Preparedness criteria were MET: I l.a.l, l.c.1, l.d.l, l.e.l, 3.d.l, 3.d.2.

a. Level 1 Finding: None I

b. Level 2 Finding: None

c. Not Demonstrated: None I

d. Prior Level 2 Findings - Resolved: None

e. Prior Level 2 Findings .. Unresolved: None I

Public Information and Warning Core Capability Summary:

I The Public Information and Warning Core Capability was successfully demonstrated by the Huntsville-Madison County Emergency Management Agency emergency operations staff. The staff coordinated the activation of the primary notification system, the I

broadcast of the emergency alert system messages, and special news bulletins for the risk counties through the Huntsville National Weather Service. The Huntsville-Madison County message controller facilitated calls on the risk county talk group, synchronized I

times with the risk counties, and received concurrence from the risk counties to issue selected messages. Upon conclusion of each call, the message controller would contact the National Weather Service and request activation of the Emergency Alert System and I

message broadcast. The National Weather Service confirmed the successful activation and message broadcast to Huntsville-Madison County. The Huntsville-Madison County staff coordinated five activations of the public notification system and emergency alert I

system sequences. The county staff also coordinated six special news bulletin messages.

A Huntsville-Madison County public information officer liaison represented Huntsville-Madison County in the joint information center and coordinated information with the I

county emergency operations staff by phone and the county electronic incident management system. I For this capability the following Radiological Emergency Preparedness criteria were MET:

5.a.l, 5.b.l. I

a. Level 1 Finding: None

b. Level 2 Finding: None I

c. Not Demonstrated: None

d. Prior Level 2 Findings - Resolved: None I

I 54 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant

e. Prior Level 2 Findings - Unresolved: None I On-Scene Security, Protection, and Law Enforcement Capability Summary:

I Madison County demonstrated the core capability of on-scene security, protection, and law enforcement during out of sequence interviews conducted on May 13, 2019. Officers from the Huntsville Police Department were interviewed and discussed their ability to I establish traffic and access control, identify and resolve impediments to evacuation, and provide accurate instructions to the public.

I Madison County is a host county and has no portion of the 10-rnile emergency planning zone. Residents of Madison County would not be under an evacuation order, but traffic control is established to ease the evacuation of residents from risk counties. All I necessary equipment used in establishing traffic control is maintained by Huntsville Police Department. Redundant communication systems were available to officers.

Additional traffic control point equipment needs would be coordinated with the I Department of Transportation, local county agencies, and the emergency operations center. As Madison is a host county outside of the 10-mile emergency planning zone, dosimetry, potassium iodide, and management of radiological exposure to emergency I workers is not required. Upon being assigned traffic control duties, officers would receive just-in-time training as needed, a briefing of the incident, documentation, and equipment required to perform the assigned task. Impediments to traffic flow would be I cleared immediately or, if necessary, alternate routes would be identified and communicated to the public.

I For this capability, the following Radiological Emergency Preparedness criteria were MET: l.d.l, l.e.1, 3.d.l., 3.d.2.

I a. Level 1 Finding: None

b. Level 2 Finding: None I c. Not Demonstrated: None

d. Prior Level 2 Findings - Resolved: None I e. Prior Level 2 Findings - Unresolved: None I 3.3.6.2 Shelter Operations Mass Care Capability Summary:

I Madison County demonstrated the capability to provide services and accommodations to evacuees by establishing a congregate care facility and ensuring evacuees have been I monitored and decontaminated prior to entering the congregate care facility. Huntsville-Madison County Emergency Management Agency, Madison County Department of Human Resources, and American Red Cross personnel established a congregate care I

55

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

facility at Showers Recreation Center in Huntsville, during an out of sequence demonstration on May 13, 2019.

I Madison County is a host county and has no portion of the 10-rnile emergency planning zone. Congregate care facilities in Madison County are established as overflow facilities to support evacuees from Limestone and Morgan Counties after congregate care facilities I in those counties are full. Madison County Department of Human Resources staff ensured all evacuees from Limestone and Morgan counties wore green bands indicating they had been monitored and, if necessary, decontaminated, and were clear to enter the I

facility. Evacuee registration and evacuation records, issued by the Department of Public Health at the reception center, were reviewed. American Red Cross personnel demonstrated the ability to provide services and accommodations for evacuees at I

Showers Recreation Center. Meals and health services would be provided until the evacuee can be transported to an American Red Cross shelter for long term sheltering.

Security for the facility is provided by Huntsville Police Department.

I For this capability the following Radiological Emergency Preparedness criteria were MET:

6.c.l.

I

a. Level 1 Finding: None

b. Level 2 Finding: None I

c. Not Demonstrated: None I

d. Prior Level 2 Findings-Resolved: None

e. Prior Level 2 Findings - Unresolved: None I 3.3.7 Joint Operations 3.3.7.1 Joint Information Center I

Public Information and Warning Capability Summary: I The public information officers and their support staff from the offsite response organizations of the Browns Ferry Nuclear Power Plant demonstrated the use of a joint information center to coordinate prompt, reliable, and actionable information delivered to I

the public in a timely manner. All emergency information provided was clear and accurate, and instructions were consistent with the coordinated protective action decisions known to the representatives at the joint information center.

I Joint information center staff demonstrated, through interview, the ability to be alerted, notified, and mobilized in an effective manner to support public information and warning I

to the affected population within the 10-rnile emergency planning zone of the Browns Ferry Nuclear Power Plant. After coordination between the utility and the state, the I decision to activate the joint information center was made due to a Site Area Emergency I

56 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant declaration by utility. Pre-positioning all9wed per the extent of play aided in the joint I information center becoming operational quickly.

Multiple communications systems were readily available and used simultaneously within I the joint information center. Communications observed were cellular phones, landline phones, facsimile, electronic mail, and web-based incident management platforms; all communications used operated without failure. A recent upgrade to the wireless I connectivity by the utility within the facility appeared to alleviate any prior communication failures. Equipment, displays, and supplies were sufficient to support emergency operations within the joint information center. The structure was located I outside of the 10-mile emergency planning zone; therefore, dosimetry, and potassium iodide were not required for use and/or distribution.

I The joint information center staff sufficiently demonstrated the delivery of accurate emergency information and instructions to the public and the news media in a timely manner, with a sense of urgency and without undue delay. A total of 11 special news I bulletins, orders, and news releases were received at the joint information center. All of them originated outside of the facility and were disseminated by the originating or designated agency or organization. The joint information center served as a repository, I using the published information to inform their discussions and press conference briefings. Three press conferences were conducted which outlined protective action decisions, specific instructions for the public, emergency public health orders, and plant I conditions.

Representatives from Blount, Colbert, Cullman, Jackson, and Marion Counties I implemented mutual aid agreements to augment public information officers from jurisdictions outside the 10-mile emergency planning zone in the joint information center.

This practice permitted risk counties to retain their staff to respond to the plume phase of I the exercise. It also increased the radiological emergency knowledge of response personnel from the 10-mile portion of the emergency planning zone out to the 50-mile ingestion pathway zone for potential response to an ingestion event.

I Public inquiry was accomplished by utility staff in the joint information center. The staff I answered seven calls from the public, and there were no trends or rumors identified by the public inquiry staff. By convening for pre-media briefing meetings and public information workroom briefings, appropriate situational awareness was maintained, and I calls were answered satisfactorily.

For this capability, the following Radiological Emergency Preparedness criterion were I MET: 1.a.1, 1.d.l, 1.e.l, 5.b.1.

a. Level 1 Finding: None I b. Level 2 Finding: None

c. Not Demonstrated: None I

57 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

d. Prior Level 2 Findings-Resolved: None

e. Prior Level 2 Findings - Unresolved: None I 3.3.8 Support Organizations 3.3.8.1 National Weather Service I

Public Information and Warning Capability Summary: I The National Weather Service successfully demonstrated the core capability Public Information and Warning through discussion detailing the activation of the local emergency alert system and the National Oceanic and Atmospheric Administration I

weather radios. The risk counties of Limestone, Morgan, Lauderdale, Lawrence, with support from host county Madison, utilize the National Weather Service to transmit Emergency Alert Messages to the public over local radio and television stations with I

supplemental messaging via the National Oceanic and Atmospheric Administration weather radios. The operations center is staffed 24/7 and all operations center staff are trained in Emergency Alert Message transmission procedures. Copies of the procedures I

are available in the operations center and available within the employee intranet. The National Weather Service is notified by Madison County of the risk counties' coordinated I request of specific message number to be transmitted, the current emergency classification level, and any evacuation orders. If the National Weather Service is unable to transmit Emergency Alert System Messages, the risk counties would contact local I radio stations. Three days of backup power to the facility is immediately available, which can be increased with additional fuel. The National Weather Service staff demonstrated the process of message transmission up to the point of transmission. Their I actions were fully and in accordance with the established plans.

For this capability, the following Radiological Emergency Preparedness criteria were I

MET: l.d.l, l.e.l, and 5.a.l.

a. Level 1 Finding: None I

b. Level 2 Finding: None

c. Not Demonstrated: None I

d. Prior Level 2 Findings -Resolved: None

e. Prior Level 2 Findings - Unresolved: None I

I I

I 58 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Section 4: Conclusion I Officials and representatives from the State of Alabama; the risk counties of Lauderdale, Lawrence, Limestone, and Morgan; the host county of Madison; National Weather Service; I Tennessee Valley Authority; and numerous volunteers and other agencies participated in this exercise. The cooperation and teamwork of the participants was evident throughout all phases of the exercise.

I Highlights of the exercise included effective communication and coordination between all involved organizations, resulting in a cohesive and effective response. State, local and federal I agency and utility stakeholders were actively involved in quarterly, exercise planning, and task force meetings, resulting in enhanced organizational interactions. Players in each organization excelled in their individual responsibilities, enabling successful demonstration of the capability I targets leading to the fulfillment of the core capabilities. The demonstrated commitment of leadership in these organizations was reflected through their staffs.

I The Federal Emergency Management Agency wishes to acknowledge the efforts of the many individuals who participated and made this exercise a success. Protecting the public health and safety is the full-time job of some of the exercise participants and an additional assigned I responsibility for others. Still, others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities. State and local emergency response organizations demonstrated knowledge of their emergency response plans and procedures and I successfully implemented them.

The Federal Emergency Management Agency wishes to acknowledge the efforts of the many I individuals who participated in the exercise and made it a success. The professionalism and teamwork of the participants was evident throughout all phases of the exercise.

I I

I I

I I

I 59 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

I I

I I

I I

I This page is intentionally blank I

I I

I I

I I

I I

60 I

---

Radiological Emergency Preparedness Program After Action Report 2019 Browns Ferry Nuclear Power Plant Appendix A: Exercise Timeline Emergency Time Time That Notification Was Received or Action Was Taken Classification Utility SRMAC SRMAC Lawrence Lauderdale Limestone Morgan Madison Level or Event Declared SEOC ITC Montgomery .Decatur County County , County County County Unusual Event NIA NIA NIA NIA NIA NIA NIA NIA NIA NIA Alert 0814 0819 0824 - 0824 0825 0825 0823 0825 -

Site Area Emergency 0934 0950 - 0945 0943 0945 0944 0943 0945 0944 General Emergency 1059 1106 - 1110 1109 1111 1110 1109 1110 1106 Simulated Rad. Release Started 0923 1106 0932 0932 1110 Jlll 1110 1109 1110 -

Simulated Rad. Release Terminated Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Ongoing Facility Declared Operational 0850 0824 0930 0946 0900 0957 0835 0845 1000 State 1110 - - - - - - - 1054 Declaration of State of Emergency Local - - - 1005 0955 0954 0935 - -

Exercise Terminated 1314 0930 1309 1308 1309 1309 1309 1309 1305 Public Notification of SAE 0947 - 0947 0947 0947 0947 0947 0947 -

l't Siren Activation 0952 - 0952 0952 0952 0952 0952 0952 -

l't EAS Messa2e 0952 - 0952 0952 0952 0952 0952 0952 0952 pt Protective Action Decision: '

Emergency Health Orders #I & #2 Public Warning 1004 - 1008 1015 1015 1015 1008 1015 1022 Restrict Access 2-Miles 2nd Siren Activation 1020 - 1020 1020 1020 1020 1020 1020 -

2nd EAS Message 1020 - 1020 1020 1020 1020 1020 1020 1025 Public Notification of GE - - 1112 1112 1112 1112 1112 1112 -

3,d Siren Activation 1118 - 1118 1118 1118 1118 1118 1118 -

3,d EAS Message 1118 - 1118 1118 1118 1118 1118 1118 1119 2nd Protective Action Decision:

Evacuate: A2, B2, F2, 02, AS 1133 - 1138 1144 1144 1144 1138 1144 1138 Emergency Health Order #3 4th Siren Activation 1152 - 1152 1152 1152 1152 1152 1152 -

4th EAS Messa2e 1152 - 1152 1152 1152 1152 1152 1152 1153 3'd Protective Action Decision:

Evacuate: A2, B2, F2, 02, AS, BS 1207 - 1212 1217 1217 1217 1212 1217 1230 Emergency Health Order#4 5th Siren Activation 1228 - - 1228 1228 1228 1228 1228 -

5th EAS Messa2e 1228 - - 1228 1228 1228 1228 1228 1228 KI Administration Decision NIA NIA NIA NIA NIA NIA NIA NIA NIA 61

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

I I

I I

I I

I This page is intentionally blank I

I I

I I

I I

I I

62 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Appendix B: Exercise Evaluators and Team Leaders I RAC Chair: Randy Hecht I South Section Chief: Robert Spence North Section Chief: JT Ackermann 1- Central Section Chief: Lawrence Robertson AL Lead Evaluator: Glenda Bryson ICF Coordinator/RC: Jill Leatherman ICF Admin Support: Erin McCarty 1 . Location* Evah1ation Tealll

• Core* Capabili!ies JoinfOp~r~tions,. .  : ;,

I Libby Adkins*

JIC Erica Houghton Public Information & Warning Henry Christiansen I NWS (OOS:

Glenda Bryson Public Information & Warning May 13, I 2019)

State of Alabama Operational Coordination I SEOC Gerald McLemore*

Bruce Swiren Situational Assessment Operational Communications Public Information & Warning I SRMAC-Situational Assessment Operational Communications Reggie Rodgers Montgomery Public Information & Warning I SRMAC-Environmental Response/Health and Safety Situational Assessment I Decatur Field Team John Fill*

Jill Leatherman Operational Communications Public Information & Warning Environmental Response/Health and Safety I Management Field Teams I (2 Field Teams for Lloyd Generette evaluation; Deb Blunt Environmental Response/Health and Safety I 1 Field Teamfor Marynette Herndon observation)

I I

63 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Lauderdale County Robert Nash*

Operational Coordination Situational Assessment I

EOC Operational Communications Gary Bolender Public Information & Warning Environmental Response/Health and Safety I

Glenda Bryson OOS:

May 14&

Lorenzo Lewis David Ortman Public Information & Warning On Scene Security and Protection I

17,2019 Mark Dalton ICF Mass Care John Wills ICF Lawrence County I

Operational Coordination EOC Quintin Ivy*

Situational Assessment Operational Communications I

Danny Loomis Public Information & Warning Glenda Bryson Environmental Response/Health and Safety I OOS: Lorenzo Lewis Public Information & Warning May 14, 2019 David Ortman Mark Dalton ICF Environmental Response/Health and Safety On Scene Security and Protection I

John Wills ICF Limestone County Operational Coordination I

EOC DeShun Lowery*

Terry Blackmon Situational Assessment Operational Communications Public Information & Warning I

Environmental Response/Health and Safety Glenda Bryson On Scene Security and Protection I Public Information & Warning OOS:

May 15, Lorenzo Lewis David Ortman Mark Dalton ICF Environmental Response/Health and Safety On Scene Security and Protection I

2019 Mass Care Mor2an County John Wills ICF I

Operational Coordination EOC David Ortman*

Glenda Bryson Situational Assessment Operational Communications I Public Information & Warning Mark Dalton Environmental Response/Health and Safety On Scene Security and Protection I Glenda Bryson OOS:

May 9 & 16, 2019 Lorenzo Lewis David Ortman Environmental Response/Health and Safety On Scene Security and Protection I Mark Dalton ICF I

64 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant John Wills ICF I Madison County I EOC Michael Dolder*

Rosemary Samsel Operational Coordination Operational Communications Public Information & Warning I OOS:

May 13, Glenda Bryson Environmental Response/Health and Safety Environmental Response/Health and Safety On Scene Security and Protection I 2019

• Jurisdiction Lead Mass Care I

I I

I I

I I

I I

I 65 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant*

I I

I I

I I

I I

This page is intentionally blank I

I I

I I I I

I I

I 66 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Appendix C: Alabama Exercise Extent of Play Agreement I BASE EXTENT OF.PLAY AGREEMENT I 2019 Browns Ferry Nuclear Plant Alabama State Emergency Operations Center I FULL PARTICIPATION RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE I All activities wiU be demonstrated fully in accordance with respective plans and procedures as they would be in an actual emergency (FEMA must receive these plans, guides and procedures I NLT 60 days before the exercise). This Extent of Play agreement is written by exception. If it is not listed as an exception it will be demonstrated as described in the plans, standard operating guides (SOGs) and/or procedures (SOPs). Any issue or .discrepancy arising during exercise play I may be redemonstrated if allowed by the RAC Chair or as listed herein. This allowance may be granted if it is not disruptive to exercise play and is mutually agreed to by the ORO controller .

and FEMA evaluator.

I Co~e Capability: Operational Coordination I Definition: Establish and maintain a unified and coordinated operational structure and process that appropriately integrates all critical stakeholders and supports the execution of core capabilities.

I Critical Task: OROs use effective procedures to *alert, notify, and mobilize emergency personnel I and activate facilities in a timely manner (NUREG-0654 A.l.a,,e; A.3, 4; C.1,4, 6; D.4; E.1, 2; G.3.a-i H.3, 4; Criterion lal). Pg. 180.

1* Performance Measure: (1) OROs must demonstrate the capability to receive notification of an incident from the licensee; (2) verify the notification, (3) contact, .alert, and mobilize key emergency personnel in a timely manner, (4) Responders must demonstrate the ability to I 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. (5)

Demonstrate the ability to maintain and staff 24-hour operations. (6) OROs must I demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival, (7) The location and contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP. (8) The I ability to identify and request additional resources or identify compensatory measures must be demonstrated.

I I

67 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

SEOC: On May 1st and June 26, 2019, AEMA Staff and SEOC Support Staff will be pre- positioned at the SEOC, (located at 5898 County Road 41, Clanton, AL) the SRMAC, and JIC. Additional State BOC staff and Emergency Management I

Coordinators will be alerted, notified, and mobilized according to the Browns Ferry Nuclear Plant Notification List and SOG. AEMA will simulate alerting, notifying, and mobilizing personnel. Pre-positioning is necessary due to the compression of the I

scenario and distances involved in traveling to various locations.

AEMA will demonstrate the ability to receive notification from the licensee and verify I

the notification. The facilities will demonstrate activation in a timely manner after receiving notification. A message will be entered into an emergency management software system deploying personnel and task action updates will be made when the I

SEOC, JIC and SRMAC are operational.

Critical Task: Key personnel with leadership roles for the ORO provide direction and control to I

that part of the overall response effort for which they are responsible (NUREG-0654 A.1 ,d; A.2.a, b; A.3; C.4, 6; Criterion lcl). Pg. 181 I Performance Measure: (1) 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 I

completion of requirements and requests.) (2) Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources. Any resources I

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

• I SEOC: Direction and Control will be demonstrated in accordance with the Radiological Annex to the State BOP and the Browns Ferry Standard Operating Guide (SOG), scenario I dependent. The SEOC will be activated and all requirements and activities to support the plan will be performed; actions required by the Emergency Management Coordinators (EMCs) will be coordinated through the SEOC Branch Directors, scenario dependent. 'I Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other*

supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, I b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

Performance Measure: ( 1) A particular facility's equipment and supplies must be sufficient I and consistent with that facility's assigned role in the ORO's emergency operations plans: (2)

For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3)At locations where traffic and access control personnel are I

deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be

• available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or I

specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c)

I 68 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant members of the general public, (5) The plans/procedures must include the forms to be used for I documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in I the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct read and permanent-record dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans or I specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits andmaximumexposurelimits contained in the ORO'~ plans/procedures. (9) All monitoring instruments must be inspected, and I operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-I 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. (12) In areas where portal monitors are used, I the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's I recommendations.

SEOC: AEMA will demonstrate use of equipment, maps, displays and other supplies in I the SEOC, SRMAC, and JIC, scenario dependent.

Critical Task: Appropriate traffic and access control is established. Accurate instructions are I provided to traffic and access control personnel (NUREG-0654 A.3; C.1, 4; J.10.g, j; Criterion 3dl) Pg. 191-192.

I Performance Measures: (1) OROs must demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with current conditions and P ADs (e.g.,

evacuating, sheltering, and relocation) in a timely manner. (2) OR Os must demonstrate the I 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 I area(s) where access is controlled. (2) 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. (3) In instances where OR Os lack I 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.

I SEOC: AEMA will contact applicable highway, rail, water, and air traffic authorities, scenario dependent, at the SEOC. This will be demonstrated during the practice exercise I May 1st and the graded exercise June 26th.

I 69 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; Criterion 3d2). Pg. 192.

I Performance Measures: (1) OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. (2) , The impediment must remain in place during the evacuation long enough that re-routing of traffic is required and (3) must also I

result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

I SEOC: AEMA will discuss coordination of state resources as requested by the counties at the SEOC, scenario dependent during the practice exercise May 1st and graded I exercise June 26th.

Core Capability: Situational Assessment I Definition: Provide all decision makers with decision-relevant information regarding the nature and extent of the hazard, any cascading effects, and the status of the response. I Critical Task: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make P ADs for the general public (including the I 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; Criterion 2.b.2). Pg. 185.

I Performance Measures: (1) OROs must have the capability to make both initial and subsequent precautionary and/or protective action decisions in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or actual I

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. (2) In addition, a subsequent or alternate precautionary and/or protective action decision may be appropriate if I

various conditions (e.g., an HAB incident, weather, release timing and magnitude) pose undue risk to an evacuation or if evacuation may disrupt the efforts to respond to a hostile action. (3) OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to I

implement a precautionary and/or protective action decision if local law enforcement, fire service, HAZMAT, and emergency medical resources are used to augment response to the NPP site or other key infrastructure. (4) If the ORO has determined that KI will be used as a protective I

measure for the general public under offsite plans/procedures, then it must demonstrate the capability to make decisions on the distribution and administration of KI to supplement sheltering and evacuation. This decision must be based on the ORO's plans/procedures or projected thyroid I

dose compared with the established PAG for KI administration. The KI decision-making process must involve close coordination with appropriate assessment and decision-making staff. (5) If more than one ORO is involved in decision making, all appropriate OROs must communicate I

and coordinate precautionary and/or protective action decisions with each other. (6) In addition, decisions must be coordinated/communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

I I

70 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I SEOC: The Alabama Department of Public Health, Office of Radiation Control (ORC) is responsible for issuing Protective Action Decisions (PAD). Prior to issuing a PAD the SEOC will conduct a State Coordinating Group (SCG) call to discuss the PAR received I from the utility. Members of the SCG will ensure that all the offsite response organizations (ORO's) can implement the PAD in order to achieve the desired outcome.

The SEOC will ensure the call is conducted in a timely manner and in accordance with I set standards in the Radiological Annex to the State BOP and the Browns Ferry SOG, scenario dependent.

I Core Capability: Operational Communications Definition: Establish and maintain a unified and coordinated operational structure and process I that appropriately integrates all critical stakeholders and supports the execution of core capabilities.

I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations.

I Communications capabilities are managed in support of emergency operations (NUREG-0654 F.1, 2; Criterion ldl). Pg. 180.

I Performance Measure: OROs must demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial I telephone system. (3) Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for I fixed and mobile medical support facilities exists.

SEOC: Communications systems will be demonstrated, scenario dependent during the I practice exercise May 1st and the graded June 26th_ The ECNS Emergency Communications Notification System is the primary means of communication.

I Telephones, E-mails, WebEOC, and fax will serve as secondary communications.

Southern Linc radios may also be used.

I Core Capability: Public Information and Warning Definition: Deliver coordinated, prompt, reliable, and actionable information to the whole I community through the use of clear, consistent, accessible, and culturally and linguistically appropriate methods to effectively relay information regarding any threat or hazard and, as appropriate, the actions being taken and the assistance being made available.

I I

71 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 Al.a, e; A.3, 4; C.l, 4, 6; D.4; E.l, 2; G.3.a; H.3, 4; Criterion lal). Pg. 180 I Performance Measure: (1) OROs must demonstrate the capability to receive notification of an incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key I emergency personnel in a timely manner, (4) 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. (5) I Demonstrate the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and contact information for facilities included in the incident I

command must be available to all appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must be demonstrated.

I SEOC: On May 1st and June 26th, 2019, AEMA Staff and SEOC Support Staff will be pre- positioned at the SEOC, (located at 5898 County Road 41, Clanton, AL) the I

SRMAC, and JIC. Additional State EOC staff, Emergency Management Coordinators, and will be alerted, notified and mobilized according to the Browns Ferry Nuclear Plant Notification List, and SOG. AEMA will simulate alerting, notifying, and mobilizing I

personnel. Pre-positioning is necessary due to the compression of the scenario and the distances involved in traveling to the various locations. I AEMA will demonstrate the ability to receive notification from the licensee and verify the notification. The facilities will demonstrate activation in a timely manner after receiving notification. A message will be entered into WebEOC deploying personnel and I

task action updates will be made when the SEOC, JIC and SRMAC are operational.

Critical Task: At least 2 communications systems are available, at least 1 operates properly, and I

communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 F.1, 2; Criterion ldl). Pg. 180.

I Performance Measure: OROs must demonstrate that a primary system and at least one I backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to I manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists. I SEOC: Communications systems will be demonstrated, scenario dependent. The PIO phone at the JIC will be the primary means of communications with the JIC. Southern I

Linc, mobile phone, email, and fax will serve as secondary communications.

I 72 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182 I Performance Measure: (1) 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. (2) For I non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. ( 3) At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be I available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) members of the general public, ( 5 ) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and I storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct read and permanent-record I dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum I exposure limits contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance withthemanufacturer'srecommendations. (10) A label indicating such calibration I must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter I should indicate when it is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for I a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I SEOC: Appropriate information and supplies for public information for use by the PIO at the JIC, will be available. This will be accomplished during the practice exercise May I 1st and the graded exercise June 26th scenario dependent.

Critical Task: Ensure OROs provide accurate emergency information and instructions to the I public and the news media in a timely manner (The responsible ORO personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay) (NUREG-0654 E.5, 7; 0.3.a; 0.4.a, c; Criterion 5bl). Pg.

I 200-201 I

73 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Performance Measure: (1) 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). I For exercise purposes, timely is defined as "with a sense of urgency and without undue delay."

Messageelements: (2) TheOROmustensurethatemergency information and instructions are consistent with PADs made by appropriate officials. (3) The emergency information must I contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, shelter-in-place instructions, information concerning protective actions for schools and persons with disabilities and I

access/functional needs, and public inquiry hotline telephone number) to assist the public in carrying out the PADs provided (4) 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 I

media releases. (5) 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. (6)

This includes demonstration of the capability to use familiar landmarks and boundaries to I

describe protective action areas. (7) 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. (8) Information about I

any rerouting of evacuation routes due to impediments should also be included. (9) The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. (10) OROs must demonstrate the capability to I

ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures. (11) OROs must demonstrate the capability to develop emergency information in a non-English language when required by the plans/procedures. (12) If ingestion I

exposure pathway measures are required, OROs must demonstrate that a system exists for rapid dissemination of ingestion exposure pathway information to predetermined individuals and businesses. Media information: (13) OROs must demonstrate the capability to provide timely, I

accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. (14) This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the incident warrants. (15) The OROs I

must demonstrate the capability to respond appropriately to inquiries from the news media. (16)

All information presented in media briefings and releases must be consistent with P ADs and other emergency information provided to the public. (17) Copies of pertinent emergency I

information (e.g., BAS messages and media releases) and media information kits must be available for dissemination to the media. Public Inquiry (18) OROs must demonstrate that an effective system is in place for dealing with calls received via the public inquiry hotline. ( 19) Hotline staff I

must demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate information source. (20) Information from the hotline staff, including I 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. RAB considerations: (21) The dissemination of information dealing with I specific aspects of NPP security capabilities, actual or perceived adversarial (terrorist) force or threat, and tactical law enforcement response must be coordinated/ communicated with appropriate security authorities (e.g., law enforcement and NPP security agencies) in accordance I with ORO Pans/procedures.

I 74 I

I Radiological Emergency Preparedness Program

• I After Action Report 2019 Browns Ferry Nuclear Power Plant I SEOC: Actual message distribution to the public and media will be simulated. This will be demonstrated during the practice exercise May 1st and graded exercise June 26th, scenario dependent.

I I

I I

I I

I I

I I

I I

I I

I 75 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

I I

I I

I I

I This page is intentionally blank I

I I

I I

I I

I I

76 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant BASE I EXTENT OF PLAY AGREEMENT 2019 Browns Ferry Nuclear Plant I SRMAC and Field Teams FULL PARTICIPATION RADIOLOGICAL EMERGENCY PREPAREDNESS I EXERCISE All activities will be demonstrated fully in accordance with respective plans and procedures as I they would be in an actual emergency (FEMA must receive these plans, guides and procedures NLT 60 days before the exercise). This Extent of Play agreement is written by exception. If it is not listed as an exception it will be demonstrated as described in the plans, standard operating I guides (SOGs) and/or procedures (SOPs). Any issue or discrepancy arising during exercise play may be redemonstrated if allowed by the RAC Chair or as listed herein. This allowance may be granted if it is not disruptive to exercise play and is mutually agreed to by the ORO controller I and FEMA evaluator.

Core Capability: Situational Assessment I Definition: Provide all decision makers with decision-relevant information regarding the nature and extent of the hazard, any cascading effects, and the status of the response.

I Critical Task: Appropriate protective action recommendations (P ARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, I as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA-REP-1, I.10 and Supplement 3; Criterion 2.b.l) Pg. 184-185 I Performance Measures: (1) The ORO must demonstrate the capability to use the appropriate means described in the plans/procedures to develop PARs for decision-makers based on available information and recommendations provided by the licensee, as well as field monitoring I data if available. Workers must also consider any release and meteorological data provided by the licensee. (2) The ORO must demonstrate a reliable capability to independently validate dose I 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 I quantities and units of the PAG to which they will be compared. (3) P ARs must be promptly transmitted to decision-makers in a prearranged format. (4) When the licensee and ORO projected doses differ by more than a factor of 10, the ORO and licensee must determine the I 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 if timely and appropriate. (5) The ORO must demonstrate the capability to use any additional I data to refine projected doses and exposure rates and revise the associated PARs.

I 77 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Players: SRMAC Montgomery (M) & Decatur (D) SRMAC M: agreed.

SRMAC D: agreed.

I The Office of Radiation Control (ORC) will make appropriate protective action recommendations (PAR) based on a dose assessment tool, field data, plant status and exercise play. The PARs will be communicated by ORC to the State Health Officer I

and/or his designee who is responsible for making a protective action decision (PAD).

Prior to the PAD being implemented, a coordination of the decision will take place through the state coordinating group call with Alabama Emergency Management Agency I

(AEMA) and other state emergency support functions. ORC will then convey the PAD via the emergency communication notification network system (ECNS) to the affected counties. ORC will further demonstrate the decision- making process of PADs for the I

general public by aforementioned process. ORC will use MIDAS as the primary dose assessment code and RASCAL as the secondary dose code. ORC will use a number of publications and resources when making PADs. This will include but not be limited to:

I Data and Information from Browns Ferry Power Plant (BFNP), EPA-400 (92), FDA (82),

State of Alabama Radiological Field Monitoring Team Manual, and State of Alabama Radiological Response Plan - Incident Annex E. There will not be an actual distribution I

of KI (simulation only); this can be discussed through staff interview.

Critical Task: A decision-making process involving consideration of appropriate factors and I

necessary coordination is used to make P ADs 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; Criterion 2.b.2). Pg. 185, I

Performance Measures: (1) OROs must have the capability to make both initial and subsequent precautionary and/or protective action decisions in a timely manner appropriate to the incident, I

based on information from the licensee, assessment of plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO authorities (e.g., incident command), and PARs from the utility and ORO staff. (2) In addition, a I

subsequent or alternate precautionary and/or protective action decision may be appropriate if various conditions (e.g., an RAB incident, weather, release timing and magnitude) pose undue risk to an evacuation or if evacuation may disrupt the efforts to respond to a hostile action. (3)

I OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a precautionary and/or protective action decision if local law enforcement, fire service, HAZMAT, and emergency medical resources are used to augment response to the NPP I

site or other key infr~structure. (4) If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must I demonstrate the capability to make decisions on the distribution and administration of KI to supplement sheltering and evacuation. This decision must be based on the ORO's plans/procedures or projected thyroid dose compared with the established PAG for KI I administration. The KI decision-making process must involve close coordination with appropriate assessment and decision-making staff. (5) If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate precautionary and/or I protective action decisions with each other. (6) In addition, decisions must be I

78 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant coordinated/communicated with incident command. OROs must demonstrate the capability to I communicate the results of decisions to all the affected locations.

Players: SRMAC Montgomery (M) & Decatur (D) SRMAC M: agreed.

I SRMAC D: agreed.

The Office of Radiation Control (ORC) will make appropriate protective action I recommendations (PAR) based on a dose assessment tool, field data, plant status and exercise play. The PARs will be communicated by ORC to the State Health Officer and/or his designee who is responsible for making a protective action decision (PAD).

I Prior to the PAD being implemented, a coordination of the decision will take place through the state coordinating group call with Alabama Emergency Management Agency (AEMA) and other state emergency support functions. ORC will then convey the PAD I via the emergency communication notification network system (ECNS) to the affected counties. ORC will further demonstrate the decision- making process of PADs for the general public by aforementioned process. ORC will use MIDAS as the primary dose I assessment code and RASCAL as the secondary dose code. ORC will use a number of publications and resources when making P ADs. This will include but not be limited to:

Data and Information from Browns Ferry Power Plant (BFNP), EPA-400 (92), FDA (82),

I State of Alabama Radiological Field Monitoring Team Manual, and State of Alabama Radiological Response Plan - Incident Annex E. There will not be an actual distribution of KI (simulation only); this can be discussed through staff interview.

I Core Capability: Operational Communications I Definition: Establish and maintain a unified and coordinated operational structure and process that appropriately integrates all critical stakeholders and supports the execution of core capabilities.

I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations.

I Communications capabilities are managed in support of emergency operations (NUREG-0654 II i

F.1, 2; Criterion ldl). Pg. 180.

Performance Measure: OROs must demonstrate that a primary system and at least one I backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) ResponsibleOROs must demonstrate the capability to I manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

I I

79 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Players: SRMAC M & D SRMAC M: agreed. SRMAC D: agreed.

ORC will demonstrate the use of a primary communication system through iPhone with LTE network and a backup system (landline telephone through voice over internet I protocol (VOIP) at the appropriate locations (Montgomery SRMAC and Decatur SRMAC). Additional systems may be discussed through staff interview and will be scenario dependent.

I Core Capability: Public Information and Warning I

Definition: Deliver coordinated, prompt, reliable, and actionable information to the whole community through the use of clear, consistent, accessible, and culturally and linguistically appropriate methods to effectively relay information regarding any threat or hazard and, as I

appropriate, the actions being taken and the assistance being made available.

Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel I

and activate facilities in a timely manner (NUREG-0654 Al.a, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; G.3.a; H.3, 4; Criterion lal). Pg. 180. I Performance Measure: (1) OROs must demonstrate the capability to receive notification of an incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key emergency person11el in a timely manner, (4) Responders must demonstrate the ability to I

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. (5)

Demonstrate the ability to maintain and staff 24-hour operations. (6) OROs must I

demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP. (8) The I

ability to identify and request additional resources or identify compensatory measures must be demonstrated. I Players: SRMAC M & D SRMAC M: agreed. SRMAC D: agreed.

The Alabama Office of Radiation Control (ORC): The Office of Radiation Control will simulate alerting, notifying and mobilizing emergency personnel. Personnel will be I

prepositioned at the Montgomery State Radiological Monitoring and Assessment Center (SRMAC) room 1266 in the RSA Tower, 201 Monroe Street, Suite 1250Montgomery, Alabama 36104, as well as at the Decatur SRMAC which is located in the basement of I

Morgan County Court House, 302 Lee Street N.E. Street, Decatur, Alabama 35601.

Personnel will also be prepositioned at the Browns Ferry Nuclear Plant Joint Information Center (JIC), located at 2055 Market Street, N.E., Decatur, Alabama 35601. The three I

(only two evaluated) field monitoring teams (FMT) (0700 CST) will be pre-positioned at the Morgan County Health Department north parking lot (for evaluation, practice, and training purposes), located at 3821 Highway 31 South, Decatur, Alabama 35603.

I I

80 I

I Radiological Emergency Preparedness Program After Action Report 2019 Browns Ferry Nuclear Power Plant I Notification by ORC to other states and federal agencies will be carried out according to I standard operating guidelines (SOG).

Discussion of agency capabilities and procedures to alert, notify, and mobilize staff may I be discussed with personnel through interview.

Radiation Control will demonstrate the ability to receive notification from the licensee I and verify the notification. The ORC facilities will demonstrate activation in a timely manner and will be scenario dependent. '

I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations.

I Communications capabilities are managed in support .of emergency operations (NUREG-0654 F.1, 2; Criterion ldl). Pg. 180.

I

• Performance Measure: OROs must demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the I commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated I communication link for fixed and mobile medical support facilities exists.

Players: SRMAC M & D SRMAC M: agreed.

I SRMAC D: agreed.

ORC will demonstrate the use of a primary communication system through iPhone with I LTE network and a backup system (landline telephone through voice over internet protocol (VOIP) at the appropriate locations (Montgomery SRMAC and Decatur SRMAC). Additional systems may be discussed through staff interview and will be I scenario dependent.

Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other I supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

I Performance Measure: (1) 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. (2) For I non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. ( 3) At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) Responsible OROs must demonstrate the capability to maintain inventories of I KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c)

I 81 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant members of the general public, ( 5 ) The plans/procedures must include the forms to be I

used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, I

provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans I

or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and I

operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-I affixed to their sides fodicating 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. (12) In areas where portal monitors are, used, I

the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to**

the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for I Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations .

I

. Players: SRMAC M & D SRMAC M: agreed. SRMAC D: agreed ..

ORC will have available equipment, maps, dosimetry, dose assessment software tools, I

potassium iodide (KI), and displays that would be necessary to support emergency operations at the two SRMAC locations. Records for monitoring instrument calibration will be provided to the evaluation team. Dosimetry and KI will be available for field I

teams only and as needed. No dosimetry injects will be annotated on the "Radiation Exposure Record." KI administration (if needed) will be simulated during the exercise.

Requests' for additional information may be discussed through staff interview and will be I

scenario dependent.

• Critical Task: Ensure OROs provide accurate emergency information and instructions to the I

public and the news media in a timely manner (The responsible ORO personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay) (NUREG-0654 E.5, 7; G.3.a; G.4.a, c; Criterion 5bl). Pg.

I 200-201.

Performance Measure: (1) The responsible ORO personnel/representatives must demonstrate I

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."

I Message elements: (2) The ORO must ensure that emergency information and instructions are consistent with PADs made by appropriate officials. (3) The emergency information must contain all necessary and app!icable instructions (e.g., evacuation instructions, evacuation routes, I

82 I

I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant reception center locations, what to take when evacuating, shelter-in-place instructions, I information concerning protective actions for schools and persons with disabilities and access/functional needs, and public inquiry hotline telephone number) to assist the public in carrying out the PADs provided (4) The ORO must also be prepared to disclose and explain the I ECL of the incident. At a minimum, this information must be included in media briefings and/or media releases. (5) 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. (6)

I This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas. (7) The emergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5.a.1 and previously I identified protective action areas that are still valid, as well as new areas. (8) Information about any rerouting of evacuation routes due to impediments should also be included. (9) The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is I rescinded and not repeated by broadcast media. (10) OROs must demonstrate.the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures. (11) OROs must demonstrate the capability to develop emergency I

• information in a non-English language whenrequired by the plans/procedures. (12) lf ingestion exposure pathway measures are required, OROs must demonstrate that a system exists for rapid dissemination of ingestion exposure pathway information to predetermined individuals and I businesses. Media information: (13) OROs must demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. (14) This would include demonstration of the capability to conduct timely and I pertinent media briefings and distribute media releases as the incident warrants. (15) The OROs must demonstrate the capability to respond appropriately to inquiries from the news media. (16)

All information presented in media briefings and releases must be consistent with P ADs and I other emergency information provided to the public. (17)Copies of pertinent emergency information (e.g., BAS messages and media releases) and media information kits must be available for dissemination to the media. Public Inquiry (18) OROs inust demonstrate that an I effective system is in place for dealing with calls received via the public inquiry hotline. (19)

Hotline staff must demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate information source. (20) Information froni the hotline I 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: (21) The dissemination of information I dealing with specific aspects of NPP security capabilities, actual or perceived adversarial (terrorist) force or threat, and tactical law enforcement response must be coordinated/

communicated with appropriate security authorities (e.g., law enforcement and NPP security I agencies) in accordance with ORO Pans/procedures.

I Players: SRMAC M & D SRMAC M: agreed. SRMAC D: agreed.

I I

83 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Core Capability: Environmental Response/Health and Safety Definition: Conduct appropriate measures to ensure the protection of the health and safety of I the public and workers, as well as the environment, from all-hazards in support of responder operations and the affected communities I

Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 A.La, e; A.3, 4; C.l, 4, 6; D.4; E.1, 2; G.a.3; H.3, 4; Criterion lal). Pg. 180: I Performance Measure: (1) OROs must demonstrate the capability to receive notification of an incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key I

emergency personnel in a timely manner, (4) 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. (5) Demonstrate I

the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and contact information for facilities included in the incident command must be available to all I

appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures mustbe demonstrated. I Players: Field Teams SRMAC M: agreed. SRMAC D: agreed.

The SRMACs located in Montgomery and Decatur will have personnel prepositioned I

prior to the exercise. The radiological field monitoring teams will also be prepositioned at the Morgan County Health Department. The procedures for alert, notification, and mobilization will be demonstrated by one or both SRMACs. Requests for additional I

information may be discussed through staff interview and will be scenario dependent.

Critical Task: Key personnel with leadership roles for the ORO provide direction and control to I

that part of the overall response effort for which they are responsible (NUREG-0654 A. l .d; A.2.a, b; A.3; C.4, 6; Criterion lcl). Pg. 181. I I

I I

I I

84 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measure: (1) Leadership personnel must demonstrate the ability to carry out the I 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.) (2) Leadership must demonstrate the ability to prioritize resource I tasking and replace/supplement resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources. Any resources identified through LOA/MOUs must be on the ORO's mobilization list so they may be contacted during an incident if needed.

I Players: SRMAC M & D SRMAC M: agreed. SRMAC D: agreed.

I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations.

I Communications capabilities are managed in support of emergency operations (NUREG-0654 F.1, 2; Criterion ldl). Pg. 181.

I Performance Measure: OROs must demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial I telephone system. (3) Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for I fixed and mobile medical support facilities exists.

Players: SRMAC M & D SRMAC M: agreed. SRMAC D: agreed.

I SRMACs will use the iPhone to initially contact the FMT members; but will use a Critical Linc LTE network which is independent of the commercial telephone system.

I The secondary system for communication will be through the use of a cellular phone.

Requests for additional information may be discussed through staff interview and will be scenario dependent.

I Three field monitoring teams will be dispatched with only two field teams being evaluated for two communication systems. The FMTs will be composed of one state I team and two teams composed of one local and one state person, all from the Alabama Department of Public Health. Field monitoring teams will be prepositioned (0700 CST)

I at the Morgan County Health Department north parking lot (for evaluation, practice, and training purposes), located at 3821 Highway 31 South, Decatur, Alabama 35603.

I I

I 85 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182. I Performance Measure: (1) 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. (2) I For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3)At locations where traffic and access control personnel are .

deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be I

available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c)

I members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage I

locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient I

quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained I

in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. (10) A label indicating such calibration must be on each I

instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it I

is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for I

Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations. I SRMAC M (if applicable): agreed. SRMAC D: agreed.

Field Teams: agreed Equipment will be evaluated by interview and observation during the exercise. Requests I

for additional information may be discussed through staff interview and will be scenario dependent I Critical Task: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in I place for EWs including provisions to authorize radiation exposure in excess of administrative limits or PAGs (NUREG-0654 C.6.f; K.4 Criterion 2al). Pg. 185.

I I

86 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measure: (1) OROs authorized to send emergency workers into the plume I exposure pathway EPZ must demonstrate a capability to comply with emergency worker exposure limits based on their emergency plans/procedures. (2) OROs must also demonstrate the capability to make decisions concerning authorization of exposure levels in excess of pre-I authorized levels and the number of emergency workers receiving radiation doses*above pre-authorized levels. (3) This would include providing KI and dosimetry in a timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating I actions, in accordance with respective plans/procedures.

Players: SRMAC M & D SRMAC M: agreed.

I SRMAC D: agreed.

The ORC will demonstrate emergency worker exposure control decision making for the I Field Monitoring Teams and for emergency workers. KI administration (if needed) will be simulated during the exercise. Requests for additional information may be discussed through staff interview and will be scenario dependent

• I Critical Task: Appropriate protective action recommendations (PARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections; I as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA-REP-1, I.10 and Supplement 3; Criterion 2.b.l) Pg. 184-185. .

• I Performance Measures: (1) The ORO must demonstrate the capability to use the appropriate*

means described in the plans/procedures to develop PARs for decision-makers based on available information and recommendations provided by the licensee, as well as field monitoring data if I available. Workers must also consider any release and meteorological data provided by the licensee. (2) 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 I 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 PAG to which they will be compared. (3) PARs must be promptly I transmitted to decision-makers in a prearranged format. (4) When the licensee and ORO

• projected doses differ by more than a factor of 10, the ORO and licensee must determine the I 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 if timely and appropriate. (5) The ORO must demonstrate the capability to use any additional I data to refine projected doses and exposure rates and revise the associated P ARs.

I I

I 87 I

Radiological Emergency Preparedness Program I After Action Report Players: SRMAC M &D SRMAC M: agreed.

2019 Browns Ferry Nuclear Power Plant I

SRMAC D: agreed.

I Critical Task: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make P ADs 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; I D.4; J.9; J.10.e.f, m; Criterion 2.b.2). Pg. 185.

Performance Measures: (1) OROs must have the capability to make both initial and I subsequent precautionary and/or protective action decisions in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO I

authorities (e.g., incident command), and PARs from the utility and ORO staff. (2) In addition, a subsequent or alternate precautionary and/or protective action decision may be appropriate if various conditions (e.g., an RAB incident, weather, release timing and magnitude) pose undue I

risk to an evacuation or if evacuation may disrupt the efforts to respond to a hostile action. (3)

OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a precautionary and/or protective action decision if local law enforcement, fire I

service, HAZMAT, and emergency medical resources are used to augment response to the NPP site or other key infrastructure. (4) If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must I

demonstrate the capability to make decisions on the distribution and administration of KI to supplement sheltering and evacuation. This decision must be based on the ORO's plans/procedures or projected thyroid dose compared with the established P AG for KI I

administration. The KI decision-making process must involve close coordination with appropriate assessment and decision-making staff. (5) If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate precautionary and/or I

protective action decisions with each other. (6) In addition, decisions must be coordinated/

communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations. .

I Players: SRMAC M & D SRMAC M: agreed.

SRMAC D: agreed.

I The Office of Radiation Control (ORC) will make appropriate protective action ,

recommendations (PAR) based on a dose assessment tool, field data, plant status and I

exercise play. The PARs will be communicated by ORC to the State Health Officer and/or his designee who is responsible for making a protective action decision (PAD).

Prior to the PAD being implemented, a coordination of the decision will take place I

through the state coordinating group call with Alabama Emergency Management Agency (AEMA) and other state emergency support functions. ORC will then convey the PAD via the emergency communication notification network system (ECNS) to the affected I

counties. ORC will further demonstrate the decision- making process of P ADs for the general public by aforementioned process. ORC will use MIDAS as the primary dose assessment code and RASCAL as the secondary dose code. ORC will use a number of I

I 88 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant publications and resources when making PADs. This will include but not be limited to:

I Data and Information from Browns Ferry Power Plant (BFNP), EPA-400 (92), FDA (82),

State of Alabama Radiological Field Monitoring Team Manual, and State of Alabama Radiological Response Plan - Incident Annex E. There will not be an actual distribution I of KI (simulation only); this can be discussed through staff interview.

Critical Task: OROs issue appropriate dosimetry, KI, and procedures, and manage radiological I exposure to EWs in accordance with the plans/procedures. EWs periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to EWs (NUREG-I 0654 K.3.a, b, K.4; Criterion 3al). Pg. 189.

Performance Measures: (1) OROs must demonstrate the capability to provide emergency I 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 I individual(s) to read the administrative reporting limits that are pre-estabfo;hed at a level low enough to consider subsequent calculation of TEDE and maximum exposure limits, for those emergency workers involved in lifesaving a~tivities, contained in the ORO's plans/procedures. (2)

I Each emergency worker must have basic knowledge of radiation exposure ,limits as specified in the ORO's plans/ procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation,exposure control. Emergency I workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control. (3) During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back I values are reached. (4) 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. (5) If exercise play'does not require emergency workers to seek I authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge. (6) 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 I to each other during the entire mission and can share a direct-read dosimeter. Each team member must still have and maintain his or her own permanent-record dosimetry. (7) OROs I must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property may require an urgent response. (8) OROs must demonstrate the capability to I accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. (9) Emergency workers must I demonstrate basic knowledge of procedures for using KI. If exercise play does not require emergency workers to consume KI, evaluators must interview at least two workers to determine

• their knowledge.

I I

89 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Players: SRMAC M & D and Field Teams SRMAC M: agreed.

SRMAC D: agreed.

I The field monitoring teams have response kits prepositioned at the county health departments as well as the state office in Montgomery. Requests for additional information may be discussed through staff interview and will be scenario dependent I

Critical Task: Field teams (two or more) are managed to obtain sufficient information to help characterize the release and to control radiation exposure (NUREG C.1; H.12; I. 7, 8, 11; J.1 O.a; I

Criterion 4a2). Pg. 195.

Performance Measure: (1) Responsible OROs must demonstrate the capability to brief FMTs I

on predicted plume location and direction, plume travel speed, and exposure control procedures before deployment. (2) During an HAB incident, the Field Team management must keep the incident command informed of field monitoring teams' activities and location. (3) Teams must I

be directed to take measurements at such locations and times as necessary to provide sufficient information to characterize the plume and its impacts. ff the responsibility for obtaining peak measurements in the plume has been accepted by licensee field monitoring teams, with I

concurrence from OROs, there is no requirement for these measurements to be repeated by ORO monitoring teams. (4) If the licensee FMTs do not obtain peak measurements in the plume, it .is the ORO's decision as to whether peak measurements are necessary to sufficiently characterize I

the plume. (5) The sharing and.coordination of plume measurement information among all FMTs (licensee, Federal, and ORO) is essential. I Players: SRMAC M & D SRMAC M: agreed.

SRMAC D: agreed. I There will be three field teams dispatched (only two evaluated) on the day of the evaluated exercise. The FMTs will be composed of one state team and two teams composed of one and one state person, all from the Alabama Department of Public

• I Health. Field monitoring teams will be prepositioned (0700 CST) at the Morgan County Health Department north parking lot (for evaluation, practice, and training purposes),

located at 3821 Highway 31 South, Decatur, Alabama 35603. Field teams will use I

instrumentation and measurement techniques to obtain sufficient information to help characterize the release and monitor radiation exposure, as stated in the State of Alabama I Radiological Field Monitoring Manual. Field teams will simulate the use of personal protective equipment for contamination control. Field teams will have previously demonstrated using shoe covers and gloves during the air sample demonstration. I Requests for additional information may be discussed through staff interview and will be scenario dependent I

I I

90 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Critical Task: Ambient radiation measurements are made and recorded at appropriate locations, I 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 C.1; I.8, I 9; H.12; J.10.a; Criterion 4a3). Pg. 195.

Performance Measure: ( 1) Two or more FMTs must demonstrate the capability to make and I report measurements of ambient radiation to the field team coordinator, dose assessment team, or other appropriate authority. (2) FMTs must also demonstrate the capability to obtain an air sample for measurement of airborne radioiodine and particulates, and to provide the appropriate I authority with field data pertaining to measurement. (3) If samples have radioactivity significantly above background, the authority must consider the need for expedited laboratory analyses of these samples. (4) Coordination concerning transfer of samples, including a chain-I of-custody form(s), to a radiological laboratory(ies) must be demonstrated. (5) 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)

I for transfer to a laboratory(ies), will be in accordance with the ORO's plans/procedures.

Players: Field Teams: agreed three field teams (only two evaluated) will be dispatched I into the field on the day of the evaluated exercise, Wednesday, June 26, 2019. The FMTs will be composed of one state team and two teams composed of one local and one state person, all from the Alabama Department of Public Health. Field monitoring teams will I be prepositioned (0700 CST) at the Morgan County Health Department north parking lot (for evaluation, practice, and training purposes), located at 3821 Highway 31 South, Decatur, Alabama 35603. Field teams will demonstrate, in the aforementioned parking I lot, taking an air sample prior to being deployed to the field. Field teams will use gloves and shoe covers for contamination control and will simulate using them thereafter.

Radioiodine sample procedures are to be found in the State of Alabama Radiological I Field Monitoring Manual. Techniques outlined in the aforementioned manual will be used to obtain sufficient data pertaining to the measurement of ambient radiation, airborne radioiodine and particulates. Due to the compression of the scenario, I radioiodine sampling will be simulated in the field during the exercise. Field teams will be instructed to complete their air sample calculation sheet in the field during the exercise and will be scenario dependent. Requests for additional information may be discussed I through staff interview and will be scenario dependent.

I I

I I

91 I

Radiological Emergency Preparedness Program

• I After Action Report 2019 Browns Ferry Nuclear Power Plant I

I I

I I

I I

I This page is intentionally blank I

I I

I I

I I

I I

92 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant BASE I EXTENT OF PLAY AGREEMENT 2019 Browns Ferry Nuclear Plant I Joint Information Center FULL PARTICIPATION RADIOLOGICAL EMERGENCY PREPAREDNESS I EXERCISE

• All activities will be demonstrated fully in accordance with respective plans and procedures as I they would be in an actual emergency (FEMA must receive these plans, guides and procedures NLT 60 days before the exercise). This Extent of Play agreement is written by exception. If it is not listed as an exception it will be demonstrated as described in the plans, standard operating I guides (SOGs) and/or procedures (SOPs). Any issue or discrepancy arising during exercise play

• may be redemonstrated if allowed by the RAC Chair or as listed herein. This allowance may be granted if it is not disruptive to exercise play and is mutually agreed to by the ORO controller I and FEMA evaluator.

Core Capability: Public Information and Warning I Definition: Deliver coordinated, prompt, reliable, and actionable information to the whole community through th~ use of clear, consistent, accessible, and culturally and ,linguistically I appropriate methods to effectively relay information regarding any threat or hazard and, as appropriate, the actions being taken and the assistance being made available.

I Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 A.l.a, e; A.3, 4; C.l, 4, 6; D.4; E.1, 2; G.3.a; H.3, 4; Criterion lal). Pg. 180 I Performance Measure: (1) OROs must demonstrate the capability to receive notification of an incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key I emergency personnel in a timely manner, (4) 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. (5)

I Demonstrate the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their I arrival. (7) The location and contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must I be demonstrated.

JIC: Alabama Emergency management Agency (AEMA) will simulate alerting, I notifying and mobilizing personnel. Personnel will be pre-positioned at the State Emergency Operating Center (SEOC), SRMAC (if operational), and the Joint Information Center (JIC). AEMA will demonstrate the ability to receive notification I

93 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

from the licensee (IAW the REP Plan) and verify the notification. A message will be entered into WebEOC deploying personnel and task action updates will be made when the JIC and SRMAC are operational. Pre-positioning is necessary due to the compression I of the scenario and the distances involved in traveling to the various locations.

Critical Task: At least 2 communications systems are available, at least 1 operates properly, and I

communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 I

F.1, 2; Criterion ldl). Pg. 180.

Performance Measure: OROs must demonstrate that a primary system and at least one backup I

system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the I

communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

I JIC: Communication systems will be demonstrated based on the scenario. The TVA Hotline is the primary means of communication. Telephones, E-mails, WebEOC, and

• I faxes will serve as secondary communications. Southern LINC radios may also be used.

Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other I

supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182. 1 I

Performance Measure: (1) 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. (2) For non-facility-based operations, the equipment and supplies must be sufficient and consistent with I

the assigned operational role. (3)At locations where traffic and access control personnel are*

deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs):must be available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI I

sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) I members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of Kl. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and.storage I locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient I quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative.reporting limits and maximum exposure limits contained I in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and I

94 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant operationally checked before each use. Instruments must be calibrated in accordance with the I manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings I documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to I the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I JIC: AEMA will have available equipment, maps, and displays that would be necessary to support emergency operations at the SEOC, and JIC, scenario dependent. Dosimetry I and KI are not applicable.

Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; I Criterion 3d2). Pg. 192.

Performance Measures: (1) OROs must demonstrate the capability to identify and take I appropriate actions concerning impediments to evacuations. (2) The impediment must remain in place during the evacuation long enough that re-routing of traffic is required and (3) must also result in demonstration of decision-making and coordination with the JIC to communicate the I alternate route to evacuees.

JIC: AEMA will demonstrate coordination of state resources assistance as needed by the I County at the SEOC, based on the scenario.

Critical Task: Ensure OROs provide accurate emergency information and instructions to the I public and the news media in a timely manner (The responsible ORO personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of I urgency and without undue delay) (NUREG-0654 E.5, 7; G.3.a; G.4.a, c; Criterion 5bl). Pg.

200-201.

I Performance Measure: (1) 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 subjec_t to specific time requirements).

I For exercise purposes, timely is defined as "with a sense of urgency and without undue delay."

Message elements: (2) The ORO must ensure that emergency information and instructions are consistent with PADs made by appropriate officials. (3) The emergency information must I contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, shelter-in-place instructions, information concerning protective actions for schools and persons with disabilities and I access/functional needs, and public inquiry hotline telephone number) to assist the public in carrying out the PADs provided (4) 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 I

95 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

media releases. (5) 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. (6)

This includes demonstration of the capability to use familiar landmarks and boundaries to I describe protective action areas. (7) 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. (8) Information about I any rerouting of evacuation routes due to impediments should also be included. (9) The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. (10) OROs must demonstrate the capability to I

ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures. (11) OROs must demonstrate the capability to develop emergency information in a non-English language when required by the plans/procedures. (12) If ingestion I

exposure pathway measures are required, OROs must demonstrate that a system exists for rapid dissemination of ingestion exposure pathway information to predetermined individuals and businesses. Media information: (13) OROs must demonstrate the capability to provide timely, I

accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. ( 14) This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the incident warrants. (15) The OROs I

must demonstrate the capability to respond appropriately to inquiries from the news media. (16)

All information presented in media briefings and releases must be consistent with PADs and other emergency information provided to the public. ( 17) Copies of pertinent emergency I

information (e.g., BAS messages and media releases) and media information kits must be available for dissemination to the media. Public Inquiry (18) OROs must demonstrate that an effective system is in place for dealing with calls received via the public inquiry hotline. (19)

I Hotline staff must demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate information source. (20) Information from the hotline staff, including information that corrects false or inaccurate information when trends are noted, I

must be included, as appropriate, in emergency information provided to the public, media briefings, and/or medfa releases. HAB considerations: (21) The dissemination of information dealing with specific aspects of NPP security capabilities, actual or perceived adversarial I

(terrorist) force or threat, and tactical law enforcement response must be coordinated/

communicated with appropriate security authorities (e.g., law enforcement and NPP security agencies) in accordance with ORO Pans/procedures.

I JIC: Actual message distribution to the public and media will be simulated. This will be demonstrated during the exercise and will be tailored around the scenario.

I I

I I

I 96 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant BASE I EXTENT OF PLAY AGREEMENT 2019 Browns Ferry Nuclear Plant I Lauderdale County FULL PARTICIPATION RADIOLOGICAL EMERGENCY PREPAREDNESS I EXERCISE All activities will be demonstrated fully in accordance with respective plans and procedures as I they would be in an actual emergency (FEMA must receive these plans, guides and procedures NLT 60 days before the exercise). This Extent of Play agreement is written by exception. If it is not listed as an exception it will be demonstrated as described in the plans, standard operating I guides (SOGs) and/or procedures (SOPs). Any issue or discrepancy arising during exercise play may be redemonstrated if allowed by the RAC Chair or as listed herein. This allowance may be granted if it is not disruptive to exercise play and is mutually agreed to by the ORO controller I and FEMA evaluator.

Core Capability: Operational Coordination I Definition: Establish and maintain a unified and coordinated operational structure and process that appropriately integrates all critical stakeholders and supports the execution of core I capabilities.

Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel I and activate facilities in a timely manner (NUREG-0654 A.La, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; G.3.a-i H.3; 4; Criterion lal). Pg. 180.

11 Performance Measure: (1) OROs must demonstrate the capability,to receive notification of an incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key emergency personnel in a timely manner, (4) Responders must demonstrate the ability to receive I and/or initiate notification to the licensees or other respective emergency management organizations of an incident in a timely manner when they receive information. (5) Demonstrate I the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and contact information for facilities included in the incident command must be available to all I appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must be demonstrated.

I LAUDERDALE COUNTY: Lauderdale County EMA: The Florence/Lauderdale EMA Staff will be pre-positioned at 8:00 a.m. at which normal duty hours begin. The Florence-Lauderdale EMA Emergency Operations Center (BOC) is*located at 110 W.

I College Street Florence, Alabama in the basement of City Hall. The Florence-Lauderdale EMA Staff is comprised of a Director, Deputy Director, Planner, Two Assistants, a Secretary and Records Clerk. A few administrative volunteers may also be pre-I 97 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

positioned with the Florence-Lauderdale County EMA staff. A call list will be utilized to ensure all required personnel are alerted, notified, and mobilized the day of the exercise.

I

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

• Should safety become a concern due to environmental hazards, the OOS River Traffic and Access Control demonstration will be a discussion-based simulation in I

accordance with the Florence-Lauderdale County EMA REP plan.

Critical Task: Key personnel .with leadership roles for the ORO provide direction and control to I

that part of the overall response effort for which they are responsible (NUREG-0654 A. l .d; A.2.a, b; A.3; C.4, 6; Criterion lcl). Pg. 181. I Performance Measure: (1) 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 I

completion of requirements and requests.) (2) Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources. Any resources I

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

• I LAUDERDALE COUNTY: Lauderdale County EMA - The Florence-Lauderdale EMA will demonstrate direction and control from the Lauderdale County BOC during the exercise on June 26, 2019. The Lauderdale County BOC is located at 110 W. College I

Street Rm B-25 City Hall, Florence, AL. Scenario Dependent. *

• Critical Task: Equipment, maps, displays, inonitoring instruments, dosimetry, KI, and other I

supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182. I Performance Measure: (1) 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. (2)

For non-facility-based operations, the equipment and supplies must be sufficient and consistent I

with the assigned operational role. (3)At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be I available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) I members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage I locations(s) will be confirmed by currentinventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient I quantities for use by: (a) emergency workers, ancillary groups as identified in plans or I

98 I

I Radiological Emergency Preparedness Program 2019 Browns Ferry Nuclear Power Plant I After Action Report specialized response teams.* (8) Appropriate direct-reading dosimetry must allow an I individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the I manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. -(11) In addition, instruments being used to measure aGtivity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings I documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to

'I the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used"for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I LAUDERDALE COUNTY: Equipment, maps, displays, and dosimetry will be in place and in use oii June 26, 2019 during the exercise scenario dependent. The EMA Field I Operations Building located at 702 Oak Street in Florence, Alabama houses field equipment including TLDs, dosimetry, and monitoring instruments and these units can be discussed during the_ out of sequence on May 14, 2019 at either the BOC or the Field

• I Operations Building. KI inventory is maintained at the Lauderdale County Department of Public Health. KI discussion wiJI occur May 7th during the out of sequence at the Health Department, 4112 Chisholm Road, Florence Alabama, and as required June 26th, I scenario dependent.

-Critical Task: OROs issue appropriate dosiinetry, KI, and procedures, and manage radiological I exposure to EWs in accordance with the plans/procedures. EWs periodically _and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to EWs (NUREG.:.

I 0654 J.10.e, K.3.a, b, K.4; Criterion 3al). Pg.189 190.

Performance Measures: (1) OROs must demonstrate the capability to provide emergency I 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 I 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 I emergency workers involved in lifesaving activities, contained in the ORO's plans/procedures.

(2) Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/ procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency I workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control. (3) During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. (4) 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 I

99 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant take other actions. (5) If exercise play does not require emergency workers to seek I

authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge. (6) 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 I

to each other during the entire mission and can share a direct read dosimeter. Each team member must still have and maintain his or her own permanent-record dosimetry. (7) OROs must ensure I that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property

• may require an urgent response. (8) OROs must demonstrate the capability to accomplish I distribution of KI to emergency workers consistent with decisions made. OROs must have the

. capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. (9) Emergency workers must demonstrate I basic knowledge of procedures for using KI. If exercise play does not require emergency workers to consume KI, evaluators must interview at least two workers to determine their knowledge.

I

• LAUDERDALE COUNTY: Emergency worker exposure control will be discussed out

.of sequence on May 14, 2019 at the ELK Riv~r Boat Launch with a member of local law I

enforcement (if available). Exposure control equipment will be pre-distributed for out of sequence having simulated the issuance procedures from the field operations building.

Representatives from the Florence-Lauderdale.Search and Rescue or Rogersville Police I

Department will discuss and demonstrate the use of issued Emergency Equipment.

Critical Task: KI and appropriate instructions are available if a decision to recommend use of KI I

is made. Appropriate record-keeping of the administration of KI for institutionalized individuals and the general public is maintained (NUREG-0654 J.10.e, f; Criterion 3bl). Pg. 190 I Performance Measures: ( 1) OR Os 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. (2) OR Os must demonstrate the capability to accomplish distribution of KI I

consistent with decisions made. (3) OROs must have the capability to develop and maintain lists of institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest KI. OROs must demonstrate the capability to formulate I

and disseminate instructions on using KI for those advised to take it. (4) If a recommendation is made for the general public to take KI, appropriate information must be provided to the public by the means of notification specified in the ORO's plans/ procedures.

I LAUDERDALE COUNTY: KI interview will occur May 7th during the out of sequence at the Health Department, 4112 Chisholm Road, Florence Alabama, and I

discussed as required June 26th, scenario dependent. There are no institutions within the EPZ in Lauderdale County. I I

I 100 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Critical Task: Protective action decisions are implemented for persons with disabilities and I access/functional needs other than schools within areas subject to protective actions (NUREG-0654 J.10.c, d, e, g; Criterion 3cl). Pg. 190 I Performance Measures: ( 1) Applicable OROs must demonstrate the capability to alert and notify (i.e., provide PARs and emergency information and instructions) to persons with disabilities and access/ functional needs, including hospitals/medical facilities, licensed day I c~es, nursing homes, correctional facilities, and mobility-impaired and transportation-dependent individuals. (2) OROs must demonstrate the capability to provide for persons with disabilities and access/functional needs.

I LAUDERDALE COUNTY: NIA, this criteria does not exist within the EPZ in Lauderdale County.

I Critical Task: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel (NUREG-0654 A.3; C.1, 4; J.10.g, j; Criterion I 3dl) Pg. 191-19.2.

Performance Measures: (1) OROs must demonstrate the capability to select, establish, and I staff appropriate traffic and access control points consistent with current conditions and P ADs (e.g., evacuating, sheltering, and relocation) in a timely manner. (2).0ROs must demonstrate the capability to provide instructions to traffic and access control staff on actions to take when I modifications in protective action strategies* necessitate changes in evacuatiori patterns or in the area(s) where access is controlled. (2) Traffic and access control staff must demonstrate accurate knowledge of their roles and responsibilities, including verifying emergency worker I identification and access authorization to the affected areas. (3) fu instances where OROs lack

. authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic),

they must demonstrate the capability to contact the State or Federal agencies that have the I needed authority.

LAUDERDALE COUNTY: Florence-Lauderdale EMA will discuss this criterion out I of sequence on May 14, 2019 with applicable personnel at the Elk River Boat Launch.

Traffic Control *and Access will be simulated the day of the exercise, scenario dependent.

Local Law Enforcement from various depts. (as available) will participate. Actual I demonstration will not be performed.

Critical Task: Impediments to evacuation are identified arid resolved (NUREG-0654 J.10.k; I Criterion 3d2). Pg. 192.

I Performance Measures: (1) OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. (2), The impediment must remain in place during the evacuatiop. long enough that re-routing of traffic is required and (3) must also I result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

I 101 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

LAUDERDALE COUNTY: Florence.:.Lauderdale EMA will discuss this criterion on June 26, 2019 with applicable personnel in our EOC or communications room, scenario dependent. Lauderdale County EOC Staff will participate. Actual demonstrations will I not be performed.

Core Capability: Situational Assessment I Definition: Provide all decision makers with decision-relevant information regarding the nature and extent of the hazard, any cascading effects, and the status of the response.

I Critical Task: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in I

place for emergency workers, including provisions to authorize radiation exposure in excess of administrative limits or protective action guides. (NUREG-0654/FEMA REP-1, C.6; f; K.3.a; K.4; Criterion 2.al). Pg. 184.

I Performance Measures: (1) OROs authorized to send emergency workers into the plume exposure pathway EPZ must demonstrate a capability to comply with emergency worker I

exposure limits based on their emergency plans/procedures. (2) OROs must also demonstrate the capability to make decisions concerning authorization of exposure levels in excess .of pre-authorized levels and the number of emergency workers receiving radiation doses above pre-I authorized levels. (3) This would include providing KI and dosimetry in a timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating actions, in accordance with respective plans/procedures.

I LAUDERDALE COUNTY: Florence-Lauderdale EMA can discuss this criterion on June 26, 2019 with applicable personnel in our EOC or communications room, scenario I

dependent. Lauderdale County EOC Staff will participate. Actual demonstrations will not be performed. In Addition, KI can be discussed during the out of sequence at the Health Department, 4112 Chisholm Road, Florence Alabama, on May 7, 2019.

I Critical Task: Appropriate protective action recommendations (PARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, I

as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA-REP-1, I.10 and Supplement 3; Criterion 2.b.l) Pg. 184-185. _ I Performance Measures: (1) The ORO must demonstrate the capability to use the appropriate means described in the plans/procedures to develop PARs for decision-makers based on available information and recommendations provided by the licensee, as well as field monitoring I

data if available. Workers must also consider any release and meteorological data provided by the licensee. (2) 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 I

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 I quantities and units of the PAG to which they will be compared. (3) PARs must be promptly I

102 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant transmitted to decision-makers in a prearranged format. (4) When the licensee and ORO I projected doses differ by more than a factor of 10, the ORO and licensee must determine the source of the difference by discussing input data and assumptions, using different models, or exploring possible reasons. Resolution of these differences must be incorporated into the PARs I if timely and appropriate. (5) The ORO must demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated P ARs.

I LAUDERDALE COUNTY: Florence-Lauderdale EMA will discuss this criterion on June 26, 2019 with applicable personnel in our BOC or communications room.

Lauderdale County BOC Staff will participate. Based on.the Critical Task criteria, I Lauderdale County has little, if any, input to PARs.

Critical Task: A decision-making process involving consideration *of appropriate factors and I necessary coordination is used to make PADs 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; Criterion 2.b.2). Pg. 185.

I Performance Measures: (1) OROs must have the capability to make both initial and subsequent precautionary and/or protective action decisions in a timely *manner appropriate to the I incident, based on information from the licensee, *assessment of plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO authorities (e.g., incident command), and PARs from the utility and ORO staff. (2) In addition, a I subsequent or alternate precautionary and/or protective action decision may be- appropriate if vm:ious conditions (e.g., an HAB incident, weather,. release timing and magnitude) pose undue*

risk to an evacuation or if evacuation may disrupt the efforts to respond to a hostile action. (3)

I OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a precautionary and/or protective action decision if local law enforcement, fire service, HAZMAT, and emergency medical resources are used to augment response to the NPP I site or other key infrastructure. (4) If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must demonstrate the capability to make decisions on the distribution and administration of KI to I 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 I appropriate assessment and decision-making staff. (5) If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate precautionary and/or I protective action decisions with each other. (6) In addition, decisions must be coordinated/communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

I LAUDERDALE COUNTY: Coordinates only. The Alabama Depiµ-tment of Public Health-Office of Radiation Control is responsible for issuing the PAD's. However, after I a PAD is issued, the county EMA reserves the right to review and/or recommend the PAD be changed due to any mitigating circumstances (road conditions, weather conditions, etc.), scenario dependent.

I 103 I

• Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Critical Task: Protective action decisions are made, as appropriate, for groups of persons with disabilities and access/functional needs (NUREG-0654 D.4; J.9; J.10.d, e; Criterion 2cl). Pg. I 186.

Performance Measures: Usually it is appropriate to implement evacuation in areas where doses I are projected to exceed the lower end of the range of PAGs, except for incidents where there is a

• high- risk environmental condition or where high-risk groups (e.g., the immobile or infirm) are involved. (1) In these cases, factors that must be considered include weather conditions, shelter I

availability, availability of transportation assets, risk of evacuation versus risk from the avoided dose, and precautionary school evacuations. In addition, decisions must be coordinated/communicated with the incident command. In situations where an institutionalized I

population cannot be evacuated, the ORO must consider use of KI. (2) OROs must demonstrate the capability to alert and notify all public_school systems/districts of emergency conditions that .

are expected to or may necessitate protective actions for students. Demonstration requires that I

the OROs actually contact public school systems/districts during the exercise. (3) OROs must demonstrate how the decision-making process takes those with disabilities and access/functional needs (e.g., nursing homes, correctional facilities, licensed day cares, mobility-impaired I

individuals, and transportation-dependent individuals) into account.**

LAUDERDALE COUNTY: This will be discussed during the exercise, scenario I

dependent.

Core Capability: Operational Communications I

Definition: Establish and maintain a unified and coordinated operational structure and process that appropriately integrates all critical stakeholders and supports the execution of core I

capabilities.

Critical Task: At least 2 communications systems are available, at least* 1 operates properly, and I

communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 I

F.1, 2; Criterion ldl). Pg. 180.

Performance Measure: OROs must demonstrate thata primary system and at least one backup I

system are fully functional. (2) All facilities, FMTs; and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the I

communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) QROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.*

I LAUDERDALE COUNTY: Communications systems will be demonstrated, scenario I dependent on June 26, 2019. The TVA ECNS (Emergency Communication and I

104 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Notification System) is the primary means of communication. Southern Linc's Critical I Linc, Land line phones, and cell phones are secondary along with, RF UHF and VHF radio systems.

I Core Capability: Public Information and Warning Definition: Deliver coordinated, prompt, reliable, and actionable information to the whole I community through the use of clear, consistent, accessible, and culturally and linguistically appropriate methods to effectively relay information regarding any threat or hazard and, as appropriate, the actions being taken and the assistance being made available.

I Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 Al.a, e; A.3, 4; C.l, 4, 6; D.4; E.1, 2; I G.3.a; H.3, 4; Criterion lal). Pg. 180.

Performance Measure: ( 1) OROs must demonstrate the capability to receive notification of an I incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key emergency personnel in a timely manner, (4) Responders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management I organizations of an incident in a timely manner when they receive information. (5) Demonstrate the ability to maintain and staff 24-hour operations. (6) OR Os must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and I contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must be demonstrated.

I LAUDERDALE COUNTY: The Florence/Lauderdale EMA Staff will be pre-positioned at 8:00 a.m. at which normal duty hours begin. The Florence-Lauderdale I EMA Emergency Operations Center (EOC) is located at 110 W. College Street Florence, Alabama in the basement of City Hall. The Florence-Lauderdale EMA Staff is comprised of a Director, Deputy Director, Planner, Two Assistants, a Secretary and I Records Clerk. A few administrative volunteers may also be pre-positioned with the Florence-Lauderdale County EMA staff and at the Joint Information Center (JIC). A call list may be utilized to ensure all required personnel are alerted and notified the day of the I exercise.

Critical Task: At least 2 communications systems are available, at least 1 operates properly, and I communication links are established and maintained with appropriate locations.

I Communications capabilities are managed in support of emergency operations (NUREG-0654 F.l, 2; Criterion ldl). Pg. 180.

I Performance Measure: OROs must demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial I

105 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

telephone system. (3) Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for I fixed and mobile medical support facilities exists.

LAUDERDALE COUNTY: Communications systems will be demonstrated, scenario I dependent on June 26, 2019. The TVA ECNS (Emergency Communication and Notification System) is the primary means of communication. Southern Linc's Critical Linc, Land line phones, and cell phones are secondary along with, RF UHF and VHF I radio systems.

Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other I supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

I Performance Measure: (1) 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. (2)

For non-facility-based operations, the equipment and supplies must be sufficient and consistent I

with the assigned operational role. (3)At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI I

sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) members of the general public, (5) The plans/procedures must include the forms to be used for I

documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in I

the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct read and permanent-record dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans or I

specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and I

operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. ( 11) In addition, instruments being used to measure activity must have a sticker-I 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. (12) In areas where portal monitors are used, I

the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's I

recommendations.

I I

106 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant LAUDERDALE COUNTY: Equipment, maps, displays, and dosimetry will be in place I and in use on June 26, 2019 during the exercise at the BOC and the JIC, scenario dependent. River access and traffic control maps/routes will be available during the OOS water clearance on May 14th. The EMA Field Operations Building located at 702 Oak I Street in Florence, Alabama houses field equipment including TLDs, dosimetry, and monitoring instruments and these units can be discussed during the out of sequence on May 14, 2019 at either the BOC, the Field Operations Building, or the Elk River boat I ramp.

Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; I Criterion 3d2). Pg. 192.

Performance Measures: (1) OROs must demonstrate the capability to identify and take I appropriate actions concerning impediments to evacuations. (2) The impediment must remain in place during the evacuation long enough that re-routing of traffic is required and (3) must also result in demonstration of decision-making and coordination with the JIC to communicate the I alternate route to evacuees.

LAUDERDALE COUNTY: Florence-Lauderdale EMA will discuss this criterion on I June 26, 2019 with applicable personnel in our BOC or communications room, and at the

• JIC, scenario dependent. Lauderdale County BOC Staff and JIC support staff (if available) will participate. Actual demonstrations will not be performed.

I Critical Task: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency I officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current FEMA REP Guidance (Timely: The responsible ORO personnel/representatives demonstrate actions to disseminate the I appropriate information/instructions with a sense of urgency and without undue delay) (NUREG-0654 E.5, 6, 7; Criterion Sal). Pg. 198-199.

• I Performance Measure: (1) Responsible OROs must demonstrate the capability to sequentially provide an alert signal followed by an initial instructional message to populated areas throughout the 10-mile plume exposure pathway EPZ. Following the decision to activate the alert and I notification system, (2) OROs must complete system activation for primary alert/notification and disseminate the information/instructions in a timely manner. For exercise purposes, timely is I defined as "with a sense of urgency and without undue delay." (3) Procedures to broadcast the message must be fully demonstrated as they would in an actual emergency up to the point of transmission. Broadcast of the message(s) or test message(s) is not required. The procedures I must be demonstrated up to the point of actual activation. The alert signal activation should be simulated, not performed. Evaluations of BAS broadcast stations may also be accomplished through SAVs. (4) The capability of the primary notification system to broadcast an I 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. (5) The initial message must include at a minimum the following I

107 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

elements:

• (a) Identification of the ORO responsible and the official with authority for providing the alert signal and instructional message; I

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

• (c) Reference to REP-specific emergency information (e.g., brochures, calendars, and/or information in telephone books) for use by the general public during an emergency; and I (d) A closing statement asking that the affected and potentially affected population stay tuned for additional information, or that the population tune to another station for additional information.

(6) If route alerting is demonstrated as a primary method of alert and notification, it must be done I in accordance with the ORO's plans/procedures. 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)

I must vary from exercise to exercise. However, the most difficult route(s) must be demonstrated no less than once every eight years. (7) All alert and notification activities along the route(s) must be simulated (i.e., the message that would actually be used is read for the evaluator, but not I

actually broadcast. (8) Actual testing of the mobile public address system will be conducted at an agreed-upon location.

I LAUDERDALE COUNTY: PNS coordination will be done via the ECNS and led by Madison County. The first siren activation will be demonstrated up to the point of PNS activation. Subsequent activations will be simulated, scenario dependent. The BFNPP I

counties have developed unified BAS and Special News Broadcast messages and distributed to the National Weather Service (NWS) Office in Huntsville. Madison County will coordinate the EAS/SNB messages with the BFNPP counties via the ECNS I

and designate to NWS via Southern Linc's Critical Linc or land line phone which message to distribute. EAS message distribution will be the responsibility of the NWS, and simulated for this exercise, scenario dependent. County-specific messages are I

released by the EOC, scenario dependent.

Critical Task: Ensure OROs provide accurate emergency information and instructions to the I

public and the news media in a timely manner (The responsible ORO personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay) (NUREG-0654 E.5, 7; G.3.a; G.4.a, c; Criterion 5bl). Pg.

I 200-201.

Performance Measure: (1) The responsible ORO personnel/representatives must demonstrate I

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."

I Message elements: (2) The ORO must ensure that emergency information and instructions are consistent with PADs made by appropriate officials. (3) The emergency information must contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, I

. reception center locations, what to take when evacuating, shelter-in-place instructions, information concerning protective actions for schools and persons with disabilities and access/functional needs, and public inquiry hotline telephone number) to assist the public in I

I 108 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant carrying out the PADs provided (4) The ORO must also be prepared to disclose and explain the I ECL of the incident. At a minimum, this information must be included in media briefings and/or media releases. (5) 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. (6)

I This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas. (7) The emergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5.a.1 and previously I identified protective action areas that are still valid, as well as new areas. (8) Information about any rerouting of evacuation routes due to impediments should also be included. (9) The OR Os must demonstrate the capability to ensure that emergency information that is no longer valid is I rescinded and not repeated by broadcast media. (10) OROs must demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures. (11) OROs must demonstrate the capability to develop emergency I information in a non-English language when required by the plans/procedures. (12) If ingestion exposure pathway measures are required, OROs must demonstrate that a system exists for rapid dissemination of ingestion exposure pathway information to predetermined individuals and I businesses. Media information: (13) OROs must demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. (14) This would include demonstration of the capability to conduct timely and I pertinent media briefings and distribute media releases as the incident warrants. (15) The OROs must demonstrate the capability to respond appropriately to inquiries from the news media. (16)

All information presented in media briefings and releases must be consistent with P ADs and I other emergency information provided to the public. ( 17) Copies of pertinent emergency information (e.g., BAS messages and media releases) and media information kits must be available for dissemination to the media. Public Inquiry (18) OROs must demonstrate that an I effective system is in place for dealing with calls received via the public inquiry hotline. (19)

Hotline staff must demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate information source. (20) Information from the hotline I 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: (21) The dissemination of information I dealing with specific aspects of NPP security capabilities, actual or perceived adversarial (terrorist) force or threat, and tactical law enforcement response must be coordinated/

I communicated with appropriate security authorities (e.g., law enforcement and NPP security agencies) in accordance with ORO Pans/procedures.

I LAUDERDALE COUNTY: The BFNPP counties have developed unified BAS and Special News Broadcast messages and distributed to the National Weather Service (NWS) Office in Huntsville. Madison County will coordinate the EAS/SNB messages I with the BFNPP counties via the ECNS and designate to NWS via Southern Linc's Critical Linc or land line phone which message to distribute. BAS message distribution will be the responsibility of NWS and simulated for this exercise. County-specific I messages are released by the BOC, scenario dependent.

I 109 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Core Capability: Environmental Response/Health and Safety I

Definition: Conduct appropriate measures to ensure the protection of the health and safety of I the public and workers, as well as the environment, from all-hazards in support of responder operations and the affected communities I

Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 A.La, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; G.a.3; H.3, 4; Criterion lal). Pg. 180.

I Performance Measure: (1) OROs must demonstrate the capability to receive notification of an incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key I

emergency personnel in a timely manner, (4) 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. (5) Demonstrate I

the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and contact information for facilities included in the incident command must be available to all I

appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must be demonstrated. I LAUDERDALE COUNTY: The Florence/Lauderdale EMA Staff will be pre-positioned at 8:00 a.m. at which normal duty hours begin. The Florence-Lauderdale EMA Emergency Operations Center (EOC) is located at 110 W. College Street Florence, I

Alabama in the basement of City Hall. The Florence-Lauderdale EMA Staff is comprised of a Director, Deputy Director, Planner, Two Assistants, a Secretary and Records Clerk. A few administrative volunteers may also be pre-positioned with the I

Florence-Lauderdale County EMA staff and JIC. A call list may be utilized to ensure all required personnel are alerted and notified the day of the exercise. I Critical Task: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible (NUREG-0654 A.1.d; A.2.a, b; A.3; C.4, 6; Criterion lcl). Pg. 181.

I Performance Measure: ( 1) Leadership personnel must demonstrate the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed through I

periodic briefings and/or other myans, coordinating with other OROs, and ensuring completion of requirements and requests.) (2) Leadership must demonstrate the ability to prioritize resource I tasking and replace/supplement resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources. Any resources identified through LOA/MOUs must be on the ORO's mobilization list so they may be contacted during an incident if needed. I I

I 110 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I LAUDERDALE COUNTY: The Florence-Lauderdale EMA will demonstrate direction and control from the Lauderdale County BOC during the exercise on June 26, 2019.

I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 I F.1, 2; Criterion ldl). Pg. 181 Performance Measure: OROs must demonstrate that a primary system and at least one backup I system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the I communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

I LAUDERDALE COUNTY: Communications systems will be demonstrated, scenario dependent on June 26, 2019. The TVA ECNS (Emergency Communication and I Notification System) is the primary *means of communication. Land line phone is secondary along with Southern Linc's Critical Linc, cell phones, and RF UHF and VHF radio systems.

I Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, arid other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; 1.7, 8, 9; J.10.a, I b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

Performance Measure: (1) Aparticular facility's equipment and supplies must be sufficient.

I and consistent with that facility's assigned role in the ORO's emergency operations plans. (2)

For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3) At locations where traffic and access control personnel .

I are deployed; appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be: **

available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI .

I sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) members of the general public, (5) The plans/procedures must include the forms to be used for I documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in I the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans or I specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and I

111 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-I 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. (12) In areas where portal monitors are used, I

the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for.

Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's I

recommendations.

LAUDERDALE COUNTY: Equipment, maps, displays, and dosimetry will be in place I

and in use on June 26, 2019 during the exercise scenario dependent. The EMA Field Operations Building located at 702 Oak Street in Florence, Alabama houses field equipment including TLDs, dosimetry, and monitoring instruments and these units can be I

discussed during the out of sequence on May 14, 2019 at either the BOC, Field Operations Building, or Elk River boat ramp. KI inventory is maintained at the Lauderdale County Department of Public Health. KI discussion will occur May 7th I

during the out of sequence at the Health Department, 4112 Chisholm Road, Florence Alabama, and as required June 26th, scenario dependent. I Critical Task: OROs use a decision.:making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for EWs including provisions to authorize radiation exposure in excess of administrative I

limits or PAGs (NUREG-0654 C.6.f; K.4 Criterion 2al). Pg. 185.

Performance Measure: (1) OROs authorized to send emergency workers into the plume I

exposure pathway EPZ must demonstrate a capability to comply with emergency worker

• exposure limits based on their emergency plans/procedures. (2) OROs must also demonstrate the capability to make decisions concerning authorization of exposure levels in excess of pre-I authorized levels and the number of emergency workers receiving radiation doses above pre-authorized levels. (3) This would include providing KI and dosimetry in a timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating I

actions, in accordance with respective plans/procedures.

LAUDERDALE COUNTY:. The Florence-Lauderdale EMA will demonstrate direction I

and control from the Lauderdale County BOC during the exercise on June 26, 2019.

I Critical Task: Appropriate protective action recommendations (PARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA- I REP-1, I.10 and Supplement 3; Criterion 2.b.1) Pg. 184-185.

I I

112 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measures: (1) The ORO must demonstrate the capability to use the appropriate I means described in the plans/procedures to develop PARs for decision-makers based on available information and recommendations provided by the licensee, as well as field monitoring data if available. Workers must also consider any release and meteorological data provided by I the licensee. (2) The ORO must demonstrate a reliable capability to independently validate dose projections. The types of calculations to be demonstrated depend on the data available and the need for assessments to support the PARs must be appropriate to the scenario. In all cases, I calculation of projected dose must be demonstrated. Projected doses must be related to quantities and units of the PAG to which they will be compared. (3) PARs must be promptly transmitted to decision-makers in a prearranged format. (4) When the licensee and ORO I projected doses differ by more than a factor of 10, the ORO and licensee must determine the source of the difference by discussing input data and assumptions, using different models, or exploring possible reasons. Resolution of these differences must be incorporated into the P ARs I if timely and appropriate. (5) The ORO must demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated PARs.

I LAUDERDALE COUNTY: Lauderdale County Field Operations Building houses two radiation equipment mobile trailers designated to deploy at moment's notice. If needed radiation equipment can be verified during the 14 May OOS exercise. Florence-I Lauderdale EMA will discuss this criterion on June 26, 2019 with applicable personnel in our BOC or communications room, scenario dependent. Lauderdale County BOC Staff will participate. Actual demonstrations will not be performed.

I Critical Task: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make P ADs for the general public (including the I 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; Criterion 2.b.2). Pg. 185.

I Performance Measures: (1) OROs must have the capability to make both initial and subsequent precautionary and/or protective action decisions in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or I actual releases, other available information related to the incident, input from appropriate ORO authorities (e.g., incident command), and PARs from the utility and ORO staff. (2) In addition, a I subsequent or alternate precautionary and/or protective action decision may be appropriate if various conditions (e.g., an HAB incident, weather, release timing and magnitude) pose undue risk to an evacuation or if evacuation may disrupt the efforts to respond to a hostile action. (3)

I OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a precautionary and/or protective action decision if local law enforcement, fire service, HAZMAT, and emergency medical resources are used to augment response to the NPP I site or other key infrastructure. (4) If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must demonstrate the capability to make decisions on the distribution and administration of KI to I 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 I

113 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

appropriate assessment and decision-making staff. (5) If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate precautionary and/or protective action decisions with each other. (6) In addition, decisions must be coordinated/ I communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

1 I

LAUDERDALE COUNTY: Florence-Lauderdale EMA will discuss this criterion on June 26, 2019 with applicable personnel in our EOC or communications room, scenario dependent. Lauderdale County EOC Staff will participate. Actual demonstrations will I

not be performed.

Critical Task: OROs issue appropriate dosimetry, KI, and procedures, and manage radiological I

exposure to EWs in accordance with the plans/procedures. EWs periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to EWs (NUREG-I 0654 K.3.a, b, K.4; Criterion 3al). Pg. 189.

Performance Measures: (1) OROs must demonstrate the capability to provide emergency I

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 I

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. (2)

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

workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control. (3) During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back I

values are reached. (4) 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. (5) If exercise play does not require emergency workers to seek I

authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge. (6) 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 I

to each other during the entire mission and can share a direct read dosimeter. Each team member must still have and maintain his or her own permanent-record dosimetry. (7) OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact I

the capability to respond to an incident where lifesaving and/or protection of valuable property may require an urgent response. (8) OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OR Os must have the I

I I

114 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant capability to develop and maintain lists of emergency workers who have ingested KI, including I documentation of the date(s) and time(s) they did so. (9) Emergency workers must demonstrate basic knowledge of procedures for using KI. If exercise play does not require emergency workers to consume KI, evaluators must interview at least two workers to determine their I knowledge.

LAUDERDALE COUNTY: The EMA Field Operations Building located at 702 Oak I Street in Florence, Alabama houses field equipment including TLDs, dosimetry, and monitoring instruments and these units can be discussed during the out of sequence on May 14, 2019 at either the EOC, the Field Operations Building, or the Elk River boat I ramp. In addition, appropriate record keeping of dosimetry and KI Issuance can be discussed or demonstrated during the river clearance demonstration.

I Critical Task: Kl and appropriate instructions are made available in case a decision to recommend use of KI is made. Appropriate record keeping of the administration of KI for institutionalized individuals and the general public is maintained (NUREG-0654 J.10.e, f; I Criterion 3bl). Pg. 190.

Performance Measures: (1) OROs must demonstrate the capability to make KI available to I institutionalized individuals and, where provided for in their plans/procedures, to members of the general public. (2) OROs must demonstrate the capability to accomplish distribution of KI consistent with decisions made. (3) OROs must have the capability to develop and maintain lists I of institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest KI. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it. (4) If a recommendation is I 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.

I LAUDERDALE COUNTY: Concur, this can be discussed during the 7 May 2019 SAV visit with the KI nurse at Lauderdale Co. Health department. In addition, the decision to issue and document KI can be demonstrated during the May, 14 Water demonstration or I the June 26, 2019 Plume Phase Exercise.

Critical Task: The reception center facility has appropriate space, adequate resources, and I trained personnel to provide monitoring, decontamination, and registration of evacuees (NUREG-0654 A.3; C.4; J.10.h; J.12; Criterion 6al). Pg. 202-203.

I Performance Measure: (1) Radiological monitoring, decontamination, and registration facilities for evacuees must be set up and demonstrated as they would be in an actual emergency.

I (2) OROs conducting this demonstration must have (a) one-third of the resources (e.g.,

monitoring teams/instrumentation/portal monitors) available at the facility(ies) as necessary to monitor (b) 20 percent of the population within .a 12-hour period. (c) This would include I adequate space for evacuees' vehicles. (2) Availability of resources can be demonstrated with valid documentation (e.g., MOU/LOA, etc.) reflecting how necessary equipment would be procured for the location. (3) Plans/procedures must indicate provisions for service animals. (4)

I 115 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. (5) 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 I monitoring productivity rate per hour needed to monitor the 20 percent EPZ population planning base. (6) 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. ( 7)

I 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. (8) The monitoring sequences for the first six simulated evacuees per I

monitoring team will be timed by the evaluators to determine whether the 12-hour requirement can be met. (9) OROs must demonstrate the capability to register evacuees upon completion of the monitoring and decontamination activities. (10) The activities for recording radiological I

monitoring and, if necessary, decontamination must include establishing a registration record consisting of the (a) evacuee's name, (b) address, (c) results of monitoring, and (d) time of decontamination (if any), or as otherwise designated in the plan and/or procedures. Audio I

recorders, camcorders, or written records are all acceptable means for registration. (11)

Monitoring activities shall not be simulated. (12) Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. (13) They must also explain I

the procedures for referring any evacuees who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency.

I Decontamination of evacuees may be simulated and conducted by interview. (14) Provisions for separate showering and same-sex decontamination must be demonstrated or explained. (15) The staff must demonstrate provisions for limiting the spread of contamination. Provisions could I

include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. (16) Provisions must also exist to (a) separate contaminated and uncontaminated evacuees, (b) provide changes of clothing for I

those with contaminated clothing, and (c) store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities. (17) In addition, for any evacuee found to be contaminated, procedures must be discussed concerning handling of potential I

contamination of vehicles and personal belongings. Waste water from decontamination operations does not need to be collected. (18) Individuals who have completed monitoring and decontamination if needed, must have the means (e.g., hand stamp, sticker, bracelet, form, etc.)

I indicating that (a) they, and their service animals and vehicles, where applicable, have been monitored, cleared, and found to have no contamination or (b) contamination below the trigger/action level or (c) have been placed in a secure area until they can be monitored and I

decontaminated, if necessary. 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 I

areas. (19) However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles (a) held in a secure area or (b) monitored and I decontaminated (if applicable) and do require confirmation that their vehicle is being (c) held in a secure area or (d) free from contamination prior to entering the congregate care areas.

I I

116 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I LAUDERDALE COUNTY: NIA Florence.,Lauderdale County will demonstrate this capability during the 2021 FEMA graded Out of Sequence exercise.

I Critical Task: The facility/ORO has adequate procedures and resources to accomplish monitoring and decontamination of emergency workers and their equipment and vehicles (NUREG-0654 K.5.a, b; Criterion 6bl). Pg. 203-204.

I Performance Measure: (1) The monitoring staff must demonstrate the capability to monitor emergency worker personnel andtheir equipment and vehicles for contamination in accordance I with the ORO's plans/procedures. Specific attention must be given to equipment, including any vehicles that were in contact with contamination. (2) The monitoring staff must demonstrate the capability to make decisions on the need for decontamination of personnel, equipment, and I 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. (3) However, appropriate monitoring procedures must be demonstrated for a minimum of two emergency I workers and their equipment and vehicles. (4) Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. (5)

The area to be used for monitoring and decontamination must be set up as it would be in an I actual emergency, with all route markings, instrumentation, record keeping, and contamination control measures in place. (6) Monitoring procedures must be demonstrated for a minimum of one vehicle. It is generally not necessary to monitor the entire surface of vehicles. (7) However, I the capability to monitor areas such as radiator grills, bumpers, wheel wells, tires, and door handles must be demonstrated. (8) Interior. surfaces of vehicles that were in contact with contaminated individuals must also be checked. Decontamination of emergency workers may be I simulated and conducted via interview. (9) Provisions for separate showering. and same-sex decontamination must be demonstrated or explained. ( 10) The staff must. demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs, and I appropriate means (e.g:, partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. (11) Provisions must also extst to separate contaminated and uncontaminated individuals where applicable, provide changes of clothing for those with I contaminated clothing, and store contaminated clothing and personal belongings to prevent further contamination of emergency workers or facilities. (12) OROs must demonstrate the capability to register emergency workers upon completion of the monitoring and I decontamination activities. The activities for recording radiological monitoring and if necessary, decontamination must include establishing a registration record consisting of the (a) emergency worker's name, (b) address, (c) results of monitoring, and (d) time of decontamination (if any),

I or as otherwise designated in the plans/procedures. Audio recorders, camcorders, or written records are all acceptable means for registration. Monitoring activities shall not be simulated.

(13) Monitoring personnel must explain use of trigger/action levels for determining the need for I decontamination. (14) They must also explain the procedures for referring any emergency workers who cannot be adequately decontaminated for assessment and follow-up in accordance I with the ORO's plans/procedures Decontamination capabilities and provisions for vehicles and equipment that cannot be successfully decontaminated may be simulated and conducted by interview. Waste water from decontamination operations does not need to be collected.

I 117 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

• LAUDERDALE COUNTY: NIA, Florence-Lauderdale County will demonstrate this capability during the 2021 FEMA graded Out of Sequence exercise. I Core Capability: On-Scene Security, Protection, and Law Enforcement (TCP's/Waterway Warning) I Definition: Ensure a safe and secure environment through law enforcement and related security and protection operations for people and communities located within affected areas and also for I response personnel engaged in lifesaving and life-sustaining op~rations.

Critical Task: At least 2 communications systems are available, at least 1 operates properly, and I communication links are established.and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operatioQ.s (NUREG-0654 I

F.1, 2; Criterion ldl). Pg. 180.

Performance Measure: OROs must demonstrate that a primary system and at least one backup I

system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the I

communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

I LAUDERDALE COUNTY: Communications systems will be demonstrated, scenario dependent on June 26, 2019. The TVA ECNS (Emergency Communication and I

Notification System) is the primary means of communication. Land line phone is secondary along with EMITS, cell phones, Southern Linc's, RF UHF and VHF radio

• systems.

I Critical Task: Equipment (to include communications), maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 I

H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

Performance Measure: (1) A particular facility's equipment and supplies must be sufficient I

and consistent with that facility's assigned role in the ORO's emergency operations plans. (2)

For non-facility-based operations, the equipinent*and supplies must be sufficient and consistent with the assigned operational role. (3) At locations where traffic and access control personnel I

are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) Responsible OROs must. demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or I

specialized response teams (e.g.; civil news media) (b) institutionalized individuals and (c) members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage I

I 118 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant location(s) or through documentation of quantities of dosimetry and KI available and storage I locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct read and permanent-record dosimeters in sufficient I

• quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an*

individual(s) to read the administrative reporting limits and'maximum exposure limits contained I in the ORO's plan*s/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. (10) A label indicating such calibration must be on each I instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies .the acceptable range ofreadings that the met~r should indicate when it I is response-checked using.a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for I Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I LAUDERDALE COUNTY: Equipment, maps, displays, and dosimetry will be in place and in use on June 26, 2019 during the exercise at the BOC and the JIC, scenario dependent. River evacuation route Maps will be available during the OOS water I clearance on May 141h. The EMA Field Operations Building located at 702 Oak Street in Florence, Alabama houses field equipment including TLDs; dosimetry, and monitoring instruments and these units can be discussed during the out of sequence on May 14; 2019 I at either the BOC, the Field Operations Building, or the Elk River boat ramp.

Critical Task: OROs issue appropriate dosimetry, KI, and procedures, and manage radiological I exposure to EWs in accordance with the plans/procedures. EWs periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to EWs (NUREG-I 0654 K.3.a, b, K.4; Criterion 3al). Pg. 189.

Performance Measures: (1) OROs must demonstrate the*capability to provide emergency I 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 I 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 I emergency workers involved in lifesaving activities, contained in the ORO' s plans/procedures.

(2) Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/ procedures. If supplemental resources are used, they must be provided with I just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control. (3) During a plume phase exercise, emergency workers must I

119 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

demonstrate the procedures to be followed when administrative exposure limits and tum-back values are reached. (4) 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 I take other actions. (5) If exercise play does not require emergency workers to seek*

authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge. (6) Although it is desirable for all emergency workers to each have a I direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission and can share a direct read dosimeter. Each team member must still have and maintain his or her own permanent-record dosimetry. (7) OROs must ensure I that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property may require an urgent response. (8) OROs must demonstrate the capability to accomplish I distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. (9) Emergency workers must demonstrate I

basic knowledge of procedures for using KI. If exercise play does not require emergency workers to consume KI, evaluators must interview at least two workers to determine their knowledge.

I LAUDERDALE COUNTY: Emergency worker exposure control will be discussed out of sequence on May 14, 2019 at the ELK River Boat Launch with a member oflocal law I

enforcement (if available). Exposure control equipment will be pre-distributed for out of

• sequence having simulated the issuance procedures from the field operations building.

Representatives from the Florence-Lauderdale Search and Rescue or Rogersville Police I

Department will discuss and demonstrate the use of issued Emergency Equipment.

Critical Task: Appropriate traffic and access control is established. Accurate instructions are I

provided to traffic and access control personnel (NUREG-0654 A.3; C.1, 4; J.10.g,j; Criterion 3dl). Pg. 191-192. I Performance Measures: (1) 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. (2) OROs must demonstrate the I

capability to provide instructions to traffic and acc.ess 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. (2) Traffic and access control staff must demonstrate accurate I

knowledge of their roles and responsibilities, including verifying emergency worker identification and access authorization to the affected areas. (3) In instances where OROs lack authority necessary to control acces,s by certain types of traffic (e.g., rail, water, and air traffic),

I they must demonstrate the capability to contact the State or Federal agencies that have the needed authority I I

I 120 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant LAUDERDALE COUNTY: Florence-Lauderdale EMA will discuss this criterion on I June 26, 2019 with applicable personnel in our EOC or communications room, scenario dependent. Lauderdale County EOC Staff will participate. Actual demonstrations will not be performed I Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; Criterion 3d2). Pg. 192.

I Performance Measures: (1) OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. (2), The impediment must remain I in place during the evacuation long enough that re-routing of traffic is required and (3) must also result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

I LAUDERDALE COUNTY: Florence-Lauderdale EMA will discuss this criterion on June 26, 2019 with applicable personnel in our EOC or communications room.

I Lauderdale County EOC Staff will participate. Actual demonstrations will not be performed.

I Core Capability: Mass Care Services Definition: Provide life-sustaining and human services to the affected population, to include I hydration, feeding, sheltering, temporary housing, evacuee support, reu'nification, and

• distribution of emergency supplies. I I

I I

Critical Task: Managers of congregate care facilities demonstrate that the centers have resources to provide services and accommodations consistent with planning guidelines. Managers demonstrate the procedures to assure that evacuees have been monitored for contamination and I have been decontaminated as appropriate before entering congregate care facilities (NUREG-0654; J.10.h; J.12; Criterion 6cl). Pg. 204.

I Performance Measure: (1) OROs must plan for a sufficient number of congregate care centers in host/support jurisdictions based on their all-hazard sheltering experience and what is I historically relevant for that particular area. In this simulation, it is not necessary to set up operations as they would be in an actual emergency. Alternatively, (2) capabilities may be demonstrated by setting up stations for various services and providing those services to I simulated evacuees. Given the substantial differences between demonstration and simulation of this criterion, exercise demonstration expectations must be clearly specified in Extent-of-Play Agreements. Congregate care staff must also (3) demonstrate the capability to ensure that (a)

I evacuees, service animals, and vehicles have been monitored for contamination,(b) decontaminated as appropriate, and (c) registered before entering the facility. (4) Individuals arriving at congregate care facilities must have means (e.g.; hand stamp, sticker, bracelet, form, I etc.) indicating that they, and their service animals and vehicles, where applicable, have been (a) placed in a secured area or (b) monitored, cleared, and found to have no contamination or (c) contamination below the trigger/action level. In accordance with plans/procedures, individuals I

121 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

found to be clean after monitoring do not need to have their vehicle monitored. These individuals do not need confirmation that their vehicle is free from contamination prior to entering the congregate care areas. (5) However, those individuals who are found to be I contaminated and are then decontaminated will have their vehicles held in a secure area until they can be monitored and decontaminated (if applicable) and do need confirmation that their vehicle is being held in a secure area or free from contamination prior to entering the congregate I care areas. This capability may be determined through an interview process. If operations at the center are demonstrated, material that would be difficult or expensive to transport (e.g., cots, blankets, sundries, and large-scale food supplies) need not be physically available at the I

facility(ies). (6) However, availability of such items must be verified by providing the evaluator a list of sources with locations and estimates of quantities.

I LAUDERDALE COUNTY: Florence-Lauderdale EMA along with ARC and DHR agencies will demonstrate this criterion Out of Sequence on May 17, 2019 at Florence High School Located on 1201 Bradshaw Dr. Florence, AL 36630.

I I

I I

I I

I I

I I

I I

122 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant EXTENT OF PLAY AGREEMENT I 2019 Browns Ferry Nuclear Plant Lawrence County I FULL PARTICIPATION RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE I All activities will be demonstrated fully in accordance with respective plans and procedures as they would be in an actual emergency (FEMA must receive these plans, guides and procedures I NLT 60 days before the exercise). This Extent of Play agreement is written by exception. If it is not listed as an exception it will be demonstrated as described in the plans, standard operating guides (SOGs) and/or procedures (SOPs). Any issue or discrepancy arising during exercise play I may be re-demonstrated if allowed by the RAC Chair or as listed herein. This allowance may be granted if it is not disruptive to exercise play and is mutually agreed to by the ORO controller and FEMA evaluator.

I Core Capability: Operational Coordination Definition: Establish and maintain a unified and coordinated operational structure and process I that appropriately integrates all critical stakeholders and supports the execution of core capabilities.

I Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 A.La, e; A.3, 4; C.l, 4, 6; D.4; E.1, 2; G.3.a-i H.3, 4; Criterion lal). Pg. 180.

I Performance Measure: (1) OROs must demonstrate the capability to receive notification of an incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key I emergency personnel in a timely manner, (4) 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. (5) Demonstrate .

I the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and I contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must be demonstrated.

I LAWRENCE COUNTY: June 26, 2019, EMA Staff and EOC Support Staff will be pre-positioned at 8:30 a.m. at the Lawrence County EOC, located at 555 Walnut Street, I Al.

The call out process for additional support staff will be discussed with demonstration of Rapid Cast System.

I I

123 I I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Critical Task: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible (NUREG-0654 A. l .d; A.2.a, b; A.3; C.4, 6; Criterion lcl). Pg. 181. I Performance Measure: (1) Leadership personnel must demonstrate the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed through I periodic briefings and/or other means, coordinating with other OROs, and ensuring completion of requirements and requests.) (2) Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement resources (e.g., through MOUs or other agreements) when faced I with competing demands for finite resources. Any resources identified through LOA/MOUs must be on the ORO's mobilization list so they may be contacted during an incident if needed.

I LAWRENCE COUNTY: Lawrence County EMA will demonstrate direction and control in the EOC, scenario dependent on June 26, 2019.

I Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

I Performance Measure: (1) 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. (2)

I For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3) At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be I

available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c)

I members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage I

locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct read and permanent-record dosimeters in sufficient I

quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained I

in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. (10) A label indicating such calibration must be on each I

instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it I

is response-checked using a standard test source. (12) In areas where portal monitors are used, I

I 124 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to I the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I LAWRENCE COUNTY: EMA will demonstrate use of equipment, maps, displays and other supplies in the BOC scenario dependent on June 26, 2019. KI will be reviewed on I May 8, 2019 at the Lawrence County Health Department 13299 Alabama Highway 157 Moulton, Al 35650. Equipment will be reviewed on May 14, 2019 at the Lawrence County BOC 555 Walnut Street Moulton, Al 35650.

I Critical Task: OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to EWs in accordance with the plans/procedures. EWs periodically and at the end of I each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to EWs (NUREG-0654 J.10.e, K.3.a, b, K.4; Criterion 3al).Pg. 189 190.

I Performance Measures: (1) OROs must demonstrate the capability to provide emergency workers (including supplemental resources)'With the appropriate direct-reading and permanent-I 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 I 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.

(2) Each emergency worker must have basic knowledge of radiation exposure limits as specified I in the ORO's plans/ procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control. (3) During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. (4) 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. (5) If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to I determine their knowledge. (6) 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 I to each other during the entire mission and can share a direct-read dosimeter. Each team member must still have and maintain his or her own permanent-record dosimetry. (7) OROs must ensure that the process used to seek authorization for exceeding dose limits does not I negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property may require an urgent response. (8) OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs I must have the capability to develop and maintain lists of emergency workers who have ingested I

125 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Kl, including documentation of the date(s) and time(s) they did so. (9) Emergency workers must demonstrate basic knowledge of procedures for using Kl. If exercise play does not require emergency workers to consume Kl, evaluators must interview at least two workers to determine I their knowledge.

LAWRENCE COUNTY: Emergency Workers will discuss exposure control, out of I

sequence, on May 14, 2019 at the EOC. The Radiological Officer issues dosimetry from the Emergency Worker Station at the Lawrence County EOC.

I Critical Task: Kl and appropriate instructions are available if a decision to recommend use of Kl is made. Appropriate record-keeping of the administration of Kl for institutionalized individuals and the general public is maintained (NUREG-0654 J.10.e, f; Criterion 3bl). Pg. 190 I

Performance Measures: ( 1) OROs must demonstrate the capability to make Kl available to institutionalized individuals and, where provided for in their plans/procedures, to members of the general public. (2) OROs must demonstrate the capability to accomplish distribution of Kl I

consistent with decisions made. (3) OROs must have the capability to develop and maintainlists of institutionalized individuals who have ingested Kl, including documentation of the date(s) and time(s) they were instructed to ingest Kl. OROs must demonstrate the capability to formulate and I

disseminate instructions on using Kl for those advised to take it. (4) If a recommendation is made for the general public to take Kl, appropriate information must be provided to the public by the means of notification specified in the ORO's plans/ procedures.

I LAWRENCE COUNTY: Demonstration will be performed by a Health Department representative, out of sequence at the Moulton Recreation Center 13550 Court Street I

Moulton, Al 35650 on May 14, 2019.

This will be discussed, scenario dependent, during the exercise scenario dependent. I Critical Task: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel (NUREG-0654 A.3; C.l, 4; J.10.g,j; Criterion 3dl) Pg. 191-192.

I Performance Measures: (1) OROs must demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with current conditions and PADs I

(e.g., evacuating, sheltering, and relocation) in a timely manner. (2) 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 I

area(s) where access is controlled. (2) Traffic and access control staff must demonstrate accurate knowledge of their roles and responsibilities, including verifying emergency worker I identification and access authorization to the affected areas. (3) In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic),

they must demonstrate the capability to contact the State or Federal agencies that have the I needed authority.

I I

126

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I LAWRENCE COUNTY: The Lawrence County Sheriff's Department will discuss traffic and access control during the out of sequence May 24, 2019 at the EOC. Actual demonstration will not be performed. Lawrence County Water Rescue Unit will discuss I and demonstrate river traffic and access control during the out of sequence on May 14, 2019.

I Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; Criterion 3d2). Pg. 192.

I Performance Measures: (1) OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. (2) The impediment must remain in place during the evacuation long enough that re-routing of traffic is required and (3) must also I result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

I LAWRENCE COUNTY: The Lawrence County Sheriff's Department will discuss Impediments to evacuation during the out of sequence May 24, 2019 at the EOC. Actual demonstration will not be performed.

I Core Capability: Situational Assessment I Definition: Provide all decision makers with decision-relevant information regarding the nature and extent of the hazard, any cascading effects, and the status of the response.

I Critical Task: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers, including provisions to authorize radiation exposure in excess of I administrative limits or protective action guides. (NUREG-0654/FEMA REP-1, C.6; f; K.3.a; K.4; Criterion 2.al). Pg. 184.

I Performance Measures: (1) OROs authorized to send emergency workers into the plume exposure pathway EPZ must demonstrate a capability to comply with emergency worker I exposure limits based on their emergency plans/procedures. (2) OROs must also demonstrate the capability to make decisions concerning authorization of exposure levels in excess of pre-authorized levels and the number of emergency workers receiving radiation I doses above pre-authorized levels. (3) This would include providing KI and dosimetry in a timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating actions, in accordance with respective plans/procedures.

I LAWREN CE COUNTY: This will be discussed during the exercise, scenario dependent.

I I

127 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Critical Task: Appropriate protective action recommendations (PARs) are based on available I

information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA- I REP-1, I.10 and Supplement 3; Criterion 2.b.l) Pg. 184-185.

Performance Measures: (1) The ORO must demonstrate the capability to use the appropriate I means described in the plans/procedures to develop PARs for decision-makers based on available information and recommendations provided by the licensee, as well as field monitoring data if available. Workers must also consider any release and meteorological data provided by I

the licensee. (2) 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, I

calculation of projected dose must be demonstrated. Projected doses must be related to quantities and units of the PAG to which they will be compared. (3) PARs must be promptly transmitted to decision-makers in a prearranged format. (4) When the licensee and ORO I

projected doses differ by more than a factor of 10, the ORO and licensee must determine the source of the difference by discussing input data and assumptions, using different models, or exploring possible reasons. Resolution of these differences must be incorporated into the PARs I

if timely and appropriate. (5) The ORO must demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated PARs. I LAWREN CE COUNTY: This will be discussed during the exercise, scenario dependent. I Critical Task: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make P ADs 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; I

D.4; J.9; J.10.e.f, m; Criterion 2.b.2). Pg. 185.

Performance Measures: (1) OROs must have the capability to make both initial and I

subsequent precautionary and/or protective action decisions in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO I

authorities (e.g., incident command), and PARs from the utility and ORO staff. (2) In addition, a subsequent or alternate precautionary and/or protective action decision may be appropriate if various conditions (e.g., an HAB incident, weather, release timing and magnitude) pose undue I

risk to an evacuation or if evacuation may disrupt the efforts to respond to a hostile action. (3)

OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a precautionary and/or protective action decision if local law enforcement, fire I

service, HAZMAT, and emergency medical resources are used to augment response to the NPP site or other key infrastructure. (4) If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must I

demonstrate the capability to make decisions on the distribution and administration of KI to supplement sheltering and evacuation. This decision must be based on the ORO' s plans/procedures or projected thyroid dose compared with the established P AG for KI I

I 128 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant administration. The KI decision-making process must involve close coordination with I appropriate assessment and decision-making staff. (5) If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate precautionary and/or protective action decisions with each other. (6) In addition, decisions must be I coordinated/communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

I LAWREN CE COUNTY: This will be discussed during the exercise, scenario dependent.

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

186 I Performance Measures: 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 I high- risk environmental condition or where high-risk groups (e.g., the immobile or infirm) are involved. (1) In these cases, factors that must be considered include weather conditions, shelter availability, availability of transportation assets, risk of evacuation versus risk from the avoided I dose, and precautionary school evacuations. In addition, decisions must be coordinated/communicated with the incident command. In situations where an institutionalized population cannot be evacuated, the ORO must consider use of KI. (2) OROs must demonstrate I the capability to alert and notify all public school systems/districts of emergency conditions that are expected to or may necessitate protective actions for students. Demonstration requires that the OROs actually contact public school systems/districts during the exercise. (3) OROs must I demonstrate how the decision-making process takes those with disabilities and access/functional needs (e.g., nursing homes, correctional facilities, licensed day cares, mobility-impaired individuals, and transportation-dependent individuals) into account.

I LAWRENCE COUNTY: This will be discussed during the exercise, scenario dependent.

I Core Capability: Operational Communications I Definition: Establish and maintain a unified and coordinated operational structure and process that appropriately integrates all critical stakeholders and supports the execution of core capabilities.

I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and I communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 I F.1, 2; Criterion ldl). Pg. 180.

I 129 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measure: OROs must demonstrate that a primary system and at least one I

backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to I

manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) *OROs must ensure that a coordinated I communication link for fixed and mobile medical support facilities exists.

LAWREN CE COUNTY: Communications systems will be demonstrated, scenario I dependent, The TV A ECNS is the primary means of communications. Southern Linc (Critical Linc), telephones and fax machines will serve as secondary communications.

I Core Capability: Public Information and Warning Definition: Deliver coordinated, prompt, reliable, and actionable information to the whole I

community through the use of clear, consistent, accessible, and culturally and linguistically appropriate methods to effectively relay information regarding any threat or hazard and, as appropriate, the actions being taken and the assistance being made available.

I Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 Al.a, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; I

G.3.a; H.3, 4; Criterion lal). Pg. 180.

Performance Measure: (1) OROs must demonstrate the capability to receive notification of an .

I incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key emergency personnel in a timely manner, (4) Responders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management I

organizations of an incident in a timely manner when they receive information. (5)

Demonstrate the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation of facilities for immediate use by mobilized persorinel upon their I

arrival. (7) The location and contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must.

I be demonstrated.

LAWRENCE COUNTY: June 26, 2019, EMA Staffand BOC Support Staff will be I

pre-positioned at 8:30 a.m. at the Lawrence County BOC, located at 555 Walnut Street, Al.

The call out process for additional support staff will be discussed with no actual I

demonstration performed. Responders are notified by 911 paging system.

I I

I 130 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Critical Task: At least 2 communications systems are available, at least 1 operates properly, and I communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 F.1, 2; Criterion ldl). Pg. 180.

I Performance Measure: OROs must demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, FMTs, and incident command must have the I capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might I disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

I LAWRENCE COUNTY: Communications systems will be demonstrated, scenario dependent. The PIO phone at the JIC will be the primary means of communications with the JIC. Southern Linc (Critical Linc), mobile phone, email and fax machine will serve I as secondary communications.

Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other I supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

I Performance Measure: (1) 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. (2)

For non-facility-based operations, the equipment and supplies must be sufficient and consistent I with the assigned operational role. (3) At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI I sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) members of the general public, (5) The plans/procedures must include the forms to be used for I documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in I the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct read and permanent-record dosimeters in sufficient I quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained I in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. ( 10) A label indicating such calibration must be on each I instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it I

131 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for I Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I LAWREN CE COUNTY: Appropriate information and supplies for public information, including a Smart Book, for use by the PIO at the JIC, will be available. This will be accomplished during the exercise, scenario dependent.

I Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; Criterion 3d2). Pg. 192.

I Performance Measures: (1) OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. (2) The impediment must remain in I

place during the evacuation long enough that re-routing of traffic is required and (3) must also result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

I LAWREN CE COUNTY: The PIO located at the Lawrence County BOC will communicate to the JIC any impediments to evacuation. Should impediments to I

evacuation be identified this information will be disseminated to the public. This will be accomplished during the exercise scenario dependent. I Critical Task: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initial instructional message to the I

public must include as a minimum the elements required by current FEMA REP Guidance (Timely: The responsible ORO personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay) (NUREG-I 0654 E.5, 6, 7; Criterion Sal). Pg. 198-199.

Performance Measure: (1) Responsible OROs must demonstrate the capability to sequentially I

provide an alert signal followed by an initial instructional message to populated areas throughout the 10-mile plume exposure pathway EPZ. Following the decision to activate the alert and notification system, (2) OROs must complete system activation for primary alert/notification and I

disseminate the information/instructions in a timely manner. For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." (3) Procedures to broadcast the I message must be fully demonstrated as they would in an actual emergency up to the point of transmission. Broadcast of the message(s) or test message(s) is not required. The procedures must be demonstrated up to the point of actual activation. The alert signal activation should be I simulated, not performed. Evaluations of BAS broadcast stations may also be accomplished through SAVs. (4) 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 I personnel from the primary notification system, including verification of provisions for backup I

132 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant power or an alternate station. (5) The initial message must include at a minimum the following I

• elements:

(a) Identification of the ORO responsible and the official with authority for providing the alert signal and instructional message; I *

(b) Identification of the commercial NPP and a statement that an emergency exists there; (c) Reference to REP-specific emergency information (e.g., brochures, calendars, and/or information in telephone books) for use by the general public during an emergency; and I * (d) A closing statement asking that the affected and potentially affected population stay tuned for additional information, or that the population tune to another station for additional information.

(6) If route alerting is demonstrated as a primary method of alert and notification, it must be done I in accordance with the ORO's plans/procedures. 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)

I must vary from exercise to exercise. However, the most difficult route(s) must be demonstrated no less than once every eight years. (7) All alert and notification activities along the route(s) must be simulated (i.e., the message that would actually be used is read for the evaluator, but not I actually broadcast. (8) Actual testing of the mobile public address system will be conducted at an agreed-upon location.

I LAWREN CE COUNTY: PNS coordination will be done via the ECNS and led by Madison County EMA. The first siren activation will be demonstrated up to the point of activation, scenario dependent. Subsequent activations will be simulated, scenario I I dependent. The BFNPP counties have developed unified EAS and Special News Broadcast messages and distributed to the National Weather Service Office in Huntsville (NWS). Madison County EMA will coordinate the EAS/SNB messages with the BFNPP I counties via the ECNS and designate to (NWS) via land line phone or Southern Linc, which message to distribute. EAS message distribution will be the responsibility of the (NWS), and simulated for this exercise.

I Critical Task: Waterway warning/ 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 E.6; Appendix 3.B.2.c; Criterion 5a3). Pg. 199.

Performance Measure: (1) Backup alert and notification procedures that would be implemented in multiple stages must be structured such that the population closest to the plant (e.g., within 2 miles) is alerted and notified first. The populations farther away and downwind of I any potential radiological release would be covered sequentially (e.g., 2 to 5 miles, followed by downwind 5 to 10 miles, and finally the remaining population as directed by authorities). (2)

Although circumstances may not allow this for all situations, FEMA and the NRC recommend I that OROs and operators attempt to establish backup means that will reach those in the plume exposure pathway EPZ within a reasonable time of failure of the primary alert and notification system, with a recommended goal of 45 minutes. (3) The backup alert message must, at a I minimum, include: (a) a statement that an emergency exists at the plant and (b) instructions regarding where to obtain additional information. When backup route alerting is demonstrated, only one route needs to be selected and demonstrated. All alert and notification activities along I

133 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

the route(s) must be simulated (i.e., the message that would actually be used is read for the evaluator, but not actually broadcast), as negotiated in the extent of play. (4) Actual testing of the mobile public address system will be conducted at an agreed-upon location. I LAWRENCE COUNTY: The Lawrence County Sheriff's Department will discuss and demonstrate back-up alert route out of sequence May 24, 2019.

I Critical Task: Ensure OROs provide accurate emergency information and instructions to the public and the news media in a timely manner (The responsible ORO personnel/representatives I

demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay) (NUREG-0654 E.5, 7; G.3.a; G.4.a, c; Criterion 5bl). Pg.

200-201.

I Performance Measure: (1) The responsible ORO personnel/representatives must demonstrate actions to provide emergency information and instructions to the public and media in a timely I

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."

Message elements: (2) The ORO must ensure that emergency information and instructions are I

consistent with PADs made by appropriate officials. (3) The emergency information must contain all necessary and applicable instructions (e.g., evacuation,instructions, evacuation routes, reception center locations, what to take when evacuating, shelter-in-place instructions, I

information concerning protective actions for schools and persons with disabilities and access/functional needs, and public inquiry hotline telephone number) to assist the public in carrying out the P ADs provided. (4) The ORO must also be prepared to disclose and explain the I

ECL of the incident. At a minimum, this information must be included in media briefings and/or media releases. (5) OROs must demonstrate the capability to use languag_e that is clear and understandable to the public within both the plume and ingestion exposure pathway EPZs. (6)

I This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas. (7) The emergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5.a.1 and previously I

identified protective action areas that are still valid, as well as new areas. (8) Information about any rerouting of evacuation routes due to impediments should also be included. (9) The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is I

rescinded and not repeated by broadcast media. (10) OROs must demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures. (11) OROs must demonstrate the capability to develop emergency I

information in a non-English language when required by the plans/procedures. (12) If ingestion exposure pathway measures are required, OROs must demonstrate that a system exists for rapid dissemination of ingestion exposure pathway information to predetermined individuals and businesses. Media information: (13) OROs must demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination I to the public. (14) This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the incident warrants. (15) The OROs must demonstrate the capability to respond appropriately to inquiries from the news media. (16) I All information presented in media briefings and releases must be consistent with P ADs and I

134 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant other emergency information provided to the public. (17).Copies of pertinent emergency I information (e.g., EAS messages and media releases) and media information kits must be available for dissemination to the media. Public Inquiry (18) OROs must demonstrate that an effective system is in place for dealing with calls received via the public inquiry hotline. (19)

I Hotline staff must demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate information source. (20) Information from the hotline staff, including information that corrects false or inaccurate information when trends are noted, I must be included, as appropriate, in emergency information provided to the public, media briefings, and/or media releases. HAB considerations: (21) The dissemination of information

• dealing with specific aspects of NPP security capabilities, actual or perceived adversarial I (terrorist) force or threat, and tactical law enforcement response must be coordinated/

communicated with appropriate security authorities (e.g., law enforcement and NPP security agencies) in accordance with ORO Pans/procedures.

I LAWREN CE COUNTY: The BFNPP counties have developed unified EAS and Special News Broadcast messages and distributed to the National Weather Service Office I in Huntsville (NWS). Madison County EMA will coordinate the EAS/SNB messages with the BFNPP counties via the ECNS and designate to (NWS) via Southern Linc or land line phone which message to distribute. EAS message distribution will be the I responsibility of (NWS) and simulated for this exercise. (Scenario dependent). Lawrence County will develop and issue county specific messages.

I Core Capability: Environmental Response/Health and Safety Definition: Conduct appropriate measures to ensure the protection of the health and safety of I the public and workers, as well as the environment, from all-hazards in support of responder operations and the affected communities I Critical Task: OROs use.effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654A.l.a, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; G.a.3; H.3, 4; Criterion lal). Pg. 180.

I Performance Measure: (1) OROs must demonstrate the capability to receive notification of an incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key emergency personnel in a timely manner, (4) Responders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management I organizations of an incident in a timely manner when they receive information. (5) Demonstrate the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and I contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must be demonstrated.

I I

135 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

LAWRENCE COUNTY: June 26, 2019, EMA Staff and EOC Support Staff will be pre-positioned at 8:30 a.m. atthe Lawrence County EOC, located at 555 Walnut Street, Al. I The call out process for additional support staff will be discussed with a demonstration of the Rapid Cast System.

I Critical Task: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible (NUREG-0654 A.1.d; A.2.a, b; A.3; C.4, 6; Criterion lcl). Pg. 181. I Performance Measure: (1) Leadership personnel must demonstrate the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed through I

periodic briefings and/or other means, coordinating with other OROs, and ensuring completion of requirements and requests.) (2) Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement resources (e.g., through MOUs or other agreements) when faced I

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 incidentif needed.

I LAWREN CE COUNTY: Demonstration of direction and control will be performed according to plans and procedures, scenario dependent. I Critical Task: At least 2 communications systems are available, at least 1 openttes properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 I

F.1, 2; Criterion ldl). Pg. 181.

Performance Measure: OROs must demonstrate that a primary system and at least one backup I

system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the I

communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists. ,

I LAWRENCE COUNTY: Communications systems will be demonstrated, scenario dependent. The TVA ECNS is the primary means of communications with AEMA.

I Southern Linc, mobile phones, landline phones, two-way radio and HAM radio will serve as secondary communications with field units and other facilities. I Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

I I

I 136 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measure: (1) A particular facility's equipment and supplies must be sufficient I and consistent with that facility's assigned role in the ORO's emergency operations plans. (2)

For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3)At locations where traffic and access control personnel are I deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or I specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage I location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability I to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an I individual(s) to read the administrative reporting limits and maximum exposure limits contained*

in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the I manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings I documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to I the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I LAWRENCE COUNTY: An adequate supply of thermos-luminescent dosimeters (TLDs) and dosimetry will be available for the emergency workers. This will be I discussed out of sequence at the Lawrence County EOC on May 14, 2019.

of The supply of KI will be viewed out sequence, at the Lawrence County Health I Department, located at 13299 Alabama Highway 157 Moulton, Al 35650 on May 08, 2019.

I Critical Task: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in I place for EWs including provisions to authorize radiation exposure in excess of administrative limits or PAGs (NUREG-0654 C.6.f; K.4 Criterion 2al). Pg. 185.

I I

137 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Performance Measure: (1) 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. (2) OROs must also demonstrate the I 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. (3) This would include providing KI and dosimetry in a timely manner to I emergency workers dispatched onsite to support plant incident assessment and mitigating actions, in accordance with respective plans/procedures.

I LAWRENCE COUNTY: This will be discussed during the exercise, scenario dependent.

I Critical Task: Appropriate protective action recommendations (PARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA-I REP-1, 1.10 and Supplement 3; Criterion 2.b.l) Pg. 184-185.

Performance Measures: (1) The ORO must demonstrate the capability to use the appropriate I

means described in the plans/procedures to develop PARs for decision-makers based on available information and recommendations provided by the licensee, as well as field monitoring data if available. Workers must also consider any release and meteorological data provided by I

the licensee. (2) The ORO must demonstrate a reliable capability to independently validate dose projections. The types of calculations to be demonstrated depend on the data available and the need for assessments to support the PARs must be appropriate to the scenario. In all cases, I

calculation of projected dose must be demonstrated. Projected doses must be related to quantities and units of the PAG to which they will be compared. (3) PARs must be promptly transmitted to decision-makers in a prearranged format. (4) When the licensee and ORO I

projected doses differ by more than a factor of 10, the ORO and licensee must determine the source of the difference by discussing input data and assumptions, using different models, or exploring possible reasons. Resolution of these differences must be incorporated into the P ARs I

if timely and appropriate. (5) The ORO must demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated P ARs. I LAWREN CE COUNTY: This will be discussed during the exercise, scenario dependent.

Critical Task: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make P ADs for the general public (including the recommendation for the use of Kl, if ORO policy) (NUREG-0654/ FEMA REP-1, A.3; C.4, 6; D.4; J.9; J.10.e.f, m; Criterion 2.b.2). Pg. 185.

I I

I 138 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measures: (1) OROs must have the capability to make both initial and subsequent I precautionary and/or protective action decisions in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO I authorities (e.g., incident command), and PARs from the utility and ORO staff. (2) In addition, a subsequent or alternate precautionary and/or protective action decision may be appropriate if various conditions (e.g., an HAB incident, weather, release timing and magnitude) pose undue risk I . to an evacuation or if evacuation may disrupt the efforts to respond to a hostile action. (3) OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a precautionary and/or protective action decision if local law enforcement, fire service, I HAZMAT, and emergency medical resources are used to augment response to the NPP site or other key infrastructure. (4) If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must demonstrate the I capability to make decisions on the distribution and administration of KI to supplement sheltering and evacuation. This decision must be based on the ORO's plans/procedures or projected thyroid dose compared with the established PAG for KI administration. The KI decision-making process I must involve close coordination with appropriate assessment and decision-making staff. (5) If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate precautionary and/or protective action decisions with each other. (6) In addition, I decisions must be coordinated/ communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

I LAWRENCE COUNTY: This will be discussed during the exercise, scenario dependent.

I Critical Task: OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to EWs in accordance with the plans/procedures. EWs periodically and at the end of

,I each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to EWs (NUREG-0654 K.3.a, b, K.4; Criterion 3al). Pg. 189.

I Performance Measures: (1) 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 I 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 I emergency workers involved in lifesaving activities, contained in the ORO's plans/procedures.

(2) Each emergency worker must have basic knowledge of radiation exposure limits as specified I in the ORO's plans/ procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage I radiological exposure control. (3) During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. (4) OROs must demonstrate the actions described in the plans/procedures by I

139 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

determining whether to replace the worker, authorize the worker to incur additional exposures, or take other actions. (5) If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to I determine their knowledge. (6) 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 and can share a direct read dosimeter. Each team member I must still have and maintain his or her own permanent-record dosimetry. (7) OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property I

may require an urgent response. (8) OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including I

documentation of the date(s) and time(s) they did so. (9) Emergency workers must demonstrate basic knowledge of procedures for using KI. If exercise play does not require emergency workers to consume KI, evaluators must interview at least two workers to determine their I

knowledge.

LAWRENCE COUNTY: Emergency workers will discuss exposure control, out of I

sequence, on May 14, 2019 at the EOC.

Critical Task: Kl and appropriate instructions are made available in case a decision to I

recommend use of KI is made. Appropriate record keeping of the administration of KI for institutionalized individuals and the general public is maintained (NUREG-0654 J.10.e, f; Criterion 3bl). Pg. 190.

I Performance Measures: (1) OROs must demonstrate the capability to make KI available to institutionalized individuals and, where provided for in their plans/procedures, to members of the I

general public. (2) OROs must deinonstrate the capability to accomplish distribution of KI consistent with decisions made. (3) OROs must have the capability to develop and maintain lists of institutionalized individuals who have ingested KI, including documentation of the date(s) and I

time(s) they were instructed to ingest KI. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it. (4) If a recommendation is made for the general public to take KI, appropriate information must be provided to the public by I

the means of notification specified in the ORO's plans/ procedures.

LAWRENCE COUNTY: This will be discussed with a Health Department I

representative, out of sequence, at Lawrence County EOC on May 14, 2019.

Critical Task: The reception center facility has appropriate space, adequate resources, and I

trained personnel to provide monitoring, decontamination, and registration of evacuees (NUREG-0654 A.3; C.4; J.10.h; J.12; Criterion 6al). Pg. 202-203. I I

I 140 I

I Radiological Emergency Preparedness Program After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measure: ( 1) Radiological monitoring, decontamination, and registration I facilities for evacuees must be set up and demonstrated as they would be in an actual emergency.

(2) OROs conducting this demonstration must have (a) one-third of the resources (e.g.,

monitoring teams/instrumentation/portal monitors) .available at the facility (ies) as necessary to I monitor (b) 20 percent of the population within a 12-hour period;* (c) This would include adequate space for evacuees' vehicles. (2) Availability of resources can be demonstrated with valid documentation (e.g., MOU/LOA, etc.) reflecting how necessary equipment would be I procured for the location. (3) Plans/procedures must indicate provisions for service animals. (4)

Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. (5) Staff responsible for the radiological monitoring of I 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. (6) The monitoring productivity rate per hour is the number of evacuees that can be I monitored, per hour, by the total complement of monitors using an appropriate procedure. (7)

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 I plans/ procedures. (8) 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. (9) OROs must demonstrate the capability to register evacuees upon completion of I the monitoring and decontamination activities. (10) The activities for recording radiological monitoring and, if necessary, decontamination must include establishing a registration record consisting of the (a) evacuee's name, (b) address, (c) results of monitoring, and(d) time of I decontamination (if any), or as otherwise designated*in the plan 'and/or procedures. Audio recorders, camcorders, or written records are all acceptable means for registration. ( 11)

Monitoring activities shall not be simulated. (12) Monitoring personnel must explain use of I trigger/action levels for determining the need for decontamination. (13) They must also explain the procedures for referring any evacuees who cannot be adequately decontaminated for assessment and follow-up inaccordance with the ORO's plans/procedures. All activities must be I based on the ORO's plans/procedures and completed as they would be in an actual emergency.

Decontamination of evacuees may be simulated and conducted by interview. (14) Provisions for separate showering and same-sex decontamination must be demonstrated or explained. (15) The I 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. (16) Provisions must also exist to I (a) separate contaminated and uncontaminated evacuees, (b) provide changes of clothing for those with contaminated clothing, and (c) store contaminated clothing and personal belongings to I prevent further contamination of evacuees or facilities. (17) In addition, for any evacuee found .

to be contaminated, procedures must be discussed concerning handling of potential contamination of vehicles and personal belongings. Waste water from decontamination I operations does not need to be collected. (18) Individuals who have completed monitoring and.

decontamination if needed, must have the means (e.g., hand stamp, sticker, bracelet, form, etc.)

indicating that (a) they, and their service animals and vehicles, where applicable, have been I 1. monitored, cleared, and fourid to have no contamination or (b) contamination below the trigger/action level or (c) have been placed in a secure area until they can be monitored and decontaminated, if necessary. In accordance with plans/procedures, individuals found to be clean I

141 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant after monitoring do not need to have their vehicle monitored. These individuals do not require I

confirmation that their vehicle is free from contamination prior to entering the congregate care areas. (19) However, those individuals who are found to be contaminated and are then I decontaminated will have their vehicles (a) held in a secure area or (b) monitored and decontaminated (if applicable) and do require confirmation that their vehicle is being (c) held in a secure area or (d) free from contamination prior to entering the congregate care areas. I LAWRENCE COUNTY: Monitoring, decontamination and registration of evacuees will be demonstrated, out of sequence, at the Reception Center at Moulton Recreation I Center, located at 13550 Court Street Moulton, Al 35650 on May 14, 2019. Protective clothing for emergency workers/evacuees will not be issued and actual decon will be simulated. Since male and female decon is mirrored, only one decon will be I demonstrated. Lawrence County will not demonstrate monitoring, decon andregistration during the exerci.se on June 26, 2019.

I Critical Task: The facility/ORO has adequate procedures and resources to accomplish monitoring and decontamination of emergency workers and their equipment and vehicles (NUREG-0654 K.5.a, b; Criterion 6bl). Pg. 203-204.

I Performance Measure: (1) The monitoring staff inust demonstrate the capability to monitor emergency worker personnel and their equipment and vehicles for contamination in accordance I

with the ORO's plans/procedures. Specific attention must be given to equipment, including any vehicles that were in contact with contamination. (2) The monitoring staff must demonstrate the capability to make decisions on the need for decontamination of personnel, equipment, and I

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. (3) However, appropriate monitoring procedures must be demonstrated for a minimum of two emergency I

workers and their equipment and vehicles. (4) Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for*proper operation: (5)

The area to be used for monitoring and decontamination must be set up as it would be in an I

actual emergency, with all route markings, instrumentation, record keeping, and contamination control measures in place. (6) Monitoring procedures must be demonstrated for a minimum of one vehicle. It is generally not necessary to monitor the entire surface of vehicles. (7) However, I

the capability to monitor areas such as radiator grills, bumpers, wheel wells, tires, and door handles must be demonstrated. (8) Interior surfaces of vehicles that were in contact with contaminated individuals must also be checked. Decontamination of emergency workers may be I

simulated and conducted via interview. (9) Provisions for separate showering and same-sex decontamination must be demonstrated or explained. (10) The staff must demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs, and I

appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. ( 11) Provisions must also exist to separate contaminated and uncontaminated individuals where applicable, provide changes of clothing for those with I

contaminated clothing, and store contaminated clothing and personal belongings to prevent further contamination of emergency workers or facilities *. (12) OROs must demonstrate the capability to register emergency workers upon completion of the monitoring and I

I 142 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant decontamination activities. The activities for recording radiological monitoring and if necessary, I decontamination must include establishing a registration record consisting of the (a) emergency worker's name, (b) address, (c) results of monitoring, and (d) time of decontamination (if any),

or as otherwise designated in the plans/procedures. Audio recorders, camcorders, or written I records are all acceptable means for registration. Monitoring activities shall not be simulated.

(13) Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. (14) They must also explain the procedures for referring any emergency I workers who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures Decontamination capabilities and provisions for vehicles and equipment that cannot be successfully decontaminated may be simulated and conducted by I interview. Waste water from decontamination operations does not need to be collected.

LAWREN CE COUNTY: Monitoring and decontamination of emergency workers will I be demonstrated, out of sequence, at the Reception Center at Moulton Recreation Center, located at 13550 Court Street Moulton, Al 35650 on May 14, 2019. Protective clothing -

for emergency workers will not be issued and actual decon will be simulated. Since male I and female decon is_ mirrored; only one decon will be demonstrated. Lawrence County will not demonstrate monitoring, decon and registration during the exercise on June 26, 2019.

I Vehicle monitoring and decontamination will be demonstrated, out of sequence on May -

14, 2019.

I Core Capability: On-Scene Security, Protection, and Law Enforcement (TCP's/Waterway Warning)

I Definition: Ensure a safe and secure environment through law enforcement and related security and protection operations for people and communities located within affected areas and also for I response personnel engaged in lifesaving and life-sustaining operations.

Critical Task: At least 2 communications systems are available, at l~ast 1 operates properly, a11d I communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 I F.1, 2; Criterion ldl). Pg. 180.

Performance Measure: OROs must demonstrate that a primary system and at least one backup I system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the I communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

I I

143 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

LAWRENCE COUNTY: A representative from the Lawrence County Sheriff's Office will discuss communications, out of sequence, on May 14, 2019 at the Lawrence County BOC. I Critical Task: Equipment (to include communications), maps, displays, monitoring instruments, dosimetry, KI, and other supplies are*sufficient to support emergency operations (NUREG-0654 I H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

Performance Measure: (1) A particular facility's equipment and supplies must be sufficient I

and consistent with that facility's assigned role in the ORO's emergency operations plans. (2)

For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3)At locations where traffic and access control personnel are I

deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or I

specialized response teams (e.g., civirnews media) (b) institutionalized individuals and (c) members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage I

location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability I

to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an I

individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the I

manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings I

documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to I

the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I LAWRENCE COUNTY: Thermoluminescent dosimeters (TLDs) and dosimetry will be distributed to available emergency workers at the Lawrence County BOC, out of I

sequence, on May 14, 2019.

I I

I 144 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Critical Task: OROs issue appropriate dosimetry, KI, and procedures, and manage radiological I exposure to EWs in accordance with the plans/procedures. EWs periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OR Os maintain appropriate record-keeping of the administration of KI to EW s (NUREG-I 0654 K.3.a, b, K.4; Criterion 3al). Pg. 189.

Performance Measures: (1) OROs must demonstrate the capability to provide emergency I 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 I 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.

I (2) Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/ procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency I workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control. (3) During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back I values are reached. (4) 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. (5) If exercise play does not require emergency workers to seek I authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge. (6) 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 I to each other during the entire mission and can share a direct read dosimeter. Each team member must still have and maintain his or her own permanent-record dosimetry. (7) OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact I the capability to respond to an incident where lifesaving and/or protection of valuable property may require an urgent response. (8) OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OR Os must have the I capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. (9) Emergency workers must demonstrate basic knowledge of procedures for using KI. If exercise play does not require emergency I workers to consume KI, evaluators must interview at least two workers to determine their knowledge.

I LAWRENCE COUNTY: Emergency workers will discuss exposure control, out of sequence, on May 14, 2019 at the EOC.

I Critical Task: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel (NUREG-0654 A.3; C.1, 4; J.10.g,j; Criterion I 3dl). Pg. 191-192.

I 145 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Performance Measures: (1) OROs must demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with current conditions and P ADs (e.g., evacuating, sheltering, and relocation) in a timely manner. (2) OROs must demonstrate the I 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. (2) Traffic and access control staff must demonstrate accurate I

knowledge of their roles and responsibilities, including verifying emergency worker identification and access authorization to the affected areas. (3) In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic),

I they must demonstrate the capability to contact the State or Federal agencies that have the needed authority I

LAWRENCE COUNTY: A representative from the Lawrence County Sheriff's Office, will discuss traffic and access control, out of sequence, on May 14, 2019 at the Lawrence County BOC. Actual demonstration will not be performed.

I Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; Criterion 3d2). Pg. 192.

I Performance Measures: (1) OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. (2) The impediment must remain in I

place during the evacuation long enough that re-routing of traffic is required and (3) must also result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

I LAWRENCE COUNTY: A representative from the Lawrence County Sheriff's Office, will discuss impediments to evacuation, out of sequence, on May 14, 2019 at the I

Lawrence County BOC.

I I

I I

I I

I 146 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant BASE I EXTENT OF PLAY AGREEMENT 2019 Browns Ferry Nuclear Plant I Limestone County FULL PARTICIPATION RADIOLOGICAL EMERGENCY PREPAREDNESS I EXERCISE All activities will be demonstrated fully in accordance with respective plans and procedures* as I they would be in an actual emergency (FEMA must receive these plans, guides and procedures NLT 60 days before the exercise). This Extent of Play agreement is written by exception. If it is not listed as an exception it will be demonstrated as described in the plans, standard operating I guides (SOGs} and/or procedures (SOPs). Any issue or discrepancy arising during exercise play may be re-demonstrated, if allowed, by the RAC Chair or as listed herein. This allowance may be granted if it is not disruptive to exercise play and is mutually agreed to by the ORO controller I and FEMA evaluator.

• Core Capability: Operational Coordination I Definition: Establish and maintain a unified and coordinated operational structure and process that appropriately integrates all critical stakeholders.and supports the execution of core I capabilities.

Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel I and activate facilities in a timely manner (NUREG-0654 A.La, e; A:3, 4; C.1, 4, 6; DA; E.1, 2; G.3.a-i H.3, 4; Criterion lal). Pg. 180.

I Performance Measure: (1) OROs must demonstrate the capability to receive notification of an incident from the licensee; (2) verify the. notification, (3) contact, alert, and mobilize key emergency personnel in a timely manner, (4) Responders must demonstrate the ability to receive I and/or initiate notification to the licensees or other respective emergency management organizations of an incident in a timely manner when they receive information. (5) Demonstrate the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation I of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and contact information for facilities included in the incident command 1pust be available to all I appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must be demonstrated.

I LIMESTONE COUNTY: On June 26, 2019, EMA Staff and some of the EOC Support Staff will be pre-positioned at 8:00 a.m. at the Limestone County EOC, located at 1011 W. Market St., Athens~ AL. Additional EOC staff, public officials, and department heads I will be alerted, notified and mobilized according to the Browns Ferry Nuclear Plant Notification List.

I 147 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Critical Task: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible (NUREG-0654 A. l .d; I A.2.a, b; A.3; C.4, 6; Criterion lcl). Pg. 181.

Performance Measure: (1) Leadership personnel must demonstrate the ability to carry out the I 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.) (2) Leadership must demonstrate the ability to prioritize re~ource I

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

I LIMESTONE COUNTY: EMA will demonstrate direction and control in the BOC, scenario dependent.

I Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; 1.7, 8, 9; J.10.a, I

b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

• Performance Measure: (1) A particular facility's equipment and supplies must be sufficient I

and consistent with that facility's assigned role in the ORO's emergency operations plans.* (2)

For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3) At locations where traffic and access control personnel I

are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or I

specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage I

location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability

• I to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified.in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must alfow an I

individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the I

manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings I

documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source. (12) In areas where portal monitors are used, I the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to I

148 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for I Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I LIMESTONE COUNTY: EMA will demonstrate use of equipment, maps, displays and other supplies in the BOC, scenario dependent.

I Critical Task: OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to EWs in accordance with the plans/procedures. EWs periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or I chart. OROs maintain appropriate record-keeping of the administration of KI to EWs (NUREG-0654 J.10.e, K.3.a, b, K.4; Criterion 3al). Pg. 189 190.

• I Performance Measures: (1) 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 I 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 I emergency workers involved in lifesaving activities, contained in the ORO's plans/procedures. (2)

Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/ procedures. If supplemental resources are used, they must be provided with I just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control. (3) During a plume phase exercise, emergency workers must I demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. (4) 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 I take other actions. (5) If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge. (6) Although it is desirable for all emergency workers to each have a I direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission and can share a direct read dosimeter. Each team member I must still have and maintain his or her own permanent-record dosimetry. (7) OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property I may require an urgent response. (8) OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including I documentation of the date(s) and time(s) they did so. (9) Emergency workers must demonstrate basic knowledge of procedures for using KI. If exercise play does not require emergency workers to consume KI, evaluators must interview at least two workers to determine their I knowledge.

I 149 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

LIMESTONE COUNTY: Emergency workers will discuss exposure control, out of sequence, on May 15, 2019 at the EOC. The Radiological Officer issues dosimetry to the Emergency Worker at the EOC. I Critical Task: 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 I and the general public is maintained (NUREG-0654 J.10.e, f; Criterion 3bl). Pg. 190.

Performance Measures: (1) OROs must demonstrate the capability to make KI available to I

institutionalized individuals and, where provided for in their plans/procedures, to members of the general public. (2) OROs must demonstrate the capability to accomplish distribution of KI consistent with decisions made. (3) OROs must have the capability to develop and maintain lists I

of institutionalized individuals who have ingested KI, including documentation of the date(s) and

• time(s) they were instructed to ingest KI. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it. (4) If a recommendation is I

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. I LIMESTONE COUNTY: Demonstration will be performed by a Health Department representative, out of sequence, at Ardmore High School, located at 30285 Ardmore Ave., Ardmore, AL 35739, on May 15, 2019. This will be discussed, scenario dependent, I

during the exercise, up to the point of actual distribution.

Critical Task: Protective action decisions are implemented for persons with disabilities and I

access/functional needs other than schools within areas subject to protective actions (NUREG-0654 J.10.c, d, e, g; Criterion 3cl). Pg. 190 I Performance Measures: (1) Applicable OROs must demonstrate the capability to alert and notify (i.e., provide PARs and emergency information and instructions) to persons with disabilities and access/ functional needs, including hospitals/medical facilities, licensed day I

cares, nursing homes, correctional facilities, and mobility-impaired and transportation-dependent individuals. (2) OROs must demonstrate the capability to provide for persons with disabilities and access/functional needs.

I LIMESTONE COUNTY: This will be discussed with a Limestone County Council on Aging representative during the exercise, scenario dependent.

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

3dl) Pg. 191-192 I

I I

150 I i I

_J

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measures: (1) OROs must demonstrate the capability to select, establish, and I staff appropriate traffic and access control points consistent with current conditions and P ADs (e.g., evacuating, sheltering, and relocation) in a timely manner. (2) OROs must demonstrate the capability to provide instructions to traffic and access control staff on actions to take when I modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled. (2) Traffic and access control staff must demonstrate accurate knowledge of their roles and responsibilities, including verifying emergency worker .

I identification and access authorization to the affected areas. (3).In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic),

they must demonstrate the capability to contact the State or Federal agencies that have the I needed authority.

LIMESTONE COUNTY: The Limestone County Sheriff's Office will discuss traffic I and access control and a Rescue Squadrepresentative will discuss river access control, during the exercise at the EOC, scenario dependent. Actual demonstration will not be performed.

I Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; Criterion 3d2). Pg. 192 I Performance Measures: (1) OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. (2) The impediment must remain in 1* place during the evacuation long enough that re-routing of traffic is required and (3) must also result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

I LIMESTONE COUNTY:

The Limestone County Sheriff's Office will discuss impediments to evacuation, during I the exercise at the EOC, scenario dependent. Actual demonstration will not be performed.*

I Core Capability: Situational Assessment Definition: Provide all decision makers with decision-relevant information regarding the nature I and extent of the hazard, any cascading effects, and the status of the response.

I Critical Task: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for emergency workers, including provisions to authorize radiation exposure in excess of I administrative limits or protective action guides. (NUREG-0654/FEMA REP-1, C.6; f; K.3.a; K.4; Criterion 2.al). Pg. 184.

I I

151 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Performance Measures: (1) 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. (2) OROs must also I demonstrate the capability to make decisions concerning authorization of exposure levels in excess of pre-authorized levels and the number of emergency workers receiving radiation doses above pre-authorized levels. (3) This would include providing KI and dosimetry in a I timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating actions, in accordance with respective plans/procedures.

I LIMESTONE COUNTY: This will be discussed during the exercise, scenario dependent.

I Critical Task: Appropriate protective action recommendations (PARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA-I REP-1, I.10 and Supplement 3; Criterion 2.b.l) Pg. 184-185.

Performance Measures: (1) The ORO must demonstrate the capability to use the appropriate.

I means described in the plans/procedures to develop PARs for decision-makers based on available information and recommendations provided by the licensee, as well as field monitoring data if available. Workers must also consider any release and meteorological data provided by I

the licensee. (2) The ORO must demonstrate a reliable capability to independently validate dose projections. The types of calculations to be demonstrated depend on the data available and the need for assessments to support the PARs must be appropriate to the scenario. In all cases, I

calculation of projected dose must be demonstrated. Projected doses must be related to quantities and units of the PAG to which they will be compared. (3) PARs must be promptly transmitted to decision-makers in a prearranged format. (4) When the licensee and ORO I

projected doses differ by more than a factor of 10, the ORO and licensee must determine the source of the difference by discussing input data and assumptions, using different models, or .

exploring possible reasons. Resolution of these differences must be incorporated into the PARs I

if timely and appropriate. (5) The ORO must demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the_ associated PARs. I LIMESTONE COUNTY: This will be discussed during the exercise, scenario dependent. I Critical Task: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make PADs 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; I

D.4; J.9; J.10.e.f, m; Criterion 2.b.2). Pg. 185.

I I

I 152 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measures: (1) OROs must have the capability to make both initial and subsequent I precautionary and/or protective action decisions in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO I authorities (e.g., incident command), and PARs from the utility and ORO staff. (2) In addition, a subsequent or alternate precautionary and/or protective action decision may be appropriate if various conditions (e.g., an HAB incident, weather, release timing and magnitude) pose undue I risk to an evacuation or if evacuation may disrupt the efforts to respond to a hostile action. (3)

OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a precautionary and/or protective action decision if local law enforcement, fire I service, HAZMAT, and emergency medical resources are used to augment response to the NPP site or other key infrastructure. (4) If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must I demonstrate the capability to make decisions on the distribution and administration of KI to supplement sheltering and evacuation. This decision must be based on the ORO's plans/procedures or projected thyroid dose compared with the established P AG for KI I administration. The KI decision-making process must involve close coordination with appropriate assessment and decision-making staff. (5) If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate precautionary and/or I protective action decisions with each other. (6) In addition, decisions must be coordinated/communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

I LIMESTONE COUNTY: This will be discussed during the exercise, scenario dependent.

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

I 186.

Performance Measures: Usually it is appropriate to implement evacuation in areas where doses I are projected to exceed the lower end of the range of PAGs, except for incidents where there is a high- risk environmental condition or where high-risk groups (e.g., the immobile or infirm) are involved. (1) In these cases, factors that must be considered include weather conditions, shelter I availability, availability of transportation assets, risk of evacuation versus risk from the avoided dose, and precautionary school evacuations. In addition, decisions must be I coordinated/communicated with the incident command. In situations where an institutionalized population cannot be evacuated, the ORO must consider use of KI. (2) OR Os must demonstrate the capability to alert and notify all public school systems/districts of emergency conditions that are expected to or may necessitate protective actions for students. Demonstration requires that the OROs actually contact public school systems/districts during the exercise. (3) OROs must demonstrate how the decision-making process takes those with disabilities and access/functional I needs (e.g., nursing homes, correctional facilities, licensed day cares, mobility-impaired individuals, and transportation-dependent individuals) into account.

I 153 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

LIMESTONE COUNTY: This will be discussed during the exercise, scenario dependent.

I Core Capability: Operational Communications Definition: Establish and maintain a unified and coordinated operational structure and process I that appropriately integrates all critical stakeholders and supports the execution of core capabilities.

I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 I F.l, 2; Criterion ldl). Pg. 180.

Performance Measure: OROs must demonstrate that a primary system and at least one I

backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to I

manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

I LIMESTONE COUNTY:

Communications systems will be demonstrated, scenario dependent. The TV A ECNS is I

the primary means of communications. Southern Linc, telephones and fax machines will serve as secondary communications. I Core Capability: Public Information and Warning Definition: Deliver coordinated, prompt, reliable, and actionable information to the whole I

community through the use of clear, consistent, accessible, and culturally and linguistically appropriate methods to effectively relay information regarding any threat or hazard and, as appropriate, the actions being taken and the assistance being made available.

I Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 Al.a, e; A.3, 4; C.l, 4, 6; D.4; E.1, 2; I

G.3.a; H.3, 4; Criterion lal). Pg. 180.

Performance Measure: (1) OROs must demonstrate the capability to receive notification of an I

incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key emergency personnel in a timely manner, (4) Responders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management I

organizations of an incident in a timely manner when they receive information. (5)

Demonstrate the ability to maintain and staff 24-hour operations. (6) OROs must I demonstrate the activation of facilities for immediate use by mobilized personnel upon their I

154 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant arrival. (7) The location and contact information for facilities included in the incident I command must be available to all appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must be demonstrated.

I LIMESTONE COUNTY: EMA Staff and some BOC Support Staff will be pre-positioned at 8:00 a.m. at the Limestone County BOC. Public Information Support Staff I and JIC personnel will be alerted and mobilized according to the Browns Ferry Nuclear Plant Notification List.

I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 I F.l, 2; Criterion ldl). Pg. 180.

Performance Measure: OROs must demonstrate that a primary system and at least one I backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to I manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

I LIMESTONE COUNTY: Communications systems will be demonstrated, scenario dependent. The PIO phone at the JIC will be the primary means of communications with I the JIC. Southern Linc, telephones, email and fax machine will serve as secondary communications.

I Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

I Performance Measure: (1) A particular facility's equipment and supplies must be sufficient and I consistent with that facility's assigned role in the ORO' s emergency operations plans. (2) For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3) At locations where traffic and access control personnel are I deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or I specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage I location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability I

155 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient

.quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an I individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the I manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings I

documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to I

the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I LIMESTONE COUNTY: Appropriate information and supplies for public information, including a Smart Book, for use by the PIO at the JIC, will be available. This will be I

accomplished during the exercise, scenario dependent.

Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; I

Criterion 3d2). Pg. 192.

Performance Measures: (1) OROs must demonstrate the capability to identify and take I

appropriate actions concerning impediments to evacuations. (2) The impediment must remain in place during the evacuation long enough that re-routing of traffic is required and (3) must also result in demonstration of decision-making and coordination with the JIC to communicate the I

alternate route to evacuees.

LIMESTONE COUNTY: The PIO, located at the Limestone County EOC, will I

communicate to the JIC any impediments to evacuation. Should impediments to evacuation be identified, this information will be disseminated to the public. This will be accomplished during the exercise, scenario dependent.

I Critical Task: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency I

officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current FEMA REP Guidance (Timely: The responsible ORO personnel/representatives demonstrate actions to disseminate the I

appropriate information/instructions with a sense of urgency and without undue delay) (NUREG-0654 E.5, 6, 7; Criterion 5al). Pg. 198-199. I I

I 156 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measure: (1) Responsible OROs must demonstrate the capability to sequentially I provide an alert signal followed by an initial instructional message to populated areas throughout the 10-mile plume exposure pathway EPZ. Following the decision to activate the alert and notification system, (2) OROs must complete system activation for primary alert/notification and I disseminate the information/instructions in a timely manner. For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." (3) Procedures to broadcast the message must be fully demonstrated as they would in an actual emergency up to the point of I transmission. Broadcast of the message(s) or test message(s) is not required. The procedures must be demonstrated up to the point of actual activation. The alert signal activation should be simulated, not performed. Evaluations of EAS broadcast stations may also be accomplished I through SAVs. (4) 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 I power or an alternate station. (5) The initial message must include at a minimum the following elements:

• (a) Identification of the ORO responsible and the official with authority for providing the alert I

• signal and instructional message; (b) Identification of the commercial NPP and a statement tnat an emergency exists there;

• (c) Reference to REP-specific emergency information (e.g., brochures, calendars, and/or I

• information in telephone books) for use by the general public during an emergency; (d) A closing statement asking that the affected and potentially affected population stay tuned for additional information, or that the population tune to another station for additional information.

I (6) If route alerting is demonstrated as a primary method of alert and notification, it must be done in accordance with the ORO's plans/procedures. OROs must demonstrate the capability to accomplish the primary route alerting in a timely manner (not subject to specific time I requirements). At least one route n_eeds to be demonstrated and evaluated. The selected route(s) must vary from exercise to exercise. However,the most difficult route(s) must be demonstrated no less than once every eight years. (7) All alert and notification activities along the route(s) must I be simulated (i.e., the message that would actually be used is read for the evaluator, but not actually broadcast. (8) Actual testing of the mobile public address system will be conducted at an

,I agreed-upon location.

LIMESTONE COUNTY: PNS coordination will be done via the ECNS and led by I Madison County EMA. The first siren activation will be demonstrated up to the point of activation, scenario dependent. Subsequent activations will be simulated, scenario dependent. The BFNPP counties have developed unified EAS and Special News I Broadcast messages and distributed to the National Weather Service Office in Huntsville (NWS). Madison County EMA will coordinate the EAS/SNB messages with the BFNPP counties via the ECNS and designate to (NWS) via telephone or Southern Linc, which I message to distribute. EAS message distribution will be-the responsibility of the (NWS),

and simulated for this exercise.

I I

157 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Critical Task: Waterway warning/ 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 E.6; Appendix 3.B.2.c; Criterion 5a3). Pg. 199 I Performance Measure: (1) Backup alert and notification procedures that would be implemented in multiple stages must be structured such that the population closest to the plant (e.g., within 2 miles) is alerted and notified first. The populations farther away and downwind of any potential I radiological release would be covered sequentially (e.g., 2 to 5 miles, followed by downwind 5 to 10 miles, and finally the remaining population as directed by authorities). (2) Although circumstances may not allow this for all situations, FEMA and the NRC recommend that OROs I

and operators attempt to establish backup means that will reach those in the plume exposure pathway EPZ within a reasonable time of failure of the primary alert and notification system, with a recommended goal of 45 minutes. (3) The backup alert message must, at a minimum, I

include: (a) a statement that an emergency exists at the plant and (b) instructions regarding where to obtain additional information. When backup route alerting is demonstrated, only one route needs to be selected and demonstrated. All alert and notification activities along the route(s) must be I

simulated (i.e., the message that would actually be used is read for the evaluator, but not actually broadcast), as negotiated in the extent of play. (4) Actual testing of the mobile public address system will be conducted at an agreed-upon location.

I LIMESTONE COUNTY: Limestone County Sheriffs Office will demonstrate backup alert routing out of sequence on May 15; 2019.

I Critical Task: Ensure OROs provide accurate emergency information and instructions to the public and the news media in a timely manner (The responsible ORO personnel/representatives I

demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay) (NUREG-0654 E.5, 7; G.3.a; G.4.a, c; Criterion 5bl). Pg.

200-201. .

I Perforinance Measure: (1) The responsible ORO personnel/representatives must demonstrate actions to provide emergency information and instructions to the public and media in a timely I

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."

Message elements: (2) The ORO must ensure that emergency information and instructions are I

consistent with PADs made by appropriate officials. (3) The emergency information must contain all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, shelter-in-place instructions, I

information concerning protective actions for schools and persons with disabilities and access/functional needs, and public inquiry hotline telephone number) to assist the public in carrying out the PADs provided (4) The ORO must also be prepared to disclose and explain the I

ECL of the incident. At a minimum, this information must be included in media briefings and/or media releases. (5) 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. (6)

I This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas. (7) The emergency information must be all-inclusive by I including the four items specified under exercise Demonstration Criterion 5 .a. l and previously I

158 I,

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant identified protective action areas that are still valid, as well as new areas. (8) Information about I any rerouting of evacuation routes due to impediments should also be included. (9) The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. (10) OROs must demonstrate the capability to I ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures. (11) OROs must demonstrate the capability to develop emergency information in a non-English language when required by the plans/procedures. (12) If ingestion I exposure pathway measures are required, OROs must demonstrate that a system exists for rapid dissemination of ingestion exposure pathway information to predetermined individuals and businesses. Media information: (13) 'OROs must demonstrate the capability to provide timely, I accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. (14) This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the incident warrants. (15) The OROs I must demonstrate the capability to respond appropriately to inquiries from the news media. (16)

All information presented in media briefings and releases must be consistent with PADs and other emergency information provided to the public. (17) Copies of pertinent emergency I information (e.g., BAS messages and media releases) and media information kits must be available for dissemination to the media. Public Inquiry (18) OROs must demonstrate that an effective system is in place for dealing with calls received via the public inquiry hotline .. (19)

I Hotline staff must demonstrate the capability to provide or obtain accurate-information for callers or refer them to an appropriate information source. (20) Information from the hotline staff, including information that corrects false or inaccurate information when trends are noted, .

I must be included, as appropriate, in emergency information provided to the public, media briefings, and/or media releases. HAB considerations: (21) The dissemination of information dealing with specific aspects of NPP security capabilities, actual or perceived adversarial I (terrorist) force or threat, and tactical law enforcement response must be coordinated/

communicated with appropriate security authorities (e.g., law enforcement and NPP security agencies) in accordance with ORO Pans/procedures.

I LIMESTONE COUNTY: The BFNPP counties have developed unified BAS and Special News Broadcast messages and distributed to the National Weather Service Office I in Huntsville (NWS). Madison County EMA will coordinate the EAS/SNB messages with the BFNPP counties via the ECNS and designate to (NWS) via Southern Linc or I telephone which message to distribute. BAS message distribution will be the responsibility of (NWS) and simulated for this exercise. (Scenario dependent) Limestone County will develop and issue county specific messages.

I Core Capability: Environmental Response/Health and Safety I Definition: *Conduct appropriate measures to ensure the protection of the health and safety of the public and workers, as well as the environment, from all-hazards in support of responder operations and the affected communities I

I 159 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 Al.a, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; G.a.3; H.3, 4; Criterion lal). Pg. 180.

I Performance Measure: (1) OROs must demonstrate the capability to receive notification of an incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key I

emergency personnel in a timely manner, (4) 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. (5) Demonstrate I

the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and contact information for facilities included in the incident command must be available to all I

appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must be demonstrated. I LIMESTONE COUNTY: EMA Staff and some BOC Support Staff will be pre-positioned at 8:00 a.m. at the Limestone County BOC.

• Additional support personnel will be alerted and mobilized according to established plans and procedures.

• I Critical Task: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible (NUREG-0654 A.1.d; I

A.2.a, b; A.3; C.4, 6; Criterion lcl). Pg.181.

Performance Measure: (1) Leadership personnel must demonstrate the ability to carry out the I

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.) (2) Leadership must demonstrate the ability to prioritize resource I

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

I LIMESTONE COUNTY: Demonstration of direction and control will be performed according to plans and procedures, scenario dependent.

I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and I communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 F.1, 2; Criterion ldl). Pg. 181. I Performance Measure: OROs must demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, FMTs, and incident command must have the I capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might I disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for I

160 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant fixed and mobile medical support facilities exists.

I LIMESTONE COUNTY: Communications systems will be demonstrated, scenario dependent. The TV A ECNS is the primary means of communications with AEMA.

I Southern Linc, telephones, two-way radio and HAM radio will serve as secondary communications with field units and other facilities.

I Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

I Performance Measure: (1) 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. (2)

I For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3) At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be I available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c)

I members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage I locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient I quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained I in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. (10) A label indicating such calibration must be on each I instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it I is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for I Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I 161 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

LIMESTONE COUNTY: An adequate supply of thermos-luminescent dosimeters (TLDs) and dosimetry will be available for the emergency workers. This will be I discussed out of sequence at the Limestone County EOC on May 15, 2019. The supply of KI will be viewed out of sequence, at the Limestone County Health Department, located at 20371 Clyde Mabry Dr., Athens, AL on May 9, 2019. I Critical Task: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in I place for EWs including provisions to authorize radiation exposure in excess of administrative limits or PAGs (NUREG-0654 C.6.f; K.4 Criterion 2al). Pg. 185.

I Performance Measure: (1) 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. (2) OROs must also demonstrate the I

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. (3) This would include providing KI and dosimetry in a timely manner to I

emergency workers dispatched onsite to support plant incident assessment and mitigating actions, in accordance with respective plans/procedures. I LIMESTONE COUNTY: This will be discussed during the exercise, scenario dependent. I Critical Task: Appropriate protective action recommendations (PARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA-I REP-1, I.10 and Supplement 3; Criterion 2.b.l) Pg. 184-185.

Performance Measures: ( 1) The ORO must demonstrate the capability to use the appropriate I

means described in the plans/procedures to develop P ARs for decision-makers based on available information and recommendations provided by the licensee, as well as field monitoring data if available. Workers must also consider any release and meteorological data provided by I

the licensee. (2) The ORO must demonstrate a reliable capability to independently validate dose projections. The types of calculations to be demonstrated depend on the data available and the need for assessments to support the PARs must be appropriate to the scenario. In all cases, I

calculation of projected dose must be demonstrated. Projected doses must be related to quantities and units of the PAG to which they will be compared. (3) PARs must be promptly transmitted to decision-makers in a prearranged format. (4) When the licensee and ORO I

projected doses differ by more than a factor of 10, the ORO and licensee must determine the source of the difference by discussing input data and assumptions, using different models, or exploring possible reasons. Resolution of these differences must be incorporated into the P ARs I

if timely and appropriate. (5) The ORO must demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated PARs. I I

162 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant LIMESTONE COUNTY: This will be discussed during the exercise, scenario I

• dependent.

Critical Task: A decision-making process involving consideration of appropriate factors and I necessary coordination is used to make PADs for the general public (including the recommendation for the use of KI, if ORO policy) (NUREG-0654/ FEMAREP-1, A.3; C.4, 6; D.4; J.9; J.10.e.f, m; Criterion 2-.b.2). Pg. 185.

I Performance Measures: (1) OROs must have the capability to make both initial and subsequent precautionary and/or protective action decisions in.a timely manner appropriate to the I incident, based on information from the licensee, assessment of plant status and potential or

• actual releases, other available information related to the incident, input from appropriate ORO

, authorities (e.g., incident command), and PARs from the utility and ORO staff. (2) In addition, a I subsequent or alternate precautionary and/or protective action decision may be appropriate if various conditions (e.g., an HAB incident, weather, release timing and magnitude) pose undue risk to an evacuation or if evacuation may disrupt the efforts to respond to a hostile action. (3)

I ORO.smust demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a precautionary and/or protective action decision jf local law enforcement, fire service, HAZMAT, and emergency medical resources are used to augment response to the NPP I site or other key infrastructure. (4) If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must demonstrate the capability to make decisions on the distribution and administration of KI to .

I 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 I appropriate assessment and decision-making staff. (5) If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate precautionary and/or protective action decisions with each other. (6) In addition, decisions must be coordinated/

I communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

I LIMESTONE COUNTY: This will be discussed during the exercise, scenario.

dependent.

I_ Critical Task: OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to EWs in accordance with the plans/procedures. EWs periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or I chart. OROs maintain appropriate record-keeping of the administration of KI to EWs (NUREG-0654 K.3.a, b, K.4; Criterion 3al). Pg. 189.

Performance Measures: (1) OROs must demonstrate the capability to provide emergency*

workers {including supplemental resources) with the appropriate direct-reading and permanent-I 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 I

163 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant enough to consider subsequent calculation of TEDE and maximum exposure limits, for those I

emergency workers involved in lifesaving activities, contained in the ORO's plans/procedures ..

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

• I radiological exposure control. (3) During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. (4) OROs must demonstrate the actions described in the plans/procedures by I determining whether to replace the worker, authorize the worker to incur additional exposures, or take other actions. (5) If exercise play does not require emergency workers to seek

. authorizations for additional exposure; evaluators must interview at least two workers to I

determine their knowledge. (6) 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 and can share a direct read dosimeter. Each team member I

must still have and maintain his or her own permanent-record dosimetry. (7) OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property I

may require an urgent response. (8) OROs must demonstrate the capability to accomplish

• distribution of KI to emergency workers consistent with decisions made. OROs must have the

.capability to develop and maintain lists of emergency workers who have ingested KI, including I

documentation of the date(s) and time(s) they did so. (9) Emergency workers must demonstrate basic knowledge of procedures for using* KI. If exercise play does not require emergency workers to consume KI, evaluators must interview at least two workers to determine their I

knowledge.

LIMESTONE COUNTY: Emergency workers will discuss exposure control, out of I

sequence, on May 15, 2019 at the EOC.

Critical Task: KI and appropriate instructions are made available in case a decision to I

.* recommend use of KI is made. Appropriate record keeping of the administration of KI for institutionalized individuals and the general public is maintained (NUREG-0654 J.10.e, f; Criterion 3bl). Pg. 190.

I Performance Measures: (1) OROs must demonstrate the capability to make KI available to institutionalized individuals and, where provided for in their plans/procedures, to members of the I

general public. (2) OROs must demonstrate the capability to accomplish distribution of KI consistent with decisions made. (3) OR.Os must have the capability to develop and maintain lists of institutionalized individuals who have ingested KI, including documentation of the date(s) and I

time(s) they were instructed to ingest KI. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it. (4) If a recommendation is I

made for the general public to take KI, appropriate information must be provided to the public by I

the means of notification specified in the ORO' s plans/procedures.

I I

164 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant LIMESTONE COUNTY: This will be discussed with a Health Department I representative, out of sequence, at Ardmore High School on May 15, 2019.

Critical Task: The reception center facility has appropriate space, adequate resources, and I trained personnel to provide monitoring, decontamination, and registration of evacuees (NUREG-0654 A.3; C.4; J.10.h; J.12; Criterion 6al). Pg. 202-203.

I Performance Measure: (1) Radiological monitoring, decontamination, and registration facilities for evacuees must be set up and demonstrated as they would be in an actual emergency.

(2) OR Os conducting this demonstration must have (a) one-third of the resources (e.g.,

I monitoring teams/instrumentation/portal monitors) available at the facility(ies) as necessary to monitor (b) 20 percent of the population within a 12-hour period. (c) This would include adequate space for evacuees' vehicles. (2) Availability of resources can be demonstrated with I valid documentation (e.g., MOU/LOA, etc.) reflecting how necessary equipment would be procured for the location. (3) Plans/procedures must indicate provisions for service animals. (4)

Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking I the instrument(s) for proper operation. (5) 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 I base. (6) 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. ( 7)

For demonstration of monitoring, decontamination, and registration capabilities, a minimum of I six evacuees must be monitored per station using equipment and procedures specified in the plans/ procedures. (8) 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 I can be met. (9) OROs must demonstrate the capability to register evacuees upon completion of the monitoring and decontamination activities. (10) The activities for recording radiological monitoring and, if necessary, decontamination must include establishing a registration record I consisting of the (a) evacuee's name, (b) address, (c) results of monitoring, and (d) time of decontamination (if any), or as otherwise designated in the plan and/or procedures. Audio I recorders, camcorders, or written records are all acceptable means for registration. ( 11)

Monitoring activities shall not be simulated. (12) Monitoring personnel must explain use of

, trigger/action levels for determining the need for decontamination. (13) They must also explain I the procedures for referring any evacuees who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency.

I Decontamination of evacuees may be simulated and conducted by interview. (14) Provisions for separate showering and same-sex decontamination must be demonstrated or explained. ( 15) The staff must demonstrate provisions for limiting the spread of contamination. Provisions could I include floor coverings, signs, and appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. (16) Provisions must also exist to (a) separate contaminated and uncontaminated evacuees, (b) provide changes of clothing for I those with contaminated clothing, and (c) store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities. (17) In addition, for any evacuee found to be contaminated, procedures must be discussed concerning handling of potential I

165 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

contamination of vehicles and personal belongings. Waste water from decontamination operations does not need to be collected. (18) Individuals who have completed monitoring and decontamination if needed, must have the means (e.g., hand stamp, sticker, bracelet, form, etc.) I indicating that (a) they, and their service animals and vehicles, where applicable, have been monitored, cleared, and found to have no contamination or (b) contamination below the trigger/action level or (c) have been placed in a secure area until they can be monitored and I decontaminated, if necessary. 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 I

areas. (19) However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles (a) held in a secure area or (b) monitored and decontaminated (if applicable) and do require confirmation that their vehicle is being (c) held in I

a secure area or (d) free from contamination prior to entering the congregate care areas.

LIMESTONE COUNTY: Monitoring, decontamination and registration of evacuees I

will be demonstrated, out of sequence, at the Reception Center at Ardmore High School, located at 30285 Ardmore Ave., Ardmore, Al 35739 on May 15, 2019. Protective clothing for one emergency worker will be demonstrated. Male and female monitoring I

and registration will be demonstrated and decon will be simulated.

Critical Task: The facility/ORO has adequate procedures and resources to accomplish I

monitoring and decontamination of emergency workers and their equipment and vehicles (NUREG-0654 K.5.a; b; Criterion 6bl). Pg. 203-204. I Performance Measure: (1) The monitoring staff must demonstrate the capability to monitor emergency worker personnel and their equipment and vehicles for contamination in accordance with the ORO's plans/procedures. Specific attention must be given to equipment, including any I

vehicles that were in contact with contamination. (2) 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.

I Monitoring of emergency workers does not have to meet the 12-hour requirement. (3) However, appropriate monitoring procedures must be demonstrated for a minimum of two emergency workers and their equipment and vehicles. (4) Before using monitoring instrument(s), the I

monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. (5)

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 I

control measures in place. (6) Monitoring procedures must be demonstrated for a minimum of one vehicle. It is generally not necessary to monitor the entire surface of vehicles. (7) However, the capability to monitor areas such as radiator grills, bumpers, wheel wells, tires, and door I

handles must be demonstrated. (8) 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. (9) Provisions for separate showering and same-sex I

decontamination must be demonstrated or explained. ( 10) The staff must demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs*, and I appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially I

166 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant contaminated areas. (11) Provisions must also exist to separate contaminated and I 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. (12) OROs must demonstrate the I capability to register emergency workers upon completion of the monitoring and decontamination activities. The activities for recording radiological monitoring and if necessary, decontamination must include establishing a registration record consisting of the (a) emergency I worker's name, (b) address, (c) results of monitoring, and (d) time of decontamination (if any),

or as otherwise designated in the plans/procedures. Audio recorders, camcorders, or written .

records are all acceptable means for registration. Monitoring activities shall not be simulated.

I (13) Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. ( 14) They must also explain the procedures for referring any emergency workers who cannot be adequately decontaminated for assessment and follow-up in accordance I with the ORO's plans/procedures Decontamination capabilities and provisions for vehicles and equipment that cannot be successfully decontaminated may be simulated and conducted by interview. Waste water from decontamination operations does not need to be collected.

I LIMESTONE COUNTY: Monitoring, decontamination *and registration of emergency

• workers will be demonstrated, out of sequence, at the Reception Center at Ardmore High I School, located at 30285 Ardmore Ave., Ardmore, Al 35739 on May 15, 2019.

Monitoring of emergency workers will be demonstrated and decon will be simulated.

Vehicle monitoring and decontamination will also be demonstrated and protective

.I clothing for one emergency worker will be dem.onstrated.

Core Capability: On-Scene Security, Protection, and Law Enforcement (TCP's/Waterway I Warning)

Definition: Ensure a safe and secure environment through law enforcement and related security I and protection operations for people and communities located within affected areas and also for response personnel engaged in lifesaving and life-sustaining operations.

I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 I F.1, 2; Criterion ldl). Pg. 180.

I Performance Measure: OROs must demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial I telephone system. (3) Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for I fixed and mobile medical support facilities exists.

I 167 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

LIMESTONE COUNTY: A representative from the Limestone County Sheriff's Office will discuss communications, out of sequence, on May 15, 2019 at the Limestone County EOC. I Critical Task: Equipment (to include communications), maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 I

H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

Performance Measure: (1) A particular facility's equipment and supplies must be sufficient I

and consistent with that facility's assigned role in the ORO's emergency operations plans. (2)

For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3) At locations where traffic and access control personnel I

are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones; and signs) must be available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or I

specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage I

location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability I

to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an I

individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the I

manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings I

'documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to I

the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I LIMESTONE COUNTY: Thermo-luminescent dosimeters (TLDs) and dosimetry will be distributed to available emergency workers at the Limestone County EOC, out of I

sequence, on May 15, 2019.

I I

I 168 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Critical Task: OROs issue appropriate dosimetry, KI, and procedures, and manage radiological I exposure to EWs in accordance with the plans/procedures. EWs periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to EW s (NUREG-I 0654 K.3.a, b, K.4; Criterion 3al). Pg. 189 Performance Measures: (1) OROs must demonstrate the capability to provide emergency I 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 I 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.

I (2) Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/ procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency I workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control. (3) During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and tum-back I values are reached. (4) 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. (5) If exercise play does not require emergency workers to seek I authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge. (6) 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 I to each other during the entire mission and can share a direct read dosimeter. Each team member must still have and maintain his or her own permanent-record dosimetry. (7) OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact I the capability to respond to an incident where lifesaving and/or protection of valuable property may require an urgent response. (8) OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the I capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. (9) Emergency workers must demonstrate I basic knowledge of procedures for using KI. If exercise play does not require emergency workers to consume KI, evaluators must interview at least two workers to determine their knowledge.

I LIMESTONE COUNTY: Emergency workers will discuss exposure control, out of sequence, on May 15, 2019 at the EOC.

I Critical Task: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel (NUREG-0654 A.3; C.l, 4; J.10.g,j; Criterion I 3dl). Pg. 191-192.

I 169 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Performance Measures: (1) OROs must demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with current conditions and P ADs (e.g.,

evacuating, sheltering, and relocation) in a timely manner. (2) OROs must demonstrate the I 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. (2) Traffic and access control staff must demonstrate accurate I knowledge of their roles and responsibilities, including verifying emergency worker identification and access authorization to the affected areas. (3) In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic),

I they must demonstrate the capability to contact the State or Federal agencies that have the needed authority I

LIMESTONE COUNTY: A representative from the Limestone County Sheriff's Office, will discuss traffic ~nd access control, out of sequence, on May 15, 2019 at the Limestone County EOC. Actual demonstration will not be performed.

I Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; Criterion 3d2). Pg. 192.

I Performance Measures: (1) OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. (2) The impediment must remain in I

place during the evacuation long enough that re-routing of traffic is required and (3) must also result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

I LIMESTONE COUNTY: A representative from the Limestone County Sheriff's Office, will discuss impediments to evacuation, out of sequence, on May 15, 2019 at the I

Limestone County EOC.

Core Capability: Mass Care Services I

Definition: Provide life-sustaining and human services to the affected population, to include hydration, feeding, sheltering, temporary housing, evacuee support, reunification, and I

distribution of emergency supplies.

Critical Task: Managers of congregate care facilities demonstrate that the centers have resources I

to provide services and accommodations consistent with planning guidelines. Managers demonstrate the procedures to assure that evacuees have been monitored for contamination and have been decontaminated as appropriate before entering congregate care facilities (NUREG-I 0654; J.10.h; J.12; Criterion 6cl). Pg. 204.

I I

I 170 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measure: (1) OROs must plan for a sufficient number of congregate care centers I in host/support jurisdictions based on their all-hazard sheltering experience and what is historically relevant for that particular area. In this simulation, it is not necessary to set up operations as they would be in an actual emergency. Alternatively, (2) capabilities may be I demonstrated by setting up stations for various services and providing those services to simulated evacuees. Given the substantial differences between demonstration and simulation of this criterion, exercise demonstration expectations must be clearly specified in Extent-of-Play I Agreements. Congregate care staff must also (3) demonstrate the capability to ensure that (a) evacuees, service animals, and vehicles have been monitored for contamination,(b) decontaminated as appropriate, and (c) registered before entering the facility. (4) Individuals I arriving at congregate care facilities must have means (e.g., hand stamp, sticker, bracelet, form, etc.) indicating that they, and their service animals and vehicles, "".here applicable, have been (a) placed in a secured area or (b) monitored, cleared, and found to have no contamination or (c)

I contamination below the trigger/action level. In accordance with plans/procedures, individuals found to be clean after monitoring do not need to have their vehicle monitored. These individuals do not need confirmation that their vehicle is free from contamination prior to I entering the congregate care areas. (5) However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles held in a secure area until they can be monitored and decontaminated (if applicable) and do need confirmation that their I vehicle is being held in a secure area or free from contamination prior to entering the congregate care areas. This capability may be determined through an interview process. If operations at the center are demonstrated, material that would be difficult or expensive to transport (e.g., cots, I blankets, sundries, and large-scale food supplies) need not be physically available at the facility(ies). (6) However, availability of such items must be verified by providing the evaluator a list of sources with locations and estimates of quantities.

I LIMESTONE COUNTY: This element will be demonstrated by discussion, out of sequence, at the Reception Center at Ardmore High School on May 15, 2019. Actual 11 setup of the Mass Care Center will not be performed. Activation of Mass Care Shelters during the exercise will be simulated, scenario dependent.

I

,I I

I I

I 171 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

I I

I I

I I

I This page is intentionally blank I

I I

I I

I I

I I

172 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant BASE I EXTENT OF PLAY AGREEMENT 2019 Browns Ferry Nuclear Plant I Morgan County FULL PARTICIPATION RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE I All activities will be demonstrated fully in accordance with respective plans and procedures as they would be in an actual emergency (FEMA must receive these plans, guides and procedures I NLT 60 days before the exercise). This Extent of Play agreement is written by exception. If it is not listed as an exception it will be demonstrated as described in the plans, standard operating guides (SOGs) and/or procedures (SOPs). Any issue or discrepancy arising during exercise play I may be redemonstrated if allowed by the RAC Chair or as listed herein. This allowance may be granted if it is not disruptive to exercise play and is mutually agreed to by the ORO controller and FEMA evaluator.

I Core Capability: Operational Coordination I Definition: Establish and maintain a unified and coordinated operational structure and process that appropriately integrates all critical stakeholders and supports the execution of core capabilities.

I Critical Task: OROs use effective;procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 A.La, e; A.3, 4; C.l, 4, 6; D.4; E.1, 2; I G.3.a-i H.3, 4; Criterion lal). Pg. 180.

Performance Measure: (1) OROs must demonstrate the capability to receive notification of an I incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key emergency personnel in a timely manner, (4) Responders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management I organizations of an incident in a timely manner when they receive information. (5) Demonstrate the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation I of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP. (8) The ability to identify and request additional I resources or identify compensatory measures must be demonstrated.

MORGAN COUNTY: On June 26, 2019, EMA Staff and some of the EOC Support I Staff will be pre-positioned at 8:00 A.M. at the Morgan County EOC, located at 302 Lee Street N.E., Decatur, AL. The call-out for additional support EOC staff, public officials, and department heads will be discussed, with no actual demonstration performed.

173

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Critical Task: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible (NUREG-0654 A. l .d; A.2.a, b; A.3; C.4, 6; Criterion lcl). Pg. 181. I Performance Measure: (1) Leadership personnel must demonstrate the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed through I periodic briefings and/or other means, coordinating with other OROs, and ensuring completion of requirements and requests.) (2) Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement resources (e.g., through MOUs or other agreements) when faced I

with competing demands for finite resources. Any resources identified through LOA/MOUs must be on the ORO's mobilization list so they may be contacted during an incident if needed.

I MORGAN COUNTY: EMA will demonstrate direction and control in the EOC; scenario dependent.

I Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

I Performance Measure: (1) 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. (2)

I For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3)At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, trafflc cones, and signs) must be I

available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c)

I members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage I

locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient I

quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained I

in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. (10) A label indicating such calibration must be on each I

instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it I

is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to I the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for I

174 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's I recommendations.

MORGAN COUNTY: EMA will demonstrate use of equipment, maps, displays, and I other supplies in the BOC, some of the dosimetry & monitoring equipment is pre-positioned in the field with the emergency workers. This will be discussed during the out of sequence at the Morgan County EMA on May 9, 2019.

I The supply of KI will be viewed during the out of sequence, at the Morgan County Health during the out of sequence on May 9, 2019, located at 3821 Hwy. 31 SW, Decatur, AL; scenario dependent.

I Critical Task: OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to EWs in accordance with the plans/procedures. EWs periodically and at the end of I each mission read their dosimeters*and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to EW s (NUREG-0654 J.10.e, K.3.a, b, K.4; Criterion 3al).Pg. 189 190.

I Performance Measures: (1) OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent-I 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 I 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.

(2) Each emergency worker must have basic knowledge of radiation exposure limits as specified I in the ORO's plans/ procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage I radiological exposure control. (3) During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. (4) OROs must demonstrate the actions described in the plans/procedures by I determining whether to replace the worker, authorize the worker to incur additional exposures, or take other actions. (5) If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to I determine their knowledge. (6) 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 I to each other during the entire mission and can share a direct-read dosimeter. Each team member must still have and maintain his or her own permanent-record dosimetry. (7) OROs must ensure that the process used to seek authorization for exceeding dose limits does not I negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property may require an urgent response. (8) OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs I must have the capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. (9) Emergency workers must demonstrate basic knowledge of procedures for using KI. If exercise play does not require I

175 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

emergency workers to consume KI, evaluators must interview at least two workers to determine their knowledge.

I PARTICIPANTS: EMA Staff; EOC Support Staff; NARCOG Transportation Systems; Morgan County Health Department Staff and Decatur City Police Department, Alabama Department of Human Resources and Morgan County Volunteer Fire Departments. I MORGAN COUNTY: Emergency Workers will discuss exposure control, out of sequence, on May 9th, 2019, at the Morgan County EMA office, 302 Lee Street N.E., I Decatur, AL.

Critical Task: KI and appropriate instructions are available if a decision to recommend use of KI I

is made. Appropriate record-keeping of the administration of KI for institutionalized individuals and the general public is maintained (NUREG-0654 J.10.e, f; Criterion 3bl). Pg. 190 I

Performance Measures: (1) 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. (2) OROs must demonstrate the capability to accomplish distribution of KI I

consistent with decisions made. (3) OROs must have the capability to develop and maintain lists of institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest KI. OROs must demonstrate the capability to formulate I

and disseminate instructions on using KI for those advised to take it. (4) If a recommendation is made for the general public to take KI, appropriate information must be provided to the public by the means of notification specified in the ORO's plans/ procedures.

I MORGAN COUNTY: This will be discussed with a Health Department representative, out of sequence, at the Priceville Junior High on May 16, 2019.

I Critical Task: OROs/School officials implement protective actions for schools (NUREG-0654 CJ.10.c, d, e, g; Criterion 3c2). Pg. 191.

I Performance Measures: (1) School systems/districts (these include public and private schools, kindergartens, and preschools) must demonstrate the ability to implement precautionary and/or I

protective action decisions for students. (2) 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. (3) Which protective action is implemented I

(evacuation to reception centers, relocation to host schools, cancel the school day, early dismissal, shelter in place), all activities to coordinate and complete the process should be evaluated. (4) School personnel including decision-making officials (e.g., schools' I

superintendent/principals and transportation director/bus dispatchers) and at least one bus driver (and the bus driver's escort, if applicable) must be available to demonstrate knowledge of their

• . role(s) in the evacuation of school children; (5) Communications capabilities between school I

I I

176 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant officials and the buses, if required by the plans/procedures, must be verified. (6) Officials of the I school system(s) must demonstrate the capability to develop and provide timely information to OROs/parents for use in messages to parents, the general public, and the media on the status of protective actions for schools.

I MORGAN COUNTY: This will not be discussed during this drill cycle. This was discussed during the 2017 exercise critique. There may still be school officials in the I EOC during the drill for the practice.

Critical Task: Appropriate traffic and access control is established. Accurate instructions are I provided to traffic and access control personnel (NUREG-0654 A.3; C.1, 4; J.10.g,j; Criterion 3dl) Pg. 191-192.

I Performance Measures: (1) OROs must demonstrate the capability to select, establish, and staff appropriate traffic and access control points consistent with current conditions and P ADs (e.g., evacuating, sheltering, and relocation) in a timely manner. (2) OROs must demonstrate the I 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. (2) Traffic and access control staff must demonstrate accurate I knowledge of their roles and responsibilities, including verifying emergency worker identification and access authorization to the affected areas. (3) In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic),

I they must demonstrate the capability to contact the State or Federal agencies that have the needed authority.

I MORGAN COUNTY: The Decatur Police Department representative will discuss traffic and access control, at the out of sequence located at the Morgan County EOC, on May 9, 2019 and a Morgan County Rescue Squad representative will discuss river access I control, during the exercise at the EOC, scenario dependent. Actual demonstration will not be performed of either task.

I Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; Criterion 3d2). Pg. 192.

I Performance Measures: (1) OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. (2) The impediment must remain in I place during the evacuation long enough that re-routing of traffic is required and (3) must also result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

I MORGAN COUNTY: The Decatur Police Department representative will discuss impediments to evacuation, out of sequence at the Morgan County EOC, on May 9th, I 2019, scenario dependent. Actual demonstration will not be performed.

I 177 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Core Capability: Situational Assessment Definition: Provide all decision makers with decision-relevant information regarding the nature I and extent of the hazard, any cascading effects, and the status of the response.

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

K.4; Criterion 2.al). Pg. 184.

Performance Measures: (1) OROs authorized to send emergency workers into the plume I

exposure pathway EPZ must demonstrate a capability to comply with emergency worker exposure limits based on their emergency plans/procedures. (2) OROs must also demonstrate the capability to make decisions concerning authorization of exposure levels in excess of pre-I authorized levels and the number of emergency workers receiving radiation doses above pre-authorized levels. (3) This would include providing KI and dosimetry in a timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating I

actions, in accordance with respective plans/procedures.

PARTICIPANTS: EMA Staff; NARCOG Transportation Services, Representatives I

from area schools MORGAN COUNTY: This will be discussed during the exercise, scenario dependent.

I Critical Task: Appropriate protective action recommendations (PARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, I

as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA-REP-1, 1.10 and Supplement 3; Criterion 2.b.1) Pg. 184-185. I Performance Measures: (1) The ORO must demonstrate the capability to use the appropriate means described in the plans/procedures to develop PARs for decision-makers based on available information and recommendations provided by the licensee, as well as field monitoring I

data if available. Workers must also consider any release and meteorological data provided by the licensee. (2) 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 I

need for assessments to support the PARs must be appropriate to the scenario. In all cases, calculation of projected dose must be demonstrated. Projected doses must be related to I quantities and units of the PAG to which they will be compared. (3) PARs must be promptly transmitted to decision-makers in a prearranged format. (4) When the licensee and ORO projected doses differ by more than a factor of 10, the ORO and licensee must determine the I 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 if timely and appropriate. (5) The ORO must demonstrate the capability to use any additional I data to refine projected doses and exposure rates and revise the associated P ARs.

I, 178 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I MORGAN COUNTY: This will be discussed during the exercise by ORO when developing the PAR for the county and state to follow the information gathered from offsite the plant. Scenario dependent.

I Critical Task: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make P ADs for the general public (including the I 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; Criterion 2.b.2). Pg. 185.

I Performance Measures: (1) OROs must have the capability to make both initial and subsequent precautionary and/or protective action decisions in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or I actual releases, other available information related to the incident, input from appropriate ORO authorities (e.g., incident command), and PARs from the utility and ORO staff. (2) In addition, a subsequent or alternate precautionary and/or protective action decision may be appropriate if I various conditions (e.g., an HAB incident, weather, release timing and magnitude) pose undue risk to an evacuation or if evacuation may disrupt the efforts to respond to a hostile action. (3)

OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary I to implement a precautionary and/or protective action decision if local law enforcement, fire service, HAZMAT, and emergency medical resources are used to augment response to the NPP site or other key infrastructure. (4) If the ORO has determined that KI will be used as a I protective measure for the general public under offsite plans/procedures, then it must demonstrate the capability to make decisions on the distribution and administration of KI to supplement sheltering and evacuation. This decision must be based on the ORO's I plans/procedures or projected thyroid dose compared with the established PAG for KI administration. The KI decision-making process must involve close coordination with appropriate assessment and decision-making staff. (5) If more than one ORO is involved in I decision making, all appropriate OROs must communicate and coordinate precautionary and/or protective action decisions with each other. (6) In addition, decisions must be I coordinated/communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

MORGAN COUNTY: This will be discussed during the exercise by ORO when I developing the PAR for the county and state to follow from the information gathered from offsite the plant; in order to issue KI to the general public. Scenario dependent.

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

I 186.

Performance Measures: Usually it is appropriate to implement evacuation in areas where doses I are projected to exceed the lower end of the range of PAGs, except for incidents where there is a high- risk environmental condition or where high-risk groups (e.g., the immobile or infirm) are involved. (1) In these cases, factors that must be considered include weather conditions, shelter I

179 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

availability, availability of transportation assets, risk of evacuation versus risk from the avoided dose, and precautionary school evacuations. In addition, decisions must be coordinated/communicated with the incident command. In situations where an institutionalized I population cannot be evacuated, the ORO must consider use of KI. (2) OROs must demonstrate the capability to alert and notify all public school systems/districts of emergency conditions that are expected to or may necessitate protective actions for students. Demonstration requires that I the OROs actually contact public school systems/districts during the exercise. (3) OROs must demonstrate how the decision-making process takes those with disabilities and access/functional needs (e.g., nursing homes, correctional facilities, licensed day cares, mobility-impaired I

individuals, and transportation-dependent individuals) into account.

MORGAN COUNTY: This will be discussed during the exercise by ORO when I

developing the PAR for the county and state to follow the information on persons with disabilities and functional needs. Scenario dependent.

I Core Capability: Operational Communications Definition: Establish and maintain a unified and coordinated operational structure and process I

that appropriately integrates all critical stakeholders and supports the execution of core capabilities. I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 I

F.1, 2; Criterion ldl). Pg. 180.

Performance Measure: OROs must demonstrate that a primary system and at least one backup I

system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the I

communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

I PARTICIPANTS: EMA Staff; EOC Support Staff; Public Information Support Staff I MORGAN COUNTY: EMA Staff and some EOC Support Staff will be pre-positioned at 8:00 AM. at the Morgan County EOC. The call-out for additional support staff including the JIC personnel according the Browns Ferry Nuclear Plant notification plan I

will be discussed with no actual demonstration performed.

I I

I 180 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Core Capability: Public Information and Warning I Definition: Deliver coordinated, prompt, reliable, and actionable information to the whole community through the use of clear, consistent, accessible, and culturally and linguistically I appropriate methods to effectively relay information regarding any threat or hazard and, as appropriate, the actions being taken and the assistance being made available.

I Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 A.l.a, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; G.3.a; H.3, 4; Criterion lal). Pg. 180.

I Performance Measure: (1) OROs must demonstrate the capability to receive notification of an incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key I emergency personnel in a timely manner, (4) 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. (5) Demonstrate I the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and contact information for facilities included in the incident command must be available to all I appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must be demonstrated.

I MORGAN COUNTY: EMA Staff and some BOC Support Staff will be pre-positioned at 8:00 AM. at the Morgan County BOC. The call-out for additional support staff including the JIC personnel according the Browns Ferry Nuclear Plant notification plan will be discussed with no actual demonstration performed.

Critical Task: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 F.1, 2; Criterion ldl). Pg. 180.

Performance Measure: OROs must demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the I communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

I MORGAN COUNTY: Communications systems will be demonstrated, scenario dependent. The PIO phone at the JIC will be the primary means of communications with I the JIC. Critical Linc, cellular phone, email and fax machine will service as secondary communications.

I 181 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182. I Performance Measure: (1) 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. (2) I For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3)At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be I

available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c)

I members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage I

locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient I

quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained I

in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. (10) A label indicating such calibration must be on each I

instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it I

is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for I

Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations. I MORGAN COUNTY: Appropriate information and supplies for public information, including a Smart Book, for use by the PIO at the JIC, will be available. This will be accomplished during the exercise, scenario dependent.

I Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; Criterion 3d2). Pg. 192 I

I I

I 182 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measures: (1) OROs must demonstrate the capability to identify and take I appropriate actions concerning impediments to evacuations. (2) The impediment must remain in place during the evacuation long enough that re-routing of traffic is required and (3) must also result in demonstration of decision-making and coordination with the JIC to communicate the I alternate route to evacuees.

MORGAN COUNTY: The PIO, located at the Morgan County BOC will communicate I to the JIC any impediments to evacuation. Should impediments to evacuation be identified, this information will be disseminated to the public. This will be accomplished during the exercise, scenario dependent.

I Critical Task: Activities associated with primary alerting and notification of the public are completed in a timely manner following the initial decision by authorized offsite emergency I officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current FEMA REP Guidance (Timely: The responsible ORO personnel/representatives demonstrate actions to disseminate the I appropriate information/instructions with a sense of urgency and without undue delay) (NUREG-0654 E.5, 6, 7; Criterion Sal). Pg. 198-199.

I Performance Measure: (1) Responsible OROs must demonstrate the capability to sequentially provide an alert signal followed by .an initial instructional message to populated areas throughout the 10-mile plume exposure pathway EPZ. Following the decision to activate the alert and I notification system, (2) OROs must complete system activation for primary alert/notification arid disseminate the information/instructions in a timely manner. For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." (3) Procedures to broadcast the message must be fully demonstrated as they would in an actual emergency up to the point of transmission. Broadcast of the message(s) or test message(s) is not required. The procedures must be demonstrated up to the point of actual activation. The alert signal activation should be I simulated, not performed. Evaluations of BAS broadcast stations may also be accomplished through SAVs. (4) 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 I personnel from the primary notification system, including verification of provisions for backup power or an alternate station. (5) The initial message must include at a minimum the following I

• elements:

(a) Identification of the ORO responsible and the official with authority for providing the alert signal and instructional message; I *

(b) Identification of the commercial NPP and a statement that an emergency exists there; (c) Reference to REP-specific emergency information (e.g., brochures, calendars, and/or information in telephone books) for use by the general public during an emergency; and I * (d) A closing statement asking that the affected and potentially affected population stay tuned for

• additional information, or that the population tune to another station for additional information.

(6) If route alerting is demonstrated as a primary method of alert and notification, it must be done I in accordance with the ORO's plans/procedures. 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)

I 183 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

must vary from exercise to exercise. However, the most difficult route(s) must be demonstrated no less than once every eight years. (7) All alert and notification activities along the route(s) must be simulated (i.e., the message that would actually be used is read for the evaluator, but not I

actually broadcast. (8) Actual testing of the mobile public address system will be conducted at an agreed-upon location.

I MORGAN COUNTY: PNS coordination will be done via the ECNS and led by-Madison County EMA. The first siren activation will be demonstrated up to the point of activation, scenario dependent. Subsequent activations will be simulated, scenario I

dependent. The BFNPP counties have developed unified BAS and Special News Broadcast messages and distributed to the National Weather Service Office in Huntsville (NWS). Madison County EMA will coordinate the BAS/ SNB messages with the I

BFNPP counties via the ECNS and designate to (NWS) via land line phone or Critical Linc (Southern Linc), which message to distribute. BAS message distribution will be the responsibility of the (NWS), and simulated for this exercise. An email will be sent after I

the BAS (simulation) has been sent to each county to show the message has been sent by NWS. I Critical Task: Ensure OROs provide accurate emergency information and instructions to the public and the news media in a timely manner (The responsible ORO personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of I

urgency arid without undue delay) (NUREG-0654 E.5, 7; G.3.a;. G.4.a, c; Criterion 5bl). Pg.

200-201. I Performance Measure: (1) 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).

I For exercise purposes, timely is defined as "with a sense of urgency and without undue delay."

Message elements: (2) The ORO must ensure that emergency information and instructions are consistent with PADs made by appropriate officials. (3) The emergency information must I

contain all.necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, shelter-in-place instructions, information concerning protective actions for schools and persons with disabilities and I

access/functional needs, and public inquiry hotline telephone number) to assist the public in carrying out the PADs provided. (4) The ORO must also be prepared to disclose and explain the I ECL of the incident. At a minimum, this information must be included in media briefings and/or media releases. (5) 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. (6) I This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective action areas. (7) The emergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5.a.l and previously I identified protective action areas that are still valid, as well as new areas. (8) Information about any rerouting of evacuation routes due to impediments should also be included. (9) The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is I rescinded and not repeated by broadcast media. (10) OROs must demonstrate the capability to I

184 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant ensure that current emergency information is repeated at pre-established intervals in accordance I with the plans/procedures. (11) OROs must demonstrate the capability to develop emergency information in a non-English language when required by the plans/procedures. (12) If ingestion exposure pathway measures are required, OROs must demonstrate that a system exists for rapid I dissemination of ingestion exposure pathway information to predetermined individuals and businesses. Media information: (13) OROs must demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media for subsequent dissemination I to the public. (14) This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the incident warrants. (15) The OROs must demonstrate the capability to respond appropriately to inquiries from the news media. (16)

I All information presented in media briefings and releases must be consistent with P ADs and other emergency information provided to the public. (17) Copies of pertinent emergency information (e.g., EAS messages and media releases) and media information kits must be I available for dissemination to the media. Public Inquiry (18) OROs must demonstrate that an effective system is in place for dealing with calls received via the public inquiry hotline. (19)

Hotline staff must demonstrate the capability to provide or obtain accurate information for I callers or refer them to an appropriate information source. (20) 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 I briefings, and/or media releases. HAB considerations: (21) The dissemination of information dealing with specific aspects of NPP security capabilities, actual or perceived adversarial (terrorist) force or threat, and tactical law enforcement response must be coordinated/

I communicated with appropriate security authorities (e.g., law enforcement and NPP security agencies) in accordance with ORO Pans/procedures.

I MORGAN COUNTY:

Core Capability: Environmental Response/Health and Safety I Definition: Conduct appropriate measures to ensure the protection of the health and safety of the public and workers, as well as the environment, from all-hazards in support of responder I operations and the affected communities I PARTICIPANTS: EMA Staff; EOC Support Staff; Volunteers and Morgan County &

Decatur City Elected Officials; Public Officials and Department Heads I Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 A. l.a, e; A.3, 4; C. l, 4, 6; D.4; E.1, 2; G.a.3; H.3, 4; Criterion lal). Pg. 180.

I Performance Measure: (1) OROs must demonstrate the capability to receive notification of an incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key I emergency personnel in a timely manner, (4) 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. (5) Demonstrate I

185 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and contact information for facilities included in the incident command must be available to all I appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must be demonstrated.

I MORGAN COUNTY: EMA Staff and some BOC Support Staff will be pre-positioned at 8:00 AM. at the Morgan County BOC located at 302 Lee Street N.E., Decatur, AL.

The call-out for additional support personnel will be discussed with no actual I

demonstration performed.

Critical Task: Key personnel with leadership roles for the ORO provide direction and control to I

that part of the overall response effort for which they are responsible (NUREG-0654 A.1.d; A.2.a, b; A.3; C.4, 6; Criterion lcl). Pg. 181. I Performance Measure: (1) 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 I

of requirements and requests.) (2) Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources. Any resources identified through LOA/MOUs I

must be on the ORO's mobilization list so they may be contacted during an incident if needed.

MORGAN COUNTY: Demonstration of direction and control will be performed I

according to plans and procedures;. scenario dependent.

Critical Task: At least 2 communications systems are available, at least 1 operates properly, and I

communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 F.1, 2; Criterion ldl). Pg. 181 I

Performance Measure: OROs must demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, FMTs, and incident command must have the I

capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might I

disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists. I MORGAN COUNTY: Communications systems will be demonstrated, scenario dependent on June 26th, 2019. The TVA ECNS is the primary means of communications. I Critical Linc (Southern Linc), landline phones; fax machines, cellular phones, two-way radio and HAM radio will service as secondary communications with field units and other facilities. I I

186 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other I supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

I Performance Measure: (1) 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. (2)

For non-facility-based operations, the equipment and supplies must be sufficient and consistent I with the assigned operational role. (3) At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI I sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) members of the general public, (5) The plans/procedures must include the forms to be used for I documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in I the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans or I specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and I operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. ( 10) A label indicating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-I 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. (12) In areas where portal monitors are used, I the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's I recommendations.

MORGAN COUNTY: The Morgan County EMA/BOC will have available equipment, I maps, displays that would be necessary to support emergency operations. There is some of our equipment that is pre-positioned with our assisting agencies for faster response.

This will be discussed out of sequence at the Morgan County BOC on May 9th, 2019.

I The KI supply will be discussed during the out of sequence that will be on May 9th, 2019 I at the Morgan County Health Department.

I I

187 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Critical Task: OROs use a decision-making process, considering relevant factors and appropriate coordination, to ensure that an exposure control system, including the use of KI, is in place for EWs including provisions to authorize radiation exposure in excess of administrative I limits or PAGs (NUREG-0654 C.6.f; K.4 Criterion 2al). Pg. 185.

Performance Measure: (1) OROs authorized to send emergency workers into the plume I exposure pathway EPZ must demonstrate a capability to comply with emergency worker exposure limits based on their emergency plans/procedures. (2) OROs must also demonstrate the capability to make decisions concerning authorization of exposure levels in excess of pre-I authorized levels and the number of emergency workers receiving radiation doses above pre-authorized levels. (3) This would include providing KI and dosimetry in a _timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating I

actions, in accordance with respective plans/procedures.

MORGAN COUNTY: This will be discussed during the exercise, scenario dependent.

I Critical Task: Appropriate protective action recommendations (PARs) are based on available information on plant conditions, field monitoring data, and licensee and ORO dose projections, I

as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA-REP-1, 1.10 and Supplement 3; Criterion 2.b.l) Pg. 184-185. I Performance Measures: ( 1) The ORO must demonstrate the capability to use the appropriate means described in the plans/procedures to develop P ARs for decision-makers based on available information and recommendations provided by the licensee, as well as field monitoring I

data if available. Workers must also consider any release and meteorological data provided by the licensee. (2) 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 I

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 PAG to which they will be compared. (3) PARs must be promptly I

transmitted to decision-makers in a prearranged format. (4) When the licensee and ORO projected doses differ by more than a factor of 10, the ORO and licensee must determine the source of the difference by discussing input data and assumptions, using different models, or I

exploring possible reasons. Resolution of these differences must be incorporated into the PARs if timely and appropriate. (5) The ORO must demonstrate the capability to use any additional data to refine projected doses and exposure rates and revise the associated PARs.

I MORGAN COUNTY: This will be discussed during the exercise, scenario dependent. I Critical Task: A decision-making process involving consideration of appropriate factors and necessary coordination is used to make P ADs 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; I

D.4; J.9; J.10.e.f, m; Criterion 2.b.2). Pg. 185.

I I

188 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measures: (1) OROs must have the capability to make both initial and I subsequent precautionary and/or protective action decisions in a timely manner appropriate to the incident, based on information from the licensee, assessment of plant status and potential or actual releases, other available information related to the incident, input from appropriate ORO I authorities (e.g., incident command), and PARs from the utility and ORO staff. (2) In addition, a subsequent or alternate precautionary and/or protective action decision may be appropriate if various conditions (e.g., an HAB incident, weather, release timing and magnitude) pose undue I risk to an evacuation or if evacuation may disrupt the efforts to respond to a hostile action. (3)

OROs must demonstrate the ability to obtain supplemental resources (e.g., mutual aid) necessary to implement a precautionary and/or protective action decision if local law enforcement, fire I service, HAZMAT, and emergency medical resources are used to augment response to the NPP .

site or other key infrastructure. (4) If the ORO has determined that KI will be used as a protective measure for the general public under offsite plans/procedures, then it must I demonstrate the capability to make decisions on the distribution and administration of KI to supplement sheltering and evacuation. This decision must be based on the ORO's plans/procedures or projected thyroid dose compared with the established P AG for KI I administration. The KI decision-making process must involve close coordination with appropriate assessment and decision-making staff. (5) If more than one ORO is involved in decision making, all appropriate OROs must communicate and coordinate precautionary and/or I protective action decisions with each other. (6) In addition, decisions must be coordinated/

communicated with incident command. OROs must demonstrate the capability to communicate the results of decisions to all the affected locations.

I MORGAN COUNTY: This will be discussed during the exercise, scenario dependent.

Critical Task: OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to EWs in accordance with the plans/procedures. EWs periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart. OROs maintain appropriate record-keeping of the administration of KI to EWs (NUREG-0654 K.3.a, b, K.4; Criterion 3al). Pg. 189.

Performance Measures: (1) OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent-i 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 I 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.

(2) Each emergency worker must have basic knowledge of radiation exposure limits as specified I in the ORO's plans/ procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage I radiological exposure control. (3) During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. (4) OROs must demonstrate the actions described in the plans/procedures by I

189 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

determining whether to replace the worker, authorize the worker to incur additional exposures, or take other actions. (5) If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to I determine their knowledge. (6) 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 and can share a direct read dosimeter. Each team member I must still have and maintain his or her own permanent-record dosimetry. (7) OROs must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property I

may require an urgent response. (8) OROs must demonstrate the capability to accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including I

documentation of the date(s) and time(s) they did so. (9) Emergency workers must demonstrate basic knowledge of procedures for using KL If exercise play does not require emergency workers to consume KI, evaluators must interview at least two workers to determine their I

knowledge.

PARTICIPANTS: EMA Staff; EMA Volunteer and Morgan County Department of I

Public Health MORGAN COUNTY: Emergency worker exposure control will be discussed, out of I

sequence on May 9th, 2019 at the Morgan County EMA and Morgan County Health Department. I Critical Task: KI and appropriate instructions are made available in case a decision to recommend use of KI is made. Appropriate record keeping of the administration of KI for institutionalized individuals and the general public is maintained (NUREG-0654 J.10.e, f; I

Criterion 3bl). Pg. 190.

Performance Measures: (1) OROs must demonstrate the capability to make KI available to I

institutionalized individuals and, where provided for in their plans/procedures, to members of the general public. (2) OROs must demonstrate the capability to accomplish distribution of KI consistent with decisions made. (3) OROs must have the capability to develop and maintain lists I

of institutionalized individuals who have ingested KI, including documentation of the date(s) and time(s) they were instructed to ingest Kl. OROs must demonstrate the capability to formulate and disseminate instructions on using KI for those advised to take it. (4) If a recommendation is I

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. I MORGAN COUNTY: This will be discussed briefly with a Morgan County Health Department Representative during the out of sequence on May 9th, 2019 visit at the I Morgan County Health Department and will be followed up at the out of sequence, at Priceville Junior High School on May 16t~. 2019 with the Morgan County Health Department Representative during the simulation of the KI issuance to the general public. I I

190 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I Critical Task: The reception center facility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration of evacuees (NUREG-0654 A.3; C.4; J.10.h; J.12; Criterion 6al). Pg. 202-203.

I Performance Measure: (1) Radiological monitoring, decontamination, and registration facilities for evacuees must be set up and demonstrated as they would be in an actual emergency.

I (2) OROs conducting this demonstration must have (a) one-third of the resources (e.g.,

monitoring teams/instrumentation/portal monitors) available at the facility (ies) as necessary to monitor (b) 20 percent of the population within a 12-hour period. (c) This would include I adequate space for evacuees' vehicles. (2) Availability ofresources can be demonstrated with valid documentation (e.g., MOU/LOA, etc.) reflecting how necessary equipment would be procured for the location. (3) Plans/procedures must indicate provisions for service animals. (4)

I Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. (5) 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 I monitoring productivity rate per hour needed to monitor the 20 percent EPZ population planning base. (6) 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. (7)

I 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. (8) The monitoring sequences for the first six simulated evacuees per I monitoring team will be timed by the evaluators to determine whether the 12-hour requirement can be met. (9) OROs must demonstrate the capability to register evacuees upon completion of the monitoring and decontamination activities. (10) The activities for recording radiological I monitoring and, if necessary, decontamination must include establishing a registration record consisting of the (a) evacuee's name, (b) address, (c) results of monitoring, and (d) time of decontamination (if any), or as otherwise designated in the plan and/or procedures. Audio I recorders, camcorders, or written records are all acceptable means for registration. (11)

Monitoring activities shall not be simulated. (12) Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. (13) They must also explain I the procedures for referring any evacuees who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures. All activities must be I based on the ORO's plans/procedures and completed as they would be in an actual emergency.

Decontamination of evacuees may be simulated and conducted by interview. (14) Provisions for separate showering and same-sex decontamination must be demonstrated or explained. (15) The I 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. (16) Provisions must also exist to I (a) separate contaminated and uncontaminated evacuees, (b) provide changes of clothing for those with contaminated clothing, and (c) store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities. (17) In addition, for any evacuee found I to be contaminated, procedures must be discussed concerning handling of potential contamination of vehicles and personal belongings. Waste water from decontamination operations does not need to be collected. (18) Individuals who have completed monitoring and I

191 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

decontamination if needed, must have the means (e.g., hand stamp, sticker, bracelet, form, etc.)

indicating that (a) they, and their service animals and vehicles, where applicable, have been monitored, cleared, and found to have no contamination or (b) contamination below the I trigger/action level or (c) have been placed in a secure area until they can be monitored and decontaminated, if necessary. 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 I confirmation that their vehicle is free from contamination prior to entering the congregate care areas. (19) However, those individuals who are found to be contaminated and are then decontaminated will have their vehicles (a) held in a secure area or (b) monitored and I

decontaminated (if applicable) and do require confirmation that their vehicle is being (c) held in a secure area or (d) free from contamination prior to entering the congregate care areas.

I MORGAN COUNTY EMA: The registration component of this criterion will be demonstrated by Alabama Department of Human Resources. The monitoring and decontamination of evacuees will be demonstrated by Brindlee Mountain Volunteer Fire I

Department, all out of sequence, at the Reception Center located at Priceville Junior High School at 317 Highway 67 South, Decatur, AL 35603 on May 16th, 2019. Vehicle monitoring and decontamination will be demonstrated by the Priceville Volunteer Fire I

Department. There will be simulation of deconning the inside of a dirty vehicle.

Protective Clothing for emergency workers/evacuees will not be issued and actual decon will be simulated; there will be demonstrated. The Male & Female decon shower walk I

through will be set-up for the simulation with no water used. Morgan County will not demonstrate monitoring, decon and registration during the drill on June 26, 2019. I Critical Task: The facility/ORO has adequate procedures and resources to accomplish monitoring and decontamination of emergency workers and their equipment and vehicles (NUREG-0654 K.5.a, b; Criterion 6bl). Pg. 203-204.

I Performance Measure: (1) The monitoring staff must demonstrate the capability to monitor emergency worker personnel and their equipment and vehicles for contamination in accordance I

with the ORO's plans/procedures. Specific attention must be given to equipment, including any vehicles that were in contact with contamination. (2) The monitoring staff must demonstrate the capability to make decisions on the need for decontamination of personnel, equipment, and I

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. (3) However, appropriate monitoring procedures must be demonstrated for a minimum of two emergency I

workers and their equipment and vehicles. (4) Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. (5)

The area to be used for monitoring and decontamination must be set up as it would be in an I

actual emergency, with all route markings, instrumentation, record keeping, and contamination control measures in place. (6) Monitoring procedures must be demonstrated for a minimum of one vehicle. It is generally not necessary to monitor the entire surface of vehicles. (7) However, I

the capability to monitor areas such as radiator grills, bumpers, wheel wells, tires, and door handles must be demonstrated. (8) Interior surfaces of vehicles that were in contact with I contaminated individuals must also be checked. Decontamination of emergency workers may be I

192 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant simulated and conducted via interview. (9) Provisions for separate showering and same-sex I decontamination must be demonstrated or explained. (10) 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 I contaminated areas. ( 11) 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 I further contamination of emergency workers or facilities. (12) OROs must demonstrate the capability to register emergency workers upon completion of the monitoring and decontamination activities. The activities for recording radiological monitoring and if necessary, I decontamination must include establishing a registration record consisting of the (a) emergency worker's name, (b) address, (c) results of monitoring, and (d) time of decontamination (if any),

or as otherwise designated in the plans/procedures. Audio recorders, camcorders, or written I records are all acceptable means for registration. Monitoring activities shall not be simulated.

(13) Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. (14) They must also explain the procedures for referring any emergency I workers who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures Decontamination capabilities and provisions for vehicles and equipment that cannot be successfully decontaminated may be simulated and conducted by I interview. Waste water from decontamination operations does not need to be collected.

MORGAN COUNTY: Monitoring, decontamination and registration of Emergency I Workers will be demonstrated, out of sequence, at the Reception Center located at Priceville Junior High School at 317 Highway 67 South, Decatur, AL 35603 on May 16th

, 2019. Emergency Workers vehicle monitoring and decontamination will be I demonstrated. There will be simulation of deconning the inside of a dirty vehicle.

Protective Clothing for emergency workers/evacuees will not be issued and actual decon will be simulated; there will be no water decon demonstrated. The Male & Female decon I shower walk through will be set-up for the simulation. Morgan County will not demonstrate monitoring, decon and registration during the drill on June 26, 2019.

I Core Capability: On-Scene Security, Protection, and Law Enforcement (TCP's/Waterway Warning)

I Definition: Ensure a safe and secure environment through law enforcement and related security and protection operations for people and communities located within affected areas and also for I response personnel engaged in lifesaving and life-sustaining operations.

Participants:

Decatur Police Dept, Morgan County Rescue Squad, Morgan County Sheriff's I Office Critical Task: At least 2 communications systems are available, at least 1 operates properly, and I communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 F.l, 2; Criterion ldl). Pg. 180.

I 193 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Performance Measure: OROs must demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, FMTs, and incident command must have I

the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without I

delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

I MORGAN COUNTY: A representative from Decatur Police Department will discuss ,

communications, out of sequence, on May 9th, 2091 at the Morgan County EOC. I Critical Task: Equipment (to include communications), maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182 I

Performance Measure: (1) 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. (2)

I For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3)At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be I

available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g,, civil news media) (b) institutionalized individuals and (c)

I members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage I

locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient I

quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained I

in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. (10) A label indicating such calibration must be on each I

instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings I documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to I the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations. I I

194 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant

• I MORGAN COUNTY: Thermo-luminescent dosimeters (TLDs) and dosimetry will be distributed to available emergency workers at the Morgan County EOC with the Emergency Workers (this equipment is prepositioned), out of sequence, on May 9th, I 2019. .

Critical Task: OROs issue appropriate dosimetry, KI, and procedures, and manage radiological I exposure to EWs in accordance with the plans/procedures. EWs periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or chart.. OROs maintain appropriate record-keeping of the administration of KI to EWs (NUREG-I 0654 K.3.a, b, K.4;*Criterion 3al). Pg. 189 Performance Measures: (1) OROs must demonstrate the capability to provide emergency I 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 I 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.

I (2) Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/ procedures. If supplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge of radiation exposure control. Emergency I workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control. (3) During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back I values are reached .. (4) 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. (5) If exercise play does not require emergency workers to seek I authorizations for additional exposure, evaluators must interview at least two workers.to determine their knowledge. (6) 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 I to each other during the entire mission and can share a direct-read dosimeter. Each team member must still have and maintain his or her own permanent-record dosimetry. (7) OROs I must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property may require an urgent response. ,(8) OROs must demonstrate the capability to I accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. (9) Emergency workers must I demonstrate basic knowledge of procedures for using KI. If exercise play does not require emergency workers to consume KI, evaluators must interview at least two workers to determine their knowledge.

I I

195 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

MORGAN COUNTY: Emergency Workers will discuss exposure control, out of sequence, on May 9th, 2019 at the BOC.

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

3dl). Pg. 191-192 Performance Measures: (1) OROs must demonstrate the capability to select, establish, and I

staff appropriate traffic and access control points consistent with current conditions and P ADs (e.g., evacuating, sheltering, and relocation) in a timely manner. (2) OROs must demonstrate the capability to provide instructions to traffic and access control staff on actions to take when I

modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled. (2) Traffic and access control staff must demonstrate accurate knowledge of their roles and responsibilities, including verifying emergency worker I

identification and access authorization to the affected areas. (3) In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic),

they must demonstrate the capability to contact the State or Federal agencies that have the I

needed authority MORGAN COUNTY: A representative from the Decatur Police Department will I

discuss traffic and access control, out of sequence, on May 9th, 2019 at the Morgan County BOC. Actual demonstration .will not be performed on May 9th or June 26th, 2019, both will be discussed. (Scenario dependent)

I Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; .I Criterion 3d2). Pg. 192 Performance Measures: (1) OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. (2) The impediment must remain in I

place during the evacuation long enough that re-routing of traffic is required and (3) must also result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

I MORGAN COUNTY: A representative from the Decatur Police Department will I discuss impediments to evacuation, out of sequence, on May 9th, 2019 at the Morgan County BOC. Actual demonstration will not be performed. (Scenario dependent)

I Core Capability: Public Health, Healthcare, and Emergency Medical Services Definition: Provide lifesaving medical treatment via Emergency Medical Services and related I operations and avoid additional disease and injury by providing targeted public health, medical and behavioral health support, and products to all affected populations.

I I

196 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant

Participants:

First Response Ambulance Service; Decatur Morgan Hospital-Main I Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, I b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182 Performance Measure: (1) A particular facility's equipment and supplies must be sufficient I and consistent with that facility's assigned role in the ORO's emergency operations plans. (2)

For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3)At locations where traffic and access control personnel are I deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or I specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) members of the general public. (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of Kl. (6) ORO physical inspection at the storage I location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability I to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an I individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the I manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings I documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source. (12) In areas where portal monitors are used, I the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I MORGAN COUNTY: Thermos Luminescent dosimeters (TLDS) and dosimetry is I prepositioned with the Emergency Workers, out of sequence on July 18, 2019, Decatur Morgan Hospital Main, 1215-71h Street SE in Decatur, Alabama.

I Critical Task: OROs issue appropriate dosimetry, KI, and procedures, and manage radiological exposure to EWs in accordance with the plans/procedures. EWs periodically and at the end of each mission read their dosimeters and record the readings on the appropriate exposure record or I chart. OROs maintain appropriate record-keeping of the administration of KI to EWs (NUREG-0654 K.3.a, b, K.4; Criterion 3al). Pg. 189 I

197 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Performance Measures: (1) 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 I 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 I emergency workers involved in lifesaving activities, contained in the ORO' s plans/procedures.

(2) Each emergency worker must have basic knowledge of radiation exposure limits as specified in the ORO's plans/ procedures. If supplemental resources are used, they must be provided with I

just-in-time training to ensure basic knowledge of radiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control. (3) During a plume phase exercise, emergency workers must I

demonstrate the procedures to be followed when administrative exposure limits and tum-back values are reached. (4) 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 I

take other actions. (5) If exercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two workers to determine their knowledge. (6) Although it is desirable for all emergency workers to each have a I

direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission and can share a direct-read dosimeter. Each team member must still have and maintain his or her own permanent-record dosimetry. (7) OROs I

must ensure that the process used to seek authorization for exceeding dose limits does not negatively impact the capability to respond to an incident where lifesaving and/or protection of valuable property may require an urgent response. (8) OROs must demonstrate the capability to I

accomplish distribution of KI to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists of emergency workers who have ingested KI, including documentation of the date(s) and time(s) they did so. (9) Emergency workers must I

demonstrate basic knowledge of procedures for using KI. If exercise play does not require emergency workers to consume KI, evaluators must interview at least two workers to determine their knowledge.

I MORGAN COUNTY: Emergency Workers will discuss exposure control, out of sequence, on July 18th, 2019 at Decatur Morgan Hospital - Main.

I Critical Task: The facility/ORO has the appropriate space, adequate resources, and trained personnel to provide transport, monitoring, decontamination, and medical services to I

contaminated injured individuals (NUREG-0654 F.2; H.10; K.5.a, b; L.1, 4; Criterion 6dl). Pg.

204-205 I Performance Measure: (1) All hospitals listed in the plan as medical services hospitals must be evaluated, with a transportation provider, every 2 years. (2) Additional transportation providers will be rotated through the drills in the 8-year exercise cycle. For I

ambulance providers who do not participate in an evaluated drill during the two-year cycle, training will be provided. This training will be documented in the ALC. (3)Monitoring, I decontamination, and contamination control efforts must not delay urgent medical care for the I

198 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant victim. (4) OROs must demonstrate the capability to monitor/ decontaminate and transport I contaminated, injured individuals to medical facilities. (5) An ambulance must be used for response to the victim. However, to avoid taking an ambulance out of service for an extended time, OROs may use any vehicle (e.g., car, truck, or van) to transport the victim to the medical I facility. It is allowable for an ambulance to demonstrate up to the point of departure for the medical facility and then have a non-specialized vehicle transport the "victim(s)" to the medical facility. This option is used in areas where removing an ambulance from service to drive a great I distance (over an hour) for a drill would not be in the best interests of the community. (6)

Normal communications between the ambulance/dispatcher and the receiving medical facility must be demonstrated. If a substitute vehicle is used for transport to the medical facility, this I communication must occur before releasing the ambulance from the drill. This communication would include reporting radiation monitoring results, if available. (7) In addition, the ambulance crew must demonstrate, by interview, knowledge of where the ambulance and crew would be I monitored and decontaminated, if required, or whom to contact for such information. (8)

Monitoring of the victim may be performed before transport or en route or may be deferred to the medical facility. (9) Contaminated injured individuals transported to medical facilities are I monitored as soon as possible to assure that everyone (ambulance and medical facility) is aware of the medical and radiological status of the individual(s). (10) However, if an ambulance defers monitoring to the medical facility, then the ambulance crew presumes that the patient(s) is I contaminated and demonstrate appropriate contamination controls until the patient(s) is monitored. (11) Before using monitoring instruments, the monitor(s) must demonstrate the process of checking the instrument(s) for proper operation. (12) All monitoring activities must I be completed as they would be in an actual emergency. (13) Appropriate contamination control measures must be demonstrated before and during transport and at the receiving medical facility.

(14) The medical facility must demonstrate the capability to activate and set up a radiological I emergency area for treatment. ( 15) Medical facilities are expected to have at least one trained physician and one trained nurse to perform and supervise treatment of contaminated injured individuals. (16) Equipment and supplies must be available for treatment of contaminated injured I individuals. (17) The medical facility must demonstrate the capability to (a) make decisions on the need for decontamination of the individual, (b) follow appropriate decontamination procedures, and (d) maintain records of all survey measurements and samples taken. ( 18) All I procedures for collection and analysis of samples and decontamination of the individual must be demonstrated or described to the evaluator. Waste water from decontamination operations must I be handled according to facility plans/procedures.

MORGAN COUNTY: Emergency workers will discuss, demonstrate the monitoring, I decontamination, transporting and supporting a patient with first aid during a contamination situation. Simulating and discussing many steps in the decontamination process but demonstrating some of the steps. During the out of sequence, on July 18th, I 2019 at the Decatur Morgan Hospital Main on 1215-7th Street SE in Decatur, Alabama.

I I

199 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

I I

I I

I I

I This page is intentionally blank I

I I

I I

I I

I I

200 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant BASE I EXTENT OF PLAY AGREEMENT 2019 Browns Ferry Nuclear Plant I Madison County FULL PARTICIPATION RADIOLOGICAL EMERGENCY PREPAREDNESS EXERCISE I All activities will be demonstrated fully in accordance with respective plans and procedures as they would be in an actual emergency (FEMA must receive these plans, guides and procedures I NLT 60 days before the exercise). This Extent of Play agreement is written by exception. If it is not listed as an exception it will be demonstrated as described in the plans, standard operating guides (SOGs) and/or procedures (SOPs). Any issue or discrepancy arising during exercise play I may be redemonstrated if allowed by the RAC Chair or as listed herein. This allowance may be granted if it is not disruptive to exercise play and is mutually agreed to by the ORO controller and FEMA evaluator.

I Core Capability: Operational Coordination I Definition: Establish and maintain a unified and coordinated operational structure and process that appropriately integrates all critical stakeholders and supports the execution of core capabilities.

I Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 A.La, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; I G.3.a-i H.3, 4; Criterion lal). Pg. 180 Performance Measure: (1) OROs must demonstrate the capability to receive notification of an I incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key emergency personnel in a timely manner, (4) Responders must demonstrate the ability to receive I and/or initiate notification to the licensees or other respective emergency management organizations of an incident in a timely manner when they receive information. (5) Demonstrate the ability to maintain and staff 24-hour operations. (6) OR Os must demonstrate the activation I of facilities for immediate use by mobilized personnel upon their arrival. (7) The iocation and contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP. (8) The ability to identify and request additional I resources or identify compensatory measures must be demonstrated.

MADISON COUNTY: Madison County EMA: On June 26, 2019, EMA Staff will be I pre-positioned at the EOC at 8:30 AM, located 320 Fountain Circle, Huntsville, AL. A call-down list will be utilized.

I Critical Task: Key personnel with leadership roles for the ORO provide direction and control to that part of the overall response effort for which they are responsible (NUREG-0654 A. l .d; A.2.a, b; A.3; C.4, 6; Criterion lcl). Pg. 181.

II 201 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Performance Measure: (1) Leadership personnel must demonstrate the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed through I periodic briefings and/or other means, coordinating with other OROs, and ensuring completion of requirements and requests.) (2) Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement resources (e.g., through MOUs or other agreements) when faced I

with competing demands for finite resources. Any resources identified through LOA/MOUs must be on the ORO's mobilization list so they may be contacted during an incident if needed.

I MADISON COUNTY: Madison County EMA will demonstrate direction and control in the EOC, scenario dependent on June 26, 2019.

I Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182 I

Performance Measure: (1) 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. (2)

I For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3)At locations where traffic and access control personnel are deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be I

available. (4) Responsible OR Os must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c)

I members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage location(s) or through documentation of quantities of dosimetry and KI available and storage I

locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient I

quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits contained I

in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. ( 10) A label indicating such calibration must be on each I

instrument. (11) In addition, instruments being used to measure activity must have a sticker-

- affixed to their sides indicating the effective range of the readings. The range of readings I documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to I the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I 202 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant MADISON COUNTY: The Madison County EMA will have available equipment, I maps and displays that would be necessary to support emergency operations. These will be viewed at the Madison County EOC out of sequence on May 13, 2019. Dosimetry will be viewed out of sequence on May 13, 2019 at the EOC.

I Critical Task: Appropriate traffic and access control is established. Accurate instructions are provided to traffic and access control personnel (NUREG-0654 A.3; C.1, 4; J .10.g, j; Criterion I 3dl) Pg. 191-192 Performance Measures: (1) OROs must demonstrate the capability to select, establish, and I staff appropriate traffic and access control points consistent with current conditions and PADs (e.g., evacuating, sheltering, and relocation) in a timely manner. (2) OROs must demonstrate the capability to provide instructions to traffic and access control staff on actions to take when I modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled. (2) Traffic and access control staff must demonstrate accurate knowledge of their roles and responsibilities, including verifying emergency worker I identification and access authorization to the affected areas. (3) In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic),

they must demonstrate the capability to contact the State or Federal agencies that have the I needed authority.

MADISON COUNTY: Madison County EMA will discuss this criterion out of I sequence on May 13, 2019 with law enforcement personnel in the EOC. Actual demonstrations will not be performed.

I Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; Criterion 3d2). Pg. 192 I Performance Measures: (1) OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. (2) The impediment must remain in place during the evacuation long enough that re-routing of traffic is required and (3) must also I result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees.

I MADISON COUNTY: Madison County EMA will discuss this criterion out of sequence on May 13, 2019 with law enforcement personnel in the EOC. Actual I demonstrations will not be performed.

I I

I 203 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Core Capability: Operational Communications Definition: Establish and maintain a unified and coordinated operational structure and process I that appropriately integrates all critical stakeholders and supports the execution of core capabilities.

I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 I

F.1, 2; Criterion ldl). Pg. 180.

Performance Measure: OROs must demonstrate that a primary system and at least one backup I

system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to manage the I

communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

I MADISON COUNTY: Communications systems will be demonstrated, scenario.

dependent on June 26, 2019. The TVA ECNS phone is the primary means of I

communications. Southern Linc, telephones and fax machines will serve as secondary communications. I Core Capability: Public Information and Warning Definition: Deliver coordinated, prompt, reliable, and actionable information to the whole I

community through the use of clear, consistent, accessible, and culturally and linguistically appropriate methods to effectively relay information regarding any threat or hazard and, as appropriate, the actions being taken and the assistance being made available.

I Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 A.I.a, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; I

G.3.a; H.3, 4; Criterion lal). Pg. 180 Performance Measure: (1) OROs must demonstrate the capability to receive notification of an I

incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key emergency personnel in a timely manner, (4) Responders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management I

organizations of an incident in a timely manner when they receive information. (5) Demonstrate the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and I

contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP. (8) The ability to identify and request additional I resources or identify compensatory measures must be demonstrated.

I 204 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I MADISON COUNTY: EMA Staff and some BOC Support Staff will be pre-positioned at 8:30 a.m. at the Madison County BOC on June 26, 2019. Public Information Support Staff and JIC personnel will be pre-positioned at the JIC facility at 8:30 AM, alerting and I mobilization will be simulated according to the Browns Ferry Nuclear Plant Notification List.

I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations.

Communications capabilities are managed in support of emergency operations (NUREG-0654 I F.1, 2; Criterion ldl). Pg. 180.

Performance Measure: OROs must demonstrate that a primary system and at least one I backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial telephone system. (3) Responsible OROs must demonstrate the capability to I manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

I MADISON COUNTY: Communications systems will be demonstrated, scenario dependent. The PIO phone at the JIC will be the primary means of communications with I the JIC. Southern Linc, mobile phone, email, and fax machine will serve as secondary communications.

I Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; 1.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182.

I Performance Measure: (1) 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. (2)

I For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3)At locations where traffic and access control personnel are I deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or I specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) members of the general public, (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage I location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability I to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an I

205 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

individual(s) to read the administrative reporting limits and maximum exposure limits contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the I manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings I documentation specifies the acceptable range of readings that the meter should indicate when it is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to I

the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I MADISON COUNTY: The Madison County EMA will have available equipment, maps, and displays that would be necessary to support emergency operations. These will I

be viewed at the Madison County EOC out of sequence on May 13, 2019. Dosimetry will be viewed out of sequence on May 13, 2019 at the EOC. Appropriate information and supplies for public information, including a Smart Book, for use by the PIO at the I

JIC, will be available. This will be accomplished during the exercise, scenario dependent. I Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; Criterion 3d2). Pg. 192 I Performance Measures: (1) OROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. (2), The impediment must remain in place during the evacuation long enough that re-routing of traffic is required and (3) must also I

result in demonstration of decision-making and coordination with the JIC to communicate the alternate route to evacuees. I MADISON COUNTY: The Madison County EOC will communicate to the JIC any impediments to evacuation. Should impediments to evacuation be identified this information will be disseminated to the public. This will be accomplished during the I

exercise scenario dependent.

Critical Task: Activities associated with primary alerting and notification of the public are I

completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current FEMA REP Guidance I

(Timely: The responsible ORO personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of urgency and without undue delay) (NUREG-0654 E.5, 6, 7; Criterion 5al). Pg. 198-199.

I I

I 206 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measure: (1) Responsible OROs must demonstrate the capability to sequentially I provide an alert signal followed by an initial instructional message to populated areas throughout the 10-mile plume exposure pathway EPZ. Following the decision to activate the alert and notification system, (2) OROs must complete system activation for primary alert/notification and I disseminate the information/instructions in a timely manner. For exercise purposes, timely is defined as "with a sense of urgency and without undue delay." (3) Procedures to broadcast the message must be fully demonstrated as they would in an actual emergency up to the point of I transmission. Broadcast of the message(s) or test message(s) is not required. The procedures must be demonstrated up to the point of actual activation. The alert signal activation should be simulated, not performed. Evaluations of EAS broadcast stations may also be accomplished I through SAVs. (4) 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 I power or an alternate station. (5) The initial message must include at a minimum the following elements:

• (a) Identification of the ORO responsible and the official with authority for providing the alert I

• signal and instructional message; (b) Identification of the commercial NPP and a statement that an emergency exists there;

• (c) Reference to REP-specific emergency information (e.g., brochures, calendars, and/or I

• information in telephone books) for use by the general public during an emergency; and (d) A closing statement asking that the affected and potentially affected population stay tuned for additional information, or that the population tune to another station for additional information.

I (6) If route alerting is demonstrated as a primary method of alert and notification, it must be done in accordance with the ORO's plans/procedures. OROs must demonstrate the capability to accomplish the primary route alerting in a timely manner (not subject to specific time I requirements). At least one route needs to be demonstrated and evaluated. The selected route(s) must vary from exercise to exercise. However, the most difficult route(s) must be demonstrated no less than once every eight years. (7) All alert and notification activities along the route(s) must I be simulated (i.e., the message that would actually be used is read for the evaluator, but not actually broadcast. (8) Actual testing of the mobile public address system will be conducted at an I agreed-upon location.

MADISON COUNTY: PNS coordination will be done via the ECNS and led by I Madison County. Siren activation will be simulated for PNS activation by each risk-county (scenario dependent). The BFNPP counties have developed unified EAS and Special News Broadcast messages and distributed to the National Weather Service Office I in Huntsville (NWS). Madison County will coordinate the EAS/SNB messages with the BFNPP counties via the ECNS and designated to the NWS via Southern Linc radio or landline phone which message to distribute. EAS message distribution will be the I responsibility of the NWS, and simulated for this exercise.

I I

207 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant I

Critical Task: Ensure OROs provide accurate emergency information and instructions to the public and the news media in a timely manner (The responsible ORO personnel/representatives demonstrate actions to disseminate the appropriate information/instructions with a sense of I urgency and without undue delay) (NUREG-0654 E.5, 7; G.3.a; G.4.a, c; Criterion 5bl). Pg.

200-201.

I Performance Measure: (1) 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).

I For exercise purposes, timely is defined as "with a sense of urgency and without undue delay."

Messageelements: (2)TheOROmustensurethatemergency information and instructions are consistent with PADs made by appropriate officials. (3) The emergency information must contain I

all necessary and applicable instructions (e.g., evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, shelter-in-place instructions, information concerning protective actions for schools and persons with disabilities and access/functional needs, I

and public inquiry hotline telephone number) to assist the public in carrying out the PADs provided. (4) 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. (5)

I 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. (6) This includes demonstration of the capability to use familiar landmarks and boundaries to describe protective I

action areas. (7) 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. (8) Information about any rerouting of evacuation I

routes due to impediments should also be included. (9) The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. (10) OROs must demonstrate the capability to ensure that current I

emergency information is repeated at pre-established intervals in accordance with the plans/procedures. (11) OR Os must demonstrate the capability to develop emergency information in a non-English language when required by the plans/procedures. (12) If ingestion exposure I

pathway measures are required, OROs must demonstrate that a system exists for rapid dissemination of ingestion exposure pathway information to predetermined individuals and businesses. Media information: (13) OROs must demonstrate the capability to provide timely, I

accurate, concise, and coordinated information to the news media for subsequent dissemination to the public. ( 14) This would include demonstration of the capability to conduct timely and pertinent media briefings and distribute media releases as the incident warrants. (15) The OROs I

must demonstrate the capability to respond appropriately to inquiries from the news media. (16)

All information presented in media briefings and releases must be consistent with P ADs and other emergency information provided to the public. ( 17) Copies of pertinent emergency I

information (e.g.,EAS messages and media releases) and media information kits must be available for dissemination to the media. Public Inquiry ( 18) OROs must demonstrate that an effective system is in place for dealing with calls received via the public inquiry hotline. (19) Hotline staff I

must demonstrate the capability to provide or obtain accurate information for callers or refer them to an appropriate information source. (20) Information from the hotline staff, including I information that corrects false or inaccurate information when trends are noted, must be I

208 I

I Radiological Emergency Preparedness Program After Action Report 2019 Browns Ferry Nuclear Power Plant I included, as appropriate, in emergency information provided to the public, media briefings, and/or I media releases. RAB considerations: (21) The dissemination of information dealing with specific aspects of NPP security capabilities, actual or perceived adversarial (terrorist) force or threat, and tactical law enforcement response must be coordinated/ communicated with I appropriate security authorities (e.g., law enforcement and NPP security agencies) in accordance with ORO Pans/procedures.

I MADISON COUNTY: The BFNPP counties have developed unified EAS and Special News Broadcast messages and distributed to the National Weather Service Office in Huntsville (NWS). Madison County will coordinate the EAS/SNB messages with the I BFNPP counties via the ECNS and designate to the NWS via Southern Linc radio or landline phone which message to distribute. EAS message distribution will be the responsibility of the NWS and simulated for this exercise. (scenario dependent)

I Core Capability: Environmental Response/Health and Safety I Definition: Conduct appropriate measures to ensure the protection of the health and safety of the public and workers, as well as the environment, from all-hazards in support of responder operations and the affected communities I Critical Task: OROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner (NUREG-0654 A.l.a, e; A.3, 4; C.1, 4, 6; D.4; E.1, 2; I G.a.3; H.3, 4; Criterion lal). Pg. 180 Performance Measure: (1) OROs must demonstrate the capability to receive notification of an I incident from the licensee; (2) verify the notification, (3) contact, alert, and mobilize key emergency personnel in a timely manner, (4) Resporiders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management I organizations of an incident in a timely manner when they receive information. (5) Demonstrate the ability to maintain and staff 24-hour operations. (6) OROs must demonstrate the activation of facilities for immediate use by mobilized personnel upon their arrival. (7) The location and I contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NPP. (8) The ability to identify and request additional resources or identify compensatory measures must be demonstrated.

I MADISON COUNTY: EMA Staff will be pre-positioned at 8:30 a.m. at the Madison County EOC on June 26, 2019. Additional support personnel will be alerted and I mobilized according to established plans and procedures.

Critical Task: Key personnel with leadership roles for the ORO provide direction and control to I that part of the overall response effort for which they are responsible (NUREG-0654 A. l .d; A.2.a, b; A.3; C.4, 6; Criterion lcl). Pg. 181 I Performance Measure: (1) Leadership personnel must demonstrate the ability to carry out the essential management functions of the response effort (e.g., keeping staff informed I 209 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant through periodic briefings and/or other means, coordinating with other OROs, and ensuring I

completion of requirements and requests.) (2) Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement resources (e.g., through MOUs or other agreements) when faced with competing demands for finite resources. Any resources I

identified through LOA/MOUs must be on the ORO's mobilization list so they may be contacted during an incident if needed. I MADISON COUNTY: Demonstration of direction and control will be performed according to plans and procedures, scenario dependent. I Critical Task: At least 2 communications systems are available, at least 1 operates properly, and communication links are established and maintained with appropriate locations. I Communications capabilities are managed in support of emergency operations (NUREG-0654 F.1, 2; Criterion ldl). Pg. 181 I

Performance Measure: OROs must demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial I telephone system. (3) Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for I fixed and mobile medical support facilities exists.

MADISON COUNTY: Communications systems will be demonstrated, scenario I

dependent on June 26, 2019. The TVA ECNS phone is the primary means of communications. Southern Linc, telephones, amateuuadio, and fax machines will serve as secondary communications.

I Critical Task: Equipment, maps, displays, monitoring instruments, dosimetry, KI, and other supplies are sufficient to support emergency operations (NUREG-0654 H.7, 10; I.7, 8, 9; J.10.a, I

b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182 Performance Measure: (1) A particular facility's equipment and supplies must be sufficient and I

consistent with that facility's assigned role in the ORO's emergency operations plans. (2) For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3)At locations where traffic and access control personnel are I

deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) Responsible OROs must demonstrate the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or I

specialized response teams (e.g., civil news media) (b) institutionalized individuals and (c) members of the general public. (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage I

location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability I

I 210 I

I Radiological Emergency Preparedness Program After Action Report 2019 Browns Ferry Nuclear Power Plant I to maintain inventories of appropriate direct-read and permanent-record dosimeters in I sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans or specialized response teams. (8) Appropriate direct-reading dosimetry must allow an individual(s) to read the administrative reporting limits and maximum exposure limits I contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the manufacturer's recommendations. (10) A label indicating such calibration must be on each I instrument. (11) In addition, instruments being used to measure activity must have a sticker-affixed to their sides indicating the effective range of the readings. The range of readings documentation specifies the acceptable range of readings that the meter should indicate when it I is response-checked using a standard test source. (12) In areas where portal monitors are used, the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for I Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's recommendations.

I MADISON COUNTY: The Madison County EMA will have available equipment, maps and displays that would be necessary to support emergency operations. These will be viewed at the Madison County BOC out of sequence on May 13, 2019. Dosimetry I will be viewed out of sequ_ence on May 13, 2019 at the BOC.

Critical Task: The reception center facility has appropriate space, adequate resources, and I trained personnel to provide monitoring, decontamination, and registration of evacuees (NUREG-0654 A.3; C.4; J.10.h; J.12; Criterion 6al). Pg. 202-203.

I Performance Measure: (1) Radiological monitoring, decontamination, and registration facilities for evacuees must be set up and demonstrated as they would be in an actual emergency. (2)

OROs conducting this demonstration must have (a) one-third of the resources (e.g., monitoring I teams/instrumentation/portal monitors) available at the facility(ies) as necessary to monitor (b) 20 percent of the population within a 12-hour period. (c) This would include adequate space for evacuees' vehicles. (2) Availability ofresources can be demonstrated with valid documentation I (e.g., MOU/LOA, etc.) reflecting how necessary equipment would be procured for the location. (3)

Plans/procedures must indicate provisions for service animals. (4) Before using monitoring instrument(s), the monitor(s) must demonstrate the process of checking the instrument(s) for I proper operation. (5) 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. (6) The monitoring I 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. (7) For demonstration of monitoring, decontamination, and registration capabilities, a minimum of six evacuees must be monitored per I station using equipment and procedures specified in the plans/ procedures. (8) The monitoring sequences for the first six simulated evacuees per monitoring team will be timed by the I evaluators to determine whether the 12-hour requirement can be met. (9) OROs must demonstrate the capability to register evacuees upon completion of the monitoring and decontamination activities. (10) The activities for recording radiological monitoring and, if I 211 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant necessary, decontamination must include establishing a registration record consisting of the (a)

I evacuee's name, (b) address, (c) results of monitoring, and (d) time of decontamination (if any),

or as otherwise designated in the plan and/or procedures. Audio recorders, camcorders, or written records are all acceptable means for registration. (11) Monitoring activities shall not be I

simulated. (12) Monitoring personnel must explain use of trigger/action levels for determining the need for decontamination. (13) They must also explain the procedures for referring any I evacuees who cannot be adequately decontaminated for assessment and follow-up in accordance with the ORO's plans/procedures. All activities must be based on the ORO's plans/procedures and completed as they would be in an actual emergency. Decontamination of evacuees may be simulated and conducted by interview. ( 14) Provisions for separate showering and same-sex I

decontamination must be demonstrated or explained. (15) The staff must demonstrate provisions for limiting the spread of contamination. Provisions could include floor coverings, signs, and I appropriate means (e.g., partitions, roped-off areas) to separate uncontaminated from potentially contaminated areas. (16) Provisions must also exist to (a) separate contaminated and uncontaminated evacuees, (b) provide changes of clothing for those with contaminated clothing, I and (c) store contaminated clothing and personal belongings to prevent further contamination of evacuees or facilities. (17) In addition, for any evacuee found to be contaminated, procedures must be discussed concerning handling of potential contamination of vehicles and personal I belongings. Waste water from decontamination operations does not need to be collected. (18)

Individuals who have completed monitoring and decontamination if needed, must have the means (e.g., hand stamp, sticker, bracelet, form, etc.) indicating that (a) they, and their service I

animals and vehicles, where applicable, have been monitored, cleared, and found to have no contamination or (b) contamination below the trigger/action level or (c) have been placed in a secure area until they can be monitored and decontaminated, if necessary. In accordance with I

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. (19) However, those individuals who I

are found to be contaminated and are then decontaminated will have their vehicles (a) held in a secure area or (b) monitored and decontaminated (if applicable) and do require confirmation that their vehicle is being (c) held in a secure area or (d) free from contamination prior to entering the I

congregate care areas.

MADISON COUNTY: The registration component of this criterion will be I

demonstrated by AL DHR and American Red Cross, out of sequence on May 13, 2019 at the Dr. Richard Showers Recreation Center, 4600 Blue Spring Road in Huntsville. The use of Reception Centers will be simulated, scenario dependent, during the June 26, 2019 I

exercise. Monitoring and Decontamination for Evacuees and Emergency Workers is not applicable. Actual demonstration of decontamination will not be performed or discussed. I I

I I

212 I

I Radiological Emergency Preparedness Program After Action Report 2019 Browns Ferry Nuclear Power Plant I

I Core Capability: On-Scene Security, Protection, and Law Enforcement (TCP's/Waterway Warning)

I Definition: Ensure a safe and secure environment through law enforcement and related security and protection operations for people and communities located within affected areas and also for response personnel engaged in lifesaving and life-sustaining operations.

I Critical Task: At least 2 communications systems are available, atleast 1 operates properly, and communication links are established and maintained with appropriate locations.

I Communications capabilities are managed in support of emergency operations (NUREG-0654 F.1, 2; Criterion ldl). Pg. 180.

I Performance Measure: OROs must demonstrate that a primary system and at least one backup system are fully functional. (2) All facilities, FMTs, and incident command must have the capability to access at least one communication system that is independent of the commercial I telephone system. (3) Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. (4) OROs must ensure that a coordinated communication link for I fixed and mobile medical support facilities exists.

MADISON COUNTY: Communications systems will be demonstrated, scenario I dependent on June 26, 2019. The. TVA ECNS phone is the primary means of communications. Southern Linc, telephones, and fax machines will serve as secondary communications.

I Critical Task: Equipment (to include communications), maps, displays, monitoring instruments, dosimetry, Ki, and other supplies are sufficient to support emergency operations (NUREG-0654 I H.7, 10; I.7, 8, 9; J.10.a, b, e; J.11, 12; K.3.a; K.5.b; Criterion lel). Pg. 182 Performance Measure: (1) A particular facility's equipment and supplies.must be sufficient I and consistent with that facility's assigned role in the ORO's emergency operations plans. (2)

For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. (3)At locations where traffic and access control personnel are I deployed, appropriate equipment (e.g., vehicles, barriers, traffic cones, and signs) must be available. (4) Responsible OROs must demonstrate. the capability to maintain inventories of KI sufficient for use by: (a) emergency workers, ancillary groups as identified in plans or I specialized response teams (e.g.,civil news media) (b) institutionalized individuals and (c) members of the general public. (5) The plans/procedures must include the forms to be used for documenting emergency worker ingestion of KI. (6) ORO physical inspection at the storage I location(s) or through documentation of quantities of dosimetry and KI available and storage locations(s) will be confirmed by current inventory submitted during the exercise, provided in the ALC submission, and/or verified during an SAV. (7) OROs must demonstrate the capability I to maintain inventories of appropriate direct-read and permanent-record dosimeters in sufficient quantities for use by: (a) emergency workers, ancillary groups as identified in plans or I

213 I

Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant specialized response teams. (8) Appropriate direct-reading dosimetry must allow an I

individual(s) to read the administrative,reporting limits and maximum exposure limits contained in the ORO's plans/procedures. (9) All monitoring instruments must be inspected, and operationally checked before each use. Instruments must be calibrated in accordance with the I

manufacturer's recommendations. (10) A label indicating such calibration must be on each instrument. (11) In addition, instruments being used to measure activity must have a sticker-* I 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. (12) In areas where portal monitors are used, I the OROs must set up and operationally check the monitor(s). The monitor(s) must conform to the standards set forth in the Contamination Monitoring Standard for a Portal Monitor Used for Emergency Response, FEMA-REP-21 (March 1995) or in accordance with the manufacturer's I recommendations.

MADISON COUNTY: The Madison County EMA will have available equipment, I

. maps and displays that would be necessary to support emergency operations. These will be viewed at the Madison County EOC out of sequence on May 13, 2019. Dosimetry will be viewed out of sequence on May 13, 2019 at the BOC.

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

3dl). Pg. 191-192.

Performance Measures: (1) OROs must demonstrate the capability to select, establish, and I

staff appropriate traffic and access control points .consistent with current conditions and P ADs (e.g., evacuating, sheltering, and relocation) in a timely manner. (2) OROs must demonstrate the

. capability to provide instructions to traffic and access control staff on actions to take when I

modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled. (2) Traffic and access control staff must demonstrate accurate knowledge of their roles and responsibilities, including verifying emergency worker I

identification ahd access authorization to the affected areas. (3) In instances where OROs lack authority necessary to control access by certain types of traffic (e.g., rail, water, and air traffic),

they must demonstrate the capability to contact the State or Federal agencies that have the I

needed authority .

MADISON COUNTY: A representative from the Huntsville Police Department, will I

discuss traffic and access control, out of sequence, on May 13, 2019 at the Madison County BOC. Actual demonstration will not be performed. I Critical Task: Impediments to evacuation are identified and resolved (NUREG-0654 J.10.k; Criterion 3d2). Pg. 192 I I

I 214 I

I Radiological Emergency Preparedness Program I After Action Report 2019 Browns Ferry Nuclear Power Plant Performance Measures: (1) OROs must demonstrate the capability to identify and take I appropriate actions concerning impediments to evacuations. (2) The impediment must remain in place during the evacuation long enough that re-routing of traffic is required and (3) must also result in demonstration of decision-making and coordination with the JIC to communicate the I alternate route to evacuees.

MADISON COUNTY: A representative from the Huntsville Police Department, will I discuss impediments to evacuation, out of sequence, on May 13, 2019 at the Madison CountyEOC.

I I

I I

I I

I I

I I

I I

I 215 I